ML14143A289

May 13, 2014 Summary of Meeting with Omaha Public Power District Presented the Status of Inspection Manual Chapter 0350 Oversight Activities at Fort Calhoun Station

ML14143A289
Person / Time
Site:	Fort Calhoun
Issue date:	05/23/2014
From:	Hay M NRC/RGN-IV/DRP
To:
Hay M
References
Download: ML14143A289 (13)

Text

Omaha Public Power District May 23, 2014 LICENSEE: Omaha Public Power District (OPPD)

FACILITY: Fort Calhoun Station

SUMMARY

OF MAY 13, 2014 MEETING WITH OMAHA PUBLIC POWER DISTRICT On May 13, 2014, a Category 1 meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and Omaha Public Power District (OPPD), at the Omaha Marriott located at 10220 Regency Circle, Omaha, Nebraska.

The NRC presented the status of Inspection Manual Chapter 0350 oversight activities at Fort Calhoun Station, and the Omaha Public Power District presented details of their actions for continued performance improvement following the plant restart in December, 2013. The slide presentations are available electronically from the NRCs Agency wide Documents Access and Management System (ADAMS) and are enclosed in this notice. A video of the public meeting will be posted on the web site 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/reading-rm/adams.html.

CONTACT: Michael Hay, RIV/DRP (817) 200-1147 Docket No.: 50-285 :

NRC Presentation Slides :

OPPD Presentation Slides

ML14143A289 SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:

By: MCH Yes No Non-Publicly Available Sensitive SUNSI REV Compl.

OFFICE RIV/C:DRP/F NAME MCHay:DLL/PBH SIGNATURE /RA/

DATE 05/23/14 Omaha Public Power District Electronic distribution by RIV:

RIV Regional Administrator (Marc.Dapas@nrc.gov)

RIV Deputy Regional Administrator (Steve.Reynolds@nrc.gov)

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

RIV DRP Deputy Director (Troy.Pruett@nrc.gov)

RIV DRS Director (Anton.Vegel@nrc.gov)

RIV 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)

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

FCS Administrative Assistant (Janise.Schwee@nrc.gov)

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

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

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

RIV Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)

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

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

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

Technical Support Assistant (Loretta.Williams@nrc.gov)

OEMail Resource OEWEB Resource (Sue.Bogle@nrc.gov)

RIV/ETA: OEDO (Joseph.Nick@nrc.gov)

RIV RSLO (Bill.Maier@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)

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

ACES (R4ACES@nrc.gov)

Introductions

Fort Calhoun Station Public Meeting

• Welcome Nuclear Regulatory Commission

• Introduction of NRC personnel May 13, 2014 Omaha, Nebraska 1 2 Purpose of Meeting Opening Remarks

• NRC will present status of regulatory activities

• Tony Vegel, Director, Division of Reactor Safety associated with the Fort Calhoun Station

- Chair, Fort Calhoun Station Oversight Panel

• OPPD will present details of Fort Calhoun

• Louise Lund, Deputy Director, Division of Operating Station performance improvement initiatives Reactor Licensing

- Vice Chair, Fort Calhoun Station Oversight Panel

• Public comments and questions 4

Enclosure 1

PostRestart CAL NRC Actions Completed

• NRC issued PostRestart Confirmatory Action OPPD committed to the NRC to continue Letter December 17, 2013 implementing improvement initiatives in key - Key areas for sustained performance improvement

• Human Performance areas and address specific technical items

• Safety Culture

• Corrective Action Process

• Design Basis Reconstitution 5 6 NRC Assessment Activities In Summary

• Routine inspections

• Increased NRC oversight activities remain

- Resident Inspectors

- Regional inspections

• Team inspection (Summer 2014)

• NRC continues to implement independent and

- Assess Corrective Action Process effectiveness thorough inspection activities to assess station

- Assess PostRestart Confirmatory Action Letter performance improvement progress items 7 8 Enclosure 1

OPPD Presentation Contacting the NRC

• Report an emergency

- (301) 8165100 (call collect)

• Report a safety concern

- (800) 6957403

- Allegation@nrc.gov

• General information or questions

- www.nrc.gov 9 10 11 Enclosure 1

Topics for Discussion OPPDs Fort Calhoun Station

• Plant Status Driving To Excellence

• Problem Identification and Resolution Public meeting with the U.S. Nuclear Regulatory Commission

• Engineering Products

• Design and Licensing Basis Control and Use

• Containment Internal Structures

• Site Operational Focus

• Integration

• Nuclear Oversight

• Closing Remarks May 13, 2014 1 2 Plant Status Plant Status Sitewide Industrial Safety Sitewide Human Performance Injury Comparison Summary 2013 2014 2014 Sitewide Clock Reset:

Untreated Injuries: 11 3 March 17: Stator water First Aid Injuries: 15 0 cooling leak caused an automatic trip of the unit Occupational Safety and Health 4 0 Administration (OSHA) Recordable:

Industry best is in the Lost-Time / Restricted: 4 0 range of 0 to 2 sitewide clock resets per year 3 4 Enclosure 2

Plant Status Plant Status Department-Level Human Performance Capacity Factor 140 100 120 90 100 80

• • Department-Level Performance Goals 70 80 93.2%

Percent

• 2014 Year-to-Date 134 60 60 50 since 40 61 40 restart 58 30 20 41 6* 8 8 20 0 Dec-13 Jan-14 Feb-14 Mar-14 Apr-14 May-14 Jun-14 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 2011 2012 2013 *2014 **2015 **2016 Historical Data Site Performance Goal Industry Top Quartile Year End Projection Industry best is in range of 6 to 12 dept. clock resets per year 5 6 Plant Status Problem Identification and Resolution

• Corrective Action Program (CAP) changes implemented to Operational Challenges improve OPPDs detection and correction of plant issues

• Shut down due to maintenance - Provide an updated status of actions and effectiveness reviews evolution on stator water system

• Results

• Down power due to VA-46 Control - Focused area self-assessment insights Room Air Conditioning Units

- Performance indicators insights

- Trending insights

- Areas providing challenges and actions to address 7 8 Enclosure 2

Engineering CAP Health: March 2013 - March 2014 Comparison Engineering Engineering Engineering Products M arch 2013 M arch 2014 Coding and Event Code Backlog (1 month)

Analysis Number of CRs Coded w ith Adverse Trend (1 month)

• Observations and trends for: (trending) Cause Code Backlog (1 month) 1 0 Overall Number of Significant Events (1 year)

- Corrective Action Products Number of CRs Identified (1 month) 392 124 Identification

- Quality of Engineering Products and 3 Month Engagement Ratio 65% 66%

Screening Self-Identification Ratio - Level 1,2,3 CRs (1 month) 42% 74%

Meetings

- Operability Evaluations Number of CAP Meeting Observations (1 month) 4 0 Number of Repeat Events (1 year) 1 0

- Reportability Determinations Number of Ineffective Effective Review s for Root Causes Only (1 month) 0 0 DCARB RCA Rejection Rate (3 month avg.) 0% 0%

DCARB ACA (Tier 1) Rejection Rate (3 month avg.) 29% 20%

Analysis DCARB ACA (Tier 2) Rejection Rate (3 month avg.) 58% 13%

RCA Rejection Rate (3 month avg.) 57% 0%

ACA (Tier 1) Rejection Rate (3 month avg.) 0% 0%

DCARB CR Closure Rejection Rate (3 month avg.) 30% 15%

9 10 MRC CR Closure Rejection Rate (3 month avg.) 50% 25%

Engineering CAP Health: March 2013 - March 2014 Comparison Engineering Engineering M arch 2013 M arch 2014 Overdue Priorities (1 month) 47 7 Number of Overdue Non-ACA and Non-RCA REs (1 month) 9 0 Number of Overdue Corrective Actions (3 month total) Closure Rate for Engineering of Active Action items A, B, C 9 7 4000 Number of Overdue Simple Causes (1 month) 8 0 3500 Average Time to Perform RCAs (12 month avg.) 151 83 3000 Number of Average Time to Perform Tier 1 ACAs (1 month avg.) 252 380 2500 Average Time to Perform Tier 2 ACAs (1 month) 241 68 2000 Action items Average Time to Perform Simple Causes (1 month) 15 15 1500 Median Age of Open Non-Outage AIs (days) (1 month) 965 1,148 Timeliness 1000 Number of Open Non-Outage AIs > 365 days (1 month) 212 733 500 Oldest Open Non-Outage AI (days) (1 month) 1,930 2,294 0 Number of Open Outage-Related AIs (1 month) 261 124 Dec13 Jan14 Feb14 Mar14 Apr14 Number of Open CAPR's (1 month) 26 15 Number of AC Actions 3,683 3,459 3,230 2,652 2,374 Number of Open CA's (1 month) 1,785 1,270 Number of Open RE's (1 month) 465 144 Median Age of Open RA's (days) (1 month) 774 956 Number of Open RA's > 365 days (1 month) 320 321 11 12 CRs in Ready to Close (1 month) 917 497 Enclosure 2

Engineering Products Engineering Assurance Group Products 2013-2014 Comparison 120.00%

• Observations and trends for:

100.00%

Percent of Accepted EAG Products

- Corrective Action Products 80.00%

- Quality of Engineering Products 60.00%

- Operability Evaluations 40.00%

- Reportability Determinations 20.00%

0.00%

Applicability Immediate Applicability Engineering Operability Reportability 50.59 50.59 Screens Determinations Operability Total Determinations Products Evaluations Evaluations Evaluations 72.48 Screens Determinations Percent Accepted 82.80% 94.29% 98.53% 90.75% 98.00% 70.30% 80.43% 78.38% 94.87%

2013 Percent Accepted 100.00% 96.55% 96.43% 92.31% 98.49% 66.67% 81.25% 0 97.56%

2014 13 14 Design and Licensing Basis Design and Licensing Basis Control and Use Control and Use

• OPPDs post-restart commitment states:

• Project Activities Completed or In Progress

- After restart, OPPD will complete a significant effort to perform a risk- - January 2014 - Commenced drafting project request for proposal focused reconstitution of the: (COMPLETE)

Design basis, - February 7, 2014 - Issue project request for proposal to vendors Licensing basis, and (COMPLETE)

Updated Safety Analysis Report - March 28, 2014 - Vendor proposals due (COMPLETE)

- As part of this project, OPPD will: - April 30, 2014 - Award project contract (COMPLETE)

Ensure proper classification of equipment, - May 5, 2014 - Commence project (COMPLETE)

Convert to a safety-related Q List approach for equipment classification, and Complete a key calculation review

- January 2014: Commenced review of key calculations

- A pilot program will be completed during 2014 on a selected system Pre-restart 93 calculations were reviewed, with 45 revisions recommended to check & adjust the process, scheduling and resource allocation 330 of 382 key calculations have been reviewed with 147 revisions recommended

- Complete the reconstitution project before the end of the Calculation issues identified to date have been determined to be not 4th quarter, 2018 consequential, but calculations must be brought up to todays standards 15 15 16 16 Enclosure 2

Design and Licensing Basis Design and Licensing Basis Control and Use Control and Use

• Project Activities to be Completed

• Project Oversight

- June 30, 2014 - Complete Phase 1 (Develop project processes/procedures) - Oversight to be provided as follows:

- December 31, 2014 - Complete Phase 2 (Pilot program - NRC

• OPPD project manager who is independent of the production work commitment)

• OPPD/Exelon senior management

- February 1, 2015 - Complete project status assessment Approximately every six months between Feb. 1, 2015, and Dec. 31, 2018 -

• Periodic project status assessments Perform project status assessments

• Independent project oversight board

- February 28, 2015 - Complete Phase 3 (Incorporate lessons learned from pilot program)

• FCS Nuclear Oversight Department

- December 31, 2018 - Complete Phase 4 (Complete reconstitution

• Nuclear Safety Review Board project - NRC commitment)

- February 1, 2019 - Complete project final effectiveness review 17 17 18 18 Containment Internal Structures Containment Internal Structures

• OPPD committed to:

• Resolution strategy for 2015 refueling outage

- Evaluate the structural design margin for the containment internal - Install columns in the basement of the containment building under structure, and reactor cavity and compartments, and resolve any floor Beams 22A and Beam 22B to reduce the loading on the two deficiencies in accordance with FCSs CAP floor beams

- Regarding Beams 22A and Beam 22B under Safety Injection Tanks - Replace the existing RVHS pedestal supports with a structural steel 6B/D, resolve any deficiencies in accordance with the CAP box frame that spans the floor and transfers the loads to adjacent

- Resolve and correct any deficiencies surrounding the reactor vessel walls and columns head stand (RVHS) prior to its next use - Preliminary design will be complete by third quarter 2014 19 20 Enclosure 2

Site Operational Focus The Exelon Nuclear Management Model Procedures Integration status

• Procedure focus

• More than 4,000 tasks completed

- Quality - Design Review Board

- Use and Adherence - Human Performance Fundamentals

- Level of Detail - Nuclear Oversight Processes

• Cornerstone for performance - Learning Programs

- Emergency and Abnormal - Operations Standards and Expectations Operations

• Approximately 8,000 tasks remain, with 6,000 of these Demonstrated using simulator Upgrades continue scheduled for completion in 2014

- Normal Operations - Weekly integration status meetings to review schedule adherence Support plant operations Require verbatim compliance

• Lessons Learned

- Administrative - Data Sharing Station-wide effort - Gap Analysis 21 22 Nuclear Oversight Flooding Recovery Action Plans Independent Assessment

• Five Flooding Recovery Post-Restart Action commitments outlined in Section 2 of the Confirmatory Action Letter (CAL)

• Three of the Section 2 Flooding Recovery Post-Restart Action commitments have been submitted to the NRC resident inspectors

- Item 4.4.3.1 - Gather flood response lessons learned through condition report reviews to determine if procedure or strategy changes should be implemented (completed December 12, 2012)

Plant Observations and Performance - Item 4.4.3.3 - Implement procedure and strategy changes as indicated by the lessons learned review conducted (completed February 20, 2013)

- Item 1.2.3.21 - Inspect tank and equipment on demineralized water tank for damage (completed February 10, 2014)

• Two of the Section 2 Flooding Recovery Post-Restart Action commitments are scheduled

- Item 4.4.3.2 - Review flood design basis and determine if the 2011 flood event provides additional information that should drive design basis changes

- Item 1.2.3.82 - Perform independent spent fuel storage installation route load test 23 24 Enclosure 2

Fukushima Response Project Closing Remarks

• Project scope

• Plant Status

- Flooding reevaluation and seismic evaluation Portable Submersible

• Problem Identification and Resolution

- Flooding and seismic walkdowns Results submitted to the NRC Pumps

• Engineering Products Actions ongoing

• Design and Licensing Basis Control

- Mitigating strategies for beyond design basis and Use external events

• Containment Internal Structures

- Strategy developed and submitted to NRC Portable equipment pre-staged at FCS

• Site Operational Focus Procedures (Admin/Operations/PM/Testing)

Staffing

• Integration Communications (internal and external)

• Nuclear Oversight

- Spent Fuel Pool Instrumentation (SFPI)

• Closing Remarks SFPI modifications submitted to the NRC 25 26 Enclosure 2