ML110900537

Audit Report Tables 2 and 3

ML110900537
Person / Time
Site:	Kewaunee
Issue date:	04/11/2011
From:	Feintuch K Plant Licensing Branch III
To:	Heacock D Dominion Energy Kewaunee
Feintuch K, NRR/DORL/LPL3-1, 415-3079
Shared Package
ML110900569	List: ML101550684 ML110900537
References
TAC ME3804
Download: ML110900537 (10)

Text

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 1 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 ML073100354 None None 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 Reference none Yes NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 2 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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-103 None Yes NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 3 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 LA000133 Note 03-C LI*

CA069210 says to update procedure GNP-08.12.02 plus tags.

None Yes-it was timely since it accomplis hed a design change.

NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 4 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 LAR

• Interfacing lift points will meet the guidance in NUREG-0612, 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.

NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 5 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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.

NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 6 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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.

NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 7 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 LA000737 USAR LI*

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.

NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 8 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 controlled none Yes NA NA 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 ML073180499 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.

NA NA 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 9 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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, 7/18/2010 NA NA 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 -

PM 53065.

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.

NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 10 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 7/8/10 NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 11 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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

1. 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 Supplement none Yes NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 12 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 enforcement discretion.

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 edit NA NA 14 6/1/09 09-291 ML091600037 MD9408 Review 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 NRC LI*

Note 14-E Not yet determined No Yes NA 15 Sample deleted MD9408 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 Data Page 13 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 license renewal 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) none NA Yes NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 14 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 LA001848 Yes NA 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 3.0.8 none NA Yes NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 15 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 LA001902 Procedure LI*

Procedure OP-KW-AOP-GEN-005 "Unplanned Barrier Control none Yes NA NA 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 reactor protection system 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) none Withdrew NA NA

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 16 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 LA001858 Not closed LI*

Revised work control program document (TBD) none NA Yes NA 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 NRC LI*

Note 19-E Change to date only (10/1/09 to 10/15/09)

Yes NA Yes

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 17 1 - Audit Sample No.

2 - DEK Submittal 3 - NRC TAC No.

4 - NRC Issuance 5 - Summary of Commitment A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS closeout information D - Governed by KPS process document # (See Note LI*)

E - Affected implementing document F - Affected change document G - 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 LA001179 LI*

Note 19-E Uses LI* -

commitment change evaluation Change to date only (10/1/09 to 10/15/09)

Yes NA Yes

Table 3 - Kewaunee Power Station RgCm Data Table - Notes and Legend Page 18 Topic or Word / Symbol Note, legend or discussion ADAMS Agencywide Document Access and Management System Amd 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.

CFR Code 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.

ECN Engineering 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 2005 kdf Karl D. Feintuch (Mainly used in combination with brackets to indicate an auditor comment.)

KPS Kewaunee Power Station LA Licensing Action;one or more LA can be associated with one LC LC Licensing 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.

NC Not Changed (as used in column A)

Table 3 - Kewaunee Power Station RgCm Data Table - Notes and Legend Page 19 Topic or Word / Symbol Note, legend 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-C NRC 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)

Audit 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 Legend Page 20 Topic or Word / Symbol Note, legend 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, 1985 NRC Information Notice 92-15 "Failure of Primary System Compression Fitting," February 24, 1992 NUREG/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 1979 NUREG-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]

Supple Supplement Title 10 The 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)

TS Technical Specifications, as described in 10 CFR 50.36 tTrack Name of database used to track RgCm.

UCR USAR Change Request USAR Updated Safety Analysis Report