ML20207F858
| ML20207F858 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/31/1986 |
| From: | Jens W DETROIT EDISON CO. |
| To: | |
| Shared Package | |
| ML20207F722 | List: |
| References | |
| FOIA-86-430 NOD-38, NUDOCS 8607220627 | |
| Download: ML20207F858 (5) | |
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DETROIT EDISON NOD 3c)
FERMI 2 Revision 1 NUCLEAR OPERATIONS DIR~CTIVE Page 1 January 31,1986 CLARIFICATION OF DISCIPLINARY POLICY PURPOSE The purpose of this directive is to cl'arify Detroit Edison's Corporate disciplinary policy in order to recognize further limits on behaviors which are unique to the nuclear industry in general and to Fermi 2 specifically. This directive also sets forth certain minimum actions which will result from violations of such limits to help ensure all personnel are aware of requirements ' nd the a
consequences of noncompliance. It is the intent of this directive to increase the safe operation of the Fermi 2 facility.
GENERAL POLICY Corrective action to prevent recurrence of problems, events and errors requires that they be described promptly and accurately. Subsequent action should be remedial with the primary emphasis on figng the equipment or procedure or retraining the person that made the erro,
therefore, fact finding and corrective action must precede any disciplinary action.
t While Nuclear Operations fully endorses General Order 191, Disciplinsry Procedure. certain characteristics of employment at any nuclear site impose restrictions on behavior which exten:
beyond those anticipated by corporate policy makers. Actions which you may not necessarily consider serious in and of themselves become magnified when viewed in the light of adverse i
regulatory, legal, and public impact. It is therefore incumbent on all personnel assigned to Fermi l
2 to increase their sensitivity to Fermi 2 rules and federal regulations that the management team f
is committed to accomplishing it is recognized that violations may be purposeful but well intentioned, or completely accidental, in either. case, violations are not acceptable. Examples of 1
i violations may include, but not be limited 10, the following:
Honest and prompt disclosure of a problem or error may mitigate any disciplinary action.
Conversely, covering up and dishonesty willlead to even more severe discipline. These factors j
should be carefully considered by a supervisor before issuing discipline.
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G NOD 38 Revision 1 Page 2 SPECIFIC POLICY 1.
Physical Security Plan Violations (Security requirements in the orientation training summarized in the Fermi 2 handbook.)
Minimum action: Suspension of unescorted access until such time as the individual requalifies on the Seccity module of
- Orientation A* and any associated Security Plan implementing Procedures. Unescorted access will be reinstated after a consultation between the individual and the supervisor to minimize the likelihood that the individual will repeat the violation, and upon the recommendation for reinstatement by the supervisor with approval of the Assistant Manager, Nuclear Production. A repeat of any such violation will result in more severe disciplinary action.
2.
Procedural Violations Safe operatien is the paramount requirement in carrying out any discipline. Obtaining the facts and taking remedial action should precede any discipline.
Minimum action: Removal from assigned job functions until such time as the individual requalifies (within 2 working days) on Procedure Compliance, Module 1, and on any training associated with the procedure which was violated or ignored. Documentation of, a consultation between the individual and the supervisor to minimize the likelihood that the individual will repeat the violation is required when the supervisor requests reinstatement of the individual's responsibilities. Return to normal job functions wil: be allowed on approval of the Superintendent or Director of the individual's organizational u nit.
A repeat of any such violation will result in more severe disciplinary action. In addition, if a procedure violation results in an NRC noncompliance or a licensing event covered under Title 10 Code of Federal Regulations Part 50.73 (10CFR50.73) or 10CFR73.71, disciplinary action must be considered.
3.
Insubordinate Actions Constituting Disregard or Challenge of Rules and/or Properly Constituted Authority (such as Health Physics Technicians, Nuclear Security Officers.
Operators, Quality Assurance personnel, superviscrs)
Minimum action: Suspension without pay for a minimum of one day.
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]'it NOD 38 i
Revision 1 Page 3 f)(w These actions should be viewed as the minimum required in any of the stipulated situations.
],i They do not supersede or supplant the provisions of General Order 191 which shall be invoked as appropriate in the context of an individual's disciplinary history, in this regard, violations such 1.j as those described above, which have been committed prior to approval of this directive, will be y
considered when applying the provisions of this NOD. Except for a new employe still in the j'
probationary period, discipline normally is progressive, starting with oral and written warnings and continuing to suspension, demotion and discharge as the offenses become more severe or repetitive. Where the offense is serious and employes deliberately violate standards of good conduct, however, they may be discharged without having been previously disciplined, i
3 Copies of all disciplinary actions are to be directed to the Director, Human Resources and j
Administrative Support Services.
BL f.
W yrip H.Jens Vice President Nuclear Operations Paragraphs 1 and 3 are added in the
- General Policy
- section and Revision Summary:
Paragraph 1 in item 2 of tne " Specific Policy
- section is added.
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DOITOlt Edison ".rc '
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February 6, 1986 To:
Joseph H. Korte W ear Sec
'ty oordinator 3
h From:
lter P
, ohs mclear Security Chief
Subject:
Tenerarv Zone Dc/iation - Corrective Action During an internal security audit, January 19-24, 1986 a concern was revealed dealing with the current policy in regards to Te::porary Zone De/iations. It was discovered that under the system in use at the time certain sections of SPIP 4 were not being followed. Since the systen to Iglement tenorary zone deziations in use at the time showed a potential for N!C violations it was amended.
The new system does away with the " Log Book" concept and has
" authentication" rcquirements in accordance with SPIP 4.
The " memo" form has been modified and requires authentication to be received.
The meno form is divided into 2 sections. The top portion for making the zone de/iation and the bottom portion for the deletion of the zone. In addition the ACO who removes the zone places his initials next to the deletion entry. All active Terporary Zone Deilation are kept in a 3 ring binder at the A-1 location. Once the deviation expires it is removed from the active book and placed in the inactive book.
To insure this is being coglied with the SL will conduct an audit of the bock once per shift. In addition the NSC conducts unannounced audits of the tenporary zone deviations on a random basis.
KPH/gjs cc: file L.W. Hastings S.L. Thonyson f/
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y w w m x. m a g w: w n g, ~ - w w.e. u.w m p ; a February ll, 1986 Note to Editor For your information, ettached is a brief report by an independent overview conmittee, composed of recognized nuclear power experts, which Detroit Edison established to identify, evaluate and analyze proble=s with management, management structure and management systems at the Fermi 2 Power Plant:
The company announced the formation of this committee in its January 29 letter to the Nuclear Regulatory Commission.
Significantly, the committee said the recomendations and actions needed to resolve the problems are not prerequisites for startup.
Detroit Edison has forwarded this internal report to the NRC and ; i3 9? G also is making it available to the media.
The company is also working closely and expeditiously with the committee to implement its recomendations with one single purpose - the safe and efficient operation of Farmi 2 In evaluating this report, please keep in mind that:
1.
Detroit Edison voluntarily established the independent overview committee and asked it to identify problems only.
2.
In accordance with its charter, the committee concentrated exclusively on problems and did not ecmment on "what is right" at the plant.
3.
The ccmmitteo's report caid specifically that " Detroit Edison necessary action to resolve the problems listed.p.the has sufficient managemont capabilities to develo 4.
The committee said that resolution of the problems that it identified does' not have to precede restarting the plant.
5.
While Detroit Edison accepts the report and intends to carry out all of its recenmendations, the ccmpany has already addressod, and intends to fully resolve, all of the problemn identified by the cc:cmittee.
Enclosed, together with the comittoa's full report, are coplos of D1troit 2dison Chairman Waltar J. McCarthy, Jr.'s lotter to
. 30 vith -4!:h ha forwar f 2d the c:enittM's riport to the th 2 T C =ission aa v11 as his ecmpohansin Janusry 29 1.ett3r to th Commission.
If you naod additional information, p12sae es11 us, p
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ausessensa M ese Y" February 10, 1986 Nr. Damas C. Keppler Regional Administrator Region !!!
U.S. Nuclear Regulatory Cenaission 799 Roosevelt Reed Cien Ellyn, Illinola 40137 Nas Report of Independent Overview cannittee Dear Mr. Kappler As set forth in my letter or 3anuary 29,1986,(VP-88-0008)
Detroit Edison Capany has established an Independent Overview Committee, one of whose purposes is to provide Detroit Edison manegement with recosnandations for improvir.g management of Fermi 2.
The Independent Overview committee ast on Friday, February 7, 1986, with the Noelaar Arview Ccamittes of the Detroit Edison Board of Directors, a ocsnriitt'oe censisting of four outside Directors of ovr Cc29any. At this meeting, the Independent Overview Cr.saittaa presented its first report, a ecpy of which I encloeg herewith.
Although I did not have a espy of this report prior to my letter to you of January 29, 1986, esebers of the Independent Overview Comunittee reviewed drafta or that letter and made careents which vere incorporated in the final eutnittal.
Therefore, a number of actions to respond to the matters raised in the report are already undar way. Detroit Edison sanagement has ocermitted to our Board Nuclear Review Coneittee, not only to accept and implement correctiva actions with respect to the six roccamendations of the report, but sloo to address the problems Adentified by the Independent Overview Connaittee as the underlying factors which were the beels for the recommendations.
I thit* It le especially important to note the Independent Overview Committee's finding that, "We consider the recommendations and the actions to rssolve the problems ars not prerequisites for utsetup."
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Mr. Demos C. keppler February 10, 1986 Page 2 The Cverview Committee will continue with its charter as previously described to you in my January 29, 1988 letter. Ao future reporta become available, they will be forwarded to you.
As I have previously indicated, it is my intent to maintain oversight and review by the Independent Overview Committee, the Detroit Edison Board Noelear Review Ccanittee, and myself until we are satisfied that this plant with its new management, its plant operators, end its support ateffs have demonstrated satiafactory performance as measured against other plants and the perforamce critaria established by the Institute or Nuclear Power Operations. Termi 2 will only be operated in a manner which ensures the public health and saraty.
Very truly yours, r
Enclosure
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i FDMI 2 INDEPDCENT OYERVIEY CCHITTEE EVALUATION CF DETROIT EDISON MNOW XEhT AT MMI 2
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EVALUAT10M CF Ctilt0IT EDISCM NTNT AT TEml 2 FERMI 2110EPEHDENT OVERVIEN CCMITTEE M
The purpose of this report is to. present the results of the Independent Overview Coantitee's evaluation of the Forst 2 management in accordance with that Cosmittee's charter.
The Comnittee has been directed to identify..
evaluate and analyse problems with management, management strveture, and management systems.
INTRODUCTIQq the Adefatstrator for Nuclear Regulatory By letter dated December 24, 1985, Commisston Region III requested that Detrott Edison furntsh a response describing plans e.rd programs to address management and progreenatte wea identtfled by the Nuclear Regutatory Commfssion.
accordance w1th the provtsfons of 10CTR50.54(f) and, spec 1f teally reques Detrott Edison to evaluate and address:
'The adequacy of manag'ement, management structures and systems that h contributed to the performance of Formt 2; the adequacy of training to assure that responsible persoons) recognias and respond, as appropriato
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to significant safety conditfons; and, changes assure taproved 'rsgulatory performance.
The arens of operations, mainteoance, engineering and security should be included in your evaluation,'
As part of Detroit Edison's program to respond to this lettor. this Indenn Overview Ccentttee was formed to provide adyfee t full power operattoa.
The Ce ntttae met intttt11y with the Chafrman of the Board and chfaf Exec Officsr, the Prostdsnte and the Ytes Prssident, Huc1sar Op the Cosnittee's charter.of this Committee and indicated that channels ar i
with the Personnel at all levels, with the Board Nuclear Review Cosatttet, 5eard af Directors. ftselfe or with any of its seabers.
l During a one wsek' period, the Committee as a whole, or in groups of members, latervtaved the Vice Prestdant, Nucle Plant operation, maintenance, engineerfag, licensing, quality assurance, l
In cddition,. :ta entire occurity, ad.stnistrativo sarvtess, and trafstng.
l Ccamitt>> also intarvt:ved the Nuclaar :tsgulat:ry Cczutssten Scator Inspector.
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313 586 2798 Durfog ceveral assstens, the Committee evaluated end ctmartzad tu prcS1ces identiffad durfag the intervfers and devoleysd rm.andattens f'or peasthis corrective actica.
In reaching tto camelvatons, the Conetttso tock advantaDa of thz expertence with Feral 2 uhtch scos of its moders have, etthor as members of the Nuclear f>afety fleview Group, as adytner to the plant manager, or as participants in other technical and manageeont ucrk at For:al 2.
PROBLD4 IDENTIFICATION MC EVM.UATICM We recognize that the Fermi 2 oparating staff particfpated 13 plant ecapletton and fn the startup testing program up to five porcent pcwor.
Furthermore, we find that manasseent personnel are conscious of the need for safety la the operetten, malatenance and support of Farmt 2.
While many elements of managwent are satisft.ctory, there era problems which have prevented the orgenfration from achiaving the hfgh standards of performance to which Detroit Edisoa is' coevatttod.
Durfag the intervf avs, it was apparent that most of thess problems had already been recognt:64 by those persons intervfewed. Following is the Independent Overview Ccemitta4's suemary of the principal prob 1ses. We look forward to roviewing the responses to each of the problems identified below.
A.
Lock of Conmeref al k:1sar Power Plant Cotratino Exoortenet Of the levels of management and supervisfon from the Chairman of the Board down ta the Nuclear Shift Supervisors, there is virtur.11y no exporfonce wf th opsratf ng a coernercial aucisar parar plant. However, l
soma personnal.h4Ys B3Y31 Pa8Clar op5 rating experf 00C2 Dad others havS been assigned for ahort periods at cporating nuclear plants cened by i
other utilitias.
B.
Leadershis 1.
Subordfnates often do not know who is in charge, :nd la sano cases have the impression,that nobody is in charge.
2.
t,ack of a constatent definitten or atssion fr.htbtts approprints ection.
3.
kanagers ars esluctant to define goals and rorpensthfif tf as and then require lower tier nanagers to carry thos crit.
4.
The tendency of some upper level managers to engage in etcromanagement reduces the effectiveness of lower level managers i
and evporvisors.
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Managers fati to hold their subordinates aceovatable and fatt to follow up ts verify accomplishment of as 1gned work.
2.
In a few cases, demonstrated lack of management ability ta accepted rather than corrected.
D.
Manacement Ineffectiveness 1.
There is scoe reluctance to face facts, toer.ttfy problems.
estabitsh their sources or root causes, work toward timely and offective solutions, and take action to prevent recurrence.
2.
There is evidence of lack of effective tsamwork eithin the organization, in terms of concerted, corstned efforts to support the needs of an operettag plant.
3.
Nuclear Prodvetton does not.always receive the necessary support from other organtzstions at Ter'at 2.
4.
Plannfag ia pot offeetfwe for e1ther shert-tana er long-tera activtttes, and 11tt1s constderation is given to conttagency pitantag.
5.
Unrssalved interdepartmental confilets perstat.
G.
Excesstys orevnts of ttae are t.ksn to taplement important agreements, manageoent directives, and preesdural changes.
7.
Line managment often abrogates its responsibilf ttes by depending upon doctsfons by committee, a practica which results la too sany moottags.
E. Crenntratten
- 1. The dtvision cf responsibilttles within Nelear Engfnesttag 10 ect well h1anced and reduces overal) offectiveness of the organizatica.
2.
The tality Assuranc5 ergantaatton does not report to a level of amnegement consistent with the necessary emphasis on quality.
F.
Menacement Snteep 1.
Adatatstrative procedurss and controls are oxesssitaly rigid and emberscue.
2.
Thors is no integrated systaa in uso for planning. cchsdvling and estabitshing ">rforittis for Nuci w Cparattens..
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/.i int w,t r t,m RECO'FOCATICNS Ife conalQr that Cotroit Edfson bas sufficient management capab111ttes develop the necessary action to resolvo the problems 11stod above. Mcvever, tr.
the course of our dollberations, as formulatM a number of roccmandatica; which, if adopted, sheutd result ta ever:11 fr.provomonts in the organtastica and management. Ife consider the roccmandations and the actions to resolve the probicas are not pror:quisitos for startup.
1.
Intenstfy and expaM efforts to recruf t and hire personnel for certatti key managesant positions who have extenstye experience with operattoc commerctal nuclear povar plant:),
with particular attention to Positions in sanfor mana2ement.
2.
For the Yfes President, Welear Cperattons, provide an advfsor vhe has extensive cour.arefal nuclear persr plant exportance, to serve in that capacity untti ths roccemndet recruitment efforts are successful.
3.
Emphastas to other site orgentzations the importance of full; espporting kclear Productfen, with particular attentton to resoluttee of conflicts with engfacoring, edstnistration and security.
A concertad tor.2 effort is needed to eltatnato organfzational cad procedural impodteents to accceplishing operattenal and cutatonance objectives.
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4 Establish challongtas prforsarce seals at all lovs1s of sanagoeant and, through a syste:S of parfor:ance indfestors, coatter progress toward achfoycsut of thus Ccals.
5.
Realfga the orsint atfcul structurs ef Nuc1ssr 2nsinooring and strengthan its ovarall canagement.
I 6.
Acqvtre an expertenced evetear security professtonal to improve the overall effectiveness of the foctrity organisatton.
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