ML110900537

Kewaunee Audit Report Tables 2 and 3

ML110900537
Person / Time
Site:	Kewaunee
Issue date:	04/11/2011
From:	Feintuch K D Plant Licensing Branch III
To:	Heacock D A Dominion Energy Kewaunee
Feintuch K D, 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 11 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 1 10/29/2007 07-0436B ML073100354NoneNone 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

Quality Assurance Program

Description, will be

incorporated into the KPS

Updated Safety Analysis

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)

.complete 4/18/2008;

NC LC000111 ,

LA000697 No ML#, since no separate response to

the NRC LI*USAR 8.2.4.3, 8.2.4.12, 8.2

ReferencenoneYesNANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 21 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 2 11/9/07 07-0416A ML073106750 MD6144 Letter of 2/25/08 granting relief, ML080240029 Prior to use of nonwelded valves with end connections

other than flanges at KPS, procedures will be

developed for installation of

nonwelded valves with end

connections other than

flanges that address

operating experience of

NRC Information Notices 92

-15, 84-55 and 84-55, Supplement 1. The specific

provisions include: a) not

mixing the parts from one

manufacturer to another, b)

following manufacturer's

recommended instructions

for installing compression

fittings, and c) the training

or familiarity with the

procedure(s) for personnel

doing this work.

complete 1/2/2008; NC LC000142 ,

LA000741

("LA type"soluti

on was incorrect.

Data entry

was performed

by inexperien

ced person -

self corrected) no response to the NRC

required LI*Maintenance Procedure

MA-KW-GMP-103NoneYesNANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 31 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 3 11/9/07 07-0352 ML073170705 MD7300 Amend. No.

200, 11/20/08, ML082971079 Notify the NRC when the modifications to the

Auxiliary Building (AB)

crane to make it single-

failure proof are complete complete 6/12/08; NC LC000141 ,

LA000133Note 03-CLI*

CA069210 says to update procedure

GNP-08.12.02 plus

tags.None Yes- it was timely

since it accomplis hed a design change.NANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 41 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 4 11/9/07 07-0352 ML073170705 MD7300 Amend. No.

200, 11/20/08, ML082971079 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 to this license

amendment request (LAR).

• Lifting devices not specially designed will meet

the guidance in NUREG-

0612, Section 5.1.6(1)(b)

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 Complete 1/16/09; NC LC000141 ,

LA000135 Addressed in TRM [a licensee controlled

document kdf] See Note 04-C LI*TRM 3.8.1, Rev 0, 1/15/09.none Yes. Completio n took place within 60

days, as planned.NANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 51 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 5 11/9/07 07-0352 ML073170705 MD7300 Amend. No.

200, 11/20/08, ML082971079 Crane operator training will meet the guidance in ASME

B30.2-2005.

complete 12/15/08 LC000141 ,

LA000736 None to NRC LI*Lesson Plan M-MD-LP 2.2.1 "Cranes"; M-

PM2-LP 1.9.1 "Crane Maintenance

/ Inspection" None Yes. Lesson Plans had

guidance incorporat

ed in reference

to this Amd's approval.NANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 61 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 6 11/9/07 07-0352 ML073170705 MD7300 Amend. No.

200, 11/20/08, ML082971079 Crane maintenance and inspections will meet the

guidance in ASME B30.2-

1976.complete 1/16/09, NC LC000141 ,

LA000740 TRM Bases, USAR LI*TRM Bases (TRM 3.8.1

pg 381-2)

USAR Rev22

Sec. 9, pp

9.5-9, -10

(6/30 None Yes. During NRC ISFSI Inspection

(6/09) issues were identified

with crane

inspection

procedure s

concernin g B30.2 guidance.

REF CR 337889.

Revised MA-KW-MPM-CRN-007 Rev.

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

3. ASME B30.2 is referenced

in procedure s.NANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 71 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 7 11/9/07 07-0352 ML073170705 MD7300 Amend. No.

200, 11/20/08, ML082971079 Revise USAR Section 9.5.2 to remove the dropped cask

analysis from the USAR.

complete 1/15/09: NC LC000141 ,

LA000737USARLI*USAR 14.2.1, 9.5 none Yes, implement ed in a timely manner.

Amd was issued 11/08 and

implement ed 1/09.

Much work

took place

- USAR revision submitted

9/09 with

the next scheduled

update of

USAR being 3/31/10.NANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 81 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 8 11/9/07 07-0352 ML073170705 MD7300 Amend. No.

200, 11/20/08, ML082971079 After LAR approval and relocation of TS 3.8.a.7 to

the technical requirements

manual (TRM) is

authorized, add to the TRM

required actions to take if

the AB crane lifting system

is found not to meet the

TRM requirements during a

heavy load lift.

complete 1/16/09; NC LC000141 ,

LA000735 TRM LI*TRM, licensee controllednoneYesNANA 9 11/9/07 07-0465 ML073180499 MD7301 Letter of 5/9/08 (ML081150741),

notice of

withdrawal of

application for

amendment DEK will complete required modifications to the AB

crane bridge girder to end-

tie connections and confirm

bolting material as

described in Section 4.2.2.9

of this LAR.

NC, design change recorded as

completed

on 5/5/08

according to

tTrack LAR

ML07318049

9 withdrawn

by letter

dated 4/11/08 LC000141 ,

LA000732 None to NRC; Design

change DCR3629 was completed

on 4/22/09;

ready to install 9/10/07, which is RgCm closure.LI*DCR3629 is the implementing

document none Yes. Bolting material is

confirmed, per ECN3629-06.NANA 10 2/8/2008 08-0017 ML080650314 MC4691 Review is ongoing The KPS USAR will be modified upon final

resolution of GSI-191 and

response to Generic Letter 2004-02.In progress; NC LC000181 ,

LA000907 None to NRC LI*USAR 6.2.9.3 are planned

to be changed.USAR Change Request (UCR) R21-

108 dated

9/19/08.NA Yes - tTrack shows completi on date changed to 6/1/11.NA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 91 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 11a 6/2/08 08-0113 ML081550342 MD7300 Amend. No.

200, 11/20/08, ML082971079

1. DEK will place a restriction in the Kewaunee

procedure governing the

use of the AB crane

prohibiting the use of

synthetic slings for heavy

load lifts with the AB crane

when this crane is in the "Cask Handling" or "Override" modes of

operation.

complete 1/16/09, NC LC000141 ,

LA000997 None to NRC LI*Changed procedure

GNP-08.12.02 none Yes. Verified Step 4.15

of GNP-08.12.02 Rev 26, 7/18/2010NANA 11b 6/2/08 08-0113 ML081550342 MD7300 Amend. No.

200, 11/20/08, ML082971079

2. For the AB crane bridge welds whose failure could

result in a drop of the critical

load, DEK will perform

nondestructive

examinations at least once

every four years following

completion of initial cold

proof load testing of the AB

crane.complete 1/16/09, NC LC000141 ,

LA000998 None to NRC; entered Preventive

Maintenance

Program, RE89105 LI*Preventive Maintenance (PM) Task -

PM 53065.

Examinations

IAW AWS-01.1-1994.

PM Card has

TS Amend.

Referenced.

none Yes. Preventive

Maintenan ce Program

RE89105, which notes it is

a RgCm.NANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit DataPage 101 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 11c 6/2/08 08-0113 ML081550342 MD7300 Amend. No.

200, 11/20/08, ML082971079

3. DEK will not perform a heavy lift greater than 50

tons using the AB crane.

This commitment will be

superseded when a seismic

analysis, using NRC-

approved methods, demonstrates acceptable

results are achieved for the

AB crane and establishes a

new limit based on lifting

heavy loads greater than 50

tons.complete 1/27/09, NC LC000141 ,

LA000999 None to NRC; changed procedure

GNP-08.12.02, "Control for

use of cranes in

protected

area" LI*Chnged procedure

GNP-08.12.02 none Yes. GNP-08.12.02 change done 7/8/10NANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit DataPage 111 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 12 7/7/08 08-0211 ML081930317

is a resubmittal

of an amendment

request from

11/9/07.

(i.e.,Audit

Sample #12 is

a pickup from

1. 9 with supplements

dated 9/19/08

and 3/17/09)

Note 12-2 MD9221 Amend. No, 205, 4/30/09, ML090570710

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

the force required to induce

crane trolley and bridge

drive wheel rolling with the

brakes applied. The results

of the test will be provided

to the NRC.

3. DEK will have an independent peer review

performed of the nonlinear

structural model and

outputs of the nonlinear

analysis to confirm the

methodology is appropriate

for the application and

provide a summary of the

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]

complete 7/15/10; NC

[All 3 managed as

one - kdf]

LC000228 (No LAs are needed since the

actions can be managed as a group

within the

LC number.)SN 08-211 sent to NRC

on 7/7/08 (DEK accomplishe

d all RgCm

in the sample.

Submitted to

the NRC within the

9/19/08 sample)LI*Push Test details provided in

9/19/08 SupplementnoneYesNANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit DataPage 121 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 13 1/27/09 09-061 ML090510149 ME0435 Letter approving notice of

enforcement

discretion, 1/29/09, ML090291061 DEK commits to administratively control the

amount of fuel oil in each

fuel oil storage tank such

that a minimum usable

amount of 32,858 gallons (including the day tanks) is

available to supply each

emergency diesel generator (EDG) (without reliance on

a portable transfer pump),

for the duration of the

enforcement discretion.

complete 6/10/09; NC LC000315 (No LA number -

one item only)None to NRC LI*USAR Rev 22 update

6/30/10 pg 8.2-18, Section 8.2.3.1 none Yes. Control is

USAR editNANA 14 6/1/09 09-291 ML091600037MD9408Review ongoing The installation of EDG exhaust duct insulation (SAMA 160) will be further

evaluated as part of DEK's

ongoing performance

improvement programs.

In progress; NC LC000345 ,

LA001560 None to NRCLI*Note 14-E Not yet determinedNoYesNA15Sample deletedMD9408 Sample deleted at request of

Project Manager

making the

selection..

See Note 15-5 sample results not

used.sample results not

used sample results not

used LI*sample results not

used sample results not

used sample results not

used sample results not used sample results not used Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit DataPage 131 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 16a 8/17/09 09-469 ML092320093 MD9408 License renewal review ongoing

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

changes will be consistent

with the responses to

Requests for Additional

Information (RAIs) B2.1.13-

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.

In progress; NC LC000343 ,

LA001541 Reportable through USAR change LI*USAR (pages to be defined;

expected to

be complete

4/4/11)noneNAYesNA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit DataPage 141 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 16b 8/17/09 09-469 ML092320093 MD9408 License renewal review ongoing

2. The response to RAI B3.2-2 will be provided

following reevaluation of the

environmental effects of

fatigue for the NUREG/CR-

6260-required evaluations

that used stress-based

fatigue monitoring.

Complete and transferred

for action by

LA001848 LC000343 ,

LA001542

[original

tracking]

transferre

d to LC000392

,

LA001848

[Observati

on 16b-B]Transferred to LA001848 LI*Letter SN 10-033 dated

dated 2/2/10 (responded to

RAI B3.2-2)

No change to RgCm.

Change was

to tTrack to

record transfer from

LA001542 to

LA001848YesNA Yes. RgCm itself not

changed (transfer

was successfu l)17a 9/24/09 09-491 ML092440398 ME2139 Conversion to Improved TS

review ongoing (The following commitments are selected from

) [Three of

nine commitments were

selected for audit - kdf]

2. DEK will establish the Technical Specification

Bases for Limiting Condition

for Operation (LCO) 3.0.8, as adopted, with the

applicable license

amendment.

In progress; NC LC000407 ,

LA001897 None to NRC LI*Tech Spec Bases LCO 3.0.8noneNAYesNA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit DataPage 151 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 17b 9/24/09 09-491 ML092440398 ME2139 Conversion to Improved TS

review ongoing

7. DEK will have written procedures available

describing compensatory

measures to be taken in the

event of an intentional or

unintentional entry

into LCO 3.7.12, Auxiliary

Building Special Ventilation (ASV) System, Condition B, "Two ASV trains inoperable

due to inoperable ASV

boundary."

Complete 12/6/10; NC LC000407 ,

LA001902ProcedureLI*

Procedure OP-KW-AOP-

GEN-005 "Unplanned

Barrier ControlnoneYesNANA 17c 9/24/09 09-491 ML092440398 ME2139 Conversion to Improved TS

review ongoing

8. DEK will add procedural direction to perform an

extent of condition

evaluation and perform

additional testing for

plausible common failure

modes associated with the

reactor protection system

and the engineered safety

features actuation system

instrument analog channels.

.Withdrew 12/6/10; NC LC000407 , LA1903 Withdrew via 8/18/2010

Supple LI*Letter SN10-457 to NRC

withdrew commitment (Letter is

8/18/10 supplement

on TAC ME2139)noneWithdrewNANA Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit DataPage 161 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 18 9/25/09 09-597 ML092710045 MD9408 License renewal review ongoing The revised Work Control Process program will be

developed and implemented

prior to the period of

extended operation.

In progress; NC LC000394 ,

LA001858Not closedLI*

Revised work control program document (TBD)noneNAYesNA 19a 10/15/09 09-645 ML092890560 MD7838 Letter of 4/1/10, ML100880212 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]

1. DEK will revise current fill and vent procedures to

provide a means and

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.

Complete (This RgCm

was changed

from 10/1/09

to 10/15/09)

LC000239 ,

LA001178 Leter SN 09-645 dated

9/15/09 to

NRCLI*Note 19-E Change to date only

(10/1/09 to

10/15/09)YesNAYes Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit DataPage 171 - Audit Sample No.2 - DEK Submittal 3 - NRC TAC No.4 - NRC Issuance5 - Summary of CommitmentA - Action Completed (date)Action in Prgress (no date)Not Changed / Changed to what?B - KPS Tracking #LC#,, CAP#C - If closed, then KPS closeout informationD - Governed by KPS process document # (See Note LI*)E - Affected implementing documentF - Affected change documentG - Closed RgCm implemented in timely manner (Yes / No / NA)H - Open RgCm is adequately Maintained (Yes / No / NA)I - Changed RgCm is adequately managed (Yes / No / NA) 19b 10/15/09 09-645 ML092890560 MD7838 Letter of 4/1/10, ML100880212

2. DEK will revise current inservice test procedures to

provide dynamic sweeping

as part of the filling of the

systems where needed to

ensure systems are

sufficiently full.

Complete (This RgCm

was changed

from 10/1/09

to 10/15/09)

LC000239 ,

LA001179LI*Note 19-E Uses LI* -

commitment

change evaluation

Change to

date only

(10/1/09 to

10/15/09)YesNAYes Table 3 - Kewaunee Power Station RgCm Data Table - Notes and LegendPage 18 To p ic or Word / S ymbolNote, le g end or discussionADAMSAgencywide Document Access and Management SystemAmd or Amend.amendment Audit observation (general)

The Preventive Maintenance Program would be improved if the Comment field on the PM (preventive maintenance) Data Sheet informed the user that the sheet had a RgCm associated with it.

Audit observation (training)

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

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

LA001542 with LA001848.CFRCode of Federal Regulations

Column headings and cell

designations Columns are labeled numbers 1 through 5 and letters A through I. Sample numbers are listed in column 1.

Notes are designated as "Note (row) - (column)" Commitment management staff Persons identified as making routine, standardized data entry into tTrack, identified as Noreen Wenborne, MaryJo Haese, and Thomas Breene during the course of RgCm data collection.ECNEngineering Change Notice Generic Letter 2004-02"Potential Impact of Debris Blockage on Emergency Recirculation during Design Bais Accidents at Pressurized-Water Reactors," September 13, 2004 GSI-191"Experimental Studies of Loss-of-Coolant Accident-Generated Debris Accumulation and Head Loss with Emphasis on the Effects of Calcium Silicate Insulation," May 2005kdfKarl D. Feintuch (Mainly used in combination with brackets to indicate an auditor comment.)

KPSKewaunee Power Station LALicensing Action;one or more LA can be associated with one LC LCLicensing Commitment LI*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, "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.

ML#"MLnnnnnnnnn" (i.e. ML followed by 9 digits) is the identifier used by the NRC to access documents and records within its Agencywide Document Access and Management System (ADAMS) document control system.NCNot Changed (as used in column A)

Table 3 - Kewaunee Power Station RgCm Data Table - Notes and LegendPage 19 To p ic or Word / S ymbolNote, le g end or discussion Note 01-G, -H, -I (i.e., headings in column G, H and I)

A "Yes" in Column G, H, or I indicates that the RgCm was successfully managed according to the description in the heading.

NA applies if the particilar column does not apply. As examples, for a closed RgCm, "open" is NA; for

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

Note 12-2, Audit Observation and Audit Finding 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)

A udit Finding: DEK lacks a documented instruction in LI-AA-110, "Commitment Management," that the instructs 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.

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

Note 15-5 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

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.

Note 19-E Affected procedures (21 documents, as indicated by separate serial numbers):

OP-KW-NOP-RHR-001, -003

SP-34-099A, -099B

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 Note on references to TS In this audit TS references are to the Custom Technical Specifications (CTS), which preceded the conversion to Improved Technical Specifications (ITS) on February 2, 2011.

Note on sample characteristics for the sample size of 24, categorized

from audit results 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)

RgCm items changed and closed = 16b, 19a, 19b (3 items)

RgCm items open and remaining the same = 10, 14, 16a, 17a, 18 (5 items)

RgCm items open and changed = none Table 3 - Kewaunee Power Station RgCm Data Table - Notes and LegendPage 20 To p ic or Word / S ymbolNote, le g end or discussion Note row-column A discussion pertaining to Table 2, row number and column number, which is inserted in Table 3 due to space 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, Supplement 1"Seal Table Leaks at PWRs," May 14, 1985NRC Information Notice 92-15"Failure of Primary System Compression Fitting," February 24, 1992NUREG/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 1979NUREG-0612"Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical Activity A-36," July 1980 RgCm Regulatory Commitment, as interpreted by NEI 99-04 (the industry document governing RgCm management) and LIC-105 (the NRC document governing RgCm audits)

SAMA 160 SAMA 160 is described in the license renewal submittal as "Insulate EDG Exhaust Ducts." The context is that 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.

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

11a, b, c)

[Commitment management staff should monitor processes that cause users to contact them for RgCm information and arrange to add RgCm information to relevant databases. - kdf]SuppleSupplement Title 10The section of the Code of Federal Regulations pertaining to "Energy" TRM Technical Requirements Manual - a licensee controlled document for managing plant specific technical requirements. The TRM is incorporated by reference into the Updated Safety Analysis Report (USAR)TSTechnical Specifications, as described in 10 CFR 50.36 tTrackName of database used to track RgCm.

UCRUSAR Change Request USARUpdated Safety Analysis Report