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

2. 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

3. Efficiency Bulletins: Issued and Scheduled
63 EBs Issued to date (Feb 2016 – Oct 2017)
~35 additional EBs scheduled for development in 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

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

11. 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 and ACAD …
… however, EB implementation shortfalls that contribute/result in performance declines may be noted in INPO plant evaluation or accreditation report products 11

12. 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

13. 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

14. 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 b- Utilizing Minor Maintenance c – Fin Team Efficiency
CAP-001, Reducing Cumulative Impact From the Corrective Action Program 14

15. 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

16. Access to DNP Materials from Member’s Website16

17. INPO’s Role: Delivering the Nuclear Promise17

18. Questions?