IR 05000305/2008003

IR 05000305-08-003, on 03/31/2008- 06/30/2008; Kewaunee Power Station; Adverse Weather Protection

ML082210482
Person / Time
Site:	Kewaunee
Issue date:	08/08/2008
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Christian D Dominion Energy Kewaunee
References
IR-08-003
Download: ML082210482 (79)

Text

August 08, 2008

SUBJECT:

KEWAUNEE POWER STATION NRC INTEGRATED INSPECTION REPORT 05000305/2008003

Dear Mr. Christian:

On June 30, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Kewaunee Power Station. The enclosed report documents the inspection findings, which were discussed on July 16, 2008, with Mr. S. Scace and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding involved a violation of NRC requirements. However, because of its very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating this issue as a Non-Cited Violation (NCV) in accordance with Section VI.A.1 of the NRC Enforcement Policy. Additionally, a licensee-identified violation is listed in Section 4OA7 of this report.

If you contest the subject or severity of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Kewaunee Power Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

Mr. component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael Kunowski, Chief Branch 5 Division of Reactor Projects Docket No.

50-305 License No.

DPR-43 Enclosure:

Inspection Report 05000305/2008003 w/Attachment: Supplemental Information cc w/encl:

S. Scace, Site Vice President

M. Wilson, Director, Nuclear Safety and Licensing

C. Funderburk, Director, Nuclear Licensing and

Operations Support

T. Breene, Manager, Nuclear Licensing

L. Cuoco, Senior Counsel

D. Zellner, Chairman, Town of Carlton

J. Kitsembel, Public Service Commission of Wisconsin

P. Schmidt, State Liaison Officer

M

SUMMARY OF FINDINGS

IR 05000305/2008003; 03/31/2008 - 06/30/2008; Kewaunee Power Station; Adverse Weather

Protection.

This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors.

The finding was considered an NCV of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

A finding of very low safety significance (Green) and an NCV of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors following an inspection of licensee preparations for adverse weather protection. Specifically, the licensee failed to perform inspections for hot weather operations as required by plant procedure GNP-12.06.01, "Hot and Cold Weather Operations."

The finding was greater than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 20, 2007, because if left uncorrected would become a more significant safety concern.

Specifically, the licensee failed to implement the provisions of GNP-12.06.01, "Hot and Cold Weather Operations," which resulted in a failure to ensure pre-summer readiness of numerous safety-related and risk-significant systems. The inspectors evaluated the finding using Attachment 0609.04, of IMC 0609, Significance Determination Process, dated January 10, 2008, and answered no to all of the questions in the Initiating Events column; therefore, the finding was determined to be of very low safety significance. The inspectors determined that the primary cause for this finding was related to the cross-cutting area of human performance, work practices component, because personnel have been trained in the need for procedural use and adherence, but failed to follow applicable procedures. Specifically, the procedure which required the performance of plant inspections for hot weather operations, and the maintenance of QA documentation for these inspections, was not followed H.4(b) (Section 1R01.2).

Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by inspectors. Corrective actions planned or taken by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Kewaunee was shut down during the entire month of April for a refueling outage. Following refueling, the unit was restarted on May 8, 2008, reached full power operation on May 12, and operated at full power for the remainder of the inspection period with the following exception:

• On May 27, the unit power was reduced to 70% power to repair an oil leak on a turbine valve.

1R01 Adverse Weather Protection

.1 Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate AC power systems during adverse weather were appropriate. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors review included:

• the coordination between the TSO and the plant during off-normal or emergency events;

• the explanations for the events;

• the estimates of when the offsite power system would be returned to a normal state; and

• the notifications from the TSO to the plant when the offsite power system was returned to normal.

The inspectors also verified that plant procedures addressed measures to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:

• the actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system supplying power to the plant would not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;

• the compensatory actions identified to be performed if it is not possible to predict the post-trip voltage at the plant for the current grid conditions;

• a re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and

• the communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged.

The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment.

This inspection constitutes one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings of significance were identified.

.2 Summer Seasonal Readiness Preparations

a. Inspection Scope

The inspectors performed a review of the licensees preparations for summer weather for selected systems, including conditions that could lead to an extended drought as a result of high temperatures.

During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions.

Additionally, the inspectors reviewed the Updated Safety Analysis Report (USAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures.

The inspectors reviews focused specifically on the following plant systems:

• evaluation of station adverse weather procedures for extreme weather conditions; and

• walkdown inspection of safeguards alley.

The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into its corrective action program in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment.

This inspection constitutes one seasonal adverse weather sample as defined in Inspection Procedure 71111.01-05.

b. Findings

Failure to Follow the Provisions of General Nuclear Procedure, GNP-12.06.01, "Hot and Cold Weather Operations"

Introduction:

A finding of very low safety significance and an associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for failure to perform inspections for hot weather operations as required by plant procedure GNP-12.06.01, "Hot and Cold Weather Operations."

Description:

General Nuclear Procedure, GNP-12.06.01, "Hot and Cold Weather Operations," required that the licensee perform, prior to April 1, a pre-summer inspection checklist and that this checklist be retained as a Quality Assurance Record. This procedure required the licensee to perform pre-summer readiness inspections on numerous safety-related and risk-significant systems. On May 28, 2008, during a routine baseline inspection of adverse weather protection, the inspectors requested a copy of the completed checklist and the licensee was unable to produce a copy of the completed checklist. In condition report (CR) CR100329, dated May 31, 2008, the licensee documented that the procedural requirements of GNP-12.06.01, were recorded as completed in the schedule on May 23, 2008, but that completed checklist documentation to verify this could not be located. Corrective action (CA) CA076415 dated June 3, 2008, was initiated to determine the cause and corrective actions for this issue.

The inspectors determined that the licensee failed to implement the provisions of GNP-12.06.01, "Hot and Cold Weather Operations," because the licensee failed to complete the required inspections by April 1, 2008. Additionally, the licensee was unable to provide the inspectors with Quality Assurance Record documentation for its pre-summer inspection that was recorded as completed on May 23, 2008. After the end of the inspection period, the licensee provided a completed copy of GNP-12.06.01, dated June 27, 2008.

Analysis:

The inspectors determined that the licensees failure to complete the summer readiness inspections on safety-related equipment and risk-significant systems was contrary to procedure GNP-12.06.01 and was a performance deficiency.

The finding was determined to be greater than minor because the finding, if left uncorrected, would become a more significant safety concern. Specifically, failure to perform the inspections required by the procedure may result in inoperable or degraded safety-related equipment or risk-significant systems due to hot weather. The inspectors concluded this finding was associated with the Initiating Events Cornerstone.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Initiating Events Cornerstone. Since all of the questions in this cornerstone column were answered no, the finding was determined to be of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of human performance, work practices component, because the licensee personnel have been trained on the need for procedure use and adherence but failed to follow applicable procedures. Specifically, the licensees failure to complete the summer readiness inspections on safety-related equipment and risk-significant systems was contrary to procedure GNP-12.06.01.

H.4(b)

Enforcement:

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on April 1, 2008, the licensee failed to perform the activities prescribed by a documented procedure. Specifically, the licensee failed to implement the provisions of GNP-12.06.01, "Hot and Cold Weather Operations," which resulted in a failure to ensure pre-summer readiness of numerous safety-related and risk-significant systems.

Because this violation was of very low safety significance and it was entered into the licensees corrective action program as CR 100329, and the inspections and documentation required by the procedure were completed as part of CA 076415, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000305/2008-003-01).

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• component cooling water train A;

• emergency diesel generator B;

• residual heat removal (RHR); and

• spent fuel pool cooling.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, USAR, Technical Specification (TS) requirements, outstanding work orders, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies.

The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Documents reviewed are listed in the

.

These activities constituted four partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete system alignment inspection of the emergency diesel generator A to verify the functional capability of the system. This system was selected because it was considered both safety-significant and risk-significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line-ups, electrical power availability, system pressure and temperature indications, component labeling, component lubrication, component and equipment cooling, hangers and supports, and operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders (WOs)was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program (CAP)database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment.

These activities constituted one complete system walkdown sample as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• auxiliary building mezzanine and basement;

• turbine building operations floor and mezzanine;

• auxiliary feed pump rooms and 480-volt bus rooms;

• emergency diesel generator A; and

• emergency diesel generator B.

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees corrective action program. Documents reviewed are listed in the Attachment.

These activities constituted five quarterly fire protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings of significance were identified.

1R06 Flooding

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the USAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors performed a walkdown of the following plant area(s) to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

• auxiliary building to safeguards alley watertight door (door 8); and

• Division 2 service water spray shield installed in Division 1 diesel generator room.

The inspectors also reviewed licensees corrective action documents with respect to past flood-related items to verify the adequacy of the corrective actions. Documents reviewed are listed in the Attachment.

This inspection constitutes two internal flooding samples as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings of significance were identified.

1R07 Annual Heat Sink Performance

.1 Heat Sink Performance

a. Inspection Scope

In April 2008, the inspectors reviewed the licensees testing of auxiliary building basement fan coil units and associated heat exchangers to verify that potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. Documents reviewed are listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71111.07-05.

b. Findings

Lack of Calculation to Show That the Auxiliary Building Fan Floor Fan Coil Units (FCUs) Can Perform Their Safety-Related Function at the Maximum Design Service Water Temperature

Introduction:

The inspectors identified an unresolved item (URI) due to lack of a calculation to demonstrate that the auxiliary building fan floor FCUs can perform their safety-related function at the maximum design service water temperature of 80°F (degrees Fahrenheit). Specifically, the inspectors questioned the adequacy of the licensees corrective actions in resolving this issue. This issue is unresolved pending NRC review of the results of the new calculation.

Description:

The auxiliary building floor contains two FCUs whose safety-related function is to maintain the temperature in the area at 120°F or less. This is the environment qualification temperature for the equipment that is located in this area, categorized as mild environment.

These FCUs are cooled by the service water system which has a maximum design inlet temperature of 80°F.

Last summer, the licensee commenced a reconstitution of its heating, ventilation and air conditioning calculations. During this effort, the licensee became aware that the calculation used to determine the amount of heat generated in the auxiliary building floor FCU area had several non-conservative assumptions. As an example of these non-conservatisms, the licensee assumed:

• A loss of off-site power (LOOP) during the postulated loss of coolant accident (LOCA) is the most limiting design basis accident for this case. This is a non-conservative assumption as there is additional heat loads generated from nonsafety-related components involved in a non-LOOP LOCA, such as lighting.

• That the refueling water storage tank (RWST) was full of water; therefore, some heat was exchanged with the tank during this scenario. This might not be the case since during a LOCA, the RWST would empty as the transient develops.

• That there is some leakage of hot air from the Zone SV [special ventilation]

charcoal filters to the environment. The exhaust for this hot air is on the fan floor.

The licensee assumed that some of this hot air leaked to the environment but no design basis was found for the number. The licensee performed a test and determined that the actual leakage was much less than what the calculation assumed; therefore, this is a non-conservative assumption.

Additionally, the calculation did not take into account the heat generated by the FCU pump motors.

All these non-conservatisms questioned the operability of the auxiliary building fan FCUs as well as the other equipment in the area, which is supported by the system including the shield building and special ventilation zone air handling systems.

The licensee performed an operability evaluation and included all the non-conservatisms from the previous calculation. The result of this operability evaluation was the FCUs were operable up to a service water inlet temperature of 71°F, but nonconforming with their design requirement of 80°F. Through this inspection cycle, the FCUs and supported systems have remained operable.

The licensee is currently performing a more thorough calculation.

The inspectors have the following concerns:

• The service water temperatures may rise to 71°F in approximately the June and July time frame (last year, service water inlet temperature of 77°F was recorded during July). If the licensee fails to prove operability of the FCUs by then, the plant would have to shutdown per TS 3.0.3.

• The inspectors believe that there is not enough conservatism in the design assumptions to prove operability above 71°F.

Currently, the licensee is taking the corrective actions necessary to resolve this issue.

This issue is unresolved pending NRC review of the results of the calculation (URI 05000305/2008003-02).

1R08 Inservice Inspection Activities

From March 26, 2008, through April 10, 2008, the inspectors conducted a review of the implementation of the licensees Inservice Inspection (ISI) Program for monitoring degradation of the reactor coolant system (RCS), steam generator (SG) tubes, emergency feedwater systems, risk-significant piping and components and containment systems. Documents reviewed are listed in the Attachment.

The inspections described in Sections 1R08.1, 1R08.2, 1R08.3, IR08.4 and 1R08.5 below count as one inspection sample as defined in Inspection Procedure 71111.08-05.

.1 Piping Systems ISI

a. Inspection Scope

The inspectors observed the following non-destructive examinations mandated by the American Society of Mechanical Engineers (ASME) Code,Section XI, to evaluate compliance with the ASME Code,Section XI and Section V requirements and, if any indications and defects were detected, to determine if these were dispositioned in accordance with the ASME Code or an NRC approved alternative requirement.

• Ultrasonic examination (UT) of containment spray pump 1B discharge piping to penetration 29E, (6 elbow-to-pipe weld) weld RCS-W111;

• UT of containment spray pump 1B discharge piping to penetration 29E, (6 pipe-to-pipe weld) weld RCS-W112;

• Dye penetrant examination of containment spray pump 1B discharge piping to penetration 29E, (6 elbow-to-pipe weld) weld RCS-W111; and

• Dye penetrant examination of containment spray pump 1B discharge piping to penetration 29E, (6 pipe-to-pipe weld) weld RCS-W112.

The inspectors reviewed the following examination completed since the beginning of the previous refueling outage with relevant/recordable conditions/indications accepted for continued service to determine if acceptance was in accordance with the ASME Code,Section XI, or an NRC approved alternative.

• UT of steam generator weld SG-W10 (B SG girth weld).

The inspectors reviewed the following pressure boundary weld repairs completed on risk-significant systems since the beginning of the last refueling outage to verify that the welding and any associated non-destructive examinations were performed in accordance with the Construction Code and ASME Code,Section XI. Additionally, the inspectors reviewed the welding procedure specification and supporting weld procedure qualification records to determine if the weld procedure(s) were qualified in accordance with the requirements of Construction Code and the ASME Code Section IX.

• RCS replacement valve RC-46 pipe-to-valve welds (welds 05-14596-1, 2, and 7).

• Chemical and volume control (CVC) system valve CVC-204A pipe-to-valve welds (welds 06-10400-1, 2, and 3).

b. Findings

No findings of significance were identified.

.2 Reactor Pressure Vessel Upper Head Penetration Inspection Activities

a. Inspection Scope

The licensee replaced the reactor pressure vessel upper head in 2004. No examination was required pursuant to NRC Order EA-03-009 and none was conducted during the previous or current refueling outage. Therefore, no NRC review was completed for this inspection procedure attribute.

b. Findings

No findings of significance were identified.

.3 Boric Acid Corrosion Control (BACC)

a. Inspection Scope

The inspectors observed the licensees BACC visual examinations for portions of the reactor coolant, RHR, and safety injection (SI) systems and verified whether these visual examinations emphasized locations where boric acid leaks can cause degradation of safety significant components.

The inspectors reviewed the following licensee evaluation of a RCS component with boric acid deposits to determine if degraded components were documented in the corrective action system. The inspectors also evaluated corrective actions for any degraded RCS components to determine if they met ASME Code Section XI.

• CR094046; Active Packing Leak from RC-300A.

The inspectors reviewed the following corrective actions related to evidence of boric acid leakage to determine if the corrective actions completed were consistent with the requirements of ASME Code Section XI and 10 CFR Part 50, Appendix B, Criterion XVI.

• CR013095; Dry White Boric Acid at the Body/Bonnet for RHR-10B.

• CAP028202; Dry Boric Acid Deposit on SI-303B.

b. Findings

No findings of significance were identified.

.4 Steam Generator Tube Inspection Activities

a. Inspection Scope

No examination was required pursuant to the TSs and none was conducted during the current refueling outage. Therefore, no NRC review was completed for this inspection procedure attribute.

b. Findings

No findings of significance were identified.

.5 Identification and Resolution of Problems

a. Inspection Scope

The inspectors performed a review of ISI/SG related problems entered into the licensees corrective action program and conducted interviews with licensee staff to determine if:

• the licensee had established an appropriate threshold for identifying ISI/SG related problems;

• the licensee had performed a root cause (if applicable) and taken appropriate corrective actions; and

• the licensee had evaluated operating experience and industry generic issues related to ISI and pressure boundary integrity.

The inspectors performed these reviews to evaluate compliance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On June 2, 2008, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment.

This inspection constitutes one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

• diesel generator;

• auxiliary feedwater; and

• internal containment spray.

The inspectors reviewed events, such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems, and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and components/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Documents reviewed are listed in the Attachment.

This inspection constitutes three quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• review of outage risk safe shutdown assessment checklists;

• review of revision to Kewaunee probabilistic risk assessment risk summary;

• emergent issue on potential degraded voltage due to energization of main transformers;

• review of revision to probabilistic risk assessment safety monitor;

• risk management for schedule changes during the week of May 7, 2008;

• downpower due to leak in actuator on HRS-2A2, A2MSR intercept valve; and

• weekly schedule changes as a result of T-ave instrument spiking.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Documents reviewed are listed in the Attachment These activities constituted seven samples as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• pressure and level transmitter instrument tubing over-pressurization ;

• polar crane functional checks due to radio interference;

• operation of RHR, component cooling water, and service water prior to drain-down;

• operability of emergency diesel generator B following control switch failure;

• containment FCU unit A degraded due to tube plugging;

• boron found in steam generator A vault;

• boric acid on bio-shield wall from crack in wall; and

• special ventilation zone train B declared operable with train B back-draft damper degraded.

The inspectors selected these potential operability issues based on the risk-significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and USAR to the licensees evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the

.

This inspection constitutes eight samples as defined in Inspection Procedure 71111.15-05

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

.1 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the following temporary modifications:

• diesel generator emergency fuel oil transfer temporary modification; and

• Furmanite' repair of body-to-bonnet leak on feedwater heater manual isolation valve.

The inspectors compared the temporary configuration changes and associated 10 CFR 50.59 screening and evaluation information against the design basis, the USAR, and the TSs, as applicable, to verify that the modification did not affect the operability or availability of the affected systems. The inspectors also compared the licensees information to operating experience information to ensure that lessons learned from other utilities had been incorporated into the licensees decision to implement the temporary modification. The inspectors, as applicable, performed field verifications to ensure that the modifications were installed as directed; the modifications operated as expected; modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. Lastly, the inspectors discussed the temporary modification with operations, engineering, and training personnel to ensure that the individuals were aware of how extended operation with the temporary modification in place could impact overall plant performance. Documents reviewed are listed in the This inspection constitutes two temporary modification samples as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings of significance were identified.

.2 Permanent Plant Modifications

a. Inspection Scope

The following engineering design package was reviewed and selected aspects were discussed with engineering personnel:

• auxiliary feedwater pump flow control upgrade; and

• main transformer replacement.

This document and related documentation were reviewed for adequacy of the associated 10 CFR 50.59 safety evaluation screening, consideration of design parameters, implementation of the modification, post-modification testing, and to verify that relevant procedures, design, and licensing documents were properly updated. The inspectors observed ongoing and completed work activities to verify that installation was consistent with the design control documents. Documents reviewed are listed in the This inspection constitutes two samples as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• reactor protection system relay lug replacement and relay termination retest;

• emergency diesel generator A voltage regulator retest after repair;

• post-maintenance testing on safety injection B accumulator isolation valve following maintenance;

• post-maintenance testing on energizing new transformers;

• post-maintenance testing on local leak rate test for SI-351A;

• post-maintenance testing on local leak rate test for SI-51B;

• post-maintenance testing on emergency diesel generator B following 18-month overhaul;

• post-maintenance testing on emergency diesel generator B following fuel pump repairs;

• post-maintenance testing on emergency diesel generator following voltage spiking repairs;

• post-maintenance testing on component cooling water pump B wear-ring scoring;

• post-maintenance testing on RHR pump B following flange repairs;

• post-maintenance testing on auxiliary feedwater motor-driven pump lube oil cooler and recirculation line; and

• turbine-driven auxiliary feedwater pump post-maintenance test following modifications.

These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written, in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion), and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment.

This inspection constitutes thirteen samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings of significance were identified.

1R20 Outage Activities

.1 Refueling Outage Activities

a. Inspection Scope

The inspectors reviewed the shutdown risk management activities and contingency plans for the refueling outage, conducted March 29 through May 8, 2008, to confirm that the licensee had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth. During the refueling outage, the inspectors observed portions of the shutdown and cool-down processes and monitored licensee controls over the outage activities listed below. Documents reviewed during the inspection are listed in the

.

• licensee configuration management;

• implementation of clearance and tagging activities;

• controls over the status and configuration of electrical systems;

• monitoring of decay heat removal processes, systems, and components;

• controls to ensure that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system;

• reactor water inventory controls;

• reactor vessel head-lift;

• repair of fuel transfer system in the spent fuel pool canal;

• pre-200°F containment walk-down to verify that debris had not been left which could block emergency core cooling system suction strainers;

• controls over activities that could affect reactivity;

• tracking of startup prerequisites;

• startup and ascension to full power operation;

• reactor physics testing; and

• licensee identification and resolution of problems related to refueling outage activities.

This inspection constitutes one refueling outage sample as defined in Inspection Procedure 71111.20-05.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

.1 Routine Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• FCU 1B coil inspection;

• emergency diesel generator A inspection and retest;

• containment pressure instrument channels test;

• SI-13B, safety injection to loop B check valve leakage measurement; and

• main steam isolation valve solenoid test.

The inspectors observed in-plant activities and reviewed procedures and associated records to determine whether: any preconditioning occurred; effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing; acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis; plant equipment calibration was correct, accurate, and properly documented; as left setpoints were within required ranges; the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments; measuring and test equipment calibration was current; test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied; test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used; test data and results were accurate, complete, within limits, and valid; test equipment was removed after testing; where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure; where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished; prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test; equipment was returned to a position or status required to support the performance of the safety functions; and all problems identified during the testing were appropriately documented and dispositioned in the corrective action program. Documents reviewed are listed in the Attachment.

This inspection constitutes five routine surveillance testing samples as defined in Inspection Procedure 71111.22, sections -02 and -05.

b. Findings

No findings of significance were identified.

.2 Inservice Testing Surveillance

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• residual heat removal pump A full flow test at refueling shutdown;

• residual heat removal pump B full flow test at refueling shutdown; and

• safety injection flow test.

The inspectors observed activities and reviewed procedures and associated records to determine whether: any preconditioning occurred; effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing; acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis; plant equipment calibration was correct, accurate, and properly documented; as left setpoints were within required ranges; the calibration frequency were in accordance with TSs, the USAR, procedures, and applicable commitments; measuring and test equipment calibration was current; test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied; test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used; test data and results were accurate, complete, within limits, and valid; test equipment was removed after testing; where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, ASME Code, and reference values were consistent with the system design basis; where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure; where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished; prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test; equipment was returned to a position or status required to support the performance of its safety functions; and all problems identified during the testing were appropriately documented and dispositioned in the corrective action program. Documents reviewed are listed in the Attachment.

This inspection constitutes three inservice testing samples as defined in Inspection Procedure 71111.22.

b. Findings

No findings of significance were identified.

.3 Reactor Coolant System Leak Detection Inspection Surveillance

The inspectors reviewed the test results for the following activities to determine whether the equipment was capable of performing its intended function of monitoring RCS leakage and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• RCS leak rate check.

The inspectors observed in plant activities and reviewed procedures and associated records to determine whether: preconditioning occurred; effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing; acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis; plant equipment calibration was correct, accurate, and properly documented; as left setpoints were within required ranges; the calibration frequency were in accordance with TSs, the USAR, procedures, and applicable commitments; measuring and test equipment calibration was current; test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied; test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used; test data and results were accurate, complete, within limits, and valid; test equipment was removed after testing; where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure; where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished; prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test; equipment was returned to a position or status required to support the performance of its safety functions; and all problems identified during the testing were appropriately documented and dispositioned in the corrective action program. Documents reviewed are listed in the Attachment.

This inspection constitutes one reactor coolant system leak detection inspection sample as defined in Inspection Procedure 71111.22.

b. Findings

No findings of significance were identified.

.4 Containment Isolation Valve Testing

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• post-LOCA valves timing test SP-55-167-4A.

The inspectors observed in-plant activities and reviewed procedures and associated records to determine whether: any preconditioning occurred; effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing; acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis; plant equipment calibration was correct, accurate, and properly documented; as left setpoints were within required ranges; the calibration frequency were in accordance with TSs, the USAR, procedures, and applicable commitments; measuring and test equipment calibration was current; test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied; test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used; test data and results were accurate, complete, within limits, and valid; test equipment was removed after testing; where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished; prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test; equipment was returned to a position or status required to support the performance of its safety functions; and all problems identified during the testing were appropriately documented and dispositioned in the corrective action program. Documents reviewed are listed in the Attachment.

This inspection constitutes one containment isolation valve inspection sample as defined in Inspection Procedure 71111.22.

b. Findings

No findings of significance were identified.

1EP2 Alert and Notification System Evaluation

.1 Alert and Notification System Evaluation

a. Inspection Scope

The inspectors reviewed documents and conducted discussions with emergency preparedness (EP) staff regarding the operation, maintenance, and periodic testing of the Alert and Notification System (ANS) in the Kewaunee Power Station's plume pathway Emergency Planning Zone. The inspectors reviewed monthly trend reports and siren test failure records from October 2006 through May 2008. Information gathered during document reviews and interviews was used to determine whether the ANS equipment was maintained and tested in accordance with Emergency Plan commitments and procedures. Additionally, the inspectors observed a siren test to evaluate procedure usage and interaction between licensee staff and county officials. Documents reviewed are listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71114.02-05.

b. Findings

No findings of significance were identified.

1EP3 Emergency Response Organization Augmentation Testing

.1 Emergency Response Organization Augmentation Testing

a. Inspection Scope

The inspectors reviewed and discussed with plant EP staff the emergency plan commitments and procedures that addressed the primary and alternate methods of initiating an Emergency Response Organization (ERO) activation to augment the on shift ERO as well as the provisions for maintaining the plants ERO emergency telephone book. The inspectors also reviewed reports and a sample of corrective action program records of unannounced off-hour augmentation tests, which were conducted from December 2006 through June 2008, to determine the adequacy of post-drill critiques and associated corrective actions. The inspectors also reviewed a sample of the EP training records, approximately 27 records for ERO personnel, who were assigned to key and support positions, to determine the status of their training as it related to their assigned ERO positions. Also, the inspectors conducted a walkdown of the technical support center to evaluate material condition and readiness of the facility. Documents reviewed are listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71114.03-05.

b. Findings

No findings of significance were identified.

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies

.1 Correction of Emergency Preparedness Weaknesses and Deficiencies

a. Inspection Scope

The inspectors reviewed a sample of nuclear oversight staffs 2007 and 2008 annual audits of the Kewaunee Power Station EP program to determine that these independent assessments met the requirements of 10 CFR 50.54(t). The inspectors also reviewed critique reports and samples of corrective action program records associated with the 2007 biennial exercise, as well as various EP drills conducted in 2006, 2007, and 2008, to determine that the licensee fulfilled its drill commitments and to evaluate the licensees efforts to identify, track, and resolve concerns identified during these activities.

Additionally, the inspectors reviewed a sample of EP items and corrective actions related to the facilitys EP program and activities to determine whether corrective actions were completed in accordance with the sites corrective action program. Documents reviewed are listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71114.05-05.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee full activation emergency drill on June 2, 2008, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and technical support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1 Plant Walkdowns and Radiation Work Permit (RWP) Reviews

a. Inspection Scope

The inspectors reviewed licensee controls and surveys in the following radiologically significant work areas within radiation areas, high radiation areas, and airborne radioactivity areas in the plant to determine if radiological controls, including surveys, postings and barricades, were acceptable:

• containment building;

• refueling floor; and

• various portions of the auxiliary building.

The inspectors reviewed the RWPs and work packages used to access these areas and other high radiation work areas to identify the work control instructions and control barriers that had been specified. Electronic dosimeter alarm set points for both integrated dose and dose rate were evaluated for conformity with survey indications and plant policy. Workers were interviewed to verify that they were aware of the actions required when their electronic dosimeters noticeably malfunctioned or alarmed.

The inspectors walked down and surveyed (using an NRC survey meter) these areas to verify that the prescribed RWP, procedure, and engineering controls were in place, that licensee surveys and postings were complete and accurate, and that air samplers were properly located.

The inspectors reviewed RWPs for airborne radioactivity areas to verify barrier integrity and engineering controls performance (e.g. high-efficiency particulate air ventilation system operation) and to determine if there was a potential for individual worker internal exposures of >50 millirem committed effective dose equivalent : The work areas having a history of, or the potential for, airborne transuranics were evaluated to verify that the licensee had considered the potential for transuranic isotopes and provided appropriate worker protection.

Documents reviewed are listed in the Attachment.

This inspection constitutes four samples as defined in Inspection Procedure 71121.01-5.

b. Findings

No findings of significance were identified.

.2 Problem Identification and Resolution

a. Inspection Scope

The inspectors reviewed licensee documentation packages for all performance indicator (PI) events occurring since the last inspection to determine if any of these PI events involved dose rates >25 R/hour at 30 centimeters or >500 R/hour at 1 meter. Barriers were evaluated for failure and to determine if there were any barriers left to prevent personnel access. Unintended exposures >100 millirem total effective dose equivalent (or >5 rem shallow dose equivalent or >1.5 rem lens dose equivalent) were evaluated to determine if there were any regulatory overexposures or if there was a substantial potential for an overexposure. Documents reviewed are listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71121.01-5.

b. Findings

No findings of significance were identified.

.3 Job-In-Progress Reviews

a. Inspection Scope

The inspectors observed jobs that were being performed in radiation areas, airborne radioactivity areas, or high radiation areas for observation of work activities that presented the greatest radiological risk to workers and reviewed radiological job requirements for the following activities including RWP requirements and work procedure requirements:

• reactor coolant pump 1B removal;

• repair of RHR-2A valve; and

• cleaning of reactor head studs.

Job performance was observed with respect to these requirements to assess whether radiological conditions in the work area were adequately communicated to workers through pre-job briefings and postings. The inspectors also evaluated the adequacy of radiological controls, including required radiation, contamination, and airborne surveys for system breaches; radiation protection job coverage, including any applicable audio and visual surveillance for remote job coverage; and contamination controls.

Radiological work in high radiation work areas having significant dose rate gradients was reviewed to evaluate the application of dosimetry to effectively monitor exposure to personnel and to assess the adequacy of licensee controls. These work areas involved areas where the dose rate gradients were severe, thereby increasing the necessity of providing multiple dosimeters or enhanced job controls.

Documents reviewed are listed in the Attachment.

This inspection constitutes five samples as defined in Inspection Procedure 71121.01-5.

b. Findings

No findings of significance were identified.

.4 Radiation Worker Performance

a. Inspection Scope

During job performance observations, the inspectors evaluated radiation worker performance with respect to stated radiation protection work requirements and evaluated whether workers were aware of the significant radiological conditions in their workplace, of the RWP controls and limits in place, and of the level of radiological hazards present.

The inspectors also evaluated that worker performance accounted for these radiological hazards. Documents reviewed are listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71121.01-5.

b. Findings

No findings of significance were identified.

.5 Radiation Protection Technician (RPT) Proficiency

a. Inspection Scope

During job performance observations, the inspectors evaluated radiation protection technician (RPT) performance with respect to radiation protection work requirements and evaluated whether they were aware of the radiological conditions in their workplace, of the RWP controls and limits in place, and if their performance was consistent with their training and qualifications with respect to the radiological hazards and work activities. Documents reviewed are listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71121.01-5.

b. Findings

No findings of significance were identified.

2OS2 As Low As Is Reasonably Achievable (ALARA) Planning And Controls (71121.02)

.1 Inspection Planning

a. Inspection Scope

The inspectors reviewed plant collective exposure history, current exposure trends, and ongoing and planned activities to assess current performance and exposure challenges.

This included determining the plants current 3-year rolling average for collective exposure in order to help establish resource allocations and to provide a perspective of significance for any resulting inspection finding assessment.

The inspectors reviewed the outage work scheduled during the inspection period and associated work activity exposure estimates for work activities which were likely to result in the highest personnel collective exposures.

The inspectors reviewed documents to determine if there were site-specific trends in collective exposures and source-term measurements.

The inspectors reviewed procedures associated with maintaining occupational exposures ALARA and processes used to estimate and track work activity specific exposures.

Documents reviewed are listed in the Attachment.

This inspection constitutes four required samples as defined in Inspection Procedure 71121.02-5.

b. Findings

No findings of significance were identified.

.2 Radiological Work Planning.

a. Inspection Scope

The inspectors evaluated the licensees list of work activities ranked by estimated exposure that were in progress and reviewed the following work activities of highest exposure significance:

• reactor coolant pump 1B removal;

• repair of RHR-2A valve; and

• cleaning of reactor head studs.

For these three activities, the inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements to verify that the licensee had established procedures and engineering and work controls that were based on sound radiation protection principles to achieve occupational exposures that were ALARA.

This also involved determining that the licensee had reasonably grouped the radiological work into work activities, based on historical precedence, industry norms, and/or special circumstances.

The integration of ALARA requirements into work procedure and RWP documents was evaluated to verify that the licensees radiological job planning would reduce dose.

Documents reviewed are listed in the Attachment.

This inspection constitutes two required samples and one optional sample as defined in Inspection Procedure 71121.02-5.

b. Findings

No findings of significance were identified.

.3 Job Site Inspections and ALARA Control

a. Inspection Scope

The inspectors observed the following three jobs that were being performed in radiation areas, airborne radioactivity areas, or high radiation areas for observation of work activities that presented the greatest radiological risk to workers:

• reactor coolant pump 1B removal;

• repair of RHR-2A valve; and

• cleaning of reactor head studs.

The licensees use of engineering controls to achieve dose reductions was evaluated to verify that procedures and controls were consistent with the licensees ALARA reviews, that sufficient shielding of radiation sources was provided for and that the dose expended to install/remove the shielding did not exceed the dose reduction benefits afforded by the shielding. Documents reviewed are listed in the Attachment.

This inspection constitutes one required sample as defined in Inspection Procedure 71121.02-5

b. Findings

No findings of significance were identified.

.4 Radiation Worker Performance

a. Inspection Scope

Radiation worker and RPT performance was observed during work activities being performed in radiation areas, airborne radioactivity areas, and high radiation areas that presented the greatest radiological risk to workers. The inspectors evaluated whether workers demonstrated the ALARA philosophy in practice by being familiar with the work activity scope and tools to be used, by utilizing ALARA low dose waiting areas, and by complying with work activity controls. Also, radiation worker training and skill levels were reviewed to determine if they were sufficient relative to the radiological hazards and the work involved. Documents reviewed are listed in the Attachment.

This inspection constitutes one required sample as defined in Inspection Procedure 71121.02-5.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification (71151-05)

.1 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures PI from the fourth quarter 2007 through the first quarter 2008. To determine the accuracy of the PI data, the inspector used definitions and guidance in Nuclear Energy Institute (NEI) document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73".

The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC Inspection reports to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment.

This inspection constitutes one safety system functional failures sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.2 Mitigating Systems Performance Index - Emergency AC Power Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - Emergency AC Power Systems from the first quarter 2007 through the first quarter 2008. To determine the accuracy of the data, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports, and NRC inspection reports for the above period to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment.

This inspection constitutes one MSPI emergency AC power systems sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.3 Mitigating Systems Performance Index - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - High Pressure Injection Systems from the first quarter 2007 through the first quarter 2008. To determine the accuracy of the data, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports, and NRC inspection reports for the above period to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment.

This inspection constitutes one MSPI high pressure injection systems sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.4 Mitigating Systems Performance Index - Heat Removal Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Heat Removal Systems from the first quarter 2007 through the first quarter 2008. To determine the accuracy of the data, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports, and NRC inspection reports for the above period to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the

.

This inspection constitutes one MSPI heat removal systems sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.5 Mitigating Systems Performance Index - Residual Heat Removal Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Residual Heat Removal Systems from the first quarter 2007 through the first quarter 2008. To determine the accuracy of the data, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports, and NRC inspection reports for the above period to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment.

This inspection constitutes one MSPI residual heat removal systems sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.6 Mitigating Systems Performance Index - Cooling Water Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems from the first quarter 2007 through the first quarter 2008. To determine the accuracy of the data, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports, and NRC inspection reports for the above period to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the

.

This inspection constitutes one MSPI cooling water systems sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.7 Drill/Exercise Performance

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill/Exercise Performance PI from the 4th quarter 2007 through 1st quarter 2008. To determine the accuracy of the data, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during predesignated control room simulator training sessions, performance during the 2007 biennial exercise, and performance during other drills.

Documents reviewed are listed in the Attachment.

This inspection constitutes one drill/exercise performance sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.8 Emergency Response Organization Drill Participation

a. Inspection Scope

The inspectors sampled licensee submittals for the ERO Drill Participation PI from the 4th quarter 2007 through 1st quarter 2008. To determine the accuracy of the data, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI, performance during the 20007 biennial exercise and other drills, and revisions of the roster of personnel assigned to key emergency response organization positions. Documents reviewed are listed in the Attachment.

This inspection constitutes one ERO drill participation sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.9 Alert and Notification System

a. Inspection Scope

The inspectors sampled licensee submittals for the Alert and Notification System PI from the 4th quarter 2007 through 1st quarter 2008. To determine the accuracy of the data, the inspectors used PI definitions and guidance contained in NEI Document 99-02. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI and results of periodic alert and notification system operability tests. Documents reviewed are listed in the Attachment.

This inspection constitutes one alert and notification system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Routine Review of items Entered Into the Corrective Action Program

a. Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program (CAP) at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; that evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue. Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings of significance were identified.

.2 Daily Corrective Action Program Reviews

a. Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings of significance were identified.

.3 Semi-Annual Trend Review

a. Scope

The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on trends related to switch or valve mispositioning errors, tagout errors and opposite train maintenance or operations errors. The inspectors review also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the six-month period of November 2007 through April 2008, although some examples expanded beyond those dates where the scope of the trend warranted.

The review also included issues documented outside the normal CAP in major equipment problem lists, departmental problem/challenges lists, and self-assessment reports. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.

b. Findings

No findings of significance were identified.

.4 Annual Sample:

Review of Operator Workarounds (OWAs)

a. Scope

The inspectors evaluated the licensees implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the OWAs on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents.

The inspectors performed a review of the cumulative effects of OWAs. The documents listed in the Attachment were reviewed to accomplish the objectives of the inspection procedure. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into its corrective action program, and proposed or implemented appropriate and timely corrective actions which addressed each issue.

Reviews were conducted to determine if any operator challenge could increase the possibility of an initiating event, and if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds.

The above constitutes completion of one operator workarounds annual inspection sample as defined in IP 71152-05.

b. Findings

No findings of significance were identified.

.5 Selected Issue Follow-Up Inspection:

Seismic Storage and Scaffold Construction

a. Scope

The inspectors reviewed the corrective actions of two recent repeat NRC violations related to improper seismic housekeeping control and improper seismic scaffolding construction in safety-related areas.

Included in the review of the seismic storage corrective actions were the revised Plant Cleanliness and Storage Procedure, GNP-01.31.01, and the Engineering Evaluation for Temporary Storage of Unrestrained Portable Equipment in Acceptable Storage Areas Shown in KPS GNP-01.31.01 by Stevenson and Associates. In addition to the documents reviewed, the inspectors toured the plant and identified two locations were the procedure allowed uncontrolled storage near safety-related equipment. One location had been documented by an engineering evaluation and appeared to be acceptable and the other location had been previously identified by the licensee and had compensatory measures in-place until completion of the next procedure revision.

Included in the review of the seismic scaffolding construction corrective actions were Root Cause Evaluation (RCE) 2008-0224, Scaffolding Affecting Safety-Related Equipment and the revised Requirements and Guidelines for Scaffold Construction and Inspection, GMP-127. The inspectors also toured the plant and reviewed a select number scaffolding inspection checklists to verify they had been filled out in accordance with procedure and had engineering evaluations when required. All of the scaffolding inspected appeared to be acceptable.

The above constitutes completion of one in-depth problem identification and resolution sample as defined in IP 71152-05.

b. Findings

No findings of significance were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 Response To Unplanned Or Non-Routine Events

a. Inspection Scope

The inspectors reviewed the plants response to the following unplanned or non-routine events:

• radioactive water spill outside containment on April 17, 2008;

• seismic event response on April 18, 2008;

• emergency diesel generators declared inoperable due to fuel oil equalizing line problems; and

• leaking core-exit thermocouple assembly.

Documents reviewed in this inspection are listed in the Attachment.

This inspection constitutes four samples as defined in Inspection Procedure 71153-05.

b. Findings

Introduction:

The inspectors identified an unresolved item (URI) associated with the emergency diesel generator fuel oil storage tank design and licensing basis.

Description:

The licensee issued event notification EN#44182 for the siphon line that interconnected the two emergency diesel generator fuel oil storage tanks was not functioning as designed. The inspectors reviewed the licensing basis with the licensee for both the safety-related design requirements, including single failure, and the fuel oil storage volume requirements as described in the licensees TSs and USAR. At the end of the inspection period, the inspectors had not received the licensees final position and could not conclude that the licensee was in compliance with its license requirements; however, because there was always more than a 24-hour supply of fuel oil available to the diesel generators, a preliminary review of this issue by the Region III Senior Reactor Analysts indicated that the issue was likely of low safety significance. Because of the complexity of the issue, the inspectors determined that this issue would remain unresolved pending a review by the inspectors and the NRCs Office of Nuclear Reactor Regulation (NRR) of the licensees final position on the licensing basis (URI 05000305/2008003-03).

.2 (Closed) Licensee Event Report (LER) 05000305/2005-004-02, Safe Shutdown

Potentially Challenged by Unanalyzed Internal Flooding Events and Inadequate Design This event, which occurred on March 15, 2005, involved the discovery that the Kewaunee Power Station plant design for protection against internal flooding would not ensure that required equipment would be protected from the postulated failure of non-safety-related piping in the turbine building. The issue and associated enforcement was documented in Inspection Report 05000305/2005011. The issue was determined to have substantial safety significance (Yellow) and a cited violation was issued in Inspection Report 05000305/2005018. The corrective actions for this issue were assessed as part of the supplemental inspection documented in Inspection Report 05000305/2006007. Documents reviewed are listed in the Attachment. This LER is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.3 (Closed) LER 05000305/2006-005-00, Seal Water Flow to the Service Water Pump

Bearings Found Degraded This event, which occurred on May 30, 2006, involved the loss of the safety-related back-up seal water flow to service water pumps. This issue was the subject of Unresolved Item 05000305/2006003-03. The URI was discussed and closed in Inspection Report 05000305/2007002, Section 1R15.b.3. A Non-Cited Violation was identified (NCV 05000305/2007002-06). Corrective actions taken and planned by the licensee were also discussed in Inspection Report 05000305/2007002. Documents reviewed are listed in the Attachment. This LER is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.4 (Closed) LER 05000305/2006-005-01, Seal Water Flow to the Service Water Pump

Bearings Found Degraded This event, which occurred on May 30, 2006, involved the loss of the safety-related back-up seal water flow to service water pumps. This LER was reviewed as part of the review for LER 2006-005-00 discussed in Section 4OA3.3 above. Documents reviewed are listed in the Attachment. This LER is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.5 (Closed) LER 05000305/2006-006-00, Safety Injection Accumulator Level to Volume

Correlation and Alarm Setpoints Non-Conservative This event, which occurred on July 13, 2006, involved the licensee identification that non-conservative values had been used for safety accumulator level correlations and associated level alarm setpoints. As a result, the licensee determined that there would have been numerous times in the past during which the safety accumulator levels would have been below the minimum required TS volume. As part of its review, the licensee determined that sufficient volume was available for the safety accumulators to perform their safety function. The licensee concluded that using setpoint methodology which considered instrument accuracies and a failure to update operator aides and alarm setpoints in response to a previously identified issue were the causes for this event. The licensee revised alarm setpoints for the safety accumulator levels to account for instrument uncertainty. At the time of this inspection, the licensee was in the process of reviewing other values used for adherence to TSs for potential issues associated with instrument uncertainties. The operator aide used for determining safety accumulator volumes was eliminated and the information was added to operating procedure N-SI-33, Filling, Draining, Pressurizing and Venting SI Accumulators, using appropriate values.

Enforcement aspects associated with this LER are discussed in Section 4OA7.

Documents reviewed are listed in the Attachment. This LER is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.6 (Closed) LER 05000305/2006-009-01, Emergency Diesel Generator Fuel Oil Leak

This event, which occurred on August 17, 2006, involved a fuel oil leak on the A emergency diesel generator engine during a surveillance testing on August 17, 2006, and required an engine shutdown. This issue was the subject of URI 05000305/2006004-02. The issue, with associated enforcement action, was further documented in Inspection Report 05000305/2007007. The issue was determined to have substantial safety significance (Yellow) and a cited violation was issued in Inspection Report 05000305/2007009. The corrective actions for this issue were assessed as part of the supplemental inspection documented in Inspection Report 05000305/20070011. Documents reviewed are listed in the Attachment. This LER is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.7 (Discussed) LER 05000305/2007-002-00, Issues With AMAG/Westinghouse

Calculations for Full Power Result in Reduced Power Operation This event, which occurred on January 3, 2007, involved the determination that a potentially larger uncertainty existed with the feedwater ultrasonic flow measurement system than what was assumed for determining power levels. Since identification of this issue, the licensee has limited steady-state power levels to 99.69 percent (1766.5 MegaWatts thermal (MWt)) of their licensed power level (1772 MWt). The inspectors noted that the 1766.5 MWt level which the licensee was limiting power levels to was above the 1749 MWt limit for when the ultrasonic flow measurement system was out-of-service. Documents reviewed as part of this inspection are listed in the attachment. This LER is open pending review of analyses supporting operation at licensed power levels with uncertainties associated with the ultrasonic flow measurement system are considered.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.8 (Closed) LER 05000305/2007-008-00, Inadequate Emergency Diesel Generator Testing

When Redundant Emergency Diesel Generator Was Inoperable This event, which occurred on June 19, 2007, involved the determination that testing performed for a diesel generator to confirm operability when the other diesel generator was inoperable was inadequate because the testing did not include assuming a load on the diesel generator. Subsequent to this issue being identified, the NRC issued License Amendment No. 194 by letter dated February 7, 2008, with revised TSs (ADAMS Accession Nos. ML080160412 and ML080280252, respectively). The License Amendment and revised TSs clarified the diesel generator testing requirements to specify assumption of load when testing a diesel generator to confirm operability when the other diesel generator was inoperable. The revised TSs also permitted operability to be demonstrated by determining that the operable diesel generator was not inoperable due to a common cause failure. Documents reviewed are listed in the Attachment. This LER is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.9 (Closed) LER 05000305/2007-010-00, Allowed Outage Time of the Function for

Automatic Initiation of the Control Room Post-Accident Recirculation System on a High Radiation Signal Not Met This event, which occurred on September 21, 2007, involved the licensee determination that past surveillances of the control room radiation monitor, R-23, resulted in the monitor being inoperable for a period exceeding the time allowed by TSs. The allowed outage time had been exceeded on two occasions in November 2006. However, the safety function had been accomplished by placing the control room ventilation system into recirculation mode. The inspectors considered the deficiency associated with not meeting TS allowed outage times in this instance to be minor because the safety function had been met. The licensee attributed the cause to a lack of recognition that how operability was defined for the control room radiation monitor was changed by a prior TS amendment. In addition, the surveillance procedure in place during 2006 did not provide guidance to operators that equipment was being rendered inoperable by certain steps in the surveillance procedure. As a corrective action, the licensee submitted a licensee amendment request to revise TSs for the control room radiation monitor to be consistent with NRC guidance. In addition, the licensee had revised the surveillance procedure to limit performance of the surveillance to when the plant was in hot shutdown or below or when the control room radiation monitor was out of service and had been declared inoperable by Operations personnel. The surveillance procedure had also been revised to explicitly state which procedure steps would render the control room radiation monitor inoperable. Documents reviewed are listed in the Attachment.

This LER is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.10 (Closed) URI 05000305/2006-016-04, Internal Flooding Licensing Basis

The inspectors had identified issues with respect to the licensing basis for internal flooding. A modification for addressing potential flooding of RHR pump pits did not take into account the potential for multiple flooding sources due to a seismic event. In addition, the inspectors noted that safety-related equipment could be adversely affected by a failure of a safety-related service water pipe in the turbine building. Subsequent to this issue being identified, the NRC issued License Amendment No. 197 by letter dated March 28, 2008, (ADAMS Accession No. ML080770179). License Amendment No. 197 revised the licensing basis by modifying the design criteria for internal flooding. The modified design criteria specifically limited consideration of potential flooding sources to the worst case flooding scenario for each area evaluated to a single pipe or tank failure.

In addition, the modified design criteria addressed the service water header in the turbine building. As such, the license amendment addressed the issues identified by the inspectors. Documents reviewed are listed in the Attachment. This URI is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.11 (Closed) URI 05000305/2007-002-03, Inadequate Testing of Diesel Generator When the

Redundant Diesel Generator Was Inoperable Testing performed for a diesel generator to confirm operability when the other diesel generator was inoperable did not include assuming a load on the diesel generator. As discussed above in Section 4OA3.8, this issue was addressed through issuance of License Amendment No. 194 and revised TSs. Documents reviewed are listed in the

. This URI is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.12 (Closed) URI 05000305/2007-008-02, Auxiliary Building Roof Degradation

There was a concern associated with roof leakage resulting in conditions which could affect operation of a SG power-operated relief valve located in the auxiliary building.

The licensee completed its evaluation of this issue. The inspectors agreed with the licensees conclusion that operation of the SG power-operated relief valve would not be affected. During this inspection, the inspectors performed an on-site inspection of the area of concern and verified that the drain trap associated with the B power-operated relief valve vent stack line had been cleaned of excessive corrosion. In addition, discussions with licensee engineering personnel indicated that some repairs to the auxiliary building roof had been performed and additional repairs are planned.

Documents reviewed are listed in the Attachment. This URI is closed.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

4OA5 Other Activities

.1 Reactor Coolant System Dissimilar Metal Butt Welds (TI 2515/172, Revision 0)

a. Inspection Scope

From April 7, 2008, through April 10, 2008, the inspectors conducted a review of the licensees activities regarding licensee dissimilar metal butt weld (DMBW) mitigation and inspection implemented in accordance with the industry self-imposed mandatory requirements of Materials Reliability Program (MRP) -139, Primary System Piping Butt Weld Inspection and Evaluation Guidelines. Temporary Instruction (TI) 2515/172, Reactor Coolant System Dissimilar Metal Butt Welds, was issued February 21, 2008, to support the evaluation of the licensees implementation of MRP-139. Documents reviewed are listed in the Attachment.

(1) Licensees Implementation of the MRP-139 Baseline Inspections The licensee identified six DMBWs. The inspectors performed a document review and concurred with the licensee that there were no other dissimilar metal (DM) welds, including those in the pressurizer, that fell within the MRP-139 scope. The six welds were grouped into two categories. Four welds were SG nozzle-to-safe end welds, which were installed in 2001 during SG replacement. These four welds were mitigated with Alloy 690 cladding (inlaid) on the interior diameter when installed. It was the licensees position that since these welds were inlaid, they were not susceptible to primary water stress-corrosion cracking (PWSCC) and, therefore, baseline inspections per MRP-139 were not applicable.

The other two welds were reactor vessel SI 4-inch nozzle-to-safe end welds consisting of Alloy 82/182 from original construction in 1974. The licensee believed that these welds were not susceptible because the operating temperatures were 40 degrees Fahrenheit cooler (495oF) than Kewaunees cold leg temperature (535oF) and, therefore, were not classified in Section 6 of MRP-139. The licensee stated that the MRP-139 group has informally concurred with the licensees position that due to the lower temperature the welds did not fall within the MRP-139 scope. The licensee also stated that the MRP group will address this issue in Revision 1 of MRP-139 to be issued this Fall.

The inspectors relayed this information to pertinent NRR staff for evaluation and possible use in discussions with NEI.

(2) Volumetric Examinations There were no required MRP-139 volumetric examinations conducted during this outage or previous outages since the licensee does not consider any of its DMBWs falling within the scope of MRP-139.

The licensee did not plan on performing weld overlays or any mitigation strategies at this time.

The inspectors verified that the licensee did not perform any DMBW weld overlays during this or previous outages.

(3) Mechanical Stress Improvement The inspectors verified that the licensee did not perform any DMBW stress improvement activities during this or previous outages.

(4) Inservice Inspection Program Because the licensee did not consider any of its DMBW to be within the scope of MRP - 139, the requirement to categorize welds in accordance with MRP-139 was not applicable. The inspectors also determined that the licensee did not have any DMBW categorized as H or I. Although the inspectors did not identify any deviations from the inspection guidelines of MRP-139, the licensee was seeking additional clarification on the appropriate classification for the reactor vessel SI nozzle-to-safe end DMBWs.

b.

Observations Summary: Kewaunee is a Westinghouse 2-loop design with six DMBWs containing 82/182 material, four in the SGs and two in SI piping. The four SG welds were mitigated/inlaid with Alloy 690 material with one receiving a manual UT examination in 2004. The SI welds operate at a temperature 40 degrees less than the cold leg temperature and the licensee believe them to be non-susceptible to PWSCC at that low a temperature. The two welds received an automated Performance Demonstration Initiative (PDI) UT exam in 2004. All six welds have been placed in the ASME Code 10-year risk informed (RI) ISI program for future examinations due to their non-susceptibility to PWSCC.

Depending on interpretation, the licensees binning of the SI system welds due to the 40 degrees below cold leg temperature issue may or may not be a deviation from current MRP-139 requirements. However, the licensee indicated that the binning of these welds will be clarified in the next planned revision to MRP-139.

In accordance with requirements of TI 2515/172, Revision 0, the inspectors evaluated and answered the following questions:

(1) Licensees Implementation of the MRP-139 Baseline Inspections

1. a. Have the baseline inspections been performed or are they scheduled to be

performed in accordance with MRP-139 guidance?

Not applicable. The licensee determined that none of the six DMBWs fell within the scope of MRP-139.

b. Were the baseline inspections of the pressurizer temperature DMBWs of the nine plants listed in 03.01.b completed during the spring outage.

Not applicable. Kewaunee was not one of the nine plants listed in 03.01.b

2. Is the licensee planning to take any deviations from the MRP-139 baseline inspection

requirements of MRP-139? If so, what deviations are planned, what is the general basis for the deviation, and was the NEI 03-08 process for filing a deviation followed?

With regard to the two SI welds, the licensee is not planning to mitigate or to perform inspections other than Code required non-destructive exams (NDE ) per its 10-year RI-ISI program. The licensee may change this plan depending on the feedback the licensee receives from the MRP group regarding the susceptibility of the material in that the licensee believes temperatures to be 40 degrees less than nominal cold leg temperatures.

As noted above, depending on interpretation, the licensees treatment of the SI welds may or may not be a deviation and the licensee expects clarification in a future MRP-139 revision. Regardless, even if subjected to cold leg temperatures, examination or mitigation was not yet required to have occurred at the time of the NRC inspection.

(2) Volumetric Examinations Since the licensee did not perform any examinations pursuant to MRP-139, the associated TI-172 questions were not applicable.

(3) Weld Overlays

1. Performed in accordance with ASME Code welding requirements and consistent with

NRC staff relief request authorizations? Has the licensee submitted a relief request and obtained NRR staff authorization to install the weld overlays?

Not applicable.

2. Performed by qualified personnel? (Briefly describe the personnel

training/qualification process used by the licensee for this activity.)

Not applicable.

3. Performed such that deficiencies were identified, dispositioned, and resolved?

Not applicable.

(4) Mechanical Stress Improvement Not applicable. There were no stress improvement activities performed or planned by this licensee in response to MRP-139.

(5) Inservice Inspection Program

1. Has the licensee prepared an MRP-139 inservice inspection program? If not, briefly

summarize the licensees basis for not having a documented program and when the licensee plans to complete preparation of the program.

Not applicable. Because none of the six DMBWs fell within the scope of MRP-139, the licensee did not prepare a MRP-139 inservice inspection program. Of the six DMBWs identified, the licensee believed that none are susceptible to PWSCC as four SG welds are inlaid with Alloy 52 and two SI system welds experience operating temperatures which are 40 degrees below cold leg temperature. The licensee stated that the MRP group has agreed informally with the licensee in that the SI system welds do not fall within the scope of MRP-139. The licensee also stated that the MRP group planned to address the issue of the welds outside the cold leg temperatures in Revision 1 of MRP-139, due to be issued this Fall.

2. In the MRP-139 inservice inspection program, are the welds appropriately

categorized in accordance with MRP-139? If any welds are not appropriately categorized, briefly explain the discrepancies.

Not applicable. No DMBWs were identified within the MRP-139 scope.

3. In the MRP-139 inservice inspection program, are the inservice inspection

frequencies, which may differ between the first and second intervals after the MRP-139 baseline inspection, consistent with the inservice inspections frequencies called for by MRP-139?

Not applicable. No DMBWs were identified within the MRP-139 scope.

4. If any welds are categorized as H or I, briefly explain the licensees basis of the

categorization and the licensees plans for addressing potential PWSCC.

Not applicable. No DMBWs were identified within the MRP-139 scope. Therefore, no welds are categorized as H or I.

5. If the licensee is planning to take deviations from the inservice inspection

requirements of MRP-139, what are the deviations and what are the general bases for the deviations? Was the NEI 03-08 process for filing deviations followed?

See answer to Item (1), Question 2 above.

b. Findings

No findings of significance were identified.

.2 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

On July 16, 2008, the inspectors presented the inspection results to Mr. S. Scace and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings

Interim exits were conducted for:

• inservice inspection and TI 2515/172 with Mr. S. Scace, on April 10;

• access control to significant radiological areas and ALARA planning and controls with Mr. S. Scace, on April 18 and on May 29; and

• emergency preparedness inspection with Mr. S. Scace, on June 20.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

4OA7 Licensee-Identified Violations

The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.

• Title 10, Part 50, Appendix B, Criterion III, Design Control, required, in part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. On July 13, 2006, the licensee identified that applicable regulatory requirements had not been correctly translated into procedures and instructions in that an operator aide used for determining safety accumulator volume and alarm setpoints for safety accumulator levels were non-conservative (see Section 4OA3.5). The licensee revised alarm setpoints for the safety accumulator levels to account for instrument uncertainty. The operator aide used for determining safety accumulator volumes was eliminated and the information was added to operating procedure N-SI-33, Filling, Draining, Pressurizing and Venting SI Accumulators, using appropriate values. This issue is of very low safety significance based on a Phase I SDP screening because the licensee determined that safety accumulators had sufficient volume maintained to support their safety function.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

S. Scace, Site Vice-President

M. Crist, Plant Manager

L. Armstrong, Site Engineering Director

P. Blasioli, Organizational Effectiveness Director

T. Breene, Nuclear Licensing Manager

J. Egdorf, Emergency Preparedness Supervisor

W. Henry, Maintenance Manager

M. Hovis, Radiation Protection Supervisor

B. Lembeck, Radiation Protection Supervisor

J. Madden, Nuclear Oversight Manager

C. Olson, Radiation Protection Supervisor

K. Peveler, Manager Engineering Programs

J. Ruttar, Operations Manager

P. Serra, Emergency Preparedness Fleet Manager

D. Shannon, Health Physics Operations Supervisor

B. Steckler, Radiation Protection Supervisor

S. Wood, Emergency Preparedness Manager

Nuclear Regulatory Commission

M. Kunowski, Chief, Division of Reactor Projects, Branch 5

LIST OF ITEMS

Opened

05000305/2008003-01 NCV Failure to Follow the Provisions of General Nuclear Procedure, GNP-12.06.01, Hot and Cold Weather Operations (Section 1R01.2)

05000305/2008003-02 URI Lack of Calculation to Show that the Auxiliary Building Floor Fan Coil Units Can Perform Their Safety-Related Function at the Maximum Design Service Water Temperature (Section 1R07.1)

05000305/2008003-03 URI Siphon Line Which Interconnected Two Diesel Generator Emergency Fuel Oil Storage Tanks Was Not Functioning as Designed (Section 4OA3.1)

Closed

05000305/2008003-01 NCV Failure to Follow the Provisions of General Nuclear Procedure, GNP-12.06.01, Hot and Cold Weather Operations (Section 1R01.2)

05000305/2005004-02 LER Safe Shutdown Potentially Challenged by Unanalyzed Internal Flooding Events and Inadequate Design (Section 4OA3.2)

05000305/2006005-00 LER Seal Water Flow to the Service Water Pump Bearings Found Degraded (Section 4OA3.3)

05000305/2006003-00 LER RHR Pumps Declared Inoperable Due to Flooding Vulnerability*

• Item closed in IR 03000305/2008002, Section 4OA3.1, with incorrect number

05000305/2005003-00. This item is included to correct numbering error from the referenced report.

05000305/2006005-01 LER Seal Water Flow to the Service Water Pump Bearings Found Degraded (Section 4OA3.4)

05000305/2006006-00 LER Safety Injection Accumulator Level to Volume Correlation and Alarm Setpoints (Section 4OA3.5)

05000305/2006009-01 LER Emergency Diesel Generator Fuel Oil Leak (Section 4OA3.6)

05000305/2007008-00 LER Inadequate Emergency Diesel Generator Testing When Redundant Emergency Diesel Generator Was Inoperable (Section 4OA3.8)

05000305/2007010-00 LER Allowed Outage Time of the Function for Automatic Initiation of the Control Room Post-Accident Recirculation System on a High Radiation Signal Not Met (Section 4OA3.9)

05000305/2006016-04 URI Internal Flooding Licensing Basis (Section 4OA3.10)

05000305/2007002-03 URI Inadequate Testing of Diesel Generator When the Redundant Diesel Generator Was Inoperable (Section 4OA3.11)

05000305/2007008-02 URI Auxiliary Building Roof Degradation (Section 4OA3.12)

Discussed

05000305/2007002-00 LER Issues With AMAG/ Westinghouse Calculations for Full Power Result in Reduced Power Operation (Section 4OA3.7)