ML20210K623

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Responds to Forwarding F James Re Facility.Disagrees W/James Perception That NRC Attitude Towards Public Is Annoyance.Mgt Problem at Util Will Be Resolved as Result of Listed Actions
ML20210K623
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 04/22/1986
From: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Levin C
SENATE
Shared Package
ML20210K627 List:
References
NUDOCS 8604280405
Download: ML20210K623 (7)


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l The Honorable Carl Levin ~ United States Senate Washington, DC 20510

Dear Senator Levin:

This is in. response to your letter dated February 13, 1986, regarding the correspondence you enclosed from Fred James of Monroe, Michigan. Mr. James stated in his letter dated December 28, 1985, a number of his concerns related-to the Fermi-2 facility. l In his letter to you, Mr. James makes' three separate points. The first of these is that his confidence in the safety.of the Femi-2 facility has been _ eroded by Detroit Edison's (DECO's) reluctance to inform the NRC of potential i safety problems and by his perception that the NRC's attitude is "that the public.is an annoyance that simply must'be tolerated." He also states that there are too many critical unanswered questions concerning the Femi-2 facility and suggests that a Congressional investigation of these questions might be appropriate. With regard to Mr. James' first point concerning DECO's apparent reluctance to promptly inform us of potential safety problems, the NRC has previously noted l this_ problem and openly criticized Deco for it at a public meeting held at our Region III Offices in Glen Ellyn, Illinois on July 23, 1985. Deco's apparent 4 reluctance in these matters is a factor in the current restrictions which the NRC has imposed on the operation of the Fermi-2 facility. We believe that the management problem at DECO will be resolved as a result of: (1) our public meetings with DECO on July ?3, and. September 10, 1985; (2)'our 4 direct communications with DECO's top management; (3) our letter dated December 24, 1985, in which we requested additional information from DECO.so that we could determine whether the Fermi-2 operating license should be modified, suspended or revoked (Enclosure 1); and (4) our continued close surveillance. i DECO's enhanced sensitivity to the matter of informing-us of potential problem areas is illustrated by its establishment of an Independent Overview. Committee 4 which has stressed the need for frank and forthright communications within DECO. itself and with the NRC (Enclosure 2). With resrect to Mr. James' perception that the NRC's attitude towards tke public' is that the public is an annoyance, I must disagree. Beginning.with the application for a construction permit for the Fermi-2 facility, and continuing through the issuance of the operating license, the public is given access by. . law and by agency policy to substantial information pertaining to safety issues and-environmental matters. For example, we have established in the community near the Fermi-2 site, a Local Public Document Room (LPDR) where all formal-communications, inspection reports,~NRC staff Safety Evaluation Reports', environmental assessment repons and similar material are maintained. All 1 } 8604280405 860422 PDR ADOCK 05000341 - H PM g

, 3. M -. s a - r these documents are available for public inspection in the Monroe County Library System, 3700 South Custer Road, Monroe, Michigan 48161. These documents are. also available for public inspection at the NRC's PDR at 1717 H Street, N.W., j '. Washington, D.C. 20555. 4 Most of our meetings with the licensee are open to the public. Some are held at the plant site with provision for public attendance. We have responded to all questions from the public at the end of these mestings. In response to ~ the questions of one of the Monroe County Commissioners and the interest - 4 1, expressed by other members of the community,'.we have sent some of our senior Region III management to meet with the County Consnissioners. To keep the County Commissioners promptly informed, we and Deco have placed them on our distribu-tion lists to receive copies of all correspondence between Deco and the NRC.. I do not believe these actions support the view that the NRC treats the public as an annoyance to be tolerated. Because Mr. James has not provided any specific reference to an action or s.tatement which may have led him to his perceptions about our alleged attitude, we cannot respond more definitively. i The second concern expressed in Mr. James' letter is that there are too many critical unanswered questions concerning the Fermi-2 facility. We have brought. l each of these safety issues to the attention of the licensee and required it to resolve them in an acceptable manner before we would consider = the question of restarting the Fermi-2 facility. As an example, we have told the licensee that it must propose and successfully implement a program which will demon-strate that the Fermi-2 emergency diesel-generators can reliably perform their I intended function. We have taken a similar position with respect to the required analysis of all modifications to safety-related piping systems', including embedments. DECO's response in its letter dated January 29,-1986, to our positions on these j various safety concerns transmitted in our letter of December 24, 1985 (Enclosure 1), indicates that it understands the need to resolve these' issues and ths need to avoid similar problems in the future. This letter transmits DECO's "get well" program;.we ara present1/ reviewing this submittal. Finally, Mr. James suggests.in his letter that the.only way critical' issues can be resolved may be through a Congressional investigation. His basis is that this would require witnesses to. testify under oath. While.a Congressional investiga-l tion could be convened at the discretion of the appropriate Congressional.com-- mittees, we do not believe this is necessary. For all safety-related matters, our regulations require that the licensee submit its written proposals signed 1 i under oath or affirmation. Further, if we determine there is a need for.an investigation into the conduct of Deco's employees, we can and have interrogated the licensee's staff under oath. On this basis,.we believe that our normal ] review process of the safety issues at the Fermi-2 facility and our investiga-1 tory process will achieve the goals which Mr. James seeks.- W 4 [- s s .~

A i p Y ..I. hope that this letter responds fully to the. concerns raised by Mr. James.. IfL we can provide additional information on these and other issues related to the Fermi-2 facility, please contact us again. i ~ -Sincerely, Original sirned by Victor Stel > + Victor Stello, Jr. Executive Director for _0perations

Enclosures:

~~ 1. Letter-to DECO Pursuant to

c 10 CFR 50.54(f) 2.

Report of the Independent Overview Committee dated January 30, 1986 J f 4 4 2

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, A,n f j . I hope that this response clarifies the issues raised by Mr. James. If we can provide additional information on these and other issues related to the Fermi-2 facility, please contact us again. Victor Stello, Jr. Acting Executive Director for Operations Enc 1csures: 1. Letter to DECO Pursuant to / 10 CFR 50.54(f) f 2. Response to Mr. James' neerns before the Monroe Coun Commissioners N N .i 4 D-3:DRL D

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a. f DISTRIRtlTION: (Green Ticket No. 001467) Docket No.' 50-341 NRC PDR* Local PDR* EDO 001467 EDO r/f. HDenton/DEisenhut Glantas 'BWD-3 r/f OELD (puRNS) - OCA (9t) Secy (S) g6 -/9 g VStello DMossburg (EDO #001467) RBernero DLynch EAdensam EHylton JTaylor JKeppler 6 i 2

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34 FROM: DUE: 03/43/86 FDO CONTROL: 001467 DOC DT: 02/13/06 SEN. CARL LEVIN FINAL REPLY: TO- - KAMMERER ~ FOR SIONATURE OF: GREEN SECY NO: 86-178 EXECUTIVE DIRECTOR DESC: ROUTING: ENCLOSES LETTER FROM FRED JAMES RF SAFETY OF KFPPLER FERMI II TAYLOR DATE: 02/27/86 ASSIGNED TO: NRR CONTACT: DFNTON k- ~ _ _. SPECIAL INSTRUCTIONS OR REMARKS: GV MARK ENVELOPE ATTN: KAY DEKUIPER <f N o t/8N db NRR-RECEIVED':1..102/ /86' gACTION:. /7 DBLT BERN5it0? %2 a _s,- ~~.-- NRR ROUTING: DENTON/EISENHUT PPAS MOSSBURG

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET l PAPER NUMBER: CRC-86-0178 LOGGING DATE: Feb 25 86 ACTION OFFICE: EDO AUTHOR: C. Levin --Const Ref AFFILIATION: U.S. SENATE LETTER DATE: Feb 13 86 FILE CODE: ID&R-5 Fermi II

SUBJECT:

Newspaper clippings and remarks concerning the Fermi II fac and its safety ACTION: Direct Reply DISTRIBUTION: OCA to Ac SPECIAL HANDLING: None NOTES: DATE DUE: Mar 6 86 SIGNATURE: DATE SIGNED: AFFILIATION: Roc'd 0*1. too se.. . A-A M/ 6 Time..... j s % ] EDO 001467 4

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======..u., n NC p, a am, Docket No. 50-341 ) Detroit Edison Company ATTN: Wayne H. Jens Vice President Nuclear Operations 6400 North Dixie Highway Newport. MI 48166 Gentlemen: The Detroit Edison Company's Femi 2 Nuclear power plant has experienced numerous events involving operational errors and degraded plant equipment. Furthemore, programatic weaknesses have been identified by the NRC concerning engineering and security. A number of the events occurred despite the efforts i of your Company to improve the regulatory perfomance of the Femi 2 station. l The events of concern can be attributed to four functional areas: operations, maintenance, engineering and security. The operations group, and to a lesser extent the maintenance group, were responsible for a number of the events i including; (1) the premature criticality. (2) a license violation which shut off cooling water for an entire ECCS Division. (3) six technical specification limiting condition of operation violations. (4)(multiple personnel errors.6) an "unnon (5) rupture of the condensate storage tank and slightly contaminated water from the site. The engineering staff was responsible in part for (1) failure of the south reactor feedpump turbine. (2) failure to perform proper stress analysis following system modifications, and'(3) error in routing a 4160 volt bus in the same vicinity as the remote shutdown cables without proper fire protection. The security organization has been unable to properly implement the pecvisions of the security plan as evidenced by the numerous violations ider.tified by both Detroit Edison and the i NRC. The diversity of problems and functional areas involved with these problems indicate to the NRC that the present aantgoment systems have been ineffective. If left uncorrected, and current trends (.ontinue, significant safety problems may develop at the Femi 2 facility. Act.ordingly, to enaole us to determine whether or not the Femi 2 license should be modified, suspended, or revoked. you are requested, pursuant to the provit. ions of 10 CFR 50.54(f). to evaluate and address the following:

..,.g7. tr 0 - l,. Detroit Edison Company -2 DEC 2 4 G85 1. The adequacy of management, managemer.t structures and systems that have contributed to the performance of Femi 2; the adequacy of training to assure that responsible personnel recognize and respond, as appropriate, to significant safety conditions; and, changes in controls needed to assure improved regulatory perfomance. The areas of operations, maintenance, engineering and security should be included in your evaluation. .2. Actions you plan to take to ensure readiness of the facility to support restart of the unit and power escalation after testing is completed at each power ascension plateau. Include in your assessment how you will review the management and system performance at each plateau, who will perfom the review, objective criteria for determining adequacy of perfomance at each pir.teau, and the manager who will authorize proceeding to the next plateau. 3. Actions you will take to improve regulatory and operational performance during and after the startup testing phase of operations. Pursuant to 10 CFR 50.54(f), you are requested to furnish, under oath or affirmation, no later than 30 days from the date of this letter, your plans and programs to address the items identified above. Sincerely. m b ha b O [/JanesG.KeppfeY Regional Administrator L. P. Bregni, Licensing cc: Engineer l P. A. Marquardt. Corporate L Legal Department L DCS/RSB (RIDS) Licensing Fee Management Branch l Resident Inspector, RIII Ronald Callen. Michigan Public Service Comission Harry H. Voigt, Esq. Nuclear Facilities and Environmental Monitoring Section Monroe County Office of Civil Preparedness i e

a [< ENCLOSURE 2 T FEMI 2 INDEPENDENT OVEAVIEW CXN41TTEE ^ i EVALUATION OF DETROIT EDISON MMAGpefT AT FE4t! 2 - i '(. I l JANUARY 30,19N i e e R / ,#, w. u n s 0 vi o ita. j l _ _ _ _ _ _ _ __ g

~ EVALUATION OF DETROIT E01$0N MANAGDIENT AT FEMI 2 FERMI 2 DCEPENDENT CVERVIDI C0mbTEE l l N l The purpose of this report is to present the results of the Independent Overview Cosentitee's evaluatten of the Ferut 2 mana0ement in accordance eith that Constitee's charter. The committee has 6een directed to identify, evaluate and analyse problems eith management, management structure, and management systems. INTR 000CTIQff By lotter dated Decaster 24, 1985, the Admintatrator for Nuclear llegulatory i III requested that Detreft (dison furnish a response Coretssten Regten describtna plans and progress to address management and protrasmatic eeshnesses fdentifled by the Nuclear Regulatory Commissten. This letter eas it ived in l accordance olth the provistens of 10CFR50.84(f) and speciffcally a !uested Detrott Edison to evalusto and address: l 'The adequecy of management, penanecent structures and systems that have contributed to the performance of Forst 23 the adequacy of training to ato assure that respenstble personnel recognize and respond, as appm j -{ to significant safety condittensa and, changes in centrols n ope {at assure teproved regulatory performance. no area en$ asering and security should be t maintenance, evaluatten.' As part of Detroit Edtson's program to respond to this letter, this Independent Overview Cesulttee wa's formed to provide adytce to the Chfor Extevtive Offleer l and the Board of Directors during startup testin0 of Forut 2 and escalatten to full power operation. l The Cosetttee met intitally eith the Chatrean of the Beard and Chief Enocutive l Officer, the President, and the Vice President Nuclear Operattens to discuss the Cosetttee's charter. The Chafrman of the Board sophasfted the fedependence of this Cosetttee and ladicated that channels are open for comunicatten eith personnel at all levels, eith the Board Nuclear Aaview Cosetttee, with the seerd of Directors itself, or eith any of its seabers. During a one eeek perled, the cosatttee es a ehele, or to groves of tre er more sombers, intervtowed the Vtco Prosident Nuclear Operatfens, the usneper of Nuclear Operattens, all four assistant managers, and other hoy anna 0*fe in plant operation, maintenance, engineering, licensing, quality assurance, security, administrative services, and training. In addttten, the entire Committee else interviewed the Nucleat As3ulatory Ossefesten senter Resident Inspector. i

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D[rsag several sessfens, the Committee ovatreted cad sweerfaed the prettene 1dontf ff:d derfag the fatervfees and d:veloped reconcendettens f:r pensfbio correctivo actfen. In reachlag its conc 1rstcne, tho Conafttee took advantage of the experfonce of th Feral 2 shich some of its members 6 eve, efther as members of the Nuclear Safety Iteview Group, as advisor to the plant managere er as participants in other toe witcal and management work at Formt 2. PRenLEN IDENTIFICATION ADO EVM.UATION We recognise ht the Femt 2 sperating staff participated in plant completten and fa the startup testing program op to five percent power. Furthersore, we ffnd that management personnel tre conscleus of the need for safety la the operetton, malatenance and support of Forst 2. While many elements of management are satisfactorye there are problems which have prevented the organisation from ochfeving the hfgh standards of performance to ehtch Detroit Edison is~ cesaftted. During the fatervlees, it was apparent that most of these problems had already been recognfaed by Nee persons intervfewed. Felieving is the Independent Overvfew Coenfttee's summary of the principal problems. We 1eek forward to reviewfne the responses to each of the pro 61ess identiffed below. A. Lack of Wrcfa1 Nucisar Power Plant _Operatfno twperfence Of the levels of management and supervision from the Chaf tsen of the ,( Board down to the Nuclear Shift gupervisorse there is virtually no expertence with operettag a coeewref a1 nuclear power plant. However, some personnel have naval reactor operating expertence and others have been assfgned for short perfeds at operating nuclear plants owned by other ottiftfes. l 3. Leadersh13 1. Subordinates often de not know who is in charge, and in some esses have the impression,that nobody is in charge. 2. Lack of a sonsistent deffnftfon of misefon Inhibits appropriate ectfen. 3. Managers are reluctant to define goals and respensttttttfes and then require lever tier managers to carry them out. 4. The tendency of some opper level manegers to engage ~ fn sferamanatoment reduces the effectiveness of lever level managers and esporvisors. r 90*d 4tt0020 2LE4 4

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C. Accountability 1. Managers fall te held their ombordinates accountable and fail to follow op te verify accomplishment et assigned work. 2. In a few cases, demonstrated lack e? management abt11ty is accepted rather than corrected. D. Itananement leeffectiveness 1.. There fs some reluctance to face facts, identify problems, establish their sources er root causes, work toward tteely and effective selettense and take actfen to prevent recurrence.

2. There is evidence of lack of effective teamverk within the organization, in terms of concerted, combined efforts to support the needs of an operating plant.
3. Nuclear Freducifen does not always receive the necessary support from other organtaations at Feruf 2.
4. Planning to met effective for either short-tors or long-tors activittee, and little consideration is given to contingency planning.

[ S. Unresolved interdspartmental conf 1fets porstst. 6. Excessive ameenta of time are taken to implement important agrooments, management directives, and procedural changes. 7. Line management eften abrogates its responsiblitties by depending spen deelstens by ccounf ttee, a praettce which results in tee many seetings. E. Orsantaatten

1. The dietston of responstb111 ties within Eclear Engineering is not well balanced and reduces evere11 effectiveness of the organisation.
2. The belity Assurance organtsatten dess not report to a level of management eenstatent with the necessary eethasta en quality.

F. panagempet Systes 1. Adntatstrative, procedures and controls are excesetvely rfgid and cumberseas. 2. There is ne integrated system in ese for planning, scheduling and establishing priertties for helear Operettens. -Sa m.s .n.. a m in 6

s MCC8eOCATIONS We constdor that Detrett Edtsen has sufficient management capablittles to However in develop the necessary action to resolve the problems Itsted above. the course of our dellberattens. et formulated a number of recoseendations ohtch, if adopted, should "uult la overall improvements in the organtaatten and management. We constder the recosmondattens and the acttens to resolve the prehlems are not prerequisites for startsp. 3. Intenstfy and expand efforts to recruft and hire personnel for certain key management positions oho have extenstv,e exportence eith operating cessercial nuclear power plants, alth particular attention to pestitons in senter management. For the Vice Presidente Nuclear Operations, provide an advisor one has 2. extensive conneretal nuclear power plant expertence, to serve in that capacity untti the recoseended recruitment efforts are successful.

3. Emphastre to other site organtsations the tapertence of fully supporting Nuclear Productfene eith particular ettention to resolution adatnistratten and seewrity.

A confitets eith engineering, d to e11etnote organtaattenal of and team effort is neede concerted procedural tapedteents to accomplishine operettenal and safatenance objectives. Establish challenging performance goals at all levels of management l ( d. and, through a system of performance ladicatorse..montter progress toward achievement of those goals.

5. Realten the organizattenal structure of Nuclear Engineering and strengthen its overall annagement.
6. Acquire an empertenced outloar security profeestenal to ispreve the overall effectiveness of the Security organisetten.

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