ML072430431
| ML072430431 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 08/31/2007 |
| From: | Caldwell J Region 3 Administrator |
| To: | Christian D Dominion Energy Kewaunee |
| References | |
| Download: ML072430431 (8) | |
Text
August 31, 2007 Mr. David A. Christian Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - KEWAUNEE POWER STATION
Dear Mr. Christian:
On August 14, 2007, the NRC staff completed its performance review of Kewaunee Power Station for the first half of the calendar year 2007 assessment cycle. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results over the previous 12 months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only - Security Information" will include the security cornerstone review and resultant inspection plan.
Plant performance for Kewaunee Power Station for the most recent quarter was within the Degraded Cornerstone Column of the NRCs Action Matrix, based on one inspection finding of substantial safety significance (Yellow) within the Mitigating Systems cornerstone. This Yellow finding, from the first quarter of 2007, involved the failure to evaluate and repair a fuel oil leak on an emergency diesel generator.
In our Assessment Follow-up Letter dated May 16, 2007, we informed you that we would be conducting a supplemental inspection at Kewaunee using Inspection Procedure 95002, Inspection For One Degraded Cornerstone Or Any Three White Inputs In a Strategic Performance Area, for the Yellow inspection finding. We also informed you that we would conduct a supplemental inspection using Inspection Procedure 95001, Inspection for One or Two White Inputs in a Strategic Performance Area, for the White PI for Unplanned Scrams per 7000 Critical Hours in the Initiating Events cornerstone and for the White Mitigating System Performance Index in the Mitigating Systems cornerstone. It is anticipated that a supplemental inspection using IP 95002 for all three issues will begin in October or November pending our receipt of your letter notifying us that you are prepared for the inspection. The objectives of this inspection are to provide assurance that the root and contributing causes of risk significant performance issues are understood, the extent of condition is identified, and the corrective actions are sufficient to prevent recurrence.
D. Christian Additionally, the staff has continued to identify substantive cross-cutting issues in the areas of human performance (HP) and problem identification and resolution (PI&R). During this assessment period, there were thirteen findings that were attributable, at least in part, to weaknesses in HP. Eight of the thirteen findings were identified in 2007. Because five of these findings shared the common aspect of inadequate procedures (H.2(c)) and five shared the common aspect of not following procedures (H.4(b)), the substantive cross-cutting issue in the area of HP will remain open. Furthermore, there were ten inspection findings that were attributable, at least in part, to weaknesses in PI&R. Six of these findings shared the common aspect of inadequate problem evaluation (P.1(c)). Nine of the ten inspection findings were identified in 2007. During the biennial PI&R inspection in May 2007, the inspectors concluded that you had not established either qualitative or quantitative measures for determining the effectiveness of the correction actions to prevent recurrence.
Because the NRC does not have assurance that the planned corrective actions were sufficient to address the causes of the performance deficiencies associated with the findings, these substantive cross-cutting issues will remain open until the number of findings with the same cross-cutting aspect is reduced or when the NRC gains confidence in the performance of your corrective action program to evaluate and correct problems.
A substantive cross-cutting issue in HP was first identified by us in our 2006 Mid-Cycle Performance Review letter (dated August 31, 2006, ADAMS Accession Number ML062430340) and a substantive cross-cutting issue in PI&R was first identified by us in our Annual Assessment Letter for 2004 (dated March 2, 2005, ADAMS Accession Number ML050620423).
The persistence of these issues to the 2007 mid-cycle assessment indicates that actions by Kewaunee to address them have not been effective. We would like to meet with you to discuss this matter further. We will contact you with the meeting details but it should be scheduled before the IP 95002 inspection.
The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 2008. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite.
Routine resident inspections are not listed due to their ongoing and continuous nature. Of note, the plan includes an inspection using Temporary Instruction TI-150 related to reactor pressure vessel head and vessel head penetration nozzles, the PI&R inspection, the triennial fire protection inspection, and the component design bases inspection. The inspections in the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle review.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
D. Christian The NRC is currently evaluating the scope and frequency of all the baseline inspection procedures. If the results of the evaluation, or any other circumstances, cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Jamnes Cameron at (630) 829-9833 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
James L. Caldwell Regional Administrator Docket No. 50-305 License No. DPR-43
Enclosure:
Kewaunee Power Station Inspection/Activity Plan DISTRIBUTION:
See next page
D. Christian The NRC is currently evaluating the scope and frequency of all the baseline inspection procedures. If the results of the evaluation, or any other circumstances, cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Jamnes Cameron at (630) 829-9833 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
James L. Caldwell Regional Administrator Docket No. 50-305 License No. DPR-43
Enclosure:
Kewaunee Power Station Inspection/Activity Plan DISTRIBUTION:
See next page DOCUMENT NAME: G:\Branch TSS\ALL MOC\midcycle 2006 to 2007\Kewaunee\KEWA 2007 MOC Letter.wpd G Publicly Available G Non-Publicly Available G Sensitive G Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII RIII NAME MKunowski:dtp JCameron CPederson JCaldwell DATE 08/27/07 08/28/07 08/28/07 08/28/07 OFFICIAL RECORD COPY
Letter to Mr. David A. Christian from J. Caldwell dated August 31, 2007
SUBJECT:
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - KEWAUNEE POWER STATION cc w/encl: L. Hartz, Site Vice President C. Funderburk, Director, Nuclear Licensing and Operations Support T. Breene, Manager, Nuclear Licensing L. Cuoco, Esq., Senior Counsel D. Zellner, Chairman, Town of Carlton J. Kitsembel, Public Service Commission of Wisconsin State Liaison Officer, State of Wisconsin Mayor of Kewaunee City Council President Chair, Manitowoc County Board County Executive Chair, Kewaunee County Board Director, Manitowoc County Emergency Management Agency Director, Kewaunee County Emergency Management Agency City Manager of Two Rivers Village President of Mishicot INPO
Letter to Mr. David A. Christian from J. Caldwell dated August 31, 2007
SUBJECT:
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - KEWAUNEE POWER STATION DISTRIBUTION:
DXC1 TEB MHC RidsNrrDirslpab JLC1 MAS KGO JKH3 RML2 SAM9 SRI Kewaunee DRPIII DRSIII PLB1 TXN
Kewaunee Inspection / Activity Plan 09/01/2007 - 12/31/2008 No. of Staff Planned Dates Inspection Inspection Activity Title on Site Start End Type BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 IP 7112102 ALARA Planning and Controls 10/01/2007 10/05/2007 Baseline Inspections IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 10/01/2007 10/05/2007 Baseline Inspections BI EP - EP EXERCISE INSPECTION / PI VERIFICATION 1 IP 7111401 Exercise Evaluation 12/03/2007 12/07/2007 Baseline Inspections IP 71151-EP01 Drill/Exercise Performance 12/03/2007 12/07/2007 Baseline Inspections IP 71151-EP02 ERO Drill Participation 12/03/2007 12/07/2007 Baseline Inspections IP 71151-EP03 Alert & Notification System 12/03/2007 12/07/2007 Baseline Inspections BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 IP 7112101 Access Control to Radiologically Significant Areas 02/11/2008 02/15/2008 Baseline Inspections ISFSI - ISFSI INSPECTION 1 IP 60854 Preoperational Testing Of An ISFSI 04/01/2008 09/30/2008 Other Routine IP 60854.1 Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating P 04/01/2008 09/30/2008 Other Routine BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 IP 7112101 Access Control to Radiologically Significant Areas 04/07/2008 04/11/2008 Baseline Inspections IP 7112102 ALARA Planning and Controls 04/07/2008 04/11/2008 Baseline Inspections BI ENG - ENGINEERING INSERVICE INSPECTION/ TI-150 1 IP 2515/150 Reactor Pressure Vessel Head and Vessel Head Penetration Nozzles (NRC ORDER EA 03/31/2008 04/25/2008 Safety Issues IP 7111108P Inservice Inspection Activities - PWR 03/31/2008 04/25/2008 Baseline Inspections PI&R - BIENNIAL PI&R INSPECTION 3 IP 71152B Identification and Resolution of Problems 05/19/2008 06/06/2008 Baseline Inspections BI ENG - TRIENNIAL FIRE PROTECTION INSPECTION 3 IP 7111105T Fire Protection [Triennial] 06/23/2008 07/11/2008 Baseline Inspections BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 07/14/2008 07/18/2008 Baseline Inspections IP 71151-BI01 Reactor Coolant System Activity 07/14/2008 07/18/2008 Baseline Inspections IP 71151-OR01 Occupational Exposure Control Effectiveness 07/14/2008 07/18/2008 Baseline Inspections IP 71151-PR01 RETS/ODCM Radiological Effluent 07/14/2008 07/18/2008 Baseline Inspections ISFSI - ISFSI INSPECTION 1 IP 60855 Operation Of An ISFSI 07/01/2008 09/30/2008 Other Routine IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants 07/01/2008 09/30/2008 Other Routine BI EP - EP ROUTINE INSPECTION / PI VERIFICATION 1 IP 7111402 Alert and Notification System Testing 08/04/2008 08/08/2008 Baseline Inspections IP 7111403 Emergency Response Organization Augmentation Testing 08/04/2008 08/08/2008 Baseline Inspections IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 08/04/2008 08/08/2008 Baseline Inspections
Kewaunee Inspection / Activity Plan 09/01/2007 - 12/31/2008 No. of Staff Planned Dates Inspection Inspection Activity Title on Site Start End Type BI EP - EP ROUTINE INSPECTION / PI VERIFICATION 1 IP 71151-EP01 Drill/Exercise Performance 08/04/2008 08/08/2008 Baseline Inspections IP 71151-EP02 ERO Drill Participation 08/04/2008 08/08/2008 Baseline Inspections IP 71151-EP03 Alert & Notification System 08/04/2008 08/08/2008 Baseline Inspections BI ENG - COMPONENT DESIGN BASES INSPECTION 5 IP 7111121 Component Design Bases Inspection 08/25/2008 09/26/2008 Baseline Inspections BI OL - BIENNIAL REQUAL. PROGRAM INSPECTION 2 IP 7111111B Licensed Operator Requalification Program 10/13/2008 10/17/2008 Baseline Inspections BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 11/03/2008 11/07/2008 Baseline Inspections