ML13093A473

Summary of Meeting with Omaha Public Power District

ML13093A473
Person / Time
Site:	Fort Calhoun
Issue date:	04/03/2013
From:	Hay M NRC/RGN-IV/DRP
To:
References
Download: ML13093A473 (21)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I V 1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511 April 3, 2013 LICENSEE: Omaha Public Power District (OPPD)

FACILITY: Fort Calhoun Station

SUMMARY

OF MARCH 27, 2013 MEETING WITH OMAHA PUBLIC POWER DISTRICT On March 27, 2013, a Category 1 meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and Omaha Public Power District (OPPD) at the Doubletree Hotel at 1616 Dodge St, Omaha, Nebraska.

The NRC presented the status of Inspection Manual Chapter 350 oversight inspections, the revised Confirmatory Action Letter, associated Restart Checklist, and Restart Checklist Basis Document (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 NRCs Rules of Practice, a copy of this letter and its enclosures will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agency wide Documents Access and Management System (ADAMS). ADAMS is accessible from the Public Electronic Reading Room page of the NRCs 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 may 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 : NRC Presentation Slides : OPPD Presentation Slides

OPPD Electronic distribution by RIV:

Regional Administrator (Art.Howell@nrc.gov)

Deputy Regional Administrator (Robert.Lewis@nrc.gov)

RIV DRP Director (Kriss.Kennedy@nrc.gov)

RIV Acting DRP Deputy Director (Michael.Scott@nrc.gov)

RIV Acting DRS Director (Tom.Blount@nrc.gov)

RIV Acting DRS Deputy Director (Jeff.Clark@nrc.gov)

RIV Senior Resident Inspector (John.Kirkland@nrc.gov)

RIV Resident Inspector (Jacob.Wingebachl@nrc.gov)

RIV Branch Chief, DRP/F (Michael.Hay@nrc.gov)

RIV Senior Project Engineer, DRP/F (Rick.Deese@nrc.gov)

RIV Project Engineer, DRP/F (Chris.Smith@nrc.gov)

RIV Project Engineer, DRP/F (Jesse.Rollins@nrc.gov)

RIV Public Affairs Officer (Victor.Dricks@nrc.gov)

RIV Public Affairs Officer (Lara.Uselding@nrc.gov)

NRR Project Manager (Lynnea.Wilkins@nrc.gov)

NRR Project Manager (Joseph.Sebrosky@nrc.gov)

RIV Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)

RIV RITS Coordinator (Marisa.Herrera@nrc.gov)

RIV Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEWEB Resource (Sue.Bogle@nrc.gov)

RIV/ETA: OEDO (Doug.Huyck@nrc.gov)

RIV RSLO (Bill.Maier@nrc.gov)

MC 0350 Panel Chairman (Anton.Vegel@nrc.gov)

MC 0350 Panel Vice Chairman (Louise.Lund@nrc.gov)

MC 0350 Panel Member (Michael.Balazik@nrc.gov)

MC 0350 Panel Member (Michael.Markley@nrc.gov)

R:\ R:\_REACTORS\_FCS\2013 ADAMS ML13093A473 ADAMS: No Yes SUNSI Review Complete Reviewer Initials:

Keyword: Publicly Available Non-Sensitive Public Release Date: Non-publicly Available Sensitive RIV/C:DRP/F MHay

/RA/

4/3/13 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Opening and Introductions Fort Calhoun Station Public Meeting

• Welcome Nuclear Regulatory Commission

• Introduction of NRC personnel March 27, 2013 Omaha, Nebraska NRC Personnel Purpose

• Tony Vegel - MC 0350 Panel Chair

• Status of NRC and OPPD actions

• Louise Lund - MC 0350 Panel Vice Chair - NRC will present status of inspections

• Mike Hay - Branch Chief and issuance revised CAL and Basis

• Joe Sebrosky - Project Manager Documents

• John Kirkland - Senior Resident Inspector - OPPD will present details of plant issue

• Rick Deese - Senior Project Engineer resolution

• Allow for public interaction and questions Enclosure 1

NRC ACTIONS Confirmatory Action Letter Restart Checklist Items (26 Items) 1 2 3 4 5 6 7 8 9 1 1 1 1 1 1 1 1 1 0 1 2 3 4 5 6 7 8 Basis Document Items (450+)

6 Revised Revised Basis Document Confirmatory Action Letter

• Issued March 7, 2013 http://www.nrc.gov/info-finder/reactor/fcs/special-oversight.html

• Issued February 26, 2013 http://www.nrc.gov/info-finder/reactor/fcs/special-oversight.html

• SSFFs consisted of 9 Licensee Event

• Added 3 items to the Restart Checklist R Reports t (LERs)

(LER )

- Safety System Functional Failures (SSFFs)

• Containment Penetrations and Internal

- Qualification of Containment Electrical Structures Penetrations - Root Cause

- Containment Internal Structures - Extent of Condition and Cause Evaluation

- Corrective Actions Enclosure 1

Status of Inspections Status of Items Completed and Reviews

• CAL Inspection Team - On Site Inspection

• All Restart Checklist Items Remain Open Complete

• Security - On Site Inspection Complete

• Approximately 150 of 460 Restart

• Safetyy Culture - On Site Inspection p Complete p

• Operational Assessment - April 2013 Ch kli t Basis Checklist B i Document D t Items It Cl Closed d

• Containment Structure - Ongoing

• Containment Penetration - Ongoing

• Majority of Flood Recovery Items Near

• Flooding - Review in Progress Completion

• Special Inspection - On Site Inspection Complete 9

Flood Recovery Items Current Assessment

• Original CAL had 231 individual items

• Improvements:

- Overall Site Safety Culture

- Nuclear Oversight Assessments

• Restart Checklist Basis Document split - Plant Equipment outt items it nott directly di tl related l t d tot flood fl d

- 162 directly related to flood, including 22 specifically

• Challenges:

related to geotechnical inspection - Inconsistent quality of Fort Calhoun Stations

- 102 have been inspected and closed reviews and actions to address CAL and Basis Document items

• Station actions were not always complete

• Lack of consistent thoroughness of station evaluations Enclosure 1

Path Forward Path Forward

• Fort Calhoun Station

• NRC

- Complete Identification and Implementation of - Operational Assessment Team Inspection Corrective Actions for Restart Checklist Items in a - Security Follow Up Inspection High Quality Manner - MC 0350 and CAL Follow Up p Inspections p

- Determine Readiness for Inspection Activities PERFORM THOROUGH and

- Provide NRC in Writing Results and Readiness for Inspection of CAL Items INDEPENDENT VERIFICATION of PLANT SAFETY OPPD Presentation NRC Remarks Lou Cortopassi Vice President and Chief Nuclear Officer Omaha Public Power District Closing Remarks Enclosure 1

Open to the Public

• The NRC places a high priority on keeping the public and stakeholders informed of its activities

• At www.nrc.gov, you can:

- Find p public meeting g dates and transcripts; p

Open Discussion - Read NRC testimony, speeches, press releases, and policy decisions;

- Access the agencys Electronic Reading Room to find NRC publications and documents; and

- Subscribe to automatically receive correspondence from the NRC Contacting the NRC

• Report an emergency

- (301) 816-5100 (call collect)

• Report a safety concern

- (800) 695 695-7403 7403

- Allegation@nrc.gov

• General information or questions

- www.nrc.gov Enclosure 1

Fort Calhoun Station Topics for Discussion Driving Through Restart

• Plant Status - Readiness for Restart Public Meeting with the U.S. Nuclear Regulatory Commission

• Progress on Commitments for Restart

• Plan for Sustained Improvement

• Independent Assessment

• Closing Remarks March 27, 2013 1 2

. Industrial Safety Overview Plant Status 1st .

FCS March 2013 ..

. 1st quartile 26th .

U.S. Pla ant Ranking IMPROVE EMENT 2nd quartile 52nd 3rd quartile

• Safety Performance 78th

• Human Performance 4th quartile FCS January 2012

• Fixing the Plant 104th Industrial Accident Rating

• Readiness for Restart 3 4 Enclosure 2

Human Performance Overview 1st ...

Fixing the Plant 1st quartile

• Approximately 20,000 tasks completed 26th (November 2012 through February 2013)

U.S. Plantt Ranking FCS March 2013 2nd quartile

• Approximately 5,000 tasks remaining to be IMPROVEMEN NT 52nd ready for restart 3rd quartile

- Approximately 3,900 tasks to complete 78th reloading fuel into the reactor 4th quartile - Approximately 1,000 additional tasks to heat FCS January 2012 104th up the plant Human Performance Errors 5 6 Major Tasks to Complete Loading Major Tasks to Complete Fuel into the Reactor Plant Heat-Up

• Complete high-energy line break and

• Complete maintenance work on electrical electrical equipment qualification distribution system modifications

• Complete maintenance work to resolve

• Complete major safety system testing equipment service life issues

• Complete installation of new containment

• Load fuel into the reactor penetrations

• Heat up the plant 7 8 Enclosure 2

Major Tasks Remaining to Ready the Current Schedule Plant for Start-Up

• Complete Systems, Programs and Departments Load fuel into the reactor Readiness Reviews

• Mid-April 2013

• Complete Operational Readiness Assessment Heat up the plant with y Confirmatoryy Action Letter commitments and

• Verify Restart Checklist items are resolved non-nuclear l heat h t

• Mid-May 2013

• Chief Nuclear Officer submits Restart Report to NRC (Confirmatory Action Letter Commitment 6)

Plant ready for

• Operators confirm plant ready for start-up and Plant start-up Review Committee recommends restart

• Late May 2013

• Plant ready for start-up 9 10 Driving to Restart OPPD Commitments for Restart

• Station Priorities 1. Identify causes and implement corrective actions for Safety safety significant findings (Checklist 1.a through 1.d and Human Performance 1.g)

Fix the Plant

2. Assess safety culture and organizational effectiveness and implement improvement actions (Checklist 1.e and Corrective Action 1.f)

P Program 3

3. A Assess andd resolve l flflooding di iimpact,t evaluate l t systems, t

- Training Program and ensure plant is ready for restart (Checklist 2.a through 2.d)

• Human Performance Continues 4. Assess and improve programs and processes that to Improve caused significant performance decline (Checklist 3.a Our Supervisors are

• Remaining Work is Known and through 3.f)

Driving our Improved Scheduled 5. Implement the Integrated Performance Improvement Performance

• We are Driving to Restart Plan (Checklist 4)

6. Submit Fort Calhoun Station Restart Report 11 12 Enclosure 2

CAL Commitment No. 1 CAL Commitment No. 1 Commitment 1 Commitment 1 Progress on Addressing Safety Findings Progress on Addressing Safety Findings November Scoping Discovery Analysis Implement Current Scoping Discovery Analysis Implement 1.a. Flooding 100% 100% 100% 5% 1.a. Flooding 100% 100% 100% 98%

1.b. Reactor Prot. 1.b. Reactor Prot.

Sys. Contactor 100% 100% 100% 75% Sys. Contactor 100% 100% 100% 89%

Failure Failure 1.c. Electrical Bus 1.c. Electrical Bus Modification & 100% 100% 75% 5% Modification & 100% 100% 100% 89%

Maintenance Maintenance 1.d. Safeguards 100% 100% 100% 75% 1.d. Safeguards 100% 100% 100% 99%

Information Control Information Control 1.g. Safety System Performance *** *** *** ***

Indicator 13 14 CAL Commitment No. 1 CAL Commitment No. 1 1.a. Flooding Yellow Finding 1.a. Flooding Yellow Finding

• Completed scoping, discovery and analysis Intake Cell Level Control

• Completed root cause analyses

• Modification for level control - complete Cell level controlled through four 10-inch manual

• Completed key corrective actions throttle valves off 18-inch pipes

- Replaced certain flood barriers

- Inspected conduit/piping seals Operators O t will ill monitor it llevell d during i extreme t flflood d

- Successfully completed penetration seal testing and adjust valves to control flow

- Improved flood procedures Significant improvement - ease of operation and system function

• Restart Checklist item closure package approved and ready - One action remains for

• Remaining action for restart readiness restart readiness - Piping classification being updated 15 16 Enclosure 2

Protecting Fort Calhoun Station from Flooding Topics

• Display the Missouri River dam and reservoir system

• Explain the NRC approved Design Basis Flood in the Fort Calhoun license

• Describe Fort Calhoun protection for the Design Basis Flood

• Describe mitigation strategies OPPD put in place for much more severe floods 17 18 18 Fort Calhoun Station License Protection from Design Basis Flood

• Site grade was established at the level of the estimated 1000 Requirements year flood with no dam failures (1960s USACE Analysis)

• NRC established license requirements for safe

• Critical structures permanently sealed an additional three feet higher for safety margin and wave action plant operation

• Design Basis Flood in Fort Calhoun license -

• Estimated three foot higher probable maximum flood (PMF) -

extreme t precipitation i it ti with ith no d dam ffailure il (1960 (1960s USACE extreme precipitation and failure of the Oahe or Analysis)

Fort Randall Dam

• Permanently sealed structures protected an additional six feet higher with removable engineered barriers

• Fort Calhoun Station has physical protection from that flood

• Estimated PMF with failure of Oahe or Ft. Randall Dam (1960s Fort Calhoun Station is safe from USACE Analysis) - Design Basis Flood (DBF) in License

• Removable engineered barriers with one foot of temporary Design Basis Flood barriers (sandbags) in limited areas protect against DBF 19 20 20 Enclosure 2

Voluntary Mitigation Strategies for Risk from Floods at Fort Calhoun More Severe Flooding Station

- OPPD Initiated Individual Plant Examination for External Events (IPEEE) in 1990s following NRC Generic Letter

• IPEEE estimated plant risk from floods

- Fort Calhoun IPEEE included evaluation of external - All analyzed floods, including IPEEE flood from flooding far beyond the original licensing basis significant precipitation and four dam failures

- Included plant protection features and use of

• Procedures in place to mitigate a flood 21 feet higher mitigating strategies than DBF - will keep the plant safe from a PMF plus - Resulting plant accident risk is 4 in 1,000,000 for all failure of the Oahe Dam with cascading failures of Big Bend, Fort Randall and Gavins Point downstream external flooding scenarios - similar to other plant dams (1990s USACE Analysis) risks

• Procedures involve temporary gasoline-powered pumps and hoses to cool the reactor Fort Calhoun is safe from flooding 21 21 22 22 CAL Commitment No. 2 CAL Commitment No. 2 Commitment 2 Commitment 2 Progress on Safety Culture and Organizational Progress on Safety Culture and Organizational Effectiveness Effectiveness November Current Scoping Discovery Analysis Implement Scoping Discovery Analysis Implement 1.e. Safety Culture 100% 100100

% % 100%100%93% 1.e. Safety Culture 100% 100100

% % 100%100%100%

1.f. Organizational 100% 1.f. Organizational 100%

100% 100% 89% 100% 100% 100%

Effectiveness Effectiveness 23 24 Enclosure 2

CAL Commitment No. 2 CAL Commitment No. 2 Actions Taken 1.e. Safety Culture

• Root Cause Analyzed What is Safety Culture - Management changed

- Governance and Oversight Policy implemented An organizations values

- Leaders and staff trained and behaviors, behaviors modeled - Dozens of staff 2Cs (Compliments and Concerns) by its leaders and meetings held with Chief Nuclear Officer internalized by its - Corrective Action Program improved members that serve to - Employee Concerns Program enhanced make nuclear safety - Survey our staff monthly to monitor effectiveness and adjust actions the overriding priority.

25 26 CAL Commitment No. 2 CAL Commitment No. 3 Industry-Leading Safety Culture Commitment 3 Monthly Survey Results Progress on Systems Ready for Restart Safety Culture Index 3

November Scoping Discovery Analysis Implement 2.95 2.95 2.a. Flood Recovery 100% 100% 100% 91%

2.9 2.90 Restoration Actions 2.83 2.85 2.83 2.81 2.b.1. System Health 50%

100% 70% 10%

2.8 Reviews 2.75 2.b.2. Reactor Safety 50%

2.7 Strategic Performance 100% 100% 100%

October 2012 November 2012 December 2012 January 2013 February 2013 Three-Month Average, Month Ending Area Review 27 28 Enclosure 2

CAL Commitment No. 3 CAL Commitment No. 3 Commitment 3 Commitment 3 Progress on Systems Ready for Restart Progress on Systems Ready for Restart - Contd Current November Scoping Discovery Analysis Implement Scoping Discovery Analysis Implement 2.a. Flood Recovery 2.b.3. Flood Impact 100% 100% 100% 94% 100% 100% 95% 80%

Restoration Actions on Soils & Structures 2.b.1. System Health 50%

100  % 2.c. Containment 100% 100% 96% 100% 100% 75% 10%

Reviews Penetration Design 2.b.2. Reactor Safety 2.d. Containment Strategic Performance 100% 100% 100% 100% Internal Structure 100% 100% 75% 5%

Area Review Design 29 30 CAL Commitment No. 3 CAL Commitment No. 3 Commitment 3 2.b.1 System Health Reviews Progress on Systems Ready for Restart - Contd 27 Risk-significant systems reviewed Current Scoping Discovery Analysis Implement

• Detailed review and evaluation of the most 2.b.3. Flood Impact important components in each system.

100% 100% 100% 93%

on Soils & Structures

>> Selected based on historical performance and risk worth th 2.c. Containment 100% 100% 100% 50%

• Historical review of open and closed Condition Penetration Design Reports and Work Orders 2.d. Containment Internal Structure 100% 100% 90% 77%

• Comprehensive system walkdowns were Design performed to evaluate the physical condition of the equipment 31 32 Enclosure 2

CAL Commitment No. 3 CAL Commitment No. 3 2.b.1 System Health Reviews 2.b.1 System Health Reviews (Continued) (Continued)

• Many System Health Improvement Items were

• Each System Health Review was performed by identified and entered into the Corrective Action the system engineer, an operator and a member Program including:

of the maintenance staff - A wire jumper was found in poor condition during a diesel generator starting air system walkdown. It has

• Comprehensive reports prepared documenting been repaired.

repaired the health of the systems - Turbine Generator review revealed several work orders that should be worked prior to start up. Work orders added to the outage schedule.

• Reviewed by senior reactor operator and senior - Minor seal leakage on Component Cooling Water maintenance staff prior to approval pump 3C, and minor surface corrosion on piping that is cosmetic in nature. Not required to be fixed prior to start up.

• Reviewed and Approved by Plant Health

• Continuing reviews performed quarterly by Plant Committee Health Committee 33 34 CAL Commitment No. 3 CAL Commitment No. 3 2.c. Containment Penetrations -

2.c. Containment Penetrations Contd

• Fort Calhoun staff identified Teflon in some containment electrical penetration feed-throughs that could degrade under accident conditions

• Recent testing demonstrated that the outboard seal on the feed-throughs did not leak when exposed to the Fort Calhoun post-accident conditions

• Safety-focused decision made to:

- Upgrade penetration feed-throughs with fully qualified design that does not include Teflon

- Remove feed-throughs and cap unused penetrations 35 36 Enclosure 2

CAL Commitment No. 3 CAL Commitment No. 3 Containment Shell and Structures 2.d Containment Internal Structure

• Self-identified issue involves concrete beams, and columns inside containment that support plant components p p and systems y

• Containment Internal Structure (CIS) does NOT include the containment boundary or the containment liner VIEW FROM ABOVE 37 38 CAL Commitment No. 3 CAL Commitment No. 3 Containment Internal Structure History and Identification of Issue Reanalysis

• Original design calculations were performed

• Confirmed as-built configuration through during the 1960s extensive walkdowns

• Discrepancy self-identified by Fort Calhoun

• Developed three-dimensional computer-staff during extended power uprate analysis based model for pipe supports

• Validated assumptions and input parameters

• Conducted challenge boards and

• Multiple deficiencies identified in original independent third-party reviews calculations

• New analyses rigorously documented 39 40 Enclosure 2

CAL Commitment No. 3 CAL Commitment No. 4 Reanalysis Results Commitment 4 Progress on Programs and Processes Ready for Restart

• Containment internal structures are November capable of meeting their required safety Scoping Discovery Analysis Implement 3.a. Corrective function and safe for restart Action Program 100% 100% 100% 70%

• Modifications to restore design g margins g 3.a.1. Identify, f Analyze will be completed during future outages & Correct Performance 100% 100% 100% 50%

• Significant planning, design work and Deficiencies preparation completed during this outage 3.b.1. Safety 100% 100% 75% 5%

Related Parts

• Fort Calhoun Station containment is safe for restart 3.b.2. Equipment 100% 60%

20%

Qualification 90%

41 42 CAL Commitment No. 4 CAL Commitment No. 4 Commitment 4 Commitment 4 Progress on Programs and Processes Progress on Programs and Processes Ready for Restart Ready for Restart (Continued)

Current November Scoping Discovery Analysis Implement Scoping Discovery Analysis Implement 3.c.1. Vendor 3.a. Corrective Modifications 100% 100% 95% 10%

Action Program 100% 100% 100% 100%

3.a.1. Identify, f Analyze 3 c 2 10CFR50 3.c.2. 10CFR50.5959 Screening & Safety 100% 98% 20%

& Correct Performance 100% 100% 100% 87% 75%

Deficiencies Evaluations 3.b.1. Safety 3.d.1. Vendor 100% 100% 95% 55%

100% 100% 100% 68%

Related Parts Manuals 3.b.2. Equipment 3.d.2. Equipment 100% 100% 90% 72% 100% 100% 95% 5%

Qualification Service Life 43 44 Enclosure 2

CAL Commitment No. 4 CAL Commitment No. 4 Commitment 4 Commitment 4 Progress on Programs and Processes Progress on Programs and Processes Ready for Restart (Continued) Ready for Restart (Continued)

Current November Scoping Discovery Analysis Implement 3.c.1. Vendor Scoping Discovery Analysis Implement Modifications 100% 100% 100% 87%

3.e.1. Operability Determinations 100% 100% 80% 15%

3.c.2.

3 c 2 10CFR50 10CFR50.5959  %

Screening & Safety 100% 100% 100% 3.e.2. Degraded /

71%

Evaluations Non-Conforming 100% 100% 80% 15%

Equipment 3.d.1. Vendor 100% 100% 100% 87%

Manuals 3.f. Quality 3.d.2. Equipment Assurance 100% 100% 100% 83%

100% 100% 100% 29%

Service Life 45 46 CAL Commitment No. 4 CAL Commitment No. 4 Commitment 4 3.a Corrective Action Program Progress on Programs and Processes Ready for Restart (Continued)

Current

• Program improvements implemented 11 months Scoping Discovery Analysis Implement ago 3.e.1. Operability - New Corrective Action Program procedures and Determinations 100% 100% 100% 47% guidance g

- Additional staff - CAPCOs 3.e.2. Degraded /

Non-Conforming - Training 100% 100% 100% 47%

Equipment - Accountability 3.f. Quality

• Performance is improving Assurance 100% 100% 100% 100%

47 48 Enclosure 2

CAL Commitment No. 4 CAL Commitment No. 4 3.a. Corrective Action Program 3.a. Corrective Action Program Station Engagement Ratio Condition Report Generation Rate 80 2500 70 2000 60 50 1500 40 Non Start-up CR 30 Station Engagement Ratio 1000 Generation Start-up CR Generation 20 500 10 0 0 49 50 CAL Commitment No. 4 CAL Commitment No. 5 Corrective Action Program Commitment 5 (Continued)

Integrated Performance Improvement Plan (IPIP)

• Capturing issues in the Corrective Action Program has improved

• IPIP Revision 5 will be

• Resolving issues through the Corrective docketed in April 2013 Action Program is improving

• Will address the three

- Safety Culture improvement additional Restart

- Containment penetration and structural Checklist items design issue resolution

• Will expand detail in

- Flood preparedness and mitigation post-restart Plan for

• Continued improvement in the Corrective Sustained Improvement Action Program is under way 51 52 Enclosure 2

CAL Commitment No. 5 Plan for Sustained Improvement Actions to continue performance improvement after restart

• Continued emphasis on

- Corrective Action Program and Training Program effectiveness

- Safety culture and human performance Engineering effectiveness Corrective Actions to Prevent Recurrence Independent Assessments

• Continue assessing FCS programs against the Exelon Nuclear Management Model (ENMM)

• Implement action plans to close gaps to ENMM

• Fully integrate Fort Calhoun into the Exelon fleet

• Perform periodic self assessments of Corrective Action Program effectiveness, safety culture, and engineering effectiveness 53 54 OPPDs Commitment Tonight We Updated You on

• Plant Status and Readiness

- Driving to Restart

• Progress on Commitments for Restart

• Plan for Sustained Improvement after Restart

• Independent Assessments 55 Enclosure 2