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| issue date = 01/18/2007
| issue date = 01/18/2007
| title = IR 05000305-07-006, Kewaunee Power, Inspection Plan
| title = IR 05000305-07-006, Kewaunee Power, Inspection Plan
| author name = Falevits Z, Louden P L, Stone A M
| author name = Falevits Z, Louden P, Stone A
| author affiliation = NRC/RGN-III/DRS/EB3
| author affiliation = NRC/RGN-III/DRS/EB3
| addressee name =  
| addressee name =  
Line 14: Line 14:
| page count = 14
| page count = 14
}}
}}
See also: [[followed by::IR 05000305/2007006]]
See also: [[see also::IR 05000305/2007006]]


=Text=
=Text=
{{#Wiki_filter:1/22/07COMPONENT DESIGN BASES INSPECTION (CDBI)INSPECTION PLANKEWAUNEE POWER STATION (INSPECTION REPORT NUMBER 05000305/2007006(DRS) )Inspection ObjectivesThis inspection fulfills the baseline inspection program requirements for biennial InspectionProcedure (IP) 71111.21.  The inspection's objective is to verify that design bases have been
{{#Wiki_filter:1/22/07
COMPONENT DESIGN BASES INSPECTION (CDBI)
INSPECTION PLAN
KEWAUNEE POWER STATION  
(INSPECTION REPORT NUMBER 05000305/2007006(DRS) )
Inspection Objectives
This inspection fulfills the baseline inspection program requirements for biennial Inspection
Procedure (IP) 71111.21.  The inspections objective is to verify that design bases have been
correctly implemented for the selected risk significant components and that operating
correctly implemented for the selected risk significant components and that operating
procedures and operator actions are consistent with design and licensing bases.  This is toensure that selected components are capable of performing their intended safety functions.
procedures and operator actions are consistent with design and licensing bases.  This is to
ensure that selected components are capable of performing their intended safety functions.
This inspection verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity
This inspection verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity
cornerstones for which there are no indicators to measure performance.Inspection Dates:January 29, 2007, through March 2, 2007Exit:March 2, 2007Applicable Inspection ProceduresIP 71111.21"Component Design Bases Inspection ," dated June 22, 2006IP 71152"Identification and Resolution of Problems" (reference)Prepared By:          /RA/                  01/18/2007Lead InspectorDateZelig FalevitsApproved By
cornerstones for which there are no indicators to measure performance.
:            /RA/                01/18/2007DRS Branch ChiefDateAnn Marie StoneReviewed By
Inspection Dates:
:        /RA/                    01/18/2007DRP Branch ChiefDatePat Louden  
January 29, 2007, through March 2, 2007
-2-INSPECTION PLAN DETAILSI.INSPECTION TEAM:Z.  Falevits, Senior Engineering Inspector, Lead, x9717, zxfC. Brown, Senior Engineering  Inspector, x9605, ceb1
Exit:
March 2, 2007
Applicable Inspection Procedures
IP 71111.21
"Component Design Bases Inspection , dated June 22, 2006
IP 71152
Identification and Resolution of Problems (reference)
Prepared By:          /RA/                   
01/18/2007
Lead Inspector
Date
Zelig Falevits
Approved By:            /RA/                 
01/18/2007
DRS Branch Chief
Date
Ann Marie Stone
Reviewed By:        /RA/                     
01/18/2007
DRP Branch Chief
Date
Pat Louden
 
-2-
INSPECTION PLAN DETAILS
I.
INSPECTION TEAM:
Z.  Falevits, Senior Engineering Inspector, Lead, x9717, zxf
C. Brown, Senior Engineering  Inspector, x9605, ceb1
R. Langstaff, Senior Engineering Inspector, x9747, ral4
R. Langstaff, Senior Engineering Inspector, x9747, ral4
A. Dahbur, Engineering Inspector, x9810, akd
A. Dahbur, Engineering Inspector, x9810, akd
S. Burgess, Senior Reactor Analyst, x9752, sdb2
S. Burgess, Senior Reactor Analyst, x9752, sdb2
M. Yeminy, Mechanical Consultant, 305-238-4732
M. Yeminy, Mechanical Consultant, 305-238-4732
G. Skinner, Electrical Consultant, 412-963-9889F. Tran, Engineering Inspector, Observer, x9623, fptIIDetailed Inspection ScheduleLead Inspector Preparation: January 8, 2007Prep. at Region III Offices:  January 22-26, 2007Inspection Onsite Weeks:  January 29 to February 2, 2007February 12-16, 2007
G. Skinner, Electrical Consultant, 412-963-9889
February 26 to March 2, 2007In-office Weeks:  February 5 to 9, 2007February 19 to 23, 2007Entrance Meeting:January 30 at 9:00 a.m.Exit Meeting:  March 2, at 9:00 a.m.Preparation of Inspection Report
F. Tran, Engineering Inspector, Observer, x9623, fpt
:*Inputs Due: March 9, 2007 COB*Draft Completed: March 30, 2007  
II
*Management Review and Approval Completed (target): April 6, 2007 Inspection Report Must Be Issued Before April 16, 2007IIILead Inspector Preparation ActivitiesReview licensee material received based on information request letter, Review PRAinformation with the SRAs, select 30 high risk components, and provide the team a copy
Detailed Inspection Schedule
of the inspection plan.Information Requests  
Lead Inspector Preparation: January 8, 2007
-3-As part of the inspection preparation, the lead inspector contacted the licensee,informed them of the scope of the inspection, and requested that the necessary
Prep. at Region III Offices:  
  January 22-26, 2007
Inspection Onsite Weeks:   
January 29 to February 2, 2007
February 12-16, 2007
February 26 to March 2, 2007
In-office Weeks:   
February 5 to 9, 2007
February 19 to 23, 2007
Entrance Meeting:
January 30 at 9:00 a.m.
Exit Meeting:   
March 2, at 9:00 a.m.
Preparation of Inspection Report:
*
Inputs Due: March 9, 2007 COB
*
Draft Completed: March 30, 2007  
*
Management Review and Approval Completed (target): April 6, 2007  
Inspection Report Must Be Issued Before April 16, 2007
III
Lead Inspector Preparation Activities
Review licensee material received based on information request letter, Review PRA
information with the SRAs, select 30 high risk components, and provide the team a copy
of the inspection plan.
Information Requests
 
-3-
As part of the inspection preparation, the lead inspector contacted the licensee,
informed them of the scope of the inspection, and requested that the necessary
information be provided to the inspection team.  The information request letter was sent
information be provided to the inspection team.  The information request letter was sent
to the license on November 6, 2006.Distribution of Collected InformationOn Monday, January 22, 2007, or sooner, the lead inspector will distribute informationprovided by the licensee, for the 30 components selected by the SRA and the lead
to the license on November 6, 2006.
Distribution of Collected Information
On Monday, January 22, 2007, or sooner, the lead inspector will distribute information
provided by the licensee, for the 30 components selected by the SRA and the lead
inspector.  The majority of the information will be provided electronically.  This
inspector.  The majority of the information will be provided electronically.  This
information will be reviewed by the team members in order to reduce the selected items
information will be reviewed by the team members in order to reduce the selected items
to about 15-20 high risk/low margin (HR/LM) components and to divide up the
to about 15-20 high risk/low margin (HR/LM) components and to divide up the
components to be reviewed by the team during the onsite inspection weeks.  In addition,
components to be reviewed by the team during the onsite inspection weeks.  In addition,
other items required by the procedure will be selected.IVTeam Preparation ActivitiesIn-office Prep Week to select final 15-20 components and other items based on highrisk significance and the least available margin.  (January 22-26, 2007)We will have a team meeting on Monday, January 22
other items required by the procedure will be selected.
nd, at 2:00 pm to discuss inspectionlogistics and plan.  Team members will use this preparation week to review the design
IV
Team Preparation Activities
In-office Prep Week to select final 15-20 components and other items based on high
risk significance and the least available margin.  (January 22-26, 2007)
We will have a team meeting on Monday, January 22nd, at 2:00 pm to discuss inspection
logistics and plan.  Team members will use this preparation week to review the design
related material the licensee provided for the 30 selected components to determine low
related material the licensee provided for the 30 selected components to determine low
margin components and to narrow the selection to the final 15-20 HR/LM components to
margin components and to narrow the selection to the final 15-20 HR/LM components to
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and other inspection items.  In addition, the lead inspector will combine the list of
and other inspection items.  In addition, the lead inspector will combine the list of
additional team member requested information to be submitted to the licensee so that
additional team member requested information to be submitted to the licensee so that
the information will be ready for review during the first onsite inspection week. The inspectors should review the latest revised inspection procedure to familiarizethemselves with the process for selection of components, operator actions, and
the information will be ready for review during the first onsite inspection week.  
The inspectors should review the latest revised inspection procedure to familiarize
themselves with the process for selection of components, operator actions, and
operating experience; and conduct of the inspection. Latest completed CDBI inspection
operating experience; and conduct of the inspection. Latest completed CDBI inspection
reports, should be reviewed.  In particular, review the following RIII issued CDBIinspection reports: Quad Cities 254/265/2006003(DRS) and Duane Arnold IR #331/2006007(DRS) (Follow latest report format to write your input; including the list ofdocuments).  Also, please review the Kewaunee CDBI pilot IR #305/2005002(DRS) forattributes and components inspected and be mind full of what was looked at during the
reports, should be reviewed.  In particular, review the following RIII issued CDBI
inspection reports: Quad Cities 254/265/2006003(DRS) and Duane Arnold IR #
331/2006007(DRS) (Follow latest report format to write your input; including the list of
documents).  Also, please review the Kewaunee CDBI pilot IR #305/2005002(DRS) for
attributes and components inspected and be mind full of what was looked at during the
pilot inspection to ensure that we do not review the same attributes/documents during
pilot inspection to ensure that we do not review the same attributes/documents during
this inspection, as much as possible.  Also, the inspection procedure and  the Matrix
this inspection, as much as possible.  Also, the inspection procedure and  the Matrix
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attributes and considerations that can be used in support of the inspection to verify
attributes and considerations that can be used in support of the inspection to verify
certain system or component attributes.  Since most of the material may be electronic,
certain system or component attributes.  Since most of the material may be electronic,
inspectors should bring a laptop computer to the site for their use in preparation for the  
inspectors should bring a laptop computer to the site for their use in preparation for the
-4-inspection.  Also, if possible, bring a memory stick for efficient information transfer offindings and exit notes between team members and the lead inspector.A component inspection Matrix will be developed to identify component attributes to beinspected and team member assignments. Component SelectionThe sample selection of 15-20 components should be based on risk significance and theleast available margin.  The team will initially select more than the minimum required to
 
-4-
inspection.  Also, if possible, bring a memory stick for efficient information transfer of
findings and exit notes between team members and the lead inspector.
A component inspection Matrix will be developed to identify component attributes to be
inspected and team member assignments.  
Component Selection
The sample selection of 15-20 components should be based on risk significance and the
least available margin.  The team will initially select more than the minimum required to
ensure the minimum number of samples are met.  If it is determined that either the team
ensure the minimum number of samples are met.  If it is determined that either the team
does not have the time or resources to complete all of the selected components, they
does not have the time or resources to complete all of the selected components, they
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component margin, analytical (design) margin, operations margin, maintenance margin
component margin, analytical (design) margin, operations margin, maintenance margin
and complexity margin.  Margin includes, corrective action insights, maintenance
and complexity margin.  Margin includes, corrective action insights, maintenance
history, design changes, complex design schemes, and maintenance rule insights. Low margin can be a function of the original design, caused by design modifications,power uprates, or can be due to degraded material conditions.  Inspection samples
history, design changes, complex design schemes, and maintenance rule insights.  
Low margin can be a function of the original design, caused by design modifications,
power uprates, or can be due to degraded material conditions.  Inspection samples
(safety or non-safety risk significant components) should be identified at the major
(safety or non-safety risk significant components) should be identified at the major
component (e.g. pump, motor operated valve, batteries, etc.) or procedural step level to
component (e.g. pump, motor operated valve, batteries, etc.) or procedural step level to
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etc, in same system, if possible), which will limit the amount of preparation time required
etc, in same system, if possible), which will limit the amount of preparation time required
to understand design and system requirements necessary to conduct a successful
to understand design and system requirements necessary to conduct a successful
inspection.In order to identify low margin areas, the inspectors should review detailed calculationsassociated with the identified risk-significant components to identify areas of low margin.  
inspection.
In order to identify low margin areas, the inspectors should review detailed calculations
associated with the identified risk-significant components to identify areas of low margin.  
In this case, the inspector should identify calculations showing little margin between
In this case, the inspector should identify calculations showing little margin between
predicted results and calculation and/or regulatory acceptance criteria. In addition, the margin review should include corrective action program insights andrepetitive maintenance summaries associated with the identified risk-significant
predicted results and calculation and/or regulatory acceptance criteria.  
In addition, the margin review should include corrective action program insights and
repetitive maintenance summaries associated with the identified risk-significant
components as poor performing components may be indicative of inadequate design.  
components as poor performing components may be indicative of inadequate design.  
Component review should also include evaluation of the impact of plant modifications or
Component review should also include evaluation of the impact of plant modifications or
licensing basis changes on available margin.  In particular, licensing changes that canreduce safety analysis margins, such as extended power uprates, should be considered.  
licensing basis changes on available margin.  In particular, licensing changes that can
-5-The SRA and SRI will participate and provide information to be used for selecting thesamples for review.Operator Action SelectionThe operations inspector should review the list of risk significant operator actionsprovided by the licensee, and with insights provided by the SRA the resident inspector,
reduce safety analysis margins, such as extended power uprates, should be considered.
 
-5-
The SRA and SRI will participate and provide information to be used for selecting the
samples for review.
Operator Action Selection
The operations inspector should review the list of risk significant operator actions
provided by the licensee, and with insights provided by the SRA the resident inspector,
and the team leader select 3-5 for review during the inspection.  A review of operating
and the team leader select 3-5 for review during the inspection.  A review of operating
procedures, and operator task analysis validation studies should be performed to
procedures, and operator task analysis validation studies should be performed to
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available to complete an action.  Based on the operator actions selected, the inspector
available to complete an action.  Based on the operator actions selected, the inspector
should request from the licensee the procedures necessary to conduct the operations.   
should request from the licensee the procedures necessary to conduct the operations.   
Select high risk operator actions that have no job performance measure (JPM). Operating Experience SelectionBased on the components selected, the regional inspectors will review the list ofoperating experience provided by the licensee and identify selected operating
Select high risk operator actions that have no job performance measure (JPM).  
Operating Experience Selection
Based on the components selected, the regional inspectors will review the list of
operating experience provided by the licensee and identify selected operating
experience issues, either component specific, common cause, or generic issues that the
experience issues, either component specific, common cause, or generic issues that the
team may want to evaluate.  Other operating experience that the inspectors are aware
team may want to evaluate.  Other operating experience that the inspectors are aware
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should cover initiating events and barrier integrity cornerstones.  Based on those issues
should cover initiating events and barrier integrity cornerstones.  Based on those issues
identified, the team will narrow down the samples to 4-6, which will be divided between
identified, the team will narrow down the samples to 4-6, which will be divided between
team members, as appropriate. Additional Prep ActivitiesOnce it is determined which components, operator actions, and operating experiencesamples will be reviewed, they will be assigned to individual inspectors.  Once this
team members, as appropriate.  
Additional Prep Activities
Once it is determined which components, operator actions, and operating experience
samples will be reviewed, they will be assigned to individual inspectors.  Once this
designation has been accomplished, the inspectors should obtain sufficient familiarity
designation has been accomplished, the inspectors should obtain sufficient familiarity
with the chosen components, operator actions, and operating experience samples and
with the chosen components, operator actions, and operating experience samples and
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inspectors review should also identify potential areas where the interface between
inspectors review should also identify potential areas where the interface between
engineering and operations procedures can be reviewed by the operations inspector to
engineering and operations procedures can be reviewed by the operations inspector to
ensure design requirements are adequately implemented into procedures.The inspectors should review the list of modifications performed on their assignedcomponents to determine whether any are either complex, reduced margin, required for
ensure design requirements are adequately implemented into procedures.
The inspectors should review the list of modifications performed on their assigned
components to determine whether any are either complex, reduced margin, required for
power uprate, etc., such that the modification should be considered for review during the
power uprate, etc., such that the modification should be considered for review during the
inspection.  Although the inspection procedure does not identify a specific number of  
inspection.  Although the inspection procedure does not identify a specific number of
-6-modifications that need to be reviewed, the team will select approximately 4-6modifications for review (one per inspector).  These modifications will be selected by the
 
-6-
modifications that need to be reviewed, the team will select approximately 4-6
modifications for review (one per inspector).  These modifications will be selected by the
team from those identified by individual team members.  Note that a modification/50.59
team from those identified by individual team members.  Note that a modification/50.59
inspection was performed by the NRC in November 2006 which looked at modifications
inspection was performed by the NRC in November 2006 which looked at modifications
completed in the last 2 years.  Make sure we do not select the same modifications for
completed in the last 2 years.  Make sure we do not select the same modifications for
review during this inspection.Requests for Additional InformationDuring the course of the inspection, team members should request their licenseecontact to provide any specific information and/or documents they want to have readily
review during this inspection.
Requests for Additional Information
During the course of the inspection, team members should request their licensee
contact to provide any specific information and/or documents they want to have readily
available when they return to the site.  This might include any specific modification
available when they return to the site.  This might include any specific modification
packages, calculations, drawings, condition reports, procedures, and scheduling
packages, calculations, drawings, condition reports, procedures, and scheduling
interviews or walkdowns, etc.  Licensee computers may be available in the conference
interviews or walkdowns, etc.  Licensee computers may be available in the conference
room with access to mainly calculations, condition reports and procedures.VOnsite Inspection ActivitiesPlant WalkdownsThe inspectors are expected to walkdown their assigned components and theirassociated systems by discipline groups (electrical, mechanical, operations).  The intent
room with access to mainly calculations, condition reports and procedures.
V
Onsite Inspection Activities
Plant Walkdowns
The inspectors are expected to walkdown their assigned components and their
associated systems by discipline groups (electrical, mechanical, operations).  The intent
of the component/system walkdowns is for the inspectors to obtain basic familiarity with
of the component/system walkdowns is for the inspectors to obtain basic familiarity with
the systems, material condition of equipment, where components are located, etc. in
the systems, material condition of equipment, where components are located, etc. in
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also asked to be aware of general plant material conditions.  Any abnormal or
also asked to be aware of general plant material conditions.  Any abnormal or
questionable conditions should be brought to the lead inspector to discuss with the
questionable conditions should be brought to the lead inspector to discuss with the
resident staff and the licensee.InspectionSuccessful completion of the CDBI inspection procedure requires a full understanding ofhow the components and their associated system operates, and is supposed to operate.  
resident staff and the licensee.
Inspection
Successful completion of the CDBI inspection procedure requires a full understanding of
how the components and their associated system operates, and is supposed to operate.  
Inspection of some broad-based attributes, such as those described in the inspection
Inspection of some broad-based attributes, such as those described in the inspection
procedure, cannot be accomplished by a single inspector working independently of the
procedure, cannot be accomplished by a single inspector working independently of the
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inspector to review the degraded voltage calculation.  The team lead will facilitate these
inspector to review the degraded voltage calculation.  The team lead will facilitate these
types of reviews and will attempt to assign them at the start of the inspection to equalize
types of reviews and will attempt to assign them at the start of the inspection to equalize
the work load between inspectors.Inspectors should plan their workload so that all major areas are preliminarily reviewedprior to the end of the first two onsite weeks of the inspection.  Most of the last onsite
the work load between inspectors.
Inspectors should plan their workload so that all major areas are preliminarily reviewed
prior to the end of the first two onsite weeks of the inspection.  Most of the last onsite
week should primarily be spent reviewing responses to questions previously asked,
week should primarily be spent reviewing responses to questions previously asked,
resolving issues, and developing any findings.  This does not mean that new inspection
resolving issues, and developing any findings.  This does not mean that new inspection
can't be done; just that doing so leaves little time to develop issues before the end of the
can't be done; just that doing so leaves little time to develop issues before the end of the
inspection.  
inspection.
-7-Inspection Objectives (IP 71111.21, Sections 02.02a thru e)For the inspection attributes and inspection activities identified during the prep week,conduct a detailed design review of the selected components' calculations,
 
-7-
Inspection Objectives (IP 71111.21, Sections 02.02a thru e)
For the inspection attributes and inspection activities identified during the prep week,
conduct a detailed design review of the selected components calculations,
surveillances, and other associated system documentation to confirm each of the
surveillances, and other associated system documentation to confirm each of the
specified attributes for your assigned areas (02.02a).  Perform plant walkdowns of
specified attributes for your assigned areas (02.02a).  Perform plant walkdowns of
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(02.02c).  Review permanent plant modifications to ensure design bases, licensing
(02.02c).  Review permanent plant modifications to ensure design bases, licensing
bases, and performance capability have not been degraded (02.02d).  Review the
bases, and performance capability have not been degraded (02.02d).  Review the
licensee's evaluation and disposition of selected operating experience to ensure it has
licensees evaluation and disposition of selected operating experience to ensure it has
been adequately addressed (02.02e). Identification and Resolution of ProblemsIdentifying Design Issues - threshold and corrective action program.Sample of Problems - verify appropriateness of corrective actions.In-office InspectionInspectors should be aware of the direct inspection hour limits for this inspection.  Thenumber of hours used during the in-office weeks should be carefully monitored as to not
been adequately addressed (02.02e).  
Identification and Resolution of Problems
Identifying Design Issues - threshold and corrective action program.
Sample of Problems - verify appropriateness of corrective actions.
In-office Inspection
Inspectors should be aware of the direct inspection hour limits for this inspection.  The
number of hours used during the in-office weeks should be carefully monitored as to not
exceed the total hours allotted for this inspection.  The lead inspector will track both the
exceed the total hours allotted for this inspection.  The lead inspector will track both the
preparation and direct inspection hours used for each inspector, including contractors.  
preparation and direct inspection hours used for each inspector, including contractors.  
This information should be provided to the lead inspector every Monday, on a weekly
This information should be provided to the lead inspector every Monday, on a weekly
basis, via e-mail. If significant issues arise that require use of more hours, the lead
basis, via e-mail. If significant issues arise that require use of more hours, the lead
inspector and branch chief should be informed prior to expending the resources. VIIssues and FindingsAny issues arising from the inspection are to be preliminarily evaluated using MC 0612,MC 0609 and the Kewaunee specific Phase 2 worksheets prior to more than 4 hours
inspector and branch chief should be informed prior to expending the resources.  
VI
Issues and Findings
Any issues arising from the inspection are to be preliminarily evaluated using MC 0612,
MC 0609 and the Kewaunee specific Phase 2 worksheets prior to more than 4 hours
inspection time being spent on them.  The lead inspector will have copies of the
inspection time being spent on them.  The lead inspector will have copies of the
worksheets available on site.  Doing a preliminary evaluation will ensure that inspection
worksheets available on site.  Doing a preliminary evaluation will ensure that inspection
effort is focused on risk significant activities and will provide direction for areas needing
effort is focused on risk significant activities and will provide direction for areas needing
exploration in order to confirm a finding.Unless an issue can be shown to be greater than minor, additional inspection time (overthe 4 hours) should not be spent.  If an issue appears greater than minor, then sufficient
exploration in order to confirm a finding.
Unless an issue can be shown to be greater than minor, additional inspection time (over
the 4 hours) should not be spent.  If an issue appears greater than minor, then sufficient
questions need to be asked of the licensee to enable the inspectors to confirm any
questions need to be asked of the licensee to enable the inspectors to confirm any
assumptions and complete the Phase 1 and 2 worksheets.  Green findings will be
assumptions and complete the Phase 1 and 2 worksheets.  Green findings will be
documented in the inspection report.  Findings that appear to be "other than green" or a
documented in the inspection report.  Findings that appear to be "other than green" or a
potential operability issue shall be immediately brought to the lead inspector's attention
potential operability issue shall be immediately brought to the lead inspector's attention
so that it can be discussed with the licensee and the senior reactor analyst.  If a color  
so that it can be discussed with the licensee and the senior reactor analyst.  If a color
-8-cannot be determined by the end of the inspection, the issue will be described as an"unresolved item," pending final determination of the appropriate risk significance.  
 
Enforcement action will be handled in accordance with the Enforcement Policy.VIIDocumentationInspection QuestionsDetailed design inspections normally result in a number of questions being raised. These questions are to be given to the licensee verbally - or, if written, the licensee
-8-
cannot be determined by the end of the inspection, the issue will be described as an
"unresolved item," pending final determination of the appropriate risk significance.  
Enforcement action will be handled in accordance with the Enforcement Policy.
VII
Documentation
Inspection Questions
Detailed design inspections normally result in a number of questions being raised.  
These questions are to be given to the licensee verbally or, if written, the licensee
must copy the information and the inspector must retain the written document.  No
must copy the information and the inspector must retain the written document.  No
written information is to be provided to the licensee.Questions should not be "stored up" to the end of the day, but given to the licenseereasonably soon after being generated.  As part of the daily interfaces with the licensee,
written information is to be provided to the licensee.
Questions should not be "stored up" to the end of the day, but given to the licensee
reasonably soon after being generated.  As part of the daily interfaces with the licensee,
the lead inspector will go over the status of outstanding questions.  Therefore, the team
the lead inspector will go over the status of outstanding questions.  Therefore, the team
members need to keep the lead inspector apprized of any concerns regarding the
members need to keep the lead inspector apprized of any concerns regarding the
timeliness or quality of responses to questions.Lack of response to questions will not be accepted as a reason for any delay inproviding an input unless the licensee did not respond in a reasonable time frame
timeliness or quality of responses to questions.
Lack of response to questions will not be accepted as a reason for any delay in
providing an input unless the licensee did not respond in a reasonable time frame
(usually 24 hours), the lead inspector has been informed of the delay and has discussed
(usually 24 hours), the lead inspector has been informed of the delay and has discussed
it with the licensee prior to the exit, and the issue is one that has been determined to bepotentially "greater than minor."  Any document requests generated on the day of the
it with the licensee prior to the exit, and the issue is one that has been determined to be
potentially "greater than minor."  Any document requests generated on the day of the
debrief or afterwards must be approved by the lead inspector, must pertain to areas
debrief or afterwards must be approved by the lead inspector, must pertain to areas
already inspected and must be only for the purpose of finalizing a finding or ensuring an
already inspected and must be only for the purpose of finalizing a finding or ensuring an
accurate document list entry.Report PreparationThe report will be prepared in accordance with the guidance in MC 0612, MC 0620,Region III model inspection report, and regional procedure 1220.  It's recognized thatRP 1220 does not strictly apply; however, it provides the best guidance available for
accurate document list entry.
Report Preparation
The report will be prepared in accordance with the guidance in MC 0612, MC 0620,
Region III model inspection report, and regional procedure 1220.  It's recognized that
RP 1220 does not strictly apply; however, it provides the best guidance available for
formatting of the report and document lists.  Input will primarily consist of a list of the
formatting of the report and document lists.  Input will primarily consist of a list of the
documents reviewed, unless a finding meets the guidance for documentation.  Issues
documents reviewed, unless a finding meets the guidance for documentation.  Issues
Line 191: Line 349:
with the team lead and during team meetings and document it in the report input.  Inputs
with the team lead and during team meetings and document it in the report input.  Inputs
are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the
are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the
exit.In keeping with the requirements of MC 0620 (see latest revision changes), only thosedocuments which were reviewed as part of meeting an inspection attribute are to be
exit.
included.  The document list does not include procedures reviewed as part of  
In keeping with the requirements of MC 0620 (see latest revision changes), only those
-9-preparation for the inspection.  Corrective action documents generated as a result of theinspector's questions shall be called out separately from corrective action documents
documents which were reviewed as part of meeting an inspection attribute are to be
included.  The document list does not include procedures reviewed as part of
 
-9-
preparation for the inspection.  Corrective action documents generated as a result of the
inspector's questions shall be called out separately from corrective action documents
that were in the licensee's system prior to the inspection.  It is strongly recommended
that were in the licensee's system prior to the inspection.  It is strongly recommended
that inspectors keep a list of documents up-to-date to ensure that no documents are
that inspectors keep a list of documents up-to-date to ensure that no documents are
missed.XIIIHRMS InformationOverall Time ManagementThe baseline inspection hours primarily encompasses only those hours spent startingwith the first on-site inspection week and prior to the exit meeting.  Time spent during
missed.
XIII
HRMS Information
Overall Time Management
The baseline inspection hours primarily encompasses only those hours spent starting
with the first on-site inspection week and prior to the exit meeting.  Time spent during
the three in-office preparation weeks are to be charged to prep.  They do not include
the three in-office preparation weeks are to be charged to prep.  They do not include
time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-
time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-
mail, or keeping track of hours to correctly credit them.  However, they do include time
mail, or keeping track of hours to correctly credit them.  However, they do include time
spent in team meetings and in preparing for team meetings.  Between 10 to 15% of the
spent in team meetings and in preparing for team meetings.  Between 10 to 15% of the
baseline hours are to be spent in evaluating problem identification and resolution efforts.Baseline Inspection (BI) ChargesThe hours given for the this procedure is as follows:ProcedureNominalMinimumMaximum71111.21347408470As a result, each inspector should be able to charge approximately 102 hours over the3-week inspection period (4 x 102 = 408 +/- 15%).  Contractors are allotted
baseline hours are to be spent in evaluating problem identification and resolution efforts.
approximately 272 hours of direct inspection effort (136 each).Preparation ChargesThe lead inspector has estimated that each inspector should charge approximately 60hours (60 X 4 = 240) to BIP for this inspection over the three weeks preparation period.  
Baseline Inspection (BI) Charges
The hours given for the this procedure is as follows:
Procedure
Nominal
Minimum
Maximum
71111.21
347
408
470
As a result, each inspector should be able to charge approximately 102 hours over the
3-week inspection period (4 x 102 = 408 +/- 15%).  Contractors are allotted
approximately 272 hours of direct inspection effort (136 each).
Preparation Charges
The lead inspector has estimated that each inspector should charge approximately 60
hours (60 X 4 = 240) to BIP for this inspection over the three weeks preparation period.  
If an inspector is unable to prepare due to other work demands, please discuss this with
If an inspector is unable to prepare due to other work demands, please discuss this with
the lead inspector (who will then work with management to ensure proper inspection
the lead inspector (who will then work with management to ensure proper inspection
preparation occurs.) Documentation ChargesDuring the inspection, any time spent documenting items which have been reviewed isto be charged to BID.  Also, the time spent on the exit meeting is to be charged to BID.  
preparation occurs.)  
Documentation Charges
During the inspection, any time spent documenting items which have been reviewed is
to be charged to BID.  Also, the time spent on the exit meeting is to be charged to BID.  
If the inspector has no findings, documentation time should be about 6-8 hours.  
If the inspector has no findings, documentation time should be about 6-8 hours.  
Documentation of findings should take about 20 hours, or more, depending on their
Documentation of findings should take about 20 hours, or more, depending on their
complexity.  Please note that this does not change the time period over which the input
complexity.  Please note that this does not change the time period over which the input
is due: It still will be five working days following the exit.  
is due: It still will be five working days following the exit.
-10-Checking E-mail and Other Such ActivitiesFor planning purposes, the lead inspector has assumed that each inspector will spend amaximum of 2 hours during each on-site week of the inspection, maximum of 6 hours,
 
-10-
Checking E-mail and Other Such Activities
For planning purposes, the lead inspector has assumed that each inspector will spend a
maximum of 2 hours during each on-site week of the inspection, maximum of 6 hours,
checking e-mail, HRMS, or doing other activities not directly related to the inspection.  
checking e-mail, HRMS, or doing other activities not directly related to the inspection.  
This time, if used, should be charged to general administration. Travel ChargesAll travel time is to be charged in HRMS to an IPE code of "AT", including travel duringnon-regular hours (see below).  For planning purposes, a total of approximately 21
This time, if used, should be charged to general administration.  
Travel Charges
All travel time is to be charged in HRMS to an IPE code of "AT", including travel during
non-regular hours (see below).  For planning purposes, a total of approximately 21
hours is allotted to each inspector for travel to site and back during this inspection (7 per
hours is allotted to each inspector for travel to site and back during this inspection (7 per
week).OvertimeOvertime for each regional inspector should be minimal and normally not to exceed 4hours per onsite week.  The overtime is to only be requested and used to meet the
week).
Overtime
Overtime for each regional inspector should be minimal and normally not to exceed 4
hours per onsite week.  The overtime is to only be requested and used to meet the
inspection requirements or if an issue comes up at the end of the day that requires
inspection requirements or if an issue comes up at the end of the day that requires
prompt resolution.  Inspectors need to inform the team leader if overtime will be used.  
prompt resolution.  Inspectors need to inform the team leader if overtime will be used.  
Overtime must be claimed in HRMS if used.  Any overtime spent traveling (although
Overtime must be claimed in HRMS if used.  Any overtime spent traveling (although
there shouldn't be any) also must be claimed in HRMS using the overtime code of
there shouldn't be any) also must be claimed in HRMS using the overtime code of
"CPETV".IXInterface and Coordination MeetingsEntrance Meeting
"CPETV".
:The team will conduct the entrance meeting on Monday, January 30, 2007, tentativelyscheduled for 9:00 a.m. Team members are expected to arrive onsite to attend the
IX
entrance meeting.  A field walkdown will be conducted after the team entrance meeting.Licensee DebriefingsDaily debriefings with the licensee will start Tuesday, January 30
Interface and Coordination Meetings
th at approx. 9:30 am. These daily meetings will normally be between the lead inspector and the licensee, with
Entrance Meeting:
team member attendance only on an as-needed basis. Routine InteractionsThroughout the inspection, team members are expected to have routine interactionswith licensee employees.  It is expected that these interactions will be professional in
The team will conduct the entrance meeting on Monday, January 30, 2007, tentatively
scheduled for 9:00 a.m. Team members are expected to arrive onsite to attend the
entrance meeting.  A field walkdown will be conducted after the team entrance meeting.
Licensee Debriefings
Daily debriefings with the licensee will start Tuesday, January 30th at approx. 9:30 am.  
These daily meetings will normally be between the lead inspector and the licensee, with
team member attendance only on an as-needed basis.  
Routine Interactions
Throughout the inspection, team members are expected to have routine interactions
with licensee employees.  It is expected that these interactions will be professional in
nature and will normally be conducted without the lead inspector present.  Inspectors
nature and will normally be conducted without the lead inspector present.  Inspectors
should keep track of any questions or requests for further information arising from these
should keep track of any questions or requests for further information arising from these
meetings.
meetings.  
-11-Team Meetings at RIII OfficeTeam meetings during the in-office prep week will be held on Monday, January 22
 
nd, at2:00 p.m. and on Thursday, January 25
-11-
th, at 10:00 am.  The intent of these meetings isto discuss the selection of components, operator actions, and operating experience that
Team Meetings at RIII Office
Team meetings during the in-office prep week will be held on Monday, January 22nd, at
2:00 p.m. and on Thursday, January 25th, at 10:00 am.  The intent of these meetings is
to discuss the selection of components, operator actions, and operating experience that
will be reviewed during the inspection, the following week.  Final selection of
will be reviewed during the inspection, the following week.  Final selection of
components, operator actions, operating experience, and modifications should occur
components, operator actions, operating experience, and modifications should occur
during this in-office prep week.  Team meetings will also be held during the last two in-office weeks on Tuesdays at10:00 a.m. in the DRS conference room.  Contractors will be tied into the meeting via
during this in-office prep week.   
teleconference, as appropriate due to inspection hour considerations.Team Meetings OnsiteTeam meetings during the onsite inspection weeks will be held starting Tuesday,January 30
Team meetings will also be held during the last two in-office weeks on Tuesdays at
th, at 3:00 p.m.  The meetings should last approximately 45 minutes.  Theintent is to allow each inspector, including the lead inspector, to briefly discuss the day's
10:00 a.m. in the DRS conference room.  Contractors will be tied into the meeting via
teleconference, as appropriate due to inspection hour considerations.
Team Meetings Onsite
Team meetings during the onsite inspection weeks will be held starting Tuesday,
January 30th, at 3:00 p.m.  The meetings should last approximately 45 minutes.  The
intent is to allow each inspector, including the lead inspector, to briefly discuss the day's
activities/issues, status of inspection activities, and any administrative or logistics items.  
activities/issues, status of inspection activities, and any administrative or logistics items.  
  An extensive team meeting will be held on Wednesday , February 28
   
th to discuss theteam's findings and determine what issues will be presented at the exit.  This meeting
An extensive team meeting will be held on Wednesday , February 28th to discuss the
will probably begin at 2:00 p.m. and will probably run longer than normal team meetings.Final De-briefThe final de-brief with the licensee will be held on Thursday, March 1
team's findings and determine what issues will be presented at the exit.  This meeting
st around 2:00 p.m. Inspectors should be ready to discuss in detail the areas they inspected, observations,
will probably begin at 2:00 p.m. and will probably run longer than normal team meetings.
and any potential violations/findings.Exit MeetingThe team will conduct the exit meeting on Friday, March 2
Final De-brief
nd tentatively scheduled for9:00 a.m.  Team members are expected to attend the final exit meeting and to be
The final de-brief with the licensee will be held on Thursday, March 1st around 2:00 p.m.  
prepared to present any of their findings to the licensee.XLogisticsTravelKewaunee is approximately 220 miles from the RIII office.  The lead inspector hasallotted approximately 4.0 hours of driving travel time each way. There is no need for
Inspectors should be ready to discuss in detail the areas they inspected, observations,
and any potential violations/findings.
Exit Meeting
The team will conduct the exit meeting on Friday, March 2nd tentatively scheduled for
9:00 a.m.  Team members are expected to attend the final exit meeting and to be
prepared to present any of their findings to the licensee.
X
Logistics
Travel
Kewaunee is approximately 220 miles from the RIII office.  The lead inspector has
allotted approximately 4.0 hours of driving travel time each way. There is no need for
Sunday travel.  Additionally, the lead inspector requests that everyone use good
Sunday travel.  Additionally, the lead inspector requests that everyone use good
judgement in all travel arrangements.  If severe weather conditions arise, it is expected
judgement in all travel arrangements.  If severe weather conditions arise, it is expected
that inspectors will take sensible precautions during traveling.The following hotel is in the area around Kewaunee.  Per diem is (60/39/99).  
that inspectors will take sensible precautions during traveling.
-12-HotelTelephoneCountry Inn Suites, Green Bay, WI (Phone # 920-336-6600)Residence Inn, Green Bay, WI  (Phone # 920-435-2222)Inspection LocationThe inspection team will be located in room ATF-107 (1
The following hotel is in the area around Kewaunee.  Per diem is (60/39/99).
st week) and AdministrationAssembly Room (2
 
nd and 3 rd weeks) rooms are inside the protected area. The telephoneextension in ATF-107 is Later and in the AAR is Later.Hours of WorkInspectors are expected to generally adhere to their normal working hours, as much aspossible.  Significant changes should be coordinated with the lead inspector but will be
-12-
Hotel
Telephone
Country Inn Suites, Green Bay, WI (Phone # 920-336-6600)
Residence Inn, Green Bay, WI  (Phone # 920-435-2222)
Inspection Location
The inspection team will be located in room ATF-107 (1st week) and Administration
Assembly Room (2nd and 3rd weeks) rooms are inside the protected area. The telephone
extension in ATF-107 is Later and in the AAR is Later.
Hours of Work
Inspectors are expected to generally adhere to their normal working hours, as much as
possible.  Significant changes should be coordinated with the lead inspector but will be
accommodated if possible.  However, compressed days off should be changed to a non-
accommodated if possible.  However, compressed days off should be changed to a non-
onsite week.  Inspectors desiring to work overtime on their compressed days off need to
onsite week.  Inspectors desiring to work overtime on their compressed days off need to
individually coordinate this with their branch chief prior to the inspection. Work at HomeIt is acceptable to the lead inspector for inspectors to have work-at-home for the in-between week, the documentation week, and for parts of the prep weeks.  Team
individually coordinate this with their branch chief prior to the inspection.  
Work at Home
It is acceptable to the lead inspector for inspectors to have work-at-home for the in-
between week, the documentation week, and for parts of the prep weeks.  Team
meetings will occur during these weeks and it is expected that inspectors working at
meetings will occur during these weeks and it is expected that inspectors working at
home will be available via teleconference for these meetings.  If you desire to do work-
home will be available via teleconference for these meetings.  If you desire to do work-
at-home, please note that work-at-home must be approved by the appropriate branch
at-home, please note that work-at-home must be approved by the appropriate branch
chief.  
chief.
Attachment ADESIGN REVIEW QUESTIONS-13-During the design review, inspectors should consider the following questions:Valves1.Are the permissive interlocks appropriate?2.Will the valve function at the pressures that will exist during transient/accidentconditions?3.Will the control and indication power supply be adequate for system function?
 
4.Is the control logic consistent with the system functional requirements?
Attachment A
5.What manual actions are required to back up and/or correct a degraded function?Pumps1.Is the pump capable of supplying required flow at required pressures undertransient/accident conditions?2.Is adequate net positive suction head (NPSH) available under all operating conditions?
DESIGN REVIEW QUESTIONS
3.Is the permissive interlock and control logic appropriate for the system function?
-13-
4.Is the pump control adequately designed for automatic operation?
During the design review, inspectors should consider the following questions:
5.When manual actions are required, do the operating procedures appropriately describenecessary operator actions?6.What manual actions are required to back up and /or correct a degraded function?
Valves
7.Has the motive power required for the pump during transient/accident conditions beencorrectly estimated and included in the normal and emergency power supplies?8.Do vendor data and specifications support sustaining operations at low flow rates?
1.
9.Is the design and quality of bearing and seal cooling systems acceptable?Instrumentation1.Are the required plant parameters used as inputs to the initiation and control system?2.If operator intervention is required in certain scenarios, have appropriate alarms andindications been provided?3.Are the range, accuracy, and setpoint of instrumentation adequate?
Are the permissive interlocks appropriate?
4.Are the specified surveillance and calibrations of such instrumentation acceptable?Circuit Breakers and Fuses1.Is the breaker control logic adequate to fulfill the functional requirements?2.Is the short circuit rating in accordance with the short circuit duty?
2.
3.Are the breakers and fuses properly rated for the load current capability?
Will the valve function at the pressures that will exist during transient/accident
4.Are breakers and fuses properly rated for DC operation?
conditions?
Cables1.Are cables rated to handle full load at the environments temperature expected?2.Are cables properly rated for short circuit capability?  
3.
Attachment ADESIGN REVIEW QUESTIONS-14-3.Are cables properly rated for voltage requirements for the loads?Electrical Loads1.Have electrical loads been analyzed to function properly under the expected lowest andhighest voltage conditions?2.Have loads been analyzed for their inrush and full load currents?
Will the control and indication power supply be adequate for system function?
3.Have loads been analyzed for their electrical protection requirements?As-built System1.Are service water flow capacities sufficient with the minimum number of pumps availableunder accident conditions?2.Have modified equipment components falling under the scope of 10CFR 50.49 beenthoroughly evaluated for environmental equipment qualifications considerations such as
4.
temperature, radiation, and humidity?3.Are the modifications to the system consistent with the original design and licensing
Is the control logic consistent with the system functional requirements?
5.
What manual actions are required to back up and/or correct a degraded function?
Pumps
1.
Is the pump capable of supplying required flow at required pressures under
transient/accident conditions?
2.
Is adequate net positive suction head (NPSH) available under all operating conditions?
3.
Is the permissive interlock and control logic appropriate for the system function?
4.
Is the pump control adequately designed for automatic operation?
5.
When manual actions are required, do the operating procedures appropriately describe
necessary operator actions?
6.
What manual actions are required to back up and /or correct a degraded function?
7.
Has the motive power required for the pump during transient/accident conditions been
correctly estimated and included in the normal and emergency power supplies?
8.
Do vendor data and specifications support sustaining operations at low flow rates?
9.
Is the design and quality of bearing and seal cooling systems acceptable?
Instrumentation
1.
Are the required plant parameters used as inputs to the initiation and control system?
2.
If operator intervention is required in certain scenarios, have appropriate alarms and
indications been provided?
3.
Are the range, accuracy, and setpoint of instrumentation adequate?
4.
Are the specified surveillance and calibrations of such instrumentation acceptable?
Circuit Breakers and Fuses
1.
Is the breaker control logic adequate to fulfill the functional requirements?
2.
Is the short circuit rating in accordance with the short circuit duty?
3.
Are the breakers and fuses properly rated for the load current capability?
4.
Are breakers and fuses properly rated for DC operation?
Cables
1.
Are cables rated to handle full load at the environments temperature expected?
2.
Are cables properly rated for short circuit capability?
 
Attachment A
DESIGN REVIEW QUESTIONS
-14-
3.
Are cables properly rated for voltage requirements for the loads?
Electrical Loads
1.
Have electrical loads been analyzed to function properly under the expected lowest and
highest voltage conditions?
2.
Have loads been analyzed for their inrush and full load currents?
3.
Have loads been analyzed for their electrical protection requirements?
As-built System
1.
Are service water flow capacities sufficient with the minimum number of pumps available
under accident conditions?
2.
Have modified equipment components falling under the scope of 10CFR 50.49 been
thoroughly evaluated for environmental equipment qualifications considerations such as
temperature, radiation, and humidity?
3.
Are the modifications to the system consistent with the original design and licensing
bases?
bases?
}}
}}

Latest revision as of 03:36, 15 January 2025

IR 05000305-07-006, Kewaunee Power, Inspection Plan
ML070310250
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 01/18/2007
From: Falevits Z, Louden P, Ann Marie Stone
Engineering Branch 3
To:
Nuclear Management Co
References
IR-07-006
Download: ML070310250 (14)


See also: IR 05000305/2007006

Text

1/22/07

COMPONENT DESIGN BASES INSPECTION (CDBI)

INSPECTION PLAN

KEWAUNEE POWER STATION

(INSPECTION REPORT NUMBER 05000305/2007006(DRS) )

Inspection Objectives

This inspection fulfills the baseline inspection program requirements for biennial Inspection

Procedure (IP) 71111.21. The inspections objective is to verify that design bases have been

correctly implemented for the selected risk significant components and that operating

procedures and operator actions are consistent with design and licensing bases. This is to

ensure that selected components are capable of performing their intended safety functions.

This inspection verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity

cornerstones for which there are no indicators to measure performance.

Inspection Dates:

January 29, 2007, through March 2, 2007

Exit:

March 2, 2007

Applicable Inspection Procedures

IP 71111.21

"Component Design Bases Inspection , dated June 22, 2006

IP 71152

Identification and Resolution of Problems (reference)

Prepared By: /RA/

01/18/2007

Lead Inspector

Date

Zelig Falevits

Approved By: /RA/

01/18/2007

DRS Branch Chief

Date

Ann Marie Stone

Reviewed By: /RA/

01/18/2007

DRP Branch Chief

Date

Pat Louden

-2-

INSPECTION PLAN DETAILS

I.

INSPECTION TEAM:

Z. Falevits, Senior Engineering Inspector, Lead, x9717, zxf

C. Brown, Senior Engineering Inspector, x9605, ceb1

R. Langstaff, Senior Engineering Inspector, x9747, ral4

A. Dahbur, Engineering Inspector, x9810, akd

S. Burgess, Senior Reactor Analyst, x9752, sdb2

M. Yeminy, Mechanical Consultant, 305-238-4732

G. Skinner, Electrical Consultant, 412-963-9889

F. Tran, Engineering Inspector, Observer, x9623, fpt

II

Detailed Inspection Schedule

Lead Inspector Preparation: January 8, 2007

Prep. at Region III Offices:

January 22-26, 2007

Inspection Onsite Weeks:

January 29 to February 2, 2007

February 12-16, 2007

February 26 to March 2, 2007

In-office Weeks:

February 5 to 9, 2007

February 19 to 23, 2007

Entrance Meeting:

January 30 at 9:00 a.m.

Exit Meeting:

March 2, at 9:00 a.m.

Preparation of Inspection Report:

Inputs Due: March 9, 2007 COB

Draft Completed: March 30, 2007

Management Review and Approval Completed (target): April 6, 2007

Inspection Report Must Be Issued Before April 16, 2007

III

Lead Inspector Preparation Activities

Review licensee material received based on information request letter, Review PRA

information with the SRAs, select 30 high risk components, and provide the team a copy

of the inspection plan.

Information Requests

-3-

As part of the inspection preparation, the lead inspector contacted the licensee,

informed them of the scope of the inspection, and requested that the necessary

information be provided to the inspection team. The information request letter was sent

to the license on November 6, 2006.

Distribution of Collected Information

On Monday, January 22, 2007, or sooner, the lead inspector will distribute information

provided by the licensee, for the 30 components selected by the SRA and the lead

inspector. The majority of the information will be provided electronically. This

information will be reviewed by the team members in order to reduce the selected items

to about 15-20 high risk/low margin (HR/LM) components and to divide up the

components to be reviewed by the team during the onsite inspection weeks. In addition,

other items required by the procedure will be selected.

IV

Team Preparation Activities

In-office Prep Week to select final 15-20 components and other items based on high

risk significance and the least available margin. (January 22-26, 2007)

We will have a team meeting on Monday, January 22nd, at 2:00 pm to discuss inspection

logistics and plan. Team members will use this preparation week to review the design

related material the licensee provided for the 30 selected components to determine low

margin components and to narrow the selection to the final 15-20 HR/LM components to

be inspected during the onsite inspection weeks. In addition, HR/LM operator actions,

operating experience, and related modifications and condition reports will be selected

during this week. The specific team assignments will be determined during this

preparation week. A second team meeting will be held on Thursday, January 25, at

10:00 am to discuss specific team assignments, final selection of (15-20) components

and other inspection items. In addition, the lead inspector will combine the list of

additional team member requested information to be submitted to the licensee so that

the information will be ready for review during the first onsite inspection week.

The inspectors should review the latest revised inspection procedure to familiarize

themselves with the process for selection of components, operator actions, and

operating experience; and conduct of the inspection. Latest completed CDBI inspection

reports, should be reviewed. In particular, review the following RIII issued CDBI

inspection reports: Quad Cities 254/265/2006003(DRS) and Duane Arnold IR #

331/2006007(DRS) (Follow latest report format to write your input; including the list of

documents). Also, please review the Kewaunee CDBI pilot IR #305/2005002(DRS) for

attributes and components inspected and be mind full of what was looked at during the

pilot inspection to ensure that we do not review the same attributes/documents during

this inspection, as much as possible. Also, the inspection procedure and the Matrix

provided by the lead inspector identifies a number of component design review

attributes and considerations that can be used in support of the inspection to verify

certain system or component attributes. Since most of the material may be electronic,

inspectors should bring a laptop computer to the site for their use in preparation for the

-4-

inspection. Also, if possible, bring a memory stick for efficient information transfer of

findings and exit notes between team members and the lead inspector.

A component inspection Matrix will be developed to identify component attributes to be

inspected and team member assignments.

Component Selection

The sample selection of 15-20 components should be based on risk significance and the

least available margin. The team will initially select more than the minimum required to

ensure the minimum number of samples are met. If it is determined that either the team

does not have the time or resources to complete all of the selected components, they

will not be included as part of the number of completed samples. Design margin is

typically defined as the difference between the actual (or predicted) and required

performance of a system, component, or operator action (see IP for more details). The

procedure states that the following attributes should be considered in evaluating

component margin, analytical (design) margin, operations margin, maintenance margin

and complexity margin. Margin includes, corrective action insights, maintenance

history, design changes, complex design schemes, and maintenance rule insights.

Low margin can be a function of the original design, caused by design modifications,

power uprates, or can be due to degraded material conditions. Inspection samples

(safety or non-safety risk significant components) should be identified at the major

component (e.g. pump, motor operated valve, batteries, etc.) or procedural step level to

assist in inspection planning. Included within the sample selected should be passive

components such as sump screens, strainers, piping, cables, etc., whose failure could

impact system functionality, component design function that involves a lot of operation

and human actions, availability/reliability issues, and components design attributes

which are not fully demonstrated through testing. To the extent practical, the sample

should include a diverse range of equipment. The team in their selection of samples

should attempt to limit the number of systems involved (i.e. select pump, valve, strainer,

etc, in same system, if possible), which will limit the amount of preparation time required

to understand design and system requirements necessary to conduct a successful

inspection.

In order to identify low margin areas, the inspectors should review detailed calculations

associated with the identified risk-significant components to identify areas of low margin.

In this case, the inspector should identify calculations showing little margin between

predicted results and calculation and/or regulatory acceptance criteria.

In addition, the margin review should include corrective action program insights and

repetitive maintenance summaries associated with the identified risk-significant

components as poor performing components may be indicative of inadequate design.

Component review should also include evaluation of the impact of plant modifications or

licensing basis changes on available margin. In particular, licensing changes that can

reduce safety analysis margins, such as extended power uprates, should be considered.

-5-

The SRA and SRI will participate and provide information to be used for selecting the

samples for review.

Operator Action Selection

The operations inspector should review the list of risk significant operator actions

provided by the licensee, and with insights provided by the SRA the resident inspector,

and the team leader select 3-5 for review during the inspection. A review of operating

procedures, and operator task analysis validation studies should be performed to

identify critical operator actions with little margin between the time required and the time

available to complete an action. Based on the operator actions selected, the inspector

should request from the licensee the procedures necessary to conduct the operations.

Select high risk operator actions that have no job performance measure (JPM).

Operating Experience Selection

Based on the components selected, the regional inspectors will review the list of

operating experience provided by the licensee and identify selected operating

experience issues, either component specific, common cause, or generic issues that the

team may want to evaluate. Other operating experience that the inspectors are aware

of that may be relevant to the components selected can also be selected for review. In

addition, the team should identify for review one or two generic or common cause issues

that are not related to the selected samples. Some of the operating experience selected

should cover initiating events and barrier integrity cornerstones. Based on those issues

identified, the team will narrow down the samples to 4-6, which will be divided between

team members, as appropriate.

Additional Prep Activities

Once it is determined which components, operator actions, and operating experience

samples will be reviewed, they will be assigned to individual inspectors. Once this

designation has been accomplished, the inspectors should obtain sufficient familiarity

with the chosen components, operator actions, and operating experience samples and

their associated systems to understand the design and safety requirement for the

samples selected and their associated system. The inspectors should also review the

flow paths (mechanical) and control logic circuitry (electrical) for the selected

components to verify if other components in those flow paths or control logic could

potentially affect their function. For each component or inspection area assigned, the

inspector needs to develop a list of attributes (see IP 71111.21, section 02.02, Appendix

1 and Appendix 2 for examples) that will be reviewed during the inspection. The

inspectors review should also identify potential areas where the interface between

engineering and operations procedures can be reviewed by the operations inspector to

ensure design requirements are adequately implemented into procedures.

The inspectors should review the list of modifications performed on their assigned

components to determine whether any are either complex, reduced margin, required for

power uprate, etc., such that the modification should be considered for review during the

inspection. Although the inspection procedure does not identify a specific number of

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modifications that need to be reviewed, the team will select approximately 4-6

modifications for review (one per inspector). These modifications will be selected by the

team from those identified by individual team members. Note that a modification/50.59

inspection was performed by the NRC in November 2006 which looked at modifications

completed in the last 2 years. Make sure we do not select the same modifications for

review during this inspection.

Requests for Additional Information

During the course of the inspection, team members should request their licensee

contact to provide any specific information and/or documents they want to have readily

available when they return to the site. This might include any specific modification

packages, calculations, drawings, condition reports, procedures, and scheduling

interviews or walkdowns, etc. Licensee computers may be available in the conference

room with access to mainly calculations, condition reports and procedures.

V

Onsite Inspection Activities

Plant Walkdowns

The inspectors are expected to walkdown their assigned components and their

associated systems by discipline groups (electrical, mechanical, operations). The intent

of the component/system walkdowns is for the inspectors to obtain basic familiarity with

the systems, material condition of equipment, where components are located, etc. in

order to accomplish inspection objectives. During the walkdowns, the inspectors are

also asked to be aware of general plant material conditions. Any abnormal or

questionable conditions should be brought to the lead inspector to discuss with the

resident staff and the licensee.

Inspection

Successful completion of the CDBI inspection procedure requires a full understanding of

how the components and their associated system operates, and is supposed to operate.

Inspection of some broad-based attributes, such as those described in the inspection

procedure, cannot be accomplished by a single inspector working independently of the

rest of the team. However, to avoid duplication of work, each individual will be assigned

primary responsibility for the attributes being inspected. For example, if a mechanical

inspector is assigned to review a motor-operated valve, they may need an electrical

inspector to review the degraded voltage calculation. The team lead will facilitate these

types of reviews and will attempt to assign them at the start of the inspection to equalize

the work load between inspectors.

Inspectors should plan their workload so that all major areas are preliminarily reviewed

prior to the end of the first two onsite weeks of the inspection. Most of the last onsite

week should primarily be spent reviewing responses to questions previously asked,

resolving issues, and developing any findings. This does not mean that new inspection

can't be done; just that doing so leaves little time to develop issues before the end of the

inspection.

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Inspection Objectives (IP 71111.21, Sections 02.02a thru e)

For the inspection attributes and inspection activities identified during the prep week,

conduct a detailed design review of the selected components calculations,

surveillances, and other associated system documentation to confirm each of the

specified attributes for your assigned areas (02.02a). Perform plant walkdowns of

selected components to verify as-built condition is consistent to design requirements

and inspect component for material condition; and review components corrective action

and maintenance history that could affect the components to function (02.02b). The

operations inspector should verify performance of risk significant operator actions, along

with a walk-through of a sample operations procedures for the selected components

(02.02c). Review permanent plant modifications to ensure design bases, licensing

bases, and performance capability have not been degraded (02.02d). Review the

licensees evaluation and disposition of selected operating experience to ensure it has

been adequately addressed (02.02e).

Identification and Resolution of Problems

Identifying Design Issues - threshold and corrective action program.

Sample of Problems - verify appropriateness of corrective actions.

In-office Inspection

Inspectors should be aware of the direct inspection hour limits for this inspection. The

number of hours used during the in-office weeks should be carefully monitored as to not

exceed the total hours allotted for this inspection. The lead inspector will track both the

preparation and direct inspection hours used for each inspector, including contractors.

This information should be provided to the lead inspector every Monday, on a weekly

basis, via e-mail. If significant issues arise that require use of more hours, the lead

inspector and branch chief should be informed prior to expending the resources.

VI

Issues and Findings

Any issues arising from the inspection are to be preliminarily evaluated using MC 0612,

MC 0609 and the Kewaunee specific Phase 2 worksheets prior to more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

inspection time being spent on them. The lead inspector will have copies of the

worksheets available on site. Doing a preliminary evaluation will ensure that inspection

effort is focused on risk significant activities and will provide direction for areas needing

exploration in order to confirm a finding.

Unless an issue can be shown to be greater than minor, additional inspection time (over

the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) should not be spent. If an issue appears greater than minor, then sufficient

questions need to be asked of the licensee to enable the inspectors to confirm any

assumptions and complete the Phase 1 and 2 worksheets. Green findings will be

documented in the inspection report. Findings that appear to be "other than green" or a

potential operability issue shall be immediately brought to the lead inspector's attention

so that it can be discussed with the licensee and the senior reactor analyst. If a color

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cannot be determined by the end of the inspection, the issue will be described as an

"unresolved item," pending final determination of the appropriate risk significance.

Enforcement action will be handled in accordance with the Enforcement Policy.

VII

Documentation

Inspection Questions

Detailed design inspections normally result in a number of questions being raised.

These questions are to be given to the licensee verbally or, if written, the licensee

must copy the information and the inspector must retain the written document. No

written information is to be provided to the licensee.

Questions should not be "stored up" to the end of the day, but given to the licensee

reasonably soon after being generated. As part of the daily interfaces with the licensee,

the lead inspector will go over the status of outstanding questions. Therefore, the team

members need to keep the lead inspector apprized of any concerns regarding the

timeliness or quality of responses to questions.

Lack of response to questions will not be accepted as a reason for any delay in

providing an input unless the licensee did not respond in a reasonable time frame

(usually 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), the lead inspector has been informed of the delay and has discussed

it with the licensee prior to the exit, and the issue is one that has been determined to be

potentially "greater than minor." Any document requests generated on the day of the

debrief or afterwards must be approved by the lead inspector, must pertain to areas

already inspected and must be only for the purpose of finalizing a finding or ensuring an

accurate document list entry.

Report Preparation

The report will be prepared in accordance with the guidance in MC 0612, MC 0620,

Region III model inspection report, and regional procedure 1220. It's recognized that

RP 1220 does not strictly apply; however, it provides the best guidance available for

formatting of the report and document lists. Input will primarily consist of a list of the

documents reviewed, unless a finding meets the guidance for documentation. Issues

which an inspector considers as meeting the criteria for inclusion in the report shall be

discussed with the lead inspector prior to preparing an input. Finding input shall consist

of both the detailed write-up for the body of the inspection report and the associated

paragraphs for the summary of finding section of the inspection report. Also, make sure

you evaluate each finding for cross cutting aspects, discuss the cross cutting aspect

with the team lead and during team meetings and document it in the report input. Inputs

are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the

exit.

In keeping with the requirements of MC 0620 (see latest revision changes), only those

documents which were reviewed as part of meeting an inspection attribute are to be

included. The document list does not include procedures reviewed as part of

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preparation for the inspection. Corrective action documents generated as a result of the

inspector's questions shall be called out separately from corrective action documents

that were in the licensee's system prior to the inspection. It is strongly recommended

that inspectors keep a list of documents up-to-date to ensure that no documents are

missed.

XIII

HRMS Information

Overall Time Management

The baseline inspection hours primarily encompasses only those hours spent starting

with the first on-site inspection week and prior to the exit meeting. Time spent during

the three in-office preparation weeks are to be charged to prep. They do not include

time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-

mail, or keeping track of hours to correctly credit them. However, they do include time

spent in team meetings and in preparing for team meetings. Between 10 to 15% of the

baseline hours are to be spent in evaluating problem identification and resolution efforts.

Baseline Inspection (BI) Charges

The hours given for the this procedure is as follows:

Procedure

Nominal

Minimum

Maximum

71111.21

347

408

470

As a result, each inspector should be able to charge approximately 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> over the

3-week inspection period (4 x 102 = 408 +/- 15%). Contractors are allotted

approximately 272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br /> of direct inspection effort (136 each).

Preparation Charges

The lead inspector has estimated that each inspector should charge approximately 60

hours (60 X 4 = 240) to BIP for this inspection over the three weeks preparation period.

If an inspector is unable to prepare due to other work demands, please discuss this with

the lead inspector (who will then work with management to ensure proper inspection

preparation occurs.)

Documentation Charges

During the inspection, any time spent documenting items which have been reviewed is

to be charged to BID. Also, the time spent on the exit meeting is to be charged to BID.

If the inspector has no findings, documentation time should be about 6-8 hours.

Documentation of findings should take about 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, or more, depending on their

complexity. Please note that this does not change the time period over which the input

is due: It still will be five working days following the exit.

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Checking E-mail and Other Such Activities

For planning purposes, the lead inspector has assumed that each inspector will spend a

maximum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> during each on-site week of the inspection, maximum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

checking e-mail, HRMS, or doing other activities not directly related to the inspection.

This time, if used, should be charged to general administration.

Travel Charges

All travel time is to be charged in HRMS to an IPE code of "AT", including travel during

non-regular hours (see below). For planning purposes, a total of approximately 21

hours is allotted to each inspector for travel to site and back during this inspection (7 per

week).

Overtime

Overtime for each regional inspector should be minimal and normally not to exceed 4

hours per onsite week. The overtime is to only be requested and used to meet the

inspection requirements or if an issue comes up at the end of the day that requires

prompt resolution. Inspectors need to inform the team leader if overtime will be used.

Overtime must be claimed in HRMS if used. Any overtime spent traveling (although

there shouldn't be any) also must be claimed in HRMS using the overtime code of

"CPETV".

IX

Interface and Coordination Meetings

Entrance Meeting:

The team will conduct the entrance meeting on Monday, January 30, 2007, tentatively

scheduled for 9:00 a.m. Team members are expected to arrive onsite to attend the

entrance meeting. A field walkdown will be conducted after the team entrance meeting.

Licensee Debriefings

Daily debriefings with the licensee will start Tuesday, January 30th at approx. 9:30 am.

These daily meetings will normally be between the lead inspector and the licensee, with

team member attendance only on an as-needed basis.

Routine Interactions

Throughout the inspection, team members are expected to have routine interactions

with licensee employees. It is expected that these interactions will be professional in

nature and will normally be conducted without the lead inspector present. Inspectors

should keep track of any questions or requests for further information arising from these

meetings.

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Team Meetings at RIII Office

Team meetings during the in-office prep week will be held on Monday, January 22nd, at

2:00 p.m. and on Thursday, January 25th, at 10:00 am. The intent of these meetings is

to discuss the selection of components, operator actions, and operating experience that

will be reviewed during the inspection, the following week. Final selection of

components, operator actions, operating experience, and modifications should occur

during this in-office prep week.

Team meetings will also be held during the last two in-office weeks on Tuesdays at

10:00 a.m. in the DRS conference room. Contractors will be tied into the meeting via

teleconference, as appropriate due to inspection hour considerations.

Team Meetings Onsite

Team meetings during the onsite inspection weeks will be held starting Tuesday,

January 30th, at 3:00 p.m. The meetings should last approximately 45 minutes. The

intent is to allow each inspector, including the lead inspector, to briefly discuss the day's

activities/issues, status of inspection activities, and any administrative or logistics items.

An extensive team meeting will be held on Wednesday , February 28th to discuss the

team's findings and determine what issues will be presented at the exit. This meeting

will probably begin at 2:00 p.m. and will probably run longer than normal team meetings.

Final De-brief

The final de-brief with the licensee will be held on Thursday, March 1st around 2:00 p.m.

Inspectors should be ready to discuss in detail the areas they inspected, observations,

and any potential violations/findings.

Exit Meeting

The team will conduct the exit meeting on Friday, March 2nd tentatively scheduled for

9:00 a.m. Team members are expected to attend the final exit meeting and to be

prepared to present any of their findings to the licensee.

X

Logistics

Travel

Kewaunee is approximately 220 miles from the RIII office. The lead inspector has

allotted approximately 4.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of driving travel time each way. There is no need for

Sunday travel. Additionally, the lead inspector requests that everyone use good

judgement in all travel arrangements. If severe weather conditions arise, it is expected

that inspectors will take sensible precautions during traveling.

The following hotel is in the area around Kewaunee. Per diem is (60/39/99).

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Hotel

Telephone

Country Inn Suites, Green Bay, WI (Phone # 920-336-6600)

Residence Inn, Green Bay, WI (Phone # 920-435-2222)

Inspection Location

The inspection team will be located in room ATF-107 (1st week) and Administration

Assembly Room (2nd and 3rd weeks) rooms are inside the protected area. The telephone

extension in ATF-107 is Later and in the AAR is Later.

Hours of Work

Inspectors are expected to generally adhere to their normal working hours, as much as

possible. Significant changes should be coordinated with the lead inspector but will be

accommodated if possible. However, compressed days off should be changed to a non-

onsite week. Inspectors desiring to work overtime on their compressed days off need to

individually coordinate this with their branch chief prior to the inspection.

Work at Home

It is acceptable to the lead inspector for inspectors to have work-at-home for the in-

between week, the documentation week, and for parts of the prep weeks. Team

meetings will occur during these weeks and it is expected that inspectors working at

home will be available via teleconference for these meetings. If you desire to do work-

at-home, please note that work-at-home must be approved by the appropriate branch

chief.

Attachment A

DESIGN REVIEW QUESTIONS

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During the design review, inspectors should consider the following questions:

Valves

1.

Are the permissive interlocks appropriate?

2.

Will the valve function at the pressures that will exist during transient/accident

conditions?

3.

Will the control and indication power supply be adequate for system function?

4.

Is the control logic consistent with the system functional requirements?

5.

What manual actions are required to back up and/or correct a degraded function?

Pumps

1.

Is the pump capable of supplying required flow at required pressures under

transient/accident conditions?

2.

Is adequate net positive suction head (NPSH) available under all operating conditions?

3.

Is the permissive interlock and control logic appropriate for the system function?

4.

Is the pump control adequately designed for automatic operation?

5.

When manual actions are required, do the operating procedures appropriately describe

necessary operator actions?

6.

What manual actions are required to back up and /or correct a degraded function?

7.

Has the motive power required for the pump during transient/accident conditions been

correctly estimated and included in the normal and emergency power supplies?

8.

Do vendor data and specifications support sustaining operations at low flow rates?

9.

Is the design and quality of bearing and seal cooling systems acceptable?

Instrumentation

1.

Are the required plant parameters used as inputs to the initiation and control system?

2.

If operator intervention is required in certain scenarios, have appropriate alarms and

indications been provided?

3.

Are the range, accuracy, and setpoint of instrumentation adequate?

4.

Are the specified surveillance and calibrations of such instrumentation acceptable?

Circuit Breakers and Fuses

1.

Is the breaker control logic adequate to fulfill the functional requirements?

2.

Is the short circuit rating in accordance with the short circuit duty?

3.

Are the breakers and fuses properly rated for the load current capability?

4.

Are breakers and fuses properly rated for DC operation?

Cables

1.

Are cables rated to handle full load at the environments temperature expected?

2.

Are cables properly rated for short circuit capability?

Attachment A

DESIGN REVIEW QUESTIONS

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3.

Are cables properly rated for voltage requirements for the loads?

Electrical Loads

1.

Have electrical loads been analyzed to function properly under the expected lowest and

highest voltage conditions?

2.

Have loads been analyzed for their inrush and full load currents?

3.

Have loads been analyzed for their electrical protection requirements?

As-built System

1.

Are service water flow capacities sufficient with the minimum number of pumps available

under accident conditions?

2.

Have modified equipment components falling under the scope of 10CFR 50.49 been

thoroughly evaluated for environmental equipment qualifications considerations such as

temperature, radiation, and humidity?

3.

Are the modifications to the system consistent with the original design and licensing

bases?