IR 05000445/1991017
| ML20024H560 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/22/1991 |
| From: | Cain C, Mclean M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20024H559 | List: |
| References | |
| 50-445-91-17, 50-446-91-17, NUDOCS 9106050027 | |
| Download: ML20024H560 (8) | |
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ADPENDIX U.S. NtJCLEAR REGULATORY COMMISSION REG 10N lY NRC Inspection Report:
50-445/91-l'
Operating License:
NPF-87 50-446/91-17 Construction Permit:
CPPR-127 Dockets; 50-446 50-445 Licensee:
TV Electric Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Facility Name:
Comar.che Peak Steam Electric Station (CPSES)
Inspection At: Glen Rose, Texas Inspection Conducted: April 30 through May 3, 1991 Inspector:
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M.LindaMcLean,Fbysicai~SecurityTecialist Date Nuclear Materials and Safeguards Inspection Section
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%tdA4 a[g 5~hft Approve 1:
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_Cha.les L. C_ain, Chief Nuclear Materials and Date Safeguards Inspection Section Inspection Summary Inspection Conducted April 30 through May_3 1991 (Report 50-445/91-17 i
50-446/91-1]_]
Areas Inspected:
Special, announced inspection of the licensee's fitness-for-cuty (FFD) progrr.m required by 10 CFR Part 26.
This inspection included a review of the licensee's written policies and procedures and orogram implementation, as required by 10 CFR Part 26 in the areas uf:
program administration and management support, selection and notification for testing, collection and processing of specimens, FFD training and worker awareness, the employee assistance program, management actions and sanctions, appeals, audits, and maintenance and protection of records.
The review of the program implementation involved interviews with key FFD program personnel and a sampling of the licensee's employees and contractor personnel with unescorted access, a review of relevant program records, and observation of key processes, such as specimen collection.
9106050027 910531 PDR ADOCK 0500
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Results: Based upon NRC's selective examination of the licensee's FFD program, l
it has been concluded that the licensee is satisfying the general objectives of
i 10 CFR 26.10.
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The inspection identified many program strengths.
The dedication and
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profes.*onalism of the FFD staff and the management support of the FFD program j
are strengths that have greatly contributed to the licensee satisfying the general objectives of the rule. Other program strengths are described in the
" Details" section of this report, i
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One program weakness was identified:
the absence of a clear procedure t
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describing required training for designated contract supervisors.
A commitment
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j was made to revise the procedure to ensure that all designated contract
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supervisors complete the required training prior to gaining uneecorted access.
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-3-pETAILS 1.
Persons Contacted TV Electric j
- A. B. Scott, Vice President, Nuclear Operations
- L. Terry, Director, Nuclear Overview
- H. R. Hutchison, Manager, Personnel
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- B. T. Lancaster, Manager, Plant $upport
- D. McAfee, Manager, Quality Assurance (QA)
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- J. Rumsey, Manager, Corporate Security-Nuclear
- W. G. Guldemond, Manager, Site Licensing t
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- L. G. Barnes, Technical Staf f Training Manager
- J. M. Ayres, Operations, QA Manager
- R. Werner, Executive Assistant i
S. Swan, Training Supervisor
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'G. Bell, Senior Licensing Engineer
- W. S. Isom,-Senior Corporate Security Representative
- J. Britt, Senior Corporate Security Representative
- J. E. Brown, FF0 Coordinator
- P.
E. Mills, Senior QA Specialist R. Coffey,- Training Specialist NRC
'R M. Latta, Senior Resident Inspector, Unit 2
- D. N. Graves, Resident Inspector, Unit 1
- Attended exit interview.
The inspectors also interviewed other licensee and contractor personnel during the course of the inspect. ion.
2.
Written policies and-Procedures (TI2515/106-05.01)
The licensee's written FFD policies and procedures were reviewed and
. compared to the requirements of 10 CFR Part 26 to assure that they were
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comprehensive and of sufficient clarity anc detail to communicate duties and responsibilities and to support the implementation of the program.
Written procedures had been developed which adequately detailed responsibiliti b for important aspects of the program involving random-selection and notification, specimen collection, testing for cause, appeal process and procedures,-followup testing, and the role of the medical review officer (MRO).
TV Electric s Policy No. 123 has served as the program's fitness-for-duty policy statement and had-been signed by the executive vice president of nuclear engineering operations.
Two attachments to the policy stated the
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. rules regarding use and/or posse sion of intoxicants, drugs, and narcotics; ene for TU Electric employees, and the.econd for contractor
employees.
The FF0 program procedures were found in CPSES's adminipration manual i
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(Procedure No. STA 910) and were in the first revision.
The policy and
procedures addressed the FFD organizational responsibilitica, random chemical testing, testing f',,r cause, sanctions, and appeals.
The policy and procedures further addressed the prohibition of the sale, use, and possession of illegal drugs; abuse of prescription and over-the-counter drugs; and the consumption of alcohol.
The policy and procedures were considered comprehensive and written with sufficient clarity and guidance to allow effective implementation of the program.
The policy statement and the procedures were considered a program strength by virtue of their
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thoroughness.
3.
Program Administration and Management _ Support (T12515/106-05.02.aj The administration of the FFD program was evaluated through review of management involvement and support of the program, the organization
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i structure, and the assigned authorities and responsibilities.
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The CPSE$ personnel manager has been assigned the responsibility for
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coordinating preemployment drug testing and the random selection of
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personnel to be tested. The manager of corporate security-nuclear has been responsible for the overall administration of all drug and alcohol testing.
Reporting to the personnel manager was the FFD coordinator.
The FFD coordinator has provided coordination and administration of the day-to-day activities associated with the program.
The MRO was a licensed physician under contract to the licensee. Additionally, the collection site. personnel, which included a registered nurse, were under contract to the licensee.
CPSES has had an outside, independent organization under contract since July 1989 to administer their employee assistance program (EAP).
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The, inspector interviewed key FFD implementation personnel, including the manager of corporate security, the personnel manager, the FF0 coordinator, the EAP director, and the MRO.
Each appeared to understand their specific responsibilities and authorities.
Resources in terms of staff assignment appeared adequate.
Notable program strengths were the professionalism of the staff and the management support of the program.
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4.
Worker Awareness and FFD Training _(TI_2515/106-05.02.b)
Worker awareness and understanding of the FFD program were determined
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through interviews with licensee and contractor / vendor employees.
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sampling of training records were inspected to determine the licensee's compliance with 10 CFR 26.21 and 26.22.
I The inspector conducted six interviews of licensee and contractor employees.
One was a CPSES supervisor.
These individuals appeared to have a good understanding of the FFD policy and program elements that
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Those interviewed indicated support for the program and felt that the program was deterring substance abuse. All interviewees commented on the quality of the collection site and indicated confidence in the collection process.
The licenste's FF0 Procedure STA-910, Section 6.0, described the procedure fur training of supervisors and escorts.
This procedure stated, in part, that all TU Electric supervisors and all contract supervisors shall have initial behavioral observation training completed within 3 months of being assigned supervisory duties.
10 CFR 26.22(c) requires that individuals coming on site identified as supervisors to complete supervisory training before granting unescorted access.
The inspector was informed by the licensee that supervisory training was provided to all supervisors within 90 days, with no distinction as to whether they were newly promoted supervisors, or newly hired supervisors.
However, all elements of supervisory training required by 10 CFR 26.22(a) appeared to have been covered by the licensee's escort training.
Escort training has been provided to all TV Electric employees and contract workers prior to granting unescorted access.
Omission of the specific requirement in CPSES's Procedure STA-910 for designated contract supervisors to complete required training prior to gaining unescorted access was identified as a program weakness. The licensee committed to revising this procedure with an effective date of May 6, 1991.
5.
Selection and Notification (T1 2515/106-05.02.c)
Inspection cf the selection and notification process was conducted to ensure that:
(a) affected workers are subject to random testing, (b) the annual testing rate is at least 100 percent'of the affected workforce each year, and (c) adequate measures exist to prevent subversion of testing, Selection for testing has been conducted by use of a computer generated
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list. The program required two members of the FF0 administrative staff with unique passwords to generate the selection list.
This practice was used to ensure that one person alone could not subvert the selection process.
Notification of personnel selected for testing was accomplished by a member of the FFD administrative staf f notifying the supervisor of the idividual selected.
The selected individual must report to within i
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of notification. A memo was required from the individual's supervisor if a delay of greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> was necessary.
i If the selected ind.vidual was temporarily absent, due to illness or vacation. tM test would be cancelled, Individuals with infrequent access And un:.vailable far tesz4ng on the selected date have been aoministratively emoved from unescorted access.
Upon the individual's next rehuest for access to ihe protective area (PA), he or she has been requnted to re.urt to the FFD collection site before being permitted to enter the PA.
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-6-As of the dates of this inspection, approximately 4500 names were in the pool.
The number in the pool was updated daily to reflect the changing population.
Statistics for 1990 indicated an annual random testing rate of at least 100 percent of the affective workforce, it is noteworthy to add that since 1988, random selection was conducted on selective groups:
engineering, construction, and quality assurance personnel.
Testing has been conducted on weekends, holidays, and backshifts.
The procedures were found to adequately satisfy 10 CFR 26.24(a) requirements.
6, Chemical Testing / Collection and Processing'of Specimens
[W2M57iOT~TEU2.c and d)
The licensee's chemical testing procedures were evaluated to determine if the program provides a means to deter and detect substance abuse, complies with 10 CFR 26.24, and conforms with, at a minimum,- Appendix A of this rule.
The inspector conducted a walkthrough of the procedures for collecting sampleo The collection site was well laid out,-secured,- and adequately equipped.
Effective measures were implemented to prevent subversion of specimens. The chain-of-custody procedures were maintained within the collection site, and specimens were secured when unattended. A registered
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nurse under contract with the licensee has-been assigned the supervisory responsibility for the collection site.
The collection site personnel appeared to have a thorough knowledge of specimen collection procedures.
CPSES has contracted with a Department of Health and Human Services (HHS)
certified laboratory for its chemical testing.
The licensee met NRC criteria for preliminary and confirmatory cutoff levels.
In the event that the breath alcohol concentration (BAC) results were less than the 0.04 percent cutof f level, the individual tested has been interviewed by a member of corporate security for assessment.
The inspector considered this a commendable practice-The FFD program performance forms were submitted in a timely manner to NRC as required by 10 CFR Part 26.
The specimen collection site was located in the central processing facility at CPSES.
The quality of the collection site and processing facility was exceptional.
7.
Maintenance and Protection of Records (Tl 2515/106.05.01.c)
The licensee's record maintenance and filing systems were evaluated to
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ensure that their procedures achieved protection of personal information as required by 10 CFR 26.29, Records of tests and tests results were maintained at the corporate security offices. Access to such records were limited to the FFD administrative staff on a need-to-know basis. A system of files and I
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procedures to protect personal information contained in FFD-related
records had been developed.
Results of tests from the HHS laboratory were transmitted by electronic transmission, with hard copy to follow.
Release of information adheres to 10 CFR 26.29 in that the records systems protect personnel information and ensures confidentiality.
Suitable inquiries made under the provisions of 10 CFR 26.27(a) must be accompanied by a signed release form.
The controls observed during the inspection appeared adequate to provide the required protection and personal privacy for rccords.
8.
Employee _ Assistance Pro _ gram (EM) lil 2515/106.05.01.c)
The EAP required by 10 CFR 26,25 was evaluated to determine if the program is designed to achieve early intervention and provide confidential assistance to employees and that the EAP staff is aware of their
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responsibility of reporting to management any individual whose condition constitutes a hazard.
The licensee has contracted with an independent,_outside organization to administer their EAP.
The EAP has provided assessment, short-term counseling, and referral services to TU Electric employees.
The inspector determined through an interview with the EAP coordinator, that the rate of utilir i hts been sufficient to rate the program as effectively working.
The aggressive aftercare program provided by the EAP was considered a notable program component.
Interviews with selected CPSES employees indicated an awareness of the program although none had used the
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EAP services have not been extended to contractor nor vendor
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r<rsonnel.
9.
Audits,_ITI 2515/106.05.01.c)
The inspector examined the licensee's audit program to determine if it had an adequate program for identifying deficiencies and weaknesses, and to ascertain whether appropriate corrective actions were implemented in a timely manner,
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- The licensee had conducted two QA audits. Audit QAA-90-006 was conducted
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March 26 through April 6,1990, and Audit QAA-91-113 was performed
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l March 11-22, 1991. The 1990 audit contained four deficiencies and five
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observations. All corrective actions for this audit were closed by August 1990. The 1991 audit identified four observations.
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As part of tF' audit, the audit team _ created dif ferent scenarios which tested the pe'rformance of the collection-site and HHS laboratory personnel.
Several weaknesses were discovered in the laboratory procedures as a result of the test scenarios This innovative approach to a QA audit was considered a notable program strength.
Additionally, the
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FFD administrative staff has continued this practice in their internal assessment program.
The inspector found the licensee's audits to be both timely hnd thorough.
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10. Management Actions and Sanctions; Appeals ( T l _ _2515/106. 05._01. c)
The inspector examined the management actions and sanctions policies to
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ensure compliance with 10 CFR 26.27.
The appeals procedure was reviewed, and a review of an appeal filed under the provisions of 10 CFR 26.28 was
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conducted.
The licensee's procedures were found to establish sanctions as set forth
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by 10 CFR 26.27. On the first confirmed positive of a random, a TV Electric employee's protected area access has been suspended for at least 34 days, and the employee has been referred to the EAP for assessnent.
Contractor personnel receiving a confirmed positive have had their site access permanently revoked.
After receiving notification of a confirmed positive test result, CPSES's quality review board has been required-to meet to review and determine if a safety impact on-the plant eFist$, and if.there was a need for a review of the individual's work.
This procedure has been implemented for all
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workers, regardless of their Job responsibilities, a notable program strength.
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All employees, contractors, and vendors have been afforded an opportunity to appeal the determination of a confirmed drug or alcohol test.
The inspector reviewed an appeal that had been through the entire appeal process. The outcome of the appeal was a denial to overrule the results i
of the confirmed positive test.
The executive vice president-nuclear operations has.had the firal decision on appeal decisions.
The procedures
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appeared to have met the rule requirements and were executed thoroughly during the appeal-process.
11.
Exit Interview (IP30703)
The inspector met with licensee tepresentatives denoted in paragraph 1 on May 3, 1991, and summarized the scope and findings of the inspection as presented in this report.
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