IR 05000010/1997026

Insp Repts 50-010/97-26,50-237/97-26 & 50-249/97-26 on 971029 & 1106.No Violations Noted.Major Areas Inspected: Selective Review of Plant Support Activities Re FFD Program, Licensee Procedures & Implementation Requirements

ML20197H944
Person / Time
Site:	Dresden
Issue date:	12/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197H882	List: IR 05000010/1997026 ML20197H876
References
50-010-97-26, 50-10-97-26, 50-237-97-26, 50-249-97-26, NUDOCS 9801020038
Download: ML20197H944 (6)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-010; 50 237; 50 249 License Nos: - DPR 2; DPR 19; DPR 25 Report Nos: 50-010/97026(DRS); 00-237/97026(DRS);

50-249/97026(DRS)

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Licensee: Commonwealth Edison Company (Comed)

Facility: Dresden Nuclear Station, Units 1,2 and 3 Location: R. R. N Morris,IL 60450 Dates: October 29 and November 6,1997 Inspectors: T. Madeda, Physical Security inspector D. Funk, Jr., Emergency Preparedness Analyst Approved by: James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety

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EXECUTIVE SUMMARY Dresden Nuclear Power Sten NRC Inspection Reports 50-010/97026; 50 237/97026; 50 249/9702C This inspection included a selective review of plant suppvrt activities relating to the Fitness Fo Duty program. This inspection effort reviewed and evaluated licensee procedures and implementation requirements regarding personnel called in to perform unscheduled work. The inspection was conducted on October 29 and November 6,199 . The inspectors identified a procedure violation. Two employees failed to document their contact of personnel called-in for unscheduled work. Both individuals stated that they were not aware of the!r responsibility to document the call-out of personnel reporting for unscheduled work. The error involved the failure to properly document the evaluation on the required form. (Section S8.1).

• The inspectors identified that the Dresden site procedure that provided guidance for the evaluation of personnel called in for work in the area of evaluating personnel for mental stress, fatigue, or illness in determining fitness for duty was less detailed and more open to mis-interpretation than the corporate procedure. This could adversely impact the staff's understanding of their responsibilities and actions. (Section S8.2).

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l Repott Details ly. Plant Supped 88 Miscellaneous Security and Safeguards issues i

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S Fitness For Dutv Documentation Deficiency i Insoection Scone (81502):

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The inspectors leviewed documentation and interviewed cognizant personnel to evaluate the effectiveness of licensee implementation of fitness for duty (FFD) -

requirements to document call-out contacts of personnel for unscheduled work tour Observatiom and Findings:

The inspectors reviewed licensee Corporate Nuclear Security Guideline No. 206 and Dresden Administrative Procedures (DAP) 1317, both of which described the evaluation method and documentation for the call-out of personnel for unscheduled work. Those procedures required that the person performing the call out will complete a " call-out work record" file for each individual contacted for unscheduled work. The form documented that an individual was contacted and certified for unscheduled work. It also provided documentation that the individual Is fit to respond to tne site through the answers to a series of fitness for-duty question The inspectors interviewed a licensee Safety and Property Loss Prevention Scheduler and a supervisor from the same group. The interviews showed that each has the responsibility to contact personnel for unscheduled work. Both individuals stated that they routinely contacted personnel for unscheduled work, but that neither used the call- .

out record form to document that action. The scheduler stated that he did not recall that the proceduralizeci call-out form was to be used to document the contact until the NRC Interview. He also stated that he was not aware of DAP 1317 until the day before the Interview, October 28,1997. The supervisor stated that he was aware of DAP 1317 and the call out form, but annotated his calls on this personal overtime log record. He stated that he thought that his method of documentation was acceptabl The inspectors' review of the two individuals' training records showed that they had received the appropriate FFD training during annual site access training. Further review of this training indicated that DAP 1317 and the form were specifically mentioned in the ,

trainin After the above findings were presented to the licensee's Assistant Security Administrator, the two individuals were retrained on how to properly document unscheduled call out contacts. In addition, at the direction of the licensee's Regulatory Assurance Manager, the site's Quality and Safety Assessment Group was tasked to evaluate the inspectors' findings and to determine if additional corrective action was necessar ,

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It should be noted that even though the two individuals did not fill out the required call in form, they both verified alcohol abstinence as required by DAP 13-17. In addition, the supervisor conducted an in person FFD evaluation of called-in personnel upon their arrival onsite as required by DAP 13-1 CFR 26.20 requires that each licensee establish and implement written procedures to meet NRC FFD requirements. DAP 1317 requires that a call-out work record file be documented for each Individual contacted for unscheduled wor Two licensee personnel, designated to document contacts of personnel called-in for unscheduled work, failed to document their personnel contacts on the required call-out work record form, which was associated with DAP 13-17. This represents a non cited violation, consistent with Section IV of the NRC Enforcement Policy. (NCV 50-10/97026 01 (DRS); 50 237/97026-01(DRS); 50 249/97026 01(DRS)). Conclusion.s:

The inspectors identified a violation when it was determined that two individuals had failed to document called in personnel for unscheduled work tours in accordance with DAP 1317. However, the called in personnel were properly evaluated to determine tM fitness for duty. The documentation failures appeared to be due to the Individuals .

tc ag to recognize the procedural provisions even though they had received trainin S8.2 Emcodure Adequacy

, Insoection Scoon (81502):

The inspectors reviewed licensee guidance regarding superv;cory FFD responsibilities regarding call outs for unscheduled work, QbacIyations and Findings:

I The inspectors' identified that the scope of FFD questions required to be documented in the DAP 1317 and its call-out work record form were different from the analogous Corporate Procedure No. 206. The Dresden form required the caller to determine only if i the called individual had consumed alcohol in the last five hours The corporate form i further required the caller to ask the individual whether there were any other factors that make the individual unfit for duty. (Note: These factors include mental stress, fatigue ,

t and illness.)

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The inspectors' evaluation of the two procedures showed that the questions in the corporate procedure provided the licensee better ir. formation to evaluate the FFD of personnel called in to perforrn unscheduled work. The corporate FFD Administrator indcated that the corporate form is an attachment to Corporate Nuclear Security Guideline No. 206 and that each site is to use the corporate guidelines to establish site '

specific procedure guidance. Discussions with the Dresden Assistant Security

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Administrator verified that the corporate guideline was to be used, but he was not sure i why Dresden's procedure was different. He is evaluating the inspectors' finding. This ,

finding, regarding ttm differing scope of the Dresden procedure, will be tracked as an ;

Inspection Followup item, (IFl 5010/97026-02(DRS); 50 237/97026-02(DRS); 50- l 249/97026 02(DRS)). l Conclusions: j i

The inspectors identified that procedural guidance utilized by the site to determine the l FFD of personnel contacted for unscheduled work tours is less detailed than corporate ;

procedure guidance. The Dresden's Assistant Station Security Administrator  !

acknowledged this finding and will further evaluate this findin l V. Managemant Meeting

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X1 The inspectors discussed the inspection results with the licensee's Manager of ;

Regulatory Services and Assistant Station Security Administrator on October 29,1997, i Further onsite inspection activity was required and was completed on November 6, i 1997. On November 6,1997, the Assistant Security Administrator was advised o NRC's findings, as described in this report. Actions agre.ed to by the licensee to ,

address the inspection findings were also discussed and were documented in this '

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PARTIAL LIST OF PERSONS CONTACTED Ucensee R. Morley, Corporate, Nuclear Security Administrator F. Sprangenberg, Manager, Regulatory Assurance R. Oulck, Assistant Station Security Administrator INSPECTION PROCEDURE USED IP 81502 Fitness For Duty Program ITEMS OPENED, CLOSED, AND DISCUSSED DJMt0Ad 50 10;237;249/97026-01 NCV FaWure to document unscheduled work tours 50 10; 237; 249/97026-02 IFl Adequacy of a fitness for duty procedure

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