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05000305/FIN-2012005-0331 December 2012 23:59:59KewauneeNRC identifiedRemoval of Refueling Procedure Requirement For Spent Fuel Pool Cooling Without Prior NRC ApprovalThe inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, and associated finding of very low safety significance for the failure to document an evaluation that provided a basis for the determination that the changes implemented in Procedure RF-01.00, KNPP (Kewaunee Nuclear Power Plant) Refueling Procedure, Revision I, did not require a license amendment in 2001. Specifically, the licensee failed to include, in the written evaluation, a basis as to why the change did not create a possibility for a malfunction of an structure, system or component (SSC) important to safety with a different result than any previously evaluated in the Updated Safety Analysis Report (USAR) and did not result in a departure from a method of evaluation described in the USAR used in establishing the design bases. The changes to procedure RF-01.00 removed a requirement to place the residual heat removal (RHR) A heat exchanger in parallel with the spent fuel pool (SFP) heat exchanger, when a full core offload took place with service water temperatures greater than or equal to 60 degrees Fahrenheit (◦F). The licensee initiated condition report (CR) 493206, and at the end of the inspection period, was conducting a causal evaluation and developing corrective actions to restore the required actions to the refueling procedure. The violation was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because the performance deficiency adversely affected the Barrier Integrity Cornerstone objective to maintain functionality of the SFP cooling system. Specifically, the configuration control and design control attributes, related to the design margins for the SFP, increase in allowable fuel assemblies as documented in License Amendment No. 150. Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process instead of the SDP because they are considered to be violations that potentially impede or impact the regulatory process. However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. In this case, the inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012 and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions, dated June 19, 2012. The inspectors answered No to questions 1 through 4 in Section D, Spent Fuel Pool, and screened the finding as having very low safety significance (Green). In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation is categorized as SL IV because the resulting changes were evaluated by the SDP as having very low safety significance. The inspectors determined that this finding did not reflect present performance since the error was introduced in a design change that was greater than three years old; therefore, there was no cross-cutting aspect associated with this finding.
05000305/FIN-2012003-0430 June 2012 23:59:59KewauneeNRC identifiedIncorrect Leakage Requirement Submitted for a Proposed Temporary Pipe ClampA Severity Level (SL) IV NCV of 10 CFR Part 50.9(a), Completeness and Accuracy of Information, was identified by the inspectors for the failure of the licensee to provide complete and accurate information in all material respects to the Commission in licensee Request RR-2-3, dated April 29, 2012 (ADAMS Accession No. ML12122A138). As part of a license amendment for a proposed temporary deviation from the requirements of 10 CFR 50.55a and ASME Code, Section XI, the licensee incorrectly stated the allowable leakage from the temporary clamp in transition from Mode 5 to 4 was governed by TS 5.5.2, Primary Coolant Sources Outside Containment, and proposed an allowable leakage value of 5.5 gallons per hour (gph). After licensee Request No. RR-2-3 was verbally approved by the NRC on April 30, 2012, the inspectors and NRC staff determined that the governing leakage requirement was no leakage in Mode 4 for the clamp as required by TS 3.4.13, Reactor Coolant System Operational Leakage. The performance deficiency was determined to be more than minor in accordance with the NRC Enforcement Policy and Enforcement Manual because the NRC identified the performance deficiency, the NRC relied on the information provided in a licensing decision, and the misinformation was identified after the NRC relied on the information in its licensing decision. Because violations of 10 CFR 50.9 are considered to be violations that potentially impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the ROP SDP. Because the performance deficiency, specifically a failure to submit complete and accurate information, was not an ROP finding per IMC 0612, Appendix B, Issue Screening, a cross-cutting aspect was not assigned to this violation. The severity of the violation was mitigated because of the facts surrounding the licensees implementation of Request No. RR-2-3.
05000305/FIN-2012002-0631 March 2012 23:59:59KewauneeNRC identifiedFailure to Submit LER Per 10 CFR 50.73The inspectors identified an SL IV NCV of 10 CFR 50.73(a)(2)(vii) for the failure of the licensee to report an event where a single cause or condition caused two independent trains to become inoperable in a single system designed to control the release of radioactive material. Specifically, the licensee failed to report that both trains of shield building ventilation (SBV) were inoperable due to a single cause, because both trains contained unqualified control card standoffs that were needed to maintain the seismic qualification and operability of the system. The licensee entered this into their CAP as CR429469, planned to perform an ACE, and was drafting an update to Licensee Event Report (LER) 05000305/2011-005. The inspectors determined that the failure to report the event in accordance with 10 CFR 50.73 was a performance deficiency. Because violations of 10 CFR 50.73 are considered to be violations that potentially impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Reactor Oversight Process (ROP) SDP. Because the performance deficiency, a failure to report, was not an ROP finding per IMC 0612, Appendix B,` Issue Screening,` a cross-cutting aspect was not assigned to this violation. Per the NRC Enforcement Policy, Section The inspectors identified an SL IV NCV of 10 CFR 50.73(a)(2)(vii) for the failure of the licensee to report an event where a single cause or condition caused two independent trains to become inoperable in a single system designed to control the release of radioactive material. Specifically, the licensee failed to report that both trains of shield building ventilation (SBV) were inoperable due to a single cause, because both trains contained unqualified control card standoffs that were needed to maintain the seismic qualification and operability of the system. The licensee entered this into their CAP as CR429469, planned to perform an ACE, and was drafting an update to Licensee Event Report (LER) 05000305/2011-005. The inspectors determined that the failure to report the event in accordance with 10 CFR 50.73 was a performance deficiency. Because violations of 10 CFR 50.73 are considered to be violations that potentially impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Reactor Oversight Process (ROP) SDP. Because the performance deficiency, a failure to report, was not an ROP finding per IMC 0612, Appendix B,` Issue Screening,` a cross-cutting aspect was not assigned to this violation. Per the NRC Enforcement Policy, Section 6.0,` Violation Examples,` a failure to submit a required LER is categorized as an SL IV violation.
05000305/FIN-2011001-0130 September 2011 23:59:59KewauneeNRC identifiedQuality Assurance Controls of Safety-Related Lifting YokeA Severity Level IV non-cited violation of 10 CFR 72.146, Design Control, was identified by the inspectors for the failure of the licensee to incorporate the lifting yoke, a safety-related device, into the licensees quality assurance program. Specifically, the inspectors identified that the licensee did not have measures in place to ensure suitability of materials, parts, equipment, and processes which are important to safety. At the conclusion of this inspection, the licensee entered the issue into the corrective action program and was developing corrective actions. Consistent with the guidance in Section 2.2 of the NRC Enforcement Policy, independent spent fuel storage installations are not subject to the Significance Determination Process and, thus, traditional enforcement was used for this issue. The inspectors compared this violation to the minor questions of Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, dated January 1, 2010, and determined that this violation was more than minor because, if left uncorrected, it would become a more significant safety concern. Absent NRC intervention, the failure to incorporate the lifting yoke into the licensees quality assurance program could have allowed nonsafety-related materials, parts, and processes to be installed or performed on the safety-related lifting yoke. Consistent with the guidance in Section 2.6.D of the NRC Enforcement Manual, if a violation does not fit an example in the Enforcement Policy Violation Examples, it should be assigned a severity level: (1) commensurate with its safety significance; and (2) informed by similar violations addressed in the Violation Examples. The inspectors determined that the violation could be evaluated, using example 6.5.d.1 of the NRC Enforcement Policy, as a Severity Level IV Violation because the licensee failed to meet a quality assurance requirement that has more than a minor safety significance.
05000305/FIN-2011003-0430 June 2011 23:59:59KewauneeNRC identifiedFailure to Submit LER per 10 CFR 50.73A Severity Level IV non-cited violation of 10 CFR 50.73(a)(2)(i)(B) and 50.73(a)(2)(v)(C) was identified by the inspectors for the failure of the licensee to report an event or condition that was prohibited by Technical Specifications, and an event or condition that could have prevented the fulfillment of a safety function that is relied upon to control the release of radioactive material. Specifically, the licensee failed to report that shield building ventilation train A was inoperable from December 3, 2010, through January 26, 2011. Technical Specification 3.6.c.1 allows a single train outage time of seven days. Additionally, shield building ventilation train B was inoperable on multiple occasions during the same time period, requiring the licensee to also report an event or condition that could have prevented the fulfillment of a safety function, which is relied upon to control the release of radioactive material. At the end of the inspection period, the licensee was completing an apparent cause evaluation to determine the cause and develop corrective actions. Because violations of 10 CFR 50.73 are considered to be violations that potentially impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Reactor Oversight Process Significance Determination Process. A cross-cutting aspect was not assigned to this violation. Per the NRC Enforcement Policy, Section 6.0, Violation Examples, a failure to submit a required licensee event report is categorized as a Severity Level IV violation.
05000305/FIN-2010004-0330 September 2010 23:59:59KewauneeNRC identifiedReplacement of Automatic Action with an Operator Manual Action Without Prior NRC ApprovalA Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, was identified by the inspectors for the failure to document an evaluation that provided a basis for the determination that the changes implemented in DCR 3163 and Emergency Operating Procedure ES-1.3, Transfer to Sump Recirculation, in 2001 did not require a license amendment. Specifically, the licensee failed to provide an evaluation that adequately documented why replacing the automatic opening of the service water (SW) valves SW-1300A and SW-1300B upon a safety injection signal (to support the service water safety function of loss of coolant accident (LOCA) recirculation operation) with a manual action to open the valves in Emergency Operating Procedure ES 1.3, did not present more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the updated safety analysis report. The licensee initiated CR389330 and, at the end of the inspection period, planned to submit a license amendment request to the NRC for this design change. The violation was determined to be more than minor because the inspectors could not reasonably determine that the changes would not have ultimately required prior NRC approval. Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process instead of the SDP because they are considered to be violations that potentially impede or impact the regulatory process. However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. In this case, the inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Tables 3b and 4a, for the Mitigating Systems Cornerstone. The inspectors answered yes to question 1 of the Mitigating Systems Cornerstone column of the Phase 1 worksheet because the inspectors concluded that this was a design basis deficiency confirmed not to result in the loss of operability. Based upon this Phase 1 screening, the inspectors concluded that the issue was of very low safety significance (Green). In accordance with Section 6.1.d.2 of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance. The inspectors determined that this finding did not reflect present performance since the error was introduced in a design change that was greater than three years old; therefore, there was no cross-cutting aspect associated with this finding.
05000305/FIN-2010502-0130 September 2010 23:59:59KewauneeNRC identified(Traditional Enforcement) Changes to EAL Technical Bases Document Decreases the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a Green finding and an associated Severity Level IV NCV of 10 CFR 50.54(q) associated with 10 CFR 50.47(b)(2) because the licensee failed to obtain prior NRC approval for a change made to its emergency plan that decreased the effectiveness of the plan. Specifically, the licensee changed wording in their EAL technical basis document for EAL SU5 and CU1, RCS Leakage. The new wording eliminates leakage from the charging and letdown systems from consideration as RCS Leakage and therefore, leakage from these systems that meet the EAL thresholds would not constitute an Unusual Event declaration, using the licensees revised wording. This change was made without prior NRC approval. The performance deficiency was more than minor and of very low safety-significance using MC 0612 and MC 0609, Appendix B, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using MC 0609, Appendix B, the inspectors determined that the finding had a very low safety significance. The inspectors also determined that the finding had a cross-cutting aspect in the area of Human Performance, decision-making because the licensee did not recognize that the change that was made to the EAL Technical Basis document decreased the effectiveness of the emergency plan.
05000305/FIN-2009004-0730 September 2009 23:59:59KewauneeLicensee-identifiedLicensee-Identified ViolationTechnical Specification 6.4 states: A training and retraining program for the Plant Staff shall be maintained and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI-18.1-1971 and 10 CFR Part 55. General Nuclear Procedure GNP-13.03.01 Revision 23 Conduct of Training implements these requirements. This procedure identifies that trainees are responsible for ensuring personal qualifications are current to independently perform assigned work. Contrary to the above, on July 16, 2008, a lead chemistry technician independently performed an activity without having met the requisite qualification. Specifically, the individual completed a radiological liquid waste release discharge permit after his qualification for performing the activity was revoked during the periodic re-qualification program on July 16, 2008. Based on an Office of Investigations investigation; Case No. 3-2008-027, the NRC staff concluded that a lead chemistry technician deliberately violated the training requirements by completing a radiological liquid waste release discharge permit knowing that his qualifications were not current. The violation was categorized as a Severity Level IV violation because: 1) the violation had limited actual radiological significance and low potential significance; 2) the violation involved the acts of a low-level individual; 3) the violation resulted from an isolated action without management involvement; 4) there was no economic or other advantage gained as a result of the violation; and 5) adequate remedial action was taken by the licensee. Because the violation is of very low safety significance, it meets the additional criteria in Section VI.A.1 of the NRC Enforcement Policy, and because it has been entered into the corrective action system (CR103866) it is being treated, after consultation with the Director, Office of Enforcement, as an NCV
05000305/FIN-2009006-0430 September 2009 23:59:59KewauneeNRC identifiedInadequate 50.59 Evaluation of Shutdown Loss of Coolant Accident ProcedureThe inspectors identified a finding of very low safety significance and associated Non-Cited Violation of 10 CFR 50.59(d)(1) for the licensees failure to perform an adequate review of an abnormal operating procedure associated with a shutdown loss of coolant accident. As part of its corrective actions, the licensee revised procedure OP-KW-AOP-RHR-002 to remove the procedure applicability to the Cold Shutdown mode and Refueling mode with reactor vessel head on. The inspectors determined that the finding was more than minor because it could not reasonably be determined that the activity would not ultimately have required NRC approval. Operation in accordance with the procedure may have challenged the reactor coolant system barrier. The inspectors determined that the finding did not require a quantitative assessment per IMC 0609, Appendix G. Therefore, the finding screened as having very low safety significance (Green) and was determined to be a Severity Level IV violation. The cause of this finding is related to the cross-cutting aspect in the area of Human Performance, Decision Making, because the licensee failed to use conservative assumptions in decision making to demonstrate that the proposed action to include additional modes of applicability for the Shutdown LOCA procedure was safe in order to proceed.
05000305/FIN-2009004-0630 September 2009 23:59:59KewauneeNRC identifiedFailure to Follow ISFSI Loading Procedure StepThe inspectors identified a Severity Level IV NCV of 10 CFR 72.150, Instructions, Procedures, and Drawings, during the Independent Spent Fuel Storage Installation loading campaign. The licensee failed to follow procedure OP-KW-NOP-ISF-001, Dry Shielded Canister Loading. The inspectors determined that the licensees failure to follow step 5.2.6 of Procedure OP-KW-NOP-ISF-001 to perform a crane brake check was contrary to 10 CFR 72.150. The licensee immediately evaluated the situation and discussed the need to check the crane brakes when lifting loads approaching the rated loads with the refueling crew to prevent missing this step in the future. The inspectors determined that the violation had more than minor safety significance because the failure to check the crane brakes, results in not knowing if the brakes are functioning properly, which may lead to a failure of the brakes while lifting a loaded spent fuel canister. The issue was addressed by traditional enforcement since 10 CFR Part 72 is not risk based and is not covered under the reactor oversight process. Because this violation was of very low safety significance, was non-repetitive and non-willful, and was entered into the corrective action program, this violation is being treated as a NCV of 10 CFR 72.150 consistent with Section VI.A.1 of the Enforcement Policy. The inspectors determined that there was no cross-cutting aspect associated with this finding
05000305/FIN-2008004-0230 September 2008 23:59:59KewauneeNRC identifiedFailure to Perform a 10 CFR 50.59 Screening for Alteration During Maintenance That Existed for More Than 90 DaysA finding of very low safety significance and an associated Severity Level IV, NCV of 10 CFR 50.59 was identified by the inspectors for a failure to perform a 50.59 screening for an alteration during maintenance that existed for more than 90 days. Specifically, the licensee failed to perform a 50.59 screening when spare breakers were removed from safety-related motor control centers (MCCs) and the cubicle were left in an altered state for more than 90 days. Proposed corrective actions include changes to the station housekeeping and work control/planning procedures to better evaluate job site and environmental conditions. The finding is greater than minor because, if left uncorrected, the failure to perform a 10 CFR 50.59 screening on an alteration/change to the facility would become more significant. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 2 for the Mitigation Systems Cornerstone. Using information provided by the licensee relative to the affected MCCs, the inspectors answered no to all of the questions in this cornerstone column; therefore, the finding was determined to be of very low safety significance. Additionally, the inspectors determined that the finding has a cross-cutting aspect in the area of human performance, work control because the licensee failed to appropriately plan work activities by incorporating risk insights gained from operating experience and factor in environmental conditions during planning contingencies for systems, structures, and components anticipated to be in a maintenance condition for extensive periods of time. (H.3(a)) (Section 1R15)
05000305/FIN-2005002-0631 March 2005 23:59:59KewauneeNRC identifiedInadequate Evaluation of Procedure Changes to Address AFW Design Deficiencies

The team identified a finding involving a Non-Cited Violation of 10 CFR 50.59, \"Changes, Tests, and Experiments.\" The finding involved a failure to perform an adequate review of operations procedure changes in accordance with 10 CFR 50.59 associated with the operation of motor-operated valves for the auxiliary feedwater suction source from the service water system. The team determined that the licensee's approval of changes to Procedure E-0-05, with the introduction of adverse effects, and a determination that 10 CFR 50.59 was not applicable was a violation of 10 CFR 50.59. The licensee subsequently performed additional evaluations of the procedure changes.

Because the issue affected the NRC's ability to perform its regulatory function, this finding was evaluated with the traditional enforcement process. The finding was determined to be of very low safety significance since the design basis safety-related function of the AFW system, to remove reactor decay heat following a loss of normal feedwater, was not adversely affected. This was determined to be a Severity Level IV NCV of 10 CFR 50.59.

05000305/FIN-2003008-0131 December 2003 23:59:59KewauneeNRC identifiedNON-CITED Violation of 10 CFR 50.59, for the Failure to Perform a Written Evaluation, as Required, for a Modification to the Component Cooling Water System

The inspectors identified a finding of very low safety significance associated with a Non-Cited Violation of 10 CFR 50.59(d)(1) for the licensee's failure to perform a safety evaluation for changes made to the facility. Specifically, the licensee screened out' of the 10 CFR 50.59 process a modification that included the addition of a minimum flow recirculation line to the component cooling water pumps. This modification further cross-connected the suction and discharge piping of both component cooling water pump trains. Subsequently, the inspectors identified and the licensee concurred that a safety evaluation was required for this modification.

Because the Significance Determination Process is not designed to assess the significance of violations that potentially impact or impeded the regulatory process, this issue was dispositioned using the traditional enforcement process in accordance with Section IV of the NRC Enforcement Policy. However, the results of this violation were assessed using the Significance Determination Process. In this case, the licensee failed to perform a safety evaluation in accordance with 10 CFR 50.59 and had placed the new system in service for testing prior to the completion of the required safety evaluation.

The inspectors considered this issue to be of more than minor significance because, if left uncorrected, the issue could become a more significant safety concern. Specifically, the inspectors noted that the licensee's processes for permanent modifications failed to identify this issue at several review levels. The inspectors determined that the issue was of very low significance because the new system was placed in service for a short period of time for testing prior to the completion of the required safety evaluation. In addition, the final safety evaluation completed by the licensee in October 2003 determined that the modification did not require prior NRC approval. The inspectors determined this finding was a Severity Level IV Non-Cited Violation of 10 CFR 50.59. The inspectors also determined that the finding had, as a primary cause, a human performance deficiency which affected the cross-cutting are of Human Performance.

05000305/FIN-2003005-0231 December 2003 23:59:59KewauneeNRC identifiedFailure to Provide Accurate Information to the NRC Concerning Licensed Operator Medical Requirements Per NRC Form 396.Severity Level IV. The inspector identified a Level IV Non-Cited Violation of 10 CFR 50.9, "Completeness and Accuracy of Information." The inspector identified that the facility licensee, between January 2, 2000, thorugh August 26, 2002, submitted to the NRC, NRC Forms 396 for 13 individuals applying for an initial operator's license and 18 licensed operators applying for renewal of their operator licenses, that were not accurate in all material respects. Specifically, the NRC Forms 396 certified that each applicant and licensed operator met the medical requirements of ANSI/ANS 3.4-1983. In fact, all the applicants and licensed operators were not adequately examined for all medical tests as required to meet the minimum standards of ANSI/ANS 3.4-1983.
05000305/FIN-2003005-0431 December 2003 23:59:59KewauneeNRC identifiedFailure to Provide Accurate Information to the NRC Concerning Eligibility Requirements for Operator License Application Per NRC Form 398.Severity Level IV. The inspector identified a Level IV Non-Cited Violation of 10 CFR 50.9, "Completeness and Accuracy of Information." The inspector identified that on or about August 13, 2002, a senior facility licensee representative submitted to the NRC, NRC Forms 398 for three individuals, each applying for an initial operator's license, that were not accurate in all material respects. The facility licensee provided inaccurate information by certifying on the NRC Form 398 that the initial operator license applicaitons for three individuals had appropriately met the minimum training requirements for reactivity manipulations on the refrenced facility simulator in accordance with 10 CFR 55.31(a)(5) and 10 CFR 55.46(c)(2).