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 Driving Through Restart Plan for Sustained Improvement August 27, 2013 1
Topics for Discussion Disc ssion
- Plant status and major remainingg work
- Fort Calhoun Station Performance Improvement Policies and Procedures
- Plan for Sustained Improvement
- Key Drivers for Achieving and Sustaining Excellence
- Exelon Nuclear Management Model (ENMM)
- Integration of Fort Calhoun Station into the Exelon Nuclear Fleet 2
C Current t Pl Plantt StStatust and dRRemainingi i Work W k
- Core re-load completed July 29, 2013
- Reactor R t vessell hheadd iinstalled t ll d A Augustt 25 25, 2013
- Critical path work
- Tornado missile protection modifications
- High-energy line break modifications
- CVCS letdown and charging lines
- Steam generator blow down lines
- Containment internal structures
- Plant heat heat-up up with non non-nuclear nuclear heat - September
- Submit Integrated Restart Report - After heat-up
- Ready for restart 3
R Regulatory l t Documents D t G Governing i Restart R t t
- December 13, 2011: NRC letter to OPPD documenting 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 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, Improvement Rev Rev. 0 submitted 4
Restart Decision-Making Decision Making Criteria
- Confirmatory Action Letter commitments addressed and 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
- Nuclear Safety Review Board
- Post-Restart Plan for Sustained Improvement in place
- Integrated Restart Report Submitted to NRC 5
E l Implementation Early I l t ti off Exelon E l Performance P f Improvement (PI) Program
- Demonstrate excellence in performance improvement
- Embrace continuous improvement
- Exemplify problem prevention, detection and correction
- Strive to achieve high levels of operational performance
- PI program and d procedures d iissued d to iimplement l
the policy 6
Plan for S Sustained stained Impro Improvement ement Vision Safe and efficient restart of Fort Calhoun Station and achievement of sustained excellence Plan for Sustained Improvement (PSI)
Performance Improvement Integrated Matrix (PIIM)
Key Driver Actions 7
Plan for S Sustained stained Impro Improvement ement
- PSI will continue improvement momentum
- Outcome is achieving g sustained excellence
- OPPD and Exelon senior executives reviewed and fully support the PSI
- Fleet-, Site-S 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
- OPPD and Exelon corporate executives will review progress during periodic Management Review Meetings
- Nuclear Oversight g and Nuclear Safety y Review Board will p provide independent oversight of progress
- Action plans will not be closed until SLT concludes outcomes are achieved
- E Excellence ll will ill b be cemented t dbby ffullll iimplementation l t ti off th the ENMM and integration into the Exelon fleet 8
E l Implementation Early I l t ti off Performance P f Improvement Program
- Brings focus on gaps to excellence and plans to close gaps
- Predictable - reliable - continually updated
- Systematic approach utilizing full range of PI tools to address gaps
- Planning, Pl i analyzing l i and d monitoring it i allll d driven i b by th the PIIM
- Facilitates effective management oversight
- Computerized PIIM system y directlyy connected to the Corrective Action Program computerized system 9
Plan for S Sustained stained ImproImprovement ement
- Key Drivers for Achieving and Sustaining Excellence identified
- Key Drivers provided as regulatory commitments for Restart Confirmatoryy Action Letter
- Key Drivers address actions that ensure
- Corrective actions are effective
- Actions to prevent recurrence are effective
- Sustained performance improvement Addresses those issues iss es in Restart Checklist Checklist, safet safety-significant Fundamental Performance Deficiencies and other critical performance improvement areas 10
Key Drivers for Achieving and Sustaining Excellence
- O Organizational i ti l effectiveness, ff ti safety f t culture, lt andd safety f t conscious work environment
- Problem identification and resolution
- Performance improvement and learning programs
- Design and licensing basis control and use
- Site operational focus
- Procedures
- Equipment performance
- Programs P
- Nuclear oversight g
- Transition to the ENMM and integration into the Exelon Nuclear Fleet 11
Ke Dri Key Drivers ers
- Organizational effectiveness, safety culture, and safety 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)
- Implemented GOSP accountability model
- Implemented GOSP management model with emphasis on nuclear safety and continuous improvement
- Implemented performance management, succession planning, knowledge retention, and strategic workforce planning
- Created C t d organizational i ti l effectiveness ff ti metric ti 12
Ke Dri Key Drivers ers
- Organizational effectiveness, safety culture, and safety 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 2Cs meetings with Site VP (Compliments and Concerns)
- Performed site-wide site wide safety culture focus group interviews
- Established pulse surveys and industry leading safety culture metric 13
Ke Dri Key Drivers ers
- Organizational effectiveness, safety culture, and safety conscious work environment - Results achieved
- Improving trend in organizational effectiveness
- Fleet support pp and challenge g on station issues
- Improving trend in safety culture and safety conscious work environment
- Operations O ti department d t t is i leading l di ththe station t ti iin safety f t culture lt
- Most departments have made significant improvement in safety culture - targeted department-level improvement actions being implemented
- Ready for restart 14
Ke Dri Key Driversers
- Organizational effectiveness, safety culture, and safety conscious work environment - Plans going forward
- Continue the safety culture pulse survey metric
- Focused safetyy culture improvement p action g granularity y at department level
- External assessments annually for three years on station safety culture
- Continue to monitor the organizational effectiveness metric during plant operations
- External assessment of organizational effectiveness six months after restart 15
Ke Dri Key Driversers
- Problem identification and resolution - Actions taken
- CCorrective ti AAction ti P Program (CAP) roott cause analysis l i performed f d 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 pp cause qquality, y and timely y action closure in targeted g
work groups 16
Ke Dri Key Driversers
- Problem identification and resolution - Actions taken
- Additi Additionall iimprovementt necessary - Second S d CAP roott 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 Key Drivers ers
- Problem identification and resolution - Results achieved
- Problem P bl id identification tifi ti
- 16,690 condition reports generated in 2013 (to date)
- Station engagement g g ratio at 70% ((white rating) g) and improving p g
- Issue Resolution
- DCARB closure rejection rate at 13% and improving (white rating)
- DCARB RCA rejection j ti rate t att 11% andd iimproving i ((white hit rating) ti )
- RCA products demonstrating improvement
- Readyy for restart 18
Ke Dri Key Driversers
- Problem identification and resolution - Plans going forward
- CAP b behavior h i iimprovementt plans l
- 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 Key Drivers ers
- Design and Licensing Basis Control - Actions completed
- 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 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
- Scope of the review covered the period from 1968 when the construction permit was issued to 2013 20
Key Drivers
- Design and licensing basis control and use - Actions completed
- Developed key calculation review program for accuracy and consistency
- Completed Phase 1, 1 Phase 2 in progress
- Trained engineers and operators in utilizing the design and licensing basis for operability determinations and 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
- Ready for restart 21
Ke Dri Key Driversers
- Design g and licensing g basis control and use - Actions g going 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 independent oversight of engineering work product quality 22
Key Drivers
- Design and licensing basis control and use - Engineering Department Performance
- 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
- Feedback to engineers and supervisors across engineering
- Comprehensive engineering work product quality performance indicators
- Ready for restart 23
Ke Dri Key Drivers ers
- Procedures - Actions taken
- PProcedure d revision i i process adjusted dj t d tto ensure procedure d
content and accuracy are addressed
- Revision criteria established based on
- Known issues and extent of condition
- Risk significance
- Support of event mitigation
- Reviewed and revised procedures (over 200)
- Annunciator Response Procedures (ARP)
- Operating Instructions (OI) 24
Ke Dri Key Drivers ers
- Procedures - Results achieved
- PProcedures d revised i d tto minimize i i i lik likelihood lih d off kknowledge-based l d b d errors
- Additional performance details developed in attachments
- Abnormal Operating Procedures (AOP)
- Emergency Operating Procedures (EOP)
- Level of detail and accuracy improved
- Alarm Response Procedures (ARP)
- Incorporated industry best practices
- Training operators on new procedures 25
Ke Dri Key Drivers ers
- Procedures - Plans going forward
- Continue C ti tto
- Incorporate operator input
- Reinforce pprocedure usage g expectations p
- Reinforce culture of rule-based execution
- Use field operators and simulator for verification and validation of actions and confirming procedure flow
- Integrate procedure revisions
- Train new operators to revised documents
- Coordinate C di t plantl t ttraining i i with ith ttransition iti tto revised i d fformatt
- Institute enhanced review of maintenance work order instructions 26
Key Drivers Equipment Performance - Actions Taken 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 AP 928 Work Management attributes
- Revised PHC agenda to focus on oversight of equipment reliability programs and processes
- Increase PHC meeting g frequency q y to weekly y to align g with industry y
standards Performance Monitoring
- System walk downs are now regularly performed by System Engineers
- Supervisors perform observations during system walk downs to ensure station expectations are being met
- p monitoring Start-up gpplans have been developed p for systems y following g
extended shutdown 27
Ke Dri Key Driversers Equipment Performance - Actions taken Equipment Service Life (ESL)
- 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
- 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
Ke Dri Key Drivers ers Equipment Performance - Results achieved 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 Replaced d Ch Chemical i l anddV Volume l C Control t lSSystem t piping i i and d supports t
- Upgraded turbine controls to digital system 29
Ke Dri Key Driversers Equipment Performance - Results achieved Additional actions include
- 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 Water Pump AC-10B prior to failure
- Bias for action demonstrated on recent plant issues including HPSI Pump SISI-2B 2B low flow issues and system imbalance imbalance, and HCV HCV-2983 2983 excess leakage
- Ready for restart 30
Ke Dri Key Drivers ers Equipment Performance - Plans going forward
- Adopt Ad t Exelon E l E Equipment i tR Reliability li bilit processes and d procedures d
- 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 Key Driversers
- Nuclear Oversight - Actions taken
- Conducted C d t d a roott cause analysis l i iin 2012
- Established safety-focused OPPD strategic plan
- 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 Key Driversers
- Nuclear Oversight - Results achieved
- Expectations E t ti clear l
- NOS intrusive and actively engaged
- 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
- Ready for restart 33
Key Drivers
- Nuclear N l O Oversight i ht - Plans Pl going i fforward d
- 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 35
Exelons Exelon s Philosophy on Nuclear Power Plant Leadership
- Exelon uses a comprehensive management system known as the Exelon Nuclear Management Model
- To ensure top safety performance and operational efficiency in normal, l outage, transient, i andd emergency situations i i
- 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 g
36
E elon N Exelon Nuclear clear Management Model
- Model defines how Exelon works
- Common vision and shared values
- Conduct business
- Set priorities
- Develop p and execute p plans
- 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
- Establishes processes for f continuous assessment and improvement
- Documents progress and change
- Manage Fleet as single cohesive entity
- Passion for Excellence 37
IIntegration t ti off FortF t Calhoun C lh Station St ti into the Exelon Fleet
- Integration managed by joint OPPD/Exelon management team
- Corporate and Site Functional Area Managers and Subject Matter Experts p completing p g integration g activities
- Integration organized around 27 functional areas 38
CFAM 90% Corp 60% Corp 25% Corp 10% Corp SFAM 10% Site Input 40% Site Input 75% Site Input 90% Site Input
- Phase I:
- Phase IV:
- Phase II:
- Phase III:
- Phase V:
Framework Implementation Analysis Design Implementation Development Planning Early Accelerated Analysis Implementation Phase I Phase II Phase III Phase IV Phase V Objectives: Objectives: Objectives: Objectives: Objectives:
- Establish foundation
- Complete Early
- Develop the
- Develop an
- Turnover all for the integration Analysis and proposed end-state actionable implementation process Accelerated for FCS implementation plan responsibilities to line
- Form and charter I l Implementation t ti
- Define specific t achieve to hi th the end-d managementt Transition Team
- Identify "gaps" corporate and site state
- Establish appropriate
- Establish decision- between the FCS organization
- Create detailed on-going progress making and issue- current state and the structures and schedule with monitoring resolution processes Exelon Nuclear staffing levels resource loading, mechanisms
- Define roles and baseline in controlled
- Design complete accountability responsibilities documents documents, suite it off controlled t ll d assignments and organization structure, documents completion timing
- Create tools and performance metrics defined templates
- Recommend metrics and IT systems and other
- Support station restart departmental tools
- Complete gap templates to record Exec Challenge Challenge 2 findings OPPD & Exelon 39
Fort Calhoun Calho n Integration Status Stat s
- Framework Development
- Complete C l t
- Analysis
- Complete
- Early Implementation
- Nuclear oversight
- Securityy
- Human performance
- Regulatory assurance
- Performance improvement p
- Records management
- Fort Calhoun Station performance challenged daily during Midwest fleet morning g calls 40
Fort Calhoun Calho n Integration Status Stat s
- Integration Design
- EExecutive ti challenge h ll meetings ti iin progress
- Scheduled to be completed by October 29, 2013
- 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
- Scheduled S h d l d tto b be completed l t dbby MMarchh 31 31, 2015 41
Progress To Toward ard Restart
- Core re re-load load completed July 29 29, 2013
- Reactor vessel head installed August 25, 2013
- Plant heat-up with non-nuclear heat -
September
- Submit Integrated Restart Report - After heat-up
- Readyy for restart 42
Closing Remarks
- Today we updated you on
- Plant status and major remaining work
- Fort Calhoun Station Performance Improvement Policies and Procedures
- Plan for Sustained Improvement
- Ke Key Drivers Dri ers for Achie Achieving ing and Sustaining Excellence
- Exelon Nuclear Management M d l Model
- Integration of Fort Calhoun Station into the Exelon Nuclear Fl t Fleet 43