Overview
1. Introduction
This report summarizes the results of the peer review (hereafter referred to as"review") conducted at Nuclear Development Corporation (NDC). In the Reviews
conducted by Japan Nuclear Technology Institute (JANTI), review teams consistingof experts from both the member organization and JANTI visit the member facilities
to conduct a specialized technical review regarding the theme of nuclear safety.
The purpose of the review is to promote safety culture in the whole nuclear powerindustry by identifying good practices from which other members can learn andareas for improvement of the facility.
2. Overview of the Facility Reviewed

2.1 Company history
NDC was established in April 1990 through a succession of the operations ofboth Tokai Experiment Station, Takasago Research Institute of Mitsubishi Heavy
Industries, Ltd. and Tokai Research Institute of Mitsubishi Atomic Power
Industries, Inc., which merged with Mitsubishi Heavy Industries, Ltd. in 1995.

In

April 1998, all of the operations of Nuclear Power Applied Technology
Department (reactor chemistry, radiation measurement, etc.) of the Mitsubishi
Heavy Industries, Ltd. including reactor chemistry and radiation were transferred
to NDC where they continue to be up to the present.

NDC is located in

Tokai-mura, Naka-gun, Ibaraki Prefecture and has approximately 80 employees.

2.2

Business profile

NDC specializes in nuclear power research and development.

It conducts

research and development as well as verification testing and evaluation forsafety and reliability with regard to nuclear fuel, nuclear reactor materials,
reactor chemistry, radiation measurement and so on.
The research and development of nuclear fuel includes the improvement,
development and research on fuel pellets, fuel clad as well as the development
and testing of fuel assemblies. Post-irradiation testing of spent fuel at nuclear
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power plants is also conducted in hot cells.
In the research and development concerning reactor components and otherrelated materials, test pieces placed inside the reactor beforehand (surveillance
test pieces) are examined in hot cells to confirm the integrity of the materials. In
addition, NDC conducts performance tests of charcoal filters used in power
station HVAC systems to confirm the containment function of power plants.
In research and development related to reactor chemistry and radiation, thecompany undertakes improvements in PWR primary system water quality
control technology, development of technology to reduce radiation exposure at
power plants, development of technology for measuring radioactivity ofradioactive waste, radiation behavior analysis and design of shielding, and soforth.
The obtained results have been applied to nuclear fuel, PWR plants,
reprocessing facilities, waste disposal facilities and so on.

3. Review viewpoints
This is third peer review for NDC including the reviews by JANTI’s
predecessor, Nuclear Safety Network, in July 2000 and March 2005.

In thisreview, the review team mainly focused on those which have been altered after
the previous review as well as the company's current activities.

NDC exclusively engaged in nuclear power research and development andhas obtained a license to use nuclear fuel material and radioactive isotopes.

It

has also enacted the Safety Regulations for Fuel Hot Laboratories and Nuclear
Fuel Material Use Facilities. Since 2004, quality assurance program has been
included in the scope of the Safety Regulations and the Safety Quality
Assurance Plan has been enacted as a subordinate regulation, on which theCompany has been carring out its safety activities.
The NDC Company Policy, which gives the basic managerial philosophy of NDC,
expressly states: "Ensure the nuclear safety first and contribute to the developmentof nuclear industry". In addition, it cites: "challenge high goals," "develop newtechnology and enhance research capabilities," "communicate actively with entities2

outside the company," "achieve a liberal and open-minded workplace," etc. Also,
standards of the NDC Employee behavior consists of six statements, including "putthe nuclear safety first before everything else," "perform duties with integrity," and"endeavor to vitalize the workplace, to improve and refine operations, and to develop
new technology."

Based on the situations above, following points were focused in the review:
・Specific activities to cultivate a safety culture

・

Disseminationofseniormanagement

policyintoresearch,development and testing works
・Communication between the Testing and Research Departments・

Performance of testing・

Handling of minor nonconformance・

Approach to the reduction of radiation exposure

・Conditions of the workplace・Planning and training for emergencies

Specifically, the review was conducted in four functional areas: organization andadministration, training, work management and maintenance, and radiation
protection. In addition, following four items were reviewed as key issues: criticalsafety, UF6 leak events, nonconformance management and human error prevention,and risk management.

4. Conducting the Review(1) Review dates

October 22 (Wed) to October 24 (Fri), 2008
(2) Review team composition

Team leader: from NS Network Division, JANTITeam members: team leader and five others(One from Hitachi Zosen Mechanical Corporation, one from Kobe Steel,3

Ltd. three from NS Network Divison JANTI, and one from JANTI as atechnical advisor)(3) Allocation of Review group assignments

Group A: organization and administration, key issues
Group B: training, work management and maintenance, radiation protection

45. Review schedule
The review was carried out over a period of three days, with the schedule for each of
the groups as shown below.
Group B

Group A

(Training, work management and maintenance,(Organization and administration, key issues)radiation protection)

Review team meeting
Opening (greeting, member introduction)

AM

Interview with the President○Training○Key issues

Management

Interview○Radiation

Senior staff, etc.

Interview

Management, etc.

Interviewprotection○Training
Oct.

○Work

22

Event

(Wed)

Event observation

observation

management
andmaintenance○Radiation

PM

protection○Organization andadministration○Key issues

Management,
Personnel responsible

Interview

On-siteOn-siteobservation

observation

Review team meeting
Debriefing with host (Confirm review results, confirm schedule for 2nd day)Observation
morningofOn-sitegreeting,

observation

ObservationofOn-sitemeetings, etc.

observation

etc.

AM
○Organization andadministration

Oct.
23

○Training
Management,
Personnel responsible

Interview○Work
management○Key issues

Management,
Personnel responsible

Interview

Personnel
etc.

Interview

andmaintenance(Thu)

Event observation

walk-down○Trainingobservation○Workmanagement○Organization andPMadministration

Senior Staff responsible

Interview

responsible,andmaintenance○Key issues

Review team meeting
Debriefing with host (Confirm review results, confirm schedule for 3rd day)
Oct.

Review team meeting

24
(Fri)

AM

[Confirm findings]
Make final adjustments with hostClosing preparations

5

PM

Closing (explanation of results)

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6. Review Method and Report of Review Results
6.1 Review Method(1) Document Review
Facility documents, such as business directions and expectations, manuals
and relevant documents, for each review item were explained by facility
personnel and reviewed by the team(2) Interviews
55 people including the president, managers, and personnel responsible wereinterviewed. Also, questions based on document review were asked to facility
perssonel.
(3) Observation
Along with items confirmed through document review and interviews, several
activities of the Company were observed.

In addition, the review team discussed with NDC personnel by providing industy
best practice which would be good reference for NDC while carring out document
review, interviews and observations.

6.2 Report of Review Results
Good practices and areas for improvement were developed based on the resultsof document review, interviews, and observations with regard to each review area.
"Good practices" shall be defined as "exemplary, effective, and unique practices
and/or processes of the facility that ensure safety and are worthy to be widely
shared with JANTI members and those in nuclear power industry.""Areas for improvement" shall be difined as "suggestions for further
improvement/refinement of reviewed facility's activities made through thecomparison with industry best practices, in order to achieve the excellence innuclear safety." Due to this definition, areas for improvement are sometimes madeeven thought the current activities are above the average of nuclear industry
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standards.
7. Summary Interview with President

The review team interviewed the President in order to understand the senior
management policies. His thoughts are shown as follow:(1) Nuclear safety at NDC
Ensuring nuclear safety is essential for NDC to continue to exist. NDC is the
only company in the Mitsubishi Heavy Industries Group that handles radioactive
material. We always address the work of research and development with anawareness of potential risks.

We experienced the increase of radiation

monitors in our site when there was a criticality accident at JCO because NDC
is located close to JCO. I think it was the experience that diffused a sense of
nuclear safety as the highest priority among the employees.
If something should happen, it would result in problems not only for NDC, but
the nuclear industry of Japan and in some cases, of the world. We have theemployees keep in mind that ensuring the nuclear safety is everything to us.
We just do the right things in the right way as a matter of course. We do not
accept the status quo blindly only because nothing has happened.
I think NDC has established an appropriately system to ensure nuclear safety,
however, we should make further improvement gradually by looking forproblems in the workplace. Even though the each improvement may be small,continuous improvement will result in significant change even thought the
improment is small. There is no sense in making quick forceful changes. To thisend, I say to the employees that they should scrupulously acquire training,
improve their skills and knowledge, and conduct themselves with pride in theirwork.

(2) Specific activities to cultivate a safety culture
In cultivating a safety culture, what should be done depends on the level in6the organization that the personnel belongs: the top level management, themanagers and workers.

The NDC Company Policy and the Guideline of

Employees’ Behavior, which is the company's action plan, are written to spread
an awareness of the importance of ensuring nuclear safety among all thecompany's employees. We believe that the safety culture will be fostered bycarring out duties steadily in accordance with these plans.
One of the specific efforts to cultivate a safety culture is, for instance, themessages from the top management to employees through the addresses atinstallation ceremony of CEO, new year ceremony, and safety week as well as
through the in-house website.

Another example is meetings set up on avariety of levels, such as senior management meeting, division and department
managers meeting, and employees meeting.

These meeting allow personnel

to hear from the top level management. Communication within the workplace isalso enhanced through these meetings.

(3) Dissemination of president policy to the work site
All managers are requested to disseminate the president's policy in the worksite.
I visit the work site as much as possible. I believe that a safety culture starts
with the morning meeting at the beginning of the day. Therefore, I participate
daily in the morning assemblies of the Testing Department and the Safety
Management Office. I also deliver lectures four times a year.
I also join the Health and Safety Committee Patrols and the Pre-work safety
verification activities (KYK). Even if the president does not say anything, justmy presence serves to raise the motivation of employees.

(4) Reporting culture
I strive to create the atmosphere in the workplace that allows employees todiscuss frankly.

It is important that personnel do not keep silent whensomething would happen. I see to it that reporting, contact, consultation andcommunication are always conducted in an active manner. I do not impose
penalties on those who bring forward issues, but commend them because we
7learn from problems or consider them as opportunities for improvement. I
think that we have a culture where even negative information is easily
communicated. Even minor near-miss events are reported.

(5) Strenght and confronting issues
Since NDC is the only organization which possesses a hot laboratory within
Mitsubishi Heavy Industries, Ltd., we are able to advance research anddevelopment of radioactive materials and send those results out.
There are three issues we are facing.
The first is knowledge management. There are many employees near theage of 60. In preparation for the retirement of these experienced personnel,
we are conducting “e-Tradition Activity” (activity digitalizing the knowledge) topass on the knowledge of experienced personnel, and the activity to enhance
our unique technical knowledge considering ten years ahead.
The second is measures concerning aging facilities. Most of our facilities
are unique and, in case of failure, it is hard to acquire replacement. We willdevelop a medium-term plan by April of this year and address this issue
systematically.
The third is developing capabilities of personnel and securing personnel.

(6) Performance status
A company activity plan is prepared annually. Based on this plan, eachdepartment formulates its own plan and undertakes its work. A follow-up is
conducted at the half-year mark and the plan is recapitulated at the end of the
fiscal year. The same thing is done with the training plan.
Also, risk management is implemented by the Safety and Health Committee.
In order to diminish risks, we are scrupulously implementing the Pre-work safety
verification activities (KYK), taking countermeasures against other company's
events and so on. Additionally, when installing new facilities or equipment, we
examine risk reduction within the context of validation activities before and after
research and development operations as well as KYK.
With regard to the zirconium fire which occurred the other day at Mitsubishi
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Nuclear Fuel Co., Ltd., we conducted reproducible experiments to acquire
knowledge and had a real feeling for the risks so as to raise our safety
consciousness.

(7) Expectations for management
I expect the managers to appropriately convey the president's ideas to thoseactually doing the work.

Also, I want them to steadily implement safety

activities without cutting corners. As I stated previously, I want them to strive toimprove while always wondering if things are really all right, and be sufficiently
aware of the importance of reporting, correspondence, consultation andcommunication.

(8) Addressing recent events
Although there have been few events at our company, they have occurred.
Therefore, we are conducting in-depth investigation regarding the causes of theevents implementing countermeasures to prevent reoccurrence and similar
events. We do the same with events occurred at other companies.
With regard to insufficient checks becoming the cause of nonconformance, I
am considering the tasks which we should address. The key issues for thisyear are the steady implementation of PDCA, preventing the occurrence ofnonconformance, and properly responding to matters indicated by regulatory
inspections or other external bodies.

(9) Expectations for peer review
I expect that by having an outside perspective, the peer review will provide us
with instructive indications regarding aspects which the participants on site do
not notice.
Also, I think the peer review will create an air of tension bearing on theemployees' safety consciousness and it is a good opportunity for reconsidering
our own actions. Moreover, I would like to ask that it be used as an opportunity
for enhancing the compliance awareness of our new employees.

9(10) Others
Since assuming this post at NDC, considering my experience in areas otherthan nuclear power in the past, I realized afresh that anybody involved innuclear power industry, are earnestly addressing the work without cutting
corners. Accordingly, since becoming president, it has been my intention not
to make sudden forceful reforms, but make small improvements and continue
these unceasingly so that major changes will take place before long.

I

continue to treasure the culture here that my seniors ardently built and will makethis an even better company.

108. Synopsis of Review Results
At NDC, the idea of "prioritizing nuclear safety" is stipulated in the company policy
and other statements. This idea is spread throughout the entire company throughdaily activities from the top level to managers and the personnel responsible. Since
the top level and managers frequently visit the work site to convey messages andcommunicate, a workplace with a good open atmosphere has been created and aclimate is in place where anything can be reported. It is expected that the company
will maintain a high awareness of nuclear safety in the future as well. In addition to
the current activities, it is desirable for the company, as a means for further raising
this awareness, to enhance the systematic recognition of activities so as to foster asafety culture as well as formulate and implement new approaches and policies forthe same activities.
At NDC, there have been few occurrences of nonconformance events. The
company diagnoses the causes of each event and adopts measures to prevent areoccurrence. With regard to events which occur externally, the company alsofaithfully takes countermeasures. Furthermore, attempts are made in research anddevelopment operations to prevent nonconformance by creating rules for theadministration of review meetings (FRM, ORM) by the relevant departments andsections before and after the commencement of research and development. Minor
failures are reported orally and the necessary measures are adopted, but it isdesirable to lead to the prevention of the occurrence of major events by recording,analyzing and effectively utilizing such information.
Also, NDC is an organization of experts possessing specialized skills and is facing
the issue of securing personnel and handing down technical knowledge due to theaging of its employees. The e-Tradition Activity is being promoted for the purposeof transmitting technical knowledge and accumulating specialized techniques. It isbeing improved for use and the expectation is that it will be a continuing effort as
well.

Listed below are one good practice and four areas for improvement extracted as
specific review results.
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Please note that these areas for improvement do not need to be responded to
immediately for nuclear safety.

128.1 Good Practices(Organization/administration)
None in particular(Education/training)
None in particular(Work management/maintenance)● Activities to prevent nonconformance in research and development operations
In the research and development operations, there are review meetings [FRM(front loading review meetings) and ORM (outlet review meetings)], which arepreventive

measures andactivities implemented

in

order

to

prevent

nonconformance. FRM and ORM deduce potential challenges in new areas,
new equipment and facilities and so forth, and are effective as a means for
adopting countermeasures in advance.
The Research and Development Department prepares a work plan prior tocommencing research and development. In the FRM, diversified opinions andrequests of the relevant departments are compiled and integrated into the work
plan from the perspective of safety and quality regarding the system, devices,
procedures, and so forth. Then, development and testing is implemented. Afterthe conclusion of the research and development, the effectiveness of thepreventive measures examined in the FRM and the appropriateness of theresearch and development results are verified during the ORM.

(Radiation protection)
None in particular(Key issues)
None in particular138.2 Areas for Improvement(Organization/administration)● Further enhancement of activities to cultivate a safety culture
There is an adequate awareness from the top level of the company down to thepersonnel responsible regarding the importance of nuclear safety.

This isregarded as something fostered through everyday operations. In addition, one
factor is thought to be also the experience of responding to an emergency as themonitors inside the establishment went up during the JCO criticality accident.
In order to maintain and improve the present high level of awareness regarding
nuclear safety, it would be desirable to systematically consolidate the activities forcultivating a safety culture and formulate new approaches and policies andimplement them.

(Education/training)
None in particular(Work management/maintenance)● Control of operator aids in the work site
Various operator aids, such as "wiring diagram" on the distribution panel and"use prohibited" on the testing equipment, exist within the facility. However, they
have not been controlled with such information as issue date, expiration date, andname of personnel responsible.
Unless the operator aids on this testing equipment are controlled, this could leadto misuse of the equipment. Therefore, it is desirable to have the operator aids
appropriately controlled.

(Radiation protection)
None in particular(Key issues)● Analysis and effective utilization of minor internal events to prevent events from14

occurring
Comparatively major events including nonconformance are properly reported,
their causes are analyzed, measures to prevent reoccurrence are undertaken andthey are recorded. On the contrary, although minor events are reported to thesuperior on such occasions and the necessary measures are taken, efforts suchas recording the minor events for the entire organization and analyzing the trends
and similarities are not adequately undertaken.
With regard to minor events as well, it is desirable to record and analyze theirtrends and similarity in order to prevent the occurrence of major events.
● Further enhancement of analysis of the causes of nonconformance events
The frequency of nonconformance at NDC is low and major ones have notarisen. Also, for the nonconformance which has occurred, the major causes
have been identified and measures to prevent reoccurrence have been adopted
to the relevant equipment as well as similar equipment. However, it is difficult to
say that a systematic analysis of the causes of events is being conducted.
In order to implement more effective measures to prevent failures fromoccurring, it is desirable to have a complete analysis of the causes with reference
to analytical methods recognized by academia or industry.

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