The United States of America Seventh National Report for the Convention on Nuclear Safety (2016)

during construction that it has successfully performed the ITAAC. Periodically during

construction, the NRC staff will publish notices of the successful completion of inspections,

tests, and analyses in the Federal Register. Not less than 180 days before the date scheduled

for initial loading of fuel, the NRC will publish a notice of intended operation of the facility in the

Federal Register. Affected members of the public have an opportunity to request a hearing on

whether the facility complies or will comply with the accepted criteria. However, requests for

such a hearing will be considered only if the petitioner demonstrates that one or more of the

acceptance criteria have not been (or will not be) met, and the specific operational

consequences of nonconformance would be contrary to providing reasonable assurance that

the public health and safety is adequately protected.

19.2 Definition and Revision of Operational Limits and Conditions

The license for each nuclear facility must contain technical specifications that set operational

limits and conditions derived from the safety analyses, tests, and operational experience. The

regulations contained in 10 CFR 50.36, “Technical Specifications,” define the requirements that

apply to the plant-specific technical specifications. At a minimum, the technical specifications

must describe the specific characteristics of the facility and the conditions for its operation that

are required to adequately protect the health and safety of the public. Each applicant must note

items that directly apply to maintaining the integrity of the physical barriers designed to contain

radioactive material. In 10 CFR 50.36, the NRC requires that the technical specifications must

be derived from the analyses and evaluations in the safety analysis report. Licensees cannot

change the technical specifications without prior NRC approval.

In 1992, the NRC issued improved, vendor-specific (e.g., Babcock & Wilcox, Westinghouse,

Combustion Engineering, and General Electric) standard technical specifications in NUREGs

1430-1434 and periodically revises them on the basis of experience. The NRC issued

Revision 4 to these NUREGs in April 2012.

The NRC encourages licensees to use the improved standard technical specifications as the

basis for plant-specific technical specifications. The agency also considers requests to adopt

parts of the improved standard technical specifications, even if the licensee does not adopt all of

the improvements. These parts, which will include all related requirements, will normally be

developed as line-item improvements. To date, almost three-quarters of the operating

commercial nuclear plants have converted their technical specifications to the improved

standard technical specifications.

Consistent with the Commission’s policy statements on technical specifications and the use

of PRAs, the NRC and the nuclear industry are developing risk-informed improvements to

technical specifications. These improvements and initiatives are intended to maintain or improve

safety while reducing unnecessary burden and to make technical specifications congruent with

the agency’s other risk-informed regulatory requirements (in particular, the risk management

requirements of the Maintenance Rule in 10 CFR 50.65(a)(4)).

19.3 Approved Procedures

In the United States, operations, maintenance, inspection, and testing of a nuclear installation

are conducted in accordance with approved procedures. Each nuclear facility is required to

follow the quality assurance requirements in Appendix B to 10 CFR Part 50. Criterion V,

“Instructions, Procedures, and Drawings,” of Appendix B to 10 CFR Part 50, requires that

licensees establish measures to ensure that activities that affect quality will be prescribed by

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appropriate documented instructions, procedures, or drawings. RG 1.33, Revision 3, provides

supplemental guidance.

19.4 Procedures for Responding to Anticipated Operational Occurrences and Accidents

The NRC has provided guidance on responding to anticipated operational occurrences and

accidents in NUREG-0737, “Clarification of TMI Action Plan Requirements,” issued in

November 1980; NUREG-0737, Supplement 1, “Requirements for Emergency Response

Capability,” issued in January 1983; and NUREG-0899, “Guidelines for the Preparation of

Emergency Operating Procedures,” issued in August 1982.

After the 1979 accident at Three Mile Island, Unit 2, the NRC issued orders requiring licensees

to develop procedures for coping with certain plant transients and postulated accidents. It also

issued NUREG-0737 in 1980 and Supplement 1 to that document in 1983, which recommended

that licensees develop procedures to cope with accidents and transients that are caused by

initiating events analyzed in the final safety analysis report with multiple failures of equipment.

NUREG-0899 gives programmatic guidance for developing emergency operating procedures.

To ensure that proper procedures had been developed to respond to plant transients and

accidents, the NRC reviewed plants using the guidance in NUREG-0800, Section 13.5.2.1.

Furthermore, as discussed in Section 1.3.1 of this report, the NRC has ordered all power reactor

licensees to develop mitigating strategies to respond to beyond-design-basis events at all units

at a site for an indefinite period of time. A related rulemaking is underway that would codify that

order, including the procedures and guidance for managing situations at multiunit sites, as well

as incorporate a Fukushima lesson-learned initiative associated with strengthening and

integrating emergency procedures. The proposed Mitigation of Beyond-Design-Basis Events

rulemaking would require that licensees ensure smooth transition between each of their

response guidelines, including FLEX support guidelines which are used for mitigating strategies,

and emergency operating procedures. The implementation of the order is being inspected by

the NRC after all units at a site come into compliance. The implementation of the rule

requirements will be inspected at a later date, after the rule has been finalized.

In SRM-SECY-15-0065, “Proposed Rule: Mitigation of Beyond Design Basis Events,” dated

April 30, 2015, the Commission directed that SAMGs continue to be implemented voluntarily

rather than being imposed as an NRC requirement. As such, each licensee has made a formal,

written regulatory commitment to perform timely updates of the site-specific SAMGs with the

vendor-specific owner’s group technical guidance document and to integrate them with other

emergency response guideline sets and symptom-based emergency operating procedures.

Based on the Commission’s direction, the NRC will provide periodic oversight of the SAMGs

through the Reactor Oversight Process.

19.5 Availability of Engineering and Technical Support

The NRC’s Reactor Oversight Process, described in Article 6 of this report, includes techniques

to ensure that adequate engineering and technical support is available throughout the lifetime of

a nuclear installation. Section 50.120 of 10 CFR, “Training and Qualification of Nuclear Power

Plant Personnel,” requires licensees to establish, 18 months before fuel load, a variety of

training programs for instrumentation and control, electrical maintenance and mechanical

maintenance personnel, including engineering support personnel. The NRC verifies the

adequacy of these programs during initial licensing. During the lifetime of the plant, availability

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of trained and competent engineers and technical support is revealed through equipment

performance. The NRC’s Reactor Oversight Process implements several IPs that focus on

verifying the availability and operability of safety-related equipment and equipment important to

safety. Inspectors may identify findings during these inspections. Licensees also report

performance indicators, which are verified by the Reactor Oversight Process. Depending on

inspection findings and performance indicators, the NRC conducts additional inspections to

focus on the causes of the performance problems as prescribed by the Reactor Oversight

Process Action Matrix.

19.6 Incident Reporting

Two of the many elements contributing to the safety of nuclear power plants are emergency

response and the feedback of operating experience into plant operations. The licensee event

reporting requirements of 10 CFR 50.72, “Immediate Notification Requirements for Operating

Nuclear Power Reactors,” and 10 CFR 50.73, “Licensee Event Report System,” help to achieve

these goals, as 10 CFR 50.72 requires immediate notification requirements through the

emergency notification system, and 10 CFR 50.73 requires 60-day written licensee event

reports. All 10 CFR 50.72 event notifications and 10 CFR 50.73 licensee event reports, except

those containing sensitive security-related information, are available on the NRC’s public Web

site.

The NRC staff uses the information reported under these regulations to respond to

emergencies, monitor ongoing events, confirm licensing bases, study potentially generic safety

problems, assess trends and patterns of operational experience, monitor performance, identify

precursors of more significant events, and provide operational experience to the industry.

Evaluations of events as documented in NRC inspection reports are publicly available on the

NRC Web site. The annual abnormal occurrence report to Congress (NUREG-0090, “Report to

Congress on Abnormal Occurrences”), which details specific events that result in a conditional

core damage probability greater than 1×10^-4 and other events of significant interest, is also

publicly available.

The NRC modified these rules in 1992 and 2000. The modified rules continue to provide the

Commission with reports of significant events for which the NRC may need to act to maintain or

improve reactor safety, or to respond to heightened public concern. The modified rules also

better align requirements on event reporting with the type of information that the NRC needs to

carry out its safety mission. The NRC issued NUREG-1022, “Event Reporting Guidelines

10 CFR 50.72 and 50.73,” Revision 2, in October 2000, concurrent with the rule changes.

NUREG-1022, Revision 3, published in January 2013 and effective July 2013, revises the event

reporting guidelines in NUREG-1022, Revision 2, to provide clearer guidance. Supplement 1 to

NUREG-1022, Revision 3, published in September 2014, endorses NEI 13-01, “Reportable

Action Levels for Loss of Emergency Preparedness Capabilities,” dated July 2014. NEI 13-01

provides specific guidance for reporting under 10 CFR 50.72(b)(3)(xiii) and, as a result, reduces

the need for engineering judgment.

NUREG-1022 is structured to help licensees promptly and completely report specified events

and conditions. It discusses general issues that have been difficult to implement in the past,

such as engineering judgment, time limits for reporting, multiple failures and related events,

deficiencies discovered during licensee engineering reviews, and human performance issues. It

also includes a comprehensive discussion of each reporting criterion with illustrative examples

and definitions of key terms and phrases.

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Event reporting under these rules since 1984 has contributed significantly to focusing the

attention of the NRC and the nuclear industry on the lessons learned from operating experience

to improve reactor safety. Over the years, improvements in reactor safety system performance

and decreasing trends in the number of reactor transients and significant events have been

evident. Between 2007 and 2012, there were no significant U.S. reactor events (defined as

having a conditional core damage probability greater than 1×10^-4).

The NRC reviews each reported reactor-related event and assigns a rating of 1 through 7 or

below scale on the International Nuclear and Radiological Event Scale. The agency submits

events with a rating of 2 or higher to the IAEA nuclear events Web-based system for public

posting. Other events that attract international public interest are also considered for posting

regardless of the International Nuclear and Radiological Event Scale rating. The NRC describes

this process in RIS 2002-01, “Changes to NRC Participation in the International Nuclear Event

Scale,” issued in January 2002, and Information Notice 2009-27, “Revised International Nuclear

and Radiological Event Scale User’s Manual,” issued in November 2009.

19.7 Programs To Collect and Analyze Operating Experience

As outlined in GL 82-04, “Use of INPO SEE-IN (Significant Event Evaluation and Information

Network) Program,” issued in March 1982, INPO and the individual licensees are jointly

responsible for compiling and analyzing operating experience within the industry. In

November 2011, INPO replaced the Significant Event Evaluation and Information Network

program with the Operating Experience and Construction Experience programs. These

programs use four different levels of INPO event reports to communicate significant events to

the industry. In addition, INPO’s Consolidated Events System provides member utilities with the

ability to report lower level events and equipment failure data to INPO. The data is shared with

all INPO members and, in a limited fashion, with the NRC.

The NRC Operating Experience Program consists of a process with four phases:

(1) collection, (2) screening, (3) evaluation, and (4) application of operating experience data,

with a common theme of communication running throughout.

The NRC facilitates the collection, storage, and retrieval of operating experience data through

an internal Web site, which provides a centralized repository of links to databases relevant to

operating experience on the NRC, including event reports, international reports, and inspection

findings. Since 2010, a broader database has been providing the same type of centralized data

storage and retrieval options for lower level operating experience, which can be a useful source

of information for long-term trending and analysis even when the issues do not rise to the

threshold of reportable events.

The NRC reviews event notifications and lower level operating experience from resident

inspector feedback to the regional offices daily to determine the level of followup each item

requires. The NRC also considers licensee event reports, reports of defects and noncompliance

submitted under 10 CFR Part 21, “Reporting of Defects and Noncompliance,” international

operating experience received from the International Nuclear and Radiological Event Scale Web

site and from the IAEA International Reporting System for Operating Experience, and any items

of potential interest brought forward by the Office of New Reactors and the Office of Nuclear

Regulatory Research.

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Items that do not require significant evaluation are still reviewed and considered for followup

actions. These can include email notification of technical staff review for event analysis and

trending or an operating experience communication distributed internally throughout the agency

summarizing the issue and its safety significance. Events that may be of broader interest to

technical staff may be summarized in an article for a periodic newsletter, or developed into

standalone operating experience notes, which serve to provide a high-level summary of the

issue and any actions being taken. Items that meet the criteria for both safety significance and

generic applicability are held for further evaluation. This evaluation will generally involve an

in-depth examination of the technical aspects of each issue, its potential safety significance, and

a review of previous operating experience.

Finally, the operating experience program applies the results of these evaluations. An operating

experience application may include the issuance of a generic communication, a proposal for

rulemaking, a referral for further study as a generic safety issue, or a revision of IPs.

The NRC’s ConE program is described in Section 18.4 of this report. The NRC participates in

the International Nuclear and Radiological Event Scale and the IAEA international reporting

system for operating experience to both communicate operating experience internationally and

review events that other member States have posted. Operating experience personnel review

all reactor event notifications the agency receives and rate them on the International Nuclear

and Radiological Event Scale. As Section 19.6 of this report discusses, events with a rating of 2

or higher are posted to the International Nuclear and Radiological Event Scale Web site within

48 hours. The NRC screens all international reactor events posted to this Web site to determine

the appropriate level of evaluation required based on safety significance and applicability to U.S.

plants. The NRC uses the same criteria to screen the IAEA’s international reporting system for

operating experience reports as they are posted. The NRC submits all U.S. relevant reactor-

related generic communications to the IAEA international reporting system for communication to

the international community along with selected licensee event reports related to events that

have attracted international interest.

19.8 Radioactive Waste

The NRC has regulations and guidance for nuclear power reactor licensees to ensure the safe

management and disposal of low-level radioactive waste. Onsite low-level waste must be

managed in accordance with the NRC regulations in 10 CFR Part 20, “Standards for Protection

against Radiation,” and 10 CFR Part 50. For example, Subpart K, “Waste Disposal,” to

10 CFR Part 20, deals with licensee treatment and disposition of radioactive waste. In addition,

GL 1981-38, “Storage of Low-Level Radioactive Wastes at Power Reactor Sites,” dated

November 10, 1981, provides guidance on measures for ensuring the safe storage of low-level

waste. The low-level waste storage guidelines were last updated in RIS 2011-09, “Available

Resources Associated with Extended Storage of Low-Level Waste” in August 2011.

Notwithstanding these regulations and guidance, the economics of waste disposal in the United

States have encouraged practices to minimize radioactive waste. In the past decade or so,

disposal costs have risen significantly, and volumes of waste produced have decreased greatly

as operations technology evolves. In June 2008, the NRC published RG 4.21, “Minimization of

Contamination and Radioactive Waste Generation: Life-Cycle Planning.” Additionally, in

May 2012, the NRC published the Policy Statement on Low-Level Radioactive Waste

Management and Volume Reduction. The Policy Statement is a revision of the NRC’s 1981

Policy Statement on Low-Level Radioactive Waste Volume Reduction to encourage licensees to

take steps to reduce the amount of waste generated and to reduce the volume of waste once

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generated. Currently, nuclear power reactors generate only small amounts (about 1,000-2,000

cubic feet per unit) of operational waste each year.

For storage, waste is conditioned into a form that is stable and safe to minimize the likelihood

that it will migrate. Waste placed into storage is in a form that is suitable for disposal, or at least

a form that can be made suitable for future disposal. The NRC maintains specific regulations for

the independent storage of spent nuclear fuel, high-level radioactive waste, and reactor-related

low-level waste greater than Class C¹⁸ in 10 CFR Part 72, “Licensing Requirements for the

Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and

Reactor-Related Greater than Class C Waste,” and detailed regulations for designing and

operating low-level waste disposal facilities in 10 CFR Part 61, “Licensing Requirements for

Land Disposal of Radioactive Waste.”

The U.S. Government addresses in detail the spent fuel and radioactive waste programs,

including high-level waste, in a report prepared to satisfy the reporting requirements of the Joint

Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste

Management. The latest report (DOE/EM-0654, “United States of America Fifth National Report

for the Joint Convention on the Safety of Spent Fuel Management and on the Safety of

Radioactive Waste Management,” Revision 4, issued in September 2014) is available on the

DOE Environmental Management Web site.

In August 2013, the U.S. Court of Appeals for the District of Columbia Circuit ordered NRC to

continue with the licensing process for DOE’s Yucca Mountain construction authorization

application, until Congress directs otherwise or there are no appropriated funds remaining. After

the Court’s decision, in January 2015, NRC completed the safety evaluation report for the

application and found that DOE’s application meets most, but not all, of the applicable NRC

regulatory requirements. Specifically, requirements not met are related to certain conditions of

land ownership and water rights. The NRC published a supplement to DOE’s environmental

impact statements in May 2016. “Supplement to the Department of Energy’s Environmental

Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and

High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada” evaluates the potential

environmental impacts on groundwater and impacts associated with the discharge of any

contaminated groundwater to the ground surface due to potential releases from a geologic

repository for spent nuclear fuel and high-level radioactive waste at Yucca Mountain, Nye

County, Nevada. The NRC’s adjudicatory proceeding for the Yucca Mountain application, which

must be completed before a licensing decision can be made, remains suspended.

19.9 Vienna Declaration on Nuclear Safety

The NRC relies on regulations in 10 CFR Chapter I and internally developed associated

programs in granting the initial authorization to operate a nuclear installation and in monitoring

its safe operation throughout its life. These regulations are generally consistent with IAEA and

NEA safety standards and serve to prevent accidents and mitigate adverse consequences in a

18 NRCs classification system contained in 10 CFR Part 61 includes Class A, B, and C low level waste that is

suitable for land disposal. Low level waste that does not meet the criteria for these classes is considered greater

than Class C and eventually will be managed by DOE in a yet-to-be-determined manner. Until then, such waste

must be managed (stored) by licensees. Regulations in 10 CFR Part 72 allow, but do not require, the onsite

management of greater than class C low level waste in independent storage facilities separate from the ones

used to manage spent fuel.

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manner that effectively addresses long-term offsite contamination. Because NRC requirements

protect public health and safety through prevention of accidents and by mitigating releases in

the event of an accident, the risk of offsite contamination is rendered acceptably low.

Furthermore, a recent Integrated Regulatory Review Service (IRRS) mission conducted at the

NRC found that the NRC has a number of processes in place, including a robust and mature

inspection program, the analysis of the operating experience, the generic upgrades and

regulatory changes, the use of risk informed regulation, and the license renewal rule, that meet

the intent of a periodic safety review. The results of the IRRS mission and the alternate program

that the United States employs in lieu of conducting periodic safety reviews are further

discussed in Sections 8.1.5 and 14.1.5 of this report.

In conclusion, the NRC’s regulatory practices are consistent with the principles of the Vienna

Declaration on Nuclear Safety.

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Convention

on Nuclear Safety

Report:

The Role of the Institute of Nuclear Power

Operations in Supporting the United States

Commercial Nuclear Power Industry’s

Focus on Nuclear Safety

January 2016

other rights reserved.

NOTICE: This information was prepared in connection with work sponsored by the Institute of Nuclear Power Operations (INPO).

Neither INPO, INPO members, INPO participants, nor any person acting on the behalf of them (a) makes any warranty or

representation, expressed or implied, with respect to the accuracy, completeness, or usefulness of the information contained in

this document, or that the use of any information, apparatus, method, or process disclosed in this document may not infringe on

privately owned rights, or (b) assumes any liabilities with respect to the use of, or for damages resulting from the use of any

information, apparatus, method, or process disclosed in this document.

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Executive Summary

The U.S. nuclear power industry established the Institute of Nuclear Power Operations

(INPO or “the Institute”) in 1979 after the event at Three Mile Island Nuclear Station to

promote the highest levels of safety and reliability (i.e., to promote excellence) in plant

operation. INPO is a nongovernmental corporation that operates on a not-for-profit basis.

Under United States tax law, the company is classified as a charitable organization that

“relieves the burden of government.”

Since its inception, all utility organizations that have direct responsibility and legal authority

to operate or construct commercial nuclear plants in the United States have maintained

continuous membership in INPO, which currently has 23 members. In addition, many utility

organizations that jointly own these nuclear power plants are associate members. A number

of international utility organizations and major suppliers also voluntarily participate in the

Institute’s activities and programs.

In forming INPO, the nuclear power industry took an unusual step. The industry placed itself

in the role of overseeing INPO activities while endowing INPO with ample authority to bring

pressure for change on individual members and the industry as a whole. This feature makes

INPO unique. The industry clearly established and accepted a form of self-regulation

through peer review by helping to develop INPO performance objectives and criteria (POCs)

and then by committing to meet these POCs. The industry’s recognition that all nuclear

utilities are affected by the action of any one utility motivated its support of INPO. Each

individual member is solely responsible for the safe operation of its nuclear plants. The U.S.

Nuclear Regulatory Commission (NRC) has statutory responsibility for overseeing the

licensees and for verifying that each licensee operates its facility in compliance with Federal

regulations to ensure public health and safety. INPO’s role — encouraging the pursuit of

excellence in the operation of commercial nuclear power plants — is complementary but

separate and distinct from the role of the NRC.

The nuclear industry’s commitment to go beyond regulatory compliance and continually

strive for excellence, with INPO’s support, has resulted in substantial performance

improvements over the past 35 years. For example, in the early 1980s the typical nuclear

plant had a capacity factor of 63 percent, had experienced six automatic scrams a year, had

high collective radiation dose, and had experienced numerous industrial safety accidents

among its staff. Today, the median industry capacity factor is above 92 percent, most plants

have no automatic scrams a year, and collective radiation dose and industrial accident rates

are both lower by a factor of 7 when compared to the rates of the 1980s.

The earthquake and tsunami in Japan on March 11, 2011, and subsequent nuclear accident

at Tokyo Electric Power Company’s Fukushima Dai-ichi nuclear power plant, have resulted

in worldwide attention toward improving nuclear safety. This report includes an overview of

the industry actions to address extreme external events and the Institute’s role in response

to the accident at Fukushima.

As discussed in Part 1 of this report, the United States ratified the Convention on Nuclear

Safety (CNS) in 1999 and has been actively participating in its peer review activities. The

conclusions from the review of the 2013 U.S. National Report at the Sixth CNS review

meeting in April 2014 were very positive. The United States was a member of Country

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Group 1. Country Group 1 identified the following challenges regarding the United States

nuclear industry strategy:

Continuous improvement in self-awareness. In 2014, INPO established a continuous

monitoring program with the purpose of maintaining an accurate picture of plant

performance between evaluations. This program helps INPO identify early signs of

performance decline so that actions can be taken to prevent further decline.

Additional information can be found in Section 7.d of this report.

Effective use of operating experience. INPO’s analysis and information exchange

programs help improve plant safety by identifying the causes of industry events that

may be precursors to more serious events. INPO requires that stations share operating

experiences and lessons learned with INPO. INPO staff then analyzes and

communicates this information to the industry through a variety of methods and

products. Additional information can be found in Section 7.c of this report.

Maintaining proficiency of the nuclear workforce. INPO interacts with all members in

preparing for, achieving, and maintaining accreditation of training programs for

personnel involved in the operation, maintenance, and technical support of nuclear

plants. Section 7.b of this report describes the training and accreditation programs of

the nuclear industry and INPO’s role in this area.

Sharing best practices of supplier and nonnuclear support. INPO maintains a

supplier participant program in which supplier participant members share best

practices and operating experience. In October 2014, INPO issued an industry

standard for nuclear suppliers, INPO 14-005, “Excellence in Nuclear Supplier

Performance.” This standard describes the essential principles and attributes that

support achieving excellence in the services and products provided by nuclear

suppliers. Supplier Participants completed their first self-assessment in August 2015

against INPO 14-005. Several work teams were created to provide recommendations

to the supplier community on how to close identified gaps.

Site resiliency against external events. INPO developed and communicated lessons

learned from the Fukushima Dai-ichi accident in the form of INPO Event Reports

(IERs). INPO conducted review visits at each domestic site to verify the

implementation of the recommendations from the various Fukushima related IERs.

INPO continues to evaluate site readiness against extreme external events during

plant evaluations and peer reviews. Additional information can be found in

Sections 7.a.iii and 9 of this report.

Quickly and sustainably recovering lower performing plant. INPO maintains a special

focus program for stations where behaviors and results are not representing high

levels of performance or stations experiencing a steep decline in performance that

increases the likelihood for a significant event. Section 7.e of this report describes

this program.

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2. Organization and Governance

In many ways, INPO’s organizational structure is similar to that of a typical U.S. corporation.

A board of directors, comprising senior executives from INPO’s member organizations,

provides overall direction for the Institute’s operations and activities. Currently, the board

comprises 13 chief executive officers (CEOs) from the member utilities. The Institute’s

bylaws specify that at least two directors must have recent experience in the direct

supervision of the operation of a facility that generates electricity or steam for commercial

purposes through the application of nuclear power. In addition, at least one director must

represent a public utility. The president and CEO of the Institute, normally a single

individual, is elected by, and reports to, the board of directors. INPO’s organization chart is

presented below:

Because the INPO board is made up of utility executives, the industry believes that having

support from an advisory council of distinguished individuals, mainly from outside the

nuclear generation industry, to provide diversity of experience and thought is also important.

This advisory council of 9 to 15 professionals selected from outside INPO’s membership

meets periodically to review the Institute’s activities and to provide advice on broad

objectives and methods to the board. Members include prominent educators, scientists,

engineers, business executives, and experts in organizational effectiveness, human

relations, and finance.

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The industry actively participates in the oversight of INPO’s programs. Representatives from

member utilities serve on the Executive Advisory Group, the Academy Council, and the

Industry Communications Council. The Executive Advisory Group, which comprises the

chief nuclear officers of all the member organizations, advises INPO management on the

programs and products in the nuclear technical areas. The Academy Council provides

advice in the areas of training, accreditation, and human performance. The Industry

Communications Council advises on effective communication of INPO programs and

activities. Frequently, INPO establishes ad hoc industry groups to provide input on specific

initiatives.

Six core characteristics enable INPO’s self-regulation model to be effective in fostering the

highest standards of safety and reliability at U.S. nuclear power plants:

CEO engagement: A fundamental element in founding INPO was the personal

involvement and support of member CEOs. Today, that same level of support and

involvement remains fundamental to INPO’s continued impact on the industry.

Nuclear safety: INPO’s mission of promoting the highest levels of safety and

reliability - to promote excellence - in the operation of commercial nuclear power

plants has not wavered. Nuclear safety is at the forefront of every INPO activity.

Additionally, the distinction between excellence and regulatory compliance is

foundational to continuous improvement in nuclear safety and reliability.

Broad industry support: The nuclear industry was involved in developing standards

of excellence and is committed to meeting those standards. The industry accepts

that as part of the self-regulation model, its nuclear stations are subject to onsite

evaluations that involve participation by industry peers. The evaluations are intrusive,

comprehensive, and performance-based. The industry also supports and participates

in self-regulation through involvement with advisory groups, industry task forces and

working groups, and by loaning employees to INPO. Through such involvement,

participants gain firsthand experience and knowledge on improvement opportunities

at their own sites and also increase their understanding of INPO’s role and the

importance of self-regulation.

Accountability: INPO’s formal process of evaluations and assessments provides a

basis for continuous industry improvement that includes peer pressure and the

identification and targeting of plants that require special assistance to help improve

performance in key areas. Furthermore, in rare instances utility insurance rates can

be impacted as a consequence of INPO evaluation results.

Independence: Although INPO is part of the nuclear power industry, it remains

independent. The Institute establishes high industry standards and distinguishes

clearly between its evaluative role and other collaborative interactions and activities

with its members.

Confidentiality: INPO and its member utilities recognize that for continued success, it

is essential that the nuclear industry maintain a healthy environment for peer review

and self-improvement. Candid interactions with utility staff, which are central to the

evaluation process, are predicated on the assurance the information will be used

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privately and constructively. Misuse of information contained in INPO reports by

individuals outside the utility would have a detrimental effect on INPO’s ability to

obtain information and to identify needed improvements.

The Institute is committed to a long-term strategic design that outlines the ways and means

by which it will fulfill its mission through 2023. The strategic design takes into account the

current state, the desired end state, and potential barriers in shaping desired outcomes in

three separate but interrelated areas: INPO’s corporate responsibilities, U.S. nuclear

industry performance, and international nuclear industry performance. Defined within its

strategic design are priorities and measurable outcomes that guide the application of INPO’s

limited resources.

INPO’s Corporate Strategy

INPO is guided in its corporate responsibilities by the strategic bases for shaping U.S. and

international industry performance, together with traditional corporate tasks of developing its

workforce:

INPO is committed to attracting top-performing employees whose talents match

Institute and industry needs.

Understanding that a strong culture has a powerful influence on behaviors and

performance, the Institute strives to instill a culture that emphasizes integrity,

accountability, and high performance. It also ensures employees are equipped with

the necessary sensitivities and flexibility to navigate cultural differences encountered

both domestically and internationally.

Clear, well-executed processes guide INPO’s application of resources. The Institute

ensures that processes support its mission and provide reliable and predictable

results.

INPO employs a matrixed organizational structure whereby its staff supports

cross-functional initiatives. This requires an internal work environment that is stable,

complete, unambiguous, and consistent across the organization, while maintaining

the flexibility and scalability to adapt to changing needs.

U.S. Industry Strategy

In pursuit of nuclear safety, reliability and operational excellence, INPO sets performance

standards for the industry. It then measures industry performance against those standards

and facilitates performance improvement through education and training, widespread

sharing of best practices, lessons learned, and assistance. Finally, when it must, INPO

exercises the self-regulatory authority granted by its member utilities.

INPO’s industry-facing strategy currently addresses six challenge areas:

Fundamental attributes of high-performing industries include self-awareness and the

capability to continuously improve. Industry management must be proactive,

intrusive, and knowledgeable to reduce recurring or long-duration shutdowns, as well

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as recognize the presence of key risk factors that can lead to significant events. It is

vital that a high level of awareness is maintained regarding worker proficiency and

that training be applied to mitigate proficiency shortfalls and to minimize human error.

The more that leaders are educated, trained, developed and committed to knowing

their plants and adapting to inevitable variances in performance, the less susceptible

the nuclear industry will be to unanticipated, negative outcomes.

An operating experience culture is paramount to ensuring that the nuclear industry

remains alert to adverse safety and reliability trends. In embracing lessons learned,

operating experience must become pervasive and central to management and

worker decisionmaking. Achieving long-term performance goals requires that

management recognizes the merits of operating experience and transfers its lessons

down to the worker level.

Considering the vital importance of a knowledgeable workforce to nuclear safety,

training must be of the highest quality to ensure industry needs are met. This

requires an integrated approach to sourcing, educating, training and qualifying

workers. A broad array of management, leadership, and training approaches is

necessary to help sustain worker proficiency and minimize human error. Leaders

must prepare the workforce to adapt to changing conditions, including changes in

site performance, to ensure the right management and leadership mix, along with the

right qualifications, are in the right place at the right time.

Suppliers and nonnuclear support organizations provide vital functions for the

nuclear industry and can directly impact overall safety and reliability. Therefore, it is

vital that INPO encourages the management of such groups to improve these areas

— to achieve uniformity and quality for the nuclear industry.

Lessons learned from the Fukushima Dai-ichi accident establish that nuclear sites

need to be resilient against extreme external events. By applying concepts of

defense-in-depth, sound response strategies, planned outside assistance, and

having committed leadership, the nuclear industry will better withstand such events.

Corporate leadership and site leadership are pivotal in plant recovery, workforce

alignment, and sustainability. They must have an unwavering focus on finding and

fixing problems by being intrusive, engaged and adapted to a site’s culture while

managing challenges and distractions. Management teams will be better equipped to

lead recoveries by developing the applicable leadership skills in advance of such

circumstances and by preidentifying the means to augment leadership capability or

capacity shortfalls.

International Industry Strategy

Internationally, INPO leverages the World Association of Nuclear Operators (WANO) for its

widespread global reach, facilitates like-minded international regulatory and self-regulatory

organizations that promote safe nuclear operations, and focuses on international

partnerships for which the benefits to industry safety are most impactful.

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Leveraging WANO’s global reach, INPO liberally shares its informational products

throughout the international industry. As a WANO member, INPO participates in peer

reviews, technical assist visits, and other WANO activities.

INPO associates with and facilitates improvement of like-minded organizations, such

as other national-level self-regulators, the International Atomic Energy Agency

(IAEA) and the Nuclear Energy Agency (NEA), so that synergies in operational

safety approaches may be realized.

To the maximum extent, INPO will apply its limited resources directly to international

utilities deemed to pose the highest safety risk, as well as learn from the most

proficient ones.

Financial and Human Resources

The 2015 operating budget for INPO of $116 million is primarily funded through member

dues. Dues are approved annually by the board of directors and are assessed based on the

number of each member’s nuclear plant sites and units.

INPO’s permanent staff of about 350 is augmented extensively by industry professionals

who serve as loaned employees or international liaison engineers on assignments of 18 to

24 months. Loaned and liaison employees comprise about one-third of the total technical

staff. They gain extensive experience and training while providing current industry expertise

and diversity of thought and practices. A small number of permanent INPO employees serve

in loaned assignments to member organizations primarily for professional development. The

total number of both permanent and loaned employees is approximately 400 people.

INPO resources and capabilities are further enhanced by the extensive use of U.S. and

international utility peers and executive industry advisers. These peers participate in a wide

range of short-term activities, especially on evaluation and accreditation teams that visit

nuclear plants. Peers enhance the effectiveness of the INPO teams by offering varied

perspectives and by providing additional current experience. The peers benefit from learning

other ways to conduct business that can be shared with their stations. In 2015, the industry

provided INPO with more than 970 peers for short-term assignments.

INPO’s Role within the Federal Regulatory Framework

The Federal Government regulates the nuclear utility industry in the United States, as it

does other industries that could affect the health and safety of the general public. This

regulatory function is based principally on the Atomic Energy Act of 1954, as amended, and

is carried out by the NRC. In 1979, after the accident at Three Mile Island, the President of

the United States appointed a commission to investigate the accident. The commission,

which came to be known as the Kemeny Commission, helped influence the industry’s

decision to create INPO as a method of self-regulation.

The industry created INPO to provide the means whereby the industry itself could, acting

collectively, improve the safety and reliability of nuclear operations. Industry leaders

envisioned that peer reviews and POCs based on excellence would effectively bring

improvements. In the broad sense, the ultimate goals of the NRC and INPO are the same in

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that both organizations strive to protect the public; therefore, both review similar areas of

nuclear power plant operations. In granting INPO its not-for-profit status, the U.S.

Government acknowledged that INPO’s role reduces the burden on the Government

through the conduct of its activities. However, the industry does not expect INPO to supplant

the regulatory role of the NRC. INPO recognized that it would have to work closely with the

NRC while not becoming or appearing to become an extension of, or an adviser to, the NRC

or an advocacy agent for the utilities. As recognition of their different roles but common

goals, the NRC and INPO have entered into a memorandum of agreement that includes

coordination plans covering specific areas of mutual interest.

The conduct of plant and corporate evaluations is one of INPO’s most important functions. It

is also the function that is closest to the role of a regulator. Although the two roles

— evaluation and regulation — may appear similar, they differ in some ways. The industry

and INPO jointly develop numerous POCs. INPO then conducts regular, extensive, and

intrusive evaluations to determine how well they are being met. These POCs are broad

statements of conditions reflecting a higher level of overall plant performance —striving for

excellence and often exceeding regulatory requirements. These POCs, by their very nature,

are difficult to achieve consistently.

Because of the differences in the roles of INPO and the NRC, the industry maintains a clear

separation between INPO evaluations and NRC inspections. The industry expects INPO to

keep the NRC apprised of its generic activities. Although INPO interactions with an

individual member remain private between that member and INPO, stations are encouraged

to make their INPO plant evaluation and accreditation results available to the NRC for

review at each utility or site.

The industry recognizes the need for the NRC to assess the overall quality of INPO’s

products and the success of its programs. Therefore, the industry expects INPO to provide

the NRC with the following information on programs and activities at the Institute:

copies of selected generic documents

access to other pertinent information, such as the INPO Consolidated Event System

(ICES) as described in specific agreements

observation of certain INPO field activities by NRC employees, with agreement from

members

observation of National Nuclear Accrediting Board sessions

INPO regularly participates in industry-led working groups and task forces that interface with

the NRC on specific regulatory issues and initiatives relative to the Institute’s mission and

strategic objectives. These cooperative interactions have led to the elimination of some

redundant activities, thus benefiting INPO members while enabling both the NRC and INPO

to maintain or strengthen the focus on their respective missions. For example, the

Consolidated Data Entry system, operated by INPO, collects operating data that the NRC

uses in its industry oversight process.

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INPO has implemented a policy and appropriate procedures on the handling of items that

are potentially reportable to the NRC. The Institute’s policy is to inform utility management of

such items during the normal course of business so that the utility can evaluate and report

the items as appropriate. If INPO becomes aware of a defect or failure to comply that

requires a report under Federal regulation, the Institute has an obligation to ensure that the

item is reported, if the utility has not already done so.

Responsibilities of INPO and its Members

INPO members are expected to strive for excellence in the operation of their nuclear plants

to meet INPO POCs and other industry standards of excellence. This effort also includes

the achievement and maintenance of accredited training programs for personnel who

operate, maintain and support their nuclear plants. Members are expected to be responsive

to all areas for improvement identified through INPO evaluation, accreditation, and events

analysis programs.

Nuclear operators are explicitly responsible for complying with the terms and conditions of

the operating license and the applicable rules and regulations. The licensee is ultimately

responsible for the safety of its activities and the safeguarding of nuclear facilities and

materials used in operation. This concept is a key principle concerning INPO’s relationship

with its members.

The INPO Board of Directors approved a special procedure that provides guidance if a

member does not respond to INPO programs, if it is unwilling or unable to take action to

resolve a significant safety issue, has persistent shortfalls in performance, or if the

accreditation for its training programs has been put on probation or withdrawn by the

National Nuclear Accrediting Board. The procedure specifies that INPO and the member

utility’s management work to resolve any issues in contention, using a graduated approach

of increasing accountability. Specific options for accountability include interactions between

INPO’s CEO and the member’s CEO and, if necessary, the board of directors. One option

also includes suspending INPO membership if the member continues to be unresponsive.

Suspension of membership has never been necessary; however, such action would

significantly affect the utility’s continued operation, including limiting its ability to obtain

insurance.

Furthermore, members are expected to participate fully in other generic INPO programs

designed to enhance nuclear plant safety and reliability industrywide. Examples include

providing INPO with detailed and timely operating experience information and participating

fully in the loaned employee, peer evaluator, and WANO performance indicator programs.

Members share information, practices and experiences to assist each other in maintaining

high levels of operational safety and reliability.

In return, the industry expects INPO to provide members with results from evaluation,

accreditation and review visits, including written reports and an overall numerical

assessment that characterizes performance relative to standards of excellence. The industry

expects INPO to follow up on effective corrective actions by a member and to verify that the

member has implemented these actions.

INPO and its members clearly understand that all parties must maintain the confidentiality of

the Institute’s evaluation reports and related information, and that members must not

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distribute this information externally to their utility organizations. INPO also expects

members and participants to use information provided by the Institute to improve nuclear

operations, not for other purposes (to gain commercial advantage, for example). Members

are to avoid involving INPO or INPO documents in litigation.

INPO members that are also members of the collective insurance organization Nuclear

Electric Insurance Limited (NEIL) have authorized and instructed the Institute to make

available to NEIL copies of its evaluation reports and other data at its office. NEIL reviews

these reports and data for items that could affect the insurability of its members.

INPO POCs are written with input from, and with the support of, the industry. However,

these POCs are written without regard to constraints or agreements, such as labor

agreements, of any individual member. INPO expects each member to resolve any

impediments to the implementation of the POCs that may be imposed by outside

organizations.

INPO does not engage in public, media, or legislative activities to promote nuclear power.

Such activities would undermine INPO’s objectivity and credibility and may jeopardize the

Institute’s not-for-profit status.

Principles of Sharing (Openness and Transparency)

Throughout the changes that have occurred in the U.S. electric industry, including electric

deregulation, the industry has reaffirmed INPO’s mission to promote the highest levels of

safety and reliability in the operation of nuclear power plants. Even with U.S. utilities now in

competition in certain areas, these plant operators clearly understand the need to continue

sharing pertinent operational information to continuously strengthen safety and reliability.

Nuclear utility owners believe that this cooperation is fundamental to the industry’s

continued success.

Through INPO, nuclear utilities quickly share information important to safety and reliability,

including operating experience, operational performance data, and information related to the

failure of equipment that affects safety and reliability. The industry also actively encourages

benchmarking visits to support the sharing of best practices and the concepts of emulation

and continuous improvement.

INPO facilitates the sharing of industry information by including participation of industry

peers in several of the Institute’s programs — plant evaluations, training and accreditation,

analysis and information exchange, and plant recovery. INPO communicates and shares

information through a variety of methods, including the secure Nuclear Network^®member

Web site, written guidelines, and other publications.

Although the industry and INPO recognize that the rapid and complete sharing of

information important to nuclear safety is essential, both entities clearly understand that

certain information is private in nature and is not appropriate to share. Examples are INPO

plant-specific details of evaluation and accreditation results, personal employee and

individual performance information, and appropriate cost and power marketing data.

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6. Priority to Safety (Safety Culture)

The U.S. nuclear industry believes that a strong safety culture is central to excellence in

nuclear plant operations, partly because of the special and unique nature of nuclear

technology and the associated hazards—radioactive byproducts, concentration of energy in

the reactor core, and decay heat. Within the INPO members’ power plants and within INPO

itself, the elements, activities and behaviors that are part of a strong safety culture are

embedded in everything that the Institute does day to day and has been doing since its

establishment in 1979.

The U.S. nuclear industry has defined safety culture as follows: An organization’s

values and behaviors — modeled by its leaders and internalized by its members —

that serve to make nuclear safety the overriding priority.

In 2012, INPO distributed a report titled “Traits of a Healthy Nuclear Safety Culture.” This

document was developed through a collaborative effort of the U. S. and international nuclear

operating communities, and representatives from NRC, the public, and INPO staff. The

report replaced the INPO report “Principles for a Strong Nuclear Safety Culture,” issued in

November 2004.

In April 2013, two addenda were developed and distributed in support of the Nuclear Safety

Culture Traits. Addendum I is titled “Behaviors and Actions that Support a Healthy Nuclear

Safety Culture.” It includes the behaviors and examples found in the “Traits of a Healthy

Nuclear Safety Culture,” but sorted by organizational level and attribute. Addendum II is

titled “Cross-References for Traits of a Healthy Nuclear Safety Culture.” It cross-references

the Traits to the INPO principles document, NRC safety culture components, and IAEA

safety culture characteristics.

INPO activities reinforce the primary obligation of the operating organization’s leadership to

establish and foster a healthy safety culture, to periodically assess safety culture, to address

shortfalls in an open and candid fashion, and to ensure that everyone from the boardroom to

the shop floor understands his or her role in safety culture.

As part of its focus on safety, the industry uses INPO, through evaluations and other

activities, to identify and help correct early signs of decline in the safety culture at any plant

or utility. Furthermore, the industry has defined INPO’s role doing the following:

Define and publish standards relative to safety culture

Evaluate safety culture at each plant

Develop tools to promote and evaluate safety culture

Assist the industry in providing safety culture training

Develop and issue safety culture lessons learned and operating experience

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Make safety culture visible in various forums such as professional development

seminars, assistance visits, working meetings, and conferences, including the CEO

conference

In 2002, INPO published Significant Operating Experience Report (SOER) 02-4, “Reactor

Pressure Vessel Head Degradation at Davis-Besse Nuclear Power Station.” SOER 02-4

describes the event and the shortfalls in safety culture that contributed to it and

recommends actions to prevent similar problems at other plants. The nuclear power industry

considers this event a defining moment because it highlights problems that can develop

when the safety culture at a plant receives insufficient attention. Every U.S. nuclear power

station has implemented the recommendations in SOER 02-4, and INPO evaluation teams

have reviewed each station’s actions. Briefly, the recommendations encompass:

discussing a case study on the event with all managers and supervisors in the

nuclear organization

periodically conducting a self-assessment to determine the organizational respect for

nuclear safety

identifying and resolving abnormal plant conditions or indications that cannot be

readily explained

Safety culture is thoroughly examined during each plant evaluation. INPO expects each

evaluation team to review the safety culture throughout the process, including during the

preevaluation analysis of plant data and observations made at the plant. The results of this

review are included in the summary on organizational effectiveness and may be

documented as an area for improvement as appropriate. The INPO evaluation team

discusses aspects of a plant’s safety culture with the CEO of the utility at each evaluation

exit briefing.

Operations, Activities and Actions

In the execution of its strategic design, INPO conducts a broad spectrum of large-scale

operations, such as plant evaluations and training accreditation visits, recurring activities (for

example, processes), and one-time actions. Several of these are long-standing, cornerstone

INPO efforts, including those described below.

a. Evaluation Programs

Members host regular INPO evaluations of their nuclear plants approximately every

2 years. The INPO evaluation teams periodically conduct additional review visits on

corporate support and on other more specific areas of plant operation. During these

evaluations and reviews, the INPO teams use standards of excellence based on the

POCs, their own experience, and their broad knowledge of industry best practices. This

approach shares beneficial industry experience while promoting excellence in the

operation, maintenance, and support of operating nuclear plants. Written POCs,

developed by INPO with industry input and review, guide the evaluation process and are

the basis for identified areas for improvement. The evaluations are performance oriented

and emphasize the results achieved and the behaviors and organizational factors

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important to future performance. The evaluations focus on those issues that affect

nuclear safety and plant reliability.

Plant Evaluations

Teams of approximately 18 to 25 qualified and experienced individuals conduct

evaluations of operating nuclear plants that focus on plant safety and reliability. In

2015, U.S. utilities were visited for 31 plant evaluations or WANO peer reviews. The

evaluation teams include senior reactor operators, other peer evaluators from

different utilities, host utility peer evaluators, and an executive industry advisor. The

scope of the evaluation includes the following functional areas:

operations

maintenance

engineering

radiological protection

chemistry

training

emergency preparedness

fire protection

industrial safety

The teams also evaluate cross-functional performance areas (processes and

behaviors that cross organizational boundaries) and address process integration and

interfaces. The teams evaluate the following cross-functional areas:

safety culture

operational focus

configuration management

equipment reliability

work management

performance improvement (learning organization)

organizational effectiveness

Teams also evaluate the following foundational areas:

leadership

nuclear professionalism

As part of the process, an evaluation team looks at important aspects of a site’s

quality assurance and oversight programs to ensure that these programs provide

confidence that the plant is satisfying the requirements for activities important to

nuclear safety.

Team leaders provide a focal point for the evaluation of station management and

leadership by concentrating on evaluating leadership, teamwork, organizational

effectiveness, safety culture, technical conscience, and nuclear oversight topics.

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A key part of each evaluation includes the performance of operations and training

personnel during simulator exercises. In addition, the evaluation includes, where

practicable, observations of refueling outages, plant startups, shutdowns, major

planned evolutions and planned fire and emergency preparedness drills.

The evaluation team provides the utility with formal reports of strengths and areas for

improvement and a numerical rating of overall plant performance. As part of the 1983

CEO workshop, INPO prepared a set of indicators for each nuclear station that

reflected station participation in and commitment to INPO programs. INPO provided

this information to each CEO. One of these indicators was an assessment of each

station’s overall performance based on INPO evaluations and on the judgment of

INPO team managers and senior management.

With the approval of the board of directors, INPO decided that it would assess the

overall station performance in the context described above after each evaluation and

that it would share this assessment privately with the CEO at the exit meeting.

Eventually, the Institute developed a numerical assessment and now provides each

station an assessment from Category 1 (excellent) to Category 5, which is defined as

the level of performance at which the margin to nuclear safety is substantially

reduced. Such a process reflects the desire of utility managers to know more

precisely how their station’s performance compares to the standards of excellence.

In addition, this process is in accordance with INPO’s responsibility to the individual

CEO and to its members for identifying low-performing nuclear plants and for

stimulating improvement in performance.

Even though standards for performance have risen substantially over the years, the

number of plants in categories 1 and 2 has remained relatively constant, even as

standards of excellence have improved. Several conclusions can also be drawn from

evaluations over the years. Good performing plants (Category 1 and 2) show strong

leadership, are self-critical, do not tolerate complacency, are operationally focused,

have exceptional equipment performance, and effectively use training to improve

performance. Category 3 and Category 4 stations may include leaders who do not

set high standards, possess a weak self-critical attitude, weak day-to-day operations,

broad equipment problems, and deficient fundamental knowledge and skills in

several areas. INPO has not assessed a station as Category 5 in over a decade.

The final report includes utility responses to the identified areas for improvement and

their commitments to specific corrective action. In subsequent evaluations and other

interactions, INPO specifically reviews the effectiveness of actions taken to

implement these improvements.

INPO technical department managers also provide an area performance summary in

which they provide perspective on current performance in their area as compared

with the industry. Each summary includes an articulation of the trend and the

trajectory of performance.

Subjective team comments are often communicated to the member CEO during the

evaluation exit meeting. The intent of these comments, which are often more

intuitive, is to help the utility recognize and address potential issues before they

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adversely affect actual performance. Copies of the plant’s evaluation report are

distributed according to a policy approved by the Institute’s board of directors.

The industry also hosts WANO peer reviews conducted by the WANO-Atlanta

Centre. These peer reviews are conducted at each U.S. station approximately every

6 years in place of an INPO plant evaluation. They use a methodology and

performance objectives similar to that of plant evaluations, but with teams that

include international peers.

Numerous improvements have been made in plant safety and reliability as a result of

addressing issues identified during evaluations, peer reviews, plant self-assessments

and comparison and emulation among plants. The time that plants operate versus

the amount of time that they are shut down has improved significantly, the frequency

of unplanned shutdowns has decreased markedly, and the reliability and availability

of safety systems has improved measurably.

ii.

Corporate Evaluations

Member utilities that operate nuclear stations request that INPO conduct corporate

evaluations at 5 to 6-year intervals. The evaluations reflect the important role of the

corporate office, as well as corporate nuclear and nonnuclear leaders, in supporting

safe and reliable nuclear operation. INPO conducted six corporate evaluations in

2015.

A tailored set of POCs defines the scope of activities and the standards for corporate

evaluations. The corporate evaluation focuses on the impact that the corporation has

on the safe operation of its nuclear plants. Areas typically evaluated include the

following:

organizational effectiveness, including leader and team behaviors, as well as

the effectiveness of programs, processes and the implementation of the

management model

direction and standards for station operation, including the organizational

alignment, communications, and accountability for strategic direction,

business and operational plans, and performance standards

governance, monitoring, and independent oversight of the nuclear enterprise

support for emergent station issues and specialty areas such as major plant

modifications, including replacement of steam generator and reactor vessel

heads and station upgrades to extract more power and efficiency

performance of corporate functions, such as human resources, industrial

relations, fuel management, supply chain management, and other areas

applicable to the nuclear organization

INPO members use corporate evaluation results to help ensure that essential

corporate functions are providing the leadership and support necessary to achieve

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and sustain excellent nuclear station performance. As a consequence of responding

to issues identified during corporate evaluations, stations often have refocused

appropriate resources and leadership attention on improving station safety and

reliability.

At the request of its members, INPO meets with utility boards of directors to provide

an overview of plant and fleet performance when applicable. The boards use these

briefings as an input to their assessment of operational, project and enterprise risk.

iii.

Other Review Visits

The industry also uses INPO to conduct review visits in selected industrywide

problem areas to supplement the evaluation process. These visits are typically

initiated by INPO and are evaluative in nature. The results of review visits may be

used as an input to the evaluation process. The visits are designed as indepth

reviews of technical areas that could have a significant impact on nuclear safety and

reliability. Such areas include critical materials issues that affect the structural

integrity of the reactor coolant system and reactor vessel internals of both

boiling-water reactors (BWRs) and pressurized-water reactors (PWRs). Other areas

include components or systems that are significant contributors to unplanned plant

transients and forced loss rate, including main generator and transformer,

switchyard, and electrical grid components. INPO conducted 94 review visits in 2015.

Similar to plant evaluations and peer reviews, review visits evaluate station

performance against the INPO POCs to a standard of excellence. In some areas,

such as materials, industry groups have developed detailed technical guidance that

each utility has committed to implement. The materials review visit teams also use

this guidance to ensure that program implementation is consistent and complete and

meets the industry-developed standards.

Review visit teams are led by an INPO employee and include industry personnel who

have unique expertise in the area of the review that is not typically within the skill set

of INPO members of plant evaluation or peer review teams. Review visits typically

include a week of preparation followed by a week on site.

Review visit reports contain beneficial practices and recommendations for

improvement. These reports are sent to the station site vice president. For potential

safety-significant recommendations, INPO may request a response. The subsequent

plant evaluation or WANO peer review team follows up on each of the

recommendations requiring a response to ensure that identified issues are

addressed. Periodically, INPO compiles the beneficial practices and

recommendations and posts the information on the secure member Web site to allow

all utilities to benchmark their programs.

The following sections discuss the details of selected review visit programs.

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PWR Materials Review Visits

INPO initiated review visits targeting the steam generator in 1996. In the early 1980s,

steam generator tube leaks and ruptures contributed to lost power generation and

were the cause of several events deemed significant by INPO. The industry as a

whole became more sensitive to the importance of steam generator integrity as a

contributor to core damage frequency. The industry, through the Electric Power

Research Institute (EPRI) Steam Generator Management Program (SGMP), issued

detailed guidance on qualification and implementation of nondestructive testing

techniques, engineering assessments of steam generator integrity, and detection

and response to tube leakage and ruptures. In mid-1995, the industry requested that

INPO help improve the prevention and detection of steam generator degradation by

verifying correct and consistent implementation of industry guidance at individual

stations and by evaluating steam generator management programs against

standards of excellence. As a result, INPO established the Steam Generator Review

Visit Program.

Subsequently, in 2003, a primary systems integrity review visit was launched in

response to a number of notable events associated with leakage from PWR borated

systems resulting in additional oversight by the NRC and INPO. In some cases,

these leakage events resulted in corrosion and wastage of pressure-retaining

components in the reactor coolant system. The EPRI PWR Materials Reliability

Program was formed as an industry initiative in 1998 to develop guidance to address

materials degradation issues. Because of the importance of primary systems

integrity, INPO began performing indepth review visits focused on boric acid

corrosion control and Alloy 600 degradation management, including dissimilar metal

butt welds.

Industry performance has steadily improved in both steam generators and primary

system integrity as evidenced by the lack of safety-significant events and events that

contribute to lost generation. Utility programs addressing these areas are mature.

In 2012, the two programs were combined to form the PWR materials review visit to

capture all aspects of the industry initiative codified in NEI 03-08, “Guideline for the

Management of Materials Issues.” This initiative encompasses the Steam Generator

Review Visit Program, the Materials Reliability Program, and other programs directly

dealing with primary system materials. While the review visit scope and team size is

larger, the objective remains the same: ensure nuclear safety and plant reliability are

not compromised because of weakness associated with the primary pressure

boundary, including the steam generators. However, the focus on establishing

effective station programs and capturing newly implemented industry guidance has

been replaced with an emphasis on program implementation, capturing ongoing

industry operating experience, and performing forward-looking trending to ensure

material degradation is proactively managed.

In 2016, the scope of the PWR materials review visit is being expanded to take an

even broader look at materials degradation and will include flow accelerated

corrosion programs and buried pipe and tank integrity.

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BWR Materials Review Visits

In 2001, INPO initiated BWR vessel and internals review visits at the request of the

industry. In the early 1990s, vessel and internal issues caused by intergranular

stress-corrosion cracking became significant contributors to lost power generation.

Safety concerns associated with this degradation prompted the industry to form the

EPRI BWR Vessel and Internals Project. This group developed detailed guidance to

address inspection, mitigation, repair, and evaluation of degradation for components

important to safety and reliability.

BWR vessel and internals review visits focus on nondestructive examinations;

inspection scope and coverage; evaluation of crack growth and critical flaw size;

effectiveness of strategies to mitigate intergranular stress-corrosion cracking,

including hydrogen addition and application of noble metals; and chemistry

conditions that affect long-term health, including potential effects on fuel.

Overall industry performance improved as evidenced by the lack of safety-significant

events and events that contribute to lost generation.

In 2016, the scope of the BWR vessel and internals review visit is being expanded to

take an even broader look at materials degradation and will include flow accelerated

corrosion programs and buried pipe and tank integrity. In conjunction with this scope

change, the name of the review visit is being changed to reflect the broader scope to

BWR materials review visit.

AC Power Source Reliability Review Visits

In 2014, INPO combined the transformer, switchyard and grid review visit program

with the emergency diesel generator review visit program to support the industry

focus area of AC power reliability. There are four to six loss of offsite power (LOOP)

matrix reviews targeted per year prioritized on a performance basis. These reviews,

termed AC power reliability review visits, integrate the scope of the transformer,

switchyard and grid review visit program and the emergency diesel generator visit

programs with additional focus on program and procedures relied on to prevent,

detect, and mitigate LOOP and station blackout events. Team peer selection will

include individuals with transmission system and emergency diesel expertise.

To ensure consistent monitoring of performance, AC power reliability will remain an

industry focus area on evaluation teams through review of plant events. In addition, a

new indicator was developed to reflect AC power reliability for the industry and

individual sites. The metric combines LOOP events and emergency diesel generator

performance and availability on a 2-year rolling average.

INPO is also actively partnered with the North American Transmission Forum (NATF)

to develop common expectations and risk assessment tools for the switchyard and

grid system interface. In 2014, INPO, NATF and EPRI began joint efforts focused on

AC power reliability. A May 2015 industry summit meeting highlighted actions each

work group is taking to mitigate challenges to AC power reliability. As a part of the

AC power source reliability strategy, INPO is also engaged with EPRI in the industry

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Flexible Power Operations initiative for plants requested to accommodate renewable

resource power contribution to grid load demand.

Main Generator Review Visits

The industry initiated main generator review visits in 2004 after the identification of

an adverse trend involving failures of main generators and related support systems.

The number of main generator failures that hindered power production, extended an

outage, or both, had doubled from 1999 to 2003. During this time, unplanned scrams

caused by generator problems increased to around five a year from the previous

average of two a year. These review visits were suspended once industry

performance improved and resources were shifted to emergent industry issues.

In 2016, INPO will resume monitoring main generator performance based on an

increase in challenges to reliability of generator excitation and stator water cooling

systems. Initially, main generator health will be reviewed on plant evaluations.

Teams will focus on performance and condition monitoring to ensure that the

generator is operating within design parameters and that monitoring is in place to

detect early signs of equipment degradation.

Emergency Preparedness

Between 2007 and 2015, INPO conducted emergency preparedness review visits at

U.S. nuclear stations and provided recommendations for improving readiness to

respond to radiological and other site emergencies. Actions were also taken to

improve timeliness and accuracy of event classifications, notifications, and protective

action recommendations; strengthen drill programs; and increases in emergency

response organization staff training.

In 2012, INPO established a new division focusing on emergency response. The

division is responsible for continuing improvements in emergency preparedness, as

well as working in concert with the U.S. industry during implementation of

post-Fukushima changes to increase resilience for beyond-design-basis external

event threats. Since 2013, INPO conducts review visits at each domestic site

verifying implementation of recommendations from the various IER related to the

Fukushima accident.

In 2015, fire protection was added to the division’s scope, and emergency response

evaluators began examining emergency preparedness and fire protection during

WANO peer reviews. Starting in 2016, emergency management and fire protection

will form a single department under the plant operations division. Emergency

management and fire protection evaluators will review these areas as part of

evaluation teams.

Training and Accreditation Programs

The U.S. commercial nuclear power industry strongly believes that proper training of

plant operators, maintenance workers, and other support group workers is of paramount

importance to the safe operation of nuclear plants. As a result, the industry established

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the National Academy for Nuclear Training (NANT or “the Academy”) in 1985 to operate

under the responsibility of INPO. The industry formed the Academy to focus and unify

high standards in training and qualification and to promote professionalism of nuclear

plant personnel. The Academy integrates the training-related activities of all members,

the independent National Nuclear Accrediting Board, and the Institute. Through INPO,

the Academy conducts seminars and courses and provides other training and training

materials for utility personnel.

All U.S. nuclear plants have accredited training programs and are branches of the

Academy. A utility becomes a member of the Academy when all of its operating plants

achieve accreditation for all applicable training programs.

INPO interacts with all members in preparing for, achieving, and maintaining

accreditation of training programs for personnel involved in the operation, maintenance,

and technical support of nuclear plants. These interactions are similar in content to the

accreditation efforts of schools and universities and include evaluations of accredited

training programs, activities to verify that the standards for accreditation are maintained,

and assistance at the request of member utilities. Written objectives and criteria are

jointly developed with the industry and guide the accreditation process.

Unlike its role in the plant evaluation and assessment process described above, INPO is

not the accrediting agency. The independent National Nuclear Accrediting Board

examines the quality of utility training programs and makes all decisions on

accreditation. If training programs meet accreditation standards, the National Nuclear

Accrediting Board awards or renews accreditation. If significant problems are identified,

it may defer initial accreditation, place accredited programs on probation, or withdraw

accreditation. Accreditation is maintained on an ongoing basis and is formally renewed

for each of the training programs every 6 years. The National Nuclear Accrediting Board

comprises training, education, and industry experts. It is convened and supported by

INPO; however, it is independent in its decisionmaking authority. National Nuclear

Accrediting Board members are selected from a pool of individuals from utilities,

postsecondary education, nonnuclear industrial training, and NRC nominations. Each

National Nuclear Accrediting Board consists of five sitting members, with a maximum of

two utility representatives to ensure its independence from the nuclear industry.

The accreditation process is designed to identify strengths and weaknesses in training

programs and to assist in making needed improvements. The process includes

self-evaluations by members with assistance from INPO staff, onsite evaluations by

teams of INPO and industry personnel, and decisions by the independent National

Nuclear Accrediting Board. Members seek and maintain accreditation of training

programs for the following positions or skill areas:

shift managers

senior reactor operators

reactor operators

nonlicensed operators

continuing training for licensed personnel

shift technical advisors

instrument and control technicians and supervisors

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electrical maintenance personnel and supervisors

mechanical maintenance personnel and supervisors

chemistry technicians

radiological protection technicians

engineering support personnel

In 2015, the industry updated the accreditation objectives to better focus on the

fundamental aspects of accredited training programs. Also, a training evaluator was

added to the plant evaluation process to provide a more distinct look at the linkage

between knowledge, skill, and performance. Together, these changes are designed to

provide a clearer picture of the health of station training programs and the impact on

worker proficiency.

The systematic approach to training remains the essential tool for providing training that

is results oriented. Both line and training organizations are expected to work together to

analyze performance gaps and to design, develop, and deliver training that enhances

knowledge and skills to measurably improve plant performance. Such an approach to

improving worker knowledge and skills contributes to high levels of safety and reliability

in the nuclear industry. The role of training will continue to be vital in the coming years

as many experienced workers retire and as new workers enter the workforce.

Although the accreditation process is independent of the NRC, the agency recognizes

and endorses the process as a means for satisfying regulatory training requirements. In

a report titled “Annual Report on the Effectiveness of Training in the Nuclear Industry,”

the NRC noted that “monitoring the INPO-managed accreditation process continued to

provide confidence that accreditation is an acceptable means of ensuring the training

requirements contained in 10 CFR [Part] 50 and 10 CFR [Part] 55 are being met.” In

addition, the NRC assessment of the accreditation process indicates that continued

accreditation remains a reliable indicator of a successful systematic approach to training

implementation and contributes to the assurance of public health and safety by ensuring

that nuclear power plant workers are being trained appropriately.

i. Training and Qualification Guidelines

The Academy develops and distributes training and qualification guidelines for

operations, maintenance, and technical personnel. These guidelines are designed to

assist the utility in developing quality training programs and in selecting key

personnel.

The guidelines are revised and updated periodically to incorporate changes to

address industry needs and to take into account lessons learned from other INPO

programs such as evaluations, events analyses, working meetings, and workshops.

These training and qualification guidelines provide a sound basis for utility training

programs.

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ii.

Courses and Seminars

The industry benefits extensively from courses and seminars that the Academy

conducts to help personnel better manage nuclear technology, more effectively

address leadership challenges, and improve their personal performance.

In February 2006, INPO launched the National Academy for Nuclear Training

e-Learning (NANTeL) system. Using Web-based technologies that allow distance

learning, NANTeL system training includes a variety of courses and proctored

examinations. These include courses for plant access, radiation work, and industrial

safety, maintenance, and engineering qualifications. Over 8 million courses have

been completed in NANTeL since its inception.

In 2015, the Leadership and Team Effectiveness attributes, INPO 15-005, were

integrated into these courses and seminars. Examples of courses and seminars

conducted are as follows:

a nuclear education course designed for directors in the nuclear industry

reactor technology course for utility executives

senior nuclear executive seminar

senior nuclear plant management course

nuclear operational risk course for managers

operations supervisor professional development seminar

first-line leadership seminar

next-level leadership seminar

seminars for new managers

INPO continues to work with the industry to develop and deliver training to address

industry needs. For example, INPO recently developed an instructor training and

certification program and a regulatory exam authors course for the industry. In 2016,

an industrywide simulator instructor certification program will also be available.

Analysis and Information Exchange Programs

The analysis and information exchange programs help improve plant safety by

identifying the causes of industry events that may be precursors to more serious events.

Stations are required to share operating experiences and lessons learned with INPO.

INPO then analyzes and communicates the information to the industry through a variety

of methods and products. In addition, INPO analyzes a variety of operational data to

detect trends in industry performance and communicates the results to the industry.

INPO operates and maintains extensive computer databases to provide members and

participants ready access to information on plant and equipment performance and

operating experience. These databases are accessible from INPO’s secure member

Web site. For example, the industry uses Nuclear Network^®, a worldwide Internet-based

communication system, to exchange information on the safe operation of nuclear plants.

WANO also uses Nuclear Network as a primary means for communicating and

exchanging operating experience among its members and regional centers.

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Events Analysis Program

INPO reviews and analyzes operating events from both domestic and international

nuclear plants through Operating Experience Program. The program is designed to

provide indepth analysis of nuclear operating experience and to apply the lessons

learned across the industry. Events are screened, tagged, and analyzed for

significance; those with generic applicability are disseminated to the industry in one

or more of the following forms:

Level 1 IER

Level 2 IER

Level 3 IER

Level 4 IER

Members support the events analysis program by providing INPO with detailed and

timely operating experience information. Operating experience information is freely

shared among INPO members via the ICES. These entries enable a single station to

multiply its experience base for identifying problems. This experience base includes

safety systems, which have similar components across many stations. A key to this

success is the timeliness of reporting. Stations typically report events in less than 50

days after occurrence.

Members are required to evaluate and take appropriate action on recommendations

provided in Level 1 and Level 2 IERs. During onsite plant evaluations, INPO teams

follow up on the effectiveness of each station’s actions in response to the

recommendations. Topics of Level 1 and Level 2 IERs in recent years include

integrated risks to plant viability, weakness in reactivity control, recurring electrical

shock events, and ineffective dose monitoring.

Members should review and take actions, as appropriate, on IERs. INPO evaluates

the effectiveness of utility programs in extracting and applying lessons learned from

industrywide, and internal station operating experience.

INPO maintains all operating experience reports on the secure member Web site.

This information supports members in applying historical lessons learned as new

issues are analyzed or activities are planned. INPO also provides “just-in-time”

summaries in numerous topical areas in a format designed to help plant personnel

prepare to perform specific tasks. These documents provide ready-to-use materials

to brief workers on problems experienced and lessons learned during recurring

activities.

ii.

Development of Documents and Products

Several categories of documents and other products are designed and developed to

help member utilities and participants achieve excellence in the operation,

maintenance, training, and support of nuclear plants. INPO documents and products

include the following key categories:

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The Performance Objectives and Criteria are standards for plant and corporate

performance used to promote excellence in the operation, maintenance, and

support of operating nuclear electric generating stations. The POC document is

the standard used in INPO evaluation activities, and member utilities often use

it in self-evaluations.

The POCs support the achievement of the following set of operational

excellence outcomes:

— sustainable, high-level plant performance

— sustainable, event-free operation

— avoidance of unplanned, long-duration shutdowns

— well-managed and understood safety, design, and operational

margins

— high levels of plant worker safety

— a highly skilled, knowledgeable, and collaborative workforce

Principles documents address professionalism, management and leadership

development, human performance and other cross-functional topics important

in achieving sustained operational excellence. INPO prepares these

documents with substantial involvement of industry executives and

managers. The principles extracted from the documents are used extensively

in evaluation and assistance activities.

The first of the principles documents, “Principles for Enhancing

Professionalism of Nuclear Personnel,” addresses human resource

management areas focused on developing nuclear professionals and

includes personnel selection, training and qualification and career

development. There are also principles documents providing expectations for

excellence in areas including leadership and team effectiveness, integrated

risk management, effective technical conscience and nuclear supplier

performance.

Guideline documents establish the bases for sound programs in selected

areas of plant operation, maintenance, training and cross-functional areas of

direct importance to the operation and support of nuclear stations. Guidelines

assist members in meeting the objectives used in evaluations and accredita-

tion. The guidelines are recommendations based on generally accepted

industry methods. They are not directives; instead, the intent of these

guidelines is to help utilities maintain high standards.

INPO provides good practices, work process descriptions, nuclear exchange

documents, and other documents to assist members. Typically, these

documents are developed from programs of member utilities and INPO’s

collective experience. INPO synthesizes the information into a document by

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its staff, with industry input and review. The documents define one method of

meeting INPO POCs in specific areas, although other programs or methods

may be as good or better. Utilities are encouraged to use these documents in

developing or improving programs applicable to their plants. These

documents can be used in whole or in part, as furnished, or modified to meet

the specific needs of the plant involved.

INPO produces various other documents, such as analysis reports and special

studies, as needed. Other assistance products include lesson plan materials,

computer-based and interactive video materials, videotapes, and examination banks.

iii.

Workshops and Meetings

INPO sponsors workshops and working meetings for specific groups of managers on

specific technical issues as forums for information exchange. This exchange

provides an opportunity for INPO and industry personnel to discuss challenges,

performance issues, and areas of interest. It also allows individuals from INPO

members and participants to meet and exchange information with their counterparts.

In 2015, more than 2,100 industry personnel participated in more than 70 seminars

and workshops at INPO.

iv.

Nuclear Network System

Nuclear Network is an international electronic information exchange for sharing

nuclear plant information. It is a major communication link for the operating

experience program and WANO event reporting system. The system transmits

operating experience information and other nuclear technical information.

The system includes a special dedicated method for reporting unusual plant

situations. This feature allows the affected utility to provide timely information

simultaneously to all Nuclear Network users, including the U.S. industry, INPO’s

international and supplier participants, and WANO members, so the affected station

does not have to respond to multiple inquiries. In addition, members are promptly

informed of problems occurring at one station, allowing them to implement actions to

prevent a similar occurrence.

Performance Data Collection and Trending

INPO operates and maintains a Consolidated Data Entry system as a single process

for the collection of data and information related to nuclear plant performance.

Members provide routine operational data in accordance with the WANO

Performance Indicator Program or regulatory requirements on a quarterly basis.

Plant data are then consolidated for trending and analysis purposes. Industry wide

trends developed from the data are provided to member and participant utilities for a

number of key operating plant performance indicators. Members use these data for

comparison and emulation with other plants, in setting specific performance goals,

and in monitoring and assessing the performance of their nuclear plants.

In the mid-1980s, the industry worked with INPO to establish a set of overall

performance indicators focused on plant safety and reliability. These indicators have

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gained strong acceptance and use by utilities to compare performance, set targets,

and drive improvements. Examples of indicators collected and trended include

unplanned automatic scrams, safety systems performance, unit capability factors,

forced losses of generation, fuel reliability, collective radiation exposure, and

industrial safety accidents.

The industry has established long-term goals for each indicator on a 5-year interval,

beginning in 1990.

vi.

Equipment Performance Data

The industry reports equipment performance information to ICES, and member

utilities use the data to identify and solve performance problems of plant equipment

with the goal of enhancing plant safety and reliability. INPO also uses the information

for performance trending to identify industry wide performance problems. The

Institute also makes the data available to the NRC to support equipment

performance reviews by the regulator.

vii.

Operating Experience for New Plant Construction

In 2009, a means for collecting and distributing experience from construction

problems was established through the U.S. industry’s Nuclear Network system.

Nuclear Network has long been the forum for rapid and secure communications and

has hosted the industry’s operating experience program. The new plant construction

program has a similar mission to that of the operating experience; however, it is

tailored to the unique needs of utilities with construction projects. The new plant

construction program has since been upgraded to include work at Watts Bar Nuclear

Plant Unit 2, and the new construction units at the Vogtle Electric Generating Plant

and Virgil C. Summer Nuclear Station.

viii.

Other Analysis Activities

INPO analyzes industry operational data from a variety of sources — events,

equipment failures, performance indicators, and regulatory reports — to detect

trends in industry performance. INPO communicates the results of analyses to the

industry using several methods. These documents typically review events and other

data over a period of years to summarize performance trends and causes and

suggest actions. Subjects of recent reports include event classification and

notification, mechanical maintenance performance, operator performance

proficiency, and piping and tubing leaks. Stations use these reports to assess their

performance and to identify improvements. In addition, individual plant performance

data are analyzed, and the results are used to support other INPO activities, such as

evaluations and assistance.

d. Comprehensive Performance Monitoring Program

In the second half of 2014, INPO established a performance monitoring program that

uses all available data and information in combination with targeted, systematic

assistance visits to develop an ongoing, comprehensive picture of plant performance

between evaluations, such that timely and effective action can be taken to avoid

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declines. Preventing declines is part of an overall strategy help the industry achieve a

condition that all stations operate at a high level of performance, meeting industry goals,

with no significant events, or long-duration shutdowns, and no training program

accreditation probations.

A team of performance monitoring leaders (PMLs) and support personnel continuously

review and analyze performance data of stations to identify subtle signs of decline.

Additionally, a core team of assigned INPO subject matter experts continuously review

and analyze performance data pertaining to their specific functional areas. Performance

is reviewed by all PMLs and support team members twice a quarter. The INPO senior

leadership team reviews and challenges on a quarterly basis the picture of performance

presented by the PML. Each PML is responsible for monitoring approximately eight

stations that are grouped by fleet organizations. When signs of decline are identified, the

PML works with station leaders to craft an assistance plan to arrest the decline and

improve performance.

The methodology to achieve the comprehensive monitoring objective has three

dimensions:

Monitoring: Monitoring leaders use all available data and information to

characterize station performance. Integrating data with plant observations and

insights from other touch points allow the PML to develop an integrated picture of

station performance. Credible trigger points are used to identify early gaps that

require intrusion.

Engage: Monitoring leaders engage station leaders, primarily site vice

presidents, to understand the station leader’s awareness of performance issues

and the effectiveness of corrective actions. Station leaders receive an INPO

Performance Summary Report (IPSR) twice a quarter. This report summarizes

the current integrated picture of station performance from INPO’s perspective.

Additionally, the chief nuclear officers and chief executive officers of each utility

receive a quarterly performance summary letter that provides a high-level

paragraph describing the current performance and trajectory of their stations.

Intervention: Intervention is required to shape performance improvement using a

graded and specific approach. There are two levels of intervention - elevation for

narrow shallow gaps, and escalation for wider deeper, or cross functional gaps.

Targeted elevation or escalation plans are developed with the station leadership

team to focus industry and INPO efforts to turn performance. In the case of a

precipitous decline, the plant may be assigned to the plant performance recovery

organization. Performance recovery uses a different process that relies more on

direct observations of station performance and more interactions with station

leaders.

Special Focus Program

A special focus program is in place for stations where behaviors and results are not

representing high levels of performance or stations experiencing a steep decline in

performance that increases the likelihood for a significant event. In most cases,

improvements are needed in a number of areas and significant weaknesses may exist. A

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recovery plan is developed as part of an integrated strategy to improve plant

performance. Routine and frequent interactions occur with station and utility/fleet

leaders. Specific INPO and industry assistance, including structured interactions with the

site, utility executives, the utility CEO and utility board of directors are required to

address persistent shortfalls or a significant decline in performance.

Between evaluations, a station can request and receive assistance in specific problem

areas to help improve plant performance. Assistance resources are provided using a

graded approach that provides a higher priority to those plants that need greater

performance improvement. This assistance is targeted for specific technical concerns

and for broader management and organizational issues. Although a station generally

requests assistance, INPO may, in some cases, suggest assistance in a specific area to

stimulate improvements.

Assistance Visits

Members may request assistance visits in specific areas of nuclear operations in

which INPO personnel have experience or expertise. INPO personnel and industry

peers normally conduct such visits. For example, if a member requests assistance in

some specific aspect of maintenance, INPO will include a peer from another plant

that handles that aspect of maintenance particularly well. INPO provides written

reports that detail the results of the visits to the requesting utility. In most cases, the

assistance visit includes actual methods and plans for improving performance as part

of the assistance visit.

In 2015, INPO provided more than 270 assistance visits using over 225 industry

peers. Key areas of assistance provided included operational focus, maintenance

and work management, engineering programs, chemistry, radiological protection,

human performance, and industrial safety. Additional areas of assistance conducted

in 2015 involved supplier participants, with a focus on supplemental personnel and

fuel performance. In addition to assistance visits to stations for specific functional

areas, INPO Performance monitoring representatives monitor and trend station

performance using data provided by the stations on a quarterly frequency. Over 120

data elements involving a wide variety of operating, maintenance and other stations

activities are reviewed for possible adverse trends, and INPO monitoring

representatives interact with station management for early signs of performance

decline. INPO teams also made multiple assistance visits at stations designated as

special focus.

Effectiveness reviews performed by INPO approximately 6 months after assistance

visits show that the visits are highly valued by station management and contribute to

improved performance.

New Plant Deployment

No new nuclear plants have been built in the United States for many years. However,

because of the need for additional power, concerns over the environmental effects of

carbon-based fuels, the streamlined licensing process, and financial incentives provided

by the Energy Policy Act of 2005, some U.S. utilities are once again planning or have

begun new plant construction. To support this effort, INPO formed a new plant

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deployment group several years ago and began to engage with the nuclear industry and

plan for the Institute’s involvement though application of its cornerstone programs.

INPO updated a report entitled, “Operating Experience to Apply to Advanced Light Water

Reactors,” which includes lessons learned from significant events. The updated report

includes experience from operations and maintenance activities that the design of new

plants should address. INPO participant plant designers and utility groups have used this

document in their review of the new designs.

INPO also engaged utilities in a series of benchmarking trips to international utilities and

plant designers in several countries as well as unrelated industries such as an aircraft

company, a coal plant with advanced control systems, and a company that uses modular

technology to build refinery installations. These trips provided an opportunity to learn

more about new technologies that have evolved since the last period of nuclear plant

construction, most notably in plant standardization, computerized man-machine

interface, and modular construction. INPO has issued several reports to its members

that features the information gathered from these trips.

In an effort to further support utilities with construction projects underway, INPO issued a

nuclear exchange on operational readiness lessons learned from a recent plant startup.

With these lessons in mind, INPO issued an operational readiness guidance document

and uses this guidance to conduct periodic review visits at units preparing for initial

operation, which allows for the early identification of potential gaps and help to ensure

the success of the project.

Relationship with World Association of Nuclear Operators

U.S. nuclear utilities are represented in WANO through INPO. As such, INPO coordinates

the U.S. nuclear utilities’ activities in WANO. INPO also provides operational support and

facilities for the WANO-Atlanta Centre, one of the four WANO global regional centers. The

WANO-Atlanta Centre Governing Board appoints an INPO executive to serve as the Atlanta

Centre director.

WANO-Atlanta Centre contracts with INPO to provide resources in terms of seconded staff

to support Atlanta’s day-to-day operations. WANO-Atlanta Centre also contracts with INPO

to provide administrative support services, such as payroll, computer support, and employee

benefit administration.

WANO-Atlanta Centre activities and programs include the following:

WANO-Atlanta Center teams of U.S. and international peers conduct reviews at the

request of INPO members to identify strengths and areas for improvement

associated with nuclear safety and reliability. A WANO-Atlanta Center peer review

conducted at a U.S.-INPO member plant is performed in place of an INPO plant

evaluation.

U.S. nuclear utilities share their operating experience with INPO, and WANO-Atlanta

Center and passes along the U.S. operating experience to WANO. The operating

experience sharing provides detailed descriptions of events and lessons learned to

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member utilities worldwide. International operating experience comes to WANO and

in turn is entered into ICES to share with the U.S. members.

WANO-Atlanta Center collects, trends, and disseminates performance indicator data

to facilitate goal setting and performance trending and to encourage emulation of the

best industry performance.

WANO-Atlanta Center conducts technical support missions to allow direct sharing of

plant operating experience and ideas for improvement.

WANO-Atlanta Center, with the support of INPO, designs professional and technical

development courses, seminars, and workshops to enhance staff development and

to share operating experience.

The U.S. nuclear power industry and INPO receive a substantial benefit through their

relationship with WANO and the international nuclear community. Many improvements have

been implemented in the U.S. based on lessons learned from the more than 340 units that

exist outside of the United States. INPO works to remain fully aware of trends in the global

nuclear industry and continues to strengthen relationships in this area.

Industry Response to the Accident at Fukushima

The earthquake and tsunami in Japan on March 11, 2011, and the subsequent nuclear

accident at Tokyo Electric Power Company’s Fukushima Dai-ichi nuclear power plant

resulted in worldwide attention toward improving nuclear safety.

EPRI, INPO, and the Nuclear Energy Institute (NEI), in conjunction with senior utility

executives, created a joint leadership model to integrate and coordinate the U.S. nuclear

industry’s response to events at the Fukushima Dai-ichi nuclear energy facility. This model

helped ensure that lessons learned were identified and well understood, and that response

actions were effectively coordinated and implemented throughout the industry.

Separately, the NRC conducted an independent assessment and has initiated actions to

ensure that its regulations reflect lessons learned from the Fukushima events.

The primary objective of the industry response is to maintain and improve already high

levels of operational safety and reliability, while applying the lessons from the Fukushima

Dai-ichi nuclear accident to strengthen resilience for external events. The U.S. nuclear

industry has established the following strategic goals to maintain and provide where

necessary, added defense-in-depth for critical safety functions, such as reactor core cooling,

spent fuel storage pool cooling, and containment integrity:

The nuclear workforce remains focused on safety and operational excellence at all

plants, particularly because of the increased work that the response to the

Fukushima event will represent.

Timelines for emergency response capability to ensure continued core cooling,

containment integrity and spent fuel storage pool cooling are synchronized to

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preclude fuel damage following station blackout (SBO) or challenges to the ultimate

heat sink.

The U.S. nuclear industry is capable of responding effectively to any significant event

in the United States with a scalable response to support an international event, as

appropriate.

Severe accident management guidelines, security response strategies, and external

event response plans are effectively integrated to ensure that nuclear energy

facilities can provide a symptom-based response to events that could affect multiple

reactors at a single site.

Margins for protection from external events are sufficient based on the latest hazards

analyses and historical data.

Spent fuel pool (SFP) cooling and makeup functions are fully protective during

periods of high heat load in the SFP and during extended SBO conditions.

Primary containment protective strategies can effectively manage and mitigate

postaccident conditions.

Accident response procedures provide steps for controlling, monitoring and

assessing potential radiation and ingestion pathways during and following an

accident, including timely communication of accurate information.

In addition to directly supporting the industry response strategy to the Fukushima accident,

INPO issued several INPO event reports (IERs) providing recommendations for addressing

lessons learned from Fukushima. In general, the recommendations were crafted to be

compatible with and supportive of actions required by the NRC. The IERs are summarized

below:

(1)

IER 11-1, “Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake

and Tsunami” dated March 15, 2011, and its supplement dated October 3, 2011

The events at the Fukushima Dai-ichi plant were caused by factors directly affecting

nuclear safety that were outside the design basis for the facility. Immediate actions

by the U.S. industry were appropriate to assess and take corrective actions to

address potential vulnerabilities that could challenge response to events that are

beyond site design bases.

The following four recommendations were provided to the U.S. nuclear industry to

provide near-term assurance that each station is in a high state of readiness to

respond to both design-basis and beyond-design-basis events:

Verify the capability to mitigate conditions that result from beyond design

basis events, typically bounded by security threats, committed to as part of

Section B.5.b of the NRC Security Order, dated February 25, 2002, and

severe accident management guidelines. Include, but do not limit, the

verification to the following:

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— Verify through test or inspection that equipment is available and

functional. Active equipment shall be tested and passive equipment

walked down and inspected. (The intent is not to retest permanently

installed equipment that is tested under a regulatory testing regime.)

— Verify through walkdowns or demonstration that procedures to

implement the above strategies are in place and are executable. (The

intent is not to connect to, or operate, permanently installed

equipment.)

— Verify that the qualifications of operators and the support staff needed

to implement the procedures and work instructions are current.

— Verify that any applicable agreements and contracts are in place and

can meet the conditions needed to mitigate the consequences of

these events.

Verify that the capability to mitigate SBO conditions required by station

design is functional and valid, as follows:

— Verify through walkdowns and inspection that all required materials

are adequate and properly staged.

— Demonstrate through walkdowns that procedures for response to an

SBO are executable.

Verify the capability to mitigate internal and external flooding events required

by station design, as follows:

— Verify through walkdowns and inspections that all required materials

and equipment are adequate and properly staged and that accessible

doors, barriers, and penetration seals are functional.

Perform walkdowns and inspections of important equipment needed to

mitigate fire and flood events to identify the potential that the equipment’s

function could be lost during seismic events appropriate for the site. Develop

mitigating strategies for identified vulnerabilities. As a minimum, perform

walkdowns and inspection of important equipment (permanent and

temporary) such as storage tanks, plant water intake structures, and fire and

flood response equipment, and develop mitigating strategies to cope with the

loss of that important function.

(2)

IER 11-2, “Fukushima Daiichi Nuclear Station Spent Fuel Pool Loss of Cooling and

Makeup,” dated April 25, 2011 and revised October 28, 2014

The earthquake and tsunami caused the loss of all station power supplies. As a

result, all SFP cooling and makeup was lost to each of the Fukushima Dai-ichi SFPs.

The loss of cooling to the fuel pools for Units 1, 2, 3, and 4 resulted in the pools

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heating up and ultimately reaching saturation or near saturation temperatures. The

resultant evaporation reduced the SFP inventories.

The inability to maintain SFP water inventory in multiple units resulted in

extraordinary recovery efforts. These actions included helicopter seawater drops, fire

truck seawater sprays, water cannons, and fire pump seawater injection into the fuel

pool cooling systems. Recovery efforts and operator access to the SFPs were limited

by adverse conditions, including high dose rates, radiological contamination, and

reactor building and plant systems damage. A lack of recovery plans and suitable

makeup equipment is believed to have further hindered fuel pool cooling and water

inventory recovery.

The following recommendations were provided to the U.S. nuclear industry to ensure

that each station will increase its sensitivity to spent fuel storage event response and

that each station will maintain a high state of readiness to respond to events that

challenge spent fuel storage integrity:

For outage periods, verify the implementation of actions to address

Recommendations 1 - 4 and Recommendations 6 - 12 in SOER 09-1,

“Shutdown Safety,” as they relate to the safety functions associated with SFP

cooling and inventory makeup. Implement this recommended action within 60

days.

For online periods when the time for the SFP to reach 200 degrees

Fahrenheit upon loss of normal cooling is less than 72 hours, establish

controls to identify and protect systems and equipment required to maintain

the functions of SFP decay heat removal and inventory control. The controls

should include the following:

— Protected systems and equipment are clearly identified in the field to

prevent inadvertent work on or near protected equipment. Physical

barriers are used whenever possible, particularly in areas in which

personnel could bump into a component, thereby causing an

inadvertent trip or system transient. Protected spaces are monitored

to ensure that barriers are in place and that unauthorized work is not

occurring. Nonintrusive work is controlled and limited to activities,

such as visual inspections and operator rounds.

— For work required on protected SFP equipment, support systems, or

backup equipment, establish specific management controls for the

conduct of work. These controls will include additional barriers, such

as walkthroughs, contingencies and direct management oversight.

Establish compensatory actions for the SFP decay heat removal and

inventory control functions commensurate with the risk of the

associated SFP configuration. The establishment of compensatory

actions will prevent the SFP from reaching saturation conditions on

loss of cooling.

For all plant conditions, establish the time for the SFP to reach 200 degrees

Fahrenheit (bulk temperature) in the event that normal cooling is lost.

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Maintain this information in a format that is readily available in the control

room and emergency response facilities. This time is intended for information

purposes only in case a sustained loss of SFP cooling or inventory occurs.

Implement this recommended action within 90 days.

Verify the adequacy of station abnormal operating procedures for responding

to the loss of SFP cooling or inventory.

— Ensure these procedures include actions to monitor SFP level and

contingencies to monitor SFP temperature and area radiation

readings when necessary because pool cooling or level cannot be

maintained.

— Provide the capability to make up inventory to the SFPs during a loss

of all AC power.

— Verify that the guidance in the abnormal operating procedures can be

implemented during severe weather, seismic events, loss of control

room, and flood conditions.

Revise station emergency operating procedures or other event-based

procedures to include a precautionary statement that SFP level and

temperature should be monitored.

If dry casks are used for storage of spent fuel, establish procedures to verify

the cask condition following severe weather, seismic events or flooding.

These procedures should include visual inspections to identify cask damage

that could result in a loss of containment, shielding or cooling functions.

Procedures should also include area radiation surveys to identify any

deviation from normal background levels and should identify response

actions if abnormal conditions are found. Include use of these procedures in

training for applicable personnel.

Establish a periodic surveillance test or maintenance activity to verify the

functionality of any vacuum/siphon breakers associated with spent fuel or

coolant inventory systems.

(3)

IER 11-4, “Near-Term Actions to Address the Effects of an Extended Loss of All AC

Power in Response to the Fukushima Daiichi Event,” dated August 1, 2011

The earthquake and large tsunami that inundated the Fukushima Dai-ichi nuclear

plant caused an extended loss of all AC power that resulted in emergency core

cooling systems being unable to prevent fuel damage at three of the six units.

Most U.S. plants have 4-hour coping durations for mitigating SBO conditions. U.S.

plants also developed emergency response strategies to mitigate the effects of fires

that would adversely affect safety system functions. In many cases, stations rely on

SBO diesel generators, gas turbines, or AC power from other onsite sources to

mitigate the blackout condition. Although existing capabilities for coping with loss of

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AC power conditions are robust, postulating low-probability events and scenarios

that are beyond SBO design basis and that challenge those capabilities is possible.

IER 11-4 details processes by which station personnel can identify reasonable

strategies and actions to extend the time in which existing equipment can be used to

maintain critical safety functions for extended loss of AC power until additional

equipment can be supplied to support long-term safe shutdown conditions. The

scope of this effort should include operating conditions to determine the most limiting

conditions.

The recommendations call for the development of preplanned contingencies for

protection from an extended loss of AC power and beyond station blackout events

similar to those experienced at Fukushima Dai-ichi pending longer-term industry

response. The recommendations also require stations to provide unit-specific

information concerning coping time and design limitations for extended loss of power

events to support U.S. industry awareness and response to the Fukushima Dai-ichi

event. The four recommendations are listed below:

For all units, develop methods to maintain (or restore) core cooling,

containment integrity, and SFP inventory using existing installed and portable

equipment during an extended loss of electrical AC power event that lasts at

least 24 hours. Included in this recommendation are implementing actions to

address loss of AC power events (beyond station blackout) simultaneously at

each unit of multiunit sites using the conditions described in the body of IER

L1-11-4. Implement actions to improve operating margin that can be

accomplished within the existing license.

— Report the length of time the station can maintain critical safety

functions listed in Recommendation 1 using existing installed

equipment, even if less than 24 hours. Identify and report conditions

that limit achieving the 24-hour duration.

— Report the length of time the station can maintain the critical safety

functions listed in Recommendation 1 using existing installed and

portable equipment, even if less than 24 hours. Identify and report

conditions that limit achieving the 24-hour duration or longer

durations. Describe and report the protective measures or measures

that differentiate portable equipment from installed electrical AC

power sources.

— If enhancements or station upgrades are proposed for extending

station ability to increase operating margin for extended loss of AC

power events, include in your response the proposed upgrades and

the expected margin improvement. The proposed upgrades will

inform the industry working group process on methods and strategies

recommended for broad industry consideration.

Identify essential instrumentation needed for monitoring core, containment,

and spent fuel safety. Develop methods to ensure these functions are

maintained throughout an extended loss of AC power event. This

recommendation includes performing a plant-specific analysis of methods

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that would be used. Specifically, methods and instructions should include the

identification of needed equipment and materials to power the minimum

essential components in the event installed DC batteries are depleted.

Develop methods for providing fuel to power emergency response

equipment. Develop strategies for obtaining fuel oil sufficient to operate

temporary power equipment in the event of a loss of all site AC power

sources lasting at least 24 hours. Onsite fuel oil reserves that are protected

from flood and seismic events appropriate for the site may be credited for this

recommendation.

Provide communications equipment suitable for onsite and offsite

communication needs during an extended loss of AC power event. Develop a

means for communicating with emergency response personnel for an

extended loss of AC power event. To assess a needed communications

strategy, expect that AC power is not available to cell or other

communications infrastructures within 25 miles of the plant site.

(4)

IER 13-10, “Nuclear Accident at the Fukushima Daiichi Nuclear Power Station,”

dated March 28, 2013

In 2012, a team of INPO, WANO and U.S. industry personnel conducted an event

review in Japan focusing on lessons learned for the broader nuclear industry. Tokyo

Electric Power Company fully supported this review and provided full access to

individuals and information available 1 year following the accident at Fukushima

Dai-ichi. The lessons learned were summarized in a report made broadly available,

and IER 13-10 was issued to provide recommendations for addressing the

leadership, organizational, cultural, resource, and training issues that contributed to

the event and that detracted from an effective emergency response. WANO issued a

Significant Operating Experience Report containing similar recommendations.

IER 13-10 includes a broad set of recommendations, some with multiple parts. For

brevity, the full text of the recommendations is not listed in this update to the

Convention on Nuclear Safety Report for 2015. Instead, the following provides an

overview of the recommended actions:

Through senior manager and leader actions, foster development of a culture

in which the staff recognizes that an extreme external event can occur and

rigorous preparations must be made to respond to such an event.

Establish enterprise and station risk management processes that consider

nuclear risks, including those associated with changes in design basis

assumptions for external events that could exceed the capability of installed

equipment and accident response procedures.

Implement emergency and accident response strategies for an extreme

external event that provide multiple methods to restore and maintain safety

functions, such as core cooling, emergency power, and containment integrity,

using a defense-in-depth approach.

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Equip personnel responsible for performing emergency response duties with

the required knowledge, skills, and proficiency to execute their roles.

Staff organizations with sufficient personnel to respond effectively during

initial stages of an extreme external event involving more than one unit at a

multiunit site, and develop plans for staffing during long-duration events.

Stage, maintain, test, secure, and programmatically control equipment

needed for event response in a manner that protects from damage from the

initiating event, supports timely deployment, and reduces likelihood of human

error.

Establish procedures and make preparations to enable the site organization

to provide and receive assistance for mitigating a complex or long-duration

emergency event.

Beginning in 2013 and continuing through 2015, an industry group coordinated by INPO

developed training materials to assist utilities in preparing their organizations for

beyond-design-basis events. These materials include case studies and instructor-led

training focused on decisionmaking and decisionmaking under stress. The group also

developed a guideline for establishing effective training for emergency response personnel.

The guideline includes results of a job analysis that identified the needed knowledge and

abilities required for each job function.

The INPO emergency plan and emergency response facilities were updated in early 2013 to

better assist members in mobilizing the resources of the nuclear industry to provide

assistance to a site experiencing an event. All INPO member utilities signed a mutual

assistance agreement to provide resources during such an event, if requested. INPO

conducts quarterly drills, most involving the Nuclear Energy Institute and the Electric Power

Research Institute, to practice response actions. Some are conducted in conjunction with

utilities during their regularly scheduled emergency preparedness drills. In July 2015, the

industry response capability was demonstrated during a large-scale radiological release

exercise conducted by Federal and State governmental agencies. This event, known as

Southern Exposure 2015, was a fully integrated exercise that demonstrated the nation’s

ability to effectively respond to a nuclear power plant event that resulted in widespread

contamination to the surrounding community. The exercise was conducted in multiple

phases over 5 days, beginning on July 21, 2015, and included time jumps to 14 days, 6

months, and 18 months postevent. Additional information can be found in Section 1.3.3 of

Part 1 of this report.

Diverse and Flexible Coping Strategies (FLEX)

NEI and INPO worked with the U.S. nuclear industry to develop a “Diverse and Flexible

Coping Strategy” that was endorsed by the NRC in August 2012. It provides a diverse and

flexible means to prevent fuel damage while maintaining the containment function in

beyond-design-basis external event conditions, resulting in an extended loss of AC power,

and a loss of normal access to the ultimate heat sink.

273

The objective is to establish an indefinite coping capability by relying upon installed

equipment, onsite portable equipment, and prestaged offsite resources. The equipment

ranges from diesel-driven pumps and electric generators to ventilation fans, hoses, fittings,

cables and communications gear. The new equipment will be stored at diverse locations at

the sites and protected to ensure that it can be used if other systems that compose a

facility’s multilayered safety strategy are compromised. This flexible approach builds on

existing safety systems to protect against unforeseen events. FLEX employs a three-phase

approach:

Phase 1 - following the event and prior to the time when portable equipment can be

deployed, the plant must be able to maintain the key safety functions using installed

equipment.

Phase 2 - with adequate time and staffing, deploy onsite portable equipment.

Phase 3 - after 24 hours, offsite equipment can be deployed to sustain key safety

functions indefinitely.

In summary, the concept is diverse and flexible to enable deployment of the strategies for a

range of initiating events and plant conditions.

The offsite staged equipment strategy consists of the following elements:

Identify and plan for each site’s offsite equipment needs

Standardize interconnections

Align with onsite coping strategies

Determine required deployment times

Designate offsite locations

Establish logistics, transport, and shipping requirements

Establish sharing agreements

Plan for self-sufficiency, but include government

The concept for offsite support is based on the assumption that onsite resources must be

sufficient to cope for the first 24 hours. FLEX analyses determine what coping equipment

can be credited as coming from offsite sources. Procedures used to respond to FLEX

address contacting the offsite sources. A standardized list of equipment connectors was

developed to address interchangeability of the equipment. Each site is required to have one

set of FLEX equipment onsite for each unit, plus one extra set. Therefore, these sites

become a source of FLEX equipment for a site in such an event. During an emergency

event, a call to INPO or directly to the other site will activate mobilization of FLEX equipment

from other sites.

In addition to support from other sites, there are two response centers, in Memphis and

Phoenix, capable of delivering equipment to any site. The response centers are managed by

a vendor, Strategic Alliance for FLEX Emergency Response. The Pooled Equipment

Inventory Co. joined forces with AREVA to create this new company to develop and manage

the response center program. Each response center has five sets of FLEX equipment: four

sets to support sites and one set out of service for maintenance. Each center also has

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additional equipment specified by a site in their site-specific response center mobilization

manual.

Each site has identified a staging area for delivery of the equipment. The response center

will deliver the specified equipment to the staging area within 24 hours of being notified.

Delivery will generally be made by air transport. Support will include equipment and may

include equipment technicians to assist with setup and deployment. Qualified technicians

from the 60 other facilities can be dispatched.

10. Conclusion

The U.S. commercial nuclear industry has made substantial, sustained, and quantifiable

improvements in plant safety and performance during the 3 decades since Three Mile

Island. The leaders who guided this industry over decades of challenge and change

showed great insight when they recognized the need for an unprecedented form of industry

self-regulation through peer review. The industry members acknowledged that nuclear

energy would remain a viable form of electric power generation only if utilities could ensure

the highest levels of nuclear safety and reliability (i.e., the achievement of excellence) in

nuclear power plants. The industry responded to this challenge by creating an independent

oversight process of the highest integrity and by requiring of itself an uncompromising

commitment to the standards and ethical principles that are essential to success.

This insight and commitment to integrity has provided the foundation for a unique, sustained

partnership between INPO and its members. INPO is pleased to serve as an essential

element of an industry that has raised its standards and improved its performance in nearly

every aspect of plant operation. INPO does not take credit for this success, but it does take

pride in its contribution to that success.

INPO also recognizes that the pursuit of excellence is a continuing journey. As the U.S.

nuclear industry evolves and advances, it will continue to encounter situations that challenge

both people and equipment in a business environment that is competitive, complex, and

increasingly global in character.

These challenges, although demanding, are not insurmountable. The U.S. commercial

nuclear industry, in partnership with INPO, will continue the tradition of both sharing insight

and acting with integrity and, in doing so, will continue on the shared journey to ever higher

levels of excellence.

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APPENDIX A

NRC STRATEGIC PLAN 2014 - 2018

The U.S. Nuclear Regulatory Commission (NRC) published NUREG-1614, Volume 6, “Strategic

Plan: Fiscal Years 2014-2018” in August 2014. Appendix A to this report summarizes the key

points of this plan.

Key Challenges

During the upcoming planning period, the NRC will face new challenges as it continues to

operate in a dynamic environment. Key factors the agency has considered in developing this

plan include the following:

continued implementation of enhancements to improve nuclear safety based on insights

arising from operating experience reviews and lessons learned from the 2011 nuclear

accident at the Fukushima Dai-ichi nuclear facility in Japan

continual learning and adaptation of the regulatory framework to address knowledge of

and response to the specific hazards, uncertainties, and risks associated with each

nuclear site

continued readiness to review applications involving new technologies such as small

modular reactors, medical isotope production facilities, and rapidly evolving digital

instrumentation and control systems

changes in the demographics, experience, and knowledge of the workforce

continued awareness of and support to the development of nuclear safety and security

regulations around the world

changing economic conditions in the energy market affecting current and planned

applications to construct and operate new nuclear facilities or decommission existing

ones

globalization of nuclear technology and the nuclear supply chain, driving the need for

increased international engagement on the safe and secure use of radioactive material

and the need for new oversight approaches, including ensuring that foreign components

used in U.S. nuclear facilities are in compliance with NRC requirements

continuous monitoring of the threat environment to ensure the security of facilities and

accountability controls for radioactive materials.

To meet these challenges, the NRC must use its resources effectively and efficiently, enhance

the regulatory framework as appropriate to address existing or emerging issues, and deploy

effective and innovative strategies for maintaining staff competence and readiness. Even as the

NRC works to address these challenges, the agency’s mission and organizational values

remain unchanged. The agency will remain a strong, independent, stable, and effective

regulator that places the highest priority on ensuring the safety and security of the nuclear

facilities and radioactive materials it regulates.

A-1

Key External Factors

The NRC’s ability to achieve its strategic goals and their associated strategic objectives is

influenced by many external factors, including industry operating experience, national priorities,

the threat environment, legislation, Federal court litigation, market forces, and resource

availability. The NRC will strengthen its ability to manage change and maintain its readiness to

respond promptly to any agency priority shifts necessitated by factors that are beyond its

control. The agency will also make efforts to influence those factors that enable the

achievement of its strategic objectives.

External Factors Affecting Safety Objective 1: Prevent and mitigate accidents and

ensure radiation safety.

Market Pressures on Operating Plants and License Applications. Market forces result in

pressures for licensees to reduce operating costs. As a result, the NRC needs to be

prepared for changes in workload and to address potential shutdowns of facilities before

license expiration and to continue to ensure that oversight programs identify degrading

facility safety and security performance. Conversely, the lower capital costs of small

modular reactors (under 300 megawatts) may offer industry a more attractive option to

add new capacity. Several entities are seeking to submit license applications for small

modular reactors in the next several years. The U.S. Department of Energy (DOE) is

funding a program “to design, certify and help commercialize innovative small modular

reactors (SMRs) in the United States.” Therefore, the NRC is developing a licensing

framework for these as well as other advanced reactors.

Significant Operating Incident at a Non-U.S. Nuclear Facility. A significant incident at a

nuclear facility outside the United States could cause the agency to reassess its safety

and security requirements, which could change the agency’s focus on some initiatives

related to its objectives until the situation stabilizes.

Significant Operating Incident at a Domestic Nuclear Facility. A significant incident at a

U.S. nuclear facility could cause the agency to reassess its safety and security

requirements, which could change the agency’s focus on some initiatives related to its

objectives until the situation stabilizes. Because the NRC’s stakeholders are highly

sensitive to many issues regarding the use of radioactive materials, even events of

relatively minor safety significance could potentially require a response that consumes

considerable agency resources.

International Nuclear Standards Developments. International organizations, such as the

International Atomic Energy Agency, will continue to develop and issue standards and

guidance affecting global commitments to nuclear safety and security. To ensure that the

best results are achieved both domestically and internationally, the NRC needs to

proactively engage in these international initiatives and to provide leadership in a

cooperative and collegial manner.

International Treaties and Conventions. As part of the international response to lessons

learned from the Fukushima Dai-ichi nuclear accident in Japan, the international nuclear

regulatory community is reviewing the Convention on Nuclear Safety. As one of the

contracting parties to the Convention, the NRC is a member of the working group that is

A-2

reviewing the Convention. Likewise, the NRC participates in the Joint Convention on the

Safety of Spent Fuel Management and on the Safety of Radioactive Waste

Management.

Globalization of the Nuclear Technology and the Nuclear Supply Chain. Components for

nuclear facilities are increasingly manufactured overseas, resulting in challenges of

providing effective oversight to ensure that these components are in compliance with

NRC requirements. In addition, the continuing globalization of nuclear technology is

driving the need for increasing international engagement on the safe use of radioactive

material.

External Factors Affecting Security Objective 1: Ensure protection of nuclear facilities

and radioactive materials.

Significant Terrorist Incident. A sector-specific credible threat or actual significant

terrorist incident anywhere in the United States would result in the Department of

Homeland Security raising the threat level under the National Terrorism Advisory

System. In turn, the NRC would similarly elevate the oversight and response stance for

NRC-regulated facilities and licensees. Potentially, new or revised security requirements

or other policy decisions might affect the NRC, its partners, and the regulated

community. In a similar fashion, a significant terrorist incident at a nuclear facility or

activity anywhere in the world would need to be assessed domestically and potentially

lead to a modification of existing security requirements for NRC-regulated facilities and

licensees.

International Treaties and Conventions. The ratification by the United States of

international instruments related to the security of nuclear facilities or radioactive

materials could potentially impose binding provisions on the Nation and the

corresponding governmental agencies, such as the NRC and DOE.

Globalization of Nuclear Technology. The continuing globalization of nuclear technology

is driving the need for increased international engagement on the secure use of

radioactive material.

Legislative and Executive-Branch Initiatives. Congressional and Executive Branch

initiatives concerning cyber security could affect the NRC’s regulatory framework for

nuclear security. If the NRC were to become concerned about an aspect of a bill or

policy initiative that had been introduced, the staff would consult the Commission to

develop a strategy for making such concerns known.

External Factors Affecting Security Objective 2: Ensure protection of classified and

Safeguards Information.

Lost, Misplaced, Intercepted, or Delayed Information. With the increased use of mobile

devices and alternative storage options, the introduction of new communication

technologies, and the increased use of telecommunication, there is a heightened risk

that sensitive information held by the NRC or its licensees can be lost, misplaced, or

intercepted and fall into the hands of unauthorized persons.

A-3

APPENDIX B

NRC MAJOR MANAGEMENT CHALLENGES FOR THE FUTURE

By law, the Inspector General of each Federal agency (discussed in Article 8 of Part 2 to this

report) must describe what he or she considers to be the most serious management and

performance challenges facing the agency and must assess the agency’s progress in

addressing those challenges. Accordingly, the Inspector General of the U.S. Nuclear Regulatory

Commission (NRC) prepared his annual assessment of the major management challenges

confronting the agency. The NRC published the latest report in October 2015; this report can be

found on the agency’s public Web site.

The Fiscal Year (FY) 2016 management and performance challenges are directly related to the

NRC’s mission areas (i.e., commercial nuclear reactors and nuclear materials), security,

information technology and information management, financial programs, and administrative

functions. The agency’s work in these areas indicates that while program improvements are

needed, the NRC is continually making progress to address the Inspector General’s

recommendations and improve the efficiency and effectiveness of its programs. These

challenges represent what the Inspector General considers to be inherent and continuing

program challenges relative to maintaining effective and efficient oversight and internal controls.

As a result, it is likely they will continue to be challenges from year to year. Challenges do not

necessarily equate to problems. In the 2015 report, the Inspector General identified the six

management challenges described below to be the most serious as of October 1, 2015.

Challenge 1: Regulation of nuclear reactor safety programs

The NRC is responsible for maintaining an established regulatory framework for the safe and

secure use of civilian nuclear reactors, including commercial nuclear power plants as well as

research, test, and training reactors. As of October 1, 2015, there are 99 nuclear power plants

licensed to operate in the United States, which generate about 20 percent of the Nation’s

electrical use, as well as 5 plants under construction (i.e., Vogtle Units 3 and 4; Summer Units 2

and 3; Watts Bar Unit 2). There are also 31 licensed research and test reactors. The NRC’s

regulatory oversight responsibilities in the reactor arena include developing policy and

rulemaking, licensing and inspecting reactors, licensing reactor operators, and enforcing

regulations. The agency implements the nuclear reactor safety program with approximately 77

percent ($810 million) of its total budget authority and 76 percent (2,900 full-time equivalent

employees) of its total staff. Thus, it is of paramount importance that the agency implements

these programs as effectively and efficiently as possible.

Challenge 2: Regulation of nuclear materials and radioactive waste programs

The NRC is responsible for maintaining an established regulatory framework for the safe and

secure use of nuclear materials; medical, industrial, and academic applications; uranium

recovery, conversion and enrichment activities; fuel fabrication and development; and high-level

and low-level radioactive waste. The NRC is authorized to grant licenses for the possession and

use of radioactive materials and establish regulations to govern the possession and use of

those materials. Upon a State’s request, the NRC may enter into an agreement to relinquish its

authority to the State to regulate certain radioactive materials and limited quantities of special

nuclear material. The State must demonstrate that its regulatory program is adequate to protect

public health and safety and the environment, and compatible with the NRC’s program. The

States that enter into an agreement assuming this regulatory authority from the NRC are called

B-1

Agreement States. Currently, there are 37 Agreement States.

The NRC regulates high-level radioactive waste generated from commercial nuclear power

reactors. High-level radioactive waste is either spent (used) reactor fuel when it is accepted for

disposal or waste material remaining after spent fuel is reprocessed. Because radioactive waste

becomes harmless only through decay (which may take hundreds of thousands of years for

high-level waste), the material must be stored and ultimately disposed of in a manner that

provides adequate protection of the public for a very long time.

Low-level radioactive waste is typically produced at nuclear power reactors, hospitals, research

facilities, and clinics from the use of nuclear materials for industrial and medical purposes. The

NRC regulates the management, storage, and disposal of radioactive waste produced as a

result of NRC-licensed activities. Low-level radioactive waste includes contaminated protective

clothing, equipment and tools, medical supplies, and laboratory animal tissues.

Challenge 3: Management of security over internal infrastructure (personnel, physical,

and cyber security) and nuclear security

The NRC must remain vigilant with regard to the security of its infrastructure and that of nuclear

facilities and nuclear materials. The NRC must continue to use robust, proactive measures to

protect its infrastructure — the buildings, personnel, and information — from both internal and

external threats. Moreover, as the nature of the threat continues to evolve, the NRC faces

challenges with oversight of protecting nuclear facilities and materials, the sharing of sensitive

information, as well as emergency preparedness and incident response.

Challenge 4: Management of information technology and information management

Technology advances rapidly. New technologies such as cloud, virtualization, and mobility are

tools that can be implemented. The challenge is deciding which of these new technologies will

work to the best interest of the NRC now. The mission of the NRC’s information

technology/information management program is to manage information and employ information

technology to enhance information access and strengthen agency performance. The most

important goal of the NRC’s information technology/information management program is

effective information access— enabling both NRC staff and the public to quickly and easily

obtain the information they need. This goal reflects the NRC’s commitment to openness and is

essential for effective agency operations.

Challenge 5: Management of financial programs

The NRC is required by the Omnibus Budget Reconciliation Act of 1990 to collect fees totaling

approximately 90 percent of its annual budget authority. The agency’s budget authority for FYs

2013 and 2014 was $985.6 million and $1,055.9 million, respectively. The NRC estimated that

$859.6 million for FY 2013 and $916.7 million for FY 2014 should be recovered from invoiced

fees. The NRC is required to establish a schedule of charges that fairly and equitably assess

the fees to license holders and license applicants. In recent years, multiple external

stakeholders have questioned the NRC’s budget and fees structure. To maintain transparency,

the NRC must continue to implement solid internal controls over financial management and

reporting.

B-2

Challenge 6: Management of administrative functions

The NRC should continue exploring ways to reduce administrative inefficiencies while

maintaining the appropriate corporate support to carry out agency operations. During FY 2015,

NRC workforce totaled approximately 3,700 staff positions. To support the agency’s technical

staff, the NRC provides corporate support services, such as contract support and multiple

human resource programs. Although the NRC has implemented multiple programs to support

agency staff, the NRC continues to operate in a Federal Government environment of stagnant

or reduced agency budgets, and increasing pressure to reduce corporate support costs.

Because of this, the agency needs to have an adequate balance between administrative

functions and technical needs. In addition, the NRC must be able to effectively recruit, train

and transfer knowledge to new hires. This includes maintaining up-to-date guidance to

effectively transfer knowledge and train current staff.

B-3

APPENDIX C

REFERENCES

American National Standards Institute

American National Standards Institute N18.7-1976, “Administrative Controls and Quality

Assurance for the Operational Phase of Nuclear Power Plants,” American National

Standards Institute, Washington, DC, February 1976.

American Nuclear Society

American Nuclear Society, ANSI/ANS 3.2-2012, “Managerial, Administrative, and

Quality Assurance Controls for the Operational Phase of Nuclear Power Plants,”

American Nuclear Society, La Grange Park, IL, March 20, 2012.

American Society of Mechanical Engineers

American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,

Section XI, “Inservice Inspection of Nuclear Power Plant Components,” American

Society of Mechanical Engineers, New York, NY, 2010.

ASME Code Case N-716-1, “Alternative Piping Classification and Examination

Requirements,” American Society of Mechanical Engineers, New York, NY, 2013.

ASME Code Case N-770, “Alternative Examination Requirements and Acceptance

Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated with

UNS N06082 or UNS W86182 Weld Filler Material with or without Application of Listed

Mitigation Activities,” American Society of Mechanical Engineers, New York, NY,

January 26, 2009.

ASME-RA-Sa-2009, “Standard for Level 1/Large Early Release Frequency Probabilistic

Risk Assessment for Nuclear Power Plant Applications,” American Society of

Mechanical Engineers, New York, NY, 2009.

Boiling Water Reactor Vessel Internals Program

Boiling Water Reactor Vessel Internals Program (BWRVIP)-75-A, “BWR Vessel and

Internals Project, Technical Basis for Revisions to Generic Letter 88-01 Inspection

Schedules,” October 2005.

BWRVIP-194, “Methodologies for Demonstrating Steam Dryer Integrity for Power

Uprate,” December 18, 2008.

BWRVIP Letter 2007-051, William A. Eaton (BWRVIP Chairman) to BWRVIP Executive

Committee, “Request for Information on Dissimilar Metal Weld Examinations,”

January 23, 2007.

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BWRVIP Letter 2007-062, Robin Dyle/Randy Stark to All BWRVIP Committee Members,

“Letter to NRC Regarding BWRVIP Actions in Response to Flaw Indications in

Recirculation Inlet Piping Nozzle to Safe End Welds at Duane Arnold,”

February 28, 2007.

BWRVIP Letter 2007-139, Rick Libra (BWRVIP Chairman) to BWRVIP Executive

Committee, “Request for Review of Dissimilar Metal Weld Examination Information,”

May 24, 2007.

BWRVIP Letter 2007-367, Rick Libra (BWRVIP Chairman) to BWRVIP Executive

Committee, “Recommendations regarding Dissimilar Metal Weld Examinations (Includes

Needed Requirement per NEI 03-08),” December 4, 2007.

Code of Federal Regulations

Title 10 of the Code of Federal Regulations (10 CFR) Part 2, “Agency Rules of

Practice and Procedure,” U.S. Nuclear Regulatory Commission, Washington, DC.

10 CFR Part 19, “Notices, Instructions and Reports to Workers: Inspection and

Investigations,” U.S. Nuclear Regulatory Commission, Washington, DC.

10 CFR Part 20, “Standards for Protection against Radiation,” U.S. Nuclear Regulatory

Commission, Washington, DC.

10 CFR Part 21, “Reporting of Defects and Noncompliance,” U.S. Nuclear Regulatory

Commission, Washington, DC.

10 CFR Part 26, “Fitness for Duty Programs,” U.S. Nuclear Regulatory Commission,

Washington, DC.

10 CFR Part 30, “Rules of General Applicability to Domestic Licensing of

Byproduct Material,” U.S. Nuclear Regulatory Commission, Washington, DC.

10 CFR Part 34, “Licenses for Industrial Radiography and Radiation Safety

Requirements for Industrial Radiographic Operations,” U.S. Nuclear Regulatory

Commission, Washington, DC.

10 CFR Part 35, “Medical Use of Byproduct Material,” U.S. Nuclear Regulatory

Commission, Washington, DC.

10 CFR Part 39, “Licenses and Radiation Safety Requirements for Well Logging,”

U.S. Nuclear Regulatory Commission, Washington, DC.

10 CFR Part 40, “Domestic Licensing of Source Material,” U.S. Nuclear Regulatory

Commission, Washington, DC.

10 CFR Part 50, “Domestic Licensing of Production and Utilization

Facilities,” U.S. Nuclear Regulatory Commission, Washington, DC.

10 CFR Part 51, “Environmental Protection Regulations for Domestic Licensing and

Related Regulatory Functions,” U.S. Nuclear Regulatory Commission, Washington, DC.

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The United States of America Seventh National Report for the Convention on Nuclear Safety (2016) - page 5