ML20203D245
| ML20203D245 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/26/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8604220067 | |
| Download: ML20203D245 (16) | |
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General Offices: 1945 West Parnalf Road. Jackson MI 49201 e (517) 788-1636 March 26, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
RESPONSE TO NOTICE OF VIOLATION (INSPECTION REPORT NO. 50-155/85014) DATED FEBRUARY 24, 1986 NRC letter dated February 24, 1986 contained a Notice of Violation (Level III) pertaining to IE Inspection Report 50-155/85014. During an NRC inspection conducted during the period July 30 through October 31, 1985, a number of violations of NRC requirements were identified. The violations involved personnel errors, inattentiveness and failure to follow procedures. These violations were categorized in the aggregate as a Severity Level III. At the December 5, 1985 Enforcement Conference regarding this violation, we presented corrective actions being pursued in the areas of counseling of personnel, component identification, training, upgrading of procedures, disciplinary
- action and involvement by corporate management in control of maintenance activities.
l The violations, Consumers Power Company response and a separate section describing the corrective actions presented at the December 5, 1985 Enforce-ment Conference are as follows:
A. Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained for all structures, systems and safety actions defined in the Big Rock Point Quality List.
Local Control Procedures - Part I, RESPONSIBILITIES, Repairman, which implements Technical Specification 6.8.1, requires that "after" working I clearance has been received and "before" the verk is started, it is the l
responsibility of the repairman doing the work to ensure that the equip-ment is depressurized and de-energized as is necessary to perform the work.
Contrary to the above, on September 11, 1985, even though a repairman had received working clearance on the steam isolation valve for the steam seal 8604220067 860326' OC0386-0056-NLO4 PDR ADOCK 05000155 g g G PDR t P bl
J G Keppler, Administrator 2 Big Rock Point Plant Response to IEIR 85014 March 26, 1986 regulator CV-4104 and it had been determined that the associated system was depressurized and de-energized, work was incorrectly performed on turbine bypass warming valve CV-4106 for which working clearance had not been received and for which its associated system had not been determined to be depressurized and de-energized.
Response
The repairman originally assigned to work on CV-4104 could not meet certain protective clothing requirements during the performance of the repair activity and another repairman was assigned to complete the work. The second repairman was given directions as to what work had to be performed and where the valve was located. However, during the 24-hour delay that occurred, the scaffolding was moved to CV-4106. The repairman performed the described work assuming he was working on CV-4104.
The action that was taken regarding this occurrence is contained in the Corrective Action Section of this submittal.
B. Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained for all structures, systems, and safety actions defined in the Big Rock Point Quality List.
Local Control Procedures - Part I, RESPONSIBILITIES, Operator, which implements Technical Specification 6.8.1, requires the operator (auxiliary operator] to accept, write and carry out all switching orders to the best of his ability and with strict adherence to Local Control Procedures. If at any time there is not complete understanding and agreement of what is to be done, the operator shall stop and resolve the misunderstanding or disagreement before continuing.
Local Control Procedures - Part I, RESPONSIBILITIES, Issuing and Receiving Working Clearance, which implements Technical Specification 6.8.1, requires that the person in charge have a complete understanding of the condition of equipment involved and that the electrically de-energized and/or mechanically isolated and protective tagged equipment encompass the work area needed, thereby making the equipment safe to work on. It also requires that tagging be double checked by the Operations Supervisor after equipment is removed from service.
Local Control Procedures - Part I, EXPANDING WORKING CLEARANCE, which implements Technical Specification 6.8.1, states that if at any time working clearance does not encompass the work area needed, a new switching and tagging order shall be completed. Modification of or adding to an existing switching order is prohibited.
Local Control Procedures - Part I, RESPONSIBILITIES, Repairman, which Implements Technical Specification 6.8.1 requires that "after" working clearance has been received and "before" the work is started, it is the l
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J G Keppler, Administrator 3 Big Rock Point Plant Response to IElR 85014 March 26, 1986 responsibility of the repairman doing the work to ensure that the equip-ment is depressurized and de-energized as is necessary to perform the work.
Administrative Procedures, Volume I, Chapter 5, Section 1.5.6.4.2.E.8, which implements Technical Specification 6.8.1, requires that the mainte-nance procedure shall contain a step-by-step description of the work to be performed and shall be sufficiently detailed to allow correct and safe performance by a qualified individual without direct supervision.
Maintenance Procedure TR-74, Sections 5 and 6, Inspection of Liquid Poison Supply Check Valves VP-301 and VP-302, describes the procedures for isolation from the reactor vessel, proper tagging, disassembly, inspection repair, and testing prior to returning these valves to service.
Contrary to the above, written procedures for systems defined in the Big Rock Quality List were not properly implemented which results in the wrong valve, control rod drive system check valve VRD-305, being disassembled on September 25, 1985 instead of VP-301 and a loss of approximately 1400 gallons of water from the associated system. The following examples of the violation occurred:
- 1. Notwithstanding the Local Control Procedures on Operator Responsibili-ties, on September 23, 1985, the auxiliary operator issued a work clearance to the maintenance supervisor on liquid poison supply check valve VP-301 even though a misunderstanding on the location of the valve VP-301 had not been resolved.
- 2. Notwithstanding the Local Control Procedures on Issuing and Receiving Working Clearance, prior to commencing work on f.ptember 25, 1985, the maintenance supervisor did not require that the operations supervisor double check the tagging but instead requested a radiation protection technician to identify valve VP-301 for the repairman.
- h. Notwithstanding the Local Control Procedures on Expanding Working Clearance and Repairman Responsibilities, on September 25, 1985, after working clearance had been received for valve VP-301 and before work was started, a maintenance supervisor improperly modified the existing switching and tagging order for VP-301 by adding liquid poison supply check valve VP-302 to the order. Maintenance was performed on VP-302
[ without the repairmen who did the work ensuring that the added equip-l ment was depressurized and de-energized as necessary.
- 4. Notwithstanding the referenced Administrative Procedure and Mainte-nance Procedure TR-74, when VP-302 was improperly added to the existing switching and tagging order for VP-301, the step-by-step description of work contained in Maintenance Procedure TR-74, l Sections 5 and 6 was not included in the tagging Order for VP-302 and was not followed before returning VP-302 back to service.
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J G leppler, Administrator 4 Big Pock Point Plant Response to IElR 85014
- March 26, 1986
Response
The repairmen disassembled the wrong valve, ie, VRD-305 instead of VP-301.
The valve was incorrectly identified during receipt of clearance by the repairmen's supervisor from the Auxiliary Operator. At the time this clearance was issued, neither VRD-305 or VP-301 had a component identification tag. This lack of component identification tags and a weakness in Local Control practices resulted in the repairmen disassembling the wrong valve.
The action taken regarding this occurrence is contained in the Corrective Action Section of this submittal and is combined with the previously described occurrence of September 23, 1985.
Corrective Action Section In regards to these two occurrences identified in the February 24, 1986 NRC Inspection Report, Consumers Power Company has taken the following corrective actions in the six identified areas of Counseling of Personnel, Component Identification, Training, Upgrading of Procedures, Disciplinary Action, and Involvement by Corporate Management in control of maintenance activities:
- 1. Counseling of Personnel Regarding the CV-4104 incident, a letter was distributed to all mainte-nance personnel describing the incident including the ramifications regarding equipment operability and personnel safety. Also in the letter, 1
the supervisors were told to provide proper working clearance and to i review this with the repairmen assigned to perform the work. If it was found that equipment identification was not present, maintenance personnel were instructed to notify Operations immediately, prior to making repairs.
This practice would assure that the right equipment was being worked on.
Repair efforts could proceed after component verification by Operations, with subsequent identification tagging.
Regarding the VRD-305 incident, a letter had been sent from the Plant Superintendent to all Operations Maintenance and Chemistry / Health Physics personnel and support group department heads describing the activities related to the improper disassembly of VRD-305. Also, meetings between the Plant Superintendent and previously mentioned personnel and department heads have been instrumental in identifying the weakness in performance, procedures or practices.
- 2. Component Identification A program has been implemented to appropriately identify Plant equipment in areas not routinely accessed. This program entitled " Component Identi-fication Program" has been completed for plant areas not routinely cntered.- Identification tags have been provided for all valves, valve operators, pumps and tanks in the Recirculating Pump Room / Steam Drum Area, '
Clean-Up Regeneration Heat Exchanger Room, and Clean-up Demineralizer Pit.
OC0386-0056-NLO4
i-J G Keppler,' Administrator 5
- Big Rock Point Plant l Response to IEIR 85014 l March 26, 1986 l
L The " Component Identification Program" will be implemented in remaining areas of the Plant with an anticipated completion by July 1, 1986.
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- An "ALARA" photograph book currently exists which contains pictures of j .some high radiation areas and rooms considered inaccessible during power operations. The book currently provides some details of equipment config l uration and surrounding radiation fields. -This book is being expanded to i identify additional major components as well as their locations and I
associated radiation fields. The book will provide a visual reference which will be utilized during pre-job scoping and scheduling. The initial expansion is scheduled to be completed by September 1, 1986. Actual completion of the initial expansion is dependent on the accessibility of areas normally considered uninhabitable during power operations. The book will be considered a "living document" such that the plant will continue to revise it appropriately as changing plant configuration demands.
- 3. Training l
l Local Control Procedures Training has been upgraded and utilized during l the last training cycle of 1985, and the 1986 training cycle to date, i This training was provided to Plant management, first line supervisors, all Operations personnel, selected repairmen, and appropriate Chemistry /
j Health Physics personnel during this period. Plant management considers
- this aspect of the proposed corrective action complete.
l Training material for supervisors of Field Maintenance Services and contractors who perform work at Big Rock Point is being prepared. This material describes the use and method of completion of maintenance orders y and procedures, the expected process of receiving workmen's protection and l the responsibility for clearance review by the supervisor of the assigned workers. This training material will be completed prior to the 1986 refueling outage.
- 4. Upgrading Procedures j
l In conjunction with the meetings conducted between the Plant Superintendent and Operations, Maintenance and Chemistry / Health Physics personnel and Support Group Department Heads which identified weakness in performance, procedures or practices, Maintenance Procedures are being upgraded to alleviate the identified problems in the conduct of valve preventative
! maintenance. This procedure upgrade will be completed prior to the 1986
! refueling outage.
- 5. Disciplinary Action The Auxiliary Operator that was involved in the September 25, 1985 incident was counseled on his actions and, because he was previously counseled for involvement in a similar event, was given a written reprimand which was placed in his personnel file. The Auxiliary Operator was then moved to a different shift and told that further inappropriate OC0386-0056-NLO4 l
J G Keppler, Administrator 6 Big Rock Point Plant Response to IEIR 85014 March 26, 1986 actions on his part would hinder his eligibility for a Reactor Operator License.
Field Maintenance Services repairmen that were involved with the CV-4104 and VRD-305 incidents attended a counseling session; expected performance
. standards were communicated to them.
Four Field Maintenance Service crew menbers were disciplined with a 30-day layoff for their involvement in painting graffiti on the containment structure. This disciplinary layoff was appealed by the Union and upheld by an arbitrator.
There is also an attached copy of Consumer Power Company's constructive discipline policy and program for OM&C in this correspondence. Consumers Power Company Corporate and Plant Management believe that the policy was effectively used to establish expected behavior and performance standards relative to the referenced incidents.
- 6. Involvement by Corporate Management in Control of Maintenance Activities On October 4, 1985 following the improper disassembly of VRD-305 the Vice President of Nuclear Operations held a meeting at the plant site. The purpose of this meeting was to review the referenced errors, the subsequent investigation, and the proposed corrective actions. These actions were described at the December 8, 1985 enforcement conference.
Corporate and Field management responsible for the Field Maintenance Service personnel visited the site on several occasions following the two referenced incidents to assist in developing appropriate corrective action. These actions include those previously described. In addition, the Field Maintenance Service management has determined that extra controls will be imposed on future outages. These include:
- 1. Single point plant contact to resolve issues and concerns.
- 2. Pre-job planning by a Field Maintenance Service Supervisor to inspect jobs prior to repairman assignment.
- 3. Additional training previously discussed in this submittal.
. #L Kenneth W Berry Director, Nuclear Licensing CC Director,' Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Big Rock Point OC0386-0056-NLO4
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! ATTACHMENT RESPONSE TO NOTICE OF VIOLATION (INSPECTION REPORT NO. 50-155/85014)
DATED FEBRUARY 24, 1986 Entitled CONSTRUCTIVE DISCIPLINE POLICY Dated March 26, 1986 0C0386-0056-NLO4
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UNION RELATIONS BULLETIN v
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Subject:
CONSTRUCTIVE DISCIPLINE POLICY Bulletin No. 79-4 AND PROGRAM - Ob!SC Date November 14, 1979 To: Personnel Directors CONSTRUCTIVE DIS ~~pLI:TE POLICY OBJECTP/E The purpose of this policy is to maintain e. stable and productive vork force.
This is eccomplished through reasonable, equitable and consistent treatment of all employees with respect to ma+ a-e involving employee discipline.
POLICY ii The Company vill establish necessary and reasonable standards of employee work performace and behavior. The Company, through its Supervisors, will communicate these standards to affected employees piccing emphasis upon (1) the importance of and need for such standards, (2) hav the standards are to be implemented, and (3) what vill be expected of affected employees.
Reasonable standards are generally accep;cd and complied with by employees.
Of these few employees who deviate from the standards to the extent of committing minor infractions, experience has shown that most vill respond to constructive counseling. Therefore, with an effective disciplinary policy, there should be very few instances thrt require actual disciplinary action.
Whenever an employee's performance or behavior is unsatisfactor/ , he has placed himself in a position forcin6 the Conpany to take action. Such action vill begin with counseling for o minor sffense. Repeated qffenses, or the first occasion of a major offense, vill require disciplinary acticn. The purpose of employee counseling und/or disciplinary action in to bring to the employee's attention the importance of altering his work perforcance or behavior to conform to acceptable standtrds.
An effective discipline policy cust incorporate all the elemente of industrial justice. The disciplinary penali.ies imposed should be equitable, appropriate for the offense and applied consistently Company-wide. The goal is to main-tain these standards when administering '.he constructive discipline policy of Censuners power Company.
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RESPCHSIBILITIES The i==ediate Supervisor is responsible for recognizing unacceptable employee work performance or behavior and taking the proper corrective measures.
The Personnel Director is responsible for providing advice and counnel to the Supervisor and other members of local management where needed on all phases of the disciplinary program, including the determination of whether sufficient cause exists to varrant disciplinary action and the extent of such action.
The General Manager (Plant and Regicn), Flant Superintendent or General Office Department Head is responsible for the effective administration of this policy in his crganization.
The Union Relations Department is responsible for coordinating the policy and providing guidance and counsel to taintain consistent application throughout the.Conpany. It should be consulted by local management, through the Personnel Department, in any instance where there is a question as to whether sufficient cause exists for disciplinary action or the extent of such action.
The Union Relations Departnent is also responsible for determining the merits of grievances heard at final conference, presidential hearing or referred to arbitration (including those involving disciplinary matters).
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CONST.UCTIVE DISCIPLINE PROGRAM IHTRODUCTION A pri=ary goal of Consumers Power Company is to provide energy and service to its customers at the lovest reasonable ecst. This can only be achieved by maintainin6 high standards of productivity and workmanship throughout the Company.
Management must, therefore, establish reasonable standards of employee work performance and behavior. Performance standards must represent a high level of productivity and workmanship. Behavior standards must meet the needs of the Company by contributing to an orderly and productive work environment while simultaneously protecting the rights of employees.
The First-Line Supervisor must maintain vork goals and expectations that are neither too easy nor too difficult to attain. Only reasonable standards of l
vork performance and behavior, effectively communicated and fairly and
(. consistently administered, vill be accented by emnloyees.
One of the most difficult tasks for supervision has been the administration i and maintenance of discipline in the verk force. Discipline tends to have i
negative overtones and is often associated with confrontation and hard
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. 3 I i Employees will respond positively to reasonable standards of verk perfernance and behavior if they are properly corrunicated and censistently applied. The tajority of employees will alco understand and support a disciplinary plan based on fair, equitable and consistent treatnent of all employees.
Most instances of unsatisfactory performance or behavior can be resc1ved by the Supervisor through assistance or counseling and without resorting to disciplinary action. The purpose of counseling is to inform the employee that his performance or be'havior is not satisfactory, to verify that he understands what is expected of him, to determine if he needs assistance in overcoting any problems affecting his performance or behavior and to encourage and help formulate corrective action.
This human relations approach to the subject of employee discipline is directed toward encouraging employees to correct any prcblems they have relating to work perfornance or behavior before disciplinary action becomes necessary.
Over 905 of all Concurers Power Company employees work their entire careers without receiving formal disciplinary action. This attests to the quality and capability of both the work force and supervision. Even so, experience has shown that disciplinary action is still required in those few instances where employees cctait tajor offenses or do not respond to counseling. These actions are discussed in the following pages.
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CONSTRUCTIVE DISCIFLIHE A successful constructive discipline progran must be concunicated and administered in such a manner that it is perceived by empicyees as a fair and equitable system to change unacceptable employee behavior. The philosophy of a constructive discipline program is to provide the employee a reasontble opportunity to bring his work behavior back into the range of acceptability.
In most cases, the Supervisor can assist the employee in avoiding disciplinary action by identifying unacceptable behavior and explaining the importance of avoiding a repeat of such behavior. This counseling vill, in the =ajority of cases, prevent recurrences.
When supervisory counseling is unsuccessful in preventing recurrence, or in cases where counseling is inappropriate, disciplinary steps must be taken.
The purpose of constructive disciplinary steps is to impress upon the employee the seriousness of the infraction and the importance of neeting the standards of acceptability. These few employees failing to make the necessary changes, after being provided the opportunity available in the disciplinary progression, are truly unacceptable.
The constructive discipline progran divides employee nisconduct into two general categories - ncnmajor offenses and major offenses. There are also a small number of offenses so serious that they do net lend therscives te constructive disciplinary action. These offences vill result in first-offense
[ discharge. In the following pages each catecory is discussed.
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1 NONMAJOR OFFEISES This category includes ' offenses that, while unaccepcable, will not normally result in disciplinary action on the first occurrence. On the first occasion of an offense in this category, the Supervisor vill counsel and alert the employee to the unacceptable behavior and explain that a second occurrence will result in disciplinary action. Should the employee nevertheless repeat
< the same offence, progressive discipline will follow. The type and severity
<>f such disciplinary action will be discussed later under a section entitled
" Extent of Discipline".
Nonnajor offenses would include but not be limited to:
- 1. Attendance-related of snses.
- 2. Low productivity.
3 Violation of safety standards 1
- h. poor workmanship.
5 Failure to follow instructions.
Although the offenses listed above vould nor ally be classified as nontajor,
[ any one of then may be viewed nore serious depending upon the severity,
-disruption, duration, hazard or damage created by the offense.
4 MAJOR OFFEISES These are violations or infractions of a nere serious nature which, based upon the circumstances, may require severe disciplinary action (but short of
-discharge) on the first occasion. Offenses of this nature vould include, but are not limited to:
- 1. Falsification of Company records.
- 2. Incubordination.
- 3. Abusive language directed at a Supervisor.
- h. Violation of the Alcoholic Eeverage Rule.
Although the offenses listed above would normally be classified as major, any one of then may be considered a more serious offense depending upon the severity, disruption, duration, hazard or damage caused by the offense.
FIRST-OFFE'ISE DISCHAEGE These are acts of misconduct of such a nature that constructive procreasive discipline steps to rehabilitate the employee are inappropriate. Such acts
{ vould constitute cause for discharge on the first occasion and require nc
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) 5 preliminary steps in the progression of discipline. Examples of these
'( infractions vould include but not be lindted te:
- 1. Theft.
- 2. Assault or threat of physical violence.
3.- Sabotage.
- h. Curbing of meter reads.
Conviction for violation of a lav vhile off duty would be viewed in teres of
.its effect on the e=ployer.
THE NATL"1E OF THE DISCIPLINE Unless e=ployees are aware that certain actions constitute a violation or an act of misconduct, takin6 disciplinary steps a6ainst them is clearly inappropriate. This requires that management provide e=ployces vith clear instructions of what is expected of then in terns of work behavior. This information can be supplied in a number of ways, including:
I. New employee orientation.
- 2. Prior counseling sessions by the e=ployee's Supervisor.
g 3 Information passed along to employees durin6 general department meetings, safety meetings or headquarter meetings.
L. Work rule postings on bulletin boards.
5 Safety and Work Standards Manuals.
Listed below are the conditions necessary to initiate disciplinary action:
- 1. A reasonable rule or standard must exist.
- 2. The employee cust be aware of the standard and that violation vill result in disciplinary action.
3 There must be clear evidence of a violation of the rule or standard.
Conmon sense dictates that such things as striking another employee, striking a Supervisor, stealing Company property, carrying firearrs on Company property and other offenses of this nature are obviously not tolerable and, therefore, need not be specifically covered by explanations.
CAUSE OF DISCIPLINAF.Y ACTION When counseling has failed to prevent an employee from repeating a nonnajor offense, or when a more serious act is committed, disciplinary action c.ust be
'[ Before any action is considered, however, the circumstance involving taken.
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the incident rust be reviewed to deternine if cause actually exists to warrant discipline. In some cases, what initiall;. appears to be an act of misconduct, when investigated, may not be sufficient cause to take disciplinary action.
This investigation nust take place as scen after the incident as possibic.
(The status of the employee immediately following the incident vill be
! discussed under the section entitled "IIotification and Suspensicn".)
L ?!OTIFICATIO I A'ID SUSPENSION
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it is essential that prompt supervisory action be taken when an offense is suspected. Delay in bringing the unacceptable behavior to the employee's
! attention tends to mininite the importance of the event and may nullify subsequent management action. Should the Supervisor determine that immediate disciplinary action is warranted, the exployee is to be so notified.
In cases of repeated nontajor offenses, a major offense or first-offense discharge, the Supervisor may place the employee on suspension, without pay, for the purpose of investigation. The employee should be notified of the reason for the suspension and, at the stre tite, be given a specific date and time onshich to either call or return to the headquarters for discussion of the investigation.
In either case, the employee may be returned to work and taken off investigaticn status if it is determined that the alleged infraction does not constitute an i offense requiring disciplinary action.
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l l After cause and the type of infraction have been determined, the a= cunt of discipline to be imposed must be decidei upon. (The arount of discipline vill be discussed under " Extent of Discipline". )
IliVESTIGATION This is probably the cost vital step'in the constructive discipline program.
All the facts surrounding the incident rust be gathered. This involves obtaining the answers to six important questions: Who, what, where, when, why and how? After 6athering and thoroughly evaluating all the facts of the case, and prior to deciding whether cause for action exists, the employee must be provided the opportunity to present his explanation of the incident. (The topic of Union representation during this interview is covered later.)
When all the facts have been gathered, great care and objectivity must be exercised in evaluating then to. determine if disciplinary action should be taken. If the evidence does not suppor; cause, no action is to be taken.
Decreasing the extent of penalty to conpensate for lack of evidence defeats the objective of a cound discipline progrE and is to be avoided.
If the employee was suspended for investigation and it is determined that no cause for discipline exists, he =ust te inforced immediately that he vill be reinstated with no loss of pay er benefits. The employee should be told that g
while the action was necessary at the time, it has proven to be without basis and vill not be a part of the enployee's record.
T UNION REPRESENTATION During a disciplinary investigation, an e=plcyee nuat be provided the oppor-tunity to present the facts as he views them. The employee vill be provided Union representation at the investigation interview if requested. Under unique circumstances, canagement may arraage for Union representatien without the employee's request. The Personnel Director will assist with problets of this nature.
When an employee believes that an interview may lead to disciplinary action, Union representation vill be provided upcn request.
ET'E'I? CF DISCIPLINE All efforts to this point have been directed toward determining 's cause does exist. Once cause for disciplinary action is firmly established, the type and appropriate arount (or' extent) of discipline cust be deternined.
Any discipline program, to be successful in changing employee behavior, rust avoid inconsistencies in the extent of discipline for the case offensca under
'similar circumstances. Thoughtful consideration must be given this decision.
If an employee is unsuccessful in changing his work behavior and repests a nonnajor violation after the oral warning counseling session, disciplinary action is in order. The constructive disciplinary progression includes the l
following steps:
- 1. A formal letter of discipline.
- 2. Short-tern disciplinary layoff (1 to 5 verkdays).
3 Long-term disciplinary layoff (2 calendar weeks to 30 calendar days).
- h. Discharge.
The formal letter of discipline must inform the employee of the violation, clearly state what is expected in the future and specify actions the Company must take if the violation is repeated. Specifically, the crpicyce is to be told that future disciplinary layoffs and ultimately discharge vill follow if the violations continue. The subsequent disciplinary steps are to be imposed with repeated nonrajor violationr .
Disciplinary action for major violations vill not begin with the fortal-disciplinary letter but vill involve a disciplinary layoff on the first offense. The steps of progressive discipline may be varied slightly There depending may upon the circumstances of the case and the category of violation.
be mitigating fac' ors that vill have an influence on the extent of discipline. i
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The mitigating factors would include, but not be litited to, such iters as:
- 1. Unique circunstances surrounding the infraction.
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- 2. Length of employee's continuous service.
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( 3 Time since last disciplinary action.
- h. The nature of the last disciplinary action.
5 Unique circumstances that may have an influence on the employee at the time of infraction.
When cause is established for a first-offense discharge, there is normally only one avenue to follow and that is discharge. Mitigating circumstances rarely justify any lesser action.
The detertination of the extent of discipline requires a great deal of thought and care to insure that the discipline decided upon is neither too severe nor too light for the infraction and the individual circu= stances of the case.
Re=e: bering the cbjective of this policy, other nenbers of local managenent and Union Relations should be consulted on any question of doubt regarding the extent of discipline. -
U'IRELATED OFFEI!SES .
While the. constructive progressive disciplinary steps are rather casily applied to repeated infractions of the same nature, these steps must be varied somewhat when applied to infractions that are not of the same nature. For instance, an employee who has received a disciplinary letter for an attendance-related offense subsequently viointes a safety rule. Should the employee's progressive g
discipline start again with counseling, another letter or should the extent of penalty be baced upon the earlier attendance infraction?
While it is difficult to make these determinations, it should be re=echered that progressive discipline is based upon the theory that increasing penalties vill alert the employee to the importance of complying with a rule previously -
violated. To say that one disciplinary letter written for one violation serves as the disciplinary foundation for all subsequent infractions of anz, nature is not reasonable. This vould truly detract from a constructive discipline progran.
On the other hand, en employee who repeatedly commits acts of miseenduct that are unrelated does, at some point, demonstrate inability to conform to reasonable and acceptable workplace behavior. This point ic reached when various disciplinary j measures fail to bring the employee's behavior back into the range of accept-ability. The conclusion is that past progressive discipline has proven ineffective.
Therefore; future disciplinary steps could not be expected to be successful.
When this is evident, disciplinary penalties may be based upon the entire past disciplinary record regardless of the nature of the infractions.
CHANGING PRACTICE When it is apparent that an existing practice or behavicr has becore unacceptable or intolerable, it must be changed. For example, the scheduled quitting time g
may be known to be h:30; however, over the years, it has not been strictly enforced. Another example vould be a posted safety eye glass area which, through oversight or ned lect, has not been enforced.
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.. 9 A reasonable approach cust exist to inplement a fair and orderly change. The best method to resolve a problem of this type is to hold a meeting for all those c=ployees who will be affected by the change of practice and informing them of the change in practice and exrleinine the rencons for the change. In this way, employees are more likely to accept and adapt to the change in practice.
ATTE'TDANCE Questions are always posed as to how attendance-related problemn are handled.
Following is a brief outline concerning absenteeic=.
The Attendance Improvement Program currently in use for Oy&C employees provides a counseling procedure to assist enployees in improving their attendance records.
This program is utilised in the hope that employees who have unsatisfactory attendance record: vill be able to irprove and bocene acceptable enricyees.
Enployees need to 'oe given an opportunity to demonstrate that they are capable of reaching and maintaining acceptable levels of attendance. Hcvever, if the Attendance Improvement Program fails to help employees reduce their absentee problems, the Company has no choice but .to take disciplinary steps.
Aside from attendance-related offenders , there are some employees whose health' Even though abuse is not or other circumstances result in excessive absence.
involved, the absence record may truly be unacceptable and cannot be tolerated.
Cases of this nature ray involve continued poor health, domestic problems or l other circumstances.
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If the Company has nade reasonnble efforts to e=phasize the importance of acceptable attendance and there is no reasonable prospect that future improvement -
is likely, steps vill be taken which could ultinately result in ter=ination due to unavailability for work.
These cases involve unique circumstances and, therefore, careful coordination with the Personnel Department is essential. Conventional progressive disciplinary steps are not involved because the cource of the problem may be beyond the control of the employee. Eventual discharge in these cases may appear extrece but it is equitable when excessive absenteeism makes the enployee's services unavailable.
CONCLUSION Administerin6 disciplinary action is by no means a simple task. There are no set patterns or rules to be applied that will accornodate all of the facts of each case. The objective of any prograr must be designed to first notify employees of a violation and then assist them in complying with acceptable work standards l prior to imposing any disciplinary action. Employees who are unable to attain or maintain acceptable verk perforcance or behavior nust receive constructive j
i pr creasive discipline. Such neasures nust be designed to point out the severity
' of ' heir actions and clearly indicate tha necessity of improving their behavior.
In most cases, employees vill return to the range of acceptable work behavior. j l
Unfortunately, there are isolated cases where improvement does not cecur and-no alternative remains except further disciplinary action or, eventcally, r I
l This action should not be taken unless all other reasonable avenues discharge.
of constructive progressive discipline have been exhausted. l l
The Company reserves the right to take necessary changes at any time.
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