IR 05000454/1998013
| ML20248B099 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248B091 | List: |
| References | |
| 50-454-98-13, 50-455-98-13, NUDOCS 9806010180 | |
| Download: ML20248B099 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION lil Docket Nos:
50-454;50-455 License Nos:
50-454/98013(DRS); 50-455/98013(DRS)
Licensee:
Commonwealth Edison Company Facility:
Byron Nuclear Generating Plant, Units 1 and 2 Location:
4448 North German Church Road Byron, IL 61010-9750 Dates:
April 15-May 8,1998, Region ill Office Inspector:
G. Pirtle, Physical Security inspector
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Approved by:
James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety A
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EXECUTIVE SUMMARY
Byron Nuclear Generation Plant NRC Inspection Reports 50-454/98013; 50-455/98013 This inspection included a review of the licensee's investigation report (dated March 9,1998)
pertaining to fitness-for-duty (FFD) concerns identified to the licensee by NRC Region 111 letter dated January 23,1998. Other licensee documents pertaining to the same issues were requested and also reviewed. The inspection effort was completed by a physical security inspector.
Two occasions occurred between May 22, and late December 1997, where FFD
procedures were not complied with in a timely manner by one individual and two supervisors. The incidents pertained to reporting and evaluating the odor of alcohol on personnel working on shift. The lack of timely actions constituted a viciation of the licensee's FFD procedures, and a notice of violation was issued. The individual involved in the May 22,1997 incident was FFD tested and was negative. The individual involved
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In the December 1997 ;ncident did not require FFD terting (Section S8).
The licensee's report of investigation (dated March 9,1998) of FFD concems idLntified
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by the NRC was adequate in scope and depth. One area of the investigation report warranted clarification (Section S8).
l implementation of identified corrective actions for the Nuclear Generation Group (all
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nuclear plants) should be adequate to prevent recurrence of the violation (Section S8).
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Report Details IV. Plant Sunoort S8 Miscellaneous Security and Safeguards issues a.
Insoection Scooe (81502)
The licensee was advised on January 23,1998, of fitness-for-duty (FFD) concems received by NRC Region Ill. The concerns pertained to alleged reluctance of some supervisors to request FFD for-cause tests to be completed. The licensee provided their investigation results of the concems to NRC Region ill by letter dated March 9, 1998. The details of the concems and the investigative results were identified as containing sensitive and confidential personal information the disclosure of which could cause an unwarranted invasion of the personal privacy for those named in the report.
This inspection included a review of the licensee's investigation report (dated March 9,
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I 1998) pertaining to fitness-for-duty concems identified to the licensee by NRC Region ill letter dated January 23,1998. Other licensee documents pertaining to the same issues were requested and also reviewed (Refer to the Partial Listing of Documents Reviewed Section of the Report Details for further information).
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Observations and Findinas
10 CFR 26.20 requires each licensee to establish and implement written policies and procedures designed to meet the general performance objectives and specific j
requirements of 10 CFR Part 26. The inspector's review of the investigation report and other requested documents identified three occasions (during two time periods) in which individuals did not complete actions in a timely manner. Collectively, the instances constitute a violation of the licensee's FFD policies that is more than of minor significance. The incidents are described below:
Section 5.2.2 of the licensee's procedure, Corporate Nuclear Security Guideline No.
207," Testing For Cause", Revision 10, effective April 18,1997, requires the supervisor who becomes aware that an individual's fitness is questionable, to immediate!y remove l
the individual from work activities. The individual is also required to be escorted at all times until the concem is satisfactorily resolved or until the individual exits the protected area.
Section 5.6.5 of the licensee's procedure, Corporate Nuclear Guideline No. 200,
" Comed FITNESS FOR DUTY PROGRAM". Revision 7, effective July 7,1997, requires l
FFD for-cause testing to be completed as soon as possible after the odor of alcohol has been detected on an individual and confirmed by a management employee trained in j
FFD Supervisor responsibilities.
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On May 22,1997, a supervisor was advised that the odor of alcohol had been detected l
on an individual working on shift. The supervisor did not evaluate the individual,
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remove the individual from work activities, escort the individual at all times, or request a
for-cause Fitness-For-Duty testing until approximately 1% hours after being advised.
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Although the actions were eventually completed, they were not completed as soon as l-possible. The individual's for-cause test results were negative.
l The immediate corrective actions consisted of the supervisor being counseled on
. actions to take when encountering the odor of alcohol, as required by the licensee's Corporate Nuclear Security Guideline No 207," Testing For Cause."
Section 5.5.1 of the licensee's procedure, Corporate Nuclear Guideline No. 200,
" Comed FITNESS FOR DUTY PROGRAM". Revision 7, effective July 7,1997, states that Fitness For Duty (FFD) and adherence to FFD procedures is the responsibility of each individual who has been grantact unescorted access. Individual responsibilities include reporting to their supervisor instances of violation of the Fitness For Duty policy and/or procedures which might adversely impact safe operation and maintenance of the
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station.
Section 5.3.1 of the licensee's procedure, Corporate Nuclear Security Guideline No.
207, " Testing For Cause", Revision 10, effective April 18,1997, requires a supervisor who is concemed that an employee may not be fit for duty, to ask the employee to explain why they appear not to be in condition to work and document the event and the interview and notify the department head.
In late December 1997 (exact date could not be confirmed) an individual detected the odor of alcohol on a coworker's breath, but did not report this to a supervisor until a couple of hours later. Although the supervisor's evaluation determined that For Cause FFD testing was not necessary, the required documented record of the FFD evaluation was not completed by the supervisor. The individual who delayed notification to his supervisor was counseled on his FFD responsibilities for timely notification.
The safety significance of both incidents noted above is low because the FFD testing was eventually completed, even if not within the time limits required by the licensee's procedures. Additionally, the person eventually tested was not positive for alcohol (BAC
.04 or higher) or drugs. However, the number of errors (late testing, late notification, and lack of documentation) collectively is more than of minor significance.
The department (Corporate Security) that conducted the investigation was independent of the individual's work location and management and supervision chain of authority. Root causes, generic implications, and corrective actions for FFD concems at all of the licensee's nuclear sites were identified and are being implemented on a Nuclear Generation Group basis (to include the Byron plant). One area within the licensee's investigation report required clarification, and is addressed below:
e The fourth paragraph on page 4 of the investigation report noted that a supervisor
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E noticed a problem with an individual about 7:30 AM on January 8,1995, and the individual involved was not sent for FFD testing for about one hour and twenty minutes after the supervisor was aware FFD testing may be necessary. However, another
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C document (Bums Security Incident Report, dated January 8,1995) confirmed that the incident occurred about 7:30 PM on January 8,1995, and that the individual was removed from the protected area about 7:50 PM (20 minutes after evaluating the individual). The actual off-site drug testing portion of the for-cause test was completed
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about 9:30 PM, which is 6xeptable provided the individual has been removed from the.
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..As a result of FFD concems identified at other Comed sites prior to the issues identified at the Byron plant, the licensee initiated corrective actions for FFD issues identifed by the NRC and their self-assessment efforts on a Nuclear Generation Group basis (all nuclear sites). The corrective actions for FFD-related issues identified at all of the nuclear sites (to include the Byron station) included the following actions which will also address the violation identifed at the Byron plant.
The licensee formed a trend investigation team to determine the root cause(s) for o
repeated failures at all Comed nuclear stations to properly conduct and document call-outs for unscheduled work and for individuals' failure to perform as expected after identification of the odor of alcohol.
The investigation team identified root causes on a. Nuclear Generation Group basis to include:
- lnfrequent task / activity (for many people, encountering the odor of alcohol can be an infrequent or first time task).
Pre-occupation with job at hand and lack of consequences for procedural non-compliance.
Uncomfortable task to report (people were uncomfortable in confronting and reporting the odor of alcohol for a variety of reasons).
The investigation team identified specific corrective actions to address these causes including: Measures to heighten awareness and enhance visibility for call-outs and handling the odor of alcohol at all six nuclear stations. Develop and provide FFD lessons leamed for inclusion in Safety or tailgate meetings every quarter (a lessons leamd program was completed for the Byron station staff on February 5,1998).
Develup and implement an improved and standard accountability system.
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Additionally, the investigation team also identified on a Nuclear Generation Group basis I
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contributing factors to include: 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
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with the contributing causes, such as the communication by executive management of
their commitment to the FFD program, to all nuclear station personnel. (A letter signed
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by the President, Nuclear Generation Group was sent to all Station Managers on
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March 31,1998, with a statement that First Line Managers are accountable to assuring
that FFD requirements are implemented and followed). Station Managers were designated the owners of the FFD program.
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Conclusions
' Two occasions occurred between May 22, and late December 1997, where FFD procedures were not complied with in a timely manner by one individual and two supervisors. The incidents pertained to reporting and evaluating the odor of alcohol on personnel working on shift. The lack of timely actions constituted a violation of the
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licensee's FFD procedures (50-454/98013-01; 50-455/98013-01).-
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The scope and depth of the licensee's investigative *$ns appeared adequate to
. support the conclusions in their March 9,1998 letter. One area of the investigation
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report required clarification. Implementation of identified corrective actions should be adequate to prevent recurrence of the violation.
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Exit Meeting Summary The inspector and Chief. Plant Support Group, Branch 1, presented the inspection results to members of the licensee management on May 8,1998. The personnel present acknowledged the inspector's findings. The inspector asked the licensee if any inspection findings discussed during the exit meeting should be considered as proprietary or safeguards information. It was agreed that the names and positions of personnel involved in FFD-related issues would be -
considered as exempt from public disclosure because of personal privacy rights. No proprietary or safeguards information was identifed.
PARTIAL ListT OF PERSONS CONTACTED Licensee:
K. Kofron, Plant Manager R. Cassidy, Assistant Security Administration R. Colgiazier, NRC Coordinator P. Laird, Corporate Security Cliector C. Martin, Human Resources Supervisor i
S. Mills, Station Security Administrator J. Papaleo, FFD Program Coordinator i
B. Saunders, Supervisor, Nuclear Security Operations G. Toleski, Special Projects INSPECTION PROCEDURE USED
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i IP 81502 Fitness For Duty Program ITEMS OPENED AND CLOSED Opened
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PARTIAL LIST OF PERSONS CONTACTED Licensee.
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K. Kofron, Plant Manager R. Cassidy, Assistant Security Administration R. Colglazier, NRC Coordinator
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P. Laird, Corporate Security Director C. Martin, Human Resources Supervisor S. Mills, Station Security Administrator J. Papaleo, FFD Program Coordinator B. Saunders, Supervisor, Nuclear Security Operations G. Goleski, Special Projects
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lNSPECTION PROCEDURE USED IP 81502 Fitness For Duty Program ITEMS OPENED AND CLOSED Ooened j
50-454/98013-01 VIO Three Examples of FFD Procedures Not Being Followed For Reporting and Assessing a FFD Concem
50-455/98013-01 VIO Three Examples of FFD Procedures Not Being Followed For Reporting and Assessing a FFD
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Concem Closed 50-454/98013-01 VIO Three Examples of FFD Procedures Not Being Followed For Reporting and Assessing a FFD Concem 50-455/98013-01 VIO Three Examples of FFD Procedures Not Being Followed For Reporting and Assessing a FFD Concern
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PARTIAL LISTING OF DOCUMENTS REVIEWED NRC Region til Letter from H. Clayton to O. Kingsley, dated January 23,1998 l
Comed letter from K. Graesser to H. Clayton, with attachment, dated March 9,1998 Corporate Nuclear Security Guideline No. 207," TESTING FOR CAUSE" Revision 7, effective November 9,1994 Corporate Nuclear Security Guideline No. 207, " TESTING FOR CAUSE". Revision 10, effective April 18,1997 Corporate Nuclear Security Guideline No. 208," Handling of Fitness For Dutv Allegations",
Revision 5, effective December 13,1993 Corporate Nuclear Security Guideline No. 208," HANDLING OF FITNESS FOR DUTY ALLEGATIONS". Revision 6, effective Februsry 23,1996
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Burns Intemational Security Services incident Report, dated January 8,1995, pertaining to a
for-cause fitness for duty test
Bums Intemational Security Services incident Report, dated.May 22,1997, pertaining to a for-
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cause fitness for duty test Confidential Comed Byron Station Intemal memcrandum. Subject: *5/22/97 FFD Event", dated May 26,1997 l
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