ML20209E759

Response to Independent Overview Committee

ML20209E759
Person / Time
Site:	Fermi
Issue date:	07/02/1986
From:	DETROIT EDISON CO.
To:
Shared Package
ML20209E709	List: IR 05000341/1985040 IR 05000701/2010015 ML20209E702 ML20209E725 ML20209E744 ML20209E759 ML20209E779 ML20209E832
References
NUDOCS 8609110348
Download: ML20209E759 (17)

Text

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DETROIT EDISON RESPONSE TO Il0EPENDD7f OVERVIDi (INKTITEE July 2,1986 I

I 0609110340 060027 PDR COMMS NRCC CORHESPONDENCE PDR

'5GE2 W G3ttstrS DerKBUCTIGt REEEGEE 'IO IOC IDetrIFIID PMBtJ54 ARERS A. Lack of Ccenercial Itaclear Experience B. Leadership C. Accountability D. Managenet Ineffectiveness E. Organization F. Management Systems RESOEE 't0 IOC NEIBGENRTICBE

1. Recruit Additional mclear Experience

2. Provide an Advisor to the Vice President-Maclear Operations

3. Eliminate Impediments to Supporting Mclear Production

4. Establish Challenging Performance Goals

5. Realigt Maclear Engineering

6. Acquire an Experienced Naclear Security Professicral OHIER mrys App IMpgMgtENPS

1. Engineering Issues

2. Sinulator Training Inprovements

3. Non-Licensed Operator Activities Inprovements

4. Role Clarification and Team Building

5. Increased Surveillances and Audits l 6. Accesplishments and Trends l

moonass est mesmar

1. Criteria l

! 2. Justification l

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l INTRODUCTION The Independent Overview Committee (IOC) report of January 30, 1986, related to the management of Fermi 2, identified six probles areas and made six recommendations. The report stated that while not " prerequisites for restart" the recommendations and actions to resolve identified problems would improve management of Feral 2. In a February 10, 1986 letter to the Nuclear Regulatory Commission, Detroit Edison committed to accept and laplement corrective actions with respect to those recommendations and to address the problems which were identified as the underlying factors leading to the recommendations.

This response describes the actions taken with regard to each of the specific probles areas and recommendations contained in the IOC report. It also describes the criteria established by Nuclear Operations management to assure that the Ferai 2 plant and organization are ready to restart and operate, and progress through power ascension testing in a safe and effective manner. -

It should be noted that our. efforts have not been limited to just those l items contained in the IOC report. We have also addressed the concerns '

identified in the NRC's 10CFR50.54(f) letter, as well as the findings resulting from evaluations of Fermi 2 operations performed both internally and by INPO and by an independent consulting company. Where appropriate, the additional actions and/or results are included with the response to the specific IOC items. Certain issues and improvements are not directly related to the IOC report and these are addressed in a separate section of

this response.

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RESPONSE TO IOC IDENTIFIED PROBLEM AREAS The IOC report identified six probles areas, some of which included' aultiple items. Each of the probles areas and specific items are addressed below.

Identification of the major paragraphs and subparagraphs corresponds to the format used in the IOC report.

A. LACE OF COMMERCIAL NUCLEAR POWER PLANT OPERATION EIPERIENCE Detroit Edison has successfully intensified efforts to recruit individuals with commercial nuclear experience. Since January 1, 1986, fifty-one nee employes have been hired into Nuclear Operations. Of this group of new hires, fifteen have had commercial operating experience including the Group Vice President, and five employees in Nuclear Production, three in Nuclear Engineering, three in Nuclear Training, two in Nuclear Quality Assurance and one in Nuclear Information. The majority of the remainder.were either contractors hired due to their previous experience with Fermi 2, their experiences in the Navy nuclear -

program, or nuclear plant start-up experience at other locations.

B. LEADERSHIP

1. At the Corporate level the reporting line of the Nuclear Operations organization has been changed so that the officer responsible for that organization, now Group Vice President Ralph Sylvia, reports directly to the Chairman and Chief Executive Officer instead of to the President. This has resulted in a more direct and increased involvement of the Chairman and Chief Executive Officer, as well as clearly identifying the Feral 2 operation as one of the major components of the corporate structure. There.is now clearly one person, the Group Vice President, in charge of the Nuclear Operations organization, and it is clear that this person has direct access to.the chief executive of the Company.

In order to emphasize and better focus the authority and responsibility for actual plant operation, the title " Plant Manager" has been established. The former Assistant Manager titles and positions have been eliminated and different organizational

, titles and positions have been used to more clearly indicate that j other Nuclear Operations organizational units exist to provide support for plant operations.

2. A significant effort was undertaken to give clear direction to the Nuclear Operations organization. The Vice President-Nuclear Operations and his senior staff, with the assistance of two individuals from the Detroit Edison corporate office, a Senior Strategic Planner and an Organization and Management Development l

' Consultant, and with input from the whole Fermi 2 Management Team, developed the Nuclear Operations Improvement Plan (NOIP). As part i of this process, Nuclear Operations management established a singular mission and defined major goals for the entire Nuclear

Operations organization. The NOIP identifies the specific tasks / actions necessary to accomplish the mission, assigns responsibility for their accomplishment, and provides performance measures and a monitoring system to assure effective implementation.

3 Reluctance of managers to establish goals and hold subordinates accountable is being addressed on several levels. As stated in the preceding paragraph, Nuclear Operations management has established the mission and goals and the NOIP identifies the tasks / actions necessary to assure their accomplishment. With regard to l integrated planning and scheduling, the NOIP requires (Item 5) the l designation of task leaders who are responsible and accountable for task completion in a timely manner. Finally, the NOIP also requires (Ites 11) that the appropriate action items be incorporated into l the Annual Work Plan (AWP) for each of the members of the Fermi 2  ;

Management Team. Each individual's performance in meeting his AWP l will be reviewed, and feedback will be provided by the individual's supervisor at least quarterly.

In addition, supervisory skills training emphasizing accountability is being provided to new supervisors. I

4. Micromanagement is directly addressed by the responsibility /

accountability system built into the NOIP. Specific action and task assignments, coupled with the regular review process, effectively utilize the management chain of authority in controlling work, thus minimizing the perceived need for micromanagement. It should be noted, however, that the Management Team is also committed to the practice of " managing by walking around" which, by its very nature, can lead to some micromanaging. It would be imprudent of a manager not to step forward and correct observed activities which are contrary to desired practices. The management team recognizes this and will seek to act in ways which minimize micromanagement without adversely affecting safety or performance.

C. ACCOUNTABILITY Holding subordinates accountable and following up on assigned work has been addressed in a number of ways. Most importantly, the NOIP, which has been communicated to the Fermi 2 Management Team, establishes clear assignments of responsibility for specific actions and requires that the action items be incorporated into each Management Team acaber's AWP. The l NOIP also provides on-going performance sensures which will be used to reinforce the accountability of the Management Team members by providing individual performance monitoring, feedback and appraisal at all Management levels at the site on at least a quarterly basis.

1here have also been organizational changes to address and strengthen the resolve for improved accountability and performance. Other changes have been made in order to stress the line function and enhance the Plant Manager's role, i

More effective discipline is also being used to bring about desired results. Since the beginning of 1986, discipline for job performance has increased.

D. MANAGEMENT INEFFECTIVENESS 1

1. The criticism of reluctance to face facts, identify problems, root cause determination, timely corrective action and actions to

• prevent recurrence is being addressed in several ways.

First, the corrective action process is being improved to assure an emphasis on results and timeliness, rather than en the method used. '

Second, facing facts and identifying problems are addressed in the NOIP (Items 2a, 7 and 8) which are directed at improving problem identification and reporting, problem solving skills and the incorporation of " lessons learned". In general, the strategic planning process focuses attention on the real causes of problems resulting in a dynamic and comprehensive Nuclear Operations Improvement Plan.

Lastly, approximately 90 members of the Management Team participated in a series of 2-day Regulatory Workshops to increase their sensitivity and responsiveness to regulatory and safety issues.

2. Lack of effective teamwork had been recognized and some actions taken by management prior to the IOC report being issued. An Organizational Climate and Management Practices Survey was conducted to help analyze the teamwork issue in more detail.

The strategic planning process used to develop the NOIP required significant teamwork at the senior level of the Nuclear Operations organization, not only to develop a comprehensive and meaningful laprovement plan, but also to move ahead and manage Nuclear Operations. Implementation of the NOIP requires and reinforces effective teamwork in supporting the plant.

Specific team building sessions were held betweeen the Nuclear Production and Engineering staffs to identify and implement methods to improve effectiveness of their combined efforts in supporting the operation of the plant.

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3 several actions have been taken to improve the support provided to Nuclear Production. Since the beginning of the year there have been numerous organizational changes, realignments and relocations to bring about more effective support. This includes seven '

management reassignments within the plant organization, strengthening of simulator training management, streamlining and strengthening of engineering management, and relocation of key support services management to the plant.

The process of establishing priorities for work orders has been significantly improved, and the procedure for equipment clearance and tagging associated with work performance is being streamlined.

It should also be noted that authority for the establishment of plant priorities'is assigned to Nuclear Production which clearly j emphasizes that the other Nuclear Operations groups are supporting Nuclear Production and the Shift Supervisor. Management directives clearly indicate that the Shift Supervisor is in charge and ~~

establishes priorites in the absence of line management.

Also of note is the in-plant " rounds" program being utilized to strenghten the non-licensed operator function in support of plant operation.

4. Improvements in planning and scheduling are specifically addressed by the NOIP (Items 4 and 5) which require coordinated involverent of all affected organizations in the development and maintenance of integrated plans and schedules, and the assignment of responsiblitiy, authority and accountability for controlling and

accomplishing specific activities. Planning and scheduling i activities have become better focused and more integrated over the last several months. As a result, the schedules are more realistic, l

and there is a better grasp of outstanding work which sharpens the focus on the coordination of key activities.

In addition to the improvements in routine planning and scheduling, increased emphasis has been placed on contingency planning in the weekly schedule meeting currently being chaired by the Vice President-Nuclear Operations.

5. With regard to the existence of " unresolved interdepartmental conflicts", the Organizational Climate and Management Practices Survey addressed in Iten D.2 above provided significant insight to the causes of, and established a basis for, resolution of the real or perceived conflicts. The Detroit Edison corporate Organization '

and Management Developmens Specialist, using the results of this survey, is working with the various organizations to reduce conflict. The NOIP will also help in reducing such conflicts i through the clarification of organizational responsibilities.

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Personal / personnel conflicts are also expected to be resolved through policy clarification, or the reassignment of individuals l which has in some cases already taken place.  !

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6. With regard to the timeliness of annagement response to issues, it should be noted that since the IOC report was issued on January 30,  !

1986, a significant number of annagement and organizational changes i have occurred. These were accomplished in a relatively short l period of time. Responses to other reviews have also been prompt as demonstrated by the Operations Section putting into place a new, non-licensed operator training and qualification program, and the management / organization changes related to the simulator training function.

The NOIP also addresses this area (Items 1 and 2). Specifically, j existing Nuclear Operations Management Plan documents are being '

completely revised to reduce redundancy and ambiguity, and clarify program direction. Nork processes and administrative controls are

-l also being reviewed and revised, where appropriate, to provide more effective, yet more flexible, control of important activities.

These improvements .should have a secondary affect of imp:vving the timeliness of management decisions.

7. Decision making has been significantly improved through the assignment of task managers for key activities and improved meeting utilization. The scheduling, plant status and staff meetings are now focused with specific responsibilities assigned for decisions and action. Organizational assignment changes were also made to

. reinforce and bring about effective line management decisions.

E. ORGANIZATION

1. The Nuclear Operations organization has been realigned to establish the authority of the Plant Manager and provide the necessary support to the plant.

2. The Nuclear Engineering organization has been realigned into three functional groups, reporting to the Director, Nuclear Engineering, in order to establish a balanced and more effective organization.

Further changes in the organization may occur, but none are contemplated until recruiting for an officer level engineering and support services person, which recruiting is actively underway, has been completed.

3 The Nuclear Quality Assurance (NQA) organization originally reported to the Vice President-Nuclear Operations. As an interim response to the IOC's concern, NQA's reporting relationship was temporarily elevated so that NQA reported to the President.

Bowever, with the appointment of the Group Vice President-Nuclear Operations, NQA now reports to that position.

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4. The Nuclear Operations Services organization is being eliminated.

The security and administrative support services for the plant are being assigned to a new Superintendent of Services reporting to the Plant Manager. 1he training function is being elevated within Nuclear Operations and the Director will report directly to the Vice President - Nuclear Operations.

F. MANAGEMENT SYSTEMS

1. The IOC report indicates that administrative procedures and controls are inflexible and hard to use. Part of the effort in revision of the Nuclear Operations Management Plan documents (Ites 1) is directed at clarifying management direction with regard to procedure development. The improved clarity is intended to permit simplification and increased flexibility, where appropriate, in the administrative controls (Ites 2) and implementing procedures (Ites 3). However, this is a long tera effort and, in the mean -

time, specific procedures which cause inefficiencies are being addressed on a case-by-case basis (Item 2).

2. The lack of an integrated system for planning and scheduling was addressed in D.4 above.

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RESPONSE TO IOC REC 00MENDATIONS The IOC report included six specific recommendations. The actions taken with respect to each of those recommendations are described below. The paragraphs are numbered to correspond to the IOC report.

1. Recruitment of individuals with operating commercial nuclear plant experience is on-going. B. Ralph Sylvia, who has extensive operating nuclear plant experience, began with the Company on May 5,1986, as a

, Group Vice President. Efforts are continuing to recruit an officer level engineering and support services person. Ne are also reviewing the other areas of the organization to determine where additional operating commercial nuclear plant experience would be beneficial. The response in Paragraph A of the preceding section describes our overall progress in this area. -

2. In addition to the operating commercial nuclear plant experienced advisor for the Plant Manager and the Vice President-Nuclear Operations, -

an additional nuclear experienced individual has been advisor to the Vice President-Nuclear Operations since April 3,1986. This support has proven very beneficial to date and will continue at least until certain NOIP tasks are completed.

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3 Sixteen of the twenty-two items in the NOIP address, directly or indirectly, the resolution of organizational conflicts, elimination of procedural impediments to accomplishing operational and maintenance objectives, and teamwork in supporting Nuclear Production.

In addition, several organizational changes have been accomplished to improve support and teamwork. These changes include the assignment of an Assistant Operations Engineer, reporting to the Vice President -

Nuclear Operations, to be in charge of simulator training; and the strengthening, by reassignment, of six key positions in the Operations and Maintenance Sections of Nuclear Production. Organizational changes which will assign responsibility for the plant administrative and i security functions to a Superintendent of Services reporting to the Plant Manager have also been announced.

l Team building sessions between Nuclear Engineering and Nuclear

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Production have minimized the conflicts between these organizations.

Also, the selection of a member of the Nuclear Engineering organization to be the Technical Engineer, a supervisory position on the plant staff, has proven to be beneficial with regard to team building.

4. As discussed previously, Nuclear Operations management has established a singulu mission and defined goals for the entire Nuclear Operations organimation. The NOIP was written to encompass the already existing improvement plans for Reactor Operations, Nuclear Security and j Radiolqgical Control. The established goals are both challenging and perforannce-related. Monitoring and accountablity systems have been 1

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established to assure progress of the individual Management Team members in accomplishing their specific responsiblities with respect to the attainment of those overall organizational goals. The performance measures are reviewed at least monthly (weekly in the case of the ROIP measures) by Nuclear Operations senior management and failure to reach -

acceptable performance levels will result in additional management action.

5. The Nuclear Engineering organization has been realigned and management has been strengthened as discussed in Paragraph E.2 in the preceding section. In addition, it should be noted that the NOIP requires (Itea 6) an independent review of Nuclear Engineering procedures and an evaluation of the adequacy of permanent engineering expertise. The results of these efforts will be used to further upgrade the capability of Nuclear Engineering to support operation of Feral 2.

6. Efforts are continuing to recruit a nuclear security professional. '

Candidates for the position have been interviewed and an offer is being prepared. In the meantine, a group of nuclear security experienced consultants are being utilized to assist in the review and improvement of the Security Plan and implementing procedures.

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OTHER ISSUES AND IMPROVEMENTS i Detroit Edison has addressed all of the Independent Overview Consittee concerns and recommendations as well as those indicated by the NRC in their 10CFR50.54(f) letter. Not all of these issues are required to be resolved by restart, nevertheless they have been thoroughly addressed along with a number of other improvements incorporated during the last six months.

Several of these activities and associated improvements are not directly related to the issues contained in the IOC report. However, in view of the charter of the IOC, we believe it is appropriate to discuss these issues.

1. Engineering Issues Several concerns relating to the design of Fermi 2 have surfaced during -

the last several months. In sussary, these were:

o The adequacy of interdisciplinary reviews of design changes issued since September 1984, and in particular the seismic and '

environmental verifications; o The adequacy and completeness of engineering calculations to reflect as-built conditions; o Deviations from the small bore pipe design manual without adequate documentation of justification; o Potential overloading of certain embedded plates;

. o Potential problem with Nelson studs on embedded plates; and, o The incompleted detailed engineering work items outstanding at the time of licensing.

Each of these items was thoroughly addressed. The results indicated the need for relatively few hardware changes. The NRC (Region III) has reviewed each of these issues and indicated that they find our actions, both completed and planned, to be acceptable.

In addition, Stone and Webster was engaged to perform a third party

• review of Fermi 2 Engineering practices. They concluded that the Engineering records are satisfactory and what they would expect to find for any nuclear power plant. l As a result of the internal reviews and the third party review, baseline documentation for the plant is very good, and Nuclear Engineering has improved and strengthened procedures and has an excellent verification ,

program including personnel trained in the verification process.  ;

2. Slaulator Training Improvements There have been significant improvements in the simulator training program. An Assistant Operations Engineer has been assigned to supervise the slaulator training effort and is reporting directly to the Vice President - Nuclear Operations. A more structured program, prepared with the assistance of both INPO and General Electric, emphasizes teamwork, use of approved " conduct of operations" practices, individual responsibilites and accountabilities, and effective overall plant operation. The Shift Operations Advisors, Shift Technical Advisors and Reactor Engineers now participate in simulator training with the rest of the operating shift.

Each of the operating shifts are completing training specifically directed at startup and operation through five percent power with particular attention to the recognition and mitigation of reactivity control problems. As the power ascension test program progresses, the ,

simulator training will be focused toward operation at the next test progran power level. In , addition, the Startup Engineers will participate in simulator training to the extent appropriate.

3 Non-Licensed Operator Activities Improvements Several actions have been taken to improve the effectiveness of the Non-Licensed Operators. This includes: revising related plant orders to increase clarity, reorganization of operator rounds documentation, improved labelling of equipment, development of a new qualification card for operator rounds, and expanded training. This non-licensed operator training has already produced positive results in terms of better understanding of plant functions and related job duties.

4. Role Clarification and Team Building Shift Operations Advisor and Shift Technical Advisor roles were clarified following the July 1985 rod-pull incident. These roles were clarified with each individual through one-on-one sessions with the Plant Manager or the Superintendent-Operations with specific attention to che areas of responsibility, authority and performance expectations.

Furthsi, the rolas have been proceduralized and, more importantly, are now stressed and exercised through the simulator training program in which these personnel participate.

As discussed previously, certain changes in the simulator training program were specifically directed at fostering teamwork. Role clarification is also accomplished through emphasis on individual i

responsibilities and accountabilities.

5 Increased surveillances and Audits A management surveillance of control room activities will be conducted by the Group Vice President or the Vice President - Nuclear Operations, assisted by an individual experienced and knowledgeable in nuclear power plant control room operations, and a representitive from Nuclear Quality Assurance. The surveillance will be conducted on an unannounced basis to assure that shift personnel are proficient in performing their assigned responsibilities in a safe manner.

A Non-Licensed Operator Surveillance Plan is also being developed to provide Nuclear Operations management with feedback on the adequacy of "on-rounds" performance of non-licensed operators. The results of these surveillances will be reported to both plant and senior Nuclear Operations management to assure that any necessary corrective actions are identified and implemented.

l At the request of the Plant Manager, the Independent Safety Engineering -

Group (ISEG) is conducting an evaluation of the Fermi 2 Technical Specification Surveillance Program. The ISEG has requested INPO assistance in this evaluation and the assistance visit is expected to be completed and preliminary results available by July 21, 1986. A final

, report will be provided to the Plant Manager and senior Nuclear Operations management no later than September 15, 1986. Results of the evaluation will be used to assure completeness of the surveillance program.

6. Accomplishments and Trends The Reactor Operations Improvement Plan is accomplishing its objectives. Recent reports regarding the performance indicators, while showing some fluctuation in trends, indicate that all measures are currently at acceptable levels and overall the trends are in the desired direction.

! Nuclear Security has also accomplished positive results with their Nuclear Security Improvement Plar. and recent reports indicate a i

reduction in the number of security non-conformances.

i l The Nuclear Quality Assurance Organization, through its audit, surveillance, and inspection programs, and other support functions has observed steady, progressive improvement since late summer of 1985 in areas of importance such as implementation of the Reactor Operations ,

Improvement Plan and the Nuclear Security Improvement Plan; planning and I implementation of the Nuclear Operations Improvement Plan; I implementation of commitments made to the NRC in response to the l 10CFR50.54(f) letter; and, responsiveness to NQA audit and surveillance  !

findings including the timeliness and effectiveness of corrective action i associated with those findings and other identified conditions adverse ,

to quality.

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READINESS FOR RESTART l

1. Criteria l Many activities have taken place to assure readiness to restart Feral.

Additional items, while not required, were completed so that the Fermi 1 management team is assured of not only restarting, but also of continued '

safe and effective power ascension testing and operation.

Certain items remain to be completed prior to restart. Nuclear j Operations management is closely monitoring the status of each of the following items and will ensure that they have been satisfactorily completed prior to permitting the Plant Manager to restart.

o Resolve engineering issues with the NRC (effectively accomplished at June 26, 1986 neeting with Region III).

o Resolve NRC (NRR and Region III) open items for restart. -

o Implement surveillance programs for Control Room and simulator training.

o Implement surveillance plan for Non-Licensed Operator " rounds" activities.

o Complete Technical Specification required surveillances satisfactorily, o Determine status of the plant as defined by the "out-of-spec" log to be acceptable.

o Address INPO issues satisfactorily, o Complete current outage.

o Complete On-Site Review Organization reviews:

ROIP items completed and related measures are acceptable.

- Quality Assurance issues resolved.

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- Plant readiness review list completed for those items required for restart.

NOTE: The OSRO checklist (and related criteria) to determine plant readiness for restart has been laproved from that used for the startup in March 1985. Additional items have been added and the criteria have been further defined. OSRO will recommend that the Plant Manager proceed only when it is convinced that each line iten meets the defined criteria and intent. This checklist is structured to address not only restart but each subsequent step in the power ascension and test program including heatup and the six test conditions. The checklist indicates which items are required to proceed to each successive step.

- Document recommendations to Plant Manager. -

o Complete Plant Manager reviews:

- Material condition of the plant acceptable for plant restart and operation.

- On-Site Review Organization recommendations reviewed and approved.

- Summary review completed.

o Complete Executive Management reviews

i Group Vice President meetings with Shift Supervisors and other key personnel completed.

- Reactor restart major activity checklist completed.

NOTE: This is a comprehensive list of those items which must be completed prior to plant restart. This includes many of the items already covered above as well as the On-Site Review Organization checklist.

2. Justification I

Detroit Edison has responded comprehensively to both the NRC 10CFR50.54(f) letter and the Independent Overview Committee report. The problems identified by the Independent Overview Committee have been addressed and the recommendations implemented. In addition to our actions in response to the 10CFR50.54(f) letter and the IOC report, there have been numerous other 1

improvements, some of which have been described above. More than is required has been accomplished to satisfy Fermi annagement and Detroit Edison Company Senior Management that the plant will be ready to restart once the actions identified in the preceding paragraph have been completed, and to operate safely through power ascension testing and on into commercial operation.

During the current outage, Nuclear Operations has demonstrated its ability to plan, monitor, measure and resolve matters affecting the plant.

Nuclear Operations has requested and received assistance visits from the Institute of Nuclear Power Operations, met with the Nuclear Regulatory Commission to review and resolve open issues and requested changes in technical specifications appropriate to the safe operation of Fermi 2.

Additionally, the Group Vice President has personally set with key staff seabers of Nuclear Operations and the operating authority; the Plant Manager previously met individually with all shift supervisors; and, the Nuclear Operations staff has individually given assurances that every management -

area is prepared for restart once the few remaining open items are closed and the outage is completed.

The IOC report did not cite any actions as required " prerequisites" to restart.

Nonetheless, Nuclear Operations management established additional requirements to assure that the Company's and the Committee's single purpose

- the safe and efficient operation of Fermi 2 - is attained. With respect to activities which remain to be completed prior to restart, comprehensive checklists with acceptance criteria have been developed and will be utilized by the On-Site Review Organization and senior Nuclear Operations management to ensure final readiness of the plant for restart.

Based on these factors we are convinced that Fermi 2 and its supporting organizations are ready to restart.

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f Poemt2 d i S O n 5 5Iild

• W; May 9,1986 l

. i Mr. Janes G. Kappler Regional Administrator Region III U. S. Niclear Regulatory C<menission 799 Boosevelt Road Glen Ellyn, Illinois 60137

Reference:

1) Detroit B51 son to NIC Letter, " Response to Request for Information Pursuant to 10TR50.54(f)",

VP-86-0006, January 29, 1986

Subject:

Nuclear Ocerations T erovament Plan Pursuant to the cannitment made in Reference 1 above, Detroit R51 son has been developing a Nuclear Operations Improtement Plan (NGP) for Fermi 2. Se purpose of the Plan is to effect improvements in the overall management of Fermi 2; in Nuclear Operations' ability to recognize and respond to problans which could affect plant safety; and, in management controls to assure improved regulatory, operating, engineering, maintenance and security performance. A copy of that Plan is enclosed.

Se Plan was developed utilizing the Company's Corporate strategic planning process which has proven successful many times in the i past. his process provides a ccuprehensive and systenatic approach to identifying areas needing improvement or change and for determining the actions necessary to bring about the desired l results. Dphasis was placed on those concerns ex1ressed in your letter of December 24, 1985, the problans identified and reccanendations made by the Independent Overview Counittee in their report dated January 30, 1986, and areas identified during Nuclear Operations' own introspective management review.

While the Fermi 2 senior managers established the mission, goals, and strategies, the specific actions required to accomplish these objectives were developed with input from other levels of the Fermi 2 management team. As a result, the Nuclear Operations Improvanent Plan contains the actions necessary to ensure that the desired improvements are obtained.

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Mr. Janos G. Esppler May 9, 1986 VP-86-0054 Page 2 In their 1985 Annual naport, DPO indicated that ' nuclear plants with high equivalent avaAlability, maall numbers of forced outages, few urplanned acrans, few significant events and low personnel radiation exposures are generally well-managed overall." maclear Operations agrees and will use these and other performance  !

indicators to measure the progress of the Plan. In general, l supervisors and managers at various levels in the organisation will track progress and performance within their areas of responsibility using the typical INPO performance indicators.

Ten indicators will be tracked and progress will be reviewed on a '

monthly basis as part of the NOIP. In addition to these performarce indicators, each action identified in the Plan has a specific due date associated with it. Progress in meeting these due dates will be reviewed monthly. As the trend of any of the ten NOIP sensures -

indicates that the desired performance levels have been achieved, senior management will determine whether a specific measure should be removed fra the monthly NOIP review. Although such measures might no longer receive the focused attention of senior management, through the NOIP review, they would nevertheless continue to receive normal manager and supervisor reviews. If any of these reviews indicate trends toward undesirable performance, prompt and appropriate action would be taken to respond to those trends. Such action might include modifications to the Plan to ensure that the appropriate management attention is focused on the problem area.

In addition to the developnent of the Nuclear Operations Improvement Plan, a number of other improvenents bare been inplemente5 since the sutanittal of our January 29, 1986 letter. Sczne of these inprovements include:

l o Appointment of an experienced individual as Group Vice i

President of Nuclear Operations; Otr. B. Ralph Sylvia) o Assigment of a nuclear industry-experienced individual to advise the Vice President - Nuclear Operations; o Inglementation of the Nuclear Security Inprovement Plan; o organizational and management changes within Nuclear Engineering to assure more effective support cf Nuclear Production; o Organizational realignment within Nuclear Pro 5uction so that the Rad / Chem Engineer reports directly to the Plant Manager; o Changing the Assistant Manager - Nuclear Production title to Plant Manager to strengthen the position in the organization; o Temporary relocation of the General Diretor, Nuclear Operations Services to the Plant Office Building to provide more effective day-tcMay support of Nuclear Production;

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nr. James G. Egplcr May 9, 1996 VP-96-0054 Page 3 o Continued monitoring of the performance indicators established for the Deactor Operations Igrwenant Plan; o Initiation of a search for nuclear industry-experienced individuals to fill management positions in Bgineering and security; o Involvement of the Femi management team in the develognent of the Plan; and I o Isplementation of a series of two-day workshops for approsimately ninety Fermi 2 managers and supervisors to increase their sensitivity and responsiveness to safety and regulatory issues.

Detroit B51 son believes that these changes and the implementation of the naclear Operations Improvement Plan will result in further improvanents in the management and overall performance of Fermi 2.

The Capany is cemitted to ensuring that such inprovements coeur.

Sincerely,

[ [.

F. E. ti oc: Mr. M. David Lynch j Mr. G. C. Wright  ;

Fermi 2 Resident Inspector '

USNIC Document Control Desk Washington, D. C. 20555 I

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. Enclosure The Detroit Edison Company Fermi 2 Nuclear Operations Improver.ent Plan

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' z) w kO L g & JJ g,,- s April 30, 19EC

A NX22Nt GMTIGES DIPMWBENT PLAN DmOUCTICRI the Raclear Operations Improvement Plan DIGIP) includes a cogrehensive att of specific actions and related performance indicators directed at bringing about significant improvement in overall performance throughout the Femi 2 Ituc3aar Operaties organisation. The specific actions were developed by the Fami 2 senior managers, with significant input from most of the Femi 2 Management Team l members. This plan has been approved for implementation by the Vice President - l 1eaclear Operations.

The Iqu!P establishes due dates and assigns specific respmalbility to one or -

more Raelear Operations groups. Where more than one group is involved, the group with lead responsibility is identified. Each affected manager and supervisor is responsible for identifying and applying the necessary resources within his or her organization, for maintaining appropriate interfaces with other affected organizations, and for ensuring that the required actions are cepleted in an effective and timely manner. The 100ZP specifically addresses accountability for acceplishing the identified actions by requiring that the actions be included in individual .Nmual Work Plans.

The 180IP contains ten performance indicators to acnitor and measure the

, effectiveness of the Plan. These performance indicators ard the specific j actions of the Plan will be reviewed at least acnthly by Femi 2 management to ensure that the necessary improvements are being obtained and to identify areas where further action is necessary.

The IEDIP is a plan for improvement of the leuclear Operations organization. Its success depends on the individual efforts ard contributions of every leuclear Operations esploye involved.

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! Pav e 1 April 29, 1986 i

i Fermi 2 l Nuclear Operations Improvement Plan I

-Action Deliverablen Reso (1) Due Date I i I

1. Review Nuclear Operations Management l Plan reviewed & criterial NO l 6/96 Plan documents (Nuclear Operations l develooed I l Directives, Nuclear Operations Pro- l l l grams, Operational Quality Assurance l Documents reviewed & I NO I 8/06 Policies, Quality Assurance Program l prioritized for revisionl l Requirements) and revise as necessary I and begin high priority i I i to eliminate redundancy and clarify I revisions. 1 I programmatic direction. l l l

' l Appropriate documents l NO l 1988 I rev ised l l l l I I

I I I

! I l l

2. Improve administrative controls and work l l l

< processes to provide more effective  ! I l ,

i support to the operating authority. I l l Examples includes clarification of re- l l l quirements, responsibilities and account-l I l abilities; elimination of redundancy; I l l simplification of processes, where l l l possible; and, reduction of time to I l l procese paper and complete tasks. l l l 4

l l l 1

a. Revise identified processes or l PM program revised l *NP l 7/96 controls l DER procens revised l NE I 7/86 .

I LER preparation process i RA I 9/86 i

i revised l l

! l PN-21 process revised l l 11/96 l Procedure preparation l l 9/86 I controls and guidelinee l l l revised l I i

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l I j l FDP Procens revined l *NE l lat Qtr '87 i I l NP l l l I NOS l 1 1 I I

• , (1) See notes on lant page

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) Po, 2 April 29, 1986 Feral 2 Nuclear Operations Improvement Plan a

i Action ..

Deliverablen Remn (11 Dum Date *

(Item 2 cont'd) l l l

! b. Review other processes and controin l Review completed & l *NP l 12/06 3

to identify needed revisions, I priorities established l NE I  ;

NOS l determine priority and revise. l I I I I i Process controls revised l NO l 4th Otr '87 I I i

, I I I I I I i 3. Upgrade existing procedures, as part l Revisions completed l *NOS l 1988 of normal review cycle, based on l I NP l revised procedure preparation guide- l I NE l lines (See Item 2a ebove) which will l l NQA l address human factors considerations, I l l need for procedure, level of detail, I l l flexibility, and elimination of l I I redundancy and unnecessary detail. l l l I I I ~

I I I l I i

4. Initiate coordinated involvement of l Integrated -

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• NP I 7/86 s af fected Nuclear Operations organi- l Plans / Schedules l NE I On-going ,

sations to develop and maintain i maintained l NOS l integrated plans and schedules. I l l l l l .

l l 1

. I I I l S. Assign organizational and indiv idual l Initial Task l

• NP I 5/86 I

responsibility, authority and l Nanagers/ Leads l NOS l l

accountability for controlling and I assigned l NE I accomplishing elements of the l i i integrated plans and schedul es . I Few ansignments l

• tfP l On-going 4 l an necessary l NOS l

! I I NE I i i 1 i

• , (1) See noten on lant page s

Pagt >

April 29, 1986 Fermi 2 Nuclear Operations Improvement Plan (7

Action Deliverables Reno (1) Due Date i i I

, 6. Upgrade engineering capability to support l l 1 operation of Fermi 2. l l l 1 I I a) Perform third party review of l I I Nuclear Engineering procedures l Revlew Group l NE l 6/96 in support of 10CPR50.54(f) I established and plan l l response. I for review complete. l l l l 1 l Review complete l NE l 11/86 l 1 I i l Recommendations l NE l 2nd Qtt '87 l l evaluated & imple- I i

! I mented as appropriate l l l

I I b) Evaluate adequacy of permanent i Evaluation completed l NE l 9/86 engineering expertise and i I I l upgrade as appropriate. I Required recruiting l NOS l 12/ 86 ,

I initiated l I I l I I 1 I

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7. Establish and communicate guidelines l Guidelines l *NE l 7/86 i

for improved, systematic problem I communicated l NP l l solving. l l 1 -

I l I I i

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8. Evaluate and upgrade existing methods i Evaluation completed l NO I let Otr '87 for identifying and incorporating l 1 I

" lessons learned" into day-to-day l l l activities. I Upgrade completed l NO I 3 rd Ot r '97 I I I I I I

• , (1) See noten on lant page t

Pas #

l April 29, 1986 1

Fermi 2 Nuclear Operations Improvement Plan

} Action Deliverables Remn til Dum Data I i I

9. 7mprove knowledge of industry experi- l Policy for l NO I 12/06 l ences through increased participation I increased utilization I l in, and utilization of, INPO peer l established I i l evaluations. l l l l l l l l 1 l i I

10. Communiente the Nuclear Operations l Methodology developed I *NI l 5/06

Improvement Plan to af fected organi- l l NO I l zations and individuals. l I I i j l Plan communicated i NO l 5/86 i i i I j i i I 1 I 1 I l I

! 11. Include NOIP action items in l Work Plans revised l NO I 7/96 -

! Annual Work Plans of Nuclear l I I Operations Management Team i Monitor performance l NO I On-going members as part of individual' I and provide feedback I I

performance appraisal process. I at least quarterly. l l l

i I I I I I I I i 12. Complete Reactor Operations Improve- l l l i

ment Program l l l .

l I I l a) Evaluate and identify program l Selected items l NP i 9/86 j elements to determine items which I identified l I

should be incorporated into existing l I l 1 administrative controls. I I i i I i b) Complete formal program by l Program completed i NP l 12/86 j incorporating identified elements I l l l

Into existing procedures. I I I i l i I

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• , (1) See notes on lant page '

i s

I . , a Pas ., '

April 29, 1986 Feral 2 Nuclear Operations Improvement Plan Action Deliverables Remn (1) Dana Date l I i

13. Improve Technical Specification i l l interpretations & applications: I I I t

i I I l a) Complete current upgrading of I Upgrading completed l NP l 7/06 Interpretation Log i l l s ongoing i

i I i i b) Identify specific Tech Spec l Needed changes

! changes necessary to reduce l NP l 8/06 I documented i I a Ongoing

{ ambiguity and request appropriate l I I j amendments. I Initiate amendment l RA I 9/06 i

i requests l l 6 Ongoing I I I I I I l l l 14 Develop s implement a scram reduction l Program implemented r

program ut111 ring techniques found l NP l 12/86 I l l

, successful by INPO and other industry l l l l groups. l l I I I I i -

1 1 I I I l

15. Complete Nuclear Security Improve- I Plan completed NOS I j ment Plan l l 12/96 l l I I I .

i i i I j l i I

< 16 Implement Radiological Control l Plan implemented l

• NP l 6/96 Improvement Plan l l NO I I I I I I i I I I I I i

• , (1)

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, d" i-Pag April 29, 1986

Fermi 2 l Nuclear Operations Improvement plan l

ll Action Deliverables Rose (1) Dane Date i l I i i 17 Improve QA awareness by identifying l Training approach l *NQA l 9/06 key elements of program and develop- I determined l NOS l ing a training approach which l I I j emphasizes those aspects of program l Training material l *NQA i 12/06 j that apply to various levels and i developed l NOS I l types of workers /eupervisors/ managers. l I I j l Training implemented l NOS l let Otr '87 i i l I i I i

1 I I

18. Improve methods to increase & main- l Methodologies l *RA i 6/96 I tain awareness of industry, regula- 1 identified i NO l

! tory and public concerns i I I

, l Implementation plans I *RA l 8/86

I developed & approved l NI l 6

I I I l 1 1 I i l I l

! 19. Recruit and select qualifled in- l Positions identifled l NO I 8/96 j dividuals for the Nuclear Operations l 5 prioritized l l I permanent work force to reduce con- 1 I I tractor dependency in positions of l Recruiting initiated l NOS l 8/86 organizational leadership. l l l l I 1 -

1 I I l l l

! 20. Meet Corporate commitments regarding l SER's submitted l NOS I 6/96 i INPO accreditation of training pro- l l l

{ grams. l l l l l I l i I I I I I I I I I I I i

• , (1) See notes on last page t

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, Paga l April 29, 1986 1

Fermi 2 Nuclear Operationn Improvement Plan

-Q f Action Deliverables Rezn (1) Dum Date i I I l 21. Improve management information l Systems needing in- l NOS I 12/06

! systems by consolidating existing I provement identified l l

! systems to eliminate redundancy I (user organization) l i I and delete outmoded systems  ! I I l or unnecessary data. I Implementation plan l NOS l 2nd Otr '87 j l developed and approved l l

! l I I l 1 1 I l l l l j 22. Maintain industrial safety record l Formal safety l WO I On-going l by continued emphasis on personal l program implemented l l l' safety and the analysis of near l I l injury events. I l l j i i l i

Notes:

Resp (1) is the responsible organization as follows:

• NO = Nuclear Operations NP = Nuclear Production NE = Nuclear Engineering .

RA = Regulatory Affairs NI = Nuclear Information MOS = Nuclear Operations Services HQA = Nuclear Quality Annurance Nuclear Quality Assurance will be involved in essentially all actions of the Nuclear Operations Improvement Plan (HOIP) as a normal part of their function.

• Indicates Lead Organization i

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Ihclear Operations Improvement Plan Derformance Measuras I i

Parmi 2 Management will review the following tan performance l measures at least monthly to assess progress and to identify further 1 actions which may be required to improve operating performance. The IUC has indicates that they will monitor and evaluate our progress in iglementing the plan on a monthly basis.

, 1. Cb11ective Radiation Ruposure: total amount of whole body radiation exposure received by all personnel at Ftrui 2.

2. eplanned Radiological **1a====: number of liquid or -

gaseous releases to the erwironment which were either unplanned or urunonitored.

3. Oplanned Safety Systa Actan'; ions: the number of unplanned EX:S actuations and energency PC power system actuations.

4. th-tetry out of specificatie: mober of hours that reactor coolant, feedwater and condensate chemistry was out of specification.

5. Volume of Low Level Solid Radioactive Wasta: ma&er of

cubic feet of low level solid rm51oactive waste shipped for dis W .

6. Startsp Test Phase 9:bedule: measure of actual startup test performance milestones ccupared to scheduled startup test milestones.

7. Sbtal Rmcogliances: number and severity level of EUC notices of violation.

8. Reportable cocurrences Omt's): number of written Licensee j Brent Reports submitted.

9. Time Sensitive ICD's: nurber of unplanned time sensitive Limiting Conditions of Operations.

10. @ Findings Delinquant: ntaber of delinquent ICA andit and surveillance findings.

April 30, 1936 i

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