LIC-12-0165, Integrated Performance Improvement Plan, Revision 4

Integrated Performance Improvement Plan, Revision 4

ML12311A164
Person / Time
Site:	Fort Calhoun
Issue date:	11/01/2012
From:	Simpkin T Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-12-0165
Download: ML12311A164 (68)

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ým M Omaha PublicPower Ditric 444 South 16" Street Mall Omaha, NE 68102-2247 November 1,2012 LIC-12-0165 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

References:

1. Docket No. 50-285

2. Letter from NRC (E. E. Collins) to OPPD (D. J. Bannister), "Confirmatory Action Letter - Fort Calhoun Station," dated June 11, 2012 (NRC-1 2-0055)

3. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), "Fort Calhoun Station Integrated Performance Improvement Plan Rev. 3," dated July 9, 2012 (LIC-12-0098)

4. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), "Fort Calhoun Station Integrated Performance Improvement Plan, Revision 3, Security Flood Recovery Plan," dated July 9, 2012 (LIC-12-0099)

SUBJECT:

Fort Calhoun Station Integrated Performance Improvement Plan, Revision 4 In accordance with the commitments described in Reference 2, enclosed is Revision 4 of the Fort Calhoun Station (FCS) Integrated Performance Improvement Plan (IPIP). The Security portion of the Flood Recovery Plan is unchanged from Revision 3 of the FCS IPIP (References 3 and 4). As a result, Appendix B2 (Pages 157 through 166) has been removed from the enclosure.

If you should have any questions, please contact Mr. Bill Hansher at (402) 533-6894.

No regulatory commitments are contained in this submittal.

Sincerely, Terrence W. Simpkin Manager-Site Regulatory Assurance TWS/mle

Enclosure:

Fort Calhoun Station Integrated Performance Improvement Plan, Revision 4 E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector c)./

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TABLE OF CONTENTS Introduction ............................................................................................................................................................................... 3 Vision ....................................................................................................................................................................................... 3 M ission .................................................................................................................................................................................... 3 Values ...................................................................................................................................................................................... 3 Goals ......................................................................................................................................................................................... 3 Plan Overview ...................................................................................................................................................................... 3 D evelopm ent .................................................................................................................................................................... 5 Governance ....................................................................................................................................................................... 7 Organization ....................................................................................................................................................................... 11 A dm inistration .............................................................................................................................................................. 11 Plan Details ............................................................................................................................................................................... 12 Plant ....................................................................................................................................................................................... 13 People .................................................................................................................................................................................... 13 Leadership A lignm ent ................................................................................................................................................ 13 Organizational Effectiveness ................................................................................................................................... 14 Training ............................................................................................................................................................................ 15 Com m unications ........................................................................................................................................................... 15 Process .................................................................................................................................................................................. 15 Review of M anagem ent Controls ........................................................................................................................... 15 95003 A ssessm ents ......................................................................................................................................................... 16 Short-Term W ins .............................................................................................................................................................. 17 Plan Execution ........................................................................................................................................................................ 18 M anagem ent Controls and Perform ance M onitoring ................................................................................. 18 M anagem ent Controls ................................................................................................................................................ 18 Perform ance M onitoring .......................................................................................................................................... 19 Transition to Plant Operations .................................................................................................................................... 21 Post-Restart W ork ....................................................................................................................................................... 22 Transition to Sustained Exellence ............................................................................................................................. 22 Implementing the Exelon Nuclear Management Model ......................................................................... 22 M onitoring Progress ................................................................................................................................................... 25 Com munications Strategy .................................................................................................................................................. 26 A ppendix A : P6 Schedule .................................................................................................................................................... 27 A ppendix B: Flooding Recovery Plan ............................................................................................................................ 28 1

A ppendix 131 ........................................................................................................................................................................ 29 A ppendix B 2 ..................................................................................................................................................................... 157 A ppendix C: R estart Checklist Im plem entation Strategy ................................................................................... 16 7 A ppendix D: Perform ance Indicators ......................................................................................................................... 200 A ppendix E: Com m unications Plan ............................................................................................................................. 202 R evision H istory .................................................................................................................................................................. 239 2

INTRODUCTION Fort Calhoun Station (FCS) is currently under the oversight of U.S. Nuclear Regulatory Commission (NRC) Inspection Manual Chapter 0350 (MC0350), "Oversight of Reactor Facilities in a Shutdown Condition due to Significant Performance and/or Operational Concerns." Additionally, FCS is in the Institute of Nuclear Power Operations (INPO) Special Focus Program under Policy Note 14. To address the underlying causes that led to these conditions and chart the course to safe restart, continued performance improvement and return to performance excellence, Omaha Public Power District (OPPD) and FCS leadership recognized the need to establish an Integrated Recovery Team.

This team created the Integrated Performance Improvement Plan (IPIP), and drives the execution of the plan.

VISION Safe and efficient restart of Fort Calhoun Station and achievement of sustained excellence.

MISSION Safe, event-free, cost-effective, nuclear production of electricity.

VALUES

" Safety - Nuclear, Industrial, Radiological, and Environmental

" Alignment

" Accountability

• Bias for Action

" Strong Nuclear Safety Culture GOALS

" Create an aligned, accountable organization with clear individual roles and responsibilities

" Transform culture to one that drives and rewards timely problem identification and resolution

" Strengthen Organizational Effectiveness, Corrective Action Program (CAP) and Human Performance - the right Tools, the right Behaviors, right NOW

" Develop an operational focus that results in improved station performance, equipment reliability, and risk reduction

• Ensure ownership of the improvement initiatives

• Reestablish regulatory confidence

" Reinforce stakeholder confidence PLAN OVERVIEW There are a large number of activities required to be addressed simultaneously by OPPD at FCS related to problem discovery and resolution, performance improvement, restart readiness, and regulatory margin recovery. The purpose of the IPIP is to consolidate these activities to:

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• Embody the full scope of recovery by consolidating various existing plans and validating scope and approach

• Coordinate resources and efforts through resource-loaded scheduling

" Drive accountability by assigning action items to specific owners

• Provide insight into critical path, milestones, and dependencies

" Create vertical and horizontal alignment across the site through comprehensive communications of the plan site-wide

" Set the conditions for transition to the Exelon Nuclear Management Model The IPIP work schedule (link provided as Appendix A) shows the activities and tasks included in the plan. The activities and tasks are in one of three categories: Plant, People, and/or Process (the "3Ps"). The illustration below shows selected events that led to the current state as well as a general categorization of plan activities into the 3Ps. It is designed to create a baseline understanding across management and the plant staff. The intent of the timeline is to show the series of events that lead to the current situation. Below the timeline is a diagram that illustrates the path forward and a high-level inventory of the items that need to be addressed through the recovery. This part of the illustration shows the steps 0PPD will take to recover FCS.

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This plan, the supporting activities, and resulting schedule are living documents. That is, as additional issues, extent of condition, or other items of impact are identified, the plan will be revised.

Development Since the June 2011 flood, OPPD created several different plans to address the issues at FCS. These include, but are not limited to, documents related to flood recovery, engineering issues, and CAP.

These plans were in varying states of completion and had been created independently with little-to-no coordination between them. Upon its formation, the Recovery Team took the following steps:

0 Inventoried current plans 0 Challenged and validated scope 0 Conducted additional discovery 0 Integrated plans and added missing pieces 0 Entered refined plans and additional discovery findings into the Primavera P6 Enterprise Project Portfolio Management tool (P6)

As Found Revised Approach Integrated Performance Timeline Improvement Plan Level 2 detail in P6 by (IPIP)

Existin 2/13 stasnutagi schedule Additional discovery by Exelon team by 2117 RX a&"t - Fort Calhoun Level 3 & 4 detail for Am utevlei Critical/Near Critical items by 2/20 Integrated Performance Draft IPIP Executive Improvement Summary by 2/24 Plan EngneeIgbI abut. Level 3 & 4 detail for Mdntsn.,ce Issues Draft all known issues by Plan Consolidated Plan 2/27 Horizontal Reviews " Embodies full scope of MAssesft Corroding Critical/Near Critical by recovery Peromac 2/28

• Coordinates resources Deldce~ndee II GCPD) IPIP Rev 0 IPIP and efforts approved 3/6 " Drives accountability Rev 1 approved on

• Enables discipline and No high-level integrated rigor around execution 3/16 plan existed and management Rev 2 approved 4/24 Rev 3 target approval " Provides Insight Into 7/9 critical path, milestones, dependencies, etc.

The resulting schedule forms the core of the Integrated Performance Improvement Plan, which has been loaded into P6 for scheduling and tracking. Using this tool, each item is assigned an accountable party and completion date.

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Like other recovery items, the Flooding Recovery Plan, Revision 3 (FRP) actions, the Confirmatory Action Letter (CAL), and Restart Checklist (dated June 11, 2012) actions are included in the IPIP P6 schedule. The FRP is included as Appendix B to the IPIP and the Restart Checklist Implementation Strategy is included as Appendix C.

Additionally, the IPIP incorporates INPO's Eight Steps for Improving Nuclear Plant Performance.

These eight steps were compiled through a review of successful plant performance turnarounds accomplished by several major U.S. utilities over the past decade. Input from executives involved in developing the turnaround strategies, preparing the plans, and executing initiatives was included in the steps presented by INPO. The following are the key elements that will provide the means to move the plant toward excellence:

1. Establish Sense of Urgency

2. Align the Leadership Team

3. Develop or Revise Vision, Goals and Plans, Management Controls and Performance Monitoring

4. Communicate the New Vision and Goals

5. Engage the Workforce for Broad Based Action

6. Create Short-Term Wins.

7. Consolidate Gains and Produce More Change

8. Ingrain New Approaches in the Culture Significant additional consideration was given to the INPO-identified attributes of a high-performing nuclear plant organization:

• Strong leadership

• Self-critical

• Operationally focused

" Exceptional equipment performance

• Training to improve performance As we work to change the culture at FCS, these five attributes will help shape the future state.

Regulatory Interaction While under Inspection Manual Chapter (IMC) 0350 oversight, a decision to restart the plant not only requires the endorsement of Fort Calhoun Station management, but also needs agreement from the NRC.

OPPD and the NRC have agreed upon a "Restart Checklist" and this formal Checklist has been provided to OPPD in a publically available CAL dated June 11, 2012. This CAL describes the commitments that OPPD has made to:

" Understand the causes and implement corrective actions for the significant performance deficiencies as addressed in Restart Checklist Sections l.a through 1.d

• Conduct a third-party safety culture assessment and integrated organizational effectiveness assessment as addressed in Restart Checklist Sections 1.e and 1.f and implement actions to address the findings of those assessments 6

" Update and implement the FRP and assess and improve the plant as addressed in Restart Checklist Section 2 to assure it is adequate to support safe restart

" Assess and improve the programs and processes addressed in Restart Checklist Section 3 to assure that they are adequate for safe restart

• Submit and implement this IPIP, including a schedule for completing the recovery activities

• Provide a written report to the NRC on the completion of the recovery actions and the basis for restart readiness Restart is defined in the CAL as entering Operating Mode 2; the reactor will not be made critical and operated "above Hot Shutdown Condition (Operating Mode 3)" until the NRC has completed its review of the FCS recovery actions.

To ensure alignment with the NRC and across all OPPD and contractor personnel working on Restart Checklist items, the "Restart Checklist Implementation Strategy" was developed and provides additional detail and guidance on the basis for, the scope of, and the tasks necessary for completion of each Restart Checklist item. It is attached to this Integrated Performance Improvement Plan as Appendix C.

OPPD is developing a set of metrics to provide insights on recovery progress as shown in Appendix D and will discuss recovery progress with the NRC at regular public meetings.

Restart Issue Definition The first phase of the recovery process includes the conduct of multiple root cause assessments, organizational effectiveness and cultural assessments, and discovery activities to bring more clarity and granularity to the scope and depth of the performance issues at FCS. Emerging from these discovery activities and assessments will be a large number of Condition Reports within CAP precipitating a large number of corrective actions and actions to prevent recurrence. Some of those actions will be necessary to be completed before restart and some will become part of the post-restart plan for sustained improvement, which will be developed as the later stage of the IPIP.

OPPD has developed a set of safety-based criteria for categorizing those actions necessary to be completed before restart. These criteria will be applied by the Recovery Overview Panel which consists of a minimum of three members with Senior Reactor Operator certification and a Design Engineer Supervisor or representative.

Governance The OPPD Chief Executive Officer (CEO) has ultimate accountability for the recovery and restart of the plant. The OPPD Chief Nuclear Officer and Site Vice President (CNO/SVP) has overall responsibility for the execution and success of the IPIP. The CNO/SVP has decision authority on restart of FCS given NRC agreement. The Chief Recovery Officer (CRO) is responsible for providing advice to the CEO and CNO on recovery, restart and plant-related matters and has direct responsibility for those items delegated organizationally to the recovery team. The CEO, CNO/SVP, and CRO will receive advice and insight from regular accountability. discussions with direct reports, as well as input from Nuclear Oversight, OPPD executives, Exelon senior leaders, and the SARC. At 7

his discretion, the CNO may call upon a restart readiness expert or form an advisory panel to provide insights on recovery progress and restart readiness.

Recovery and Outage Monitoring Activities A recovery project management team operates a Recovery Control Center where the Recovery Lead and direct reports conduct plan status updates and coordinate and prioritize planned activities and schedules related to the performance of the recovery tasks. In addition, there are daily station meetings (Plan of the Day and Daily Outage Meeting) with a broader group of plant and recovery personnel designed to align and integrate efforts across the station. These meetings serve to sharpen the prioritization of work activities and focus of the station and recovery team.

Scope Control An effective recovery scope approval and control process ensures the restart objectives are achieved while reconciling scope changes such that tasks can be added/altered with appropriate controls over critical deadlines, quality, and cost. The recovery scope control process maintains flexibility allowing critical changes to be incorporated into the restart scope and filters non-restart scope into the station post-restart Plan for Sustained Improvement.

The recovery team has instituted the Recovery Scope Approval Committee (RSAC) to review and approve problem definition, initial discovery scope, and scope expansion criteria, and set thresholds for cost and schedule change that would require approval by the RSAC. The RSAC is comprised of recovery team and station management so that scope approvals are aligned with station priorities.

Issue owners are required to present scope items to the RSAC committee for approval. The RSAC committee approving members are the area manager, the Engineering Director, and the Senior Recovery Manager. The RSAC process itself is designed as a project management tool to facilitate scope approval, control, and the management of resources and tasks. It builds from the information documented in CAP and does not replace any elements of CAP. The process and documentation necessary for identification, review, and closure of deficiencies are contained in station procedure SO-R-2, "Condition Reporting and Corrective Action." As shown in the process diagram below, the problem statement and plan to resolve as documented in CAP are also documented on the RSAC form. In this manner, CAP maintains the quality documentation of the problem and how it is resolved; the RSAC process enables effective project management of the tasks required to resolve the problem.

8

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Common Process Key milestones required to resolve the problem are documented in CAP, whereas the RSAC process hones in at the detailed task level. This is the key difference between CAP documentation and the RSAC process. CAP and RSAC processes are used synergistically; the RSAC process does not circumvent nor subvert CAP. As detailed tasks are performed, as documented in the RSAC form, any adverse conditions identified are documented via condition reports (CR) in CAP. The review, evaluation, and closure of each CR entered into CAP are accomplished according to CAP.

As tasks are completed, new issues are entered into CAP. Each of the CRs is coded based on the issue identification and a collective evaluation of the CRs is performed through cause analysis. The results of the collective evaluation are also fed back into CAP, such that corrective actions can be developed and tracked to completion to prevent recurrence. All of the CR reviews and collective evaluation reviews are performed according to the quality requirements of CAP. In this manner, the station management approves CAP products as prescribed by CAP requirements.

RSAC committee packages, signed Issue Status & Scope Approval & Control forms, meeting minutes with action item list, calendar of meetings, templates, and other relevant information/documents are housed on a SharePoint website for recovery team members to access. These scope control elements help to ensure the required recovery objectives are accomplished within the allotted schedule and cost. Further details and sample forms can be found in FCSG-65, FCS IMC-350 Recovery ProjectAdministrative Controls.

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Inspection Readiness Structure The NRC will review or inspect each of the Restart Checklist items at multiple stages:

• The IPIP Restart Checklist Implementation Strategy, the RSAC approved problem definition, scope, and scope expansion criteria, and the discovery implementation procedures or guidelines will be reviewed by the NRC to assure alignment between the NRC and OPPD on expectations under each Restart Checklist item.

" Once discovery is complete for a Restart Checklist item and identified issues are entered into the Corrective Action Program, the NRC will confirm the adequacy of the scope and depth of the discovery activities and the actions to fix and prevent recurrence of the performance problems.

" Prior to restart, the NRC will confirm that the People, Plant and Processes at FCS are ready for restart. This will involve selected review of completed corrective actions and actions to prevent recurrence, evaluation of effectiveness assessments and assessment of operational readiness, including around-the-clock observation of facility operations.

The preparation for inspection activities are described in FCSG-65-2, Issue Closure/NRC Inspection Readiness Guideline. The purpose of the document is to provide guidance on:

" Developing a package for NRC inspectors to facilitate their inspection of the Recovery Issue (RI) and provide a clear, consistent, and transparent understanding of how the RI was resolved

• Completing inspection readiness reviews for issues that are associated with the NRC IMC 0350 evaluation of Fort Calhoun Station's restart

• Determining NRC Inspection readiness

" Supporting execution of the inspection The Licensing Staff will coordinate closely with the assigned inspectors to assure effective coordination on the scheduling and facilitation of inspections.

Additional Oversight.

In addition to the OPPD and FCS executives and management, there are several additional boards and organizations that play a key role in providing oversight to the recovery and performance improvement process. This includes:

• Engineering Assessment Board - expert group in place as an interim measure to assure high confidence in the quality of engineering products (PED-HU-3, EngineeringRisk and Rigor)

• Station Corrective Action Review Board, Department Corrective Action Review Boards and Condition Review Group - standing groups that provide high confidence in the effective implementation of the corrective action program

• Plant Review Committee - existing station committee to provide oversight of operating issues and activities and provide high confidence in safe approach to restart

• Plant Health Committee - existing station committee which provide high confidence in system readiness for restart

• Nuclear Oversight (NOS) - permanent organization responsible for providing independent assessment of station organizations and activities 10

• Safety Assessment and Review Committee - independent assessment of station performance with feedback to station management, the CEO, and CNO

" Corporate Governance and Oversight Committee - independent of the nuclear chain of command, reports to the OPPD Board of Directors and the CEO. Provides strong, intrusive, and frequent independent oversight Additional boards and committees may be convened if additional needs are identified.

ORGANIZATION The IPIP will be executed by the Integrated Recovery Team. The team is structured to provide clear roles and responsibilities around each area in the recovery scope. The team is staffed with as many station personnel as possible to facilitate continuity once normal operations resume. This was balanced with the need to allow sufficient station staff to keep up with urgent work related to day-to-day station operations. Supplemental personnel are used where station personnel or expertise was not available. Each area has a lead that is accountable for results in their area.

Administration The IPIP is maintained up to date by the Recovery Project Director or his designee. The IPIP is published to the FCS HOME web page and updated versions posted as revisions are made. The recovery schedule has been developed in and tracked using P6 and schedule documents will be published to folders linked to the FCS HOME web page.

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PLAN DETAILS The purpose of the IPIP is to return FCS to sustained excellent performance. The primary phase of this effort will result in the plant in a ready-to-restart condition. The focus is on issues around the plant, processes, and people. Although each aspect encompasses numerous issues, actions, and tasks in the plan, the general process followed is:

1. Discovery

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2. Cause AnAysis

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1. Some items are fully developed and do not require additional discovery; however, most issues require further data gathering and analysis. This confirms that the scope identified for recovery in a given area is of appropriate breadth and depth. This phase is designed to provide an opportunity for further problem identification and characterization.

2. Issues requiring cause analysis where the cause analysis has not been completed undergo this determination through the execution of the IPIP.

3. Once root causes are determined, corrective actions are developed and implemented.

4. When corrective actions are in place, they will be monitored for effectiveness.

5. The area will be deemed to be ready for restart in accordance with FCSG 65-2.

An exception to the linear process is in our approach to improving problem identification and resolution. At FCS, this is mainly addressed through CAP, NOS, and components of organizational effectiveness. Experience tells us that corrective actions and common cause determinations will show common themes across all areas:

" Equipment is broken and needs to be replaced

" Personnel did not properly utilize or adhere to procedures

" Accountability for performance is insufficient Given this, the approach that we deem to be most efficient and effective is to address CAP, NOS, and organizational effectiveness now, in parallel with the additional discovery and causal analysis. That way, when the causal analysis determines that there were deficiencies in accountability, for instance, corrective actions will already be in place.

The overall framework of the IPIP follows three focus areas: Plant, Process, and People:

" Plant - Safely managing the station to restart-readiness. This includes most of the engineering technical issues and issues related to the physical condition of the plant.

" People - Building an engaged, thinking organization that identifies problems, implements timely and effective corrective actions, and regains regulatory and industry confidence.

This addresses cultural and leadership aspects of the organization.

" Process - Developing the infrastructure for sustained excellence. This is the programmatic codification of the approach to work at the plant.

Categorization into these areas is not absolute. Each detailed component of the plan may have implications for one or more of the 3Ps. For instance, the resolution of an item categorized as 12

"plant" will likely involve some hardware changes but could also involve corrective actions with respect to people and processes. Also within each of the 3Ps are "short-term wins" designed to buoy FCS morale, develop a sense of urgency, and a winning momentum. Each is described in greater detail below.

In order to establish accountability deeper in the organization, department, system, and other key components of restart readiness will be verified by key personnel. This will occur more broadly and in greater detail than a typical mode change checklist due to the length of shutdown and the extent of needed changes suggested by analysis.

Following the return to ready-to-restart condition, the IPIP will focus on setting the conditions for FCS to achieve sustained excellent performance. This will mainly stem from the transition to the Exelon Nuclear Management Model. Detailed transition plans for each functional area will be created along with implementation schedules that include management challenges and substantial input from Exelon functional area managers and subject matter experts.

PLANT The Plant items are those related to safely managing the station to restart-readiness with respect to the system readiness as well as operations, maintenance, and engineering technical and physical condition issues. This part of the plan will evolve further as discovery and cause determinations clarify the precise fixes required. The focus is on addressing those items required for station restart inspection readiness. Post-restart items will continue improvements to the plant via work items not required for restart.

PEOPLE This part of the IPIP describes the steps needed to build an engaged, thinking organization that identifies problems, implements timely and effective corrective actions, and regains regulatory and industry confidence. This includes cultural and leadership aspects of the organization. Several key areas are explained in more detail below. These initiatives will continue well past restart; some are permanent changes to personnel and the way we manage them.

Leadership Alignment The IPIP recognizes that alignment of the leadership team is integral to the effective execution of the recovery. The primary vehicle for alignment is the IPIP. Leadership will develop confidence in the plan and commitment to following the schedule, and hold each other and the team accountable for results. In conjunction with the IPIP, the communications plan, the Leadership Assessment completed in late 2011, and several standing meetings are designed to further foster alignment.

Leadership Assessment An external leadership assessment of the CNO through first line supervisors was completed in 2011. We will review the results and incorporate actions to address gaps and develop personnel into the Organizational Effectiveness section of the IPIP.

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Standing Meetings In addition to the periodic station-wide all-hands meetings outlined in the communications plan, there are three key meetings designed to promote alignment:

• Regular Recovery Team Meetings - weekly alignment meetings with the recovery team ensures that work under each discipline is progressing to achieve the same end goal in a synchronized fashion

• Leadership Alignment Meetings - weekly meetings between station leadership and the Chief Recovery Officer and/or OPPD CEO and CNO. Provide information and talking points for leadership to communicate back to the line

" Daily station meetings (Plant Plan of the Day, Daily Outage meeting) - several times daily personnel dedicated to recovery projects and personnel dedicated to daily plant operations confirm key focus areas and update status The goal of these meetings is to convey a clear set of priorities for the station and ensure that personnel are aligned and driving towards the stated vision.

Organizational Effectiveness A top-down accountability model is central to reviving organizational effectiveness. Implementing this accountability model and aligning personnel performance management with it is key to achieving stakeholder confidence. The illustration below shows that the organizational effectiveness pieces of the confidence model are at the top of the pyramid and therefore critical to effectiveness and achieving confidence.

Confidence Model Culture of Accountabili1 Problem Identification and Resolution Process Personnel Trained and - t Qualified Processes and Procedures in Place High -reof Design and Licensing Basis -u Key to effective creation of a culture of accountability is analysis and understanding of the current state of organizational effectiveness and its deficiencies. An organizational effectiveness root cause 14

analysis will provide the assessment and establish corrective actions for improvement. These will become part of the IPIP.

Additionally, OPPD commissioned an Independent Safety Culture Survey in early 2012. The results of the survey are driving corrective actions designed to ensure that OPPD maintains a safety conscious work environment at FCS and the desired level of employee engagement and buy-in to drive accountability.

The Corrective Action Program is already in place as the primary tool for problem identification and resolution. However, CAP was not fully effective as implemented. A new CAP process has been implemented and root cause analysis on topics such as Condition Report quality continue to create improvement actions.

In all cases, the goal is to cultivate the right behaviors aligned with our vision and goals. We will reinforce this by reinstituting and linking individual performance plans to expected accomplishments and institute effective performance management.

Training Throughout the IPIP and across the 3Ps, achieving the desired results will require changes and improvement to current approaches, resetting expectations, refreshing understanding, and retraining on standards - to name a few. As we identify opportunities or needs for training support to make these endeavors effective, we will engage the training organization to apply a systematic approach to training. Training is recognized as a valuable tool for changing behaviors in the organization.

Communications A communications component is central to the IPIP. The communications plan includes cascading initial messages around the plan as well as detailed updates to the station and other stakeholders on a regular basis. For additional details, see the Communications Strategy section of this document.

PROCESS Processes are the infrastructure for sustained improvement. They are documented in policies, programs, procedures, etc. They are the programmatic codification of the approach to work at the plant. As such, they are the key management controls. The IPIP contains steps to identify gaps in existing management controls. This will result in modifying existing programs, or instituting new ones. Some of these will need to be addressed prior to restart; others will be addressed as post-restart initiatives.

Review of Management Controls The IPIP contains steps to identify gaps in existing management controls. To maintain momentum, we will execute the plan using the "as found" controls recognizing that we will identify cases where we need to modify existing programs or institute new ones. We will use the Exelon Nuclear Management Model in the gap analysis to assess the adequacy of management controls and specific 15

areas of focus for improvements needed. Additionally, as detailed in the Transition to Sustained Excellence section, the Exelon Nuclear Management Model will be implemented after broader gap analysis to be completed after restart.

95003 ASSESSMENTS The intent of the NRC's Inspection Procedure (IP) 95003 is to obtain a comprehensive understanding of the depth and breadth of safety and organizational, and performance issues at facilities for which data indicates the potential for serious performance degradation. The multiple degraded cornerstones at FCS placed the station under 95003.

In response, FCS formed a 95003 Recovery Team whose responsibility was to complete assessments of the following three major areas of NRC IP 95003:

1. Identifying, Assessing and Correcting Performance Deficiencies

2. Independent Nuclear Safety Culture Assessment (INSCA)

3. Reactor Safety Strategic Performance Area (RSSPA)

4. Radiation Safety Strategic Performance Area - Occupational Radiation Safety

5. Radiation Safety Strategic Performance Area - Public Radiation Safety

6. Safeguards Strategic Performance Area Additionally, from the above assessments, the team would provide input in the development of action items to be included in the IPIP to address the causes of the FCS performance deficiencies and gaps.

The Team would work through four phases:

• Discovery

" Analysis

• Inspection

" Implementation The figure below depicts the 95003 Discovery process.

16

Oct 12 (FPO) Fundamental Performance Deficiencies. Some PARs may be significant enough to be an FPD by itself or several grouped together to become a Fundamental Performance FPD Deficiency.

July 27 (CE) Collective Evaluation or binning of the PARs and other inputs to identify common themes/issues.

July 7 (PAR) A Performance Area Report is developed for each key review area. Problems will be discussed in each PAR for use in the Collective Evaluation.

(PDS) Problem Development Sheet Some Findings by themselves or grouped together may become problems discussed on a Problem Development Sheet-(F) Findings: Some Observations by themselves or grouped together may become Findings. A Fkidn is a condition that does not meet requirements of procedures, policies, accepted industry standards, fads to meet regulatory requirements, or represents a significant weakness or gap to excellence.

(0) Observations are a collection of facts gathered during review of documents, from interviews, or from field observations.

The Analysis process also includes Causal Analysis/Assessment for Fundamental Performance Deficiencies and Action Item Development to address them.

The Inspection Phase involves NRC inspection activities to comply with NRC IMC 0350, the Reactor Oversight Process and Inspection Procedures 95003, 95002 and 95001, as applicable.

The Implementation Phase involves implementing appropriate corrective actions from the FPD causal analyses. Also included is the corrective action closure review per NOD-QP-42.

Additional details can be found in NP-95003-ADMCONTROLS, Administrative Controlsfor 95003 Work Scopefor Station Recovery.

The results of the 95003 team's work are documented in reports available on the Recovery SharePoint site located at this link.

SHORT-TERM WINS The IPIP includes "short-term wins" designed to reinforce positive behaviors and recognize accomplishments. This will buoy OPPD morale, develop a sense of urgency, and a winning momentum. Short-term wins are quickly executed and are sometimes identified on an ad-hoc basis.

Additional short-term wins will be celebrated as they are identified and implemented.

17

PLAN EXECUTION The IPIP will be executed with the discipline and rigor typically associated with station outage plans. It will be reinforced by regular performance monitoring and rigorous management controls.

MANAGEMENT CONTROLS AND PERFORMANCE MONITORING To keep the plan execution on track and to ensure that the activities are producing the required results, OPPD will consistently apply a program of performance monitoring and management controls.

Management Controls Management review meetings are conducted at several levels for the core of performance monitoring in the IPIP. Each meeting has a standard attendee list and standing agenda:

Meeting____ FrequecyAtendee Agenda~

Plan of the Day Daily Recovery Report-out of action item status and (morning) Leads and results. Challenge progress and Plant effectiveness.

Leadership Senior Leader Daily SVP/CNO and Alignment and progress towards Turnover and (afternoon) direct reports realizing mission, vision, values.

Alignment Meetings Leader Alignment Weekly SVP/CNO and Alignment on priorities, goals, progress Meeting plant for the week.

leadership Outage Meeting Daily Recovery Report-out of action item status and (afternoon) Leads and results. Challenge progress and Plant effectiveness.

Leadership Recovery Meetings 1 x Daily Recovery Lead, Report-out of action item status and Recovery Team results. Scope includes outage and Leads, other daily plant work items. Challenge Engineering progress and effectiveness.

Director, Plant Manager Senior Team Daily CEO, CNO, Alignment meetings to ensure clear Operational Chief Recovery picture of progress across the Readiness Meeting Officer, leadership team and provide guidance (STORM) Recovery Lead to the Recovery Lead.

Management Review Every 4 - 6 Chief Recovery Reviewing and assessing current Meeting Weeks Officer, performance against desired Recovery Lead performance and goals.

NOS Review Ongoing NOS Lead, Contains components of internal and others as external independent oversight with required regular report-outs.

18

Additionally, existing management controls remain in place, including existing station procedures such as the contract approval process, and boards and committees such as Corrective Action Review Boards (CARB) at the department level and the Safety Audit and Review Committee (SARC) at the station level.

Performance Monitoring A distinct suite of metrics is used to track the progress and effectiveness of the IPIP. These metrics, as well as standard ECS plant performance metrics, will be published in monthly communications to all site personnel. Key areas of monitoring are listed below.

Schedule Schedule adherence and milestone achievement are the focus of recovery-specific metrics. They are monitored using work-down curves. Task leads will present their work-down curve on a regular basis to demonstrate progress and enhance accountability. A work-down curve of all team tasks is used to track overall team adherence. A sample of the overall recovery work down curves is shown in Attachment D.

Readiness The majority of the existing station performance indicators will be used to show system and program readiness for restart. An annunciator of these indicators as well as the System and Program Health reports will be prepared and reviewed regularly by the station and recovery leadership. Attachment D has an example of this annunciator. The supporting Performance Indicators can be found here:

http:!/insideoppd/Divisions/FcsHome/1nformation/fcspis/pi2012/Aprl2.pdf Department or functional area readiness for restart will be assured by challenge boards.

Performance indicators to support this will be presented in an indicator matrix that tracks the progress of each department's completion of readiness milestones. Color coding will be used to indicate whether activities are complete, on track, or behind schedule. A sample section for three departments is shown below. All 18 departments will be displayed similarly:

19

Restart checklist items, from discovery to inspection, will be displayed as a large chart distributed throughout the station to visually communicate the progress of the recovery to all personnel.

Sample sections of this chart are shown below. Color coding will be used to indicate whether activities are complete, on track, or behind schedule. All checklist items will be shown similarly:

20

Safety and Quality Safety and human performance goals for recovery will fall under existing station metrics. These include items such as clock resets, OSHA recordable events, and Human Performance events. They are published regularly on the FCS home page located here:

http:I/insideoppd/Divisions/FcsHome!Information/fcspis/Pages/smpirpts.aspx.

TRANSITION TO PLANT OPERATIONS The transition to plant operations will be deliberate and well-planned and executed. Based on industry experience, we intend to avoid the danger of declaring victory too early. Exiting IMC0350 oversight and meeting other regulatory milestones are only part of what is necessary. OPPD must consolidate gains and ensure that improvements are ingrained in the culture. The causal analysis and corrective actions implemented from our broad-based discovery activities forms the 21

foundation for the successful transition to plant operations. Formal tracking and closure of post-restart actions will be maintained.

Post-Restart Work We anticipate that some amount of work will remain to be done after the restart of the plant. This work remains from the 95003 corrective actions, IMC 0350 checklist items, and Confirmatory Action Letters. Additionally, the Flooding Recovery Plan contains post-restart items, as does the CAP and other standard sources of work such as work orders and surveillances. Addressing this will include physical work to the plant and actions related to people (e.g., organizational effectiveness monitoring) and processes (e.g., controlled documents improvement and implementation).

Some of this work will be addressed during the transition to the Exelon Nuclear Management Model (see below). The remainder will be captured in work inventories that will enable planning, scheduling, and execution of the work and ensure that augmenting resources are employed as needed. Tracking the work and backlog of work through the inventories and associated metrics will enable OPPD to understand and drive the backlogs down to manageable levels and manage risks associated with unsolved problems or work not completed.

TRANSITION TO SUSTAINED EXELLENCE As noted in the timeline on page 3 of the IPIP, the journey from recovery through Plant Restart to the goal of sustained excellence is a multi-year effort. The IPIP will include triggers to disband the Integrated Recovery Team and execute a transition to sustainable plant operations. Senior management will challenge that these triggers have been met and that the IPIP contains plans for sustained improvement and addresses latent issues that may emerge.

The final transition to the Exelon Nuclear Management Model and into the Exelon fleet will complete the transition from the IPIP.

Implementing the Exelon Nuclear Management Model In August 2012, OPPD entered an Operation Services Agreement with Exelon that includes the implementation of the Exelon Nuclear Management Model at FCS and the integration of FCS into the Exelon fleet for purposes of fleet operational and technical support as well as the fleet rigor around operational excellence. This will provide the framework for FCS to achieve sustained excellence in the same manner as other plants in the Exelon fleet The integration effort will be conducted as a multiphase project managed by a centralized team of key managers. Each phase benefits from the work products of its predecessor, so continuity throughout the process is critical. There are five major phases of integration activities. The functional areas will proceed through the phases in two groups. Feedback and lessons learned will be incorporated into the process throughout execution.

22

Phase I - Framework Development The purpose of this phase is to establish an appropriate foundation for the integration process.

Integration teams are formed and chartered, and decision-making and issue-resolution processes are established. In addition, appropriate roles and responsibilities for each level of the project oversight hierarchy are defined. Tools and templates are created.

Phase II - Analysis The focus of this phase is on the identification of "gaps" between the FCS's current state and the Exelon Nuclear baseline in a variety of areas, including: Management Model, organization structure, process flows, policies and procedures, performance metrics and benchmarks, and best practices among entities. The first part of this phase will focus on identifying any needs for "accelerated implementation" that will result in elements entering an abbreviated process to enable implementation by mid-December 2012. At this point, Analysis will "pause" to enable resources to support FCS restart efforts. Analysis will conclude with focused site visits after restart (100%

power + 30 days). The overall output of this phase is a high-level definition of what needs to be changed to align FCS to the Exelon Nuclear Management Model, structure and operating philosophy. The Analysis phase is the first part of the functional area assessments.

Phase III - Design During this phase, a detailed description of the proposed end-state for FCS is developed. The recommended suite of controlled documents is outlined. Specific corporate and site organization structures and staffing levels are defined. Key enablers are identified in detail, with organizational inter-dependencies outlined. Performance Indicators are defined and recommendations for IT systems detailed. Any support requirements for FCS from other affiliates (such as Exelon Business Service Company) or other business units within Exelon must be also be defined in detail. The Design phase is the second part of the functional area assessments. The basis for the design is the Exelon Nuclear Management Model and standard organization (using the Exelon standard for a single-unit site as the model for comparison).

Phase IV - Implementation Planning The purpose of this phase is to develop an actionable implementation plan to achieve the end state.

A detailed schedule is created with resource loading, accountability assignments and completion timing defined. Any internal (and external) schedule dependencies are also determined.

Coordination with Site Functional Area Managers (SFAMs) and use of appropriate change management are keys to a successful plan.

Phase V- Implementation Key activities during this phase include the turnover of all implementation responsibilities to line management and the establishment of appropriate on-going progress monitoring mechanisms.

The integration effort will be completed as one continuous project, with five phases. The functional area teams, led by the Corporate Functional Area Mangers (CFAMs), will remain accountable through turnover to site management. CFAMs will, through their ongoing accountabilities, have oversight responsibilities during implementation.

23

Throughout Throughout all phases of the project we will continue to look for "quick hit," high-impact changes that establish management control, provide immediate operational improvement and result in early wins. These will also help maintain a sense of urgency with team and station personnel.

Likewise, we will seek opportunities to celebrate victories when appropriate.

Additionally, special topics are likely to arise throughout the integration that will require attention outside of the functional areas. Examples of these special assessments may include the budget process and the institution of workforce fundamentals.

To allow line management to focus on work related to safely restarting the station, integration and implementation will be led by a dedicated project team or "Transition Team."

The team will be led by an Exelon senior manager and supported by a full-time project management support. The Transition Team lead will take direction from Exelon's Senior VP, New Development.

Other CFAMs, SFAMs, and subject matter experts (SMEs) will be brought in to play central roles in performing the analysis, design, and implementation planning if needed.

The overall timeline and approach is depicted in the figure below:

Key Events Early Analysis 10/20- Int im Report-A~t Accelerated Implementa-tion Station Restart F Provide 0 ersight and Sjpport I C I ~ 12/7 - I~riem Report+-jt GroupA*

I4 3/15 - Analy s Part 2 (Site Visits) 9 - Challengi

'6/10- Clallenge 1 1 3 5 1 Group 8* I I ~ 12/7 - i4~rim Report4Aut --- V112- A-nalys IPart 2(Site /isits) 1lA- Ck..I,.

ge I,

17/5 hallen I I The functional areas are divided into two groups based on priority and to enhance manageability of the process. The groups are as follows:

Operations Rad Protection Maintenance Chemistry/Environmental/Radwaste Work Management Fuels 24

Outage Management Supply Project Management IT Systems Engineering HU/Safety Programs Engineering Performance Improvement Design Engineering Licensing PRA Communications Training Security Nuclear Oversight Business Operations EP HR/MD Records Management Monitoring Progress A critical characteristic of the Exelon Nuclear Management Model is the rigor and discipline with which Exelon plants approach Management Review Meetings (MRMs). The focus of an MRM is to hold the organization accountable for performance and workforce goals in Operational Execution, Production, Cost, and Collective Radiation Exposure. In addition, the effectiveness of continuous improvement initiatives will be reviewed as well as specific site abnormal or unexplained conditions. This standardized process provides strong oversight of site activities, ensuring that people, process, and equipment support superior performance. Exelon-style MRMs will be phased in at FCS and will continue as the standard to monitor progress and ensure that management model implementation and the achievement of excellent performance continue.

Additionally, participation in Exelon fleet activities, such as daily plant status calls, and the oversight provided to the site by CFAMs will ensure that FCS performance is constantly evaluated and is not overlooked.

25

COMMUNICATIONS STRATEGY The Communications Plan supports the implementation of the Fort Calhoun Station Integrated Performance Improvement Plan. It is key for all employees (our people) to fully understand and be able to act upon the critical priorities, and this will mean adopting behaviors that will change our culture now and in the future.

Clear information is power, and this plan is designed to empower our people to bring Fort Calhoun Station back online and back to the forefront of nuclear excellence. The cultural change necessary must be more than sustainable; it must become part of our corporate DNA.

The plan builds on OPPD's vision of being recognized as the ideal utility, with a mission of delivering energy services that exceed the expectations of our customers. It uses the corporate values throughout and will remain flexible to respond to changing events. Additionally, it reinforces the OPPD vision of sustained excellence.

The communications plan includes a number of steps, some already underway, that are divided into three basic phases: build a foundation of change, solidify and build on that foundation, and lock that change into our DNA for sustainability.

L(--)ck that chinge

6. Prorwite positive resLdtý & behavior into otir DNA Sr-lidifV "'Ind Wild on th,)t foundatioii

2. Create,, dim,'tte for chawle BL111d il fOLIndafion Ph&$*' of Change Additional detail can be found in the Communications Plan included as Appendix E.

26

APPENDIX A: P6 SCHEDULE The P6 schedule can be accessed through the OPPD intranet using this link:

http://insideoppd/DIVISIONS/FCSHOME/Pages/default.aspx 27

APPENDIX B: FLOODING RECOVERY PLAN The Flooding Recovery Plan is attached in two sections. Appendix B I is the main Flooding Recovery Plan which is appropriate for public disclosure.

Appendix B2 is the Security portion of the plan should be withheld from public disclosure in accordance with the requirements of 10 CFR 2.390. The pages have been marked accordingly with the notation "Security-Related Information - Withhold Under 10 CFR 2.390."

28

APPENDIX Bi 29

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION FLOODING RECOVERY ACTION PLAN REVISION 3 30

Fort Calhoun Station Flooding Recovery Plan - Revision 3 FRP Revision Log Revision Date Description 0 8/10/11 Initial issuance 1 8/30/11 Updated some individual action items and/or deliverables, and changes in format and numbering. Added sections 4.5 and 4.6.

2 Not Issued 3 7/2/12 Updated and revised action items and/or deliverables.

Changes from the Rev I Flooding Recovery Plan are described.

31

Fort Calhoun Station Flooding Recovery Plan - Revision 3 Table of Contents Section 1 Recovery Plan Overview Section 2 Assessment and Restoration Focus Areas Section 3 Action Plan Summary Section 4 Internal and External Oversight FRP Flooding Recovery Action Plans Appendix A FRP Removed Flooding Recovery Action Plans Appendix B 32

Fort Calhoun Station Flooding Recovery Plan - Revision 3

1. RECOVERY PLAN OVERVIEW INTRODUCTION The Missouri River flooding experienced at Fort Calhoun Station (FCS) during the summer of 2011 has significantly challenged plant operation and has resulted in the station remaining shutdown since April 9, 2011, when the unit was removed from service for the start of the 2011 refueling outage. Throughout the flooding, Omaha Public Power District (OPPD) has ensured that FCS continues to be operated in a manner that protects the public health and safety. OPPD is fully committed to ensuring that public health and safety is assured when FCS is returned to power operation.

In response to this flooding event, OPPD is undertaking comprehensive, aggressive actions to fully scope, and then correct, the extent of flooding impact at FCS, beginning with comprehensive assessments of systems, structures and components (SSC) and continuing with detailed plans for repair and restoration. This document, the FCS Flooding Recovery Plan (FRP),

provides detailed plans and actions regarding the structure, content and methods for these restart actions.

The FCS Flooding Recovery Plan is organized as follows:

Section 1 - Recovery Plan Overview Section 2 - Assessment and Restoration Focus Areas Section 3 -Action Plan Summary Section 4- Internal and External Oversight Appendix A - Flooding Recovery Action Plans Appendix B- Removed Flooding Recovery Action Plans PURPOSE The purpose of the FRP is to provide a roadmap for successful recovery of Fort Calhoun Station from the 2011 flooding event.. The FRP identifies specific focus areas that will be addressed..

ASSESSMENT AND RESTORATION FOCUS AREAS As described above, the FRP identifies actions that must be completed to recover FCS from the 2011 flooding event.. The objectives for the focus areas are characterized by the following statements:

• Assessment of SSCs impacted or potentially impacted by flooding to verify operability or functionality;

• Assessment of emergency preparedness to verify that the on-site and off-site emergency response infrastructure has been restored;

• Assessment of the current configuration of the physical protection system; 33

Fort Calhoun Station Flooding Recovery Plan - Revision 3

• Restoration of facilities and equipment to pre-flooding conditions;

• Identification of SSCs that must be monitored long-term for degradation;

• Evaluation of the effects of the flooding event on the station design and licensing basis;

• Incorporation of lessons learned into station procedures.

These objectives are broad in scope and form the foundation for comprehensive evaluation of the impact of this flooding event. The focus area objectives have been translated into six focus areas for development of action plans:

" Site Restoration

" Plant Systems and Equipment

• Equipment Reliability

• Design and Licensing Basis

" Emergency Planning

" Security The focus areas are discussed and defined in detail in Section 2.

EMERGENCY PREPAREDNESS The FCS Emergency Preparedness program and emergency response capability was maintained throughout the flooding event and assured protection of the health and safety of the public.

Recognizing that the emergency response infrastructure may have been damaged by the flooding, OPPD assessed the capabilities of both the on-site and off-site emergency response facilities and organizations in the site's 10-mile emergency planning zone (EPZ) to respond to site emergencies. OPPD assisted the state emergency management organizations in Iowa and Nebraska with preparation of their required assessments of the infrastructure associated with the radiological emergency preparedness program. OPPD assisted the states in drafting a letter of certification that was submitted to FEMA stating that the offsite emergency response organizations are capable of responding to a radiological emergency. FEMA has since issued a Statement of Reasonable Assurance that offsite radiological emergency preparedness remains adequate to protect the health and safety of the public.

PHYSICAL SECURITY Throughout the flooding event, OPPD has maintained physical security measures in accordance with the Security Plan. However, because of the flooding, some security systems and equipment have been removed from service. A security system damage assessment and restoration plan has been included in the FRP and OPPD fully intends to restore the out-of-service equipment as soon as possible. If circumstances prevent full restoration of the physical security protection, OPPD will use compensatory measures as allowed by the Security Plan.

Prior to plant restart, OPPD will conduct an assessment of the current configuration of the physical protection system to verify the security protective strategy meets the objective of providing high assurance that activities involving special nuclear material are not inimical to the 34

Fort Calhoun Station Flooding Recovery Plan - Revision 3 common defense and security and do not constitute an unreasonable risk to the public health and safety. This assessment will include local law enforcement and emergency response organizations to verify that their response capability for a security event has not been adversely impacted.

DOCUMENTATION REQUIREMENTS Flooding Recovery Action Plans For each action in the FRP, closure packages are developed to summarize the actions taken to address the issue and complete the deliverable identified in the individual action plan. The result will be an easy-to-review document summarizing the actions taken and describing the results achieved by implementation of the action plan.

2. ASSESSMENT AND RESTORATION FOCUS AREAS

SUMMARY

OF FOCUS AREAS An important step in developing the FRP was to identify and understand the scope of the assessment and restorationactivities that will be required. Development of the FRP emphasized a broad and comprehensive approach to short term and long term assessment of flooding impact on plant systems, structures and components. As a result, FCS has identified six focus areas. Each focus area has been assigned to a station manager as the Focus Area Owner and each focus area has one or more associated action plans with Action Plan Owners.

The process requires that each action plan includes an Issue Definition and Objective to clearly define the scope and expected results for each action plan, action steps, due dates, and deliverables are included in each action in the individual action plans. As a summary overview, the following paragraphs identify the six focus areas and provide a brief characterization of scope of each focus area. Details regarding specific objectives and actions are contained in the FCS Flooding Recovery Action Plans in Appendix A.

FOCUS AREAS Site Restoration Includes all activities to remove flooding protection and equipment from the site, restore facilities and equipment with known damage and restore equipment that was moved off-site for protection from flooding.

35

Fort Calhoun Station Flooding Recovery Plan - Revision 3 Plant Systems and Equipment Includes assessment of the condition of plant systems and equipment to determine what, if any, damage has occurred and identify actions necessary to restore the equipment to operable or functional status.

Long Term Equipment Reliability Includes assessing the condition and reliability of station equipment that may have been impacted by flooding conditions but has not failed. This will include both short term and long term assessment and monitoring.

Design and Licensing Basis Includes all activities to verify that FCS is in compliance with the NRC-approved design and licensing basis and determine if changes to the licensing basis are required due to changes in the frequency or magnitude of an external flooding event.

Emergency Planning Includes assessing the capabilities of both the on-site and off-site emergency response facilities and organizations in the site's 10-mile emergency planning zone (EPZ) to respond to site emergencies and restoration of those facilities where required. Also includes identifying lessons learned from the external flooding event and incorporating those lessons into station procedures.

Security Includes assessment of security system damage and restoration of damaged equipment. Also includes verifying the response capability of local law enforcement and emergency response organizations for a security event has not been adversely impacted.

3. ACTION PLAN

SUMMARY

ACTION PLAN FORMAT AND CONTENT The FRP action plans are the primary tool for documenting and tracking flooding recovery progress and issue closure. The action plans show the desired action, the expected deliverable, and any change as compared to the Revision 1 Action Plan. Actions that were selected to be part of NRC letter CAL 4-11-003, Confirmatory Action Letter - Fort Calhoun Station, dated September 2, 2011 are indicated by an orange background behind the action number.

Oversight processes and practices will be used to oversee and monitor implementation and closure of each action plan. Section 4.0 provides additional details on the management oversight and monitoring practices that will be used to monitor execution of the FRP.

36

Fort Calhoun Station Flooding Recovery Plan - Revision 3 LIST OF ACTION PLANS The seventeen FRP action plans are grouped by focus area as shown below. This is the current list of action plans. During assessment activities, it is possible that additional action plans will be identified for development.

1. Site Restoration 1.1. Flooding Protection and Equipment Demobilization 1.2. Plant and Facility Restoration 1.3. Bus 1B4A Restoration and Extent of Condition Actions (Removed from FRP but will be addressed by the IM 0350 Recovery Team) 1.4. 13.8 kV Underground Distribution Damage Assessment and Restoration

2. Plant Systems and Equipment 2.1. Station Fire Protection System Damage Assessment and Restoration 2.2. System Health Assessments 2.3. Wetted Motor Damage Assessment and Restoration

3. Long Term Equipment Reliability 3.1. Engineering Program Reviews 3.2. Underground Cable Assessment 3.3. Underground Piping and Tanks Assessment 3.4. I&C Power Supply Service Life Assessment (Removed from the FRP and will be addressed by the IM 0350 Recovery Team)

4. Design and Licensing Basis 4.1. Plant and Facility Geotechnical and Structural Assessment 4.2. External Flooding Barrier Configuration 4.3. Plant Design Configuration Control 4.4. External Flood Design Basis Review (Removed from the FRP but will be addressed by the IM 0350 Recovery Team) 4.5. High Energy Line Break Remediation/EEQ Resolution (Removed from the FRP but will be addressed by the IM 0350 Recovery Team) 4.6. Design Resolution Items (Removed from the FRP but will be addressed by the IM 0350 Recovery Team)

5. Emergency Planning 5.1. Return Alert Notification Sirens To Functional Status 5.2. Field Monitoring and Post Accident Environmental Monitoring 5.3. Assessment of Offsite Emergency Response Following a Natural Disaster 37

Fort Calhoun Station Flooding Recovery Plan - Revision 3 5.4. Onsite Facility and Equipment Restoration

6. Security 6.1. Security System Damage Assessment and Restoration ACTION PLAN IMPLEMENTATION RESPONSIBILITIES The focus area owner is responsible for the overall implementation of their action plans and will review all completed action plans for closure following completion. Each action plan step has a specific individual assigned responsibility for its implementation. Responsibilities of these individuals are summarized below:

• The Action Step Owner is responsible for completing the assigned action step by the specified completion date and preparing a closure package that documents action step closure;

• The Action Plan Owner is responsible for ensuring the on-time completion of all action steps and approving the closure packages;

" The Focus Area Owner is responsible for ensuring on-time and effective implementation and completion of all action plans in the assigned focus area and approving action plan closure.

ACTION PLAN SCHEDULING AND TRACKING The actions outlined in the FRP will be included in an integrated project schedule. The action plan owners are responsible for updating the project schedule.

ACTION. PLAN CLOSURE PROCESS The closure process for the action steps and action plans are summarized in the following paragraphs.

ACTION STEP CLOSURE The closure of each action step in an action plan will require a closure report using a standard closure format. The action plan owner will be responsible for ensuring that the completion of an action step is documented and preparing the closure report package. An independent review of the action step's closure documentation will be performed.

ACTION PLAN CLOSURE Following completion of the action steps in an action plan, the Action Plan Owner and the Focus Area Owner will review the action plan for closure. A final closure report will be prepared which documents justification for closure of the action plan. The package will then be reviewed and signed by the Action Plan Owner and Focus Area Owner.

38

Fort Calhoun Station Flooding Recovery Plan - Revision 3 ACTION PLAN REVISIONS Revisions that affect the scope, intent, or basis of previously approved revisions (e.g., deletion of actions or addition of actions) require review and approval by the Action Plan Owner and the Focus Area Owner. Revisions that affect scope will require a change to the revision number and date of the action plan. Revisions that may impact NRC commitments will be reviewed by Licensing to evaluate the potential commitment impact and any changes to commitments will be approved by the Site Vice President.

4. INTERNAL AND EXTERNAL OVERSIGHT FCS management is responsible for monitoring progress in accomplishing the FRP and is accountable for the overall implementation of the FRP. Management oversight will accomplished through review meetings and oversight activities as described in the following paragraphs:

FRP PROGRESS REVIEW MEETINGS Overall progress toward completing FRP action plans will be managed through the recovery schedule process.

INDEPENDENT OVERSIGHT Nuclear Oversight has developed a plan for oversight of activities associated with the FRP. This plan contains guidance for performing evaluations of FRP activities and action plans.

Specifically, the plan ensures that NOS activities are documented and performed in accordance with written procedures or checklists to verify, by examination and evaluation of evidence, that applicable elements of the FRP have been developed, planned, effectively implemented and appropriately documented. During these evaluations, NOS will use existing processes for oversight of and for response to emergent issues. Any NOS findings that identify conditions adverse to quality will be documented in the Corrective Action Program (CAP) as required by Standing Order R-2, "Condition Reporting and Corrective Action."

39

Fort Calhoun Station Flooding Recovery Plan - Revision 3 FRP APPENDIX A - FLOODING RECOVERY ACTION PLANS 40

FCS Flooding Recovery Action Plan 1.1 Flooding Protection and Equipment Demobilization FOCUS AREA: Site Restoration ACTION PLAN: Flooding Protection and Equipment Demobilization ACTION PLAN NUMBER: 1.1 ISSUE DEFINITION:

Temporary flood protection barriers and equipment were installed prior to the flooding event OBJECTIVE:

Remove temporary flood protection barriers and equipment 41

FCS Flooding Recovery Action Plan 1.1 Flooding Protection and Equipment Demobilization 42

FCS Flooding Recovery Action Plan 1.1 Flooding Protection and Equipment Demobilization Remove or relocate switchyard berm I Berm removed or relocated 43

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration FOCUS AREA: Site Restoration ACTION PLAN: Plant and Facility Restoration ACTION PLAN NUMBER: 1.2 ISSUE DEFINITION:

Site structures and facilities may have been damaged by flooding OBJECTIVE:

Repair flood-related damage to site facilities and structures 44

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration yinnl ueIIvuraULIU. DuronULUrUs uaen UJg vvorarng cnangea ior consiswency vs

%-rIYIIUr biohazardsul*;url:

exist utilrr"I"Fl in Protected1 unly Area fab and resolved other similar actions.

shop and resolve Revised Action: Determine if any Revised Deliverable: Mitigation complete biohazards exist in Protected Area fab shop; mitigate as required 45

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration M

Remove temporary berms around A/C units and transformers in Protected Area 46

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration Replace carpet tiles in Training Center Carpet replaced auditorium I 47

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration I

IuuIEtM ini Mut '5K5 Uf1U IUAU5~ FM.)IUCeU unju nreirip Art-n I 1 1-40 criuriges I spec- ng I inspec )n and cleaning con I No changes I Unplug drains in the Training Center atrium and simulator J Drains restored I I No changes I rump OUT pocKeTs or waTer maT are Iwater pumpea our I NO cnanges I e environmental issues in I

ivironmental issues resolved I No changes I

)r Uu LAUccislo WrIuirie 10) pururiuml ItIrlipurury Iq rulu

.......... L Z.I, ............ ,L ."1------

I Lvaluate it each trailer is worth salvaging or needs to be scrapped I Assessment completed I NO changes I 48

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration 49

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration I completed Kepairs, repiacement ana TesTing 50

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration Mow grounas ana spray weeas prior I ara mainTenance compieTea to winter I 51

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration iKemove equipment and material trom I Equipment removed, area restored A C ra,,-- - cr --r,- I No changes I Kepuii uiscovereu geoiecnnicai problems in common areas outside I Kepairs compieTea I NO cnanges I Repair structural or geotechnical deficiencies in Chemistry Storage I Repairs completed I No changes I citmir iii! Itmr~uireu iuriUNUUPIriy I ^sesumrnum omreii I NO cnanges I unginal Action: isi-s1 faul route load ial Deliverable: Load test complete Closed based on no planned spent fuel test movements in the near future. Load Revised Deliverable: None testing of the ISFSI haul route will be Revised Action: None included as part of the process for moving spent fuel and is therefore not needed in m this plan.

52

FCS Flooding Recovery Action Plan 1.2 Plant and Facility Restoration Original Action: Repave the DeSoto marker turnout at top of hill Revised Action: None IRevised Deliverable: None Original Deliverable: Area repaved 53

FCS Flooding Recovery Action Plan 1.4 13.8 kV Underground Distribution Damage Assessment and Restoration FOCUS AREA: Site Restoration ACTION PLAN: 13.8 kV Underground Distribution Damage Assessment and Restoration ACTION PLAN NUMBER: 1.4 IISSUE DEFINITION:

Flooding conditions and temporary mitigation measures have degraded station 13.8kV System fOBJECTIVE:

Restore Station 13.8kV System to functional status Original Action: Inspect manholes MH 1 through MH4 associated with circuit 231 (T&D 122) between T&D Revised deliverable to add more soecific 54

FCS Flooding Recovery Action Plan 1.4 13.8 kV Underground Distribution Damage Assessment and Restoration bWlltll-3Vy IUOL 1U IO*U IlUN IlUMItil a Pictures documenting the cable pull UVIUt:ill-i[.;: Ul (.;rUlI 1i,}t*

13TN43G through manholes.

0 T&D work order 425377 or Completed Revised Action: Inspect manholes and Surveillance EM-ST-ESF-0002, Emergency ducts for MH01 through MH04 from Power Periodic Test T&D switch SW 1062 to transformer TI B-3C-1 to facilitate pulling a new 1/0 uriginai ACTion: inspect ana/or Tesi unginai ueuveraDue: inspecflon puncn lIST 4-IOSe To new actions 1.4.1 ./, 1.4.1.0, 1.4.1 Y, Circuit 231 from T&D switch SW 1062 to and/or test report 1.4.1.10, 1.4.1.11 and 1.4.1.12 which T&D transformer 13TN43G and repair provide a more detailed description of this as necessary Revised Deliverable: None scope of work.

KupIuuu I&LJ aWlitrdi .)y IVOL U I aU W(.,)K V)IUt:f* 14LO3f

• 1 .. ow uailun 0 Pictures showing new switch SW 1062 installation.

0 Documentation showing that new switch SW 1062 is eauivalent to existina 55

FCS Flooding Recovery Action Plan 1.4 13.8 kV Underground Distribution Damage Assessment and Restoration rernorm t-M-sI-tI-l-J-UUZ emergency I t.ompleTea burveiiiance tM-zi-I'--uuuz, Power Periodic Test Emeraencv Power Periodic Test 56

FCS Flooding Recovery Action Plan 1.4 13.8 kV Underground Distribution Damage Assessment and Restoration 57

FCS Flooding Recovery Action Plan 1.4 13.8 kV Underground Distribution Damage Assessment and Restoration jIlyulUI '.;I u l*lt-ll .,*1npt ..;l 10u killyliful Ut!11Vtj1ULj1t1. Imptiullut] pulic.;1I 11bi urniu ueiiveruiLil iKeVl!tu uuliOrl io miore switchgear SW 1067 and recommend clearly define action and incorporate replacement and/or relocation to Revised Deliverable: scope of T&D work order 425377 to preclude loss during design basis " T&D Work Order 425377 document inspection and T&D's FCS Off-flooding

• Copy of Transmission and Distributions Site Power Reliability Report.

FCS Off-Site Power Reliability Report Revised Action: Inspect T&D switchgear SW 1067 and recommend r rca ml~t-*r~aar nAl/Ir r~lmrtirn 58

FCS Flooding Recovery Action Plan 1.4 13.8 kV Underground Distribution Damage Assessment and Restoration Original Action: Inspect and/or test Original Deliverable: Inspection punch list Revised action and deliverable to more T&D 13.8kV transformers located in the and/or test report clearly define action and remove testing PA requirements. T&D did not perform testing; Revised Deliverable: T&D Work Order they inspected and/or reenergized OCA Revised Action: Inspect, clean and 425377 transformers consistent with their normal energize, as required, all 13.8kV practice. Transformer Ti B-3C-1 replaced transformers located in the PA as under action 1.4.1.9 and tested under Original Action: Inspect any pole Original Deliverable: Inspection punch list Close based on no action required.

mounted drops for necessary Conduits associated with the T&D 13.8kV extensions and waterproofing Revised Deliverable: None system have an open design that cannot be waterproofed. They are designed to Revised Action: None allow water to drain from the enclosures i

naturally 59

FCS Flooding Recovery Action Plan 1.4 13.8 kV Underground Distribution Damage Assessment and Restoration 60

FCS Flooding Recovery Action Plan 1.4 13.8 kV Underground Distribution Damage Assessment and Restoration Original Action: Replace/repair pad Original Deliverable: Complete Work Orders Close based on no action required:

mounted switches as recommended Except for switch SW 1062 replaced by by T&D Revised Deliverable: None action 1.4.1.8, T&D inspected, cleaned and energized the remainder of the 13.8kV system as normal practice. No additional switches required replacement. See action 1A'17 Replace 13.8kV feeder cables to MET I T&D Work Order 425377 tower and shootina ranae I 61

FCS Flooding Recovery Action Plan 2.1 Station Fire Protection Damage Assessment and Restoration FOCUS AREA: Plant Systems and Equipment ACTION PLAN: Station Fire Protection Damage Assessment and Restoration ACTION PLAN NUMBER: 2.1 ISSUE DEFINITION:

Flooding conditions and temporary mitigation measures may have degraded station fire protection and fire detection systems and components.

OBJECTIVE:

Restore all flood affected fire protection systems and equipment to functional and operable status. Ensure all areas of the plant are in compliance with applicable fire protection standing orders and program requirements.

Kepair any aamagea or non- unginat ueilveraDie: L-ompieTea Kevisea aeiiveraoie TO staTe specITric TeST functional fire hydrants located inside maintenance work documents (WR 167645) that demonstrates functionality.

the protected area or connected to (Tool Pouch to Ops to return the equipment the main fire protection header ring that has been removed from the cabinets)

Revised Deliverable: Completed copy of OP-ST-FP-0001 A, WO 422051 62

FCS Flooding Recovery Action Plan 2.1 Station Fire Protection Damage Assessment and Restoration Inspect all SO-G-103 fire barriers in Original Deliverable: Completed Revised deliverable to remove reference plant buildings affected by flood maintenance / inspection work documents to maintenance.

waters. Include Pyrocrete barriers in WO 423212-01 (Completed copy of SE-ST-FP-Intake Structure. 0005) complete I-V system rMs and Sis on I Original Deliverable: Completed PMs and flood impacted equipment which was STs and associated work order documents 0009. This test was not impacted by not accessible for inspection and testinQ (OP-ST-FP-0002, OP-ST-FP-0009, 1 OP-ST-FP-000I A, OP-PM-FP-0001 A) Iflooding.

Revised deliverable to remove OP-ST-63

FCS Flooding Recovery Action Plan 2.1 Station Fire Protection Damage Assessment and Restoration

ompietea worK documenTs wU 425634-U I , New action WO 425636-0 1I 64

FCS Flooding Recovery Action Plan 2.1 Station Fire Protection Damage Assessment and Restoration

,drant l Completed maintenance work documents l New action.

(WO 418123) and operability testing of FP-(

3C.

65

FCS Flooding Recovery Action Plan 2.1 Station Fire Protection Damage Assessment and Restoration 66