ML20151D053

Rev 1 to Section I, Corporate Action, of Plan for Restart of Peach Bottom Atomic Power Station

ML20151D053
Person / Time
Site:	Peach Bottom
Issue date:	04/08/1988
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20151D042	List: ML20151D040 ML20151D053 ML20151G460
References
PROC-880408, NUDOCS 8804130366
Download: ML20151D053 (128)

Text

PHILADELPHIA ELECTRIC COMPANY 4

PLAN FOR RESTART OF ,

PEACH BOTTOM ATOMIC POWER STATION SECTION I CORPORATE ACTION

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PHILADELPHIA ELECTRIC COMPANY PLAN FOR RESTART OF PEACH BOTTOM ATOMIC POWER STATION SECTION It CORPORATE ACTION REVISION 1 April 8, 1988 I

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PREFACE.

The Plan for Restart of Peach Botton Atonic Power Station, Sections I and II, i describes the management changes and actions which have been or are being 1 implemented to address the root causes of declining station performance. l The preeminent themes discussed in Section II--plant leadership and station l culture--cannot be addressed in isolation fro, the corporate enviror ment. Changes l in a company's culture must start at the very top, i Culture embodies basic values and beliefs, and how those values and beliefs are l translated into the operations of a company. Philadelphia Electric's top management i has clearly defined those values and will whole-heartedly support, by word and I action, the changes needed in Company culture. l Therefore, it is important to describe in this preface the cultural environment we l want to establish for all of Philadelphia Electric Company, including our nuclear j generating stations. [

PE's central business mission is to provide quality services to its customers on a I reliable basis at fair prices while earning a fair return for its stockholders. l To accomplish this mission, Philadelphia Electric Company, with its significant I investment in nuclear power, is totally comnitted to the safe and reliable operation 1 of Peach Bottom an<' Linerick. This simple statement of commitment has taken on new l meaning as we deepen our understanding of today's nuclear requirements and l re-dedicate ourselves to nuclear excellence. l 1

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The foundation for excellence of our operations is a work force that believes that l excellence is the minimum acceptable level of performance. This means that I nanagement must provide the leadership to develop the vision of excellence that will l guide everi work activity, and establish the work climate that will enable employees i to enact that vision in their daily job performance. It means that management must i provide the organizational structure, staff resources, training and f acilities to l support excellence of works recognize and reward excellence; and make it clear, l

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through decisive a,ctions, that it will not tolerate substandard performance. It I means that all employees understand and accept high work performance stanc'ards; I participate actively in performance monitoring; and make it clear, through timely I conmunications, when conditions exist which do not support excellence of work. l While individual performance accountabilities must be clearly defined and upheld, I excellence is equally dependent on team performance. Team performance requires I trust and open communications at all levels so that there is clear understanding l of what must be done, why, by when, by whom, and with what approval authority. Team 1 performance means that we all recognize that each work group has a vital role to l I play as a service provider to other work groups so that the Company can provide j timely, reliable and quality service to its customers. I If each employce understands and believes in the Company's vision.of excellence and l commits to supporting the vision through indiv'idual performance, and i'f each j employee recognizes that success depends on team performance, two of the basic l ingredients for the Company culture will exist. A third element of that culture  !

is pride in one's work--not arrogance, but pride. Pride is infectious and (reates 1 its own momentum toward excellence. Clearly all of us want to succeed end feel proud l

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Demonstration of these beliefs must be especially clear at Peach Bottom. 1 Corporately, we support their efforts to the maximum extent, because success at l Peach Bottom mea.is success for all of us. l We know that on the day that Peach Bottom goes back on line, it m7y not yet be among l the best operating nuclear plants in the country. Culture is not changed overnight, I nor are efforte toward bringing about cultural change immediately effective in I achieving the desired results. But, if a cultural change is sincerely motivated, I constantly supported and consistently implemented, it will be successful in steadily l improving the operational performance at Peach Bottom. Improved performance l instills pride, and a prideful work force refuses to accept anything less than the l best. l l

In summary, these are some of the key elements cf the corporate culture that we I l <

intend for Philadelphia Electric Company. These intentions are supported by I corporate and Peach Bottom 1.adership. l To support our cultural change efforts, we have adopted a set of guiding principles 1.

for Nuclear Operations to which the entire Company, from the Chief Executive Officer I to the individual employee, must be dedicated l

• Assuring the safety, quality and reliability of nuclear operations, in I accordance with the highest standards of excellence, to fulfill and exceed I government and industry requirements. l 5

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• Assuring timely training of all Noelear managers, supervisors, cechnical and I crafts personnel to the highest ;ndustes standards; achioving and e.ointaining l INPO accreditation in all relevant training arzah. l

• Maintaining candid, open communications with the IMO, INPD, other indu:s ry l groups, regulatory agencies and other utilities, tn pr ano te vndorstanding and 1 effective utilization of regulatory and industry 7xperience by PE. l A

• Maintaining candid, open communications between all nuclour line and support i organizations, between all levels of nuclear management, and bcdween nucleer l management and enployees, to promote efficient opera + ions timely problem l identification, and effective problem resolution. I l

• Promoting cultural change by fostering nanagement ,nd work bthaviors which I support an orientation to nuclear excellencq, and rcutinsiv monitoring progress l toward those objectives. J

• Assuring that the nuclear organizational structure, manasenent systens and I staffing levels are adequate to provide the .mecessary euthorities and resources l to those managers who are held accountable for the excellence of each aspect i of the nuclear progran. l

• Assuring that the programs and informotion nanagement systems are in place to l assist line n.anagement with tinely and effective self-assessn:ent of the quality 1 of operations. l 4

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• Assuring that the independent assessment process supports line management and l is structured and staffed to provide broad coverage of nuclear operations at I different levels of Company nanagement up to and including the Board of l Directors. l philadelphia Electric's management is totally committed to these principles and will 1 do everything within its power to support their implementation as we proceed with I w

our plan for the restart of Peach Bottom. l E

Corbin A. McNeill, JCNk Executive Vice President-Nuclear

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[sepM'F. Paquette, r. [

President and Chie / Operating Officer

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Section I CORPORATE ACTION EXECUTIVE

SUMMARY

On March 31, 1987, the Nuclear Regulatory Commission (NRC) ordered Philadelphia Electric Company (PE) to shut down the Peach Bottom Atomic Power Station (PBAPS) at Delta, Pennsylvania. The Shutdown Order stated that neither unit at PBAPS could be restarted until PE submitted a detailed, comprehensive plan and schedule to assure the NRC that Peach Bottom would be operated safely and in compliance with all requirements.

PE has identified four root causes of declining performance at PBAPS:

1) There was a lack of adequate personal leadership and manaaement skills on the part of senior manaaement at the plant.

2) The Company failed to initiate timelv licensed operator replacement trainina proarams.

3) The station culture, which had its roots in fossil and pre-TMI operations, had not adapted to chanoina nuclear requirements.

4) Corporate manaaement failed to recoanize the developino severity of the problems at PBAPS and thus, did not take suf ficient corrective actions.

This document contains the Corporate Action Section of PE's Plan for Restart of PBAPS and addresses the fourth root cause. Section II contains the Site Action i Section of the Plan and addresses the first three root causes. These two documents l are collectively submitted as PE's response to the NRC's requirement of a l comprehensive corrective action plan and schedule prior to restart of PBAPS.

Three corrective action objectives have been established for the Corporate Action Section of the Plan for Restart of PBAPS:

1) Change the organizational structure to increase control, necountability and corporate direction for nuclear operations.

EXECUTIVE

SUMMARY

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Section I CORPORATE ACTION

2) Develop the management systems and managerial skills which will strengthen self-assessment and problem resolution capabilities within the Nuclear organization.

3) Strengthen the independent assessment process to increase upper management's involvement in timely problem solving.

Oroanizational and Procram Improvements To increase control, accountability and corporate direction for nuclear operations, PE has brought in proven leaders to fill the top corporate executive positions and i established, within the corporate structure, a nuclear-dedicated organization with direct line management authority and control over all aspects of nuclear operations, engineering, maintenance and construction. M The new Nuclear organization reporting structure and management responsibilities are described in Section 2.0 of this document. By implementing the new Nuclear organization PE willi provide fully dedicated organizational resources to meet nuclear needs in a timely manners ensure timely corporate level management attention and decision making for station concerns A increase the level of corporate technical direction and oversight of plant programs; and establish clear management accountabilities and authorities for each aspect of the Company's nuclear operations.

Significant changes are being made to develop the management systems and managerial skills for improved self-assessment and problem resolution within the Nuclear organization. The strong management philosophy for assurance of quality which will guide Nuclear management in the execution of their responsibilities is described in Section 3.1. A new Nuclear Performance Management Program (Section 3.2) will be used as a key management tool to establish and track performance relative to EXECUTIVE

SUMMARY

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Section I: CORPORATE ACTION coals established at each organizational level. This will provide timely recognition of performance variances and potential problem areas.

The Nuclear QA organization (Section 3.3) will be strengthened by elevating the reporting relationship to the Executive Vice President level and integrating l previously separate quality assurance and control organizations into one centralized QA organization and program. The scope of Nuclear QA audits is being expanded to include comprehensive technical and performance based audits in addition to classical quality assurance audits of adequacy and ef fectiveness.

A Perfornance Assessment Section will be added to Nuclear QA with responsibility for assessing organizational performance and providing independent evaluation of I

the effectiveness of the Company's nuclear program. The Independent Safety Engineering Group (ISEG) at each site will also report to Nuclear QA. The renoval of peripheral duties from this function will permit an enhanced focus on improving the safety of plant activities.

Improvements to +he Operating Experience Assessment Progran (CEAP) are being developed (Section 3.4). The OEAP nanager will have corporate accountability for coordination and oversight of OEAP activities and will prepare monthly status reports on OEAP corrective action status for review by senior Nuclear management.

A strengthened Nuclear Connitnent Tracking Prograns (Section 3.5) will ensure l integrated commitnent tracking for the Nuclear organization and affective, timely nanagement of corrective action programs.

EXECUTIVE

SUMMARY

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Section I CORPORATE ACTION Nuclear information nanagement and reporting systems are being inproved (Section 3.6) and the Nuclear Monthly Perfernance Indicators Report will be upgreded to assist nanagement with perf ormance monitoring and early problem identification.

A Nuclear Training organization (Section 3.7) will be established to focus on the special training and development needs of Nuclear nanagenent and enployees, and ensure timely participation in training prograns by Nuclear personnel .

Inprovenents in Nuclear Moni torino and Problen-Solvina Processes With the changes describc J in Section 3.1-3.10 of this document, the nanagement structures and systens will be in place to provide ef f ective monitoring of the three I key areas of safety, quality, and organizational performance (i.e., how the organization nanages itself to ensure the safety and quality of operations).

Line management, with the lead responsibility for monitoring the safety and quality of all aspects of its nuclear activities, will havw the benefit of strengthened Operating Experience Assessnent and Connitment Tracking Prograns, inproved 1 information nanagenent and reporting systens, and an enhanced Nuclear nanagement training progran to help in this respect.

The centralization of GA programmatic activities, which will bring more independent perf ormance assessnent inf ornation together under one organization, will contribute to the effectiveness of independent nonitoring and assessment of all three areas of safety, quality and organizational perfornance.

EXECUTIVE

SUMMARY

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Section I: CORPORATE ACTION An Organizational and Management Development Division, staffed by professional l organization development consultants (Section 3.8) and reporting to the Executive l Vice President-Nuclear, assists with monitoring and assessing the "people l management" aspects of organizational performance. A new Management and l Professional De>elopment Section within the Organizatioral and Management l Development Division is responsible for training and development programs for l Nuclear nanagers, supervisors and professional personnel. l Increased emphasis has been placed on the importance of interactive communications j and problem solving toi 1) inprove corporate direction and oversight of plant operations; and 2) ensure timely management follow-up on independent assessment feedback. Nuclear off-site support personnel with responsibility for providing corporate direction and oversight of plant prograns will conduct periodic meetings with the relevant site personnel to review progrannatic performance in each functional area, identify and discuss potential problem areas, and develop corrective action plans. Sinilar interactions will occur to identify and address priorities for engineering support.

C The Executive Vice President will hold periodic neetings at each nuclear site to I review the status of plant activities with site management personnel, identify problen areas, and establish priorities and lead responsibilities for any required corrective actions.

Interactive connunication processes will be used regularly to obtain and discuss feedback from independent assessnent groups within the Nuclear organization. The General Manager-Nuclear QA will report on performance trends on a regular basis at EXECUTIVE

SUMMARY

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Section I: CORPORATE ACTION senior Nuclear management meetings, and time will be dedicated to discussing the implications of these trends. M Upper Manaaenent Involvement in Monitorina and Problen Solvina The independent assessment process has been strengthened to increase upper management's involvement in tinely problem solving (Section 4.0). The Nuclear l Reviaw Board (NRB) charter will be revised to improve the review processes to better l encompass technical safety concerns. The reporting relationship of the NRB will l be elevated to the Executive Vice President-Nuclear level, with copies of reports l to the Office of the Chief Executive Officer. The NRB has been provided with l appropriate staff support and enhanced leadership and direction. l A new Nuclear Committee of the Board (NCB) has been established by the PE Board of Directors to review on a continuing basis, and report to the full board one the safety, reliability, and quality of nuclear operations; the effectiveness of the management of nuclear operations; the effectiveness of nanagement systems for the self-identification of problems and for pronet and complete corrective actions.

The NCB will use outside technic &l experts as advisors to provide specialized technical and operating experience and independent evaluation objectives.

The Committee will serve as the highest level of a structured independent assessment process which will assure PE's ability to self identify problems and implement '

tinely and of fective corrective actions. Information flows will link the Nuclear  !

QA organization to the NRB, and link ooth independent assessment groups to the NCB. I EXECUTIVE

SUMMARY

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Ssetion I CORPORATE ACTION Conclusion Significant corrective actions have been or will be taken to improve and strengthen i the Nuclear organizational structure; the management systems and programs which support perf ormance monitoring and assessment by line managements the independent assessment function within the Nuclear organizations and the Company's independent assessment and oversight process. Thnse changes will promote timely and appropriate involvement by Nuclear and Company manigement in effective problem identification, analysis and resolution. PE believes that these corporate improvements will ensure continued excellence of operations at Limerick Generating Station and, when combined with plant management changes, organizational improvements, progranmatic enhancements and attitudinal training programs (to be discussed in the Site Action Section of PE's Plan for the Restart of PBAPS), will resolve the root causes of the performance problems at PBAPS which led to the NRC Shutdown Order.

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SUMMARY

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SECTION It CORPORATE ACTION TABLE OF CONTENTS

1.0 INTRODUCTION

. . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1 CORPORATE MANAGEMENT PHILOSOPHY FOR NUCLEAR OPERATIONS . . . . . . 2 1.2 CORRECTIVE ACTIONS TO IMPROVE CORPORATE NUCLEAR MANAGEMENT , . . . 4 2.0 ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS . . . . . . . . . . . . . . . 7 2.1 NUCLEAR-DEDICATED ORGANIZATION , . . . . . . . . . . . . . 7 2.2 CHAIN OF COMMAND AND CONTROL FROM CORPORATE TO SITE , . . . . . . . 8 2.3 ORGANIZATIONAL ACCOUNTABILITIES . . . . . . . . . . . . . . . . . 10 2.4 SITE ORGANIZATIONS . . . . . . . . . . . . . . . . . . . . 17 2.5 NUCLEAR ENGINEERING ORGANIZATION . . . . . . . . . . . . . . . . . 23 2.6 NUCLEAR SERVICES ORGANIZATION . . . . . . . . . . . . . . . . . . . 27 2.7 NUCLEAR MANAGEMENT TEAM . . . . . . . . . . . . . . . . . . . . 33 2.7.1 Management Assignnents . . . . . . . . . . . . . . . . . . . 33 2.7.2 Management Strategy . . . . . . . . . . . . . . . . . . . . . 35 3.0 IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION WITHIN THE NUCLEAR OROANIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 3.1 MANAGEMENT PHILOSOPHY FOR ASSURANCE OF QUALITY . . . . . . . . . 36 3.2 NUCLEAR PERFORMANCE MANAGEMENT PROGRAM TO ACHIEVE AND MAINTAIN EXCEL-LENCE , . . . . . . . . . . . . . . . . . . . . . . . . . 37 3.3 NUCLEAR QA ORGANIZATION . . . . . . . . . . . . . . . . . . 38 3.3.1 Expansion of Nuclear QA Progrannatic Activities . . . . . . . . 40 3.4 OPERATING EXPERIENCE ASSESSMENT PROGRAM

. . . . . . . . . . . . . . 42 3.5 COMMITMENT TRACKING PROGRAM . . . .

. . . . . . . . . . . . . 43 1 3.6 INFORMATION MANAGEMENT AND REPORTING SYSTEMS .

. . . . . . . . . 45 3.7 NUCLEAR TRAINING . . . . . . . . . . . . . . . . . . . . . . . . 46 1 3.7.1 Nuclear Training 3.8

. . . . . . . . . . . . . . . . 46 l ORGANIZATION AND MANAGEMENT DEVELOPMENT , . . . . . . . . . . . . . 47 l 3.8.1 Organization Development Section . . . . . . . . . . . . . . 47 l 3.8.2 Managenent and Prof essional Development Section . . . . . . . 48 l 3.9 MONITORING OF SAFETY, QUALITY, AND ORGANIZATIONAL PERFORMANCE 3.10

. . . 50 l INTERACTIVE COMMUNICATION PROCESSES FOR PROACTIVE PROBLEM SOLVING BY l MANAGEMENT . . . . . . . . . . . . .

. . . . . . . . . . 51 4.0 COMPANY NANAGEMENT OVERSIGHT OF NUCLEAR OPERATIONS . . . . . . . . 53 4.1 NUCLEAR REVIEW BOARD (NRB) ROLE AND REPORTING RELATIONSHIPS . . 53 4.2 NRB MEMBERSHIP . . . . . . . . . . . . . . . . . . . . . . . 53 4.3 PROCESSES AND RESOURCES TO BE USED BY THE NRB FOR IMPROVED REVIEW AND ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . 54 4.4 THE NUCLEAR COMMITTEE OF THE BOARD OF DIRECTORS (NCB) . . . . . . . 55 4.5 NCB MEMBERSHIP . . . . . . . . . . . . . . . . . . . . . . . . . . 57 4.6 STAFF AND RESOURCES TO BE USED BY THE HUCLEAR COMMITTEE OF THE BOARD 58 4.7 INDEPENDENT ASSESSMENT FEEDBACK LOOP . . . . . . . . . . . . . . . 58 5.0 CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 . . . . . . . . . . . . 62 5.1 CORRECTIVE ACTIONS TO IMPLEMENT OBJECTIVE 1 . . . . . . . . . . . 63 5.2 CORRECTIVE ACTIONS TO IMPLEMENT OBJECTIVE 2 . . . . . . . . . . 65 5.3 CORRECTIVE ACTIONS TO IMPLEMENT OBJECTIVE 3 . . . . . . . . . . . . 69 Table of Contents ii

SECTION I: CORPORATE ACTION APPENDIXES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 Appendix A. FUNCTIONAL ORGANIZATION CHARTS FOR SITE PLANT, PROJECT, SUPPORT AND TRAINING ORGANIZATIONS . . . . . . . . . . . . . . . . . . . . . . 73 Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS . . . . . . . . . . . 78 Appendix C. RELATIONSHIP INDEX (partial) . . . . . . . . . . . . . . . . 98

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Table of Contents iii

SECTION It CORPORATE ACTION LIST OF ILLUSTRATIONS Figure 1. Chain of Command and Control for Operations . . . . . . . . . 9 Figure 2. Reporting Structure for the Top Level of the Nuclear Organization 11 Figure 3. Functional Organization Chart for Site Organization . . . . . 19 Fi gu re 4. Functional Organization Chart for Nuclear Engineerins . . . . 24 Figure 5. Functional Organization Chart for Nuclear Services . . . . . 28 Figure 6. Functional Organizational Chart for Nuclear QA . . . . . . 39 Figure 7. Independent Assessment Function Information Flow and Feedback Loop . . . . . . . . . . . . . . . . . . . . . . . . . . 60 Figure 8. Independent Assessment Function Infornation Flow and Feedback loop After . . . . . . . . . . . . . . . . . . . . . . . . . 61 List of Illustrations iv

, SECTION I: CORPORATE ACTION

1.0 INTRODUCTION

On March 31, 1987, the Nuclear Regulatory Connission (NRC) ordered Philadelphia Electric Conpany (PE) to shut down the Peach Botton Atomic Power Station (PBAPS) at Delta, Pennsylvania. The Shutdown Order addressed three concerns in addition to control roon operators sleeping while on duty, or being otherwise inattentive to their license obligations. These included: a complacent attitude toward

, procedural compliance; failure of the quality assurance program to identify conditions adverse to safety; and inef fective managenent, as evidenced by a lack of tinely managenen t action to correct these problens, poor dissenination of nanagement goals and policies, poor connunications between different departments and divisions, and a focus on compliance rather than acknowledgement and correction of the root causes of problems.

The Shutdown Order stated that neither unit at PBAPS could be restarted until PE submitted a detailed, comprehensive plan and schedule to assure the NRC that Peach Botton would be operated safely and in compliance with all requirements, including station procedures.

Since the Shutdown Order PE has engaged in extensive investigative and review activities, using both internal and external resources, to deternine the root causes of the problems which led to the NRC Shutdown Order.M

• The relationships between issues raised by the NRC in the shutdown order, the root causes identified by PE, the corrective action objectives and related najor activities are presented in a Relationship Index in Appendix C.

INTRODUCTION 1 l

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SECTION It CORPORATE ACTION Based on the results of these analyses, the Company has identified four r,ot causes of declining performance at PBAPS

1) There was a la ck o f a da_qv- t e persona l leadership and ranaaenent skills on the part of senior .enent at the plant.

2) The Company failed to initiate timelv licensed operator replacement trainina procrans.

3) The station culture, which had its roots in fop _gil and pre-TMI operationst had not adapted to chanoina nuclear requirements.

4) Corporate manaaenent failed to eccanize the developina severity of the problems at PBAPS and thus, did not take sufficient corrective actions.

This docunent reflects a broadened consideration of the fourth root cause, based on responses to PE's earlier Connitnent to Excellence Action Plan submittal.

It describes the corporate section of the Plan which PE has developed to implement a conpany wide program for improved management of nuclear operations.

A second document contains a plan focused on site specific corrective actions I for the restart of PBAPS, and addresses the first three root causes. These two l documents will collectively be PE's response to the NRC's requirement of a comprehensive plan and schedule for a corrective action program prior to restart of PBAPS.

1.1 CORPORATE MANAGEMENT PHILOSOPHY FOR NUCLEAR OPERATIONS After thorcugh review of its nucleer program, PE has conmitted to a corporate management philosophy for achieving and maintaining excellence in the managenent of its nuclear operations. This connitment requires that every level of nanagement from the Chief Executive Officer to the first line nuclear supervisor be dedicated to the following principles l INTRODUCTION 2

I SECTION It CORPORATE ACTION

• Assuring the safety, quality and reliability of nuclear operations, in accordance with the highest standards of excellence, to fulfill and exceed government and industry requirements.

• Assuring timely training of all Nuclear managers, supervisors, technical and craf ts personnel to the highest industry standards; achieving and maintaining INPO accreditation in all relevant training areas.

• Maintaining candid, open communications with the NRC, INPO, other industry groups, regulatory agencies and other utilities to promote understanding and effective utilization of regulatory and industry experience by PE.

• Maintaining candid, open communications between all nuclear line and support organizations, between all levels of nuclear nanagement, and between nuclear management and employees to promote ef ficient operations, timely problem identification, and effective problem resolution.

• Promoting cultural change by fostering management and work behaviors which support an orientation to nuclear excellence and routinely monitoring progress toward meeting those objectives.

Assuring that the nuclear organizational structure, management systems and sta f fing levels are adequate to provide the necessary authorities and resources to those managers who are held accountable for the excellence of each aspect of the nuclear program.

Assuring that the programs and information management systems are in place to assist line management with timely and effective self-assessment of the quality of operations.

Assuring that the independent assessment process is r cructured and staf fed to provide appropriate coverage of nuclear operatice.s at different levels I of Company management up to and including the Board of Directors.

PE senior management will provide the leadership and direction to ensure that Nuclear management and personnel support nuclear excellence through adherence to these principles.

In addition to addressing the fourth root cause, the Corporate Action Section of the Plan for Restart of PBAPS incorporates these principles in the activities required to accomplish the Plan objectives.

INTRODUCTION 3 l

SECTION I CORPORATE ACTION 1.2 CORRECTIVE ACTIONS TO IMPROVE CORPORATE NUCLEAR MANAGEMENT In determining how to address the fourth root cause and promote excellence in its corporate nanagement of nuclear operations, PE used two underlying concepts.

The first concept is that organization structure, management systens, and managerial ability are interdependent elements. Each inpacts upon the varying degrees of effectiveness of the others. These three elements affect the Company's ability to self identify problems in its Nuclear operations, analyze and address these problems in a timely manner, and monitor corrective action results.

The second concept is that there are three interdependent aspects of PE's self-assessment activities which need to be strengthened for improved problem identification and resolution. These include:

1) The programs used within the nuclear line orcanization to establish perfornance standards, nonitor and assess performance against those standards, and take prompt corrective action as required; 2 .' The programs used by independent assessment aroups to monitor nuclear activities and provide feedback to the line organization at different levels;

3) The interactive processes used between line nanacement and independent assessnent arouns to ensure timely consideration of assessment data and performance trends; identification of problem priorities for nanagement attention and evaluation; and development and follow up on corrective action plans by management to achieve the desired results.

These two concepts (i.e., the interdependency of organization structure, nanagenent systens and managerial ability, and the interdependency of dif ferent aspects of the nonitoring/ assessment function for improved self-assessment and problen resolution) formed the foundation on which the objectives for the Plan were developed.

INTRODUCTION 4

SECTION Il CORPORATE ACTION The Corporate Action Section of the Plan For Restart of PBAPS consists of three corrective action objectives:

1) Change the organizctional structure to increase control, accountability and corporate direction for nuclear operations. Specifically

• Establish within the corporate structure a nuclear-dedicated organization with direct line management authority and control over all aspects of nuclear operations, engineering, naintenance, construction and training.

• Shorten and strengthen the nuclear operations chain of connand.

• Provide on site corporate direction and operational responsibility at the vice president level for all station activities.

• Initiate activities to increase interfaces between corporate and site organizations to inprove corporate technical oversight of nuclear operations.

• Clarify and document nanagement authorities and accountabilities.

• Ensure that enployees assigned to site work locations on a permanent basis are accountable to the site vice president, except for those personnel responsible for independent assessnen'. and oversight activities.

2) Develop the nanagenent systems and managerial skills which will strengthen self assessment and problen resolution capabilities within the Nuclear organization. Specifically Establish a strong line management philosophy f or assurance of quality.

• Support this pnilosophy with an effective performance goals and measurements program and improved nanagenent monitoring.

• Centralire, strengthen and elevate Quality Assuranca's (QA's) role in the Nuclear organization.

• Strengthen the Operating Experience Assessment Program.

• Improve the Connitment Tracking Progran. l INTRODUCTION 5 l

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SECTION It CORPORATE ACTION

• Establish nore ef fective information managenent and perfornance reporting systens to support problen identification and corrective action follow up by nuclear management.

• Ensure that the developmont and training needs of Nuclear nanagers are identified and addressed in a tinely manner.

• Establish interactive connunication and problem solving processes between corporate office and site personnel to ensure effective corporate direction and oversight of plant programs.

• Establish interactive communication and problen solving processes between line management and independent assessment groups to jointly review independent assessment feedback and identify problens needing corrective action by management.

3) Strengthen the independent assessment process to increase upper nanagenent's involvenent in tinely problem solving. Specifically Revise the Nuclear Review Board (NRB) charter to better address l technical safety issues. l

• Elevate the reporting level of the NRB and include outside industry e expertise in its membership.

• Establish a permanent committee of the Board of Directors, with outside expertise serving in an advisory role, to provide oversight of nuclear operations. M e

Ensure timely feedback by independent assessment groups to upper nanagement so that they are involved, as appropriate, in corrective action.

While these corrective action objectives are primarily designed to resolve performance problens at PBAPS, the resulting corporate management inprovements will ensure continued excellent performance at Limerick Generating Station and prevent occurrences of future problems at both sites.

INTRODUCTION 6

D SECTION It CORPORATE ACTION 20 ORGANItaTIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 2.1 NUCLEAR-DEDICATED ORGANIZATION By establishing a new Nuclear organization within the corporate structure with responsibility for all aspects of nuclear operations, PE will eliminate the company-wide matrix structure under which it has provided engineering, naintenance and construction support for its nuclear operations. This will ensure that fully dedicated management attention and organizational resources are available to meet nuclear needs; provide additional focus on early recognition of problens; and take timely and effective corrective action as required.

This vertical integration of all nuclear functions will provide a single point of accountability for nuclear operations in the position of the Executive Vice l President-Nuclear and increase nanagement "ownership" of progrannatic interfaces within t!,e organization.

The inplementation of additional interactive connunication and problen-solving processes between Nuclear-dedicated off-site support organizations and the stations (See Section 3.9) will ensure increased corporate technical oversight and involvement in site activities.

ORGANIZATIONAL RESTRUCTURING FOR INCRtASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 7

SECTION Il CORPORATE ACTION 2.2 CHAIN OF COMMAND AND CONTROL FROM CORPORATE TO SITE Figure 1 on the following page shows the new operations chain of command structure from corporate to site. The Executive Vice President-Nuclear will I have direct line management control and corporate accountability for nuclear plant operations, engineering, maintenance, and construction. The operations chain of command will be shortened and strengthuned in two ways. First, two reporting levels of off site corporate management will be removed between the plant managers and senior nuclear management. Second, a vice president-level organization will be established at each site to provide on-site corporate direction and oversight of all station activities.

The site vice presidents will have full authority for planning, di recting, coordinating and controlling the work of all site organizations. All permanent and contract employees assigned on a regular basis to site work locations will be accountable through their reporting chains to the site vice presidents, except for those personnel involved in independent assessment and oversight activities. Expenditure authorization levels and nucl. ear personnel management policies will also be changed to support this authority.

With their close involvement in day-to-day site activities and their corporate-level decision-making authority, the site vice presidents will be able to make informed and timely corporate decisions in response to site organizational and operational concerns. They will also bring first hand knowledge of site issues which require collaborative managenent attention between site and off-site support organizations to senior Nuclear management staff meetings.

ORGANIZATIONAL RESTRUC1URING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION CF NUCLEAR OPERATIONS 8

SECTION Z: CortPORATE ACTION CHAlN OF COMMAND AND CONTROL FOR OPERATIONS Office of the Chief Executtve Officer Executive Vice President -

Nuclear I

I I I Vice President - Vice President -

Peach Bottom Limerick fes e Nuclear Plant Manager - Plant Manager . Construction Peach Bottom Manager -

Limerick Limerick Unit 2 Figure 1. Chain of Connand and Control for Operations ORGAt1I2ATI0ttAL RESTRUCTURIt4G FOR ItiCREASED C0!4 TROL, ACCOUf4TABILITY. A tI D CORPORATE DIRECTI0ti 0F t1UCLEAR OPERATI0t45 9

SECTION Il CORPORATE ACTION Until LGS Unit 2 is placed in commercial operation, its construction, testing, quality assurance, licensing and start up will be managed by project teans under the direction of the Executive Vice President-Nuclear. The Executive Vice l President-Nuclear and a construction project management team, headed by a Senior l Vice President, will be accountable for ensuring that the Project successfully I reaches fuel load, meeting established quality, schedule, and cost objectives.

The Vice President-LGS and a star t-up tean will be accountable to the Executive l Vice President-Nuclear for the Start-up Progran prior to fuel load, and for all power ascension test programs after fuel load. Af ter Unit 2 is placed in connercial operation, it will be integrated into the normal site management structure as described in Section 2.4 2.3 ORGANIZATIONAL ACCOUNTABILITIES Accountabili ti es for each aspect of the Company's nuclear program will be clearly defined. An organization chart for the top reporting level of the Nuclear organization is shown in Figure 2 on the following page.

The Executive Vice President-Nuclear will have five direct line reportsi Senior l Vice President-Nuclear, Vice President-PBAPS, Vice President-LGS, Vice President-Nuclear Engineering, c,d Vice President-Nuclear Services. In addition, ne will have three staff reports: General Manager-Nuclear QA, Manager-Organization and Management Development, and the Nuclear Review Board l (discussed in Section 4.0).

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 10

SECTION I CORPORATE ACTION REPORTING STRUCTURE FOR THE TOP LEVEL OF THE NUCLEAR ORGANIZATION I

Board of Directors PCB l

Chairman of the Board Presdent l

Nuclear Executrve Vice General Manager Revew Board President - Nucleat Quakty Nuc! ear Assurance Organizatonal and Management Deveboment i I I l l p *s e[

Nuclear f4 fe'ar Vice Presdent PBAPS Vice Presdent LGS

• I Engmeereg g Figure 2. Reporting Structure for the Top Level of the Nuclear Organization ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 11

. - . ~. .- .- -. . . _ . . - - . . - . . .. . . _ .

SECTION Il CORPORATE ACTION The key accountabilities for each member of the senior Nuclear management team I

will be as follows:

The Executive Vice President-Nuclear will be accountable to the Chairman and l I Chief Executive Officer fore i i

e Providing leadership anc unified management direction to achieve and maintain excellence in all aspects of PE's nuclear operations, in accordance  !

with the principles outlined in the corporate nuclear management philosorhy.

• Proactively managing a cultural change effort to establish an orientation to nuclear excellence within the Nuclear organization.

• Providing management oversight and control of the design, construction, maintenance, and operation of PE's nuclear power plants. This includes all planning, scheduling, engineering, construction, operational, maintenance, quality assurance, regulatory, licensing, training, personnel and other technical or organizational matters relevant to the PE Nuclear organization. I

• Establishing management, quality assurance and operating policies and procedures for governance of the PE Nuclear organization.

• Establishing the mission, objectives and goals for the Nuclear organization and ensuring that the appropriate performance measurement programs are in place to monitor organizational performance effectively.

• Determining the need for, and ensuring the appropriate requisition, technical evaluation and receipt of all materials and services required for the Nuclear organization.

• Developing and managing the approved capital and operating budget for the entire Nuclear organization.

• Ensuring coordination of activities and functions of the Nuclear i organization with those of other PE organizations.  !

• Ensuring full cooperation by PE with the Nuclear Regulatory Commission, the Institute of Nuclear Power Operations, American Nuclear Insurers and other regulatory, industry or public agencies with jurisdiction over or interest in the safe, reliable and efficient design, construction, operation and maintenance of PE's nuclear facilities. ,

1

• Maintaining open and regular communications between all Nuclear line and staft organizations, between Nuclear management and employees, and between the Nuclear organization and other Company functions.

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 12

SECTION It CORPORATE ACTION

• Reporting regularly to the Board of Directors and the Nuclear Committee of the Board.

The site Vice Presidents will be accountable to the Executive Vice l President-Nuclear for

• Ensuring that the company's nuclear units are operated safely, reliably and efficiently, and in accordance with the highest standards of excellence.

-

• Ensuring that site work activities are conducted in a manner which promotes nuclear, employee, and public safety.

• Providing site leadership for assurar.co of quality and ensuring compliance with all regulatory, quality assurance, industry and corporate standards for nuclear operations.

• Fulfilling site-related nuclear and environmental regulatory requirements and conmitments.

• Directing the planning and scheduling of all site work activities to ensure timely, high quality, and cost-effective integration of plant operations, maintenance, modification, and outage work activities.

• Coordinating major modifications with Nuclear Engineering.

• Coordinating configuration control with Nuclear Engineering.

• Ensuring that site personnel fulfill their responsibilities as specified in the Emergency Plan for both normal and emergency conditions.

• Establishing site objectives and goals to support overall Nuclear objectives for excellence, and ensuring that the appropriate performance measurement programs are in place to monitor erganizational and operational performance effectively.

• Developing the site capital budget in coordination with other Nuclear organizations and managing it effectively.

Developing and managing an approved operating budget for the site.

• Ensuring that site staffing requirements, training needs, and employee concerns are addressed in a timely and effective manner.

• Maintaining open and regular communications among all site organizations, including independent assessment groups; between site organizations and of f-site Nuclear support organizations and other Company functions; and between site management end employees.

• Maintaining an open, cooperative stance with site NRC Resident Inspectors and with other regulatory and industry auditors or representatives.

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTAB Y, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 13

SECTION Is CORPORATE ACTION

• Serving as PE's of ficial site representative in all matters related to public interface and relations.

The Vice President-Nuclear Enoineerina will be accountable to the Executive Vice l President-Nuclear for:

• Ensuring the design integrity of the nuclear plants, e Maintaining configuration control of the nuclear plants, l

e Providing high quality, timely, and cost-ef fective engineering of plant nodifications at the nuclear sites.

• Providing timely, hich quality, cost effective engineering of LGS Unit 2 until fuel load.

• Providing technical support as requested by any Nuclear organization.

• Establishing Nuclear Engineering objectives and goals to support overall Nuclear objectives for excellenue, and ensuring that the appropriate perfornance measurenent prograns are in place to monitor organizational perfornance effectively.

• Coordinating the develop.nent of the Integrated Management Program and l managing it tor the Nuclear organization.

• Developing and managing the approved operating budget for Nuclear Engineering.

• Ensuring that Nuclear Engineering staffing requirements, training needs, and employee concerns are addressed in a timely and effective manner.

• Maintaining open and regular communications among Huclear Engineering divisions, between Nuclear Engineering and other Nuclear and Company functions; and between Nuclear Engineering nanagemsnt and enployees.

The Vice President-Nuclear Services will be accountable to the Executive Vice l Presit'ent-Nuclear f or

• Identifying all licensing conditions and nonitoring to ensure that they are net, e Establishing and maintaining an effective commitment tracking program. l e Serving as the corporate focal point for regulatory and INPO interfaces with respect to receiving, analyzing, and distributing correspondence and informations following up with the relevant Nuclear organizations to ensure that appropriate and tinely actions are taken in responses coordinating preparations for all corporate audits, evaluations or assist visitsa ORGANIZATIONAL RESTRUCTURINO FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIDHS 14

SECTION It CORPORATE ACTION coordinating management responses, as required, to audits and evaluations; and preparing Technical Specification Amendments and other license-related documents for submittal.

• Ensuring that an effective Operating Experience Assessment Program is in place to analyze industry and plant operating experiences communicate the information in a timely manner to the sites, other Nuclear groups and the l NRBs and monitor the effectiveness of line management's follow-up on the information to achieve the desired results.

• Establishing corporate direction and technical performance standards for l

radiation protection, radwaste management, plant chemistry, cmergency preparedness, security and safeguards, and nuclear training programs; providing periodic programmatic assessments to ensure compliance with industry and corporate standards; identifying root causes fr/ any problem areas; and working with site management to develop effective corrective action programs.

• Ensuring that effective processes are in place to identify Nuclear organization training and development needs, scheduling and implementing appropriate programs to address these needs, and monitoring timely participation in programs by Nuclear personnel.

• Providing timely, high quality, cost effective services in the areas of specialized maintenance work, plant security, fuel management, plant chemistry analysis, emergency preparedness training, and craft training to both nuc16ar plants.

• Preparing final Nuclear capital- O&M and personnel budgets for the Executive l Vice President-Nuclear's approval, incorporating budgets submitted by PBAPS, LGC, Nuclear Engineering, Nuclear QA, Organization and Management i Devele 4ent and Nuclear Services. I 1

• all cost tracking, monitoring and reporting ior the Nuclear organization to the Executive Vice President-Nuclear.  ! ,

l

• Serving as the corporate focal point with joint owners of PBAPS. )

• Coordinating the development and application of personnel policies for the j Nuclear organization.  ;

• Establishing Nuclear Services objectives and goals to support overall Nuclear objectives for excellence, and ensuring that the appropriate perfornance neasurement programs are in place to monitor organizational performance effectively.

• Developing and managing the approved operating budget for Nuclear Serv.ces.

• Ensuring that Nuclear Services staffing requirements, training needs, and enployee concerns are addressed in a timely and effective manner.

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 15

SECTION It CORPORATE ACTION 1

• Maintaining open and regular connunications among Nuclear Services divisions, between Nuclear Services and other Nuclear and company I functions; and between Nuclear Services management and employeos.

The General Manaaer-Nuclear Qual (ig_Apsurance (CA) will be accountable to the Executive Vice President-Nuclear fori l

• Establishing and implementing a centralized organization to effectivaly implenent the Nuclear QA Program.

• Conducting independent safety reviews of plant events and planned activities.

• Conducting audits to ensure effnetive implementation of the Nuclear QA P r o g ra n .

• Providing quality control surveillance and monitoring to ensure the safety and quality of work performed.

• Identifying safety-related quality problems and ensuring that they receive prompt line and senior management attention.

• Providing input to the Orerating Experience Assessment Progran (CEAP) in a timely mannerJ naintaining independent oversight of the adsquacy and timeliness of actions taken by line management in response to OEAP items.

• Monitoring and assessing the effectiveness of the Nuclear Performance Managenent Progran for Excellence and providing independent feedback to line management and the Executive Vice President-Nuclear. l

• Conducting independent evaluations of the effectiveness of the Company's nuclear performance and pruviding feedback for line and senior Nuclear

'anagement's use.

• Providing technical support to the Nuclear Review Board, 1

• Establishing Nuclear QA objectives and guals to support overall Nuclear i objectives for excellence, and ensuring that the appropriate performance neasurements are in place to monitor organizational performance effectively. l l

• Developing and nanaging the approved operating budget for Nuclear QA. )

• Ensuring that Nuclear QA staf fing requirenents, training needs and employee )

concerns are addressed in a timely and effective manner. l l

• Maintaining open and regular connunications anong Nuclear QA sections; j between Nuclear QA and other Nuclear and Company functionsa and between Nuclear QA management and employees.

l l

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL. ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 16

-- a SECTION It CORPORATE ACT80H

• Reporting on a regular basis to the NRB wnd to tho Nuclear Committee of the l Board of Directors. -

l

!- s The Manaaer, Oraanizatior12mLtianaaenentlexe.lement s'wirf cq will be l

accountable to the Executiva Vice Prer4 dent-t;uc1' car for providing or ganization i j development assistance aimed at achieving and maintaining Nuclear or'ganizatiosi excellence by:

• Providing consulting ond"doordinating assistance to the Executive Vice l President-Nuclear and his direct reports in the areas of organizational l goal setting, organizational communications and 'organiza tion M re structuring. l

• Assisting tha Nuclear managenant team to establish and implement specific objectives for cultural chansa in terms of manessment and work behaviors, and monitorins progross tcwcrd meeting these objectives.

• Designing and facilitating organization change and transition management processes.

Designing and impicmenting Nuclear management team building activities.

• Providing direct assistar:ce, as requested,'to managers in all Nuclear line and staff organizations in conflict management problem solving, task forgs facilitation, and other hvean relations aspeht9-of management. '

Designing and implementing a comprehensive management and supervisory l training a. development program. [

M 2.4 SITE ORGANIZATIONS The mission of the site organizations is to: 1) generate' o!setricity sa fely, e

reliably and efficiently in complionce with fede.ral, state and local regula tory requirements, applicable industry technical sis.idards, quality assurance requirements, an1 company pcliciesJ 2) maintain the public trust; and 3) maintain standards of excellence in all areas of operations as exenplified by "1" ratings in SALP and INPO evaluations.

}

ORGANIZATIONAL RESTRUCTURINO F';R INCREASED CONTROL, ACCOUNTABILITY, AND CORPOP. ATE DIRECTION OF NUCLEAP. OPERATIONS 17 2

, - - - - - . - ,- u .. - - - - . , , , , , , , . , . , , _, . , , ,,-w- . . , , . , .n,+ , ~ - - .- ,_,- ,,.,nm-

SECTZON It CORPORATE ACTION A functional organization chart for the site organizations is included in Figure 3 on the following page.

As shown, the vice president for each site will have four direct line reports:

the Plant Manager, the Project Manager, the Support Manager, and the Training Superintendent. Functional organization charts for each of these organizations are attached in Appendix A.

The Plant Manaaer will be accountable to the Vice President-PBAPS/ LGS for

Operating the plant safely, reliably and efficiently in compliance with all applicable Technical Specifications, quality assurance requirements, PE procedures, and federal, state, and local requirements, and in accordance with the highest standards of nuclear excellence.

Ensuring that all operating and technical personnel are trained and/or licensed as required and that there is an adequate number of qualified operators and supervisors available for duty.

Ensuring that the Radiation Protection Program is being properly implemented with emphasis on "AL ARA."

Ensuring that the plant is being properly maintained through implementation of effective site maintenance and chemistry programs and that plant operational and maintenance activities maintain the integrity of the configuration management program.

Approval, control and application of blocking for plant and personnel safety.

Identifying and communicating the need for plant modifications or technical services and final acceptance of completed modifications.

Ensuring ef fective management of plant activities to minimize radwaste generation and assure safe and proper radwaste disposal.

Ensur'ig timely fulfillment of all regulatory commitments for which the plant organization is responsible.

Maintaining effective relations in a spirit of openness and cooperation with the NRC Resident Inspectors and other regulatory or industry visitors.

Serving as Emergency Director, implementing releve.nt requirements of the site Emergency Plan, and ensuring that the plant staff is prepared to fulfill its responsibilities under the site Emergency Plan.

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 18

SECTION I: CORPORATE ACTICN FUNCTIONAL ORG ANIZATION CHART FOR SITE ORG ANIZATION Vice Preskient -

PDAPS/ LGS l Slalf I

Engineer I

Nuclear

• --- Training Drvision Plant Project Support Trahing

- l%nt operations and - Outage Managemont - Commitment - Provide trabhg for licensed oporations support' - Integrated Planning Management Program and non licensed operators,

- Prevcative Mahlenance and Scheduhng - Site Secunty chemistry and health physics

- Electrical Mahtenance

• outages - INasonnel personne4, GET, GRT

- Mechanical Maintenance e rnodif 6 cations Admnistration - Schedule and coordhate all

- instrumentation

• maintenance /t&C - Employee trabhg for mabtenance,

& Contsois e mini-outages Commumcalms l&C construction,and 1

- Plant Chemistry and - Ptant Performance and Relations engheerho personnel; fitness 1 Iladic:hemistry and and Management - Emesgency for duty, fire school l Chemical Controd Report 6ng - Preparedness - Coordinate trabing for

- ifealth Physics - Data Systems - Document Control Emergen,:y Ptannhg

- AlNIA Management Cenler - Assese Trainbg needs of site

- Radwaste Managentent - Construcbon of all - Procedora personnel and monitor

- Plant ilousekeeping rnodifications and Administratm participation l

- flegulatory and INPO Check out and testino - Records Management - Ensure operating expedence  !

toter faco of improvernent - Industnal Safely input into trainho 1

- Syslum Engineering pro)ocis Progsam - Mmitor effecuveness of site

- Deactor Engineering - Configuration conttof - Facihties Coordination and off-slie trabbg

- Test Engnecting Coordination - Ollice Services - Mahtah site Tranning records

- Computer Enc,noering - Purchasing - Uuilding Maintenance - Responsible for site simulator coordnation - Dudget and Cost

- Stores / spare parts ' Control management - Site Access

- Materials Management Coordnatm

- Engineering and - Medical Deson of minor modifications Figure 3. Functional Organi:ation Chart for Site Organization ORGAtlIZATIOilAL RESTRUCTURIllG FOR IllCREASED C0llTROL, ACC0VitTABILITY, AllD CORPORATE DIRECTI0tl 0F flVCLEAR OPERATI0fis 19

I SECTION It CORPORATE ACTION

• Ensuring that the Plant Operations Review Committee (PORC) is functioning effectively and in accordance with the Technical Specifications.

• Keeping the Vice President-PBAPS/ LGS promptly informed of significant plant activities and providing the appropriate status reports.

• Maintaining open conmunications and a spirit of collaboration within the Plant organization and between the Plant organization and other site and off site support groups.

The Superintendent, Plant Services; the Superintendent, Maintenance and Instrumentation & Control; the Superintendent, Technical; and the Superintendent, Operations will report directly to the Plant Manager.

The Proieet Manaaer-PBAPS/ LGS will be accountable to the Vice i

President-PBAPS/ LGS for:

• Coordinating site management of the Integrated Management Program with l Nuclear Engineering.

• Ensuring that unit outages are effectively planned and managed so that outage durations are minimized and outage work is performed within all safety and quality parameters as established by the Plant Manager.

Providing integrated planning and efficient scheduling of all daily non-outage and outage work ectivities related to plant operations, maintenance and modifications. '

• Coordinating major plant modifications and improvement projects with Nuclear Engineering to ensure high quality, cost-effective implementation l

in a manner supportive of plant operational needs.

l

• Ensuring that minor plant modification and improvement projects are implemented in a coordinated, cost effective manner supportive of plant operational needs and in compliance with configuration control requirements.

• Ensuring that plant and organiza unnal performance data are collected, analyzed and reported in a timely and effective manner as directed by the Vice President-PBAPS/ LGS.

• Establishing and maintaining effective materials managesent systems which will ensure timely availability of required spare parts, equipment and materials, and timely resolution of receipt inspection deficiencies and obsolete parts issues.

ORGANIZAT!0NAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 20

l l

SECTION 18 CORPORATE ACTION l

• Maintaining open communications and a spirit of collaboration within the Project organization and between the Project organization and other site and corporate office support groups.

I Adninistration of projects within the scope of.the Project organization.

1 1

The Superintendent, Outages; Superintendent, Planning, Scheduling and Reporting; Superintendent, Modifications; and the Materials Management function will report directly to the Project flanager.

I l

The Support Manaaer will be accountable to the Vice President-PBAPS/ LGS for

• Ensuring that the approved site security program is ef fectively implemented and managed for normal and emergency conditions.

• Coordinating Emergency Preparedness activities for the site.

• Administering the Commitment Tracking Program for the site. l

• Coordinating with Nuclear Engineering on site Capital budget development and preparing PBAPS/ LGS operating, maintenance, and capital budgets for approval by the site Vice President.

Implementing an effective cost control and tracking program, monitoring cost allocations, and recommending corrective actions to the Vice President-PBAPS/ LGS as appropriate.

+

Coordinating the use of site facilities and their maintenance aad equipment l allocation; ensuring that all office services are provided as required.

Ensuring that procedures are regularly updated, maintained, distributed and controlled effectively.

• Ensuring that all required records and documents are prepared, stored and protected appropriately.

• Providing assistance to the Vice President-PBAPS/ LGS with site employee communications programs.

• Providing effective personnel administration services and assistance to site managers with employee performance and employee relations concerns.

The Superintendent, Administration, and the Coordinators for Security, Personnel, and Budget / Cost Control will report directly to the Support Manager.

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 21

SECTION I8 CORPORATE ACTION l

l l

The site Trainino Superintendent will be accountable to the Vice President-PBAPS/ LGS for:

• Coordinating with site management staff to identify the programmatic training needs of all site personnel.

• Providing excellent training programs on site, under the technical direction of corporate Nuclear Training to meet regulatory and INPO accreditation requirements for licensed and non-licensed operators, chemistry and health physics technicians, General Employee Training, respiratory protection training, and any other regulatory required and accredited training programs conducted on site.

l

• Coordinating the provision of training for IaC technicians, mechanical and electrical maintenance personnel, construction personnel, Emergency Plan  ;

training and supplemental professional training with corporate Nuclear l Training.

• Monitoring the effectiveness of all training provided for site personnell  :

implementing appropriate corrective action for site-provided training or l providing input to corporate Nuclear Training for off site training programs.

• Incorporating identified operating experience into site training programs in a timely manner.

• Maintaining current and complete training records for site personnel.

• Effectively managing the operation of the plant simulator to ensure maximum technical performance capability and maintenance of plant configuration accuracy.

Benefits Provided bv Reoroanization of the Site This revised site organizational structure will provide for a strong corporate management presence on site, and shorten and strengthen the nuclear chain of command. Corporate goals for improving communications throughout the Nuclear I organization and establishing a culture dedicated to nuclear excellence will be strongly supported by the site Vice Presidents. ,

l By establishing a Project organization separate from the Plant organization, the structure will also provide separate management accountability and authority for j I

I ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 22 l l

1 SECTION I8 CORPORATE ACTION plant operations and outage management. While each of these critical functions will receive dedicated management attention, the integrated planning and scheduling of both outage and non outage work will ensure that activities and resources are coordinated to support the needs of both organizations.

j A site-dedicated training function will ensure more attention and responsiveness l

l to site training needs while a corporate Nuclear Training organization (See Section 2.6) provides technical direction and support.

Strengthened management focus and accountability for critical station support

f. ctions, such as security, emergency preparedness, commitnent tracking, document control, personnel administration and facilities management, are provided by the establishment of a separate station support organization.

l 2.5 NUCLEAR ENGINEERING ORGANIZATION The mission of Nuclear Engineering will be to provide excellent, timely, cost effective technical support and engineering services to PBAPS and LGS in support of station priorities, and to manage the design bases of these stations. A functional organization chart for Nuclear Engineering is shown in Figure 4 on the following page.

The key accountabilities for the Projects, Engineering and Engineering Design organizations will be as follows:

The Manaaer. Project Manaaenent Division will be accountable to the Vice President-Nuclear Engineering fore ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 23

SECT 80N 8: CORPORATE ACTION

.a 1 FUNCTIONAL ORGANIZATIONAL CHART FOR NUCLEAR ENGINEERING

/ ice President -

Nuclear Engineering Manager I I I I Construction Project Supenntendent Engineenng Management Engineenng LGS 2 Design

- Constructon manage- - Single point of - Single point of - Provide Pesponsible ment of LGS 2 centact for all accountability for Engineers with con-Nuclear Engineenng engineenng of cectual design work at each site modificabons support, engineenng

~

Nu

- Planning and sched-ent h tud assistance /expertse - Maintain configuration uling support for contrdof design the Nuclear Engi. - Manage the eng'.

• drawings including neenng Deoartment neering design bases pgjDs, e4ectncal and each Division schemabcs, piping

- Management of the

- Planning and sched- configurabon control physical drawings, uling interface program and circuit diagrams he $n e e - Engineeringassurance - Ass p an to scheduling inte-graton - Procuremerit of wa;kdowns Engineered mate #.ls

- Provide budget and - Reprographics cost control support - Comput5r support of including estmating, engineenng software -D W Msd e d budgeting and fore- and procure materia]s castng for Nuc! ear needed for modifictons Engineering - Computar aided design

- Maintain Nuc! ear . . - Review and maintain

^

sh((T Procedures h vendor documentabon

- Administrabon of of contracts for Eng'.neenng Services

- Document Control

- Spec:al Protects Figure 4. Functional Organization Chart for fluclear Engineering ORGAllIZATI014AL RESTRUCTURI!iG FOR IllCREASED C0tiTROL, ACCOUtiTABILITY, AtlD l CORPORATE DIRECTI0ft OF IJUCLEAR OPERATI0 tis 24 l

I SECTION It CORPORATE ACTION

• Project management of engineering projects for each station to ensure that all engineering work is defined, planned, scheduled, budgeted, implemented, technically supported, and evaluated in a timely, high quality, cost effective manner.

• Managing the interface with the Station Project Manager who is responsible for managing the construction, testing, and operations acceptance of engineering projects.

• Planning, scheduling, resource loading, budgeting and cost control support for Nuclear Engineering, j

• Developing and monitoring Nuclear Engineering planning, scheduling, budgeting I and cost control procedures; maintaining Nuclear Engineering technical procedures.

l

• Administration of contracts providing engineoring services.

• Planning, scheduling and budgeting interface with other Nuclear organizations to integrate Nuclear Engineering plans, schedules and budgets with PBAPS, LGS, Nuclear Services, and Nuclear QA. .

I

• Coordinating the development of, and managing the Nuclear organization's Integrated Management Program in cooperation with the site organizations and l Nuclear Services.

l

• Managing major projects as determined by scope or complexity.

The Manaaer, Enoineerino Division will be accountable to the Vice President-Nuclear Engineering for

• Management of engineering for modifications to ensurn that the engineering work is defined, planned, scheduled, budgeted, and implemented in support of the established Project Management Division schedule.

• Engineering designs, analyses, studies, and assistance / expertise as required, to support the safe anu effective operations of the Company's nuclear units.

• C#nducting engineering studies of nuclear plant systems enhancements.

• Managing, controlling and monitoring the engineering design bases for the Company's nuclear units.

• Managing the Nuclear configuration control program.

• Performing independent evaluations of engineering work to assure technical compliance.

• Providing specifications for procurement of engineered materials.

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF HUCLEAR OPERATIONS 25

SECTION I: CORPORATE ACTION Developing, controlling and maintaining computer software used as engineering tools within Nuclear Engineering.

The Manaaer, Enoineerina Desian Division will be acco ;ntable to the Vice President-Nuclear Engineering for:

Providing conceptual design support, engineering design, and drafting services to support the development and implementation of nuclear plant modifications per the established Project Management Division schedule and to support the day-to-day operations of the company's nuclear units.

Maintaining configuration control of design drawings and vendor documentation.

Providing reprographics service to the Nuclear organization.

The Manaaer, Nuclear Enaineerina will have two major roles. Reporting directly to the Vice President-Nuclear Engineering in a one over one relationship, the Manager, Nuclear Engineering will stand in for the Vice President at his request. The second major role is as Construction Manager-LGS Unit 2. In this capacity, he will report directly to the Senior Vice President-Nuclear and use his line authority to ensure timely engineering and construction actions in support of the LGS Unit 2 Project.

Benefits Provided by Reoraanization of Nuclear Enoineerina PE will capitalize on its engineering and project management strength by: 1) dedicating a significant portion of its corporate engineering resources to the support of nuclear operations exclusively, and 2) establishing single point accountability for the management of engineering projects at appropriate management levels.

Clarification of interface responsibilities between site system engineers and Nuclear Engineering with respect to plant systems monitoring will contribute to improved problem identification, analysis and resolution, ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND c f CORPORATE DIRECTION OF NUCLEAR OPERATIONS 26 l

l l

. = . _ . _. _. .._ - . _ . _ _ . _ . . -

SECTION It CORPORATE ACTION 2.6 NUCLEAR SERVICES ORGANIZATION The mission of fluclear Services is to provide corporate technical direction and performance standards for plant programmatic areas in support of excellence of nuclear site activities, including management of participation in all INP0 programs.

Nuclear Services also performs maintenance work requiring centralized shop services and mobile specialist forces; oversees and/or provides accredited nuclear and craf t X training; and serves in a staff support role to the rest of the Nuclear organization in the areas of budget and cost accounting, computer applications, personnel administration and Nuclear records management.

A functional organization chart for Nuclear Services is shown in Figure 5 on the l

following two pages.  !

i I

OR0ANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 27

FUNCTIONAL ORGANIZATIONAL CHART FOR NUCLEAR SERVICES Oo Vice President

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SECTION Is CORPORATE ACTION The key accountabilities for each of the four organizations reporting to the Vice President-Nuclear Services will be as follows: The Manaaer, Nuclear Maintenance will be accountable to the Vice President-Nuclear Services for

• Providing specialized mechanical maintenance services and support to the sites.
• Providing specialized electrical maintenance services and support to the sites.
• Providing in-service inspection services to the sites.
• Providing specialized ISC services and support to the sites.
• Operating the central maintenance shops.
• Maintaining a central pool of mechanics to supplement the site Maintenance organization as required.

The Manaaer, Nuclear Support will be accountable to the Vice President-Nuclear Services fore l

• Ensuring that all licensing conditions and requirements are known to Nuclear management; monitoring compliance with regulatory conditions and requirements.
• Maintaining the UFSAR; coordinating preparation and submittal of licensing documents.
• Serving as the corporate focal point for regulatory and INPO interfaces; coordinating preparations for audits, evaluations and assist visits; coordinating management follow-up actions and responses. I r

l l

• Developing and maintaining an ef fective commitment tracking program. 1 i

{ j

• Managing an effective operating experience assessment program including:

l reviewing and analyzing all regulatory and industry information for application to nuclear operations; ensuring timely distribution of such information to site organizations, other Nuclear services functions, Nuclear Engineering, Nuclear QA and the NRB; monitoring management's timely incorporation of such information as appropriate into operations and support activities.

• Developing technical standards for plant chemistry programs; conducting periodic on-site assessments of the effectiveness of station chemistry activities; ascertaining that problems are identified in a timely manner; determining root causes of problems and working with site management to ensure that corrective actions are taken with effective results.

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF HUCLEAR OPERATIONS 30

SECTION It CORPORATE ACTION

• Developing technical standards for the plant radiological protection programs conducting periodic on-site assessments to monitor the effectiveness of plant radiological protection activities; tracking trends in radiological protection activities; identifying basic causes of any problem areas and monitoring the results of corrective actions.
• Developing technical standards for the plant radwaste program; monitoring plant conditions, trends and radwaste data to ensure that radwaste volume generated is within the limits established by corporate standards, and that radwaste processing complies with all corporate standards; conducting periodic on site assessments to nonitor the effectiveness of the radwaste program; ascertaining that problems are identified in a timely manner; determining root causes of problems; and w;rking with site management to ensure that corrective actions are taken with effective results.
• Developing technical standards for the plant emergency preparedness programs maintaining and periodically reviewing corporate emergency preparedness plans, procedures and training programs to monitor effectiveness and to ensure that required revisions have been nades coordinating necessary interfaces with federal, state and local authorities; ascertaining that review of the EPP has been performed independently of PE's corporate emergency preparedness organization.
• Performing nuclear fuel / core design, reload planning and specifications, core

                      '  analysis and operations supports core management; nuclear fuel accountability; methods developments safety analysis; budgeting of nuclear fuel costs; fuel quality assurance, reload licensing, spent fuel management, and developing, controlling and maintaining computer software used in nuclear fuel and core design analysis activities.

• Providing technical direction and performance standards for the Physical Security Program including the Security Plans; performing periodic assessments of the station's security performance and providing recommendations for improvement.

The Manaaer, Nuclear Trainino will be accountable to the Vice President-Nuclear Services for:

• Providing corporate level direction and oversight for all regulatory-required and accredited training programs at PBAPS and LOS.
• Ensuring that accreditation and regulatory requirements (including curriculum development, updating of training programs, instructor accreditation, and training records management systems), are met to obtain and maintain accreditation of nuclear training programs.
• Providing craft training programs for maintenance and ce struction workers. X
• Integratinc OEAP information and corrective actions int training programs and ensuring tr.ct all appropriate personnel receive regular aining in new and continuing OEAD matters.

ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 31

l l SECTION It CORPORATE ACTION l l e Developing and reviewing all training curricula to ensure excellence in fulfilling the training needs of site and corporate personnel. j e Ensuring the proper selection, training, monitoring and evaluation of l instructors. e Coordinating with Nuclear Engineering to assure provision of training facilities which support learning. I l The Manaaer, Nuclear Administration will be accountable to the Vice 1 1 President-Nuclear Services fori

• Coordination and monitoring of the development and application of personnel policies for the Nuclear organization. I
• Coordination, monitoring and reporting activities in the area of budget and cost l control.
• Computer sof tware development and support, systems coordination, and user assistance with computer applications.
• Coordination and maintenance of the corporate Nuclear Records Management System.

Benefits Provided by Reorcanization of Nuclear Services The establishment of a centralized, nuclear-dedicated enrporate training function will increase corporate management attention to nuclear training needs and ensure more consistently controlled development and implementation of all nuclear and craf t training activities. M The creation of the centralized Nuclear Maintenance organization will provide experience in specialized activities, flexibility in use of resources, and uniformity in methods and techniques to support bo th nuclear sites. There will be increased familiarity with the units at both sites and full understanding of the nuclear safety and quality requirements which must govern all work. ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 32

SECTION I8 CORPORATE ACTION  ! Staff support for the Nuclear organization will be pulled together within one line organization ensuring that the special needs of nuclear operations with respect to personnel, budget and cost control, computer applications, and nuclear records are well coordinated. 2.7 NUCLEAR MANAGEMENT TEAM 2.7.1 Manaaement Assianments l New top management with proven leadership has been brought in from outside PE to l l 1 provide strong, competent and experienced direction to PE's management team. The l  ! new President and Chief Operating Officer, Joseph F. Paquette, has returned to PE l i i to lead the Company and provide clear guidance to its nuclear operations. The Board I l of Directors has announced its intention to elect Mr. Paquette Chairman of the Board i I and Chief Executive Officer on April 13, 1988. l The Executive Vice President-Nuclear's manacement team will consist of Corbin A. l McNeill, Executive Vice President-Nuclear; John S. Kemper, Senior Vice l President-Nuclear; Dickinson M. Smith, Vice President-PBAPS; Graham M. Leitch, Vice President-LOS; Joseph H. Gallagher, Vice President-Nuclear Services; S. Joseph Kowalski, Vice President-Nuclear Engineering; and David R. Helwig, General Manager-Nuclear Quality Assurance. The PBAPS site manaaement team, under the direction of Dickinson M. Smith, will include John F. Franz, Plant Manager-PBAPS; Kenneth P. Powers, Project Managers l David R. Meyers, Support Manager; and Ernest A. Till, Training Superintendent. 1 ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 33

SECTION It CORPORATE ACTION Ihe LGS nanacement tean, headed by Graham M. Leitch, Vice President and Plant l Manager, will include: Edward F. Sproat,III, Project Manager; Herner T. Ullrich, l Unit 2 Start-up Manager; James H. King, Support Manager-LGS, and Edwin G. Firth, 1 Training Superintendent. l l Jn Nuclear Enoineerina, the management team, headed by S. Joseph Kowalski, will l l l include Thomas P. Gotzis, Manager, Nuclear Engineering; James J. Clarey, Construction Superintendent LGS-Unit 2; Herbert R. Halters, Manager, Project Management Divisions Lubomir B. Pyrih, Manager, Engineering Division; and Edward P. McKeown, Manager, Engineering Design Division. The Nuclear Services nanaaenent team, under the direction of Joseph H. Gallagher, will consist of H. H. Traver, Manager, Nuclear Maintenance; E. P. Fogarty, Manager, Nuclear Support; Robert A. Goucher, Manager, Nuclear Administrations and a Manager, Nuclear Training (to be selected). The Nuclear QA manaaenent teen, headed by David R. Helwig, will include Robert H. Moore, Assistant General Manager, Nuclear QA; J. Michael Pratt, Manager, PBAPS Quality; James M. Coreccan, Manager, LGS Quality; J. Theodore Robb, Manager, Independent Safety Engineering; Richard N. Charles, Manager, Performance l l Assessment; and John F. O'Rourke, Manager, Quality Support. l Biographical data for all of the managers is included in Appendix B. l ORGANIZATIONAL RESTRUCTURING FOR INCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 34

      . , , , .         - , , . - . . - -   --.--,----ce              ,     - - ,                    ~ ~                      ' " 'i

SECTZON Z CORPORATE ACTION 2.7.2 Mananement Strateav The Executive Vice President-Nuclear will use his fresh perspective and record of M achievement in analyzing requirements for organization structure, management I authority, staf f resources and personnel policies to er.aure organizational effectiveness. Senior Company management is committed to supporting these requirenents to provide the framework for success. M The Executive Vice President-Huclear and his direct reports are working closely to I ensure successful planning and implementation of new management structures and processes. They are developing a team approach to replace past practices which fostered each departnent's autonony in relationship to other departments. An example of this approach is the collaborative decision-making process which will be used by the Senior Nuclear Managenent Team to prepare the capital budget based M on the collective priorities of both the site and support organizations. This approach will be replicated down through the Nuclear organization, with emphasis on lateral communications and problem solving, rather than a hierarchical approach. The Organization and Management Development staff is working directly with the  ! Executive Vice President-Nuclear and his staff in an ongoing team development I process which includes coaching on individual managerial conpetencies and managerial styles, teamwork, and organizational comnunications. ORGANIZATIONAL RESTRUCTURING FOR IhCREASED CONTROL, ACCOUNTABILITY, AND CORPORATE DIRECTION OF NUCLEAR OPERATIONS 35 l

SECTION Is CORPORATE ACTION 3.0 IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION WITHIN THE NUCLEAR ORGANIZATION l 3.1 MANAGEMENT PHILOSOPHY FOR ASSURANCE OF QUALITY The Nuclear management team is developing a strong management philosophy embodying the concept of assurance of quality. This philosophy is expressed as follows: 1 l l

• Line management is responsible for assuring the quality of the operations and j services which they provide, j

1

• Line management establishes performance goals to achieve excellence, as well as the indicators to be used in assessing the performance of their organizations.
• Line management communicates regularly about the quality of operations with each other, their employees, and other company organizations through field visits, meetings, retreats, and written reports.
• Line management monitors the performance. of their organization and takes l corrective action when there is a variance. I l
• Line management reports on their performance with respect to j established goals.

i Line management is responsible to effectively close out all open items on a { l timely basis. ' Every Nuclear employee is responsible to identify and report observed quality problems /deficienciem in a timely manner. The direct reports to the Executive Vice President-Nuclear will be held I accountable to ensure that effective problem / deficiency reporting programs are in place for their employees to use. QA monitors and assesses the performance of the other Nuclear organizations, providing independent audit reports and evaluations to line management and upper management. I QA monitors and assesses the effectiveness and timeliness of follow up on open items which have been identified to line and upper management. This management philosophy for assurance of quality will be implemented and supported in a nunber of ways: IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION WITHIN THE NUCLEAR ORGANIZATION 36

SECTION Is CORPORATE ACTION

• The Executive Vice President-Huclear and his management team will develop a l statement of their philosophy and expectations for assurance of quality which will be printed in the company and site newspapers, displayed on appropriate corporate and site bulletin boards, and referred to in communication with Nuclear employees.
• A Nuclear performance management program (Performance Management to Achieve and Maintain Excellence) will be established.
• Effective feedback information systens will be provided to ensure that line management is aware of the quality performance level of their organization.
• Improved employee perfornance evaluation processes will be used to communicate management expectations for quality performance and conduct face-to-face employee performance reviews.
• Improved processes for reporting quality work related problens will be developed including formal systems and informal programs.

3.2 NUCLEAR PERFORMANCE MANAGEMENT PROGRAM TO ACHIEVE AND MAINTAIN EXCELLENCE Performance goals for excellence will be established by each Nuclear line organization. These will include goals for organizational performance as well as technical and operational performance standards. Performance indicators will be identified for use in tracking and reporting on perfornance against established goals. l The Executive Vice President-Nuclear will be held accountable by the President to l l have the new Nuclear Performance Management Progran fully operational throughout the Nuclear organization within one year. The Executive Vice President-Nuclear and I his management tean will work together to develop key performance improvement goals for the Nuclear organization, using comparisons with peer plant key indicator trends in this process, and to communicate these goals to Nuclear employees. Each direct report to the Executive Vice President-Nuclear will then work with his I diroet reports as a team to develop goals for excellence (which support the overall IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION HITHIN THE NUCLEAR ORGANIZATION 37

SECTION Z: CORPORATE ACTION Nuclear goals and standards) for each organizational unit and to identify the perfornance indicators to be used to track performance. Measurement of performance against established performance objectives / s tanda rds will be tracked and reported frequently to line management. The timeliness and effectiveness of each management level with respect to corrective action follow up will be monitored and enphasized in the performance appraisal process. Nuclear QA will provide overall assessment of the effectiveness of the Performance Management Progran, and report the results of this assessment to line management and the Executive Vice President-Nuclear. I 3.3 NUCLEAR QA ORGANIZATION The Nuclear QA organization will be strengthened by: 1) elevating the reporting relationship to the Executive Vice President level; and 2) integrating previously l separate quality assurance and control organizations into one centralized QA organization and program nanaged by the General Manager-Nuclear Quality Assurance (Nuclear QA). The General Manager-Nuclear QA will report directly to the Executive Vice l President-Nuclear and be an integral part of his Senior Nuclear Managenent Tean. A functional organization chart for Nuclear QA is shown in Figure 6 on the following page. Quality Control and Quality Assurance activities at each site will be under the direction of the site Quality Managers. The Manager, Quality Support will be IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION HITHIN THE NUCLEAR ' l ORGANIZATION 38 I

SECTION It CORPORATE ACTION FUNCTIONAL ORGANIZATIONAL CHART FOR NUCLEAF QUALITY ASSURANCE General Manager Nuclear Quahty Assurance l Assistant General Manager Nuclear Quahty Assurance l C* PBAPS Quality LGS Quality ISEG  %, Quakty Support L

• Sogle pont of
• Soge poet of
• Inccent investigation
• Independent assessment
• Single poet of accountabihty for accountability for of Nuclear operatonal accountabd4 for aal Ovale activites aa Quahty Actmties
• Operatzns rnonstoring performance quality supcort at PBAPS at LGS
• Revew of seected
• Independent eva.uatons
• NOA manuals and

 - Auditing                   - Audating                modificatons               of Nuclear orgnanizaton      procedures effectrveness
  - Inspectons                - Inspectons

• NAB safety evajuaton
• Tramng ccordnation revews
• Monitoring effectreeness of OA/OC personnel

 - Surveillance               - Surveiltance                                       of Nuclear Performance

• Input to Operatog Management Program
• Vendor survedlance

 - Monitonng                  - Monitonng               Espenence Assessment Program

• Trend analysis of a Suppher audds

  - Reve*s                    - Revews                                             performarsce

• Independent oversght
• Support for JUMA aud$

of line management

• Techncal support for program response to CEAP items the NRB
• Specialinterdisciplinary studies as requested Figure 6. Functional Organizational Chart for fluelear QA IMPROVED SELF ASSESSMEllT Ai4D PROBLEf1 RESOLUTI0tl WITHIti THE ilVCLEAR O RGAi1IZAT I 0t1 39

1 l SECTION I: CORPORATE ACTION responsible for all quality support activities common to (and not specific to) both sites. This includes manuals and procedures, vendor audits and surveillance, training, procurement controls, and oversight of the quality activities of Nuclear Engineering and Nuclear Support. Each of these three quality managers will be responsible for the identification of specific and programmatic deficiencies, tracking of these items until they are fully resolved, and performing trend analysis, l Specific improvements in these areas, and other areas of Nuclear QA functional responsibility are discussed below. 3.3.1 Expansion of Nuclear QA Pronrammati Activities The scope of Nuclear QA audits is being expanded to include comprehensive technical and performance based audits in addition to the classical quality assurance audits of adequacy and ef fectiveness. The ability of Nuclear QA to perform these types of audits will be supplemented as necessary by the use of technical experts either from within or outside of PE. In this manner, Nuclear QA will be able to focus on the adequacy and appropriateness of the technical activities of the various Nuclear organizations. Trending and evaluation of the results of the independent quality assurance and quality control activities will be used to highlight significant areas of concern 1 for line managenent's attention. Periodic status reports on overdue close outs on ' audit findings, together with quarterly trending reports, will be distributed to

                                                                                       )

i inPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION WITHIN THE NUCLEAR l 6kOANIZATION 40 I

                   ---- .               .          .         .    .           . - - -             ~           --

SECTION Il CORPORATE ACTION the five Nuclear Vice Presidents and the Executive Vice President-Nuclear to keep I them informed of any problem areas. A Performance Assessment Section will be added to Nuclear QA. The Manager, Performance Assessment will be responsible for assessing organizational performance and providing independent evaluations of the effectiveness of the Company's Nuclear i program. These assessments will be based on sources of information such as monitoring of plant performance trends, QA and Quality Control reoorts, reports from the Independent Safety Engineering Groups (ISEG), trend analysis, observation of plant condition and activities, the conduct of internal evaluations similar to those performed by INPO, and special investigations and reviews. The Manager, Performance Assessment will report on these subjects to the NRB, the Executive Vice l President-Nuclear and the five Vice Presidents through the General Manager-Nuclear l QA. The Independent Safety Engineering function will be added to the Nuclear QA Department. Under the direction of the Manager, Independent Safety Engineering, the ISEG at each site will continue to be responsible for performing independent reviews of plant operations, reviewing operating experiences which may indicate the l need for improvements, recommending needed improve. 3nts, and advising management ' on the overall quality and safety of operations. The ISEGs will provide input to the OEAP based on their reviews and maintain independent oversight of the adequacy and timeliness of actions taken by line management in response to OEAP items. l IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION HITHIN THE NUCLEAR ORGANIZATION 41 l

 . _ - - _ _ - . . , _ . . _ , _m___         , , , . . . . _        _

, - . . - = l SECTION I CORPORATE ACTION Activities formerly assigned to the Independent Safety Engineering organization, which were peripheral to the safety function of ISEG, will be reassigned to other organizations to allow the ISEOs to enhance their focus on improving the safety of plant activities. As examples, the administration of the OEAP and the provision of technical support for interfaces with joint owners will both be reassigned to the Nuclear Support organization within Nuclear Services. The Manager, Independent Safety Engineering will report to the Executive Vice l President-Nuclear through the General Manager-Nuclear QA. l 3.4 OPERATING EXPERIENCE ASSESSMENT PROGRAM A strengthened Operating Experience Assessment Program (OEAP) is being developed under the direction of the Manager, Nuclear Support. The OEAP manager will have corporate accountability for the timely implementation of the following activities:

• Receiving and screening incoming information from external sources (e.g.,

Service Information Letters, Significant Event Reports, Significant Operating Experience Reports, Information Notices, Inspection and Enforcement Bulletins, Significant Event Notifications) and internal sources (e.g. , Licensee Event Reports, ISEG Event Reports).

• Forwarding items as appropriate to all relevant line organizations and independent assessment groups, e Consulting with relevant line organizations to clarify, research and evaluate the inplications of information received; determine the need for new or corrective actions with respect to plant procedures, design or operating practices; and determining lead responsibility for that action.
• Communicating cerrective action requirements in writing to the relevant functional nanagers, who are then responsible for implementing the corrective actions within their scope of responsibility. l
• Ensuring that copies of relevant information notices and corrective action comnitnants are received by Nuclear Training, Emergency Planning and other IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION HITHIN THE NUCLEAR ORGANIZATION 42

l SECTION It CORPORATE ACTION organizations which need to ins ,t his information into their functional activities,

• Updating the OEAP tracking program to include corrective action requirements.
• Preparing monthly status reports on corrective action progress with summary remarks flagging overdue items and areas of concern.
• Assessing the effectiveness of the OEAP on an annual basis.

i

• Reporting on the OEAP through the Manager, Nuclear Support and the Vice President-Nuclear Services, to the Executive Vice President-Muclear. l The Independent Safety Engineering Group (ISEG) will maintain independent oversight of the adequacy and timeline s of the actions taken by line managers in response to OEAP items.

This strengthened OEAP will be an important element in the development of a comprehensive and effective self assessment capability to support timely and i appropriate corrective action programs within the Nuclear line organization. I 3.5 COMMITMENT TRACKING PROGRAM l Under the direction of the Manager, Nuclear Support, e strengthened Nuclear commitment tracking program will be developed to ensure integrated commitment I management for the Nuclear organization. As with the assurance of quality program, the responsibilities of line managers and the Licensing Manager will be clearly l l l delineated as follows: l l l

• Line management is responsible for making commitments, assuring the resource availability to meet the commitment, and providing all relevant data about the commitnant to the Licensing Manager. l
• Line management is responsible for communicating details in a timely manner about connitments they have made and how they expect to meet them to their own organization and to other involved organizations.

IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION HlTHIN THE NUCLEAR ORGANIZATION . 43-

i l 1 l SECTION Z8 CORPORATE ACTION

• Line management is responsible for implementing the actions which will fulfill the commitments they have made.
• Line management is responsible for taking appropriate action to ensure that commitments are maintained through subsequent program or procedural changes.
• The Licensing Manager (serving in a staff role to the Executive Vice President- l Nuclear through the Nuclear Services chain of command) is responsible for providing the administrative support to line management to facilitate meeting the commitments. This support includes the development and implementation of an effective commitment tracking system and the distribution of useful management reports which highlight the status of each organization's commitmer.ts and alert managers to potential problem areas.
• The Licensing Manager is also responsible for maintaining the policy and l procedure documents which are used to define the control of the commitment management program.

Careful thought has been put into the identification of each step in the commitment tracking process from identifying potential commitments through taking appropriate l actions to maintain commitments. A responsibility chart which conforms to the new Nuclear organization will be developed to indicate who is responsible, who should P be consulted, and who should be informed for each step in the commitment management process. This responsibility chart will be used as a discussion tool with all key managers to develop final agreements with respect to responsibilities for commitment management interfaces. Once these agreements have been reached, the responsibility chart will be used to communicate management expectations with respect to commitment management responsibilities to lower levels of the organization. The Commitment Tracking Prcoram will reinforce the effective and timely managemer.t l of corrective action programs in response to intarnal and external audits through the following:

• Establishment of a single point of line accountability with appropriate authority for each commitment.

1 IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION HITHIH THE NUCLEAR l ORGANILATION 44 I

                                                                                   /

SECTION El CORPORATE ACTION 1

• Development o f a . plan. nnd schedule, including negotiation of resources tu meet commitments on time and eti4etively.

i

           +           Proactive review of commitment activity by each managenent level up to and                                                  I including the Exekutive Vice President-Huclear.                                                                        l

• Facilitation of problem res' olution acro'ss organization boundaries at the lowest possible management levels.

l l , /  ! l l 3.6 INFORMATION HANAgnBENT AND REPORTING SYSTEME, >- Information management and rwrorting systems support the management and performance of work, the identifics tion uof problems, the tracking of corrective actions, and appropriate implementation of solutions. To ensure that the Nuclear information management and reportingmystems are providing effective support in these ways, each program and work management process critical to sustaining a safe nuclear generating l' environment will be evaluated relative to current PE commitments, industry requirements, and good practices. Any processes requiring improvement will be prioritized and then enhanced through appropriata corrective action. 1 1 An Information Management assessment will then be performed on each of these programs and work manany ant processes to assist managers in identifying the data required to support the wifective implementation of thy proc /ss, the information needed to monitor performanc , a;/d' how the information cu$ be managed to assist them in the early identification of p::oblems. Existing'information data bases will be 1 , '., assessed to determine what portion of managementy infc mation needs can be met,

;           how the data can be manipulated to provide the,various' levels of management with
                                                                     .               o appropriate status and trending reportm. and what data elements are not in the data bases.             Based on these assessments, a plan will b'e developed and implemented to
)            improve information management and reporting systems' Nuclear QA will perform periodic audits to assure that the data associated with canagement processes and i

IMPROVED SELF ASSESSMENT AND PROBLEM RESOLui10H HITHIH THE NVCLEAR j ORGANIZATION f, y 45 r ---,em. ,-

               - - - -          --                          .,              .,, ,                    n ,.            -   , - - -

I SECTION It CORPORATE ACTION performance indicators are maintained, and required actions are being effectively pursued. This improvement "rogram will require comprehensive effort and is considered to be a long-term effort. A shorter term effort will upgrade the current monthly Performance Indicators Report using the INPC Key Indicators Program, as well as additional performance indicators. Significant data will be identified and highlighted to assist management with improved performance monitoring and early problem identification. 3.7 NUCLEAR TRAINING l Effective and timely training of all Nuclear personnel is a critical element in improving self-assessment and problem re:olution capability within the Nuclear line organizations. A Nuclear Training organization will be established, reporting to the Vice President-Nuclear Services, to focus on the spe:ial training and development needs of the Nuclear Group. Line managers will ensure tinely I participation id training programs by their subordinate managers, supervisors and l personnel. l 3.7.1 Nuclear Trainina l The new Nuclear Training organization will includes the Nuclear Training Section which wil' have responsibility for all license, accredited and General Employee Traini ..id the Barbadoes Training Center, responsible for all crafts training for maintenance and construction workers.

• IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION WITHIN THE NUCLEAR ORGANIZATION 46

l.-_.-_. l SECTION It CORPORATE ACTION A Manager for Nuclear Training is being recruited from outside the Company. A key l l qualification for recruitment includes successful experience in managing accredited l training programs. In addition to the responsibility for developing the new Nuclear * ! Training organization, the Manager will work closely with Nuclear managers and with M  ! l Nuclear personnel to assess supplementary professional training needs not covered I by regulatory and accreditation programs, and coordinate provision of training to  ; meet identified needs. 4 l 3.8 ORGANIZATION AND MANAGEMENT DEVELOPMENT l { l l In order to ensure that senior management has the necessary resources to continue l to develop the management systems, programs and processes essential to support l cultural change, an Organization and Management Development Division has been l established. The Organization and Management Development Division includes two i sections: Organization Development, and Management and Professional Development. l The Manager of the Organization and Management Development Division and the Director l of the Management and Professional Development Section report to the Executive Vice l President-Nuclear. l l l 3.8.1 Ornanization Development Section l The Organization Development staff assists Nuclear managers in their change and l improvement efforts by providing processes by which managers can clarify the present l l state and specify the future state of their organization, help them to identify l blocks to goal achievement, develop strategies to move from the present state to l A the desired state and monitor the progress of the transition. Organization l r Development Section staff also assist managers with monitoring and assessing the i i

        "people management" aspects of organizational perfornance.                        A key element in this                l 1

i IMPROVED SELF ASSESSMENT AND PROBLEM RESQLUTION HITHIN THE NUCLEAR ORGANIZATION 47

SECTION It CORPORATE ACTION process is helping Nuclear managers to specify the changes desired in terms of l management and employee work behaviors and communications, and to routinely assess l , progress toward achieving the desired organizational values, performance and l culture. Additionally, the Organization Development staff provides ongoing support l  ; to Nuclear managers in managing organizational change. l 3.8.2 M naaement and Professional Development Section l j PE recognizes that excellence in nuclear operations requires excellence in M management and supervision. The new management assignments for Nuclear ensure that, in the short-term, corporate management will be of high quality. In the longer-tern, if PE is to ensure management excellence, it will be necessary to develop the management potential of technically competent individuals who presently 4 do not fill management roles and to upgrade the knowledge, skills and competencies of present managers. Thus, the Director, Management and Professional Development, l 2 is responsible for the overall design and implementation of a comprehensive l management and supervisory training and development program. 1 I l l The Director, Management and Professional Development, will assess management and l l supervisory training needs with Nuclear management to determine the core management competencies and skills required for each level of Nuclear management from first-level supervisor to the executive level, i e l l These core competencies and capabilities will be used to provide guidance for l I { overall progran developnent, monitoring and evaluation. Organizational needs l (e.g., inproved planning and problem solving) will receive priority attention in  ; developing management skill training requirenants. i 1 4 l IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION WITHIN THE NUCLEAR

ORGANIlATION 48 1

l l l SECTION It CORPORATE ACTION l 1 l l Existing Company training courses, currently used external educational / training programs, job rotation options, and other developmental opportunities, such as visits or short-term assignments to other utilities and loan assignments to INPO, 1 will be reviewed for their applicability to Nuclear management needs. J Short-term programmatic efforts will be focused on the ongoing development of I current managers; adapting the schedule and location of Company management training I programs to better meet the needs of more Nuclear managers; reviewing training i  ;

                                                                                        )

records; and identifying priorities for manager participation in available training l programs over the next year. Specific organizational needs with respect to improved l goal-setting, problem solving, and performance management will be addressed through l coaching and infornal training with intact work groups as well as through formal training prograns. A part of the short-term and the long-term program activity will I include the use of a variety of assessments of managerial skills and abilities. l Assessment of managerial performance will provide the basis for individual l development planning and selection for higher supervision and management positions. l A longer-term programmatic focus will also include the development of technical l personnel for promotion to supervisory and management positions. An individual l development plan for each Nuclear manager will be established and monitored. This l effort will be carried out in conjunction with an improved Nuclear performance appraisal program. Each level of line nanagement will be trained and/or coached I in the effective use of the perf arnance review process to provide ongoing assessment of individual rianagerial and technical competencies, identify specific individual development plans to be met within the next review cycle, and discuss any problem areas with overall management of the work unit's performance. IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION WITHIN THE NUCLEAR ORGANIZATION 49

SECTION I CORPORATE ACTION 3.9 MONITORING OF SAFETY, QUALITY, AND ORGANIZATIONAL PERFORMANCE l Three key areas need to be monitored for effective Nuclear organization self assessments safety, quality, and organizational performance (i.e., how the organization manages itself to ensure the safety and quality of operations). With l the changes described in Sections 3.1-3.8, the nanagement structure and systems will l be in place to provide effective nonitoring of all three areas. Line management has the lead responsibility for monitoring the safety and quality of all aspects of its nuclear activities. It will have the benefit of strengthened Operating Experience Assessment and Commitment Tracking Programs, and improved i information mar,agement and reporting systens to help in this respect. Nuclear QA provides independent monitoring and assessment of the safety and quality of nuclear operations as well as assessment of Nuclear organizational performance. The centralization of QA progrannatic activities, which will bring more organizational performance assessment information together under one organization, will contribute to the effectiveness of this independent monitoring and assessment. Quarterly Nuclear QA reports will provide Nuclear performance trend analysis for management

• review. x The review and assessment capability of the Nuclear Review Board (NRB) will be l supported by its revised charter, the addition of new outside members with different i perspectives and increased assistance with analysis and trending of problem areas. l Reporting of NRB concerns to the Executive Vice President-Nuclear will be improved I by including written problen analysis and recommendations for follow up. I IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION HITHIN THE NUCLEAR ORGANIZATION 50

SECTION II CORPORATE ACTION The manner in which line manegement will use improved independent assessment feedback from Nuclear QA and the NRB for timely and proactive problem solving is discussed in Section 3.10. l 3.10 INTERACTIVE COMMUNICATION PROCESSES FOR PROACTIVE PROBLEM SOLVING BY l MANAGEMENT l Emphasis is being placed on the importance of interactive communications and problem solving toi 1) improve corporate direction and oversight of plant operations; and

2) ensure timely management follow-up on independent assessment feedback. Nuclear Services managers who have responsibility for providing corporate direction and oversight of site technical programs will conduct periodic meetings on site with the corresponding site functional manager (s) to review programmatic performance in each functional area, identify and discuss potential problem areas, and develop corrective action plans.

Periodic meetings will also be conducted on site between relevant Nuclear Engineering managers and site Plant and Project managers toi discuss priorities for engineering support with respect to plant technical needs and planned modifications; evaluate the effectiveness of the project engineering interface between the site and Nuclear Engineering; and establish agreements for any needed improvements. The Executive Vice President's periodic site meetings at PBAPS will be continued I and the same process will be established at LGS. Using a pre established agenda which keeps track of open items, the status of plant activities will be reported by site management personnels concerns will be identified from these reports. Operating Experience Assessment Program information, QA reports and other IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION HITHIH THE NUCLEAR ORGAHlZATION 51

SECTION Il CORPORATE ACTION , resources; and priorities and lead responsibilities for corrective actions will be assigned. These corrective actions will be included in the open items list for , statusing at the next meeting (s). , Interactive communications will occur frequently with respect to independent ' assessment feedback to senior Nuclear line management by having the General Manager-Nuclear QA as an integral part of the senior Nuclear management team. The General Manager-Nuclear QA will report on performance trends and the results of program evaluations on a regular basis at senior Nuclear management meetings, and I time will be dedicated to discussing the implications of these trends. As required,

; appropriate corrective actions will also be identified and lead responsibility I

assigned. x 1 i i j { i i l I IMPROVED SELF ASSESSMENT AND PROBLEM RESOLUTION WITHIN THE N'JJLEAR ORGANIZATION 52

SECTION It CORPORATE ACTION 4.0 COMPANY MANAGEMENT OVERSIGHT OF NUCLEAR OPERATIONS In addition to strengthing self assessment capability within the Nuclear l organization, PE has provided for additional independent assessment and oversight and has structured this process to ensure that executive company nanagement and the l Board of Directors receive timely information about nuclear operations so that they can take prompt corrective action if required. M 4.1 NUCLEAR REVIEW BOARD (NRB) ROLE AND REPORTING RELATIONSHIPS The NRB Chairman provides leadership and direction on NRB activities and is assisted I by an appropriate staf f. To ensure that executive management receives timely l infornation about nuclear operations, and is appropriately involved in corrective action, the reporting relationship of the NRB will be elevated to report directly to the Executive Vice President-Nuclear on a regular basis (with copies of written I reports used as the foundation for these discussions to the Office of the Chief Executive Of ficer) . The written reports used in these discussions will also be sent M to the Nuclear Connittee of the Board (discussed in Section 4.4). In addition, the Chairman of the NRB will meet directly with the Chairnan of the Nuclear Committee of the Board, and will report to this Board, at least once annually, w 4.2 NRB MEMBERSHIP The Chairman of the NRB is E. C. Kistner, fornerly Chief Mechanical Engineer of the Company with nore than 20 years of nuclear power plant engineering experience. Biographical data for Mr. Kistner are included in Appendix B. COMPANY MANAGEMENT OVERSIGHT OF NUCLEAR OPERATIONS 53

SECTION I: CORPORATE ACTION s PE has taken steps to strengthen the NRB membership by broadening the organizational areas and expertise represented by PE members and by including respected nuclear executives from outside the company. Outside representation will ensure that dif f erent perspectives are of fered and that lessons learned from the experiences of successfully performing utilities and other outside industry organizations are utilized by PE. The membership will currently include six internal PE members and I three members from outside the company. The internal membership includes: E. C. Kistner, Chairnan of the NRB l E. P. Fogarty, Nuclear Support Manager, Nucl,ar Services D. R. Helwig, General Manager, NQA G.M. Leitch, Vice President-LGS L. B. Pyrih, Manager, Engineering Division of Nuclear Engineering D. M. Smith, Vice President-PBAPS X The outside membership will include Jack R. Calhoun, Dr. William R. Corcoran and Dr. Roger Mattson. Biographical data for these external NRB members are included in Appendix B. 4.3 PROCESSES AND RESOURCES TO BE USED BY THE NRB FOR IMPROVED REVIEW AND ANALYSLR The NRB Chairman will be charged with providing direction to the NRB with respect to the areas of review covered by the Board, and improving the processes used to X enhance the effectiveness of the review function. x COMPANY MANAGEMENT OVERSIGHT OF NUCLEAR OPERATIONS 54 l

   . - , - - - _ . - ~ _ -                                     . ~ .      .-.          .-

l l SECTION Z8 CORPORATE ACTION t i ! Nuclear QA will be charged with providing expanded assistance to NRB members in i analyzing data provided from various sources, and trending the data to identify developing problem patterns for NRB discussion. M To improve the efficiency of the NRB meeting process, agenda items with supportive detail will be distributed to NRB members prior to the monthly meeting. This i supportive detail will include summary reports prepared by Nuclear QA and the NRB l Chairman's staff on topics such asi plant upsets / transients and plant trips; the l results of NRC and industry inspections and reviews (NRC Inspection Reports, SALP, INPO, ANI, etc.); independent safety reviews and assessments; data included in the Nuclear Operations Performance Indicator reports; and external and internal M j operating experience assessment activities. In advance of NRB meetings, each NRB member will be required to review these summary reports independently. 1 , This will facilitate a more comprehensive review of items prior to meetings and provide an opportunity to obtain additional information in an area prior to the meeting if required. Line management, Nuclear QA Performance Assessment Section 1 i staff, ISEG staff, OEAP staff and others will be available at the NRB meetings as

'                  required to provide additional information.                                                       '

i NRB site audit visits will be formalized. A member will visit the site on a l quarterly basis and will audit specific functional areas using a predetermined l checklist. Members will be assigned on a rotating basis. l i i l l 4.4 THE NUCLEAR COMMITTEE OF THE E0ARD OF DIRECTORS (NCB) l } The Board of Directors of PE, at its meeting on October 26, 1987, took action to establish a Nuclear Committee as a standing conmittee of the Board. The charge of COMPANY MANAGEMENT OVERSIGHT OF NUCLEAR OPERATIONS 55

SECTION It CORPORATE ACTION the Nuclear Committee of the Board (NCB) is to advise and assist the Board of Directors in the proper and complete discharge of its responsibilities for oversight of the company's nuclear operations. In the pursuit of its charge, the NCB will review on a continuing basis and report to the full board on: 1) the safety, reliability, and quality of nuclear operatiofis; 2) the effectiveness of t'ha management of nuclear operations; and 3) the effectiveness of management systems for the self-identification of probieras and potential problems, and for prompt and complete corrective actions. The NCB will meet as often 's deemed desirable and will hava a required meeting schedule of not less than voartirly tieslings, Minutes will be n;epared within two weeks of each NCB meeting and copies wii. be distributed to each Director at the next regularly scheduleo meeting of *h; Board. Additionally, the Chairman of the NCB will report to lhl full board at esi.1 regeler2y $pSeduled meeting. Outside technica' experts ei.1 s6evo as adviso70 to the NCB to provide the directors with specialized technical and operr, ting axpe*ier;ra and independent evaluation perspectives. Specific duties of the NCB will include, but r ot be limi ted to the Collowing: Receive and review in a timely fashirn reports of each evaluation by NRC M (including SALP), INPO, and ANI, together with written or verbal reports of nanagement responses. Receive prompt notification of any significant incidents or events.

• 5 Receive and review nonthly report of klart "key indicator" trenc'y enct nenthb. g report "letter" from the Executive Vics Frt;ident-Nucie r t? the Cenirtsn, l
• At least annually, visit and inspect each clant site,
• Meet privately as appropriate with:

Executive Vice President-Nuclear j g 1 COMPANY MANAGEMENT OVERSIGHT OF NUCLEAR OPERATIONS I6 i b; 1 u

SECTION It CORPORATE ACTION Vice Presidents-PBAPS and LGS Clairnan-NRB General Manager-Nuclecr QA Manager-Internal Auditing Administrator-NRC Region I (or designated representative) President-INPO (or designated representative) Co-Owners' designated representatives The NCB will thus provide general independent oversight of all nuclear and nuclear-related operations of the Company to assess safety, quality and excellence. The Connittee will serve as the top nost level of a structured self-assessment process, independent of line managenent, which assures the ability of PE to self identify pr+blems and implement tinely and ef fective corrective actions. In.ornation flows will link the Nuclear QA organization to the NRB, and link both I independent assessment groups to the NCB. On-site plant inspections and I face-to-face interviews with key managers will keep the NCB directly in touch with site operations as well. This structured independent assessment process has been de signed to help assure the capability of line nanagement to identify problens pronptly, analyze and address them effectively, and nonitor and evaluate the results of corrective actions. 4.5 NCB MEMBERSHIP NCB nenbership will consist of not more than four non employee directors, one of whom will be designated Chairman, In addition, one or more outside experts will serve as advisors to the committee. COMPANY f1ANAGEMENT OVERSIGHT OF NUCLEAR OPERATIONS 57

1 SECTION It CORPORATE ACTION Effective April 13, 1988, the following Directors will serve on the NCB l Robert D. Harrison Hi,11iam S. Gaither l Edithe J. Levit, M.D. Joseph J. McLaughlin Advisors to the NCB will include Eugene P. Hilkinson, Past President of INPO, and Solomon Levy. l 4.6 STAFF AND RESOURCES TO BE USED BY THE NUCLEAR COMMITTEE OF THE BOARD Administrative support for the NCB will be provided by the Company as deemed necessary by the committee. Upon the request of the NCB Chairman, independent consultants will be retained to perform specific studies or analyses as directed by the NCB. The NCB will receive all minutes and reports of the NRB and will meet periodically with the Chairman and/or members of HRB. To the extent practicable, the NCB will use the work of the NRB to minimize duplication of data analyses and review efforts. 4.7 INDEPENDENT ASSESSMENT FEEDBACK LOQE The PE Huclear organizational changes, the strengthening of the ISEG function, the l establishment of a Performance Assessment Section in Nuclear QA, the revised role l l and membership of the NRB, and the establishment of the NCB will significently J improve the independent assessment function of the company so that problems can be COMPANY MAH4GEMENT OVERSIGHT OF NUCLEAR OPERATIONS ,[$4

                                                                                . . p.e

l I SECTION It CORPORATE ACTION promptly identified and elevated to the appropriate level for resolution. The i "Before" and "Af ter" diagrams shown in Figures 7 and 8 on the following two pages illustrate how the independent assessment process has been improved. As shown in the "Before" diagram, the assessment feedback of the Nuclear Operations QA and the Engineering and Research QA organizations was given separately to two different vice presidents. The process for review by corporate management at higher levels was not formally defined. The Nuclear Review Board also repc.-ted at the vice president level, to the Vice President-Nuclear Operations. In contrast, the "After" diagram illustrates:

• One centralized, strengthened Nuclear QA organization monitoring site activities as well as support organization activities, and reporting its independent assessment directly to the Executive Vice President-Huclear. I
• A revised Nuclear Review Board monitoring QA and PORC activities and reporting its independent assessment directly to the Executive Vice President-Nuclear. M i e A new standing Nuclear Conmittee of the Board monitoring the work of the NRB, as well as having direct oversight access to HQA and plant operations, and reporting its independent assessment directly to the full Board of Directors.

This expanded independent assessment process will ensure that senior Nuclear J management, Company management, and the Board of Directors are kept well informed 3 of the status of PE's nuclear activities so that they can take timely corrective action as required to promote excellence in the company's nuclear operations, l, I COMPANY MANAGEMENT OVERSIGHT OF NUCLEAR OPERATIONS 59 1

SECY20N Il CORPORATE ACTION INDEPENDENT ASSESSMENT FUNCTION INFORMATION FLOW AND FEEDBACK LOOP BEFORE Board of Directors CEO/ COO SVP En0 l neerino

                                                          & Production r--------------------------                         -- --      - -     -----
                                                                                  ......[......g
       .....I......                                                                    tJHB         !.

OA(E&R) ! VP En0lneerino VP b' - - - --- T

       ............j       & Research (E&R)          PJuclear Operations j 6fjp[,;g(,a'ilf.

i..O..pe..ra.tlons)

                                                                                   .       ....... i Mana0er tJuclear Generation Mana00'                   PORC             J PBAPS/ LGS legend:
     ,.....)- = Providul0 independent assessment feedback to line and senior mana0ement l

s....... [ j = Information flow and line assessment e-l {,, ,l - = Informahon llow and rnonitorina of the independent assessment functions l l l l Figure 7. Independent Assessnent Function Infornation Flow and Feedback loop l Before 1 COMPAt4Y mat 4AGEMENT OVERSIGHT OF NUCLEAR OPERATIONS 60

i I l SECTION 2: CORPORATE ACTION j l INDEPENDENT ASSESSMENT FUNCTION INFORMATION FLOW AND FEEDBACK LOOP AFTER Board of

• Nuclear Committee  !""""""""1 Directors a e

                                                % . . . .o.f.t.h.e. B. .o.a.r.d.

l . . . e: " "l 9 l l l CEO/ COO j j NUCLEAR REVIEW ,....j i BOARD EVP Nuclear j j I NUCLEAR  : I OUAUTY ***** J ASSURANCE  : ,,,,;,,,,, VP PBAPS/ LGS  :  : l  : . . . :. . . , Plant Manager - PORC  : lPBAPS:i....., aLGS: PBAPS/ LGS """a ...oo. 'no. Legend:

             ......;       = Providing independent assessment feedback to line and senior management       1
                           = Information flow and line assessment                                          I l      j

= Information flow and monitoring of the independent assessment functions s......P"*

l l Figure 8. Independent Assessment Function Infornation Flow and Feedback Loop After l l i COMPANY mat 4AGEMEtiT OVERSIGHT OF NUCLEAR OPERATIONS 61 l

SECTION It CORPORATE ACTION 5.0 CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 T PE recognizes the importance of having clearly defined action steps to implement i i its plan for improved corporate nuclear management and to monitor progress toward meeting corrective action objectives. The preceding sections of this Plan have stated these objectives, described the changes to be made to meet the objectives i and explained some of the benefits of the changes. This section correlates with the preceding text by listing the principal corrective actions PE will take to meet these objectives. These actions will all be completed before restart. A. I comprehensive schedule for the major activities is being provided and will be l updated monthly to enable PE and the NRC to monitor progress toward meeting the l

corrective action objectives. A l

I Root Cause 4, and Related Corrective Action Obiectives l As previously stated the fourth root cause was s Corporate manacement failed to recoonize the developino severity of the problens at PBAPS and thus, did not take sufficient corrective actions. l i l The three corrective action objectives which PE established to address this root l l cause ares i ! 1) Change the organizational structure to improve control, accountability and I corporate direction for nuclear operations. l 1

2) Develop the nanagement systems and managerial skills which will strengthen l l 1 self assessment and problem resolution capabilities within the Nuclear l l organization. l

5) Strengthen the independent assessment process to increase upper management's involvement in tinely problem solving.

J CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 62

SECTION It CORPORATE ACTION 52 1 CORRECTIVE ACTIONS TO IMPLEMENT OBJECTIVE 1 To implement Objective 1 ("Change the organizational structure to improve control, I accountability and corporate direction for nuclear operations"), the following l actions will be takeni Establish within the corporate structure a nuclear-dedicated organization with direct line management control over all aspects of nuclear operations, maintenance, engineering, and construction. MAJOR l l ACTIVITY l NUMBER l

• Identify all nuclear dedicated functions which should be CA4-1.1.1 l noved from Engineering and Production to the new Huclear organization.
• Develop and implement an organizational reporting structure CA4-1.1.2 l for Nuclear.
• Assign personnel to all Nuclear management positions to the CA4-1.1.3 l senior engineer level.
• Develop and document a set of top-level Nuclear nanagement CA4-1,1.4 l and operating policies.
• Develop nission statements f or the Nuclear organization and CA4-1.1.5 l each organization reporting to the Executive Vice l President-Nuclear. l l
• Review and revise all necessary corporate personnel CA4-1.1.6 l policies to reflect the new organizational structure and ensure that Nuclear nanagement has all appropriate authorities.
• Document Nuclear Services responsibilities with respect to CA4-1.1.7 l interface with corporate Personnel and Industrial Relations on personnel management issues.
• Conduct a series of on-site and off-site tean-building CA4-1.1.8 l l meetings with the Nuclear nanagement team to: 1) review all l

assigned functional responsibilities 2) identify and ' address unassigned progrannatic items; 3) clarify interface responsibilities; and 4) agree on specific objectives for cultural change within the Nuclear organization. Use results of meetings to develop a Transition nanagement plan.

• Inplement a transition nanagement process that will track CA4-1.1.9 l reorganization progress, and identify and resolve transition issues in a tinely nanner.

CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 65

SECTION It CORPORATE ACTION ' Shorten and strengthen the nuclear chain of commands provide on-site corporate direction and overview at the vice president level for all station activities. MAJOR l ACTIVITY l NUMBER l l

• Eliminate the positions of Vice President-Nuclear CA4-1.2.1 l Operations, and Manager, Nuclear Generation.
• Establish the positions of Vice President-PBAPS and Vice CA4-1.2.2 l President-LOS, i
• Locate site Vice President organizations at the nuclear CA4-1.2.3 l sites.
• Establish a regular staf f meeting process for the Executive l CA4-1.2.4 l Vice President-Nuclear and his direct reports to ensure timely communications and problem solving about nuclear operational concerns.

Clarify and document management authorities and accountabilities. MAJOR l ACTIVITY l t HUMBER l Redefine functional responsibilities and develop and CA4-1.3.1 l , document transitional interface agreements to be used as interim procedures for the following programs and functions:

                             - Operating Experience Assessment Program
                             -  Commitment Management
                             -  Configuration Management
                             -  System Engineering                                                                                   j
                             -  Project Engineering
                             -  Materials Management 1

Integrated Managenent Program  !

                             - Capital and expense budget development /

cost tracking / cost control for Nuclear

                             - ISEG

• Revise and/or develop position descriptions for each CA4-1,3.2 l

 !                Nuclear management position down to the Responsible Senior 2

Engineer level to reflect mission statements, and interface responsibility / authority agreements. CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 64 I

                                                                                             .- ,      -n--.-              .

SECTION It CORPORATE ACTION Ensure that employees assigned to site work locations on a permanent basis are accountable to the site vice presidents, except for those personnel responsible for , independent corporate assessment and oversight activities. MAJOR I ACTIVITY l NUMBER l

• Reassign site-dedicated maintenance, maintenance testing, CA4-1.4.1 l and construction personnel to site organizations and payrolls (except for those personnel who will continue to work on the Limerick Unit 2 Project through fuel load.)

5.2 CORRECTIVE ACTIONS TO IMPLEMENT OBJECTIVE 2 To address Objective 2 ("Develop the management systems and managerial skills which will strengthen self-assessment and problem resolution capabilities within the l Nuclear organization") the following actions will be taken Establish a strong management philosophy for assurance of quality. MAJOR l ACTIVITY l NUMBER l

• Develop and document a statement of Nuclear management's CA4-2.1.1 l philosophy and expectations for assurance of quality.
• Communicate this statement by publishing it in company / site CA4-2.1.2 l newspapers, displaying it on corporate and site bulletin

, boards, incorporating it into OET training, and referring i to it in discussions with Nuclear employees. , l 1 Develop and implement a Nuclear Performance Management Program for Excellence. MAJOR l ACTIVITY l NUMBER l l e Develop and document a set of Nuclear organization CA4-2.2.1 l performance goals.

• Identify the performance indicators to be used for CA4-2,2.2 l l monitoring and assessment purposes; include comparisons l with benchmark peer plant perfornance trends. l 1

I CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 65 l i l

1 SECTION It CORPORATE ACTION 4 MAJOR l ACTIVITY 4 l NUMBER l Develop and document performance goals and indicators which CA4-2.2.3 l support Nuclear objectives for each Division within the Nuclear organization.

• Develop and document agreements with respect to managenent CA4-2,2.4 l '

and staff responsibilities for monitoring and reporting progress on meeting objectives.

• Initiate the Nuclear Performance Managenent Program CA4-2,2.5 l throughout the Nuclear organization, including management conmunications with Nuclear employees to ensure understanding of and commitment to Nuclear goals.

Centralize, strengthen and elevate Quality Assurance's (QA's) role in the Nuclear organization. MAJOR l ACTIVITY l NUMBER l

• Establish the reporting structure for a centralized Nuclear CA4-2.3.1 l Quality Assurance (QA) function within the Nuclear organization.
• Assign personnel to all Nuclear QA management positions. CA4-2.3.2 l
• Clarify and document the roles and responsibilities for CA4-2.3.3 l each Nuclear QA function.
• Clarify and document the reporting responsibilities of CA4-2.3.4 l l Nuclear QA with line managers, the F.xecutive Vice l President-Nuclear, and the NRB.

Strengthen the Operating Experience Assessment Program (CEAP). i MAJOR l j ACTIVITY l

'                                                                                                                   NUMBER    l          !

i

• Define and assign the OEAP management function within the CA4-2.4.1 l l Nuclear Support organization. '

1 j 't I CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 66

SECTION It CORP 0AA1E ACTION MAJOR l ACTIVITY l NUMBER l

• Clarify and document the interface responsibilities of the CA4-2.4.2 l OEAP manager, ISEG, the Site Regulatory Engineer,and other

Nuclear managers with respect to providing input to the l OEAPJ evaluating DEAP information to determine any ,

corrective action requirements; implementing corrective actions; tracking corrective action status; and assessing the effectiveness of corrective actions.

• Initiate the revised OEAP. CA4-2.4.3 l Improve the Commitment Tracking Program. l MAJOR l

, ACTIVITY l NUMBER l

• Clarify and document the responsibilities of the Licensing l CA4-2.5.1 l Manager in Nuclear Support. I
• Clarify and document line management responsibilities for CA4-2.5.2 l commitment management.
• Develop and document interface agreements between line l CA4-2.5.3 l management and the Licensing Manager for the commitment l management process.
• Initiate the revised Commitment Tracking Program. l CA4-2.5.4 l Establish effective information management and reporting systems to support problem identification and corrective action follow-up by nuclear management.

4 MAJOR l ACTIVITY l NUMBER l

• Identify and prioritize needs for improved Nuclear program CA4-2.6.1 l and work management processes.
• Develop and initiate a plan for management process CA4-2.6.2 l assessment and information management improvement.

1 e Initiate improvements to the Nuclear Performance Monthly CA4-2.6.3 l Reports, with emphasis on additional performance

;                        measurement criteria and more timely deviation status reporting.                                                                            1 I

J CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 67

  . - _  ._ _ _.          . _ _ . - .. _ _-                       _._.___ _     m . __.       . .,

I l I SECTION It CORPORATE ACTION l Ensure that the development and training needs of nuclear managers are identified and addressed in a timely manner. I I MAJOR l ACTIVITY l - NUMBER l

• Establish the Nuclear Training organization within Nuclear CA4-2.7.1 l t Services, including the reporting structure and the responsibilities of each organizational unit.
• Clarify and document transitional interface agreements to CA4-2.7.2 l be used as interim policies and processes for the

. development, assessment, evaluation and upgrading of Nuclear training programs.

• Initiate a program to determine the core management CA4-2.7.3 l competencies required for Nuclear management positions.
• Identify priorities for the development of new training and CA4-2.7.4 l development programs for Nuclear nanagers and supervisors, i and develop a plaii to address these priorities.
• Initiate training and/or coaching for Nuclear managers in CA4-2.7.5 l the effective use of the personnel performance evaluation ,

I review process within the next year. Establish interactive communication and problem-sc1ving processes between nuclear l i off-site and site personnel to ensure effective corporate direction and oversight , of plant programs. MAJOR. l ACTIVITY l NUMBER l } e Establish written guidelines for Nuclear Services personnel CA4-2.8.1 l and relevant site personnel with respect to meetings, timely communications, problem identification and analysis, and follow-up corrective actions in the following areasi I regulatory and INPO interface i

                    - plant chemistry J                    -

radiological protection

                    - radwaste management                                                             i i                    - emergency preparedness                                                          1
!                   -   fuel management

] security and safeguards CA4-2.8.2 l Initante a managener.t monitoring process to ensure that j these guidelines are followed.

                                                                                                      )

i CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 68 , 4 i

SECTION 18 CORPORATE ACTION  ! l i  ; MAJOR l l ACTIVITY l l NUMBER l

• Establish guidelines for Nuclear Engineering personnel and CA4-2.8.3 l  !

relevant site personnel with respect to meetings, timely communications, problem identification and analysis, and 1 follow-up corrective actions in the areas ofi  ; plant systems monitoring  :

                        - plant equipment, systems or procedure problems requiring corrective action                                                                           -

J - planned corrective actions and/or problems with follow-up on corrective actions.

• Initiate a management monitoring process to ensure CA4-2.8.4 l i that these guidelines are followed.  !
• Continue Executive Vice President-Nuclear site meetings. l CA4-2.8.5 l t

I Establish interactive communication and problem-solving processes between line management and independent assessment organizations to jointly review independent feedback; identify problems needing line management attention) and develop follow-up corrective action plans, l t MAJOR l  ;

,                                                                                                                       ACTIVITY l        l NUMBER         l l                                                                                                                                        ,

• Establish Nuclear QA reporting as a routine agenda item at CA4-2.9.2 l' Executive Vice President-Nuclear meetings. l ,
• DELETED M CA4-2.9.2 l  !

53 CORRECTIVE ACTIONS TO IMPLEMENT OBJECTIVE 3 a  ! 2 To address Objective 3 ("Strengthen the independent assessment process to increase l . upper management's involvement in timely problem-solving"), the following actions will be taken: 1 i i i i CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 69 l

i

i SECTION 19 CORPORATE ACTION j ' Revise the Nuclear Review Board (NRB) charter to better encompass technical safety l concerns. l

MAJOR l ACTIVITY l NUMBER l t

1 I

• Revise the NRB charter to better define the scope of review l CA4-3.1.1 l

 ;                                                             activities, and obtain all necessary approvals.

• Define and document the responsibilities of the position  ! CA4-3.1.2 l -

of the NRB Chairman. l 9 i

• DELETED M CA4-3.1.3 l
• Develop and dccument additional NRB processes for proactive CA4-3.1.4 l investigation of safety-related concerns. i
• Clarify and document the reporting responsibilities of the CA4-3.1.5 l PORC Chairman and Nuclear QA with respect to the NRB. l
• Establish reporting and meeting guidelines for the NRB. CA4-3.1.6.]

i Elevate the reporting level of the NRR and include outside erpartise in its membership. , 4  : MAJOR l ACTIVITY l ' t j NUMBER l 1 1

• i Establish an organizational structure which provides for CA4-3.2.1 l '

the NRB to have a direct reporting relationship to the l 2 Executive Vice President-Nuclear. M

• Establish and appoint the membership of the NRB to include CA4-3.2.2 l ,

six internal PE members and three members from outside PE l  ; with recognized nuclear industry experience. Establish a permanent committee of the Board of Directors, with outside expertise j serving in an advisory role, to provide oversight of nuclear operations. I i MAJOR l ACTIVITY l NUMBER l l

• Establish the Nuclear Committee (NCB) as a standing CA4-3.3.1 l committee of the Board of Directors. l
• Develop the charter of the NCB and obtain full Board CA4-3.3.2 l l approval.

CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 70 l I I

   - - _ . .            . . . _ , - .                    .- - -               - . - . .        .- , - - - - _ , - _ _ - - _ . -          - - _.       - -         _.     ~

j. SECTION It CORPORATE ACTION - MAJOR l ACTIVITY l MIRE 8 1

• Establish and appoint NCB membership. .'CA4-3.3.3 l
• Contract with one or more outside experts to serve as {0A4-3.3.4 l advisors to the committee.
• Establish review procedures for the NCB including document CA4-3.3.5 l review, site inspections, and meetings with senior Nuclear management, independent assessment groups, regulatory and industry personnel, and PBAPS co owners.
• Develop and document the reporting responsibilities of CA4-3.3.6 l senior Nuclear management and the NRB with respect to the NCB.

DELETED a MAJOR l , ACTIVITY l NUMBER l

• DELETED

                                                                          , t{,CA4-3.4.1 1

• DELETED

                                                                            # CA4-3.4.2 l

• DELETED 4 x CA4-3.4.3 l

                                                                                                      '\

g. CORRECTIVE ACTIONS TO ADDRESS ROOT CAUSE 4 71

SECTION I CORPORATE AC7 ION APPENDIXES d

              /

I 1 i ( 1 l l APPENDIXES 72

7 SECTION Il CORPORATE ACTION APPENDIX A. FUNCTIONAL CRGANIZATION CHARTS FOR SITE PLANT, PROJECT, SUPPORT AND TRAININO OROANIZATIONS i i I I I l i [ t v Appendix A. FUNCTIO *4AL ORGANIZATION CHARTS FOR SITE PLANT. PROJECI, SUPPORT AND TRAINING OROANIZATIONS / 73

                                                                -           .. . - ,-.       - ~    _

                                                             =,

C7 Ea

                                                            =x                                                                                                                                                                                                              -

Z>

                                                           =.

O g' FUNCTIONAL ORGANIZATION CHART E

                                                          =3                   0 FOR PLANT MANAGER N=

oo Ptant Manager Go 4 N m

                                                                             >                                                                                                                                                                                           o
                                                                            -*                                                                                                                                                                                           -4
                                                                            ~                                                                                                                                                                                            M o
                                                                            =                                                                                                                                                                                            O Maintenance /

O Plant " instrumentathn Technical Operahons "

                                                                            >                                                           Services
                                                                                                           & Control                                                                                                                                                     o 3                                                                                                                                                                                             o m

u Maintenance Chemistry Regulatory Shift Operarons

• Preventive Maintenance
• Radiochemistry o
• Regulatory and INPO
• Shaft Management
• ElectncalMaintenance - Plant Crem stry $

w (except 15C) - ChemealControl interface

                                                                                                                                                                 - LER Program

• STAS y

                                                                         ~                                Mechanical Maintenance

• Commitment Operations Support m -

MOV ma:ntenance Health Physics o Traciong Blocking Coordination

                                                                         ,                                and LLRT

• ALARA
• Operahng Experience d

g

• Shift Training and 9

                                                                         =                                                                                          Assessment Program   Administration
                                                                        "                              Instrumentation a Control     Radwaste

• Cahbraton
• Fire Protecton

                                                                                                                                     - Radwaste operation       Technical
                                                                        ,

• Testing management
• System Engineering g
• Repair
• Radwaste Disposal
• Reactor Engineenng u a Computer Activstles
• Plant Housekeeping
• Test Engineenng 3

                                                                                                       - Survedlance

• Computer Engineering M

C

                                                                      ~3 "U

o

                                                ~

46

SECTIOil It CORPORATE ACTION FUNCTIONAL ORGANIZATION CHART FOR SITE PROJECT MANAGER Project Manager i Planning, Outages Scheduling Modifications Materials

                                    & Reporting                                            Management

• Outage Olroctkwi
• Integrated Planning /
• Fleid En0 lneering
• Purchasing coordination Scheduling - Mod Change
• Area Work Coor. - Outago nosolution
• Stores / Spare Paris dinalion - Mods - Mod Checkout

         - Drywell,00P,          - Mini outago                                         a Materials NSSS, Refueling     - Maintenance /1&C                                       Engineering

• Modifications F kx>r
• Wo;k managomont/
• Minor Mod Engineering
• Outage Work control in coor-Conflici dlnation with ILS
• Major Mod Coordination
• fotograted ReportinD
• Technical Direction - Plant Performance
• Construction. Including to contractors - Management - checkout / testing for outage work Heports - tracking / records

                                 - Data System                - closecut Management

• Tochnical administration of modibcallon contracts and direction of contract personnel for modihcations l

l 1 l l l l l Appendix A. FUNCTIONAL OROAllIZATI0il CNARTS FOR SliE PLAlli, PROJECT, SUPPORT AllD TRAINIllG OROANIZATI0ilS 75

SECTI0t{ It CORPORATE ACTION FUNCTIONAL ORGANIZATION CHART FOR SITE SUPPORT MANAGER Support Manager Security 0ud001/ Cost Administrallon Personnel ' Contsol

• Site Security
• OAM/ Capital
• Procedure
• Site Access

        - Protected Area       BudDot & Cost
        - All Site Proporty                               Adtninistratlori                    Coordinal'on TeacMno/ Control          - Milntenance
                                                         - Hoproducilon

• Medical
• Genernicontracts - Distritautlori administration
• Personnel
• Document Control Adminisfrallon Center - Re ords

                                                         - Station Lit >rary                 - Payroll
                                                                                             - Denellis Counseling

• Records Management
• Industrial Helations
• Emer0ency Prop. - Grievances and Planning complaints
• IndustrialSafety
• Performance Review Progeam System

                                                                                            - Coordinnilon and

• Employco f.?onitoring Communicallons
• Ollice Services e facilities Coordination

                                                        - Phones
                                                        - Space
                                                        - Eriuipment

• 13uilding Maintenance Appendix A.

FUllCTIONAL ORGANIZAT10il CHARTS FOR SITE PLAlli, PROJECT, SUPPORT AtlD TRAllilllG ORGANIZA110NS 76

l l l SECTIOff It CORPORATE ACTI0tl l FUNCTIONAL ORGANIZATION CHART FOR SITE TRAINING SUPERINTENDENT Vice President - PGAPS/ LGS Corporate fluclear

                                               ,............      Training
                                               !                  Division Training Superintendent
                               + Identify programmatic training needs for all slio personnel

• Develop and provide tralning for.

                                  - Licensed operators
                                  - tJoo-licensed operators
                                  - Chemistry
                                  - IIP
                                  - GET/GTIF
                                  - First Aid

• Schodutos/coordinatos training for.

                                  - Maintent.cco
                                  - l&C
                                  - Construction
                                  - Professional (Engineering)
                                   - Emorgency Planning
                                   - Fitnoss for Duty
                                  - Fire Sclxx>l
                                   - Fito Drifts

• Monitors ellectiveness of all training /

kipuls to corporalo

                                + Feeds back operating exporlonce into                ;

training (mods, proceduro changes)

                                + Monitors participation of sito personnet            I hi training                                        )

l

• Ilesponsibfo for silo simulator l l

Appendix A. FUllCT10tlAl ORGAtlIZATIOil CHARTS FOR SITE PL AtlT, PROJECT, SUPPORT APID TRAlllll10 ORGAlll2ATI0fts 77

l SECTION Is CORPORATE ACTION APPENDIX B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS l I Appendix B. BIOGRAPHICAL DATA FOR HUCLEAR MANAGERS 78

SECTION Il CORPORATE ACTION Joseph F. Paquette, Jr., President and Chief Operatina Officer, was elected to this l position when he rejoined PE in March,1988. I Mr. Paquette was previously employed by PE for 30 years, beginning in 1956. He was i f I i appointed Manager of its Financial Division in 1969, Controller in 1971, Manager i of Finance and Accounting in 1972 and Vice President, Finance and Accounting l Department in April,1978. In April, 1986, Mr. Paquette lef t PE to become Executive l Vice President and Chief Financial Of ficer for Consumers Power Company, Jackson, 1 Michigan. In February, 1987, he was elected Vice Chairman and in December, 1987, I was elected President of CMS Energy Corporation and President and Chief Operating l Of ficer of its principal subsidiary, Consumers Power Company. l Mr. Paquette earned a Bachelor's Degree in Civil Engineering from Yale University l in 1956. He completed varicus courses in finance, accounting and economics at l Temple University's Evening Graduate School. l Mr. Paquette is a member of the Financial Executives Institute. Mr. Paquette has l previously served on the Board of Directors of th,e Old Kent Financial Corporation, 1 First Pennsylvania Bank and the First Pennsylvania Corporation, the Keystone l Automobile Club and the Keystone Insurance Company. l Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 79

SECTION 18 CORPORATE ACTION Senior Nuclear Manaaenent Tean l Corbin A. McNeill, Jr.. Executive Vice President-Nuclear, w s elected to this l position for Philadelphia Electric Company in March,1988. I:s is responsible for 1 all aspects of operation and engineering of PE's four nuclear plants: Peach Bottom 1 2 and 3 and Limerick 1 and 2. l Mr. McNeill completed a twenty year career with the U.S. Navy in 1981 af ter serving i as Commanding Officer of the USS Tautog (SSN 639) and Commanding Officer of the l Naval Nuclear Power School. Mr. McNeill joined the New York Power Authority as l Resident Manager of the James A. FitzPatrick Nuclear Power Power Plant in 1981 and I subsequently was named Senior Vice President-Nuclear Generation. He joined Public l Service Electric and Gas Company as Vice President-Nuclear in March, 1985, and was I appointed Senior Vice President-Nuclear in April, 1987. l Mr. McNeill received his Bachelor of Science Degree in 1962 from the U.S. Naval l Academy and has completed graduate courses in business at the University of I California (Berkeley) and Syracuse University. I John S. Kenper, Senior Vice President-Nuclear, received his Electrical Engineering i degree from the University of Pennsylvania in 1950 and was employed by PE as a fossil power plant test engineer. From 1951-1953, he served in the United States Army in l l l the radiological division of the Chemical Corps. He completed the first atonic power training program for Utility Engineers at Shippingport, and in 1959 was loaned to Detroit Edison Company as a shif t supervisor at the Enrico Fermi fast breeder plant where he completed the reactor operator training program. He was then assigned to General Atonic, the designer of the Peach Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 80

SECTION Il CORPORATE ACTION Bottom Unit 1 HTGR, where he worked with the designers in the development of the training program and operating procedures for that station. Named Superintendent of Peach Bottom Unit 1, he was in charge of the start-up, power ascension program and commercial operation of that station. Following this assignment, he becamo the Manager, and, later, Vice President of the Engineering and Research Department, where his principal responsibilities included the design, construction, and start-up of Peach Bottom Units 2 and 3 and Limerick Units 1 and 2. In 1986, he became Senior Vice President of the Engineering and Production Department. Mr. Kemper is a member of Institute of Electrical and Electronic Engineers, American Nuclear Society, Eta Kappa Nu, and the Nuclear Power Division Committee of the , Electric Power Research Institute. He has served on several nuclear advisory committees for the utility industry. He is a Registered Professional Engineer in Pennsylvania, and in 1986, was named Engineer of the Year for the Grea ter Delaware Valley. Dickinson M. Snith, Vice President-PBAPS, a retired Rear Admiral, United States Navy, brought over twenty-five years of nuclear experience to the position of Plant Manager, PBAPS when he joined PE in May, 1987. At the time of his retirement from the Navy in 1986, Mr. Smith served as Chief of Staf f, Allied Command Atlantic, where he directed an international military staff of 450 from eleven NATO nations. Prior to his Atlantic Command, Mr. Smith was Senior Military Commander in the Philippines, managing the largest U.S. naval installation overseas with a total military and civilian workforce of 35,000. Appendix B. BIOGRAPHICAL DATA FOR HUCLEAR MANAGERS 81

SECTION I CORPORATE ACTION Mr. Smith's nuclear responsibilities with the Navy began in 1959. Over the next 14 years, he served on, or commanded, several nuclear submarines. Between 1973 and 1979, Mr. Smith held a number of senior military positions, which included the training for and operation of nuclear submarines. He also served as a senior military staff assistant to Admiral H. G. Rickover. Mr. Smith graduated from the U.S. Naval Academy in 1955 with a B.S. degree. He also holds a Master of Public Administration degree from The American University. Graham M. Leitch, Vice President and Plant Manaoer-LGS received a B.S. and an M.S. I degree in Mechanical Engineering from Drexel University. He joined PE in 1956, and held increasingly responsible positions in fossil power plants including serving as Assistant Superintendent at the Eddystone and Barbadoes Stations and as Superintendent, Barbadoes Station. He served on the PE HRB from 1970 to 1975, and the . tions and Safety Review Committee at PBAPS from 1972 to 1976. In June,

1. sas named Plant Superintendent, LGS and served in that capacity through construction, start-up and commercial operation of Unit 1. In April, 1986, he was appointed Superintendent, Nuclear Generation Department and in November, 1986 he 1

became the Manager, Nuclear Generation Department. Mr. Leitch is currently a member of the Industry Review Committee for the Training and Education Division of INPO. l l Joseph W. Gallacher, Vice President-Nuclear Services, joined PE in 1950 after graduating from Villanova University with a B.S. in Electrical Engineering. Mr. Gallagher's 37 years with PE have included experience in planning, design, construction, maintenance, and operation of the company's generation and transmission facilities, with assignments in System Planning as Branch Head; General j I Administration as Assistant to the Vice Presidents System Operation as ' l Appendix B. BIOGRAPHICAL DATA FOR HUCLEAR MANAGERS 82

                                                                                                                              \
 .- ,,    . . , - . ,           - - - ,   -   -- -         ---                                          ~,~       +           J

m SECTION IS CORPORATE ACTION Superintendent; Maintenance Division as General Superintendent; Electric Production 4 as Manager; Engineering and Research as Managers and Vice President-Nuclear Operations. Mr. Gallagher is a Registered Professional Engineer in Pennsylvania and has completed various management programs including the Cornell Executive Development Program and the Edison Electric Institute Executive Management Program. He was a member of the PE NRB for nine years, serving as Chairman from 1978-86. S. Joseph Kowalski, Vice President-Nuclear Enaineerina received his B.S. in Mechanical Engineering from Drexel University in 1951. Starting his 36 year career with PE in the Mechanical Engineering Division, he served in a variety of roles including Project Manager for PDAPS Units 2 and 3; Resident Project Manager at the Bechtel Office in San Francisco; Engineer-in-Charge of the power plant services I section; Assistant Chief Mechanical Engineer; and Chief Mechanical Engineer. In November, 1986, he was appointed Vice President-Engineering and Research. Mr. Kowalski is a Registered Professional Engineer in Pennsylvania and has completed + various management programs including the Cornell Executive Management Program. He serves on the Board of Directors and the Executive Committee of the American Nuclear Society and is a member of the Electric Apparatus Committee of the Association of the Edison Illuminating Compe.nies. l David R. Helwia, General Manaaer-Nuclear Quality Assurance, joined PE in 1973 af ter graduating fron the University of Delaware with a B.S. in Mechanical Engineering. He received a M.S. in Mechanical Engineering from the University of Pennsylvania in 1977, and is a Registered Professional Engineer in Pennsylvania. Mr. Helwig has been actively involved in local and national activities associated with the American Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 83

i ( SECTION 18 CORPORATE ACTION - Nuclear Society, the American Society of Mechanical Engineers, and the Atomic Industrial Forum. He served as chairman of the Boiling Water Reactor Owner's Group for a number of years. He has also been a member of the Electric Power Rosearch Institute's Materials and Systems Task Force and the PE NRB, Mr. Helwig's career has included assignments, within the Mechanical Engineering Division, which have encompassed aspects of engineering and management related to plant design, construction, startup, licensing, and operations support. He held the positions of Engineer, Senior Engineer, Branch Head-Power Plant Services, and Fngineer-in-Charge-Power Plant Design Section. s i 1 l l l Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 84

SRCTION It CORPORATE ACTION PEAPS 3ite Manacement Tean 19hn_f Fra.ntdaji t Ma na a e r- P B A PS , j o i n e d P E i n 196 2. Beginning in 1963, he served l in supervisory positions at PBAPS Unit 1 and, later, at Units 2 and 3. In February, l 1976, he was named Assistant Superintendent of LGS, and remained in that position l ,t through March, 1985, when he was assigned as Superintendent-Operations. In April, 1 1986, he was appointed Plant Manager of LOS where he served until December, 1987, l when he accepted the Plant Manager-PBAPS position. He received a B.S. in Mechanical l Engineering from Drexel University and participated in the G.E. Station Nuclear i Managenent School. He is a Registered Professional Engineer in the Commonwealth 1 of Pennsylvania and has held an NRC Senior Reactor Operator License on PBAPS Units l 1, 2 and 3, and LGS Unit 1. I Kenneth Powers, Proiect Manaaer-PBAPS, recently joined PE, bringing 18 years of experience in engineering, administration and cost control, scheduling, Navy nuclear submarine duty an. quality control experience in the automotive industry to his nen position. Mr. Powers received his B.S. in Industrial Engineering from General Motors Institute. He was Lead Planner for Westinghouse /Tenneco's floating nuclear plant, Lead Cost Engineer and the Piping Superintendent for Fluor, Chief Planning Engineer at Lsguna Verde, WNP-2, and Oak Ridge. He worked for Bechtel from 1978 to 1985 in a variety of positions; Cost / Schedule Supervisor at LGS and Ann Arbor, MI., as Technical Services Manager, and Project Field Engineer at LOS. In 1985, he became Project Engineering Manager at Seabrook, NH for United Engineers and Constructors, returning to Bechtel in 1986 as Project Field Engineer at LGS. He is a qua li fi ed Nuclear Senior Ship Superintendent, United States Navy and a Certified Cost Engineer, American Association of Cost Engineers. Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 85

SECTION I CORPORATE ACTION David R. Meyers, Support Manaaer, received a B.S. in Mechanical Engineering from l the University of Delaware in 1964 and an M.S. in Mechanical Engineering from Drexel l University in 1970. In 1979, he earned an MBA from Drexel University. During his l 23 years of experience with PE, he has progressed from Junior Engineer in Training l to Engineer-Plant Tests, Engineer-Economy Division and System Operation, Results l Engineer for the Chester and Cromby Stations and Senior Engineer in the System l Operation Division. Most recently, he served as Assistant Superintendent, Delaware l Station, where he initiated and successfully completed several cost-saving l programs. He has taken company-sponsored management courses and is a past l Vice-Chairman and Chairman of the Pennsylvania Electric Association's System l Operation Committee. A recognized leader in his community, he has been a member l l of the School Board for the Centennial School District for eight years, serving two l l years as Vice President and two years as President. l ) Ernest A. Till. Site Trainino Superintendent, who retired from the U.S. Navy in 1984 1 after 33 years of service, brings to his position at PE a varied background in i nuclear training in the industry. As a career Naval Officer, he was involved in i i the management of technical facilities serving as Staff and Action Officer, Office l l l of the Chief of Naval Operations at the Pentagon; as Chief of Staff, Submarines l l l Mediterranean in Naples, Italy; as Commanding Of ficer of the nuclear submarine, the 1 USS Woodrow Wilson; and Chief Engineer of the USS Lafayette. Mr. Till was Director I of the Mathematics and Science faculty at the U.S. Naval Academy in Annapolis, l Maryland from 1974-77, where he administered the academic affairs of five technical l departments. He most recently served (1986-87) at Illinois Power Company's only l nuclear generating station, where he instituted major changes in the training I department organization to ensure success of operational, maintenance, and general l training programs, including maintainiiig INPO accreditation. At Clinton Power 1 Appendix B. DI0 GRAPHICAL DATA FOR NUCLEAR MANAGERS 86

SECTION It CORPORATE ACTION Station, he also served as head of the Emergency Planning organization. Mr. Till l graduated from the Norwegian Defense College in Oslo, Norway, attended Defense l Attache Training in Nashington, D.C., the Nuclear Power School in New London, l Connecticut, completed the Atomic Energy Commission Training Program on Nuclear l Power Plant Operations and received a B.S. from the University of Pennsylvania. I ( Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 87

SECTION It CORPORATE ACTION LGS Site Manacement Team M Edward F. Sproat, III, Proiect Manaaer-LGS, joined PE in 1973 as an assistant electrical engineer at LGS. From 1978 to 1980, he was assigned to Gas Cooled Reactor Associates in La Jolla, California, where he performed technical and marketing studies for the High Temperature Gas Cooled Reactor. He returned to PE in 1980 and was appointed Electrical Project Engineer for Limerick, responsible for design and licensing of the electrical systems. He was appointed Supervisory Engineer of the l ( Nuclear Generation Branch in the Electrical Engineering Division in 1984 and in 1986 1 assumed the responsibilities of Engineer-in-Charge, Computer Engineering Section. A Registered Professional Engineer in Pennsylvania he received a B.S. in Electrical Engineering from the University of Pennsylvania in 1973 and is presently a candidate for the M.S. in Dynamics of Organizations at the same university, i Werner T. Ullrich, Manaaer-LGS Unit 2 Start ue, joined PE in 1957 af ter graduating, with a B.S. in Electrical Engineering, from Drexel University and has served in increasingly responsible positions in electrical field engineering and in nuclear power plants. Appointed Superintendent, PBAPS 2 and 3 in 1971, he served in that role until 1984 when he assumed responsibilities as Superintendent, Nuclear Generation Division. In March 1986, he was appointed Superintendent, LGS Unit 2 Project. He serves on the American Nuclear Society-3 Standards ( ANS-3) Subcommittee for Operations and is a member of the Nuclear Power Plant Standards Committee (NUPPSCO), as well as being a member of the PE NRB. From 1981 through 1984, Mr. Ullrich served as a member of the INP0 Board of Directors. James H. Kina, Support Manaaer, LGS, received a B.S. in Electrical Engineering from l Howard University in 1972 and an M.B.A. from Widener University in 1976. In his l 16 years experience with PE he has progressed from an Assistant Engineer in the l Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 88

SECTION It CORPORATE ACTION Engineering and Research Department to Engineer-Suburban Branch, l Engineer-Generation and Transmission Section, Administrative Assistant-Office of l the Vice President for Affirmative Action. Most recently he was appointed Director, 1 Affirmative Action, Personnel and Industrial Relations Department. He was appointed l to the position of Support Manager, LGS, in January, 1988. He has completed the l Penn State Emerging Executive Program. l Edwin G. Firth, Superintendent-Trainino, LGS, received a B.S. in Ocean Engineering l from the U.S. Naval Academy in 1975. He has also attended the U.S. Naval Nuclear l Power Training. He joined PE in 1980 as the Modification Coordinator at PBAPS and I progressed to the Site Emergency Planning Coordinator-PBAPS, Assistant Operations l Engineer-PBAPS, and most recently the Nuclear Training Coordinator-LGS. In his last i position, he was responsible for management, administration, coordination, content, I and technical guidance concerning all licensed and non-licensed operator, plant l , I engineering and management staff, health physics and chemistry technician, l emergency planr.ing, radwaste, and general training programs. I l l l l Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 89

SECTION It CORPORATE ACTION l Nuclear Enaineerina Manacenent Tean j l Thomas P. Gotzis, Manaaer, Nuclear Enaineerina has 32 years of engineering and management experience in PE's Construction Division. Joining PE in 1955 after receiving his B.S. in Civil Engineering from Lehigh University, Mr. Gotzis advanced up the engineering progression and became Assistant Superintendent, Mechanical Construction in 1972. Mr. Gotzis served as the Resident Construction Engineer during construction of the Muddy Run Pumped Storage Plant and Peach Bottom Unit 2 and 3. As Assistant General Superintendent he had managerial authority over the construction of Limerick Units 1 and 2. He is a Registered Professional Enginear in Pennsylvania. Janes J . Clarev, Construction Superintendent LGS-Unit 2, joined PE in 1957 two years af ter he received a B.S. in Civil Engineering from Villanova University and has 30 years of experience in PE's Construction Division beginning as a Junior Engineer and progressing tnrough positions of increasing responsibility in the engineering line. In 1977, Mr. Clarey assumed the position of Assistant Mechanical Superintendent and has since served as Project Manager, (LGS) and Superintendent LGS 2 Project. He is a Registered Professional Engineer in Pennsylvania. Herbert R. Walters, Manaaer, Proiect Manaaenent Division bas over 35 years of engineering experience with PE, joining the Company in 1953 af ter receiving his B.S. in Civil Engineering from Drexel University. From a starting position of junior engineer, he has progressed through a series of increasingly responsible assignnents in the Engineering and Research Department including Project Engineer, Architectural Branch, Industrial Section to Engineer-in-Charge, Industrial Section; QA Manager; Resident Project Manager at Bechtel, San Francisco for the personnel design and construction at LGS. His nost recent position has been as Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 90

SECTION It CORPORATE ACTION Engineer-in-Charge, Project Management Section of the Mechanical Engineering Division. He is a Registered Professional Engineer in New Jersey and Pennsylvania. Lubomir B. Pyrih, Manaaer, Enaineerina Division, brings ?.7 years of experience in PE to his current position. He began his career as a test engineer in a fossil-fueled generating station. Upon transferring to the Mechanical Engineering Division in 1966, he r. ogressed through a series of increasingly responsible assignments, including: Project Engineer of the Muddy Run Pumped-Storage facility; Senior Engineer in the Hydraulics Branch; Supervising Engineer of the Nuclear Steam Supply Branch; and Supervising Engineer of the Nuclear Branch. In 1984, he became Engineer-in-Charge of the Nuclear and Environmental Section and shortly thereaf ter , served as the Engineer-in-Charge of the Power Plant Services Section. In January of 1986, he was promoted to Assistant Chief Mechanical Engineer and most recently served as Chief Mechanical Engineer. Mr. Pyrih holds a B.S. and M.S. degree in Mechanical Engineering from Drexel University and an MBA from LaSalle University. He completed the Cornell Executive Development Program and is a Registered Professional Engineer in Pennsylvania. He is a member of the PE NRB. Edward P. McKeown, Manaaer, Enaineerina Desian Division has 22 years of experience in the design of electrical control systems. Most recently, he hac served PE as the Assistant Chief Design Engineer. Prior to assuming that responsibility, Mr. McKeuwn served as Design Engineer-in-Charge, Electrical Systems and as Nuclear 18C l l Design Supervisor. He has a B.S. in Electrical Engineering from Drexel University l l and is a member of the American Nuclear Society and the Institute of Electrical and l Electronic Engineers. Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 91

   -. ~ _ _ - -

SECTION It CORPORATE ACTION Huclear Services Manaaenent Tean H. H. Traver, Manaaer, Nuclear Maintenance, has over 28 years of increasingly responsible assignments in PE. Af ter joining PE in 1959, following his graduation from Union College with a B.S. in Mechanical Engineering, he started as a plant test engineer, progressed through a series of staff assignments including Station Economy Division, Computer Applications; System Operations Group and Service Division, Cost Section. Management positions have included Assistant Superintendent, Schuylkill Station; Superintendent of Station Section in Maintenance Division, Superintendent, Electrical Section, and finally, Superintendent, Centralized Maintenance Division. E. P. Foaartv, Manaaer Nuclear Support has 23 years of experience in PE starting as an engineer in the Electrical Engineering Division where he was involved in the design of Peach Botton Units 2 and 3. He had further career development through l Research and Testing where he had field assignments supporting the startup of Peach Bottom Units 2 and 3 and Limerick Unit 1. In November,1986 he was promoted to Chief Engineer, Research and Planning. His most recent assignment has been as Project Manager, Peach Bottom Commitment to Excellence Project, reporting directly to the President. Mr. Fogarty received his B.S. in Electrical Engineering from Villanova University and is a Registered Professional Engineer in Pennsylvania and California. I He is a senior member of the Institute of Electrical and Electronics Engineers where { he served seven years as a member of the Nuclear Power Engineering Committee. He is now a member of the Standards Board of the Institute of Electrical and i Electronics Engineers. l Robert H. Goucher, Manaaer-Nuclear Administration, joined PE in 1956 and worked in I the System Planning Division of the Engineering and Research Departnant until 1984. During this 28 year period he advanced through various supervisory positions Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 92

SECTION I CORPORATE ACTION spending the last 5 years of this work as Engineer-in-Charge of the Services and Cost Section. He was appointed Superintendent of the Services Division in the Electric Production Department in 1984. In 1986, the Nuclear Records Section was added to his Division. He received s B.S. in Electrical Engineering and an M.B. A. l from Drexel University and has been a Registered Professional Engineer in Pennsylvania since 1973. Mr. Goucher served as president of the Philadelphia Engineers Club. Appendix B. BIOGRAPHICAL DATA FOR HUCLEAR MANAGERS 95

i l l SECTZON I: CORPORATE ACTION Huclear Quality Assurance Manaaenent Team Robert H. Moore, Assistant General Manaaer, Nuclear QA, has 38 years of experience with PE in the Electric Production Department and Nuclear Operations. He spent 22 l years in the Maintenance Division, serving 5 years as its General Superintendent. Since 1977, Mr. Moore has been Superintendent of the Electric Production /Huclear Operations Quality Assurance Division. He earned a B.S. in Machanical Engineering from Pennsylvania State University and has been a member of the PE HRB since 1983. Janes M. Corcoran, Manaaer, LGS, Quality, has 23 years experience with PE beginning with assignment as as a test engineer in fossil generating stations. He worked in the Electrical Engineering Division on nuclear plant design activities for a number of years and has been involved with PE's Engineering and Research Departments Quality Assurance program for 15 years. During this time he held various supervisory positions at PBAPS during construction and initial operations. He has most recently served as the Engineer-in-Charge for LGS Activities. Mr. Corcoran earned a B.S. in Electrical Engineering from Villanova University and an M.B. A. from Drexel University. He is a Registered Professional Engineer in Pennsylvania and California. J. Theodore Robb, Manaaer. Independent Safety Enaineerina Group, has 21 years experience with PE. Assigned as an engineer in the Mechanical Engineering Department for 8 years, he spent 2 years in the Erigineering and Research Department Quality Assurance organization with responsibilities for LGS activities. Mr. Robb served 5 years in Corporate Analysis and subsidiary organizations and for the past 5 years has been responsible for the Engineering and Research Department licensing activities. He graduated from Rutgers University with a B.S. Civil Engineering Appendix B. BIOGRAPHICAL DATA FOR HUCLEAR MANAGERS 94 i

SECTION Z8 CORPORATE ACTION and received an M.B.A. from Drexel University. He is a Registered Professional Engineer in Pennsylvania. John F. O'Rourke, Manaaer Quality Support, has 15 years expe;ience with PE in the Mechanical Engineering Division. He has a B.S. and M.S. in Mechanical Engineering, and an M.S. in Engineering Management. He held the positions of Engineer; Senior Engineer; Branch Head, Fossil Stean Supply; and Branch Head, Nuclear Services. Mr. O'Rourke is a Registered Professional Engineer in Pennsylvania and has served as Chairman of the Philadelphia Section of the American Society of Mechanical Engineers. J. Michael Pratt, Manager-PBAPS Quality Division, has over 30 years of engineering I and management experience in power generation including 21 years in nuclear power. l His experience includes 23 years with the Royal Navy, retiring as Manager of Nuclear i Popair at Britain's premier nuclear base; 3 years with the South African Electricity l Supply Commission in the seniot management position in nuclear operations and I quality assurance; and 10 years in management and consulting positions in the I donestic nuclear power industry primarily in the areas of QA and QC, During a one I year loaned assignment to INPO, Mr. Pratt was Program Manager for the development I of evaluation performance objectives. Mr. Pratt is currently chairman of the ASQC l Working Committee on Operations QA Surveillance. I l Richard N. Charles, Manager, Performance Assessment Division, received a B.S. from I the U.S. Naval Academy in 1957. He received an M.B.A. in 1984 from the University i of New Haven. Mr. Charles brings to PE almost 30 years of experience in the Nuclear l Navy that included Director Officer Training-Naval Submarine School, Commanding l Of ficer-Mediterranean Nuclear Submarine Repair and Support Tender, Chief Staff l Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 95

   .       . . - . =    _-              .. -           -                                                    -   -    ._-

SECTION It CORPORATE ACTION Officer and Deputy Commander-Submarino Development Squadron Twelve, Commanding l Officer - US9 Parche-Fast Attack Nuclear Submarine, Engineer Officer - USS l Kamehameha - Nuclear Fleet Ballistic Submarine. In addition to the above l assignments, he had direct responsibility for the performance evaluations of the i Force Commander reactor safeguards examinations and radiological practices of all l Pacific fleet submarines and nuclear support facilities (tenders and bases). I Chairman, Nuclear Review Board Mr. Kistner earned a B.S. in Mechanical Engineering from Massachusetts Institute of Te-hnology in 1947, and began his 40 year career with PE in the Mechanical Engineering Division as a junior engineer. He was promoted through increasing levels of responsibility, becoming the Chief Mechanical Engineer in 1969. He remained in this position until 1986, when he became Assistant to the Vice President, Engineering and Research. He has served as a member of the PE NRB since 1969 and as its Chairman since January, 1987. I i Mr. Kistner has been Chairman of the Prime Movers Committee of the Edison Electric Institute, member of the Pennsylvania Boiler Advisory Board, Chairman of the Section I Power Boiler Committee, and a member of the Main Committee of the ASME Boiler and Pressure Vessel Committee. He is a registered Professional Engineer in Pennsylvania. Jack R. Calhoun, NRB is currently the Vice President of Power Management Associates, j i Inc. He has an extensive background in nuclear operations serving as Senior Vice ' President-Nuclear for Pennsylvania Power and Light, and as Director) Nuclear Power Division, TVA. Mr. Calhoun played a key role in achieving commercial operation of . l Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 96 1

SECTION II CORPORATE ACTION ' 1 Susquehanna Units 1 and 2. His nanagerial expertise contributed to the fact that Pennsylvania Power and Light is an industry acclaimed nuclear organization with high ratings by INPO and HRC. Dr. Willian R. Corcoran, NRB is presently an Executive Consultant with IT Delian Corporation. He is a technical leader in the field of nuclear safety with significant contributions in the field of management leadership and team building. He served Combustion Engineering, Inc. as Director of Nuclear Safety, System Engineering, Performance Engineering and Manager of Nuclear Licensing. He is a member of the Nuclear Review Board Safety Committee at the Susquehanna, Pilgrim and the South Texas Project plants. He also serves on the Management Oversight Committee for Commanche Park. Dr. Roaer Mattson, NRB, currently Vice President-Scientech, Inc. is an internationally recognized expert in reactor safety, system design, licensing and nuclear operations. He has extensive experience as an industry consultant for nuclear power plant safety, quality assurance, systems engineering and regulatory reform. He was the Director, Systems Integration and Reactor Safety for the NRC. l Appendix B. BIOGRAPHICAL DATA FOR NUCLEAR MANAGERS 97

SECTION It CORPORATE ACTION APPENDIX C. RELATIONSHIP INDEX (PARTIAL) This chart, and following pages, trace the relationships between: Shut Down Issues (SD), Root Causes (RC), Corrective Action Object!ves (CAD), Corrective Actions (CA) and Major Activities (MA)M. Only Root Cause number four, the focus of Section I, shows the entire relationship chain. The other three oot cause relationships will be daveloped in Section II. Overview ChartMM Shut Down Root Corrective Actic, Corrective Issues Causes Obiectives Actions SD-1 i SD-2 SD-3 SD-4 SD-5 SD-6 RC-4: SD-5, SD-6, SD-7 CA04-1 CA4-1.1 SD-8, SD-9 CA4-1.2 SD-7 CA4-1.3 CA4-1.4 CA04-2 CA4-2.1 SD-8 CA4-2.2 , CA4-2.3 ' SD-9 CA4-2.4 CA4-2.5 CA4-2.6 CA4-2.7 CA4-2.8 CA4-2.9 CA04-3 CA4-3.1 l CA4-3.2  ; CA4-3.3 l l DELETED l M Major Activities support each Corrective Action and therefore have the same relationship to Objectives, Root Causes and Shut Down Issues as the Corrective Action they support. They are identified by code numbers to their Corrective Action. Nu Numbering system and text presented in tne following pages. Appendix C. RELATIONSHIP INDEX (partial) 98

_ - . -. - . _ . _ - . - _ - - ~ .-. . . - . i SECTION IS CORPORATE ACTION Shut Down Issues , SD-1. Operations Control Room staff I reriodically slept or have otherwise been inattentive to licensed duties. SD-2. Pattern of inattention to detail, failure to adhere to procedural requirements, and a generally complacent attitude by the operations staff toward performance of their duties. SD-3. Management at the Shift Supervisor and Shift Superintendent level have either known and condoned the facts (SD-1), or should have known of these facts. SD-4 Plant management above the shift superintendent position either knew or l should have known the facts (in SD-1) and either took no action or inadequate action to correct this situation. SD-5. The licensee must have and implement procedures to ensure that activities affecting quality, including operations of the facility, are satisfactorily accomplished. The Peach Bottom quality assurance program has failed to identify this condition adverse to safety. SD-6. The licensee, through its enforcement ' history and from what has been developed by the ongoing investigation, knew or should have known of the unwillingness or l inability of its operations staff to l conply with Commission requirements, and has been unable to implement effective correctivo action. SD-7. Lack of adequate management involvements poor dissemination of management goals and policies. SD-8. Lack of adequate management involvenenti poor communications between different departments and divisions. SD-9. Lack of adequate management involvement s focus on compliance rather than acknowledgement and correction of the root causes of problems. Appendix C. RELATIONSHIP INDEX (partial) 9-

                                                                         ,._ .~,_   __

i ? t.-/ SECTION I8 CORPORATI ACTION Root Causes RC-1. There was a lack of adequate personal leadership and management skills on the part of senior management at the plent. V , f

                                                  )

P

                                                ?

RC-2. The Company failed to initiate timely licensed operator replacement training programs. RC-3. The station culture, which had its roots in fossil and pre-TMI operations, bad not adapted to changing nuclear requirements. ~ o RC-4 Corporate management failed to recognize the developing severity of the problems at PBAPS end thus, did not take sufficient corrective actions. i l Appendix C. RELATIONSHIP INDEX (partial) 100 t

I i SECTION It CORPORATE ACTION i Corrective Action Obiectives to Address Roo+ Cause RC:s I CA04-1. Change the organizational structure to l i r.p r ov e control, accountability and I corporate direction for nuclear operations. l 1 i CA04-2. Develop the management systems and managerial skills which will strengthen ,- self-assessment and problem resolution capabilities within the Nuclear organization. I a 1 e i I I CA04-3. Strengthen the independent assessment process to increase upper r.anagement's I involvement in timely problem solving. Appendix C. RELATIONSHIP INDEX (partial) 101

si SECTION I! CORPORATE ACTION Corrective Actions to Address Obiective CA04-1 CA4-1.1 Establish within the corporate structure a nuclear-dedicated organization with direct line management control over all aspects of nuclear operations, maintenance, engineering, and construction. CA4-1.2 Shorten and strengthen the nuclear chain of command; provide on site corporate direction and overview at the vice president level for all station activities. CA4-1.3 Clarify and docunent management authorities and accountabilities, p' CA4-1.4 Ensure that employees assigned to site work locations on a permanent basis are accountable to the site vice presidents, except for those personnel responsible for independent corporate assessment and oversight activities.

     ,}         Corrective Actions to Address Obiective CA04-2 CA4-2,1      Establich a strong management philosophy for assurance of quality.

CA4-2,2 Develop and implement a Nuclear Performance Management Program for Excellence. CA4-2.3 Centralize, strengthen and elevate Quality Assurance's (QA's) role in the Nuclear Organization. CA4-2.4 Strengthen the Operating Experience Assessment Pregram (OEAP). CA4-2.5 Inprove the Commitroant Tracking Program. l CA4-2.6 Establish effective information management and reporting systems to support problem identification and corrective action follow-up by nuclear management. t CA4-2.7 Ensure that the d'. c:.opment and training needs of nuclear aar, agers are identified and addressed in < timely manner. Appendix C. RELATIONSHIP INDEX (partial) 102

SECTION It CORPORATE ACTION CA4-2.8 Establish interactive communication and problen-solving pricesses between nuclear I off site and site personnel to ensure effective corporate direction and oversight of plant programs. CA4-2.9 Establish interactive communication and problem solving processes between line I management and independent assessment organizations to jointly review independent feedback; identify problems needing line management attention; and develop follow-up corrective action plans. Corrective Actions to Address Obiective CA04-3 CA4-3.1 Revise the Nuclear Review Board (NRB) l charter to better encompass technical i safety concerns. l CA4-3.2 Elevate the reporting level of the NRB and include outside expertise in its membership. CA4-3.3 Establish a pernanent committee of the Board of Directors, with outside expertise serving in an advisory role, to provide oversight of nuclear operations, ca 3.4 DELETED m \ Appendix C. RELATIONSHIP INDEX (partial) 103

l SECTION Z8 CORPORATE ACTION Maior Activities to Support Corrective Action 4-1.1 CA4-1.1.1 Identify all nucl.ar dedicated functions which should bo moved from Engineering and Production to the new Nuclear organization. (SD-8) CA4-1,1.2 Develap and implement an organizational reporting structure for Nuclear. (SD-8) CAG-1.).3 Assign personnel to all Nuclear management partitions to the senior engineer level. 1 (SD-8) l CA4-1.1.4 Develop and document a set of top-level Nuclear management and operating policies. (SD-7) CA4-1,1.5 Develop mission statements for the Nuclear organization and each organization reporting to the Executive Vice l President-Nuclear. (SD-7, SD-8) CA4-1.1.6 Review and revise all necessary corporate personnel policies to reflect the new organizational structure and ensure that Nuclear management has all appropriate l authorities. (SD-7, SD-8) CA4-1,1.7 Document Nuclear Services responsibilities with respect to interface with corporate Personnel and Industrial Relations on personnel management issues. (SD-7, SD-8) CA4-1,1.8 Conduct a series of on site and off-site team-building meetings with the Nuclear management team to: 1) review all assigned functional responsibilities; 2) identify and address unassigned programmatic items; 3) clarify interface responsibilities; and 4) agree on specifi: objectives for cultural change within the Nuclear organization. Use results of nestings to develop a Transition management plan. (SD-7, SD-8, SD-9) CA4-1.1.9 Implement a transition management process that will track reorganization progress, and identify and resolve transition issues in a timely manner. (SD-7, SD-8) Appendix C. RELATIONSHIP INDEX (partial) 104 i

SECTION 18 CORPORATE ACTION j Maior Activities to Support Corrective Action CA4-1.2 CA4-1.2.1 Eliminate the positions of Vice President-Nuclear Operations, and Manager, Nuclear Generation. (SD-6, SD-8) CA4-1.2.2 Establish the positions of Vice President-PBAPS and Vice President-LOS. (SD-6, SD-8) CA4-1.2.5 Locate site Vice President organizations at the nuclear sites.(SD-6, SD-8) CA4-1.2.4 Establish a regular staff meeting process for the Executive-Vice President-Nuclear l and his direct reports to ensure timely communications and problem solving about nuclear operational concerns. (SD-6, SD-8) Maior Activities to Support Corrective Action CA4-1.3 CA4-1.3.1 Redefine functional responsibilities and develop and document transitional interface agreements to be used as interin procedures for the following prograns and functions: (SD-7, SD-8, SD-9)

• Operating Experience Assessment Progran
• Commitment Management i e Configuration Management j
• System Engineering
• Project Engineering
• Materials management
• Integrated Management Program l
• Capital and expense budget development / cost tracking / cost control for Nuclear
• ISEG CA4-1.3.2 Revise and/or develop position descriptions for each Nuclear management position down to the Responsible Senior Engineer level to reflect mission statements, and interface responsibility / authority agreements.

(SD-7, SD-8) Appendix C. RELATIONSHIP INDEX (partial) 105

SECTION I: CORPORATE ACTION Maior Activities to Support Corrective Action CA4-1.4 CA4-1.4.1 Reassign site-dedicated maintenance, maintenance testing, and construction personnel to site organizations and payrolls (except for those personnel who will continue to work on the Limerick Unit 2 Project through fuel load). (SD-8) Maior Activities to Support Corrective Action CA4-2.1 CA4-2.1.1 Develop and document a statement of Nuclear management's philosophy and expectations for assurance of quality. (SD-5, SD-7, SD-8, SD-9) CA4-2.1.2 Communicate this statement by publishing it in company / site newspapers, displaying it on corporate and site bulletin boards, incorporating it into GET training, and referring to it in discussions with Nuclear employees. (SD-5, SD-7, SD-8, SD-9) Maior Activities to Support Corrective Action CA4-2.2 CA4-2.2.1 Develop and docunent a set of Nuclear i organization performance goals. (SD-5, SD-7, SD-9) CA4-2.2.2 Identify the performance indicators to be used for monitoring and assessment purposes; include comparisons with l benchmark peer plant performance trends.  ! (SD-5, SD-7, SD-9) I l I CA4-2.2.3 Develop and document performance goals and indicators which support Nuclear objectives for each Division within the Nuclear organization. (SD-5, SD-7, SD-9) CA4-2.2.4 Develop and docunent agreements with respect to management and staff responsibilities for monitoring and reporting progress on neeting objectives. (SD-5, SD-7, SD-9) CA4-2.2.5 Initiate the Nuclear Performance Management Program throughout the Nuclear organization, including management connunications with Nuclear employees to ensure understanding of and commitment to Nuclear goals. (SD-5, SD-7, SD-9) Appendix C. RELATIONSHIP INDEX (partial)' 106

SECTION I CORPORATE ACTION Maior Activities to Suppert Corrective Action CA4-2.3 CA4-2.3.1 Establish the reporting structure for a centralized Nuclear Quality Assurance (QA) function within the Nuclear organization. (SD-5, SD-6, SD-9) CA4-2.3.2 Assign personnel to all Nuclear QA management positions. (SD-5, SD-6, SD-9) CA4-2.3.3 Clarify and document the roles and responsibilities for each Nuclear QA function. (SD-5, SD-6, SD-9) CA4-2.3.4 Clarify and document the reporting responsibilities of Nuclear QA with line managers, the Executive Vice l President-Nuclear, and the NRB. (SD-5, SD-6, SD-8) Maior Activities to Support Corrective Action CA4-2.4 CA4-2.4.1 Define and assign the OEAP management function within the Nuclear Support organization. (SD-8, SD-9) CA4-2.4.2 Clarify and document tne interface responsibilities of the OEAP manager, ISEO, the Site Regulatory Engineer, and other Nuclear managers with respect to providing input to the OEAP; evaluating OEAP information to determine any corrective action requirements; implementing corrective actions: tracking corrective action status; and assessing the effectiveness of corrective actions. (SD-8, SD-9) CA4-2.4.3 Implement the revised OEAP. (SD-8, SD-9) Maior Activities to Support Corrective Action CA4-2.5 CA4-2.5.1 Clarify and document the responsibilities of the Licensing Manager in Nuclear l Support. (SD-6, SD-8) CA4-2.5.2 Clarify and document line management responsibilities for commitnant management. (SD-6, SD-8) ( Appendix C. RELATIONSHIP INDEX (partial) 107

SECTION It CORPORATE ACTION i l CA4-2.5.3 Develop and document interface agreements between line management and the Licensing l , Manager for the commitment management l l process. (SD-6, SD-8) l CA4-2.5.4 Initiate the revised Commitment Tracking l 1 Program. (SD-6, SD-8 ) Maior Activities to support Corrective Action CA4-2.6 CA4-2.6.1 Identify and prioritize needs for improved

Nuclear program and work management processes. (SD-6, SD-8, SD-9) i CA4-2.6.2 Develop and initiate a plan for management process assessment and information management improvement. (SD-6, SD-8, SD-9)

CA4-2.6.3 Initiate improvements to the Nuclear Performance Monthly Reports, with

emphasis on additional parformance r I

measurement criteria ar.d more timely deviation status reporting. (SD-6, SD-8, SD-9) Maior Activities to Support Corrective Action CA4-2.7 CA4-2.7.1 Establish the fluelear Training organization within Nuclear Services, including the reporting structure and the responsibilities of each organizational unit. (SD-7, SD-8) CA4-2.7.2 Clarify and document transitional interface agreements to be used as interim policies and processes for the development, assessment, evaluation and upgrading of Nuclear training programs. ( SD-7, SD-8 ) CA4-2.7.3 Initiate a program to deternine the core l managenent competencies required for Nuclear management positions. (SD-7, SD-8) CA4-2.7.4 Identify priorities for the development of new training and development programs for Nuclear managers and supervisors, and develop a plan to address these priorities. (SD-7. SD-8) CA4-2.7.5 Initiate training and/or coaching for Nuclear managers in the effective use of Appendix C. RELATIONSHIP INDEX (partial) 108

SECTION'It CORPORATE ACTION the personnel performance evaluation review process within the next year. (SD-7, SD-8) Maior Activities to Support Corrective Action CA4-2.8 CA4-2.8.1 Establish written guidelines for Nuclear Services personnel and relevant site personnel with respect to meetings, timely communications, problem identification and analysis, and follow up corrective actions in the following areas (SD-8, SD-9)

• regulatory and INPO interface e plant chemistry
• radiological protection
• radwaste management
• emergency preparedness a fuel management
• security and safeguards CA4-2.8.2 Initiate a management monitoring process to ensure that these guidelines are followed. (SD-6, SD-8, SD-9)

CA4-2.8.3 Establish guideli..es for Nuclear Engineering personnel and relevant site personnel with respect to meetings, timely communications, problem identification and analysis, and follow-up corrective actions in the areas ofi (SD-8, SD-9) e plant systems monitoring

• plant equipment, cystems or procedure problems requiring corrective action
• planned corrective actions and/or problems with follow up on corrective actions.

CA4-2.8.4 Initiate a management monitoring process to ensure that these guidelines are followed. (SD-6, SD-8, SD-9) CA4-2.8.5 Continue Executive Vice President-Nuclear l site meetings. (SD-6, SD-8) l I Appendix C. RELATIONSHIP INDEX (partial) 109

  ,~.      . -    ~    - - .     .                               . . , . - , .

I SECTION IS CORPORATE ACTION . Maior Activities to Support Corrective Action CA4-2.9 CA4-2.9.1 Establish Nuclear QA reporting as a routine agenda item at Executive Vice l President-Nuclear staff meetings. (SD-5, l SD-6, SD-8) i CA4-2.9.2 DELETED x  : Maior Activities to Support Corrective Action CA4-3.1 CA4-3.1.1 Revise the NRB charter to better define. l the scope of review activities, and obtain l all necessary approvals. (SD-6, SD-9) CA4-3.1.2 Define and document the responsibilities l of the position of the NRB Chairman. l (SD-6, SD-8) CA4-3.1.5 DELETED M CA4-3.1.4 Develop and document additional NRB

processes for proactivre investigation of safety-related concerns. (SD-6, SD-9)

CA4-3.1.5 Clarify and document the reporting responsibilities of the PORC Chairman and l

Huclear QA with respect to the NRB. (SD-6, 1 SD-8)

CA4-3.1.6 Establish reporting and meeting guidelines for the NRB. (SD-6, SD-8) Maior Activities to Support Corrective Action CA4-3.2 ' CA4-3.2.1 Establish an organizational structure which provides for the NRB to have a direct reporting relationship to the Executive Vice President-Nuclear. (SD-6) M j CA4-3.2.2 Establish and appoint the nembership of the NRB to include six internal PE members l and three members from outside PE with recognized nuclear industry experience. (SD-6) i Maior Activities to Support Corrective Action CA4-3.3 CA4-3.3.1 Establish the Nuclear Committee (NCB) as a standing committee of the Board of Directors. (SD-6) l 4 CA4-3.3.2 Develop the charter of the NCB and obtain , full Board approval. (SD-6)

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l I Appendix C. RELATIONSHIP INDEX (partial) 110

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1

l l SECTION Z8 CORPORATE ACTION l CA4-3.3.3 Establish and appoint NCB membership. (SD-6) CA4-3.3.4 Contract with one or more outside experts to serve as advisors to the committee. (SD-6) CA4-3.3.5 Establish review procedures for the NCB including document review, site inspections, and meetings with senior Nuclear management, independent assessment groups, regulatory and industry personnel, and PBAPS co-owners. (SD-6) i CA4-3.3.6 Develop and document the reporting responsibilities of senior Nuclear management and the NRB with respect to the NCB. (SD-6) Maior Activities to Support Corrective Action CA4-3.4 - DELETED M CA4-3.4.1 DELETED M I CA4-3.4.2 DELETED M i CA4-3.4.3 DELETED M { 1 Appendix C. RELATIONSHIP INDE.V (partial) 111 __ . -_ . _ _ _ - _ _ - . - . - _ _ - - - _ .}}