August 8, 2013 SUMMARY OF JULY 24, 2013 MEETING WITH OMAHA PUBLIC POWER DISTRICT

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August 8, 2013 LICENSEE: Omaha Public Power District (OPPD) FACILITY: Fort Calhoun Station

SUBJECT: SUMMARY OF JULY 24, 2013 MEETING WITH OMAHA PUBLIC POWER DISTRICT

On July 24, 2013, a Category 1 meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and Omaha Public Power District (OPPD) at the Ramada Plaza Omaha Hotel and Convention Center located at 3321 South 72nd Street, Omaha, Nebraska. The NRC presented the status of Inspection Manual Chapter 350 inspection to review the licensee’s progress in addressing items on the Confirmatory Action Letter Restart Checklist (Enclosure 1.) The licensee presented details of their progress for issue resolution and plant restart activities (Enclosure 2.)

A video of the public meeting will be posted on the website devoted to the special oversight at Fort Calhoun Station, available at:

http://www.nrc.gov/info-finder/reactor/fcs/special-oversight.html.

In accordance with 10 CFR 2.390 of the NRC’s “Rules of Practice,” a copy of this letter and its enclosures will be available electronically for public inspection in the NRC’s Public Document Room or from the Publicly Available Records (PARS) component of the NRC’s Agency wide Documents Access and Management System (ADAMS). ADAMS is accessible from the Public Electronic Reading Room page of the NRC’s public web site at:

http://www.nrc.gov/readingrm/adams.html.

To receive a summary of future meetings and other plant-specific e-mail distributions, you must subscribe to the Operating Reactor Correspondence electronic distribution for this plant via:

http://www.nrc.gov/public-involve/listserver/plants-by-region.html

Once subscribed, if you wish to discontinue receiving electronic distribution, you may unsubscribe at any time by visiting the same web address above.

CONTACT: Michael Hay, RIV/DRP (817) 200-1147

Docket No.: 50-285

Enclosure 1: NRC Presentation Slides Enclosure 2: OPPD Presentation Slides

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I V 1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511

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Fort Calhoun Station

Public Meeting

Nuclear Regulatory Commission

July 24, 2013

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Opening and Introductions

• Welcome

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Purpose

• NRC will discuss current status of

assessment activities associated with the

Confirmatory Action Letter Restart

Checklist

• OPPD will discuss activities to support

plant restart

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(6)

NRC PERSPECTIVES

• NRC Inspections

– Independent

– Thorough

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NRC PERSPECTIVES

• Fort Calhoun Station is making progress

– People

– Plant

(8)

STATUS OF RESTART CHECKLIST

• Majority of Restart Checklist Items have

been inspected

• A number of areas have been adequately

addressed

• A number of areas require additional

inspection

(9)

Item Number

Description of Item Current Status

1 Causes of Significant Performance

Deficiencies and Assessment of Organizational Effectiveness

1.a Flooding Issue – Yellow Finding Open

Corrective actions adequate, Extent of Condition under review

1.b Reactor Protection System contact

failure – White Finding

Open

Corrective actions adequate, Causes under review

1.c Electrical bus modification and

maintenance – Red Finding

Open

Corrective actions adequate, Extent of condition under review

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Item Number

1.d Security – Greater than Green Findings Closed

1.e Third-Party Safety Culture Assessment Closed

1.f Integrated Organizational Effectiveness

Assessment

Closed

1.g Safety System Functional Failures White

Performance Indicator

Open

Inspections in progress

2 Flood Restoration and Adequacy of

Structures, Systems, and Components

2.a Flood Recovery Plan actions associated

with facility and system restoration

Open

Majority of items

inspected and closed

2.b System readiness for restart following

extended plant shutdown

Open

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Item Number

2.c Qualification of containment electrical

penetrations

Open

2.d Containment internal structure Open

3 Adequacy of Significant Programs and

Processes

3.a Corrective Action Program Open

Inspected, Long term corrective actions under review

3.b Equipment design qualifications Open

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Item Number

3.c Design changes and modifications Open

3.d Maintenance Programs Open

3.e Operability Process Open

Inspected, Long term corrective actions under review

3.f Quality Assurance Closed

4 Review of Integrated Performance

Improvement Plan

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Item Number

5 Assessment of NRC Inspection

Procedure 95003 Key Attributes

5.a Design Open

Inspection in progress, Long term corrective actions under review

5.b Human Performance Closed

5.c Procedure Quality Open

Inspected, Corrective actions under review

5.d Equipment Performance Open

5.e Configuration control Open

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Item Number

5.f Emergency response Closed

5.g Occupational radiation safety Closed

5.h Public radiation safety Closed

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OPPD Discussion

Lou Cortopassi

Vice President and Chief Nuclear Officer

Omaha Public Power District

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NRC Remarks

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Contacting the NRC

• Report an emergency

– (301) 816-5100 (call collect)

• Report a safety concern

– (800) 695-7403

– Allegation@nrc.gov

• General information or questions

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1

Fort Calhoun Station

Driving Through Restart

Public Meeting with the U.S. Nuclear Regulatory Commission

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2

• Recovery Actions Completed –

People, Processes and Plant

• Progress Toward Restart

• Post-Restart Plan for Sustained

Improvement

• Independent

Assessment

• Closing

Remarks

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3

Progress Toward Restart

• Overarching causes of performance decline addressed for

restart

– Organizational Effectiveness

• Leadership, accountability, governance and oversight

– Safety Culture

• Leadership values and Safety Conscious Work Environment

– Problem Identification and

Resolution

• Corrective Action Program (CAP) effectiveness and bias for action

– Design and licensing

basis control

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4

• Improved safety and human performance – Ready for

Restart

– Developed and implemented a safety and human

performance strategy with accountability-driven expectations

» Rigorous work planning

» Discipline in completing work » Required procedure adherence » Supervisors and managers in the field monitoring work

performance

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5

– Established Human Performance Oversight

Committee

» Senior managers and department staff

» Review department performance weekly

» Maintain focus on human

performance strategies

• Performance monitoring • Training

• Communications

Fort Calhoun industrial safety and

human error rates are 1

st

_{quartile of}

U.S. nuclear power plants

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6

• Strengthened operational focus throughout the

organization – Ready for Restart

– Incorporated industry-best

practices into FCS operational

decision-making procedure

– Trained operators and

monitoring their behaviors in

» Using risk assessment tools » Anticipating system response during evolutions

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7

– Established and monitoring operational decision-making

expected behaviors

– All departments aligned in supporting Shift Manager for

safe operations

» Outage Control Center 24/7 safely controlling outage work

» Senior leadership providing direct oversight of operational safety focus

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8

• Corrective Action Program (CAP)

– Enhanced procedures, staffing and training

– Improved station and department corrective action

review boards

– Implemented detailed Exelon Nuclear

performance monitoring tools

– Marked improvement in problem

identification, root and apparent cause

quality, and timely action closure in

targeted work groups

– Ready for Restart

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9

• Systems evaluated for restart readiness

– System health readiness reviews of all important

systems

» Interdisciplinary team of

engineering, maintenance and

operations staff

» Focused on

• System performance, health

and maintenance

• Risk significant components

» Identified necessary actions to

be completed before restart

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10

• Containment Internal Structures (CIS)

– Fuel reload

» CIS analysis completed for fuel reload – structures remain operable

– Plant heat-up

» Analysis of reactor cavity and compartments and CIS being finalized for heat-up

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11

• Containment penetrations replaced

– All new penetrations installed

– Teflon material susceptible to radiation degradation

eliminated from containment integrity boundary

– All post-modification testing scheduled to be completed

for heat-up

(30)

12

• Electrical equipment environmental qualification

program

– Re-evaluated high energy line break analyses to develop

harsh environment profiles

– Analyzed equipment in harsh environments

– Initiated modifications to restore environmental

qualification of electrical equipment

– Actions being completed for heat-up include:

» Final field verifications and actions scheduled to be

completed before heat-up

» Complete final documentation of results

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13

• Equipment Service Life

– Identified and performed necessary preventative maintenance

tasks for safety-significant components

– Identified and implemented part replacement activities where

necessary

– All work completed for components

necessary for fuel reload

– Established a dedicated Project

Manager to focus on project

completion prior to heat-up

– All remaining work items scheduled

to be completed before heat-up

– 60% of post restart reviews

completed

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14

• Tornado missile engineering analysis and barrier

installation completed for fuel reload

– 14 separate changes for tornado missile barriers

installed in the plant

• Engineering analysis

and engineering

changes in progress

for plant heat-up

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15

• Significant safety enhancement regarding tornado

missile protection

– Aligned with current NRC requirements

» 4,000 pound automobile at

135 feet per second

» 287 pound 15 foot 6 inch

pipe at 135 feet per second

» 1 inch diameter solid

sphere at 26 feet per

second

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16

• Design and licensing basis control and use

– Actions completed before restart

» Developed key calculation review program for accuracy and consistency

• Completed Phase 1, Phase 2 in progress

» Performed structural walk downs of safety-related systems to ensure consistency with design

drawings

» Trained engineers and operators in utilizing the design and licensing basis for operability

determinations and safety screenings/evaluations » Monitoring engineer and operator work product

quality utilizing review comments and scores from independent Engineering Assurance Group

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17

• Design and licensing basis control and use

– Actions to be completed after restart

» Define model for form and content of design basis and licensing basis documents

» Reconstitute design and licensing basis in a desktop available platform

» Perform annual risk-significant system design reviews until completion of reconstitution

» Train station staff on utilizing new

design and licensing basis resources » Maintain Engineering Assurance

Group while necessary to provide independent oversight of engineering work quality

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18

• Developed new flooding mitigation system that is

beyond regulatory requirements

– Completed reactor analysis to support system design

– Procured equipment and constructed and tested portable system » Electrical generator with fuel supply

» Appropriate pumping systems

» Necessary piping, hoses and connections / fittings

– Revised abnormal operating procedures – procedures validated on simulator and during field walk downs

– Established equipment storage location – Finalizing emergency preparedness and

security procedures

– Developing preventative maintenance and testing procedures

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• Fuel reload milestones

– Equipment tested, surveillances

completed

– Personnel trained and qualified

to job assignments

– Reactor Engineers developed

reactor core reloading plan

– Submitted license amendment

request to implement current

NRC tornado protection standards

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20

• Implementing Consolidated Operational Plan

– Systems run and readiness verified

• Safety Systems

– Inventory make-up – Boration flowpath

– Emergency Diesel Generators – Radiation Monitors

• Primary systems

– Nuclear Instrumentation System – Shutdown Cooling System

• Cooling systems

– Raw Water System

– Component Cooling System – Spent Fuel Pool Cooling System

• Secondary systems

– Circulating Water System – Condensate System

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21

• Implementing Consolidated Operational Plan

– Integrated organizational performance

• Operations • Engineering • Maintenance • Chemistry • Radiation Protection • Security • Training

– Senior management oversight

and monitoring

– Independent oversight

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22

• Implementing Consolidated Operational Plan

– Operations department readiness

• Benchmarked operating plants and frequent external assessments of plant operations

• “Fast Cruise” just-in-time training • Shift mentoring during heat-up

– Monitoring system operation

• Critical Parameter Trending

– System Temperature, Pressures, Flows

• Equipment Monitoring

– Bearing temperatures – Vibration

– Thermography

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23

– Containment electrical penetrations replaced

– Emergency diesel generator voltage regulators replaced

– Equipment Service Life addressed (hundreds of component/part

replacements)

– 4160 Volt breakers replaced and maintained

– Reactor Protection System power supplies replaced

– Chemical and Volume Control System piping replaced with additional supports – Raw water pumps/motors overhauled

– Manholes 5 and 31 restored – Auxiliary feedwater pump motor

refurbished

– Various parts and components replaced to address environmental qualification – Extended Power Uprate modifications

• Main generator stator replacement • Isophase bus duct cooling enhancement • Nuclear detector well coolers modification • Supports for several systems modified • Heater drain tank modified

– Digital turbine controls installed – Main generator stator replacement

Progress Toward Restart – Plant

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24

Procedure Upgrade Project

– Alarm Response Procedures (ARP)

– Abnormal Operating Procedures (AOP) – Emergency Operating Procedures (EOP)

• Incorporated Industry Best Practices

• Added detail, clarified actions, enhanced technical detail

• Revisions in progress including

– Cross disciplinary reviews

– Field verification and validation of actions – Confirming procedure flow

– Corrections and enhancements cover extent of condition

Preparing the Organization

and Plant for Heat-up

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25

OPPD has completed early implementation of the

proven Exelon Nuclear Management Model (ENMM)

performance improvement Policy and Program, and

the procedure for the Performance Improvement

Integrated Matrix (PIIM)

Post-Restart Plan for

Sustained Improvement

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26

• Plan for Sustained Improvement (PSI) using the

PIIM has been developed and is in final review

• 78 detailed corporate, site and department level

action plans included in the PIIM

• Key Drivers for Achieving

and Sustaining Excellence

highlighted in the PSI

Post-Restart Plan for

Sustained Improvement

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• Key Drivers address multiple areas including

– Organizational effectiveness, safety culture, and safety conscious work environment

– Problem identification and resolution

– Performance improvement and learning programs

– Design and licensing basis control and use – Site operational focus

– Procedures

– Equipment performance – Programs

– Nuclear oversight

– Transition to the ENMM and integration into the Exelon Nuclear Fleet

Post-Restart Plan for

Sustained Improvement

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28

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• Actions taken to improve independent oversight

– Established OPPD policy and corporate nuclear safety oversight committee

– Established Nuclear Oversight Department – implemented Exelon Nuclear model

» New experienced leader

» Focus on behaviors that result in excellence – Strengthened Employee Concerns Program

– Implemented Exelon Nuclear Safety Review Board at Fort Calhoun

• Results

– Expectations clear – Assessments intrusive – Actively engaged – Reinforcing expected values and behaviors

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• Areas that require additional management attention

– CAP implementation with focus on engineering

• Timely completion of causal analyses • Closure quality and timeliness

– Design and Licensing Basis activities

• Engineering Assurance Group observations

• Quality records not maintained properly resulting in rework

• Areas found acceptable

– Management meetings and quality challenges

– Integrated Performance Improvement Plan and Plan for

Sustained Improvement after restart

Results of Nuclear

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Restart Checklist Item Issue Description Scoping Discovery Analysis Implementation

1.a Flooding Issue 100 100 100 72

1.b Reactor Contactor Failure 100 100 100 95 1.c Electrical Bus Mod and Maintenance 100 100 100 88

1.d Security Issue 100 100 100 100

1.e Safety Culture 100 100 100 100

1.f Organizational Effectiveness 100 100 100 100 1.g Safety System Performance Indicator *** *** *** 50 2.a Flood Recovery Restoration Actions 100 100 100 94 2.b.1 System Health Reviews 100 100 100 96 2.b.2 Reactor Safety Strategic Performance Area Review 100 100 100 100 2.b.3 Flood Impact on Soils and Structures 100 100 100 100 2.b.4 Containment Penetration Design 100 100 100 85 2.b.5 Containment Internal Structure Design 100 100 95 85

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Restart Checklist Item Issue Description Scoping Discovery Analysis Implementation 3.a Corrective Action Program 100 100 100 95 3.a.1 Identification, Analysis and Correction of

Performance Deficiencies 100 100 100 100 3.b.1 Safety Related Parts 100 100 100 80 3.b.2 Equipment Qualification 100 100 95 75 3.c.1 Vendor Modifications 100 100 100 70 3.c.2 10CFR50.59 Screening and Safety Evaluations 100 100 100 95 3.d.1 Vendor Manuals 100 100 100 100 3.d.2 Equipment Service Life 100 100 100 75 3.e.1 Operability Determinations 100 100 100 95 3.e.2 Degraded / Non-Conforming Equipment 100 100 100 95 3.f Quality Assurance 100 100 100 100