Text

Rev 0 to Perry Nuclear Power Plant Course of Action
	ML20059M611
Person / Time
Site:	Perry
Issue date:	11/15/1993
From:	; CENTERIOR ENERGY
To:	;
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ML20059M599	List: ML20059M597; ML20059M611;
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	NUDOCS 9311190187
	Download: ML20059M611 (74)
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h l lD PERRY NUCLEAR POWER PLANT COURSE OF ACTION D

PCA - Rev. O O rante or coureurs Statement from Robert J. Farling i Statement from Donald C. Shelton ii Executive Summary 1 Section 1: Introduction

1.1 Background

6 1.2 Management Actions 6 1.3 Deficiencies 10 1.4 Action Plan Approach 11 Section 2: Management 14 Section 3: Issues and Action Plans by Organization 3.1 Operations 18 3.2 Maintenance 24 3.3 Radiation Protection 29 3.4 Quality Assurance 32 3.5 Engineering 34 Section 4: Issues and Action Plans for Selected Topics 4.1 System Operation and Test Review Program 40 4.2 Corrective Action Program 42 4.3 Material Condition improvement 45 4.4 Related Issues 48 Attachments Attachment A - Plant Emergency Instruction Team Charter. A-1 Attachment B - Independent Assessment Policy Statement B-1 Attachment C - Nuclear Quality Assurance Program Policy C-1 O l l

9CENTERDW1 PCA - Rev. 0 E04EntCnf 6200 Oak Tree Boulevard Mail Address: Robert J Farling Independence. OH P.O. Box 94661 Chairman (216)447 3100 Cleveland, OH 44101 4661 President Fax (216)447 3123 Chief Executive Officer Statement of the Chairman, President, and Chief Executive Officer As Chairman, President, and Chief Executive Officer of Centerior Energy i Corporation, I vant to clearly state in the strongest possible-terms my intent and commitment, as well as that of the Board of Directors and executive management, to operating the Perry Nuclear Power Plant in the safest and most reliable manner achievable. Although our record for safe operation remains unquestioned, the plant has fallen short of meeting our expectations for reliability and performance. To correct this, significant improvements vill be necessary in several key areas. Ve are determined to make these improvements. As a first step, the Centerior Board approved the assignment of Donald C. Shelton as Senior Vice President - Nuclear, based on his experience in turning around and successfully managing the formerly troubled Davis-Besse Nuclear Pover Station. In his new capacity, Mr. Shelton is charged with the responsibility for the Perry Plant, as well as for the Davis-Besse Station and reports directly to me. In addition, I have authorized Mr. Shelton to undertake a six-veek nonrefueling outage at Perry for the purpose of improving the material condition of the plant. That outage started on October 1, 1993, and is currently under way. The problems ve face vere not created overnight, and they vill not be corrected overnight--but they vill be corrected. The Perry Course of Action represents a comprehensive outline and detailed plan of action for effecting the much-needed improvements at Perry. Ve are determined to make the Perry Plant reach or exceed the level of performance of our Davis-Besse plant. Ve have the people who know how to accomplish this goal, and ve have the vill to do it. The Boards of Di:ectors for Centerior Energy Corporation, Duquesne Light. Company, and Ohio Edison Company are firmly committed to providing the necessary resources, as well as any other support within their ability, to ensure the success of this effort. To augment its ability to fulfill its responsibilities, the Centerior Board of Directors vill elect a member with nuclear industry operating experience to advise the Board regarding the performance of its nuclear power plants. In the long run, however, it is up to the hundreds of people at the site, from top management down, to work together to achieve the common goal. ~ / 1 Operotmg Componses-Clewand Electric illummanng Toledo Edison

PCA - Rev. O PERRY COURSE OF ACTION i Statement from Donald C. Shelton to Perry Plant Personnel This is the Perry Course of Action. It charts the course for bringing our plant to the standards the owners, regulators, and public expect and deserve. This Course of Action will be no easy task to accomplish. We have learned to live with and accept certain conditions and ways of doing business. Changing the way we do business, what we expect of ourselves and others, is what this document is all about. Safe, conservative operation of the Perry Plant is our fundamental responsibility. As you are probably aware, several assessments have been conducted over the last few months.- These assessments were conducted by our staff as well as teams of highly qualified experienced nuclear industry professionals. I requested the assessments to help me determine what needed to be fixed and more importantly whether the plant could be safely operated while we make the fixes. I have evaluated these assessments and concluded that the plant can and will be operated safely while it we make the improvements. How we got where we are today is useful only in pointing out what we need to do to improve and assure ourselves we won't repeat those mistakes tomorrow. In my assessment of Perry's past perfc.mance, I conclude that management was the key ingredient to the shortcomings. As you ( read this Course of Action it should be no surprise that many of the corrective measures relate to enhancing management effectiveness. I and my management team are committed to providing the leadership and management necessary to take Perry to the top. I There is one area that I particularly want to stress because it is so critical to the successful operation of a nuclear power plant. I am referring to oversight. At Perry, as is the case at all nuclear plants, there are multiple groups that serve the purpose of monitoring all phases of the plant's performance. There is external oversight such as the NRC and INPO and there is internal oversight such as QA, NSRC, PORC, ISEG, Licensing, and Radiation Protection. While those responsible for Perry's internal oversight activities cannot be blamed for the plant's declining performance, they can be criticized for failure to recognize and assure it was corrected, llowever, oversight organizatioas can be criticized less if, over the years, line management has failed to respond appropriately to critical appraisals. There is some indication that this occurred at Perry. Accordingly, I emphatically affirm that it is my policy to reestablish the proper functioning and effectiveness of all internal oversight activities. All levels of management will look upon oversight as a positive and beneficial attribute and will respond accordingly. O ii

PCA - Rev. 0 - I have brought to the site a number of advisors, all of whom have years of experience in-operating nuclear power plants, to assist me in evaluating the effectiveness of our corrective actions. I refer to this group as the Independent Assessment Team (IAT). For me they represent additional eyes and ears for my own use. While the presence of these people will be apparent as they probe our actions, they do not in any way supplement or diminish line's responsibility to manage its work. This independent team reports to me and is not empowered to give direction. These comments, incidentally, are applicable to all oversight functions. In addition to this IAT, to facilitate our activities, experienced contractor personnel will assist us in a variety of roles. 2 This assistance will be as assessors, coaches and augmentation to the staff. They are here to help; listen to their counsel, but don't let yourself be steamrollered. This is our facility and we retain responsibility for everything that occurs here. For a number of reasons the material condition of the plant, particularly the balance of plant, was never allowed to reach an acceptable level of reliability or performance since the construction period. Over the years there was a valiant but unsuccessful attempt to correct this_ situation. We intend to address this problem. As we correct the material condition of the plant, we will be putting in place an effective maintenance program which will ensure the material condition is maintained at the right level. Mr. Farling's letter on the previous page contains his and the Board of Directors commitment to support our efforts to raise Perry's performance to the highest standards. We will be provided the necessary resources to do ourjob, but it is up to us to make the changes. From now on there will .O be no exce es for eccenties iess th n ten verforme ce from evervoee et 1 hie eite. ^nd by the i same token, after we have materially upgraded the plant, there should be no instances of hearing the words, "I could have told you that it was going to break" when a piece of equipment fails. 5 There is no reason Perry cannot become the best plant in the United States. It was well-designed and well-built; it has a dedicated, well-trained and knowledgeable staff from top to bottom. i Although it may take time, I am convinced we can rise to the occasion. I encourage each and everyone of you to work together. If you think of ways to improve that are not being taken, tell your supervisor. If you don't think you are getting through, come and talk to me. We need everyone to be a part of this program. Let's do it! O. iii i

l PCA - Rev. O O PERRY NUCLEAR POWER PLANT COURSE OF ACTION Executive Summary Centerior Energy Corporation is committed to the highest safety, performance, and reliability standards for its nuclear power plants. Results of both external and internal reviews indicate that these standards presently are not being met in several important areas at Centerior's Perry Nuclear Power Plant, as demonstrated by a decline in the plant's ope:ational performance and reliability. Several internal and external assessments of all phases of plant and management performance have been conducted. This Perry Course of Action documents the deficiencies identified during these assessments and the Corrective Actions taken or planned to bring about necessary improvements. Management Actions Centerior's corporate management has assigned Donald C. Shelton, Senior Vice-President. Nuclear, the responsibility for effecting substantive improvements in Perry operations. In this p capacity, Mr. Shelton reports directly to Centerior's Chairman, President, and Chief Executive

V Officer. As initial steps towards effecting such improvements, the following actions have been initiated.

Changes in management assignment As an important first step in addressing deficiencies which are rooted in management performance, Centerior Energy made several management assignment changes. These changes were made to ensure that select, experienced management and supervisory personnel from Centerior's Davis-Besse Nuclear Power Station, as well as from the Perry Plant, are directly responsible for directing plant activities, identifying areas in which deficiencies exist, and implementing a corrective action program. Management changes to date include:

- Assignment of personnel with demonstrated management capability from Davis-Besse to the positions of Director of Engineering, Director of Nuclear Services, Maintenance Manager, and Materials Manager. These changes were additional to the earlier assignment of the former Davis-Besse Operations Superintendent to the position of Perry Operations Manager. - Site-wide reassignment of Perry management personnel to best utilize the strengths of the Perry organization. O 1

PCA - Rev. O These changes provide the leadership needed to set and meet the high standards required by Centerior, including enhanced personnel performance and improved operations. These changes are depicted in Figure 1, Section 1, page 8. Additional management changes will be made if necessary. . An immediate assessment of overall plant operations by an independent team of experienced, industry-recognized senior management and technical personnel I The purpose of this assessraent was to determine whether plant operations could be safely continued while a broad-based improvement program is being developed and implemented, and to identify deficiencies that should be addressed by Perry's management and staff. The team reviewed previous assessments conducted by the Nuclear Regulatory Commission (NRC), the Institute of Nuclear Power Operations (INPO), and others; interviewed plant personnel; and inspected the plant. The team concluded that several deficiencies collectively have resulted in the degraded material condition of the plant; however, the team also concluded that this condition did not compromise the continued safe operation of the plant. This conclusion was confirmed by the results of technical / operational reviews conducted by the new plant management of plant functional characteristics that are considered important to maintaining safe operation. j A near-term plant outage O teted ebove.the ieitiet ient es e m ent ceecteded thetthe P met cee be o Pereted eafeir. P i ^ The new management, however, concluded that a mid-cycle maintenance outage was warranted. This outage began on October 1,1993, and is scheduled to last six weeks. The l outage is being used to perform the modifications and testing required to improve the plant's overall margin of safety, reduce the number of temporary modifications, improve overall plant housekeeping, and complete other necessary maintenance activities. Such maintenance activities are designed to reduce the existing backlog and are concentrated on reducing system leakage to control the potential spread of low-level radioactive contamination. l l A phased, broad-based improvement program This program is direc.ed at identifying and addressing specific deficiencies. The program will be implemented in three phases. Phases one and two have been designated as the Perry Course of Action. Pt ase three will be incorporated into the long-range Five-Year Plan. The Perry Course of Action contains summary descriptions of the deficiencies identified and the actions required to address them. This information is also provided in brief in this i Executive Summary [see Deficiencies section below]. Thc three phases of this broad-based improvement program are: O 2

PCA - Rev. O Short-Term Phase Actions included in this short-term phase were developed to quickly provide substantial, measurable improvements, particularly in the areas of management performance,-plant material condition, and the corrective action process. These actions are to be implemented by the completion of Refueling Outage 4 (RFO-4). Mid Term Phase I-The remaining corrective actions identified in this Perry Course of Action are scheduled for completion by restart from RFO-5. By that time, the necessary programs, practices, and policies are planned to be in place to ensure that Centerior's goals for continuous-- improvement are set and met, eventually resulting in Perry's achievement of superior performance. Lone-Term Phase Perry management anticipates that additional actions will be required to improve the performance of the Perry Plant and staff to a level that exceeds current industry standards. Activities necessary to achieve this level of superior performance will be incorporated into the Five-Year Plan. Deficiencies This course of action is directed at addressing those deficiencies that have been identified to ensure that the Perry Plant's performance improves to meet the high standards expected by i Centerior. Areas in which deficiencies have been identified include: Material condition a Degraded material conditions within the plant are indicated by the extent of radioactively contaminated areas, the number of steam and water leaks which have led to the spread of low-level radioactive contamination within the plant, increased levels of radioactive effluent, and the large maintenance backlog. The number of preventive maintenance deferrals has contributed to this degraded material condition. Corrective actions Correction of plant problems has not been timely or effective. Inadequate, narrowly-focused root-cause determinations have frequently resulted in a recurrence of problems. For example, external reviews have cited ongoing leakage problems with the main steam 1 O I i 3

PCA - Rev. 0 isolation valves. In addition, inadequate maintenance of suppression pool cleanliness recently caused the fouling of the Emergency Core Cooling System (ECCS) suppression pool suction strainers, which resulted in escalated NRC enforcement action. Critical self-assessments Perry Plant management and staff have not performed adequate critical assessments ofilleir own performance. The Quality Assurance department has conducted audits which have failed to identify deficiencies or were ineffective in resolving those that were identified. This critical assessment deficiency was demonstrated when external organizations, such as the NRC and INPO, reevaluated areas in which deficiencies had been previously identified and found significant deficiencies still present. Recent examples include NRC inspections l .l of the emergency operating procedures and the motor-operated valve program. 1 1 Conduct of operations and professionalism l Examples of weaknesses in this area include inattention to detail, ineffective plant status control, and inadequate performance standards and accountability, as indicated by continued acceptance of the degraded material condition of systems and equipment. Procedural compliance A number ofin:tances of noncompliance with procedural requirements by operations and maintenance personnel have been cited (e.g., control rod mispositioning events, and scaffolding installation violations). Radiological controls Past performance in the area of radiological controls has been deficient. In addition to the l presence oflarge contaminated areas in the plant, there has been high cumulative personnel exposure and a large number of personnel contaminations. Although within regulatory limits, radioactive releases have not kept pace with industry efforts to reduce them. Control of facility design Examples of deficiencies in this area include changes to the plant design configuration outside of the procedural process for control of modifications. Engineering support Examples of deficiencies in providing timely, effective engineering support include a large backlog of Engineering Design Change Requests and Design Change Packages, the large number and the age of the temporary modifications installed, and a lack of thoroughness in engineering evaluations and engineering products. The lack of thoroughness in 4

i PCA - Rev. 0 performance of engineering evaluations has contributed to the deficiencies noted in the corrective actions category above.

Resolution of technical problems Examples of ongoing, unresolved technical problems include repeated leakage problems with the main steam isolation valves, denciencies in the motor-operated valve program, unresolved deDciencies in emergency operating procedures, an incomplete erosion / corrosion program, and deficiencies in the Integrated Leak Rate Test / Local Leak Rate Test (ILRT/LLRT) instrumentation.

The individual action plans in this Perry Course of Action are designed to correct these and other denciencies as they are identified. Plant management at all levels will have the responsibility for implementing these actions. Specific individuals will be assigned responsibility for managing and completing each action item. Other management levels will be responsible for providing a higher level of overview. Internal plant assessment techniques, such as Quality Assurance / Quality Control, will be used to provide oversight. i To augment oversight of the Perry Course of Action by plant management, independent assessment will be provided by a team of experts with a broad range of experience in the puclear industry. This team will review the scope, depth, and approach of the action plans to confirm that they will satisfactorily meet the Perry Course of Action objectives and provide assistance to plant ,( management in assessing the effectiveness of the program. The team will report to D. C. Shel:on, Senior Vice-President-Nuclear. / l I O 5

PCA - Rev. 0 - 0 1 L: PERRY-NUCLEAR POWER PLANT COURSE OF ACTION O SECTION 1 INTRODUCTION i ) lO J

PCA - Rev. O SECTION 1 INTRODUCTION

1.1 Background

In 1993, the Perry Nuclear Power Plant experienced a series of operational events. Furthermore, in April 1993, an NRC Systematic Assessment of Licensee Performance (SALP) evaluation of the plant indicated a decline in plant performance. At an NRC meeting in June, Perry was singled out as a plant whose safety performance was " trending downward." Centerior Energy Corporation is committed to the highest safety, performance, and reliability standards for its nuclear power plants. Therefore, the decline in the Perry Plant's operational performance and reliability warrants the focused attention of Centerior's management. Several internal and external assessments of all phases of plant and management performance have been conducted. This Perry Course of Action documents the deficiencies identified during these assessments as well as the corrective actions taken or planned. 1.2 Management Actions Centerior's corporate management has assigned Donald C. Shelton, Senior Vice-President-Nuclear, the responsibility for effecting substantive improvements in Perry operations. In this capacity, Mr. Shelton reports directly to Centerior's Chairman, President, and Chief Executive Officer. As initial steps towards effecting immediate or near-term improvements, the following activities have been initiated. Changes in management assignment i To begin addressing those deficiencies which are rooted in management performance, Centerior Energy made several management assignment changes. These changes were made to ensure that select, experienced management and supervisory personnel from Centerior's Davis,13 esse Nuclear Power Station, as well as from the Perry Plant, are directly responsible for directing plant activities, identifying areas in which deficiencies exist, and implementing a corrective action program. l l l O 6

l PCA - Rev. 0 Robert A. Stratman continued as Perry Plant Vice-President, with four direct-reports: David l P. Igyarto continued as General Manager, Operations; Neal L. Bonner, formerly. Design l Engineering Manager at Davis-Besse, was promoted to Director, Engineering; Robert W. i Schrauder, formerly Licensing Manager at Davis-Besse, was promoted to Director, Nuclear Services; and Kenneth R. Pech, fmmer Perry Outage Planning Manager, was promoted to .( Director, Nuclear Assurance. In addition, Mark B. Bezilla, former Davis-Besse Operations ] Superintendent, continued as Perry Operations Manager; Vincent J.- Sodd, former Davis. J Besse Maintenance Services Superintendent, was promoted to Perry Maintenance Manager; and Lonnie W. Worley, formerly Nuclear Materials Manager at Davis-Besse, was assigned to the position of Perry Materials Manager. Other management changes to date include the site-wide reassignment of Perry management and supervisory personnel to best utilize the strengths of the Perry organization. These changes, depicted in Figure 1, provide the leadership needed to set and meet the high standards required by Centerior, including enhanced personnel performance and improved l operations. Additional management changes will be made if necessary. l + An immediate assessment of overall plant operations by an independent team of experienced, industry-recognized senior management and technical personnel l l The purpose of this assessment was to determine whether plant operations can be safely I continued while a broad-based improvement program is being developed and implemented. l lO end to ideetifx deficiencies thet sheeid be eddre, ed bx Perrx s meneaemeet end steff rh-team reviewed previous assessments conducted by the Nuclear Regulatory Commission (NRC), the Institute of Nuclear Power Operations (INPO), and others; interviewed plant personnel; and inspected the plant. The team concluded that several deficiencies collectively have resulted in the degraded material condition of the plant; however, the team also concluded that this condition did not compromise the continued safe operation of the plant. This conclusion was supported by the results of technical / operational reviews conducted by the new plant management of plant functional characteristics that are considered important I to maintaining safe operation.

A near-term plant outage l'

As stated above, the initial plant assessment concluded that the plant can be operated safely. The new management, however, concluded that a mid-cycle maintenance outage was warranted. This outage began on October 1,1993, and is scheduled to last six weeks. The outage is being used to perform the modifications and testing required to improve the plant's overall margin of safety, reduce the number of temporary modifications, improve overall plant housekeeping, and complete other necessary maintenance activities. Such maintenance activities are designed to reduce the existing backlog and are concentrated on reducing system leakage to control the potential spread of low-level radioactive contamination.

O 7

l PCA - Rev. O Figure 1 l I: lO Management Reorganization Sr. Vice President, Nuclear DONALD C. SHELTON. { M i 1 Vice President, Nuclear - Perry ROBERT A. STRATMAN M ~ d PLANT DEPARTMENT ENGelEERHWG DEPARTMENT David P. Igyarto Neal L. BotwMir OPERATIONS MECHANICAL DESIGN J Mark B. Bezllia Vincent J. Concel MAINTENANCE ELECTRICAL DESIGN j. Vincent J. Sodd J Russell J. Tadych RADIATION PROTECTION ENGINEERING SUPPORT l Pasquale Volza Will!am E. Coleman INSTRUMENT & CONTROLS SYSTEM ENGINEERING Peter D. Roberts Frederick G. Von Ahn INTEGRATED SCHEDULING & COSTS William R. Kanda ASSURANCE DEPARTMENT SERVICES DEPARTMENT - Kenneth R. Pech R0tlert W. $ChrSuder OUALITY ASSURANCE REGULATORY AFFAIRS Vernon K. Higaki Kevin P. Donovan QUALITY CONTROL TRAINING Edward M. Root Michael L Wesley INDEPENDENT SAFETY ENGINEERING SITE PROTECTION Anthony F. Silakoski Thomas E. Mahon MATERIALS MANAGEMENT New in PositlOn Lonnie W. Worley - Davis-Besse Transfer PLANT SERVICES Leo R. Haworth

PCA - Rev. 0 . A phased, broad-based improvement program To improve plant performance to meet the high standards of excellence required by management, the long-range Five-Year Plan is being revised. To facilitate the timely, near-term improvement of plant performance, however, the Senior Vice-President-Nuclear, directed the identification of those improvements which could be implemented immediately or in the near-term. This subset of the Five-Year Plan has been designated the Perry Course i of Action. The purpose of the Perry Course of Action is to address those deficiencies that have been identified and to make effective, substantive improvements to ensure the Perry Plant's conformance with current industry norms, with the goal of eventually exceeding these norms. For this reason, clearly defined parameters are needed so that a proper assessment can be made of the improvements achieved. Development of this Perry Course of Action began on August 3,1993. Activities associated with the short-term and mid-term phases are scheduled for completion prior to startup from Refueling Outage 5 (RFO-5). The three phases of this broad-based improvement program are: Short-Term Phase Actions included in this short-term phase were developed to quickly provide substantial, measurable improvements, particularly in the areas of management performance, plant material condition, and the corrective action process. These actions are to be implemented by the completion of Refueling Outage 4 (RFO-4). Additional actions requiring longer lead and elapsed time will continue through the fifth operating cycle. Mid-Term Phase The remaining corrective actions identified in this Perry Course of Action are scheduled for completion by restart from RFO-5. By that time, Perry management plans to have the necessary programs, practices, and policies in place to ensure that Centerior's goals for continuous improvement are set and met, eventually resulting in Perry's achievement of superior performance. Lonn-Term Phase The primary long-range planning vehicle at Perry is the Five-Year Plan. Perry management i anticipates that additional actions will be identified that are necessary to improve the plant's performance and staff to a level that exceeds current industry standards. Deficiencies or i improvement activities identified during development of this Perry Course of Action, but not included as part of it, will be considered long-term elements of the Five-Year Plan. .O 9 J

y 5 PCA - Rev. O Detailed scopes and commencement / implementation schedules for each of the actions described in this Perry Course of Action have been or are currently being developed. As these detailed plans and schedules are completed, they will be available for review on the site. 1.3 Deficiencies This course of action is directed at addressing deficiencies that have been identined to ensure that the Perry Plant's performance improves to meet the high standards expected by Centerior.. Areas in which deficiencies have been identined include: o Material condition Degraded material conditions within the plant are indicated by the extent of radioactively contaminated areas, the number of steam and water leaks which have led to the spread of low-level radioactive contamination within the plant, increased radioactive effluent, and the large maintenance backlog. The number of preventive maintenance deferrals has contributed to this degraded material condition. Corrective actions Correction of plant problems has not been timely or effective. Inadequate, narrowly-focused A(> root-cause determinations have frequently resulted in a recurrence of problems. For example, external reviews have cited ongoing leakage problems with the Main Steam Isolation Valves. In addition, inadequate maintenance of suppression pool cleanliness recently caused the fouling of the Emergency Core Cooling System (ECCS) suppression pool suction strainers, which resulted in escalated NRC enforcement action. Critical self-assessments Perry Plant management and staff have not performed adequate critical assessments of their own performance. The Quality Assurance department has conducted audits which have failed to identify denciencies or were ineffective in resolving those that were identified. This critical assessment denciency was demonstrated when external organizations, such as the NRC and INPO, reevaluated areas in which de6ciencies had been previously identined and found significant denciencies still present. Recent examples include NRC inspections of the emergency operating procedures and the motor-operated valve program. Conduct of operations and professionalism Examples of weaknesses in this area include inattention to detail, ineffective plant status control, and inadequate performance standards and accountability, as indicated by continued acceptance of the degraded material condition of systems and' equipment. O 10

PCA - Rev. 0 + Procedural compliance A number of instances of noncompliance with procedural iequirements by Operations and Maintenance personnel have been cited (e.g., control rod mispositioning events, and scaffolding installation violations).

Radiological controls Past performance in the area of radiological controls has been deficient. In addition to the presence oflarge contaminated areas in the plant, there has been high cumulative personnel exposure and a large number of personnel contaminations. Although within regulatory limits, radioactive releases have not kept pace with industry efforts to reduce them.

Control of facility Jesign Examples of deficiencies in this area include changes to the plant design outside of the procedural process for control of modifications. l Engineering support + Examples of deficiencies in providing timely, effective engineering support include a large backlog of Engineering Design Change Requests and Design Change Packages, the large number and the age of the temporary modifications installed, and a lack of thoroughness t in engineering evaluations and engineering products. The lack of thoroughness in-performance of engineering evaluations has contributed to the deficiencies noted under the { corrective actions category above. l Resolution of technical problems + f Examples of ongoing, unresolved technical problems include repeated leakage problems with the main steam isolation valves, deficiencies in the motor-operated valve program, unresolved deficiencies in e.nergency operating procedures, an incomplete erosion / corrosion program, and deficiencies in the Integrated Leak Rate Test / Local Leak Rate Test (ILRT/LLRT) instrumentation. f 1.4 Action Plan Approach 1.4.1 Overview The Perry Course of Action is comprised of(1) a succinct summary of issues identified through the assessment process (see Section 1.4.3, Methodology) and (2) a summary of ongoing and planned approaches to address the issues identified. The issues and related action plans are O 11

PCA Rev. O summarized by organization (e.g., Quality Assurance, Operations, Engineering, etc.,) and by selected topics (e.g., System Operation and Test Review Program, Corrective Action Program, and Material Condition Improvements). 1 This Perry Course of Action was developed by a combined team of all levels of Perry Plant managers, as well as senior personnel experienced in the performance improvement, recovery, and restart of commercial and government nuclear facilities. 1.4.2 Course of Action Management 4 i The individual action plans in this Perry Course of Action are designed to correct these and other { deficiencies as they are identified. Plant management at all levels will have the responsibility for i implementing these actions. SpeciSc individuals will be assigned responsibility for managing and completing each action item. Other management levels will be responsible for providing a higher .j level of overview. Internal plant assessment techniques, such as Quality Assurance / Quality l I Control, will be used to provide additional oversight. To augment plant oversight of the Perry Course of Action by plant management, independent l assessment will be provided by a team of experts with a broad range of experience in the nuclear industry. This team will include outside, senior personnel experienced in the performance improvement, recovery, and restart of both commercial and government nuclear facilities. The team will review the scope, depth, and approach of the action plans to confirm that they will h satisfactorily meet the Perry Course of Action objectives and provide assistance to plant management in arsessing the effectiveness of the program. The team will report to D. C. Shelton, Senior Vice-President-Nuclear. l 1.4.3 Methodology l Potential problem areas requiring attention as par: of the Perry Course of Actior, were identined and will be resolved and tracked using the following approach. Document Review A total of 155 internal / external documents pertaining to potential deficiency areas were reviewed, from which 504 specific issues were identified. These documents were generally less than two years old. Examples of such documents include internal assessments, NRC reports, and INPO reports. The scope and diversity of this document review are considered to be representative of the Perry Plant's performance. O 12

PCA - Rev. O O intmi-s Interviews were conducted with current and previous Perry Plant employees. Interviewees included executive management, upper-and mid-level managers, and other selected individuals. Interviews were conducted by senior personnel experienced in the performance improvement, recovery, and restart of commercial arJ government nuclear facilities. Issues A Fst of issues was compiled from the deliciencies identified during the document reviews and interviews by using the judgment and experience of the senior personnel comprising the review team. In general, the issues were grouped by organizational function (e.g., Operations, Engineering, etc.). Where judged appropriate, specific deficiency areas were grouped separately (e.g., Corrective Action Program; Motor-Operated Valve Program; Systems Operation and Test Review Program). Summaries of these issues are included in Sections 3 and 4. Action Plan Development Individual action plans have been or will be developed for each issue. Each action plan includes a description of the problem, planned correction or improvement activities, assignment of specific responsibilities, and a planned schedule for completion of each 'O ectivitv. The e ectier P en ere semmarized in Sec ton s end 4. i Tracking and Reporting Methodology The action plans for this Perry Course of Action are contained in a data base for tracking to completion. Reports will be provided to management on a periodic basis to show progress on the actions scheduled for completion. Any overdue Perry Course of Action l tasks will be reported to the Vice-President and Directors. O 13 1

PCA - Rev. 0 0 SECTION 2 MANAGEMENT !O

PCA - Rev. 0 O secrioN 2 MANAGEMENT The success of the Perry Course of Action is heavily dependent on management performance. In order to bring about prompt, lasting improve.i et in the performance and reliability of the Perry Plant the new management team must: Demonstrate an ability to communicate clear goals, to hold personnel accountable, to obtain consensus, and to strive for excellence in the operation of the Perry Plant; Develop the technical and supervisory / management capabilities of personnel and provide a depth of capabilities and industry experience it, the management structure; Encourage the identification and resolution of plant problems, i.e., must instill a questioning attitude, resulting in the cemiction among plant staff that management welcomes identification of problems; Provide personnel with broad exposure to industry experience resulting in an acute / awareness of the increasing level of standards and performance expectations being implemented throughout the industry; Improve the safety culture to maintain a constant respect for the technology used to generate electrical power by nuclear energy; and Demonstrate an intolerance for problems and deficient plant conditions. Included under the following headings are descriptions of the most important actions being taken to ensure effective management performance. Leadership by Example A fundamental approach to achieving substantive improvement in management performance is the concept of " leadership by example." This approach is being implemented through the' following actions. Management Changes Some previous management personnel were replaced with individuals who have shown an understanding of the importance of continuous improvement end striving for excellence, and have demonstrated an ability to communicate this understanding to others. These O 14

4 PCA - Rev. O individuals played important roles in bringing the Da;is-Bene plant to its current industry-leading position. Additionally, Perry personnel who were judged to have the best potential for developing and implementing this approach were chosen to fill other important positions. Tutorial Managet.mt Style An effective way to communicate an understanding and appreciation of changes in attitude and expectations is through management and management / worker forums. These forums are being established to communicate expectations of formality and a rigorous approach to site activities. This will be accomplished by concentnting the new management's attention through forums such as: - Extended Staff Meetings These meetings will be chaired by the Senior Vice-President-Nuclear and attended by the Vice-President-Nuclear, Perry, Perry site directors and their directly reporting managers, and selected supervisors who are considered essential to the effort of making short-term improvements in management peformance. Initially, the meetings will be conducted weekly; over time, at the judgme tt of the Ser.ior Vice-President - Nuclear, the meeting: schedule is expected to change. O The ex1eeded staff meetinae are e ed to review in deteii theee ectivitice thet are imPertent to the effective operation of the Perry Plant and to provide a forum for senior management to demonstrate, by example, the attitude and approach expected by the new management. When management performance is judged satisfactory, the Senior Vice- ~ President will relinquish the chair to the Vice-President-Nuclear, Perry f - Plan of the Day This meeting is attended by directors, managers important to day-to-day plant operations, and other managers and supervisors on a range of levels in the areas of operations, maintenance, and engineering support activities. The meeting provides another forum for - management to demonstrate, by example, the attitude and approach expected by Centerior. Business conducted during this meeting includes discussing and evaluating the status of daily plant activities and assigning actions as necessary. j i O 15

L- -l PCA - Rev. 0 " Seed and Shadow" Another aspect of leadership by example is the use of outside expertise to temporarily augment the technical and management capabilities of the site staff. This will be done by " seeding" selected technical talent into the organization to help resolve ongoing problems and to provide "mentoring" to develop the staff's technical capabilities. To complement this effort, selected site management will be provided with temporary " shadow" management consultation and hands-on assistance in the day-to-day management of the site. i Expert. Advisors A complementary aspect of leadership by example is the use of expert advisors who have extensive experience in the recovery, restart, and performance improvement of commercial and government nuclear facilities. These advisors are used both as members of review committees and as direct consultants to assist in addressing selected technical and management issues. Exnectations and Accountability Expectations and accountability were discussed and emphasized by the Site Vice-President, the Directors, and the General Manager to employees in face-to-face meetings. This message also has been communicated through site mission, vision, and values statements. I In addition, a plant staff member who reports to the Plant General Manager has been assigned the responsibility to lead the human error assessment program for plant-related issues. The focus of this program will be to investigate the root causes of personn-1 errors, trend these errors, and provide recommended approaches for reducing such personnel errors. Successful human error assessment programs in use at other facilities will be reviewed to determine which attributes should be emulated at Perry. The person designated for this responsibility will work closely with personnel in maintenance, operations, eng:neering, and other departments, as well as with senior j management, to identify generic problems and effective means of reducing human error. hnnroved Manacement/ Labor Relationshin Perry Plant senior management. is taking several substantive steps toward improving the i management / labor relationship, including the following: The Vice-President - Nuclear, Perry, has been assigned management responsibility for long - term improvements in management / labor relationships, as well as daily resolution oflabor l problem.s. The techniques used in Management Action Response Checklists (MARCS), as described l in the. Manager's Guide to Labor Relations, will be emphasized for use by all management and supervisory personnel. 1 16 - - =. -

U b PCA - Rev. 0

A review of labor relations problems will be performed by a team of Perry managers in combination with external, experienced personnel, to identify root issues that should be resolved to improve short-and long-term management / labor relationships.

Communications Senior management has directed that, in the future, managers at all levels should meet more frequently with employees to better communicate and reinforce expectations and accountability t policies, and to receive feedback and suggestions from employees. In addition, an Ombudsman position has been established to enhance communication between management and employees. Normally, problems and concerns are resolved through the management chain of command. When the established communication paths do not function satisfactorily, quality, security, industrial safety, nuclear safety, and radiological concerns may be reported to and resolved by the Ombudsman in a confidential manner. Manacement involvement In order to reinforce expectations and improve accountability, a management involvement plan will be developed. This plan will include a schedule, including backshifts, for management tours of plant spaces; minimum requirements for time spent in the field; requirements for documentation of these activities; and an assessment of the observation training necessary to

O seggert these toers. importent fecai geints of thcee toers wiii ieciude reiefercine improved material condition, providing a management presence, and promoting communication between.

workers and management. j Supervisor Assessment and Trainine Procram .{ .A supervisory assessment and training program will be developed and implemented by senior management to determine those areas in a supervisor's performance which require correction or improvement. Counseling, training, and monitoring will be utilized to correct identified deficiencies. This program will help ensure that supervisors have the ' skills'and experience i required to meet the expectations placed on them. a Succession Plannine-t A succession plan will be developed to identify and train those individuals who possess a sufficiently' high degree of management potential. Included in this program will be a schedule for - providing these individuals with the training, work experience, and formal education needed to allow them to be given increased responsibility. This program will provide breadth ~and depth to the technical management capabilities of potential successors.. LO 17 i = - -

. ~ ~ _ -. -.. PCA - Rev.~ 0 IO. 1 t J SECTION 3

O ISSUES AND ACTION PLANS BY ORGANIZATION q

i d 's 1 i 1 I' 1 1 i 'l 1 o lO i u 1 -j < }- .a.

PCA - Rev. 0 O SeCriON 3 ISSUES AND ACTION PLANS BY ORGANIZATION This section describes the issues which have contributed to the Perry Plant's declining operational performance and reliability. A summary of the actions planned to address these issues is provided. Detailed scopes and schedules for commencing, implementing, and completing each af these actions have been or are currently being developed. As these plans and schedules are completed, they will be available for review on the site. 3.1 Operations 3.1.1 Issues The Operations Section has not shown sufficient professional stature, as indicated by the following problems. l Substandard conditions have been tolerated, including the marginal functionality and .O reliability f equipment, the marginal quality of many maintenance activities, and the ~ overall inadequacy of plant housekeeping. Ownership of plant systems, equipment, and related problems has been ineffective. Encouragement of a questioning attitude has been inadequate. The operations staff has shown an inability to recognize and/or document problems. Management's expectations were not effectively communicated to the operations staff. Individual accountability was not enforced. Operators have demonstrated unprofessional behavior, including inattention and deficient watch-standing practices. Procedural compliance problems have existed. Valve mispositioning problems have occurred. Personnel have failed to fulfill technical specification surveillance / compliance requirements.

O 18 1

PCA - Rev.' 0 Ineffective communication among plant personnel has existed. Errors in reactivity control manipulation have been made. Repeated instances of deficient work control have occurred. Records and logs have been inadequately maintained. Chemistry control problems that could lead to material degradation have existed. Safety tagging inadequacies that could lead to potentially hazardous conditions have been allowed. Deficiencies in fire protection have existed. l There have been problems with poor housekeeping and cleanliness control. J 3.1.2 Action Plan Summary To address the issues listed above, the following objectives and associated actions have been established. Management and supervision will continually emphasi7e the importance of applying the STAR (Stop, Think, Act, and Review) principle to every activity to instill a conservative, t (n) cautious, questioning attitude in all section personnel. Objective 1: Promote professionalism Operations Section personnel will work with selected other plants and INPO, and will i participate in selected other industry forums (e.g, INPO peer and assist visits, INPO shift supervisor development seminars, and industry-spoasored events such as-Professional Reactor Operator Society and American Nuclear. Society meetings),.to develop an understanding of industry examples of excellence in plant operations. Specific activhies and programs will be developed to address the following problem areas: - Radiological protection practices; - Thoroughness of readings, logs, and rounds; - Strict safety tagging program compliance, including accurate document completion;- t - Use of personnel safety equipment; - -- Control of plant configuration and status; and ( - Use of procedures. 19

PCA - Rev. O O Objective 2: Communicate expectations and feedback Senior operations management will provide continuous feedback to reinforce expectations and ensure that consistent shift policies are implemented and roles clarification is achieved. Supervisors will promote use of the " chain-of-conunand" in conducting daily activities. Shift supervisors will increase their field involvement and provide ~ coaching and encouragement to crew mernbers and support organizations. Objective 3: Enhance communications Supervisors will promote and coach their crews in the application of section communications policies (i.e., closed-loop communications and repeat-backs). This action will be supplemented by increased emphasis during simulator training. Operations will improve written communications by: - Increasing the content and accuracy of turnover notes; - Enhancing the quantity and quality of log entries; and .O i - Improving the content and direction of Daily Instructions and Standing Instructions. Communications between operations, planning, scheduling, maintenance, and instrumentation and control organizations will be enhanced through creation of an Operations Work Control unit. u The quantity and quality of preevolution briefings will be improved. Supervisors will specifically. monitor the quantity and quality of these briefings. l Objective 4: Establish better teamwork among shifts, sections, and departments In conjunction with enhancing communications (described above), the following actions will be implemented to establish better teamwork. Peer reviews will be used to identify strengths and weaknesses and to correct those weaknesses that are identified. The " vision" of Operations Section personnel will be enhanced through exposure to other utility _ operations and methods of doing business by such methods as INPO peer reviews and focused visits to other nuclear facilities. 20

PCA - Rev. 0 AV Supervisors will use a " coaching and counseling" approach to correct personnel and crew deficiencies; this is another implementation of the " leadership by example" principles. Objective 5: Promote responsibility and ownership for events and errors A system will be developed to promote personal accountability. An effective set of performance indicators will be developed to evaluate trends in performance and accountability. Shift involvement will be strengthened in the areas ofinvestigating and determining causal factors and root causes for problems and events occurring on shift, and in applying appropriate corrective actions. Improved root-cause training will be provided to the operations staff. Use of human performance evaluations and evaluators will be continued to address a personnel errors. Communication concerning problems or events among shifts will be enhanced through the use of shift personnel to communicate informatior. about the event, the causes identified, !O en d the corrective ec1io ee i m pie m ented to prevent recerreece of si m iier events. Objective 6: Improve overall plant material condition Better management leadership will be provided to effectively communicate expectations for improved plant material condition and housekeeping. Reduction of the work order backlog will be actively supported to achieve established plant. management expectations. These expectations include: - Continuing improvement in plant cicanliness to meet acceptable industry standards; - Minimizing the extent of radiologically contaminated areas; and t - Refusing to tolerate repeated equipment failures. - Opportunities for leakage will be minimized by making changes in design and maintenance practices. The number and extent ofleaks will be minimized during operations in conformance with ALARA practices and without compromising the reliability and operability of the plant. iO 21

PCA - Rev. 0 The Operations Section will increase its role in prioritizing work and developing outage scopes. Objective 7: Enhance operator training through increased involvement of shift personnel and management Shift Supervisor ownership for the crew training effort will be promoted by making the Shift Supervisor the leader during simulator performance critiques. Operations management will also participate in these critiques to provide independent assessment. Performance indicators will be developed or modified for evaluating and " trending" crew performance. Management will monitor and provide feedback to the operating and training staffs to promote the consistent application of operating philosophy, policies, and procedures. An " Operating Philosophy and Issues Handbook" will be developed and used to provide lessons from past Perry and other industry experiences and to promote the prevention of similar events. Operators who are normally on shift will be routinely rotated through the Training Section

O to vrevide en-te-dete keewiedse of viaet eneraties grec1 ices.

Operations and Training personnel will investigate other program enhancements through. evaluation of training practices at other plants.- Objective 8: Improve operating effectiveness through refinement of current practices Management and supervision will continually emphasize the need for feedback to ensure that programs and procedures are continually improved. Existing programs / organizational structures will be modified to improve effectiveness. Particular attention will be paid to the tagout program, the procedure revision / temporary change notice process, and the locked valve program. In addition, supervisor control, record /logkeeping, configuration control, and verification requirements will be emphasizedc Objective 9: Improve emergency operating procedures and programs A Plant Emergency Instruction (PEI) Improvement Team, comprised of six full-time personnel, has been formed to review the emergency operating procedures and resolve outstanding technical and administrative problems. The charter for this team is included as =O ^ttecameet ^. 22

PCA - Rev. O y Objective 10: Correct system problems affecting chemistry control Chemistry-monitoring capabilities will be improved to make them commensurate with industry standarcs for rapid response to changes in plant chemistry. This will be accomplished by replacing the existing chemistry database management system with an improved system and the installation of a new turbine plant sampling panel. The availability of on-line monitors and the reliability of on-line indicators in general have been improved by increasing the priority given to maintenance activities. The reactor panel conductivity monitors, the reactor panel dissolved oxygen monitors, and the turbine plant dissolved oxygen monitors have been replaced or upgraded with more reliable instruments. The turbine plant sampling panel will be replaced in RFO-5. Objective 11: Improve auxiliary system chemistry controls A plan for improving auxiliary system chemistry control has been formulated. A thorough investigation has been performed for materials of construction and on current industry methods for corrosion control. Oxygen control practices were also evaluated, and leakage into the system will be corrected. The current hydrazine additive appears to be effective for scavenging oxygen. However, a faster-acting, less toxic additive will be tested and evaluated for use in oxygen control. The upper pH limit has been lowered from 10.0 to 9.2 for auxiliary cooling systems. This places the upper limit closer to the normal operating rang and ensures that action is taken before copper-bearing heat exchanger tube corrosion becomes a concern. O 23 'I

PCA - Rev. 0 3.2 Maintenance 3.2.1 Issues Performance standards were not well established or effectively communicated. Performance of maintenance activities was not adequately monitored. The value of explaining the urgency of jobs to maintenance personnel was not recognized thereby ensuring that other supporting preparations were completed. Maintenance processes have been inefficient. Productivity has been low. A degraded material condition exists. Poor housekeeping and cleanliness control have been allowed. A large maintenance backlog exists. Deficiencies exist in maintenance work practices / control and material control. Deficiencies exist in work package preparation and implementation. There has been an excessive amount of rework due to deficiencies in craftsmanship and design, as well as inadequate problem resolution. Jumpers and lifted leads have been improperly used. Deficiencies in spare parts storage exist. Deficiencies in pre-and post-maintenance testing exist. Deficiency tags have not always been used. ) There have been lax industrial safety and health practices. 1 b w 24-

~ PCA - Rev. 0 3.2.2 Action Plan Summary These objectives and associated actions comprise the maintenance " pursuit of excellence" plan, which is designed to address the following objectives. Objective 1: Address management issues The following process improvements address the management issues listed above and will result in improved worker productivity. The maintenance organization is being reorganized to improve lines of communication, establish ownership of maintenance assignments, and promote consistency in work practices. Individual maintenance superintendents will be assigned for electrical / mechanical. plant systems, instrument and control systems, plant structures, and administration / planning. Management, from director-level through first-line supervisors, will clearly communicate performance expectations and reinforce standards by: - Maintaining direct, daily contact with workers; - Holding periodic "all-hands" meetings; 10 - Contieeins deiir m eeties ; - Conducting backshift plant tours; - Emphasizing management's presence in the working spaces. These actions provide a dialog between management, supervision, and workers that allows discussion of problems, communication of the importance of the work being performed, and recognition of quality work and successes. Specific perfonnance indicators will be modified or developed to assist management in assessing maintenance performance in areas such as productivity, rework, nonconforming-activities, personnel training, and retesting. + LO 25 )

PCA - Rev. O Objective 2: Improve work practices Improved root-cause training will be implemented for selected maintenance personnel. This training will support the human error reduction effort and improve worker sensitivity to system and equipment problems which are often first observed by rnaintenance personnel. Work package preparation and implementation will be improved through the following actions. - An improved computer-based work order preparation system will be developed and implemented. The following will be reviewed as part the development of this system: 1. Use of a combination of optical imaging and character recognition to prepare a single work document; 2. The form and accessibility of data files for vendor information, procedures, and instructions; 3. Use of a computer software graphics package to construct sketches; 4. Use and annotation of layout drawings and/or survey maps; iO 5. siectronic greveretiee, review, end engrovei or eciei Permits; r 6. Accessibility of on-line review of radiological work permits; and 7. The extent of ties needed to procurement activities, ALARA planning, and system constraints. - Maintenance procedures and practices used at selected successfully managed nuclear facilities will be reviewed, and strengths noted during these reviews will be incorporated into the Perry Plant's procedures and standard practices. Improved maintenance training will be implemented, based on review of procedures and ~ "1 practices at other facilities and INPO good practices. This training will focus on reducing the extent of rework by improving root-cause determinations ei the original problem, ensuring strict procedural compliance, and emphasizing the importance of exemplary work for all maintenance activities. Standardized inspection and pre-and post-maintenance testing requirements-will' be developed. A multi-disciplinary team will review other facilities' inspection and testing procedures / practices, current industry standards, and INPO Good Practices' to identify attributes to be emulated at the Perry Plant. i, 26

,_~ -. PCA - Rev. 0 Methods for tracking staged and stored materials in the plant will be improved to eliminate the amount of excess materials improperly stored in the plant, contaminated materials, tools, and scaffolding. Maintenance will be a key member of the interdisciplinary review team which will perform a review of tempo'ury modification controls, including the use ofjumpers and lifted leads. Among the team's objectives are reducing the use of temporary modifications (including usage time) ar'a implementing a minor modification control process to reduce the need for the tempor.ry modification process (see also Section 3.5.2, Engineering Action Plan Summary). Objective 3: Reduce large maintenance backlog Planning for on-line maintenance and RFO-4 will emphasize reduction in the total number of work orders, as well as completing work orders considered most important to improving overall material condition and ensuring the continued safe and reliable operation of the Perry Plant. Work orders will be reviewed to confirm currently assigned priorities and to remove duplicate work orders and those that no longer require completion. O The preventive meintenaece werk erder beckieg wiii be reviewed 1e en ere ihe11he mest important maintenance tasks are performed and that the extent and form of the preventive maintenance specified is appropriate. Work orders will be categorized by type of work activity, as well as by priority. - Labor and supervisory activities that can be grouped (e.g., valve packing replacement and adjustment and nondestructive examination (NDE) activities such as the erosion / corrosion monitoring program) will potentially be contracted in bulk to a maintenance / construction service company. This will release company maintenance resources to work on specialized or limited scope maintenance activities. - For selected tasks involving repetitive maintenance activities, a prr-assigned team may be used to perform this work. Working agreements will be pursued with other nuclear facilities, particularly those using boiling water reactors (BWRs), to arrange for the use of specialized machines and tooling, as well as specially trained personnel for equipment maintenance and modification activities .(e.g., main steam isolation valve maintenance and modifications; motor-operated valve maintenance, modification, adjustment and testing; reactor pressure vessel internals inspection; and turbine testing and modification). This approach will expand the total capabilities of the Perry maintenance team without the necessity of permanently increasing O its size. 27

PCA - Rev. 0 Objective 4: Improve plant material condition Work activities which address improvements in plant material condition will be emphasized as part of the prioritization process described above.

High standards of plant housekeeping and cleanliness will be enforced during the outage periods, as well as during operation. Pride in plant appearance will be emphasized, recognizing that exemplary plant cleanliness reduces the potential for personnel injury, minimizes the spread of radiological contamination, and facilitates identification of conditions requiring corrective maintenance.

Objective 5: Implement deficiency tagging process

A material deficiency tagging process will be implemented following the Fall 1993 maintenance outage. This process will complement the current computerized tracking system of work requests and facilitate identification and recognition of deficient material conditions in the plant.

Objective 6: Improve industrial safety and health practices lO The overall improvements in plant material condition and plant cleanliness described above ~ V will contribute to improved industrial safety and health for the plant.

The Stop, Think, Act, Review (STAR) program will be used by managers and supervisors, and this program will be complemented by human error assessment program activities.

O-28 i

PCA - Rev. 0 3.3 Radiation Protection 3.3.1 Issues Deficiencies have existed in: - Administration and enforcement of the radiation protection program; - Radiation protection practices; - Radiation protection planning; - ALARA standards; and - Radiation protection instrumentation / dosimetry accuracy. Control of radiological areas has been substandard. Control and processing of radioactive material has been ineffective. 3.3.2 Action Plan Sun: mary D V To address these issues, the following objectives and associated actions have been established. Objective 1: Reduce unplanned personnel contamination events Emphasis will be placed on increased first-line supervisory accountability, increased worker awareness of potential causes for personnel contaminations, and improved worker training. The Decontamination Task Force has been formed to reduce the extent of contaminated ' areas and to improve controls to ensure that areas which are designated " clean" remain contamination-free. Objective 2: Reduce radioactive waste volume A Radioactive Waste Volume Reduction Task Force has been established to recommend means of reducing plant-generated solid and liquid waste, including the volume oflow-level solid radioactive waste packaged for burial and liquid radioactive waste discharges. i = 29

i PCA - Rev. 0 1 Objective 3: Improve Radiologically Restricted Area access Radiologically Restricted Area (RRA) primary and secondary access and egress points will be modified to improve traffic flow, enhance communications, reduce background noise interference during prejob briefings, and to minimize the potential for clean area contamination. Objective 4: Reduce the volume of stored radioactive material inside the RRA A Radioactive Material Disposition Task Force has been established to minimize the volume of radioactive material, equipment, and tools stored in the plant or in the Radioactive Waste Interim Storage Building (RISB). Benefits to be obtained from this action include minimizing the cost of radioactive material disposal and aiding the overall plant housekeeping effort. Plant Administrative Procedure (PAP)-0515, " Control of Radioactive Material," has been revised to better define, label, and control contaminated tools and equipment that can be used inside the RRA. A centralized location will be established for the issue and return of tools, equipment, vacuum cleaners, hoses, High Efficiency Particulate Absolute (HEPA) units, etc. In h addition, secondary locations for issue and return of tools will be established during outages to increase worker efficiency. New and innovative decontamination processes for tools and equipment will be researched and evaluated. Objective 5: Controllocked IIigh Radiation Area doors An audible / visible locking control system will be installed in locked High Radiation Areas. Where this system has been installed, no High Radiation Areas have been found unsecured. Objective 6: Improve radiation protection instrumentation / dosimetry sensitivity and accuracy A technical evaluation of the clean trash monitoring program has been completed. The evaluation recommended numerous changes to the calibration and operation of the equipment in use, which have resulted in a fourfold increase in detection capabilities. 'A digital alarming dosimeter and computerized access control system has been installed at both RRA access control points. These digital alarming dosimeters provide a monitoring

h capability similar to that of thermoluminescent dosimeters (TLDs).

30

PCA - Rev. 0 To provide real-time access contr

to the RRA, an HIS-20 Canberra automated access control system has been obtained arJ is being tested. Once installed and operational, this

c stem will provide additional accuracy in tracking egress and ingress to the RRA.

Objective 7: Improve administration and enforcement of radiation protection controls A code of conduct and standards of performance for Radiation Protection Section personnel will be developed and implemented. This document will clearly state that management will hold Radiation Protection personnel accountable for adhering to established standards of performance. Radiation Protection management tours of the plant will be conducted to assist in communicating expectations and enforcing standards. Management credibility will be improved by the participation of Radiation Protection managers in Advanced Radiation Worker Training question and answer sessions. Management ownership of training will be improved by establishing quarterly Radiation Pmtection training review meetings to address training performance issues. The Radiadon Protection Section's support of qual'ty assurance will be improved by requesting more problem-specific surveillance, similar to a recently completed personnel i contmnination surveillance. Objective 8: Emphasize ALARA standards in radiation protection planning Revised 10CFR20 requirements were implemented on October 4,1993. These requirements include significantly reducing individual radiation exposures and implementing a fermal ALARA program. Worker involvement in tre SLARA program will be encouraged by implementing a new ALARA suggestion program. Plant material condition will be enhanced by reducing the need for shielding (e.g., by flushing lines) or by installing permanent shielding via a design change. f Pre-and post-job ALARA reviews, commumcation, and planning will be improved by requiring a formal first-line work supervisor review and obtaining worker feedback during postjob evaluations. Management will evaluate the procurement and use of robotics to inspect and survey High Radiation Areas to maintain ALARA doses. I 31 .t r-

. A.--.---------

P PCA - Rev. 0 3.4 Quality Assurance 3.4.1 Issues - Quality Assurance (QA) management has accepted minimum requirements and did not strive towards improvement and/or excellence. QA management has not supported efforts by QA personnel to pursue quality issues. QA management has not encouraged pursuit of improvements or set higher standards due to senior management's tacit policy of discouraging problem identification. - QA personnel have been isolated from other industry facilities, which has resulted in a. failure to reflect the increasing standards and improving performance of the industry in the operation of the Perry Plant. Line management has been unreceptive to constructive criticism. P Technical problems have not been effectively resolved by the Independent Safety Engineering Group (ISEG). 3.4.2 Action Plan Summary The following ot3jectives summarize an overall program for further improvements in Quality Assurance activities at the Perry Plant. Objective 1: Assure management support Senior plant management and Quality Assurance / Quality Control (QA/QC) management changes have been made to implement the necessary improvement programs. An Independent Assessment Policy Statement was issued by the Senior Vice-President - Nuclear. This policy describes the role of independent assessments. in achieving performance improvements, as well as senior management's expectation that all personnel will welcome, encourage, and cooperate with those performing such assessments. To clarify this management expectation, the policy specifically states, "We will not be defensive or argumentative when discussing the observations, inquiries, or results of an assessment." A L copy of the Independent Assessment Policy Statement is included as Attachment B. A new Nuclear Quality' Assurance Program Policy has been approved for implementation I at Perry by Centerior's Chairman and Chief Executive Officer. In a_ddition to establishing guidelines for the development, maintenance, and implementation of the Perry QA Program, the policy describes the Chief Executive's expectations of the Vice-President - ~ LO 32-1

PCA - Rev. 0 p. V Nuclear, and the Director, Nuclear Assurance. A copy of this Nuclear Quality Assurance Program Policy is included as Attachment C. The Nuclear Assurance Department's mission has been redefined and issued to all QA personnel to clearly communicate that the prime objective is to identify, effectively communicate, and, subsequently, to confirm the resolution of quality problems. Objective 2: Perform more effective QA Quarterly Assessments New assessment guidelines will be established which will assure that proper focus is placed on key issues requiring senior management attention. A special directors meeting will be held each quarter to jointly review assessment results for performance indicators, thereby trending the performance of the plant and plant staff. Objective 3: Improve audit, assessment, and inspector performance The QA and ISEG Section managers will jointly develop a systematic plan to ensure QA and ISEG Section personnel observe activities at other plants which exhibit exemplary performance, with the purpose of raising the standards at Perry. The inclusion of technical experts on audit teams and ISEG projects will be expanded to assure that adequate technical content is included in audits and assessments. The process and philosophy for selection ofinspection points will be evaluated to determine the effective application of QC resources. Objective 4: Achieve quality organization excellence

An assessment using external, experienced QA personnel will be conducted to confirm the adequacy of the Nuclear Assurance Department's staffing and programs.

u 33 I

.] PCA - Rev. 0 3.5 Engineering 3.5.1 Issues Day-to-day responsive, effective support to the plant has been lacking. Inappropriate focus has been placed on resolving specific, narrow issues of the day without adequate assessment of the potential extent-of-condition (generic applicability) of the problems encountered. Efforts to address the long-term needs of the plant have been ineffective. Known potential problems have not been addressed on a contingency basis Inadequate technical maturity has existed, i.e., judgment has been lacking concerning the extent to which a problem should be pursued and a questioning attitude has not been encouraged. Root-cause evaluations either have not been performed or have been inadequate when required. The design review process has been inadequate. Deficiencies have existed in the temporary modification process. Overall technical quality has not been improving. There is a backlog of modification requests. Deficiencies have existed in the administrative activities associated with the Engineering program. Deficiencies have existed in the control of procurement and vender specifications. 3.5.2 Action Plan Summary The following objectives and actions address the issues listed above. tO 34 J

PCA - Rev. O Objective 1: Prepare an Engineering Development Plan A plan for the short-and long-term development of the Engineering Department will be prepared. This plan will include a description of: - Organizational responsibilities and selected position descriptions; - Interfaces with Operations, Maintenance, Materials Management, Regulatory Affairs, and Quality Assurance, as well as with outside organizations such as the BWR Owners Group, the Nuclear Utilities Management and Resources Council (NUMARC), and the Electric Power Research Institute (EPRI); - Important Engineering Department weaknesses and deficiencies, and a sununary description of planned actions for improvement; - An overall breakdown of types of work and specific programmatic areas, with designation of whether work is to be completed by in-house engineering capability, including-augmented staff, or by a contractor organization; - Areas of planned technical and management development for Engineering personnel; and - Programs being developed and led by the Engineering Department.

O Objective 2: Improve processing of design changes The engineering design process has deficiencies. While the process for design control and implementation of design changes is judged to be adequate, there are deficiencies in the design and review process, as well as in configuration management controls. The following actions are planned to improve the engineering design process.

A Design Practices training course will be implemented, and completion will be mandatory for Engineering personnel. This course will be offered periodically to refresh Engineering personnel who are not actively involved in detailed design review activities on a day-to-day. basis. The course will be used as one method for communicating lessons learned through the corrective action and quality assurance processes. The course curriculum will include major elements of design development, design review, design verification, and root cause determination and assessment of potential extent-of-condition. Emphasis will be placed on the technical quality of the design process, rather than the administrative process.- An Engineering Design Processes training course will be implemented that has several parts. Each part will be directed toward particular aspects of the engineering process and - interfaces with other plant organizations, (e.g., design control; design package preparation; - configuration management, design basis documentation; and procurement activities). ..O 35

PCA - Rev. 0 A detailed Configuration Management Improvement Program Description will be developed by May 1994. In support of the development of these plans, reviews of the adequacy of currently existing databases (e.g., equipment, calculations, design basis documents, and drawings), as well as the design basis documentation, will be completed to determine the extent of upgrades required and the extent ofinterconnections desired for computer-based databases. These reviews will be coordinated with complementary reviews performed for procurement databases, work package preparation, and planning functions to identify common needs, reach agreement on site-wide and corporate interconnections, and ownership of the databases and information. A review of the design change process will be performed to ensure proper controls. - A review is currently being applied to procurement activities (e.g., specifications, vendor manuals, vendor notifications). The quality of engineering safety evaluations will be improved. Steps in this action plan will include the following actions. - The policy statement and implementing procedure for safety evaluations will be prepared / revised, clearly delineating the technical / regulatory expectations associated with preparation and review of safety evaluations. The extent to which engineering judgment. is considered acceptable and the means for documenting the use of engineering judgment .O w4ii be iecieded in thie veiicx stetemeet. - Training on the preparation and review of safety evaluations, and on the use _of engineering judgment, will be a prerequisite to preparing and approving safety evaluations. The Director, Engineering, will specifically approve those individuals who may prepare and approve safety evaluations. - Self-assessments using external assistance will be' performed as judged necessary to measure the effectiveness of improvements made to the. quality of safety evaluations. Objective 3: Reduce backlog of modification requests To reduce the large existing backlog, the following actions are planned. A common method for prioritizing work on site, including modifications, is' being - developed. The prioritization review will be performed by a working group of management personnel from Operations, Maintenance, Engineering, arid Regulatory Affairs. Application of this priority scheme will serve as the basis for evaluating' the backlog of modifications. Lower priority modifications will be evaluated and either placed on the long-range schedule, cancelle'd, ' or be identified byl planning status on - the database (e.g., for contingency work). Cancellation will involve ensuring related documentation is updated to O retiectthe cenceiied etetes efthe mediricetien. Taie wiii se compieted bv 3eee 1995. 36

PCA - Rev. 0 An initial review of the modification request backlog will be completed by December 1993 - to identify modifications which should be implemented during RFO-4 and RFO-5. Once prioritized, the backlog of modification requests will be categorized to identify which work will be performed by Perry's Engineering personnel, and which can be grouped or packaged for completion by an engineering services contractor. Use of engineering services contractor resources over the short term will permit reducing the backlog to a size that is manageable by the Perry Nuclear Engineering Department. Objective 4: Increase Engineering section involvement in refueling outage planning and execution The Director of Engineering, together with the Plant General Manager, will issue a policy for increasing Engineering Department participation in the outage planning process. Engineering will provide designated individuals to work on RFO-4 planning and scheduling. The Engineering Department will provide on-shift representatives for support during outages. Engineering will prepare and periodically update performance indicators which monitor A progress in the preparation of design packages and other engineering products to support refueling outages. Objective 5: Improve System Engineering involvement in the plant work process System Engineering procedures and practices used at selected other nuclear units, including Davis-Besse, will be reviewed to compare expectations and standards and to determine successful practices which should be emulated at the Perry Plant. An INPO assist visit will' be requested to assess the overall System Engineering organization and its interfaces with the plant organization and the other Engineering Sections.' l A System Engineering work practices instruction will be prepared. This instruction will= ] outline the expectations of Perry Plant management regarding the role of system i engineering in day-to-day activities and in the planning process for refueling outages. Training for system engineers will be reviewed and modified periodically to reinforce management expectations and to facilitate the necessary level of system engineering and -{ operational knowledge. Emphasis will be placed on training system. engineers to consider i the root cause and the potential extent-of-condition for problems, and to communicate with 37 i ~

PCA - Rev. O other system engineers and operations engineers on a regular basis to ensure a shared knowledge of observations and plant problems. Objective 6: Improve the temporary modification process System Engineering has been assigned to monitor the temporary modification process. The objective of such monitoring is to ensure that the temporary modification process is used properly, i.e., is not used in place of the permanent modification process, and that temporary modifications are removed in a timely manner or evaluated for conversion to a permanent modification. A minor modification process will be implemented to facilitate modifications that do not require the full extent of review and verification used in the current permanent modification process. Use of this process will require satisfying a strict set of criteria. The success of this process depends on the experienced judgment of the Engineering managers who must approve its use. The number of temporary modifications will be reduced, with special focus on removing existing mechanical foreign items, lifted leads, and jumpers by the end of RFO-4. Remaining temporary modifications will be removed or replaced by a permanent I

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modification by the end of RFO-5. Until these objectives have been satisfied, a performance l. indicator will be maintained to trend the remaining number of temporary modifications. Following RFO-5, the objective will be to keep the total number of temporary modifications at less than ten at any time during an operating cycle. Objective 7: Implement improved Incident Response Team Weaknesses have been identified in the response to plant incidents (e.g., plant trips and transients; equipment failures). An improved Incident Response Team will be implemented as an on-call team comprised of broadly experienced personnel. A management policy and procedure will be prepared, which will describe the specific approach and responsibilities of the Incident Response Team members. Formal incident response training will be provided to team members, including conduct of interviews, preservation of plant data, and application of assessment techniques. O 38

PCA - Rev. O Objective 8: Improve support for the Corrective. Action Program Root cause, extent-of-condition, and remedial actions training will be improved. [See Design Practices training course under Objective 2.] Contingency planning, including evaluation of potential adverse consequences for unresolved technical issues will be considered in developing corrective actions. l 'O 1 lO l 39 l l l

. PCA - Rev. O. LO i ) -i SECTION 4 O ISSUES AND ACTION PLANS' FOR SELECTED TOPICS l 4 l l i o .O 1 .j i

PCA - Rev. 0 O SECT 1ON 4 ISSUES AND ACTION PLANS FOR SELECTED TOPICS This section summarizes the issues and planned actions for selected topical areas which are important to both short-and mid-term improvements in operation of the Perry Plant. Detailed scopes and schedules for commencing, implementing, and completing each of these actions have been er are currently being developed. As these plans and schedules are developed, they will be available for review on the site. 4.1 System Operation and Test Review Program 4.1.1 Issues Currently, there is no known system equipment degradation or fundamental inadequacy in the design or work process controls that suggests a compromise in the safe operation of the Perry Plant. This conclusion was reached by a combination of technical and operational reviews by the new Perry senior management of the functional characteristics important to maintaining safe operation (e.g., reactivity control, inventory control, heat removal capability, readiness of engineered safety systems, and operator / machine interface), as well as a high-level assessment of overall plant operations by an independent team of experienced, industry-recognized senior management and technical personnel. The aggregate of the observed system material degradation and equipment reliability problems, however suggest that a direct, deliberate confirmation of system and equipment readiness and functionality is warranted. This confirmation will be initiated as part of the System Operations and Test Review Program. In addition, such testing will assure that the shortcomings observed in the execution and implementation of process controls (e.g., design and configuration control, work control, preventive maintenance, testing, and quality assurance) have not adversely affected the functional adequacy of plant systems and equipment. 4.1.2 Action Plan Summary This is a phased program that will first focus on several selected systems considered important to the safe and reliable operation of the Perry Plant. Based on the results of this focused effort, management will determine the scope and extent for a long-term program. The following describes the specific steps and schedule associated with each phase. O l 40

y.- ' PCA - Rev. O Phase i During Phase I, the following actions will be performed. Systems will be selected for review and testing based on the extent of associated operational problems and the level of interaction with other systems considered important to the safe, reliable operation of the Perry Plant. Maintenance, modification history, and acceptance testing records will be reviewed to identify problem areas requiring particular attention. Important material and design deficiencies will be addressed as part of this first phase. Detailed functional requirements will be verified or identified. = Existing surveillance or other periodic testing requirements will be reviewed to assess the completeness of testing used to confirm functional adequacy. Existing testing will be revised and/or new testing requirements will be prepared,~ inchding one-time testing (if judged necessary). Based on these functional requirements, detailed acceptance criteria applicable to periodic I or one-time testing to confirm functionality will be confirmed or determined. l l l.

Functional testing of the selected systems will be performed.

Based on results of this functional testing, the extent of required corrective actions will be determined. Phase I, as described above, is scheduled for completion by the end of RFO-4. Phase II l Determination of the scope, extent, and schedule for the second phase of this program will be based on the results of Phase 1. Phase II activities are planned for completion by the end of RFO-5. .O 41

PCA - Rev. 0 4.2 Corrective Action Program 4.2.1 Issues The Corrective Action Program has often been ineffective and response has been untimely in correcting known problems, as well as in identifying problems that should be addressed. The program is not being properly utilized to document problems. Root cause determinations of identified deficiencies often have been incomplete or incorrect. The possible causes of these problems may be summarized into the following categories: Identification - The corrective action procedure is deficient because it permits too much discretion in identifying problems that should be documented. - There has been a perception among plant staff that management is willing to accept y:v deficient plant conditions, and that problem identification will not be followed through to completion. Determination of Root Cause and Extent-of-Condition - The adequacy of root cause determinations varies greatly. - No multidisciplinary review of root cause evaluations has been required - Potential extent-of-conditions often have been inadequately assessed. - Ineffective quality controls nave been applied to root cause evaluations and processes. Corrective Action Implementation - Completion of the corrective action process has not been confirmed. - Trending of corrective action causes has been ineffective, and management's explanation of the importance of using the corrective action program to identify adverse trends in overall plant condition has been inadequate. - Limited emphasis has been placed on the importance of timely corrective actions. 4 42 9

PCA - Rev. O t 7s l' 4.2.2 Action Plan Summary Perry's new management is resolving issues related to the Corrective Action Program in two phases. Phase I The following steps have been or are being taken to provide improvements as part of the Perry. Corrective Action Program. Senior management has emphasized the importa*.cc of effective problem identification in daily Plan-of-the-Day meetings. As a resul., plant personnel are identifying and documenting problems at a much lower threshold of significance, as evidenced by a twofold increase in the number of Condition Reports initiated. i The Director, Nuclear Assurance, now chairs the biweekly Corrective Action Progress Review meeting to emphasize the importance of timely investigations and corrective actions. This action has resulted in a significant reduction in the number of delinquent items. By December 1,1993, the following interim improvements will be made to the Corrective Action Program. The current Condition Report procedure will be revised to provide guidelines for problem identification and additional examples of potential conditions that are adverse to quality. A multidisciplinary review board, comprised of senior supervisory personnel, will be established. This board will meet frequently to review new corrective action items and. assign organizational responsibility for determining resolutions. Director or General Manager approval will be required for extension of scheduled completion dates for corrective actions. Phase II , A new Corrective Action Program will be developed after the Fall 1993 Maintenance Outage is completed. This new program will incorporate the best features of several successful programs in place elsewhere in the industry, including: A single process system for conditions considered potentially adverse to quality; s A multidisciplinary review board; O 43

PCA '- Rev.' 0 l 2'

An improved root-cause investigation process that is supplemented by training;.
A detailed action-tracking process; and
A trending process to assess the program's effectiveness.

This new Corrective Action Program will be irnplemented by the completion of RFO-4. o ,i . O 44 ?

PCA - Rev 0 -O

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'4.3 Material Condition Improvement 4.3.1 Issues Planning is needed for outage work activities that will improve the overall margin of safety, material condition, and reliability of the Perry Plant. 4.3.2 Action Plan Summary To achieve immediate improvement in the plant's material condition, a previously unscheduled maintenance outage is being performed, and the length of RFO-4 is being extended. This Fall 1993 maintenance outage commenced on October 1,1993, and will last six weeks. During the outage, several hundred work items will be completed. RFO-4 will commence on February 4, 1994. The length of this outage will be determined by the extent of the maintenance, modification, and testing activities required. A preliminary summary of planned RFO-4 activities is described below. At present, RFO-4 is scheduled to last 85 days. Additional improvements in material condition will be implemented through increased on-line maintenance and an extension of RFO-5. The Fall 1993 Outane o-The Fall 1993 maintenance outage is focused on selected improvements in the material condition V of the plant and implementation of selected modifications to increase the margin of safety. The outage scope will include the following activities. The reactor pressure vessel water level indicating system and the Emergency Core Cooling System check valves will be modified to improve the Perry Plant's safety margin (approximately 30 additional, smaller modifications also will be implemented, including changes to the fuel handling syster and to selected motor-operated valves). The adequacy of the improved motor-operated valve engineering and testing procer., witi j be confirmed by modifying and testing eight selected motor-operated valves. The number of steam and water leaks in the plant will be reduced to decrease: (1) the spread of low-level radioactive contamination; (2) plant personnel radiation exposure and contamination; (3) off-site release; and (4) waste water processing and make-up requirements. The potential for future valve leakage will be reduced by repacking approximately 300 valves. The number of temporary modifications will be reduced, including the removal of temporary leak repair clamps. O 45

__ ~ PCA - Rev. 0 + The containment and drywell will be inspected and cleaned, as required, to minimize debris which could compromise proper operation of the Residual Heat Removal System. General housekeeping improvements will be performed to enhance overall professionalism and pride in the plant. Refueline Outace-4 A preliminary list of important activities that will be completed during RFO-4 may be summarized into the following categories. Improvements in the Overall Margin of Safety: . A broad range of modifications to motor-operated valves will be completed. These include selected gear train and motor size changes, resolution of potential pressure lock / binding problems, and adjustment of torque switch settings. In addition, a combination of static and dynamic testing will be performed to confirm the functional capabilities of selected safety-related motor-operated valves, in response to the requirements of Generic Letter 89-10. Review and evaluation activities and performance of confirmatory functional testing will be completed for the three systems considered important to the Perry Plant's safe, reliable operation, as part of the System Operations and Test Review Program described in Section 4.1. + Modifications to the two "C" line main steam line isolation valves will be completed to - resolve recurrent leakage problems. This upgrade will complete all main steam isolation valves. Modifications will be installed to upgrade the Division 3 diesel generator to permit its use as a backup electrical power source for a wider range of equipment in the event of a station blackout. Selected instrumentation upgrades will be made to: - Facilitate periodic performance testing of the Residual. Heat Removal System heat exchangers and Emergency Service Water / Emergency Closed Loop Ccoling heat exchangers; and - Improve the operability of the containment hydrogen analyzer and reduce the associated maintenance attention required.

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..... ~ PCA - Rev. 0. f Reliability and Material Condition Upgrades: As a goal, the number of temporary modificatiens will be reduced'to less than 25. Approximately 1500 maintenance work orders will be completed, including attention to overall material condition and housekeepmg improvements. Modifications will be made to permit removal of selected safety-related piping system and equipment snubbers to reduce the extent of periodic testing / inspection and corrective maintenance attention, and to permit focusing on other important maintenance and material condition improvements over the long term.

Additional instrumentation upgrades, e.g., Riley process control module replacements, will -

be made to improve equipment reliability and reduce maintenance burden. Retiribility will be improved by making modifications to the motor-driven feed pump and the reactor feed pumps to change the vane passing frequency and, thereby, reduce overall vibration levels. Main turbine torsional testing will be performed to evaluate the sensitivity to negative phase } sequence currents and determine the extent of subsequent modifications. e v i O 47

PCA - Rev. 0 ' 4.4 Related Issues This section includes a range ofitems related to overall improvement of Perry Plant operations. These items do not directly address the issues listed elsewhere in Sections 3 and 4, but instead, constitute programmatic and technical areas that warrant focused attention as an integral part of the Perry Course of Action to achieve substantive improvements in performance. 4.4.1 Motor-Operated Valve Program 4.4.1.1 Issue The motor-operated valve program, which is being implemented under the requirements of NRC Generic Letter 89-10, has been determined to be deficient in engineering, testing, and planning. 4.4.1.2 Action Plan Summary The following actions are being completed to resolve the inadequacies in the motor-operated valve program.

Deficiencies identified by previous internal and external assessments currently are being resolved. These include issues identified in both the external assessment that was previously.

completed by a third party and the quality assurance audit performed in August 1993.

s Selected valves are being modified and tested during the Fall 1993 maintenance outage to confirm that several important deficiencies have been resolved.

-A motor-operated valve program manual will be developed to provide a compilation of actions, procedures, and activities required to bring and maintain the motor-operated valves within the requirements of NRC Generic Letter 89-10. .An extension request will be prepared for submittal to the'NRC. This request will indicate a that the requirements of Generic Letter 89-10 will not be completed until the end of RFO-5. That correspondence will describe the anticipated status of the motor-operated valve program at the end of RFO-4, including a description of risk prioritization and the specific condition of valves for which the program has not yet been completed. 442 Service Water and Circulating Water Piping Failures 4.4.2.1 Issues Service Water and Circulating Water underground fiberglass piping systems have previously exhibited problems that require specific actions to maintain adequate operational reliability and integrity. Extensive repairs, recommended and performed by experienced fiberglass contractors c during previous forced and planned outages, were 2equired to provide continued fiberglass piping .\\ system reliability and integrity. 48

PCA - Rev. 0 ' 4.4.2.2 Action Plan Summary i The Circulating Water system will be inspected / repaired each refuel outage to maintain system integrity. The assumptions used in Service Water System repairs that were previously performed to provide a high level of operational con 6dence through RFO-6 will ~ ~' be reviewed to determine if any subsequent inspections / repairs are needed during the upcoming RFO-4 and RFO-5 outages. r Subsequent inspections will be scheduled, and necessary modifications will be identified and implemented.

A feasibility study will be initiated to evaluate the available options for improving Service Water reliability (e.g., pipe replacement, parallel routing, pipe lining, etc.).

+ The options identified will be evaluated to improve Service Water reliability and to determine what future actions will be needed. Available on-line monitoring techniques will be evaluated to determine ifleaks in fiberglass piping systems can be detected. t 4.4.3 Reactor Recirculation Pump Shaft Replacement 4.4.3.1 Issue Thermal cracking and mechanical fatigue failure of the reactor recirculation pump shaft may occur due to design deficiencies. 4.4.3.2 Action Plan Summary Seal injection flow is turned off at normal operating conditions to reduce thermal stresses.

Operating procedures have been revised to reduce mechanical bending loads.
The reactor recirculation pump rotating assemblies will be replaced by an improved design (scheduled for RFO-4).

As a precaution, the vibration and phase angle of the reactor recirculation pump continues 'j to be monitored to detect impending failure. ~ i O. 49 u

PCA - Rev. 0 4.4.4 Off-Gas Effluents 4.4.4.1 Issues Off-gas system equipment deficiencies have led to reduced equipment reliability and the potential for increased off-site dose levels. These deHeiencies include: i A reduced availability of carbon bed vault refrigeration systems; A high off-gas flow rate (compared to other BWRs); and A refrigeration system operating at a temperature (0 F) that makes successful corrective maintenance difDeult to accomplish. An off-gas system designed to run at ambient would allow elimination of the carbon vault refrigeration systems and reduce equipment maintenance. 4.4.4.2 Action Plan Summary Equipment deGeiencies are to be corrected. A review of the off-gas system design will be conducted to determine whether changes should be made to the operating temperature of the carbon beds. This plan will be accomplished in two phases. ~ Phase 1: Eauinment Deficiencies Leaks in the brine system will be repaired. Sources of air input into the condensers and/or off-gas system will be identified and corrected. Air handling units will be repaired. The brine control system will be repaired and adjusted to properly maintain system temperature. System insulation and the vapor barrier will be restored to its design configuration. System operating temperature will be temporarily increased from 0 to 35 F as a test to assess functionality with temper'ture. Phase 2: Eauipment Desien Altematives A design review will be conducted tc determine whether design modi 6 cations should be made to allow ambient operation of he carbon beds, or to maintain operation at 35* F. 50

PCA - Rev. O If determined practical by a feasibility study, a design change v.I be processed, and the off-gas system will be operated at ambient temperature. 4.4.5 Maintenance Rule Implementation 4.4.5.1 Issue On July 10, 1991, the NRC published in the Federal Register (56 Fed. Reg. 31324) its final Maintenance Rule entitled, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 and NUMARC 93-10 were issued in May 1993 to provide guidance on implementation of this rule. Compliance with 10CFR50.65 is required by July 10,1996. 4.4.5.2 Action Plan Summary A project plan is being developed to establish a program to satisfy the requirements of the new NRC Maintenance Rule. A Steering Committee of Engineering, Operations, and Maintenance managers, with the assistance of Davis-Besse personnel, will be responsible for implementation of this project plan. The project plan will define responsibilities, implementation steps, and a project schedule. NUMARC 93-01 will be used as the primary guidance document. Some of the strategies for the Maintenance Rule project include: Strengthening and using existing plant programs and procedures to the maximum possible extent to achieve rule compliance; Participating in industry activities to exchange ideas and plans with other utilities; Obtaining independent assessment of project compliance approximately six months prior to the mandatory compliance date; and Using a plant-specific verification and validation (V&V) process early in the project to identify those programs, procedures, and data bases that require modification to support compliance with the NRC rule. 4.4.6 Control Room Upgrade Project 4.4.6.1 Issue The existing configuration of the Control Room has evolved to include changes made during the last twelve years, including both the test phase and commercial operation of the plant. These Control Room changes were completed in several phases using make-shift components and available " standard" office furniture. Consequently, there have been numerous problems identified 51

+ PCA - Rev. O by Control Room operators, such as a high ambient noise level due to the absence of sound dampening features in the room, the unsightly appearance of work areas due to the configuration of workstations, and a lack of proper storage space. With the recent adaptation of large Plant Emergency Instruction (PEI) flowcharts, the inadequacy of the current workstations and storage areas has presented additional problems. Also, concerns have been identified that are related to the current configuration of Control Room workstations equipped with CRT computer displays. These CRTs have a small-(19-inch) display and were designed to be used by the Supervising Operator (SO). These CRT displays cannot be read by the Unit Supervisor (US) because of the size and positioning of the CRTs. This is a problem particularly during "off-normal" conditions because the US does not have direct access to critical information. The US must obtain this information verbally from the SO, which is not desirable. 4.4.6.2 Action Plan Summary As part of the Control Room upgrade project, which is being implemented by Design Change Package (DCP) 90-140, operator and supervisor workstations, as well as related components, will be upgraded to facilitate operations in the Control Room and the range of tasks performed by Control Room personnel. In addition, computer-generated system displays will be installed above the P681 panel horseshoe area, and the Simulator will be upgraded to maintain configuration control. O 4.4.7 view-Aeceierated cerresien Preuram 4.4.7.1 Issue Perry's Flow-Accelerated Corrosion (FAC) Program was developed in the early 1980s using engineering judgment as the basis for the program. Since that time, the nuclear industry, through EPRI, has made major improvements in the development of engineering models which can estimate the FAC process through the use of the "CHEC" family of software programs. Based on industry experience and a review of Perry's FAC program (performed by an EPRI assist visit) the program was determined to need revision to make it consistent with current industry experience. 4.4.7.2 Action Plan Summary This is a program which will focus concurrently on short-and long-term nhancements of the Perry FAC program to ensure the continued safe operation of the Perry Nuclear Power Plant. The following program t.ctions will be implemented.

The program will be revised to update inspection requirements that are based on industry and Perry-specific experience prior to RFO-4.

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i i PCA - Rev. 0 Modeling of the Perry Plant's system will be performed using the engineering modeling techniques developed by EPRI in the "CIIEC" family of programs. Based on the results, inspection requirements for RFO-5 will be updated. Plant procedures will be revised to incorporate the recommendations of the EPRI NSAC 2004, " Recommendations for an Effective Flow-accelerated. Corrosion Program." i Additionally, software / hardware will be upgraded to remain current with industry enhancements (e.g., use of CHECWORKS software in 1994-1995). Completion of these items will take place before the third quarter of 1995. 4.4.8 Post-maintenance Testing Manual 4.4.8.1 Issues There is no single compilation of requirements for retest following work on equipment or components. The implementation of the Postmaintenance Retest Manual will provide a consistent retest of equipment and components. 4.4.8.2 Action Plan Summary [ A review will be conducted of industry standards, including EPRI NP 7213 " Post-O m einteneece Testies" eed 1N e o eed errerm ers en Pest-m eintenance teetins. s P .A Post-maintenance Test Manual will be developed. Retest requirements from all other PAPS will be eliminated. a Affected site personnel affected will be trained in the use of the Post-maintenance Test Manual. A third-party review of the new program will be performed after implementation. The program will be revised as necessary. 4.4.9 ILRT/LLRT Program 1 4.4.9.1 Issues The Integrated Leak Rate Test / Local Leak Rate Test (ILRT/LLRT) needs to be upgraded. Instrumentation used during the most recent ILRT surveillance did not perform consistently. l LOl 53 n e. .-..n

~ PCA - Rev. O O - kJ 4.4.9.2 Action Plan Summary 1 A third-party review of the ILRT/LLRT program will be performed. The ILRT procedure will be revised as required. Identified procedure and equipment changes will be incorporated into the program to resolve ILRT/LLRT program issues. 4.4.10 Suppression Pool Strainers -i 4.4.10.1 Issues The suppression pool strainers have been found fouled and damaged in previous inspections since the first refueling outage at Perry. Short-term actions have been taken to minimize the " fouling" of these strainers. 4.4.10.2 Action Plan Summary Actions being performed to address this problem include improving housekeeping / cleanliness standards and inspecting the containment and drywell pools. Pump strainer monitoring and (p material accountability and control has been implemented, and personnel training regarding this / problem and its importance to the Perry Plant's safe operation have been completed. Design alternatives are being evaluated to identify other changes, such as insulatior uplacement, that may be necessary to reduce the potential for fouling. 4.4.11 Safety Relief Valve Seat Leakage 4.4.11.1 Issues Safety relief valve (SRV) leakage has been a problem at the Perry Plant. As a result, the suppression pool cooling mode of the residual heat removal (RilR) system is being used more than is desirable, since this operation increases service time on the RHR pumps and other system equipment. 4.4.11.2 Action Plan Summary An SRV leakage reduction task force will review the industry experience with this problem, as well as the Perry Plant experience to ascertain the changes needed to improve plant performance. The possibility of creating an owners group to support the industry-wide problem will be reviewed. Evaluation of the SRV seat design and the addition ofinsulation will aid in the overall determination of the root cause of the SRV leakage. Additional monitoring of the success of the SRV seat refurbishment plan will also provide understanding of the root cause. 54 w

PCA - Rev. 0 .r 4.4.12 Main Steam Isolation Valves 4.4.12.1 - Issue The Perry Plant has had continuing problems with main steam isolation valves (MSIVs). Leak rate failures for these 26" Atwood Morrill valves have been above industry norms. An MSIV task force was set up by System Engineering to review industry experience regarding effective methods for resolving this problem through either design changes or changes in system operation to minimize the repair of these high-maintenance valves. 4.4.12.2 Action Plan Summary A two-phase process which focuses on the completion of design modifications and the review of test data over the next two refueling outages is being implemented to determine the effectiveness of the design changes. These modifications include implementing the slope change on the leakage control lines and the nose cone modifications on the "C" MSIV line. These tasks will be completed by the end of RFO-4. 4.4.13 Reactor Vessel Level Instrument Modification i 4.4.13.1 Issues The NRC notified the holders of BWR operating licenses (NRC Bulletin 93-03, Generic Letter 92-04, and Information Notice 93-27) of the effects of noncondensable gas build-up in the reference legs associated with reactor vessel level instrumentation. 4.4.13.2 Action Plan Summary Some BWRs have experienced dissolution of noncondensable gases in the refermee leg of the instrumentation. This could possibly result in a false high-level indication after a repressurization event. The planned modification (DCP 93-075) will overcome this problem by i njecting a small, continuous flow of water from the Control Rod Drive (CRD) System into the i#erence leg of each of the four reactor vessel level channels. This involves tapping into the CRD system, metering the flow through four flow control stations, and directing the cool CRD water to each reference leg. The expected results of the Reactor Vessel Level Instrument modification are that the small flow from the CRD rystem will act to continuously sweep noncondensible gas-laden water from the reference legs, thereby maintaining the indicated reactor vessel level throughout such depressurization events.

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PCA - Rev. 0 4.4.14 Temporary Scaffolding 4.4.14.1 Issues Scaffolding is currently being used throughout the plant to aid in the performance' of work. Depending on how often specific jobs are repeated, scaffolding may be installed and removed I each outage or remain to support various repetitive tasks. Installation of temporary scaffolding requires a large labor expenditure, and in the RRA, potentially results in increased radiation exposure. 4.4.14.2 Action Plan Summary A review of scaffolding use in the plant will be performed. There is a potential for savings in both manpower and radiation dose if the current use is evaluated to determine which scaffolding should be replaced with permanent platforms and v. hat equipment changes could be made to climinate the need for scafTolding. Use of permanent platforms instead of scafTolding will also improve general housekeeping in the plant. 4.4.15 Engineered Spare Parts List 4.4.15.1 Issue .O Information related to the Perry Approved Applications List (AAL) is inadequate (e.g., safety designation at a component parts level, stock code assignment at a component level). 4.4.15.2 Action Plan Summary An Engineered Spare Parts List that specifies spare parts for safety-related components will be developed and maintained. This effort will include an engineering review of spare parts needs, 4 applicability, and specification. This effort is scheduled for initiation by January 1994. 4.4.16 Auxiliary Iloiler Contamination 4.4.16.1 Issue Contamination of the boiler is caused by plant in-leakage. Identification and correction of in-leakage sources will eliminate boiler contamination. 4.4.16.2 Action Plan Summary Potential in-leakage sources will be identified using resistance temperature detectors and thermography to monitor equipment supply lines and ta ' for an indication ofin-leakage. 56

{ PCA - Rev. O A '\\

Identified in-leakage sources will be corrected by repairing existing isolation valves or installing additional isolation valves.

4.4.17 IIangers (Spring Cans) 4.4.17.1 Issues Preset bars and hydro-stops are used for specific purposes on a hanger spring can during piping system operation and plant shutdom1. If these items are not used as designed, a potential exists for the piping system to become overstressed. There have been several documented instances in which preset bars and/or hydro-stops'were found incorrectly installed in piping system hanger spring cans during system operation. Also, there have been two specifically documented occurrences in which preset bars have fallen from the overhead spring cans to the floor. One of these occurrences was documented as a near miss industrial safety incident. 4.4.17.2 Action Plan Summary

Walkdowns of hangers will be completed to identify any potentially hazardous industrial safety conditions from preset bars and/or hydrostops and to generate a list of affected spring 1

cans. In addition, spring cans found during the walkdowns will be evaluated for incorrectly installed preset bars and/or hydro-stops and Condition Reports will be written. The need for using preset bars and hydro-stops will be evaluated to reduce or eliminate their use throughout the plant wherever possible. To the extent that preset bars and hydro-stops are required, procedures will be reviewed and design modifications will be investigated to minimize the potential industrial safety problem. 4.4.18 Materials llandling 4.4.18.1 Issue An excessive quantity of materials and parts are staged or issued, resulting in a large return rate to the warehouse. 4.4.18.2 Action Plan Summary A process will be developed and implemented to allocate stock on the computer against individual work orders and to retain the stock until it is actually needed in the field. !] 57

PCA - Rev. 0 Contingency materials and parts will not be prestaged. . A performance measure will be developed to track returns of worked and unworked equipment. 4.4.19 Inventory Review 4.4.19.1 Issue The Project's 01 Warehouse inventory value is excessive. Current procedures, practices, and computer programs have failed to provide an enviromnent in which a means of maintaining an optimum inventory level can evolve. 4.4.19.2 Action Plan Summary To address the issues listed above, the following actions will be initiated. . An economic order quantity process will be developed and implemented for stock-coded items. This order will be based on historical usage and other criteria specific to the stock-coded item (e.g. lead time). O in trectiees eed receeeree wiii 8e reviewed. endeted. eed revieed te eccereteir reriect the P materials management processes. . A computerized, "paperless" materials management data processing system, including use of bar-coding technology, will be developed and implemented.

Performance indicators and goals will be developed and maintained to reflect performance.

4.4.20 Solenoid-Operated Valve Testing and Design 4.4.20.1 Issue Tl e NRC notified the holders of BWR operating licenses (NUREG-1275 Volume 6, and Generic Letter 91-15) regarding solenoid-operned valve (SOV) problems in U.S. Reactors. NUREG-1275 Volume 6, " Operating Experience Feedback Report - Solenoid-Operated Valve Problems," describes deficiencies in design and application, manufacture, maintenance, and surveillance' testing. Several events are described in these reports regarding SOV failures which have affected redundant safety components, multiple trains of safety systems, or multiple safety system's. i i 58 l

PCA - Rev. O ~ 4.4.20.2 Action Plan Summary A Performance Improvement Team (PIT) was formed to evaluate Perry Plant and industry concerns relative to SOVs. The PIT was chartered to increase the reliability of the SOV applications at the Perry Plant by reviewing the design and performance history relative to current industry developments. Results of the evaluation were issued in a fmal SOV report which included a list of recommended actions for improving the reliability of the valves. A total of about 150 valves are potentially affected. A management review of the PIT report will be completed by June 1994. Based on the results of this review, an action plan will be developed. 4.4.21 Air-Operated Valve Program 4.4.21.1 Issues The nuclear industry has experienced a wide range of design and maintenance problems with air-operated valves (AOV). Some of these may require special testing for evaluation. The utility-sponsored Air-Operated Valve User's Group has taken a proactive approach by establishing various woding groups to investigate and inform other nuclear utilities of AOV issues, including the need to establish an AOV testing program. ,3 C/ 4.4.21.2 Action Plan Summary A review of the AOV program at Davis-Besse, a plant which is currently an industry leader, will be performed to assist Perry in developing its own AOV program. A review of past experience with air-operated valves at Perry, as well as other industry experience, will be performed to determine whether an AOV program needs to be established at Perry to ensure reliable AOV operation. This action will be completed by December 30,1995. 4.4.22 Hydrogen Analyzers 4.4.22.1 1ssues The performance and reliability of the Coinbustible Gas Control Hydrogen Analyzer system has been deficient during the operational history of the Perry Plant. Hydrogen recorder indication associated with this system is designated as a Type A Category 1 variable by Reg. Guide 1.97, Post-Accident Monitoring." Consequently, Plant Emergency Instructions specify that operators utilize information from this system to take appropriate safety actions based on specific hydrogen concentration readings. Repair activities to keep the hydrogen analyzers operational have been 7-Q too frequent, and a concern exists about the reliability of these monitors. 59

PCA - Rev. O p V . 4.4.22.2 Action Plan Summary A major upgrade of the existing analyzer design will be performed to improve the reliability of the monitors. The overall goal of this modification is to significantly improve the performance of the hydrogen analyzers. The design change will minimize condensation and improve measurement accuracy. 4.4.23 Integrated Scheduling 4.4.23.1 Issues l 1 + There is no integrated schedule to track plant modifications from inception to closecut to ensure completion.

The priority system for plant modifications is not consistent with the priority system for H

work orders. The current definition of projects includes only design changes; non-generating facilities changes, engineering studies, and other large projects are not included. Therefore, not all projects are scheduled and tracked. l O + actiee item ere curreetir trecked under a meititede of srstems. 4.4.23.2 Action Plan Summary 1 The Engineering schedule has been modified to track a plant modification from inception j to closure. The plant modification installation is scheduled to _the appropriate outage l window or Functional Equipment Grouping in the on-line schedule. 1 The current Engineering Priority System is being revamped to reflect plant needs and make it part of a single plant priority system. In conjunction with the priority system, standard lead times and milestones are being defined to establish on-line design change scope. A set of criteria is being developed to expand the definition of a project. f Current action item tracking systems are being modified to provide a centralized system for a } tracking active items to completion. ( - O 60

PCA - Rev. O nV ATTACHMENT A PLANT EMERGENCY INSTRUCTION TEAM CHARTER

Purpose:

To ensure that the Plant Emergency Instruction (PEI) program will develop and maintain high quality PEls. Charter: Enhance the PEI program to ensure that the fundamental components of PEI development - detailed technical basis documents and procedure writer's guides, verification and validation plans, training, and PEI maintenance and revision-are well defined, documented, and properly used to establish quality PEls. Process:

1. Enhance the PEI flowchart and Special Plant instruction (SPI) writer's guides to ensure that they provide clear guidance and criteria and are sufficiently restrictive to prevent inconsistencies in the flowcharts and PEls.

2. Enhance the Verification and Validation Plans to provide sufficient detail to ensure that verification and validation (V&V) of the PEls will provide a technically correct, user-friendly, correctly written, quality document.

3. Ensure that all weaknesses identified in the PEI program by both the NRC and ourselves are addressed and resolved.

4. Ensure that human factors weaknesses identified in the SPIs, writer's guides, and verification and validation program are addressed and resolved.

5. Ensure that the PEI maintenance and revision process will maintain its quality over time through the establishment of:

a formal policy to determine when V&V is required on a revised instruction; a formal notification system to the Operations and Training Sections that helps ensure appropriate feedback on revisions; a mechanism to solicit, encourage, and utilize comments as a result of PEI use; a mechanism to ensure timely disposition of errors in the PEls and to ensure + consistency with technical guidelines and the writer's guides; a program to ensure management of the PEI technical documentation; and a program to ensure continued review of the PEls and applicable incorporation of plant design changes into the PEls and basis documents.

6. Enhance the PEI flowcharts and SPIs to satisfy the criteria of the upgraded writer's guides, and perform V&V of these enhanced PEls.

A-1

l PCA - Rev. 0 0 INDEPENDENT ASSESSMENT POLICY STATEMENT It is the Perry Nuclear Power Plant's policy to fully utilize independent assessments as part of our continuing efforts to achieve the highest level of performance. Improvement begins with self-assessment. Self-assessment is the continuing critical evaluation of one's own performance. Self-assessment cannot be perfonned by anyone else and is an important complement to independent assessments. Independent assessments performed by Quality Assurance, Quality Control, Independent Safety Engineering, the Nuclear Regulatory Commission, the Institute for Nuclear Power Operations, and others are valuable tools that can be used to ensure that our performance reflects the highest level of quality. g I expect Peny Nuclear Power Plant personnel to welcome and encourage k 7 independent assessments as part of our continuing efforts to improve our performance. While assessments are being planned or performed, we will cooperate to the maximum extent possible. We will not be defensive or argumentative when discussing the observations, inquiries, or results of an assessment. We will carefully consider all of the recommendations presented. Any attempt to discourage or inhibit the discussion of quality concerns is intimidation and is not acceptable. By implementing this policy, we will fully realize the contributions independent assessment can make towards our mission of safe, efficient, and reliable power generation. k' A/. Donal C. Shelton Senior Vice-President, Nuclear O B-1

PCA - Rev; 0 o CENTERIOR ENERGY ROM A k"9 620o ook Tree Boulevara us Adoress i Chairman and - Independence oH PO Box 94661 Chief bacutrve Officer 716 447 3100 Clevelona. oH 441014661 a-t NUCLEAR QUALITY ASSURANCE PROGRAM POLICY It is the policy of Centerior Energy Corporation and its subsidiaries to provide' an adequate and reliable source of electric power on demand to customers within its service territory. Implementation of this policy at the Perry Nuclear Power Plant requires plant management to assure the highest feasible degree of functional-integrity and reliability of those systems, equipment, and structures that are essential to the prevention of nuclear incidents and could adversely affect the health and safety of the public and company employees or the mitigation of the consequences of such incidents in the unlikely event they should occur. i This policy shall be incorporated into the development and implementation of a Perry Nuclear Quality Assurance Program which fully complies with the re-quirements of the Code of Federal Regulations - Title 10 Part 50, Appendix B; applicable NRC Regulatory Guides, ANSI Standards and ASME Boiler and Pressure j Vessel Code sections. The Perry Nuclear Quality Assurance Program shaU be. established as one means to achieve the objectives of this policy..This Nuclear 1 Quality Assurance Program shall-define specific individual and_ organizational responsibility and authority. Further, it shall prescribe procedures for compliance with regulatory requirements and establish appropriate guidelines for implementation of these proce6ures. It is the policy of executive management that the responsibility for the imple-mentation.of the Nuclear Quality Assurance Program is interdisciplinary and not the sole responsibility of any one organization or group. It shall be the'res-ponsibility of each company and contractor employee working under.the scope.of this Nuclear Quality Assurance Program to reflect the attitude of executive 1 management on quality assurance and to implement the contents of this Nuclear Quality Assurance Program rigorously in the execution of their duties. The Vice President - Nuclear - Perry is assigned the responsibility for assur;ing. that the Nuclear Quality Assurance Program is established and impicmented. Periodically, he shall review the overall effectiveness of the Nuclear Quality Assurance Program and assure that I am kept informed of the program's overall effectiveness. \\ P

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PCA - Rev. 0 NUCLEAR QUALITY ASSURANCE PROGRAM POLICY (Continued) The Director - Nuclear Assurance, reporting to the Vice President - Nuclear - Perry, is responsible for development, including revision and updating, of the Quality Assurance Plan. The Director - Nuclear Assurance is responsible for assuring the adequacy and the effectiveness of implementation of the approved Nuclear Quality Assurance Program. The Director - Nuclear Quality Assurance has the responsibility and authority for the interpretation of the Quality Assurance Plan requirements and of codes, standards and regulatory conenitments as they pertain to quality assur-ance requirements, and to stop nonconforming activities and the processing of nonconforming materials. The Director - Nuclear Assurance has the authority and organizational freedom necessary to adequately fulfill assigned responsibili-ties. The Director - Nuclear Assurance is authorized direct access to the Chairman, President and Chief Executive Officer, keeping the Vice President - Nuclear - Perry informed, if the need for such access should arise. Any employee who believes that the Nuclear Quality Assurance Program is not be-ing followed, has the right, and indeed the obligation, to so inform his or her management of such deviations, including the right of direct appeal to the Chairman, President and Chief Executive Officer. Robert J. Farling C-2 ) - ------}}

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