IR 05000280/1991005
| ML18153C604 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/18/1991 |
| From: | Tillman A, Tobin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C601 | List: |
| References | |
| 50-280-91-05, 50-280-91-5, 50-281-91-05, 50-281-91-5, NUDOCS 9104230051 | |
| Download: ML18153C604 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-280/91-05 and 50-281/91-05 Licensee:
Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.:
50-280 and 50-281 Facility Name:
Surry 1 and 2 License Nos.: DPR-32 and DPR-37 Inspection Conducted:
March 12-14, 1991 Inspector:
t
\\5Y""r-
/
~~ J. Tobin, Senior Safeguards Inspector
~dJ:c~ Th
../'.jt Tillman, Safeg~pector Accompanying Personnel:
R. Manili, Safeguards Reviewer, ONRR Approved by:
\\ ~
Scope:
D. c ui Safeguards ion Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards SUMMARY 41 g /'?JI Date Signed 4/S(C)t Date Signed v(J/<;1 Date Signed This special, announced inspectibn was conducted in the area of the licensee's Fitness For Duty Program as required by 10 CFR Part 2 Specifically, at the the Surry Station, the inspectors reviewed 'the operation of the site Collection and Preliminary Testing Facilit Results:
In the areas inspected, violations or deviations were not identifie The lic~nsee tests for a broader panel of drugs then NRC requires and uses more restrictive cutoff level The inspectors found the actual operation of the Fitness For Duty Facility to be very well run and professionally staffe ~866~80 PDR ADOCK PDR Q
i J
~~~---~--~*---~------ Persons Contacted Licensee Employees REPORT DETAILS
,'
- S. Cornwell, Corporate, Super~isor of Management Information N. Cross, Corporate, Manager of Employee Health Services
J. Haddock, Supervisor, Flour Daniels (Interviewee)
- D. Hart, Quality Supervisor M. Kansler, Station Manager J. Larson, Westinghouse (Interviewee)
- C. Luffman, Sta ti on Security Manager
__
J. Patrick, Training Supervisor (Interviewee)
- J. Price, Assistant Station Manager
-
W. Runner, Corporate, Director of Nuclear Administrative Services
$. Tausignant, Access Receptionist (Interview~e)* *.
D. Tucker, Fitness For Duty Technician C. Warmick, _Administrative Clerk (Interviewee)
- O. Wegman, Fitness For Duty Coordinator F. Williams, Fitness For Duty Supervisor R. Wilson, Auxiliary Operator_(Interviewee)
NRG Resident Inspectors
- W. Holland, Senior
- Attended exit interview Program, Procedures, Personnel The licensee's.FFD Policy was previously reviewed at the North Anna Station along with the inspection conducted at thi VEPCO. Corporate Offices in Glen Allen and Richmond, Virgini *
Currently it is the licensee's FFD procedure to test as follows:
Preliminart Levels ng/ml Confirmator1 Levels ng/ml Marijuana 50 (100-NRC)
10 (15-NRC)
Cocaine 300 150 Opiates 300 200 (300-NRC)
Amphetamines 1000 500 Barbiturates *
200 200 Benzodiazephines *
300 300 Methaqualone *
750.
750-Phencyclidine
20 (25-NRC)
Alcohol
.04% BAC
.04% BAC
- - Not in NRC drug testi.ng pane * The licensee continues to use Procedure ASNS 105-as its key implementing FFD documen Since the North Anna/Corporate inspection the licensee has revised its technitjue for puttin~ "holds" on those *candidates who for various reasons cannot be tested upon being randomly chosen.. Previously the licensee allowed a candidate three opportunities of being unavailable (offsite, leave, etc.) before being placed on "hold" for a pre-access required test prior to being badged upon retur Currently, a second occasion of ~eing unavailable results. in a "hold" on a person's badg In 1990 the licensee tested 105 percent of its entire nuclear population of 1831 individual_s; 1095 ltcensee employees and 736 contractor employee * From June to the end of December 1990 (seven months), the followin*g irregular ho~r tests were performed:
- 42 * - weekends 8 - holidays 151 - weekday backshifts 201 - Total The licensee schedules weekend testing one day per month.
The licensee employs a proprietary Site FFD Administrator and a contract
- technician service to perform day-to-day collection and prelimina-ry testin All personnel charged with administering or implementing the testing are part of the population pool, and the licensee has instituted administrative safeguards to prevent circumvention of testing by those personnel related to others in the population poo Collection Facility The Collection Facility is *located along with the Security Access Processing Unit in a double-wide trailer exte"rior to the protected are A floor to ceiling wall separates the two functions allowing the Collection Facility with about half the trailer spac Seven parking spaces in front of the tra.iler are reserved for Fitness For Duty candidate *
I
During *irreg1,1lar hq1.1rs the facility is locked and secured. with a combination of door alarms (2) and motion detector Security patrols are the responsibility of both the onsite licensee's security force as well as a contract force assigned to the buildings and warehouses exterior to the protected are During operation, the.technicians inside the Collection Facil"ity or.inside the Preliminary Laboratory have nearby duress.alarms to summon the licensee's security patrol There are two locked refrigerators inside the facility and keys are assigned to each technician
.and to *the FFD Site Administrato Backup electrical power is provided by an emergency diesel located_ outside the facilit...
Appendix A to the Rule, Subpart B, paragraph 2.*3(g)(5) requires outer garments remain outside of the room in which samples are collected. * Due to the floor plan of the licensee's Collection Facility all candidates exit through a rear door, thus the need for clothing lockers interior to the Facility yet exterior to the bathroom in which samples are collecte This unique situation allows the technicians to better control candidates*
entering and exiting the facility on an almost one-on-one relationshi To compensate for the requirement of the. Rule the licensee has placed the clothing lockers away from the restroom collection area and has the technicians monitor the. individuals removal of outer garments which are stored inside the lockers near the exit door.* It is noted that during the Summer of 1991 the facility will be moving to a new Administration Building adjoining the protected area perimeter and this minor renovation can be correcte During this inspection several candidates undergoing pre-access or random testing were monitored by the inspectors throughout several day The inspectors witne.ssed the process from the time of the candidates entry into the Collection Facility foyer which included positive identification,.
documentation of drugs taken over the last 30 days, breath analysis, urine specimen collection, temperature. and Ph/specific gravity. verification, specimen splitting, sealing, initialling, chain-of-custody initiation, and final storage inside a locked refrigerator.* Prior* to the candidate exiting the facility the Permanent Record Log is verified and initialle Through the use of a 11multi-stix reagent strip" the technicians measure Ph (acidity) and specific gravity' (water weight).
Creatinine (kidney meltabilities) is measured at the laborator *
The inspectors noted that*the candidate is not only asked to list those medications/prescriptions taken in the last 30 days but is also asked why the medication was taken, i.e. allergy, diet, muscle relaxers, asthma, et The licensee has found that this additional request has challenged the memory of candidates allowing them to remember all medical/dental/
optical treatment in the last 30 day The inspectors voiced a concern over the sterility of the thermometer used*
to measure the body temperature of the urine specime Appendix A to th Rule, Subpart B, paragraph 2.4(g)(13) requires that the device used to measure the temperature of the specimen must not contaminate the specime It is the procedure * of the *licensee to rinse off the probe of the thermometer, wipe it dry, and place it in a cup containing rubbing alcohol (methane 1).
This is done each time a specimen is measured for temper- *
atur The inspector was concerned that residual urine from a prior candidate's specimen may still be on the thermomete The licensee stated that the Medical Review Officer has evaluated this technique. and found it to be adequate to prevent specimens contaminatio *
The inspectors reviewed the.training and qualification records of the Collection Facility Technicians, witnessed performance and have concluded
- the licensee is in compliance with that part of the Rule requiring experience and training of FFD personne.
Preliminary Testing Laboratory The licensee 1 s contractor operates the Preliminary Testing Laboratory as a separate office adjoining the Collection Facilit It is secured and access is controlled as stated earlier in this repor During this inspection the contractor supervisor was witnessed in the process of running six specimens through the Hitachi (Model No. 705) analyze No weaknesses were observed with the preliminary tests nor with the calibration of the equipmen The supervisor*exbibited a knowledge of and experience with the preliminary testing process, documentation of results, chain of custody and storage requirement Although the licensee could document the Laboratory Supervisor 1 s certification as a Clinical Laboratory Technologist registered with the U. S. Department of Health Education and Welfare there was little else in her personnel file to* reflect 11equivalency
to the requirements of Appendix A, Subpart B, paragraph 2.6(a).
Such Laboratory supervisors, 11 *** shall have at least a bachelors degree in chemical or biological sciences, medical technology or equivalent.
The licensee explained that its Quality Assurance auditors identified this issue in mid-1990 and that 11equivalency
was determined based upon other Rule requirements for experience, practice and understanding of testing procedures, interpretation of results and reporting of*test result The inspector suggested and the licensee agreed to document this 11 equivalency
determination in a more formal and auditable manne Proactive Measures With respect to those measures taken in excess of the Rule, the licez,see conducts contraband searches (patdown searches which include checking the wallet, keycase and handkerchief) in addition to the normal 11walk-thru
searches of personnel entering the sit The 1 i censee averages approximately 1500 of these searches each mont For all licensee employees, including non-nuclear personnel who fail a clearance, psychological test, violate a utility rule, or receive some type of disciplinary action, the licensee has a utility-wide 11denial/bar 1 ist.
Depending on the infraction the security force knows those individuals who are to be denied access or to be escorted under a limited access restrictio There is an 11 Ethics Inquiry 11 telephone number which employees can use to voi\\:e complaints or furnish information to the Employees Relations Coordinator at the Corporate Offic '
Canines have been used to conduct quarterly unannounced seq.rches of parking lots, office spaces, and locker About 25 percent of the
.,
licensee's *security force are former law enforcement officers familiar with the symptoms of alcohol and drug abus.
Quality Assurance Audit The onsite Quality Assurance auditors had completed the March 6, 7, and 8 audit (No. 91-04) of the Surry FFD progra This audit was both comp 1 i a nee and performance based, and used a contract Medi ca-1 Review *
- Officer to evaluate the confirmatory laborator The in$pectors had noted several auditors spent hours inside the Collection Facility based upo their recorded access as documented in the Permanent Record Lo While the results of the audit were sti 11 "draft" the inspector reviewed the report and found that the auditors concluded the licensee 1s program is effectively implemented and in some cases there were several strength There was one obs~rvation" relative tri FFD supervisor training of those personnel assigned continuous behav.ior observation duties.*
Several
"enhancements" were also suggested relative to cut-off levels, for cause test results, and additional tests to establish the reliability of the*
preliminary test.
Appeals/Records Discussions were held with the. approp.riate individuals from the NRC 1s Office of Nuclear Reactor Regulation knowledgeable in the requirements of Part 26 relative to individuals. having access to their FFD testing record The inspector received guidance to the extent that those records*
in question are the records needed by an appealing individual to challenge the accuracy of the test Thus is was agreed with the 1 i censee I s FFD Corporate Manager that the 1 icensee' s records to be furnished an individual upon written request were as folJows:
In-Process Traveler Instruction for Participants in the NRC Chemical Testing Program Virginia Power Chain of Custody (2-sided document)
Permanent Log Book (individuals entry only)
Intoxiliser Card
~
.
Preliminary Results (Carpenter Medical Laboratory)
Confirmatory Results (Roche Laboratory)
Confirmatory Results Chain of Custody MRO Checklist Positive Chemical Test MRO FFD Appe~ls Checklist Exit Interview The exit meeting was held on March 14, 1991 with those so noted in paragraph 1 in attendanc The licensee was informed that there were n Yiolations and that its FFD program was meeting the general performance criteria of Part 2 The licensee was also informed that the results of the limited interviews of employees and contractors were favorable and reflected a supportive opinion of the progra Several strengths were noted; a greater panel of drugs than NRC requires, more restrictive cut-off levels for some drugs, and the professionalism of the FFD staff and its facilitie No exceptions to the inspectors findings were voice.
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