IR 05000269/1991015
| ML16148A537 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/08/1991 |
| From: | Mcguire D, Tillman A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16148A536 | List: |
| References | |
| 50-269-91-15, 50-270-91-15, 50-287-91-15, NUDOCS 9109100030 | |
| Download: ML16148A537 (8) | |
Text
PA REa,
-
UNITED STATES o
NUCLEAR REGULATORY COMMISSION
REGION II
o 101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-269/91-15, 50-270/91-15, and 50-287/91-15 Licensee:
Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-269, 50-270, License Nos.: DPR-38, DPR-47, and and 50-287 DPR-55 Facility Name:
Oconee 1, 2, and 3 Inspection Cond te July 9-11, 1991 Inspector:
/
A. Till e uards Inspector
'Da igned Approved by:
RA/
D. R. McGuire, Chief ate Signed Safeguards Section Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This special, announced inspection was conducted in the area of the licensee's Fitness For Duty (FFD)
Program as required by 10 CFR Part 2 Specifically, the licensee's policy, program administration and key program processes were reviewed utilizing NRC Temporary Instruction 2515/106, Fitness For Duty Initial Inspection of Implemented Program, dated July 11, 199 Results:
In the areas inspected, violations or deviations were not identifie Based on selective examination of key elements of the licensee's. "Fitness for Duty" Program it was concluded that the licensee was in compliance with, and was meeting the intent of the general performance objectives of 10 CFR Part 2 Several strengths were noted in the licensee's FFD program including a professional and well trained staff in the Site Collection Facility, a knowledgeable and dedicated site FFD Program Administrator and an effective, supportive Employee Assistance Program Coordinato Procedural requirements and practices at the Site Collection Facility were determined to be positive and adequat However, the adequacy of "chain of custody" of collected specimens while in transit between the Site Collection Facility and the receiving laboratory appear-to warrant further revie PDR ADOCK 05000269 Q
REPORT DETAILS 1. Persons Contacted Licensee Employees
- G. Addis, Superintendent Station Services, McGuire Nuclear Station (MNS)
- C. N. Alexander, Director, Power Group Human Resources, Duke Power Company (DPC)
- B. Caldwell, Superintendent Station Services, Catawba Nuclear Station
- (CNS)
- A. Clark, Security Specialist, Oconee Nuclear Station (ONS)
- J..Coulter, Manager, Employee Assistance Program (EAP), ONC
- I. R. Crawford, Program-Administrator -
FF0, DPC
- J. Davis, Acting Station Manager, ONC
- G. Dukes, Medical Review Officer, DPC
- E. H. Dummeyer, Quality Assurance, ONC
- N. Hammett, Security Specialist, ONS
- 0. Kohler, Licensing Coordinator -
Compliance, ONS
- T. K. McQuarrie, Manager, Security, ONS
- S. P. Murdock, Manager, Nuclear Access and Fitness For Duty, DPC
- D. Penell, Superintendent Station Services, ONS
- S. C. Perry, Assistant Licensing Coordinator - Compliance, ONS
- P. Rice, Supervisor, Occupational Health, ONS
- R. Wilkerson, Manager, Nuclear Planning and Consulting, DPC Other licensee employees contacted during this inspection included craftsmen, engineers, security force members, technicians, and administrative personne Other Organizations N. Bridwell, Courier, Smithkline Beecham Laboratories NRC Resident Inspectors P. Harmon, Senior Resident Inspector, ONS K. Poertner, Resident Inspector, ONS B. Desai, Resident Inspector, ONS
- Attended exit interview 2. Licensee Written Policy and Procedures Management Procedure No. 101.07, titled, "Alcohol/Drug Use," revised as of April 1, 1991, implements the licensee's Fitness For Duty (FFD) program in accordance with the requirements of 10 CFR Part 26. In addition, a series
of unnumbered procedures addressed various aspects and program functions as follows:
a. Medical Procedures Urine drug screen testing (NRC)
Alcohol breath analysis testing Processing split urine specimens for appeals Intoximeter 3000 accuracy check Log book entry procedure Appendix "A" Direct observation of urine collection Process for submitting blind specimens Intoximeter 3000 certification b. Testing Procedures Random d'ug and alcohol testing and scheduling Holiday, weekends and night shift testing Fitness For Duty Reporting Requirements Record Keeping Requirements e. Confidentiality/security Review confirmed that the procedures were current, detailed and addressed pertinent requirements of the program to include; call-in procedures, searches, appeals, for cause testing, random testing, abstention period, referral to Employee. Assistance Program and management disciplinary sanctions. The prohibition against alcohol abuse, on-duty use of alcohol and drug sale or possession on or off company property was clearly defined. In addition, a vendor/contractor policy statement summarizes the key points of the licensee's FFD policy for vendor/contractor employees covered by 10 CFR Part 26, and is detailed in the licensee's FFD procedure for vendor and contracted personnel with unescorted access to nuclear stations and/or access to the Crisis Management Center and the Technical Support Cente. Program Administration a. Management Responsibilities Review and observation of routine FFD activities during the course of the inspection revealed that the Oconee FFD Program Administrator was responsible to the site Supervisor, Employee Relations who in turn reported to the Site Superintendent of Station Service Discussion confirmed that the FFD Program Administrator was knowledgeable and highly dedicated to program requirement Responsibilities were clearly defined and management support for the program was eviden Observation of routine and unscheduled activities *verified the programs functional efficienc b. Resource Allocation Tours of the licensee's FFD program facilities and discussion with assigned personnel confirmed that adequate staffing and facilities were provided and functioned in a highly efficient manne The FFD Program Administrator was assigned an assistant who was trained and qualified to act as backup in the absence of the primar The collection facility was staffed with four full-time and two part-time registered nurses, one technician and one clerical positio All personnel observed in the collection facility demonstrated a high level of competency and professionalis The collection facility, located on the first floor of the Oconee Administration Building outside the protected area, was of sufficient size and appropriately equipped to provide efficient collecting, testing and control of specimen Adequate security for the facility, collected specimens and associated documentation was demonstrate Employee Assistant Program (EAP)
Discussion with the site EAP Coordinator and observation of coordina tion and interface efforts demonstrated by the EAP Coordinator and the FFD Program Administrator in response to receipt of notification of an employee related event that impacted both functional areas, confirmed the validity and effectiveness of the licensee's established EAP and FFD programs. It was noted that immediate actions relative to notifications, coordination and employee assistance were. initiated in accordance with regulatory requirements and licensee commitment Review of the licensee's established EAP and related documentation revealed that it was broad in scope and was effectively administere. Training Policy Communication Two booklets, entitled "Fitness For Duty 1990" and "Fitness For Duty, Supervisors Guide," were furnished to attendees at the FFD training session b. Training The licensee's awareness training conducted prior to the effective date of the rule was randomly witnessed by the Senior Resident Inspector utilizing NRC Temporary Instruction 2515/104 and was documented in Inspection Reports No. 50-269-270-287/89-36 and 50-269-270-289/90-0 The licensee adequately addressed initial concerns noted in the areas of behavior observation and escort trainin A limited sampling of supervisors and employees authorized to perform escort duties were interviewed and found to. be knowledgeable of the FFD Program and their inherit responsibilitie It was noted during interviews that the personnel had retained knowledge of, and were very familiar with the FFD Program requirements and responsibilities, which indicate that the training presented was effectiv. Key Program Processes Random Testing The licensee's FFD Program Manager located in the General Office provides the site FFD Program Administrator with computer generated randomly selected lists of personnel to be tested via computer termina The lists, consisting of primary and alternate selectees for daily testing is provided on a weekly basis and includes approxi mately two percent of the total number of personnel authorized unescorted access to the site. It was noted that personnel selected for testing on a specific date are re-entered in the selection pool and become candidates for selection on subsequent dates. However, as noted during inspection at the licensee's other nuclear facilities, a newly badged individual entered into the system after the weekly random selection was completed would not be subjected to random selection for a maximum period of seven days. Newly badged personnel are -entered into the FFD computer system in "batches" on a weekly basis. The licensee contended that entering newly badged personnel in the system on a "as badged" basis was not feasible relative to the selection proces With regard to random testing during non-regular hours, the licensee conducts tests on three of nine annual holidays and on five percent of weekend (8) and night (18)
shift Review of test schedules and related documentation confirmed compliance with the established rate of testing with the exception that random testing was being accomplished on seven rather than eight weekend shift It was further determined that the licensee had assumed a normal 4-day work week in mid-1990, resulting in 3-day weekends, and had not made the necessary adjustment in the random selection program for weekend testing. The licensee agreed to make the necessary adjustment to the selection program to ensure that random testing was accomplished as a minimum of eight weekend shifts. in calendar year 1991 and annually thereafte Chemical.Testing The licensee's test and collection facility at the Oconee Nuclear Station tests a minimum of eleven employees and two contractor employees during each routine duty da In addition, random followup, for cause and pre-access testing is conducted on an as needed or required basis..Observation of testing and collection activities on July 10, 1991, revealed that personnel authorized
unescorted access to any of the licensee's nuclear facilities, when selected for testing, are tested at the facility in which they are located on the date selected for testin During the period of January 1 through June 30, 1991, the total number of personnel randomly tested at Oconee Nuclear Station with frequency of testing-as indicated, are as follows:
Frequency Tested Licensee Vendors
759 225
226
3
14
9
5
0
4
Totals:
1053 300 A tour of the licensee's medical facility at the Oconee Nuclear Station, discussion with the medical staff-and observation of routine testing and specimen collection did not identify any deficiencies in the collection and testing proces It was further determined that the licensee's method and procedures for testing and collecting specimens, identification, storage and release to laboratory couriers was adequate and acceptabl It was noted that the licensee had implemented appropriate corrective action for a concern relating to
"chain of custody" of collected specimens upon release to laboratory couriers identified during the inspection of the licensee's FFD Program at the McGuire Nuclear Station April 16-18, 199 The corrective action included verification of individual. specimens, tamper sealing of containers and certification by signature of the maintenance of "chain of custody" by the medical testing facility releasing authority and the receiving laboratory courier However, there was no indication that the "chain of custody" by signature receipt was maintained in transit between the collection facility and the receiving laboratory. The specimens are routinely transported in a tamper sealed containe Discussion with the licensee's FFD Program Manager and Medical Review Officer and review of a licensee report of the loss of a drug screening specimen in transit from the licensee's Catawba Nuclear Station to Smithkline Beecham Laboratory in Chicago, IL revealed that the specimen remained unaccounted for and.the circumstances of the loss had not been establishe Investigation by the licensee and Smithkline Beecham Laboratories in Atlanta and Chicago confirmed that the specimen left the site collection facility in the custody of the courier, but concluded that the specimen was never received at either
,the Atlanta or Chicago Laboratories. The licensee had instituted a
procedural change that required the courier.to receipt for specimens to be shipped by requisition numbe Implementation of the revised procedure was confirmed during the FFD inspection at Oconee Nuclear Statio c. Audit Review of Departmental Audit No. FD-91-01, Fitness For Duty Program, dated June 19, 1991, revealed that the licensee's Quality Assurance function had performed an audit of the FFD Program at the General Office and the three nuclear stations during the period of April 8 through May 28, 1991. Review of the Audit Report and discussion with FFD Management and Program Administration personnel from the General Office and the Oconee Nuclear Station revealed that the audit was thorough and detailed in scope. The audit identified one finding relating to call-out procedures, generic to all three nuclear stations, four followup items and five observations, none of which were applicable to the Oconee FFD Progra The licensee had implemented appropriate corrective action for the identified findin.
Exit Interview The inspection scope and results were summarized on July 11, 1991, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in. detail the inspection results listed belo Dissenting comments were not received from the license The licensee was informed that no violations of regulatory requirements were identified during the inspectio Observations and strengths relative to the effectiveness of the licensee's FFD Program were noted, specifically with regard to the well staffed and professionally operated collection facility, the knowledge and dedication demonstrated by the FFD Program Administrator, and the apparent effectiveness and support provided by the Site Employee Assistance Program Coordinato The adequacy of "chain of custody" of collected specimens in transit between the site collection facility and the receiving laboratory was briefly discussed and the licensee was informed that the issue may be subjected to further revie II
NteroA"Mu U.S. NUCLEAR REGULATORY COMMISSION P Iwea Cy awar mAno woIW 1548)
NAR MC am INSPECTOR'S REPORT Office of Nuclear Reactor Regulation INSPiCTORS LICENS(E VENDOR DOCKET O
6so.gts Da LICEINSE REPOT 0(XT INSPIC DATE
/
-ISTYf NO Y PRODUCT ngts 0o
$0 MO YRt M - MODIFY
-
DELETE A
- REPLACE F
i IS
-
o PERIO OF INVESTIGATION RNSPECTION INSPECTION PERFORMED BY ORGANIZATION CODE OF REGCN 'NO CONDUCT FROM to I - REGIONAL OFFICE STAFF OMER IG ACTIVITY ISP, IEMIC 05X
&ddae rEDO'
MOD DAY YP MO DAY I 2 - RESIDENT INSPECTOR is ANCm 3 -
PERFORMANCE APPRAISAL TEAM D
a
33
33 St
REGIONAL ACTION TYPE Of ACTIVITY CONDUCTED Cwek ow bo. ene
IChech o
y3-SAFETY
.0M
- MGMT VISIT to - PLANT SEC 14 -
,thOUIAY I - %PCFORMSI 03 -
INCIDENT 07 - SPECIAL 11 - INVENT VER 15 - INVESTIGATION 2 -
REGIONAL OFFICE LETER 0o - ENFORCEMENT (
- VENDOR 12 - SHIPMENT EXPORT S - MGMT AUDIT 0 - MAT ACCT 3-IMPO T thbPRCIONhvET I
N a*
DI N6 TOTAL NUMBER ENFORCEMENT CONFERENCE REPOT CONTAIN2 g LETTER OR REPORT TRANSMITTAL DATE OF VIOLATIONSAND NEI INFORMATION A
I C 0 DEIATIONS NRC FORM W1 REPORT SENT 1 - CLAR ORR EG TO NO FOR 2 - VIOLATION LETTER ISSUED ACTION 3 - DEVIATION
0 C
A C 0 1-C D
40-4,
43 4950
OR MODULE NUMBER NSF MODULE RED FOLLOWUP MODULE NUMBER INSP DULE REO FOLLOWUP
L2 I
I I4
I
I
II I
.
L U-A IIY I LLI--wf I flIIw J
IL II a
IL wI JI I
li1 I
il lilI -
LJI II-II ft~
I iTh
fl
~
I f II s-IM II II
-
IIL LI ZI i II II
~
I II CC B
I II I
I I
_
_
-
1
12 13
16
I9 20 21 26 1J 2 1 50
3
'5 16
9 20 2
%PC FORM '66 5. 8: