ML20151E188

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Forwards Supplementary Info,Per Commitment in to Provide Info Before 880715 Meeting
ML20151E188
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 07/14/1988
From: Corbin McNeil
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Myers M
PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 8807250403
Download: ML20151E188 (217)


Text

{{#Wiki_filter:y,n , n _. -. -_ _ - 4 PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. 80X 8699 PHILADELPHI A. PA 19101 C. A. McNEILL, >=. (215) 841 4221 EX5CUTIVE VICE PRE $lDENT

  • NUCLE AR July 14, 1988 Morey M. Myers, General Counsel Office of General Counsel Commonwealth of Pennsylvania 17th Floor, Harristown 11 333 Market Street Harrisburg, PA.

Dear Mr. Myers:

In my letter to you dated July 12, 1988, I stated that we would provide supplementary information prior to the meeting on July 15. The attachments to this letter provide that supplementary information. Attachment 1 is a revision to our suggested agenda for the July 15 ceeting. Attachment 2 contains additional information in response to many of the concerns contained in your letter to Mr. Russell of the NRC dated June 16, a 1988. We have grouped these into 15 categories for which PL has cognizance: i

1. Return to Duty of Culpable Peach Bottom Operations Personnel
2. Number of Operators and Overtime
3. NiSI standards
4. Whistleblower Program
5. Organization and Staffing
6. Independent Safety ingineering, Operating Experience Assessment, and Re-Evaluation of Industry Experience l
7. Mark I Containment Issues
8. Other Hardware Issues
9. Commitment Tracking
10. Commonwealth of Penitsylvania Involvement in Peach Bottom l Inspections j
11. Analysis of Peach Bc ttom Problems l
12. INP0 Assessment Role l
13. Training }g$ 1
14. Fitness for Duty '
15. Insurance Reports [~L 8807250403 880714 r PDR ADOCK 05000277 P PNU I((

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Mr. Morey M. Myers July 14, 1988 Page 2 For each category we have prepared a summary sheet which identifies the issue and our approach to address and resolve the issue. We look forward to discussing these issues with the Commonwealth's representatives on July 15. Sincerely, Attachments \ - cc: J. F. Paquette w/a E. J. Bradley w/a W. T. Russell, Administrator, NRC Region I, w/a v/ i l L

ATTACHMENT 1 AGENDA (REVISED) HEETING BEWEEN REPRESENTATIVES OF C0}N0hTEALTH OF PENNSYLVANIA AND PHILADELPHIA ELECTRIC COMPAh7 RE: RESTART OF PEACH BOTTOM AT0 HIC POWER STATION HARRISBURG, PENNSYLVANIA JULY 15, 1988 2:00 P.M.

1. Review of Categorization of Issues, Approach to Resolution, and Closecut Criteria
2. Briefing - Shift Operator Staffing, Shift Rotation Schedule, and Overtice
3. Briefing - Organization and Staffing Selection Process
4. Schedule for Site Briefings on OEAP, ISEG, Coccitment Tracking, and Observation of Operations

i l l I ATTACHMENT 2 t ISSUE

SUMMARY

SHEETS ( ( ( l l i l l l I l l

n ISSUE: Return.to Duty of Culpable Peach Bottom Operations Personnel APPROACH: As indicated in the July 12,-1988 letter:from Mr. W. T.' Russe 11'- - of the NRC to Mr. C. A. McNeill of PE (attached), the NRC will respond to the Commonwealth directly concerning information provided by PECo as' requested by the NRC for use in making an enforcement decision about individual operator culpability. Having held a series of enforcement. conferences. involving. individual operators, the NRC will determine the acceptability of utilizing those persons in future Peach' Bottom' operations.- l PE has completed a comprehensive operator rehabilitation ' program, as discussed in the Restart ' Plan. In addition, the operations staff has been increased 'and responsibility and accountability has been clearly defined. Further, PE has changed the pr ' cipals in its nuclear organization from the . Chairman down to the Shift Superintendent. There is significant management and independent oversight in place. CLOSURE: 1. The NRC retains closure authority on culpability of operators.

2. PE has restructured its management, retrained personnel, and instituted significant new policies and practices.
3. PE will provide a briefing by Mr. D. M. Smith on the Rohrer, 1

Hibler, and Replogie (RHR) report if the Commonwealth requests.

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UNITED STATES NUCLEAR REGULATORY COMMISSION

             %                                              REGION I

[ 478 ALLENoALE ROAD KING OF PRUSSIA. .'ENWYLVANIA 1 Mot

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12 JUL 1988 Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTH: Mr. C. A. McNeill Executive Vice President-Nuclear 2301 Market Street Philadelphia, Pennsylvania 19101 a Gentlemen:

  .y            

Subject:

y of Peach Bottom Atomic Power StationState of Pennsylv i Enclosed for your information and use in revising the subject plan is M . Morey M. Myers' letter from the Office of General Counsel, dated , 1988 June 16 forwarding to NRC the comments of the Commonwealth of Pen . will respond to the Commonwealth of Pennsyivan c e NRC issues can generally be grouped into the following categories: . These 1. a NRC for use in making an enforcement decision operator culpability.

2. \

Information describing the NRC approach to the review of the

3. .

Information describing and justify requirements, inspection programs,ing NRC technical specification state programs, and generic programs such as the Mark I containment integrity. 1 While you may wish to comment on these issues as appropriate, t expect you to respond to such matters regarding NRC requirements a . 4 0t me}

                                             ~
                                       }

Philadelphia Electric Company 2 12 JUL 1988 Thank you for your cooperation in this matter.

 .3                                               Sincerely, W N' T. Russell i

Regional Administrator

Enclosures:

As stated l cc w/ encl: I John S. Kemper, Sr., Senior Vice President-Nuclear J. W. Gallagher, Vice President, Nuclear Services  ! E. C. Kistner, Chairman, Nuclear Review Board i Dickinson M. Smith, Vice President, Peach Bottom Atomic Power Station i

  !     Jack Urban, General Manager, Fuels Department, Delmarva Power & Light Co.            !

John F. Franz, Plant Manager, Peach Bottom Atomic Power Station Troy B. Conner, Jr. , Esquire i W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric Bryan W. Gorman, Manager, External Affairs . I g

Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)

Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations j W. M. Alden, Director, Licensing Section i Doris Poulsen, Secretary of Harford County Council 2 i Dave Honan i Public Document Room (POR) Local Public Document Room (LPDR)

 !      Nuclear Safety Information Center (NSIC)                                            j NRC Resident Inspector                                                              1 j      Commonwealth of Pennsylvania -

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  ,                                                                                         1 3                                                                      -

a I ia er

O PENNSYLVANIA COMMENTS ON PEACH BOTTOM RESTART PLA TO WHICH NRC WILL RESPOND

 !      ITEM      PAGE DESCRIPTION
1. 5 Technical Specification organizational changes, potentially raise Health and Safety concerns.
2. 7 Standards NRC will Use to Judge Restart Plan Management Issues, NRC Policies on Management.
3. 7 NRC acceptance of PECo root cause analysis.
4. 7 Identify NRC personnel judging plan acceotability and performing reviews.
 ;      5.      7 l                                       Provide memorandum of agreement between NRC and INPO.                                                        .
6. 8 c Provide Claims Security interviews and signed i

statements,

 . 7.       16 Adequacy of Technical Specification staffing requirements.

8, 24 NRC promulgate criteria for integrity of Mark I containment. l 9. 25 d Involvement of Pennsylvania in verification i role due to lack of confidence in NRC,

10. 26
-                                      NRC review of inspection procedures to ascertain 1

why problems undetected. e t

ISSUE: Number of Operators and Ov?rtime

;PPROACH:

The Commonwealth has expressed concern about the staffing levels of Peach Bottom and whether the levels proposed by PE would preclude burdensome overtime. The number of operators required for safe operation is defined in the Technical Specifications which are a part of the license to operate. PE will operate Peach Bottom under a six-licensed operator /six shif t rotation schedule that will minimize overtime. At the July 15 meeting, PE will brief the Commonwealth on how this six person /six shift schedule diminishes the need for overtime yet fills the requisite staffing. PE will also discuss plans to substantially increase the pool of licensed operators. PE is prepared to establish for a substantial period, additional constraints on the use of overtime. PE's policy, which will track the overtime policy currently under development by the NRC, will provide both short- and long-term overtime restrictions. We will discuss our current approach at the July 15 meeting. CLOSURE: 1, FE will provide a briefing to the Commonwealth's representatives on staffing, shift rotation, and impact on overtime.

2. Explain the specific overtime policy.
3. Upon agreement of the Commonwealth, formally commit to strengthened overtime restrictions.

4 t~ ISSUE: AN3I Standaru. t APPROACH: The Commonwealth nuggested a t'at certain industry standards or later tevisicas of standards be adopted. PE's compliance with these standards is addressed below.

1. ANSI /ANS-3.1-1987, "Selection, Qualification and Training for Faclear Power Plants". The NRC has not yet adopted the 1987 revision of ANSI /ANS-3.1. Peach Bottom is currently j committed to the 1971 revision. Limerick is committed to ~

the 1978 uvision. PE will compare the 1971 revision to the 1978 revision and will upgrado Peach Bottom compliance as a long-term commitment. PC will evaluate the 1987 revision of the standard, if adopted by the NRC, and will determine r the need to upgrade to the 1987 standard or equivalent. CLOSURE: 1. PE will upgrade Peach Bottom to the 1978 revision of ANSI /ANS-3.1 as a long-term commitment.

2. PE will evaluate the 1987 revision of the standard if adopted by the NRC.

e 4 II II

2.. ANSI /ANS-3.3-1982, "Security for Nuclear Power Plants." PE currently adheres to this standard. The NRC'has issued a proposed policy stat'ement to adopt a recent NLHARC

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guideline. If the hWMARC guideline is issued as policy, PE will commit to.it. The NOfARC guideline is generally more stringent than the ANSI /ANS: standard. CLOSURE: 1. P2 will formally. commit to comply with ANSI /ANS-3.3-1982.

2. PE will change its commitment to the NW! ARC guideline if the hTMARC guideline is adopted by the NRC.
3. ANSI /ANS-3.4-1983, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses at Nuclear Power Plants." Although not formally committed to this standard, i

PE currently adheres to it. CLOSURE: SE will formally commit to comply with ANSI /ANS-3.4-1983. M

4. ANSI /ASME NQA-1-1986, "Quality Assurance Program Requirements for Nuclear Facilities." Currently, PE is committed to Regulatory Guide 1.33, Revision 0, and ANSI-N45.2 ( and its daut,hter documents). PE is committed to implementing 10 CFR, appendix B, "Quality Assurance

Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." These coccitments are substantially equivalent to ANSI NQA-1-1986. _ CLOSURE: PE is cocmitted to equivalent of ANSI NQA-1-1986. l i

t ISSUE: Whistleblower-Program APPROACH: PE has. in effect a formalized policy that encourages employees and contractors to identify and' report possible deficiencies concerning Peach-Bottom activities and ensures protection-from sanctions for such identification and reporting. PE is not aware of any PE employees with ongoing disputes' that claim sanctions resulted f rom raising safety concerns.. There are a number of7 ontractor employees with ongoing disputes over terminations; these disputes are being appropriate 1yJpursued. PE's program encourages identification, reporting, and resolution through line management; however, it also clearly states an employee's right and responsibility, where necessary, to report such deficiencies directly to the NRC through the , NRC's site resident inspector. PE believes the existing policy provides viable, effective communication of an employce's right and responsibility to report suspected deficienclea in any aspect of Peach Bottom operations and assurance of PE's commitment to protection from sanctions for such reporting. PE has recently re-af firmed its commitment to this policy and has publicized it to employees and contractors in several ways. PE will provide you with a copy of its policy and copies of corporate and site communications promoting this program. i r

Employees have access to the "Nuclear Group Quality Concerns Hotline," a direct communication to PE's Nuclear Quality Assurance Organization. In addition to PE's internal program, copies of NRC Form 3, "Notice to Employees," are posted. This NRC form notifies employees of their access to the NRC's resident inspectors. A copy will be provided to you. CLOSURE: 1. PE will provide its policy to the Commonwealth (attached).

2. PE will provide a copy of corporate and site communications promoting this program (attached).
3. Attachment of NRC Form 3.

NUCLEAR GROUP POLICY NO. NZ 03Z001 EFFECTIVE DATE: 7 01<88 NUCLEAR GROUP POLICY TITLE:

              ,     % . .. A ,

qNC SERVICEg QUALITY ISSUE DATE: 615-88 REV. NO.: O PAGE 1 OF 1 POLICY STATEMENT-Assurance of quality is paramount in all nuclear activities and is based on a commitment to excellence in one's oun work performance and an acceptance of responsibility for the overall quality of nuclear activities. POLICY INTENT-The Nuclear Group shall:

  • Ensure that each work group is responsible for the quality of its work. This responsibility shall not be delegated; however, separate and independent verification may be employed when required by regulations or dictated by approved logic processes.
  • Provide confidence through the Quality Assurance Program that safety-related structures, systems and compo-nents will perform their intended functions.
  • Give quality considerations top priority in situations w here choices between quality and cost or schedule must be made.
  • Provide adequate resources and environment to implement the quality program.
  • Perform every activity so that it results in the desired level of safety and reliability.
  • Perform corrective actions for conditions adverse to quality in a manner that is both timely and addresses the roct cause(s) of the problems.

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  • Have individuals assume personal responsibility for the quality of their activities.
  • Adhere to standards and procedures.

APPLICABILITY-All organizational elements and personnel who panicipate in the nuclear mission. IMPLEMENTATION-This policy shall be implemented by establishing and maintaimng: i 1

  • An atmosphere and reponing system that ensures anonymity and freedom from discriminatior, against individ- l uals who identify quality concerns. l l
  • Effective problem reponing processes that enable rapid and easy reporting of quality problems or deficiencies.

All employees shall be encouraged to panicipate in matters affecting quality by reporting problems and o'fering suggestions for improvement. ) 1

  • A means for identifying all significant programs and activities that are subject to QA requirements.
  • Performance reporting systems that enable the monitoring of progress toward meeting nuclear goals and identifying and resolving potential problem areas on a timely basis.
  • A Quality Assurance Program in accordance with regulations, license requirements, and this policy.

SOURCE DOCUMENTS-10CFR50, Appendix B; LGS & PBAPS QA Plans: Nuclear Group Management Philosophy for Assurance of Quality.

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A EXECUTIVE VICE PRESIDENT NUCLEAR

tfJCLEA9 OJALITY ASSURANCE 57-1, 2301 varket Street Feoruary 12, 1988 FROM: D. R. Helwig TO: J. S. Kemeer D. M. Smith G. M. Leiten S. J. Konalski J. 4. Gallagner

SUBJECT:

Nuclear Group Quality Concerns Hotline Effectise Fecruary 15, 1988, the Nuclear GrouD Quality Concerns Hotline has been changed to (215) 841-4900. This is a new numoer that will reach an answering machine in my office. Attacned are revised drafts of the letters issued and posted at PBAPS and LGS in 1986 regarding the process for reporting of deficiencies. It may be appropriate to update and reissue these letters. I have also attached a transcript of the message which callers will' near and a copy of the desk procedure which will be used to process any calls received. Please advise if you have any suggestions for improvements. General Manager DRH:mes 0436s Attachments (4)

Pea:n Bottom REPORTING 0 DE ICIENCIES

Pniladelonia Electri
Comoany is conmitted to operation and maintenance of Company facilities witn :ne hignest cegree cf quality a nievaole. To nels us a:Comolisn tnis, you can and should report anything you Delieve is a

, ceficiency and'could cause a proolem. Suen a ceficiency could ce equipment

                                       , unsafe working conditions, radiation exo0sure ceteriorated  or not workinglance cuestions, degraced    survei-       test results, or anytning else which concerns you.

You should report plant equipment deficiencies by dialing AMR~ and describing the problem to the snift clerk. Report anything else you think is a ceficiency to your sucervisor, steward, PECO Shif t Suoerintendent, or plant management in that order. The suspected deficiency you report will be

investigated and corrected if it is a problem. If tne suspected deficiency is not a problem, this will be explained to you. There will be no recriminations, regardless of what you report.

If you believe you are not receiving a correct oE timely response, please . contact our Superintendent, Administration, Bruce Clark, on Peacn B:ttom . Extension 4249. He will assure that accropriate pecole aedress your concern including the Plant Manager,"if necessary. He will not icentify you, if you so request. You may also report anonymously 24 hours a day, by calling (215) 841-4900 or

81-4900. This phone is in the ' office of the General Manager, Nuclear Quality i Assurance. Your report will be recorded manually or ele 0tronically, assigned J a number, and investigated. The investigation report will be sent back to j that office for resolution and you can get information aoout it by referring to the number of your concern.

The above Jolicy apolies to anyone--PECO employee or not--who has a concern about Peat.h Bottom. While we prefer that you pursue your concerns within our organization first, this in no way replaces or affects your rights to take your concerns to the NRC. The NRC resident phone number is Extension 4213 or (717) 456-7614 The NRC pnone at King of Prussia is (2}5) 332-5000. , l i I l j Issued l 4 a l i l l

                                                                                    *ime i:':

n: . P e, a. A. , -<, _ n :._ _ u. :._,L- . .m Pniladel:nia Electric Co cany is On-itted to oceration an: eainteaan e :f Company facilities witn :ne highest cegree of cuality acnievaole. To nelo us a::cmplish this, you can and should report anything you oelieve is a ceficiency and could cause a Orcolem. Su:n a Oeficiency could be e uionent ceteriorated or not wor <ing, unsafe working conditions, radiation excesure cuestions, cegraced surveillan:e test results, or anytning else whien concerns you. You should report plant equipment ceficiencies by dialing 2126 and describing the problem to the snift clerk. Report anything else you think is a deficiency to your sucervisor, steward, PECO Shift Superintendent, or plant management in that o:cer. Tne suspected ceficiency you report will ce investigated and corrected if it is a preolem. If the suspectec ceficiency is not a proolem, this will he exclained to you. Tnere will be no recriminations, regercless of wnat you report. If you believe you a::: not receiving e correct or timely resconse, please 4 contact Carl Encriss, our Regulatory Engineer on Extension 2020. He will assure that aoprocriate pecole accress your concern including the Plant Manager, if necessary. He will not identify you, if you so recuest. You may also recort anonymously, 24 hours a day, by calling (215) 841-4900 or 80-4900. Tnis phone is in the office of the General Manager, Nuclear Quality Assurance. Your recort will be recorded manually or electronically, assigned a numcer, and investigated. Tne investigation report will te sent back to that office for resolution and you can get information about it by referring to the number of your concern. The above policy applies to anyone--PECO employee or not--wno has a concern about Limerick. While we prefer that you pursue your conce!.ns within our organization first, tnis in no way reolaces or affects your rights to take your concerns to the NRC. Tne NRC resicent phone numoer is Extension 431S cr (215) 327-1344/1345. The NRC phone at King of Prussia is (215) 332-5000. Issued

e N!) OLE AR ' QJALIT Yl AS$dRANCE 57-1, 2301 Market Street-S3 JECT: Nuclear Grouc Quality Concerns Hotline Transcript of Recorded Message Hello. This is David Helwig, General Manager, Nuclear Quality Assurance.-

. You have rea ned the Pniladelphia Electric Nuclear Group Quality Concerns Hotline.

The ourpose of this notline is to receive-information-regarding potential , deficiencies which might adversely effect the cuality1of .our nuclear activities. You are encouraged to icentify all suen issues to your sucervis10n and-to plant management. Concerns. identified via tnis notline shoule'be those tnat you do not feel able to discuss witn these parties _'or those'where you co not believe aporocriate action has been taken on concerns which..you have raised for their

          . attention. Personnel grievances may not be handled through this hotline.

Following the tone, please state the date and time, describe your concern, and leave your name and a phone number where you can be reached. If you choose to identify yourself, your name will be held in conficence and I will contact you-regarding the action being taken in response to your concern. If you choose not to leave your name and number, you may obtain information on the status of your concern by calling 841-5203 during normal. working nours. Your concern will ce identified by its date and time of origin. Again, following the tone, please state the date-and time, describe your. Concern, and leave your name and phone number. 1 r i o l J i i DRH:mes 1 0436s 1 l H i

                              -- -          . . -                    - , _,       .  . . . .   -...-,i

PROCE0JRE FOR RECORDING AND DISTRIBUT!NG OJALITY CONCERNS A cuality concern may be any issue icentified as having the potential to af fect nuclear safety. This does not incluce personnel grievances : items *hi:n could be resolve 0 tnrougn normal cnannels of supervision.

   . An encloyee may contact the Office of tne General Manager, Nuclear Quality Assurance on (215) 641-4900 to report a cuality concern. Tnese calls may be anonymous, but if the caller wishes to identify nimself, tne nane will be held confidential.
   . The Office of the General Manager, Nuclear Quality Assuran:e will:
       .      Log in the ch ne call.
       .      Assign a unique recort number.
       .      Transcribe the Quality concern.
       .      Suunit cecies of the cuality concern to the relevant Vice Pres!-ant and to the Senior Vice Presicent-Nuclear.
   . The relevant Vice President will review the cuality concern anc initiate accrocriate investigations and cc rective actions.
   . As the investigation continues, interim reports on the status of the quality concern will be issueo to the General Manager, Nuclear Quality Assurance on at least a biweekly basis with a copy to the Senio: Vice President-Nuclear.
   . These interim reports will be made available to the caller by the Office of the General Manager, Nuclear Quality Assurance.
   . Uoon comoletion of the investigation, a final report will be issued to the General Manager, Nuclear Quality Assurance with a ecoy to the Senior Vice President-Nuclear.
   . Tne final report will be mate available to the caller. If requested by tne caller, a written report will be oroviced.

Prepared by: D. R. Helwig FeDruary 12, 1988

               +             .-

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               -                                                                                                     proget begun in 1985, has ken completed virtuaDy on schedule                                The Company has anmurad a to ts-The MenG1 Creek Resenoir (Warren          ing program for the emergency warnty si-County, New Jerse>t capaNe of stoned 15          rens in the Peach Bottom Emergergy bubon gallons of watet is the onh wster          Plann:r.4 Zone (EPZ).
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               *h Basin in the 1980s ard the only such             sirnaltaneously at 1 p.m. on Wednesday
               +                                                                                                     project in rnam years to base been con-          Apr0 6.for three minutes                         .
               #                                                                                                     structed entirely with pmste furds                   The procedure wG te repcated at 1 p.m.

d it is desgned to protect the estron- on the first Wednerday of each mont T rnental integnty d the Delaware Rner and to help assure an adequate supply of ciec-therca*,er " - Tha d be the first ume many resdents

                    ;;                                                                                               tnoty for the Delaware Rrer Basm.                4 have heard a fu!kscale stren test *
                     -                                                                                                      The resenotr wc guarantee that there          Until rm, the trens in each county-f                                                                                               wG be enough wa:er to supmrt the generar         30 in 12ncaster. 20 in York.19 in Harford.

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               ' -1Dendit.Wg,.p.mgworel enenoper.mdeer truelpy assurimce, wMh the Nudeer GrwP                        Delaware Rrwr Basin ewn dunr4 penods              tested b on}y a few seconds on dIfferent igweiny concerns heelw eWpenern.no Iw is open 24 hours e dey to recobre reports.           d iciw nwr flow or seen drought This or anonyrnousMh or concems anic ony espect e Ae W                                                                                 dmd           the first week deach month, rehabil'ty is key to meetzng the tunent and                          is being made to conform ?

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                          /utenuduforMhitVaderCrry in wG be recorded Ine or ekcroncalb Eat                           upmer d pump water to the reservoir pony Mielear Group Ouchty Concems report 4 be ass 4ned a numberand trnes '                 through a weMed steel pipehneJ3rU2 mues '

A "*'*# ** '~ twe f the effectneness of the comrenents Hothne* % .h& . bgated An irnestgabon report on eat cord Anyone. PE ernployees. contractors, anw cern wc come back to Helsgs(Ace, and long When nver 60ws m so b that ekc-d the seem than are the shorter tes that - tne utihees wouM otherwue be bred to one who ercounters anytlung that he or she thosewho report concans can g<tinforrry had been used in the past cu'.hil their output resenott uter w-I be-beheves is a deficiency or could cause a bon on the results of the investgabon b retumcd to the nver through the same in h cent d a nal emeqem sinns problem in the ograbon or mamterarse d refemns to rt by its assigned number ptrehne. Pumping into or out of the reser- ' "U 8"Ud N #" D b* **"d a Compam nuclear facihty, can and should ' Het ig sass that whDe he would pn*r tha: voir will conform with the requtrements d 'N "d'"'5 S * " " """ report those concems immediatch buch a concems te pursued through the Compa- s*abwis fm heuons from emememy the Dela.2re River Basm Commssion deficency could be detenorated equ:pment ry orgmadort through reiar sunn.saon (DRBa the leM bcensng agency for the nspome am W gudebu @ r or equ:pment not work:r4 unsafe werk:rg a b use of the bothne.amrwush or rot Memil Creek Reservoir late hat W emegency s.amy onn swr corkicons, raiaton exposure questons. these charmels m no way replace amone's tem must be tested penoidh-,, DRBC requi es that dunr4 renc4s of deg aded surwdance test results or anw nghts to take their con: ems d: rect!) to the The orens ce sourded b county emer-d@a dm du opem m N th:ng else d concerr.. NRC There an NRC residentmsNeton at ban pude b the o:er w gepey rr.r. age nent penonnel TT.* EPZ ts I

                             % are comt ee'ed to cmatng rd r.u:r,      Pea:h Bottom and at bir.enck and the                                                             a2 the ana snhin appronmately ten mile pbes bcc mn siier plants L.nenck rd                                                                            .

ta:ntng our facittes wth the hc.es' deg ee reg;onal NRC c6ces are located neatty in of the pir.t  ! Kg of Pruit Eddsstone generatmg stacons a t among douaht) adiesable" sm Daw Hehc4 A . thm.e phnts Dur:4 the rnontiv tes's there 4 be no l coring to Helet the purpose of the hot To report a nuclear deficiency or Besdes Phnaddpha Electn:. s.x other actmty b emergency respotue agences l i hne is to recewe m!crmation regardms problem: electn uttues compnse the MerrG Creek The Ememency Broadcast System 4 rot I potental dd.actries whKh m:ght adwne- At L.irnerick-Call the Shm Cieri at be aceva'ed and the pubbe 4 not be ex-Cwn Grour They are: Pubb: Sem:e I h ahect the quabty d the Compam s nuckar exteng,on 2126 Eiectne ud Gas Compaw .h.0:Electn: rected to take ruton. actwtes 'ke are encouracr4 ewn'one to Ca!! sour Supwso' Compan). Jeno Cent a' ber & L;ht The s:rer: smem was mstakd and is i denth aD such issues to thezr supems>on St.u d aMtoplantmawement smHeie But Cmm We's Eh Co ms mnwd b PE The t e u re sourded She Sutvmntencent pynny,hg.ua her & L.4M Comte aM on$ b crder of the emeteno mr. age-the to bothne is for tnme concems the em- p, ant Manage *nent N.nz,sa Mer & L;ht Comran. rnent cE:als m ca:h counts pknees or othen do not feel aNe to d:scus' I? sou are not sattshed with tne , wth those par'aes or these when. a pe wr. response can ine Eeti.,laton En- . feels that apprornate a: ton has not bect- pneer at evenvo* 2020 4 taken on conecrn3 alrea6 r.csed sRC keuoen a'euenvoq 34 o. Peach Bottom Walks on-se empbee3 a c re; y,.cd t' a. m3 n .13mp3 repen dethnau or concerm t. tN sv At Peach Bortom-Ca': sou' 5# for March of Dimes , OtTPA orlogototSC:r suNNW sh* ward pees .gy M;.a A'""rat C# rament ATd i .y. v sh:" sJMr*tenJc".t or le pd** =>%ge l* gg ye no' g353nec w e t y; CnnlTO st0L # nan ha"E rd i

                                                                                                                                                                                                       %    *    '-        ~j me".t The susxcted deros'o *.'. rc &            re<pmw taxe sus concern up t se                      h hil'd M(t rd ccm m                        .         s~..

IJ"U *t'It h000ffdb IId bMO N .i ne5Lga'.cd ard (UTreshd !* lt 15 a pic he". EnrgeSe9t Cna ". E"Mit 13 Ine s ICS - '$ i 1:the rencsc adaens Im ma aru p e, oe~ c necesom Dro Danng l# urs Mrch d * -' '

                                                                                                                                                                                                     ., th Om=. .1he  . , wm , n       . 1 ~                 s mem. -~                                          v.m u . < v m ,, ,
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i

Excerpt f rom TIIE SUSQUEllANNA LIQIT, March 16, 1988, pages i and 2 30 bi lancaster,20 in Yor k,19 in liarford, Josep], y,'. htqtiette, Jr. 5 75t,-AC 1.. a^ i>rbin A. McNeil, pany alter a successful two >c.us .n w, Jr. ibWer Company," Everett said. six in Cecil arul two in Chester-h;ne been , , . .s

                                                                                                                                                                                          .                            4        sumers tested for only a few seconds on different                                                                                                              ,
                                                                                                                                                                  ,,,,              .          .g c        ,y.           i, '"Pm also pleased that Corbirt McNeiH ac-dos during die first week of each month.

i E officials saxi the change is being "Don't Wait-Report It" k%g.pj,g.. eM g%dr q,

                                                                                                                                                                                                          ,#.d. :.certed.outhffer of er p!orment r=ther h'

than contmue as a loanhd executive from

                                                                                                                                                          -        ,gA -        .,,

D Public.1Service ElectHe and Gas made to umform with the siren testing m NuclearQuah.tyA. ssur M g ance:Hoth.f M M Y W P. Ia "r d i k.m; m .nemPSE se 1

f 3 "IIrllo. This is David IIcEwig, anemi. . pb>ees or others do not kel able to disWwell.qualifiedr bringinif kith them out-managr. Nuclear Quality Assumnce. Ibu cuss kitif those'barbdCb/those wilere ad standing reputations fotjleadership and inte'actiolld stiong and ihhoVativdhian6gementlf he harv trached the I*hiladelphia Electric
peis8djfsels' that C
  • noGbeeh taken;s A
  • Q Contpany Nucitar Gmup Quality Con. o dd6ths; s'tated.Q@

pQ alfhad { ldt PaSette' rilllie refinind PE UQf4f.1.b?Y from

                                                                                                                                                            !raihdgh OnIbite 7 !.; ' @lih IIn!3nd5 : titiient p6sitionjas blesident;and chief
                                                                                                       %"    cerns IIotline."                          e Anyone, a PE empknee or a contrador,         Limerd, e% .Iieamployeefar,e bbing asked to; i6perating offi who encoimters anything that he or she
                    ,l                                    eg                                                                                                                                                                                                     based in Jackson,         '

9  %@G. - 3 l_ i believes is a deficiency or could cause a reporfdeficiencies and/or concems iight t ; electric and gas utility iidd Everett, up the thain,' going from the shift clerks,! 4 Michigan ~.jile will repl I h i

                                        /k@Mp ..

NM; y F problem in the operation or maintenance of a Philadelphia Electric Company

                                                                                                                                                          ~

supervisbni, stewanI! shift superintendent'. 3 Idd assumed.the'dutierof president and

                                                                                                                                                                                                                              ~

f to plint k4;end!it idcluding de vice ' chief opefatirig ollicer folkming Oc recent 3 nuclear facility, can and shouki report- o pM h those concerns immediately. Such a dc6-f ?b # -'$pl J < presiderithif'necessitry. He suspected!., retirementofJohitII/Aditin;Jr : g]. d ciency couhl be deteriorated equipment :deficieric%will be idvestigated and cor-j.g ! Pagineith%asinitialhHe*niplayed by PE

                                                             . &y'9d g:oringhequipment f                                                                                               rected if ifis'd problem: If the reported ; 3 n i1956, hbidmg 5 tiuihb& of managerial not working. unsafe work-h      .
                                                               ' % @,                                             conditions, radiation exposure ques.        deficie6cy panes nol to thi teal problerid ' . posts incknding vice prEsideht, finance aal tions, degraded surveillance test results,      this will be explained td be person whd 'p,Faccounhnd/and (fiief firta'ricsal offx:er fmm 1978 to 1986. lie left PE in' April,1986 to or anything else of concern.                     rebriedmmwons,'

il lleiwig tiressed that there will M} ! accept 'the host of ex procedure which has pmven effecti e at "We nur committed to operating be no r teg;inlless of what.is the la.menck Generating Station, Mont-g . gg g , j dent and. chief; financial officer at Con-gomery County, for the past two years. est degree of quality achievable,"'says .delief'atsone fr6m reporting somethird 6f M[sumers Ibwer.llie fa's'blected Consu-

         %cy said a three-minute siren test is                                                                Dave llelwig. Actonling to IIelwig, the                     says llo!*igT!4 .              diMNP meis lifweY president Ahd.'vice chairman                                         I trane trulicatne of the effectheness of die                                                             purpose of the hotline is to receive infor-
                                                                                                                                                            'c6hcfr'n,"h tin lWe         the "II60ind     is  avidlable                !  "in  February,1987               and      president components of the system than are die                                                                   mation reganling potential deficiencies         24 bdiffs a day to take calls, ' anonymous or ' Enetgy and president and chief opera 2ing shorter tests that had been used in the                                                                 which might adsersely affect.0ie qua5ty of iidentified.%e,hotlindisinIlclwig's of5ce i, officer of its subsidiaiy, Co the Company's nuclear adivities. **%b are ' ! and idioris coming Iri will be reconfed Eve p.-Ibwer, irt December                                  o         ' f 1987.

past. In the esent of a real emergency, suens encouraging everyone to identify aH such i o'r'elethonically. EfchE port will bias., P McNeill ' completed $ 20-year career waid mmd for Oirce to fise minutes, issues to their supervision and to plant signed is number add investigated. An id-Mith the'd.S. Navy in 1981, ha Ang com-atenting residents to listen to radio and management," says IIelwig. But the new %stig:iliod ieport 6i cach concern will 8]manded the" USS 'Piutog and the Naval cm, a- w 2 hotline is for those concerns that em-  ; ., C=6==d = N 2 7 ' c, rim,a = N 2

                                                                                                                                                                   *Q
                                                                                                                                                                    .                 ' I:

t . '

                                                                                                                                                                                                                        -l l   Page 2                                                                                       TIIE SUSQUEllANNA LIGIIT                                                                        March 16.1988         !

3 : ii l XuclearQualityHotlineEstablished xetSchedule !i . . . .- nj ForSirens come back to IIelwig's office, arw! those r ; y s f, who report concerns can get informa' son I Ce=t=wd/mm N f i j , f ' l on tir results of tir imrstigation by rvfer- i f

                                                                                  ;        Ll                                           ,                               tfievision stations for instructions      .m    ,;

j ring to it try its assigned number. 1

                                                                        <b                 l emergency response agencies.                    .;

L' I{. \g 1IcIwig says that while he woubl prefer

                                                                                             ' ', ,i 1                                                                                                                                                                          Federal guk'elines stipuhte that the          '

i that concerns he pursued thr<nigh tir '

; 'Y d
                                                                                                               .           I                                            ernergency warnirig sireri systern inust t>e Company organization, through regular                         ' y :; j            j fy                      y'                                             tested periodically.

j 4 j supervision or by use of the llothne, , e

                                                                                                                                                        ,                  The sirens are sounded by county
;   anw>nynw nisly or not, these channels in no              . ..            !
                                                                                ~,i!           g     .-        6 emergency management personnel. The w iy replace amune s nghts to take Iheir                                                                                                                    >

j conccrns clirectly to Ihe NRC. There are ,li- l iI ,j rI , ! g. :J

                                                                                                        ' ,[                                           \,

E{'Z is all the area within appmximately 10 miles of the Peach Bottom plant.

NRL, rrsient insicciors at Peach Ik>ttony )

and at I.nncnck and the regional NRL I)uring the monthly tests t!rre will be j

   < Ifires are located nearby m hing of                                                                                                                                no activity by emergency responsc agen-j                                                                                                                                                                        cies. The Emergency Broadcast System i                                                                                                                                                                        wi!I not be activated and the pub 5c will not be expected to take any action.

! . In the unlikely event of a real emer-TrimTrees Safely  % xencv i2xina riace aerina ihe testiez. county officials would make announce-I Alrivs check for wires nmning ihnnigh ments on radio and television stations. tace linitrs, bus!rs arwl otirr leavily <nvr- The siren system was installed and is

                                                         ~                                                                                                              " " "               *"E        U I             k n la<kler instead of a nrtal

! one, a.wl even then keep wvil clear of ' m AnL sirens am sounN sim v only by onler of the emergency manage- ! l I) avid R. IIelwig I'E's genera' manager, nuclear quality assurance, ment officials in each county.

   ]r irw s A}                    ,

willi the Nuclear Group quality concerns hotline equipment. The tint or reach so far that pni can't see where pns rc cutting. Ako. make certain yni can is open 24 hours a day to receive reports, identified or anonymous, of deficiencies or concerns about any aspect of the Company's nuclear I confidently han<lle a power saw or other heavy ceguipment. operations. { OfPowerLines Maryland Health Fair At Whiteford Center Being Studied *

  • I "'E" #"T T!r Whitefor.1 Family Ca:e Center on free tralth screenings for ble wwl pressure. through increased personal health aware-Wheelcr Srhool Road in Whiteford, Marybnd is prepasing to ho<.t a "Mary-visual:n,iity. Iriyht arwl wright along wit):

Iralth pmnwition activitics and counsefing ness. Rose atterxling tlie Fair will get in-formation about possibk? health pmblems ( [([ 1[ [d The majority of studies conducted in and ways to change or impmvc their life-bnd iIcatth Fair 88." an<I refer ral services. the United States over the past 25 years sylet have found that electric and magnetic j On Friday. April 9. Imm 8 a.m. thnnigh De idea hehirwi "Marytarvi IIcalth Fair . . . . 1 p.m., the Whiteford Center will offer 88" is to promote healthier lifestyles kl ca adve se health effects Bu d Si of ! MaryLind. WBAl, Radio and TV and the To alleviate any concerns Philadelphia

   --                             -                                                    ---==---i                        Amencan Red crm in noncoring the                m _. . - c      .,__.._ _...,,,_ _, _

j __

 ,                Handout distributed to PBAPS workers at ALL HANDS MEETINGS held on February 17 and 18,1988 OUALITY CONCERNS                                            ?

They are ours as well . . . If you have a concern -

  • bring it to your supervisor If you are not satisfied with the results e

take the concern up the chain even to the Vice-President, if necessar,y If you are still not satisfied, e call the Quality Concerns Hotline 81-4900 or 215-841-4900 QUALITYIS EVERYONE'S CONCERN . If you em not satisfied with re'sults from the Quality Concerns Hotline You can always call the NRC

      \               Resident Inspector
                      # 456 4 614                                                  .

_ ._m p*** ****se , UNITED STATES NUCLEAR REGULATORY COMMISSION

      .e              _fe,                                                                                                                                                                                           Washington, D.C. 20555 ie                  -, i                                                                                       NOTICE TO EMPLOYEES k *eee' .E                                                                                     STANDARDS FOR PROTECTION AGAINST f"ADIATIO'W (PART 201. NOTICES. INSTRUCTIONS ANO REPORTS TO WORKE RS. INSPECTIONS (PART 19t EMPLOYEE PROTECTION
WHAT IS THE NUCLEAR WHAT IS MY RESPONSIBILITY? MAY I GET A RECORD OF work.ag crmd*heae. you mov reewet sa VVHAT FORMS OF DISCRIMINA. WHAT CAN THE LABOR P EGULieTORY COMMIS$3ON? ,, MY RADIATION EXPOSURE? *noeciana Yew r* wn wwu es am TION ARE PROHIBITEO? DEPARTMENT 007 med
  • e'w en C Regoaa The Nuc6ser hensee se ye., co.orne,,, ,e. ne.nd nae. he. ve. vous e ,se,e, .e w, s ee wg ,e No emp**ver mov e.re ve y d.ecresuame The Deewenione e Leeuw a av.e, me
   -de.ead.a. Ieder ery     Co==.emea re.de,-,   e-v -no en            .C ree-re a.s re.          . ,* eur .or e d                  - e.                                v. r-e.ee .-e.                                                                              es                                                       ee       .e.                                          e            e, e como a_                   d some.h.* be liceamat ead w. opec'*g aucher posure seewe the an.=es see a che NRC vie = m deed. N muu to cred h, m er                                     s. - ee ,e.. t.sae.as,. e,
                                                                                                                                                                                                                                                                                                                 ,,,,,,,,,,,,,,,,,,,c,,,,v,,,e,,,                       ,ne ,,, ,,wu,p,, p, ,w.

eheued ,ew, them se yo. ee,s e.eia,.no po.et pienes and other c. ;iel e,see of of stie requ.remoan, yo.e ehe.pd repyt rees8st.eae. er your e eusever s kease la NRC g red.eectees mereress,. se . odest.ea. <# voor sete meos w. res.se.ca- HOW DO I CONTACT THE NRC7 HOW AM I PROTECTED FROM *"*'o*" **c'****ad WHAT DOES THE 1RC DO7 't )",,,, ",e,s. .ea Neefy wo N4C imoeew onese er ces DISCRtMINATION? *eman vee.""a a*.a'****"v ev weer vou to tw a. HOW DO I REPORT VIOLATSONSF ,eso, . mM m Fh T'e IrmC awaarv senosawn.rlty is to

   - m.'s.            .e -         .u .c .*

of yo er .,.t~g ohn.,.e

                                                                      ,ar_se     ,seesa.e= e_s NnC         ,r-d.rwies-~-
                                                                                                                        "'d e armea w,.re er eur wea easewre
                                                                                                                                              .se. - ,o.v..                                                                                                [e  a
                                                                                                                                                                                                                                                           ,,e .,, .ed N

e,,,,,, ,e,,_ ec y ,,

                                                                                                                                                                                                                                                                                             ,,,e,, e, e,,,e, g vew gg,w *M vow w tw,, +$c,,,*,

as d .- ~ -v - 9 tey w_,_e,. t u. to the NRC, yew may ble e compow.t we,h posecwd from uaneceemory er escoseae yo pe.se ,eper, me. enmedevei, se , cur moecn e81. ceased so a.e, such en me WHAT WILL THE NRC 00? esecewe se redee.ea and shot aucteer oveerv.ac. of yo ees.se'shes edeousee HOW AltE VIOLATIONS OF NRC the u S. Deperiniwa of Latner. Your com-es cr e s eachat.ag power eseaes are coa- cereactee acteoa .e v au t r., usea, vow REQUIREMENTS IDENTIFIEDF ****v,e'**""****a*8'*"'**** pe.as a n descr.ee me f..ae er acer.m.**'

                                                                                                                                                                                                                                                                                                                  *** **8 "t > f.ke           ma M deys e me The Nmc me, see se the Deow,mean ee eerwceed to sugh onesqv seeadeeds sad                 a.e, ,eper, ih.e e4 en NRC enspener er                          NpC coac. css requier saepect.eas et IIceawd                                                                                                                                                                                                   g,,,,,e,,,,,,,,,,,,,,ung,,,,,,,

opermed ta e see . _ . The mmc does tow nearese NMC Repeast O'fece. far.s. we r3 soeure CAN I BE FtRED FOR TALKING am m e.a =ww.eseen .h e necene, sa ed. c,omps acee.,sevem NRC TO THE NRC? Sead comp 4 mars ee. ae thee 99 emetNaas reew- - .a Title 10 ,ee se-,,,e a.ea, go, todeer=.as=eweew,uwe.#wse ,w,,,,,, a HAT V"OnK IN A ,,,,,,,,,,,,,,,,%,,,, of Cm, eae- Code

             -o wof foderes me, d sedeem.es
                                     ~        (to o.
                                                                                                                         ,,e,,,,g,,,,,,,,,,%..,.,.%,,,,,

o.c. e. .ee.re c eme- ,,,_,,,_,e,e,,,,_e.,,,,,,___, ,,,, s d ,ee_ ,_ea

                                                                                                                                                                                                                                                                                                                                                                        . .            - ~

specto.s ere powceems me, Ie.estes Lea Nmc or Departmeat of Letser *.ade em of yo. .ert e res.oecerme a.sesres s er in , , , , , , , , , , p ,,,e p  %,,,,,,, e r hee.e sceaoen.n erw. see - :e ia' *~ am m m== ==v ===N

  • wHAT CESPONSIBILITY DOES remotea eso eure the ve *ae, beney creamos crowrunen ser a f edwel er%aw.

ceae se the awae.ea of me Nac. ve. u s. Dee waeae e Leemer ami e 53W2

                                                                                                                                                                                                                                                                                                                                                                        "'""*'*'**'""""*'******"*".c'8**

NRC =ay issue a Neoce of V oie* a se MY EMPLOYER HAVEF , e he e.,ed air disc, imed

                                                                                                                                                                                                                                                                                                                                                                         '** '*#"""'****'***'"""d rer        6e swa.es.f by the NRC. The hash oa                                                                                                                                                    tweeuw yew.                                             200 Ceamtween Awaew.** w'                            moe' fv. er reeohe your e*oseveeNRC Aay compeay that conducts actio t o                                sovre we cwie ed ist wetse e                     MAY I TALK WITH AN NRC                                                                                                                                                                    """*'**-

bc need tiv the NRC must reaipov ==* INSPECTOR 7 e e.h she r;nC se ea8erce its awks ege. nee htoaw 20.101.20103.and 20 toe of T vie to ee your erapiover er saw .etel o'hr* et she Departmeat of

    ** 88 D                     8' ' **'"8'**V           po r dee of f ederes Regdes.eae (10 C7 N                       ves your                                                       e e, aae pewne yew
    - NRC w"9"a"***"e'* .-d                               20,. .h.se        e .e t e       e        a -                   e_ , , , Noc .a.,_,or                                                                                                       d    e      e.    .           C .,eces.,_, .                       . -e - No- a-ea. C>-e -

he~a"****.==a***- ,- m .d e.oo 6- vo, ,,.e.,e,,

                                                                                                                                                                                                                                                                                                                   "'    ea* *'ac'*v *ad- us c_

so.ed. ha es. ,e re e.,oa e._e es ,e. e, _ ,,,e.e ., ., e,es,er,,,, e .re -.---.a . -e ou. .e be.'.'* .

                                                                                                                                                                       " "                                                                                                 aem                   NRC shous ve., empseyw mouse ses you which NaC                  twaas a Waeaena, achemenw '                                          ,,,,,,,,                                                                                                                               ,,',g ese se.en me.we=enes aces , se veur . erb MAY I FEQUEST AN IN5PECTION?                                                                                                       e        shour e        si sw or wn.sy. swie.
    ,.e muss som espC Ner.ces of v.oispea                                                                                                                                                                                                                     8' '8' 8"' 'a sa NRC pecweag er esses remodeg.cas werting coad.neie.                                                                              ,, ,e, awae,                                           , ye , - _ _ - hoe noe correrted uselessene sauseweg ree. fog.ced UNITED STATES NUCLEAR REGULATORY COMMISSION REGIONAL
  • OFFICE LOCATIONS
s. The Repenel ONeos een semera e.diect - . dW A, _ of the Nuclear R*Tuamor, O cea to esaucmf et me fo#eemas addresse end -

opioyes. he en is reyere- co-pas.ie se emae..e ehe. red.eleyces .erh m, esamtenas er other emners weareas semp4* ace wah C - 'wl" ead "e"88**"*- Regeonel Offices atosose Aooma ss Ta ttrNoNE _]

                                            ""                 ==          =a"                                      e                                                                                                                                                                                            e            a s. es         ehed=., c_

s  ! ,, , c, ruga o si.e.- e 215 W 5000 a* Ab*_SK A R.CO

e. I '.'n.e'*

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  • 404 331 4503 I
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ISSUE: Organization and Staffing: Potential Impairment of Communications and Use of Navy Experience APPROACH: At our meeting on July 15, PE will brief the Commonwealth's representatives on its staff selection process and will discuss the experience embodied in the current organization and its contribution, including navy nuclear experience, to the formation of a strong management team. 1 CLOSURE: 1. PE will provide a briefing on the selection process at the July 15 meeting.

2. PE will provide a tabulation of nuclear Navy and civilian nuclear experience.
3. PE will brief the Commonwealth on organizational improvements since issuance of the shutdown order.

5

i i I ISSUE: Independent Safety Engineering, Operating Experience Assessment, and Re-Evaluation of Industry Experience. APPROACH: The Independent Safety Engineering Group (ISEG) and the Operating Experience Assessment Program (OEAP) are separate organizations and programs with distinct functions. The ISEG is part of the Independent Safety Engineering Division (ISED) of the Nuclear Quality Assurance Department. The OEAP is a program administered by the Nuclear Support Division of the Nuclear Services Department. The major ISED functions are to examine information and to review and investigate events at PE's nuclear plants in order to determine ways to improve plant safety. The charter for the ISED is attached. The OEAP has been revised and was fully implemented on July 1, 1988. The OEAP evaluates information from the nuclear industry and from Peach Bottom and Limerick events to determine what actions are needed at PE to mitigate or prevent similar events f rom occurring at Peach Bottom or Limerick. The Nuclear Group Administrative Procedure, NGS-0XX.Y, which describes the OEAP is attached.

PE is re-evaluating previously closed Significant Operating Experience Reports (SOERs). The result of the evaluation and planned actions will be provided. In order to provide a detailed explanation of how the ISEC and OEAP operate and the results of the above re-evaluation of SOERs, PE proposes to conduct a briefing for Pennsylvania representatives on these issues at a time and location to be determined at the July 15, 1988, meeting. CLOSURE: 1. PE will provide a copy of the ISED Charter (attached).

2. PE will provide a copy of the NGAP which describes PE's operating Experience Assessment Program (Attached).
3. PE will conduct a briefing for Pennsylvania representatives on ISEG, OEAP and results of the re-evaluation of SOERs.

9 a

 *%-   M   e NUCLEAR QUALITY ASSURANCE     .

Independent Safety Engineering Division

                                                   $7-1, 2301 Market Street-March 8, 1988 i-                                                               Rev. 4                                      i MEMORANDUM                                                                                   i s ..

j

SUBJECT:

Charter for'ISElDivision (ISED) 4-Division Goal: The' Independent Safety Engineering Divisicn (ISED)-will conduct its activities in a manner which will identify it as a leader among such f organizations in the nuclear industry, L 1.

The IFE0 will perform its Technical Specification-mandated role of examining information which may indicate areas for improving unit safety and making  ;

recommendations for means of improving unit safety by: o Reviewing external operating experience-which may identify areas of Plant operation which should be examined, i o i Reviewing and trending internal operating experience. o Actively participating in the BWR Owners Group Scram Frequency Reaction-Committee. o Conducting routine (a minimum of 5 days / week) observations of. Plant operations and maintenance activities.

                                                                                                         ~!

i

!                       o Conducting preplanned surveillances of. Plant activities,' identified
i. based on analysis of internal and external operating information. t o

Maintaining an up-to-date awareness of PECo Nuclear and Plant o Providing input to the Company's Operating Experience Assessment Program, o Assessing whether plant activities are performed correctly and whether human' errors are reduced as far as practicable. ' I l l I i l l I i 4

P 4 Page 2

11. The ISED will perform activities mandated by commitments to other PECo organizations or regulatory b mies as follows:

o Reviewing safety evaluations (mandated by NR8 and comt.titted to in "Plan for Restert of P8APS" suomittec to the NRC on November 25, 1987), o Monitoring the timeliness and adequacy of actions taken by Management in response to tne Operating Experience Assessment Program (mandated by Company's "Plan for restart of PBAPS" submitted to the NRC on November 25,1987). o Reviewi.ng of Plant readiness for restart after each refueling and other major maintenance outage by reviewing identified ISED Concerns (committed to in letter frcm J. W. Gallagher to NRC, dated November 9, 1937). III. The ISED will conduct the following activities related to specific events / requests: 1 o Perform an independent review of each Scram at each Plant, i o Perform detailed investigations of events and/or incidents at each Plant determined by the Plant ISEG to have the potential for producing a recommendation for improving Plant safety. o Perform a review of the outage plan for open ISED concerns prior to entering a planned maintenance / refueling cutage, o Provide, within the limits of available resources and with appropriate ISE management approval, assistance to line organizations for special reviews / investigations. IV. The ISED will provide the results of ISED reviews and investigations by: o Providing feedback and input to Plant staff via attendance at and participation in meetings, o Generating formal recommendations to affected responsible Company l organizations and Company management as a result of ISED activities.

Page 3

v. ine ISE0 will manage its activities in a manner anicn allo.ss responsiveness to specific Plant events while assuring a systematic independent overview of all Plant activities by:

o Preparing a detliled systematic plan for activities / reviews to be conducted quarterly and annually, o Functioning indepencently of Plant management in order that reviews / investigations appropriately consider all aspects of all Plant activities. o Making regular reports on ISED activities to the General Manager, Nuclear Quality Assurance; the Nuclear Review Board; and the balance of Nuclear Group managsmen.t. o Making specific recommendations for improving the safety of nuclear operations to appropriate organizations and tracking the response to each recommendation, o Serving as the corporate focus for INP0's Human Performance Evaluation System. o Annually performing a self-asseisment of the performance of the ISED. Issued by: II

                                                      ,I   1   --
                                                        .    . Robb March 8, 1988 JTR/cmb i

l l I l l l 1 l i l i l

I e d l l l l 1 TITLE: Interim Nuclear Group Administrative Procedure for l Operating Experience Assessment Program l NO: NGS-0XX.Y REV. NO: 00 i I ISSUE DATE: 06-15-88 EFFECTIVE DATE: 07-01-88 PAGE 1 OF 9 l i 1.O PURPOSE This N.2 clear Group Standard (NGS) describes the Phila-  ! delphin Electric Company Operating Experience Assessment i Program (OEAP). The OEAP ev".luates information from the l nuclear industry and from Peach Bottom (PBAPS) and Limerick l (LGS) events to determine what actions are needed at PECO l to mitigate or prevent similar events from occurring at LGS or PBAPS. , I i 2.0 SCOPE This NGS applies to activities within the Nuclear Group l necessary to accomplish the OEAP. The NGS describes the major elements of the OEAP, defines responsibilities and i interfaces, identifies requirements of the OEAP, and identifies types of documents screened and evaluated by the OEAP. ' i 3.0 SOURCES AND REFERENCES 3.1 SOURCE DOCUMENTS 3.1.1 PECO Plan for Restart of Peach Bottom Atomic Power Station - Section I-Corporate Action (Rev. 1)  : Relating to OEAP. 3.1.2 PECO Plan for Restart of Peach Bottom Atomic Power Section II-PBAPS Actions Relating to Station - OEA P . 3.1.3 INPO Good Practice OE-901, Industry Operating Experience Review. 3.1.4 NUREG 0737 Item I.C.5, Procedures for Feedback of Operating Experience to Plant Staff I 3.1.5 PECO Commitment to NRC Generic Letter 83-28, letter to NRC dated April 23, 1984. f I 3.1.6 LGS FSAR Section 13.4.5 3.1.7 INPO Good Practice OE-902 Revision 01, In-house l Operating Experience Review, March 1987. ' 3.1.8 INPO 86-017, Significant Event Evaluation and Information Network (SEE-IN) Program Description, { May 1986. 3.1.9 INPO Good Practice TQ-502, Incorporating Operating l Experiences into Training Programs, May 1983. I T-88-259 i

l TITLE: Interim Nuclear Group Administrative Procedure for Operating Experience Assessaent Program i NO: NGS-0XX.Y REV. No: 00 ISSUE DATE: 06-15-88 EFFECTIVE DATE: 07-(>1-88 PAGE 2 OF 9 ) i I 3.1.10 INPO 85-001, Performance objectives & Criteria for Operating and NTOL Plants 3.1.11 INPO 87-030, Perfornance Objectives & Criteria for l Corporate Evaluations 3.2 CROSS-REFERENCE 3.2.1 NGAP-002.X, Commitment Tracking Program 3.2.2 NGAP-YY, Correspondence Control Program (later) 4.O DEFINITIONS 4.1 SIGNIFICANT EVENT EVALUATION AND INFORMATION NETWORK (SEE-1E.1. SEE-IN is managed by INPO for the purpose of screening nuclear plant events occurring worldwide and disseminating information on those events considered by INPO to be significant to safety and reliability. The SEE-IN Program is described in Reference 3.1.8. Information provided by plants on significant in-house events with generic implications is a key input to SEE-IN. 4.2 INPO SIGNIFICANT EVENT REPORTS (SERS) SERs are generated by the SEE-IN Program from the screening of Licensee Event Reports (LERs) and their operating experience reports. Each SER provides a brief description of the' significant event or problem and comments on why it was considered significant. SERs are disseminated via NUCLEAR NETWORK as they are identified. 4.3 INPO SIGNIFICANT OPERATING EXPERIENCE REPORTS (SOERS) i Each significant event identified in the SEE-IN Program undergoes analysis within INPO. When INPO recommendations l result from these analyses, the recommendations are l incorporated into an SOER. The SOER is disseminated by , mail from INPO. i 4.4 NUCLEAR NETWORK NUCLEAR NETWORK is a computerized communications network used to disseminate operating experience and other information to the industry. The operating experience T-88-259 l

l

                                                                                                  )

l l TITLE: Interim Nuclear Group Administrative Procedure for ' Operating Experience Assessment Program NO: NGS-0XX.Y REV. NO: 00 ISSUE DATE: 06-15-88 EFFECTIVE DATZ 07-01-88 PAGE 3 OF 9 information may be input by utilities, INPO, NSSS suppliers, architect / engineers, or others. 4.5 NRC NOTICES. BUTT 5' TINS. AND GENERIC LETTERS l The NRC uses information notices, bulletins and generic letters to inform licensees of problems of potential generic significance, to solicit supplemental information from licensees, or to require specific licensee actions in response to identified concerns. 4.6 GENERAL ELECTRIC IITTERS GE's Service Information Letters (SIL's), Rapid Information Communication SIL's (RIC SIL's), Technical Information Letters (TIL's), and Service Advisory Letters (SAL's) serve as sources of operating information from the vendor of the nuclear steam supply systems and other equipment for PBAPS and LGS. 4.7 SUPPORT ORGANIZATION Nuclear Engineering Department, Nuclear Services Department 4.8 STATIONS The PBAPS or LGS organizations with responsibility to: (a) evaluate an OEA item; (b) determine appropriate corrective action:. for an OEA item; or (c) imple=ent a corrective action identified in evaluation of an OEA item. 4.9 QEAP TRACKING SYSTEM i Administrative controls and computer software used to monitor the status of items under review in the OEAP. I 4.10 APPLICABLE ' An OEA item involving equipment or situations that are comparable to those of PBAPs or LGS. For the purposes of the OEAP, a broad interpretation of the terms "comparable" and "applicable" should be used. T-88-259 l l I I l

TITLE: Interim Nuclear Group Administrative Procedure for ! Operating Experience Assessment Program NO: NGS-0XX.Y REV. NO: 00 ISSUE DATE: 06-15-88 EFFECTIVE DATE: 07-01-88 PAGE 4 OF 9 5.0 RESPONSIBILITY AND AUTHORITY 5.1 VICE PRESIDENT-NUCUAR SERVICES Ensures that an effective Operating Experience Assessment Program is in place to analyze industry and plant operating experience and communicate the information in a timely ' manner to the Stations and other Nuclear Group organizations; monitors the effectiveness of line manage-ment's follow-up on the information,to achieve the desired results; ensures thint the Nuclear Services Department provides timely support to other organizational units requesting NSD assisuance in the evaluation of OEA items. 5.2 VICE. PRESIDENT-PSAPS. VICE PRESIDENT-LGS Ensures that the plant staffs evaluate applicable OEA items, develop and implement appropriate corrective actions in a timely manner. 5.3 VICE PBESIDENT-NUCLEAR ENGINEER QQ Ensures that the Nuclear Engineering Department provides ti=ely support to other organizational units requesting NED assistance in the evaluation of OEA items. 5.4 OEAP COOR7IHATQB A. Receives incoming information from external sources I and internal sources. l B. Forwards items to stations as appropriate. l l C. Reviews completed evaluations and recomrended I corrective actions for consistency and endorses the evaluation when satisfied. 4 D. Maintains information on the status of OEAP l assignments. ' E. Prepares monthly status reporta for senior management on corrective action progress with summary remarks

flagging overdue items and areas of concern.

] F. Performs a self-assessment of the effectiveness of the l OEAP on an annual basis. (An independent annual ) T-88-259

TITLE: Interim Nuclear Group Administrative Procedure for Operating Experience Assessment Program NO: NG S -0X.Y . Y REV. NO: 00 , ISSUE DATE: 06-15-88 EFFECTIVE DATE: 07 01-88 PAGE 5 OF 9 program effectiveness review of the OEAP will also be performed by HQA.) G. Reports on the OEAP through the Manager-Nuclear Support and the Vice President-Nuclear Services, to the Executive Vice President-Nuclear. H. Interfaces with INPO as the PECo primary contact on all matters relating to INPO's industry operating experience programs. I. Serves as the Company's INPO NETWORK Coordinator. 5.5 SUPERINTENDENT-TECHNICAL..__P.BAPS_ AND SUPERINTENDEbT-TECHNICAL. LGS Provides single point of contact for OEAP Coordinator's interface with PBAPS or LGS; identifies PBAPS or LGS staff to evaluate potentially applicable OEAP items assigned to the site by the OEAP Coordinator; maintains information on the status of OEA assignments at PBAPS or LGS in the 07A 3 tracking system; receives completed evaluation package from site staff; forwards completed evaluation package to OEAP Coordinator. 5.6 GENERAL MANAGER-NUCLEAR OUAIITY ASSURANCE Maintains independent oversight of the adequacy and timeliness of actions taken by line management in response to OEAP items; and conducts an annual audit to ensure effective implementation of the OEAP. 6.0 P_BEREOUTSITES Not applicable. 7.0 OEA PROGRAM 7.1 SCOPE The type of documents screened and evaluated by the OEAP are listed in Exhibit 1. 1 T-88-259

1 l TITLE: Interim Nuclear Group Administrative Procedure for Operating Experience Assem.ce".t Progr am , NO: NGS-0XX,Y REV. NO: 00 ' ISSUE DATE: 06-15-88 EFFECTIVE DATE: 07-01-58 PAGE 6 OF 9 7.2 PROCESS The process for receipt, screening, evaluating, and responding to OEA items is depicted in Exhibit 2. Highlights of the process are enumerated below. 7.2.1 RECEIPT  ! PECo addressees of external experience docunents identified in Exhibit 1 shall ensure that a. copy of identified documents which they receive is forwarded to the OEAP Coordinator. The OEAP Coordinator ensures that items provided by the NUCLEAR NETWORK are retrieved daily and fed into the OEA process. 7.2.2 PBAPS AND LGS EVENTS Nuclear Group organizations investigate and document PBAPS and LGS events in accordance with implementing procedures. Nuclear Groups responsible for this documentation disseminate copies to PBAPS, LGS, Nuclear Training, and other support organizations as appropriate .to ensure widespread awareness of lessons learned from events at PBAPS and LGS. The Stations prepare reports for issuance on NUCLEAR NETWORK for PECo evnts of potential significance to the nuclear industry. In addition, the Stations prepare Licensee Event Reports (LERs) as required by procedures for events reportable to NRC. The Stations ensure copies of PECo LERs and NETWORK reports are provided to the OEAP Coordinator. 7.2.3 LOGGING The OEA Coordinator logs ne; items into the OEA tracking system. He stores a copy of new items in the program files, in accordance with Document Control requirements. T-88-259 I w _ _ . .

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The OEAP Coordinator examines each OEAclearly item.and not determines. whether the itenor isis potentially applicable to PBAPS or LGS arplicable are applicable. Itens clearly not . verified by an independent reviewer to be no: applicable. I' the independent' reviewer concurs, the ite= is closed. The OEAP . Coordinator documents the basis for-his determina:ien, files the evaluation, and clcses the item en the OEA Tracking System. If the independent reviewer n .e.4.,1,y

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f the evaluater determines that thedeter item is applicable to his station, he also =ines whether services frc a sueport organi:atien actions. are necessary to deter ine corrective Support is requested, and prcvided, in accordance V:. h i=ple:enting procedures. The evaluator and the support organiza icns deter =ine c:rrective actions necessary to =itigate si=ilar cvent at his station. er prevent a

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                                                                                         ~ " - - - - - - - - - - - - - - _ _ . _ _ _ _ _ _ _ _ _                                                                                -               &

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                                                                                                              -l TITLE:     Interim    Nuclear     Group    Administrative                  Proceduto   for Operating Experience Assessment Program                                                   )

NO: NGS-0XX.Y REV. NO: 00 ISSUE DATE: 06-15-88 EFFECTIVE DATE: 07-01-88 PAGE 8 OF 9 Corrective actions may include changes to plant procedures, licensed operator training, other l personnel training, plant modifications', and 1

                            -dissemination of the          OEA. item to station and                             '

support organization personnel for action or i awareness. l 1 When the assigned evaluator determines thr.t the evaluation is complete and all corrective actions , have been identified, he ensures that the l evaluation is documented. He returns the evaluation to the Site Contact. The Site Contact ) verifies that the OEA item has been addressed and  ; returns the evaluation to the OEAP Coordinator. l The station organizations proceed with corrective i actions in accordance with implementing- I nrocedures, j 7.2.6 EVALUATION FOILOWUP i The OEAP Coordinator reviews the completed evt.luation and corrective .ctions. He ensures i that all items have been addressed and that corrective actions appear consistent with the OEA items and consistent between PPAPS and LGS as he  ! judges to be appropriate. I The OEAP Coordinator directs followup questions to l ' the assigned evaluator (s) as necessary. If answers require modifying the OEA evaluation, the i OEAP Coordinator returns the evaluation to the assigned evaluator, as necessary. When the OEAP Coordinator is satisfied that all items have been addressed appropriately, he endorses the evaluation by signature. The OEAP Coordinator files a copy of the approved I evaluation and closes the OEA item on the OEA l Tracking System. 7.2.7 CORRECTIVE ACTIONS The assigned evaluator (or evaluators), including Support Organizations, ensures that corrective actions determined from the evaluation of OEA items are entered into corrective action systems T-88-259

TITLE: Interim Nuclear Group Administrative Procedure for Operating Experience Assessment Program NO: NGS-0XX.Y REV. NO: 00 ISSUE DATE: 06-15-88 EFFECTIVE DATE: 07-01-88 PAGE 9 OF 9 I l or the Commitment Management System. The stations ensure that corrective actions committed in response to the OEA item are implemented in accordance with implementing procedures. 7.3 . REPORTS TO MANAGEMENT  ! The OEAP Coordinator shall ensure that a writter, report to l the Executive Vice President is issued at least monthly. l The written report shall identify problem areas and other I information necessary to permit management to verify  ; performance of the OEA program. The report should include ' (a) number of open items, (b) number of overdue items, (c) i number of items due in next two months. I l 8.O DOCUMENTATION The OEAP Coordinator shall retain a copy of OEA items l received for processing. OEA items shall be accompanied ' by a "traveler" to ensure a standard format for documentation of evaluations. 1 Documentation of the basis for completed evaluation 3 shall i be retained by the OEAP Coordinator in accordance w*th Document Control procedures. 9.O EXHIBITS 9.1 EXHIBIT 1 - TYPES OF DOCUMENTS INCLUPED IN THE OEAP 9.2 EXHIBIT 2 - INTERFACE AGREEMENT i l T-88-259 I i

l EXHIBIT 1 TYPES OF DOCUMENTS INCLUDED IN THE OEAP

1. External Experience Sources INPO o Significant Event Reports (SERs) o Significant Operating Experience Reports (SOERs) o' Significant by Others Notification (Sos) o SEE-IN Documents EE.C o IE Bulletins and Information Notices o Generic Letters 91 c Service Information Letters (SILs) o Rapid Information Communications SILs (RICSILs) o Technical Information Letters (TILs) o Service Ad isory Letters (SALs)

Other o Supplier and Architect / Engineer Reports

2. Internal Experience Sources o PBAPS and LGS LERs o PBAPS and LGS Network Items t

T-68-259 June 15, 1988

OPERATING EXPERIENCE ASSESSMENT PROGRAM INTERFACE AGREEMENT FINAL PflOCESS DIAGRAM Ff10M 4/19/01) OEAP SC MEETING OUTSIDE flEGIN ISSUE EXPERIENCE AGEtJCIES OCESS DOCUMENTS

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itibiT TO COMMITMEtJT ! TilACKitJG PflOGRAM (10 ItE DEFillED) SitPPORT 01IGAtJIZAllOt S tressee g (t A to 44 a LI

1 ISSUE: Mark I Containment Issues' APPROACH: On May 25, 1988,_ the NRC issued SECY-88-147, "Integration Plan - for Closure of Severe Accident' Issues," which-addresses-Mark.1 containment. issues. The NRC's plan includes consideration of a requirement for Individual Plant Esaminations (IPE) and generic containment performance improvements, as well as other severe - accident issues. PE is closely following the NRC's progress oa this issue. We will evaluate final NRC requirements when they are promulgated to determine appropriate PE actions in support of Peach Bottom. CLOSURE: 1. NRC action necessary to formalize specific . requirements.

2. PE will determine appropriate action for Peach Bottom upon -

promulgation of NRC requirements. s

ISSUE: Other Hardware Issues APPROACH: The Commonwealth expressed concern over the capacity of the spent fuel pool, the main condenser leakage, and cracks in the reactor vessel shroud structure. As you know, we are addretsing all of these issues and have taken appropriate. steps for their resolution. Since these are principally economic rather than safety issues, they are not tied to Peach Bottom restart. d CLOSURE: A briefing on the status of our plans for dealing with these hardware issues will be scheduled at the July 15 meeting. i l l

ISSUE: Commitment Tracking APPROACH: .An enhanced Commitment Tracking Program (CTP) was developed by PE in January, .1988. The new program provides a high level of if.ne management and staff involvement to identify, implement and assure compliance with PE commitments. The Nuclear Group Administrative Procedure, NGAP-002.X, which describes the PE Commitment Tracking Program, is attached. The enhanced CTP was fully implemented July 1,1988 and will be more fully discussed at a time to be agreed upon. CLOSURE: 1. PE will provide a copy of NGAP-002.X, which describes the CTP (attached).

2. PE will conduct a briefing on CTP for Pennsylvania representatives.
t. :
p Proccdure for
  • TITLE: Interin Nuclear Group Administrative Co=itment Tracking Pr ogram
     -NO:            NGAP-002.X    REV. NO: 00 EFFECTIVE DATE: 07-01-88                       PAGE 1 CP 13 ISSUE DATE: 07-01-8B 1.O      PURPOSE This Nuclear Group           Administrative Procedure' (NGAP)

Companys ,(PECO) describes the. Philadelphia Electric Commitment Tracking Program (CTP). Spo.cifically, this NGAP-establishes the responsibilities, authorities,-process and ~ assuring and interfaces for tracking organicational organizations compliance with PECO commitments ~ to the listed in Exhibit 1.- 2.0 Ecof_E_ This NGAP applies to commitment tracking and compliance activities for its operating nuclear facilities (PBAPSiand. LGS Unit 1). Commitments within the CTP scope are those made to or imposed by the organizations listed in E>:hibit- 1 with the exception that Design Basis commitments are-not within the scope of the CTP. Design Basis commitments are within the scope of the Configuration Management Program. The documents that shall, as a minimum, be reviewed to identify commitments are listed in Exhibit 2. i i 3.O SOURCES AND REFERENCES 3.1 SOURCE DOCUMENTS i 3.1.1 PECO Plan for Restart of Peach Bottom Atomic' Power 1, Station - Section I-Corporate Actions, Revision Relating to CTP. 3.1.2 PECO Plan for RestartII-PBAPS of PeachActions Botton Atomic

                                                                                      ~ Relating. Powerto-Station    -

Section CTP. 3.2 CROSS-REFERENCES Policy No. 2.1, Licensing and 3.2.1 Nuclear Group Regulatory 3.2.2 NGAP-AA, Configuration Management Program (later) 3.2.3 NGAP-EB, Correspondence Control Program (later) T-88-280.REV 06/15/88

Interin Nuclear Group Administrative Procedure for TITLE: Corsitment Tracking Program NO: NGAP-002.X REV. NO:' 00 EFFECTIVE DATE: 07-01-88 PAGE 2 OF 13 ISSUE DATE: 07-01-88 NGAP-052.1, Preparation and Control of Nuclear 3.2.4 Group Administrative Procedures 4.O DEFINITIONS 4.1 COMMITMENT A documented obligation, either. imposed upon or made by.a designated PECO representative by one of the organizations listed in Exhibit 1, that either has or will establish requirements or promises actions to be performed. 4.2 ACTION ITEM COMMITMENTS Commitments that require a non-routine, one time, future action by PECO, where an action may be a single activity or set of activities. 4.3 PROGRAMMATIC COMMITMENTS Commitments that: (a) define or describe required programs, (b) require continuing routine / periodic actions by PECO over a defined period of time or (c) maintenance of l an existing programmatic condition. 4.4 DESIGN BASIS COMMITMENTS Corsitments that describe the design criteria or design and j basis associated with the structures, syste=s l components of PBAPS or LGS. 4.5 HISTORICAL COMMITMENTS Cormitments that have been closed out and, th ere f :. re , do-not require future action. Historical commitments are typically Completed Action Item Commitments, but can also include commitments that are closed on some ether basis, for example, commitments that are superceded by or redundant to other corsitments. Historical commitment data records are archived in a data base, for retrieval when required, and provide the principal historical record describing how each commitment was satisfied or closed out. T-88-280.REV 06/15/S8

TITLE: Interim Nuclear Group Administrative Procedure for Commitment Tracking Program NO: NGAP-002.X REV. NO: 00 ISSUE DATE: 07-01-88 EFFECTIVE DATE: 07-01-88 PAGE 3 OF 13 4.6 RESPONSIBLE DEPARTMENT The department (PBAPS, LGS, NED, NSD or NQA) assigned to either implement or ensure continuing compliance with a commitment. 4.7 RESPONSIBLE IMPLEMENTING ORGANIZATION (RIO) assigned by the Responsible Department to The Section implement a commitment or a section that is responsible for procedures or other controlled documents that implement one or more Prograrratic Commitments. 4.8 RESPONSIBLE INDIVIDUAL The individual in the RIO accountable for carrying out the activities and responsibilities of the RIO. 4.9 SUPPORT ORGANIZATIONS An organization that is assigned to perform a specified task to support the RIO in implementing a corritment. 4.10 IMPLEFENTING DOCUMEFT A document that contains information that forms the basis for partially or completely satisfying a commitment. For Action Item cormitmente, implementing-documents can be any of a wide variety of documents including: procedures, modification packages, calculations, correspondence, program plants, etc. For Prograrratic Commitments implementing documents are typically controlled procedures, but can be other controlled documents, such as the Quality Assurance Manual. 5.0 RESPONSIBILITY AND AUTHORITY 5.1 RESPONSIBILITIES 5.1.1 Vice President - PBAPS, Vice Precident-LCS are accountable for the following activities for corritments assigned to PBAPS or LGS: T-88-280 REV 06/15/88

1 TITLE: Interin Nuclear Group Administrative Procedure for Commitment Tracking Prograta NO: NGAP-002.X REV. NO: 00 ISSUE DATE: 07-01-80 EFFECTIVE DATE: 07-01-88 PAGE 4 OF. 13 A. Ensures that commitment implementation recponsibilities are assigned. to a RIO and Responsible Individual. B. Ensurts that commitnent implementation activi-ties assigned to plant staff are timely, and correctly implement the committed to actions. C. Ensures that Programmatic Commitments assigned are complied with on a-to plant staff continuing basis. 5.1.2 Vice President - Nuclear Services is accountable for ensuring that an ef f ective Commitment Tracking Program is in place to: A. Identify new or revised cc:=itments; B. Identify the Nuclear Group Department respon-sible for implementing commitments: C. Track the status of commitment implementation activities to closure; D. Maintain a current, concise and accurate data Action Item, Programmatic and base (s) of Historical Commitment data records. 5.1.3 Vice President - Nuclear Encineerino- and Vice President - Nuclear SeWices are accountable for the following: A. Ensures that commitment implementation responsibilities are assigned to a RIO and Responsible Individual. B. Ensures that commitment implementation activi-ties assigned to NED or NSD are timely and correctly implement the committed to actions. C. Ensures the ' Programmatic Commitments assigned to NED or NSD are complied with on a continuing basis. 5.1.4 Commitment Trackinc Orcanization is accountable for the following activities: T-88-280.REV 06/15/88

TITLE: Interin Nuclear Group Administrative Procedure for Commitment Trac);ing Program NO: NGAP-002.X REV..NO: 00 ~ ISSUE DATE:' 07-01-88 EFFEC"RIVE DATE: 07-01-88 PAGE 5 OF 13 A. With the exception of safeguards Information, receives and reviews incoming information from external sources and internal sources fcr commitment identification. Forwards commitments as appropriate to B. Responsible Departments for implementation. C. Consults with Responsible Departments to identify the RIO and Responsible Individual for commitment action and schedule for that action. D. Maintains information on the status of co=it-ment trac):ing assignments. E. Prepares t.onthly status reports for senior management on co=itment trac);ing status with su=ary remar);s flagging overdue -items and areas of concern. F. Performs a self-assessment cf the effective-ness of the Co=itment Trac);ing Program on an annual basis. (An independent annual program effectiveness review of the CTP will also be performed by NQA.) G. Reports on the CTP through Director o f' Licensing to the Manager-Nuclear Support and the Vice President-Nuclear- Services, to the l Executive Vice President-Nuclear. i

                                                                                  )

1 5.1.5 Director, Nuclear Plant Security Sectica is accountable for the following activities: A. Evaluates proposed new co=itments in draft outgoing documents containing safeguards information. B. Receives and reviews safeguards information l from external and internal sources for I commitment identification. C. Completes commitment data records to the extent possible, without recording safeguards T-88-280.REV 06/15/88

for TITLE: Interim Nuclear Group Administrative- Procedure Commitment Tracking Program NO: NGAP-002.X REV. NO: 00 EFFECTIVE DATE: 07-01-88 PAGE 6 OF 13 ISSUE DATE: 07-01-88 information.. This Vill typically include all required fields in the data record with the exception of all or part of the "Statement of Commitment". Specifically it shall include.the identification of the Responsible Department. D. Forwards completed data . records to the Cormitment Tracking organization for entry into the commitment tracking data base. E. Consults with NSD Licensing as necessary to control and assist in the processing of proposed revisions to commitments containing safeguards information. F. Provides limited verification of cc=mitment closure for commitments containing safeguards information. G. Ensures that Programmatic Commite.ents containing safeguards information are complied with on a continuing basis. 5.1.6 NSD Licensinc/ Site Reculatorv Orcanization are accountable for performing those activities necessary to: A. Evaluate from a regulatory perspective, proposed new or revised commitments in. draft outgoing documents to the external agencies listed in Exhibit 1. B. Control and process revisions.to corritments. C. Provide limited verification of .coraitment Closure. Nuclear Oualitv Assurance is 5.1.7 General Manacer, accountable for the following activities: A. Ensures that the closure of commitments made in responses to NRC Notices of Violation and INPO Findings are verified. T-88-280.REV 06/15/88 \ - -

TITLE: Interim Nuclear Group Administrative Procedure for Commitment Trac);ing Program NO: NGAP-002.X REV. NO: 00 ISSUE DATE: 07-01-88 EFFECTIVE DATE: 07-01-88 PAGE 7 OF 13 B. Ensures that commitment _ implementation responsibilities are assigned to a RIO and Responsible Individual. C. Ensures that commitment implementation activities assigned to NQA are timely, and correctly implement the committed to actions. . D.- Ensures that Prograrratic Commitments assigned to HQA are complied with on a continuing basis.- 5.1.8 ResDonsible Imolementine Orcanization- in accountable for (1) managing the. corritment implementation activities for assigned Action Item commitments or (2) ensuring continuing compliance with Programmatic Commitments for assigned-Implementing Documents. For Action Item Commitments this includes: A. Plans commitment implementation t a s):s (schedule, manpower, budget). B. Acquires support from other organizations (Support RIos) as necessary to plan and perform the implementation tas);s. of all tas); C. Coordinates the activities participants to ensure completion of assigned activities within agreed to schedules. D. Consolidates all necessary documentation into a Commitment Completion Pac}; age. E. Consults with/ assists Licensing and/or the Site Regulatory Organization, as required, with the preparation of documents to e>:ternal organizations relative to the implementation.of the commitmen ,

                                                                                              \

For Prograrmatic Cormitments this includes: l A. Ensures that Implementing Documents containing j assigned corritments are not changed without an evaluation of their impact on corsitments. T-88-280.REV 06/15/88 l

TITLE: Interin Nuclear Group Administrative Procedure for Commitment Tracking Program NO: NGAP-002.X REV. NO: 00 ISSUE DATE: 07-01-88 EFFECTIVE DATE: 07-01-88 PAGE 8 OT 13 B. Identifies the impacts of planned revisions to Irnplementing . Documents on existing' commitments. as Develops proposed . commitment- revisions, appropriate. with NSD Licensing or the Site C. Consults Regulatory Organization .to ensure that proposed commitment revisions are captured'and appropriately processed. D. Prepares a documentation package to provide-objective evidence of the comnitment review prior to revising- assigned Implementing Documents. 5.1.9 Succort Orcanizations are accountable for the timeliness, completeness and quality of perf ormance of assigned commitment implementation tasks. 5.1.10 Pesconsible Individual is responsible for carrying out the activities and responsibilities of the RIO. 5.2 AUTHORITY PECO corsitments can only be made~by Nuclear Group Vice

                                           ~

Presidents or above; their direct reports; or the General Manager, Nuclear Quality Assurance. 6.O PREREOUISITES Not Applicable, 7.0 COMMITMENT TRACKING PROGRAM 7.1 PROCESS DIAGRAM The process for the Corsitment Tracking Program is depicted in Exhibit 3. . Highlights of the process are delineated below. 7.1.1 Nev/ Revised Commitments Draft documents to the external acencies listed-in identify and Exhibit 1 shall be reviewed f.o T-88-280.REV 06/15/88

TITLE: Interin Nuclear Group Administrative Procedure for Commitment Tracking Program NO: NGAP-002.X .REV. NO: 00 ISSUE DATE: 07-01-88 EFFECTIVE DATE: 07-01-88 PAGE.9'OT 13 4 evaluate new or revised commitments. This review shall include an identification and review .of existing related commitments as well as an estimate for of the schedule,' budgets and priorities implementation of the commitments.' New or revised commitments that will require special budget in-approvals to implement, shall .be planned accordance with the Integrated Management Process and approved by appropriate, management prior to submittal to external agencies. These activities shall be carried out by the organization originating the commitment in consultation with the Site Regulatory Organization or' NSD Licensing, as appropriate. Requests for revision to existing commitments shall be evaluated by the Site Regulatory Organization or NSD Licensing to identify the regulatory impact and to identify and coordinate the appropriate regulatory . actions necessary to revise the Commitment. 7.1.2 Docurent Cacture The Document Control Organization shall capture and distribute a copy to the Commitment Tracking Organization, of all incoming and outgoing documents listed in Exhibit 2. l I 7.1.3 Cornitnent Identification The Commitment Tracking Organization shall review in Exhibit 2 to identify all documents listed commitments and complete commitment data records. This commitment identification process shall include: (a) a requirement to document the review I and disposition of documents reviewed and (b) l verification of newly created or revised comm'tment data records by a second individual. 1 7.1.4 Ide-tifv/Acree on Restonsibilitv The Commitment Tracking organization shall identify the Responsible Department for eachshall new commitment. The identified department review the proposed assignment and shall notify the T-88-280.REV 06/15/88

TITLE: Interin Nuclear Group' Administrative Procedure 'for Co==itment Trac):ing Program NO: NGAP-002.X RI:V. NO: 00 ISSUS DATE: 07-01-88 EFFECTIVE DATE: 07-01-88 PAGE 10 OP 12' Commitment Trac):ing ' Organi::ation as to:whether it agrees or disagrees with. the assignment. When an agreement has been reached, the Commitment' Trac};ing organi::etion shall ' enter the assignment int o the commitment data base. The Responsible Department shall assign a RIO, which in turn shall assign a Responsible Individual for Corsitment implementation. Tnese

                 -assignments shall be entered into the Commitment data base.

7.1.5 Ta sl: Plannino The Responsible Individual shall plan the tas):s necessary to implement the assigned commitment and-enter the completion due date (if not already established by the commitment itself) into the Con =itment data base. For commitment implementation activities that recuire special budget approvals, Tas): Planning shall include budget approvals and scheduling through the Integrated P.anagement Process as apprc:riate. 7.1.6 Ta s): Tra c):i nc The Responsible Individual shall routinely update _ the Cormitment data base to provide current status information. The Cc=itment Trac):ing Organization j shall generate routine and a- ho: reports fcr-managers at all levels as necetsary to monitor the-concitment activities within their areas cf responsibility. 7.1.7 Corritrent Closure Co=itment closure activities s h a l l i n c l u d e.: (a) consolidation of a Corsitment Conpletion Pac); age  ! by the RIO; (b) certification by the RIO that the j commitment has been satisfied; (c) a chec);ing activity by the Site Regulatory or NSD Licensing Organizations to the extent necessary to concur that the corritment has been closed; and (d) 100% verification by Nuclear Quality Assurance of the closure of ce=itments made in responses to NRC Notices of Violation and INPO findings. The T-SS-280.REV 06/15/88

i

                 . Interim      Nuclear Group Administrative                   Procedure        for TITLE:

Co=itment Tracking Program NO: NGAP-002.X REV.-NO: 00 EFFECTIVE DATE: 07-01-88 PNGE 11 OF 13 ISSUE DATE: 07-01-88 Commitment Tracking Organization shall archive and maintain the data records for closed commitments in the Commitment Tracking data base. 7.1.8 Continuina Comoliance with Existino Commitronts ensuring RIOs. assigned . responsibility .'f o r continuing compliance with Programmatic Commitments-shall control the revision of assigned Implementing are not-documents to assure that commitments inadvertently violated or changed. These controls shall inc3ude: (a) a review of the Commitment data base and development of documentation to provide evidence of this . review; (b) appropriuttexisting processing of requested revisions to corritments (see 7.1.1) . 8.0 DOCUMENTATIOli be retained to provide objective Documentation chall evidence of the performance, results and conclusions cf various cc=itment tracking ard compliance activities, and shall include the followinc. (a) a record of document reviews to identify cerc. . .cments ; (b) commitment closure RIO documentation (Commitment Completion ofPackage, verifying. certifications, and concurrence organizations); (c) commitmer.t data records for Action Item, Prograrsatic and Historical Commitments; (d)documents a record of com=itment review prior to revising implementing Programmatic Commitments; (e) the basis for approvals received and applicable regulatory ccrresp ndence , for co=itment 2.evisions; and (f) self assessment reports. l l 9.O EYHIBITS Included Scope of the Exhibit 01 - Organizations in Co=itment Tracking Program Exhibit 02 - Document Sources for Co=itments Exhibit 03 - Co=itment Tracking Process Diagram T-88-280.FIV 06/15/88

Interim Nuclear Group Administrative Procedure for TITLE: Commitment Tracking Program NGAP-002.X REV. NO: 00 NO: PAGE'12 OF 13 ISSUE DATE: 07-01-88 EFFECTIVE DATE: 07-01-88 COMMITMENT 9.1 ORGANIZATIONS IITCLUDED IN THE SCOPE OF THE TRACKING PROGRAM 9.1.1 External Organisations Nuclear Regulatory Commission (NRC)' U.S. Environmental Protection Agency-(EPA) State and Local Agencies U. S. Department of Transportation (DOT) American Nuclear Insurers (ANI) Institute of Nuclear Power Operations (INPO) Joint Utility Management Audits (JUMA) 9.1.2 Internal Organizations Nuclear Review Board (NRB) Independent Safety Evaluation Group (ISEG) Nuclear Quality Assurance (NOA) Operating Event Analysis Program (CEAP) 9.2 DOCUMENT SOURCES FOR COMMITMENTS NUCLEAR REGULATORY COMMISSION Iroosed Comritment Document Sources NRC Rules and Regulations (10 CFR)

        . Operating License and License Amendments                            I Technical Specifications                                             j NRC Orders l

i i 1 T-88-280.REV 06/15/86

e et

      ,TITLI:        Interim Nuclear- Group Administrative             Procedure                  for Commitment Tracking Program NO:           NOAP-002.X       REV. NO: 00 EFFECTIVE DATE:. 07-01-80.        PAGE 12 OT 12 ISSUE DATE: 07-01-88 Docunent Sources of Utility General Commitnents to NPT FSAR Environmental Reports Correspondence - Utility to NRC Quality Assurance Program Description Emergency Plan Environmental Qualification Program Fire Protection Program Plan Site Security Plan PSI /ISI/IST Program Descriptions Process Control Program Description Offsite Does Calculation Manual Special Reports (e.g., Event Related. Reports, Overexposure           Declared Reports, Effluent greater than Appendix I.

j Emergency Event Reports. ILRT Reports). . . Other R0utine Reports (Annual Rad. Env. Op Report, Annual 5-A. Env. Op. Report, Annual Personnel Exposure Report, Report, i Effluent Release Reports, Annual 10CFR50.59 Annual Operating Reports, Monthly Operating Reports) l l Hearing Transcripts 1 Other Potential NPC Cor-itren Docurent Sources-NRC Generic Letters NRC Letters Representing Information under 100FR50.54-(f) NRC Inspection Reports Requesting. info under 10CFR2.2401 NRC Safety Evaluation Reports NRC Letters related to Owner's Group Activities NRC Meeting Minutes or Inspection Reports, etc., referencing PECO Commitments NRC Bulletins and Information Notices LERS 10 CTR Part 21 Reports NRC Environmental Impact Statements 9.3 COMMITMENT TRACKING PROCESS DIAGFAM T-SS-280.REV 06/15/88

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ISSUE: Commonwealth of Pennsylvania Involvement in Peach Bottom 4 Inspections APPROACH: On June 12, 1988, the NRC published for comment a policy statement (Federal Register, Vol. 53,LNo. 113, pp. 21981-83),

             "Cooperation with States' at Commercial Nuclear Power Plants and                   ~

Other Nuclear Production.or Utilization Facilities: Policy Statement." In this Policy Statement, the NRC provides for routinely informing the State on matters of interest and allowing State observation and participation in NRC inspection activities. A copy of the proposed Policy Statement is attached. l l l Although the NRC's Policy Statement is for public comment and not yet final, PE commits to abide by the provisions in th2 proposed Policy Statement at this time. CLOSURE: 1. PE will provide a copy of the NRC's proposed policy (attached).

2. PE committ to abide by the proposed Policy Statement.
   .                                                                                                                                                                      1 Federal Rosleter [ Vol. 53, No. 213 / Monday.. June 13, 1988 / Rules and Regulations 21981 10 CFM Part 80 publjuuon in the Fedatal Register. The                  operatica of any nuclear production or Coopersticm W)th States at                     proposed policy will be followed in the                 ut!!1:aden facility, except for certsin Cosmerciamuoiear Power Planta arW              interim. eespt for thcee paragraphs in                  authority over air smaalons granted to Other Nuclear Production or Utiltaation the poltt.y sutement and                                      States by the Clean Air Act.

Peelttlos; Potoy Statement Implemercatm section dealing with State propoesis for instmments of The NRC hae had extensive formal Acesecn Nuclear Reguletory cooPeraen for parucipadonin and infonnalintuscdon with the Statea Commtnion thmughout its histcry. The Agreement inspecuons

  • t m**dn8s, and inapecuan entranca and State Program, under section 2745 o Act#om:Pohey statement-ommias n set on then speelf!c types of State- AM , Act,is an examph of a femalprogram 80esesAsm no Nuclear Reguletory propond instmments of cocparation when the NRC nlinquishes its Corrsf esten(NRC) bellaves that the until the comment period expires and regulatory authority ovn entain~

esency's mlesica to protect the public the licy statem6 Ala published as a ra<cactin matuish to the States. health and 64fety and the environment ha pohey statament. Thor, ere entrently 28 Agrennent States can beet be n ved by a policy of regujaung apptcximately 65 percent of DAtta:The comment period expires on cooperstjon with Stata governmants N!y 13.1986. Comments received after thne beensees natienwide dat use or which unites de common goals of the manufacture those types of redjesedvs G!a date will be considered ifitis material.W Ag*sement State Program NRC and the States. Accordingly,it is practfcal to do so. but aseurance of the NRC's policy to cooperate fuuy with operates under two Commlulon Policy State govem=ents as they suk to consideretion cannot be given except for Statements. one for entuir:s into section comments received on or before this 274b ogtumants and one for respond to the expectations of their date. citisens that their health and safety be periodicaUy nytewmg Agreement State protected and that there be minimal ADonsnese:Mailwritten ecmments to radiation control programs for adequacy the Secretary. U.S. Nuclear Regulatory in protecting public health and safety impact en the enntenment as a result of Commbslon. Washington. DC 20555, and for cc=pstibility w:th NRC acttvities licennd by the NRC. In Attention: Decketing and Sevice acccrdance with this polley statement, programs.Th!: policy statement the NRC wiU keep Covemor-appeinted Branch. Deliver comments to One White supperta contbusts of the Ag eement Fl!nt Ncrth.11555 RockviUe Pike, State Program and is not n:eant to affect State Uafson OffMars mutinely Rockvi!!s, Maryland between 7:30 a.m. it. - infomed on matters ofinterest to the and 415 pm, Federal workdays. This policy statement is not intended State , and NRC will respond ia a timely Ccmments may also be delivered to the to aJect rights to notice and to manner to State requesta for tnformation NRC Pubite Document Room, m7 H and State recommendations concerning Street NW., Washington. DC, between participate in hearings b. anted to Stotes matters within NRC's regulatory by ststute er NRC ngu.at!ons. jurisdiction. lf re 045 a.m. and t15 pm. Co;tes of Under to CFR Part 9. Subpart D, the routinely inforn: quested. the NRC will comments recetved may be exam!ned at NRC has provided procedure for State Unison Officers the NRC Pub!!c Document Rcom. l handling requests for an NRC of public meetings betwun the NRC and Poe PuafMan meonuAnoN CONTAon ; ita licensus and applicants. in order re7esentative to participate or provide that State representadyn may attend as Carlton C. Ka=m:ru. Director for State, informadon in Ndf cial or quasi judicle! d observers, and NRC will eDow State I.oce! se lodian Tribe Prcgrams, Office proceedic4s conductsd by Statee or observation of NRCinspection of Governmental and Public AHain, U.S. other courts and agencies. n!s policy Nuclear Regulatory Commlulon, . statement supports Gese procedures activities. Tbs NRC will consida State Wa shington. DC 20855. Telephone: (302) Propeaak a enterinto instramanta of and dou not affect esm. 402 4m, or Jane Mapu Sen!ct '. cooperation for State participation in Under to CFR 50.55a. the NRC has Attemey. Division for Roaemaking and recognised the role cf the Sta:es within NRCleerion activities when thue Fuel Cycle. OEca of the Ceneral Programa have provialone to ensure the American Soclery of Mechanical close cooperstion with NRC. The NRC Counsel. U.S. Nuclear Regulatory Engineers' Bo!!er and Pressure Vessel Comminion. Washington, DC 20551, Code (ASME C de} 6ystem.This policy will not consider State preposale for Telephone:(Sol) 4024642. , lastmments of cooperation to conduct , statement dosa not aHect the State and suppl.sas5NTARY WPORMAD08C NRC relationship as laid outin the independentinspection programe of NRC-regulated activities without cloes 1. 3ackpound ash 2 Code. cooperatiou uth, and overefsht by, the The State Llelson Officer Program.

                                                            ,The Atomic Energy Act of1954                    establiebed in 1976, providea a local NRC. Th!: pokey statement is intended to provide a uniforni beeis for NRC/            Act) was amandedln isse to                        add point (the  in each of the 60 States and the Stata coeparation as it talates to the           section 274, "Cooperatics WiB States".

Commonwealth of Puerto Rico for Section174 of the Act provides the regulatory oversight of commercial communicstica between NRC and the statutcry basis fcr NRC/ State nuclear power plants and other nuclur States.The Governor eppointed State production or utilisation facillues. cooperationin nuclear mattare and practibes the framework for State 1.latoon Offloor is intended to be the Instruments of cooperation between the tegulation of certain nuclear materiale principal person in the State to kup the NRC and the States, approved prior to Govunor informed of nuclur regulatory the affective date of this policy and facilities. The focus of eaction 274 la matters ofintamat to the Governor, to primarily on protecting the public frorn ksep other State officiale informed of statement will continue to* be honoted PLdiological hasards of ecuros, by the NRC. theet rnetters, and to respond to NRC byproduct, and special nuclear materiale inquiries. The Commluloninvitu interveted below critical mwe Under section 274, States. Ifeennu, applicants, and Other areas in whJch NRC and States members of the pubhc to comment on the Pederal Government, primarily NRC, . haveworked together teclude the policy before it becomes !!nal - is anigned axelnetve authority and

  • environmental monitoring around the responsibility to regulate the agency policy. The ecmment partod will premises of nuclear power plant exofre 30 days fctlowing the data of radiological and rational security facultiaa and participation in the especta of the constnetfeu and

! Conference of Radstion Centrol

                                                                   -~e     n                                     -n--           - - - - ,     _ _ _- - - - -   , ,-

F3 s 21982 Federal' Register / Vol. 53, NS 118 / Monday, June 13. 1988 / Rules and Regulations i Program Directors,Inc., which addresses cooperative bests an'd are deeltable for activity involved. In the prcpesal to radiological health in areas such se State personnel to perform on behalf of enter into an instrument of coopwation. diagnostic and brapeutic X teys, the NRC; and (2)its oversight the State must identify those activitin i radioactive matertale, and otberrelated- responsibiltty to ensure that NRC for which cooperation with the NRC14 ' actiylties. etandarda, regulaticas, and procedures destred. The State must propose a Under subsection 2741 of the Act. the - an met where State represerstatives program thstr(1) Recogniaes the Federal Comminion W authorised, in cerrying. Carry out NRC func6cne. Purther, it is - Government, primardy NRC. u having out its licensing and regulatory the Commfssion's intention to prov:de - h excluelve sudority and '. , responetbibtfee, to enter into a ,unifor alty in its hand!!ng of Stau responsibility to regulate h a Memorandum of Understanding (MOUF requests. radiological and national secunty. ~ ~ With any State to perfonn inspections or  ?

11. Shhmani gD aspects of the construction and - .

other functions on a cooperctive baste - operation of nue.lut production or as the NRC deems a priate,' Itle the NRC's policy to cooperate mtfilration facilities,*xcept for certain According to the I lative klat6cy of fully with Stt.; aovernments ne.they i authority o'vw att emiselons anted to ' esetion 274, subsecnon 2741 o!anflee the. ' esek toreepo,,, athe espectaticm of ' States by theClean Air Act itin Commission's ex! sting authonty arrder the!r citisens that their health and safety . accordance with Feder:al stan rds and subsection 1stf which enables the NRC . be prelected sad that there be minima! . to obtain the serytces of State pmonnet . impact on the enYiMSment at a rHuh of renlations:T3) specifles minimum

  • g[ucation, experfeAce, tralfdng. and t_o perform funettons ourits behalf u ,. activities lleenwd by:the NRC. N,NRC
                                                                                                                                          .      qualthcados             mquitenante for State '. <-

may be desirable. and the Statu have . complementary _ reprmatative4 which an pattemedo NRC hee uted lato MOUs with responobbi!!tf es in protecting public after thou of NRC inspectore:[4P - several States under subentlen 2741 of health and safety and the. environment. - the Act. MOUs have helped to facilitate Furthbrmore, the NRC la casumitted to. containe provisioes for the findingeof 6 tate reprnentadyte to be transtnitted environmutal review during - 1 the full ud timefy.dhelosun of mattne . construction of nucleerpower plants 'At affectina t'o NRC for dienoettiert it) would not lic and to the felt ande.' *-Impou an uclue burden en the NRC one point, there was a perceived need to unifonn h of a!! agener broaden the basis for formal cooperative ' interections anditiHeenwu and applicanurand(4) the Statw, the pubbe,

  • abides by NRC protocol not to be instrumuts with Ststee under and NRClicenseesc ...i .'

pubtf cly discicae ta pection findinge subsection 2741 beyond that of water . quality MOUs. As a result, general or keep Accord!ngly..b NRC,' will ebatinui to . ' h7 tot to bl relea cinted State !.!alson .

          "umbrella" MOUs were negotiated, with                      Of!!cersGovemor.a routine           fnformed on mattera                                    . pMonyport.               .

euhaaramuts on spectfic asuu such ; . ofintmet to th tatu.m uRa ein . . Comtut wah neh 274(ei of the as lowdevel weste package and respond la'a timely. manner to a StaWe Act, the NRC will not. consider State transportinspections. Two uniq .. requests for informauda and its ~ . * . . . . Prop.Csals for Inseurnente of egwadon asnements were negotiated withs'.recdaufenditions

                                                                       .                     concordhij matters , . that do notlaclude theelements gsted Oregoru one concerntag the sharic 9(#- within the'NRC's resufat'ory jurledletfon.                                                                  . aboy, which are Mgned to mm .

groprietaryinformation regarding e If rehuested, th's NRC wiliroutidel ' ' . clou coopmuori and conslatency with . Trojan facility and the other govwing '. .infonn 8 tate L!aleca Officers of the NRC inspection program. As a . licao's . peacWal:6attet the Els ooncuned ,- coordination of the State and NRC - meetthga 6stween hfRC a:id tte ruldentins or prograrhe at Trojait; " and applicante in order that 5ta'tvu - . thatindependant State inspect!on - Additionali , the NRC has documeet6d representatives may attend to- * ' . Programa could direct aq applicant's or the protoco that States must follow to- obemers. Additionally, at the See'ta's . 41oensee's attention to steas not ) be permitted to observe certain NRC request, State NprHentatiVbe Willb4 C comedstent with NRC safety prior! tin. activitin in "letter agreements." . , _ . . able to observa spec 15e inepections W mistaterpret NRC safety requirements. In recent years. States have taken the,: and/or inspection entrance and sxtt . . , or givs the perception of dual regulation. In!Untive to monitor more olosely For purpoets of this policy atstement. as l meetings when St4te representat!Yes comroertfalnuclearpowerplante anJ - 'are knowledgeabte la rediological hul,th one Inde othat nuclear production or utillsatid and safety:ssttm, ~ ' . gendent State which 5fsta inspection program is repnwatativu facilities within. and adjacent to, thett - ' % Commission recognisse that th's would conduct taspectione and aseees State boundarias by becoming better involvement of qualified State .r NRC regulated acdvities on a State's Informed and,in reme cases, more reprenatattves m NRC rediological own initiative and authority without involved.ta astivttles related to the health and safety ma has the cleos cooperation with, ana oversight tes lation and operation of thou - ential for provi additional safety by, en authorised NRC representativry - fa ities. It was thfe increased internt enafit. Thefore, NRC will Instrumente of cooperation between by States to become more actively - consider Stampeoposala to enter into the NRC and the States, approved prior - involved ia NRC asuvrtfee that caused - inetsuments of cooperation for State to the date of this polley statement will the NRC to tHxemiae those* / participation (A thopectione and , ' . ' continus to be honored by the NRC. The-agreements pronously negadated with" Inapectos satrunee and enJt meetings. ' NRC etrengly enoeurages these States - Statw and to deterunne a untfenn poiloy State pu' 'ticipation (at NRC proyama) J holding thne'aeroemente'to consider, for bow futun State proposals slouhi be would allow quellfkd State . . modifymg them< if necmary, to bring

  • handled. . .. . .

reprnentatives, either tedividually or as them into conformance with the

       .. In devoleping thle policy statement to- a member of a team, to ::nduct spectfle                                                        prowskas of tble policy statement.

be used to respond to future 5teto . - inspection activities in s icordance with proposals, b Commiss;on, recognistag - NRC standards, regulatit es, and UI Implementation ,, that the regulatory responsibilitises nagement at all levala witte respect to adequate root cause analysis and effec ive corrective actions. A review of PECo relations with the NRC and other external reviewing organizations over t: e past several years provides extensive insight into the significance of the growing problems at Peach Bottom. This review indicates that management at all levels was not aware of or did not sufficiently understand how the post-TMl regulatory environment and changing industry standards were affecting Peach Bottom personnel performance. PECo's formal responses to regulatory ano industry assessments were not effective in solving long-standing personnel performance problems. Since 1981, NRC/INPO reviews have identified significant findings of a repetitive nature in the f ellowing areas:

5160h7 e ten findings regarding lack of procedure adherence, e four findings in Radiological Control. e I three findings in Emergency Preparedness. Since 1983, NRC enforcement actions have been increasingly severe since 1983. Although there were some recent positive indications, deficiencies continued to be identified in NRC and INPO findings. The misperception of the severity of NRC concerns in correspondence and in meetings over the past year, along with the continued display of defensiveness in responses to NRC and INPO findings at Peach Bottom, have contributed to diminished credibility with the regulatory and industry reviewers. Electric Production management has not ensured adequate involvement of all levels of the organizatior, in developing and carrying out commitments. Interviews at the corporate and site levels indicate that in some cases appropriate line and staff members are not involved in problem analysis and development of corrective action responses, in other cases, when they are asked to provida input it is not always ;tilized in the company's response, and the reason for de'eting the input is not communicated back to the authors. In either case, Peach Bottom management and other key personnel feel less ownership and responsibility to implement commitments made to regulators. This has also impeded the effectiveness of corrective action programs. The total and cumulative resource requirements have not been adequately considered when the company commits to new programs and other corrective actions. The management pi,ilosophy of ten appears to be that the existing resources should just work harder to accomplish corrective action programs, no matter how comprehensive they are. Until the recent establishment of the Quality Assurance Tracking and Trending System (QATTS), there was no single corporate-wide source for commitment listing ana tracking. which made it difficult for any management level to u' ferstand the full impact of cumulative commitments involved. QATTS is not ' widely implemented or resource loaded l l _ --_ _ _ _ _ _ _ _ _ _ _ - -

5160h7 ' and thus does not yet provide the requ! red management control in this import at area. This has caused frustration for all organizations invoNed in tracking and implementing commitments. Nuclear Operations and Peach Bottom management were not effective in addressing the increasingly negative attitude of the plant staff toward the changing regulatory environment and the impact of this attitude on Pesch Bottom relationships with the NRC. INPO and ANI. Most senior operations-experienced employees have been working at Peach Bottom since before the TMI-2 accident and have, for the most part, maintained a negative attitude toward post-TM! regulatory requirements and clarifications. There was apparent disregard for NRC Circular 31-02 dated February 9,1981, which reinforced NRC's position regarding the meaning of 10CFR50.54(k) as it relates to licensed operator conduct in the control room. This was re-emphasized to the Peach Bottom licensed operators on June 20,1985 in a letter from the Peach Bottom plant manager after the June 10,1985 incident regarding an inattentive operator. However, this management by memo effort appears to have had little or no effect on operator attitudes regarding control room behavior. Some operators have the wrong opinion that they are there to back up the safety systems. Sitti .g back in the chair with their feet up in an apparent inattentive mode, therefore, was not considered to be wrong because the plant j was on autoniatic. 4.0 CO"CLUSIONS There are four primary root causes identified as the major contribuors to issues and events at Peach Bottom which led to the shutdown order. They are: o Poor leadership by management at Peach Bottom, e Failure to initiate an aggressive operator training program to provide a sufficient number of licensed operators in a timely manner. e A transplanted PECo fossil station otganization, concept of shift operation, shift structure, and the PECo fossil way of doing business. Peach Bottom management did not perceive the need, or take sufficient action, to adapt these to the current nuclear operating environment.

   $160h7                                                                                     '

e The slowness of corporate management, above the Peach Bottom plant level, to recognize the severity of the root causes escribed above and to insist on stronger, more timely and appropriate corrective actions. Indicators of poor leadership at Peach Bottom and the slowness of department management's response include: e Ineffective implementation of the Company's performance evaluation program, with most Peach Bottom and Nuclear Operations managers not conducting face-to-face annual reviews e Improvement programs which addressed symptoms rather than root causes did not involve appropriate line managemen+ levels, and were not communicated effectively to ensure employee enmmitment to success e Poor urderstanding by Peach Bottom management of their authority and accountability e Poor two-way communication between Nuclear Operations / Peach Bottom management and employees e Poor first-line supervision training and inadequate numbers for proper span of control e QA/QC programs not fully integrated into op2 rations e inadequate management systems for proper procedure update and control e Ineffective implementation of matrix management teamwork e Inconsistent implementation of disciplinary policy e Management over-reliance on the IGA to respond to employee concerns Re3olution of these problems depends upon:

         'e     Increased management awareness of the root cause influences e     Management's willingness, ability, and leadership to change root cause influence where possible, or to address the negative impacts when the influence cannot be changed                                                           ,

e Management's application of resources to correct the current acute l problems These root causes, which have a combined and interrelated effect, are embedded in and nurtured by the traditional PECo cultura. Some of the same cultural characteristics which produced operational excellence in the early years at Peach Bottcm became contributing influences to the primary root causes,

. 3160h7 resulting in its shutdown. Examples of the ways in which these cultural characteristics produced both positive and negative effects include: e Entry level hiring practices.which produced loyal, dedicated, well trained employees during the first five years of operation have also contributed to a shortage of licensed operators, minimal shif t staffing flexibility, inability to use operations experienced people in other functional areas, and resulted in operators who feel trapped, distrustf il, and have negative attitudes. e An orientation towa d hiring and promoting engineers, which produced a highly professional and technical staff for entry into the nuclear- power business, also contr!'suted to a reduced awareness of neople performance problems and people management solutions. e Long-term management and staff assignments that created a protective '

                "insulating bubble" around the team during start-up and early years of operation subsequently created an "isolating bubble" around the operations team which obscured from' upper management's view the negative influence of fossil / hydro operating practices, poor plant management performance, and provided a shield resistant to regulatory change, o     Personnel policies and practices, which had been carefully constructed over the last half century, and which have produced a satisfactory relationship with the PECo Employee Independent Group Association (IGA) and a stable personnel resource environment, contributed to resistance to rapidly changing nuclear operations personnel requirements, e      PECo's pride in pioneering and achievement in nuclear operations produced leadership in the nuclear utility industry and regulatory technical standards development.      Later that pride also contributed to protectionism and defensiveness to criticism of their more recent performance and to questioning of the changes to regulatory standards.

Limerick is a newer plar t still in its early operation phase, a condition similar to Peach Bottom's "insulating bubble" of the early years. It has had some of the advantages inherent in start-up organizations over steady-state organizations (e.g., more resources supplied, more fle.sibility with rerpect to policy implementation) as well as the benefit of an effective plant management team. Over time, however, there is the potential for some of the same Peach Bottom attitudinal problems to develop at Limerick if management does not take an aggressive stance in recognizing the need for substantive change in its management philosophy and approach to nuclear operations. There are many appropriate and effective short-term actions which PECo should take to address the problems cited by the NRC and get Peach Bottom back on line. However, to ensure that problems do not recur at Peach Bottom and to

, 5160h7 prevent their occurrence in the future at Limerick, there is a need for in-depth, long-term changes. The recommendations in the following section are a combination of short- and :ong-term actions to produce these changes. 5.0 RECOMMENDATIONS The recommendations have been grouped in the same manner as the root causes in the areas of: o Cultural and attitudinal influences e Leadership and management issues e Personnel policies: Nuclear Operations applications and implementation e External relationships Additionally, a number of recommendations for the action plan process have been made at the end of this section. It is important to note that at this time no effort has been made to priori.. the recommendations made in this report. It is expected that in preparing the action pian to respond to the NRC shutdown order, PECo will combine these recommendations with the recommendations of others and develop an integrated priority system to ensure that all recommendations are addressed in a coherent and logicci manner. It is not intended, nor is it implied, that all of the l recommendations in t'..s c report must be completed prior to restarting either unit at Peach Bottom. The recommendations themselves fall into two general categories. First, those that deal with the acute problems that are the result of the pressure of long-term root causes and require direct action. Second, those that deal with the longer term chronic root cause problems to prevent reoccurrence of problems at Peach Bottom and potential manifestation of these problems at Limerick. The impact and visibility of the shorter term actions appear to overwhelm the more difficult longer term solutions; however, it is essential that PECo make plans now for accomplishing the more broad based changes in organizational attitudes, leadership and management practices, policy implementation, and

, 5!60h7 -24 external relationships so that Peach Bottom's recovery efforts are sustained over time. 5.1 CULTURE AND ATTITUDINAL INFLUENCES Attitudinal change is a difficult undertaking since attitudes are a key element of the complex entity known as "organizational culture." If the attitudinal problem resides in only a small group of individuals, it can be addressed through a strategy of attitudinal assessment, counseling and training of each individual. When attitudinal change is needed on a large scale, as is the case with Peach Bottom nuclear operations, this strategy is not sufficient. The change in Peach Bottom plant management which has resulted in the establishment of a new managerial perspective on site will contribute significantly to a broader scale attitudinal change among Peach Bottom management and employees, at least in the short term. However, to ensure long-term attitudinal change, additional steps must be taken. Psychological research about attitudinal change in organizations indicates that a disciplinary approach (i.e., management enforcement of new behavior) is not as effective or as quick to produce results as a carticipatory approach (i.e., providing opportunities for employees to identify work-related problems which have negative influence on their attitudes and to recommend appropriate solu-tions to those problems). MAC recommends that PECo implement a broad scale attitudinal change effort with one aspect focused specifically at the Peach Bottom site and another aspect focused on corporate / Peach Bottom site transactions.

1. Complete an organizational survey at Peach Bottom using an accepted instrument which identifies employee attitudinal issues, as well as work productivity and quality concerns, followed up by a well-managed employee involvement program which uses the results of the survey in an organized manner. This should be accomplished work group by work group. An example of this kind of program is the Employee Involvement Program instituted at Rancno Seco by the Sacramento Municipal Utility District.
2. Initiate a team development process from the President down to shift management which involves Nuclear Operations, Engineering and Research, Electric Production, and other corporate organizations which support Peach Bottom. Include in this process:

. 5160h7 o25-e Commitment to excellence from the Piesident down to and including each level of management e Clarification of roles, accountabilities and authorities at each management level with respect to nuclear organizational and plant performance e Improvement of communication processes both vertically and hori-zontally within management chains and between corporate line management and employees e Identification of management processes to be used to ensure integrated planning and implementation of operational goals, including how prior-ities will be established or changed, and how work-related conflicts will be resolved e Coaching in how tc, ask for and give honest, effective management performance feedback e Reso'ution of inter-departmental conflicts related to work flow man-agement, lack of responsiveness, or support between work groups The process could be implemented in a phased manner, starting with senior corporate management, progressing to the corporate / senior plant manage- l ment level, and then to plant management, with appropriate levels of top ' and middle management involvement in the process as it cascades down . through the organization. 1 Implementation of these recommendations requires careM planning and facilitation, usually with external assistance, to be e"ective.

3. Establish a comprehensive operator retraining program to address at least the following areas:  !

e The impact of the traditional PECo culture and Peach Bottom sub-culture to ensure that all participants understand and are committed to the attitudinal requirements for safe nuclear plant operation e Operator behavior which is consistent with the requirements of 10CFR50.54K e Emphasis that the operator's responsibility is to proactively operate the plant and that safety systems are in place to back up the operator e Strict adherence to all plant and operational procedures e Operator responsiveness to, and positive attitude toward, the levels of detail and attention required for safe, professional control room operations, e.g., exception reporting, systems monitoring, etc.

5160h7 , o Effective communications, teamwork, and ability to manage the i interpersonal processes involved in control room operations e Understrading and acceptance of all of the roles in the safe and efficient operation of a nuclear generating station, e.g., Operations, QA/QC, Health Physics, Maintenance, etc. l 3.2 LEADERSHIP AND MANAGEMENT ISSUES  ! PECO's efforts at broad-scale attitudinal change in Nuclear Operations cannot be successful without careful realignment of management philosophy and practices and organizational structures to support the goals of the change effort. The infusion of new managerial perspectives and nuclear talent into the Nuclear Operations organization will also support this effort. MAC recommends the following:

1. Replacement of Peacn Bottom Plant Manager, Operations Superintendent and Operations Engineer is supported. The impact of the loss of cumulative Peach Bottom-specific experience currently represented in these positions must be taken into account in replacing personnel, making any future organizational changes, and retaining these personnel in contributing staff positions.
2. Assess the adequacv and effectiveness of the current Peach Bottom shif t #

organization, supervision, and staffing with consideration given to: e Strengthening management presence on shift by establishing the shift manager concept, e implementing a day shif t supervisor concept (general supervisor of operators or o;.erator support). e Adding another licensed operator (LO) in the control room, e Providing back bp relief capability for control room supervision, e Redefining the outside shif t supervisor responsibilities to strengthen and include direct supervision of outside tasks and relief of the control room shif t supervisor, e Assigning senior licensed operator (SLO) qualified engineers to selected supervisor /superintentendent positions for hands on experience, training for future management positions, and removal of the "wall."

                                                                                                   )

e Completing the ongoing study of shif t rotation at Limerick with involvement and participation of Peach Bottom operators and supervision. Give due consideration of alternatives to current Peach Bottom shif t rotation schedules based on this study. 1 l l

1 , 3160h7 3. Increase direct supervision by ensuring sufficient numbers of-supervisory , positions to effectively supervise and direct activities. Expeditiously fill l vacant supervisory positions where clear need exists.

4. Establish a Nuclear Personnel Specialist position at the nuclear plant site, reporting to the plant manager, with adequate experience to: (1) advise all levels of plant management on personnel policy matters and employee relations; and (2) represent the special needs of Nuclear Operations to corporate personnel r...nagement when policy changes cr exceptions are required.
5. Reduce one management layer, and strengthen the organizational changes made in establishing the Vice President, Nuclear Operations position by having plant managers report directly. Add strong direct support staff for that position.
6. Establish and/or clarify specific accountabilities and authority levels for each management and supervisory level in Nuclear Operations. This should be done as part of the team development process recommended in Section 5.1, Cultural and Attitudinal influences. Hold managers and supervisors accountable for appropriate exercise of responsibility and authority.
7. Refine the role and authority of QA/QC, particularly as it relates to surveillance and audits for verification of technical and performance based activities. Take into account current NRC and INPO philosophy in this area. Assure that an appropriate level of expertise (Operations, Instrumentation and Controls, Health Physics, etc.) is available in the QA/QC organization.

e Consider grouping all Operations, Maintenance and Construction QA/QC functions under one manager reporting to the Senior Vice President, Engineering and Production. e Communicate and support the further integration of QA's role throughout the organization. e Establish a quality deficiency reporting program which addresses each  ; issue reportee tc it from any source.  ! e Require plant management and shift management to include the QA l function as an integral part of all operational work planning, decision-making and problem-solving processes. Hold meetings between QA management and personnel and management and personnel from Operations, Maintenance, H.P., Technical Engineering, I&C, Testing & Lacoratories, Chemistry, Construction, Rad Waste Management and other relevant functions to discuss QA's role in their work activities and l address any related concerns. '

8. Establish an administrative management system for procedures to ensure accuracy, comprehensiveness, timely review and updating of corporate, plant, and operational procedures which includes the following:

o Complete the implementation process for developing, formall:ing and distributing Nuclear Operations Requirements and Guidelines. )

 . 5160h7                                                                                   l e    Input all plant procedures into a common automated data base to assure efficiency and accuracy when typing plant procedure changes.

e Establish a two-year review cycle for department procedures as opposed to the current five-year cycle; provide additional resources as needed to complete such reviews, o Establish an automatic expiration date for temporary procedure changes to ensure comprehensive review before the change becomes permanent. o Consider alternatives to the use of the full PORC committee for. review of all procedural changes in order to decrease the backlog on procedure revisions and allow the PORC to focus on additional matters related to plant operations, e Establish a written process for flagging needed procedural changes to management's attention. e Ensure more effective t.sc of the references section of procedures to keep track of previous commitments during subsequent procedure updates.

9. Assure that the QATTS system is appropriately resource . loaded and integrated into all aspects of nuclear operations so that commitments may be tracked effectively.
10. Develop and implement a comprehensive management / supervisory leadership improvement program for Nuclear Operations including:

e Evaluation of supervisory leadership skills needs at all levels from first line (including "lead" or other defacto supervisor levels) up to manage- ) ment. 1 e Development and implementation of training programs to address-  ! identified needs with careful attention paid to the skills required at j each level of managernent/ supervision in the organization so that the skills targeted for development at each level build on those achieved at previous levels. In scheduling training modules, particular attention i should be paid to the most effective means of making the training i accessible to all Nuclear Operations supervisory personnel (e.g., offering short trair.ing modules on-site at a variety of times). l l e Provision of more supervisory training opportunities for non-supervisory personnel who have been identified as having supervisory potential; emphasize the importance of such training in consideration of candi-dates for supervisory openings, e Additional emphasis on a supervisory / leadership curriculum in the SLO training program. Make supervisory capability evaluation a mandatory element in selecting candidates for training and SLO qualification.

Si60h7 e Emphasis in management training programs on how to coach and support subordinate levels of supervisors, . including; identification - of their training needs, on-the-job coaching, and assessment of training program effectiveness, by observing behavior on the job following such programs. Institute a process to ensure that training program management receives regular input from plant management at different levels about supervisory training needs and the effectiveness of training programs, e inclusion in training programs of the rationale for personne! policies and how to implement them effectively, especially in areas such as employee performance evaluation and discipline, e For upper level management, exposure through seminar format to notable management experts and practitioners and successful nuclear utility managers.

11. Consider establishment of a rotational management assignment process so that key Nuclear Operations and Peach Bottom man 6gerial personnel are exposed to the functional realities of different departments within PECo and thus acquire a broader base of experience and do not become isolated at a plant location for extended periods of time.
12. Require all levels of Peach Bottom management and supervision to conduct formal face-to-face performance reviews with their direct reports on an annual basis as a minimum. To ensure the effectiveness of these performance reviews, participation in performance appraisal training sessions should be required for all management and supervisory persennel. -

The Nuclear Personnel Specialist should monitor the quality of written performance reviews, and initiate or recommend necessary actions for improvement as required. 3.3 PERSONNEL POLICIES: NUCLEAR OPERATIONS APPLICATION AND IMPLEMENTATION PECo has always emphasized company-wide uniformity of personnei policies, which is, basically, a sound management philosophy. The task facing corporate ' management is to become more aware of the special requirements involved in , 1 managing its nuclear business. In some cases, personnel policies will require modifications and/or different applications to address Nuclear Operations I needs. Nuclear Operations managemant must also monitor and ensure more effective implementation of personnel policies by Peach Bottom managers and supervisors. MAC recommends the following:

1. Initiate an aggressive recruiting program to bring in technically qualified personnel, including licensed operator candidates, at other than entry levels (i.e., at levels appropriate to their qualifications and experience and
   $160h7 comparable to the levels at which they would be hired in at other nuclear plants).
2. Design and implement required training programs for new licensed operator' candidates over the next 12-15 months to supplement available licensed operator resources. Consider vendor training personnel for this purpose if required.  ;
3. Design and implement an immediate training program to prepare SLO I licensed engineers for shif t positions.
4. Consider non-degreed licensed operators for promotion to positions in ,

operations management, outage planning, QA training and other functional I areas on the basis of merit.

3. Establish alternative career paths in the immediate future for senior non-licensed operators so that they can be more fully utilized in positions such as floor coordinator and training instructor.
6. Conduct a survey to identify those personnel practices, e.g., no way off shif t; no lateral transfers; amount of nuclear differential pay, which servc as major disincentives for personnel to pursue the nuclear operator job progression up through supervisory levels. Use a task force approach (with representation from licensed and non-licensed operator personnel, the Personnel Department and the IGA) to make recommendations 'to management about how these disincentives could be addressed.
7. Ensure that definitions of various levels of infractions and corresponding disciplinary actions in the disciplinary guidelines are congruent with nuclear performance standards; if necessary, identify special applications and/or interpretations of the policy to meet Nuclear Operations needs.
8. Permit plant managers to suspend employees _for reasonable cause at the time of the infraction, even when the suspension is appealed by the employee, rather than holding such suspensions in abeyance until the appeals process has been completed.
9. When grievances involve individual employee disciplinary action, process these grievances formally up through successive supervisory levels documenting each step. The employing officer and the Vice President, Nuclear Operations should meet together with appropriate Personnel -

Department and IGA representatives to resolve the grievance, with the Vice President, Nuclear Operations having ultimate line management decision-making authority with respect to disciplinar) actions. The role of Personnel and Industrial Relations Department management should be reserved to serve as an appeals source only in those cases where the grievance solution is appealed by the IGA.

10. Streamline the grievance resubmittal/ appeals process to ensure timely responsiveness and resolution.
11. Establish written guidelines for managers and supervisors on management responsibilities and authorities for implementing the company's Disciplinary Guidelines.

l 5160h7 12. Mandate special training sessions for all Nuclear Operations management l and supervisory personnel to ensure their understanding and consistent  ! implementation of disciplinary policies, the grievance process and work l rules.

13. Build into the Peach Bottom employee involvement program an ongoing process for management to solicit and respond to employee concerns and sugga"ia" .

5.4 EXTERNAL RELATIONSHIPS PECo management must demonstrate to the NRC its awareness of the serious-ness of the root carse issues which led to the shutdown of Peach Bottom as well as its sincere dedication to a change in management philosophy and approach at all levels with respect to its nuclear operations. This awareness and dedication 1 forms the keystone for an acceptable action plan. In addition, management must assure that the appropriate processes are in place to maintain open and effective t ongoing relationships with its regulators and industry auditors. MAC recommends the following:

1. Evaluate and correct the management practices which have resulted in ineffective relationships with the NRC regarding the concerns at Peach l Bottom. The evaluation should pay close attention to the successful program established at Limerick and at other utilities.
2. Review commitments made since 1983 to the NRC/INPO/ANI, etc. for desired results to ensure that corrective actions taken were appropriate and are achieving the desired results. Include in this review any subsequent actions taken in the recovery plan.  ;
3. Reinforce internal monitoring of nuclear plant performance (NRB, ISEG, PORC) by ensuring tha; specific responsibility has been assigned to evaluate, I

analyze, characterize and trend performance indicators from external ) sources (NRC, INPO, ANI, etc.). Conduct periodic meetings with senior l management (corporate and plant) to review results and provide recom- ' mendations to address problems, or potential problems. I

4. Assure that future commitments / responses are based on:
                                                                                                              )

e  ! sound, thorough analysis with explicit consideration regarding reactor l safety, not just compliance. l e consideration of current regulatory philosophy, recognized problems at other facilities, and the NRC's viewpoint, e emphasis on the role of personnel and personal actions to nuclear safety.

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 $160h7                                                                                    l l

e realistic schedules based on safety significance and available resources with appropriate monitoring of milestones and of ongoing progress to assure desired results are achieved. 5.5 ACTION PLAN PROCESS It is also critically important that PECo management pay as much attention to the use of effective management processes in developing and implementing the Peach Bottom recovery plan as they do to the content of the plan itself. These processes must be thoughtfully applied if PECo management is to assure itself that the recovery plan will result in operational excellence and will assure the NRC both of the company's awareness of the need to change and its sincere commitment to making the change happen. MAC recommends the following with respect to developing and implementing an effective Peach Bottom recovery plan:

1. Provide full-time leadership, management, and attention to detail to suc-cessfully plan and execute the recovery plan. This will require additional staff dedicated to this project to ensure the least disruptiva impact on normal, ongoing operations of Peach Bottom outages and Limerick <

operations and outages.

2. Integrate ongoing improvement plans into the recovery plan in order to assess the total resource requirements and commitments. These plans should include the significant plant improvement projects, the PBEP, and  ;

improvements with respect to administrative management and work control systems (e.g., procedures, Radiation Work Permit (RWP) system automation, exposure records, nuclear records). Assign responsibilities and incorporate a i system for measuring results which involves both Peach Bottom and Nuclear Operations management.

3. Provide overview of the recovery plan independent of line management, to monitor and to assess program effectiveness, i

HE

 .. u.

9 l I APPENDIX A INTERVIEWED PERSONNEL

3160h7 A-! PERSONNEL INTERVIEWED NAME TITLE OR POSITION W. Alden Licensir.g, Engineer in Charge M. Alderfer STA E. Allwood Shif t Superintendent C. Anderson Branch Engineer J. W. Austin Construction Superintendent J. H. Austin, Jr. President J. Baldwin ACO J. Ballantyne CO B. Barnshaw Shif t Superintendent - Limerick R. Betz Electrical Supervisor J. Birney, Director Nuclear Records D. Blasy Shift Superintendent M. Brown APO J. Budzynski Reactor Engineer (Supervisory) B. Bulmer NTS Superintendent - Limerick T. Cabrey Former STA B. Carr STA W. Casey Superintendent, Station Maintenance Division M. Cassada Director, Radiation Protection A. Clark Shif t Supervisor B. Clark Director Administration J. Clupp  !&C Engineer (Supervisory) E. Collins GE Shif t Eningeer J. Cooney Manager, Support Services R. Costagliola Superintendent, Nuclear Station Section J. Cotton Director Plant Services P: Cromwell CO E. Cromwell Shif t Supervisor J. Davenport Supervisor, Engineering Maintenance P. Davidson Computer Applications, Engineer in Charge G. Dawson Senior Engineer, Maintenance ., J. Deni CO

5160h7 A-2 PERSONNEL INTERVIEWED (Continued) NAME TITLE OR POSITION J. Doering Operations Manager - Limerick - T. Donnell QA Supervisor D. Duane Shif t Supervisor W. Eagles CO J. Everett Chairman and CEO D. Falcone CO-D. Felts APO D. Fleischmann Station Manager J. Franz Plant Manager - Limerick C. Fritz VP, Perconnel and Industrial Relations A. Fulvio Technical Engineer J. Gallagher VP, Nuclear Operations N. Gazda Physicist, ALARA (Supervisory) G. Gellrich Test Engineer T. Geyer Engineering Maintenance (Former STA) B. Gleaves Radwaste Supervisor M. Gribble ACO S. Grosh Former IGA Committeeman D. Harrington Shif t Typist R. Hart ACO

3. Hesler Former STA B. Hinkle Superintendent, Maintenance Services Section R. Hoopes Shif t Supervisor L. Hopkins Operations Engineer - Limerick J. Hufnagel Assistant Outage Engineer G. Hunger Nuclear Safety Engineer K. Iepson Former STA
3. Jordan Results Engineer (Supervisory) j R. Kankus '.iirector, Emergency Preparedness l D. Kauffman PO  ;

D. Keene I&C Engineer D. Kei .per Maintenance Area Supervisor I

. Si60h7 A-3 PERSONNEL INTERVIEWED (Continued) i NAME TITLE OR POSITION l l J. Kemper Sr. VP, Engineering and Production C. Kerr STA l R. Kirkhoff ACO W. Knapp Director, Radiation Protection C. Koehler Shif t Supervisor E. Kohler Staff Engineer 1

3. Kovalchick STA l S. Kowalski VP, Engineering & Research J.Lange IGA Chairman K. Lathrop GE G. Leitch Manager, Nuclear Generation Department J. Lindinger STA R. Lcgue Assistant to Manager, Nuclear Support T. Love GE Shift Engineer L. MacEntee ACO R. Maldonado ACO S. Mannix Assistant Operations Engineer (Supervisory)(Former STA)

M. Manski Former STA F. Mascitelli Modifications Coordinator G. McCarty Physicist, Support HP (Supervisory) M. McCormick, Jr. Maintenance Department J. McElwain QC Site Supervisor D. McRoberts Shift Supervisor H. Metz Shif t Superintendent C. Miller GE Operations Engineer 1 J. Mitman Senior Radwaste Engineer R. Monacho Shif t Operator - Limerick i R. Moore Superintendent, QA P. Navim STA S. Nelson Physicist (Supervisory) T. Niessen Assistant Operations Engineer (Supervisory) M. Norman AO ' J.Oddo Nuclear Security Specialist

 . 5160h7                                                                 A ,

PERSONNEL INTERVIEWED (Continued) NAME TITLE OR POSITION D. Oltmans, Sr. Chemist A. Parry, Jr. VP, Purchasing G. Paton Shif t Supervisor - Limerick F. Pfender Shif t Superintendent B. Pieper Shitt Superintendent W. Pinnel Engineer (Supervisory), Maintenance F. Polaski Operations Engineer D. Potocik Senior Health Physicist M. Restaino STA L. Rhodes PO S. Roberts Operations Engineer J. Rogenrnuser PM Activities Coordinator M. Ryan Compliance Engineer B. Saxman CO R. Segeletes Superintendent, Mobile Section R. Sheetz Shif t Supervisor D. Smith Superintendent Operations F. Solis General Superintendent, Testing and Laboratories J. Spencer Superintendent of Services - Limerick B. Stambaugh CO T. Stone IGA Executive Committeeman S. Sullivan APO G. Swayne ACE S. Tharpe Chief Security Coordinator W. Tharpe ACO C. Townsend GE Shif t Engineer R. Truax CO T. Ullrich Plant Manager, Limerick 2 J. Vall:. ski STA L. Vernecchio Test Engineer H. Walters Project Management, Engineer in Charge D. Warfe! Assistant Maintenance Engineer - A. Wargo Shif t Supervisor

3160h7 A-5 ; I I PERSONNEL INTERVIEWED (Continued) NAME TITLE OR POSITION A. Weigand VP, Electric Production R. Weindorfer Director, Security R. Weingard I&C Engineer, Susquehanna Branch B. Widener Shif t Superintendent H. Wiegel Testing and Laboratories, Engineer in Charge P. Wilson GE Shift Engineer T. Winters ACO J. Winzenried Staff Engineer i l D. Woodrow Shitt Supervisor S. Wookey Foriner STA j N. Yost Shif t Supervisor J. Zellmer AO

ISSUE: INP0 Assessment Role APPROACH: INPO's assessment will follow a comprehensive and detailed self-assessment by PE. In connection with the INPO role, as well as its policy for disclosure of INP0 documents, we are providing a letter from Governor Schaefer of Maryland to Mr. Zack Pate of INPO and Mr. Pate's response. CLOSURE: 1. PE will provide a copy of letter, Governor William Schaefer to Mr. Zack Pate, dated February 12, 1988 (attacFed).

2. PE will provide a copy of letter, Mr. Zack Pate to Governor William Schaefer, dated March 14, 1988 (attached).

I 1

1 }. ,A 1

                                                                                                   &e l        STATE OF MARYLAND i i' OFFICE OF THE GOVERNOR e;pgi             l I

l At REPLY REFER TO G-04 l WfLLIAM DONALDgEy l ANNyg og

                                                                                ^~~^*
  • W W.=
                                                                                         ""*SsA"M Jof WE$r PRE 5?oN 5f tff f l

February 12, 1988 &%Wo#E. A4A

                                                                                                      ,2f ws>cNoroNycj Mr. Zach T. Pate                                    '" ~ "2^~'se~57!"as 1202i e jecizes President                                                       roc oc'i m so+e Institute of Nuclear Power Operations Suite 1500 1100 circle 75 Parkway Atlanta, Georgia     30339 l

Dear Mr. Pate:

I am writing to commend you and the Institute of Nuclear Power Operations for your firm stand on the problems at ' Peach Bottom Atomic Power Station. Your letter to Mr. Harrison of PECO's Board of Directors has helped to focus  : attention on PECO's continuing failure to address not ) only the problems at Peach Bottom, but throughout the company. i l I am fully aware that it is not your organization's policy to make such reports public. I am convinced that INPO provides a valuable service to the nuclear industry j and to the public. I also understand your~ reasons for not conducting your business in public. Nonetheless, I i am requesting that INPO continue to make reports concerning Peach Bottom public as long as the plant is shut down and for one year after it is restarted. I also suggest full time inspection in the olant for at least six to twelve months, twenty-four hours a day. I am convinced that INPO's involvement in the review of Peach Bottom is critical to the successful resolution of these problems. I also hope that you can assist me in another matter  ! regarding Peach Bottom. I have urged the NRC to identify specific criteria which PECO must meet prior to restarting the plant. While identifying such restart criteria is admittedly difficult given the nature of the problem, I believe it can and must be done. Judging whether or not attitudes have actually changed is difficult, but not impossible. It is clear from your letter to Mr. Harrison that they have not changed yet. I would like for you and your staff to suggest re_ start criteria which you believe PECO should' meet prlor to restart.

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l Mr. Zach T. Pate February 12, 1988 Page 2 Thank you once again for your very significant contribution.to achieving safety not only at Peach Bottom, but at all nuclear power plants. If you or your staff have specific questions about my requests I would appreciate your contacting Thomas Magette of the Department of Natural Resources' Power Plant Research Program at (301) 974-2261. I look forward to hearing from you. 0 .ly Gov or #

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l institute of Nuclear Power ' , v Operations Suite 1500 11oo Circle 75 Parkway Atlanta, Georgia 30339 Telephone do4 953 3600 March 14, 1988 j l l The Honorable William D. Schaefer l Governor of Maryland 1 Annapolis Office State House Annapolis, Maryland 21401

Dear Governor Schaefer:

Thank you for your letter of February 12, 1988 concerning INP0 interac-tions with the Philadelphia Electric Company. 1 Of the several important points or requests you made, the question of Peach Bottom readiness for restart is among the most important, and I will address that question first. The best method that INP0 has for assessing a plant's operational performance (and therefore its readiness for operation) is through our plant evaluation program. This program involves teams of 16 to 20 experienced nuclear professionals that spend a full two weeks at the plant  ! site, after some weeks of preparation in Atlanta. We plan on, and indeed will l insist on, conductino _iqjLt_3nch a full scala avaluation prior to Peach Bottom's restart. Dates for the evaluation will be set as soon as'the Philadelphia l Electric Company establishes a schedule that can lead to restart. l An important evaluation activity that complements our site visits is the review of corporate support of a company's nuclear plants, conducted by a team of 10 to 12 nuclear professionals and executives. A visit of this type, conducted at the Philadelphia Electric Company in October 198/, formed a significant part of the basis for our letter of January 11, 1988 to Mr. Harrison. Because of the problems in corporate support that are discussed in j our January 11 letter, and that you cite in your February 12 letter to me, we l plan another full scale coroorate evaluation at Philadelphia Electric prior to start-up of Peach Bottom. These arrangements have already been confirmed with i I the company. In conducting these visits, our teams will use comprehensive criteria for l plant performance and separate criteria for corporate support that have been developed by INP0 and refined over the past several years. These criteria, and our application of them, represent standards of excellence in nuclear power plant operation. Copies of the documents that contain these criteria are enclosed as you requested.

The Honorable William 00 Schaefer March 14, 1988 Page . In conducting each of these evaluations, INPO will identify conditions that require correction prior to start up to the company, and will follow up to see that corrective actions are implemented. If conditions are found that impair safety and that make it imprudent for the plant to start up, we will call this to the attention of the company, and I can assure you that the plant will not be started up while such conditions exist. INP0 is an independent safety organization; independent of the government and independent of any single utility (while we receive funding from 54 utili-ties and 22 participants, we have adequate independence from any one utility). As such, we consider our work to be independent of, but complementary to, that of the Nuclear Regulatory Commission (NRC). I point this out because it is important to note that while INP0 conducts the activities I have described, NRC will make its own independent determination of plant safety before it autho-rizes start-up. Thus, the company is undergoing and will continue to undergo careful scrutiny by two outside organizations. With respect to your recommendation that INP0 maintain full-time inspectors in the plant, while we do have a highly capable INPO employee on assignment at the plant, and in a line position in the operations department, we will rely on our proven methodology as described above to make our determination of plant readiness for operation. I should point out, however, that NRC does maintain three resident inspectors at the Peach Bottom site full time. In response to your question about public release of INPO documents, we treat our evaluation reports as privileged for the reasor,s cited in the attached paper. In this particular case, however, the important .information related to Peach Bottom perfe mance and corporate support is contained in our January 11, 1988 letter to Mr. Harrison which, as you know, has been made public. In an overall context, NRC's strong action in shutting down the plant on March 31, 1987, and INP0's action as reflected in the January 11, 1988 letter to Mr. Harrison, are indicative of a good system at work. (NRC ordered the plant shut down as soon as either NRC or INP0 recognized that the evident lack of leadership of the company's nuclear pro cant performance shortfalls at the plant.) gramThe was resultbeing is anreflected example in of signifi-a strong regulator and an industry-sponsored safety organization working in a complementary way to provide safe and reliable nuclear power, while putting safety of the public foremost. In our view, the safety oversight system for U.S. comercial nuclear plants, consisting of both federal and private programs, is stronger and more rigorous than that provided for any other U.S. industry, or than is provided for nuclear power in any other country. I trust we have responded adequately to the points in your letter. I regret that our response is a bit slow, but your letter was not received in our office until February 25, and we did want to respond fully in view of the importance of this matter.

The Honorable William D. Schaefer March 14, 1988 Page . In sunmary, I can assure you that INP0 will continue to follow the situ-ation at Philadelphia Electric Company closely and will carefully evaluate and insist on high standards at Peach Bottom and in corporate support of Peach Bottom before plant operation commences. At the same time, I am confident that NRC will conduct a rigorous review of Peach Bottom and the company's readiness, in accordance with its statutory obligations, before authorizing the plant to operate. Respectfully,

                                                             ). C
                                              / 2ack T. Pate President

[ ZTP:vpm

Enclosures:

(1) INP0 Performance Objectives & Criteria for Corporate Evaluations (2) Performance Objectives and Criteria for Operating and Near-term Operating License Plants cc/wo The Honorable Lando W. Zech, Jr. Chairman, U.S. Nuclear Regulatory Commission 1 1 I l

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REASONS WHY INPO EVALUATION REPORTS OF UTILITIES SHOULD NOT BE MADE PUBLIC

1. INPO was founded as a cooperative effort among all utilities that own nuclear piants to promote high standards of excellence in plant operation. As a condition of mem-bership, the utilities agreM to subject their operations to review by INPO and their peers. It is vital to the success of key INPO programs that the Institute be able to hold private certain interactions it has with individual utilities. Public disclosure of evaluation reports that identify shortcomings based on standards of excellence will be counterproductive. (The evLlustion reports identify exceptions to performance objectives and critaria based on standards of excellence rather than minimum  !

requirements.)

2. Without confidence in the privacy of INPO interactions, the openness and candor of utilities and individuals being evaluated would be significantly reduced and inhibit the Institute's ability to obtsin detailed information from that utility in the future and  !

from other utilities. As a direct consequence, tho effectiveness of INPO evaluations  ! could be impaired.

3. INPO has found through experience that public disclosure of a utility's shortfalls in

!; performance-as measured against standards of excellence rathe? than minimum standards-makes it difficult for the utility to kecp its sights on excelence, instead, the utility's position becomes defensive to protect its financial viability and public credibility. The utility's focus can shift to doing just what must be done to meet minimum requirements to avoid criticism, rather than seeking excellence. The clearlong term consequence of these combined effects will be a reduction in the margin of saf6iy of the nation's nuclear plants. '

4. Public disclosure of INPO evaluations would position the Institute as thzt of a regulator. Althcugh the fundamental goals of'the NRC and INPO are the.same -

safety and reliability of plants and protection of the public the roles, while comple-mentary, are considerably different. The NRC has a statutory responsibility to enforce regulations and to do so with Congressional oversight and public scrutiny. INPO's programs, on the other hand, encourage and assist utilities in improving th operations beyond minimum legal standards--in striving for. excellence. The NRC has recognized this difference and has accommodated the relationship between INPO and utilities. While utilities provide the NRC with access to !NPO documents, the NRC does not take possession of these documents and respects their confidentiality.

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       . ISSUE:      Training APPROACH:    The Organization and Management Develon: ment Division which reports dir-ectly to the Executive Vice President-Nuclear, has designed and implemented several training programs with the purposes'to promote cultural change, build team spirit, and develop management skills.                 A sample of course and lesson plans and tha Management and Supervisory Development Strategy which demonstrate the quality and comprehensive nature of the training provided are attached.
                                                                                                        .f The organization development professionals whc are providinL the individual coaching to managers, facilitating management staff meetings, and reinforcing good management practices are well qualified to perform in these functions. Resumes of the professionals who have designed programs and provided assistance in establishing good mangement practices are also attached.

The trainin,, f off-sit. tisk jurisolction emerge.ncy response agencies is not addressed in the ' Restart Plan-because plans for this training have been previously negotiated and accepted by the off-site emergency response agencies of the State of Maryland and the Commonwealth of Pennsylvania. PE has previously sommitted to provide ongoing training for the

                  . Maryland and Pennsylvania.off-site emergency response

personnel. A letter from R. A. Kankus to the Director, Berks County Emergency Management Agency, is attached as an example of the commitment, t 1 f I CI.0SURE: 1. PE will provide samples of course and lesson plans l [ (attached).

2. PE will provide the Management and Supervisory Development Strategy (attached).
3. PC vill provide resutes of professionals who designed l

1 programs and provided assistance in establishing good management practices (attached).

4. PE will provide a copy of the letter, R. A. Kankus to the Director, Berks County Emergency Management Agency, dated April 30, 1985 (attached).

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I 1 l 1 i PHILADELPHIA ELECTRIC COMPANY l NUCLEAR GROUP SUPERVISORf WORKSHOP LESSON PLAN MODULE 1: SUPERVISING WORK GROUPS TITLE: SUPERVISORY ROLES AND PERSONALITY DIFFERENCES PURPOSE: To develop an awareness of the Supervisor's role and responsibilities and provide an opportunity to explore infotaation about themselves and their relationships with others. OBJECTIVES:

1. Identify roles and responsibilities of PECO Supe rvisors.
2. Receive an overview of the four workshop modules.
3. Identify and discuss the behavioral characteristics of their Myers-Briggs type.
4. Explore and discuss the implications of the preference type on their relationships at work and elsewhero.
5. Develop action plans for on-the-job application of learnings.

1 MOCULE II: MANAGING TASK GROUP MEETINGS 1 TITLE: EFFECTIVE MEETING AND GROUP MANAGEMENT l PURPOSE: To acquaint participants with skills in organizing and conducting effective meetings and develop an awareness of how their Jork groups can develop effective on-the-job behaviors. 1 1 OBJECTIVES: The participants will: I l

1. Identify and practice skills in organizing an effective meeting.
              ?    Identify skills in conducting meetings.
3. Recognize factors influencing Group Processes.

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4. Assess group member c.acess functions in a decision-making simulation.
5. Develop action plans for on-the-job application of learnings.

MODULE III: MANAGING PERFORMANCE TITLE: Implementing the Performance Review Cycle PURPOSE: To acquaint participants with the background, methodology and skills required for performance through the performance review cycle, including the three principles of One Minute Management: Goal Setting, Praising and Reprimands. Ob7ECTIVES:

1. Participants will discuss the performance review cycle in terms of a six stage model.
2. Participants will identify the importance of goal setting, praising and reprimands in the accomplishment of effective work.
3. Participants will practice writing clear goals.
4. Participants will state, write or 4.dentify examples of effective praising and reprimands,
5. Participants will perform praising and reprimands.
6. Participants will identify individual styles for performance appraisal meetings.
7. Participants will discuss how to fill out PECO Performance Appraisal Forms.
8. Participants will develop action plans for an effective performance appraisal system.

MODULE IV: MANAGING DIFFERENCES TITLE: Managing Differences I PURPOSE: To provide participants with an opportunity to explore l the kncwledge, skills, and attitudes needed to i effectively supervise a woic.V group which is comprised of a variety of individuals. l

OBJECTIVEE1 Participants vill be able to:

1. Identify and discuss conflict as an ever present dynamic in the work environment.
2. Identify and discuss various conflict resolution strategies.
3. Practice applying various strategies to specic situations (simulated and plant specific).
4. Identify and discuss their own strengths and developmental areas in managing conflict and differences.

l C MANAGING ORGANIZATIONAL CHANGE l Managing a work environment in transition requires two highly- ' developed capabilities: Decision Making Skills The ability to make the right decision at the right time about what changes need to be initiated or responded to. Implementation Skills The ability to understand and orchestrate the human variables necessary to gain support and commitment from those affected by change decisions. l l OBJECTIVES l THE IMPLEMENATION PLANNING PROCEDURE (IPP) is structured i methodology designed for managers with the responsibility for l carrying out major strategic decisions. Application of this i disciplined planning methodology will lead to the development of i implementation strategies that produce a significant reduction in resistance problems and a dramatic increase in support among , those involved in major changes. Participants in the program I will learn how to: o Identify critical implementation problems that must be addressed for the change to succeed. o Identify barriers from past experience that block the  : successful implementation of change in the j organization. 1 o Assess the human and organizational impact of a l specific, major change. ) o Determine the level of management commitment for the change. o Determine the readiness of key individuals to perform their role in the change process. o Identify deficits in teamwork among the key people affected by the change. o Measure the strength of resistance to the change, determine the exact cause of the opposition, and

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develop effectivo strategies for its containment-or elimination, o Assess'the degree of consistency.between the change and the existing culture of the organization, o Improve the effectiveness of resource ~allecation (financial and human) by directing support to those areas that contribute to the risk of implementation failure. o Complete a detailed. implementation plan for the orchestration of the human variables necessary for the-change to succeed. 4 i i

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1 PHILADELPHIA ELECTRIC COMPANY Nuclear Operations Nuclear Generation Department Nuclear Training Section SITE LOCATION: Peach Bottoa /tomic Power Station DOCTYPE #: DOCUMENT IITLE: COURSE PLAE PROC / COURSE TITLE: Manaring For Excellence d CODE NO: _______________ ITEM NO: _______________ COMPONENTS OF COURSE Unic Titles Unit 1 . Personal Insicht and Interoersonal

                                          -Processes                                                         ,

Unit 2 - Team Develooment Unit 3 . Vertical Team Develooment Unit 4 - Lateral Team Develooment Recommended: Instructor Date Approval: _____________________________ ___________________ Training Coordinator / Branch Head Date , Approval: _____________________________ ___________________ . NTS Superintendent Date. l Acceptance: ________________________~____ ___________________ Station Manager -Date Acceptance: j Department Manager Date l 1

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Page 2 of 11 COURSE TITLE: Maneging For Excellence PURPOSES: The purposes of this course are:

1. To begin the professional managerial development of the new PBAPS Shift Managers. Prior to the recent assigraen in the control room at Peach Bottom, their principal role was that of individual contributor. Part of the preparation for the new duties they are assuming will be done during the Managing For Excellence course.
2. To begin the development of the PBAPS Operations management team.

All of the members of that team are relatively new to their positions, and the Managing For Excellence course represents a unique opportunity to start their team development at the beginning of the team's life.

3. To continue the development of an integrated Pear.h Bottom top management group which includes all of the S3nior Engineers in other functional Operations and support groups within the plant.

Lv The course will enable participants to identify, develop and practice the skills which Shift Managers will require for their personal managerial effectiveness. The course will focus especially on the skills necessary to develop, improve and maintain inter - and intra-team e f fec tivenes s . Specific strategies and techniques will be practiced in the training environment so they can be applied and maintained in the plant environment. The interdependent roles of all participants will be clarified so as to achieve mutual understanding of  ; work expectations. l 1 TARGET POPU1ATION: Shift Managers; Superintendent, Operations; Asst. Superintendent, Operations; Senior Engineers; and other designated supervisory or management l penonnel. PRE REQUISITES: Management selection process SCOPE AND DESCRIPTION: The Management For Excellence course is decigned to provide the new ' Shift Managers with a conceptual understanding of the requirements for personal effectiveness in a managerial role. It will relate the

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Pap 3 of 11 concepts of managerial effectiveness to the specific behaviors and practices of the individual Shift Managers whi;h will complement their technical competencies. The course is designed within the context of the desire to enhance and support a plant culture which emphasizes management team and work team effectiveness. It will provide the Shift Managers, the Operations Superintendent, the Assistant Operations Superintendent and the Senior Engineers from other units at PBAPS with skills and techniques ' to develop and maintain teamwork. Those skills include: decision making, problem solving, communicating, planning, delegating, leadership, and the management of conflict. These team development skills, methods and processes will be practiced in various skill development exercises. The training will occur primarily in the classroom / workshop setting. Emphasis will be placed on providing participants the opportunity to reco5nize and to practice behaviors and techniques that will significantly contribute to team effectiveness. A major emphasis will be the attempt to relate the total content of the course to the plant environment. CONTENT: The content of this course is the processes, skills and behaviors of personal managerial effectiveness and the processes skills and methods needed to develop, improve and maintain team work. Typical content areas include communications skills, leadership, motivation, performance coaching, role clarification and managing conflict. The course is sequenced into four interconnected and progressive units. The topics covered and the skills and methods lea:ned and practiced in  : earlier units are the basis for more advanced and diversified skill I development in later units. ) i ATTACEMENTS: (A) Unit goals, Objective and Activities / Topics DURATION: Approximately 15 days EVALUATION CRITERIA: Self, peer, management and instructor evaluution ) and feedback will occur throughout the course. A , descriptive summary report will be submitted to j management for further assessment of participant . and course effectiveness.

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Page 4 of 11 Unit 1 , PERSONAL INSIGNr AND INTERPERSONAL PROCESSES GOAL: This unit will provide methods for individuals to learn more about themselves and tneir relationships with others, and to relate those learnings to the role of Shift Manager. OMECTIVES:

1. Identify individual personality preferences and preferred interpersonal approaches to others.
2. Identify preferred individual approaches to team activities as a team member.
3. Identify bases for individual behavior in team situations.

4 Develop and practice communication and interpersonal skills. 1

5. To relate insights and learnings to the role of Shift Manager.

1 ACTIVITIES AND TOPICS: I l I Participants will identify their personal preferences for processing information, making decisions and solving problems. 1 i Participants will practice how to give and receive high quality l interpersonal feedback to learn how their typical behaviors impact  ! others, and vice versa. Moreover, they will practice specific I communications skills which will enhance their capacity to I effectively transmit and understand verbal messages in a "high fidelity" manner. Participants will identify their personal preferences for i processing information, making decisions, and solving problems; they will also learn to recognize and adapt to the range of different preferences that naturally occur among people. They will practice specific communication skills which will enhance

their capacity to effectively transmit and understand ~ verbal messages in a "hi bh fidelity" manner.

They will learn and use the tive practical modes for managing and using conf *ict.

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Page 5 of 11-Participants will explore the meanings - of personal effectiveness for the position of Shif t Manager and relate ' their laarnings . to p themselves and the work at-the plant. METdODS AND TECHNIQUES WILL INCLUDE:

1. Myers - Briggs Type Indicator (MBTI) - understanding preferences and
strengths of self and others and then relatin5 to interpersonal differences.
2. Fundamental Interpersonal Relations: Orientation (FIRO B)- ,

understanding of behavicts relevent to . interpersonal relationships.

3. Career Anchors understanding career choice and preferences.
4. Thomas -

Kilman - understanding conflict using the dimensions of compating, collaborating, compromising, avciding and accommodating. 4 3 i 4 4

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Page 6 of 11 - Unit 2 TEAM DEVEIDPMENT GOAL: This unit will develop teamwork among shif t managers and their immediate manager (the Assistant Operations Superintendent). OBJECTIVES:

1. Determine effectiveness /appro,riateness of individual behavior in various situations.
2. Develop skill in using methods and procedures to enhance team effectiveness.
3. Practice interpersonal skills in order to improve communications among "team" members.

[h 4. Distinguish between opportunity for group or individual decision making

   '                 and problem - solving.
5. Identify and match leadership styles to various team situations.
6. Relate managerial practices and behavior to effectiveness in the ' role of team leader / team member.

ACTIVITIES AND TOPICS: i The unit on developing teamwork among the newly appointed shif t managers and betwren them and their manager (The Assistant Superintendent, Operations) will provide participants with opportunities to acquire an enhanced proficiency in concepts and the behavioral skills needed to ensure optimal effectiveness in l l their work relationships. l Participants will continue to practice how to give and receive j high quality interpersonal feedback to learn how their typical  ! behaviors impact others, and vice versa. l l Participants will review their personal preferences for processing information, making decisions, and solving problems; they will , also learn to recognize and adapt to the range of different 1 preferences that naturally occur among people. They will continue  ; to practice specific communication skills which will enhance their j l 1 l I

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     ',                                                                 Page 7 of 11 capacity to effectively transmit and understand verbal messages in a "high fidelity" manner,                                                                i They will acquire a working understanding of the phases of group development through which all working teams evolve (and sometimes recycle).

They will practice group leadership skills that. facilitate a tean's development into a "performing" phase where task achievement is balanced by attention to the needs, desires, and preferences of team membership. They will learn to distinguish between decision or problems which are best made or solved by a team and those which are best dealt with by individuals. They will, also, be able to understand the consequences of employing different levels of active participation and involvement , of members in team responsibilities. Achieving consistency between shifts will be addressed through an examination of methods and procedures for intershif t cooperation. EE- These methods and techniques will include:

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1. Participatory Problem solving and analysis techniques (Force Field Analysis).
2. Establishing mutually acceptable priorities among competitive tasks, activities, functions, demands or objectives.
3. Establishing goals aJ objectives which team members understand and accept and to which thy feel committed.
4. Developing corre'ctive and preventive action plans which are  !

cocprehensive and realistic; to which implementors contribute; and which spell out lines of authoriry, responsiblity and accountability. I

5. Establish mutually acceptable and appropriate agreements as to who has I what degree of authority or responsibilit,v in the making of various types of decisions (Decision Matrix),

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B e Page 8 of 11 Unit 3 VERTICAL TEAM DEVEIDPMENT COAL: This unit will develop teamwork vertically across lines of authority and responsibility. OBJECTIVES:

1. Develop skills enhancing the individual skill of subordinates.
2. Identify the essential elements for creating a motivating work environment.
3. Apply skills in managing interpersonal differences.
4. Clarify authority, responsibility and role relationships between Shift ,

Managers and upper management. di:- P ACTIVITIES AND TOPICS: The unit on Vertical Team Development recognizes the need for each Shif t Manager to relate effectively on a one to one basis with his subordinates and direct line superiors as well as to manage. the team of subordinates to get the job done. Individuals will learn the criteria fer choosing an individual or group approach to work tasks and problems solving. They will identify characteristics of high performance teams and the issues to rasolve en achieve high performance. Participants will review various leadership styles and activities and assess the effectiveness of their own preferred styles. They i vill analyze how to develop a team through the use of various leadership styles and create a climate where team members put forward their best effort. Using data already generated l concerning the operators' personality types and needs, they will ' strategize ways to develop teams with those particular characteristics. As part of the activities in this unit, participants will analyze j their responses to leadership style assessments and engage in j management simulations. Videotapes also will be used for i instruction as well as extensive practice sessions.  ! During the course of this unit' participants will continually engage in clarifying responsibilities and authority and begin the

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process of establishing effective workinh' relationships among the

                      ' Shift Managers, Assistant Superintendent, Operations and the Superintendent, Operations.

The methods and techniques will include:

1. Recognizing -the priorities for any working team to . resolve to achieve high performance and ootimum productivity.
2. Planning to manage a group of different personalities '(from a Myers-Briggs Type Indicator perspective).
3. Using performance management skills such as feedback, appraisal, coaching, counseling, and Soal setting.

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f Page 10 of 11 UNIT 4 1ATERAL TEAM DEVEIAPMENT COAL: This unit will develop teamwork 'across lateral functional interfaces in the nuc1 car plant environment. OMECTIVES:

1. Assess inter / intra group relations to manage differences and solve common problems.
2. Assess external groups demands and requirements which impact on plant operations.
3. Develop or improve skill in coordinating and integrating the specialized activities of various plant functions, g'/.y 4 Plan and manage organizational change efforts.

ACTIVITIES AND TOPICS: The unit on Lateral Team Development is predicated on 'the necessity for Shift Managers to work effectively with their counterparts in other departments. Shift Managers will learn the dangers in making assumptions about those interfaces and will learn to communicate more effectively across department lines. Appreciating ene's o"n personal power base can enhance the ability to influence others, so an assessment tool will be provided for this purpose, Knowing one's self as oniv part of being effective! so an exploration of dealing with intergroup competition will occur.

This will lead co identifying effective ways to understand and manage change and resistance. The establishment of a mutually satisfactory resolurion of intergroup differences is a goal for most managers. Therefore, procedures to "get to Yes" and ways to negotiate successfully will follow an understanding of the issues of resistance to change.

Since much confusion across departmental interfaces occurs because of role confusion between the parties, role clarification and , negotiation will be addressed and practiced by the participants as a helpful technique. Finally, participants raise their own 4 awareness of the criticality of "outside influence", including the

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Page 1; of 11 NRC, and INPO, and their legitimate roles' and potential as , resources. This unit will close with an opportunity for. the Shif t Managers to set personal goals and plan the'.r next steps to achieve them. The methods and techniques will include:

1. The Abilene Pcradox - understanding the dynamics of true agreement and avoiding the traps of Group Think.
2. The 6 Power Bases and how to use them effectively to influence others.
3. Collaboration and competition between groups -

dynamics and strategies.

4. Managing change and dealing with resistatice to it, heightening the awareness of system nuances.
5. Productive negotiation - focusing on the problem not the people and pf striving for mutual gain rather than a vin lose resolution, i

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HIIIADEIRIIA ELECIRIC COiPNE Nuclear Cptions Nuclear Generation Department Nuclear Training Section STIE IIXATICH: Ibach Bottcan Atcznic Power Station DocIYIE f: Doc 0Mafr TITLE: CUJRSE PIAN 190G/000RSE TITIE: Indivichal ard Ormnizaticrnl Effectiwness (ICE) CD[E NO: IIIM NO: CDGMDTIS OF COURSE Unit Titl m Unit 1 - Personal Insicht/ Self-Awareness Unit 2 - Interr;ersonal Prrasses Unit 3 - Team Develoment Unit 4 - Iateral Relations Actres Omanizational Boundaries i W->---<aad: - Instructor Date Amrwal: - l Training Coordinator / Branch Head [hte

 ;gprwal:

NIS Superintendent Oste Acceptance: Station Manager Date ] W ance: l Department Manager Date

OJURSE PIAN OXJRSE TITII: 1rdividual aM Organizatioml Effectiveness (IOC) WRMSES: 7b ensure that supervisors of all furrtional organizations at PinPS understand ard use the same: o w%t.ual language to analyze, describe aM irprove interpersom1, team, intergroup, and organizational dymmics o behavioral skills for effective ocumunications which aru essential for participating in team and inter-group processes o dimensions of persoml awareness aM interpersonal insight rtquired to enhance individual ard organizational effectiveness Most limnsed and non-licensed operators ard their shiit ranagers have received similar training. Managers and supervisors of all administrative, project, and support service organir,ations rust receive similar training to ensure that all site employees can work together (within ard across functions) effectively ard efficiently. TARGET MNIATIQ1: New licensed operators. First ard secoM line supervisors from all cite organizations incitriing: Maintenance, Enginocring, Crafts, Projects (outage mamgerent; planning /arh:dulirg/ reporting; rateriale mnagement; modifications), Health Physics, Chemistry, Technical Staff Groups, Sectrity, Instrument and Cbntrols, Radwaste, etc. PRERIUJISITES: Mamgement selection Process 1 SCOPE AND DESCRIPTIQi: The IOE course is inteMed to support ard enhance a site culture khich emphasizes participative management, team cohesiveness, arti persoml  ! effectiveness. The wagat of '.earawerk enccep,ws both vertical tears (up  ! ard down the authority strutture) ard lateral teams (between interdependent l work groups, across organizational boundaries) . Tb the extent that these i intentions are realized, site safety, reliability, availability, and ) maintainability will be enhancal. The IOE course is designed to pIwide participants with four weeks of adult learning opportunities which are intended to corplement their existing technical ocmpetencies by enabling thern to:

1. Enhance personal, interpersom1, team, intergroup, and organizational knowledge and skills frun the perspectives of both "the leader" ard "the follomr."

l I

2. Obtain a functional understaniirq of the demnds of their organizational rules.
3. Acquire aM enhance mastery of concepts as well as proficiency in the application of skills needed to satisfy the demrds of their organizational roles.

The trainirg course is conducted in a classrocrVworkshcp setting and enploys such educational methods as: lectures, discussions, VIR-enhanced self and peer faahck procedures, self-assessnent instn:ments, role plays, sinulations, skill practice /develc5 ment exercises, case studies, and back-home application planning sessions. CEtEDE: The IOE course consists of four discrute but interconnected units of instruction. The first week focuses on "Personal Insight /Self-kareness". The foci of the secord, third, and fourth weeks are "Interpersonal Prmw," "Supervision ard Team Develc5 rent," and "Iateral Relations Across organizaHorVBcundaries, respectively. Each unit of instruction er:5 h asizes difi runt aspects of individual aM organizational effectiveness. The information, skills, and methcds learned in each unit are the basis for more advanced and ocuplex develc5 rental experiences in later units. Typical titles for individual lesson plans incitde: verbal ccrrunication skills, situational leadership, creating a motivating environnent, coaching the urder-perfoming er:ployee, role clarification and negotiation, and the management and utilization of conflict. ATTACH 4 DES: Unit Goals, Objectives, Activities and 7tpics, and Methcds and 7bchniques for each of the four units of instruction. DURATION: 20 classrocn contact days, each starting at 8:00 A.M. and eniing at 4:30 P.M., with a one hour break for lunch, and i several torning and afterncon breaks (one every hour to one i and one-half hcurs). 1 EVAIIJATION CRITERIA: I l Self, peer, manager, ard instructor-trainer fudh,ck to peticipants is provided thrugh the course. Two types of fermal evaluations of participants will be condacted: (1) each participant is given a written objective test of content knowledge at the conclusion of eads of the four major units of instnx:: tion; (2) during the last two or three days of the IOE course, participants are involved in a set of "aw-nt center" sinulations during which site managers rate indivichial participant's behavior to assess the extent to which they donorstrate proficiency in the skills in khich participants have been trained. Muf. of this will be enhanecd through the use of VIR equipment.

In the event that site managers are not available to perfom the assessor function, a person who is well emerienced in NPP operations and management, but who is not a part of the training staff will serve as an irriependent third-party ac m anr. Participants will also assess the course and provide feedback on its perceived relevance tr the training staff. A descriptive sumary rtport on the course will be subnitted to PEOo , management for further assessment of the effectiveness, relevance, ard apprwriateness of the course. 4 l I 1 1 I e d

UNIT 1. PIRSONAL INSIGfr/SPTF-AHARMFES GOAL: Tb enable participants to understand how their personal preferences, tardencies, habit pattems, and cormunication styles impact the manner in which they respord to the demands of their supervisory roles. OBJECTIVES:

1. Participants will identify their individual personal ard interpersonal preferences for dealing with people ard job responsibilities in the work envirornent.
2. Participants will develcp or enhance and practice effectiva interpersonal cxxmunication skills.
3. Participants will begin to identify and describe their perceptions of theselves and others in terms of observable behavior by learnirg and practicing how to give and receive "high fidelity" f e ck.
4. Participants will begin to consider options and alternatives regardirg possible changes in their job-related behavior, l

ACTIVITIES AND TOPICS: I Participants will be guided through a series of adult learnirg experiences l which have been carefully designed and selected to ensure relevance to their  ! real-life organizational roles and responsibilities. These experiences will l be created by such activities as: brief lectures, case studies, sinulations, self-assessment instrunents or inventories (questiennaires), VIR faadhACk, ard theory-building djewiens. This "Personal Insight /Self-Awareness" unit of instruction is a

respcnse to the recognized need for site personnel to understand themselves first in order to accurately urderstard and work effectively with others

( W m , subordinates, ard peers). Once they have acquired relevant personal awareness, participants wf11 be able to identify ard choose frun l among a range of alternative behaviors in order to match the demands of i various work situations ard corditions. Thus, participants will learn hcu l to enhance their personal ard professional effectiveness and, thereby, how l they can personally contribute to PE00's goals ard objectives. The topics of the irdividual lesson plans for this unit of instruction may include scune or all of the follcwirg:

1. Interpersonal omrunications Skills
2. How People Relate to One Another; Why Rxple Relate To Others Tne Way They Do

I . i l I

3. Effective F*ck In Managing (Vertically ard Iaterally) "Ihe Jchari Window" l
4. Difference In Mrsonal Preferences l
5. Managirg ard Utilizing Conflict In the Work Place
6. Creative Perception: 'Ibe Basis for Behavier  ;

l 1 ME3ODS AND TECHNIQUES:

1. MYERS-BRIGGS TYPE INDICATOR (the MHI'I): A self-assessment questionnaire that enables respondents to understand their own and others' penal preferences for promssirg infomation (collecting and organizirq data, reccgnizing trends and cptions, choosing frcan alternatives, anticipating others' reactions to one's choices, and taking action).
2. RIndamntal InterDersonal Relations Orientation - Behavior /Feelims (FIR)-B and F):

o The FIPO-B is a self-ac w ament questionnaire that enables respordents to urderstard their interpersonal behavior in terms of: hcw central or peripheral they prefer to be in relation to work that involves other people; how ruch they prefer to be in control or be influenced by others; and how c1cce or distant they prefer to be in relation to others, o 7he FIIO-F is a questionnaire that illuminates how respordents want others to permive them.

3. 'Ihe Johari Windcw: A self-at"w-nt inventory ard semi-structured procadure that explores the extent to which respctdents: self-disclose  !

their thoughts and feelirgs; ask for or are receptive to persorni fauThack frcra co-workers; ard give fmih,ck to others.

4. Rtim Oruanizatioml Conflict Irr/entories (ROCI): Two self-ae m e nt inventories stich enable respondents to examine the similarities or differences in the styles they typically use to manage conflict (within ther:selves, within their con work tearc, between work grmps or with l their bosses, subordinates, ard peers) . H2E1 The ROCI are {

oorceptually ccrpatible with the 7hcanas-Kilmann conflict Mcde ' Instrument.

UNrr 2. D7FERPERSONAL WOCESSES GCAL: 7b emble participants to understand nere about how they interact with others: how their behavior inpacts others, how others' behaviors impact thau, which behaviors contribute to high quality results, and how to ensure that others urderstand them as they interd to be understood. OBJECTIVIS:

1. Participants will identify their own personal individual preferences for interacting with others.
2. Participants will identify barriers to effective interperraul occumication.
3. Participants will assess the effectiveness of their own ard others' ocrmunication in typical working relationships.
4. Participants will practice ard develop increased and enhanced effectiveness in both excessive and listenirg ccumunication skills.
5. Participants will identify opportunities for increased carmunications effectiveness in their mnagerial and supervisory roles and responsibilities.

ACTIVITIES AND 70 PICS: Thrugh a structured sequence of learnirg activities, participants will identify, select, and practice ccumunications techniques to enhance their perfomance as contributors to PE00's ard the site's mission, goals, ard objectives. Each activity provides a building block toward Supervisory Ozrunications that terd to prtrete nutual understandirq and positive working relationships. Methodolcgy will incitde lectures, sinulations, VIR frwhck, self-went questionnaires ard theory-buildirg discussions. This unit of instruction responds to the reocgnized need for all site personnel to be able to ccxmunicate effectively with subordinates, peers, and bosces. By understardirg one's current style of ocumunicatirg, assessing it's inpact, and learnirg how to adjust for maxinum I effectiveness, the individual contributes to enhancai perfomance in the interpersonal arena. Site personnel also enhance organ.izational effectiveness, irdividually and collectively, by modelling sourd cx=unications practice to others who may them adopt the same skills. l 1

Luvidual lesson plans may include scme or all of the following:

1. Amairg personal style and effectiveness
2. Barriers to effective comunications
3. Practicing positive f
  • ck
4. Non-verbal comunications: What Does It Really Say?
5. 'Ibe supervisor as a facilitator of ocanmunication processes MEIHODS AND 'IECHTIQUES:
1. Cantunication Skills Develepaent. A series of activities designe<1 to build confidence ard trust in what we and others hear ard say.
2. Interpersonal Styles: 'Ihe SPIRO Instrument, a conceptual franeWrk to describe an individual's style using Transactional Analysis theory.
3. Positive Reinforcement Skills. Based on the principles of the "One Minute Manager".
4. Johari Window (Part II): "It takes two to see one." Increasing one's understandiry one's self through an exercise in self-disclosure and interpersonal f
  • ck.

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                                                                              )

UNIT 3. SUPERVISION AND TEAM DEVELOFENT GOAL: To enable participants to gain new or enhance existing ekills when functioning in the capacity of 'Ibam Inaders or Followers. OBJECTIVES:

1. Participants will diagnose and evaluate their own individual Supervisory Skills and Styles.
2. Participants will develop ard practice effective performnce coaching and counseling techniques for working with urder-achieving or non-perfoming subordinates.
3. Participants will identify benefits and opportunities for delegation of responsibilities to subordinates and peers.
4. Participants will understand and identify the stages of team developT.nt and their relevance to on-the-job situations.
5. Participants will distinguish between opportunities for group or individual problem-solving / decision making.
6. Participants will identify and match their leadership styles to various team situations.

l ACTIVITIES AtQ 'IOPICS:

 'Ihis unit provides participants with opportunities to develop new or enhance existing Supervisor, 'Ibam Isader, and Team Member Skills. Participants will add to their Self-Awareness and Interpersonal Process Skills (frun the two previous units of instruction) to increase their repertory of Supervisory        I skills. In recognition of PEco's mission, goals, and objectives, Unit 3 is       l designed to integrate positive relationship-building and personal                I accountability with participants' technical perfomance.                          l
 'Itpics may include, but not be limited to:
1. 'Ibe mupervisor: 'Ihe Person in the Mickile
2. Delegating Effectively: Khen, Why, How
3. Counseling and F*ck: 'Ibols for Effective Supervision
4. Situational Isadership
5. 'Ibam Development: Significant Stages of Growth

1 1 METIHON AND TEO NIQUES:

1. Foroc Field Analysis: A Participatory problem-solvirg ard analysis technique.
2. Performance Management Process: "One Minute W " Applied
3. Decision Matrix: Establishirs nutually ameptable and appropriate agreenents regartiirq authority and responsibility in various types of decisicos.
4. Delegation Checklist: Instrumentation'to ider.tify opportunities for appropriate and productive delegation.
5. Group Decision-Making Sinulations (e.g. , NASA): Identifyirg task and maintenance functions ard group decision-making procedures khich enhance the identitication ard utilization of human resourms in team tasks.

l I l l l l v

UNIT 4. IATEPAL REIATIONS AGOSS OPGANIZATIONAL BOUNDARIES

 ,_ GOAL:       Tb begin to develop teamwork arx>ng interdependent functional organizations within the site environment.

OBJECI'IVES:

1. Participants will assess intergroup relations (interface transactions) among the site's operations, support service, projects, and administrative services organizations in order to:

o Identify differences or conflicts, problems, aM wrtunities to inprove performance and effectiveness of the station as a whole. o Develcp remmnrrlations for managing differences, solvirq prcblems, aM exploitirg opportunities (for senior site manager's consideration).

2. Participants will assess the demands, requirements, and expectations which may be i@osed on the site by external "stakeholder" groups (e.g. , joint cuners, NRC, INPO, stockholders, rate payers, RJC) in order to:

o Identify the ways in which such demaMs, requirements, aM expectations may igact on station activities. o Develop remaadations for managing differences, solving prcblems, ard exploitirg opportunities created by these igacts frcn external stakeholders (for senior site managers' consideration).

3. Participants will develcp or enhance their awareness of how their l functional organization operates as an interdeperdent cmponent of l the larger site system,
4. Participants will develcp or enhance their skills in coordinating ,

aM integratirs the specialized work activities of the various l functional organizations which, taken together, cmprise the site l organization.

5. Participants will develop or enhance their abilities to plan ard iglement organizational change efforts within the site system.
6. Participants will acquire insight into and begin to practice hcw to manage inevitable resistance to planned organizational change (within themselves, in their besses, among their subordinates, ard among their peers).

ACI'IVITIES AND TOPICS: All functional organizations within the station site system are "interdeoendent". That is, each neals other functional organizations' centributions (e.g., information, work products, or results) in order to

l l 1 l successfully achieve its own work objectives. No organization could i function effectively if it trial to operate as if it were totally indeperx3ent and did not require the cooperation of others. Organizatiomi personnel must develop effective ways to work together, across organizational boundaries, with their counterparts in other functiomi site organizations, through formal and infomal lateral interface relationships. Using simulations, case studies, role plays, atriio/ visual augmnted theory sessions, and other adult learning technologies, participants will be guided thrcugh such tcpics as: 1, &nagement of Iateral Interfaces.

2. Specifying and managing conflicting demrds frcn lateral arx1 external organizations:
  • Stakeholder Analysis
  • Open System Planning
3. Intergroup Cccpetition and Collaboration: Iocal versus Global Perspectives.
4. The Planning ard Management of Intentional Organizational Change.
5. Management of Resistance to Socio-Technical Charge.
   !EIHOC6 AND TECHNIQUES:
1. The Abilene Paradox (VIM : funaging the Paradox of Agreement airl Avoidirg the traps of Group Think.
2. Intercroup Sintlations: The Dynamics and Strategies for Managing 1 Intergrcup Conflict and Cbilaboration. l l
3. Skill Practice / Skill Develement Exercises:

o Planning and Managing Organizational Charge. o Productive Negotiations ("Gettirg to Yes") l l

4. The Decision Matrix: Clarifyir9 hhg participates frcn which l functional groups in what fashion in solving problems or making decisions about which organizational issues (pitblems or i esportunities). '
5. Meetirn Manacement: An organizational questionnaire and set of pro dures designed to identify those factors which either enhance or detract frca the cffectiveness, efficiency, and member satisfaction of nulti-disciplinary or single organization business meetirgs.
6. Personal Action Plans for Applyirg IOE Icarnirgs to Participants' Real-Life, Back-Hcne Work Situations.

i , 4

  • ~
        ,                MANAGDENT & SUPfRVISORY EEVEICIMENT SIFATEL"I What is to be m limbed?

To develcp and inplement a phased-in systematic program for the effective selection ard develegnent of supervisors ard ranagers within the htclear Grcup. This pregram will be sponsored by line mnage.mnt with the support of the Hu:ran Resources and Panagement and Professieral Develegnent sections. Why is it to be m 1iched? Historically, htclear management ard su p isory developnent has been hirdered by a poor selection process, a lack of effective career and summion planning; insufficient training and develegnent opportunities provided to htclear ranagement ard supervisory personnel, and inadeqmte organizatioral cer=unications about hcw to approach ramgerent ard professieml develegnent effectively. The challenge of adopting and integrating a new buclear culture provides the cpportunity to integra*a state-of-the-art ranagement practices into a Nuclear ranagerent and supervisory development program and to ersure that such a program reflects and reinforces Nuclear Group values. Hcw is it to be m lirhcd? Sumsful ranagement and supervisory development is predicated upon the company's personnel policies, I.G.A. relations, clearly defined organization structure, reward systems, career pathing st:uctures ard ongoing ranagement prem ceen, such as perforrance goal-settirg ard evaluation. All of these nust be included in a successful ramgement and-supervisory develognent strategy, not just training prcgrars. Prcgram initiatives, specific activities and key cencerrs (scre of which are outside the scope of this strategy group, but which must be addressed in support of an effective ramgerent ard supisory developrent program) have been grouped under fcur categories:

1) Establishment of role eWations for all rarage:nent and supervisory positions.
2) Implerentation of effective candidate selection processes, including pre-selection develegnent opportunities.
3) post-selection developnent of ramgerial and supisory persennel
4) developnent of options to address poor supervisory /mmgerial l perforrance.

(See attachment A, "Elenents of a Famge:nent ard Supisory Development Prtgram" for Kore details.) { The foundation on which all other program initiatives should be based is l

the definition of role exoectatices for ranacement and sucerviserv cositions (includ.f.ng generic leadership behaviors expected of all management ard supervisory staff.as well. as specific conceptual, organizational and technical ocr@etencies ._ required at different organizational levels) . 'Ihis needs to be initiated by senior Nuclear Group management, with support frcn organization DevelopmentA'anagement Development staff. In 1909, the primary focus of the strategy will be to s*a$ hen first-line supervision. Key activities to develop incurbant first-line super /isors will be: o clarification of positiens included in "first-line sq:er/ision". o training for supertisors in employee relations ard discipline; cther trainirq priorities deperdent on the results of the Paragement Training Needs survey data aralysis. o training for secord-line supervisors in how to provide en-the-job ocaching and support for subordinates, o increased use of Nuclear CD ard HR staff to provide courseling to secord-line supervisors of peer performrs and directly to poorly ~ performing first-line sq ervisors. o establishment of cne well-defined performance evaluation prccess (i.e., integrated goals pwam, consistently used perferrance evaluation forms) for the Nuclear Group. To ersure the selection of well qualifisd candidates into cpen first-line supervisory positions, key activities vu l include: o improved irplemntation (ard/or revision if . @ ed) of personnel policies related to precction to first-line supetision, o irplemntatien of selected =ent center or similar methcdology to develop a pcol of super /isory cardidates, f o the develeprent of a structured (selection interviewirg) prccess (also to he used for other superviscry and ranagement positions.) ' o trainirg and coachirg in selection interviewing skills for raragerent staff, o increased use of pre-supervisory training to prepare qualified personnel for supervisory positions. A secordary fccus durirq 1989 will be en the developrnent of incurbant and l potential maragers. In addition to same of the activities listed above,  ! t.he following activities will be undertaken in support of tMs focus: l o irplementation of selected assessment cente.r or similar methcdolcgies to provide individual fauhek for develcpnental purposes to division and section ranagers, l l l i i e +,,i - s - . - . - . . - , . , , . . m e,

                                                                            %,w .         ,.     .    . . . , , . ..

e o manage:mnt training based on prioritized results of training needs survey. o definition (i.e., Ecurds/centirgencies) and iglementation of summien planning for all Nuclear avugement positions desn to the Superinterdent level. Durirg 1990 ard 1991, erphasis vill be placed on centinuirq ard advanced training; the use of "cae w nt center methcdology for selecticn ard develegantal plw.; summion plannirg down threugh lover levels of nanagement ard supervisien; develep wnt of non-swisery career advarcenent paths; job rotatien ard excharge p t wicms; ranagerent incentives prcgra s; ard the develcpmnt of a Menter ptwics for Nuclear ranagers ard supe.wisers. In ad:iitien to resolvirq varicus personnel policy israes, the support of the Personnel ard Irdustrial Relations departrent will be regaired en the follcwire prcgran initiatives: o Lpreved recruitment and selection processes, o Develep wnt of cross-functieral career paths for supervisors and raragers, inclulirg rcre job rotation ard exchange /lcan pro:ra s. ' o Develepxnt of non-suparviscry career advancerent paths. s 1 1 i 4

e - l 1 Resources Recuired

               'Ihis strategy will require substantial time ard effort on the parts of Senior management, organization and Management Developve.t Division staff and line managers. In addition, ex*h censultants will be used in the design and start-up phases of a=="mant methods and egloyee relations trainirg, Segnants of the strategy which involve t %. may be purchased from appr priate vendors.It is also possible that based on the reczmendation of the rxss-functional task force in 1991, extermi consultant services my be appropriate.

Itaic , 123.2 12.29 1221 Design and Irplementation of Assessment Methodology $ 175,000 $ 80,000 $ 45,000 Initial Purchase of Selection Interviewing Prcgram and Trh certification 22,000 - - Trainirg of Nuclear Grcup Managers 13,500 13,500 13,500 in selectim interviewing External Consultant Delivery of Super /isory Trainirg Pr: gram in Erployee Relations 120,000 25,000 25,000 Developut and Lglementation of Program to Establish Individual Develegnent Plans - 50,000 50,000 Lylerentation of Task Force Recommendations on Jcb Rotra. ions, Ican Prcgra~. s - - 13,000 Dissemination of inferration *w Nuclear erployees about these aspects of this rategy %hich will most i: pact them 10,000 2,000 2,000

                                                    $ 340,500             S 170,500                              3 148,500 Item                       1233 Study of Ace"ment Center methcdolcgy for decision-makirg re: application to Nuclear Group needs               S 6,000                                                                             .

s , . . . ,

ACTICH S'IEPS Ly kTat ' knen _ _ Who 4

1. Define generic role expectations for all levels of 4/89 CAV i btclear Management and supervisien Senior.

Staff (cascade down-line manage-ment)

2. Establish requirement and mechanism for cctmunicating S/89 - CAVOD expectations Manager
3. Develop and irplement the prog am by %hich 4/89 C7F/

inferration about this strategy will be di"aminated Corporate to Nuclear employees Cc= uni-cations / Personnel

4. Establish integrated perforrance evaluation precess .4/89 CAVOD
   ,                    for bbclear Group                                                          Marager S.      Es,tablish s'a-tured inteniew prma and orient                       4/89    OD Manager Nuclear raragers in its use for first-line super-visory positions
6. Develop ammt methodoleyy with input frczn K. Ccok 6/89 lir/3 ranagement Establish specific criteria for first-line su p isory positions I Identify develegnental activities for each criterion Share criteria / activities with IGA Establish specific criteria for other supervisory and ranagement positions Make recomendations re:use of esment methodolcgy during 1990 to CAVsenior staff for approval I l
7. Deve]cp and conduct t %. redule in on-the-job 7/89 K. Ccok coaching for second-line supervisors
8. Develcp a plan for increased line ranagenent use of 9/89 OD Parager l 0.D. assistance with haniling supervisory %magerial performance problems; orient line managem,ent to use .

1 s

                                                                                                               \
                                                            ..,..e,   ,-=:   ;_gm.s;%s y            .            - .

1 9 ., Develcp and coMuct supe.rvisory training pregram in 12/89 K. Ccck enployee relations and discipline

10. Conduct training in selection interviewing skil'Is 12/89 K. Cook for all managers and end-line supervisors
11. Develop su m ion plans for Nuclear m nagement 12/89- CAM / Senior positions down to the Superintendent level. Staff /line It;m't/OD Manager
12. Irplement went methcdolcgy plan 12/89 K. Cook
13. Establish a cross-functional task force cmprised 1/90 CAM /VP of managerial and supervisory personnel to develop Pe m nnel reccr:rnendations re:

o Non-suparvisory career advancenent paths for IMclear - pe m nnel. o Jcb rotation and exchange / loan prcgram for IMclear mnagers and suparvisors. Report for a : proval to CAM / Senior staff by 6/90

14. Orient IMclec.r ranagers in the use of the 4/90 CD Manager structured interview p.m for ranagement positions cther than first-line supe.wisory positions
15. Develop and i::plement a pregram for establish.ent K. Ccck 6/90 of iniividual develogrent plans for all IMelear ranagement and suparvisory plans .
16. Develop succession plans for rcraining IMclear 12/90 Line rgnt/

ranagere; ; positions. CD ranager K. Ccck

17. Develop and irplement a Mmtor Prcgram for 1/91 C?-F/ senior niiddle and first-line IMclear ranagers OD ranager
18. Imple:nent recocrendations of task force on 1/91 Senior i

non-supervisory career advancenent, jeb { and line rotation and exchange / loan pregram, ranagement

                                                                                   / Personnel    l l
           ~       *
                                            ~                     ' -                          -
                 ,                                    ASSmPTICNS
  • o Early retirement program cstablish d by Fall, 1988.

o Cutplacaent ccunseling services available by Fall,1988. o Plan for core Nuclear ranagement arvi supervisory trainirg prcgram develcped, NW on survey data analysis, by Fall, 1988; ongoing implementation of plan throughout 1989, 1990 and 1991, o All positions included in definition of "fin;t-line supervision" have been clarified for stations ard Mobile Mainte. nance by 12/8S. o Policy re: "senior qualified cardidates" for prunction to first-line supervisory pcsitions has been revised by 12/88. o Budget allocation available to support investigation of assessrent center or similar rethodology during remairder of 1988 o Nuclear Grcup organization ard staffing plans fizuly in place and clearly urders*M by 1/89 o Irplerentation of rore cxrprehensive incentive prcgram (e.g. , pay-for-

perforrance throughcut the company durirg the next three years.
                                                                                                                        \

4

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

l

l 1 1 ATIAQE70 A Page 1 of 4 Elcsnents of a Managenent ard supervisory Develcpnent Fwp.am 1(Note: This rrdel is presented in four sequential stages as a means of organizig pregram initiatives ard key concerns. With the exceptien of the , first stage, however, program activities ray be applicable siruitaneously or in a spiralire pattern, rather than in chronological segae.w.) I. Role Expcctaticns for Managenent ard Supervisory Pcsiticos A. Definition and ccz=unicatien of generic leadership behaviors- i.e. , leadership behaviors expected to be de::enstrated in varf irg degrees by ill ramgerial ard supe.wisory pennel. B. Entablishment of specific skills, knowledge and ramgerial/ supervisory behavior criteria for each organizatiomi level. Incorporation of these into position guides. Cs Establish ent of reqairew_s that all ramgers h ..anicate their irdividual perforrance expectations to subordirates. And the rechanists for doing this. D. Clarification of positien-

  • o khat is the fint line sumisor?

i o k?.at positions egaate to first line supervisors? II. Effective Candidate Selecticn Prrmm A. Revisien or entry-level ard non-entry level hiring and career i progression policies to am. 4.date Nuclear Group needs for additieml technical expertise ard supervisory experience in same technical ard su p iscry positions. Reccgnition of negative irpact on supervisory candidate pipelines if entry level hires for various jcb progressiens are not screened for supervisory potential. B. Establishment of specific qJalifications criteria for praction to first-line supisory positions (sub-item of IB) Lgreved use of pre-supervisory training ard other optiens to ascertain supervisory ability before rakirq perraren*  ; pr=ctions to first-line supervisory positions. l ,l

                                                                                  -...~.n.      .

1

l i l AITAQtENT A Page 2 of 4 C. (In conjunction with A anl B above), use of accase nent center methods to develop a pool of s % wisory candidates. D. Improved processes for recruitnent of managerial / supervisory candidates-internally and externally. i - More open and systematic publication of s % wisory/ management position openings with q d ification criteria specifics. Simultaneous recruitment of internal and external candidates. E. Training and coaching in selection inteIviewing skills for ranagers. F. Structured interviewing process, based on criteria established in IB s above. Ensure the quality of the interviewing process meets corporate objectives by having candidates interviewed and evaluated by a ccebimtion of individuals, including the supervisor of the positien, a subordimte of the position, a peer of the position and a representative frcm Persennel ard Intastrial Relaticns. (bncerns 1.

                           'Ihe establishment of specific criteria for precotion to supervisory positions will create problems with the IGA. 'Ihese preblems .will have to be identified and resolved as soon as possible between senior Nuclear ranagement and IGA ranagement.
2. Roles and expectations need to be clarified between Personnel and line

,' ranagement with respect to recruitment and selection; Wat are the I *esponsibilities of each? Wat can be done to expedite the prccesses?

3. 'Ibere ray be a need to revise personnel policies regzt % jcb postings (?)

III. Ibst-Selection Developnent of Supervisor and Manags=mt Personnel A. Use of aw=mnt nethcds for develegnental purposes--e.g. , simulated ranagerial/ supervisory situations during which participa.va are { j hwed and after khich the/ are given perforrance feedback and j assisted in establishing indiv.; dual develcp ent plans to address areas ' in need of irprcuement, l l l i s*  ; t -

   '                                                                                             AITACPF.D7r A i

Page 3 of 4 B. Irproved performance evaluation prcgram - d Integration of varicus performance goal prcgrams of the cxz1pany into 9.Ds gd$ of performance goals for each manager / supervisor by stich he or she is - M . Establishnent of one well-defined Performance Evaluation precess for the Nuclear Group which all raragement - and supea: visors are th. to administer skillfully. Trainirg for all managers of supervisory staff in perforrance goal setting, on-the-job coaching /fenThweh, analyzing and addressing perforrance problems, writLN perforrance evaluations, and corduccing perforrarv a evaluatien interviews. C. Provide rotivations for excellent ranagerial and suparvisory perferrance by including: o Pay-for-Perferrance ard Corcequence Vanagerent in the ccrpensation structure. D. Establishment of a Ferral Mentoring Program for ranagers and super /isors. Include reccgaition factor for good raragers; systeratic processes for voluntary involvement of gced raragers ard selection of mentors by less experienced ranagers and sumisors; and trainirq "credit" for participatien. E. Continuing ard advanced training in technical and ranagerial areas. scre ir:nediate needs: interfacing with regulatory entities, lat:cr relations, discipline and grievances. l State-of-the-art in nuclear industrf. I State-of-the-art in ranagement. F. Establishment of supeWisory/ranagerial career paths to broaden rarage:nents' urde.% of Ccrpany's business and functional needs. Wre supervisory /nanagerial job rotation prt:grars; rore exchanges with other utilities and Im o. G. Inproved sumion planning Wre formalized ptem with individual develegnent plars to pre m cardidatec for su - ion. l-

. . y ' ' ATIAccC7r A Page 4 of 4 IV. Develcpment of Opticns to Akitess Poor Supervisory /Mamgerial Performnoe A. Establishment of non-supervisory career advancenent paths. Paerejnitien ard reward for superior technical ability in

                             <-- where irdividuals do not have the apprcpriate skills for supervisory positions.

Reassigment cptions for personnel who have not perConned well in supervisory positions. B. Counselirg available to pcorly performing s%"/isors/ranagers f';cm CD staff. O. Ccunselirg available to ramgers frcra CD staff on hcw to work with severe perforrance problems among supervinor personnel. D. Pehabilitative technical ard ramgerial t: ainirrJ prcgrams. E. Establishment of early retirenent prtgrc% F. Retention of an cutplacement ccenselirq service (cr development of internal capability to provide cutplacement ecunseling. 4 0 4

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        .                                                        ATTAOM2TT B Page 1 of 2 Operaticnal Definiticris The follcuing are not intended to describe specific programs; they are offered to provide a cxxuon frame of reference for the Manage:nent/ Supervisory Develegnent Task Team working sessions.
1. A w e-ont Center Not a physical place.
                        "A variety of testing techniques designcd to allcu caniidates to demonstrate,    under stardardized conditions, the skills and abilities most essential for suma in a given job."
2. Awe ent Methodolcgy - the use of nultiple methods and neasurerents to gather data about a person's ability to perform a given jcb or family of jobs, specific activities can include one or a ccmbination of the follcuing:

Structured Interviews Behavioral Sirulations o Analysis exercises o In basket exercises o Business gres o Imaderless Group Discussions Perforrance Observation Paper-and-pencil Tests ,

3. Mentoring - A develcynental pres khereby junior erployees receivo coachirg ard guidance frcra senior e::ployees, in the intricacies of achievirg both jcb ard organizatiomi performnce expectations. This process may be forml or inforral and not nevrily confined to chain-of-ccr=ard.
4. Mamge:aent Suermion Planning - The systens, processes and activities that emble the organization to identify ard develop e:mloyees for future supervisory and managerial positions. Ideally, manage:nent sumaion planning is linked with the organization's business plars ard hunan resource forecasts. l S. Role Expectations -

An identification of the acceptable kay of executirg the skills ard knowledge of a specific position or level of position. While the position description describes khat I do, the role expectation describes hcw' I do it (e.g. given our culture, . values ard noms, what does it lcck like when a supervisor exhibits j "Imadership"?) 1 l I i I 1

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              ,                                                ATLAQ M NT B

, Page 2 of 2

6. Structured selection interviewing pr-i a unifomly applied step by step approach for obtainirg and evaluating information for selection prmation do::isions.

At mininum the prma should .'nclude: o the identification of rags' ired job knowledge, skills and abilities o the- development of a set of questions to be used with all E candidates to best solicit the desired information o a clearly defined interviewing process o clearly defined decisions points - 1 J e t i k i 1 l 1 i

t I ItaG 1232 1229 1221 i Design and L"plementation of A - emant Methodology $ 175,000 $ 80,000 $ 45,000 Initial Purchase of Selection Interviewing Prcyram and Trainer certification 22,000 - . 4 Training of Nuclear Group Maragers 13,500 13,500 13,500 , in selection interviewing Exterral Consultant Delivery of Super.risory Training Prtgram in D:ployee Relations 120,000 25,000 25,000 Develegnent and Inplementation of Program to Establish Individual Develegnent Plans - 50,000 .50,000

  ,                 Irp.'.ementatien of Task Force 1                  Recernandations en Jcb Rotatiens,                                                                                                         ,

4 I.can Prcgrams - - 13,000  ! Dissemiration of informtion to - IMclear exployees about these

  ;                 aspects of this strategy which will rest irpact them 5

10,000 2,000 2,000 6

                                                                     $ 340,500                      $ 170,500             S 148,500 4

Item liga 1 l Study of AS 7 % .t Center ' 1 methcdology for decision-making re: application to Nuclear Group n M s S 6,000 l l 4 y

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i l i HIE PD0010 CLEAR GRIP'S I MANAGEMENT INFOR4ATICN SYS'IDO DEVEIDFMENT STPATHW I Nhat is to be aerr = 14 % d? 1 An MIS Study Team will develcp and propese a IMclear Group's Department Infor-mtion Systers Plan (DISP) . The DISP will provide a benchrark definition of the IMclear Group's ranagement and end-user inforration resource needs and directs the lcrq tem develeprent of inferration processing. An appropriate end-user involvement provides for an identification of productivity irpro-vements and an incorporation of nea technologies and applicatiens into their e p tiens. An approval of the p%n relates ranagement direction ard erpMsis to MIS develept. The develepw nt of IMelear Group's DISP r:ust include an initiation of a continuirg plannirg process that is flexible encogh to respond to nea regulatiens, changirg organizational directions, and nea technology as raintained by the IMclear Grcep's Inforration Pw.e Managerent organiza- ' tien. Specifically the DISP nust: o Identify specific needs ard applicatiens that my benefit frem nea or irproved inferration processirg tools, o Identify interface ard support requirements between Inferration Systems and a continuirg planning process raintaired by Infer-ration Resource Mamgement, o Define pricrities within an irplementation plan en the basis of benefits to be achieved and resources available, o Define the 1 erg rarge environment for inferration processLg and end-user a m am. o Develep architecture and stardards in a technology plan. o Develop migration plans to integrate existirg systers with systers preposed in the DISP. o Estirate the tire ard resources necessary to irplement the systers ard applications identified in the DISP. Why is it to be m lished? Inferration rescurce ranagement applications ard policies within the FECo ' IMclear available. Group need to be upgraded to the nea applications and technolcgies There is a need for inferration preaming inproverents ard a revement to integrated inferration ranagement systers. The advantages in irplementation of integrated systems include: , i o Accurate, faster, and rcre flexible reportirq. o control over develegnent ard irplementation prmas=s. ) o Irpreved data administration, integrity, ard security, o Irproved data processirg and inferration cccunication, o Irproved focus of raragement en critical issues and problems, o Irproved support of decisien rakirs process. . 1 l

t How is it to be acxxmplished? Ee DISP will be developed thrcugh use of an IBM Applicatiens Transfer Study and its extension to satisfy all the particular needs of the FEco Nuclear Group. We DISP is developed in three phases: Ac7mt Ihase, Cpportunity ard Strategy Phase, and Detail Definition Ihase. Each of these phases will have an identifiable prtduct to be reviewed by the Executive Sponsor and the Steering Ccmittee formed for this study. 2e review ard approval of each phase gives mnagement an opportunity for additional input to the developt of the DISP. Mwent Ihase mis phase provides for an assessrent of the current business aspects of the Nuclear Group. W e assessnent includes a definition of the organiza-tiemi, functiom1, and rayulatory requiremnts, other nuclear utility inferration systers will be reviewed and evaluated. We phase includes identifying initial end-user requirements. Current sys*ars will be ass-essed for their level of technology ard for their inferration processirg costs. An inventory and- profile of the existirq~ applications will be prepared. Prior work performed, en identifying end-user requirements ard esMesing current systers, will supplement this activity. Se deliverable at the ccepletion of this phase is a document which establishes a basis for developing the DISP. Se document will identify key end-user needs, a profile of existire inforration systers and appli-caticns, ard an evaluation of inferratien system solutions develooed by cther utilities. 4 l Optortunity and Strategy Ihase  ; j This phase will define tv.e everall approach for develepnent of applica-tiens ard sysa s, and the general strategies for hard.are orientatien, soft %are acquisitien, user cIvanization changes, ard inferration deliv- I

)

e.ry sys+ars. 2e eWad investment of resources will be estirated for i the phased develept of applications ard systers. Scre of the informtion systems cpportunities which my irprove Nuclear Group informtion processirq include: o Cata raragerent techniques o Distributed pr-:ing l o Electrcnic rail /perscnal services d o Panagerent support sys*ars o Office autcration

                                                                                            .       I i

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i l me potential projects or ranagement systems that ray be described in this part of the DISP inclufe: o Action ard ccmitment trackirxJ * ' I!udget, cost, ard scheduling o o Configuration mnageant ard ce f.rol ' o Dccu-ent ad:ninistration and concol o Engineering design change control  ; o Human resource management o Maintenance ard cutage planning o Performance renitoring ard reporting ' o Plant pr - control systens o Records and resource data management l o Regulatory and quality assurance administration The deliverable at the ccepletien of this phase will detail planning assugtions, end-user requirements, define organizational i@act for both end-user ard developer, present a generalized technical architecture, and identify possible policy irplicatiers, Detail Definition Ihase mis phase defines the requirements for the new applicatiers. ' Re evalu- 1 ation of architecture, tenefits, costs, ard priorities will verify appli-cation selectiers. Technolcgy stardards will be established kttich ersure t system application plars for cert =unications, security, and data ranage- , ment are integrated with system software. Migration plans will be devel- ' oped to incorporate proposed applicatiers ard techno1cgles as part of the overall iglementation plan. . An organizational plan will be develcped stich supports the irp2erenta-tien plan, ne irplementation plan will include full participatien of end-users both centrally and at the plants, Inforratien Resource anage-ment, and Inferration Systers. De deliverable at empletion of this phase is a Nuclear Group's Depart-rent Information Systers Plan as defined by the Sha_L cf this Develegnent Strategy. Who is goirg to execute the prm? 2e MIS Task Force, to execute this strategic inferration planning initir.tive, i include an Executive Sponsor, a Steerirrj Cc=tittee, ard a Study Team The Executive Sporser ard Steerirg Ccmittee will renitor the study by their pr-ticipation in review meetirgs called durirq the performance of the stuty. Involverent of the Study Team is essentially a full tire activity for five PEco pecple includirg representatives from Inferration Resource Management, IGS, NED, PBAPS, ard Inferration Systers; an IEf4 Applications Trarsfer Study director, ard an cutside censultant. . 3

        -   .._...m..   ...          , ;.             .                    .,

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  .          ,2e personnel assignment r+> - #adation for this MIS Task Force is as follows:                                   '

i , Initiating Executive Sponsor: C.A. McNeill together with Executive Staff  ! Steering Cct:rnittee:

o D.R. Helwig - Sustaining sponsor & Ccrrnittee Chairman o P.M. Davidson, G.N. Dodkin, R.J. I.ees, D.R. Meyers, J.T. Smogeresky, and E.F. Sproat, III.

Study Team: o I.GS Supervising Engineer - Team Chairman o R.J. Feik, D.C. Hoefner, a PBAPS Engineer, and a NED Engineer. . o Im Applications Transfer Study Director ' o J.B. R-Mie, MAC Censultant l I Iten will the prmau he executed? i An authorization to preceed with devele;rnent of the DISP and assignment of i personnel to the Study Team is scheduled to s* art on August 1,1988 khile the IIH Applicatien Transfer Study is scheduled to start on Sep*xber 5, 1988. Re initial task planning schedule sequence for developrent of the DISP is as follcws: WEEK ACTIVITY DESCRIPTICN 1 2 ,;} f 5 .5 23 2 h 11 12 i ASSESSN EHASE Definition & Assessment X X X X

Steering Comittee Review / Approve X OFFORIUNITY AND STPATIEl FHASE Cpportunities & Strategy Develeprnent X X X X (

i Steering Cct:nittee Review / Approve X ' DEIAIL DE!'IITITICH IHASE f Detail Plan Derinition X X X X Steering Comittee Review /Approvo X i i l Nhat is the cost to devalcp this plan? < 1 4 ] me order-of-Magnitude estirate of costs and perr,onnel resources for the MIS l

Task Force involved in the above Strategic Planning Precess as based on the l l abcNe schedule and the labor ard expenses of the total MIS Ta.sk Force is less i than $200,000.

What is the funding re --- rdation to implement the plan? l l The order-of-Magnitude funiing reccrrendation for the final MIS develeprent { and implementation is $4,000,000 per year for the duratien of the plan. mis l i r m ...endation is based on: o other Utility MIS Expenditures j o Consultant /I m Verification  ! l l 4 e , , - . - -. , , _ , - - .-r a . .,,-,y, , ,c-,- ,

i i DIANE L. CARTER PROFESSIONAL QUALIFICATIONS Dr. Carter has over 17 years of management experience in Fortune 500 companies, in both technical and human resource management positions. She is particularly , experienced in anticipating and managing the Human Resources issues in acquisitions, i mergers, reductions-in-force and plant closings. She has developed reward and incentive l systems for technical, sales and production personnel and implemented succession and career planning programs in a number of organizations. EXPERIENCE 1986 - Present MANAGEMENT ANALYSIS COMPANY Managing Consultant, Human Resource Management Services - Designs, develops and celivers services to assist clients in maximizing their human resources. Programs include Succession Planning, Career Development, Downsizing and Incentive Plans. Northern States Power Company - As part of a multi-disciplinary consulting team, performec a broad organizational study including analysis and evaluation of existing structure, processes, culture and resources. Assisted internal task force and steering committee in developing reorganization options; worked with CEO and officers in choosing and implementing new organization. Philadelohia Electric Comoany - Performed an evaluation of i organization, staffing and motivation of employees in the transition phase from construction to start up of the Limerick Unit 2 nuclear power plant. l Consultant, Indiana Gas Company - Designed and developed a ! Succession Planning Program; coached managers in team process l and feedback; developed retraining and outplacement options. 1984 - 1986 SMITHKLINE BIO-SCIENCE LABORATORIES Director, Personnel - Managed integration of the field sales forces anc heacquarters marketing organizations of two clinical laboratory companies following an acquisition. Developed incentive compensation plans, recognition programs and succession planning for the new organization. Instituted pro-active employee relations programs to forestall possible labor action and j employment litigation. . I 1

Resume - Diane L. Carter Page Two 1979 - 1984 SMITHKLINE CONSUMER PRODUCTS Director, Human Resources - Reporting to the company president, established and staffed a Human Resources Department to perform the full range of personnel functions. Guided the company through two plant closings, the divestiture of two businesses and several red :t!nne-in-force, involving both domestic and overseas operations. Managed a major employee attitude survey project over a th ee year period. Established a management succession and development planning process throughout the company. Developed and implemente f career path planning, including dual career ladders. 1976 - 1979 SMITHKLINE BECKMAN CORPORATION Manager, Personnel Relations / Manager, Equal Occortunity Programs - Managed the human resources internal coraulting service. Supervised 12 employees, providing services in performance appraisal, job posting, career development, conflict resolution, grievance handling, succession planning, training and organization development. Established an affirmative action plan and dealt with government agencies responsible for compliance reviews and employee complaints. 1972 - 1976 SMITHKLINE & FRENCH LABORATORIES Staff Veterinarian - Managed a staff of technicians and tecnnologists responsible for clinical care of research animais. I 1970 - 1972 MERCK, SHARP & DOHME . Research Veterinarian - Managed a three-shift operation responstble for cancer research in germ-free laboratory animals. \ 1969 - 1970 PRIVATE VETERINARY PRACTITIONER Managed large and small animal practices. EDUCATION D.V.M. - University of Queensland Extensive coursework in Human Resources and Organization Development, including NTL Institute for Applied Behavioral Science, University of Pennsylvania, Executive Enterprises 1 PUBLICATIONS Connelly, S.D., D. Phelen Carter and J. Bailey (1980). Welcome to the Titanic: , Preparing smploy:=s for a plant closing. Proceedings, 0 ganization Development l Network October,1980. . d l

r Resume - Diane L. Carter Page Three ! Golemblewski, R.T., R. Munzenrider, and D. Carter (1981). Progressive phases of burn-out and their implications for O.D. Proceeg, Organization Development Network, September,1981. Golemblewski, R.T., R. Munzenrider, and D. Carter (1981). Phases of progressive burn-out and their work site co-variants. Journal of Applied Behavioral Science, 19 % 4-481. Carter, D.L. (1985). The RIF Dilemma: Layoff Criteria in Non-Union Organizations. Proceedings, Organization Development Network, October,1985. PROFESSIONAL AFFILIATIONS Organization Development Network - Board of Trustees Human Resource Planning Society Association for Psychological Type American Veterinary Medical Association l I i l 4 .

GE0987 l

M

e ROBERT P. CROSBY PROFESSIONAL QUALIFICATIONS Mr. Crosby has 33 years of experience in the application of behavioral and social sciences to organizations and communities. Since 1930, he has consulted with or monitored consultants and staffs of about 400 organi:stions. He has varied skills in productivity and quality as related to people involvement, conflict management, performance appraisal, team building, measurement organization or group diagnoses, and community and agency interface. Mr. Crosby designed and developed a diagnostic and organization effectiveness system which has been used successfully by clients in the energy, telecommunications, aerospace and chemical industries, as well as by state and local government agencies. EXPERIENCE 1986 - Present MANAGEMENT ANALYSIS COMPANY Sacramento Municioal Utility District - Organization Effectiveness Manager of team provicing Organt:ation Development consulting services and assistance at Rancho Seco Nuclear Plant. Work involves directing ar.d helping to implement the Productivity / Quality Improvement Program, an action research method of identifying and , influer.cing human factors to improve and sustain productivity and quality. The program encompasses all levels of personne!, from the CEO to hourly werkers. He also developed a method for effective sitewide clarity about charters and accountabilities including resolution of engineering cuplications and ambiguities. As manager of the project, additional responsibilities inc!ude logistics and schedule planning, problem identification and resolution, and administrative activities. Consultant - Adapted his .Peoole Performance Profile (PPP) for MAC's use in its work with clients. Also acaptec fer the Leaders Guide to the PPP and the Torkteam Guide which guides groups in its use. Adaptation emphasizes procuctivity, quality, safety, and morale. 1979 - 1986 CONCERN FOR CORPORATE FITNESS President - Founded this firm which developed and marketed the People Performance Profile for organizational improvement. Had direct or consulting experience with over 400 firms, including the following: Naval Surface Weapons Center Rockwell City of Calgary Cabot (Engineering Disision) M.C.!. A.S.T.D. National Headquarters Detroit Edison Carnation Babcock & Wilcox Alberta Government Telephone Westinghouse Northern Telecom - R.E.I. Imperial Chemical Industries, United Nuclear Scotland Georgia Power Union Oil

   .e  _ _. ._    . ..

Resume - Robert P. Crosby Page Two 1963 - 1986 INDEPENDENT CONSULTANT . Designed and implemented varied projects: HUD Community Development, juvenile court facilities planning, staff training for a State Department, training for educators and youth workers and productivity / quality programs within government, public/ private, and project /non-project organizations. Lead numerous training programs. Prepare participants to deal with communication, third party conflict management, survey feedback, and problem-solving with employee involvement groups. Guide both white and blue collar groups in meast.rement development and team-building. Designed and implemented a variety of tools for working with groups. In addition to the People Performance Profile, developed a tool for measuring readiness to do Third Party Conflict work and a Problem-Solvine Guide (both published by University Associates), and numerous unpuolitnec pieces. Guided action-research projects with groups of several hundred people during the last 25 years including collaborating with Temple University, the Institute for Social Research at the University of Michigan, and the University of Oregon. Served as design consultant for NASA's Second National Symposium on Productivity Improvement and Quality Enhancement. 1969 - 1981 LEADERSHIP INSTITUTE OF SPCKANE/ SEATTLE President - Founded this institute which trained students in the behavtorial sciences. In 1973, founded the first Master's degree in Applied Behavioral Sciences ever offered. LIOS and Whitworth College collaborated on this program which is flourishing out of City University in Seattle, Washington, and which has influencee' other Masters programs. I 1966 - 1970 NATIONAL TRAINING LABORATORY ASSOCIATES 1 Consultant - Conducted training classes and seminars for a sariety of clients. 1968 - 1970 GONZAGA UNIVERSITY Faculty - Taught graduate courses and designed campus-wide developmental projects. Conducted team-building with the President, Vice President and faculty.

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 . Resume '- Rober t P. Crosby                                                  Page Three s        .

EDUCATION l M.A. -_ Doston University M.Th - Un;ted Theological Seminary B.S. - Otterbein College PROFESSIONAL AFFILIATION Certified Consultants Inter national RECENT PUBLICATIONS Managing Lt.rge Group Meetings - Social Change,1981 The Emerging Global Village - O.D. Practitioner,1980 E.nployee Involvement: Why it Fails, What it Takes to Succeed - Personnel Administrator,1986 Employee involvement tnat Lasts - Emoloyee involvement Reoort,1985 Make Excellence Happen - Emoloyee involvement Report,1986 d GE1287

          '~

Roger S. Karsk and Associates. Inc.  :

                 ! 2000 Century Pinza Sulle 308                                                                                  Telephone I   Columbin. Maryland 21n44                                                                 (301) 73o.8o30 Z

December 1986 EDUCATION ) Ph. D. Organizational and Coninunity Develoen:ent - Union Graduate School (Union for Experimenting Colleges ano Universities),1975 M.S. Communi+y Development - Southern Illinois University, 1966. A degree program witn empnasis on corrmunity process, planning and implementation. B.A. Design - Southern Illinois University, 1964. An interdisciplinary oegree with emphasis on problem solving. process. PROFESSIONAL EXPERIENCE 1976 - Present President, Roger S. Karsk & Associates, Inc., a firm specializing in Executive Development Programs, Managerial and Strategic Team Building Sessions. See attached for brief sunrnary of clientele. On-Going Affiliations: 1974 - Present_ Instructor at Johns Hopkins University School of Continuing Studies, plan and teac.h a variety of courses in Applied Behavioral Science Program including Organizational Develo p.ent, Group Ficilitation, Utilizing Power, Cecision Making and directed field work. 1986 - Present The Executive Committee (TEC). TEC is a 30 year old company locateo in San Diego tnat works exclusively with CE0's. I am a TEC Chairman for twc groups of CE0's in the Baltimore area. 1983 - Present_ Westinghouse Institute for Resource Development, lead consultant on organizational contract to Naval Surface Weapon Center. Responsible for organizational development component to largest technical department at NSWC, Facilitate staff meetings, lead Strategic Team Building Retreats, set up diagnostic systems and . assist in reorganization efforts. l PREVIOUS WORK EXPERIENCE l C 1979 _1986 Lead Instructor for the University of Maryland Creative

                         ,eaoership Development Program. An upper level executive assessment                                    i program that ran one week per month. Lead Training Instructor teaching                                 '

Situational leadership, Innovative Group Decision Making, Feedback and Personal Assessment. The Creative Leadership Development Program was an extension of the Center of Creative Leadership located in Greensboro, North Carolina, o ()R( ANIZATM)N Al (:ll AN(:M A l)l'Vl;l.(1PMl:NT

  • TH AININf e (:f)N4t tlTNr:()N e }:yAI.t Nil (IN A REgMARGil e g.d O'

_ . . . . . . 1._-.. . _ . - - - VITA December 1986 PREVIOUS WORK EXPERIENCE June 1972 - March 1976_ President and Chief Administrator, CORAL II (Cornmunity Research and Action Laboratory), a non-profit con:nunity research and education corporation in Columbia, Maryland. Developed organization from an idea to a $100,000 per year budget. April 1973 - March 1975 Project Director, NIMH Research Project (through CORAL,11) entitled, "Teenage Youth in a New Town Setting", a two year study of teens in the new town of Columbia, Maryland. November 1971 - June 1972 Center for the Development of Human Resources (affiliateo with tne Johns Hopkins Un.iversity, Department of Psychiatry and Behavioral Science). Project Director for Youth Awareness Evaluation, an LEAA-NIMH project to evaluate the impact of an "innovative" youth progrm. September 1966 - October 197_1 West Virginia University, Area Extension Specialist, Resource Development. Working in the southern nine counties (s! W9st Virginia through the University Extension Service. Served in cone .itant role working with planning comission, school system, comunity coalitions and other conrnunity organizations. July 1964 - August 1955 Southern Illinois Universityi Field Counselor onManpowerDemonstrationProjectinsouthernIllinois(MOTAProject). Sumn:er 1964 Special Community Developtrent Project in eastern Kentucky. BOOKS Karsk, Roger S. and Thomas, William; Working With Men's Groues, Columbia Maryland: New Community Press, 10 9 Xarsk, Roger 5.; Teenagers in the_ Next America, Columbia 'aryland: M Ne.w Comunity Press, lE ARTICLES _ AND REPORTS - Marsk, Roger S, and Klein Donaldt "Tecnagers in Columbio", e chapter in Phychology_._of the Planned Community by Donald Kleir. New York: j Human Science Press, 1978 1 Xarsk, Roger and Sharon, and Franklin, Richard; "Comniunity Change Competencies", Title I Report, Johns Hopkins Evening College, April 1974 . Xarsk, Roger and Franklin, Richard and Paula; "The Impact Team: An  ! Evolving Model for Community Change", Comunity_0roanization Technioues,, s { Bureau of Comunity Environmental Management, Department of Healtn, Education and Welfare,1972. E*d 9?:TT M. GT mf

s VITA December 1986 ARTICLES AND REPORTS Coordinator of Secuences and Consecuences: A Report of a Series of Interventions witn Wyoming CAP Organization. West Virginia University, 1971. Xentucky Summer Project: A report of a special project in Hazard, Kentucky curing the summer of 1964. Vice President's Office Southern ' - Illinois University, 1964. 9 PROFESSIONAL MEMBERSHIPS American Management Association Organizational Develou. cent Network Community Develoceent Soci_ety American Society for Performance Imorovement American Society for Training & Develocment PREVIOUS COMMUNITY MEMBERSHIP Consultant and Board Member with Family Life Cvnter, a community and educational organization of professionals who consult with families  : or individuals. President of the Board, New Community Press, a publishing company specializing in Community and Applied Behavioral Science books. Board Member of Grassroots, Inc. a crisis hot line in Howard County, Maryland. Original Incorporator of CORAL II (Community Research and Action Laboratory) and President of Board. TRAVEL England, Belgium, Switzerland, France, Italy, Ghana, Liberia, Spain, Jamaica, St. Vincent, St. Lucia, St. Kitts, St. Thomas, Balama Islands and other areas in the Caribbean. e r*y 2T:T! ti. fitMf

SELECTED CONSULTATIONS Government Accounting Office (GA01 Won competitive RFP to design program and materials, fielo test, and implement Managerial Assessment Program for GS 13 program onand 14 and then to train ten GA0 staff members to run the an on-ga basis. 1985. USF&G Conducted ser aing workshops on Situational Leadership-and Motivation f, i managers. _ Summer 1985. _ Alcoa Jamaica Setting t organizational development and training program with emphasis improvement. on manpower planning, assessrrent, and productivity Initial involvement was working with structural change involving 200 of the 1,000 employees. Primary clients were the 20 top managers. 1979 to 1984. Maryland Deoartment of Economic and Comunity Deve1coment A six month Organizational Development Program to assist in improving the effectiveness in this department of 400, including recommendetforis and setting up management training programs. 1982.- Sh_ai_vitz Furniture of Baltimore Assisted president and key staff members of this family owned cus1 ness to look at the future through a series of team building sessions. 1980. Jamaican Ministry of Ecucation Coordinating a two-year Organizational Development program for top 50 people in this ministry nf 20,000. Emphasis has been on data based intervention, team building, and problem solving. 1979 to 1981. Jobs Training Program of_Philadelchia Part of a consulting team preparing an evaluation system for this job-training agency of tne city of Philadelphia. One of the largest prime sponsors in the country. Primary role was working with the organizational aspects of implementation. 1978. USAID Consultation in Ghana, West Africa with Agricultural Develocment Bank of Ghana Ocycloped organizational plan as part of A10 loan recommencafi6n ~ Involved six weeks of data collection and collabor-ation with bank's staffi 1975i West Virginia University. Cha_rleston Medical School Worked with state-wide neaitn ecucation coirenittee on coing neecs assessment, interagency collaboration, priority setting and initial program planning. 1978. TENCO Community Development Corocration; Shelbyville, Tennessee Coordinated Organizational Development Program witn the staff ano Board of Directors of this business corporation operating in a ten county area of Tennussee. Osed data based intervention to build training program. 1977, f

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l SELECTED CONSULTATIONS Iowa Lakes Community College, Easterv111a, kowa Part of a team assisting three colleges to integrate into one institution. Focused  : on the organizational and restructuring issues brought about by this legislative mandate. State of Maryland Coastal Zone Management Program _ Part-of a team that conducted nccd3 033e3.uent of staff and Doord for haprVVIHg the public

-                         participation portion of programi    Contract through Chesapeake Research Consortium.

C&P Telephone Company Conducted Assertiveness Training and Role Playing worksnaps for tne Maryland and Virginia companies. = National Committee Against Discrimination in Housing ,(NCDH) of Washinoton. 0.0. Ircining consultant to nationwide, forty elly survey to oetermine amount of diceriminatica in housing. Set up training prngram for 61:I) interviewers, field tested and trained 40 super-visors in precess. January through May,1977 Richmond, Virr'nia Part of a consulting team that trained all the supervisoFy staff (500) in basic supervision and conmunication _ skills. This included all servic.as of the city from the police and firemen to the water department and the library services, presbyterian Church of the U.S. National Office. Served as consultant for a four day workshop on consulting sxills to the subdivisicn of church personnel service. , l Ohio University School of Nursing, Designed and conducted weekend ' programs for nurses in tne areas of power and team buildina. Johns Hookins University Evenino Colleae. Developed and cenducted evaluation of a new prograin entiiled Fellows in Organizational l and Ceranunity Systems. _Lehich Valley Community Deveicomeni, 8edilencm, Pennsylvania. l C0fp0 fat 10n in conjunction With NllCEU. Conducted Needs Assessment with Board and staff and developed training program as a result, l 33 er rt ss. et mr - .

I e c. 1 ._, e *. s ._ SELECTED CONSULTATIONS THROUGH ROGER S. KARSK & ASSOCIATES, INC.

         .J<P    .

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                          . Government Accounting Office _(_GAO)          Won competitive R.7 to design program

! and materials, field test,~ and implement Managerial Assessment Program for GS 13 and 14 and then to train te:: 0A0 staff members to run the program on an on-going. basis. 1985. USF&G Conducted series of training workshops on Situational Leadership and - Motivation for mid-level managers. Sumer 1985 Alcoa Jamaica Setting up organizational development and training program witn empnasis on manpower planning, assessment, and productivity improvement. Initial involvement was working with structural changa involving 200 employees. .Prinary clients were the 20 top managers. 1979 to 1984 Maryland Department of Economic and Community Develooment A six month Organizational Development Program to assist in improving the effective-ness in this department of 400, including reccmit.endations and setting up management training programs. 1982 Jamaican Ministry of Educ_ation Coordinated a two-year Organizational Ovvelopment Program for to) 60 people in this ministry of 20,000 people. Emphasis on data sased intervention, team building and problem solving. 1979 - 1981 Shaivitz Furniture of Baltimore Assisted president and key staff members of this family owned cusiness look at the future through a series of team building sessions. 1980 l l e d 8

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f He #/ RD E. LAMB PROFESSIONAL QUALIFICATIONS Dr. Lamb has more than 25 years of experience in program and product management in the field of organization development and training. He has worked extensively as a consultant to large institutions seeking major change and problem-solving assistance in such areas as organizational diagnosis, creation of alternative change strategies, task force implementation and facilitation, transition management, decision making and communication processes. During the past few years, Dr. Lamb has participated in four significant nuclear diagnostic root cause assessments and the development of major recovery / restart action plans. EXPERIENCE 1982 - Present MANAGEMENT ANALYSIS COMPANY Philadelphia Electric Comoany - Member of root cause assessment team at the Peach Bottom Atomic Power Station. Analyzed managerial and leadership practices and philosophies, operator behavioral and attitudinal factors, station and corporate cultural and subcultural characteristics along with management systems, personnel practices / policies, internal and external relationships. Provided input from these areas into the MAC Root Cause Assessment Report. Provided direct staff support to the PECo project manager of the recovery task force. In that capacity helped

t. design the task force processes, developed relevent Action Plan tasks from the MAC report, supported Action Plan development and facilitated the implementation of selected Action Plan tasks. Served as consultant to the president on significant organizational change issues, functional assessments and axecutive style. Worked closely with other executive managcrs on similar issues. Extensively involved as a consultant during major reorganization of the nuclear power production and support function.

Utah Power & Lieht - Provided company officers with management systems analyses, manager evaluations and developmental recommendations together with preliminary plant manager transition strategies at their major fossil plant. Sacramento Municioal Utility District - Consultant and Executive Staf f to Deputy General Manager - Nuclear. Provided consultation in Board / District relations, District / Nuclear relations, Nuclear organization reorganization, managerial assessments and special projects. Responsible for management analyses and subsequent recommendations in SMUD Restart Plari submitted to NRC. Responsible for establishing office of Deputy General Manager-Nuclear on site including determination of staff support, monitoring all communications and correspondence and establishing an office support routine. Provided direct support to Deputy General Manager-Nuclear for presentations to the Board, District management, regulatory and industry meetings.

Resume - Howard E. Lamb Page Two Tennessee Valley Authority - Consultant and Senior Staff to Site Director, Browns Ferry Nuclear Plant. Provided organizational, functional and personnel analyses, stic.egies for site change efforts, corporate / site relations, human resource issues and special projects. Designed and implemented a successful site-wide functional analysis and reorganization process. Designed and conducted an organizational analysis survey for the entire TVA Nuclear organization with results reported to the General Manager. Public Service Electric and Gas Company - Analyzed Nuclear Department organizational structure and management processes to identify ways of improving managerial controls and interdepartmental cooperation. Worked with Department's senior and middle managers to implement tne resulting recommendations. Planned and conducted an ongoing series of team-building sessions for 40 key manager:;. Analyzed corporate / Nuclear Department matrix organizations and worked with all relevant managers to improve the effectiveness of these relationships. Kansas Gas and Electric Company - Provided ongoing organization development consultation and team-building assistance to the Group Vice President for Technical Services. Helped plan a reorganization of the Nuclear Department, consulted with individual department managers and conducted team-building sessions for plant managers and their direct reports. Worked with the Director of Fossil Operations and his direct reports to improve Department planning and communications. Analyzed interface problems between Operations and Engineering, and conducted problem-solving sessions to improve productivity and responsiveness to other departments. Ducuesne Power & Light Comoany - Conducted a management diagnostic to assess the ef fectiveness of project management, scheduling and cost controls involved in the construction completion of Beaver Valley Unit 2. Detroit Edison Company - Assessed and made recommendations for improvement in company's regulatory relations program. Analyzed administrative and programmatic operations of the Nuclear Department to ensure effective organizational performance in support of Fermi 2 start-up. Reported findings and recommendations to the Vice President-Nuclear and senior management team for internal implementation. Niagara Mohawk Power Corooration - Conducted an initial management analysis of corporate officers, senior managers and their functions as they affected the Nine Mile Unit 2 project.

R'esume - Howard E. Lamb Page Threc Public Service of New Hamoshire and Yankee Atomic Power - AnalyI:ed senior and middle management level organizational structures, communication and decision-making systems, and roles and responsibilities of the major organizations involved with the Seabrook construction project. 1976 - 1982 LAMB ASSOCIATES President - Provided consultation in organization development and training for management issues and human relations. Worked with the State of South Carolina Governor's Budget & Control Board and the Department of Human Resource Management to implement a new merit performance appraisal system for the heads of all state agencies and commissions. Consulted directly with the boards / commissions and executive directors of 15 of the state's largest agencies to establish agency objectives and performance criteria for executive staf f. Trained four state-employed consultants to work with an additional 80 agencies. Consulted over a seven year period to senior management in U.S. Department of Education. Responsible for co-development and implementation of an organiza-tional process.to coordinate 42 public and private agencies involved in

 <                    serving mutual clients.        Assisted agencies working .vith widely divergent client needs to collaborate in program deve:opment and to develop effective decision making processes. Consulted extensively with legal and law enforcement organizations in areas of planning, performance assessment, problem solving and training. Provided consulting services over a nine-year period to a metropolitan police bureau. Consultant to a large public school system in developing human relations specialists.

1968 - 1976 NTL INSTITUTE FOR APPLIED BEHAVIORAL SCIENCE Program Director - Managed nationwide projects in organizational cnange using cadre of 20 to 30 organization development consul-tants. (NTL Institute invented the discipline of organization development.) Participated in the development of practical applications of organization development technology. 1962 - 1968 UNIVERSITY OF DELAWARE Professor - Responsible for designing and managing multi-disciplinary curriculum in group dynamics and organizational behavior at both the undergraduate and graduate level. EDUCATION Ed.D., Human Development and Educational Administration - University of Maryland

  • Post Doctoral Work, NTL Institute for Applied Behavioral Science, Intern Program
 . . . . -   w. .                    -                       -      . _.              --.

l l R'esume - Howard E. Lamb Page Four PROFESSIONAL AFFILIATIONS American Psychological Association American Education Research Association Association for Psychological Type Association for Transpersonal Psychology

                    . Center for Designed Change NTL Institute for Applied Behavioral Science 1

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SUSAN RIES LAMB PROFESSIONAL QUALIFICATION 3 Ms. Lamb has over 15 years of experience in program management, organization develop-ment and executive /line management consultation and training. She has specialized in-organization diagnosis and problem solving; functional analysis and team building for managing organization transitions; the design and implementation of effective performance management systems; and interpersonal communications and conflict management. Ms. Lamb researched and wrote a comprehensive manual on Human Resources Management for nuclear power industry executives, line managers and personnel services staff. EXPERIENCE 1982 - Present MANAGEMENT ANALYSIS COMPANY Philadelphia Electric Company - Consulted with the President / COO and the Project Manager on the development of a comprehensive recovery program following the NRC Shutdown Order of Peach Bottom Atomic Powar Station. Designed and facilitated a senior management retreat invoiving 44 company officers and department managers. Worked with an interdisciplinary team to perform a probler - root cause assessment of events leading to the Shutdown Order and served as a major author of the diagnostic report. Southern California Edison - Project Team Leader. Consulted with Vice l ., President, Customer Service Department, five Division Vice Presidents I and a group of District Managers in assessing the effectiveness of I organizational structures, resource allocations and work systems. Made l recommendations for department staff reorganization, work interfaces among department, division and district organizatic.m distribution operations and engineering; customer services; energy manag'ement services; distribution accounting; and communications with customers about rates and tariffs. Assisted in the design and facilitation of two of f-site planning retreats for the Vice Pres. dent and his direct reports. Public Service Electric and Gas Compay - Analyzed Nuclear Department organizational structure and rrinagement processes to identify ways of 1 improving managerial conNis and interdepartmental cooperation. Worked with Department's ser. or and middle managers to implement the resulting recommendations. Plaaned and conducted an ongoing series of team-building sessions for 40 key managers. Analyzed corporate / Nuclear Department matrix organizatK>ns and worked with all relevant managers to imr, rove the effectiveness of these relationships. Kansas Gas and Electric Company - Provided ongoing organization development consultation and team-building assistance to the Group Vice President for Technical Services. Helped plan a reorganization of the Nuclear Department, consulted with individual department managers and conducted team building sessions for plant managers and their direct reports. Worked with the Director of Fossil Operations and his direct, reports to improve Department planning and communications.

Resume - Susan Rits Lamb Page Two Hawaiian Electric Company (HECO) - Worked with CEO of Hawaiian Electric Industries and the President of HECO to identify and address corporate :t.ategic planning and utility system planning needs. Assessed the effectivenm of organizational structures, management processes, work breakos vn and staffing levels within the Power. Production, Transmission ad Distribution and Engineering Departments to improve efficiency and cest effectiveness of operations. Detroit Edison Company - Assessed and made recommendations for improvement in company's regulatory relations program. Analyzed administrative and programmatic operations of the Nuc!c .r, Department for effectiveness at Fermi 2. Reported findings and recommendations to the Vice President-Nuclear and senior management team for internal implementation. Southern California Edison Company - Analyzed management systems, interdepartmental communications and effectiveness of personnel and training functions at San Onofre Nuclear Generating Stat ion. 1976 - 1982 CREATIVE CHANGE ASSOCIATES,INC. Senior Partner - Consulted monthly over two-year period with. senior and mid-level manar?rs of U.S. Department of Education. Facilitated top-level problem-se.aving task forces; analyzed communications and power structures within large departments; designed and conducted team-

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building retreats; resolved intra- and interdepartmental conflicts; and assisted in design and implementation of work flow analysis projects. Worked with the South Carolina Governor's Budget & Control Board and j the Department of Human Resource Management to implement a new i merit performance appraisal system for the heads of all state agencies l and commissions. Helped to establish agency objectives and performance criteria for executive staffs. Co-designed and executed a county-wide interagency planning effort l invo!ving 42 public and private service agencies. Conducted needs assessment studies; resolved interagency "turf" concerns; developed an innovative organization planning and program development structure; and managed large group decision-making and prcblem-solving meetings. Analyzed professional, technical and support position functions and designed corporate performance appraisal system for headquarters and five regional offices of Federal Home Lt.an Mortgage Corporation. Developed and conducted training sessions in employee performance managemer t for all corporate executives, iine managers and supervisory personnel. Co-managed one-year organization development project for a large, nonprofit organization involving strategic planning; evaluation and improvement of internal communications; development of effective decision making and meeting management procedures; and clari.ficatio'n of Board / executive staff roles and responsibilities.

l Resume - Susan Ries Lamb Page Three Worked with managers of the City of Alexandria, Virginia to evaluate and improve recruitment / selection / promotion and employee performance management programs. Developed and conducted training sessions in selection, interviewing and performance appraisal for 150 department heads and line managers responsible for all professional, technical, clerical and labor / trade staf fs. Assessed management development needs in areas of employee grievance handling, interviewing skills, performance contracting and cr.-the-job coaching of employees for large private health care facility. Developed written materials for management / supervisory education center and designed and conducted management training series to address concerns in these areas. Provided one-on-one consultation to executive and line managers in areas of personnel utilization, conflict resolution, meeting management, conference design, grievance handling and employee termination. Conducted training sessions for 9,000 individuals, from executives to unemployed, in management and supervisory development, conflict management, selection interviewing, performance evaluation, career development, interpersonal communication skills, and organization and group dynamics. 1972 - 1976 THE AMERICAN UNIVERSITY < l Assistant Director, Career Development Center - Developed and ) conducted career planning and job search programs for university students, graduates and mid-life career changers. Programs were  ; adopted for use nationally at universities and colleges. l 1969 - 1972 ARLINGTON COUNTY, VIRGINIA j Manager. Alternative Credit Programs - Co-designed and managed three j innovative alternative high school credit programs for drop-outs and i students expelled from the regular school system. Supervised program l instructors. Developed and taught special curricula. Juvenile Court Probation Officer - Served as school-based Probation Officer with formal case load and informal "friend-of-the-court"  : functions. Counseled individual students and provided field counseling to their families. EDUCATION B.A., English/ Education - Tuf ts University M.Ed., Counseling (with distinction)- The American University Graduate work in organization development, consultation skills, laboratory education design and group dynamics, sponsored by NTL Institute, A.K. Rice Institute, The Washington School of Psychiatry and The American University

Resume - Susan Ries Lamb Page Four PROFESSIONAL AFFILIATIONS Faculty Affiliate, College of Marin and U.S.D.A Graduate School American Society for Training and Development , The Organization Development Network l Association for Psychological Type The Center for Designed Chsnge

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s 3 DEAN N. PARKER PROFESSIONAL QUALIFICATIONS Mr. Parker has over 14 years of experience as a management consultant in construction and engineering management and electrical engineering. His areas of expertise include engineering management; systems completion; data processing; management systems development; construction forecasting, tracking and control; master equipment lists; configuration control; and operations management. He has held positions ranging from electrical design engineer and senior construction engineer to project computer applications supervisor on a variety of projects including power plants, steel plants, and industrial processing facilities to project leader and manager positions on Department of Energy programs. EXPERIENCE 1985 - Present MANAGEMENT ANALYIS COMPANY Manager of Technical Services, Manages and coordinates consultants in the areas of project controls, cost estimating, rate and litigation support, project management systems, project reviews, and program management. Interact with clients on all project business management areas, provides consulting services to clients on technical service related matters. Consultant, Department of Energy's Cask System Development Program - As Project Manager, coordinated a management review of the program management systems in place at the DOE-ID, EC&G, Idaho and Sandia National Laboratories. Performed the program assessment by conducting interviews with program participants, review of program documentation and determining applicable DOE headquarters (OCRWM), DOE-Office of Storage and Transportation l Systems, NRC and DOE-Idaho operations office requirements and l standards. Assisted DOE in the definition and preparation of the program management plan. The PMP describes the methods that will be used to manage the transportation systems technology and development program for the Office of Civilian Radioactive Waste Management (OCRWM) by DOE-ID. Consultant, Department of Energy's Basalt Waste Isolation Project - Project Leader for the Project and Information Management consulting organization. Assisted DOE in the definition and preparation of the project plan and charter, the project management plan, and project directives and the implementation of baseline management (costing schedule), funds and budget management, acquisition and procurement - ngement, project resource management and information management activities. All project , management support based on DOE major systems acquisition criteria and DOE Order 4700 for project management systems and OCRWM.'s project management system manual.

w- .- .. . ....u i l l Resume - Dean N. Parker Page Two Supervised 17 consultants in the above areas; interacted with client on a!! project business management areas. Provided ' consulting services to. the program management administrator for commercial nuclear waste at DOE-Richland operations office. i 1 BECHTEL POWER /BECHTEL CONSTRUCTION, INC. 1980 - 1985 Field information Administrator and Project Computer Aoplications Supervisor, Hope Creek Nuclear Generating Station - Supervised sof tware engineers, operators, programmers, analysts, user support < coordinators, and technicians and managed user utilization of data  ! processing, engineering, cost, scheduling, material control, and report l applications. Responsible for user support on application development and change, client interface, budget control, user training and documentation. Supervised operation of the IBM System  ; 38, Model 20 computer, data communications and system interfaces 1 with microcomputers, UNIVAC, and IBM mainframe machines. ) Senior Construction Engineer and Electrical Engineering Technical , Supoort Specialist - Coordinated ) of Bechtel's relational data basetheMLCS develop (ment Material and implementation Labor Control i System) Electrical Subsystem at Hope' Creek Unit 1, Grand Gulf Units 1 & 2, Midland Units 1 & 2, and South Texas Units 1 & 2.

   .e Project Field Engineer, Seminole Electric Coal-Fired Generation                 I Station - Coordinated field engineering design activities, contract             i monitoring, cost and scheduling, procurement, construction                      ,

inspection, and start-up and completion; resolved engineerin6 design  ; problems with the client's engineer. l Construction Start-up Completion Coordinator, Massachusetts Municipal Wholesale Electric Cooperative - Responsible for the final completion and resolution of restraints to allow the orderly turnover i of systems to the client. Supervised final turnover document I preparation and conducted schedule meetings to status and stimulate the completion of electrical, instrument and control, and mechanical systems. Lead Electrical Contracts Superviscr, Massachusetts Municipal Wholesale Electric Cooperative - Responsible for administration of  ; the electrical contract and the coordination and resolution of i engineering problems. Also responsible for design and construction of l plant lighting and telephone facilities. Prepared estimates and negotiated contract charges with the various contractors. Planned and coordinated labor activities. 1970 - 1980 ARTHUR PARKER ASSOCIATES CONSULTING ENGINEERS Project Engineer and Mana2er of Microcomputer Development - Responsible for electrical design and construction management of industrial facilities, steel plants, utilities (electric, water, gas and environmental), and pharmaceutical projects.

f

 ,  Resume - Dean N. Parker                                                           Page Three Founded and directed a microcomputer software support organization for the development of contract management sof tware. Directed program preparation, testing, and implementation; coordinated client needs with software changes.

Electrical Design Engineer - Worked on environmental projects, such as pump lif t stations and sewage treatment plans; reviewed vendor documents and prepared specifications. 1971 - 1973 UNITED STATES AIR FORCE Technical Soecialist -Installed and repaired Ground Control Approach (GCA) radar units in Germany. 1968 - 1970 B. A. JEFFERIES,-INC. Electrical Estimator and Material Buycr - Responsible for reviewing drawings and field engineering problems and estimating material and labor costs for submission of bids. EDUCATION Electrical Engineering - Spring Garden College Certifieste, Electrical / Electronic Technical Training - Community Coliege of the U.S. Air Force Certificate, British History /English Literature - University of Durham, England PROFESSIONAL AFFILIATIONS Newcomen Society of North America

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- ~- BARBARA D. REDICK PROFESSIONAL QUALIFICATIONS Ms. Redick has 10 years experience in corporate account sales and marketing, training, and development. She has designed and implemented training programs, and consulted with clients to aid in meeting performance goals. EXPERIENCE 1983 - Present MANAGEMENT ANALYSIS COMPANY Consultant 1977 - 1983 OHIO BELL TELEPHONE Organizational Effectiveness Consultant, Human Resources Department - Consulted with clients to assess systems' needs, issues and problems impacting their ability to meet performance goals; implemented a participative management process (Quality of Worklife) throughout the company by providing consultation and training to management and union personnel; consulted with individuals on performance and personal effectiveness. Sales Assessment Manager, Human Resources Department - Administered sales assessment process; prepared written summary for candidate; participated in group evaluation session; made hir!ng recommendations. Account Executive II, Marketing Department - Developed and , implemented account plans for Grange Mutual and JC Penney Insurance to realize assigned revenue objectives; led marketing team to assure customer satisfaction; performed various administrative duties. Account Executive I, brketing Department - Developed and implemented account plans for many Ohio Bell customers to realize assigned revenue objective; led marketing team to assure customer satisfaction; performed various administrative duties. 1973 - 1976 OHIO STATE UNIVERSITY Assistant to the Director, Personnei Coordinator, National Center on Educational Media and Materials for the Handicapped - Prepared and monitored budget, developed proposals, wrote reports, coordinated national symposium, and supervised personnel employment. Served as liaison among professional staff, clerical sta f f, college, and University personnel. ,

Resume - Barbara D. Redick Page Two 1969 - 1973 OHIO STATE UNIVERSITY  : Graduate . Research Associate. Director of Public Relatiobs, Coorcinator of Training, Evaluation Center - Full and part time wds including editing, materials development, Phi Delta Kappa conference coordination, public relations, workshop design, and training. 1964 - 1969 - WORTHINGTON HIGH SCHOOL English teacher. Guidance Counselor. Coordinator of Student Activittes - Estantished tne position of Coordinator of 5tucent Activities and served for three years as coordinator. EDUCATION Ph.D., Guidance and Counseling - Ohio Sta.te University (1972) M.A., Guidance and Countaling - Ohio State University (1967) B.S., English, with mime in Psychology - Ohio State University (1964) English, French - Miami University (1963) PUBLICATIONS ,

         "Role Conflict and Ambiguity Among Public School Counselors in Franklin County,
c. Ohio," doctoral dissertation (1972) '

PROFESSIONAL AFFILIATIONS National Training Laboratory Institute - Staf f Member for Graduate Student Professional Development Program . I l 1 GE0188

STEPHEN H. ROESLER PROFESSIONAL QUALIFICATIONS Mr. Roesler has 11 years experience in management and organization development, adult education, and human resource management. He has designed, implemented, and managed developmental and change efforts at all organizational levels. EXPERIENCE 1987 - Present MANAGEMENT ANALYSIS COMPANY Consultant 1977 - 1987 REDICK & ROESLER Consultant, AT&T Information Systems - Managed overall change effort during divestiture. Consultations included all organizational levels through executive. Designed management sequence, facilitated team-building, and designed and conducted ongoing workshops and seminars. OD Consultant. "nzer Central Research - Completed organizational

   ,                                 diagnosis and reedback, team building, succession planning, and one-on-one executive counseling. Worked with ten divisions on design and implementation of performance management and appraisal systems.

Consultant, Saudi Arabian Airlines - Designed and implemented manpower planning and management development systems. Developed and conducted "train-the-trainer" sessions for ongoing program implementation. Conducted diagnosis and developed systems interventions for operations in Europe, Africa, and the Midd'e East. Consultant, Learning Corporation of America - Designed classroom materials for use with video-based training programs. Consultant - Worked with senior executives of Fortune 500 compames on designing start-up ventures, strategic planning, innovation, and organization diagnosis. EDUCATION B.A., M.A. - Glassboro State College Graduate studies, Managerial Behavior and Applied Beha"ioral fciences Human Interaction, Team-Building & Process Consultation, Orga nizational Diagnosis, Program for Specialists in Organization Developmem - National Training Lab - GE0183 g

WILLIAM J. THOMAS PROFESSIONAL QUALIFICATIONS Mr. Thomas has' 16 years of experience in organization deve'.opment consulting and training,11 of which is in designing and managing administrative, logistical and financial aspects of various training programs and conferences. Recently he worked with upper-level managers in both business and government, assisting in the refinement of supervisory ski!!s. He has assisted organizations of all sizes in identifying pertinent issues and problems, realistic goals and workable strategies. EXPERIENCE 1984 - Present MANAGEMENT ANALYSIS COMPAN.Y Sacramento Municioal Utility District - Member of team providing organization cevelopment consulting services and assistance at Rancho Seco Nuclear Plant. Work involves directing and helping to implement the Productivity / Quality Improvement Program, an action research method of identifying and influencing human factors to improve and sustain productivity and quality The program encompasses all levels of personnel, from the CEO to hourly workers.

                                   ,Long Island Lighting Company - Assisted in diagnostic assessment of tne orfigira+. ion management function at Shoreham Nuclear Power Station.

Niagara Mohawk Power Corocration - Provided team building and management development assistance to nuclear QA organization. Earlier, facilitated problem solving, decision-making, communica-tions, conflict management, and role clarification within A/E's area management structure and between A/E and owner-utility's project management functional groups. Focused on cost containment and enhanced productivity and morale. 1981 - Present INDEPENDENT CONSULTANT Management Training Specialist - Cenducts needs analysis, program design and organizationc! intervention. Writes training materials and articles on management topics. Conducted innovative problem solving consultations to task forces in operations and personnel at the National Security Agency (1983). Member of the external CD consultant group, General Accounting Office. Assisted in team building and transition project in the Wasnington Regional Office (1983-1984). Provided consultation to management of the Office of Safety and Security on managerial practices and communication proolems (1984).

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Management Consultant to Suoreme Court of the United States. Provided training to key managers, consultation to llorarian and staff around working relationships.

Resume - William 3. Thomas > age Two Consultant to police supervisors in refining supenisory skills. OD consultant to Naval Surface W ooons Center Personnel Department (1984). Assisted in st engthening and streamlining internal operations and improving communications with line offices. Assisted in the transfer of the EEO component to Personnel. 1975 - 1981 UNIVERSITY OF MARYLAND Project Manager Conferences and Institutes Program - Designed,

                               . marketed and presented a variety of educational programs for organizations.

Coordinated the Leadership Development Program, providing training in key management skills to over 800 mid-to-upper-level managers, including managers from five different utilities, as well as to members of the Senior Executive Service of the U.S. Department of Energy. Directed the National Health Facility Surveyor Training Program for nursing home and hospital personnel dealing with Medicare / Medicaid regulations (1976-1979). C Worked with the Executive Director and key staff to improve working relationships and communication for Tenco Developments. Worked l also with Executive Director and Chairman of .the Board to improve ' their communications (1980).  : l Taught team building and goal setting techniques to such groups as

                                 'U.S. Postal Services Customer Services Managers, key branch chiefs            I of the Indian Health Service (using Individual Assessment Profile), and       j managers of the Defense Center Group of Westinghouse Corporation (using Myers-Briggs).

1970 -1975 ST. MARY'S SEMINARY COLLEGE Assistant Professor of Humanities and Behavioral Science Director of Family Counseling Training Program l 1 REPRESENTATIVE SAMPLING OF CLIENTS I Anne Arundel County School System  ! BASF Wyandotte, Geismar, LA I Bendix Engineering Management Club CentralInte!!!gence Agency C&P Telephone Company David Taylor Naval Ships R&D Center . Delaware Department of Public Instruction Episcopal Diocese of Maryland

l Resume - William J. Thomas Page Three ) Federal Judicial Center, U.S. Courts Ford Motor Company - , Foreign Service Institute, U.S. Department of State  ; U.S. General Accounting Office i Health Care Financin Howard County (MD) g Administration, Department of Labor U.S. Department of HHS IBM Corporation Indian Health Service, U.S. Department of HHS j Maryland Association of Paroie, Probation, and Corrections Officers j Maryland Community Services Continuing Education Project i Mid-Atlantic Association for Training and Consulting,Inc. Montgomery County School System National Highway Traffic Safety Administration, U.S. Department of Transportation Naval Surface Weapons Center National Security Agency Naval Air Rewrve Unit, Andrews AFB Sheppard and Enoch Pratt Hospital, Baltimore, MD Tenco Developments, Shelbyville, TN U.S. Postal Service .  ; U.S. Supreme Court Veterans Administration Westinghouse Corporation EDUCATION B.A., Classics - Catholic University of America (Dean's List,7 semesters) M.A., Comparative Literature - University of Maryland Ph.D. Candidate, Adult Education / Human Resources Development - University of Maryland Courses in group dynamics, management and organization development, experiental education and human relations PUBLICATION Co-authored, Teambuilding: The Other Side of Engineering. Arlington, VA: NTL Institute,1985. GE0287

STOKES B. CARRIGAN, III

                                                                  .                             l l

PROFESSIONAL QUALIFICATIONS Mr. Carrigan has over 30 years of experience in human resources and organization development. He is particularly skilled in strategic planning and the design and , restructuring of organizations to enhance quality and productivity. His broad experience ' includes succession planning, career planning and development, attitude / climate surveys, conflict management, and team building. Prior to his consulting work, he served as Director of Human Resources and Organizational Development at the R&D Division of l l Smithkline and French Laboratories. Mr. Carrigan received his B.A. from Princeton. EXPERIENCc 1 1983 - Present MANAGEMENT ANALYSIS COMPANY l l Philadelohia Electric Comoany - Responsible for the design and l implementation of behaviorally-based training prograrr for licensed operators at Peach Bottom Atomic Power Station to me'et Nuclear Regulatory Commission requirements for re-start of the plant; I evaluation of organizational restructuring at Limerick and Peach , Bottom plants; diagnosis and recommendations to improve managerial effectiveness within the plants and to improve relationships with corporate headquarters, j Public Service Electric & Gas - Performed a study of the Nuclear Training Department organization focusing on management effective-ness, resulting in recommendations to improve productivity. Indiana Gas Comoany - Designed and implemented company's first succession planning program; analyzed organizational and managerial requirements relative to the consolidation of responsibility for all telecommunication functions; conducted several organization studies resulting in organization restructuring, clarifying roles and responsibilities and creation of new management positions; determined receptivity of senior management to strategic planning and monitored their interactions during initial phases of implementation. Bell South Services - Determined improved ways for the service division to integrate its activities with its two operating companies using the survey-feedback process. Ohio Edison Company - Conducted organization studies of the Fuel Department and tne Production Department resulting in revamping of managerial roles and responsibilities, restructuring, and redistribution of professional staff. Commonwealth-Lord Joint Venture - Responsible for role clarifi-cation at P51's Marole Hill Project among area managers and area engineers within matrix project systems

Resume - Stokes B. Carrigan, III Page Two 1982 - Present INDEPENDENT CONSULTANT Specialize in improving organizational effectiveness and productivity through the use of organizatio,n diagnostics, survey / feedback process, team-building, and conflict management. Clients include brokerage office, hospital medical center, a college of pharmacy, a high tech manufacturing company, and a multi-national ccrporation specializing in transportation, food distribution, and environmental waste management. 1955 - 1982 SMITHKLINE BECKMAN CORPORATION Director. Human Resources and Organization Develooment (R&D Division, Smith, Kline and French Laboratories)- Responsible for all y human resource matters including succession planning, MBO program, career planning, and EEO goal-setting. Major task was to help create climate more conducive to innovation and creativity. Corporate Manager, Organization Develooment - Served as principal ) internal consultant to divisional presidents and general managers.  ! Responsible for diagnosing organization problems and implementing i action plans, including task force on quality of work life, and use of I conflict management techniques to resolve grievances. J ( Manager, Employee and Organization Develooment - Responsible for management development and training, performance appraisal program, career development and management assessment. Intro-duced new concepts and programs, sensitivity training, flexible working Murs, and managerial behavior modification. I 1952 - 1954 U.S. NAVY Lieutenant EDUCATION B.A., History - Princeton University Organization Development and Professional-level Training Programs PROFESSIONAL AFFILIATIONS Certified Consultants International, Charter Member Internal O.D. Division Organization Development Network, Board of Trustees NTL Institute for Applied Behavioral Science American Society for Training and Development Philadelphia Human Resources Planning Group GE0987

ou:ci+.m.. ..ew - .> . u ... - . - . . . 20# 818t682 60:11 88/11

                                                                                             , ,-  T l

4 PERRY A. BEEM PROFESSIONAL QUALIFICATIONS i Over 27 years experience in organization design and cevelopment, manager selection and development, employee involvement, socio-technical systems, and compensation and equal employment program deve_19 nt. EXPERIENCE , 8 M' k 1988 - Preset. j.fg'c MANAGEMENT ANALYSIS COMPANY

                                             =

f

                                                      /P,each   Bottom     Atomic Power Station                -    .
                         /

7 [is .- Consultant, Developed Faye'er'75th 7ptions Nuclear Operatiori Personnel including alternative positions a a both developmental rotations and permanent career moves, a process for mutual selection of i' V people and positions and a staffing plan to assure training and succession needs are r. at. 1967 - 1988 GENERAL ELECTRIC COMPANY Manager. M&DSO Comoensation, Benefits, and Practices - Developed and implemented new initiatives in variable compensation system, benefits counseling delivery, and gender awareness while managing af firmative action / policy equity issues. Managed participative job evaluation boards and policy review team. Provided related training and counseling for managers and employees. ternal Organization Manager, Relations Development consulting Programs in areas of rapid c- Performed [hange new business development and research; recruiting, retention, and training of software managers and professionals; and wage management and compensation. Strengthened entire new business development process and organizations to meet increasing new compe lon. Manager, Emoloyee Relations - Provided internal W u$ ting for established statt organizations. Significantly upgraded staff functions through coordination of organization redesign, management of succession planning, and four major executive searches. Trained incumbent Relations managers in Strategic 1 Planning and Management of Human Resources. Manager. Equal Op>ortunities/ Minority Relations - Successfully managed all comp iance programs through eight Compliance Reviews. Developed and instituted complaint prevention and resolution program that reduced complaint backlog by 75 percent. Accurately anticipated needs and.. designed, developed, and successfully proposed significant%Ephtraining E and standard Affirmative Action Compliance Plans for, Women and Minorities, Vit:tnam Veterans, and the Handicapped. , y.Vf f

                                                                                .                            c

Ed 30 TO # S ICi002 0T:11 Ca ti f[,,..... Resums - Perry A. Beem - Page Two ~

                                                 /

f Strategic Plann'er and Supervisor of Custorner Requirements Analysis for6sE Aerospace GroupcPaoneered design, development

  • and use of Strategic Planning in GE*with two co-designers.

Manager, IR&D Program / Marketing / Planning Specialist - Managed a 56%Research and Development Program. A r d.D.t n ... 1961 - 1967 United States Navy yt' Submarine Officer for eight Strategic Deterrent Patrols. EDUCATION M.S., Human Resources Development - American University and NTL Institute Joint Program B.S., Marine Engineering - U.S. Naval Academy Various graduate courses in Psychology GE0388

 *~

s 9 g , _.__I----

1 l !i PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHIL ADELPHI A PA.19101 (2151841 4000 April 30, 1985 Mr. Robert L. Rober Directer Berks County Energency Management Agency Bern Township Agricultural Center R. D. $1 Leesport, PA 19533

Dear Bob:

We have reviewed your March 4, 1985 letter regarding planning and training support for Berks County. Philadelphia Electric's policy on planning and training is addressed below. l A. An ongoing planning assistance program j Philadelphia Electric will provide planning assistance to cover county, municipal, school district. and health care activities. Planning l personnel will be available to provide this i I assistance on an as needed basis. For the long term, we cannot make a commitment as to whether this planning assistance will be supplied by PECo staff or consultants. During 1985, we would expect the assistance to be provided by Energy Consultants. B. A pre-drill planning program This activity would be undertaken by personnel as part of the on-going planning assistance program and would be a scheduled item in that program keyed to full-ucale exercise dates.

Mr. kobert L. Rober i April 30, 1985 Page 2 of 2 C. An ongoing training program NRC regulations in 10CFR50, Appendix E IV.F. that "In addition, a radiological orientation state training program shall be" made available to local services personnel . ... Also 10CFR50.47 (b)(15) states "Radiological emergency roeponse training is provided to those who may be called upon to assist in an emergency." For the duration of these regulations, Philadelphia Electric will provide the necessary training. The lesson plans for this training will be developed mutually with the appropriate agencies and organizations. In most instances classroom, hands-on and table top training would be appropriate. Copien of the training materials will be provided to the County for its use. D. An tr. tensive pre-drill training program

                  'Init woulo be a portion of the on going training program scheduled in relation to the full-scale exercise dates.

The Energyslide program you Consultants whorequestea will be inwill be provided by contact with you. Philumcipnia Electric will continue to work with you ana your ataff to coordinate the planning and training programs. I will be contacting you to arrange the necessary meetings to establish schedules, programs and perc~inel contacts. i Sincerely, [ N ia

h. A. Kankus Director Emergency Preparedness Section bcca V. S. Boyer W. L. Daltroff M. J. Cooney
k. H. Logue S. R. Stowell R. B. Horne R. T. Bradshaw J.J. Tucker

i l 4 I ISSUE: Fitness for Duty APPROACH: On July 1,1988 PE implemented its Drug Policy and Program, a copy of which is attached. This program exceeds the minimum standards set by the NRC Policy Statement on Fitness for Duty and the INPO Fitress for Duty Program in that the PE program fulfills all of the NRC/INPO guidelines and, in addition, provided for substance testing on a random basis for all employees having nuclear-unescorted access. The PE policy on alcohol will be issued in late August, 1988. CLOSURE: 1. PE will provide a copy of the Drug Policy and Program (actached).

2. PE will provide a copy of the alcohol policy by August 31, 1988.
3. PE will provide a comparative analysis of these policies using NRC and INPO guidelines as a benchmark by August 31, 1988.

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                                                                                                                                                                                                                 . ; ,s - m .w  c                :      = ::

c.

                                                                                                 .#      5 vES-                              - -

E 5* .= *v

                                                                                                                                                                                                                                          ~-

W

                                                                                                          .- .-=g :.-- w.= y G                                                                                                                                                                                                     .'
  • w -

m .Y- -

                                                                                                                                                                                          . rc.<              e >               c,. ' . .C.           .=w..

( =, .x

                                           =

O

                                           =A*                                                     . cw                                                                                                                                   ...                     .*
                         .J w               ~n 6'                                                     y -
                                                                                                         *r
                                                                                                                             =      p: y .,
                                                                                                                             . = . ,-                 w"
                                                                                                                                                                      -             .?

w .v e

                                                                                                                                                                                                                                    .a 5 / *- = ~:"-.e.=. .=-:"
                                                                                                                                                                                                                                               ..a
                         <               4Q                                                      U Ckg. *:. , ~w y                                           0 w" -d I -3 5. Y .y                              =~c.Y
                                                                                                 -          ,                                                        e.
                                                                                                                                                                                                  .g W-=      y -                                              ?.
  • Cy* .2 .!"'
                                                                                                           .7. , .N: =-

a'. P nW v .= O y ==..* T

                         -               O.      . 'O                                            .4                                        l,:,,,      7           ,=-
                                                                                                                                                                                                              .. w .77                    .=*"5" L                  g
                                                                                                   -=. . gc - c = ,$
                                                                                                                                      -                w                                                                        -         --
                                                                                                                                                                                                                                                              =.=c.

3

                                                                                                                                                                                                                                                      .c
                                         =.=                                                                                                           'r                           .c                                          =
                        ,g                                                                                                                                                            J %. c                                                                       =

P L, e. - ."=. ,=

                                                                                                                             - - " 7- .

e p

                                                                                                                                                       #              C.

c-- i .h .Z,

                                                                                                                                                                                                              * - a             e"=.5' w   r          r         . p      .=
                                                                                                                                                                                                                                                      .=- V== s-g       g                                              -                                                                       -             -

O CE ", c. ,.O. .= Ew .E C 'r. F =y= T- P

                         <   ,             t:                                                        :      =
                                                                                                            ; - '.x_c =r4       "R .=
                                                                                                                                                       =
                                                                                                                                                       -              c             r .= k                   --    5 * .v .m, "." :-

r-r W -=.

                                                                                                                  .-. :- = .x                          c                                                            , . -
  • m ga. ...
r. =, = n y .,
                                         - -c                                                                                                                                                                 '9a x=

A

                        -                                                                                   5e5 5 .;;                               .=              -
                                                                                                                                                                                               -=- .=                = x .:                      r.             = .=

C. O C. ...=n ..  : 5  : = :. . : s .= = C. O O O e O O l l l

y. - . ... .,,,.
                                                     . - =
                                                                                      ..L.L,L.L,L,.
                                                                                                                               -                                          f, N. s f,.

I i i l 1 i l

      .V,        v                                                                                                                              r                     -

w

      *.          /                                                                                                                             -
  • r ': .=

s b er

  • E .=
       - v.      [..,                                                                                                                                            -

O =- V. y

             =c
  • T y
       .                         -                     -                                                                                                            ed .
       . y -*
      . f.
                                                      *- =.  -                                                                                  ,

c

      ~.~ J.' =

7, . - , *

      .e                      -                  :,. ,.< 7 .                                                           .v.                      7                      -
      " ' * . - ,,'-                                                                                                    :-                      -                      =

( . 7 - -

                                               .=.f           '*
                                                              . .= ;                                                    -

T

 ~~.;  r..                                     .: 5=.                                                                                         ,

2,, - (

       . .             r.                      *"J.                L
f. ' -
                                                                                                                                .v. .           -
                                                                                                                                                                       .=
  • r.k%

C k. .C, .=.

  =-

7 ., k. -*"

                                                . . E.

v.- ,. x f  ;

                                                                                                                                 =*             *
                                                                                                                                                =-             -     - +.           L .=t
             =..                                 .
                                                                                                              -. .r*
                      . -.L-*-                   ** ..= /0
           =           .. '*

gas, .- .,., . , , . . .

  - =...**     ~                                 *-' " /* **';
                                                             = ..                           , ..
       -.               .                                                                                        y                               -           j
                                                                                                                                                                                    . . .w..-
      -- - 'p-
                                                                                          ...f.                                                                        ', ** *
  =
                       .s e-            .T                                           g =

w

                                                                                                                        **s-                    ;
                                                                                                                                                .           .g g

e . -

                                                                                              . .                .r===..,.                                                   3.,,,'
                                                                                                                        ,., ,.                              ~                                           e

_ . ^ --

                 -                              w
                                                                        -                        -             g                        / .=-                   , .
                                                                                                                                                                        *  . * .y    '-         W
 .-                                              *                                                                                     .,*                       'y w_                       ,:.

e.

                                                                                                                                                  .,, . .- ' .: =::
 .=

w ..* . ...,- =.. =.; - -=.../. .

                                                                                                                                                & ": '..* -2- -; ,,,.
                                                                                                                                                                                 .,= .;
                                                                                                                                        .                                    ~
                                       ..                                                                               - .         r                    ,
 =

f. e. C

                                                             =r  -      *#

tP =. ,- ,.#-

                                                                                                                        = ..c. C                   .                                 .
                                                 .                                          g.                          .g.
                                                                                           -= ;-::. =..=

as g., s g ,,

                                                       ;                - t
                                                                                       ,g
                                                                                                            $ - y ; a                                  -    ._.#.
                                                                                                                                                              -        [,.         _ -J                 =
                                 ,r,     p         .
                                                                                       .e..-           --.. =
                                                                                                                                 ,,% ,-            - .*  - a . . , . y'-     .

7 v..,y - n .- E < - - - - '- - - O .. W g g, m., . 4 .. gy f ..

                             ?:          g - r:                                         0 - i : * . - L*. .* I - Y. 7. - - - - - -

g . .. . C---.,.----,,- O. O.

e

                                                                                                                                                                     -s                        .

e v , y a r ..

                                                                                                            .en o:v                                                                                                                                                     -

n y

                                                                                                                    -                                           ., . ~ - - - -~
                                                                                                                                                                     ~u-                     Cn s.
                                                                                                                                                                                                                                ~               f.        .
                                                                                                                                                                                                                                                                        . g. x. .:                ). I
                                                                                                             .e                                                 n. 5-                                  -w :                                      g   .=
                                                                                                                                                                                                                                                                       -+y+y -=

e - w r.

                                                                                            -                 - c'    v.p. .: ..' .
                                                                                                                   .X .                     ,
                                                                                                                                                                .s.                          -y.

e - - w 4 s

                                                                                                                                                                                                                                                 -=

c x ;= 0 - - s,:. J. 5 .s C =: =- E

                                                                   ~x h                 v.        N - h5(                                 d,. c wI d i .[.           --

s $". 3 C *3 3 .E *E b .i.k [Ig,I. c .

                                                                                            -               5 .:                   .p p

4Yv w (b*C c. - =h n.#' .=. e

                                                                                                                                                                                                                                                                                   --    .x.

k *j fq.y I". f  : d ~= ^4= 'g b. 4 (l

                                                                                                                                                                                                                                .'#           w                               4 %*        .-

4.

  • w. f ,L. ~P h~O. e.

r ,'. .v.

                                                                                                          .,0
                                                                                                              - .. unnf V.

2 v C 4 4 C, - r. = - .v. ' " . .# = .v. k

  • 4s .E
                                                                                                                                                                                                                                                                              =
                                                                                                                                                                                                                                                                                   - A
                                                                                                                                                                                                                                                                                    -     e.

12t.,," *f

                                                                                                                                                                                                                                                                                                     *r            "O GA,_.N p               -

w x-

                                                                                                                                                                                                                                                       -       t"
                                                                                                                                                                                                                                                               - .. > -             . t e          .
                                             .-  v. X      - ="    c 4-5"                 E,. ,C > n 2 w . = : -=              c-v

(*.,,,**."r,.- 9 c

                                                                                                                                                                     ==                                y.         k 95 -        N
                                                                                                                                                                                                                                -                y. ?. ~:~: *[. I==I, u
                                                                                                                                                                                                                                                 >. =- . .- g k.Eg*h
                                                                                                                                                                                                                                                                                                     .I

[J '

                                                                                                                                                                                                                                                                                                                   ,t

[hC7c4y.'

                         ,                     ,                                          w                                                                                                                                     -

E

                                                ~

v U. E M% # *v E. 4

v. -n
v. _5 y
"F.

4 4 E. ,, e

                                                                                                                                                                =* p-
                                                                                                                                                                                           *"~
  • e O
                                                                                                                                                                                                                                               "l=
                                                                                                                                                                                                                                              .=*    .

{ .k-s ,. uny. C C

                                                                                                                                                                                                                                                                        -     uh. wv
                                                                                                                                                                                                                                                                                                  ={E       n a.s ,* *a I. y
                                                                                                                                                                                                                                                                                                                  .l v.~.'-r O                     =                                            n                 v.=           * === .~. g
. c C .".: yc k .=~ g b 4'n l .lJ =
                        =

e *: u=W + Y. .: v W'- G : c -  : .=, = p 4 c v e - Qy ...t2. p.

                                                                                                                                                                                                                                                                        =

3'  ::. tICi. I. j . gw . F  : _^ t c. ~ y :: M_ = -n - *: mm 4 c *

                                                                                            -                v t ,c_.

v% .,,_ , A. ..

                                                                                                                                                                                        ~k .e
                                                                                                                                                                                             - .='.~-          5 ..=-

c-

                                                                                                                                                                                                                                                     .C ~ rr .-G..
                                                                                                                                                                                                                                                                                   -z _=
                                                                                                                                                                                                                                                                                                         ,J
                                                                                                                                                                                                                                                                                                            -J Y=r                     : -.
                                                         ._ wm.x -                                                                                              -v                                                                                            4.

O g *

                                                                                          .=
v. - -
                                                                                                                                             .                  n v*  nes-                                                        w              s                            x .-                          1s
                                                           ,,'".W==.                       t                                           ~~                                                                            *'                                                             *-

5 t.I A cv .v -* c C

                                                                                                                                                                ~                                                                 -
                                                                                                                                                                                                                                                .v, ,e
                                              .-V .--r=
                                                                                                                                                                                                                                                                                                         . u.

E *= *-4 v. O c -n p

                                                                                                                                ..          t.
                                                                                                                                                                =
                                                                                                                                                                .- c .,,,,...w-
                                                                                                                                                                                                          ..,v-                                  -
                                                                                                                                                                                                                                                            . L . > . .*
v. .

y O .e. i= r, . .- s , a Y -.. r .... v'

                                                                                                                   .-       .g ;= =-                            v-
                                                                                                                                                                -    =-
                                                                                                                                                                                                     ,v.
                                                                                                                                                                                                     .:. e.   . w- ..4
                                                                                                                                                                                                                                                    ,-su -
                                                                                                                                                                                                                                                                    -   w r

4 ;

                                                                                                                                                                                                                                                                                          -          , . ) & .6 e g                                                                         -       >. x                                                      4 .v: ,:,===: - = :- =

v.- - , . .., - - s=. -

                                                                                                                                                                                                                                                 - ,                                                 5
                                                                         - :-*7-n ==., .u w c u
                                                                                            =                                                                                                                                                 =.      y;       v G v: C
                                                                                                                                                                                                                                                                                        *s           .~g g. ,y   3 Q         ,:= -

5 7 .- = n g

                                                                                                                                                              %. %' - m-w                                                                               . -

v - . '=$ .~ v. - V .- y- @% c. 4' 40m e p . e w v. 1- . 4.,1.g. .L s< E 5-w y

                                                                                                                                                                                                                                                        - . ..~.w
                                                                                                                                                                                                                                                                             ._, . e--.= --. .                   1=

v

                                       , ,w ._ .w          -
y. 4 v, .,_.,w,.

w .p . , V. g..

                                                                                                                                                                         ,e.
                                                                                                                                                                                     .u._,,,

G.. , - .yV n.

                                                                                                                                                                                                                                                                        * , ,. 4 n-.=,,.,-

r- .r dLs 3 g ..

  • v w . . . - . .w EO . g6 ,
                                                                                                                                                                                            .r. , . . .                         .-       ,.      e                      -                 -                         ,,
                                                                                     ,: -. -e.=.. i:-- ":r .:
                                     , ,                   w
                                                                                          ,y                  . -               .
                                                                                                                                            -                   4_   ,. .
                                                                                                                                                                                                                     .z                  ,,, -                                                               a.      .
c. ;pc nr =- :.: .E ' y.v
                                   =-
                                         .E8 E >-:e                                                                                =E                           -=                                                                               : e. .4                      ,. p6k               4s;i.[

O . .. E .*= : ,- Q *e= Q = r' u F % = i

                                                                                                                                          - v.
p. :=. w.:... .g L- - .: -

y V c.

                                                                                                                                                                                                                                                 + .
                                                                                                                                                                                                                                              .c 5
                                                                                                                                                                                                                                                                                                     <       n.
                                                                                                                                                                                                                                                                                                   'tg=,.r.a g*. .s,
                                                -,-- -.=.=                        .c .=v.v, vc
                                     =         - -                         *                :                                                                                                                                                                           a. 5: w E                                                                                                                                                                                                                                .v-r w                   .~.,                              . <
                                                                                                   . v.

e.. ._=w e .= .0 x.. . - x

v. - .:.--n>..=

y.w- . ,_ f-. L. . v.

                                                                                                                                                                                                                                                                                                          .I-4
                                   ..                                                                         3. . -                                                                                                                                                                _ -
                                   .v- - -                         n. _ . = , - -                                   c           y                               . . v ,                                                           g w                                         -

yy - c

                                                                           .     .=      v
                                                                                                     -..v-    .

E : 9., c : v, . F ': a. ,..sJs .- r ,E ~.E

v. - ... -w
                                                                                                                                                                                                                                                                                    ..    ,-              a. 4 * ,r.

2 .: .I .

               ,e, E                                             .v- u-t                 r .i                         =             v=v' . r - v- -ev                n                                                                                         5 E -- e - E. a/  -
                                                                                                                                                                                                                                                                              =

w

                                                                                                             -v .y    -s- v .:
                                               - v                                                                                                                                                                                                -
                                                                                                                                                                                                                                                                                                   ,- 3 .r -

4s. a.yv-

                                     .- -.     > 5 s =u C A5                              4           ,-                                   .>                                                     .= k                                                            p v. >. ;                          -

m 1.. u= c

                                                                                                                                                                .   =.              -=-              c                 c             ,   =    =.            .  : .: .- .- .-                         p= =;~ 2. .

z> ".-.75. .=. .y %. n 5 2 .E '= 5 L -, - r.

                                   .:                              e,                                                                                                                                     x.      .

3 O5 g

                                                           .-      ,,,     g.m.

_e ti

                                                                                                     .n
                                                                                                                                                       - - .,,,,,                     .-e.                             -
                                                                                                                                                                                                                                .v,,,.
                                                                                                                                                                                                                                                        -     . , . . 7 6
                                                                                                                                                                                                                                                                                                        *.36
                                                                                                                                                                                                                                                                                                         .g g ., .g E                                                                                                                                                                                                                                                                                                 J1- le        -2 0         O., na 8-j kW       O         _

s J - e; n O O e e e o

                                                                                                          ,,                             , r                            ,
  - .=
                 .= _

r .: x. : = :=3 = ,.

> a z .= ?m
                                                                                                                                                                                      =
                                                                                                                                                                                      = -
                                                                                                                                                                                             .=
 -b $             =. r'
                  .
  • 3
                                           .                         'O. "." .:
                                                                                                        .J,,
                                                                                                                   =,
                                                                                                                                       .== *
                                                                                                                                                  .                   ",I,,
                                                                                                                                                                      * ,_. '=

r i .: ; L > .:

y. r r.
                         .v               r. .. -
                                                      >       -       ~ . ;==;r
                                                                                             .5 J
                                                                                                                                         - i.x y                            -

I .J. v _I

  .   ,e-
       =          r
                         .-               =
                                          . ; -x . -=                   .                     ,,.         .      ..

E. r.

                                                                                                                                                                                                                                    \
                 ..: =-                   . - 2                                .. ;

w r / . - ..'r.

                                                   .~e_..
                                                                                                            . .                        -            (.                    .. ..,;     . -. ..
                                                                                              .                                          z.       ==

g ,= x = 5 = .= = =.;- y

                                                                                                          '--r                           .': .=                          = .-                                                        g
      .=

v-=-;

                  , w 1 -L
                                          =                    ,- : 5 *- -,
                                                                             -v-= . = . .
                                                                                            *           -g
                                                                                                                -. = . .
                                                                                                                                          /

E r6 .=.= =

  . =
 .-=. F.

_= - a

                                           -          f
                                                                                     .a f
                                                                                                                                                  .x
                                                                                                                                                                         =                       .'.
                                                                                                                                                                                                                                                               ,=.

r

                   , .;                  . . :- - > 3 r                        .

f

                                                                                                        - *=.r*                           P ==,
                                                                                                                                                                           , .        s.                                                                       ..
 .= =                                    .= -                         .=                      f
                                                                                                                                                                                         .       4,                                                             .,
 ~: *:                .; -               O            h. .=y                          --                  r
                                                                                                                  .=.

( C .= 5 3- -

  .>-                                      .= , .. . r. -- 7:-              .r.   *.:r                                                   ..
                                                                                                                                                                           - - -~-                                   n                                           z r                                                                                                                      -
  =-             .=.       :                                                                              =.        -                     - :                              y          =                               \\             \

x.

                                         ..a w .=-=                     . . . =
                                                                                                                                          -                                 , -                                                     h 6'
       .L.
                                                                        . *: _: :                         ; *=      -                               7-                     .; .:_ -=                                   \ \.

s g =. =.=.

 ==..

g = = ;, . = ." a. .==- -. . . -= ..v. V-

                                                                                              -r.         k.

T- 7- 1 - .

                                                                                                                                                                                                .7                      t
                                                                                                                                                                                                                                                          ..  .=
       ?
                 == 5
                   .- -=
                                         --s .= ;,-
: r =
                                                                               - z =                    *
                                                                                                                                          =- ;

r;- .= 4 y

                                                                                                                                                                                                .=

i

                                                                                                                                                                                                                                                           -r
                                                                                                                                                                                                                                                           =

J

                  = ;-

z: ..:

                                                     - :.. .~7. ;z. - P :             - .                 =."-    -
  =..L=            , -                                                                                    -. =, .=-                       - =.
7.

0. r . . ,-

                                                                                                                                                                                                                  ,\                                    . -

_. - - - = . , r .

                                                                                                                                       .* ~ --;
                                                                                                          =       u .=-

r -2 .; - = =r  : .: r *, 7

  • i-- .=." ::.T .: ", . ""
                                                               .                      7                   =

s

                                                                                                                                                                            .e e.= -

N

r. .-
                                                               *' . - . =-

e

                                                                                                                                        ~. =                                -

N g f, Ed .

                                                     - .=. *E I 2
  *
  • d3 7 '5 .

53.d

                                                                                                          = "- =
                                                                                                         .-         ; =                                                                           .
                                                                                                                                                                                                                                            \

_ =.

  .              .3=

g

                                             . -- =:- .r. - .. ..               .
                                                                                                                    -;.                   -. ;.[                            -.a       . =-        =

ar . . = " > .= -4T

  -                ;       -s                                                   .*                                                                                     " .. ""

r

 * '.                                                                                                                        r.
                                          *. .= .'f a2 --y' L*f         =                                  -                              V         3                  *:
                                                                                                                                                                            . - r w            +
                   = .,.                                                                                                  .=               z -                                                    -

m - g W_

                                         -_ =.      . *
  • 7
  .y  ~-         :--      _a.              .                            .. - - -
                                                                                              .L           Z -Z ,
                                                                                                                                       .;  . a~                        _:
                                                                                                                                                                            = ~=
                                                                                                                                                                       "= r* ~.                   ! -'
   . -              -                                          - .              -                        - 6 .                                                                                                                                                                              ..
  ?
 .. ~.

3

      ,= ..
                           -3 h.          E. ' O.,2:- .-f.     .                . =$
- -- 2 .< h. . =.

3

                                                                                                                                                                                                                                                                                            .L.J.
                                           .;. -aL-="
                                             * . . e .-                      I :' ,=.                                                                                       ./.
                   =       a.                                    .

f . 7 = -

                                                                                                         .=* I- ;,                                                          7
  • a =
    , .: =

a .=,

                                "l
                                                                                                            . . ,                          i. L= -          -

2 Z* ='C x - -

                                                                                                                                                                                                                                                                                            .1 3

L. -:. .:= c =- ; =- . .

                                                     .=
. = ,  ; f. M, ,
r. - - _,
                                                                                                                                                                                                 ;       y
                 .=         , -
                                            =.             . :
                                                                                                          == , -  .x.
                                                                                                                                        .:        .. .=                                                                                                                               5.
  - .,=    ,                .: -
                                            * - ._                 = .-- ,, L.=
      ==.,
                  ^ *-
                            =

T.

  • 2 , ' *. =. - .*., y
                                                                                                                                        ..*"7"
                                                                                                                                        .=,          3

_g

                                                                                                                                                                        - - =. .

L =

                                                                                                                                                                                                                                                                                     " Z
                                            -N.a*.                                                                                                                                                                                                                                      ' .g T"   (                    ,,
                                                               -5
  • d ". * . j O .= h #,
                                                                                                                                                     .      O                f
                                                                                                                                                                                       - =                n=

ai 3 $ E. $ 3 U

 ** ~~ ,   r     t.         g i                      ; -
                                                                                                         ," 3 E'              -
                                                                                                                                              , r -                                               f,.    .5                                                                          _. , -
                          .:. O                                                                                                                             c.
       . 4                      .                      .- = -f ..- .*
                                                                                              -7

vc k .- - y,*. .

                                                 .n u                        u                                                                 s.,                 .va                                                              -
                                                                                                                                                                                                                                    -                                                 ,.e_-
            -              .. r.                            9              a- r.x A            e. n C . .e . ..
                                                                                                                                                                      =                c.
                                                                                                                                                                                                               .        -  -       f, W              o g .-.5r
                                                                                                                                                                                                                                                                                    ,                                .-                       p o yn : .v. yw v. a . ~u w = y.

o =c = - # - - ~ -- s .<. , - k :k y.$CJE=*k Cf c = '.x =v p . s ',..> , = W- W,.-,.

                                                                                                                                                                                                                                                                                                                    .=                     ,
                                                                    =.k .E c-C                  d.
.- .x
                                                                                                                                                                            '~
                                                                                                                                                                                   !!                .;; g .%.C_C,.==
:,  : _C =C 'C ,,: ,5 ' E =- c .,
                                                                                                                                                                                                                                                                                                                                                    ),
            =.     .v..-n U ~
                     **                   y :.u . .g. v.. nV v.                              . e.                     .-= ,: .r.

n ,r,,.,/* 'g.-

                                                                                                                                                                                                             .p
y. k5,: w. == t. -- W d y.= .-=  :

E g n Cp '.E .

  • w - V . *=. v .--

A* g,,I p C =I e .C .=- =O'%= *-

                                                                                                                                                                                                                                                                                                                                            **e; C C .-k.                  w . p '.
                                                            %.: .A           - ,C. ,- . O           b-                =,=,.r."".,h"('                                                ,,,,
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c.,

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                   =:

f

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t --

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v r Z.

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2 -r 3

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l'

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5= g 8.:

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l 7

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                                                                                                                                                                                                                                        *f, . ;.,-

l

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w i l

          -                                                                                                                                             .                                                                                                                                    l i

g

/- /. f i
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l

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t m

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u =

                                                  ==
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L 7" ' = '.=ll; -

                                                                                                                                                                                                                                                        ,,x
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1

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                                                                                                                                                                                                   .=                         .?-                                                a Z. .

W Z

'y . ./ :~ .'".y
e. =

w - N.y .-

                                                                                                                                                                                                                              -.*'                                                         1
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f

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i

                                                  ".f.
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l

1 e  % . Y e

                        -n . .=. .v.                    9 v.nY an                  v s .=      -

u y r w. w e< u. .

                                                                                                                                                                                                  =               gn                         -

n n

                         *=.

vv .- u . n.= p,e:

                                            ,=  -
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                                                                                                     ,.==x
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x

y. .,. -v=.=

_ e w v r- e.

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              .= ,c     - n.a.. ::.=y-=                                                                            .
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5 -
e. _a. m . .u y,,

c .. cn.

                 =      ax wE .<e = n                                                        e    s          y -
                                                                           . 1   . s= :w Cn ~ . .. e. . --
. = e.
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                        -n--    ...u                                    e-       r.                                                                                                               -
                                                                                                                                                                                                                                                                                 -v>

u u ,e..=..=.=.:

                                                        = v -c: +..

5 .= >. = n ==. . .e = <1n _c ,, =V,n= =,=. w- c . a==u - -

                                                                                                                                                .n.                                                       w
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                                                                                                                                                                                                                                 .v .=.

a p. <.=.

                                                                                                                                                                                                                                                                                      =. -
              .=                                                                                     .<

e C = E. v

                                                                                                                                                                                                          .=ye                                                                   =.
                                                                                                                                                                                                .> .-                               w .-. .-                                     V ==C
                                                                & s =un a v .=c.=,

v v w =

                        = v -=. ucv v                                                   w

_y v,- .-: v .= .w = c. =9 M i

                                        -       -                -      _v e    n    -       =.       w           -       w         v .= C                                                             .                g. v                                                                                                           ;
                 ~

1:u n1:.=-=u= U -

                                                                                                                                                  >2.         w                                   ,.
                                                                                                                                                                                                                                                                              -e w                                                                   ,

i a r = ,., 7 u ;=: r +e .= = .. . v- n ,--au c.w m.

              .-        .: :                                                                                                                                                                                                                                                                                                                         1 c .a p #u _ >~ c                                                               aa-c w

m =. -

                                                                                                             =                                                                                    'ss                                 Fw-                                     -= .= -                                                                l ev .e.o=n =ec                          =. = - a : :.:.n =s . =. = I:r a t e n
                                                                                                                                                                                                  = , .-           = y - n  -
                                                                                                                                                                                                                            ~. * ? .                                          1>.*s F.

e s 2 7 = += I . EC.s==T~.:n u s .=.=- = n . =. a - w= . - -

               - a-. r . v ti =                                                                            %=               9=              5     n    ". c                                                    .        -

5 .b. 5. . , C -t.s'2 e .- . . E

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c . . .ecs.. - e .<.=v<=

v - t 9- = -

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i it.=< .= & E . - E.c. n 2 ,s E = i L= 5- ..= ...= . E

                               ?                                                                                                                           ~= .                                                                                         -
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p;= 3 g

                . =. -= -. . =.                         =                .g      v     =   r-  x Y      +#
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8# " I'" - A .=%. - **

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s y

                                                                                                                    = ~

c==V v, .==r.- Y n^:-- [ 3..= g Y .

  • y
  • ps ' A."

a-h v.*=>. w v > =. V

                                                                           * .7s f%.

y y e : "-"" .C =. }v M a n -

                                                                                                                                                                                                                         ,C".

o.. "~ " . .r. -[., * *

g. == *
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= r. x,,,  % 2,  : - x. .=~

w ;j ~= t'.,==. e.

                                                                                                                                                                                                                                                                    * ' == .
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               +                                                                                                                                                                                                            ~                   +
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y"

                                                                                                                                                                                       -        ,Gg
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e b

                                                                                                                                                                                                                                                                              ' I.                                                                   {
                                                                                                                                                                                                                                                                                                                                                     )

N f A. N. - I b. N 4 i i e 1 4 O 9 ~ 9 9 E == E Y. 8'.P

n. :. .:

r ""#=yi > , . 4=:=

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T

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V.

                                                                                                                                                                                                                                             *==,i. = *. =*
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m=.=,,,, J =. .

                                                                                                                                                                                     = .
  • y=
                                                                                                                                                                                                                                                           -                                                                                         J
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5 .. =

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                                   -       i
  • 3 *
v. * .,,, .= n= -

l'* = 7 c .=. =.I .:F . == j

                                                                                                                                                                                                                                        .-.:.- *.-=
             =

y* (, z- J: == * .y

                                                                                                                                                                                            =                                                                               *=

4

             .= >;

g Z

                            ,C V       r =. =[,.                        f 4

Z 7 L. .7 *==

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y

                                                                                                                                                                                                                                                                                                                                 .y .x, l

l

             .-
  • 0 *: - =. .= e -.
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                                                                                                                                                                                                                                         * -:                        3        *                  ... ===                                  >

['=w e .=,, 'm. . Y .O*,,=, .*

                                                                                                                                                                                                                      .>                                                                                              *""!,=.             .
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               ?                                            <                                                                                                                                                                                                                                                               *
e. ' . /" .
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m. .

c , ,,.Z v - V.,,, .- .$ .=. g y G -. , . = .n, y

  • y, .
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                          *=
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K C. e.-

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                                                                                                                                                                                                                                                                                                           += _. ,
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a- , q,

                                                            .? *=.
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  • r- .

s .'= .=.: N. T. . = ~ .,,-

                           - - =.E..                          . . ,/                                                       ..                                                         - _= = "- . v$=.= k. uk .*:*                                                                                          = .- y c ,1 -

M

                ..       =g==.            . ..-./. -        a y
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th"

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r "

                                                                                                                                                                          ,/      )y=c
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n r'C. r = vs v== :. .

                                                                                                                                                                                                                                                                                                   .F y        3 -w      y ;,, .> y -
                                                                                                                                                                                                                                                                                                                                  =*

5- - r- *7 D. 'E . ?-

                                                                                                                                                    .=,.
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F nT 4 - W ,7,,,*,

             ."                                                                                                                                                                                                                                                                                    5 > n 'r".
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                                                                                                                                                                                                                                  - " n       . . n -1E                     E
              -                                     . :- k rn                r -                                            *                                 = =
                                                                                                                                                                     = , , , . - *"                                                                         5 f.                                                             +. - r                  /
                .? *= s..=.'=
                                                                                                                                                                                                                       .* i
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_ y '"

                            ..,. ~ >= -/              2 ~=~                 ~
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rwp."=. ) g J ='=" d*

                                                                            ,(                                              =...%.

e . .

                                                                                                                                                                                                                                . = ";l" Z , 3.

3 O - . d

                                                                                                                                                                                                                                                                                                                       -      P                      1
                           -O
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a. . =, .- -
                                                                                                                                                       *        >-= . *
  • ll* g
                                                                                                                                                                                             ,        J.

a- E

                                                                                                                                                                                                              ? g F. ,- .
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                 =
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A.

r. , . .+

M. ==- * .** *ll'" ..=.,a=, *? ^

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r' . =

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                           /                                                 ; ..                  a
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                                                                                                                                                                                                                                                                                                             /, .E ww - .-          g,-
4. u*/ n=.. .,=-.** *".'
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4 .,r,. .

                                   ,g                              *-
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d'" h".'

                                                                                                                                                                                              /
                                                                                                                                                                                              -     _.P W-.,,m d
                                                                                                                                                                                                                        .W         .#
                                                                                                                                                                                                                                        . M_

e

                                                                                                                                                                                                                                                                                                  - ., = ~:                   -
                                                                                                                                                                                                                                                                                                                              ; e .5 y                .
                                                                                    .a z . =                                                       #..=-a
                                                                                                                                                                             .                'p. gy g ,,, . - r = ~"= ,. x    ,

u "*e,,,.

                                                                                                                                                                                                                                                                                                                   = ; -

r, .y 'a_,,,,,,.  ;===_p,,, y .=. . " W 8 m /. =. gik-

s.  : -: .= S
                                                                                                                                          - ..= v == = = -: '-                                                                    -7 r3                                                      f*
                    . *                                                                          .M
                                                                                                                .e ~: =
                                                                                                                                                                                                                - ? 'yj - - .** * $.--p y
a. r' ,
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                  .                  ,.,., ,,g
                                           . = -
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e- - P e a

                                                                                                                =- = l= {a } ,;, b. =.='y .* 7 '-* =r g
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[1 , . ,

                 -          -                                                 7. . 0,,              G.                                                                               h $ .:. tT =b.,,. =,                               *O. **P.. ... - *' A."                               *   **w - /                                      ,.-
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? 'C. ,= .

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3 (/ '5 - *", = e==., = . = >-.

                                     . =gI *=     = -5:. . r. ~

J" . - F. ";" .*i jr b. .,= ." a - , -" ' -" .-

                                                                                                                                                                                                                                           #                  4           4 4'

P w.7.. i *

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                          *=, ..                                                      =,

w

                                   . = .. ./

8.

                                                                   .=.4                -    6
                                                                                                              *a              -

y

                                                                                                                                                                           *.            ~                                                                                                  -
g. e d* .. , .

g a* - .

                                                                                            * =.
                                                                                            'e
  • v ** > - - . ./ *
                          ** .= F'-                   == .. . . .g     / . ,,.

g

                                                                                     '.7 .--#     8
                                                                                                  -.P -

I - B I I

u.. x . v e e.. . ., -

                                                                                                                                                                                                                                                                                                                              =
                                  .J $

n = w .=

                                                                                                                                                   .>s
y. v n .n ...~ -- -w< -.-
                                                                                                                                                                                                                                       .=

c- - r x c.. e; - w v e .x . e.

                                                                                                                                                              ,                                                                          -.,.                                                                   _= . s.       -

w

                                                                                                                                                                                                                                                                                                                                                        <                  .x .. v- -

w ..

                                    - .c                                  ...

s.

                                                                                                                                                                                                                                                                   .-                          y w
                                                                                                                                                                                                                                                                                                                   - v                          - ..

k

                                                                                                                                                                                                                     -                                                                                                        L
                                                 ..                                               e                                                G ..                                e                                                 -                                                                      s.

d[v e =. e r - .= a _L c

                                                                                                                                                  -u:

y u: w - r .c -

                                                                                                                                                                                                                      .=*               u .-i, ~5 :~                                            ,:              ,.' =-                          h    7:                    7*

w e. w

                                                                                                  -                                                - .                                 -w w-n v l:
                    .-n7.
                          .,..r   -
                                                                            =                   Z                              d                   .
                                                                                                                                                  -- <.                             Z
                                                                                                                                                                                                                       $-                - -.          C ,..

c

                                                                                                                                                                                                                                                                                               &       .,=c y*...C. E,...-
                                                                                                                                                                                                                                                                                                                                                        -                  kw
                                                                                                                                                   =n w

e=. . v,...

                       =-= cn       -                                     .:

e 5 .: e-

7. . .: e n v- ..- .
                                                                           .-e                                                 .- s .-                        .                                                         :               e                                                                          n                            n -                        --
                                                                                                .-                                                            w                                                                                                    ..
v. o n. -

x-x C t8n c .

                                                                                                                               = wc=
                                                                                                                                                                                                                     .a                                                                                                              . -
                                                                                                .=                                                                                                                                     u.               .         :

c n ..V. i- .e. Lv c .=- . . .= . + - - s.- - s n

                                                                                                                                                                                                                     .e                  -
                                                                                                                                                                                                                                                                                                                                       - .-     - -                               . #x.
                    %. ,, .. w-
                           .w                                               -                                                                          .,-                             -
                                                                                                                                                                                       .                                                 .. <                      V
                                                                                                                                                                                                                                                                                                   ,v           -                      -                                   e*        .

g w .g . 4 . w y. - k* I

                           ^ ~
                                  'w" n .. k .                                        < -
                                                                                             **                            *O           =          u h u
                                                                                                                                                  'E                   O.             h" h N k.w .6 e.b ar                             D b.e                      J, 0":                                                                       ED w

4 .. " " .$ . =  : - - - e w , u *n4 n .

                                                                                                                                                                                                                                                                                                                  ,- .Jll "U v-
                                                                                                                                                                                                                                                        ;"  C -.,=. .k.
                                                                                                *:                                      -                                          *T                                 a
                                                                                                                                                                                                                                 =                                                                                                              v. -.

9 . -  %

                                                                                                                               = -                                                  . z.,                            "                                                                        -w        (,,     - - -                           g E
   -        9 ' = -

L:3

                                  *e" =.4                   w.            '.; - . &,
  • O *w- O ."
                                                                                                                                                                                                                                       -h,             L kE7 ,$                                           =

3 . .fhO m. O

            '.                      Q> I                                                          g                            llll. ' "w          >9 % (.:                           g
                                                                                                                                                                                                                                =                                                     c                         ,$ y. * -h
 ~~
         =:

k=4 pd5 ,.':

                                    =

W =

                                                             ,,,          ,1- <l      t" J Y
                                                                                                                               .u G

C..E >> .c ; n v g-v,

                                                                                                                                                                                                                                       .g . .=.

C-

                                                                                                                                                                                                                                                                 .-r.

y C =

                                                                                                                                                                                                                                                                                                - = - . -cU,-

C p;yg : .? { ( .h $ O. h E=k C. W

                                                                                                  $ {w .h
                                                                                                                    .=

0 E =w k '9 <yv h * $ F F

                                                                                                                                                                                                                                                       "           $ *3 I D F=                y4 .= ':. ^y 0=w 2=*- ,

N T.=. w :.=.6.v

                                                                                                '? <v                                                                                                                (f, .e,                          r.- .-r w..t.'. v,                        ^u
                                                                                                            ,, , - - :=.- v
                                                                                                                                                                                      -                                                 e                                                                                    w
                                                                                                                                                                                                                                                                                                                                                               %. r; -

f" v.. -

. ., #- r .
                                                            . .-=..@-                              - .,.
                                                                                                                                                                                                                                                                                                                      . .W *.r
            .,,       $ .,                                                     - -                                             ,p                                      .-             G.,,,                                                                                                     .-*                ^V
 ,          ..                      .w                                      .

f* . w , w p.  % Y g . * * . .. .= g . * . f* ., *v for . , . , , . , ."* gv p . .n. fu f*

                                                                            'w                                          g Q w.*                                                                                                          g       .e.=.                                 ,"    ,,

g~. .e. e. e

   ,                                                                                                                 =.                                       ,, e.     -            =.=.w                   .a                         .e                         .
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4.0 scars b for ihuns is infurstal. if Ihis primission is nith. In bl. Ilm sr.ni h will not en i m. Ihmvw1. the folleming ar- bNANIONS lions willIw taken hv l'ECo pnnielnl the infurst (en the w.n h was m.nic in .n i nol.nu c with p.n aniaph 3 2 I 4.1 Aherrant Itcharior-Significant dornmentnl behavior, indialing alwar- delniorating per fenmana , over a period of time, which iferiates I. Il the imlividual is a l'Ero cmplovec. hcAhc will it ilis. funn Ihe noini whie h has been established tw the prior behavior

            . h.nenI . uni not i onsi<inni fen ic emplovment foi a                     of the emplovec or the nonms of behavior wh;ch had been estah-nmunnnn of tin n- (3) year s.                                              lishni hv so<iciv annil,n the Company.
      "     ti the iinlitiitual is .m rmelover of a i onti.w Ios eng.n'ni        4.2 Cinnpany I'acmiscs-Im huh s l'Eco facilitics, buiklings, sur-hv I'l:Co. Ihr imhvninal will ir irmovnl h om I' Ecog                      nnnahne gunnuls. I asking arcas, l'ECo vehicles. ami all other pe nniw .nni pin hnini hom irifouning any subw                             aicas at whie h I'ECo peifenms mnk, whether or not owned or Icasal by l'ECo (c g. public steccis arul customer homes).

unent l'ECo irlatal wmk fin a minimum of tince (3) w ns 4.3 l)r up.s-Inchnics the following: (I) any c hemical substance whose

      't    if Ihe iniiniihul is anvonc cIw Ihe innliviilual will le rc.               manufadun , use, p mession, or sale is prohibitest by law. and (2) moral h om l'Ero's permiscs .nul elenini iut m e ai i ess                  !ccal dnigs (whether a narcotic, cont rolletl substance, or 1.n a minimum of tinre (3) years.                                          Incscriheil dr ug or over the counter medicat;on) obtained illegal-ly or taken for purposes of abuse.

I ? .I Violations

                                                                                                      "*C "'C"A" C*Idom>f im who is snhject to 5
       ! . 11 an innhvidual possesses or conceals th ut s on l',ECo~s I

IElos,fDFollow iip i u>cednics may be: pe rmivs. the following ai tions will le taken by i E(. o: A A 1. scienni to PECo*s Emplo>ve Assistance l'ingram (EAl') for (a) If tir u. nh.vn. hul is an emp!over of I,l. .3 n. ImAhc will y y appn piiate conasch.np]trcatment. Im disi luival . uni will iw in onsiilnnt foi cmpIny-ment unir atin a minimum of flun-(3) tr.ns. titefer 2. subjeded to: to I2) a. unannounced Icsling, as follows: (b) If tim iminiilual is an rinployre of a e unti.u Ior en-

  • thoce (3) times in fitsi threc (3) months folhming treat-garnt hv l'ECo. bcAhc will ir ermoval fnon the ment nr. in absence of treatment if determined by the permiws .nul pin tu Int hon. Iwilonning any snhe Medical Department to le inappropriate. following an quent l'Ero irlatol win k foi a mininunn of fluce optwntunity for the individual to haw- dea:cd hidher g.ty n.ar system of Ihe dnres which ersuiteil in the positiw- test I, ) 11 Ilu inthviilnal is anvonc Clv. the indiviihul will Ir '"5"II-semorni hom the incmises ami denini futun ;"" + lince (3) times in llu next nine (9) months.

e css foi a mininnnu of linre fIl mnt b. special superviseny observation. 2 I .aw rufou rment of fh ials will IC c"nt " InI i" N"I c. long inm monitosing throisp.h the EAl' that iltrealitings arc thsonveni on l'ECo lunniws.

d. sconity accheck.
c. cxtension of probation or trial period, for a probationary or eccently liansferred employec. as applicahic.
3. cxdudcil from Nudcar linescented Access for a minimum of 9 9 Ihrcc (3) months, if airlicahic.

45 Impcimissible Irvel of I) rugs- A positiw Icst result.

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  • ISSUE: Insurance Reports l

APPROACH: PE was not required to make any specific reports (s) to insurers regarding the circumstances leading up to and following the issuance of the shutdown order. Insurer's inspection reports are provided to PE by respective insurers. These reports and any PE responses are avai]able for review by the Commonwealth. A number of teetings were held with the insurers regarding PBAPS restart activities and the insurers retain inforced via copy of PE correspondence discussing restart. CLOSUP.E: Insurer's inspection reports and PE responses are available for Cocconwealth review.

                                                                 .. .               _ _ _ _ _ - _ _ _ _ _ _ _ _ _}}