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. i000 Ihrnm~on Roulcvard, Glen Allen, VA 2 3060 December 5, 2006 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 5 Dominion' Serial No.06-724 KPSILICIMH:

R1 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, uWA 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 Objective Implement NMC Fleet Operations Mentoring Program to improve Conduct of Operations. Raise standards of performance within Operations.

Summary of Commitment Steps To provide an immediate improvement in the Conduct of Operations, experienced SRO License holders from the NMC fleet have been temporarily placed on shift with the Kewaunee Operations crews to provide mentoring and feedback.

This objective will be achieved by: 1. conducting a gap analysis between current conduct of Operations and industry best practices, 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 provide feedback on standard adherence.

3. implement Dominion Corrective Action Program Entry CA 18561 CA 18845 COM 21 608 Completion Date Prior to Startup from the Spring 2005 Forced Outage Methods to Verify Commitment Met Fleet NOS observations.

Documented feedback from mentors. Conduct a follow-up assessment for an effectiveness review 3Q05. Revised Conduct of Operations Procedure issued. Assess as part of mentor follow-up effectiveness review 3Q05. Check Operator Program implemented. DNOS a roved and PP Page 1 of 22 Serial No.06-724 Docket No.05-305 Attachment issued. Nuclear Operations Standards (DNOS).

COM 21609 Corrective Action Program Entry CA 18846 Completion Date Methods to Verify Commitment Met Item 1 (Cont'd) Summary of Commitment Steps Objective lmprove understanding of what an Operations - led organization looks like. To gain a broader perspective and improved understanding of what an Operations - led organization is, all Shift Managers will participate in a benchmarking trip to plants recommended by INPO or other industry groups. Trip reports documenting benchmarking trip results, including improvement actions. lmprove Operations training.

To improve performance of the Operations Department, experienced personnel from INPO and the NMC fleet have been temporarily placed with Kewaunee Operations Training staff. This will provide an immediate improvement in the conduct of Operations Training, recognizing that additional actions will be nitiated based on the scheduled self- wsessment.

Documented feedback from mentors. Self-assessment of the Operations Training Programs. The self-assessment will include industry peers. mprove the effectiveness of ~perational decision making.

The Kewaunee Operational Decision Making procedure Nil1 be upgraded to align Nith a more effective 3perational decision making model, based on ndustry practices.

4ppropriate training and/or ~riefing will be conducted Page 2 of 22 Effectiveness Review of original procedure. Operational Decision Making Procedure revision issued.

Item 1 (Cont'd) Objective Improve Non-Licensed Operator Continuing Training program to revise the listed KPS EOPIAOPs into 2-column format. Summary of Commitment Steps Revise the Nuclear Auxiliary Operator Training Program Description to improve the focus on systems. Develop, review, and approve the 2006-2007 Non-Licensed Operator Continuing Two-Year Training Plan. Perform effectiveness review. COM 21 621 COM 21 621 Corrective Action Program Entry COM 21 622 COM 21623 COM 21624 Completion Date Serial No.06-724 Docket No.05-305 Attachment 1 I L~st Published Work-off curve established.

Methods to Verify Commitment Met Program revised. Develop, review and approve plan. Effectiveness review completed.

Page 4 of 22 0 bjective Improve the quality of Operability Determinations.

Validate the quality of existing open Operability Determinations.

Summary of Commitment Steps Combined Engineering and Operations training on Operability Determinations and Recommendations has been conducted.

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

To confirm quality and applicability of the operability determinations for all Operable but Degraded and Operable but Non-conforming 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. Corrective Action Program Entry CAP 26045 CE 15568 CA 191 28 CA 18563 Completion Date Prior to Startup from the Spring 2005 Forced Outage Prior to Startup from the Spring 2005 Forced Outage Serial No.06-724 Docket No.05-305 Attachment 1 Methods to Verify Commitment Met Training attendance records. Effectiveness review 4Q05. Documented summary of reviews. PORC concurrence of open operability determinations. Page 5 of 22 Serial No.06-724 Docket No.05-305 Attachment 1 Objective

-- Confirm prior NRC commitments have been implemented as required.

Confirm assumptions made in critical engineering calculations, that require operator actions to be performed within specific times, reflect actual operator response times. Provide reasonable assurance of design basis compliance for high energy line breaks, tornados, flooding, and seismic events. Summary of Commitment Steps A representative sample of existing commitments will be performed to confirm the implementation of prior commitments that Kewaunee has made to the NRC. A validation will be performed of all time critical operator actions assumed in engineering calculations for the top 19 high risk

/ low margin components prior to startup from the current outage. The balance of the top 50 high risk components will be completed by 4Q05. Assessments and plant walk downs are being conducted to identify significant issues with high 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 Corrective Action Program Entry CAP 26046 CE 15569 CA 19103 CAP 27239 CA 19531 Completion Date Prior to Startup from the Spring 2005 Forced Outage Prior to Startup from the Spring 2005 Forced Outage Prior to Startup from the Spring 2005 Forced 3utage Methods to Verify Commitment Met Documented assessment results. Documented assessment results of top 19 components prior to startup from the current outage. Documented assessment results of top 50 components 4Q05. Documented walk down results. Page 6 of 22 Serial No.06-724 Docket No.05-305 structural failures that could impact the operability of safety- related equipment.

Corrective Action Program Entry CA 18934 Completion Methods to Verify Date Commitment Met Summary of Commitment Steps Objective Resolve auxiliary feedwater system operability concerns due to loss of suction from the Condensate System.

Modifications will be implemented to restore operability of the auxiliary feedwater system. The scope of the modification will include re-routing of the auxiliary feedwater pump suction piping, and installation of a low suction pressure trip function. Prior to Startup Modification from the Spring documents. 2005 Forced Outage Prior to Startup Modification from the Spring documents. 2005 Forced Outage Address the turbine building flooding concerns. Modification and repairs will be completed to address the turbine building internal flooding issue. Reduce potential for residual heat removal pump pit flooding during shutdown. Implement modification to reduce flooding potential for RHR pump pits. COM 21626 Approved design description, approved 1 OCFR50.59, completed work order.

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

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

Serial No.06-724 Docket No.05-305 Update PRA Model Objective Validate and improve documentation of the design basis for: Internal Flooding, High Energy Line Breaks, Station Blackout, Tornados, and Seismic Events Complete documentation and validation of the license bases for the safety functions of the most risk significant safety systems. Incorporate turbine building flood modifications and operations procedure changes Summary of Commitment Steps A project plan will be developed and implemented to complete design basis topical reports. CA 18849 A project plan will be developed and implemented for the documentation and field validation of license bases for the safety functions of the Auxiliary Feedwater System, Service Water System, Residual Heat Removal System, Component Cooling Water System, and Emergency Diesel Generators, 4kV electrical system and DC electrical system. CA 18850 COM 21629 Corrective Action Program Entry COM 21749 COM 21751 COM 21753 COM 21754 COM 21756 COM 21737 COM 21738 COM 21748 COM 21739 COM 21740 COM 21741 COM 21742 COM 21 743 Completion Date Attachment PRA Notebook issued Methods to Verify Commitment Met Internal flooding topical report completed High energy line break topical report completed Station blackout topical report completed Tornado topical report completed Seismic topical report completed AFW System completed SW System completed Interim project progress review RHR System completed CCW System completed EDG completed 4kV System completed DC System completed Page 8 of 22 Item 5 (Cont'd) Objective Improve retrievability and control of calculations of record. Updating of Environmental Qualification (EQ) Program Summary of Commitment Steps The following will be completed:

1. Complete populating the current safety related calculations into the calculation database, and

2. Incorporating cross- reference information of inputs/outputs between calculations. Conduct a validation assessment of a sample of completed EQ program documents for adequacy in incorporating design basis information and assess prioritization of update plan. Corrective Action Program Entry CA 18851 COM 21631 Completion Date Serial No.06-724 Docket No.05-305 Attachment 1 Methods to Verify Commitment Met Electronic database population complete.

Cross-referencing between calculations in database complete.

Effectiveness review. Perform assessment of completed file upgrades and plan.

Page 9 of 22 Serial No.06-724 Docket No.05-305 Attachment 1 Objective Complete AC electrical models and calculations to provide clear bases for safety related settings and loads. Complete DC electrical models and calculations to provide clear bases for safety related settings and loads. Summary of Commitment Steps Complete AC electrical calculations for:

1. load flow, CA 18853 2. short-circuit currents, CA 18853 3. EDG loading, CA 18853 4. relay setting, cA 18853 5. protection coordination, CA 18853 6. control circuit voltage drops, cA 18853 7. cable ampacity, CA 18853 8. thermal overload relays. CA 18853 Complete DC electrical calculations for: 1. battery sizing, CA 18854 2. charger sizing, CA 18854 3. voltage drop, CA 18854 4. short-circuit currents, CA 18854 5. control circuit voltage Corrective Action Program Entry COM 21832 COM 21 833 COM 21834 COM 21837 COM 21833 COM 21837 COM 21834 Completion Date Methods to Verify Commitment Met lnterim project progress review. lnterim project progress review.

Calculations completed, validated, and issued. 0 lnterim Progress Review lnterim project progress review. lnterim project progress review.

Calculations completed, validated and issued. Page 10 of 22

0 bjective Improve the quality of Engineering products.

Summary of Commitment Steps An assessment of engineering has been conducted using NMC fleet and external expertise to identify the key areas for improvement and to develop associated action plans. To improve the quality of Engineering products, an interim Independent Review Group (IRG) has been established to provide an in-line independent review of engineering products, including:

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 expectations regarding Engineering product quality. Corrective Action Program Entry CE 15571 CA 18890 CA 18891 Completion Date Prior to Startup from the Spring 2005 Forced Outage Prior to Startup from the Spring 2005 Forced

Outage Serial No.06-724 Docket No.05-305 Attachment 1 Methods to Verify Commitment Met Completed assessment report.

IRG Implemented Engineering quality effectiveness review 4Q05. Training attendance records. Page 12 of 22 Serial No.06-724 Docket No.05-305 Attachment 1 Item 7 (Cont'd) Objective lmprove Engineering knowledge and understanding of design and licensing bases. lmprove the interface between Operations, Maintenance, and Engineering.

lmprove Station Engineering Support lmprove Equipment Reliability Summary of Commitment Steps Training will be conducted on design and licensing bases for Engineering personnel.

Roles and responsibilities for Operations, Maintenance, and Engineering as they relate to Engineering support will be examined and re- defined as necessary.

Corrective Action Program Entry CA 18855 CA 18856 Establish System Engineering COM 21 808 COM 21809 Completion Date Methods to Verify Establish a Station Equipment Reliability Team (SERT) and Station Equipment Reliability Issues List (SERIL). Commitment

~et Training attendance records. COM 21 81 2 COM 2181 4 Effectiveness review 2Q06. Roles and responsibilities documented.

1 Q06 1 Q06 Effectiveness review 4Q05. Dominion Assist Visit Implement Dominion Plant Health Reports.

Team established List developed Page 13 of 22 Serial No.06-724 Docket No.05-305 Attachment 1 Objective Ensure station personnel are aware of their roles and responsibilities in the Corrective Action Program (CAP). Validate the appropriateness of the significance level assigned for all wrrently open conditions adverse to quality in the Corrective Action Dr~gram. 4ssure CAP trends are identified and

~sed in the significance and level of ?ffort assigned during CAP screening.

Summary of Commitment Steps Actions will be taken to ensure that station personnel are aware of their roles and responsibilities as they pertain to the Corrective Action Program. Implement communications campaign to reinforce roles and responsibilities. An independent review of all open conditions adverse to quality in the Corrective Action Program is being completed. Trend information related to repeat CAP items will be provided to the daily CAP screen team. Corrective Action Program Entry CA 18857 COM 21632 Completion Date - - Prior to Startup from the Spring 2005 Forced Outage hior to Startup 'rom the Spring 2005 Forced 3utage Methods to Verify Commitment Met Employee briefings completed. New employee training program revised. Copies of D-15 and presentation materials.

Documented results of the assessment.

Generation of adverse trend CAPS. Effectiveness review 4Q05. Page 14 of 22 Item 8 (Cont'd) Objective Assure that managers recognize the significance of long standing issues.

Summary of Commitment Steps Training on risk significance will be provided to the management team.

This training is also part of the corrective actions to prevent recurrence from the containment equipment hatch close root cause evaluation.

Corrective Action Program Entry CA 18858 Completion Date Serial No.06-724 Docket No.05-305 Attachment 1 Methods to Verify Commitment Met Training attendance records. Assessments indicate no significant CAP prioritization errors.

Goal is to have: 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 Objective Validate the timeliness for resolution of current open significant issues. Assure operable but degraded / non- conforming issues are corrected in a timely manner. Upgrade the KPS Emergency Action Levels (EAL) to the NEI 99-01 EAL scheme as submitted to NRC on October 26, 2004 Summary of Commitment Steps An independent review is being conducted of all open corrective actions from level "A and "B action requests to validate the timeliness of resolution for significant issues. Administrative procedures have been revised to include requirements for timely resolution of operable but degraded / non-conforming issues.

As of March 15, 2005,28 open OBDs remain. Conduct training.

Implement new EALs. Corrective Action Program Entry CE 15567 COM 21635 COM 21636 Completion Date Prior to Startup from the Spring 2005 Forced Outage 6 months after NRC approval.

6 months after NRC approval Methods to Verify Commitment Met Documentation of results from the review. Revision to procedure GNP 11.08.01 issued. March 15, 2005 backlog of open operable but degraded / non- conforming conditions reduced by 2 50%. Training completed Procedures revised.

Page 17 of 22 Objective Communicate Kewaunee "Picture of Excellence" to employees to help facilitate sustained performance improvement. NRC-05-118 stated to the NRC that DEK no longer commits to the Kewaunee Picture of Excellence but rather the Kewaunee Passion for Excellence.

Summary of Commitment Steps Action steps to meet this objective include communicating and reinforcing the "Picture of Excellence" to improve accountability and individual behaviors. Training for managers and supervisors has begun, and will be completed prior to unit startup. Corrective Action Program Entry CA 1 8861 Completion Date Serial No.06-724 Docket No.05-305 Attachment 1 Methods to Verify Commitment Met Training attendance records. Page 1 8 of 22 Serial No.06-724 Docket No.05-305 Attachment 1 Objective Provide the necessary infrastructure and tools required to execute and reinforce the "Picture of Excellence". Build depth in Emergency Response Organization Summary of Commitment Steps The implementation steps include: Incorporating ACEMAN into daily Plan Of the Next Day (POND) meetings.

Implementation of a daily meeting (D-15) between 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 Management Plans to the "Picture of Excellence" Establishing monthly

Picture of Excellence Review Group (PERG) meetings to foster accountability for implementation of the site Excellence Plans.

Assess staffing needs and qualification in Emergency Preparedness positions.

Train additional personnel.

Corrective Action Program Entry CA 18958 CA 18958 CA 18993 CA 18958 COM 21637 COM 21 638 Completion Date Methods to Verify Commitment Met ACEMAN grading employed at POND meetings. D-15 meetings implemented. "Picture of Excellence" and ACEMAN incorporated into station Performance Management Plans.

PERG Assessment Report Training attendance records. Page 19 of 22 Serial No.06-724 Docket No.05-305 Objective lmprove the leadership capability of supervisors in: 1. Operations, 2. Operations Training, and 3. Engineering.

lmprove the leadership capability of supervisors in: Maintenance, Chemistry, Outage and Planning, Emergency Planning, & Radiation Protection Summary of Commitment Steps A leadership assessment will be conducted for the: 1. Assistant Operations Managers, 2. Shift Managers, 3. Control Room Supervisors, 4. Operations Instructors, 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. 4 leadership assessment tvill be conducted for:

Maintenance Supervision

hemistry Supervision 3utage and Planning Supervision Emergency Planning Corrective Action Program Entry CAP 26038 Engineering CA 18562 CA 18972 Operations CA 18973 CA 1921 1 COM 21639 COM 21643 COM 21644 COM 21641 Completion Date Operations

& Operations Training will be completed 2Q05 Engineering will be completed 3Q05 Attachment 1 Methods to Verify Commitment Met Documented results of the assessments.

Individual Performance Management Plans updated with improvement areas. Documented results of the assessments.

Individual

Performance Management Plans updated with improvement areas.

Page 20 of 22 Item 12 (Cont'd) Supervision Radiation Protection Supervision Objective Summary of Commitment Steps Improve line manager ownership and accountability. Implement DNAP 01 14, Dominion Nuclear Self Evaluation Program.

COM 21645 Corrective Action Program Entry COM 21646 Completion Date Serial No.06-724 Docket No.05-305 Attachment

' Methods to Verify Commitment Met DNAP Approved.

Station Self Assessment Meeting (SSEM) Held Page 21 of 22 Serial No.06-724 Docket No.05-305 Attachment 1 ltem 13 0 bjective lmprove Nuclear Oversight (NOS) effectiveness. Strengthen Nuclear Oversight Assessment Processes Summary of Commitment Steps Implement mentors from other NMC sites for a period of 6 weeks, assign assessors to a functional area, and implement a rotation plan. An improvement plan addressing assessor performance will be developed which will include additional actions Implement Dominion Nuclear Oversight model which includes separate Specialist Assessment and Audit Programs Corrective Action Program Entry CA 18862 COM 21647 Completion Date 3Q05 Methods to Verify Commitment Met Rotation policy in- place. Assessors assigned to functional areas. Develop improvement plan. Review effectiveness of Nuclear Oversight processes.

Establish and fill positions ltem 14 0 bjective lmprove understanding of conservative decision making by managers and supervisors.

Summary of Commitment Steps Training attendance records. Site management will conduct training on conservative decision making for managers and supervisors.

Page 22 of 22 Corrective Action Program Entry CA 18863 Completion Date Methods to Verify Commitment Met