Overview
1. Introduction
This report summarizes the results of the peer review (hereafter referred to as "review")
conducted at Mitsubishi Nuclear Fuel CO., LTD. (MNF). In the Reviews conducted by
Japan Nuclear Technology Institute (JANTI), review teams consisting of experts from boththe 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 topromote safety culture in the whole nuclear power industry by identifying good practices
from which other members can learn and areas for improvement of the facility.

2. Overview of the Facility Reviewed
MNF was founded in December 1971, with its main line of business being the
fabrication of fuel for pressurized water reactor (PWR fuel), and engages in a full rangeof production from reconversion processing to assembling fuel assemblies, and is only
domestic fuel processing manufacturer in Japan.

The number of employees including

contractors was approximately 500 as of May 2008.

The site is locating in Tokai-muraand Naka-city, with the main manufacturing facility in Tokai-mura, whereas the
production building where gadolinia-added uranium fuel is produced and the fuelprocessing testing building are both in Naka-city.
The processing facilities (main manufacturing facility and production building where
gadolinia-added uranium fuel is produced) are licensed to handle uranium that isenriched up to a maximum of 5%, and presently handles mainly uranium enriched to
4.1% and 4.8%.
The reconversion manufacturing (i.e. processing the raw material, which is uranium
hexafluoride, into uranium dioxide powder) and molding manufacturing (processing tosolidify uranium dioxide powder into cylindrical shaped pieces called pellets) work is
carried out 24 hours a day in three work-shifts (only two shifts for some parts of themolding manufacturing work) and the assembly work (assembling fuel rods andassembling the fuel assemblies) is done in day-shift operations only.

In the productionbuilding where gadolinia-added uranium fuel is processed, the gadolinia-added uraniumfuel pellets undergo the manufacturing process and these are then inserted into the fuelcladding to assemble fuel rods.

Of these processes, the pellet manufacturing process iscarried out around the clock in three work-shifts (except for some parts of the molding
process which is done in two work-shifts).
The MNF track record for producing fuel as of the end of May 2008 stands at 18,096
fuel assemblies and reconversion at 9,893 tons of uranium dioxide powder.

3. Review Viewpoint
Including Reviews by JANTI's predecessor, Nuclear Safety Network, this is the third
Review, the previous ones being in April 2000 and January 2005. For this Review, in
addition to the main focus on current activities, things that have changed since the previous
review and the state of endeavors toward "areas for improvement" from the last time will
also be reviewed.

Furthermore, MNF has been promoting the following as foundation building activities(enhancing equipment safety and the like) aimed at the assurance of comprehensive safety(nuclear safety, industrial safety, and environmental safety) since 2005: (1) promoting
motivation toward safety and systematic and continuous work improvement activities (MVP(MNF Value Plan) activities) that is consistent with the raising of product quality to an evenhigher plateau, (2) creating frank and vigorous atmosphere in work site to promote safety
culture, and (3) promoting Corporate Social Responsibility (CSR) so as to fulfil social
responsibilities expected as a member of the nuclear power industry.

Based on the above situations, following points were focused in the review.
・communicating top-management policies in the fuel production process andengineering development process・

continuous safety culture promotion activities

・

training plans, skill management, qualification certification

・

preventive maintenance・

endeavors in industrial safety

・

work site condition and workers' performance

・

criticality safety・

non-conformity management・human error preventive measures・risk management

Specifically, the review were conducted in the four functional areas; "organization &administration," "training," "work management & maintenance," and "radiation protection".
In addition, following four items are reviewed as key issues; "criticality safety," "UF６leakage event," "non-conformity management and prevention of human errors," and "riskmanagement."

4. Conducting the Review(1) Review dates
June 25 (Wed) to June 27 (Fri), 2008
(2) Review team composition
Team leader: from JANTI NS Net Division
Team members: team leader plus six others(1 from JGC Corporation, 1 from Nuclear Development Corporation and 4 fromJANTI NS Net Division)(3) Allocation of Review group assignments
Group A: organization & administration, key issues
Group B: training, work management & maintenance, radiation protection

5. Review Schedule
The Review was carried out over a period of three days, with the schedule for each of thegroups as shown below.
Group A
(organization & administration, key issues)
June25(Wed) AM

PM

Group B
(training, work management & maintenance, radiation
protection)

Meeting of the Review Team Members, etc. (60 minutes)
Opening (Greetings & Introduction of Members) (30 minutes)
Interview with Superintendent of Safety Management (60 minutes)
Documents
Overall
Overall(90 minutes)
event
on-siteEventobservation
observation
observation(15 minutes)

Documents(90 minutes)
on-siteobservation(180 minutes)

○organization& administration management class○key issues

interview (150
minutes)

observation ofshift handover

on-siteobservation(60 minutes)

observation ofshift handover

on-siteobservation(30 minutes)

Meeting of the Review Team Members, etc. (60 minutes)
Debriefing with host (confirm review results, confirm plans for day 2, etc.) (30 minutes)
observation of
meetingAM○organization& administration management class○key issues

June
26
(Thu)

event observation

PM

June
27
(Fri)

AM
PM

○traininginterviews○work(210 minutes)
management&
management classmaintenance○radiation
protection
event
observation○training(90 minutes) ○work
management engineer, etc.
&
interviews
maintenance(120 minutes)○organization& operationengineer, etc.
○important
issuesMeeting of the Review Team Members, etc. (60 minutes)
Debriefing with host (confirm review results, confirm plans for day 3, etc.) (30 minutes)
Meeting of the Review Team Members, etc. (30 minutes)[confirm findings] (150 minutes)
make final adjustments with host / review final closing report documents
closing preparations (30 minutes)
closing (explanation of results, etc.) (60 minutes)

on-siteobservation(15 minutes)

interviews(200 minutes)

interviews(180 minutes)

6. Review Method and Method of Summarizing Review Results
6.1 Review Method(1) Documents Review
Facility documents such as business directions and expectations, manuals and relevant
documents were explained by facility personnel and reviewed by team for eachindividual review item.

(2) Interviews
65 persons, including the company Vice President (Superintendent of Safety
Management), managers, engineers and workers were interviewed. Moreover, questions
based on documents review were asked to facility persons.

(3) Observation
In this review, along with items confirmed through document review and interviews,
several activities at MNF were also observed.

In addition, review team discussed with MNF people with providing industry bestpractices (examples of high standard and quality) which would be good reference for MNF
during document reviews, interviews and observations.

6.2 Method of Summarizing Review Results
Good practices and areas for improvement were developed based on documents review,interviews and observations with regard to each Review area.
For the purpose of this discussion, "good practices" shall be defined as "examples ofpractices and/or processes in facility activities to ensure safety, which are especiallyexemplary, appropriate, effective and unique and, resulted good performance. And, these
are worth to share with JANTI members and nuclear power industry. ""Areas for improvement" shall be defined as "Suggestions to improve activities toensure nuclear safety in the facility, which are developed by comparing best practices innuclear power industry in order to lead the facility to ultimate level of nuclear safety."
Toward this aim, areas for improvement are sometimes made, even though the current stateof activities is the same as or better than what are considered average standards throughout
the nuclear power industry.

7. Summary of interview with Company Vice President (Superintendent of
Safety Management)
In order to understand the policies of MNF's senior management, the review teaminterviewed the company vice president who is concurrently the Superintendent of Safety
Management. His thoughts are shown as follow.

1) Nuclear safety at MNF
Nuclear safety is something like a cross to be carried by corporate members of thenuclear power industry, and a company can be called a first-class company only when it
sincerely endeavors to maintain safety. Superintendent said he also feels that nuclear safety
is evidence of the company being able to give employees and their families peace of mind.
Insofar as this is so, he has to talk to the staff about the risks that exist day in and day out
in order to preserve an attitude of nuclear safety. Safety is something that has to beacquired by each person for him/herself. Accordingly, the first thing is to obey rules, andif there is a person among us who does not obey the rules, we must make that person obey.
The Superintendent said he believes that the level of nuclear safety measures at MNF in
comparison to other foreign and domestic companies in the same field is top-class.

2) Endeavors in the promotion and reinforce of safety culture
Indicators of safety culture are that there are no injuries, no deviations from the rules,
and a self-correction mechanism.
Generally speaking, he feels that there is a three-fold difference in ability among all
individual employees, and a ten-fold difference in disposition. In order to reinforce safety
despite this difference in individuals, however, we must make all of the approximately 500
employees feel that they are taking one step further toward advancing safety culture. If
even one person lacks that feeling, things will not go well. In order to reinforce safetyawareness among all employees, awards for blue-chip department in industrial safety wereintroduced and this makes each department strive for safety.

Furthermore, this ismentioned in monthly safety report meeting discussions and published on the intranet
safety homepage and in the company newsletter, and when trouble occurs, all employees
are assembled and given direction and the like, and seizing the opportunity, endeavors are
made to improve safety culture.

(3) Strengths and confronting issues
As for strengths, in the 35 years since the company began operation, there has not been asignificant accident, and the company is proud to have the solid confidence of customers.
On the other hand, there is concern that it could conversely lead to a false sense of security.
Other than that, another issue is that when the nuclear fuel cycle goes into effect, the levelof effectiveness of safety activities will have to be raised in order for the company tocontinue developing. The company has got to face the challenge of how to proceed so as
to head in the best direction.

(4) State of performance
Performance can also be thought of as a battle against risks. How to manage risks is an
important question. It is very important that sensitivity to risk should never fade bysystematizing the management risks and the work-site risks.

(5) Expectations on managers (all general managers, section managers, etc.)
Managers have to be aware that they are entrusted with their subordinates and theequipment in the performance of their jobs. MNF has an excellent track record of
response when troubles occur. However, the Superintendent hopes the managers will
discover symptoms of looming problems at an earlier stage, and thus be able to stave off
trouble before it happens.

(6) Reporting culture
In the Superintendent's opinion, the company earns a passing score in the eyes of thegeneral public when it comes to reporting.

However, the "reporting culture"

consciousness is not something that always existed. That is because the company got its

start in a family-like atmosphere and there was really no need for it. But at the present
time the importance of the "reporting culture" has become ingrained in the consciousnessof all employees. Unless the reported issues are paid enough attention and responded,trust will not materialize. And without this relationship of trust, the "reporting culture"itself will not function properly. Middle managers especially need to have a sense ofurgency and responsibility to deal with reported issues and must give a response. In thissense, the company still has a long way to go. In order to make the reporting culture takeroot, it will still take a while longer. Ideally, reports would be submitted without the needto ask for them. However, the company is still in the development stages in this respect.

(7) Making the company president's policies known at the front lines of work-sites
It is important that the top management make visits to the work sites. The President
makes a visit to work sites once a week, Vice President once or twice a week, and directors
almost every day, and they make effort to talk to the employees there.

(8) Endeavors in passing on skills
The transition to the next generation is a serious problem for MNF as the baby-boomers
hired when the company was first established reach the age for retirement, and so a humanresource development plan has been established to deal with orderly personnel training.
The plan appears to be progressing on track. A plan has also been drawn up for passing
down skills to the next generation and endeavors are being made toward that end.

(9) Training policies
A training program has been formulated and trainings are carried out based on this plan
according to the situation at each work site. Comprehensive safety training is carried out
evenly across the board for all employees actually working at the plant including
employees of contractors. However, there are different levels of employees attending thetraining, and so questionnaire surveys were done. In addition, manager class personnel
also attend training sessions outside the company.

(10) Expectations on the Peer Review TeamThe work involved in fabricating nuclear fuel has its own distinct characteristics, and forthat reason, MNF employees seldom have the opportunity to learn from other companies
in the same line of business or other fields of business. Through observations, interviews,
and document reviews in the peer review, MNF hope to receive advice and hear about
good practices that can be applied to their own company and lead to the improvement ofsafety culture. And the company hopes to proactively gain recognition from the generalpublic with its endeavors aimed at improving safety culture through the company's safety
activities from the standpoint of JANTI expert Reviewers.

8. Synopsis of Review Results
Continuous and systematic work improvement activities (MVP activities) have beenpromoted since 2005 as one of the endeavors aimed at assuring total safety at MNF and theaim of these is to maintain safety motivation and lead to even higher quality products.
These activities led to a reduction of the work load for on-site workers.
In addition, risk management is also implemented by employees and contractors working
together as a team.

Through such activities, specific measures are implemented

corresponding with the degree of significance of the risk, contributing to reduce overall risk
faced by the company.
Moreover, as a means of monitoring the state of plant and equipment safety, thermal
image diagnosis and measurement and analysis of vibrations are actively carried out, andthese are being done by the in-house staff themselves.

Utilizing the results of theseequipment diagnoses has proven effective in the early detection of abnormalities and thenecessary maintenance such as replacement of worn parts can be carried out based on early
detection.
However, in regard to specific endeavors in order for even stronger safety culture
awareness to firmly take root, systematic understanding by the management class isinsufficient.

It is desirable to learn more about domestic and foreign activities forpromoting safety culture and to make even greater and even more effective endeavors insafety culture promotion activities.
There are also the potential risks that large heavy items in the plant could move around
during seismic event and possibly crash into the production line, impeding the functionalityof the equipment. Temporarily stored items in the vicinity of the production line need to be
fixed into place or fastened securely.

Four good practices and five areas for improvements were developed in the Review, andare listed below.
Note, however, that the areas for improvements are not necessarily matters that need to be
dealt with immediately from the standpoint of nuclear safety.

8.1 Good Practices(Organization & Administration)●Effective promotion of work improvement activities (MVP activities)

Continuous and systematic work improvement activities have been promoted since2005 as one of the endeavors aimed at assuring total safety (nuclear safety, industrial healthand safety, environmental preservation) at MNF and the aim of these is to maintain safety
motivation and lead to even higher quality products.
Reflecting demands from the work site, one of the manifestations of the company's
posture of sincerely endeavoring in these activities has been the introduction of IC tags onfuel storage bottles as a way of preventing mistaken posting of transcripts due to humanerror, and this has contributed to a reduction of the work load for on-site workers.

●Sharing safety information via the in-house network "MINES"

A website known as MINES (MNF Information Network System) was set up on thein-house network in March 2006 to communicate safety information to plant employees.
In addition to this network conveying in-house standards, information on activities related
to safety quality management systems, information from outside (government, JANTI,etc.), information on non-conformities, integrated safety analysis (ISA) information,
information from other companies in the same field, and others are also posted on in-housebulletin boards. Since information concerning a particular job can be obtained from theeasy-to-use search function, all employees make use of it on a routine basis, which
contributes to improved work quality and in-house sharing of information.
●Proactive endeavors in risk management activities
Risk management is implemented by employees and contractors working together as ateam. Employees and contractors reduce risks using "risk assessment sheets" and sortthem into 18 risk categories such as management, operation, natural disaster and the like,and countermeasures are implemented in accordance with the degree of significance of therisk. Since this activity has been in effect, the number of assessed risks has increased
annually, with approximately 200 risks assessed in FY 2007, and in cases when necessary

they are made known via the in-house intranet. As an example of addressed risks,
equipment used in the zilcaloy cutting process, for which there is potential risk of catchingfire, was modified to improve safety, contributing to the overall reduction of risks
throughout the company.

(Training)
Nothing in particular(Work management & maintenance)●Making use of equipment diagnosis skills
Thermographic measurement of all electric parts contained in the production line
equipments, extra high voltage transformer substation and emergency diesel generator, as
well as vibration analysis of centrifuge bearings and air conditioners bearings are all done
in-house by MNF staff. Making use of the equipment diagnosis analysis results has beeneffective in the early detection of abnormalities in order to perform the necessary
maintenance for replacing worn out parts.

(Radiation protection)
Nothing in particular(Key issues)
Nothing in particular

8.2 Areas for Improvement(Organization & Administration)● Further enhancement of activities to promote safety culture
Activities for improving the reliability and safety of products and production equipment
are thoroughly put into practice in the routine daily safety activities of legal complianceconsciousness, smooth communication, and rapid reporting.

In regard to specificendeavors needed for even stronger safety culture awareness to firmly take root, however,systematic understanding by the management class is insufficient, and several instances ofendeavors that lacked coordination were observed.
Toward this end, it is desirable to learn more about domestic and foreign activities forpromoting safety culture, formulate a more decisive common consciousness as anorganization, and make more effective endeavors to promote safety culture.
(Training)●Continuous improvement of comprehensive safety training
All employees including those of contractors undergo comprehensive safety training that
includes corporate ethics and compliance with laws. This practice raises the sense ofunity among all employees and helps to raise the level of awareness of safety activities.
The year before last, opinions and impression of the trainees in regard to the training werecollected and analyzed, and making use of this feedback from trainees, efforts are being
made seeking to raise the effectiveness of the training, but it is still desirable to make evenfurther enhancements to the training that reflects the opinions and impressions of the
trainees.
(Work Management & Maintenance)●Fixing into place and fastening down articles in anticipation of earthquakes
The storage location for temporarily stored items throughout the plant have been
specified, but the methods for fixing into place or fastening down have not been decided,and some big, heavy items that were not fixed into place or fastened down were observedin close proximity to equipment that is essential to the production line. Because of thissituation, there is potential risk that these large heavy items may move around during
seismic event and crash into production line equipment, thereby impairing the functionalityof the equipment.

Accordingly, temporarily stored articles in the vicinity of the

production line should be securely fastened down or fixed into place.
●Management of supplementary operating aids
Operation aids are posted on all sorts of equipment throughout the plant indicating themethod of operation and management criteria written in the manuals, but among them,
there are some hand-written memos and some that are not being clearly managed.
Therefore, if the manuals were to be revised or method of operation changed, it would not
be possible to assure reliable update management, and thus there is concern about humanerrors arising during actual operation. As a result, it is desirable that some mechanism beconsidered to assure that reliable update management can be carried out for theseunmanaged memos.

(Radiation protection)
None in particular.
(Key Issues)●Making more effective use of minor non-conformities
Minor non-conformities for which measures can be taken rather easily are called Grade
II non-conformities and it is not necessary to file an "incident and countermeasuresconcerning safety-related non-conformities report" (S-UNDR) for these. All others arehandled as Grade I, for which an S-UNDR must be submitted, the circumstances
investigated, a countermeasures plan drafted, and corrective steps must be taken. There
are several tens of Grade I non-conformities every year, most of which are items noticed
during inspections and deficiencies in records.
Information concerning most of the Grade II non-conformities are written in the logs,
but are not entered into a database, so there is no statistical analysis or systematic
improvement activities based on the results of such analysis. It is desirable to engage involuntary improvement activities by making more effective use of Grade II
non-conformities.