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The Nuclear Energy Institute’s Regional Executive Nuclear

Workforce Meeting 2014

Table of Contents

1.0 Table of Contents 2.0 Agenda 3.0 Speaker Contact List 4.0 Welcome & Current Status of the Industry Slides 5.0 Assessing Work Force Risks Slides 6.0 New Work Force Related Performance Objectives & Criteria Slides 7.0 U.S. Energy Industry’s Work Force Planning Model Slides 8.0 Work Force Solutions and Best Practice Slides 9.0 Bringing it Together & Open Discussion Slides 10.0 Appendix of Examples, Contact Lists and Benchmarking Documents

10.1 NEI’s Major 2013 Workforce Survey Findings 10.2 CEWD Workforce Planning Assessment Tool 10.3 POC Revision Bases Summary 10.4 Energy Northwest’s Talent Management Strategy 10.5 CEWD Governance and Committee Membership 10.6 CEWD State Consortia Contact List 10.7 STP’s KT&R Process Document 10.8 TVA’s KT&R Action Plan Example 10.9 Duke’s KT&R Dashboard 10.10 NEI’s Retiree White Paper

Regional Executive Nuclear Workforce Meetings

VC Summer Jenkinsville, SC August 19, 2014

Agenda

TUESDAY, Aug. 19 General Session 9–2 p.m. Nuclear Operations Building 574 Stairway Road Jenkinsville, SC 20965 Sponsored by SCANA and the Nuclear Energy Institute Welcome & Current Status of the Industry 9–9:20 a.m. Elizabeth McAndrew-Benavides Senior Manager, Strategic Workforce Initiatives Nuclear Energy Institute

Dan Gatlin Vice President Nuclear Operations South Carolina Electric & Gas Company

Assessing Work Force Risks 9:20-9:45 a.m. Ann Randazzo Executive Director Center for Energy Workforce Development

Elizabeth McAndrew-Benavides Senior Manager, Strategic Workforce Initiatives Nuclear Energy Institute

New Work Force Related Performance Objectives & Criteria 9:45-10:15 a.m. Michelle O’Donnell Director, Human Resources Southern Nuclear

BREAK 10:15–10:30 a.m.

U.S. Energy Industry’s Work Force Planning Model 10:30-11 a.m. Randy Johnson Operational Readiness V.P. Vogtle 3&4 Southern Nuclear Ann Randazzo Executive Director Center for Energy Workforce Development Work Force Solutions and Best Practices Part 1 11 a.m.-12:45 p.m. Debra Hager Manager, Workforce Development Duke Energy Corporation Mike Bryce Vice President Human Resources Florida Power & Light Company Ann Randazzo Executive Director Center for Energy Workforce Development Elizabeth McAndrew-Benavides Senior Manager, Strategic Workforce Initiatives Nuclear Energy Institute Lunch 12:45–1:15 p.m. Bringing it Together & Open Discussion 1:15-1:45 p.m. Dan Gatlin Vice President Nuclear Operations South Carolina Electric & Gas Company Ron Jones Vice President New Nuclear Operations South Carolina Electric & Gas Company

2

Wrap Up 1:45-2 p.m. Dan Gatlin Vice President Nuclear Operations South Carolina Electric & Gas Company Optional New Nuclear Site Tour 2-4 p.m. Andy Barbee Director, Nuclear Training South Carolina Electric & Gas Company Adjournment

Speaker Contact List Andy Barbee Director, Nuclear Training South Carolina Electric & Gas Company [email protected] 803-345-4034 Mike Bryce Vice President Human Resources Florida Power & Light Company [email protected] 561-691-2376 Dan Gatlin Vice President Nuclear Operations South Carolina Electric & Gas Company [email protected] 803-345-4342 Debra Hager Manager, Workforce Development Duke Energy Corporation [email protected] 704-382-7650 Randy Johnson Operational Readiness V.P. Vogtle 3&4 Southern Nuclear [email protected] 706-848-7802 Ron Jones Vice President New Nuclear Operations South Carolina Electric & Gas Company [email protected] 803-941-9990 Elizabeth McAndrew-Benavides Senior Manager, Strategic Workforce Initiatives Nuclear Energy Institute [email protected] 202-739-8143

Michelle O’Donnell Director, Human Resources Southern Nuclear [email protected] 205-992-6487 Ann Randazzo Executive Director Center for Energy Workforce Development [email protected] 703-237-1094

mailto:[email protected]









Regional Executive Nuclear Workforce Meetings

Dan Gatlin, SCANARandy Edington, APSMike Pacillio, ExelonJohn Ventosa, Entergy

Welcome & Safety Messages

Logistics

• Meeting Schedule

• Tour

• Restrooms

Safety

• Evacuation Routes

• Emergency Equipment

Industry Status

• Plant performance

• Market issues

• Fukushima response

• New plant construction

• 2014 and beyond

Nuclear Industry Employment Distribution by Age

0%

5%

10%

15%

20%

25%

30%

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67

Empl

oyee

s

Age Range

200320052007200920112013

Source: 2013 NEI Pipeline Survey Results, Contractors and vendors not included

Total Employment:

2013–62,170

2011 - 59,700

2009 - 57,200

2007 - 55,900

2005 - 57,900

2003 - 58,400

Briefing Goals

• Transfer the strategic vision of how the many strategic workforce efforts are meant to be integrated and implemented.

Assessing Work Force Risks

Ann Randazzo, CEWD

Elizabeth McAndrew‐Benavides, NEI

How Ready is Your Work Force?

Are you ready today? Will you be ready in 5 years?

Is your company aligned? Would your colleagues agree with you?

What is Your Assessment?

Please use the next 10 minutes to complete this

Workforce Planning Assessment for your

company.

Assessment Results

4

Score Results Comments

0 to 33Program not effective or in place

Develop recovery plan

34 to 43Program is in the beginning stages of development

Review program actions and check to ensure initiatives are meeting future needs

44 to 53Program is maturing and meets a majority of objectives

Continue to check and adjust as needed

54 to 64Program is fully matured and is meeting most if not all WFP objectives

Continue to benchmark and share lessons learned with the industry

No Extent

Little Extent

Some Extent

Great Extent

Very Great Extent

0 1 2 3 4

Business Planning – Assessing Readiness

5

1. Does the organization have a business plan, or leadership model, and is workforce planning part of that document?

2. Is your workforce planning integrated with business operations/finance organization?

3. Does the organization’s strategic focus support continuous workforce planning? Is it in a procedure?

4. Are the roles for formulating and implementing workforce planning in the organization clearly understood?

No Extent

Little Extent

Some Extent

Great Extent

Very Great Extent

0 1 2 3 4

Workforce Analytics– Assessing Readiness

6

1. Does the organization have a dashboard or information that focuses on projected attrition by organization and/or critical jobs?

2. Does your organization have a 5 year hiring plan?

3. Are the projected staffing needs instilled in the line organization at all stations? Does the line own the data?

4. Does the organization implement a comprehensive knowledge risk assessment process and is it linked with their workforce planning analytics?

No Extent

Little Extent

Some Extent

Great Extent

Very Great Extent

0 1 2 3 4

Workforce Development– Assessing Readiness

7

1. Does your organization have a well defined and implemented pipeline program?

2. Does your organization have a succession planning program for key leaders and is it used to fill future talent needs?

3. Does your organization have programs to develop new talent in a timely manner?

4. Does your organization have a robust knowledge transfer program in place?

No Extent

Little Extent

Some Extent

Great Extent

Very Great Extent

0 1 2 3 4

Execution & Metrics– Assessing Readiness

8

1. Does the organization have KPI’s that measure over all program results?

2. Are actions taken to check and adjust program results arising from the KPI’s?

3. Are the KPI’s regularly shared within the line organization?

4. Does your organization measure employee performance through a systematic process? Are actions taken based on poor performance?

No Extent

Little Extent

Some Extent

Great Extent

Very Great Extent

0 1 2 3 4

Leadership Fundamentals and INPO PO&CsCassie Burgio, Wolf Creek

Carol Moody, PPL SusquehannaMichelle O'Donnell, Southern Nuclear

Nicole Reilly, PSEG

Performance Objectives & Criteria

Document was updated in 2012. Changes included:

- Incorporating lessons learned from 2005‐2012

- Adding definition and criteria for organizational shortfalls

- Defining roles for managers, leaders, senior leaders, ect.

Performance Objective Sections

Foundations

Functional Areas

Cross‐Functional Areas

Corporate Areas

OR‐2 Manager Fundamentals

Manager Fundamentals

Control & Direct

Plan, Organize,

and Coordinate

Staff

OR‐4 Leader and Manager Development

Developing future leaders is your job!

LF.1 Leadership

Leadership

Vision & Values

Teamwork AccountabilityEmployee

Engagement

Developing Managers & Leaders

U.S. Energy Industry’s Work Force Planning Model

Ann Randazzo, CEWDRandy Johnson, Southern Nuclear

John Simon, PG&EJohn Wheeler, Entergy

U.S. Utility Age Distribution Total Company

0

5

10

15

20

25

18‐22 23‐27 28‐32 33‐37 38‐42 43‐47 48‐52 53‐57 58‐62 63‐67 67+

% of Em

ployees

Age

2006 2007 2010 2012

Nuclear Industry Employment Distribution by Age

0%

5%

10%

15%

20%

25%

30%

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67

Empl

oyee

s

Age Range

2003

2005

2007

2009

2011

2013

Source: 2013 NEI Pipeline Survey Results, Contractors and vendors not included

Total Employment:

2013–62,170

2011 - 59,700

2009 - 57,200

2007 - 55,900

2005 - 57,900

2003 - 58,400

Industry Game Changers

4

External• Grid Modernization• Generation Mix / Carbon Management • New Build• Regulation / Policy changes

Internal• Aging workforce• Mergers / Acquisitions• Significant Organization Decision • Adoption of New Technology

CompanyStrategicDirection

Essential Elements of Workforce Planning

Business Planning – Quadrant 1

Company Actions

• Understand the game changers

• Determine the short and long term impacts on the workforce.

• Conduct an assessment of readiness.

6

Workforce Analytics– Quadrant 2

7

Company Actions

• Understand HR Data and determine if additional data is needed.

• Understand the lead time for hiring.

• Conduct an attrition assessment.

• Perform the data analysis.

• Prepare a five‐year hiring plan.

Workforce Development– Quadrant 3

Company Actions

• Identify the educational institutions your company is partnered with.

• Develop a recruitment strategy.

• Develop an internal pipeline of candidates.

• Develop a process for capturing knowledge.

8

Execution & Metrics – Quadrant 4

Company Actions

• Measure progress toward goal achievement.

• Implement the CEWD Metrics tool and dashboard.

9

Key Messages

• Utilities must address workforce planning holistically.

• There are many programs and processes that are apart of an organization’s workforce model.

Work Force Solutions and Best Practices

1

Talent Management

Steve Lorence, Energy Northwest

Mike Bryce, NextEra Energy

Robin Hester, Dominion

Carol Moody, PPL Susquehanna

2

Why is Talent Management Important?

3

Industry Vs. Company Model

CEWD’s Elements of a Strategic Workforce Plan

Example of a Company Specific Model

4

Succession Planning

Steve Lorence, Energy Northwest

Mike Bryce, NextEra Energy

Robin Hester, Dominion

Carol Moody, PPL Susquehanna

5

Key Elements of Succession Planning

6

Program Breadth

Candidate Selection

Evaluations

Closing GAPS

Measure & Adjust

Timing & Frequency

Program Breadth

Element One in most processes:

• Identifies which positions are included in the program.

• Documents the requirements for those positions.

7

Program Breadth

Succession plans should include critical positions in addition to leadership positions.

Candidate Selection

Element Two in most processes:

• Identifies employees to put on the plan based on education, experience and interest.

• Identifies where the organization doesn’t have bench strength.

8

Candidate Selection

High Potentials are employees not yet on the succession plan.

Evaluation

Element Three in most processes:

• Evaluates the readiness of a succession planning candidate to fill a position.

Example Aspects

- 9 Block Evaluation

- Performance Data

- Recent Achievements

- Willingness to Relocate

9

Tangible evidence is used to evaluate a candidate’s readiness.

Closing Gaps

Element Four in most processes:

• Create action plans. E.g.

- Assign a mentor.

- Rotate employees for development.

- Schedule specialized training.

10

Closing Gaps

Employees are responsible for their development. The company has to give them the resources .

Measure & Adjust

Element Five in most processes:

• Measures the effectiveness of the program.- # of positions filled by internal candidates

- Progression/retention of high potentials

- Depth and diversity of bench strength

• Adjusts the program as needed.

11

Timing & Frequency

Element Six in most processes:

• Implements a repetitive schedule to update and adjust the succession plan.

12

Timing & Frequency

Lesson Learned: Employee Ownership

13

Do your employees own their developmentlike they own safety?

Role of Site Leader: Succession Planning

14

• Ensuring employee ownership

• Managing the process

• Integration with other plant processes

Knowledge Risk Assessments

Debra Hager, Duke Energy

Julie Sickle, Exelon

Nelson Gosnell, Tennessee Valley Authority

Clarence Fenner, STP Nuclear Operating Company

1

Key Elements of a KT&R Process

Identify RisksAddress the

Risks

Implement the Plan

Process Improvement

2

Identify Risks

Element One in most processes:

• Identifies the groups, jobs functions and individuals to assess

• Identifies critical, at‐risk knowledge these groups, jobs and individuals contain

• Applies a ranking process to identify which critical, at‐risk knowledge should be retained now and which can wait until later

3

Identify Risks

Addressing the Risks

Element Two in most processes:

• Develops action plans

• Aligns to hiring strategies and succession plans

• Identifies other plant processes needed to support the action plan

4

Address the Risks

Good action plans note the owner versus the facilitator for each action.

Implementing the Plan

Element Three in most processes:

• Implements the Action Plans

• Utilizes other plant processes needed to support the action plan (talent management, training, infrequent evolutions)

5

Implement the Plan

Process Improvement

Element Four in most processes:

• Monitors action plan completion

• Incorporates learns on process strengths and weaknesses

• Pushes the site to repeat the KT&R process on regular intervals

6

Process Improvement

Lesson Learned: Identifying the Risk

7

Operations Emergency Preparedness Engineering Programs

Where do most of the potential knowledge loss risks reside?

Role of Site Leader:Knowledge Risk Assessment Process

• Ensuring line ownership

• Managing risks

• Integration with other plant processes

8

Nuclear Uniform Curriculum Program

John Wheeler, Entergy

Debra Hager, Duke Energy

Tricia Joyner, Exelon

Clarence Fenner, STP Nuclear Operating Company

1

NUCP Goals

• Establish an industry guideline for associate degree programs

- Define the expected knowledge level of graduates to reduce initial training time

- Identify common learning objectives and create one curriculum drawn from the highest standards

- Ensure consistency among the educational programs

• Strategically invest in educational programs so that program content, size and location supports industry needs

• Leverage industry resources to reduce the time it take to educate and train new employees while reducing the cost

Goals agreed upon by NSIAC in 2007.

NUCP Process

Develop Uniform Program

Size Program & Identify Partners

Align Curriculum

Conduct Oversight

Hire Graduates

Align Training

Nuclear Uniform Curriculum ProgramAugust 1, 2014

NationalCoordinatorsINPO & NEI

MidwestLakeland• Dakota • Lake Michigan• Linn State• Monroe County• St. Cloud

NortheastSouthern Maryland• Excelsior• Onondaga• Salem• Three Rivers• Westchester

NorthwestIdaho State / ESTEC• Bismarck State• Columbia Basin• Metropolitan• Southeast

SoutheastIndian River• Augusta Tech • Aiken Tech• Chattanooga State• Miami Dade• Midlands Tech• Orangeburg‐Calhoun

• Spartanburg• Wallace

SouthwestEstrella Mountain• Brazosport• New Mexico Junior• Texas State Tech• Wharton County

NUCP Challenge Boards Statusas of August 1, 2014

6 65

8

6

3

54

6 6

0

1

2

3

4

5

6

7

8

9

NortheastRegion

NorthwestRegion

SouthwestRegion

SoutheastRegion

Midwest Region

Schools in Region Completed Challenge Board

Role of Site Leader:Nuclear Uniform Curriculum Program

• Finish Your Challenge Boards

• Align Your Programs

• Focus on Sustainability

6

Center for Energy Workforce DevelopmentAnn Randazzo, CEWD

1

Vision: Where the industry speaks with one voice for a single purpose –

Companies adequately staffed

with a diverse workforce

with the right skills

to safely keep the energy flowing

Mission: Build the alliances, processes and toolsto develop tomorrow’s energy workforce.

CEWD Vision and Mission

2

CEWD Mission Build the alliances, processes, and tools to develop tomorrow’s energy workforce

Career Awareness

Education

Workforce Planning and

Metrics

Structure and Support

Industry Solutions –Regional

Implementation

MilitaryYouth WomenTransitioning

AdultsLow Income Young Adults

Utility Technician

Lineworker EngineersPlant

OperatorsNuclear

Competency Based Education

Troops to Energy Jobs Website

5

Step by step Roadmap for Veterans

Virtual Coach at any point in process

Jobs Microsite for all CEWD member company positions with exclusive occupation translation

www.troopstoenergyjobs.com

Energy Competency Tier Model for Skilled Technician Positions in Energy Efficiency,Energy Generation and Energy Transmission and Distribution

Stackable Credentials

8

7

6

5

4

3

2

1

Tier 6–8 Job Specific Skills/Credentials• Associate Degree• Boot Camp / Apprenticeship for College Credit

• Accelerated Associate Degree

Tier 4–5 Industry Fundamentals• Energy Industry Fundamentals Certificate

Tier 1–3 Basic Training• Energy Industry Employability Skills Certificate

• National Career Readiness Certificate

Occupation‐Specific Requirements

Occupation‐Specific Technical

Occupation‐Specific Knowledge Areas

Industry‐Specific Technical

Industry‐Wide Technical

Workplace Requirements

Academic Requirements

Personal Effectiveness

CO KY

State Energy Workforce Consortia

Regional Consortium Existing Consortium Planned Consortium

WA

CA

MN

TX

TN

MS

LA

IN

MO

OH

MI

NJ

CT

MD

AL

VA

GA

FL

NC

SC

PA

OR

AZ

IL

NM

KS

ID

DE

UT

WYSD

DC

IA

WI NY

NE

For more information, contact:

Ann RandazzoExecutive Director

Center for Energy Workforce [email protected]

www.cewd.org

People Health Committee


David Heler, Palo Verde

1

Palo Verde Developed the Concept ofthe People Health Committee in 2011

2

High Level Reviewof People KPI’s

Alignment AroundPeople Initiatives

Monitor PeoplePrograms

Assessment ofOrganizational Impact

on PeopleModeled after the Plant Health Committee

Primary Functions of PHC Align the people programs and initiatives to the Organizations strategic

priorities

Set strategy and direction for the people section of the plants business plans and operating model that focuses on current and future people needs for the organization

Review program results and provide guidance on the people programs

Provide senior management oversight and direction on issues, trends, and changes affecting people

Provide alignment and integration among the leadership team on programs and initiatives affecting people.

Provide the organization with a sustainable process to ensure strategic workforce planning and talent management initiatives are achieving their desired results

Jan Feb

Mar

Apr

May

JunJul

Aug

Sep

Oct

Nov

Dec

• Year End Metrics• WFP Projections• Update on Staffing Plans• Succession Planning (Year end results)

• Goal Discussion

• Performance Mgmt• KT&R Update• Benefits, i.e. STD/LTD/WC• Metrics Update• Pipeline Program Update• Selection Process Update• Employee Engagement Plan Update

• Year End ER & Labor Update

• Diversity Update/ Results

• Metrics Update• Job Rotation – year end results

• Compensation• Mentoring Nominations• Mid‐Year Perf MgmtUpdate

• Metrics Update• Status of Staffing Plans

Examples of Quarterly Topics for PHC

4

Example of People Health Committee Core Committee Members

5

Executive Vice President Nuclear and Chief Nuclear Officer

PHC Chairperson ‐ Senior Vice President, Site Operations

Vice President, Support

Vice President, Nuclear Engineering

General Plant Manager

Director/Manager, Human Resources

Director/Manager, Nuclear Assurance or Oversight

Director/Manager, Nuclear Training

Additional Directors and Key Managers as determined by the PHC Chairperson

6

Program Key Performance Indicators (example data)

Examples of PHC KPI’s

Examples of PHC KPI’s

7

Program Key Performance Indicators (example data)

51% 40% 20% 45 %

Add Rate – Pipeline Hires

Percent of new hires of all hires for pipeline & intern programs (annualized based on monthly hires)Source: Corp Leadership CouncilRef: Policy Guide 0307‐01

Add Rate – Veterans Hires

Percent of veterans hires to total hires (annualized based on monthly hires)

Source: Human Capital MgmtRef: Policy Guide 0307‐01

Add Rate – Female & Diversity Hires

Percent of female and diversity hires to total hires (annualized based on monthly hires)Source: Human Capital MgmtRef: Policy Guide 0307‐01

KT&R Assessments and Action Plans Completed

Number of KT&R assessments and action plans completed in establish time frame

Source: HR Tier MetricsRef: Policy Guide 0302‐01

Source: HR Tier MetricsRef: PV HR LTV Guidelies

Green = > 20% White = 15% to 20%Yellow = 10% to 15%Red = < 10%




Success Strategies

CEWD’s Elements of a Strategic Workforce Plan

8

• Institutionalize your processes

• Create guides or procedures to ensure sustainability

• Have objective evidence that your programs are working

• KPI’s – what are you measuring

• Benchmark others and choose a process that works for your organization

• Are you getting the results are expecting

Bringing it Together: A Utility Case Study

Dan Gatlin, SCANA

Ron Jones, SCANA

Open Discussion

Dan Gatlin, SCANA


Appendix of Examples, Contact Lists and Benchmarking Documents

Major Findings:

2013 Nuclear Workforce Pipeline and Nuclear Uniform Curriculum Program Surveys

Overview

NEI’s 2013 Nuclear Workforce Pipeline survey is the sixth in a series of biennial assessments

the industry conducts to identify nationwide demographic and hiring trends in the nuclear

workforce. NEI also conducted its fourth installment of the Nuclear Uniform Curriculum

Program survey this year.

Background

Tremendous growth in the nuclear sector during the 1970s and 1980s created a secure and

qualified workforce. Combined public and private sector growth drew former military personnel,

construction workers and university graduates into nuclear careers.

Nuclear-related employment began to decline in the early 1990s, however. Utilities, contractors

and vendors began consolidating or shifting out of nuclear businesses, and military and

government programs shrank. Previous surveys indicated that the industry should expect

significant attrition as this well-trained, experienced workforce reached retirement age.

A significant number of nuclear workers have retired in the past five years, but not as many as

originally expected. When many potential retirees approach retirement, they are choosing to

work longer. Others are retiring and then deciding to return to work at contractors or with new

employers, thus offsetting the number of vacancies required to be filled by new hires.

Participation

One hundred percent of nuclear utilities, the three major nuclear steam system supply companies

and other nuclear suppliers provided detailed information about their workforces as part of this

survey. NEI also received a 100-percent response from the community colleges on the Nuclear

Uniform Curriculum Program survey.

Results

The following pages document the major findings from that survey. Results from this survey will

be used to shape workforce planning programs and policies.

Questions

For additional information you can contact Elizabeth McAndrew-Benavides at [email protected] or

202-739-8143.

Major Findings:


2

Industry has expended significant effort preparing

to replace the aging workforce. Workforce

development efforts have been successful as

industry has been able to reinforce the critical

education and training programs that feed the

nuclear energy industry. The U.S. continues to

have the most robust nuclear education

infrastructure in the world with 30+ universities,

35 community colleges, partnership with the U.S.

Navy and a nuclear mechanic apprenticeship

program. These programs all educate nuclear

knowledgeable workers that are available to the

commercial nuclear energy industry.

NEI’s latest Workforce Pipeline Survey shows that the workforce continues to age and many

employees have delayed retirement as industry has maintained a steady 38 percent potential

retirement rate since 2009.

Historically, many employees

would retire when first eligible,

typically at 55 years old and 30

years of employment. Employees

are now likely to wait until they

are at least 60, citing physical

exhaustion and sufficient personal

retirement savings as the reasons

they choose to retire. This can be

seen by noting that, in 2003, the

largest cohorts of industry

employees were between 43 and

52 years of age. Today, the largest

cohorts are spanning between 48

and 62 years of age.

The U.S. commercial nuclear energy industry’s age distribution is very clearly bimodal: the

industry has a significant number of experienced and young professionals and far fewer

employees in the mid-career age groups of 33 to 47. With the young generation receiving fewer

benefits than its predecessors to incentivize them to be loyal, retention of mid-career

professionals will continue to be an area of concern as the economy rebounds.

Even with all of the external workforce development efforts, reinforcing the commercial nuclear

workforce has had mixed results. The 2013 survey shows that industry has hired a significant

number of new employees into operations positions, as seen in the numbers of personnel in the

23-37 cohorts. This was also seen in the 2011 survey, suggesting that the success of the industry

to reinforce the operations pipeline has been repeated.

Nuclear Generation 5-Year Attrition

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67 67+

Emp

loye

es

Age

Non Retirement Attrition (10%)

Potential Retirees (38%)

Retained (52%)

Nuclear Education in the United States

Nuclear Engineering and Health

Physics Programs at 30+ Universities

Nuclear Uniform Curriculum Program

at 35 Community Colleges

Nuclear Mechanic Apprenticeship

Program at Six Labor Organizations

Navy Agreement of Understanding

Programs with 35+ Participants

Major Findings:


3

Similar success can be

noted in the engineering

pipeline. Industry has been

consistently hiring young

engineers, as the data in the

23-32 cohorts show. But

unlike operations, there do

not appear to be enough

mid-career engineers to

offset the number of

pending retirees. Mid-

career engineers are needed

to fill first- and second-

level management positions

and other critical,

individual contributor

nuclear specialist positions.

As 33-47-year-old

engineers transfer to the

other departments to fill

technical and project

management positions,

their absence will create

hardships in the industry.

The lack of mid-career

professionals available to

fill vacancies left by

retirees in engineering,

radiation protection and

maintenance continues to

be a concern. Without

enough mid-career

professionals, the industry

may find it difficult to fill

leadership positions

vacated by retirees. This

will require expedited

development programs for

young professionals and

creation of effective

methods of recruiting and

training mid-career

professionals from other

industries to fill vacant supervisory and leadership positions.

Industry Employment Distribution by Age

0%

5%

10%

15%

20%

25%

30%

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67

Em

plo

ye

es

Age Range

2003

2005

2007

2009

2011

2013

Operations Distribution by Age

0%

5%

10%

15%

20%

25%

30%

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67 67+

Emp

loye

es

Age Range

200320052007200920112013

Engineering Distribution by Age

0%

5%

10%

15%

20%

25%

30%

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67 67+

Emp

loye

es

Age Range

200320052007200920112013

Major Findings:


4

The 2013 survey results

show that industry has not

yet addressed the need to

develop replacement

maintenance and radiation

protection workers at the

utilities. As seen by

reviewing the hiring within

the 18 to 37 year-old cohorts

on both the maintenance and

radiation protection graphs.

Industry has done little

hiring in these departments,

and incumbent workers are

the oldest in the industry.

The highest population age

group in radiation protection

is the 52-57 cohort.

Many utilities have decided

to rely on contractors to fill

radiation protection and

maintenance needs in the

future. This strategy has

proven to be successful in

the short term as nuclear

vendors have been able to

augment staff for outages

and special projects, but this

strategy is unlikely to be

sustainable.

Shortages of fully qualified

radiation protection

technicians have already

been identified during

outages. Although utilities

have decided not to develop

junior staff as full-time

hires, they are also limiting

the number of junior staff

their suppliers are allowed to bring onsite. Independent of employer, junior staff must meet the

same training and education requirements and therefore need opportunities for nuclear plant

experience in order to become fully qualified. Utilities cannot expect the nation to continue to

Maintenance/Craft Distribution by Age

0%

5%

10%

15%

20%

25%

30%

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67 67+

Empl

oyee

s

Age Range

200320052007200920112013

Radiation Protection Distribution by Age

0%

5%

10%

15%

20%

25%

30%

35%

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67 67+

Emp

loye

es

Age Range

200320052007200920112013

Supplier Employment Distribution by Age

0%

5%

10%

15%

20%

25%

18-22 23-27 28-32 33-37 38-42 43-47 48-52 53-57 58-62 63-67 67+

Emp

loye

es

Age Range

200320052007200920112013

Major Findings:


5

have qualified and available nuclear workforce if they are not willing to participate in the

development of that workforce.

Historically, nuclear suppliers

and utilities have had different

hiring trends because the

nuclear suppliers have a more

distributed existing workforce.

This relatively flat employment

distribution at the nuclear

suppliers means the aging

workforce will not cause them

as much difficulty maintaining

their daily operations.

Utilities began to add staffing

margin in 2007 and 2008 to

prepare for the aging workforce.

Although the nuclear suppliers

did not need to add staffing

margin, in 2009 they did hire

thousands of new employees to

prepare for new domestic and

international nuclear

construction projects.

Total industry attrition has

continued to increase. Over

5,200 people left the industry in

2012. Most notably, utility attrition represented 6.7 percent of the population this year, compared

to 2009 when it was just 3.6 percent. Although the attrition values have increased steadily, the

industry’s hiring rates have not followed the same trend.

In 2012, the industry saw hiring dip below total attrition rates for the first time in seven years.

The companies that added staffing margin in 2007 and 2008 are now better prepared to manage

their workloads with retirements beginning to increase, but this is not true for every organization.

The little staffing margin from 2007 and 2008 is not sufficient to offset the pending retirements

across the industry.

Many nuclear organizations are now feeling the full effects of the economic downturn and are

looking for mechanisms to control cost to weather the financial uncertainty the industry faces. If

it continues, this trend will add additional stress to the mid-career nuclear professionals as

companies depart from one-for-one replacement hiring and into a reduction in staff caused by

natural attrition.

Total Attrition & Total Hires all reported values

Total Attrition & Total Hires Utilities

Major Findings:


6

In 2007, the U.S. had only five

community colleges with

nuclear technology programs.

The industry has helped to

reconstitute this pipeline and the

Nuclear Uniform Curriculum

Program (NUCP) now has 35

academic partners, over 1,500

students enrolled and is

producing nearly 500 graduates

a year. The NUCP has become

the flagship pipeline program

for the industry. The U.S.

industry is now in a good

position to source talent, unlike

in previous years.

The goal of the NUCP is to

create a pipeline of entry-level

workers who have all received a

common level of education, are

transferable to any industry

member and come from a

nationally organized system that

is sized appropriately to meet

industry’s needs for graduates.

The industry developed and has

implemented a three-step

process to meet this goal.

The first step of the process is to

align the school’s curriculum to

the industry-recognized learning

outcomes. These are described

in ACAD 08-006, and 33 of the

schools have completed this

step. These same 33 schools

have signed an Agreement of

Understanding with their

industry partner that outlines the

roles and responsibilities of the industry and academic partners, including the industry partner’s

robust oversight requirements. Twenty-one of the academic institutions have completed the last

step of the process, which is to complete a challenge board which allows the partnerships to issue

certificates in addition to a student's associate’s degree.

NUCP Membership

36

31

13

2

3836

33

7

3735 35

16

3533 33

21

0

5

10

15

20

25

30

35

40

Schools in Program Completed GAPAnalysis

Completed AOUs Issuing Certificates#

of

Sch

oo

ls

2010201120122013

NUCP Certificates

362

16 13 11

387

13281 69

492

259

172

90

0

100

200

300

400

500

600

Total Graduates Graduated fromEligible Schools

Graduates withCertificates

FoundEmployment with

Certificate

2010

2011

2012

NUCP Employment Metrics

235 229 231

59110

6

10

1924

19

51

127

70

51

0

50

100

150

200

250

300

350

400

450

500

2010 2011 2012

College Did Not Track

Unemployeed

Student Didn't Respond

Matriculated to a 4-YearProgram

Found Non-TechnicalEmployment

Found Non-Nuclear TechnicalEmployment

Found Nuclear Employment

Total Graduates = 387



Major Findings:


7

The 2013 survey results show that the number of education and training programs is about right,

and that additional programs are not necessary at this time. Current programs will need to be

maintained, but development efforts can be tapered off as the last of the new academic programs

begins to graduate students.

The one area of concern identified from the 2013 NUCP survey results has to do with the

number of graduates with certificates who find employment. The certificate process was

designed to allow students advance placement into utility initial training programs, thus allowing

industry to streamline initial training programs by taking full credit for the education students

receive. NEI expected that more of the available certificate recipients would be finding

employment, by this point.

This issue will be investigated further during two NUCP evaluations planned for 2013. INPO is

leading an ACAD 08-006 self-assessment. ACAD 08-006 outlines the NUCP program learning

objectives that will eventually align to accredited initial training programs. INPO will collect

information on which utilities are hiring NUCP certificate recipients preferentially and how

many are aligning initial training to take full credit for the students’ education.

NEI will complete a program effectiveness evaluation in the second half of 2013. This evaluation

will focus on assessing the results of the program at achieving the three original goals of the

program.

Workforce Planning Assessment Tool Rev 2

1. Does the organization have a business plan, or leadership model, and is workforce planning part of that document?

2. Is your workforce planning integrated with business operations/finance organization?

3. Does the organization strategic focus support continuous workforce planning? Is it in a procedure?

4. Are the roles for formulating and implementing workforce planning in the organization clearly understood?

1. Does the organization have a dashboard or information that focuses on projected attrition by organization and/or critical jobs?

2. Does your organization have a 5 year hiring plan?

3. Are the projected staffing needs instilled in the line organization? Does the line own the data?

4. Has the organization implemented a comprehensive knowledge risk assessment process and is it linked with their workforce planning analytics?

1. Does your organization have a well defined and implemented pipeline program?

2. Does your organization have a succession planning program for key leaders and is it used to fill future talent needs?

3. Does your organization have programs to develop new talent in a timely manner?

4. Does your organization have a robust knowledge transfer program in place?

1. Does the organization have KPI’s that measure overall program results?

2. Are actions taken to check and adjust program results arising from the KPI’s?

3. Are the KPI’s regularly shared within the line organization?

4. Does your organization measure employee performance through a systematic process? Are actions taken based on poor performance?

No Extent

Little Extent

Some Extent

Great Extent

Very Great

Extent

0 1 2 3 4

December 2012

Change Bases Summary for INPO 12-013,

Performance Objectives and Criteria

General Comments

The 2012 version of the INPO Performance Objectives and Criteria (PO&C) is a comprehensive update to the 2005 version of the document, and includes changes in industry practices and standards, as well as lessons learned from operating experience. The document was developed with significant U.S. and international industry input, and as a result reflects the global standard for nuclear excellence.

The Foreword in the PO&C describes the purpose and structure of the document, key

considerations used in revising the content, and a few definitions of terms used throughout. The Foundations section is a new addition and contains two performance objectives

that should be reflected in the behaviors of all nuclear workers, regardless of their positions in the organization. These objectives cover attributes of a nuclear professional and also describe leadership behaviors.

The functional, cross-functional, and corporate performance objectives are similar in

structure to the 2005 version. Some new performance objectives have been added because of wanting to differentiate topics previously included together in one objective. A few other performance objectives have been added based on area needing stronger emphasis based on industry changes. Throughout the document, criteria have been clarified or added to better define standards of excellence.

This revision incorporates changes and lessons learned in our industry since 2005,

including the following:

Preliminary lessons from the nuclear accident at the Fukushima Daiichi Nuclear Power Station

Concepts from SOER 10-2, Engaged, Thinking Organizations

The industry initiative to clarify and reinforce fundamentals

INPO 12-012, Traits of a Healthy Nuclear Safety Culture

Principles for Operational Focus, Technical Conscience, Performance Improvement, and Corporate Governance and Oversight

Lessons learned from significant operating experience

December 2012

INPO 12-013, PO&C Revision Bases Summary

2

Index

Section Page

Nuclear Professionals, Leadership, Nuclear Safety Culture,

Organizational Effectiveness, Human Performance 3

Operations and Operational Focus 10

Maintenance, Work Management, Fueling Activities, Project Management 16

Chemistry 19

Equipment Reliability 22

Engineering and Configuration Management 35

Radiological Safety, Radiological Protection, Industrial Safety 43

Performance Improvement, Operating Experience, Training 49

Fire Protection 53

Emergency Preparedness 54

Corporate Areas 62

December 2012 INPO 12-013, PO&C Revision Bases Summary

3

PO&C Revision Bases Summary – Nuclear Professionals, Leadership, Nuclear

Safety Culture, Organizational Effectiveness, Human Performance

Objective & Criteria Global Changes

Basis for changes

The Nuclear Professionals, Leadership, Safety Culture, OR and HU Performance Objectives were developed based on incorporating key elements of several documents and a desire to provide more distinction between these concepts and performance objectives.

The following documents were primarily considered:

Leadership Fundamentals – This industry-developed document covers most aspects of organizational effectiveness and leadership. It was written very broadly, so we separated elements of the document into the proposed three OR Objectives.

Principles for Strong Governance and Oversight of Nuclear Power Organizations – this was used particularly in the Objective OR. 5, Independent Oversight

Current 2005 PO&C – the current criteria were determined to be comprehensive, so we are not making significant changes to individual criterion. However, the performance objective that the criterion is tied to have changed some. OR.2 of the original PO&Cs was split to provide more distinction and to align better with the WANO PO&Cs.

Current 2005 WANO PO&C – based on WANO, we have titled Safety Culture “SC”, Human Performance “HU”, and Industrial Safety “IS”. Also, OR.3 is titled similar to OR.1 of the WANO PO&Cs and addresses the organizational structure. By using SC, HU, and IS, instead of OR, it makes it clearer that these are cross functional and are applicable in each functional area.

SOER 10-02 – this was integrated into each of the objectives using “engage, thinking” and incorporating the key elements of the SOER. Each of the recommendations was addressed in OR, OF, OE, PI, or TR PO&Cs. This institutionalizes the SOER.

SOER 02-04 – the nuclear safety culture objective incorporates the concepts of this SOER. Also, added new criteria in the Performance Improvement PO&C to capture the need to keep a running list of abnormal conditions or indications that cannot be readily explained.

Principles documents for Maintaining an Effective Technical Conscience and for Strong Plant Operational Focus


4

Excellence in Integrated Risk Management document – the types and methods for assessing and managing risk from this new document were included in OR.3.

The bubble chart of Leadership Effectiveness developed by INPO’s Assistance division was compared to the draft PO&Cs to ensure elements were addressed.

Clarification of Definitions: LEADER – An individual who inspires, coaches, and influences people to accomplish organizational goals while adhering to core values. A leader intervenes, when appropriate, to shape behaviors, attitudes, and perceptions and motivates others to pursue actions, focus thinking, shape decisions, actively support change, and strive for excellence. MANAGER – An individual assigned to a managerial or supervisory position. Managers control, direct, plan, organize, coordinate, and staff the organization to achieve safe, reliable station operations, event-free outage performance, successful project execution, and effective emergency response. They monitor performance and adjust programs and processes as necessary to achieve excellence. SENIOR LEADERS / SENIOR MANAGERS – Senior leaders and senior managers can be one and the same team but have different functions as defined below.

SENIOR LEADERS – Personnel comprising the senior site executive(s), plant manager, and their direct reports who act in a leadership role to inspire, coach, and influence people to accomplish organizational goals and pursue excellence. Senior leaders work to establish the vision, values, strategies, and culture that support safe, reliable station operations, event-free outages, and effective emergency response. They establish and reinforce standards of excellence based on industry top performance, and intervene at early signs of performance decline. SENIOR MANAGERS – Personnel comprising the senior site executive(s), plant manager, and their direct reports who are responsible for execution of business activities. These activities include but are not limited to setting priorities, planning, organizing, directing, resourcing, training, monitoring performance, and adjusting processes to achieve excellence.


5

SUPERVISOR – An individual assigned to provide the first-line direction of workers, individual contributors, and engineers, and who is considered a member of the plant management team. Supervisors fulfill their management role with respect to day-to-day work activities and also act in a leadership role by intervening and coaching to influence behaviors. LINE – the organizational structure of activities with self-contained departments that contribute directly to the

organization's outputAuthority travels downward from the top and accountability upward from the bottom along the chain of command, and each department manager has control over the department's affairs and employees. MANAGEMENT SYSTEMS – the programs and

processesincluding but not limited to work management, corrective action, succession planning, system health, and

observations programsthat support achievement of the organization’s mission, vision, and goals

Leadership

Criteria Specific Changes What Changed and Why it Changed

LF.1 Leadership New Objective in the new Foundations Section

This objective on Leadership broadly addresses leaders at all levels in the organization, including senior managers, managers, supervisors, and individual leaders. The focus is on primarily on how leaders behave and influence behavior in others. This is considered a cross-functional objective and can be referenced to support strengths or areas for improvement in any of the functional areas. This objective was developed to be separate and distinct from manager roles and responsibilities, which are addressed in OR.2, Manager Fundamentals. Although managers perform most of the criteria in LF.1, certain behaviors are expected to exist at all levels of the organization. The LF performance objective is subdivided into four sections:

Vision and Values –from the Leadership Fundamentals document

Teamwork – from the Leadership Fundamentals

Accountability - from Leadership Fundamentals

Employee Engagement - from Leadership Fundamentals and SOER 10-02


6

Added criteria includes:

Technical Conscience – principle 1 of this document is captured as a criterion in LF.1

Training – leader ownership of training is addressed as a criterion

Nuclear Professionals

NP.1 Nuclear Professionals New Objective in the new Foundations Section

This objective is one of the outcomes from the INPO and industry initiative to clarify the fundamentals for the functional areas of operations, maintenance, engineering, chemistry, and radiation protection. The fundamentals are focused more towards the uniqueness of the specific disciplines. The Nuclear Professional captures the behaviors, skills, knowledge and practices that are expected of all workers, regardless of the department, role or position of the individual. This objective and its criteria were developed by incorporating many of the behavior fundamentals embodied in various documents noted in pages 3 and 4 above. This is considered a cross-functional objective and can be referenced to support strengths or areas for improvement in any of the functional areas.

Nuclear Safety Culture

SC.1 Nuclear Safety Culture

The criteria for safety culture have been revised to be consistent with the 10 traits and common language developed by the industry, NRC, and NEI, as published in INPO 12-012, Traits for a Healthy Nuclear Safety Culture.


7

Organizational Effectiveness

OR.1 Structure and Traits of a Nuclear Organization

This objective is intended to be broad and high–level, and is based on elements that should be reflected throughout the organizational culture. It generally applies to all individuals and functions – the “price of admission.” Engaged, thinking is used in the objective to implement SOER 10-02.

Organizational Structure – clear organization, defined roles and responsibilities, compiled from current PO&Cs and Leadership Fundamentals document, better reflects layout of WANO PO&Cs

Traits - from current PO&Cs and Leadership Fundamentals. Elements of SOER 10-02 are addressed in this PO&C using the terms engagement and thinking.

Also added criteria to included:

Human performance, industrial safety, and radiological work practices are addressed here at as high level criterion at leader level. The details are supported in stand-alone PO&Cs.

OR.2 Manager Fundamentals

This addresses managers and the management functions that control, direct, plan, organize, coordinate, and staff the organization. This objective is directed at who in the organization has these responsibilities. It is separate and distinct from the Leadership objective in that it is focused less on the how the behaviors are modeled or influenced through all levels of the organization, but instead is focused on the manager-level key attributes. The criteria are divided in three sections:

Control and Direct – managers define, communicate, and reinforce high standards - from current PO&Cs and WANO

Plan, Organize, and Coordinate – include criteria from current PO&Cs and addresses the manager functions described in the Leadership Fundamentals document.

Staff – added more detail in this section to address newer workforce and knowledge transfer

OR.3 Management Systems This addresses the need for robust programs and processes that are used by managers to control and monitor key station activities, include making decisions and considering risks. It is not


8

meant to be prescriptive on the specific programs or processes needed, only the results.

Management systems – this aligns with SOER 10-2 and recognizing subtle indications of performance decline. Also adds elements of business planning and performance management processes

Integrated Risk Management – addressed here to capture the processes that should be in place

Also added specific criterion to include change management

OR.4 Leader and Manager Development

Leader and Manager Development was viewed as important and distinct enough to keep as a stand-alone PO&C, similar to the 2005 versions of INPO and WANO PO&Cs. Specific elements of L&MD are addressed including identifying, screening, selecting, transitioning, training, developing, and mentoring, and assessing.

OR.5 Independent Oversight

Very similar to the 2005 PO&C OR.5 and updated to reflect the new principles document on Governance and Oversight. This includes Monitoring Performance, Structure, Conduct, Communications, and Assessment

Human Performance

HU.1 Human Performance This is similar to the 2005 PO&C OR.3 and the 2005 WANO PO&C HU.1. It was updated to consider aspects of the series of HU fundamental documents that were published. For example, elements of coaching and training role were beefed up. Also, common procedure elements were added. The HU PO&C were kept separate from the Nuclear Professional PO&Cs for the following reasons:

1. Keeping alignment current industry models on human performance

2. Industry manager and working group feedback 3. Maintaining visibility on human performance as a distinct

station and evaluation focus area 4. Alignment with regulatory framework on human

performance 5. HU PO&Cs viewed as more granular and evaluative


9

Industrial Safety

IS.1 Industrial Safety This is similar to 2005 INPO PO&C objective OR.6 and WANO PO&Cs objectiveIS.1. Changed from an OR to IS objective aligns it to WANO format. (Also discussed in the RP basis summary section.)


10

PO&C Revision Bases Summary – Operations and Operational Focus


Basis for changes

OP.1 OPERATIONS FUNDAMENTALS section was modified

The OP.1 objective in the previous version of the performance objective and criteria contained a broad overview of all the requirements for both an effective operations department and strong operator performance. The major changes in this draft of the operations PO&Cs are to break out and focus on the important operator fundamental behaviors (OP.1 OPERATIONS FUNDAMENTALS). The OP.1 objective is designed to closely parallel how the operator fundamental behaviors described in IER 11-3 Weaknesses in Operator Fundamentals. The criterion are broken into five sub-categories of monitoring, control, teamwork, conservatism, and knowledge that match the categories in IER 11-3. These take the place of the generally less detailed descriptions of important operator fundamental behaviors contained in the previous OP.1 objective. This approach takes full advantage of the INPO and industry work that went into refining the operator fundamental behaviors for IER 11-3.

OP.2 CONDUCT OF OPERATIONS New objective for non-fundamental related criterion from the previous version of OP.1

The criterion from the previous OP.1 objective related to maintenance of an effective operations department were modified as necessary and moved into the new OP.2 CONDUCT OF OPERATIONS objective. Some of the changes or additions include:

Several criteria were added around operations work force planning.

Criteria were added around operations procedures. These had been contained in the previous OF.3 objective but have been removed from the new OF objectives.

Criteria were added or clarified around managing control room formality.

Criteria were added for assessing and tracking operability of technical specification related components.

OF.1, OF.2 and OF.3 Objective overview

The OF.1, OF.2 and OF.3 objectives created in the previous version of the performance objective and criteria were created as cross functional objectives describing how risk, decision making, operationally important equipment, and other elements related to operational focus should be managed. Both INPO and industry personnel struggled at times to fully understand the concept of operational focus and in 2009 a working group was created to develop a principles document better describing the elements of


11

operational focus. This group included senior industry representatives and helped create INPO 10-004, Principles for a Strong Plant Operational Focus. This document was broken into 5 separate principles. During the development of this INPO principles document it was envisioned as a potential model for how the OF objectives would be modified in the upcoming revision to the performance objectives and criteria. In the initial draft of the new performance objectives and criteria four objectives were created to model the first four principles of the plant operational focus principles document. The fifth principle was not carried into the initial version because that principle was focused on individual responsibilities for each position level in the organization and was not well suited for INPO performance objective criterion. The first four principles contained the high level outcomes that the individual behaviors and responsibilities in the fifth principle reinforced. Consequently, nothing was lost with this omission. During early reviews, the four objectives created in the first draft of the new PO&C were consolidated into the three OF objectives as described below.

OF.1 OPERATIONAL PRIORITIES

The OF.1 objective was created to model the first principle from the principles documents. This objective focuses on how equipment important to plant operation is maintained. The attributes from the principles documents were closely paralleled in the criterion for this objective

OF.2 OPERTIONAL RISK

The OF.2 objective started as two separate objectives paralleling the second and third principles from the principles document. These objectives covered risk associated with degraded equipment or equipment removed from service and also risk associated with daily activities. Based on initial feedback these were later combined into one objective on plant operational risk. Other elements of risk are described in the integrated risk criteria of the OR.3 MANAGEMENT SYSTEMS objective and are also covered in some level in several objectives in other areas. The individual criterion of this objective are separated out into those dealing with equipment removed from service or degraded and those dealing with plant activities. Criteria dealing with safety tagging program and plant configuration control were included in this objective. Safety tagging and configuration control were initially made part of the principles document with the understanding that this would likely be used as a model for the performance objective and criterion revision.


12

OF.3 RESPONSE TO EMERGENT OPERATIONAL CHALLENGES

The OF.3 objective models the fourth principle from the principles document. The criteria in this objective provide guidance to help the organization respond to events and emergencies that require an integrated cross department response to manage.

Operations


OP.1 – Criteria 1-8 These criteria cover the operator fundamental behavior of monitoring. There is significant overlap with pervious criteria 12 through 16 of OP.1. A few criteria were added to cover monitoring elements not previously addressed and to align with elements discussed in IER 11-3.

OP.1 – Criteria 9-15 These criteria cover the operator fundamental behavior of control. Although there is overlap with previous criteria 17 through 21 of OP.1 the new criteria cover control behaviors on a more detailed level and align with how these behaviors are characterized in IER 11-3. Supervisor implementation of EOPs and AOPs has been moved to criteria 28 under teamwork.

OP.1 – Criteria 16-22 Covers conservative behaviors in controlling the plant as discussed in previous criteria 7 through 11 of OP.1. Some additional criteria were added to align with conservatism elements described in IER 11-3.

OP.1 – Criteria 23-28 The operator fundamental of teamwork is described in these criteria. This section did not have a clear parallel with any section of the previous OP.1 criteria. However, elements of teamwork which were spread among several pervious criteria are consolidated here. The new criteria the key elements of teamwork as identified in IER 11-3.

OP.1 – Criteria 29-35 Elements of operator knowledge were previously covered in criteria 22 through 26 of OP.1. The new criteria add several criteria and cover standards of excellence for operator knowledge in much more detail than previously. These criteria around knowledge are aligned with how this operator fundamental is described in IER 11-3.

OP.2 – Criteria 1 Similar to previous OP.1.22 but focuses on monitoring shift managers.

OP.2 – Criteria 2 Similar to previous OP.1.23 but provides more details.

OP.2 – Criteria 3 Similar to previous OP.1.22 but focuses on monitoring for staying in a supervisory role for SROs.


13

OP.2 – Criteria 4 Similar to previous OP.1.6 but deals more specifically with training as it applies to establishing teamwork. This also emphasizes elements from SOER 96-1.

OP.2 – Criteria 5 Based on guidance from INPO 06-006 on reactivity management.

OP.2 – Criteria 6 Previous OP criteria did not clearly describe the need to apply operating experience, this is added here.

OP.2 – Criteria 7 Previous OP.1.10





OP.2 – Criteria 12 Added to capture excellence in how on-shift operators perform initial operability assessment. This was not addressed previously.

OP.2 – Criteria 13 Added to capture excellence in how on-shift operators track open operability challenges. This was not addressed previously.

OP.2 – Criteria 14 Procedure quality was previously covered in OF.3.9 but this concept did not align with how plant operational focus is now defined. Consequently it has been moved to the administrative section of the conduct or operations objective.

OP.2 – Criteria 15 This guidance came from the INPO operations department how-to on procedure changes. This important element of operations department control of procedures was not previously defined.

OP.2 – Criteria 16 & 17 These capture some important elements from INPO 09-014 on operations workforce planning.

Operational Focus

OF.1 – Criteria 1 Based on an attribute from principle 1 of Principles for a Strong Plant Operational Focus.

OF.1 – Criteria 2 Based on two attributes from principle 1 of Principles for a Strong Plant Operational Focus. This combines elements of prioritization and aggregate assessment. Added some information to clarify some factors to consider in prioritization.

OF.1 – Criteria 3 This criteria was added during review to ensure prioritization and aggregate assessments are adjusted as necessary if the identified problem changes.


OF.2 – Criteria 1 Based on an attribute from principle 2 of Principles for a Strong Plant Operational Focus. Added some more specifics around how risk should be assessed.


14

OF.2 – Criteria 2 Based on an attribute from principle 2 of Principles for a Strong Plant Operational Focus. Some of the specifics were eliminated to make it more generic in application.

OF.2 – Criteria 3 Based on an attribute from principle 2 of Principles for a Strong Plant Operational Focus but added a statement about contingency planning.

OF.2 – Criteria 4 Summarizes elements of some previous criteria from OF.2. Some elements around operational decision making were not clearly addressed in Principles for a Strong Plant Operational Focus so this was added during the review of the performance objective and criteria revision.

OF.2 – Criteria 5 Captures some elements of previous OF.2.5 criteria. Some elements around operational decision making were not clearly addressed in Principles for a Strong Plant Operational Focus so this was added during the review of the performance objective and criteria revision.

OF.2 – Criteria 6 Based on an attribute from principle 2 of Principles for a Strong Plant Operational Focus. The wording was adjusted some to clarify the original intent.


OF.2 – Criteria 8 Based on an attribute from principle 3 of Principles for a Strong Plant Operational Focus. Most elements of principle 3 aligned with the next section of the OF.2 criteria but this one was moved since it was driven by equipment being removed from service or degraded.

OF.2 – Criteria 9 Based on an attribute from principle 3 of Principles for a Strong Plant Operational Focus. The wording was adjusted some to clarify the original intent.

OF.2 – Criteria 10 This was added during review to clarify actions necessary when work is added late in the work panning process.

OF.2 – Criteria 11 Based on an attribute from principle 3 of Principles for a Strong Plant Operational Focus. The wording was simplified based on review input.





15



OF.3 – Criteria 1 Based on an attribute from principle 4 of Principles for a Strong Plant Operational Focus. Minor adjustments were made based on review input.

OF.3 – Criteria 2 Added this criteria to capture that it is important to prioritize actions based on potential operational impact.



OF.3 – Criteria 5 Based on an attribute from principle 4 of Principles for a Strong Plant Operational Focus. The word corporate was adjusted to off-site to better clarify the intent.


16

PO&C Revision Bases Summary – Maintenance, Work Management,

Fueling Activities and Project Management


Basis for changes

MA.1 MAINTENANCE FUNDAMENTALS section was created

The new MA.1 section was created to capture 6 categories of maintenance fundamentals. These are the actions and behaviors that individuals aspire to achieve. These apply to all maintenance disciplines and all roles in the maintenance department. “The fundamentals are defined as the essential knowledge, skills, behaviors, and practices personnel need to apply to conduct their work properly.” These fundamentals are a blend of the following documents; Fundamentals for Operations, Maintenance, Engineering, Radiological Protection, Chemistry, And Training, preliminary dated October 2006, INPO 05-003, Performance Objectives and Criteria, May 2005, and WANO Performance Objectives and Criteria, Revision 3, January 2005. Changes were also made based on past industry performance reflecting a need to emphasize technical knowledge and the precision required to achieve excellence in maintenance (SOER 10-2).

MA.2 CONDUCT OF MAINTENANCE

This section provides a vision for how the maintenance department should conduct business. This blends the 2005 INPO PO&C, 2005 WANO PO&C, and INPO 05-004, Guidelines for the Conduct of Maintenance at Nuclear Power Stations. The section highlights maintenance management’s and first line supervisor’s role in excellent equipment and department performance. Additionally, the section outlines some key programs and processes for the maintenance department and recognizes maintenance management’s or other site management’s roles in supplemental personnel performance.

WM.1 WORK MANAGEMENT

This section uses the previous ER.4 from the 2005 INPO and WANO PO&C, INPO AP-928, Work Management Process Description Revision 3, INPO 06-008, Guidelines for the Conduct of Outages at Nuclear Power Plants, Revision 1. This section was written with the perspective that very similar work management processes, principles, and behaviors are demonstrated during online and outage situations, but with different time horizons.

FA.1 FUELING ACTIVITIES

Section was created to improve performance in fueling related activities including fuel movement (new, spent, and cask), and core component assembly/disassembly (blade guides, LPRMS, control rods, burnable poisons, vessel internals, vessel head, etc.).


17

Performance in the last 10 years has not improved and a review of previous industry documents showed that elements in this area were inferred and distributed across many unrelated documents. Technical Report, TR 10-72, Equipment Damaged During Core Alteration, Fuel Handling, and Reactor Vessel Maintenance used as a reference.

PM.1 Section describes attributes related to project management. Created based on the recognition that successful project management has a significant impact on the successful performance of plant operations during normal operations and outages. INPO 09-002, Guideline for Excellence in Project Management, revision 0 used a reference. Project management, to be successful, must be integrated in station work management processes and behaviors.

Maintenance


MA.1 - Criteria 1 through 4 Changes to previous criteria to emphasize to the concept of a thinking organization based on SOER 10-2.

MA.1 - Criteria 5 - 16 Added criteria to emphasize the concepts of precision maintenance, preparation and feedback based on observed industry weaknesses in these areas.

MA.1 – Criteria 17 - 19 Added criteria to highlight the need to understand equipment condition and response during maintenance. Expanded the concept of stop when unsure to uncertainty, unexpected results, and changing conditions. Added criteria for meticulous preparation to promote understating of detail. These were changed to promote industry change based on observed gaps in these areas.

MA.1 – Criteria 20-21 Highlights key areas of technical information exchange in maintenance. Similar to previous criteria.

MA.1 – Criteria 22-26 These are similar to previous criteria for maintenance ownership. Added criteria for identification of rework to help improve performance.

MA.1 – Criteria 27-29 Describes criteria for supplemental personnel, parallel to the criteria for utility personnel.

MA.2 – Criteria 1-4 Created to show the association of key attributes with equipment performance.

MA.2 – Criteria 5-10 Created in recognition of the important role maintenance


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supervisors have in an excellent maintenance department.

MA.2 – Criteria 11-21 Describes many of key programs and processes for a maintenance department.

MA.2 – Criteria 22-25 Addresses station management’s role, maintenance department or other station management, in supplemental personnel performance. Based on AP-930 and industry experience.

Work Management

WM.1 – Criteria 1-11

Describes attributes that should be demonstrated by all station managers and leaders for excellence in work management. Emphasizes teamwork required to attain and sustain a successful work management process.

WM.1 – Criteria 12-13 Describes the collaborative effort required to identify and prioritize work, taking into consideration some key factors. Also introduces the concept that aggregate impact of items may raise the importance.

WM.1 – Criteria 14-15 These criteria discuss the idea of maximizing equipment availability and minimizing risk when selecting and scoping work.

WM.1 – Criteria 16-21 Highlights the concept of investing upfront in planning activities as a significant contributor to successful work completion. Key areas are level of detail, resources, risk and shutdown safety.

WM.1 – Criteria 22-30 Discuss key attributes to attain when scheduling and coordinating work. Key aspects are understanding interaction of activities to minimize risk.

WM.1 – Criteria 31-34 Discuss the need to understand performance during a given work week, system outage, or plant outage to improve performance.

Fueling Activities

FA.1- Criteria 1-11 All new section and criteria. Intended to focus improvement of fuel handing (spent, new, cask), core component handling, vessel disassembly, assembly, and inspection.

Project Management

PM.1 – Criteria 1-20 All new section and criteria. Based on INPO 09-002, Guideline for Excellence in Project Management, revision 0.


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PO&C Revision Bases Summary -Chemistry

Objective & Criteria

Global Changes

Basis for Changes

CY.1 CHEMISTRY

FUNDAMENTALS

This objective was renamed

and expanded from 3 to 5

sections.

The new CY.1 section was renamed and expanded to capture 5 principle level categories of chemistry fundamentals. The origin of these fundamentals are found in the Preliminary - October 2006 document, Fundamentals for Operations, Engineering, Maintenance, Radiological Protection, Chemistry, and Training and also recognize the chemistry objectives in the existing WANO PO&C’s. The fundamentals describe the roles and responsibilities and are written for the chemistry individual contributor. The 5 categories include: 1) sampling and analyzing by the technicians, 2) monitoring, assessing, and responding to chemistry conditions, 3) chemistry knowledge including operating experience, 4) communicating and advocating by chemistry personnel, and 5) control of chemicals. Individual fundamentals may apply to one or all chemistry roles and are defined as the essential knowledge, skills, behaviors, and practices personnel need to apply to conduct their work properly. The SOER 10-2 concept of the engaged, thinking individual is also

integrated into these fundamentals.

CY.2 CHEMISTRY CONTROLS

This objective was added.

CY.2 focuses on Chemistry’s responsibility to optimize the chemistry conditions during all phases of plant operations. The criteria was moved out of the old CY.1 and expanded to include make up water and diesel fuel oil quality.

CY.3 EFFLUENT CONTROL

This objective was added.

The new objective CY.3 describes the station effluents as monitored and controlled to protect the environment. It is divided into radiological and non-radiological effluent criteria.

ER.4 MATERIALS RELIABILITY

A section on Material Preservation was added.

The section describes the station’s responsibility to support a strong chemistry program that will preserve the plant materials for long-term reliable plant operation.


CY.1 CHEMISTRY FUNDAMENTALS

This new Chemistry Fundamentals section lists five Principles (sub-headers) for the chemistry function. These principles serve as


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descriptors of a group of fundamentals that individual chemistry personnel must implement to fulfill their role in an excellent manner. The fundamentals grouped under the principle of sampling and analyzing focuses on the chemistry technicians. The fundamentals grouped under the principle of monitor, assess, and respond focuses primarily on the chemistry specialists. The chemistry knowledge, communicate and advocate, and control of chemicals fundamentals applies to all chemistry department personnel. Many of the fundamentals captured in these 5 categories come from Preliminary - October 2006 document, Fundamentals for Operations, Engineering, Maintenance, Radiological Protection, Chemistry, and Training. Several fundamentals/criteria were added to capture the chemistry fundamentals associated with the chemistry programs and the process of critical thinking.

CY.1 Criteria 1 Combine existing WANO criteria CY.3 – D and CY.4 – I. The criterion is written at a higher level, but addresses the same fundamentals.

CY.1 Criteria 2 Combine existing WANO criteria CY.4 – B and E with old objective CY-1 criterion 10.

CY.1 Criteria 3 Combine and expands on existing WANO criteria CY.3 – E and CY.4 – D.

CY.1 Criteria 4 New criteria based on industry events where chemistry errors have occurred concerning chemical adjustments without promptly monitoring of the results.

CY.1 Criteria 5 Reword existing WANO criterion CY.3 - S.

CY.1 Criteria 6 Same as old criteria CY.1 – 11.

CY.1 Criteria 7 Combine existing WANO criterion CY.2 – E with old criteria CY.1 – 17.

CY.1 Criteria 8 Expand on the existing WANO criterion CY.2 – B.5.

CY.1 Criteria 9 New criteria describing comprehensive expectation of using diverse technical guidance to understand and recommend changes in chemistry to address technical issues.

CY.1 Criteria 10 New criteria to use operating experience and knowledge of new industry issues to optimize plant chemistry.


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CY.1 Criteria 11 New criteria to address the must-know operating experience.

CY.1 Criteria 12 New criteria to focus on chemistry communicating adverse trends to operations and engineering. Then establishing the expectation that chemistry anticipates adverse trends and takes preemptive actions to keep contaminants low.

CY.1 Criteria 13 Expand on existing WANO criteria CY.1 – E.4 and old criteria CY.1 – 6 focusing on advocacy for critical chemistry equipment issue resolution.

CY.1 Criteria 14 Expand on existing WANO criteria CY.5 – G focusing on the actions of chemistry personnel.

CY.1 Criteria 15 New criteria to demonstrate chemistry’s ownership of the chemical control program across the plant.

CY.1 Criteria 16 Reword existing WANO criteria CY.5 – F.

CY.1 Criteria 17 Combine existing WANO criteria CY.5 – H and I.

CY.1 Criteria 18 New criteria based on operating experience where impure chemicals were supplied to plants and used in systems.

CY.2 - CHEMISTRY CONTROLS

These new criteria capture controlling chemistry within goals, communicating adverse trends and out of specification conditions, monitoring make up water quality, ensuring high quality diesel fuel oil, and using contingency plans and off normal procedures to promptly restore abnormal chemistry conditions.

CY.2 – Criteria 1 Combine existing WANO criteria CY.3 - B, C, J and O with old objective CY-1 criteria 8 and 9.

CY.2 – Criteria 2 New criteria for chemistry personnel to promptly communicate recommendations to address adverse trends and out-of-specification parameters.

CY.2 – Criteria 3 Reword existing WANO criteria CY.3 – K focusing on make-up water quality.

CY.2 – Criteria 4 New criteria focusing on the use of contingency plans to address off normal conditions to minimize chemistry excursions.

CY.2 – Criteria 5 New criteria to address industry issue with diesel fuel oil quality.


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CM.4 – Nuclear Fuel Management

There are two Configuration Management criteria within the Nuclear Fuel Management objective where chemistry has responsibility.

CM.4 – Criteria 3 CM criteria, under Reactor Core Monitoring, discuss the radiochemistry parameter monitoring to detect and confirm the presence of fuel failures. Reworded previous CY.1 – criteria 13.

CM.4 – Criteria 8 CM criteria, under Fuel Performance, discuss chemistry programs changes are evaluated, monitored, and controlled to prevent fuel failures. It further includes primary water chemistry controls prevent excessive crud buildup on fuel surfaces that can lead to fuel failure. Expanded previous CY.1 – criteria 14.

CY.3 – EFFLUENT CONTROL

A new criteria that captures the concept that the original plant design standards and operating practices may not stand the test of time, based on new operating experience or risk analysis insights. The recognition of this new operating experience or risk insight results in the realization of inadequate design or operating margins. Changes must then occur to reconcile the existing plant with the newly identified standard or practice. Recognition of the need for a new design standard is a leadership trait.

CY.3 – Criteria 1 Reworded old criteria CY.1 – 16.

CY.3 – Criteria 2 Same as existing WANO criteria CY.6 – E.

CY.3 – Criteria 3 Reworded existing WANO criteria CY.6 – G.

CY.3 – Criteria 4 New criteria focusing on ground water monitoring and mitigation.

CY.3 – Criteria 5 Reworded existing WANO criteria CY.6 – J.

CY.3 – Criteria 6 New criteria focusing on non-radiological treatment of cooling waters that are returned to the environment.

CY.3 – Criteria 7 New criteria focusing on cooling water treatment effectiveness.

ER.4 – Material Reliability Criteria 7 – 17

New section added in the Equipment Reliability section titled Material Preservation that supports long-term, reliable plant operation through plant-wide support for system chemistry.

ER.4 – Criteria 7 Expand on old criteria CY.1 – 1 focusing on plant material preservation.


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ER.4 – Criteria 8 Reword old criteria CY.1 – criteria 6 focusing on the overall plant support for chemistry.

ER.4 – Criteria 9 Reword old criteria CY.1 – criteria 6 to address the correction prioritization of chemistry equipment issues.

ER.4 – Criteria 10 New criteria to address industry issue of large equipment maintenance or replacement to minimize the chemistry impact during startup.

ER.4 – Criteria 11 New criteria to address the knowledge of the effects of chemistry on plant systems for plant workers in operations and engineering.

ER.4 – Criteria 12 New criteria to focus on the integration of resources on the operation of equipment important to chemistry.

ER.4 – Criteria 13 Expanded old CY.1 –criteria 14.

ER.4 – Criteria 14 Expands existing WANO criteria CY.6.

ER.4 – Criteria 15 Reword old CY.1 –criteria 15 to apply the control of consumable chemicals to all personnel.

ER.4 – Criteria 16 Reword old CY.1 –criteria 7.

ER.4 – Criteria 17 Reword existing WANO criteria CY.3 – focusing on make-up water equipment.


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Chemistry Must Know OE to PO&C Revision Matrix

Chemistry Must Know Lessons Learned

PO&C Objective/Criteria

Biofouling in service water system result in common-cause failure of safety-related components. Biofouling control in cooling water system is necessary to prevent a detrimental effect on plant and equipment performance.

CY.3 – Effluent Control within Criteria 6 and 7 under the heading of Non-Radiological Effluents.

Responsible personnel must be properly trained and knowledgeable about corrosion mechanisms and the ways to control corrosion.

CY.1 – Chemistry Fundamentals within Criteria 6 under the heading of Monitor, Assess, and Respond, and Criteria 7 under the heading of Chemistry Knowledge.

The control of feedwater chemistry and steam generator chemistry during both operational and nonoperational periods reduces steam generator corrosion.

CY.1 – Chemistry Fundamentals within Criteria 4 and 6 under the header of Monitor, Assess, and Respond; Also, CY.2 – Chemistry Controls within Criteria 1 and 4.

Proper pH control, especially in two-phase regions, promotes a stable oxide layer, such as magnetite, which helps reduce pipe corrosion from corrosion/erosion or flow-accelerated corrosion (FAC) processes.

CY.2 – Chemistry Controls within Criteria 1; Also CY.1 – Chemistry Fundamentals within Criteria 4 under the header of Monitor, Assess, and Respond.

Proper use and control of cooling water system corrosion inhibitors are necessary to reduce the possibility of component failures.

CY.3 – Effluent Control within Criteria 6 and 7 under the header of Non-Radiological Effluents.

Plant personnel lack knowledge of whom and what can affect reactivity (plant configuration control).

CM.4 – Nuclear Fuel Management within Criteria 3 under the header of Reactor Core Operations and Monitoring; and Also within Criteria 8 under the header of Fuel Performance.

Inadequate guidance in procedures can lead to reactivity management events.

CM.4 – Nuclear Fuel Management within Criteria 3 under the header of Reactor Core Operations and Monitoring.


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Improper worker practices (failure to follow procedures) can result in reactivity management events.

NP.1 – Nuclear Professional within Criteria 4 and 5.

Maintain air quality throughout the instrument air system by periodic monitoring and correction of problems.

CY.1 – Chemistry Fundamentals within Criteria 10 and 11 under the header of Chemistry Knowledge.

Organic-based material intrusions can go undetected for some time until they are broken down by heat or radiation. Likewise, the organic intrusions will typically not be removed via ion exchange until they are broken down into ionic form.

CY.1 – Chemistry Fundamentals within Criteria 7 and 8 under the header of Chemistry Knowledge; and Also CY.2 – Chemistry Controls within Criteria 4.

The control of chemical/material disposal to radwaste is important from both the effect on radwaste processing efficiencies as well as recovery and reuse of radwaste liquids.

CY.1 – Chemistry Fundamentals within Criteria 15 under the header of Control of Chemicals; and Also CY.2 – Chemistry Control within Criteria 15 under the header of Material Preservation.

Intrusions are not limited to power operations. Then can also occur during reactor downtime.

CY.1 – Chemistry Fundamentals within Criteria 7 under the header of Chemistry Knowledge; and Also ER.4 – Materials Reliability within Criteria 10 under the header of Material Preservation.

Plant procedures and administrative controls are very important to minimizing impurity intrusions. Procedures and processes should be in place to mitigate impurity intrusion events in a timely manner.

CY.2 – Chemistry Controls within Criteria 4; Also CY.1 – Chemistry Fundamentals within Criteria 12 under the header of Communicate and Advocate.

Chemistry needs to have both the analytical equipment as well as the procedures in place to detect and respond to impurity intrusions.

CY.1 – Chemistry Fundamentals within Criteria 2 under the header of Sample and Analyze, and within Criteria 12 and 13 under the header Communicate and Advocate; and Also CY.2 – Chemistry Controls within Criteria 1 and 4.

The effects of chemistry changes on core performance and of core design on coolant chemistry should be evaluated to obtain defect-free fuel performance.

CM.4 – Nuclear Fuel Management within Criteria 8 under the header of Fuel Performance.


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Contingency plans are necessary to minimize and control contaminated secondary water during a primary-to-secondary tube leak.

CY.2 – Chemistry Controls within Criteria 4.

Radiation monitors critical to the detection of primary-to-secondary leaks should be properly calibrated, source checked, and monitored/trended routinely.

CY.3 – Effluent Control within Criteria 3 under the header of Radiological Effluents.

Representative and accurate sampling and analysis for boron concentration, primary-to-secondary leakage, radioactive effluents, accident mitigation, and other programs are critical elements of safety.

CY.1 – Chemistry Fundamentals within Criteria 1 and 2 under the header Sample and Analyze.


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PO&C Revision Bases Summary – Equipment Reliability


Basis for changes

ER.1 EQUIPMENT PERFORMANCE

High levels of reliability are achieved for equipment that supports nuclear safety, plant reliability, and emergency response capability.

Revised to compliment OF.1 - added wording to better characterize the operational focus to ER issues. (This was accomplished via an OP, MA/WM, and ER mini-team to obtain the proper alignment.)

Shifted focus to Engineering providing solutions to support plant operations

* Drive equipment improvements * Risk assessments * Plant Health Committees * Resolve longstanding issues * Perform complex troubleshooting

Removed reference to fission products barrier (fuel covered in CM.4)

Moved critical materials to new ER.4

Added reference to fuel handling equipment, and fire protection and emergency response components to safety system equipment, systems that control or monitor reactivity in criteria 1.

ER.2 PREVENTION OF EQUIPMENT FAILURES Preventive and predictive maintenance and performance monitoring are used to prevent failures of equipment important to safety, reliability, and emergency response.

Divide criteria into 2 sections

Preventive and Predictive Maintenance

o Reference overtly first time PMs

Equipment Programs and Monitoring o Taken mostly from and (removed from) EN.1 o Brought in vulnerability reviews and mitigation (IER 11-

2 recs)

ER.3 LONG-TERM EQUIPMENT RELIABILITY Equipment is managed to maintain long-term equipment reliability.


Traditional Life Cycle Management criteria o Subtle reference to SOER 10-01 (Large power

transformers) recommendations in criteria 6

New section for Parts Quality and Availability o Developed from industry supply chain input and picture

of excellence


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ER.4 (New) MATERIALS RELIABILITY Activities are implemented to preserve materials and components in a manner that supports long-term, reliable plant operation.

New PO&C for materials


Material Selection, Inspection, and Assessment o Encompasses ‘critical’ materials (steam generators,

vessel internals) from ER.1 and passive components (tanks, structures, buried piping) from ER.3

o Subtle reference to SOER 07-02 (Intake structure blockage)

Also encompassed Chemistry attributes to form ‘Material Preservation’ section

Old ER.4 “Work Management” became WM.1

Criteria Specific Changes

What Changed and Why it Changed

ER.1 EQUIPMENT PERFORMANCE

ER.1 – old Criteria 1 Became new criteria 4 and shifted focus from Managers to Engineers

ER.1 – new Criteria 1 New criteria which focuses engineering and other organizations in finding solutions to equipment problems. Intended to compliment OF.1 and came from the INPO ‘Picture of Excellence’

ER.1 - Criteria 2 Changed to include proper priority to resolve fuel handling, fire protection, and emergency response equipment. This was missing from previous criteria

ER.1 – old Criteria 3 Deleted and moved to new ER.4 (Materials Reliability)

ER.1 – new Criteria 3 New wording for addressing operator concern – supports the operational focus concept of ER

ER.1 – old Criteria 4 Deleted , covered in CM (fission products barriers , fuel)

ER.1 – new Criteria 4 Was old criteria 1 and shifted focus from Managers to Engineers

ER.1 - Criteria 5 New criteria that focuses engineers to drive equipment performance improvements (came from the INPO ‘Picture of Excellence’)

ER.1 – old Criteria 5 and 7 Combined and reworded into new Criteria 6 – stressing cross-functional of station managers

ER.1 – old Criteria 6 Became new criteria 7 – theme changed to engineering involvement in complex troubleshooting

ER.1 – new Criteria 7 See above

ER.1 - Criteria 8 Wording changed to include emergency response equipment and include a review of programmatic and organizational weakness for the equipment degradation

ER.1 – old Criteria 9 Deleted – covered better in PI for extent of condition cause


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analysis.

ER.1 – old Criteria 10 Unchanged but became new criteria 9

ER.1 – old Criteria 11 Unchanged but became new criteria 10

ER.1 – old Criteria 12 Became new criteria 11 – added wording to review outage scope for equipment improvement opportunities

ER.1 – old Criteria 13 Deleted – covered better in WM.1

ER.2 PREVENTION OF EQUIPMENT FAILURES

Preventive and Predictive Maintenance (Criteria 1-8)

ER.2 – old Criteria 1 Moved to System, component, and program health monitoring section of ER.2 and addressed in criteria 9, 10, 15, 16

ER.2 – new Criteria 1 Simplified criteria previously covered in old criteria 2. Keeps focus on component classification as the basis for PM programs

ER.2 – old Criteria 2 Became new criteria 1 – see above

ER.2 – new Criteria2 New criteria that overtly states the management support for executing a PM program

ER.2 – old Criteria 3 SPVs moved to new criteria 13 and14 broadened to include design and degraded condition

ER.2 – new Criteria3 Unchanged but moved from old criteria 7

ER.2 – old Criteria 4 Became part of new criteria 15 and 18 for monitoring

ER.2 – new Criteria 4 New criteria that introduces first time PMs to ER.2

ER.2 – old Criteria 5 Became new criteria 9 and reworded to focus on off-normal conditions and associated risk

ER.2 – new Criteria 5 Unchanged but moved from old criteria 8

ER.2 – old Criteria 6 Moved to new criteria 17 and expanded to included routine walkdowns and prevention of potential cyber security impacts

ER.2 – new Criteria 6 Unchanged but from old criteria 9

ER.2 – old Criteria 7 Unchanged but moved to new criteria 3

ER.2 – new Criteria7 Unchanged but from old criteria 10


ER.2 – new Criteria 8 New criteria that stresses the use of diverse predictive maintenance technologies

ER.2 – old Criteria 9 Moved to new criteria 6


System, component, and programs health monitoring (Criteria 9 – 19)

General comment – several criteria came from the old EN.1 “Equipment Monitoring” section, criteria 13-18. These criteria are viewed as supporting ‘Equipment failure prevention’


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ER.2 – new Criteria 9 Moved from old criteria 5 and reworded to focus on off-normal conditions and associated risk

ER.2 - new Criteria 10 New criteria - came from the INPO ‘Picture of Excellence’

ER.2 - new Criteria 11 New criteria - came from the INPO ‘Picture of Excellence’ - introduces compensatory measures for off normal conditions

ER.2 - new Criteria 12 New criteria - came from the INPO ‘Picture of Excellence’ - stresses use of OE and vendor recommendations

ER.2 - new Criteria 13 SPVs moved from old criteria 3 and overtly states to have a bias toward elimination - came from the INPO ‘Picture of Excellence’

ER.2 – new Criteria 14 SPVs moved from old criteria 3 and broadened to include design and degraded condition. Came from an IER 11-2 recommendation



ER.2 - new Criteria 17 Moved to from old criteria 6 and expanded to included routine walkdowns and prevention of potential cyber security impacts

ER.2 - new Criteria 18 New criteria to ER.2 but came from old EN.1 criteria 17

ER.2 - new Criteria 19 New criteria to ER.2 but came from old EN.1 criteria 14

ER.3 LONG-TERM EQUIPMENT RELIABILITY

Equipment Life Cycle Management ( Criteria 1-9)

ER.3 - old Criteria 1 Slightly changed to include component replacements

ER.3 - old Criteria 2 Added the words ‘and implemented’

ER.3 - old Criteria 3 Deleted the word ‘exists’

ER.3 - old Criteria 4 Became new criteria 5.


ER.3 - old Criteria 5 Unchanged but became new criteria 7

ER.3 - new Criteria 5 Moved from old criteria 4. Changed slightly to include generis industry issues and advances in technology as related to LCM

ER.3 - old Criteria 6 Unchanged but became new criteria 8

ER.3 - new Criteria 6 New criteria - came from the INPO ‘Picture of Excellence’ and now takes into account ‘emergency response equipment’

ER.3 - old Criteria 7 Moved to new ER.4 ‘Materials Reliability’ criteria 2

ER.3 - old Criteria 8 Moved to new ER.4 ‘Materials Reliability’ criteria 3. ‘Station’ changed to ‘Managers’

ER.3 - old Criteria 9 Moved to new ER.4 ‘Materials Reliability’ criteria 4. Added ‘inaccessible equipment’ and heat exchangers and safety-related structures.

ER.3 - new Criteria 9 New criteria to address operating plants that are considering or


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may have announce a future shutdown.

Parts quality and availability ( Criteria 10 - 15)

This is a new section and most of the criteria came from the industry, particularly the supply chain user group. The intent is to provide criteria for improving general parts quality provided by vendors or manufacturers

ER.3 - new Criteria 10 New criteria - came from the INPO ‘Picture of Excellence’ and supply chain users group





ER.4 MATERIALS RELIABILITY

Material Selection, Inspection, and Assessment (Criteria 1-6)

Completely new section replaces ER.4 ‘Work Management’ that changed to WM.1. First section is Material selection, Inspection, and Assessment. Second section is Materials preservation. This section came from a Chemistry (CY) proposition

ER.4 - Criteria 1 Moved from old ER.1 criteria 3 to support this new PO&C

ER.4 - Criteria 2 Moved from old ER.3 criteria 7 to support this new PO&C

ER.4 - Criteria 3 Moved from old ER.3 criteria 8 to support this new PO&C. ‘Station’ changed to ‘Managers’

ER.4 - Criteria 4 Moved from old ER.3 criteria 9 to support this new PO&C. Added ‘inaccessible equipment’ and heat exchangers and safety-related structures.

ER.4 - Criteria 5 Moved from old ER.3 criteria 5 to support this new PO&C. Similar to ER.3 criteria 7 but tailored for materials and passive components

ER.4 - Criteria 6 New criteria - from Chemistry input

Material Preservation (Criteria 7-17)

Previously contained within the bounds of CY.1 Chemistry Controls (Asset Preservation) Criteria 7-16

ER.4 - Criteria 7 New criteria - from Chemistry input formerly CY.1 criteria 1







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ER.4 - Criteria 14 New criteria - from Chemistry input formerly CY.1 criteria 13




Equipment Reliability Must Know OE to PO&C Revision Matrix

ER Must Know Lessons Learned


Emergency Power Reliability Attribute 1

Addressed generically by ER.2 criteria 12 and 13 for identifying and eliminating single-point vulnerabilities. Also, it could be bounded within ER.1 criteria 1 for maintaining safety systems reliable


Addressed by CM.3 “Design Change Processes” criteria 1-5. Also, it could be bounded within ER.1 criteria 1 for maintaining safety systems reliable


Addressed generically by ER.2 criteria 1 and 3 for preventive maintenance and criteria 7 and 8 for equipment monitoring. Also, it could be bounded within ER.1 criteria 1 for maintaining safety systems reliable

Electrical Distribution Systems Attribute 1

Addressed generically by ER.2 criteria 7 and 8 for equipment monitoring


Addressed generically by ER.3 criteria 1 – 6 for life cycle management. Also covered by CM.1


This must know lesson is at a low level and too specific to be contained at the criteria level. However, it could be bounded within CM.3 “Design Change Processes” criteria 1-5.


Addressed generically by ER.2 criteria 1 and 3 for preventive maintenance and criteria 7 and 8 for equipment monitoring.


Addressed generically by ER.2 criteria 1 and 3 for preventive maintenance and criteria 7 and 8 for equipment monitoring. Also covered by CM.1

DC Power System Attribute 1

This must know lesson is at a low level and too specific to be contained at the criteria level.


This must know lesson is at a low level and too specific to be contained at the criteria level. An EP criteria best addresses this lesson.


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This must know lesson is at a low level and too specific to be contained at the criteria level. However, it could be bounded within CM.3 “Design Change Processes” criteria 1-5.

Anticipated Transient without Scram (ATWS) Attribute 1

This must know lesson is at a low level and too specific to be contained at the criteria level. However, it could be bounded within ER.1 criteria 1 for maintaining safety systems reliable




Addressed generically by ER.2 criteria 1 and 3 for preventive maintenance

Standby Emergency Turbine-Driven Pumps Attribute 1


Standby Emergency Turbine-Driven Pumps, Attribute 2

Addressed generically by ER.2 criteria 1 and 3 for preventive maintenance

Critical Materials Attribute 1

Addressed in the new PO&C ER.4 “Materials Reliability” criteria 1-3

Critical Materials Attribute 2

Addressed in the new PO&C ER.4 “Materials Reliability” criteria 1-3

Flow-Accelerated Corrosion Attribute 1

Addressed in the new PO&C ER.4 “Materials Reliability” criteria 4 for passive components

Turbine Generators Attribute 1

Addressed generically by ER.2 criteria 1 and 3 for preventive maintenance and criteria 7 and 8 for equipment monitoring

Turbine Generators Attribute 2

Addressed by ER.2 criteria 12 for eliminating single-point vulnerabilities


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PO&C Revision Bases Summary – Engineering and Configuration Management


Basis for changes

EN.1 ENGINEERING FUNDAMENTALS section was created

The new EN.1 section was created to capture 5 categories of engineering fundamentals. The 5 sections are essentially principle level categories of the fundamentals. The fundamentals are written for the engineer individual contributor and describe all roles of engineers at the site, including system, design, program, reactor and procurement engineers. Individual fundamentals may apply to one or all types of engineering roles. “The fundamentals are defined as the essential knowledge, skills, behaviors, and

practices personnel need to apply to conduct their work properly.”

The origin of these fundamentals was from the Preliminary -

October 2006 document, Fundamentals for Operations,

Engineering, Maintenance, Radiological Protection, Chemistry,

And Training and the INPO 10-005 July 2010 document Principles

for Maintaining an Effective Technical Conscience. Attributes from Technical Conscience Principles 3, 4, and 5 are incorporated into these fundamentals. The concept of the engaged, thinking individual is also integrated into these fundamentals.

EN.2 TECHNICAL AUTHORITY Renamed, reformatted & content was simplified – this included removal of CM and ER specific criteria such as design bases or equipment monitoring from the original EN.1

The new EN.2 format focuses on Engineering’s unique role and responsibility within the organization, being the site’s Technical Conscience. The scope of this section covers all levels of engineering personnel. All but one of the criteria of this rewritten section captures the attributes of Technical Conscience Principle 2. Previously, EN.1 was the only titled EN section and had two sub-sections for Design and Safety Analyses, and Equipment Monitoring. The criteria in these sections were either determined to be redundant to other criteria in parts of the CM or ER objectives, or wording was revised in the CM and ER criteria to pick up orphaned concepts, resulting from removal of the old EN criteria.

Design and Safety Analyses criteria 7 to 12 removed.

Equipment Monitoring criteria 13 to18 were removed.

Criteria 19 through 21 were removed, and replaced with three new criteria. The old Criteria 19 was for Training and is covered by new Criteria described later. Old Criteria 20 covered supplemental engineering personnel and is also covered by a new criteria. A new Nuclear Professional common fundamentals criteria replaces old criteria 21.


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CM.1 & CM.4 Sections were retitled and objectives were rewritten

New titles and objectives better describe the broadened scope of the criteria that were added. The new CM.1 Title and objective bring in operating margin and the concept of managing margins. CM.4 title and objective were simplified. Section CM.1 added the concept that new operating experience may lead to changes to design requirements because of recognition of diminished margin. Also, credible beyond-design-basis event planning and preparation was specified in a new criteria. Some changes were made to the criteria of CM.1 through CM.3 to clarify the use of the term “risk”, as there are several forms of risk that are managed during operation of the plant.

CM.2 Section Objective was revised

Called out “Plant operation, maintenance and testing activities …” specifically, versus just stating “activities”. In addition, removed reference to operating and design margins to avoid confusion with section CM.1. Reference now made to licensing and design bases (bases being key requirements).

CM.3 Criteria A significant increase in the level of detail was provided here. The number of criteria increased from 8 to 16. Criteria detail was provided for PSA, modification testing and risk management, modification interdisciplinary and impact reviews, equivalency evaluations, temporary configuration changes, digital design changes and cyber security aspects.

Description & number of nearly all EN and CM Criteria was increased.

Descriptions were broadened to address past operating experience lessons learned and to offer a higher level of definition of excellent performance. AFIs, Plant Evaluation and WANO Peer review experience, based on reviews of results over the last 2 years, drove many of the wording changes, and in some cases such as Mod testing, whole new criteria. These criteria may be very similar to future WANO criteria, and WANO has fewer guidance documents for performing peer reviews to verify accomplishment of objectives. Therefore, it was thought a higher level of detail would be appropriate, in the absence of other guidance for conduct of a peer review.


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Engineering


EN.1 ENGINEERING FUNDAMENTALS Criteria 1 through 33

This new Engineering Fundamentals section lists five Principles (sub-headers) for the engineering function. These principles serve as descriptors of a group of fundamentals that individual engineers must implement to fulfill their role in an excellent manner. The fundamentals grouped under the principles can apply to one or all types of engineers such as system, design or program. The majority of the fundamentals captured in these 5 categories come from Preliminary - October 2006 document,

Fundamentals for Operations, Engineering, Maintenance,

Radiological Protection, Chemistry, and Training. Most of the remaining criteria were derived from attributes identified for engineers in Technical Conscience Principles 3, 4 & 5. Wording was revised from the source document versions to better fit the principle/fundamental context of EN.2. A few fundamentals/criteria were added to capture the engineer fundamentals associated with the process of critical thinking.

EN.2 - TECHNICAL AUTHORITY Criteria 1 through 9

These new criteria capture the Technical Conscience Principle attributes for engineering leadership, management and engineers. It also emphasizes the responsibility engineering has for upholding the design and licensing basis. Criteria 6 was added to describe the importance of ensuring abnormal plant conditions or indications that cannot be readily explained, are evaluated (Must Know OE, SOER 02-1).

Configuration Management

CM.1 – DESIGN AND OPERATING MARGIN MANAGEMENT Criteria 1

This criteria addresses known plant design or operational methods that have always had low margin. Risk insights or operational events may bring to light that the low margin poses an unnecessary risk to future operation. Either from a reliability or safety point of view. Operational methods or practices that are implemented within the flexibility of existing procedures may create low margin conditions. This criteria is different from criteria 3, in that criteria 3 is intended to address equipment degradation that has worsened over time, during operation.

CM.1 – Criteria 2 A new criteria that captures the concept that the original plant design standards/requirements and operating practices may not


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stand the test of time, based on new operating experience or risk analysis insights. The recognition of the applicability of new operating experience or risk insight results in the realization of inadequate design or operating margins. Changes must then occur to reconcile the existing plant with the newly identified standard or practice. Recognition of the need for a new design standard/requirement is a leadership trait.

CM.1 – Criteria 3 This is the old criteria 4 reworded. Margins are being reduced as a result of degrading equipment performance.

CM.1 – Criteria 4 This is the old criteria 1 with some minor wording improvements. Note that the new criteria 1, 3 and 4 each address a different situation where margins are low or, in the case of this criteria, could be reduced in the future as a result of planned design or operational changes.

CM.1 – Criteria 5 New - Communication of reduced margin is an attribute of a Technical Conscience principle.

CM.1 – Criteria 6 This is the old criteria 2, second sentence. The second sentence is a technical conscience role for engineers.

CM.1 – Criteria 7 This is the old criteria 2, first sentence. This was a different concept than the second sentence of the old criteria, and was therefore separated.

CM.1 – Criteria 8 The old criteria 3 with some minor wording improvements.

CM.1 – Criteria 9 New criteria to address plant life extension situation. Passive component element was added for consideration, based on MKOE.

CM.1 – Criteria 10 New criteria for potential, credible, beyond-design-basis events. It recognizes the need to cope with them, potentially address such an event through physical plant changes and identifies methods of preparation for such an event. This generic criteria is meant to cover events such as a Loss of all AC. Driven by IER L1-11-1, Rec 2&3 and IER L1-11-4, Rec 1

CM.2 – OPERATIONAL CONFIGURATION CONTROL Criteria 1

Same as previous criteria, with added sentence stating special consideration is given to conditions that may challenge design bases or safety analyses. This recognizes that additional focus should be placed on safety significant concerns.

CM.2 – Criteria 2 New criteria which places an emphasis on validating inputs and assumptions for engineering evaluations, which are frequent causes of improper evaluations.

CM.2 – Criteria 3 Similar to previous criteria 2 with some wording improvement, but adds an increased level of detail as to what specifically may need protection, including digital assets.


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CM.2 – Criteria 4 New criteria, added concept of process controls for scaffolding installation, and equipment design function impairment as a consideration for temporary equipment installations.

CM.2 – Criteria 5 Similar to previous criteria 3, but adds some expectations for validation and training for time critical operator actions-TCOAs.

CM.2 – Criteria 6 Same as previous criteria 4.

CM.2 -Deleted old Criteria 6 The old criteria 6 for “parts” was in the wrong section and was deleted. The new “parts” criteria, with improved detail, is now in CM.3 - Design Change Processes, criteria 13. Additional parts criteria exist in the ER objective area.

CM.2 – Criteria 7 Same as previous criteria 5. added reference to vendor manual updates

CM.2 – Criteria 8 Similar to old criteria 7, and added vendor manual updates to the list of potential changes driving updates to plant documents, missing item from prior criteria (SER 1-07). Also added fidelity of “plant simulator design” as a responsibility in this criteria.

CM.2 – Criteria 9 Reworded old criteria 8. Added maintaining critical drawings current.

CM.2 – Criteria 10 New criteria. Engineering vendor manual update review and the expectation that changes should be incorporated into station procedures.

CM.2 – Criteria 11 Old Criteria 9, reworded. Added “performance capability” verification, as well as passive design feature verification. Included reference to related activity of detection of gas accumulation in piping systems (MKOE), a significant industry concern still being addressed at some plants. This was added in the broader context of identifying degraded system and component conditions.

CM.3 – DESIGN CHANGE PROCESSES Criteria 1

Similar starting wording as original criteria 1 for the design authority. The second sentence, referring to roles and responsibilities, is an expansion of the old second sentence of criteria 1.

CM.3 – Criteria 2 New criteria referring to maintaining design consistency with documentation.

CM.3 – Criteria 3 New criteria identifying an engineer’s responsibilities for performing a design change. Describes the comprehensive nature of a design change, and includes consideration of impact on emergency response capability. Additional phrase recognizing that the best designs have resulted from a process that considers multiple design options.

CM.3 – Criteria 4 New criteria, identifying needs to assess the operational risk of


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implementing a design change and identifying any impact on the PSA.

CM.3 – Criteria 5 Similar to old criteria 3. Passive design feature aspects were added.

CM.3 – Criteria 6 New criteria added to recognize excellence - bridging of documents where design, operating, and license requirements are all linked.

CM.3 – Criteria 7 Similar to old criteria 4 with some improvement in wording, (e.g. - operability changed to technical suitability and functionality). Design changes can change functionality, but not operability, of a system or component.

CM.3 – Criteria 8 New criteria for design change impact reviews

CM.3 – Criteria 9 New criteria for modification testing. This process was missed in the previous PO&C criteria. Also driven by SER 4-05.

CM.3 – Criteria 10 Same as old criteria 5.

CM.3 – Criteria 11 Replaces old criteria 6, and emphasizes that temporary configuration changes require nearly identical levels of review and change management actions, as modification design changes. Clearly states that temporary modifications must meet design and operating requirements.

CM.3 – Criteria 12 Second of two criteria addressing temporary configuration changes (replaces old criteria 6, also). Covers reviews for need and potential removal.

CM.3 – Criteria 13 New criteria for parts evaluation process

CM.3 – Criteria 14 Old criteria 7, expanded from just FMEA for engineering products, to include the concept of performing risk assessments to identify the appropriate level of engineering review (technical human performance process). Also driven by SER 4-05 and SER 1-09

CM.3 – Criteria 15 Revised wording for old criteria 8 for oversight and support of engineering service providers.

CM.3 – Criteria 16 New criteria for digital design changes, and consideration of special cyber security requirements. These types of changes are a much larger percentage of new modifications and need to be addressed.

CM.4 NUCLEAR FUEL MANAGEMENT

Section restructured to group criteria into 4 subsections: Reactor Core Operations & Monitoring, Fuel Performance, Reload Core Design, and Fuel Storage & Handling.

CM.4 – Criteria 1 Enhanced version of old criteria 1 and first part of criteria 2. SOER 03-2 elements also included here (3rd bullet). SOER 07-1 (2nd bullet)

CM.4 – Criteria 2 Enhanced, includes part of old criteria 2. This comes from SOER and MKOE list.


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CM.4 – Criteria 3 2nd half of old criteria 2.

CM.4 – Criteria 4 Part 2 of old criteria 9, part 1 of old 12 & part 2 of old 13

CM.4 – Criteria 5-11 Changed to reflect key elements INPO 07-004 “Guidelines for Achieving Excellence in Nuclear Fuel Performance”

CM.4 – Criteria 5 Changes driven by Guideline INPO 07-004, Includes parts of Old Criteria 13

CM.4 – Criteria 6 Driven by INPO 07-004

CM.4 – Criteria 7 Changes driven by Guideline INPO 07-008 (Excellence in FME) and portions of old criteria 15


CM.4 – Criteria 9 Driven by INPO 07-004 – incorporates old criteria 6


CM.4 – Criteria 11 Driven by INPO 07-004 – includes part of old criteria 12

CM.4 – Criteria 12 Picture of Excellence & SOER 96-2 Rec 5

CM.4 – Criteria 13 Old Criteria 3 enhanced based on SOER 96-2 rec 1

CM.4 – Criteria 14 Old Criteria 11 updated to include changes in core components (fuel, channels); Risk evaluations changed to Risk assessments to align with current terminology. (SOER 03-2 Rec 1 &2)

CM.4 – Criteria 15 Old Criteria 7

CM.4 – Criteria 16 New – Reference SOER 96-2 Rec 2

CM.4 – Criteria 17 Old Criteria 10 (Also ref SOER 96-2 rec 2)

CM.4 – Criteria 18 Old Criteria 8 – added fuel vendor testing and comprehensive performance monitoring plans (SOER 96-2 rec 3) as tools for validating new fuel assembly design performance.

CM.4 – Criteria 19 Picture of Excellence & SOER 96-2 Rec 2

CM.4 – Criteria 20 Old Criteria 16 – Additional wording added to call out reactivity controls and heat removal rate. Added vacuum sipping and dry cask loading as additional examples that need to be considered.

CM.4 – Criteria 21 Old Criteria 5

CM.4 – Criteria 22 New – Full core offload capability is described in the Picture of Excellence

CM.4 – Criteria 23 New – Fukushima & B5b

CM.4 – Criteria 24 New – A few units are using the reactor for other business ventures in addition to making electricity. Input from RP included based on recent increased personnel exposure during fuel component handling/shipping activities. (also SER 3-08)

CM.4 – Criteria 25 Old Criteria 14 – SNM controls (regulatory requirement) – Added special reference to core monitoring detectors.

CM.4 –Deleted old Crit. 4 Old criteria 4 requiring backup analytical techniques (No AFIs written on this criteria)


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Engineering Must Know OE to PO&C Revision Matrix

Engineering Must Know Lessons Learned


Man Core Design & Fuel Integrity Attribute 1

CM.4 - Criteria 12 through 19, under heading of Reload Core Design, covers core design reviews, risk assessment of changes, various organizations to be involved in core design process and evaluation of plant change impact on cores


CM.4 - Criteria 1 and 2 under heading of Reactor Core Operations and Monitoring


CM.4 - Criteria 3 and 4 under heading of Reactor Core Operations and Monitoring (also, fuel monitoring and awareness of fuel performance margins is in Crit. 11)

Design & Operating Margins Attribute 1

CM.1 – Criteria 1, 2 (new), 3, and 4. CM.2 – Criteria 2 ; Also, Engineering Fundamentals within EN.1 – Criteria 4 & 5


CM. 2 – Criteria 1, 2, 4 & 5 ; CM.3 - Criteria 1, 7 & 9 ; Also, Engineering Fundamentals within EN.1 – Criteria 2, 4, 5, 8, 15 and 22


CM.2 – Criteria 1 & 2 ; ER Criteria for equipment monitoring and knowledge expectations for Engineers in EN.1 – Criteria 4, 5, 28, 30, 31, 32 of Fundamentals. Also EN.2 - Criteria 2 & 3

Environmental Conditions Attribute 1

In ER monitoring Criteria and EN.1 – Criteria 1 Fundamentals for monitoring. Also, a fundamental of EN.1 Criteria 21 for equipment improvement strategies. New CM.1 – Criteria 2

Environmental Conditions Attribute 2

CM.1 – Criteria 2 & 10 ; CM.2 – Criteria 11 ; CM.3 – Criteria 5 in total cover maintenance of, evaluations for, and design consideration of passive design features. CM.1 – Criteria 2 covers new operating experience that would indicate challenges to margins and Design standards/requirements, and CM.1 – Criteria 10 specifically covers contingency develop for beyond design basis events. Criteria 10 was written with extended loss of AC power event in mind, though it is meant to more broadly cover any beyond DBE.

Addressing Abnormal Conditions Attribute 1

EN.2 – Criteria 6 directly references abnormal conditions that cannot be readily explained. EN.1 – Criteria 2 & 3 also advocate investigation and resolution of abnormal conditions

Gas Accumulation Attribute 1

CM.2 – Criteria 11 directly references gas accumulation; Several Engineering Fundamentals criteria of EN.1, for monitoring and evaluation of plant conditions, apply.

Electrical Distribution Systems Attribute 2 - partial

Several sub-attributes of this topic (Transformers & Switchyard) apply to EN/CM. Ex. Design and Manufacturing considerations (criteria 3 of CM.3), hazard analysis. New CM.1 – Criteria 2 is the key criteria which should address


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situations where the old design standards may no longer be good enough in light of new operating experience of recent years.

Electrical Distribution Systems Attribute 5 - partial

Design features verification for large power transformers. New CM.1 – Criteria 2 is the key criteria which should address situations where the old design standards are no longer good enough in light of new operating experience. Also implementation of criteria 1 of EN.1 would support this MKOE item.

DC Power System Attribute 2 – partial

Criteria 4 & 5 of EN.1 for monitoring and evaluating (not exceeding design voltage of components during any mode of operation for DC systems) apply. Two criteria for margin management in CM.1 apply, such as Criteria 3 & 5. Criteria 13 & 14 of CM.3 might also be used to address this MKOE.


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PO&C Revision Bases Summary – Radiological Safety,

Radiological Protection, and Industrial Safety


Basis for changes

RS.1 RADIOLOGICAL SAFETY New Objective was created and placed under the Foundations Section

This performance objective and associated criteria were separated from the other radiation protection objectives and criteria and details were added to address industry performance weaknesses. Industry, INPO, EPRI, ANI and NEI personnel have identified that performance in the area of radiological protection has not substantially improved in the past several years and, as a result, the industry has not met its goals for BWR collective radiation exposure, an increase of consequential radiological events have occurred, and the industry is not well positioned for upcoming regulatory changes. The 2005 PO&Cs primarily address the radiation protection organization and their role in protecting plant workers and the public. However, many aspects of radiological protection are cross-functional or heavily controlled by departments other than radiation protection. For example, source term is primarily based on primary system chemistry, fuel design, fuel integrity, component materials, and plant operations. Equipment reliability, maintenance practices, and work scope are large contributors to collective dose. Finally, worker practices are important to minimize individual and collective dose as well as the potential for unplanned dose events or an overexposure.

To address these issues and improve performance while considering the current and upcoming challenges facing the nuclear industry, additional progress will require increased engagement by most station disciplines. The Radiation Safety PO&C would apply to the station as a whole and their focus on improving radiological safety. The industry has identified the station-wide focus on radiological safety as “The Big RP”.

Previous RP.1 FUNDAMENTALS OF RADIATION PROTECTION This section was divided into four separate performance objectives.

Objective numbering was revised to more closely align with WANO PO&Cs and to reflect major areas that are evaluated from a radiological protection perspective. These include RP fundamentals, radiation dose control, radioactive contamination control, and control of radioactive material. Without this change in numbering, all RP issues are RP.1 and have little meaning as to the area they represent. The change will help the stations to


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better understand the issue and enhance our trending to more easily identify areas of decline or concern.

Previous OR.6 INDUSTRIAL SAFETY The performance objective was renamed to IS.1.

Created a separate performance objective from organizational effectiveness to clearly identify it as its own objective and to align with the 2005 WANO PO&C section IS.1.


RP.1 RADIOLOGICAL PROTECTION FUNDAMENTALS

This new Radiological Protection Fundamentals section lists four Principles (sub-headers) for the radiological protection function. These principles serve as descriptors of a group of fundamentals that individual radiological protection personnel must implement to fulfill their role in an excellent manner. These include knowledge and skills, monitoring and communicating radiological conditions, controlling radiological work, and managing radiological risks.

RP.1 Criteria 1 Replaced criteria 6, 43, and 45 for supplemental personnel from previous PO&Cs

RP.1 Criteria 2 Added new criteria that discuss the need to understand radiological aspects of plant systems.

RP.1 Criteria 3 Added new criteria concerning the importance of documented radiological information.

RP.1 Criteria 4 Added new criteria that discuss supervisors understanding of must-know operating experience.

RP.1 Criteria 5 Replaced criteria 17 from previous PO&Cs

RP.1 Criteria 6 Added new criteria concerning up-dating area postings to reflect current conditions.

RP.1 Criteria 7 Added new criteria that discuss the proper selection and use of instruments.

RP.1 Criteria 8 Added new criteria that provide more detail on monitoring and releasing material.

RP.1 Criteria 9 Added new criteria that discuss tracking and containing leaks from contaminated systems.

RP.1 Criteria 10 Added new criteria that provide more detail on monitoring for airborne radioactivity.

RP.1 Criteria 11 Added new criteria that provide more detail on monitoring for internal and external dose hazards.

RP.1 Criteria 12 Added criteria for RP personnel to monitor closely for changing radiological conditions.


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RP.1 Criteria 13 Added new criteria that provide more detail on posting radioactive material storage areas.

RP.1 Criteria 14 Added criteria that discuss working in accordance with approved procedures and radiological plans.

RP.1 Criteria 15 Added new criteria about RP personnel modeling correct radiological behaviors.

RP.1 Criteria 16 Added new criteria that discuss verifying dosimetry.

RP.1 Criteria 17 Added new criteria that discuss using multiple controls and barriers to prevent unplanned dose events.

RP.1 Criteria 18 Added new criteria discuss maintaining RCAs clean and free of contamination.

RP.1 Criteria 19 Added new criteria discuss RP personnel overseeing and assisting in contamination monitoring.

RP.1 Criteria 20 Added new criteria that discuss the use of using engineering controls to minimize airborne activity.

RP.1 Criteria 21 Added new criteria that discuss the use of using engineering controls to minimize dose to workers.

RP.1-1riteria 22 Added new criteria to discuss maintenance and testing of off-site monitors.

RP.1 Criteria 23 Added new criteria that discuss monitoring, challenging and coaching of radiation workers.

RP.1 Criteria 24 Added new criteria that discussed using approved techniques for decontamination activities.

RP.1 Criteria 25 Added new criteria that discuss RP personnel commitment to radiological safety.


RP.1 Criteria 27 Added new criteria that discuss a questioning attitude of RP personnel.


RP.1 Criteria 29 Added new criteria that discuss identification of radiological issues by RP personnel.

RP.2 RADIATION DOSE CONTROL

This new section combines previous criteria from RP.1 associated with dose control and cumulative dose reduction.

RP.2 Criteria 1 Replaced criteria 8, 14, 19, 20, 21 from previous PO&Cs

RP.2 Criteria 2 Replaced criteria 9, 10, 11 from previous PO&Cs




RP.2 Criteria 6 Replaced criteria 22, 23 from previous PO&Cs


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RP.3 RADIOACTIVE CONTAMINATION CONTROL

This new section combines previous criteria from RP.1 associated with radioactive contamination control.


RP.3 Criteria 2 Added new criteria that discuss measures to prevent PCEs and track/trend.








RP.4 Radioactive Material Control

This new section combines previous criteria from RP.1 associated with radioactive material control.



RP.4 Criteria 3 Added new criteria to discuss use of radioactive waste volume reduction techniques.


RP.4 Criteria 5 Added new criteria to discuss controls for opening radioactive containers outside of RCAs.

RP.4 Criteria 6 Added new criteria to discuss control of radioactive sources.


RP.4 Criteria 8 Added new criteria to discuss controls for radioactive material shipments.

RP.4 Criteria 9 Added new criteria to discuss to limit/control radioactive material stored outdoors.

Industrial Safety

IS.1 Industrial Safety This new Industrial Safety Fundamentals section replaces the principles previously contained in OR.6. These principles serve as descriptors of a group of fundamentals that personnel must implement to achieve high levels of personnel safety.

IS.1 - Criteria 1 Revised old criteria 2 and added requirement for specific objectives.

IS.1 - Criteria 2 Added new criteria to discuss establishment of safety committees.

IS.1 - Criteria 3 Revised previous criteria 4 to discuss management providing the necessary resources, training, and equipment.


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IS.1 - Criteria 4 Revised previous criteria 5 to include setting strategic goals and objectives, communication of those goals and monitoring and coaching by leaders.

IS.1 - Criteria 5 Revised previous criteria 1 to include personnel are accountable for their behaviors and actions.

IS.1 - Criteria 6 Revised previous criteria 1 to split out supplemental personnel. Added new criteria to discuss requirement for communication processes to ensure supplemental personnel understand industrial safety standards and are held accountable to the same standards as utility personnel and include industrial safety requirements in contracts.

IS.1 - Criteria 7 Reworded previous criteria 3

IS.1 - Criteria 8 New criteria that added verbiage about industrial safety being integrated into the station planning process including work control and the engineering design process.

IS.1 - Criteria 9 A new criterion that discusses the need to maintain, inspect, and test safety equipment.

IS.1 - Criteria 10 A new criterion that discusses the need to properly store, maintain and inspect personnel protective equipment.

IS.1 - Criteria 11 A new criterion that discusses the correct selection and use of safety equipment.

IS.1 - Criteria 12 Revised previous criteria 7 to include barriers and warnings.

IS.1 - Criteria 13 A new criterion that discusses the need to select and use appropriate tools for the job.

IS.1 - Criteria 14 A new criterion that requires materials and equipment to be properly stored and controlled to minimize injuries.

IS.1 - Criteria 15 A new criterion that discusses handling and storage of bulk chemicals, compressed gases, corrosive agents, organic chemicals, and cleaning agents.

IS.1 - Criteria 16 Revised previous criteria 8 to split out identification of safety hazards.

IS.1 - Criteria 17 Revised previous criteria 8 to split out reporting of injuries and near misses.

IS.1 - Criteria 18 Revised previous criteria 6 to coach co-workers and correct substandard conditions.

IS.1 - Criteria 19 Added criteria to include performance measures including leading indicators and a means to rapidly trend and correct safety behaviors during periods of high work activity.

IS.1 - Criteria 20 Revised previous criteria 10 to include benchmarking and self-assessments.

IS.1 - Criteria 21 Revised previous criteria 9 to review industry operating experience regularly.


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PO&C Revision Bases Summary – Performance Improvement,

Operating Experience, and Training


Basis for Changes

The new PI.1, PI.2, and PI.3 format reflects the “find, analyze, and fix” model for performance improvement described in INPO 05-005. Operating experience is separated into its own PO&C. The training PO&C revision focuses on “Training to Improve Performance” and “Conduct of Training”.

The following documents were primarily considered:

Manager and senior leader roles and responsibilities established in INPO 09-11, “Excellence in Performance Improvement,” are incorporated into the revised PO&C.

The TR.1 objectives and criteria focus on objectives 1 and 5, with selected, other important criteria cited in ACADs.

PO&C revisions are aligned with WANO PO&C changes.

SOER 10-02 – this was integrated into OE, PI, or TR PO&Cs POs using “engage, thinking” and incorporating the key elements. This institutionalizes the SOER.

SOER 02-04 – revised PI PO&C to capture the need to keep a running list of abnormal conditions or indications that cannot be readily explained.

Integrated Risk Management Principles – the types and methods for assessing and managing risk from this new document were included in TR.1.

AFIs were analyzed to ensure that current PO&Cs addressed the gaps being identified. The analysis concluded that the current PO&Cs covered the gaps being identified. Therefore, no additional PO&Cs were required based on the AFIs being written.

New Definitions:

The PI, OE and TR revisions do not introduce new definitions; however the criteria include LEADER, MANAGER, SUPERVISOR and other organizational definitions introduced in the OR PO&Cs.

Performance Improvement

Objective & Criteria Specific Changes

Basis for Changes

PI.1 Performance Monitoring Renamed from “Self-Assessment and

The new PI.1, PI.2, and PI.3 format reflects the “find, analyze, and fix” model for performance improvement described in INPO 05-005. Criteria from the previous PI.1, PI.2, and PI.3 PO&Cs were binned to support the new format. In addition, manager and senior leader roles and responsibilities established in INPO 09-11,


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Benchmarking,” reformatted & content was updated.

“Excellence in Performance Improvement,” are incorporated into the revised PO&C. All “self-assessment” terminology has changed to “assessment.” This enables a broader spectrum of evaluative techniques by the site to satisfy the goal of understanding and communicating performance.

PI.1 Criteria 1 and 2 Management and senior leader role and responsibility incorporated from INPO 09-11, “Excellence in Performance Improvement.” Reformatted to fit the “find, analyze, and fix” model. Aligned with definitions in OR PO&Cs.

PI.1 Criteria 3- Incorporated from INPO 09-11, “Excellence in Performance Improvement.”

PI.1 Criteria 4 Previously Criteria PI.2-2 Reformatted to fit the “find, analyze, and fix” model

PI.1 Criteria 5 Previously Criteria PI.2-1

PI.1 Criteria 6- Incorporated from INPO 09-11 and INPO 07-007.

PI.1 Criteria 7 SOER 02-04 – revised PI PO&C to capture the need to keep a running list of abnormal conditions or indications that cannot be readily explained.



PI.1 Criteria 10 Previous criteria PI.1-1, also includes insights from INPO 09-11, “Excellence in Performance Improvement.”

PI.1 Criteria 11 Previous criteria PI.1-3, also includes insights from INPO 09-11, “Excellence in Performance Improvement.”

PI.1 Criteria 12 Includes concepts form previous Criteria PI.1-2 and 3 also includes insights from INPO 09-11, “Excellence in Performance Improvement.”

PI.1 Criteria 13 Includes concepts from SOER 10-2.


PI.2 Solution Analysis, Identification, and Planning Renamed from “Corrective Action,” reformatted & content was updated.

The new PI.1, PI.2, and PI.3 format was developed to better reflect the “find, analyze, and fix” model for performance improvement that the industry uses. Criteria from the previous PI.1, PI.2, and PI.3 PO&Cs were binned to support the new format. In addition, manager and senior leader roles and responsibilities established in INPO 09-11, “Excellence in Performance Improvement,” are incorporated into the revised PO&C.


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PI.2 Criteria 1 Management and senior leader role and responsibility incorporated from INPO 09-11, “Excellence in Performance Improvement.”


PI.2 Criteria 3 Includes concepts form previous PI.2 criteria as well as from INPO 09-11, “Excellence in Performance Improvement.”

PI.3 Criteria 4 Includes concepts from previous PI.1 criteria as well as insights from INPO 09-11, “Excellence in Performance Improvement.” And INPO 07-007.

PI.2 Criteria 5 and 6 Includes previous criteria from PI.2 as well as insights form INPO 09-11, “Excellence in Performance Improvement.” Reformatted to fit the “find, analyze, and fix” model

PI.2 Criteria 7 Incorporated from INPO 09-11


PI.2 Criteria 9 Includes insight from INPO 09-11.

PI.3 Solution Implementation Renamed from “Operating Experience,” reformatted & content was updated. Operating Experience (OE.1) became a stand-alone PO&C.

The new PI.1, PI.2, and PI.3 format was developed to better reflect the “find, analyze, and fix” model for performance improvement that the industry uses. Criteria from the previous PI.1, PI.2, and PI.3 PO&Cs were binned to support the new format. In addition, manager and senior leader roles and responsibilities established in INPO 09-11, “Excellence in Performance Improvement,” are incorporated into the revised PO&C.

PI.3 Criteria 1 Incorporated from INPO 09-11, “Excellence in Performance Improvement.”



PI.3 Criteria 4 Criteria 4- Previously Criteria PI.2-8 also includes insight from INPO 09-11

PI.3 Criteria 5 Includes insight from INPO 09-11


PI.3 Criteria 7 Previously Criteria PI.2-10 and PI.2-11

PI.3 Criteria 8 Incorporated insights from INPO 09-11

PI.3 Criteria 9 Previously Criteria PI.2-8 and incorporated insights from INPO 09-11


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Operating Experience

OE.1 Operating Experience Created as an updated, stand-alone PO&C and included insight from SOER 10-2.

Operating experience was separated into its own PO&C as a result of the reorganization and formatting of PI.1, PI.2, and PI.3. In addition, specific criteria proposed by the Events Analysis department were added to address identified weaknesses in operating experience reviews, responses, and processing.

Criteria Specific Changes

OE.1 Criteria 1- Incorporated from INPO 09-11

OE.1 Criteria 2- Incorporated from INPO 09-11, includes must-know OE from SOER 10-2. Also includes elements of Criteria PI.3-1

OE.1 Criteria 3- Previously Criteria PI.3-7 and insights from INPO 09-11

OE.1 Criteria 4- Previously Criteria PI.3-4 and 3-5.

OE.1 Criteria 5- Previously Criteria PI.3-2

OE.1 Criteria 6- Includes several elements from previous criteria PI.3 and includes insights from INPO 09-11





OE.1 Criteria 11- Includes elements form previous Criteria PI.3-9

Training

TR.1 Training Reformatted and updated to specifically address “Conduct of Training” and “Training to Improve Performance” criteria and selected management accountability criteria. All other previous training criteria were removed.

The PIL and Training and Accreditation departments initiated a collaborative effort to better define which criteria each organization is equipped to evaluate; and should be responsible for evaluating in their specific roles. The outcome for PIL is that plant evaluation teams are realistically capable of, and focus on, evaluating criteria associated with “Conduct of Training” and “Training to Improve Performance.” This was the focus of the revision to the training PO&Cs and the criteria were divided between these two categories. The remaining training criteria that were removed by the revision are evaluated by the Training and Accreditation department and their accreditation teams. The PO&C were revised to appropriately reflect these responsibilities for the plant evaluation teams.


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In addition, specific criteria that reflect management roles and responsibilities were left or added to the training PO&Cs.

TR.1 Criteria 1-10- This section incorporated criteria from ACAD 02-001 (Rev. 0), Accreditation Objectives and Criteria, Objective 1 – Training For Performance Improvement.

TR.1 Criteria 9 – Includes concepts from INPO 11-008 Excellence in Integrated Risk Management

TR.1 Criteria 11-16- This section incorporated criteria from ACAD 02-001 (Rev. 0), Accreditation Objectives and Criteria, Objective 5 – Conduct Of Training and Trainee Evaluation.


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PO&C Revision Bases Summary – Fire Protection


Basis for Changes

Overall: Fire Protection (FP) section was significantly expanded from 8 criteria in the 2005 version to 36 criteria. The greater amount of detail is more consistent with the 2005 WANO Fire Protection performance objectives.

The expanded PO&C better define the standards of excellence and add greater detail for criteria. INPO 11-004, Guideline for Excellence for Fire Protection program Implementation, was used to develop the improved content. Lessons learned from INPO fire protection review visits were also considered. Criteria have been subdivided into eight sections for better clarity, as follows:

Organization and Program, Fire Prevention, Fire Response, Design and Equipment, Personnel Knowledge, Hazard Analyses, Assessments, and Safe Shutdown


FP.1 – Criteria 1 to 4 Expands on previous FP.1 criteria 1 and 2 regarding program management , standards, oversight, and resources

FP.1 – Criteria 5 to 9 Expands on previous FP.1 criteria 3 regarding ignition sources and fire prevention controls

FP.1 – Criteria 10 to 15 Expands on previous FP.1 criteria 1 and 7 regarding response to fires. Adds criteria on use of fire drills, fire fighter personnel fundamental knowledge, and interface with off-site resources.

FP.1 – Criteria 16 to 21 Expands on previous FP.1 criteria 5 and 6 regarding design features and equipment. Added details on periodically verifying fire mitigation capability, minimizing potential for fires to spread, assessing aggregate impact of impairments, establishing preventive maintenance, and addressing aging of equipment.

FP.1 – Criteria 22 to 25 Expands on previous FP.1 criteria 7 and 8 regarding knowledge and training.

FP.1 – Criteria 26 to 30 New criteria that discuss fire hazard and risk analyses, including their design bases, and maintaining equipment per requirements.

FP.1 – Criteria 31 to 32 New criteria that discuss periodic program assessments and monitoring of activities.

FP.1 – Criteria 33 to 36 New criteria to address safe shutdown of the plant following a fire event, including overall strategies, validation on the feasibility of actions, operator training, and equipment.


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PO&C Revision Bases Summary – Emergency Preparedness


Basis for Changes

Overall: Emergency Preparedness (EP) PO&C are significantly expanded, increasing from one to three objectives, and from nine to 62 criteria. The criteria are grouped in ten categories within the three objectives.

The expanded PO&C better define the standard of excellence by increasing the scope of emergency preparedness fundamentals and addressing performance gaps identified through review visits and plant evaluations. The revision also incorporates lessons learned from recent industry events. The new revision more closely aligns EP PO&Cs with objectives and criteria contained in other functional and cross-functional areas. The revision aligns with proposed changes to the WANO PO&C, which were reduced from eight objectives and over 100 criteria. The combined revision establishes a global standard for emergency preparedness.

Objective EP.1 EMERGENCY PLANNING LEADERSHIP This objective was added to expand and enhance the leadership criteria in the current PO&C. It was revised to be one of three EP objectives, and provides an enhanced focus on leadership’s role in EP.

The new objective is focused on leadership of emergency preparedness. It was created by revising and adding criteria to align the organization through high standards and expectations. The new objective addresses common gaps identified in the level of support provided by station managers for EP. It includes new criteria to address relationships with offsite response organizations. Criteria are grouped in two categories:

Management and Leadership

Emergency Response Organization and Interfaces

Objective EP.2 EMERGENCY PREPAREDNESS This revised objective includes the bulk of the criteria for EP. It expands existing criteria for developing and maintaining organizational and individual readiness to respond to a wide spectrum of events.

New criteria are added to address identified performance gaps, to incorporate lessons learned from recent events, and to prepare organizations to respond to a wide range of emergencies. Criteria are grouped in five categories:

Emergency Response Plan, Process, and Procedure Development

Emergency Response Organization Staffing, Training, and Qualification

Emergency Preparedness Drills and Exercises

Facilities and Equipment

Emergency Preparedness Staff


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Objective EP.3 EMERGENCY RESPONSE This new objective expands performance standards for executing emergency response actions.

Revised criteria raise standards for performing emergency response actions. New criteria address performance gaps identified in review visits, plant evaluations, and responses to actual emergencies. Criteria are grouped in three categories:

Initial Response

Emergency Response Leaders

Emergency Response Actions


EMERGENCY PLANNING LEADERSHIP EP.1 – Criteria 1

Revised criteria EP.1-1 is associated with station leaders establishing high standards and expectations for emergency preparedness and response. This is based on industry focus areas and gaps identified in EP review visits.

EP.1 – Criteria 2 New criteria for station leaders to establish and reinforce high standards for emergency preparedness by actively engaging in and providing oversight for EP activities. The criteria add maintaining an effective relationship with offsite authorities responsible for emergency actions. These are based on gaps identified in review visits, and reflect standards established in INPO 08-007, Emergency Preparedness Manual.

EP.1 – Criteria 3

Established senior managers’ responsibility for ensuring emergency response personnel are appropriately trained and qualified. These are based on gaps identified in review visits.

EP.1 – Criteria 4 Defines line manager responsibilities for emergency response personnel qualifications and use of training to improve performance. These are based on gaps identified in review visits, industry events, and are consistent with criteria added in other functional areas.

EP.1 – Criteria 5 Establishes a low threshold for identification of issues and use of problem identification and resolution processes. This is based on industry focus areas and gaps identified in review visits. It is consistent with criteria provided in other functional areas.

EP.1 – Criteria 6 Establishes standards for maintaining emergency response equipment. This reflects standards established in INPO 10-007, Equipment Important to Emergency Response, and addresses ongoing industry performance gaps.

EP.1 – Criteria 7 Revised criteria EP.1-1 to enhance actions for assigning emergency roles and responsibilities. This reflects gaps identified in review visits and industry events.


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EP.1 – Criteria 8 New criteria for ensuring adequate on-shift resources are assigned for emergency response actions. These are based on industry focus areas and gaps identified in review visits.

EP.1 – Criteria 9 New criteria for establishing clear priorities for completion of emergency actions. Criteria are added to ensure the ability to complete the assigned actions as necessary to mitigate a transient. These are based on gaps identified in review visits and lessons learned from actual events.

EP.1 – Criteria 10 New criteria for ensuring adequate resources are assigned for augmenting on shift personnel and implementing emergency plans and procedures. These are based on gaps between existing INPO guidelines and industry planning standards.

EP.1 – Criteria 11 New criteria for ensuring emergency response personnel are able to carry out emergency duties in prolonged events. These are based on lessons learned from industry events.

EP.1 – Criteria 12 New criteria for station managers’ coordination of response plans with offsite response organizations. These are based on gaps between existing INPO standards and other industry standards.

EMERGENCY PREPAREDNESS EP.2 – Criteria 1

Revised criteria EP.1-2 and EP.1-3 add flexibility to emergency plans and procedures and the ability to respond to a wide range of events. These are based on lessons learned from industry events.

EP.2 – Criteria 2 New criteria that establishes excellence in radiological assessment capabilities. This is based on lessons learned from industry events.

EP.2 – Criteria 3 New criteria for clear guidance regarding modified and abbreviated work practices that are applied in emergencies, including specifying the authority for invoking modified practices and for informing workers of the changes. These are based on gaps identified in review visits.

EP.2 – Criteria 4 New criteria for alternate methods of performing key response functions. These are based on gaps identified in review visits and lessons learned from industry events.

EP.2 – Criteria 5 Revised criteria EP.1-4 for developing processes to support response to prolonged events. These are based on lessons learned from industry events.

EP.2 – Criteria 6 New criteria for maintaining and updating emergency plans and procedure. These are based on gaps between existing INPO criteria and industry planning standards, and are consistent with criteria established for other functional areas.


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EP.2 – Criteria 7 New criteria to drive use of existing performance improvement tools, including assessments and benchmarking, to improve EP performance. This is based on EP review visit results and is consistent with standards of excellence in other areas.

EP.2 – Criteria 8 Revised criteria EP.1-5 enhance standards for maintaining, controlling, and ensuring access to emergency response documents. These are based on gaps identified in review visits and on lessons from industry events.

EP.2 – Criteria 9 New criteria that ensures adequate information is available to responders even without power. This is based on lessons learned from industry events.

EP.2 – Criteria 10 Revised criteria EP.1-9 to establish standards for training and qualification of emergency response personnel. These are based on gaps identified in review visits and plant evaluations, and on lessons learned from industry events.

EP.2 – Criteria 11 New criteria establish standards for training content and development. These are based on existing INPO PO&C for training programs, and on standards established in INPO 09-006, Guidelines for Training and Qualification of Emergency Response Organization Personnel.

EP.2 – Criteria 12 New criteria to define needed knowledge level for emergency responders. This is based on lessons learned from industry events and review visit results.

EP.2 – Criteria 13 New criteria for identifying and resolving emergency preparedness performance gaps, specifically through improvements to training programs. These are based on existing INPO PO&C for training programs, and on standards established in INPO 09-006, Guidelines for Training and Qualification of Emergency Response Organization Personnel.

EP.2 – Criteria 14 New criteria to establish standards for excellence in drill objectives and content. This is to focus drills on preparing emergency response organizations to respond to events. This criteria is based on observations from EP review visits.

EP.2 – Criteria 15 Revised criteria EP.1-8 enhance the standards for drills and exercises to include response to events ranging from minor events to severe, beyond-design basis accidents. These are based on lessons learned from industry events.

EP.2 – Criteria 16 Revised criteria EP.1-8 enhance standards for critiquing and evaluating drill and exercise performance and processes. Criteria also address resolution of drill and exercise results. These are based on gaps identified in review visits, and gaps between existing INPO criteria and industry planning standards.


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EP.2 – Criteria 17 New criteria for engaging off-site response organizations in station drills and exercises. These are based on gaps between current INPO criteria and industry planning standards.

EP.2 – Criteria 18 New criteria for developing emergency drill scenarios and evaluation criteria. These are based on the standards in INPO 08-007, Emergency Preparedness Manual.

EP.2 – Criteria 19 New criteria for emergency response personnel participation in drills and exercises. These are based on gaps identified in review visits and the standards in INPO 08-007, Emergency Preparedness Manual.

EP.2 – Criteria 20 New criteria for emergency drill controllers and evaluators. These are based on gaps identified in review visits, and the standards in INPO 08-007, Emergency Preparedness Manual.

EP.2 – Criteria 21 Revised criteria EP.1-5 enhance the standards for emergency response facilities and supplies and the ability to support response to a range of events from minor events to prolonged, severe accidents. These are based on lessons learned from industry events.

EP.2 – Criteria 22 New criteria for alternate emergency response facilities, including facility capabilities and standards for periodic testing in drills and exercise. These are based on lessons from industry events.

EP.2 – Criteria 23 New criteria for maintaining equipment important to emergency response. These are based on gaps identified in review visits and industry focus areas, on lessons learned in industry events, and standards established in INPO 10-007, Equipment Important to Emergency Response.

EP.2 – Criteria 24 New criteria associated with equipment maintained by off-site response organizations. This is based on lessons learned and corrective actions associated with industry events.

EP.2 – Criteria 25 New criteria for restoring equipment important to emergency response that is out of service. These are based on gaps identified in review visits and industry focus areas, on lessons learned in industry events, and standards established in INPO 10-007, Equipment Important to Emergency Response.

EP.2 – Criteria 26 New criteria for establishing compensatory measures for equipment important to emergency response that is out of service. These are based on gaps identified in review visits and industry focus areas, on lessons learned in industry events, and standards established in INPO 10-007, Equipment Important to Emergency Response.


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EP.2 – Criteria 27 New criteria to define expectations for timely notification of issues with equipment important to emergency response. This is based on observed gaps and guidance established in INPO 10-007, Equipment Important to Emergency Response.

EP.2 – Criteria 28 New criteria for providing reliable emergency communications systems and processes for notifying station and emergency personnel of emergencies. These are based on gaps identified in review visits, and on lessons learned from industry events.

EP.2 – Criteria 29 Revised criteria EP.1-9 enhance standards for emergency preparedness staff training and qualifications. These are based on gaps identified in review visits, gaps between current INPO criteria and industry planning standards, and the standards in INPO 08-007, Emergency Preparedness Manual. These are consistent with criteria established in other functional areas.

EP.2 – Criteria 30 New criteria for emergency preparedness staff to establish effective relationships with off-site response organizations. These are based on gaps between current INPO criteria and industry planning standards.

EP.2 – Criteria 31 New criteria for emergency response personnel to work effectively within the nuclear organization, and to improve line ownership of the emergency preparedness program. These are based on the standards in INPO 08-007, Emergency Preparedness Manual.

EP.2 – Criteria 32 New criteria for supporting emergency response planning functions with qualified technical experts. These are based on gaps between current INPO standards and industry planning standards.

EP.2 – Criteria 33 New criteria focused on performance improvement through EP staff using established improvement techniques. This is based on gaps observed during EP review visits, and is consistent with criteria established in other areas.

EP.2 – Criteria 34 New criteria for qualification of emergency preparedness staff. These are based on the INPO criteria established for other functional areas, and on standards in INPO 08-007, Emergency Preparedness Manual.

EMERGENCY RESPONSE EP.3 – Criteria 1

New criteria for prompt, accurate emergency classification, and support for this process by station personnel. These are based on gaps identified in review visits and lessons from industry events.


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EP.3 – Criteria 2 New criteria for prompt, accurate, and complete notifications of on-site and off-site personnel and organizations. These are based on gaps identified in review visits and on lessons learned from industry events as described in IER L2-11-39, Lack of Timely Emergency Response Organization and Emergency Response Facility Activation.

EP.3 – Criteria 3 New criteria for prompt activation of emergency response facilities. These are based on lessons learned from industry events as described in IER L2-11-39, Lack of Timely Emergency Response Organization and Emergency Response Facility Activation.

EP.3 – Criteria 4 New criteria for pre-emptive staging of emergency response personnel for anticipated events. These are based on lessons learned from industry events.

EP.3 – Criteria 5 Revised criteria EP.1-1 and EP.1-9 to add standards for clearly designating authority of on-shift emergency response leaders. These are based on lessons learned from industry events.

EP.3 – Criteria 6 Revised criteria EP.1-3 for emergency response leader oversight functions. These are based on gaps identified in review visits, on industry focus areas, and on lessons from industry events.

EP.3 – Criteria 7 Revised criteria EP.1-3 for emergency response leader command and control functions. These are based on gaps identified in review visits and gaps between current INPO standards and industry planning standards.

EP.3 – Criteria 8 Revised criteria EP.1-9 add standards for emergency response leaders transitioning from response to recovery mode. This is based on gaps between current INPO standards and industry planning standards.

EP.3 – Criteria 9 Revised criteria EP.1-3 enhance standards for emergency response actions to properly prioritize and maintain critical safety functions. This is based on gaps identified in review visits and on lessons learned from industry events.

EP.3 – Criteria 10 New criteria for implementing modified and abbreviated work practices in emergencies, including authorizing and communicating changes to workers. These are based on gaps identified in review visits.

EP.3 – Criteria 11 Revised criteria EP.1-6 and EP.1-7 to focus on emergency responder responsibilities for monitoring and reporting status and changes in emergency conditions. These are based on gaps between current INPO standards and industry planning standards.

EP.3 – Criteria 12 New criteria for briefing, deploying, and tracking emergency response teams. These are based on gaps identified in review visits.


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EP.3 – Criteria 13 Revised criteria EP.1-6 to enhance the focus on processes for identifying and communicating protective action recommendations. These are based on the standards in INPO 08-007, Emergency Preparedness Manual, and on industry planning standards.

EP.3 – Criteria 14 Revised criteria EP.1-4 to focus on implementing coordinated response actions with off-site authorities. This is based on gaps between current INPO standards and industry planning standards.

EP.3 – Criteria 15 Revised criteria EP.1-7 enhances the focus on providing accurate information to off-site organizations in an emergency. This is based on gaps between current INPO standards and industry planning standards.

EP.3 – Criteria 16 Revised criteria EP.1-7 enhances the focus on providing accurate emergency information to the public and news media. This is based on gaps between current INPO standards and industry planning standards.


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PO&C Revision Bases Summary – Corporate Areas


Basis for Changes

Overall: The Corporate PO&Cs were revised to more closely align with the functions of “governance, oversight, support, and perform” implemented by many utilities. The previous CO.1 Performance Objective, Leadership and Management, was replaced with two objectives, CO.1 Leadership and CO.2 Governance. In addition, the previous objective on Oversight and Monitoring was split into two objectives to better distinguish line management oversight and independent oversight activities.

INPO 11-007, Principles for Strong Governance and Oversight of Nuclear Power Organizations, was issued in late 2011 and was the result of significant industry input and collaboration. The concepts and content of that document were the basis for the majority of the changes to the PO&C. Other revisions were generally the result of changes in industry practices, and insights from INPO corporate evaluation results.

Objective & Criteria

Basis for Changes

CO.1 CORPORATE LEADERSHIP - The corporate organization provides leadership for the nuclear stations to continuously improve and sustain high levels of safe, reliable operation and emergency response.

INPO 05 – 003 Performance Objective and Criteria (CO.1 Corporate Leadership and Management) separated to focus on leadership in this objective. Leadership aspects of INPO 11-007 Principles for Strong Governance and Oversight also added to the CO.1 objective.

1. The chief executive officer communicates a clear, unambiguous message that nuclear safety is the highest priority.

INPO 05 – 003 Performance Objective and Criteria (CO.1 Corporate Leadership and Management)

2. The chief executive officer and the chief nuclear officer (or equivalent), foster open communications to promote a full understanding of all information pertaining to nuclear station and corporate operations.

INPO 11-007 Principles for Strong Governance and Oversight of Nuclear Power Organizations.

3. Corporate leaders routinely and effectively communicate information regarding the safety and reliability of the nuclear station to key stakeholders, including regulators, the board of directors, station personnel, and the public.


4. Corporate leaders foster commitment to the organization’s governance model at the corporate and station level.


5. Corporate leaders monitor, communicate, and demonstrate, through their behaviors and

INPO 05 – 003 Performance Objective and Criteria (CO.1 Corporate Leadership and


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actions, the importance of corporate and station nuclear safety culture. Identified nuclear safety culture weaknesses are addressed with a sense of urgency.

Management)

6. Executive leadership, ownership, and involvement reinforce accountability in each functional area as well as reinforcing the importance of maintaining the governance and oversight roles while concurrently supporting station operations.


7. Corporate leaders remain knowledgeable of rising industry standards, significant operating experience, emerging regulatory issues, and other external factors. They ensure these factors are considered in business planning, goal-setting, improvement initiatives, and key performance measures. Leaders coordinate station and corporate responses to major external issues.


8. Corporate leaders actively engage the workforce to stimulate innovation and develop continuous improvement initiatives. A means exists to encourage, monitor, and address employee feedback on business initiatives.


9. Corporate leaders ensure that the nuclear station and the corporate staff have the necessary resources and that the resources are applied to achieve and sustain safe, reliable plant operations. Resource needs, such as funding, staffing, training, equipment, repair parts, and information, are allocated to support emergent and long-range station issues.


10. Corporate leaders focus the corporate and station staffs on resolving important emergent and long-standing equipment issues. Owners are designated to resolve issues, and progress in the resolution of equipment problems is monitored.


11. Corporate leaders focus the corporate and station staffs on successful recovery of stations that have experienced significant declines in operational performance.


12. Corporate leaders establish high standards of emergency preparedness performance and align the organization to manage emergencies, mitigate plant damage, and protect the health

Fukushima Lessons Learned


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and safety of utility personnel and the public.

13. Corporate leaders are engaged in developing future leaders and ensure the succession planning process enables the organization to fill critical positions and develop a group of qualified candidates to meet changing organizational priorities.

INPO 11-007 Principles for Strong Governance and Oversight of Nuclear Power Organizations. INPO 05 – 003 Performance Objective and Criteria (CO.1 Corporate Leadership and Management)

14. Corporate leaders take active roles in critical industry-wide support organizations and forums.


CO.2 CORPORATE GOVERNANCE - Corporate governance provides the needed organizational structures, policies, processes, and programs to establish high standards for the operation, maintenance, and organizational support of the nuclear stations.

Some criteria that addressed governance in INPO 05 – 003 Performance Objective and Criteria CO.1 were retained in this objective. Governance aspects of INPO 11-007 Principles for Strong Governance and Oversight of Nuclear Power Organizations also added to this CO.2 objective.

1. A documented and controlled operating or management model defines the corporation’s fundamental objectives, typically through the mission, vision, values, guiding principles, and fundamentals of the organization.


2. A well-defined organizational structure implements the operating model to support proper governance, oversight, and execution of activities that support nuclear plant operation.


3. The chief executive officer holds the chief nuclear officer (or equivalent) accountable for all matters related to nuclear station performance.


4. The chief nuclear officer (or equivalent) holds station management accountable for the safe and reliable operation of the nuclear station.


5. Station line management is accountable and responsible for operational decisions and safe and reliable operation of the nuclear stations.


6. A document hierarchy and operating guidelines are in place to develop and implement management controls and to ensure consistency among the station organizations. The organization establishes a clear policy on the



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required level of standardization and on the approval authority for deviations.

7. Roles, responsibilities, and authorities of corporate and station organizations, functional area peer group members, and functional area managers are defined to ensure accountability at every level and to enhance the organizational capacity to resolve problems.


8. The decision-making authority of functional area managers is defined to maintain consistency with corporate policies and standards.


9. Roles and responsibilities for the continuity of corporate business operations are clearly established for significant event recovery scenarios.

10. Interfaces with corporate organizations responsible for functions that affect the nuclear

stationsuch as transmission and distribution, grid operations, human resources, and business

planningare clearly established and understood. Interactions among operating companies, co-owners, asset owners, and service alliances ensure that the nuclear station receives appropriate support.


11. Corporate policy clearly defines unacceptable risk conditions and includes procedures to minimize and manage risk. Integrated risk considerations include, but are not limited to, nuclear, radiological, industrial safety, and environmental safety. Specifically: • Nuclear risk relating to management of the

reactor core and barriers to the release of radioactivity is understood and is mitigated to the extent practicable; and residual risk is managed to achieve safe, reliable nuclear plant operation.

• The risks associated with low-probability but high-consequence events are considered.

• Corporate processes identify short-term operational risk, provide a means to identify off-normal situations, and identify long-term risk over the life of the nuclear plants.

INPO 05 – 003 Performance Objective and Criteria (CO.1 Corporate Leadership and Management) INPO 11-007 Principles for Strong Governance and Oversight of Nuclear Power Organizations. INPO 12-008 Excellence in Integrated Risk Management


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• Accountability for minimizing and managing risk is clearly defined and includes the accountability for short-term operational risk and long-term risk.

12. Strategic initiatives are supported by business planning and goal-setting. Measurable goals, with a comprehensive set of indicators and targets, drive continuous improvement and reflect the highest levels of industry performance.


13. Corporate managers develop long-range strategies in collaboration with nuclear station personnel. Corporate and station business plans are integrated and are prioritized to maintain focus on safe, reliable operation of the nuclear plants.


14. Business plans consider functional area performance gaps based on specific performance measures. Desired outcomes with associated performance indicators for functional areas, including corporate functions, are well defined.


15. Well-defined management processes are established for business, policy, and organizational changes. The scope, pace, resource requirements, and effectiveness measures for change initiatives are managed to sustain and improve performance in plant operations.


16. A clearly defined process is used to identify and develop a corporate response to early signs of performance decline.


17. Incentive and rewards programs promote nuclear safety.


18. Appropriate and timely adjustment of goals and expectations supports continuous improvement at the stations, with a focus on nuclear safety.


19. Corporate managers embrace continuous improvement through activities such as self-assessments, corrective actions and training.


20. Corporate managers with line responsibility for training ensure the development, training, and qualification of corporate and station personnel.



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For utilities associated with the National Academy for Nuclear Training, actions are taken to maintain program accreditation.

21. Corporate managers establish an effective program to ensure that learning from internal and external operating experience is actively promoted and sustained to prevent similar events at their stations.


22. Personnel support and participate in industry activities and benchmarking to understand, promote, and establish best practices. Formal guidance is used to coordinate and focus these efforts to achieve results.


23. A corporate emergency response organization and response plan are in place; and training is provided to manage significant events, including natural disasters that may affect multiple stations. (Specific aspects listed.)

INPO 11-007 Principles for Strong Governance and Oversight of Nuclear Power Organizations. Fukushima Lessons Learned

CO.3 CORPORATE OVERSIGHT AND MONITORING - Corporate management oversight and monitoring are used to strengthen safety and improve performance. Plant safety and reliability are under constant scrutiny through techniques such as assessments, performance indicators, and periodic management meetings.

INPO 05 – 003 Performance Objective and Criteria (CO.2 Corporate Oversight and Monitoring) divided to differentiate the line corporate monitoring responsibilities from the independent oversight role now described in CO.4 Corporate Independent Oversight.

1. The chief executive officer monitors and/or receives briefings on performance indicators, key independent internal and external assessments, and key issues that affect the nuclear station.

INPO 05 – 003 Performance Objective and Criteria (CO.2 Corporate Oversight and Monitoring)

2. The chief nuclear officer (or equivalent), corporate managers, and corporate personnel directly responsible for nuclear activities are personally involved in overseeing, monitoring, and assessing those activities within the corporate organization and in support of the nuclear station. Station assessment activities are coordinated with corporate assessment activities to identify broad, organization-wide issues.


3. Information from various sources, such as performance indicators, self-assessments and independent assessments, quality assurance reports, and corrective action trends, is



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integrated and focused to identify and allow early correction of adverse performance of the nuclear station. This information provides an objective view of performance and is routinely provided to corporate leaders, managers, and board members. Desired outcomes and metrics are clearly defined to reflect industry standards for each functional area.

4. Corporate leaders and managers monitor station and corporate performance through a variety of activities. For example, they interact with workers, attend station performance review meetings, participate in peer group activities, monitor performance indicators to detect adverse trends, review initiatives to ensure timely completion, and conduct first-hand assessments of station performance through frequent visits.


5. Periodic reviews, such as chief nuclear officer (or equivalent) meetings with station management teams and/or corporate personnel, are used as forums to better understand and challenge performance that does not meet expectations and to determine if corporate support is needed.


6. A well-defined process is in place for communicating performance gaps that require higher-level executive attention. Corporate leaders encourage the escalation of performance gaps that are not resolved at lower levels of the organization. Long-standing or repetitive issues are escalated as appropriate and are resolved.


7. Functional area and cross-functional performance trends are compared to industry and peer group standards and are used to independently assess and analyze performance.


8. Assessments are used to review and evaluate the adequacy and effectiveness of corporate and station programs, processes, and activities. Industry peers participate in assessments when appropriate, particularly those assessments that are broad in scope.



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9. The corporate staff ensures performance gaps are resolved and increases monitoring in response to declining performance or when performance assessments from diverse inputs conflict.


10. Action plans are reviewed to address gaps between governance standards and actual performance.


11. The overall effectiveness of corporate governance is periodically assessed, and corrective actions are taken for performance shortfalls.


CO.4 CORPORATE INDEPENDENT OVERSIGHT - Independent oversight provides the chief nuclear officer (or equivalent) and senior corporate leaders—up through the board of directors— with an ongoing perspective of performance at the nuclear stations and in the corporate organization compared to the industry, with a principal focus on nuclear safety, plant reliability, and emergency response effectiveness.

INPO 05 – 003 Performance Objective and Criteria (CO.2 Corporate Oversight and Monitoring) divided to differentiate the independent oversight role from the line corporate monitoring responsibilities now described in CO.3 Corporate Oversight and Monitoring.

1. Responsibilities, accountabilities, and authorities for those providing independent oversight are clearly defined, understood, and implemented.


2. Independent nuclear oversight managers establish high standards of performance for the oversight organization to provide effective monitoring and assessment.


3. Independence is maintained between independent oversight personnel and line management. The station-level independent oversight organization reports directly to a corporate executive or senior manager. Independent oversight does not usurp line management authority.


4. Effective audits and assessment activities are performed to aid management by identifying problems, potential causes, and insights.


5. The independent oversight organization assesses organizational effectiveness, as well as the effectiveness of the corporate support organization, to achieve high industry standards.



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This includes observing individual and organizational behaviors and providing insights to management on the causes of behavior performance issues.

6. The organization’s use (at all levels) of the corrective action program, self-assessment and benchmarking programs, operating experience, and the training program is assessed to identify and correct problems, compare actual performance to high industry standards, and achieve continuous improvements.


7. Independent audits and assessments are planned and performed in accordance with quality assurance program requirements. The oversight organization is staffed appropriately; and oversight personnel have the knowledge, skills, and experience necessary to identify performance shortfalls and are qualified in accordance with utility quality assurance program requirements.


8. Performance issues are communicated to line management, and appropriate management action is tracked to completion or is escalated by the independent oversight organization if not properly addressed.


9. A process is in place to assess the effectiveness of independent oversight activities.


10. Some personnel from outside the utility who are highly experienced in nuclear plant operations are involved in the independent oversight process, to ensure effective input to senior corporate leaders from outside the line organization.


11. The chief executive officer, the chief nuclear officer (or equivalent), and the board of directors receives comprehensive information, including performance trends and input from the independent oversight process. This information reflects station- and fleet-level performance relative to the nuclear industry, with a principal focus on nuclear safety.


12. The board of directors includes or has direct access to independent personnel with the

INPO 05 – 003 Performance Objective and Criteria (CO.2 Corporate Oversight and


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expertise necessary to understand the special and unique nature of nuclear operations.

Monitoring)

13. The board of directors is informed of changes in low-probability, high-consequence nuclear risk issues.

INPO 12-008 Excellence in Integrated Risk Management

14. Board and external oversight committee members periodically visit the nuclear stations to directly communicate with station personnel and to observe activities and plant conditions.


15. Performance issues are communicated to corporate and station line management. Corrective actions are tracked to completion.


CO.5 CORPORATE SUPPORT AND PERFORMANCE - Corporate managers and staff support the nuclear stations in matters related to safe and reliable plant operation by providing resources and services to organizations that execute or perform activities at the stations.

INPO 05 – 003 Performance Objective and Criteria (CO.3 Corporate Support) enhanced with aspects of INPO 11-007 Principles for Strong Governance and Oversight of Nuclear Power Organizations to emphasize the oversight role when the corporate staff works in support and perform.

1. Corporate support is provided in areas that require unique technical expertise, for emergent issues beyond the technical capabilities or resources of the stations, and to augment the nuclear station resources for special issues or projects.

INPO 05 – 003 Performance Objective and Criteria (CO.3 Corporate Support)

2. When transitioning between support and perform/execute activities, corporate personnel recognize when they have assumed a perform role and clearly communicate their role to station managers. In a perform/execute role, the corporate personnel manage and provide resources, schedules, scope, and detailed procedures to implement plans and to deliver quality work products.


3. When assuming a perform/execute role, corporate managers ensure appropriate oversight is maintained in accordance with the governance model.


4. Corporate services groups, the corporate staff, and nuclear station staffs exhibit behaviors that support a strong nuclear safety culture. They


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understand station issues, coordinate and communicate effectively and exhibit teamwork to address these issues.

5. Corporate support groups, the corporate staff, and nuclear station staffs coordinate and communicate effectively and exhibit teamwork to address issues that affect the station.


6. Corporate managers and personnel assist in solving problems, as needed, and critically challenge assumptions and decisions that can affect nuclear safety.


7. Corporate personnel have the experience, education, and training to perform their work proficiently.


8. The supply chain supports the station to maintain and repair plant equipment during on-line and outage periods. Parts and materials are procured to meet quality and design specifications, and they are controlled and stored to maintain traceability and quality.

INPO 12-013 Performance Objectives and Criteria (ER.3 Equipment Life Cycle Management)

9. Corporate managers establish, communicate, and implement a structured project management process to select, plan, and implement projects with predictable quality, scope, schedule, and cost performance.

INPO 12-013 Performance Objectives and Criteria (PM.1 Project Management)

10. The corporate staff employs controls to maintain and protect the configuration and operation of digital assets that may have special requirements, including those relating to cyber security.

INPO 12-013 Performance Objectives and Criteria (CM.2 Configuration Management)

11. High expectations and standards for engineering activities are established, communicated, and reinforced. Personnel are held accountable for implementing these standards. Shortfalls in meeting expectations are evaluated and addressed promptly. (Specific aspects listed.)

INPO 12-013 Performance Objectives and Criteria - Reinforce the corporate aspects of engineering excellence.

12. Corporate leaders set and reinforce high expectations and standards for training activities. Station managers are held accountable for implementing these standards. Shortfalls in meeting expectations are evaluated and addressed promptly. Specific (aspects listed.)

INPO 12-013 Performance Objectives and Criteria - Reinforce the corporate aspects of training excellence.


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CO.6 CORPORATE HUMAN RESOURCES - Corporate human resource personnel, in partnership with line managers, anticipate nuclear station personnel needs and work with line managers to recruit and retain sufficient knowledgeable and skilled personnel to support safe, reliable operation of the nuclear station and emergency response.

INPO 05 – 003 Performance Objective and Criteria (CO.4 Corporate Human Resources) expanded and enhanced to include specific criteria for leadership assessments.

1. Corporate leaders are engaged in developing future leaders and ensure the succession planning process enables the organization to fill critical positions and develop a group of qualified candidates to meet changing organizational priorities.

INPO 05 – 003 Performance Objective and Criteria (CO.4 Corporate Human Resources)

2. Future staffing needs are identified and tracked through an ongoing workforce planning process. A long-term operations workforce plan is in place to maintain sufficient operations staffing at the nuclear stations. Timely action is taken to fill vacancies when they occur.


3. Individual and team leadership assessments and team-building activities are used to improve leader skills and to inform succession planning.

4. New or transitioning leaders undergo an integration process that includes an understanding of the organization’s culture, leadership behavior expectations, and operating model.

5. High-potential candidates are identified for preparation as future station and corporate leaders.


6. The potential effects of organizational changes and staff reductions are considered and addressed before such changes are initiated.


7. Strategies for knowledge transfer and retention are executed to preserve unique knowledge and skills that could be lost through attrition or planned staffing changes.


8. Expertise is provided to establish and maintain effective workforce relations.

CO.7 – CORPORATE COMMUNICATIONS - Communications managers and personnel, through direct and ongoing interactions with corporate

INPO 05 – 003 Performance Objective and Criteria (CO.5 Corporate Communications) expanded to include more on external


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leaders and plant management teams, develop strategic internal and external communications for management decisions, for external public affairs, and to reinforce nuclear safety.

communications in the objective as well as related criteria.

1. A communications strategy is in place that supports the organization’s mission, nuclear safety culture, and change initiatives by identifying key objectives, strategies, and tactics for communicating with key stakeholders. The strategy includes methods to monitor and measure the effectiveness of communications. Issues identified are addressed, monitored, and tracked to closure.

INPO 05 – 003 Performance Objective and Criteria (CO.5 Corporate Communications)

2. Executives, managers, and supervisors are the key sources of information in the communications strategy. They receive ongoing training to develop effective communications skills.

INPO 05 – 003 Performance Objective and Criteria (CO.5 Corporate Communications) INPO 11-007 Principles for Strong Governance and Oversight of Nuclear Power Organizations.

3. Communications managers and personnel encourage, monitor, and address employee feedback on business initiatives.


4. Public information programs and practices are in place to provide timely dissemination of accurate, reliable, and understandable information in response to crisis situations, events of potential public interest, and declared plant emergency events. The effects of web-based information and social media activity are considered and planned for.


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Energy Northwest’s Talent Management

Strategy

Prepared by the Human Resources Department

2014

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The Talent Management framework below has nine general areas: acquisition, performance management, excellence in leadership, labor relations, workforce planning, professional development, training, employee onboarding and employee retention. Together, the integrated talent management system drives organization culture, operational excellence, employee engagement and organization capability at Energy Northwest.

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Introduction What is talent management? In the broadest sense, talent management can be described as a deliberate and ongoing process that systematically identifies, assesses, develops and retains talent to meet current and future business needs and objectives. Stated another way, it is about putting the right people with the right skills in the right position at the right time. Talent management begins as soon as our Human Resources Department identifies potential hires and continues throughout a person’s tenure as an employee of Energy Northwest. Why do we need to develop a talent management strategy? Three reasons:

First, our employees are the key to Energy Northwest achieving its goal of Excellence. Safety, reliability and predictability will only be achieved by a top performing and engaged workforce.

Second, the way we manage talent can be a game-changer for Energy Northwest. Having

leaders who understand this is critical for a successful strategy. We must invest in our leader development and continue to assess how our leaders are managing our employees.

Lastly, talent and leadership continue to be scarce. Fewer qualified workers and leaders

are entering the workforce to replace aging workers and leaders who are leaving to retire.

Energy Northwest’s Talent Management Strategy

Leverage technology to reach qualified workers that meet changing needs Build capabilities that will enable Energy Northwest to meet future challenges Develop an engaged, high-performing workforce

Energy Northwest’s Talent Management Components

Talent management at Energy Northwest is overseen by the Human Resources Committee (HRC). The Energy Northwest leadership team has the responsibility to ensure that talent management is embraced and given the proper priority. The Human Resources and Training departments are responsible for the policies and procedures that drive talent management at Energy Northwest.

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Below are the components and a description of each. Acquisition of employees Once Energy Northwest has determined a need to hire, there are a number of tools that are used to find candidates, educate them about Energy Northwest and eventually hire them. Social media (LinkedIn, Monster, and numerous job posting sites) are key to reaching talent. It’s no longer as simple as posting jobs to our web site. Our PeopleSoft system plays a large role in providing the technology to support hiring needs. Energy Northwest has two General Business Procedures (GBP) that assist our leaders in selecting the highest quality candidates for positions. GBP-HR-08, Employment and GBP-HR-09, Applicant Selection Process provides leaders with the knowledge and skills to acquire new talent. Leaders are trained in the process of using the categories of Talent, Experience, and Chemistry (TEC) to ensure candidates will meet the needs of Energy Northwest. Leaders develop the selection criteria, such as - education, experience, skills, from approved position descriptions. Human Resource Generalists are available to provide the leader with coaching and direction so the best candidate is selected. If the candidate qualifies for relocation assistance, Energy Northwest has a process in place to assist the new employee. GBP-HR-42, Relocation Expenses provides the relocation benefit details. Onboarding and New Employee Orientation On their first day of employment, each new employee attends an onboarding session conducted by Human Resources. The new employee also has an assimilation conducted by their immediate supervisor. This assimilation ensures that the employee is welcomed into the organization, is provided the proper resources to accomplish their responsibilities and has their questions answered. Each new employee also attends a New Employee Orientation class. This program provides the new employee with the history of Energy Northwest, orientation to the Excellence Model that defines our culture, exposure to the various organizations and career planning opportunities at Energy Northwest. The goals of the program are:

To welcome new employees on board and let them know that we are glad they decided to come to work for us.

To acquaint our new employees with Energy Northwest, including its mission, its operations, and its people.

To inform new employees about a broad range of policies that affects all aspects of their work, their relationship with Energy Northwest, and compliance with laws and regulations.

To open the channels of communication through which employees can obtain information, ask questions, and discuss job problems.

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New Leader Orientation and Training Each new leader at Energy Northwest, whether promoted internally or hired externally is required to go through a structured New Leader 100 Day Plan. The new leader is coached and monitored by a Training department Management Development Representative during this 100 day period. They are exposed to the basics that they will need to know to be a successful leader. Each new leader is also enrolled in our Supervisor/Manager Qualification program. They have 18 months to achieve this qualification. Their progress is monitored by the Management Curriculum Review Committee/Training Advisory Group (CRC/TAG). The program provides the new leader with the knowledge and skills to become an effective leader at Energy Northwest. The topics of the program include: Performance Management, Communications, Hiring and Selection, Affirmative Action/EEO, Labor Relations, Situational Leadership, Assessment for Leadership, Safety for Leaders and Decision Making. Performance Management Energy Northwest has a well-developed performance management process to maximize individual and organizational effectiveness. GBP-HR-020, Performance Appraisal outlines the program. Employees work with their supervisors to establish annual goals that are aligned with Energy Northwest’s strategic plan. The intent is to have a line of sight from what the employee does on a day-to-day basis and how it impacts Energy Northwest’s goals. Supervisors will perform mid-year and end-of-year performance evaluations. Also included in the annual performance appraisal is the employee’s development plan. Each employee has a development plan to increase their value and contributions to Energy Northwest, while advancing their career plans. Energy Northwest also has a process for improving an employee’s performance if performance issues arise. GBP-HR-18, Performance Improvement is the guiding document for assisting our leaders in working with employees to improve their performance. The Human Resources Department partners with leaders to ensure that improvement is occurring. In addition, our management observation program supports the coaching of employees to follow standards and improve performance. Training Energy Northwest has an experienced Training Department to ensure our employees receive the training that is necessary to perform their responsibilities. Both accredited and non-accredited programs are taught by the training staff. In addition, many employees participate in external training programs to increase their skills. Each department has budget for employee training and development. Employees are also provided with tuition reimbursement for professional development. GBP-HR-32, Tuition Reimbursement Program provides direction to employees and their supervisors.

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Energy Northwest has partnered with Columbia Basin College to establish a Nuclear Technology Program that is accredited by the National Academy for Nuclear Training. The Nuclear Uniform Curriculum Program (NUCP) satisfies the guidelines in ACAD 08-006, Uniform Curriculum Guide for Nuclear Power Plant Technician, Maintenance and Non-licensed Operations Personnel Associate Degree Programs. TDI-21, Nuclear Uniform Curriculum Program describes the program and Energy Northwest’s contributions and support of the program. This program assists Energy Northwest in ensuring we have qualified applicants for future job openings. Moreover, Energy Northwest has partnered with IBEW Local 77 to enable students in the program to temporarily work for Energy Northwest in junior level positions to gain practical experience in their chosen profession while also fulfilling the internship requirements of the curriculum. Workforce Planning Workforce planning is conducted annually by each department at Energy Northwest. The senior leadership team reviews and approves the department plans This process provides strategic direction to talent management activities to ensure that Energy Northwest has the right people in the right place at the right time to execute its business strategy. This process consists of analyzing the current workforce, determining future workforce needs, identifying the gap between the present and future to answer the following questions:

Does each department have the right number of personnel and the right type of workforce to perform their work now?

Does each department have the right number of personnel and the right type of workforce to perform their work in the future?

If not, how large are the gaps and what talent management solutions are necessary to ensure the department can accomplish its mission, goals, and objectives?

Workforce planning enables Energy Northwest to: Anticipate changes and provide strategic methods for addressing present and anticipated

workforce requirements. Prevent unanticipated employee shortages or surpluses. Anticipate and address potential knowledge gaps caused from retirements or attrition. Help identify future skills needed in the developing workforce and any gaps between

current job skills and any future job skills that may be required. Highlight resource issues that will be factored into the budget funding process.

The departments consider the following in the development of their workforce plans:

Knowledge/Skills/Abilities (KSA) Requirements. Training needs for new employees. Union Negotiations. Retention strategy for existing employees. Knowledge transfer from existing employees. Identification of other issues that may impact workforce staffing. Budget.

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Succession Planning Succession Planning at Energy Northwest is a key process to ensure we have the right people at the right time. GBP-HR-03, Succession Planning is the governing document that outlines our process. We perform succession planning at all levels of leadership, from the CEO position through the first level supervisor. The overall goal of succession planning is to minimize the negative impact of leadership changes to Energy Northwest and to ensure the systematic and long-term development of replacement candidates. We use the 9-Block evaluation process to identify our candidates and then use our developmental tools and processes to ensure they have the right knowledge and skills to advance. The senior leadership team at Energy Northwest believes that succession planning is one of their most important responsibilities to ensure the future success of the agency. Energy Northwest also has a New Leader Development Program that assists in the development of individuals who are identified as future leaders and who have expressed an interest in assuming a leadership position in the near future. Leadership Assessments A formal leadership assessment process is used at Energy Northwest to evaluate all new leaders and to identify developmental opportunities to ensure that they exhibit the leadership behaviors necessary to move Energy Northwest to excellence. GBP-HR-50, Leadership Assessments, provides:

Leaders with feedback on their leadership skills, areas for development, and support in developing a professional development plan;

Managers of leaders the opportunity to make a comprehensive assessment of their subordinates, feedback on their subordinates leadership skills and areas for development, insight on the differences between how they see their subordinates and how the senior leadership team views them, and recommendations on how they can best coach and develop the leadership skills of their subordinates; and

Senior leadership with a comprehensive understanding of the organization’s leadership skillset (strengths and weaknesses) and recommended areas for leadership development.

As part of the assessment process, each new leader also receives a 360 feedback assessment. This is critical to providing the new leaders with information and direction on their leadership skills. Knowledge Transfer/Retention Knowledge transfer/retention is the act of transferring knowledge from one individual to another by means of mentoring, training, documentation, and other collaboration. GBP-HR-48, Knowledge Retention is the governing document used by Energy Northwest’s leadership. It provides recommended methods for ensuring that knowledge is captured and transferred.

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Knowledge transfer/retention is a key component of each department’s annual workforce plan. Leaders are asked to identify the potential for key knowledge loss and to make appropriate plans to ensure that this is captured. Retention The retention of our valued employees is central to our Talent Management strategy. Energy Northwest knows that there is not just one factor that our employees consider when deciding to stay at Energy Northwest. We see this as a challenge and have taken the following actions to ensure that once we have attracted a new employee, they stay:

Competitive compensation and benefits. We offer our employees base pay that is very competitive with the market. We perform salary surveys to ensure that we do not fall behind. Our benefit programs are continually being reviewed to ensure we are competitive. We have incentive programs that align our employees with our overall goals and reward them when the agency performs well.

Rewards and Recognition is encouraged at Energy Northwest. We have a multitude of programs available to leaders to reward both team and individual performance. GBP-HR-14, Employee Recognition and Awards outlines the programs.

The supervisor/employee relationship is cited as the reason most employees decide to stay or leave the organization. Energy Northwest invests heavily in ensuring that our supervisors understand the behaviors that make a good leader and impact their relationships with their subordinates.

Career opportunities are important to our employees. Energy Northwest’s philosophy is to promote internally whenever possible. Employees need to believe that they not only have a good job at Energy Northwest, but they also have a career here. GBP-HR-08, Employment provides support for our internal promotion philosophy. We also provide employees with many developmental opportunities that are discussed below in the Development section.

Labor Relations Energy Northwest has a large population of our employees who are represented by either the International Brotherhood of Electrical Workers (IBEW) or the United Steelworkers (USW). GBP-HR-35, Labor Relations is our governing document for working with our unions. Energy Northwest respects the right of our employees to be represented by a third party. Our approach is to work collaboratively with the unions on issues and to attempt to maintain a harmonious relationship through the use of Interest Based Bargaining (IBB) principals. Energy Northwest works diligently to assure the IBB approach is understood and practiced by its leaders by offering a two-day Mutual Gains training program each fall which all new supervisors and managers overseeing bargaining unit personnel are expected to attend. New bargaining unit members and stewards join the class as well to reinforce this joint labor/management commitment to healthy and productive relations.

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GBP-HR-36, Bargaining Unit Grievance Procedure provides guidelines and assigns responsibilities for grievance handling for all Energy Northwest Bargaining Unit Agreements. These guidelines ensure that the conflicts that arise will be handled in a way that the majority of time we will come to a satisfactory resolution for all parties.

Development

Employee development is a key component to our Talent Management Strategy. We have the following processes to support employee development:

Employee Development Plans – Each employee in their annual performance appraisal is asked to identify the developmental activities that they would like to work on in the coming year. The leader and employee agree upon the development plan and work together to ensure successful completion. Energy Northwest ensures that appropriate resources are provided to assist the employee.

Mentoring – We recognize that many of the skills required for success at Energy Northwest cannot be taught in a classroom setting and that they must be acquired through personal mentoring provided by others. GBP-HR-34, Employee Mentoring provides our employees with the opportunity to receive mentoring from others. We have a variety of mentoring opportunities available. Individual mentoring is the most common, but we also have a formal Group Mentoring Program available for identified employees.

Job Shadowing - The purpose of Energy Northwest’s Job Shadow Program is to provide internal career development opportunities for employees at Energy Northwest. The Job Shadow Program allows employees to consider a different career by spending some time shadowing a fellow employee whose job is in that particular field of interest. The Job Shadow Program is intended to be used by employees to evaluate near-term career opportunities. GBP-HR-31, Job Shadowing Program provides the details of the program.

Human Resources Committee (HRC)

Energy Northwest has established a Human Resources Committee (HRC). The purpose of the HRC is to support our initiatives for achieving the objectives of the Excellence Model philosophy, employee core values and leadership competencies. The HRC functions as an executive oversight body that looks at issues, trends, and focuses on future workforce needs for the agency. The Excellence Model supports the agency’s mission and the HRC provides oversight regarding the management of the agency’s workforce, and their development. The HRC reviews all employee programs and initiatives for Energy Northwest such as:

• Performance Management • Succession Planning • Workforce Planning • Leadership Assessments/Development • Knowledge Transfer and Retention (KT&R)

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• Employment/Recruiting • Compensation • Diversity

The HRC review may include other areas and programs as determined by committee. Members of the committee include the CEO, all Vice Presidents, the General Counsel and the Human Resources Manager.

Excellence Model

The Excellence Model is a plan for changing and sustaining workforce behaviors. It is a union of management structure, procedures and processes that result in continuous performance improvement. It builds on proven industry principles to form a solid basis for long-lasting and effective performance. The model’s visual appearance includes four interdependent tiers that build on the preceding tiers’ strengths. Its foundation is based on four principles.

These four principles are key to establishing and maintaining a workplace environment that leads to and sustains desired behaviors. They are selecting and retaining the right people; communicating and reinforcing the right picture; verifying the right implementation of the right processes; and providing the right workforce coaching and engagement. The model is a proven blueprint to pursue performance excellence opportunities and realize sustainable performance excellence results.

The Excellence Model drives our culture at Energy Northwest. New employees receive training on the model and it is incorporated in all the day to day activities. This model has been extremely successful in driving Energy Northwest to the higher levels of excellence performance.

The Excellence Model is communicated to employees in many forms. Each employee receives their personal copy of The Excellence Model Handbook on their first day of employment. The Excellence Model is also located on the internal internet site. In addition, key components of the Excellence Model are located throughout the various agency facilities as posters.

Schedule

To ensure all activities associated with the Energy Northwest Talent Management Strategy are appropriately integrated and periodically completed, an annual schedule has been developed. Appendix A is the Annual Calendar for Energy Northwest’s Talent Management Strategy Activities.

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Institute of Nuclear Power Operations (INPO)

INPO sets performance objectives, criteria, and guidelines industry-wide for nuclear power plant operations to promote operational excellence. Energy Northwest values the guidance provided by INPO. We have reviewed the following INPO standards and good practices to ensure that our Talent Management strategy is aligned:

INPO 12-013, Performance Objectives and Criteria INPO 09-014, Successful Operations Workforce Planning INPO 04-003 Guidelines for Effective Nuclear Supervisor Performance INPO 06-004 Essential Elements of Knowledge Transfer and Retention INPO 13-004, Talent Management and Leadership Development

We reviewed each of these documents and extracted the elements that provide recommendations in the talent management strategy area. In Appendix B we mapped our Energy Northwest practices and policies to the INPO recommendations.

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SUMMARY Energy Northwest has a well-developed and active Talent Management strategy in place to ensure that we are able to meet the mission and goals of the organization. We have incorporated the INPO recommendations and other best practices to develop this integrated strategy. Reference Material GBP-HR-03, Succession Management GBP-HR-08, Employment GBP-HR-09, Applicant Selection Process GBP-HR-14, Employee Recognition and Awards GBP-HR-18, Performance Improvement GBP-HR-20, Performance Appraisals GBP-HR-31, Job Shadow Program GBP-HR-32, Tuition Reimbursement Program GBP-HR-34, Employee Mentoring GBP-HR-35, Labor Relations GBP-HR-36, Bargaining Unit Grievance Procedure GBP-HR-48, Knowledge Retention GBP-HR-50, Leadership Assessments TDI-21, Nuclear Uniform Curriculum Program SWP-TQS-01, Training, Qualification and Simulators Energy Northwest Excellence Model Human Resources Committee Charter INPO 04-003 Guidelines for Effective Nuclear Supervisor Performance INPO 06-004 Essential Elements of Knowledge Transfer and Retention INPO 09-014, Successful Operations Workforce Planning INPO 12-013, Performance Objectives and Criteria INPO 13-004, Talent Management and Leadership Development

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Appendix A

Annual Calendar for Energy Northwest’s Talent Management Strategy Activities

Month Activity

January Mid-Year Employee Performance Appraisal review Monthly Human Resources Committee (HRC) meeting HRC selects employees for external development courses (INPO,

Leadership Tri-Cities, MIT, NWPPA, Ag Forestry, etc.) HRC approves employees for SRO certification training program Department Workforce Planning process started At-Risk Compensation Plan results communicated to employees

February Direct report to CEO and Vice President position succession planning by CEO and VP’s

Monthly Human Resources Committee (HRC) meeting Group Mentoring Program selections made

March Semi-Annual Key Positions Reviewed by Human Resources Committee (HRC)

Quarterly Succession Plan Candidate Update by HRC First Quarter New Employee Orientation Program Department Workforce Plans approved Monthly Human Resources Committee (HRC) meeting Group Mentoring Program Kickoff

April Monthly Human Resources Committee (HRC) meeting At-Risk Compensation Plan results communicated to employees

May Assessment of Managers and Supervisors on 9-Block started Assessment of Individual Contributors on 9-Block started Monthly Human Resources Committee (HRC) meeting

June Quarterly Succession Plan Candidate Update by HRC Second Quarter New Employee Orientation Program Annual Employee Performance Appraisal period ends Monthly Human Resources Committee (HRC) meeting At-Risk and Long Term Incentive Plans approved

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Month Activity

July Assessment of Individual Contributors on 9-Block completed Annual Employee Performance Appraisal Goal Setting started Monthly Human Resources Committee (HRC) meeting At-Risk Compensation Plan results communicated to employees

August CEO succession planning by Executive Board and CEO Assessment of Managers and Supervisors on 9-Block completed New Leader Development Program 2 year Cohort identified Monthly Human Resources Committee (HRC) meeting Annual Employee Performance Appraisal Goal Setting ends

September Quarterly Succession Plan Candidate Update by HRC New Leader Development Program 2 year Cohort program begins Review the New Leader Development Program participant’s first

year progress Third Quarter New Employee Orientation Program Monthly Human Resources Committee (HRC) meeting At-Risk and Long Term Incentive Plan payouts

October Semi-Annual Key Positions Reviewed by HRC Monthly Human Resources Committee (HRC) meeting At-Risk Compensation Plan results communicated to employees

November Creation of leadership development plans for employees on the key positions list and/or top blocks

Monthly Human Resources Committee (HRC) meeting

December Quarterly Succession Plan Candidate Update by HRC Fourth Quarter New Employee Orientation Program Monthly Human Resources Committee (HRC) meeting

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Appendix B

How Energy Northwest Implements INPO Standards and Good Practices

INPO Standard or Good Practice Energy Northwest’s Procedures or Practices

INPO 12-013: PERFORMANCE OBJECTIVE (OR.4), Criteria 1

GBP-HR-08, Employment, GBP-HR-09, Applicant Selection Process and GBP-HR-03, Succession Planning


Excellence Plan and GBP-HR-20, Performance Appraisals


Position Descriptions and SWP-TQS-01, Training, Qualification and Simulators


GBP-HR-03, Succession Planning and GBP-HR-50, Leadership Assessments


GBP-HR-03, Succession Planning




New Leader 100 Day Plan and Excellence Plan


Supervisor/Manager Qualification Program andGBP-HR-20, Performance Appraisals


GBP-HR-03, Succession Planning and personal Development Plans


GBP-HR-31, Job Shadow Program, GBP-HR-03, Succession Planning and GBP-HR-34, Employee Mentoring


External seminars, personal Development Plans and GBP-HR-50, Leadership Assessments


GBP-HR-03, Succession Planning and participation in INPO’s Peer Program




GBP-HR-34, Employee Mentoring, GBP-HR-20, Performance Appraisals and GBP-HR-50, Leadership Assessments


Training Department Excellence Plan

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Supervisor/Manager Qualification Program


Supervisor/Manager Qualification Program and Paired Observation Program


Supervisor/Manager Qualification Program


Supervisor/Manager Qualification Program, Mutual Gains Training Program and GBP-HR-35, Labor Relations




GBP-HR-03, Succession Planning, GBP-HR-50, Leadership Assessment and GBP-HR-20, Performance Appraisals


Workforce Plans, GBP-HR-48, Knowledge Retention and Training Program Observation Program

INPO 12-013: PERFORMANCE OBJECTIVE (CO.6), Criteria 1



Annual Workforce Plan


GBP-HR-Leadership Assessments and Supervisor/Manager Qualification Program


New Leader 100 Day Plan and Excellence Model




GBP-HR-11,Organizational Changes and Title Definitions and SWP-ORG-01, Organizational Changes


GBP-HR-48, Knowledge Retention and department annual Workforce Plans

INPO 09-014: (3.1) Develop Recruiting and Hiring Strategies

GBP-HR-08, Employment, GBP-HR-09, Applicant Selection Process, TDI-21, Nuclear Uniform Curriculum Program and GBP-HR-14, Employee Recognition and Awards

INPO 09-014: (3.2) Partner With Educational Institutions

TDI-21, Nuclear Uniform Curriculum Program and annual college recruiting activities

INPO 09-014: (3.3) Select Candidates

GBP-HR-09, Applicant Selection Process

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INPO 04-003: A: IDENTIFICATION AND PRESELECTION OF CANDIDATES FOR NUCLEAR SUPERVISORY POSITIONS

GBP-HR-03, Succession Planning and GBP-HR-34, Employee Mentoring

INPO 04-003: B: SELECTION OF NUCLEAR SUPERVISORS

GBP-HR-08, Employment and GBP-HR-09, Applicant Selection Process

INPO 06-004: Essential Elements of Knowledge Transfer and Retention

GBP-HR-48, Knowledge Retention and annual Workforce Plans

INPO 13-004: Identifying and Attracting Talent

GBP-HR-08, Employment, GBP-HR-09, Applicant Selection Process and Department Workforce Plans

INPO 13-004: Screening and Selection

Excellence Model and GBP-HR-20, Performance Appraisals

INPO 13-004: Onboarding and Assimilation

New Leader 100 Day Plan and the Supervisor/Manager Qualification Program

INPO 13-004: Development

GBP-HR-03, Succession Planning, GBP-HR-34, Employee Mentoring and GBP-HR-50, Leadership Assessments

INPO 13-004: Ongoing Assessment and Evaluation

GBP-HR-03, Succession Planning, GBP-HR-20, Performance Appraisals and GBP-HR-50, Leadership Assessments

BACKGROUND The Center for Energy Workforce Development (CEWD) was incorporated in March 2006 as a new, non-profit organization to help ensure that the nation’s electric, natural gas, and nuclear energy companies have the workforce to meet the energy demands of tomorrow. The Center for Energy Workforce Development (CEWD) is an organization of electric, natural gas and nuclear energy companies and their associations – American Gas Association, Edison Electric Institute, National Rural Electric Cooperative Association and Nuclear Energy Institute. CEWD was formed to help member companies work together to develop solutions to the coming workforce demands in the industry. It is the first partnership between utilities, their associations, contractors and unions to focus on the need to build a skilled workforce pipeline that will meet future industry needs. In addition, CEWD has established partnerships with national education and workforce associations and organizations to leverage resources for existing and new initiatives. CEWD is also working with secondary and post secondary educational institutions and the public workforce system to create workable solutions to address the need for a qualified, diverse workforce. VISION Where the industry speaks with one voice for a single purpose – Companies adequately staffed with a diverse workforce with the right skills to safely keep the energy flowing. MISSION Build the alliances, processes, and tools to develop tomorrow’s energy workforce. SCOPE CEWD focuses on energy industry (not individual utility) workforce development issues. CEWD will operate under the specific IRS rules and governance guidelines of a 501(c)(3)

organization. CEWD mobilizes the electric and natural gas utility industry by broadly engaging independent

companies and organizations across the industry to achieve its mission. STRUCTURE Board of Directors The Board of Directors approves the strategic plan and budget, monitors overall organization operations and administration, and approves organization policy. The Board consists of a Chair, Vice Chair and board members who represent the diversity of CEWD membership. The Board meets four times a year either face to face or by teleconferences as determined by the Chair.

Governance Policy

Executive Council The Executive Council represents members, develops policy on organization issues, recommends the strategic plan and budget for approval by the Board, provides management guidance and oversight to CEWD operations, and provides support for the development of membership, partnerships, alliances, and sponsorships. The Council consists of a Chair, Vice Chair and Council members who represent the diversity of CEWD membership. The Council meets four times a year – one meeting is face to face and three meetings are by teleconferences.

Executive Council membership – The council will have up to 15 members. The members will serve a 3 year term (staggered) and can be reappointed when the term has ended.

CEWD officers and staff will nominate new members. The Chair and Vice Chair should mirror the Board of Directors.

CEWD Officers and Staff CEWD officers and professional staff are responsible for day to day management of CEWD. MEMBER ADVISORY COUNCILS There is one standing member advisory council and other ad hoc councils or task forces that provide direction, support and advice to staff in the implementation of CEWD strategy and initiatives. The councils include member company representatives as well as outside subject matter experts and each standing member advisory council is chaired by a member company representative. Additional Advisory Councils or task forces may be established as needed based on the projects and initiatives approved by the Executive Council Workforce Planning Council The Workforce Planning Council provides guidance to CEWD on data and reporting to support the balancing of job demand and educational supply including the CEWD Gaps in the Energy Workforce survey, detailed supply and demand reports, and the analysis of alternate sources of data. The council also supports CEWD in the development of metrics to evaluate the success of workforce development efforts at the national, state and company level. MEMBERSHIP CEWD Energy Company and Association Members contribute financial resources. Full

members of EEI, NEI, AGA and NRECA are eligible for energy company membership. Other companies, organizations and associations become members by Executive Council invitation. (A list of CEWD Members can be found in the Appendix)

Non-utility firms eligible to join CEWD are either: Contractors and vendors performing work on site at a member utility or directly on a

utilities transmission and distribution system such as system engineering, construction, operation and maintenance, equipment testing, refurbishment and repair, and customer service; or

Contractors and vendors performing work off site for a member utility, such as engineering modifications, component fabrication, equipment refurbishment, equipment manufacturing, and equipment testing.

• Partners have significant common interests, needs, objectives and goals and bring complementary skills and resources to the partnership. Partnerships are negotiated with agreement on specific outcomes and what each partner will provide along with fees or in-kind contributions.

• Secondary and Post Secondary Educational Institutions may become educational members by recommendation of a sponsoring member utility. Educational members agree to share information on curriculum, structure and results for individual programs.

• Workforce Systems and Government Agencies may become members by recommendation of a sponsoring member utility.

Resources The administrative budget of CEWD is funded by member contributions. Initiatives are also funded through federal/state and foundation grants and/or corporate

contributions and from other sources, such as meeting fees. The energy company member contribution schedule is as follows:

More than 15,000 employees - $30,000 10,000 – 14,999 employees - $25,000 7,500 – 9,999 employees - $18,750 5,000 – 7,499 employees - $12,500 2,500 – 4,999 employees - $6,500 1,000 – 2,499 employees - $3,500 101 – 999 employees - $1,250 Under 100 employees - $750

The utility association member contribution schedule is as follows: National association contributions are negotiated. Regional associations - $6,500 Local / State associations - $1,250

The contractor member contribution schedule is as follows: More than $1 billion in U.S. Revenue - $30,000 $500 million - $1 billion - $25,000 $250 million - $499 million - $18,750 Less than $250 million - $9,000

Appendix

BOARD OF DIRECTORS

Thomas H. Graham, Chair Vice President People Strategy & Human Resources Pepco Holdings, Inc

Thomas R. Kuhn President Edison Electric Institute

Geisha J. Williams, Vice Chair Executive Vice President, Electric Operations PG&E Corporation

Dave McCurdy President and CEO American Gas Association

John Donleavy Executive Vice President & COO National Grid

Robert Powers Chief Operating Officer AEP Utilities, American Electric Power

Jo Ann Emerson CEO National Rural Electric Cooperative Association

Elizabeth Reese President Nicor Gas

Marvin S. Fertel President and CEO Nuclear Energy Institute

Keith Trent Executive Vice President, Regulated Utilities Duke Energy

Edwin D. Hill International President International Brotherhood of Electrical Workers

Mark Lantrip President & CEO Southern Company Services, Inc.

Dr. Ralph Izzo Chairman, President and CEO Public Service Enterprise Group, Inc

.

EXECUTIVE COUNCIL

Robert E. Grasty, Chair Director, Talent Management, Diversity & Inclusion Pepco Holdings, Inc

Susan Melians VP, Human Resources Florida Power & Light Co

Tracy Elich VP, Human Resources American Electric Power

Margaret Pego Sr. Vice President and Chief HR Officer Public Service Enterprise Group, Inc.

Kathleen Geraghty Vice President, Labor & Employee Relations National Grid

Jeana Sheehan SVP Talent Management and HR Consulting Duke Energy

Jim Hunter Director, Utilities Department International Brotherhood of Elec. Workers

John R. Simon Senior Vice President, Human Resources PG&E Corporation

Randy Johnson Vice President, Operational Readiness Southern Company

Douglas A. Staebler Vice President, Engineering & Construction Washington Gas Light Company

Mike Langford President Utility Workers Union of America,

Lori Traweek Sr. VP, Operations & Engineering American Gas Association

Elizabeth McAndrew-Benavides Senior Manager, Workforce Policy & Programs Nuclear Energy Institute

Russell Turner Principal, Human Capital Issues National Rural Electric Cooperative Association

Rebecca C. Meggesin Vice President, Talent Management & Labor Relations Nicor Gas

Deborah G. Zilai VP, Business Transformation & Technology New Jersey Resources Corporation

Workforce Planning Council Debra Howell, Chair Georgia Power Company Dana Berkheimer, Staff Lead Center for Energy Workforce Development Stacy Abbott DTE Energy Co Lori Brady Nuclear Energy Institute Chris Broughan Consumers Energy Bob Chapman Xcel Energy Inc Joe Cisneros American Electric Power Olsen Deborah Dominion Resources Services Robert Dickerson Dominion Resources Services Nicholas Folz Vectren Corp Amy Forehand Consumers Energy Ty Freeland Arizona Public Service Co Nelson Gosnell Tennessee Valley Authority Debra Hager Duke Energy David Heler Arizona Public Service Co Jay Helmer Southern California Edison Co

Carol Higley JEA Ann Holland Mississippi Power Allison Honeycutt Duke Energy Debra Howell CHAIR Georgia Power Ray Kelly Center for Energy Workforce Development Sharon Kohn Public Service Enterprise Group Trish MacDonald Areva John Mallett Entergy Corp Michael Manning Southern California Edison Co Elizabeth McAndrew-Benavides Nuclear Energy Institute Kimberly McFadden-Harris Southern Company Betsy Miller Ameren Services Geri Mingura Arizona Public Service Co Sally Nadler Public Service Enterprise Group Linda Nahin American Gas Association Beth Peters Black Hills Corp

Ann Randazzo Center for Energy Workforce Development Jacquie Roth FirstEnergy Corp Paul Sanchez PNM Resources Carren Spencer Edison Electric Institute Daniel Spiak Arizona Public Service Co Juliette Trollope National Grid John Wheeler Entergy Corp Susan Wheeler Sacramento Municipal Utility District Michelle Wood American Electric Power Debra Woodworth Consumers Energy

CEWD OFFICERS AND STAFF Mary Miller, President CEWD President CEWD Chief Administrative Officer, Edison Electric Institute

Ann Randazzo, Executive Director, CEWD

Elizabeth McAndrew-Benavides, Vice President CEWD Senior Manager, Workforce Policy & Programs Nuclear Energy Institute

Carren Spencer, Program Manager CEWD Program Manager, Industry Human Resource Issues, Edison Electric Institute

J. Bruce Brown, Secretary CEWD Assistant General Counsel, Edison Electric Institute

Dana Berkheimer, Education Consultant, CEWD

Bradford Nixon, Assistant Secretary CEWD Assistant General Counsel, Edison Electric Institute

Beth Britt, Consultant, CEWD

Terri Oliva, Treasurer CEWD Controller & Assistant Treasurer, Edison Electric Institute

Mindy Feldbaum, Consultant, CEWD

Lori Traweek, Sr. VP, Operations & Engineering American Gas Association

Ray Kelly, Consultant, CEWD

Shaara Roman, Senior Vice President, Human Resources National Rural Electric Cooperative Association

Rosa Schmidt, Consultant, CEWD

Valerie Taylor, Education Consultant, CEWD Andrew Schieffer, Administrative Assistant David Washington, Administrative Assistant

CEWD Members

AGL Resources Alameda Municipal Power ALLETE Alliant Energy Ameren Services American Electric Power Company American Gas Association AREVA Arizona’s G & T Cooperatives Arizona Public Service (APS) Associated Electric Cooperative, Inc. Avista Utilities Bandera Electric Cooperative Black Hills Corporation Bonneville Power Administration Central Hudson Gas & Electric Corp. Central Iowa Power Cooperative Citizens Energy Group Cleveland Public Power Coast Electric Power Association Colorado Springs Utilities Consumers Energy Dominion DPL, Inc. DTE Energy Duke Energy East Kentucky Power Cooperative Edison Electric Institute ElectriCities of North Carolina, Inc. Electric Cities of Georgia Entergy Corp EQT Corp Exelon Corporation FirstEnergy Corp Great River Energy Iberdrola USA Idaho Power Company Indiana Statewide Association of Rural

Electric Cooperatives Indianapolis Power & Light Integrys Energy Group Inter-County Energy Cooperative JEA Kansas City Power & Light Knoxville Utilities Board

Lakeland Electric & Water Utility Lincoln Electric System Luminant MidAmerican Energy Co. Midwest Energy Association Mt. Carmel Public Utility Co. National Grid National Rural Electric Cooperative

Association Nebraska Public Power District New Jersey Resources Corporation New York Power Authority NextEra Energy, Inc. Nicor Gas North Carolina Electric Membership

Corp. Northeast Utilities NorthWestern Energy Nuclear Energy Institute OGE Energy Corp Omaha Public Power District Otter Tail Power Company Owen Electric Cooperative Pacific Gas & Electric Co. Piedmont Electric Membership

Cooperation Pepco Holdings, Inc. Piedmont Electric Membership Corp PNM Resources Portland General Electric PPL Corporation Public Service Enterprise Group Sacramento Municipal Utility District Salt River Project Santee Cooper SCANA Corp. Sempra Energy Utilities South Jersey Industries South Texas Proj. Nuclear Operating

Co. Southern California Edison Company Southern Company Sulphur Springs Valley Electric

Cooperation, Inc. Sunflower Electric Power Corp. Tacoma Power

Tennessee Valley Authority The Oglethorpe Family of Companies UGI Utilities, Inc. United Illuminating Co. UNS Energy Corporation Vectren Corporation

Virginia, Maryland & Delaware Association of Electric Cooperatives

Washington Gas Light Co. Westar Energy Wyoming Rural Electric Association Xcel Energy, Inc.

CEWD Partners

• International Brotherhood of Electrical Workers • Utility Workers Union of America • Association of Career and Technical Education • National Association of Workforce Boards • National Energy Foundation • American Association of Community Colleges • Energy Providers Coalition for Education

GUIDING PRINCIPLES FOR COMMUNITY COLLEGES AND OTHER EDUCATIONAL INSTITUTIONS

The following are the guiding principles for educational institutions regarding membership in the Center for Energy Workforce Development (CEWD). Community Colleges

1. Educational institution must be sponsored by an energy company that is a member of CEWD. This sponsorship provides the educational institution with all of the benefits of a member.

2. Educational institution must share their curriculum or program with other CEWD members. 3. Educational institution must participate in curriculum development with industry consortia

where appropriate such as state workforce consortia, Great Lakes Nuclear Consortium, etc.

4. Educational institution should participate with its energy partner in development of career awareness sessions at high schools and middle schools.

5. Educational institution should offer suggestions and programs to energy partner for attracting and recruiting students in middle and high schools.

6. Educational institution should work with energy partners and local high/vocational schools to create “dual enrollment” programs for students.

7. Educational institution should participate with its energy partner in sponsoring career awareness events such as:

a. Lego leagues b. Robotic competition c. Science fairs d. Summer camps e. Teacher awareness/education

8. Educational institution should participate in the marketing and promotion of its programs to prospective students.

9. Educational institution should have personnel knowledgeable in the career opportunities in the energy industry to counsel prospective students.

Middle school/high schools

1. Schools must be sponsored by an energy company that is a member of CEWD. 2. Schools should participate with its energy partner in sponsoring career awareness events

such as: a. Mentoring b. Career awareness sessions c. Field trips d. Lego league sponsorship e. Robotics sponsorship f. Senior project in engineering g. Summer camps

3. Schools should work with their energy partner and local community college to create “dual enrollment” programs for students.

4. Schools should encourage their teachers to become more aware of the career opportunities in the energy industry.

Criteria for CEWD Involvement in Projects and Initiatives Mission related - Project fits core mission of CEWD. Demonstrated need – the project will address a significant industry wide need as identified by CEWD members. Industry led initiative - Involvement requested by one or more member company(ies). Replication - Project will provide deliverable or results that can be leveraged or duplicated at minimum cost by CEWD members. Revenue neutral for CEWD - Project does not require substantial financial or resource investment from CEWD without compensation or leveraged funds.

State Consortia Leads

ArizonaClay Goodman, Ph.D. Estrella Mountain Community College [email protected] (623) 935-8456 David Heler Arizona Public Service Co [email protected] (623) 393-6274 Mr. Peter McSparran Arizona Public Service Co [email protected] Ms. Marji Morris Tucson Electric Power Co [email protected] (520) 917-6614 ColoradoChristine Carpenter Energy Providers Coalition for Education c/o CAEL [email protected] (303) 804-4663 Jonathan Liepe Colorado Springs Utilities [email protected] (719) 668-7446 Conneticut Joe Ryzewski United Illuminating Co [email protected] (203) 926-4641

FloridaJennifer Grove Gulf Power Company [email protected] (850) 444-6821 Betsy K. Levingston Lakeland Electric [email protected] (863) 834-6439 GeorgiaAngela Farsee Georgia Transmission Corporation [email protected] (770) 270-7614 Suzanne Powell Electric Cities of Georgia [email protected] (770) 519-1676 IowaMs. Lori Rinkert MidAmerican Energy Co [email protected] Idaho Ms. Michelle Thiel Bingham University Partnerships & Educational Outreach - Idaho National Laboratory [email protected] (208) 526-7830 Angelique Keavney Idaho Power Co [email protected] (208) 388-5870

IllinoisJames Bauer Exelon Corp [email protected] Betsy Miller Ameren Services [email protected] (314) 554-3829

IndianaSherm Johnson Ivy Tech Community College [email protected] Mrs. Lori A. Sutton Vectren Corp [email protected] (812) 491-4899

Kentucky Ms. Lynn Ingmire Kentucky Association of Electric Cooperatives [email protected] (502) 451-2430 Ms. Bernadette Toebbe Duke Energy [email protected] (513) 287-3628 Lousiana Michael Hendon Entergy Corp [email protected] (504) 364-6506 Michigan Susan Teresa DiSanto DTE Energy Co [email protected] 31323553 Stephen Tye Owsley DTE Energy Co [email protected] (313) 235-6634 Minnesota Mr. Kyle Ault ALLETE [email protected] (218) 723-7573 Mr. Tom Cascalenda Xcel Energy Inc [email protected]

Missouri Bret Bonge Kansas City Power & Light Co [email protected] (816) 556-2755 Gayla Neumeyer University of Missouri [email protected] (573) 882-8366 Kansas Sarah Whitman Kansas City Power & Light Co [email protected] (816) 245-3876 Mississippi Mrs. Ann Holland Mississippi Power [email protected] (228) 865-5124 Becky Montgomery Mississippi Power [email protected] (228) 865-5925 John Wheeler Entergy Corp [email protected] (769) 232-8105 North Carolina Chris Hage Duke Energy [email protected] (704) 382-0870 Allison Honeycutt Duke Energy [email protected] (704) 382-7355 New Jersey Ms. Sally Nadler Public Service Enterprise Group [email protected] (973) 430-3850

New MexicoPaul J. Sanchez PNM Resources [email protected] (505) 241-4915 North York Ms. Katherine Rougeux New York Power Authority [email protected] (716) 286-6842 Ohio Mr. Joe Cisneros American Electric Power [email protected] (614) 716-2918 Oregan Maureen Fallt Portland General Electric [email protected] (503) 464-7296 Shalee Hodgson Oregon Dept of Community Colleges and Workforce Development [email protected] (503) 947-2409 South Dakota Dawn S Barbeau Black Hills Corp [email protected] (515) 422-4459 Tennessee Ms. Donna Curry Tennessee Energy Industry and Construction Consortium [email protected] (423) 280-4990 Lane Mylea Winchester Tennessee Valley Authority [email protected] (423) 751-6528

TexasClarence A Fenner South Texas Project Nuclear Operating Company [email protected] (361) 972-8668 John W. Mallett Entergy Corp [email protected] (281) 297-3434 Utah Ms. Carie Raddatz PacifiCorp [email protected] Virginia Leilani Todd Mecklenburg Electric Cooperative [email protected] (434) 372-6191 Washington Jen Boettcher Avista Utilities [email protected] (509) 495-2440 Mrs. Barbara Hins-Turner Pacific NW Center of Excellence for Clean Energy, A Centralia College Partnership [email protected] (360) 736-9391 Ms. Jamie Krause Pacific NW Center of Excellence for Clean Energy, A Centralia College Partnership [email protected] (360) 736-9391 Ms. Diane Quincy Avista Utilities [email protected] (509) 495-8021

Wisconsin Mr. Brian Dobberke We Energies [email protected] (414) 944-5595 Mr. Vern Peterson Wisconsin Public Service [email protected] (920) 433-5501

STP Knowledge Transfer And Retention

Process Description

Updated: 6/30/2013

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Introduction In 2011 (updated 2012 and 2013) several Knowledge Transfer and Retention (KTR) tools were developed under the following charter: The purpose of this document is to describe STP’s comprehensive approach to Knowledge Transfer & Retention and how the selected processes and tools support the ultimate goal of capturing knowledge and experience that have helped the station achieve a high level of performance. Discussion STP’s going forward strategy can be described in the following graphic.

Evaluation Processes – In this section we will describe the processes to be used to evaluate Knowledge levels and identify gaps in knowledge availability or depth. The fundamental starting point of every Knowledge Transfer & Retention effort is recognition of an existing or pending gap in knowledge.

Leveraging broad and diverse processes and technologies to maximize the transfer of knowledge and experience possessed by

the STP work force.

Section C Foundational Capture Tools

Section A Evaluation Processes

Section B POA Development

Section D General Capture Tools

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Plan of Action Development – When a knowledge gap is identified, it them becomes imperative to develop a plan of action to close that gap. A documented POA becomes the structure to ensure successful knowledge capture or transfer. Foundational Capture Tools – Two tools have been developed with the intention of being stand-alone knowledge repositories. These two tools will have their own processes and controls. General Capture Tools – This section will describe the KTR Toolbox of various tools which each has its own benefits and applications. These are the building blocks for the Plan of Actions used to close knowledge gaps.

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Section A – Evaluation Processes There are three processes which we take credit for identifying knowledge gaps. (A.1) Individual Evaluation This process is generally based on the EPRI Technical Paper titled Capturing and Using High-Value Undocumented Knowledge in the Nuclear Industry and benchmarking similar processes within commercial nuclear industry. STP’s version is built around an annual performance of the process to ensure it has an opportunity to ensure every opportunity to identify the potential loss of critical knowledge due to retirement. It relies on four basic steps:

1) Survey employee population near retirement and use their management to assess the critical nature of their knowledge. This step is completed by January 31st of each year.

Very near January 1st Human Resources distributes risk evaluation worksheets to cost center managers. Employees 55 years of age and older are listed on the worksheet. The responsibility of the cost center manager is to survey the listed employees and determine their Retirement Risk assigning a risk value as follows (for this example assumes the survey is performed in January of 2012):

Retirement Risk Values 5 Retirement in 2012 or 2013 (i.e. within current or following

year) 4 Retirement in 2014 3 Retirement in 2015 2 Retirement in 2016 1 Retirement in 2017

Then, for each retiree the cost center manager assigns a Position Risk factor based on the following scale:

NOTE: A Tier 2 Performance Indicator currently measures Implementation of the Individual Evaluation Process for potential retirees. The PI measures percentage completion of the four steps, or annual milestones, described below. Because of the importance of KTR to station near term performance this PI currently feeds into the station Incentive Plan.

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Position Risk Values

5 Critical and unique knowledge and skills. Mission critical knowledge/skills with the potential for significant reliability or safety impacts. STP or site-specific knowledge. Knowledge undocumented. Requires 3-5 ears of training and experience. No ready replacement available.

4 Critical knowledge and skills. Mission critical knowledge/skills. Some limited duplication exists and/or documentation exists. Requires 2-4 years of training and experience.

3 Important, systematized knowledge and skills. Documentation exists and/or other personnel on site posses the knowledge/skills. External/internal applicant generally available and can be trained in 1 to 2 years.

2 Proceduralized or non-mission critical knowledge and skills. Clear, up-to-date procedures exist. Training programs are current and effective and can be completed in less than one year.

1 Common knowledge and skills. External hires possessing the knowledge/skill are readily available and require little additional training.

The worksheet, provided as an Excel spreadsheet, then performs a basic math operation to calculate the individual’s Total Attrition Factor as: Total Attrition Factor = (Retirement Risk) x (Position Risk) Any employee with a Total Attrition Factor of 20 or higher will be considered a potential Critical Retiree for step 2 of this process.

2) Perform a controlled screening interview by Human Resources of the

potential retiree to independently assess the critical nature of their knowledge. This step is completed by March 31st of each year.

This process is implemented by HR and allows an impartial participant to help the employee uncover critical knowledge and special skills that may not be obvious to the potential Critical Retiree. The interview will typically be video recorded and may include participation of another member of the employee’s line organization. The results of this interview are compiled by the HR specialist and used in the development of a Plan of Action with line management.

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3) HR and line management compare assessments and come to agreement on whether and which critical knowledge is at rise from the potential retirement of the employee. Then a Plan of Action is developed to close the identified gaps. This step is completed by June 30th of each year.

During this period the HR specialist and the line manager compare notes. While the HR specialist has their insights gained from the screening interview, the line manager has their insights and experience gained from working together over the past several years. With their combined insights they come to agreement on which Knowledge Areas are critical and in need of transferring or retaining. It should be noted that in some cases while the potential retiree may possess critical knowledge, if it is determined that adequate backup to this knowledge exists also that a specific action plan is not required. At this point the HR specialist and the line manager determine whether the employee actually possesses critical knowledge. If the answer is “yes”, a Plan of Action is developed to transfer or retain that knowledge. Development of the Plan of Action can use any of the Capture Tools described later in this document. When the appropriate knowledge capture tool is matched to the specific Knowledge Area, the action to complete this activity by the end of the current year is entered into CAP where the total Plan of Action for this Critical Retiree is maintained. Line Management is encourage to ensure that the Plan of Action is practical and focused on the specifics. General and vague actions seldom deliver the desired results.

4) The final step is line management implementation of the POA prior to

retirement of the critical retiree. This step is completed prior to December 31st.

It is our position that with enough analysis and dedication of resources, most actions required to capture critical knowledge can be completed within this time frame. This is not a universal truth and occasionally actions will extend into the following year. These actions will be evaluated to ensure they can be successful considering the Critical Retiree’s exit date.

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(A.2) Group Evaluation While the Individual Evaluation process described above represents a very vertical process, the Group Evaluation is intended to provide a more horizontal evaluation. This process also allows leadership to manage knowledge loss from mechanisms other than retirement (e.g. general attrition, movement of a subject matter expert to another working group, Etc.). Training and HR will manage this process jointly. An Educational Specialist and an Employee Development specialist familiar with this process are expected to ensure consistency. Once developed, this process will be a living and recurring tool that requires much less time in maintenance than is does in development. The process can be described in the following steps.

1) Develop an Expertise Matrix for a specific group.

This process is best performed on a working group level by a supervisor and a couple of their most experienced staff. As this group they have one deliverable, to identify those Knowledge Areas that are critical to their success. It should be noted that the identified Knowledge Areas might not be unique to this specific work group (Example: The Knowledge Area of Apparent Cause Evaluation may be required within multiple work groups on site). Experience has shown that someone familiar with this process can facilitate a group of 3 to 4 people to brainstorm this list in 1 to 2 hours. This list of Knowledge Areas is then placed into an Excel spreadsheet used to reflect the Expertise Matrix. The first column down the left side is used to list the identified Knowledge Areas. The row across the top is used to list the employees within the work group. The supervisor will then assign an expertise level to each employee for each Knowledge Area. Experience has shown that the supervisor with assistance from someone familiar with this process can complete assignment of expertise levels within one hour. For consistency, the following expertise levels are used (note that unique background colors are used for each expertise level to facilitate evaluation of the matrix):

NOTE: This evaluation process is currently under development and being piloted within Engineering and Licensing. A STARS working group was also recently established to pursue common interests in portions of this process.

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Expertise Level 1 For this employee, expertise in this Knowledge Area is not

required (Ex: not everyone in a work group will be required to perform Apparent Cause Evaluations)

2 The employee requires this Knowledge Area but does not possess it

3 The employee possess the knowledge, but is not considered proficient

4 The employee is proficient in this Knowledge Area 5 The employee is considered proficient and a good Mentor for

this Knowledge Area The following is an example of an Expertise Matrix.

2) Evaluate the Expertise Matrix to identify existing or potential Knowledge

Gaps.

The next step is for the supervisor to evaluate their depth of critical knowledge within their work group. The color-coding helps to visualize the concept and allows for both a horizontal and vertical evaluation. Horizontally the supervisor can identify specific Knowledge Areas where their group is currently weak or has inadequate depth of expertise. Vertically the supervisor can use this tool to help individual’s increase their value to the work group by increasing their knowledge level. Using the sample Expertise Matrix above as an example, the following observations can be made:

Employees #5 & #6 are relatively new to the work group and are developing their expertise level in several areas

Employee #7 is highly experienced and possibly represents a risk possessing such a large amount of expertise.

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Knowledge Area #2 represents a potential organizational weakness. Only one person has strong proficiency in this area.

Knowledge Area #7 appears to have more than adequate depth with four employees considered to be proficient in the area.

Upon determination of which Knowledge Areas need to be strengthened, the next step is to develop a plan.

3) Develop an Expertise Development Plan for each identified Knowledge Gap.

An Expertise Development Plan is intended to address very specific Knowledge Areas. The preferred development is for a recognized subject matter expert to help describe how they feel they came to be recognized as a subject matter expert. More specifically, identify what knowledge, experience, training, etc., allowed their expertise in this area to develop to this level. When time is taken to qualitatively list these items on paper it is easier to understand the effort that will be needed to develop similar expertise within someone else. Drafting of the Expertise Development Plan is typically accomplished by one or more people considered to be subject matter experts within the knowledge area. The intent is to allow this individual(s) to evaluate and describe what specific training, readings, and experiences allowed them to develop their knowledge level to the point of being considered proficient, or even an expert.

Each Expertise Development Plan will contain the following elements:

a) Specific Skill – What knowledge, qualification, experience, training, etc. the individual must acquire to increase their expertise.

b) Sequence – The supervisor determined sequence in which each Specific Skill should be addressed. Sequencing may be in support of logical development of the expertise or may be in support of work group priorities.

c) Evaluation Standard – Describe what level of knowledge the individual is expected to posses upon completion of this line item. Demonstration will typically be in the form of “Be able to answer the following questions”, or “Be able to describe the following relationship”, etc.

NOTE: As mentioned above a STARS Working Group has developed to pursue common interests in KTR. Development of a common library of Knowledge Areas and their associated Expertise Development Plans is within the current scope of this working group.

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d) Date – The target date for completion of this line item. e) Resources – The resources needed to accomplish this line item. This

field will typically identify reference documents to be read and studied, training to be attended, activities to participate in, etc.

4) Assign a Knowledge Area expert to perform as a Structured SME Mentor for

each Knowledge Gap.

Reference to Structured SME Mentoring is intentional. In this example someone considered to be proficient in a Knowledge Area is assigned to mentor a co-worker to help further develop his or her expertise in an area. It may be necessary to use multiple subject matter experts to accomplish the desired level of expertise within any one individual. The reference to “Structured Mentoring” is in reference to the focused and structured Expertise Development Plan. Structure is provided in the specified areas of development and the established target dates for completion of each line item.

The established Expertise Development Plan will then be reflected in the Performance Management Review of both the Mentor and the Mentee for tracking and accountability.

NOTE: This process of performing as a mentor in a structured process like this is also a common interest to the STARS Working Group. The working group is developing common guidance on this aspect of the process to include how to address generational differences (e.g. if typical mentor is a Baby Boomer to a typical mentee who is a Millenial).

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(A.3) Personal Assessment This is the most common and accessible of the evaluation tools. This is when a knowledgeable worker recognizes the presence of tacit knowledge and the need to move it to explicit knowledge. This process happens every day when someone initiates a Condition Report for a procedure feedback or initiates a training feedback. They are capturing or sharing their tacit knowledge (e.g. personal insights as to how to ensure success in a specific task) within the existing processes that are fundamental to commercial nuclear power. The second example is with continued and routine sharing of personal experiences and knowledge during execution of work activities. A very common example is when experienced Maintenance craft share their insights and experiences with less experienced craft during the performance of a work activity. For this evaluation area to continue to be healthy and productive, the station must continue to place a high value and emphasis on Knowledge Transfer and Retention. Simply working this term into station vocabulary and establishing it as the station Focus Area helps to demonstrate the importance and value of this most informal evaluation process.

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Section B – Plan of Action Development The forms that Plan of Actions takes are described above within the discussions of Evaluation Processes. Their application can be varied and personalized to the needs of the individuals involved. As a recap, use:

a) The Corrective Action Program will be used to capture all actions taken in response to Knowledge Gaps identified during implementation of Individual Evaluation process.

b) Individual Performance Management Review documents will be used to

capture the Expertise Development Plans developed in response to the Group Evaluation Process.

c) Personal Assessments are not expected to result in specific Plan of Actions.

They will typically move direct to procedure feedback (including PMs, PMIs, etc), training feedback, sharing tacit knowledge, etc.

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Section C – Foundational Knowledge Capture Tools There are certain knowledge capture tools that are capable of functioning stand-alone. In other words, they are expected to aid the station is capturing valuable knowledge and being a source to share that knowledge without a specific evaluation process feeding into it. The processes and their use are described below. (C.1) STP|wiki The STP|wiki is built to emulate some of the function of the Internet Wikipedia. Specifically the desired functions are that anyone with a LAN ID can edit content and that the content is easily searchable. It is also firmly established that the STP|wiki is not a controlled document and as such should not be used solely to base operating or maintenance decisions on. The wiki does provide a good and searchable road map to controlled document sources to aid in these controlled processes. While the specific processes and controls for the STP|wiki are described in more detail within the wiki, the general details are as follows:

User Familiarity – General users of the wiki are not expected to require much training. Access is obtained by clicking on the established link on the STP intranet home page and entering the individual’s LAN User ID and associated Password. This will allow the individual to search and surf through any content that does not have restrict viewing. If additional help is needed for this level use there is a User Help section of the wiki including instructional pages and videos to help the user self teach. There is also a significant amount of training material on the internet for the commercial product we chose to implement our wiki (software product name Confluence by Atlassian). Space Administrator – For a work group to establish their own wiki space, they must first establish their Space Administrator. Request forms to establish a space and responsibilities for the Space Administrator are further described in the wiki. In general, the Space Administrator will facilitate development of the wiki pages within their space, ensure group users are comfortable with their role if it includes editing content, and establish restrictions for the space and possibly individual pages. Our wiki product provides great flexibility in establishing controls over who can view and who can edit content. Typical convention is that a space will be established for a work group and while everyone on site can view the content, only individuals within the work group will be allowed to edit content. This level of flexibility is then available on an individual page level as necessary.

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Space administers also have a responsibility that if they become aware of an inappropriate use of the wiki within their space, to take action to correct or remove the material. Space Administrator User Group – To aid in station acceptance of the wiki periodic User Group meetings will be conducted for Space Administrators. The intent is to build up their skills and answer their questions so that they are better able to champion its use.

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(C.2) Video Capture Video capture is intended to provide another dimension to knowledge capture. While verbal and written knowledge transfer has high value, being able to see an infrequently performed or complicated task provides additional depth to the process. Our intent is to make available the tools necessary to capture and develop quality video materials to aid in the overall Knowledge Transfer and Retention program. The basic elements of the program are described below. Video Capture of Field Activities – Infrequently performed or complicated field activities are ripe for video capture. The video can then make a quality contribution to the prejob brief, classroom training, or other informal training outlets. We encourage individuals to identify and practice video capture as appropriate in their work groups. Concerning camera selection we have found that quality video does not require a significant investment. The KTR group is currently supporting camera request with small handheld HD video cameras recording in the MP4 format. These cameras work reasonably well provided strong zoom capability is not required (i.e. the worker can get reasonably close to the subject of the video). If a higher camera capability is desired, each cost center manager can pursue purchase of additional camera hardware as required. Video Capture of Computer Processes – Another value added instructional video involves demonstrating how to navigate through a software application using a screen capture application. Examples of this application are numerous on the internet and at STP can be witnessed in videos explaining how to revise an Expense Report or perform a search within warehouse inventory. To develop such a video tool requires a small time investment of a subject matter expert and a LAN computer with the necessary software. The KTR group has a LAN computer with these capabilities and is also willing to help establish such resources in various work areas. While there are options, our experience is that Camtasia Studio is more than capable of producing this type of product. Camtasia Studio currently costs ~$300 and can be purchased by individual cost centers through Information Technology for installation on specific LAN computers. Another necessary tool would be a USB microphone for narration of these video sequences. Again, KTR group resources are available for use in the NSC or users can purchase this type of equipment at almost any local store with electronics.

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Editing Video Files – Whether the video is captured on a handheld camera or via a screen capture software there is typically a need to perform some editing (e.g. add a title screen, remove unnecessary segments, etc.). Currently the most available resources for video editing are as follows:

a) Request KTR group to perform the editing for you. We can support based on workload and priorities.

b) Use KTR computers located in the NTF and MOF. We have several iMac computers that can edit any popular video format.

c) Purchase Camtasia Studio for one of your LAN machines. In addition to screen capture capabilities Camtasia has some very capable video editing capabilities. A copy can be purchased by any cost center manager as described above under Screen Capture Software.

CAUTION: Camtasia does have limitations concerning which file formats it can edit. For example, the video format of AVC HD is growing in popularity in upper end video cameras and currently is not supported for editing within Camtasia.

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(C.3) STP|onDemand Now that a video has been produced and edited, it should be compiled in an application that provides easy search ability and LAN distribution. To support this function we have established STP|onDemand as our video library application. It is intended to emulate the YouTube functions of search capability, video streaming distribution, and ability to link to a video file within the application. Anyone with LAN access can upload a video to the STP|onDemand video library. The video library is accessible from a link on the STP Intranet home page. Within the “onDemand Tutorial” folder there are two instructional videos:

One describes general navigation within the onDemand video library (e.g. how to search and play a video)

The second describes how to upload a video to the “In Box” area. Immediately upon being uploaded to the In Box of STP|onDemand the video is available for anyone on site to watch using the onDemand video player. The video player is capable of playing all popular video formats and is also capable of video streaming select formats (e.g. wmv). Someone from Training will periodically review the contents of the video library In Box. Those that represent long term value to the station will be moved to a folder more appropriate. Those which represent a more short term value to the station (e.g. video of an equipment degraded condition, etc) will be deleted from the video library after a suitable period of time. If the Training review determines editing would improve the value of the product, it will be discussed with the originator prior to performance. Each video contained in the onDemand video library has a unique URL address. These addresses are only capable of being determined by application administrators. If a user would like to use the URL address as a hyperlink within an Intranet web page or wiki page, they should contact Knowledge Transfer via email address of “Knowledge Transfer” and request identification of the specific video’s URL address.

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Attachment A – Knowledge Capture/Transfer Tools

General Capture Tools The methods or mechanisms used to capture tacit knowledge vary in their level of effort and effectiveness. The following is a list of potential tools to be used when developing a Plan of Action to capture this knowledge. Additional material associated with these tools can be found on the STP wiki. The following is a list of the basic description of these potential tools.

Procedure

Feedback When exiting procedure guidance exists for an activity or process, a procedure revision is the most likely method by which to capture someone’s tacit knowledge. Adding this knowledge to the body of the procedure or within its Notes and Precautions should always be considered one of the first options for capturing tacit knowledge.

Training

Feedback When valuable tacit knowledge is identified by workers within a formal training program, there should be consideration as to whether the knowledge would complement existing training or deserve its own task training. Either way, the individual can provide training feedback or a Condition Report requesting the change of development of training which will then be reviewed by the specific programs Training Advisory Committee (TAC) for inclusion in the program.

Expertise

Development

Plans

This is a way to structure the sharing of knowledge to increase someone’s expertise in a certain subject. The process provides structure in the form of knowledge content, due dates, and subject matter evaluation criteria. Typically used where a Subject Matter Expert Mentor can be assigned to the individual.

Wiki Page

Development

The wiki offers a great place to serve as a repository of informal

knowledge. It is not an alternative to procedures or training, but

lends itself to the many processes and activities where personal

developments are intended to produce understanding and

consistency.

Video

Capture

Value added when used for infrequently performed task or

complicated activities. It allows the future performer to get a

deeper understanding of the task than can be provided by

procedures or training. To further improve the value the video can

be narrated by a subject matter expert to describe the behaviors and

cautions associated with performance.

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Best Practices Best practices are ways of doing business, processes, methods,

strategies, etc. that yield superior results. They have been

implemented and honed over time to a point where they are viewed

as exemplary and should or could be adopted by others. A formal

"benchmarking" process is often used to identify best practices.

Blogs Internal social networking and online collaboration tool. Provides

for direct interaction with subject matter experts and sharing of

experience

Brown Bag

Lunches

From a knowledge sharing perspective, a brown bag lunch is a

structured social gathering during an organizational lunch time

period which is used specifically for the purpose of transferring

knowledge, building trust, social learning, problem solving,

establishing networking or brain storming.

Communities

of Practice

A Community of Practice (COP) is a group of people who share a

common concern, a set of problems, or a passion about a topic, and

who deepen their knowledge and expertise by interacting on an

ongoing basis. They generally cut across traditional organizational

boundaries and enable individuals to acquire new knowledge faster.

COPs can be more or less structured depending on the needs of the

membership.

Document

Repositories

A collection of textual showrooms that can be viewed, retrieved,

and/or downloaded. A document repository adds navigation and

categorization to the information stored. It allows different users to

unlock the intellectual property contained in the documents. This

system can be electronic, paper, or both. The STP wiki provides a

useful mechanism for electronic document repositories as its search

engine can be limited to a specific space and will search any

standard format file (e.g. Word, Excel, PowerPoint, etc) attached to

a wiki page within that space.

Exit

Interviews

Exit Interviews are usually thought of as a rather formal interview

between a manager and staff member leaving an organization,

focusing on the latters reasons for leaving. Increasingly, however,

exit interviews are a label for a specific learning process

emphasizing the importance of capturing and storing know-how.

Obviously, it is impossible to capture all of the knowledge of any

individual, but exit interviews are designed to minimize the loss of

useful knowledge through staff turnover and ease the learning

curve of new staff.

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Expert

Interviews

The Expert interview is ideal for presenting content and encourages

subject matter experts to share knowledge in an informal, relaxed

setting. With minimal preparation of participants, the expert

interview can be initiated in a workshop where participants don't

yet know each other or the organizers. The open layout encourages

greater participation due to its informal nature, and is less

intimidating than a panel discussion.

Desktop

“How to”

Guides

This would entail developing written guidance in an informal

format to help others understand and implement tasks not required

to be controlled by procedures.

Internships

and

Traineeships

Formal arrangements where an experienced person passes along

knowledge and skill to a novice who, after a designated period of

time, reaches the journey level. This process is engrained into the

apprenticeship programs of several accredited training programs at

STP and reflected here for consideration in non-accredited areas

where a less formal apprenticeship, internship, or traineeship may

be of benefit.

Job Aids A job aid can take many forms, but basically it is a document that

has information or instruction on how to perform a task. It guides

the user to do the task correctly and is used while performing the

task, when the person needs to know the process.

Job Rotation Allowing select individuals to rotate job duties over a specific period of time with the intention of increasing their knowledge concerning the varying positions.

Job

Shadowing

Allowing a less experienced worker to follow and collaborate with a more experienced worker with a specific task expertise. This expertise is shared with the less experienced worker.

Knowledge

Fairs

A knowledge fair is an event designed to showcase information

about an organization or a topic. It can be organized in many ways

using speakers, demonstrations, or more commonly, booths

displaying information of interest to the attendees. One example is

the Xerox Corporation's annual "Team Day" that showcases the

work of various quality-improvement teams.

Mentoring

Partnerships

Selecting experienced workers to Mentor less experienced personal has been a staple of professional development. Selection of a Mentor should not be taken lightly and the structure of their relationship should not be left to chance. HR has developed some guidance on this subject that should be

20

referenced before pursuing this option

21


Returning

Retirees

This is where retired employees are brought back for periodic or

part time work to supplement the work force or provide key

knowledge and experience. The retiree can be brought back to

complete the turnover of critical knowledge to select personnel, or

brought in during peek workload periods to supplement the staff.

Story Telling Storytelling uses anecdotal examples to illustrate a point and

effectively transfer knowledge. Within the context of Knowledge

Transfer and Retention at STP we will discuss storytelling as

narratives of employee actions, employee interactions or other

intra-organizational events that are communicated within the

organization, either formally or informally. In some respects,

storytelling already happens in your organization when one

employee shares their story of success or failure with a peer.

22

Attachment B – Typical Tool Usage

While there are no universal rules concerning which Knowledge Capture/Transfer Tool works best for a particular organization, it can be established which tools are expected to be used most often in certain settings. The following table attempts to provide a Quick Start for various organizations.

Setting Top 5 Tools Workers that are part of an Accredited Training Program where a strong procedure base is available (e.g. Operations, Maintenance, Chemistry, and RP)

Procedure Feedback Training Feedback Expertise Development Plan (to

address select expertise areas) Job Shadowing Video Capture

A diverse work group that is highly technical (e.g. Engineering, Licensing, IT And Training).

Expertise Development Plan Wiki page development Returning Retirees Job Shadowing Expert Interviews

An organization with many informal processes that are not proceduralized. Typical employee development is through one-on-one informal mentoring. (e.g. Financial, HR, Document Control)

Expertise Development Plan Wiki page development Returning Retirees Job Aids Desk Top “How To” Guides

BUSINESS UNIT: EXAMPLE

DEPARTMENT: EXAMPLE

Employee: Position:Position Risk Factor: 5 Manager Name/Title:

Steven Hill Sr. Engineer Retirement Risk Factor: 5 John Smith

Sum

mar

y an

d

Situ

atio

n

Ass

essm

ent

At-Risk Assigned To Knowledge Retention Actions Target Date(s) Status and Issues

Knowledge or Skills (Steps which will be taken to retain critical knowledge and skills.) for Completion

Rigorous and alternate piping analysis,

component qualification of code

components and pipe rupture analysis

skill. Mark Jennings

Identify a replacement person for the critical skills.

Replacement person complete ASME courses in piping

analysis and code requirements. Replacement person

develop a working knowledge of T-Pipe Code, ASME Code,

procedures and criteria through reading and mentoring of

_______ and _______. Dec-12 Employees are being cross trained on T-Pipes.

Rigorous and alternate piping analysis,

component qualification of code

components and pipe rupture analysis

skill. John Smith

Incumbent to develop a piping analysis, component

qualification and pipe rupture reference library of

handbooks, procedures, criteria and process in cojunction

with replacement person. Dec-12 On going.

Date Approved:

The incumbent has in depth knowledge of and expertise in piping analysis with emphasis on use of the T-Pipe software. This software is unique to SQN and little duplication of

knowledge exists. Though a replacement person with an engineering degree could become proficient in the use of this software in about six months, at least two years on-the-

job training is needed to repond quickly to urgent questions related to piping analysis. In addition to the T Pipe system, there must be extensive knowledge of the Class II

computer system, SDP- NEDP9, and SQN LDC 13.1 and 24.2. Though a person with a two year degree may be knowledgeable, it is preferable to have someone with a four year

degree in either Civil or Mechanical Engineering.

KNOWLEDGE RETENTION PLAN

Knowledge Retention Plan Prepared By:

Knowledge Retention Plan Approved By:

Additional Notes:

Tennessee Valley Authority Confidential Knowledge Retention Plan

GO BNP CNS HNP MNS ONS RNP

Engineering

Design ‐ Fleet 14

Design ‐ BNP 12

Design ‐ CNS 12

Design ‐ HNP 10

Design ‐ MNS 12

Design ‐ ONS 14

Design ‐ RNP 10

CFAM 12

Fuel ‐ GO 10

Plant Support 12

Mechanical ‐ Site 12 12 10 12 10 10

Electrical ‐ Site 10 12 10 10 16 10

Maintenance

Supervisor 8 8 8 12 8 8

Planner 12 14 8 14 14 12

Mechanical Tech 8 10 10 10 10 8

Electrical Tech 8 14 8 14 10 8

Chemistry

Exempt 10Non‐Exempt 16

Exempt & Non‐exempt 7 9 9 9 9 9

RP

Exempt 14

Non‐Exempt 12


Training

Operations 10 10 10 10 12 10

Technical 10 12 8 14 14 12

Duke Energy's KTR Dashboard

KT&R Implementation Plan

GO and Kings Mountain 12

Work Control


RED = number equal to or greater than 14 indicating the need to consider the organization for the

performance of a KT&R assessment first in the implementation process.

YELLOW = number between 10 ‐ 12 indicating the need to consider the organization for the

performance of a KT&R assessment later in the implementation process.

GREEN = number less than 10 indicating the need to consider the organization for the performance of

a KT&R assessment last in the implementation process.

The content of this article is intended for general information purposes only. It should not be construed as

legal advice or legal opinion on any specific facts or circumstances. You are advised to consult your

attorney for specific legal advice about bringing back retirees as independent contractors.

Late Career Retention and Workforce Development

as Alternatives to Retiree Contracting

Executive Summary

As in other sectors, a common practice in the nuclear energy industry is to bring back retired

employees as independent contractors. This has been a default strategy to cope with a transition to

a newer, less experienced workforce or to balance head count limitations. A closer look reveals

this practice involves considerable costs and drawbacks, including tax complications, legal issues

and a de-emphasis on necessary workforce development measures.

Actively courting senior employees to extend their careers and forestall retirement is an

alternative that preserves the advantages of retiree contracting (institutional knowledge, working

relationships, etc.) without the drawbacks (tax and legal complications, etc.) Weaning an

organization from reliance on independent contractors helps advance the much needed workforce

development goals of filling entry level positions and helping mid-career professionals grow into

senior positions.

This late career retention methodology has been popular with many of industry’s hiring managers

who otherwise need to bring back retired employees as independent contractors to fill immediate

workforce needs. Becoming reliant on retiree contractors, however, is something that all nuclear

organizations should avoid. Instead, organizations should enhance their workforce development

efforts to ensure adequate ranks of new graduate and mid-career professionals to fill vacancies.

They can also provide additional opportunities for knowledge transfer by enticing senior

employees to extend their careers and serve as mentors to the new generation of workers and to

mid-career individuals. Organizations can also implement alternative work schedules to provide

flexibility to late career professionals.

In cases where retirees are brought back as independent contractors, organizations should follow

a number of recommendations to minimize potential financial or tax complications. Independent

contractors should not be assigned to the same role they held when they were full time

employees. Nor should they be assigned jobs that are equivalent to those of other full time

employees. Companies should use the U.S. Internal Revenue Service (IRS) independent

contractor checklist to evaluate all retirees brought back into the organization to ensure

compliance with strict tax requirements.

Problem Statement

The U.S. nuclear energy industry has a large number of nuclear energy workers eligible to retire.

With these retirements creating a projected need to hire up to 25,000 new employees by 20161,

companies should be prepared to replace experienced professionals with capable employees.

1NEI’s 2011 Workforce Pipeline Survey

Industry practice has been to return retirees to the workforce as independent contractors to help

ease the transition to the newer workforce. This practice has been prevalent among hiring

managers because it is the quickest way to find a qualified individual to perform necessary work.

Even when companies change their policies to restrict the practice of bringing back retirees,

hiring managers sometimes make individual hiring decisions that undermine these policies.

Companies can become victim to this short term thinking if robust check points are not put in

place to ensure alignment between a company’s workforce development plan and its actual hiring

practices.

There are many issues to bringing back retirees as contractors. Unless retirees are being offered

salary and benefits as independent contractors that will offset their pensions, they will want to

make sure they keep their pension benefits intact. But employees are usually not eligible to

receive both a salary and their pension from the same company. More importantly, companies

that embrace the practice of bringing back retirees risk running afoul of the IRS.

Risks of Misclassifying Employees as Independent Contractors

Companies must understand the dangers of applying the Independent Contractor status too

loosely. The IRS maintains specific requirements for companies that give workers Independent

Contractor status and imposes hefty fines for noncompliance. These requirements are meant to

protect employees from unscrupulous employers who want to leverage the Independent

Contractor status as a way to avoid paying benefits, taxes and overtime pay.

The U.S. Bureau of Labor Statistics reports that about 7.3 percent for the workforce (10.3 million

workers) in the United States are independent contractors2. Of those workers, the U.S.

Government estimates that between 30 to 50 percent are misclassified3.

Misclassification of employees as independent contractors can be costly, regardless of whether

this is done intentionally or by mistake. Employer liability can include unpaid federal, state and

local income tax withholdings as well as Social Security and Medicare contributions, unpaid

workers’ compensation, unemployment insurance premiums and even unpaid overtime

compensation. All of these payments can be compounded with interest and penalties by the IRS

and other government agencies.

In addition, some states have enacted their own legislation to stem the loss of state tax revenue

that results from misclassification. According to the National Conference of State Legislatures, 26

states introduced measures in 2012 to either create or amend their laws on this issue. California

has the most significant financial penalties for employers who misclassify employees, with fines

of up to $25,000 per violation4. Pennsylvania, New York, Nebraska, Massachusetts and New

Jersey have gone so far as to introduce criminal penalties as well5.

The U.S. Small Business Administration cites additional liabilities where misclassified workers

who are otherwise entitled to coverage under employee benefit plans are not provided with

2GAO Report 09-717 (Aug. 10, 2009) at 1. 3GAO Report 09-717 at 11-13. 4California Labor Code Section 226.8. 5 Wood, R.W., (Oct. 15, 2010). Criminal Penalties for Misclassifying Independent Contractors.Forbes Magazine. Found on December 22, 2013 at http://www.forbes.com/sites/robertwood/2010/10/15/criminal-penalties-for-misclassifying-independent-contractors/.

http://www.forbes.com/sites/robertwood/2010/10/15/criminal-penalties-for-misclassifying-independent-contractors/

http://www.forbes.com/sites/robertwood/2010/10/15/criminal-penalties-for-misclassifying-independent-contractors/

health, pension, and other employee benefits6. In such cases, employers may have to retroactively

reimburse workers for these lost benefits.

In one classic example from the mid-1990s, Microsoft settled a landmark benefits case brought

by 3,000 misclassified employees. These individuals had not been eligible for the Microsoft stock

purchase plan while classified as independent contractors. Once they were determined to have

been misclassified, Microsoft spent an estimated $101 million to hire them as full time employees

and the settled the case by repaying $97 million in back stock options, interest and legal fees.7

Bringing Back Retirees Impedes Workforce Development

Inviting retirees back as independent contractors forestalls the inevitable need to develop the

workforce. This is something the industry can scarcely afford to do, given an estimated 39

percent retirement rate by 2016.8 Leadership development of incumbent mid-career employees is

necessary along with education and training programs to bring new entry level employees on

board. These priorities were underscored at a recent nuclear energy industry leadership

conference. Yet members of NEI’s Nuclear Talent Taskforce have overwhelmingly found that

retaining late career employees is difficult in an environment where the majority of companies are

bringing back retirees as contractors instead of developing their own workforce.

Many late career employees will purposefully retire when they first become eligible for their

pension payout, knowing they can double their salaries by returning to work as independent

contractors. This process, formally known as concurrent receipt, is commonly called “double

dipping”. Human resource and leadership development specialists have concluded that workforce

development interests are undermined when retirees are routinely brought back as contractors in

lieu of hiring new employees to fill vacancies.

Alternatives to Bringing Back Retirees

One alternative to bringing back retirees is to extend senior employees’ careers within the

industry. The Society for Human Resource Management (SHRM) has created many best practice

documents outlining strategies for extending senior employees’ careers. These best practices

include strategies for phased retirement, job sharing, alternative work schedules and knowledge

transfer positions. Most of the nuclear energy industry’s human resource professionals are

members of SHRM and have access to its extensive library of materials.

Another alternative to bringing back retirees is for companies to develop their own workforce so

they have the bench strength to fill individual contributor and leadership positions when senior

employees retire. SHRM has many resources for succession planning, leadership development

and knowledge transfer to ensure a steady and robust workforce. These strategies can be adopted

and customized to fit a nuclear energy company’s specific needs.

Best Practices for Situations Where Bringing Back Retirees is Deemed Necessary

If retirees must be brought back into the workforce, several best practices can help avoid the

potential tax pitfalls. Companies can provide the retirees with a limited work scope that is

different enough from their previous jobs so that they meet independent contractor requirements.

Companies can implement a break in service and implement term limits. Another strategy is to

remove a contractor’s need to collect pension benefits. Companies can do this by bringing back

6U.S. Small Business Administration. Found on January 4, 2013 athttp://www.sba.gov/content/hire-contractor-or-employee. 7 See 142 F.Supp.2d 1299 (W.D. Wash. 2001). 8 NEI’s 2011 Workforce Pipeline Survey

http://www.sba.gov/content/hire-contractor-or-employee

http://www.sba.gov/content/hire-contractor-or-employee

the retiree as an employee and reinstating benefits; or they may choose to compensate retirees

enough so they can obtain their own interim benefits while employed.

Conclusion

Bringing back retirees as independent contractors has been a common practice in the nuclear

energy industry over the past few years. This strategy can help offset a company’s near-term

workforce difficulties while transitioning to a newer employee base, but it also can delay a

company’s ultimate goal of having a robust, sustainable workforce. To ensure long-term viability,

nuclear energy companies should consider implementing widely accepted alternatives to bringing

back retirees as independent contractors.

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