ML070090054

Response to NRC Request for Additional Information Regarding Commitment Management Audit at Kewaunee Power Station from August 28 to September 1, 2006

ML070090054
Person / Time
Site:	Kewaunee
Issue date:	01/02/2007
From:	Hartz L N Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
06-1028
Download: ML070090054 (31)

Text

Dominion Energy Kewaunee, Inc.m N490 Highway 42, Kewaunee, WI 54216-9511 JAN 02 2007 U. S. Nuclear Regulatory Commission Serial No. 06-1028 Attention:

Document Control Desk KPS/LIC/MH:

RO Washington, DC 20555 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE.

INC.KEWAUNEE POWER STATION RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE COMMITMENT MANAGEMENT AUDIT AT THE KEWAUNEE POWER STATION FROM AUGUST 28 TO SEPTEMBER 1, 2006 During the period from August 28 to September 1, 2006 the Nuclear Regulatory Commission (NRC) conducted an audit at the Kewaunee Power Station for the purpose of reviewing the programs associated with the management of regulatory commitments.

During the audit, corrective actions associated with Kewaunee Improvement Initiative 3.a., "Confirm prior NRC commitments have been implemented as required," were reviewed.

These initiatives were initially defined in a letter dated March 18, 2005 (reference 2). These initiatives were endorsed and adopted with clarifications by Dominion Energy Kewaunee (DEK) in a letter dated September 15, 2005 (reference 3).They were updated in a letter dated November 14, 2005 (reference 4), and they were requested to be considered closed in a letter dated December 5, 2006 (reference 5).Subsequent to the NRC's audit, the NRC staff requested additional information to complete its review and final determination of the audit (reference 1).Attachment 1 provides the questions asked by the NRC staff and the associated DEK responses.

Attachment 2 provides the applicable Kewaunee Improvement Plan Commitment Action Closure Document and Attachment 3 provides a matrix of the improvement initiative document assessment.

If you have any questions, please contact Mr. Tom Breene at 920-388-8599.

Leslie N. Hartz Vice President

-Kewaunee Power Station Commitments made in this letter: None 4ooi Serial No. 06-1028 KPS RAI Commitment Management Page 2 of 2 References

1. Letter from Mr. David H. Jaffe (NRC) to Mr. David A. Christian (DEK), "Kewaunee Power Station -Request for Additional Information Related to Commitment Management Audit," dated October 31, 2006. (ADAMS Accession No.ML062640446)

2. Letter from C. W. Lambert (NMC) to Document Control Desk (NRC), "Kewaunee Improvement Initiatives

-Commitments," dated March 18, 2005 (ADAMS Accession No. ML050820213).

3. 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).

4. Letter from W. R. Matthews (DEK) to Document Control Desk (NRC), "Update on Improvement Initiatives," dated November 14, 2005 (ADAMS Accession No.ML053190099).

5. Letter from W. R. Matthews (DEK) to Document Control Desk (NRC), "Closure of Improvement Initiatives to Corrective Action Program," dated December 5, 2006, (ADAMS Accession No. MIL063390666).

Attachments cc: Regional Administrator U. S. Nuclear Regulatory Commission Region III 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 Mr. L. Raghavan Project Manager 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. 06-1028 ATTACHMENT 1 RESPONSE TO NRC'S REQUEST FOR ADDITIONAL INFORMATION REGARDING THE COMMITMENT MANAGEMENT AUDIT AT THE KEWAUNEE POWER STATION FROM AUGUST 28 TO SEPTEMBER 1, 2006.KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 06-1028 Attachment 1 Page 1 of 22 Response to NRC's Request for Additional Information Regarding the Commitment Management Audit at the Kewaunee Power Station from August 28 to September 1, 2006.Reference Letter from Mr. David H. Jaffe (NRC) to Mr. David A. Christian (Dominion),"Kewaunee Power Station -Request for Additional Information Related to Commitment Management Audit," dated October 31, 2006 (ADAMS Accession No. ML062640446).

The Nuclear Regulatory Commission (NRC) has requested additional information regarding a commitment management process audit performed from August 28 to September 1, 2006 at the Kewaunee Power Station. During the audit, corrective actions associated with Kewaunee Improvement Initiative 3.a., "Confirm prior NRC commitments have been implemented as required," were reviewed.Each of the NRC staff's questions regarding the above referenced Kewaunee Improvement Initiative 3.a. and DEK's corresponding responses are provided in the following.

It should be noted that the data collected during the commitment validation project was not broken down to the level of detail needed to accurately provide information in response to some of the NRC's requests.

The information provided is based upon a review of the summary documents that were compiled during the validation effort. This information closely approximates the data requested by the NRC.NRC Question 1: Please provide the Commitment Action Closure Document.DEK Response: Attachment 2 of this letter provides a copy of the requested Commitment Action Closure Document.

The seven startup issues noted in the closure document were entered into the stations corrective action program and their related corrective actions have been completed or dispositioned.

NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient.

Serial No. 06-1028 Attachment 1 Page 2 of 22 DEK Response: Attachment 3 of this letter provides a matrix showing the results of the commitment validation effort that was completed on June 5, 2005. All of the deficiencies noted on the matrix, which were predominantly documentation and administrative issues, were entered into the stations corrective action program and their related corrective actions have been completed or dispositioned.

NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response: Upon discovery of the deficiencies within the commitment management process, numerous actions were entered into the station's corrective action program.Cause evaluations were conducted for all instances of the possible failure to meet commitments.

All of these cause evaluations have been completed and their related corrective actions have also been completed or dispositioned.

Two Apparent Cause Evaluations (ACEs) were initiated to evaluate the commitment management process and determine what actions were needed to improve the process.The scope of the ACEs were: 1. Review the validation project data and determine whether there was a need to backfit the Commitment Tracking Process data to correct the errors discovered during the validation project.2. Encompass all of the problems identified within the Commitment Tracking Process through the validation project and determine why the process problems occurred and what could be done to make the process work.The results of both ACEs determined the cause of the commitment management process deficiencies to be process and procedure inadequacy.

The corrective actions initiated and completed, to improve the process and procedures were: 1) The commitment tracking procedure was revised to add the following requirements:

a) Require that documents implementing a commitment be compiled and kept on file if they are not available elsewhere in the plant.

Serial No. 06-1028 Attachment 1 Page 3 of 22 b) Better define database entry requirements to ensure that complete commitment closure information is recorded and retrievable.

c) Define management responsibilities for maintaining current status of ongoing commitments.

d) Require the Commitment Tracking System to be a living database that will be updated when changes occur to the implementation of commitments.

NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?DEK Response: Station Nuclear Oversight performed an audit of the commitment management process during the 4 th Quarter 2006. There were no commitment tracking or implementation issues discovered.

A self-assessment of all current entries within the Commitment Tracking System is planned to determine those commitment tracking system entries that meet the definition of "commitment" as defined in NEI 99-04. Once the determination of commitment items is accomplished, the implementation of Kewaunee's commitments will again be assessed.NRC Question 5: What percent of identified corrective actions have been completed by commitment category?

When will the final corrective actions be completed?

DEK Response: Corrective actions initiated for the discrepancies found within the stations commitment management program have been completed or dispositioned.

One corrective action remains open pending revision of a procedure.

Generic Corrective Actions Licensee NRC for Discovered Event Notice of Generic Actions Strategic Deficiencies Reports Violations Letters Bulletins (SERs) Issues% Complete 98% 100% 100% 100% 100% 100%Estimated Completion 1 Q07 N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 4 of 22 NRC Question 6: For Observation Report 2005-002--2007, dated March 1, 2006, please provide responses to questions 2 through 5, above, as applicable.

DEK Response: The KPS commitment management process entries as stated in Observation Report 2005-002-2-007 are:

Serial No. 06-1028 Attachment 1 Page 5 of 22 1. The commitment tracking system, used for implementing, statusing, and tracking NRC commitments lacks specific detail in identifying the documents used for implementing commitments.

It lacks details of implementing actions associated with commitments, and it does not provide current status for ongoing commitments.

NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient (concerning implementation, tracking, and statusing of commitments).

DEK Response: The following table provides a breakdown of the areas identified as deficient within the commitment tracking system. These deficiencies were entered into the stations corrective action program and all corrective actions have been completed or dispositioned.

Generic Examined Licensee NRC And Event Notice of Generic Actions Strategic Deficient Reports Violations Letters Bulletins (SERs) Issues Number Examined 54 9 41 10 45 16 Lacked Implementation Detail 17 2 8 1 1 8 Lacked Current Status 39 9 26 2 6 9 Not Tracked 7 4 11 0 7 8 NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response: Refer to DEK's response to NRC Question 3 above.

Serial No. 06-1028 Attachment 1 Page 6 of 22 NRC Question 4: DEK Response: Refer to DEK's response to Question 4 above.NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning implementation, tracking, and statusing of commitments?

When will the final corrective actions be completed?

DEK Response: Corrective actions initiated for the discrepancies found within the stations commitment management program have been completed or dispositioned.

corrective action remains open pending revision of a procedure.

One Generic Corrective Actions Licensee NRC for Discovered Event Notice of Generic Actions Strategic Deficiencies Reports Violations Letters Bulletins (SERs) Issues% Complete 98% 100% 100% 100% 100% 100%Estimated Completion 1Q07 N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 7 of 22 2. Several NRC commitments were partially implemented.

NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient (concerning partially implemented NRC commitments).

DEK Response: The following table provides information concerning those commitments that could only be partially validated as being implemented.

These deficiencies were entered into the stations corrective action program and all corrective actions have been completed or dispositioned.

Generic Partially Licensee NRC Implemented Event Notice of Generic Actions Strategic Commitments Reports Violations Letters Bulletins (SERs) Issues Number Examined 54 9 41 10 45 16 Partial Implementation Validation 21 7 10 1 0 7 NRC Question 3: DEK Response: Refer to DEK's response to NRC Question 3 above.NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?DEK Response: Refer to DEK's response to NRC Question 4 above.

Serial No. 06-1028 Attachment 1 Page 8 of 22 NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning partially implemented commitments)?

When will the final corrective actions be completed?

DEK Response: Corrective actions initiated for discrepancies found within the stations commitment management program have been completed or dispositioned.

One corrective action remains open pending revision of a procedure.

Actions for Generic Partially Licensee NRC Implemented Event Notice of Generic Actions Strategic Commitments Reports Violations Letters Bulletins (SERs) Issues% of Actions Complete 98% 100% 100% 100% N/A 100%Estimated Completion 1Q07 N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 9 of 22 3. Commitments implemented in departmental procedures were dropped when converting all department procedures for writing procedures into one site wide procedure program.NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient (concerning "dropped" procedure issues as stated above).DEK Response: The following data shows the number of commitments that were inadvertently

'dropped' during routine procedure revisions.

In regard to the NRC reference of deficiencies that may have occurred during the site wide procedure implementation, this type of deficiency was not identified during this review process, therefore data concerning numbers of these types of deficiencies does not exist.Generic Commitment Licensee NRC Procedure Event Notice of Generic Actions Strategic Deficiencies Reports Violations Letters Bulletins (SERs) Issues Number Examined 54 9 41 10 45 16 Procedure Deficiencies 7 1 5 0 1 0 NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response: Refer to DEK's response to NRC Question 3 above.

Serial No. 06-1028 Attachment 1 Page 10 of 22 NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?DEK Response: Refer to DEK's response to NRC Question 4 above.NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning "dropped" procedure issues)? When will the final corrective actions be completed?

DEK Response: The following data shows the number of commitments that were inadvertently

'dropped' during routine procedure revisions.

In regard to the NRC reference of the deficiencies that may have occurred during the site-wide procedure implementation, this type of deficiency was not identified during this review process; therefore data concerning this type of deficiency does not exist.Generic Actions for Licensee NRC Procedure Event Notice of Generic Actions Strategic Deficiencies Reports Violations Letters Bulletins (SERs) Issues% Actions Complete 100% 100% 100% N/A 100% N/A Estimated Completion N/A N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 11 of 22 4. In several instances the Commitment Tracking System was not updated with the current status of a commitment.

NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient (concerning current commitment status not being recorded in the commitment tracking system).DEK Response: The following table provides information concerning those commitments that did not have their status updated within the commitment tracking system. These deficiencies were entered into the stations corrective action program and all corrective actions have been completed or dispositioned Commitment Generic Tracking Licensee NRC System Not Event Notice of Generic Actions Strategic Updated Reports Violations Letters Bulletins (SERs) Issues Number Examined 54 9 41 10 45 16 Number Not Updated 39 9 26 2 6 9 NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response Refer to DEK's response to NRC Question 3 above.NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?

Serial No. 06-1028 Attachment 1 Page 12 of 22 DEK Response: Refer to DEK's response to NRC Question 4 above.NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning current commitment status not being recorded in the commitment tracking system)? When will the final corrective actions be completed?

DEK Response: Corrective actions initiated for the discrepancies found within the stations commitment management program in the area of the commitment tracking system not being updated, were entered into the stations corrective action program and the corrective actions have been completed or dispositioned.

Actions for Commitment Generic Tracking Licensee NRC System Not Event Notice of Generic Actions Strategic Updated Reports Violations Letters Bulletins (SERs) Issues% Actions Complete 100% 100% 100% 100% 100% 100%Estimated Completion N/A N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 13 of 22 5. There were several instances of commitments not being tracked in the Commitment Tracking System.NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient (concerning those that were not tracked in the commitment tracking system).DEK Response: The following table provides information concerning those commitments that were not tracked within the commitment tracking system. These deficiencies were entered into the stations corrective action program and all corrective actions have been completed or dispositioned.

Commitment Not Tracked in Commitment Licensee Generic Tracking Event Notice of Generic NRC Actions Strategic System Reports Violations Letters Bulletins (SERs) Issues Number Examined 54 9 41 10 45 16 Number Not Tracked 7 4 11 0 7 8 NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response Refer to DEK's response to NRC Question 3 above.NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?

Serial No. 06-1028 Attachment 1 Page 14 of 22 DEK Response: Refer to DEK's response to NRC Question 4 above.NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning those that were not tracked in the commitment tracking system)? When will the final corrective actions be completed?

DEK Response: Corrective actions initiated for the discrepancies found within the stations commitment management program in the area of commitments not being tracked, were entered into the stations corrective action program and the corrective actions have been completed or dispositioned.

Actions Not Tracked in Generic Commitment Licensee NRC Tracking Event Notice of Generic Actions Strategic System Reports Violations Letters Bulletins (SERs) Issues% Complete 100% 100% 100% N/A 100% 100%Estimated Completion N/A N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 15 of 22 6. There were several instances of documentation not being available to determine implementation of commitment.

NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient (concerning the lack of commitment implementation documentation).

DEK Response: The following table provides information concerning those commitments that lacked implementation documentation.

These deficiencies were entered into the stations corrective action program and all corrective actions have been completed or dispositioned.

Generic Implementation Licensee NRC Documentation Event Notice of Generic Actions Strategic Not Available Reports Violations Letters Bulletins (SERs) Issues Number Examined 54 9 41 10 45 16 Lack of Documentation 21 6 3 2 2 6 NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response Refer to DEK's response to NRC Question 3 above.NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?DEK Response: Refer to DEK's response to NRC Question 4 above.

Serial No. 06-1028 Attachment 1 Page 16 of 22 NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning the lack of commitment implementation documentation)?

When will the final corrective actions be completed?

DEK Response Corrective actions initiated for discrepancies found within the stations commitment management program for the lack of commitment implementation documentation were entered into the stations corrective action program and the corrective actions have been completed or dispositioned.

One corrective action remains open pending revision of a procedure.

Actions for Generic Implementation Licensee NRC Documentation Event Notice of Generic Actions Strategic Not Available Reports Violations Letters Bulletins (SERs) Issues% Complete 98% 100% 100% 100% 100% 100%Estimated Completion 1 Q07 N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 17 of 22 7. There were instances where commitments were not implemented.

NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient (concerning those commitments not implemented).

DEK Response: The following table provides information concerning those commitments that lacked proof of implementation.

These deficiencies were entered into the stations corrective action program and all corrective actions have been completed or dispositioned.

Generic Licensee NRC Commitment Not Event Notice of Generic Actions Strategic Implemented Reports Violations Letters Bulletins (SERs) Issues Number Examined 54 9 41 10 45 16 Lacked Proof of Implementation 17 2 8 1 1 8 NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response Refer to DEK's response to NRC Question 3 above.NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?DEK Response: Refer to DEK's response to NRC Question 4 above.

Serial No. 06-1028 Attachment 1 Page 18 of 22 NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning those commitments not implemented)?

When will the final corrective actions be completed?

DEK Response: Corrective actions initiated for the discrepancies found within the stations commitment management program that lacked proof of implementation were entered into the stations corrective action program and the corrective actions have been completed or dispositioned.

One corrective action remains open pending revision of a procedure.

Generic Commitments Licensee NRC Implementation Event Notice of Generic Actions Strategic Documentation Reports Violations Letters Bulletins (SERs) Issues% Complete 98% 100% 100% 100% 100% 100%Estimated Completion 1 Q07 N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 19 of 22 8. Commitment changes were not tracked in the current Commitment Tracking System database after a commitment change was processed.

NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient (concerning the tracking of commitment changes).DEK Response: The following table provides information concerning those commitments that were not updated with current status in the commitment tracking system database after a commitment change was processed, i.e. relocated to another procedure, etc. These deficiencies were entered into the stations corrective action program and all corrective actions have been completed or dispositioned.

Generic Commitment Licensee NRC Changes Not Event Notice of Generic Actions Strategic Tracked Reports Violations Letters Bulletins (SERs) Issues Number Examined 54 9 41 10 45 16 Number Not Updated 39 9 26 2 6 9 NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response Refer to DEK's response to NRC Question 3 above.NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?

Serial No. 06-1028 Attachment 1 Page 20 of 22 DEK Response: Refer to DEK's response to NRC Question 4 above.NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning the tracking of commitment changes)?

When will the final corrective actions be completed?

DEK Response: Corrective actions initiated for the discrepancies found within the stations commitment management program for not updating commitments within the commitment tracking system were entered into the stations corrective action program and the corrective actions have been completed or dispositioned.

Corrective Actions for Generic Commitment Licensee NRC Changes Not Event Notice of Generic Actions Strategic Tracked Reports Violations Letters Bulletins (SERs) Issues% Complete 100% 100% 100% 100% 100% 100%Estimated Completion N/A N/A N/A N/A N/A N/A Serial No. 06-1028 Attachment 1 Page 21 of 22 9. A commitment to determine past operability of a safety related component was not performed or documented in Licensee Event Report supplements.

NRC Question 2: For each category of commitment (Generic Letter, Bulletins, etc.) please provide the number of cases examined and the number of cases found to be deficient.

DEK Response: There was only one case of the 54 cases reviewed where a Licensee Event Report (LER) supplement was not submitted as stated. The commitment to determine past operability, as referenced above, was mischaracterized.

The past operability information was forwarded in the initial submittal of the LER and was not a concern in regard to the supplemental information that was to have been submitted.

NRC Question 3: What root cause or causes were identified which resulted in the failure to meet regulatory commitments?

For each root cause, please identify the associated corrective action.DEK Response A condition evaluation was conducted to determine if an LER supplement would be submitted.

The subject matter of the LER was the low discharge pressure trip of the AFW pumps, the minimum required flow for the AFW system, and the required level in the condensate storage tanks. After review of this issue it was determined that providing a supplement to the 1997 LER would not provide any benefit. The issues that were stated in the LER have since been addressed through plant modifications and various submittals of other station LERs and station License Amendment Requests.NRC Question 4: What follow-up self-assessments will be undertaken in order to assess the effectiveness of the corrective actions?DEK Response: Refer to DEK's response to NRC Question 4 above.

Serial No. 06-1028 Attachment 1 Page 22 of 22 NRC Question 5: What percent of identified corrective actions have been completed by commitment category (concerning the past operability of a safety related component not be performed or documented)?

When will the final corrective actions be completed?

DEK Response: All actions concerning the past operability of a safety related component not being performed or documented in a Licensee Event Report Supplement are complete.

Serial No. 06-1028 ATTACHMENT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE COMMITMENT MANAGEMENT AUDIT AT THE KEWAUNEE POWER STATION FROM AUGUST 28 TO SEPTEMBER 1, 2006 KEWAUNEE IMPROVEMENT PLAN COMMITMENT ACTION CLOSURE DOCUMENT KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Kewaunee Improvement Plan COMMITMENT ACTION CLOSURE DOCUMENT Action Title NRC Commitment Verification CAP Action # 026046 Documentation to be attached: Action Plan Documents to Validate Action Completion Performance Measures (if applicable)

Description.of Actions Taken & Basis for Closure A sampling of WPSC/KNPP/NMC and NRC correspondence were reviewed and compared to the plant's Commitment Tracking (COMTRAK)

System, In addition to NRC commitments, the scope of the review effort included a review of Kewaunee's implementation of industry initiatives developed by NEI/NUMARC.

The purpose of the full review was to determine if the COMTRAK system tracked and documented the actions specified by the correspondence or suggested by the industry guidelines and whether they were and are implemented at KNPP.Document sources selected to make up the sampling of commitments to be reviewed were:* Kewaunee Licensee Event Reports -1985 to Present -239 LERs* NRC Issued Notices of Violation to Kewaunee -1985 to Present -87 NOVs* NRC Generic Letters -174 GLs* NRC Bulletins

-49 0 NRC Safety Evaluation Reports Contained in Kewaunee Data Base -225 SERs* NEI/NUMARC Initiatives

-19 Based on exceeding 10% of commitments not met from the original data sampled, the sampling of LER and GL commitments was expanded (refer CAP027239).

The results of the expanded verification effort were similar to the original scope.Closure of this NRC commitment is based on capturing the deficiencies found from this commitment verification effort in the plant's corrective action system (75 CAPs were initiated).

The majority of problems identified are administrative in nature. Seven items were noted to be issues of such significance to warrant completion of corrective actions before plant startup. The start up related issues are: 1. LER 91-08 Action 4 -Required a review of exclusion steam RTDs set at 140 degrees response time design concerns.

Could not determine if review was performed to assure response time adequate with appropriate corrective actions to assure proper operation of the exclusion steam dampers as required by this LER action. [CAP027014]

2. SER K-04-035 Action 1 -Commitment to reduce predicted RCS flow rate by 100 gpm when making a calorimetric calibration of RCS elbow tap flow meters. Determined that by documents provided for review this commitment was not being implemented.

[CAP026991

-CAP Complete]3. IE Bulletin 87-01 Action 4 -Review of KNPP Pipe Thinning Program Long Term Program[lnpectiM

$chedule identified that, no evidence to substantiate performance of the seven year Kewaunee Improvement Plan inspection of Feed Water piping due in 2001 could be found. [CAP026916]

4. IE Bulletin 87-01 Action 5 -Review of KNPP Pipe Thinning Program Long Term Program Inspection Schedule identified that that, no evidence to substantiate performance of the five year inspection of the bleed steam extraction lines to the Feed Water heaters due in 2000 could be found.[CAP026916]

5. LER 98-005-01 Action 1 -Required MG-6 Relay installation procedure incorporating Westinghouse installation guidance.

Existing Installation procedure does not include required guidance.

[CAP027579]

6. GL 87-12 Action 4 -Abnormal RHR procedures required steps to address cavitation and vortexing conditions that may impact RHR pump operation.

Current version of abnormal operating procedure A-RHR-34 lacks the guidance previously established to meet the commitment.

[CAP027486]

7. GL 9 1-11 Action 3 -Four plant procedures do not appear to implement the commitment to limit cross connecting electrical power sources. [CAP027501]

See summary reports provided for the processes used and results of this commitment verification effort.Methods by Which Effectiveness will be Measure & Actions Tracking Effectiveness Review 'd Approval: Commitment Owner Gary Harrington Date Lai. o Department Manager/Director

-. ,,s---- Date -" Site Director/Site Vice ./ (President

__Date > (" z Serial No. 06-1028 ATTACHMENT 3 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE COMMITMENT MANAGEMENT AUDIT AT THE KEWAUNEE POWER STATION FROM AUGUST 28 TO SEPTEMBER 1, 2006 CONFIRM PRIOR NRC COMMITMENTS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 06-1028 Attachment 3 Page 1 of 2 An explanation of the items listed in the matrix follows.Item: NRC documents by industry issue and site-specific issue related to violations or plant events.Strategic Issue: Significant industry related issues taken from a tabular listing of documents provided by NMC Corporate.

Actions in Guideline:

The total number of commitments identified in the "Strategic Issues" documents.

All actions, which specifically stated or implied requirements or recommendations in these documents, were counted as "commitments" whether or not they were specifically identified as commitments.

Any site-specific responses or evaluation documents found in the Operating Experience (OE) Program and Commitment Tracking System were also included.

All completed and proposed actions documented in each response were counted.Actions Applicable to KNPP: For each 'Strategic Issue' only those requirements/actions (commitments) related to the Kewaunee plant design were counted (i.e., requirements or design issues specific to BWRs were excluded from the population).

Total Documents:

The total number of documents included in the scope of the commitment verification project.From this population a representative sample was selected for a detailed review of commitments.

Reviewed Documents:

Total number of documents in the representative sample reviewed in detail for any action items or commitments.

Total Commitments:

Commitments counted in the reviewed documents.

A commitment was conservatively defined as requirements, recommendations, or implied actions submitted by NRC or stated in related site correspondence.

Database Yes/No: Defines whether or not the commitment was entered into the Commitment Tracking System.Implementation Yes/NolPartial:

Defines whether documentation and/or proof of the commitment being met could be found. Yes indicates the commitment is fully implemented.

No indicates documented evidence or proof of the commitment being met was not available.

Partial indicates commitment being met could only be partially validated.

Serial No. 06-1028 Attachment 3 Page 2 of 2 Confirm Priru NRC, Co~mitimiireriiS 1ncludes Expansion of the R4eview*y TOTAL REVIEWED DATABASE IMPLEMENTATION DOCUMENTS DOCUMENTS YES NO YES NO PARTIAL License Event Reports 239 54 157 122 35 83 50 24 Notice of Violeation es ponso , 87 9 41 36 5 27 2 12 174 41 201 167 34 160 15 26 Bulletins 49 10 23 22 1 20 1 2 Generic NRC Actions (SERs) 225 45 28 20 8 27 1 0 TOTAL 450 367 83 317 69 64% of REVIEWED ITEMS 1 82% 18% 70% 15% 14%STRATEGIC ISSUES ACTIONS IN GUIDELINE ACTIONS APPLICABLE TO KNPP Station Blackout/Coping Assessment/EDG Performance 14 14 14 0 11 2 1 10 CFR 50.59 Safety Evaluations 5 5 1 4 5 0 0 Licensing Basis Conformance Issues 5 5 5 0 5 0 0 Piping Erosion/Corrosion 15 15 10 5 4 2 9 Substandard Circuit Breakers 4 4 4 0 3 0 1 Shutdown Issues 82 77 0 77 26 36 15 Dedication of Commercial Grade Items For Safety-Related Application' Comprehensive Procurement Initiative 6 6 5 1 6 0 0 Access Authorization Severe Accident Management 17 17 3 14 16 1 0 Steam Generator Program 20 20 20 0 17 1 2 Access Authorization Personnel Data: Guidelines, 27 26 26 0 26 0 0 Fitness ForDuty Data Collletion 1 1 0 1 1 0 0 Fitness For Duty Performahce Data Form 1 1 0 1 1 0 0 Industry Consensus 1 1 0 1 0 1 0 Management of Materials Issues 8 8 0 8 4 3 1 Maintenance Assessment N/A Withdraw Industry N/A Perform Maintenance Assessmients N/A TOTAL 200 88 112 125 46 29% of REVIEWED ITEMS 44% 56% 62% 23% 15%**Included in the plan for review of prior NRC commitments it was stated that if greater than 10% of the initial sample were found deficient the scope would then be expanded.