IR 05000295/1998006

Insp Repts 50-295/98-06 & 50-304/98-06 on 980330-0403.No Violations Noted.Major Areas Inspected:Plant Support

ML20217L813
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/23/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217L810	List: IR 05000295/1998006 ML20217L804
References
50-295-98-06, 50-295-98-6, 50-304-98-06, 50-304-98-6, NUDOCS 9805040304
Download: ML20217L813 (11)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos: 50-295;50-304 License Nos DPR-39; DPR-48 Report Nos: 50-295/98006(DRS); 50-304/98006(DRS)

Licensee: Commonwealth Edison Company Facility: Zion Nuclear Plant, Units 1 and 2 Location: 101 Shiloh Boulevard Zion,IL 60099 Dates: March 30 - April 3,1998 Inspectors: J. L. Belanger, Senior Physical Security inspector ,

G. L. Pirtle, Physical Security inspector Approved by: James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety l

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l 9805040304 990423 PDR ADOCK 05000295 G PD l

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EXECUTIVE SUMMARY

Zion Nuclear Plant, Units 1 and 2  ;

NRC Inspection Reports 50-295/98006; 50-304/98006 This regional inspection reviewed and evaluated the licensee's corrective actions and commitments described in their response to A. B. Beach letter dated January 15,1998, transmitting NRC Notice of Violation and Proposed Imposition of Civil Penalties (EA 97-249).

Plant Sucoort

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The immediate and long term corrective actions for the fitness-for-duty violations (EA 97-249) were acceptable. (Sections S8.1 thru S8.4)

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REPORT DETAILS

IV. PLANT SUPPORT S8 Miscellaneous Security and Safeguards issues By letter dated January 15,1998, the NRC transmitted a Notice of Violation and Proposed Imposition of Civil Penalties - $110,000 (EA 97-249). The four violations contained in the Notice reflected a lack of management commitment to implement the Zion Station FFD policy and procedures. Collectively, the four violations represented a programmatic breakdown in the implementation of the FFD program. The violations were classified in the aggregate in accordance with NUREG-1600 as a Severity Level ill problem. The licensee responded to the Notice of Violation by letter dated l February 13,1998.

The inspectors verified that the licensee completed the corrective actions / commitments described in their letter dated February 13,1998. Based on a review of the licensee's self-assessment (Section S8.4), inspector interviews with station management and employees, (Section S8.1), the licensee's FFD survey in November 1997 (Section S8.4),and the absence of significant FFD incidents over the past six months, the inspectors concluded that the licensee's corrective actions were appropriate and effective.

S8.1 (Closed) Violation 50-295/97017-01: 50-304/97017-01: Failure by three FFD-trained supervisors to require a for-cause test for an employee with the smell of alcohol in the protected area on February 1,1997.

The inspectors verified completion of the following corrective actions:

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Unescorted access for the supervisors was put on temporary hold pending completion of an investigation which began on February 11,1997.

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The licensee retrained the three supervisors (Fire Marshall and two fire watch  !

supervisors)in FFD requirements. The FFD event and program requirements were communicated to station employees through tailgate sessions. The licensee communicated the event and FFD expectations to the other five nuclear 1 stations on February 25,1997.

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Zion Administrative Procedure (ZAP) 1130-00 (Fitness-For-Duty) was revised on July 15,1997 to incorporate the applicable Corporate Nuclear Security Guidelines (CNSG), providing more detail and a flow-chart for handling for-cause testing events. The CNSGs were also made accwiole to employees.

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FFD reminders to actions to be taken upon the detection of the odor of alcohol were published in the station newsletter, "The Daily Plan-It".

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Semi-annual FFD tailgate sessions were established to cover FFD related issues with station employees. The session planned for the first part of 1998 will be

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conducted in May 1998 following establishment of the Zion Decommissioning Organization.

On April 2,1998, the inspectors interviewed eight randomly selected members of the recently announced Zion Decommissioning Organization regarding call-outs, actions upon detection of odos of alcohol, availability of FFD guidance documents, and

employee commitment to the FFD program. Their responses indicated that the

! employees were sensitized to the importance of these issues and that they were fully l committed to the program.

I l S8.2 (Closed) Violation 50-295/97017-02: 50-304/97017-02: Failure of a supervisor (Fire l Marshall) performing a call-out to ask an employee if they had consumed alcohol within the five hour abstinence period on February 1,1997.

The inspectors verified completion of the following corrective actions:

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Counseling and retraining of the Fire Marshall I

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Training in December 1997 by Services Director for all individuals assigned call-out responsibilities. (See Section S8.4)

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Trend investigation to determine root cause for repeated failures of all sites to properly conduct and document cailouts for unscheduled work and for

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individuals' failure to perform as expected after identification of the odor of alcohol. (See Section S8.4)

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Self-Assessment of program effectiveness. (See Section 8.4)

S8.3 (Closed) Violation 50-295/97017-03: 50-304/97017-03: Failure of an employee directed l to come in to the plant on February 1,1997 on unscheduled overtime to inform the caller than she had consumed alcohol within the five hour abstinence period.

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The inspectors verified that the licensee piaced the individual's unescorted access on temporary hold pending completion of the investigation which began on February 11, 1997. The individual's unescorted access was subsequently denied. Additional corrective actions for the specific event are noted in Section S8.1. The results of overall program effectiveness are noted in Section S8.4.

S8.4 (Closed) Violation 50-295/97017 -04: 50-304/97017-04: Failures by an individual to notify his supervisor of violations of the FFD policy which might adversely impact safe operation and maintenance of the station.

The inspectors verified completion of the following items:

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The systems engineer and Emergency Planning Coordinator were disciplined, counseled and retrained prior to reinstatement of their access to the protected area.

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FFD program requirements were communicated to station employees through a June 16,1997 letter which emphasized employee accountability for adherence to FFD procedures.

• Corporate Security personnel developed a program to sensitize Zion employees in their FFD responsibilities. The program, OVER (Observe, Verify, Escort and Report) was incorporated at all six of the licensee's nuclear stations.

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FFD program information was communicated to station employees via the Comed television on a periodic basis.

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Each plant department designated specific individuals who could perform call-outs for unscheduled work tours. The Business Manager personally trained the designated list of individuals. The FFD coordinator was responsible for maintaining the list current and for distributing the list to each department.

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To increase the accountability and visibility of the FFD program, executive management designated station managers at all six Comed stations as owners of the program.

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The licensee conducted a self-assessment of the call-out program to assess it's effectiveness. The Security Self-Assessment Administrator randomly selected a group of ten individuals from different departments on the Authorized " Call-out" personnellist. The interviews consisted of a walk through on how to perform a

" Call-out For Unscheduled Work". All interviewees gave the same correct and confident response to the procedure. Out of the 31 call-outs, there were three procedure failures. The failures were due to personnel not on the " Authorized Call-out List" making call-outs. The three individuals followed the procedures in the CNSG 206, filled out the attachment "A" form and turned them into the Site Security Administrator promptly. Their call-outs were considered improper because they did not have the Business Manager's training. The improper call-outs occurred because of mis-communication between the person performing the call-out and the person requesting the call-outs, the perceived emphasis placed on the call-out list, and a high level of activity distraction. The licensee held the three individuals who made the improper call-outs, accountable for their actions. The Security Self-Assessment Administrator concluded that the corrective action was appropriate and was properly implemented.

. The licensee formed a trend investigation team to determine the root cause(s)for repeated failures at all Comed nuclear stations to conduct and document call-outs for unscheduled work and for individuals' failure to perform as expected after the identification of the odor of alcohol. The team reviewed Quality and Safety Assessment (Q&SA) audits in the past three years and FFD Problem Identification Forms (PIFs) generated recently at the six stations. The investigation was performed January through February 1998. The inspectors found that the investigation was rigorous, self-critical, professional and thorough.

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The investigation team identified four root causes:

+ infrequent task / activity - for many people, conducting call-outs or encountering the odor of alcohol can be an infrequent or first time task.

+ Pre-occupation with job at hand - individuals involved in call-outs were pre-occupied with responding to the issue at hand (i.e. usually major plant evolution or critical act!vity that created time pressure to respond).

+ Lack of consequences of procedural non-compliance - there was minimal or no accountability for individual failures to follow the call-out procedures;

+ Uncomfortable pleasant task to report - people were uncomfortable in confronting and reporting the odor of alcohol for a variety of reasons.

(i.e. don't want to get involved)

The investigation team identified specific corrective actions to address these causes including:

+ Measures to heighten awareness and enhance visibility for call-outs and handling to odor of alcohol at all six nuclear stations.

+ Develop and provide FFD lessons learned for inclusion in safety or tailgate meetings every quarter.

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+ Develop and implement an improved and standard accountability system.

Additionally, the investigation team identified contributing factors for failing to l properly conduct and document call-outs for unscheduleo work and for failing to notify the supervisor of Security after detection of the odor of alcohol. These contributing factors included an insufficient level of management involvement in station Fitness-For-Duty activities; little or no regular proactive effort to include FFD as part of everyday job requirements; and the perception that FFD procedures may not be readily available and are complex. The report identified corrective actions associated with the contributing causes such as the communication by executive management nf their commitment to FFD program to all nuclear station personnel. (A letter signed by the President, Nuclear Generation Group was sent to all Station Managers on March 31,1998 with a l

statement that First Line Managers are accountable to assuring that FFD requirements are implemented and followed.)

The inspectors noted that the licensee tracked the completion of each of the corrective actions identified in the trend investigation report under the their NTS (Nuclear Tracking System). Most items were scheduled for completion by June 30,1998 with two effectiveness reviews scheduled for completion by January 30,1999 and February 15,1999.

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""" ment Meedngs X1

Exit Meeting Summary

The inspectors presented the inspection results to licensee management at the conclusion of -

the onsite inspection on April 3,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspecti - ehould be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED Licensee D. Beutel, Regulatory Assurance Department J. Brons, Site Vice President R. Landrum, Operations j T. Marini, Audit Supervisor, Quality and Safety Assessment D. Nelson, Project Manager, William A. Pope Company - JV J. Papaleo, Fitness For Duty Coordinator '

G. Schwartz, Engineering Manager R. Starkey, Station Manager M. Weis, Support Services Director l S. Williams, Site Security Administrator l l

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i D. Calhoun, Resident inspector, NRC Region ill IDRS j J. Yesinowski, Resident inspector, Illinois Department of Nuclear Safety i

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INSPECTION PROCEDURES USED l

l lP 81502 Fitness For Duty Program

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IP 92904 Followup Plant Support ITEM CLOSED l

l CLOSED l 50-295/97017-01; 50-304/97017-0"i VIO Failure to conduct for-cause test

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50-295/97017-02; 50-304/97017-02 VIO Failure to ask FFD questions during call out.

l 50-295/97017-03;50-304/97017-03 VIO Failure to report consumption of alcohol during call-out.

l 50-295/97017-04;50-304/97017-04 VIO Failure to report odor of alcohol to supervision

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• LIST OF ACRONYMS USED BOP Behavior Observation Program CNSG Corporate Nuclear Security Guideline Comed Commonwealth Edison EA Enforcement Action l FFD Fitness For Duty

} IP Inspection Procedure l NTS Nuclear Tracking System I Q&SA Quality and Safety Assessment l VIO Violation l ZAP Zion Administrative Procedure

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PARTIAL LISTING OF

DOCUMENTS REVIEWED

Corporate Nuclear Guideline No. 200, " Comed Fitness For Duty Program", Revision 7, Effective

July 7,1997

Corporate Nuclear Security Guideline No. 206, " Call-outs for Unscheduled Work", Revision 8,

Effective December 19,1997

Corporate Nuclear security Guideline No. 213, " Handling and Storage of Fitness For Duty

l Records", Revision 8, Effective September 12,1997

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Corporate Nuclear Security Guideline No. 226, " Review and Acceptance of Contractor Drug

and Alcohol Testing Programs", Revision 1, Effective July 7,1997

Corporate Nuclear Security Guideline No. 251," Issuing and Documenting Acceptance of the

COMED Contractor and Vendor Fitness For Duty Program", Revision 0, Effective March 27,

1997

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A. Pope Company Procedure AP# 400.03," Call-outs For Unscheduled Work Policy",

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dated January 2,1996 i

Contractor and Vendor Fitness-For-Duty Program Requirements, Revision 6, April 1997

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l FFD Portion of Quality and Safety Assessment Department Audit No. 22-98-01, dated

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Problem identification Form Z97-1414," Fitness or Duty Requirements not Adhered to Per ZAP

1130", March 19,1997

l Problem Identification Form C1097-00607, * Violations of Fitness For Duty Program",

December 4,1997

l Problem identification Form Z1998-00297, " Untrained Individual Performing Unscheduled Call-

l out", February 9,1998

Problem Identification Form Z1998-00305," Untrained Individual Performing Unscheduled Call-

l outs", February 10,1998 I

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Problem Identification Form Z1998-00348," Fuel Handlers Called Out Without Following the

Fitness For Duty Guidelines", February 16,1998

Trend Investigation Report," Adverse Trend in Fitness For Duty (FFD) Requirements

implementation Due to Program Noncompliance" with five attachments, undated

Memorandum from

G. Toleski to Various Addressees, Subject: " Expectations Following

Confirmation of the Odor of Alcohol and New Behavioral Observation Requirements", dated

February 25,1997

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Memorandum from

M. Weis to Zion Station Employees, Subject: " Fitness For Duty Violations

and Ramifications", dated June 16,1997

Memorandum and Attachment from

P. Laird to Various Addressees, Subject: " Failure to

Conduct For-Cause Test", dated June 17,1997

Memorandum with Attachment from

M. Weis to Department Heads and Senior Managers,

Subject:" Unscheduled Call-outs per CNSG 206", dated December 22,1997

Memorandum with Attachments from

G. Stanley and S. Perry to Various Addressees, Subject:

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"FFD- Call Out Program", dated January 5,1998

Letter with Attachments from

J. Brons to J. Lieberman, Subject: " Reply to Notice of Violation

and Proposed imposition of Civil Penalties - $110,000 (NRC Special inspection Report No. 50-

295/304-97017); Zion Generatina Station (EA 97-249): January 15.1998". dated February 13, ,

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Memorandum from

O. Kingsley to Various Addressees, Subject: " Fitness For Duty (FFD)

Program Implementation", dated March 31,1998,

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