ML20211J014
| ML20211J014 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/08/1986 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20211J010 | List: |
| References | |
| VP-86-0143, VP-86-143, NUDOCS 8611100141 | |
| Download: ML20211J014 (5) | |
Text
- f ca P $s erit Nuclear Operatioris or Detroit bw r.r->>
Edison 5"EF" Wc:1.
October 8, 1986 VP-86-0143 Mr. James G. Keppler Regional Administrator Region III U.
S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Reference:
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
Detroit Edison Response Inspection Report 50-341/86025 This letter responds to the notice of violation included with your Inspection Report No. 50-341/86025.
This inspection was conducted by Messrs. J. R. Knicely and T. J. Madeda of NRC Region III between July 28 and August 20, 1986.
In addition, your letter described a concern regarding Detroit Edison's disciplinary policy.
Although Detroit Edison does not fully share your conclusions regarding the cases cited in the subject inspection report, Detroit Fdison recognizes the
.importance of forthright compliance with requirements, and the philosophy is implemented in our disciplinary practices.
Detroit Edision's disciplinary policy and practices are described.in a general order which is included in the Detroit Edison Employee Handbook.
This policy provides examples cf conduct which would normally be cause for disciplinary action, and the first example provided relates to dishonesty and falsification of records.
The policy also requires that before taking disciplinary action, supervisors must assure it is based on establinhed fact.
Further guidance on disciplinary policy for Fermi 2 is contained in a Nuclear Operations Directive.
This directive provides for mitigation of discipline for situations honestly and promptly disclosed, and it provides for more severe action when dishonesty is involved.
8611100141 861M9 PDR ADOCK 05000341 007 3 4 ygg G
Mr. James G. Keppler October 8, 1986 VP-86-0143 Page 2 We trust this letter satisfactorily responds to the concerns identified in the inspection report.
If you have questions reagarding this matter, please contact Mr. Joseph E. Conen, (313) 586-5083.
Sincerely,
-j g cc:
M. D. Lynch W. G. Rogers G. C. Wright USNRC Document Control Desk Washington, D. C. 20555 J
e
THE DETROIT EDISON COMPANY FEPEI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC INSPECTION REPORT NO. 50-341/86025 DOCKET NO. 50-341 LICENSE NO. NPF-43 INSPECTION AT:
FERMI 2, NEWPORT, MICHIGAN INSPECTION CONDUCTED:
JULY 28 AND AUGUST 20, 1986 7
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RESPONSE TO NRC INSPECTION REPORT NO. 50-341/86025 Response to Violation a. Access Control-Personnel Corrective Action Taken and Results Achieved The security officer was penalized initially by a i
reduction in compensation (approximately $100.00/ week).
In addition, the individual's security clearance has been
~ denied, thereby preventing him from entering the protected area unescorted.
(He cannot obtain a keycard for access because he does not have the necessary clearance).
He has been assigned to duties unrelated to implementation of the Physical Security Plan.
The contractor employe has been removed from the Fermi site,
.and the individual will not be eligible for a clearance
-at the Fermi site.
i Corrective Action to Avoid Further Violation-The clearance records (approximately 2300) of al1 persons.
having unescorted access to the protected area at the i
time of this response have been reviewed.
No other anomalies were found.
In order to provide better. documentation of decisions to i
grant clearance, a separate form, " Security Clearance Determination", has been developed.
The purpose of the form.is to itemize all discrepant information developed throughout the conduct of a background investigation.
The Director-Nuclear Security will grant / deny,.as
. appropriate, clearances in full recognition of the l
discrepant information as documented on the form.
Date When Full Compliance will be Achieved Full compliance has been achieved.
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RESPONSE ~TO INSP'ECTION REPORT NO. 50-341/86025 Response to Violation b. Records and Reports Detroit Edison does not dispute the facts of the incident as described in section 6 of Inspection Report 86025.
However Detroit Edison interprets the facts of'the incident differently.
Detroit Edison does readily concur ~with the overall assessment of the Commission staff that an air of deception may have been created and, as a result, could imply "less than forthright compliance"; however, we do not concur that deception was' intended.
We do intend to make it more clear to all security personnel that "less than forthright compliance" even if perceived, must be avoided.
Detroit Edison. conducted a thorough investigation of this incident, including interviews with the involved parties.
Based on this investigation, Detroit Edison believes that this incident resulted from a minor licensee identified breakdown in administrative controls rather than the intent to deceive and.therefore requests the severity level be reduced to level V.
Corrective Action Taken and Results Achieved The Security Lieutenant was orally counseled by security management after the incident occurred.
The matter was i
discussed at shift briefings by individual supervisors, and supervisors were told to advise shift personnel that
~
if ever in doubt, record the incident.
Corrective Action to Avoid Further Violations Further discussions with the principal have been accomplished by the new security management.
In l
addition, discussions were held at the security supervisors' shift briefings regarding this topic.
Emphasis is placed on honesty and forthright compliance with requirements.
Guidance with respect to the-preparation of security logs has been modified to ensure that no item is eliminated, but rather, lined out to permit an audit trail.
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Date when Full Compliance will be Achieved Full compliance has been achieved.
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