Kevin Pushee INPO DNP Leader Delivering the Nuclear Promise: Advancing Safety, Reliability and Economic Performance Initiative 2017 Emergency Preparedness Working Meeting - November 7 2017 Kevin Pushee INPO DNP Leader

DNP Status Update Efficiency Bulletin Progress: Implementation Status EBs Important to Emergency Preparedness Planned/Scheduled for remainder 2017 and 2018 EB Implementation- Industry Challenges INPO’s Role- EB Development/Issuance Access to DNP Materials

Efficiency Bulletins: Issued and Scheduled 63 EBs Issued to date (Feb 2016 – Oct 2017) ~35 additional EBs scheduled for development in 2017 and 2018 Majority in areas of WM, ENG, O&A, RP Training 10 Engineering 8 Supply Chain 3 Oversight and Assessment 9 Preventative Maintenance 4 Regulatory Efficiency 2 Radiation Protection Risk Informed Operations Correction Action program Work Management Security In-Processing 1 3

EBs Important to Emergency Preparedness EB16-17: Optimizing FLEX Equipment Preventive Maintenance Strategies (Blue- Implementation Jan 2017) Establishes Industry Operating History for Portable Flex Equipment Utilizes EPRI-developed FLEX equipment database Equipment history info will be used to adjust PM task content and frequency May take several years to build history on some equipment Improves Plant Equipment Reliability and Reduces Maintenance Costs Enables Maintenance/Engineering to focus resources on maintaining important plant equipment Guiderails Revisions to component PM tasks must be documented in the station’s PM technical bases Some notable highlights of the attached information include: ? Palo Verde use of portable generators and FLEX Steam Generator (SG) Makeup Pump for risk reduction ? Shearon Harris EPRI TIP Award for use of FLEX Emergency Service Water (ESW) Pump to change the Allowed Outage Time (AOT) to replace an installed ESW Pump ? Catawba NRC finding reduction from Yellow to White utilizing FLEX portable equipment in the NRC Standardized Plant Analysis Risk (SPAR) model ? McGuire outage risk reduction improvement from Orange to Yellow using the pre-staged Medium Pressure FLEX Hale Pump for additional defense in depth 4

EBs Important to Emergency Preparedness EB17-10: Maximizing the Benefit of Portable Equipment (Green- Issued: Mar 2017) Promotes temporary use of portable equipment; e.g. FLEX and B.5.b, to improve site operations and safety Increases critical safety function defense-in-depth Leverages use of risk-informed regulatory programs to improve economic performance Use of Portable Equipment conducted IAW: NEI 16-06: Crediting Mitigating Strategies in Risk-Informed Decision Making NEI 16-08: Guidance for Optimizing the Use of Portable Equipment Guiderails: Comp Actions required for temp use of Portable Equipment- Including actions to restore portable equipment back to intended design function Use of portable equipment (DG) credited in a risk-informed emergency tech spec change- averted a forced unit shutdown of extended duration Some notable highlights of the attached information include: Palo Verde use of portable generators and FLEX Steam Generator (SG) Makeup Pump for risk reduction Shearon Harris EPRI TIP Award for use of FLEX Emergency Service Water (ESW) Pump to change the Allowed Outage Time (AOT) to replace an installed ESW Pump Catawba NRC finding reduction from Yellow to White utilizing FLEX portable equipment in the NRC Standardized Plant Analysis Risk (SPAR) model McGuire outage risk reduction improvement from Orange to Yellow using the pre-staged Medium Pressure FLEX Hale Pump for additional defense in depth 5

EBs Important to Emergency Preparedness EB16-34: Streamline Program Health Reporting (Blue- Implementation Date: June 2017) Reduces number of formal engineering programs that require health reports- without compromise to safety/reliability Streamlines program health monitoring and reporting processes- Enables Eng. to focus on most critical systems/equipment Establishes a graded approach to system monitoring and oversight- Programs classified as Tier 1 / Tier 2 / Tier 3 : Tier 1 Most complex requiring greatest oversight Promotes use of score cards, KPIs, etc. to monitor system health in lieu of detailed health report Guiderails: Program indicators must maintain a positive/acceptable trends Long-term asset management plans inlcudew required actions to preserve material condition and margin Some notable highlights of the attached information include: ? Palo Verde use of portable generators and FLEX Steam Generator (SG) Makeup Pump for risk reduction ? Shearon Harris EPRI TIP Award for use of FLEX Emergency Service Water (ESW) Pump to change the Allowed Outage Time (AOT) to replace an installed ESW Pump ? Catawba NRC finding reduction from Yellow to White utilizing FLEX portable equipment in the NRC Standardized Plant Analysis Risk (SPAR) model ? McGuire outage risk reduction improvement from Orange to Yellow using the pre-staged Medium Pressure FLEX Hale Pump for additional defense in depth 6

Key Efficiency Bulletins Under Development for 2017 / 2018 Work Management: Simplified Work Management Process (AP-928 rev5) Plant Operators Performing Limited Maint. Activities Efficient FME Control Processes Transform the Organization Oversight & Assessment: Industry Standard KPIs and Common Database Risk-Informed Internal Audits Extending Frequency of FFD Audits Alternate Emergency Plan Notification Methods 7

Key Efficiency Bulletins Under Development for 2017 / 2018 Training: Graded approach to ESP initial and continuing training program implementation Streamline Initial License Operator Training Programs Rad Protection: Weekly source checking of survey instruments Develop Industry-Standard RP Practices 10CFR50.75 documentation of low activity spills (rather than excavation/disposal) Use of ED as DLR for Permanent Station Employees 8

EB Implementation Challenges EB Implementation Impacting other Station Activities: - RFOs and Maintenance schedules - Regulatory Commitments - Resource Availability Some Organizational Reluctance to Change: - Weakness in change management, planning, organizational communication - Leadership/ownership challenges in driving EB implementation - Results: EBs not fully implemented Organizations revert back to former processes Soft savings (efficiencies) realized, but some stations unsure how to leverage the savings into staff reductions - To-date: primary savings realized by unfilled vacancies / OT reductions These issues concerns have been discussed at DNP Coordinator Meetings, INPO Plant Manager Working Meetings, and the DNP SC meetings by the industry CNOs CNOs / PMs agree: Utilities need to be more strategic in scheduling EB implementation activities along with other station activities EB implementation owners must be given clear roles / responsibilities Station leadership must support EB implmentnation owners and take primary role in communicating the purpose / benefit of Ebs with station employees 9

INPO’s Role: Delivering the Nuclear Promise Support the Industry in EB Development and Approval Processes Prevent/Monitor for Unintended Consequences 10

INPO’s Role: Delivering the Nuclear Promise Important Notes Regarding EB Implementation and INPO Plant Evaluations / Accreditation Teams Visits: INPO does not require the Industry to implement EBs INPO does not evaluate/measure industry progress in EB implementation INPO evaluates and measures industry performance strictly against the INPO PO&Cs identified in INPO 12-013 and ACAD 02-001 … … however, EB implementation shortfalls that contribute/result in performance declines may be noted in INPO plant evaluation or accreditation report products 11

INPO’s Role: Delivering the Nuclear Promise Prevention of Unintended Consequences: Identify potential safety and reliability risks associated with EBs Provide alternative initiatives that advance safety and reliability while supporting desired efficiency outcomes Add Guiderails – (actions and limitations) that target safety and reliability risk mitigation Identify and resolve conflicts with INPO guidance documents (some EBs require Guidance doc. and ACAD revisions before issuance) Collegial Reviews / Challenge of Draft EBs: focus on potential Tier 1 & 2 document conflicts and inclusion of appropriate guiderails 12

INPO’s Role: Delivering the Nuclear Promise Monitor for Unintended Consequences: Plant evaluation, peer reviews and ATV reports ICES events PIC trending PML Station Visits / Observations INPO Industry Meetings (e.g. INPO Plant Manager and Line Manager Working meetings) Industry DNP Coordinator meetings (quarterly) Expectation: Utilities also actively monitor and assess for EB implementation issues and share information/learnings with INPO and the industry 13

INPO’s Role: Delivering the Nuclear Promise Performance Related to EB implementation (Oct 2017): INPO has not identified / confirmed any unintended consequences related to EB implementation weaknesses A few plant evaluation / peer review reports reveal some EBs not implemented as planned, but none resulting consequential events: Several recent OR/LF AFIs reveal gaps in non-CAP methods for trending low-level issues Line management experiencing greater responsibility for CAP product development, resulting in some proficiency shortfalls INPO/Industry PI Orgs. to assess EB16-10: “Reduce Cumulative Impact of CAP Program” implementation as potential contributor to above performance issues (Dec 2017) Several Strengths in WM identified during recent plant evaluations related to EB Implementation Example: Strength WM.1 Turkey Point - Increased capacity and efficiency of the fix-it-now team has resulted in a significant reduction in boric acid leaks and allowed the other maintenance disciplines to improve emergency diesel generator maintenance windows and complete numerous aged Plant Health Committee priority work orders. As a result, the reliability of safety significant systems has improved. In addition, efficiencies were gained in work screening resulting in more work screened as minor maintenance, reducing the burden on maintenance resources. Relevant EBs: EBs 16-15a- Work screening process. 16-15b- Utilizing Minor Maintenance. 16-15c – Fin Team Efficiency CAP-001, Reducing Cumulative Impact From the Corrective Action Program 14

Future INPO DNP Support Sunset dedicated INPO DNP staff by EOY 2017 Retain one INPO DNP staff member though 1Q2018 transitional period Jan-Mar 2018 INPO Staff Member and INPO Tech. Depart. Managers: Perform EB reviews / safety assessments / establish guiderails Monitor KPIs, ICES, and Evaluation/Peer Review/ATV reports for unintended consequences Assist industry DNP Teams in coordinating EB communications (Webcasts) INPO SLT continue EB approvals INPO SLT and one INPO DNP staff member participate in DNP SC meetings INPO Discontinues scheduling and status support activities

Access to DNP Materials from Member’s Website 16

INPO’s Role: Delivering the Nuclear Promise 17

Questions?