IR 05000213/1993023

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Insp Repts 50-213/93-23,50-245/93-30,50-336/93-25 & 50-423/93-27 on Stated Date.Violation Noted.Major Areas Inspected:Ffd Program,Policies & Procedures,Ffd Organization & Mgt Control,Training,Chemical Testing & FFD Audit
ML20059G069
Person / Time
Site: Millstone, Haddam Neck  File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 12/17/1993
From: King E, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20059G050 List:
References
50-213-93-23, 50-245-93-30, 50-336-93-25, 50-423-93-27, NUDOCS 9401210095
Download: ML20059G069 (14)


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R U. S. NUCLEAR REGULATORY COMMISSION

REGION I

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License / Docket / Report Nos.:

DPR-61/50-213/93-23 DPR-21/50-245/93-30 DPR-65/50-336/93-25 NPF-49/50-423/93-27 l

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Licensee:

Nonheast Nuclear Enerev Company P. O. Box 270 Hartford. Connecticut 06141-0270

Facility Names:

Millstone Nuclear Power Station Units 1. 2. and 3 l

Haddam Neck Nuclear Power Plant Inspection At:

Waterford. Connecticut East Haddam Connectictu a

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Inspection Conducted:

November 15-18 and December 9.1993 N4 0 b O, 3 M

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Inspectors:

E. B. King, Physical Security Inspector date W. J. Raymond, Senior Resident Inspector b O-N. )6 11/l7/ff Approved by:

E. C. McCabe, Chief, Safeguards Section date Division of Radiation Safety and Safeguards SCOPE q

FFD Program, Policies, and Procedures; FFD Organization and Management Control; Training; Chemical Testing and FFD Audit.

-l RESULTS Generally,10 CFR 26 (the Rule) was being met. Management's involvement and support of the program was apparent in assignment of a special task force to rewrite the existing FFD

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manual. However, failing to establish and implement written procedures designed to meet

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the Rule and failing to properly investigate and report unsatisfactory laboratory performance testing results were found to violate the Rule. Additionally, weaknesses were identified in management controls and in the random selection program.

9401210095 931223

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DETAILS 1.0 Key Persons Contacted 1.1 Licensee j

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  • D. Welch, Director, Safety and Health
  • J. LaPlatney, Nuclear Services Director, Connecticut Yankee (CY)
  • R. Factora, Unit Services Director, Millstone Station
  • D. Heritage, Manager, Occupational Health j
  • G. Hallberg, Manager-System Security j
  • T. Weekley, Security Manager, Millstone Station j
  • R. Ahlstrand, Director-Internal Audit and Security l
  • R. Ciurylo, Corporate Information Security
  • T. Cleary, Licensing Engineer
  • R. Paliuca, Engineer-Assessment and Staff Services
  • M. Nericcio, Occupational Health Administrator, CY
  • C. Marien, Occupational Health Administrator, Millstone Station

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  • J. Johnson, Occupational Health Administrator, Corporate
  • E. Annio, Senior Analyst, CY 1.2 U. S. Nuclear Regulatory Commission P. Swetland, Senior Resident Inspector, Millstone Station P. Habighorst, Resident Inspector, CY
  • Present at the exit interview The inspectors also interviewed other licensee and contractor personnel.

2.0 Fitness-For Duty (FFD) Program. Policies and Procedures 2.1 FFD Program The inspectors evaluated the licensee's FFD program using Inspection Procedure 81502: Fitness-for-Duty Program. Based on interviews with FFD program staff and selected supervisors, observations and documentation reviews, the inspectors concluded that management, at all levels, is committed to the goal of the Rule: a work place free of drugs and alcohol and their effects. However, the inspectors also concluded that program weaknesses need immediate attention to ensure continued program effectiveness. These weaknesses in policies and procedures, chemical testing, and management control are further addressed in this report.

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3 2.2 Policies and Procedures The inspectors determined based on discussions with licensee management that the FFD manual was being rewritten due to repetitive discrepancies identified during the -

1991 and 1992 annual Quality Service Audits. At a May 12,1993 meeting between the inspectors and key FFD staff, the licensee had committed to having the manual rewritten and approved by the end of 1993. However, it appears that the licensee will not be able to satisfy that commitment. Based on discussions with licensee management, a revised commitment for completion of the revision of the manual by April 1,1994, will be submitted to the NRC in the near future. On November 1, 1993, the licensee assigned a special task force with the responsibility of rewriting the manual. The task force included a procedure writer and key FFD staff and met daily to ensure the contents of the rewrite satisfied the intent of the Rule. The inspectors were informed by licensee management that, during the review of the manual, weaknesses were identified and indicated that some of the licensee's policies do not fully satisfy the intent of the Rule. The licensee committed to inform the NRC of their findings and to report the corrective actions taken to resolve the weaknesses.

The inspectors determined that tl.e licensee's FFD program did not include written procedures for testing for drugs and alcohol, including procedures for protecting the employee and the integrity of the specimen, or the quality controls used to assure the test results are valid and attributable to the correct individual, as required by 10 CFR 26.20 (c). Additionally, the licensee failed to provide collection site persons with detailed, clearly illustrated, written instructions on the collection of specimens. These conditions appear to violate 10 CFR 26.20(c) and Appendix A, Section 2.2(3) thereto.

(VIO 50-213/93-23-01,50-245/93-30-01,50-336/93-25-01,50-423/93-27-01)

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3.0 FFD Organization and Management Control Since initial inspection of the licensee's FFD program in September 1990, corporate staffing had been increased to enhance program effectiveness. However, inspector review of the FFD organizational flow chart and discussions with corporate and site FFD personnel concluded that there was not a defmitive line of communication from the sites to corporate to effectively enable site staff to obtain guidance and direction.

Additionally, the inspectors were unable to obtain current job descriptions for the Occupational Health Administrators assigned on-site to administrator the program, further demonstrating a lack of management control. It appeared that there was confusion about the reporting of concerns and the responsibility of each key player.

In discussions with corporate management, the inspectors were informed tilat steps would be taken to resolve the concerns and that within 14 days written corrective actions would be submitted to the NRC for review with a commitment date for the resolution of the concern. The inspectors identified this matter as a programmatic weakness requiring management attention. As committed, the licensee provided the

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inspectors with a written response describing the schedule for resolution of the programmatic weakness regarding the reporting of concerns and the responsibility of each key player. The response was dated December 2,1993, and was reviewed December 9,1993. This will be further reviewed by the NRC, (IFI 50-213/93-23-02, 50-245/93-30-02, 50-336/93-25-02, 50-423/93-27-02)

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4.0 Trainine On November 16, 1993, the inspectors met with the licensee's training staff to review FFD-related lesson plans and training records, and to discuss program development

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and implementation. Based on that review and discussions, the inspectors determined that the licensee had a mechanism in place to inform the training department of changes to FFD policies and that the changes were incorporated, as applicable, in the training FFD lesson plans.

The inspectors' review of training records indicated that the licensee had an effective

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tracking program which ensured that required training for licensee and contractor employees was being received in a timely manner. Additionally, the inspectors determined by a review of training records that individuals promoted to a supervisory position were receiving required training within three months after the initial supervisory assignment. It was apparent that the licensee had expended considerable

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effort to ensure the effectiveness of the training. No deficiencies were noted.

5.0 Chemical Testine The inspectors determined by discussions with licensee FFD supervisory personnel, observations at the collection facilities, and a review of collection site records that the l

licensee's chemical testing program satisfied 10 CFR 26.24(a). This determination was based on the testing being performed in a random unannounced manner, with mechanisms in place for follow-up and for-cause testing, and the random test rate encompassing all of the workforce.

On November 16,1993, the inspectors met with the Occupational Health i

Administrators at the Haddam Neck Nuclear Power Plant to discuss security of the computerized random selection program. During a previous inspection in May 1993, the inspectors identified as a program weakness, the failure to ensure that only individuals with a need-to-know could gain access to the program. It was determined that the weakness was due to the lack of an effective password protection feature. At that time the licensee committed to implement interim and final corrective actions to resolve the random selection program concerns, and projected the final corrective actions to be completed by June 1993. Based on discussions with the collection site staff and observations of attempts to circumvent the security of the random selection program, the inspectors determined the protective measures implemented by the licensee were adequate. However, the inspectors discussed an administrative

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weakness involving the random selection program concerning the manner in which the selection pools are updated. The inspectors determined by a review of several random selection generated lists, that terminated individuals' names were not being deleted from the assigned selection pools in a timely manner. Although there is a mechanism in place to delete terminated employees from the selection pools, the inspectors identified individuals on the generated lists that had been terminated for over 3 weeks. The licensee stated that they would review the concern and, if needed, develop and implement corrective actions. This matter will be reviewed further by the NRC. (IFI 50-213/93-23-03, 50-245/93-30-03, 50-336/93-25-03, 40-423/93-27-03).

During discussions with licensee management, the inspectors found that the licensee had failed to report unsatisfactory performance testing of blind specimens by the licensee's contracted Health and Human Services (HHS) laboratory within 30 days of the receipt of the investigative findings and corrective actions taken by the HHS laboratory, as required under 10 CFR 26, Appendix A, Section 2.8(e)(4). In December 1992, the licensee was notified by the laboratory of false negative test results. Six weeks later, the licensee responded, in a letter dated January 15, 1993, by requesting the laboratory to investigate the unsatisfactory performance testing results. In a letter dated September 30,1993, nine months later, the HHS laboratory reported its investigative findings and commented on the issues associated with the false negatives test results. While the licensee's use of the laboratory was found acceptable, the licensee had not evaluated the laboratory's findings and was therefore found not to have accomplished it's investigative responsibilities. Also, the licensee had failed to send the signed and dated investigation to the NRC as a report of unsatisfactory performance. That had prevented the NRC from ensuring notification of the findings to the Department of Health and Human Services. In regard to this failure, the licensee stated that, based on discussions with other utilities and with information received through FFD seminars, they had concluded that there was no requirement to report false negative test results. The inspectors informed the licensee

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that, based on the Rule, the report should be made.

Licensee failure to evaluate the laboratory's findings and report the investigation findings to the NRC were found to be an apparent violation of 10 CFR 26 requirements for investigating and reporting unsatisfactory performance testing results. (VIO 50-213/93-23-04,50-245/93-3044,50-336/93-25-04,50-423/93-27-04).

6.0 Audits The inspectors reviewed the licensee's annual Quality Services Department (QSD)

audit report for 1993, Audit #A-30223, which was performed September 20 - October 5,1993. The audit reported four findings and three recommendations. One of the findings addressed the issue of the licensee's failure to evaluate and report unsatisfactory performance testing of blind specimens. Inspector review concluded

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that the audit was comprehensive in scope. Additionally, the licensee performed an

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. independent evaluation of the FFD computer system from September 28 - October 28, 1993, to address concerns identified to licensee management by the medical units.

The licensee's evaluation identified and supported most of the concerns, and directed licensee management to aggressively pursue effective corrective actions.' The inspectors determined based on audit reviews and discussions with licensee management that the audit program as designed was effective in identifying -

programmatic weaknesses and that the findings were being reported to the appropriate levels of management. No discrepancies were noted.

7.0 Exit Interview The inspectors met with the licensee representatives identified in Detail 1.0 of this report at the conclusion of the inspection on November 18,1993. At that time, the purpose and scope of the inspection were discussed with licensee management, and

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the findings were presented. The licensee acknowledged the inspection findings.

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DATE ENTRtES As detes are entered in the MMODYY (e.g. 05/1241) format.

RFPORT NUMPF A$

As Report Numbers ese entered as Aw digrt numeric (e.g 91001) values.

Ev]CirET NUMBER II t> CENSE NUMRER For reactor / vendor and materlaJs espections, docket related/part 21 and ER ltems, the approprkrte 8 dg't numerm number is emered For mate a hspectons, either the Scense rutnber or the docket number must be g6verL Ucanae numbers are entered exactly as they appear on the kcenses, inciuoe';

byphens and leasng zeros.

UoOaTE The Update selection is used to in6cate that the item being entered is an update to a prevlously recorced item. It Update es setected. also en:er the acoropria a cocument number that ongennsy opened the item: Inspection Report Nwmcer (Opened t/R). ER rumber, Part 21 Log number, or IFS numoer.

$FOUENCE NUMPER For reactor / vendor and matenalinspectons, a segsence number is reg **d for each item identffbed h the repor1. For reactor / vendor hspections a seoverse is number is entered when a "Y" was entered for ' OPENED ITEMS (Y/N)% kmilarty. a seovence number is tecuired for materalinspectens it "N" was prowoe:

in the *CEAR (Y/N)" fleid. Enter an unsove geouence number for each open Rem included in the report. Seovence numbers are cWy apphcable 1:r reactor / vendor and maternalinspectsons.

STATUS For each docaet ksted on the report, bdicate tne appropnate status code. Appropnete values are 0-Open. C-Closed. W Weherown. and N * Not Apphcac e tt is regsed that "5TATUS" be fined in for each docket. This Acid es appkcabhe for all nems.

ITEM TYoE FUNCTL aoEA$

{aOSE CTE Enter the four dei code to becate the For reactor / vendor inspections, docket Enter the two eget come oescremg ":

enspectonAnwest.gation Anongs Item type re sted/Part 21 or ER ltems, enter tne SALP cause. A mammum of two cause codes a e is acchcanis for as nems The tonoung nem f.nctional area codes. A maximum of two permmed. Shown below is a ksteg of t 4 types are permetted; funcoonalatea codes are permnted. Use the valed cause codes and what they represe 8st fumeshed becer to Octaan the approprete stem functionaf area codes.

M Desertrmon Functs Area Corte Desentfon Cause Cooe Meerwoo EEI Escalated Enforcernent item DEV Dewaton OPS Plant Opersuons

R eiate d 1o Proeedue

IFl inspecten Followsp

  • RADCON Rasological Contro4 instruction. Desmng URI Unresolved issue
  • MS Mantenance/Survesnance

Lack of Procedure Vt0 Viosation EP Emergency Preparedness

innaeounte Proteaure

SEC Securtty

Engmeereg ot Design Defic.ca:.

  • ET54 Engineer >g/ Technical Support

Inaceounte Testeg

$Uppt EMENT AUX Aunihary Systems

Personnet Error CONT Contanment. Major Structures.

C o gnit sw e Error (Perec*

A mammum of 2 supp6ement codes may te and Major Steel Supports knowledgestie Just An Errce entered for reactor / vendor and materials ElfC DoctncaJ Eguspment and Cabees

Coenmunication Error

llems. At leest 1 is regared it hem type as ET54 Engmeering/f echrscai Support

Potentet Wrongdoeg ED or VIO.

INST instrumentation

Personnel Error Due to Laca e MECHC Mechanical Components or inaaewate Trairung Sucolement N/A Not Apphcable a0 Supervison / Manageme -

{pde Descr't*on OTHR<:

Ot tie r Special Area for Control Construction / Pre-operational

enadequate Re s our c e s -

Reactor Operations Testmg Ecutoment or Stamng

Facetty Construction CTHR4 Other Spectat Area for

f outpment FaMure

Sateguards Operat6ons / Startur Testmg

Agmg

Heafth Physts 10 CF A Part 20 PIPE Pipmg Systems and Support

Random Eavipment Fadure

Transportaten SAQU{

Safety Assessment / Chairty

External (Torreso. Lightne;

Fuel Cycte And Materials verification

Otner Operatens SAOWC Safety Assessment / Oualfty

-

M:scehaneous Matters verAcat on

Emergency Preparedness

$F Soits and Founcatens o

r...

.

i

_ _ _ _ _ _ _ _ _ _ _ ___

_ _ _

_ __.__ _ _____ _ _ _ _

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,

IFS Data Entry Forrn - Reactors inspection (continued)

Update? (Y/N): _J)_

(_Dpaned h Number:

4 3 -30, Q 3 ol., Cil ol'7

'" Sequence NBR: DA Item Type: 2 Pir

"Severit' : dA

" Supplement:

'

y

-

,

Status

'UPD l!R

'Proj. Closeout

  • Actual Closeout A

O OT ib0 /$

_, _ _. _ _

B C

Of__t}Q_tf

_ _ _ _

c

or:10 d1

_ _ _. _

T.: e _O et-Q:nsfir7UMCn/ftv) bfluffftr PrlC Gaf (E*1.pga k SS D WNcnaracter w,atn; V

C:osecut Org:

"Closecut EMP:

' Contact EMP:

  • Procedure:

'Functi Area:

(ode-

"Cause CD:

"EA Number:

"NOV/NNC lssue Date:

/ _ __

_,_

Ymw, O ca 4 t/m h v d de1ChotA3 dal k /t4Jprnd$rb& e[

Text:

. fark bov

' 40'. f.% f.

dfh~

v4'l b h APD-Wfin n e A (14-a /Y-r1

[/

/ y

~

'

!

l Upcate') (Y. N): A)

(Openedh Number: 73-dO @ ol.T, 93 ol7 l

  • " Sequence NBR: _O3 Item Type: n_I

"Severdy: 2f4'

" Supplement:

/

-

,

Status

'UPD !!R

'Proj. C osecut

' Actual Closeout A

0[1)Q_I_{f

_

!

B C

dih/f_r<(

__.___r_

6L QiQ c

<

.

,

T> ie '

(</ &

04 ffirtf0W1 EfIdrO!!) 4Md/\\

(55 cuavacter w>a:n>

Closecut Org'

'Closecut EMP:

'Conta EMP:

  • Procedure:
  • Funct) Area:

Code

  • Cause CD:

"EA Number:

"NOV/NNC lssue Date:

/

_,_

jfo k#ll 43 f4d f In M7G as n rfD in cq I w b k / <ff fk k /V) per<f b l

Test:

--

C4D/la hr,/

Y

/)*ll f

Upcate? (YJN):_

OpenedIR Number:

{

"* Sequence NBR: __

ltem Type:

" Severity:

" Supplement:

i

,

Status

'U PD 1;R

  • Proj. Closeout
  • Actual Closeout A

j i

i B

/

/

/

r C

y

,

,_

,

T;t'e -

(55 character widin)

Ciosecut Org-

  • Closecut EMP:

' Contact EMP:

  • Procedure:
  • Funcil Area:

,

C de

'Cause CD:

"EA Number:

"NOV/NNC issue Date:.

/

<

_, _ _.

Text:

n

_

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

r

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NFC FOf3M um (&91}

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IFS Data Entry Form (continued)

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