IR 05000298/1997014

Insp Rept 50-298/97-14 on 970804-08.No Violations Noted. Major Areas Inspected:Licensee FFD Program Utilizing IP 81502, FFD Program,

ML20210R324
Person / Time
Site:	Cooper
Issue date:	08/27/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210R314	List: IR 05000298/1997014 ML20210R311
References
50-298-97-14, NUDOCS 9709030085
Download: ML20210R324 (9)

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ENGlQSMllE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

l Docket No.: 50 298 License N DPR 40 '

Report No.: 50 298/97-14 Licenseo: Nebraska Public Power District Facility: Cooper Nuclear Station

! Location: P.O. Box 98 Brownville, Nebraska Dates: Au0unt 4 8,1997 Inspector: Thomas W. Dexter, Senior Physical Security Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety l

i ATTACHMENT: Supplemental Inf orrnation s 970903008S 970827 PDR ADOCK 05000290 a PDR we

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l EXECUTIVE SUMMARY i

Cooper Nuclear Station

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NRC Inspection Report 50 298/97 14 This was a routino, announced inspection of the licensee's fitness for-duty program utilizing Inspection Procedure 81502, " Fitness For Duty Program," dated May 31,1991, i

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The licensco's policies and procedures were comprehensive and of sufficient detail to assure compliance with 10 CFR Part 26 (Section S1.1).

There was strong management support and involvement for the fitness for duty program (Section S1.2).

Training for the fitness for-duty staff was current and well documented. The general employee training adequately covered the fitness for duty requirements for workers and supervisors (Section S1.3).

The licensee had an effective drug and alcohol procedure in place that ensured random testing was conducted periodically, on backshifts, weekends, and holiday Records of test results were maintained, and an appeal process was in the procedures (Section S1.4).

Quality Assurance Audit 9616 of the fitness for duty program was detailed, comprehensive, and identified program concerns and strengths. A member of the audit team was from another utility with expertise in the f;tness for duty orogram (Section S1.5).

The records and documentation required by 10 CFR 26 and plant procedures were on file and properly secured in a restricted access controlled area (Section 1.6).

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ly. Plant $1:pp_ git S1 Fitness For Duty Program 81502 S1.1 Policies and Procedures (81502-02.011 i

a, inspection Sc.gnq The inspector reviewed the licensee's written policios and procedures to assure that they were comprehensive and of sufficient detail to meet the requirements of 10 CFR Part 2 '

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9tservations and Findinas The inspector confirmed by review and discussion with fitness for duty / access authorization staff that procedures had been developed that adequately communicated specific responsibilities of the staff. A program was in place that ensured policy changes were reviewed, approved, distributed, and retained as

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required, The inspector determined that the procedures covered program areas :

Involving: (1) the random selection and notification of personnel for testing, specimen collection, testing for cause, and testing for personnel called in to work; (2) appeal process and procedure'; (3) followup testing; and (4) medical raview officer's responsibilities, Conclusions The licensee's policios and procedures were comprehensive and of sufficient detail to assure compliance with 10 CFR Part 26, S1,2 .Oraanization and Manaaement Control (81502-02.02)

a, Insnection Secoe The administratica of the fitness for duty program was evaluated to determine management involvement and support of the program, assignment of authority and responsibilities, availability of a medical review officer, and an employee assistance program,

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b, Observations and Findinag Operational responsibility for the implementation of the fitness for-duty program had been assigned to the Senior Manager, Safety Assessment / Site Support. The site -

security manager was responsible for the management of the program. The security services supervisor was responsible for the day to-day implementation of

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the program, which included selecting, training, and monitoring of persons respontible for administering the testing program. The inspector discussed the program with several plant supervisors and determined that they were very .

knowledgeable of their responsibilities and actively supported the progra I The inspector also confirmed that the medical review officer was a licensed l physician under contract to the licensee, in addition, the licensee had contracted l with an independent organization to administer the employee assistance program.

l Conclusions i There was strong management support and involvement of the fitness for-duty progra i S1.3 Eitness For-Duty Traininn Inunnation Scope The inspector interviewed three collection site persons, two security supervisors who performed "callin" tests, and the plant general employee training superviso The general employee training lesson plan section pertaining to the fitness for duty program was reviewed, Observations and Findinns From a review of the training records, interviews with the collection site persons, and observing them in the performance of their duties, the inspector determined that collection sits personnel understood their responsibilities and were competent in their duties. Documentation of the training records for the collection site persons and the security supervisors assigned to conduct testing for " call-ins" were curren The supervisor responsible for the general employee training program was knowledgeable of the fitness for duty program requirements. The inspector determined that the fitness for duty requirements for employees, supervisors, and escorts were clearly stated in the general employee training lesson plan. The inspector also observed requalification of one individual and an initial training class involving several others. The training program covered the appropriate expectations and requirements for all workers and supervisors under the fitness for duty rul . The licensee also ensured that the computer generated tests for general employee training had at least one quest.on concerning the fitness for-duty program, Conclusions Training for the fitness for cuty staff was current and well documented. The general employee training adequately covered the fitness for-duty requirements for workers and supervisor _________ ..

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l S I .4 ChemicaLIestina Pronram 18_15.02-03,03) Inipagjion Sc0De The selection and notification process was reviewed to ensure that: (1) af fected workers were subject to random testing, (2) the annual testing rate was at least 50 percent of the affected workforce each year, (3) adequate measures existed to .

prevent subversion of testing, and (4) that the licensee's program included testing, j if necessary, of individuals called to work during off hours or emergencie '

j- Qhiervations and Findinns Selection of individuals for random testing was conducted by the use of a computer gener3ted list. The computer sof tware was designed to prevent access ;

to or tampering with the selection process. Notification of personnel selected I was accomplished by contacting their supervisor approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prior to the actual collection time. Collection of specimens was performed at three locations Cooper Nuclear Statien and the corporate offices in Columbus, Nebraska, I and York, Nebrask The inspector confirmed, by a review of records, schedules, and discussions with the teness for duty staff, that testing was conducted periodically on backshifts, weekends, and holidays. Records of drug testing results, including records of blind test perfortnance samples, were maintained at the plant sit The inspector confirmed by review of Nuclear Power Group Directive 2.3, " Fitness-For Duty Program," Revision 9, that the licensee had an appeal process in place for anyone who tested positive for drugs or alcohol. When an individual was informed th;,t they had tested positive they were also informed of their right to appeal the findings, Conclusions-The licensee had an effective drug and alcohol procedure in place that ensured random testing was conducted periodically on backshifts, weekends,6nd holiday Records of test results were maintained, and an appeal process.was in the procedure S1.5 fitn,ess For Dutv Audits (81502 03.05) I_nspection Scooe The 1996 fitness-for duty audit was reviewe = .- _ = -

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. b; _ Qhsqryations and Findinmi The licensee's 1996 quality assurance audit of the fitness-for-duty program was I conducted during the period November 8 22,1996. The inspector determined from )

a rev'.ew of tho' audit and discussions with a quality assurance audit person _and I the security services supervisor that the audit was detailed, comprehensive, and I identified program concerns and strengths. In addition, a technical specialist )

from another licensee was used to augment the audit team. Quality Assurance J Audit 96-16 Report documented four problem identification reports, one strength, and eight recommendations, i Conclusiong l- Quality Assurance Audit 9616 of the fitness for duty program was detailed,

! comprehensive, and identified piogram concerns and strengths. A member of the t

audit team was from another utility with expertise in the fitness-for-duty progra S 1.6 Dacument and Records Control insperijsp Scone The inspector reviewed logs, records, and conducted interviews in order to determine if regulatory requirements were met in accordance with 10 CFR Part 2 Observations and Findinos The following is a partial list of documents and records reviewed:

(1) Records of the dates and times of random tests for the year 1997 (2) Records identifying individuals who had been made ineligitle for unescorted access as a result of drug and alcohol screening (3) The 1996 and 1997 Fitness-For Duty Semi Annual Statistical Report (4) Blind oerformance test records and test files Fitness-for duty records were correct and prompt entries were made at the time of testing. The inspector also noted that the documents were reviewed and closely monitored for completeness _by management, Blind sample records were monitored J specific files properly maintained. Additionally, audit findings were maintained

- in a .Jadily retrievable manner. All records containing information on individuals were properly secured in a restricted access controlled are I; .

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c. Conclusion The records and documentation required by 10 CFR Part 26 and plant procedures were on file and properly secured in a restricted access controlled are Managemen.LMeetinas X1 Exit Meeting Summary

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The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on August 7,1997. The licensee acknowledged the findings presented, I

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- ATTACHMENT '

SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED --

Licensee i'

, M. Bennett, Licensing-Supervisor P. Caudilli Senior Manager, Safety Assessment / Site Support-J. Florence, Acting Training Manager-M. Hamm, Security Manager -

J.- Harringtoa Security Services Supervisor I

R.- Sessoms, Senior Manager, Quality Assurance-M C; Skinner, Resident inspector

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INSPECTION PROCEDURES USED I IP 81502 ' Fitness-for Duty Program :

PARTIAL LIST OF DOC J 'AENTS REVIEWED Corporate Policy / Procedure HR 40, January 6,1995 Nuclear Power Group Directive 2.3, NPG Fitness-For-Duty Program, Revision 7, -

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Security Services Procedure SS 1.2, Collection Site Person and Collection' Aide Training Procedure, Revision 2, January _28,1997 Security Services Procedure SS 2.0, Fitness-For Duty Program, Revision 2, July 3,199 Security Services Procedure SS 2.1, Fitness For Duty Program Procedure Collection Instruction,' Revision 5,~ August 22,1996

- Security Services Procedure SS 2.2, Calibration Procedure, Revision 1. July 16,1996 -

Security Services Procedure SS 2.3, Random-Selection Proceduro, Revision 1, November 5,-

1996 Problem identification Report 2-02245, For Cause Tes_ ting Problem, January 31,1997 Problem identification Report 2-04737, FFD Program Practices and Requirements, April 15, 1997--

Problem Identification Report 2 15949, Notification of Access Denial Letter, July 2,1997 r

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Problem Identification Report 2-0221, Chain of Custody Forms, June 30,1997 Problem identification Report 2-02277, Screening Records, July 22,1997 Quality Assurance Audit 9616, Fitness for Duty, December 27,1996 L :

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