IR 05000461/1987017

Insp Rept 50-461/87-17 on 870401-0526.Major Areas Inspected: Portions of Fitness Program Re Allegations Contained in 870326 to Region Iii.Allegations Unsubstantiated

ML20234F420
Person / Time
Site:	Clinton
Issue date:	06/23/1987
From:	Creed J, Drouin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20234F363	List: IR 05000461/1987017 ML20234F360
References
50-461-87-17, NUDOCS 8707080213
Download: ML20234F420 (13)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/87017(DRSS)

Docket No. 50-461 License No. NPF-55 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Inspection At: Clinton Power Station, Clinton, Illinois and.NRC Region III Office Inspection Conducted: April 1-2,1987 on site and April 3-May 26, 1987 at the Region III Office Date of Previous Security Inspection: February 5-11, 1987 Type of Inspectio - C ecial Security Inspection Inspectur:

B.' Dedufn 4&'

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Security Inspector

% bk h J. R. Creed,' Chi ~f e Date h>3kO Safeguards Section Inspection Summary Inspection on April 1-May 26,1987 (Report No. 50-461/87017(DRSS))

Area Reviewed: Applicable portions of the Illinois Power (IP) Company's Fitness for Duty program relating to allegations contained in March 26, 1987 letter received at the NRC Region III offic Results: The licensee was found to be administering the Fitness for Duty program in accordance with IP Nuclear Planning and Support Department Procedure (NP&S) 1.16 Fitness For Duty, effective date February 3, 198 The allegations contained in the March 26, 1987 letter were unsubstantiate g7080213s70626 g ADOCK 05000461 PDR

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DETAILS 1. Key Person Contacted The following key members of the licensee staff were contacted during the review of the Fitness For Duty program allegations. The asterisk (*) ,

denotes those present at the Exit Interview conducted on May 26, 198 *P. Lancaster, Director, Human Resources Illinois Power (IP)

M. Relken, Supervisor, Labor Relations, IP G. Baker, Supervisor, Medical Programs, IP J. Chevalier, Operations Support Supervisor, IP J. Schreibner, Medical Programs Assistant, IP R. Sanders, President, Hawkeye Technical Services

! J. Brownell, Licensing /NRC Interface, IP

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N. Brownlee, Technical Director, Smith Kline Bio-Science Laboratories 2. Exit Interview (IP 30703) At the beginning of the inspection the Supervisor Medical Programs {

was advised of the nature of the inspection and the related scope of i the allegation I 1 The inspector conducted a telephone exit interview with Human l Resources Director on May 26, 1986. No written material pertaining l to the inspection was left with the licensee at the conclusion of the on site inspection. Briefly listed below are the findings _ 4 discussed during the exit interview, l Based on the information developed during the course of the inspection, we determined the following facts-  !

* The alleger was randomly selected for drug testing as prescribed I in NP&S 1.1 * The urinalysis tests conducted by Smithkline on behalf of the licensee are accurate and reliabl * The alleger's fitness for duty case was administered in accordance l with NP&S 1.16.

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• There appears to be no connection between his identification of alleged safety-related concerns (whistle blowing activities) and l his random selection for urinalysis testin The licensee acknowledged our comments.

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3. Independent Inspection - Allegation Review-The following information, provided in the form of allegations, was reviewed by the inspector as specifically noted below:

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- Background: Allegation No. RIII-87-A-0027. On March 24, 1987, J. Creed, Safeguards Section Chief, Region III returned an alleger's cal The alleger stated that his site access at Clinton Power Station was terminated because he had failed a random urinalysis test administered by the licensee. The alleger stated that he had taken another, voluntary urine test on his own initiative. The voluntary test was administered by a Clinton, Illinois physician, not associated with IP. The alleger stated that the self motivated test indicated that nc drugs were presen The alleger informed IP of his voluntary test results but was informed that there was no appeal based on the existing IP Fitness For Duty progra The alleger also indicated that the final site access termination documents forwarded to him by the licensee appeared to be backdated.

, The alleger identified the following specific concerns during the conversation: (1) The backdating of documents by IP which notified the

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alleger of his site access suspension and eventual termination; (2) absence of an appeal process in the IP Fitness For Duty policy; (3) not having his site access revoked in accordance with the Fitness For Duty program; and (4) the NRC is implicated in the licensee's Fitness For Duty program because the utility had made previous commitments to the NR At the conclusion of the conversation the alleger stated that he would forward the documents which were received from IP to the Region III offic Region III received the allege 's letter on March 30, 198 The letter contained numerous assertions which generally corresponded to his four previous concerns. However, the assertions were more general and restated the previous allegations. The alleger also implied that his positive IP test results were related to his past identification and reporting of safety-related issues to IP management. He suggested that the apparent administrative discrepancies in the IP termination documents mailed to him by the licensee on January 8, 1987 indicated that documents wer j altered (backdated) because the revocation of his site access was not in consonance with the IP Fitness For Duty (FFD) progra This review only covers those allegations related to the licensee's administration of their FFD program. Allegations concerning safety-related issues were reviewed in Region III Inspection Report No. 50-461/8701 Due to extensive and redundant nature of the alleger's March 26, 1987 letter the allegations will be reviewed in the following sequence:

(1) those allegations relating to the promulgation and content of the IP FFD program; (2) reliability of tests; and (3) a review of the manner ;

in which the alleger's case was processe i Allegation: The NRC is implicated in the alleged wrongful termination of the alleger's site access because Clinton Power Station has committed to the NRC in the form of a commitment letter to have an effective drugscreen program prior to fuel load and the !

NRC reviewed and approved the IP Fitness For Duty Progra I

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Review: The IP Fitness For Duty program was not a prerequisite for the issuance of an operating licensee. The licensee has never officially transmitted a copy of the program to the NRC for review or approval as determined through interviews with IP licensing representatives and by a review of Region III file The NRC's Policy Statement on Fitness For Duty of Nuclear Power Plant Personnel which appeared in the Federal Register (FR Doc. 86-17497) {

on August 4, 1986' stated that the Commission would refrain from new I

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rule making in the Fitness For Duty area for a minimum of 18 months j l from the August 4, 1986 effective date of the policy. statement. .The j refrain was in recognition of industry efforts to self-regulat i Therefore, Region III has not evaluated or approved the licensee's progra The NRC, by policy does not " approve" any Fitness For Duty Programs at this tim ,

Conclusion: The allegation that the NRC was implicated in the termination of the alleger's Clinton site access because the NRC reviewed, audited and approved the IP Fitness For Duty program is unfounde b. Allegation: The alleger states "once IP was confronted with positive proof there may be some error in this legal matter (alleger's voluntary negative drug screen), IPs only statement was that there was no appeal and this decision is final." The alleger l

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believed there should be an appeal mechanism in the IP FFD progra Review: The IP FFD program as implemented by Nuclear Planning and Support (NP&S) Department Procedure 1.16, Revision 0), entitled

" Fitness For Duty," has no provisions for an appeal of positive urinalysis test result NP&S 1.16 requires that once a contractor's random urinalysis test indicates the presence of illegal drugs the individual is to have his site access denied. The test results were I positive and the alleger's access was denie Conclusion: The alleger's statement that there is no appeal mechanism for urinalysis test results contained in the licensee's FFD program is tru There also appears to be no NRC position for the appeal of urinalysis test results in FFD progra c. Allegation: The alleger believes that "the testing problem at Clinton is not a new one, yet your office (NRC) has remained silent fully aware of the conduct on the part of the utility."

Review: The Region III office is unaware of any on going problem with IP FFD progra Interviews with the Medical Programs i Supervisor (MPS) indicated that there was no other litigation past i or pending against IP concerning FFD matters. The MPS also stated that he had received no other complaints since he assumed the position in 198 .

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The Region III office did review an allegation which involved plant employees being able to circumvent urinalysis testing procedure The allegation (RIII-86-A-0088) was received May 13, 198 During that allegation review it was disclosed that the licensee did not always maintain adequate control of the urine specimens. As a result of the administrative control problems a new MPS was appointe An audit of the FFD Program by Bensinger, Dupont & Associates during the period December 18, 1986 to January 15, 1987 concluded that-procedural control of specimens and program administration were good and met the administrative requirements established by the Edison Electric Institut Our current review of program administration revealed no discrepancies.

I Conclusion: There were no previous nor any other pending complaints concerning the wrongful termination of site access as a result of the IP FFD program. The allegation that previous problems have occurred and that the NRC was aware of those problems and did I nothing is unfounde d. Allegation: The alleger contends several times that IPs drug testing program is grossly ;naccurat Review: The alleger presents several claims that the drug testing )

results are inaccurate. He stated that he submitted to a a voluntary urinalysis administered by a local private physician a few hours after taking the random urinalysis administered by IP on September 29, 198 The alleger states that "No Drugs Detected" results from his voluntary test contradict the positive " Drugs Detected" results obtained by IP. The alleger states the contradiction supports his claim that the IP drug test is inaccurat The alleger states that he was taking several prescribed medications and that some drug tests have indicated false positive results for illicit drugs present in urine when the results were actually due to prescribed legal medications. He also notes the discrepancy in the two IP tests as another indication of test inaccurac The Qualitative Test (Exhibit F) indicates that both Phenylpropanolamine and THC-COOH were present while the Qualitative Test (Exhibit C) indicates that THC-COOH was presen The inspector obtained a copy of the alleger's voluntary urinalysis test from IP. IP had received their copy of the alleger's voluntary urinalysis results from Hawkeye Technical Services. The difference in the final results between the voluntary and IP tests could not be explained. The voluntary test administered by private physician does not indicate the date and time the sample was collected. It only lists the date testing began and the date the results were reported. The IP test does provide the additional informatio l- - - -- -----_------ ---_- _ _--_ ___ _ _ _ _

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The IP tests are conducted by the Smithkline Bio-Science Laboratories (SK). SK reports the results of the confirmatory qualitative and quantitative tests to the client on the date indicated on their test results for The voluntary test results were given to the alleger by the physician on October 1, 1986, according to the alleger's letter. The voluntary test results form indicates, however, that the results were reported on October 28, 198 These procedural informational variances between the voluntary and Sl'. test results could indicate a difference in quality between the two test ,

Although the quality control procedures and the reliability of the )

voluntary test are unknown, the quality and reliability of SK test ;

is known and can be demonstrate Strict controls as described in Attachment 3 to NP&S 1.16 are in effect from the time the sample is taken by Medical Programs (MP)

personnel until the sample is tested and reported by SK. These sample control procedures were verified August 12-13, 1986 during the review of an allegation No. RIII-86-A-0088. These procedures were verified through interviews and record reviews to be in effect on September 29, 1986 when the alleger provided his random urinalysis i sampl Each provided urine sample is split into two containers. One container (A) is sent to the laboratory in Schaumburg, Il for 4 initial drug screening. The other container (B) is retained and 1 controlled by MP for further testing, should sample A test positiv .'

In the alleger's case sample A did test positive during preliminary screening. It was then forwarded to SK in St. Louis, M0 for j Qualitative confirmatory testing. Sample A was then tested for the 4 type of drugs present in the sample (Qualitative). Sample B was sent i to St. Louis where it was analyzed for the quantity of drug present l in the sample (Quantitative). SK does not perform Quantitative !

analysis of samples for the compound Phenylpropanolamin The compound would be identified, however, in the Qualitative test and reported. The absence of the compound in Exhibit C (Quantitative test) is therefore, consistent with established SK procedure Licensee documents provided by SK and an interview with the Technical Director-SK on May 21, 1987 indicate that SK is unaware of any interferences (false positives) caused by over the counter drugs in its gas chromatography / mass spectrometry (GC/MS) assay for I cannabinols. Both the Quantitative and the Qualitative tests are l GC/MS assay ;

The State of Illinois Department of Public Health (DPH) reviewed the testing procedures employed by SK to determine the drug content of blood and urine in 1986 but DPH had no certification program at that time. On January 1,.1987 DPH certified the SK tests and technicians who performed the tests as complying with current State Standards I

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and Procedures for drug content of blood and urine. The SK tests which were certified on January 1, 1987 were the same tests to which the alleger's September 29, 1986 urine sample were submitte Conclusion: Although the cause for the different results from the alleger's voluntary and the random IP urinalysis cannot be determined, IP FFD urinalysis carried out by SK are accurate and reliable. The allegation that IP urinalysis results are inaccurate is, therefore, unsubstantiate Allegation: Urinalysis testing cannot determine whether an individual is fit for duty and therefore, the test should not be the-basis for employment terminatio Review: Section 5.1.20 of NP&S 1.16 requires'that any contractor whose confirmatory urine test is positive for the presence of unauthorized drugs have his site access denied indefinitely and discontinue work on all Clinton Power Station (CPS) projects. The IP FFD testing program does not determine whether an individual is actually physically and mentally capable of performing assigned duties at a given time. The program has established that certain compounds present in sufficient quantities in an individual's blood or urine are grounds for termination of CPS site access and the cessation of work on all CPS project This is verified by the disclaimers on the SK test results form states that "the presence of 11-NOR-DELTA-9-TETRAHYDROCANNABIN0L-9-CARBOXYLIC Acid (THC-COOH) in the urine confirms previous cannabis exposur Urinary levels do not correlate with the degree of THC intoxication l nor do they indicate the time span since last exposure."

l The IP position as stated in NP&S 1.16 regarding employment termination based on specific blood or urine levels of certain compounds is consistent with Edison Electric Institute (EEI)

guidelines for the policy development of Drug and Alcohol / Fitness For Duty programs. EEI guidance states that " illegal use of drugs off duty and of f company premises is not acceptable because it can affect on-the-job performance and the confidence of the public and the government in the company's ability to meet its responsibilities; such use may result in discharge."

Conclusion: The alleger is correct in that a urinalysis cannot determine whether an individual is under the influence of illegal drugs at the time of the tes IP however, has determined that presence of certain substances in an individual's blood or urine are grounds for termination. The IP FFD program is consistent with EEI guidelines which allow the termination of employees for off-site drug use. The allegation is therefore unsubstantiate Allegation: The alleger claims that he was not randomly selected for urinalysis testing and that The Fitness For Duty Program was abused so that he could be removed from the work sit .

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Review: The issue that must be resolved in this matter is whether the alleger was actually selected for a random urinalysi Section 5.3 of NP&S 1.16 requires that personnel selected to participate in IP's random urinalysis program will be chosen by a computerized random number generator progra The computer program randomly selects, by name and social security number, those individuals to provide a sampl The computer printout for the personnel randomly selected on September 29, 1986 had been destroyed during the normal course of l business, according to interviews with the MP Assistant. There was no procedural requirement to maintain the printouts for.any specified time period. A review of the MD sign-in log shows that-the. alleger signed-in on September 29, 1986'and the " category".(reason) for the urinalysis test was random. Several other personnel listed on the same page of the sign-in log also indicated the random categor The MP personnel clerk completes the log, to include the type of-test (random). The individual is then asked to verify'all-entries ,

by signing the log. The alleger verified that the category of_the i urinalysis test was random by signing the log on September 29, i 198 Further discussions with the MP Assistant disclosed that she maintained a separate manual log to indicate the' disposition of plant personnel who were contacted in accordance with.the FFD progra A review of the Assistant's manual log book indicated that alleger was selected randomly for a urinalysis test. The manual log book is a permanently bound document in which each action undertaken by the'-

Assistant is chronologically listed. The activities annotated include the manner of individual's selection, the time.the individual supervisor was notified, the time the individual was notified and escorted to the MP facility. The alleger's entry had not been altered nor could any pages have been substituted since they {'

ran chronologically prior to and after September 29, 198 The selection of the alleger for a random urinalysis test is not patently suspicious. During 1986 IP conducted 2,071 random urinalysis tests (1321-IP employees; 750-contractor employees). IP management determined, sometime after October 1, 1986, that all 1 personnel employed at the Clinton Power Station would be randomly I drug tested by December 12, 198 The documents reviewed and the interviews conducted indicated that the alleger was randomly selected for urinalysis testin His selection was consistent with NP&S 1.16 requirements for random i selectio )

'i Conclusion: The alleger was randomly selected for urinalysis testing as prescribed in Illinois Power Company's NP&S 1.1 The allegation is therefore unfounde ,

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The following allegations are related to the documents attached to 1 the alleger's March 26, 1987 letter to the NRC. The documents were originally forwarded to the alleger by a January 8, 1987 IP lette To review the individual allegations concerning the documentation of the allager's FFD case, the inspector established the chronological order in which the documentt were generated. The document trail was developed through interviews with IP personnel, document reviews and review of the administrative requirements contained in NP&S 1.1 .j

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The following documents will be identified in the chronological order that they were issued in the alleger's FFD case:

(1) After receiving L. positive (presumptive) on the screening test, which was performed on the first half of the alleger's split urine sample, Smithkline (SK) notified the Supervisor-MP to forward the second half of the urine sample to SK-St. Louis for Confirmatory Quantitative testing. SK-Chicago then dispatched the remainder of the first half sample to SK-St. Louis for Confirmatory Qualitative testin (2) Normally the results of the confirmatory testing are received by IP two days after the samples are submitted to S The results of the qualitative tests are normally received prior to the quantitative results from SK-St. Louis. In this case a shortage in testing equipment (GC/MS) resulted in the results of both tests being received on October 8, 1986. The results are received three times daily at the MP facility by means of a computer terminal which is connected with SK-St. Louis. The Qualitative results were received first with the Quantitative results received later in the da (3) Positive Qualitative results (Exhibit F - Drug Abuse Screen II l Qualitative) lists all drugs present in the urine and results in an individual's site access being suspended. The Supervisor-MP initiates a memo to the Director Human Resources (DHR) to notify DHR of the results of the test (Exhibit E - Fitness For Duty Initial Positive Test Results).

(4) DHR then initiates a memo to the Vice-President for notification of initial positive urinalysis results and suspension of the individual's site access (Exhibit D - Access Suspension Letter).

The Vice-President concurred with the action but the alleger had departed site for the day before he could be notified that his preliminary urinalysis results were positive and his access was being suspende (5) Later on the afternoon of October 8, 1986 the Supervisor-MP was notified of the alleger's positive quantitative urinalysis results (Exhibit C - Quantitative Test Results).

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l (6) The Supervisor-MP notified DHR of the results (Exhibit B - Memo Positive Quantitative Test Results). However, the Vice-President had departed for an October 9, 1986 meeting with the NRC in Washington, DC and was not available to approve the DHR letter until October 10, 1986 (Exhibit A).

(7) On October 9, 1986 the alleger was notified by his supervisor that his access was suspended based on the preliminary results of his urinalysi His supervisor provided the alleger with the undated suspended site access letter on October 9, 1986 J (Exhibit I - Individual's Access Suspension Letter). The letter was signed by the Acting Director - Plant Operations because the Director - Plant Operations was on vacation October 8 and in training on October 9, 1986. The inspector determined that Exhibit I was most likely signed on October 9, 198 (8) As previously mentioned the Vice-President returned on October 10, 1986 and approved Exhibit A which resulted in i Exhibits G and H being issued. Exhibit G was not issued to the I alleger as required by NP&S 1.16 because the licensee had no forwarding address for the alleger. Exhibit G was forwarded to Hawkeye Technical Services (HTS) Corporate Headquarters on October 30, 1986 after the alleger queried HTS about the outcome of his confirmatory urinalysis test result The alleger's assertions concerning the IP administration of his FFD case were then reviewed against the established document trail described abov Allegation: The alleger claimed that he was never notified of the q final determination on his FFD case. The failure of IP to provide i the alleger with the final disposition of his FFD case was in the I alleger's opinion indicative of a licensee cover-u )1 Review: As mentioned in the document trail of this Section the licensee had no forwarding address for the alleger and therefore, did not notify him officially that his site access was terminated (Exhibit G). Exhibit G was forwarded to the alle0er's employer, HTS, on October 30, 1986 by the licensee. The licensee also i forwarded several documents and all the allegation Exhibits to the l alleger on January 8,1987. The licensee's action concerning the l alleger's notification of site access termination was not' indicative i of any cover-u Conclusion: The failure of the licensee to immediately notify the alleger that his site access was terminated was not indicative of a cover-up. IP did notify HTS, the alleger's employar. lhe allegation is unsubstantiate Allegation: The alleger claimed that his site access was terminated on October 9, 1986, yet the licensee had' received his positive urinalysis results on Octnber 1, 1986 (Exhibit A), while another document (Exhibit D) indicated the results were received on

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October 8,'1986 and that the alleger's site access.was suspended ~on October 8, 1986. The administrative-errors were indicative of an'

IP cover-up according to the allege Review: 'As discussed in the document trail of this.Section the results of the alleger's confirmatory qualitative and quantitative test results were received by..the Supervisor-MP on October 8, 198 The qualitative results were received first and action (Exhibits E and D) were initiated to suspend the alleger's site acces Responsible licensee personnel determined that the_ alleger had departed site on 0ctober 8, 1986 before he could be notified.that his access was suspended. On'0ctober 9, 1986 the alleger's site .

i access was suspended. He was given a copy of Exhibit I and' escorted off-site. ' Exhibit A states that the alleger's random urinalysis-results were received on'0ctober 1,-'1986'and that the-alleger was i suspended subsequent to receiving the results. :The Director, Human L Resources stated'that the date was-in err and._ should have been-October 8, 1986. Furthermore, the-verification;(confirmatory quantitative) test results (Exhibit C) were also received on October.8, 1986 but after the-Vice-President had departed for an October 9,1986 meeting in Washington, DC. The Vice-President (VP)

approves all FFD actions therefore, Exhibit A was not signed until October 10, 1986 after the VP's return.' Although. administrative errors existed in some of the documents in question there was no intent. identified to backdate documents. The alleger.'s site access was suspended and. terminated in an expeditious manner and in accordance with the prescribed procedure (NP&S 1.16).

Conclusion: Although there were some administrative: errors included in the documents issued in the alleger's FFD case,'all actions-required by NP&S 1.16 were completed.- The' allegation was unfounded, Allegation: The alleger asserts that there is a contradiction in- I the urinalysis results because the qualitative results were positive for cannabinols and phenylpropanolamine (Exhibit F) while the quantitative test (Exhibit C) was positive for cannabinoid onl Review: This discrepancy was explained in Part d of this Sectio Phenylpropanolamine is an over-the-ccunter compound that is identified in qualitative testing but. is not quantitatively analyze The apparent discrepancy between the two tests is  ;

appropriate and the licensee's testing procedures are adequate as well their test result reporting procedure ]

Conclusion: There is no actual discrepancy between'the results of Exhibit F and C. The allegation is unfounded, Allegation: The alleger claimed that Exhibit 'G (Termination of Site i Access) was backdated because the Director - Plant. Operations (DPO) ;

was not'on site October 10, 1986 and therefore, could not have-signed Exhibit G on the date indicate '

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Review: Interviews with the Director, Human Resources and Supervisor, Labor Relations on April 2,1987 and May 4,1987

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i determined that the DP0 was on site attending training on ;

October 10, 1986, t Conclusion: The DP0 was on site and therefore the allegation is unfounde k. Allegation: The alleger asserts thet he had not received any final disposition concerning his FFD case and his site access as of .

October 28, 1986. On October 30, 1986 the licensee forwarded i Exhibit G (Site Access Termination) to the alleger's employer yet the termination letter was dated October 10, 1986. The apparently backdated letter was an indication of an IP cover-up according to the allege Review: The alleger did not receive his site access termination letter in a timely manner because the licensee had no forwarding address for the alleger. However, the letter, Exhibit G, was promulgated on October 10, 1986 automatically as required by NP&S 1.1 The licensee did not backdate any document Conclusion: The licensee promulgated all letters required by NP&S 1.16 and took all actions to suspend / terminate site access in a timely manner. Although there were some inaccurate dates contained in the documents generated in conjunction with the alleger's FFD case, there was no attempt by the licensee to backdate or alter case )

documents. The assertion that the licensee backdated documents in 4 an effort to support a conspiracy to single-out and eliminate the alleger is unsubstantiate l l 12 l 1

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