ML110900537
| 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: |
| 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
.
- Interfacing lift points will
meet the guidance in
, 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
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 -
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
- 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
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
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
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