ML13239A103
| ML13239A103 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/27/2013 |
| From: | Omaha Public Power District |
| To: | NRC Region 4 |
| References | |
| Download: ML13239A103 (43) | |
Text
Fort Calhoun Station Fort Calhoun Station Driving Through Restart Plan for Sustained Improvement 1
August 27, 2013
Topics for Disc ssion Plant status and major remaining work Topics for Discussion g
Fort Calhoun Station Performance Improvement Policies and Procedures Policies and Procedures Plan for Sustained Improvement Key Drivers for Achieving and Sustaining Excellence Exelon Nuclear Management Model (ENMM)
Model (ENMM)
Integration of Fort Calhoun Station into the Exelon Nuclear Fleet 2
Fleet
C t Pl t St t d R i i W
k Current Plant Status and Remaining Work
- Core re-load completed July 29, 2013 R
t l h d i t ll d A t 25 2013
- Reactor vessel head installed August 25, 2013
- Critical path work
- Tornado missile protection modifications
- Tornado missile protection modifications
- High-energy line break modifications
- CVCS letdown and charging lines
- Steam generator blow down lines
- Containment internal structures
- Plant heat up with non nuclear heat September
- Plant heat-up with non-nuclear heat - September
- Submit Integrated Restart Report - After heat-up
- Ready for restart 3
Ready for restart
R l t D
t G
i R
t t
Regulatory Documents Governing Restart
- December 13, 2011: NRC letter to OPPD documenting transition from the Reactor Oversight Process to Inspection transition from the Reactor Oversight Process to Inspection Manual Chapter (IMC) 0350 - (shutdown plant with significant event involving switchgear fire)
- June 11, 2012: NRC Confirmatory Action Letter with Restart Checklist issued, updated February 26, 2013
- July 9 2012: OPPD Fort Calhoun Station Integrated
- July 9, 2012: OPPD Fort Calhoun Station Integrated Performance Improvement Plan, Rev. 3 submitted including Restart Checklist Implementation Strategy, Rev. 5 submitted June 19, 2013
- July 29, 2013: OPPD Fort Calhoun Station Plan for Sustained Improvement Rev 0 submitted 4
Sustained Improvement, Rev. 0 submitted
Restart Decision Making Criteria Restart Decision-Making Criteria
- Confirmatory Action Letter commitments addressed and Restart Checklist items resolved Restart Checklist items resolved
- Fundamental organizational weaknesses addressed and improving p
g
- Plant, people, processes and departments are ready for restart
- Independent assessments completed
- Nuclear Oversight Department
- Corporate Governance and Oversight Committee Corporate Governance and Oversight Committee
- Nuclear Safety Review Board
- Post-Restart Plan for Sustained Improvement in place 5
- Integrated Restart Report Submitted to NRC
E l
I l
t ti f E l
P f
Early Implementation of Exelon Performance Improvement (PI) Program
g p
- Demonstrate excellence in performance improvement
- Embrace continuous improvement
- Exemplify problem prevention, detection and correction
- Strive to achieve high levels of operational performance PI d
d i
d i
l
- PI program and procedures issued to implement the policy 6
Plan for S stained Impro ement Vision Plan for Sustained Improvement Vision Safe and efficient restart of Fort Calhoun Station and achievement of sustained excellence Plan for Sustained Improvement (PSI)
Performance Improvement Integrated Matrix (PIIM)
Matrix (PIIM)
Key Driver Actions 7
Key Driver Actions
Plan for S stained Impro ement PSI will continue improvement momentum Outcome is achieving sustained excellence Plan for Sustained Improvement g
PSI implemented using the PIIM
- OPPD and Exelon senior executives reviewed and fully support the PSI S
- Fleet-, Site-and Department-level action plans address gaps to excellence - Action plans owned by line managers
- Fort Calhoun Station Senior Leadership Team (SLT) will review progress at least monthly progress at least monthly
- OPPD and Exelon corporate executives will review progress during periodic Management Review Meetings
- Nuclear Oversight and Nuclear Safety Review Board will provide g
y p
independent oversight of progress
- Action plans will not be closed until SLT concludes outcomes are achieved E
ll ill b t d b f ll i l
t ti f th ENMM 8
Excellence will be cemented by full implementation of the ENMM and integration into the Exelon fleet
E l
I l
t ti f P f
Early Implementation of Performance Improvement Program
p p
- Brings focus on gaps to excellence and plans to close gaps
- Predictable - reliable - continually updated Predictable reliable continually updated
- Systematic approach utilizing full range of PI tools to address gaps Pl i
l i
d it i
ll d i b th PIIM
- Planning, analyzing and monitoring all driven by the PIIM
- Facilitates effective management oversight
- Computerized PIIM system directly connected to the 9
y y
Corrective Action Program computerized system
Plan for S stained Impro ement
- Key Drivers for Achieving and Sustaining Excellence identified Plan for Sustained Improvement identified
- Key Drivers provided as regulatory commitments for Restart Confirmatory Action Letter y
- Key Drivers address actions that ensure
- Corrective actions are effective
- Actions to prevent recurrence are effective
- Sustained performance improvement Addresses those iss es in Restart Checklist safet Addresses those issues in Restart Checklist, safety-significant Fundamental Performance Deficiencies and other critical performance improvement areas 10
Key Drivers for Achieving and Key Drivers for Achieving and Sustaining Excellence O
i ti l
ff ti f t lt d
f t
- Organizational effectiveness, safety culture, and safety conscious work environment
- Problem identification and resolution
- Performance improvement and learning programs
- Design and licensing basis control and use
- Site operational focus
- Site operational focus
- Procedures
- Equipment performance P
- Programs
- Nuclear oversight
- Transition to the ENMM and integration into the Exelon 11 g
Nuclear Fleet
Ke Dri ers
- Organizational effectiveness, safety culture, and safety conscious work environment Actions taken Key Drivers conscious work environment - Actions taken
- Entered into an Operating Service Agreement with Exelon Nuclear
- Assessed leadership capabilities and made needed changes
- Aligned organization to Vision, Mission & Values
- Established and trained leadership on corporate governance, oversight, support and perform model (GOSP) oversight, support and perform model (GOSP)
- Implemented GOSP accountability model
- Implemented GOSP management model with emphasis on nuclear safety and continuous improvement safety and continuous improvement
- Implemented performance management, succession planning, knowledge retention, and strategic workforce planning C
t d i
ti l
ff ti t i 12
- Created organizational effectiveness metric
Ke Dri ers
- Organizational effectiveness, safety culture, and safety conscious work environment Actions taken Key Drivers conscious work environment - Actions taken
- Trained managers, supervisors, and personnel on Safety Culture/SCWE
- Implemented the fleet Employee Concerns Program
- Implemented Differing Professional Opinion Process
- Implemented fleet Nuclear Safety Culture Monitoring Panel Implemented fleet Nuclear Safety Culture Monitoring Panel
- Implemented 2Cs meetings with Site VP (Compliments and Concerns)
Performed site wide safety culture focus group interviews
- Performed site-wide safety culture focus group interviews
- Established pulse surveys and industry leading safety culture metric 13
Ke Dri ers
- Organizational effectiveness, safety culture, and safety conscious work environment Results achieved Key Drivers conscious work environment - Results achieved
- Improving trend in organizational effectiveness
- Fleet support and challenge on station issues pp g
- Improving trend in safety culture and safety conscious work environment O
ti d
t t i l di th t ti i
f t lt
- Operations department is leading the station in safety culture
- Most departments have made significant improvement in safety culture - targeted department-level improvement actions being implemented
- Ready for restart 14
Ke Dri ers
- Organizational effectiveness, safety culture, and safety conscious work environment Plans going forward Key Drivers conscious work environment - Plans going forward
- Continue the safety culture pulse survey metric
- Focused safety culture improvement action granularity at y
p g
y department level
- External assessments annually for three years on station safety culture safety culture
- Continue to monitor the organizational effectiveness metric during plant operations
- External assessment of organizational effectiveness six months after restart 15
Ke Dri ers
- Problem identification and resolution - Actions taken C
ti A ti P
(CAP) t l
i f
d Key Drivers
- Corrective Action Program (CAP) root cause analysis performed early 2012 Enhanced procedures, staffing and training Improved Station and Department Corrective Action Review Boards (SCARB and DCARB)
Implemented detailed Exelon Nuclear performance monitoring tools Marked improvement in problem identification, root and apparent cause quality, and timely action closure in targeted pp q
y y
g work groups 16
Ke Dri ers
- Problem identification and resolution - Actions taken Additi l i t
S d CAP t
Key Drivers
- Additional improvement necessary - Second CAP root cause analysis completed in June 2013
- Station personnel not consistently following CAP procedures and station leadership not consistently reinforcing CAP procedure compliance
- CAP strategy for improving performance not fully implemented and understood at all organizational levels
- Station trending time consuming and not fully effective 17
Ke Dri ers
- Problem identification and resolution - Results achieved P
bl id tifi ti Key Drivers
- Problem identification
- 16,690 condition reports generated in 2013 (to date)
- Station engagement ratio at 70% (white rating) and improving g g
(
g) p g
- Issue Resolution
- Issue Resolution
- DCARB closure rejection rate at 13% and improving (white rating)
DCARB RCA j
ti t
t 11%
d i i
( hit ti
)
- DCARB RCA rejection rate at 11% and improving (white rating)
- RCA products demonstrating improvement
- Ready for restart 18 y
Ke Dri ers
- Problem identification and resolution - Plans going forward CAP b h i
i t
l Key Drivers
- CAP behavior improvement plans
- Reinforce CAP fundamentals /
accountability model with all station personnel
- Conduct additional training for Root Cause Analysts and Station and Department Corrective Action Review Board members
- Implement additional department CAPCOs and CAP advocates
Ke Dri ers
- Design and Licensing Basis Control - Actions completed
- Design and configuration control was identified as a Fundamental Key Drivers
- Design and configuration control was identified as a Fundamental Performance Deficiency
- Root cause analysis was completed in October 2012
- Scope of review covered 2007 to 2012 and identified causes and Scope of review covered 2007 to 2012 and identified causes and actions to improve performance
- Additional items have been identified by the NRC and OPPD since October 2012
- Accuracy and completeness of the design and licensing basis challenged the engineers efficiency at performing key station processes
- A new design and licensing basis root cause analysis was completed in 2013 in 2013
- Scope of the review covered the period from 1968 when the construction permit was issued to 2013 20
Key Drivers Key Drivers
- Design and licensing basis control and use - Actions completed
- Developed key calculation review program for accuracy and consistency Completed Phase 1 Phase 2 in progress Completed Phase 1, Phase 2 in progress
- Trained engineers and operators in utilizing the design and licensing basis for operability determinations and safety screenings/evaluations safety screenings/evaluations
- Performed structural walk downs of safety-related systems to ensure consistency with design drawings
- Monitoring engineer and operator work product quality utilizing review comments and scores from independent Engineering Assurance Group 21 Engineering Assurance Group
- Ready for restart
Ke Dri ers Key Drivers
- Design and licensing basis control and use - Actions going g
g g
g forward
- Define model for form and content of design basis and licensing basis documents
- Reconstitute design and licensing basis in a desktop available platform
- Train station staff on utilizing new design and licensing basis resources
- Perform annual risk-significant system design reviews until completion of reconstitution Maintain Engineering Assurance Group while necessaryto provide
- Maintain Engineering Assurance Group while necessaryto provide independent oversight of engineering work product quality 22
Key Drivers
- Design and licensing basis control and use - Engineering Department Performance Staffing Key Drivers
- Staffing
- 22 of 27 system engineers fully qualified - was 7 in 2012
- 20 of 22 design engineers fully qualified - was 15 in 2012
- 14 of 17 programs engineers fully qualified
- Additional design engineering supervision added
- Engineering Programs and Design Engineering Manager positions filled
- System and Program Health Reports prepared quarterly
- Challenged and approved by Plant Health Committee
- Engineering Assurance Group strengthened and effective Engineering Assurance Group strengthened and effective
- Feedback to engineers and supervisors across engineering
- Comprehensive engineering work product quality performance indicators 23 performance indicators
- Ready for restart
Ke Dri ers
- Procedures - Actions taken P
d i i dj t d t d
Key Drivers
- Procedure revision process adjusted to ensure procedure content and accuracy are addressed
- Revision criteria established based on
- Known issues and extent of condition
- Risk significance
- Support of event mitigation
- Support of event mitigation
- Reviewed and revised procedures (over 200)
- Annunciator Response Procedures (ARP)
- Operating Instructions (OI) 24
Ke Dri ers
- Procedures - Results achieved P
d i
d t i i i
lik lih d
f k l d b
d Key Drivers
- Procedures revised to minimize likelihood of knowledge-based errors
- Additional performance details developed in attachments
- Abnormal Operating Procedures (AOP)
- Emergency Operating Procedures (EOP)
- Level of detail and accuracy improved Level of detail and accuracy improved
- Alarm Response Procedures (ARP)
- Incorporated industry best practices
- Training operators on new procedures 25
Ke Dri ers
- Procedures - Plans going forward C
ti t
Key Drivers
- Continue to
- Incorporate operator input
- Reinforce procedure usage expectations p
g p
- Reinforce culture of rule-based execution
- Use field operators and simulator for verification and validation of actions and confirming procedure flow actions and confirming procedure flow
- Integrate procedure revisions
- Train new operators to revised documents C
di t
l t t i i ith t iti t
i d f t
- Coordinate plant training with transition to revised format
- Institute enhanced review of maintenance work order instructions 26
Key Drivers Key Drivers Equipment Performance - Actions Taken Plant Health Committee (PHC)
Plant Health Committee (PHC)
Changed PHC quorum requirements to include senior managers Revised PHC procedure for alignment with AP-913 Equipment Reliability and AP-928 Work Management attributes and AP 928 Work Management attributes Revised PHC agenda to focus on oversight of equipment reliability programs and processes Increase PHC meeting frequency to weekly to align with industry g
q y
y g
y standards Performance Monitoring System walk downs are now regularly performed by System Engineers System walk downs are now regularly performed by System Engineers Supervisors perform observations during system walk downs to ensure station expectations are being met Start-up monitoring plans have been developed for systems following 27 p
g p p
y g
extended shutdown
Ke Dri ers Equipment Performance - Actions taken Key Drivers Equipment Service Life (ESL)
Project team established - Identified critical equipment/components Project team established Identified critical equipment/components Replaced 989 equipment/components (breakers, relays, valves)
Completed review of over 10,000 components planned for post start-up Maintenance Rule / Preventive Maintenance Program Action plans for equipment in Maintenance Rule (a)(1)
- Majority are in monitoring status Majority are in monitoring status
- Systems in long term shutdown are being monitored in (a)(1)
- Condition Reports reviewed daily for Maintenance Rule issues Backlog of preventative maintenance tasks eliminated 28 Backlog of preventative maintenance tasks eliminated
Ke Dri ers Equipment Performance - Results achieved Key Drivers Significantly improved equipment reliability by repairing or replacing a large number of components Significant work on both Emergency Diesel Generators including voltage regulator modifications Refurbished 4160V and 480V busses Replaced 4160V breakers on busses 1A1 and 1A3 Replaced or refurbished Reactor Protection System power supplies R
l d Ch i
l d V l C
t l S t
i i d
t Replaced Chemical and Volume Control System piping and supports Upgraded turbine controls to digital system 29
Ke Dri ers Equipment Performance - Results achieved Key Drivers Additional actions include Completed System Health Readiness Reviews for restart Completed System Health Readiness Reviews for restart Revised system engineering quarterly system health process to be in line with industry standards Performance monitoring identified a low level vibration issue with Raw Performance monitoring identified a low level vibration issue with Raw Water Pump AC-10B prior to failure Bias for action demonstrated on recent plant issues including HPSI Pump SI 2B low flow issues and system imbalance and HCV 2983 Pump SI-2B low flow issues and system imbalance, and HCV-2983 excess leakage 30
- Ready for restart
Ke Dri ers Equipment Performance - Plans going forward Ad t E l
E i
t R li bilit d
d Key Drivers Adopt Exelon Equipment Reliability processes and procedures
- Performance Monitoring Plans, Walk Down Plans, and System Notebooks in System IQ
- Additional programmatic enhancements
- Margin Management Program
- Obsolescence Program
- Component Health Program
- Critical Component Failure Report
- Predictive Maintenance (Plant IQ) Program
- Vulnerability Review Process
- Troubleshooting Process 31
Ke Dri ers
- Nuclear Oversight - Actions taken C
d t d t
l i i 2012 Key Drivers
- Conducted a root cause analysis in 2012
- Established safety-focused OPPD strategic plan
- Early implementation of the ENMM Early implementation of the ENMM
- Documented expectations and roles and responsibilities
- Implemented Exelon Nuclear Safety Review Board (NSRB)
- Established Nuclear Oversight Department (NOS)
- Strengthened confidential Employee Concerns Program (ECP) 32
Ke Dri ers
- Nuclear Oversight - Results achieved E
t ti l
Key Drivers
- Expectations clear
- NOS intrusive and actively engaged
- NOS goes beyond minimum regulatory requirements NOS goes beyond minimum regulatory requirements
- Focus on values and behaviors that achieve excellence
- NSRB intrusive and effective
- Fort Calhoun leadership responsive to NOS and NSRB findings
- Staff utilizing ECP Staff utilizing ECP
- Ready for restart 33
N l
O i ht Pl i
f d
Key Drivers
- Nuclear Oversight - Plans going forward
- Effectiveness review of corrective actions and actions to prevent recurrence p
- Performance indicator effectiveness review
- Nuclear industry evaluation program assessment 34
Key Drivers
- Transition to the Exelon Nuclear Management Model (ENMM) and integration into the Exelon Nuclear Fleet
- Implementation of the ENMM and full integration into the Exelon fleet will cement sustained excellence in safety and efficiency of operation efficiency of operation 35
Exelons Philosophy on Nuclear Power Exelon s Philosophy on Nuclear Power Plant Leadership
- Exelon uses a comprehensive management system known Exelon uses a comprehensive management system known as the Exelon Nuclear Management Model
- To ensure top safety performance and operational efficiency in l
i d
i i
normal, outage, transient, and emergency situations
- To establish a strong safety culture The Exelon Nuclear Management Model contains all necessary policies, programs and procedures, but its success is driven by a strong and intrusive leadership team, a passion for excellence and effective independent oversight 36 g
E elon N clear Management Model Exelon Nuclear Management Model Model defines how Exelon works
- Common vision and shared values Common vision and shared values
- Conduct business
- Set priorities
- Develop and execute plans p
p
- Monitor and assess performance Playbook for driving standardization
- Gets everyone on the same page
- Defines the One way, best way to run the business
- Aligns the corporation and stations eliminating localized differences f
- Establishes processes for continuous assessment and improvement
- Documents progress and change Manage Fleet as single cohesive entity 37
- Manage Fleet as single cohesive entity
- Passion for Excellence
I t ti f F t C lh St ti Integration of Fort Calhoun Station into the Exelon Fleet
- Integration managed by joint OPPD/Exelon management team team
- Corporate and Site Functional Area Managers and Subject Matter Experts completing integration activities p
p g
g
- Integration organized around 27 functional areas 38
90% Corp 60% Corp 25% Corp 10% Corp CFAM Phase V:
Implementation Phase IV:
Implementation Planning Phase III:
Design Phase II:
Analysis Phase I:
Framework Development 10% Site Input 40% Site Input 75% Site Input 90% Site Input SFAM Early Analysis Accelerated Implementation Phase I Objectives:
Establish foundation for the integration process Phase II Objectives:
Complete Early Analysis and Accelerated I
l t ti Phase III Objectives:
Develop the proposed end-state for FCS Phase IV Objectives:
Develop an actionable implementation plan t
hi th d
Phase V Objectives:
Turnover all implementation responsibilities to line t
Form and charter Transition Team Establish decision-making and issue-resolution processes Define roles and Implementation Identify "gaps" between the FCS current state and the Exelon Nuclear baseline in controlled documents Define specific corporate and site organization structures and staffing levels Design complete it f
t ll d to achieve the end-state Create detailed schedule with resource loading, accountability assignments and management Establish appropriate on-going progress monitoring mechanisms responsibilities Create tools and templates documents, organization structure, performance metrics and IT systems Support station restart Complete gap templates to record suite of controlled documents Recommend metrics and other departmental tools assignments and completion timing defined 39 templates to record findings Exec Challenge OPPD & Exelon Challenge 2
Fort Calho n Integration Stat s Fort Calhoun Integration Status
- Framework Development C
l t
- Complete
- Analysis
- Complete
- Early Implementation
- Nuclear oversight
- Security
- Human performance
- Regulatory assurance
- Performance improvement p
- Records management
- Fort Calhoun Station performance challenged daily during Midwest fleet morning calls 40 g
Fort Calho n Integration Stat s
- Integration Design E
ti h ll ti i
Fort Calhoun Integration Status
- Executive challenge meetings in progress
- Scheduled to be completed by October 29, 2013
- Implementation Planning Implementation Planning
- Development of Level 3 schedules in progress
- Scheduled to be completed by December 20, 2013
- Implementation
- Scheduled to commence 30 days after achieving 100% power S h d l d t b
l t d b M h 31 2015
- Scheduled to be completed by March 31, 2015 41
Progress To ard Restart Progress Toward Restart
- Core re load completed July 29 2013
- Core re-load completed July 29, 2013
- Reactor vessel head installed August 25, 2013 2013
- Plant heat-up with non-nuclear heat -
September
- Submit Integrated Restart Report - After heat-up
- Ready for restart 42 y
Closing Remarks Closing Remarks Today we updated you on
- Plant status and major Plant status and major remaining work
- Fort Calhoun Station Performance Improvement Performance Improvement Policies and Procedures
- Plan for Sustained Improvement Ke Dri ers for Achie ing and
- Key Drivers for Achieving and Sustaining Excellence
- Exelon Nuclear Management M d l Model
- Integration of Fort Calhoun Station into the Exelon Nuclear Fl t
43 Fleet