IR 05000483/1990014

Insp Rept 50-483/90-14 on 900724-27.No Violations Noted. Major Areas Inspected:Licensee fitness-for-duty Program,Drug & Alcohol Abuse Policies,Testing Program & Randon Testing Program

ML20059F144
Person / Time
Site:	Callaway
Issue date:	08/31/1990
From:	Christoffer G, Creed J, Knicely J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059F106	List: IR 05000483/1990014 ML20059F103
References
50-483-90-14, NUDOCS 9009110105
Download: ML20059F144 (10)

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U.S. NUCLEAR REGULATORYJCOMMISSION: *'

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' ~ REGION III' ,L in p ,pe4 * r I ' Report NoT 50-483/90014(DRSS) _

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/ . Docket No.c50-483: ' '

License No. NPF-30:

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y Licensee:l Union Electric Company ,

.P.O.- Box-149 - Mail Code 400- .i Stt Louis, MO - 63166

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Faci 1Ity Name: . Callaway County Nuclear Power Station, Unit 1

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._ Inspection ~ At: _ Callaway Site, Callaway County, Missouri e

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-. Inspection Date: July 24-27, 1990 - '

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G. M. Christoffer Date Signed '

Physical Security Inspector >

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_ Date Signed J Physical Security Inspector 4

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Appro ed By: U Ha[teSigned

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'Utimes R. Creed, Chlef e

afeguards Section q

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' Inspection Summary "

y Inspection on July 24-27, 1990 (Report No. 50-483/90014(DRSS))

• , . Scope: <This special, announced inspection reviewed-the licensee's' fitness -  ;

<for-duty program' required by 10 CFR Part 26. The review was conducted in Jaccordance with Temporary Instruction 2515/106(TI). Specifically, the inspectors evaluated the licensee's drug and alcohol abuse policies and- ,

f procedures;: implementing organization, worker awareness of' program, random .

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ntesting .progrcm,: collection and testing facilities, training and any reported, s ,

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-fitness-for-duty-(FFD) event .,1

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.Results:' Based 'on the NRC's selective examination of key elements of the j licensee's Fitness-for-Duty' Program, it was concluded that the licensee is y

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-satisfying theLgeneral objectives of 10 CFR Part 26.10. Our inspection also

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identified several program strengths and some weaknesses- which have been  ;

. corrected.- '

" Program strengths were noted concerning the licensee's onsite testing  !

facility;- the dedication, qualification and professionalism of the sample

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$ weaknessesLwere.noted concerningfc6l oversight of the programn Program'

ntrols forzidentifying/contro111ng1 P 6M, 3 kb m. cthe: courier. vehicle,tthe(locati_on ofsthe: printer used- for random ' lists pand? g ~N

$J'd * isomei. supervisors 7dnderstandingLoff their; for ecauses:testingDrespon'sibilitiess. y~ M j v+4^

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$b W '2'1 testing lwillfrequire(furtherrevie OThe111censedsTprogramlforjestingScontractors'not immed'iatelyfavailable/ fort

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> REPORT DETAILS

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F> l Key Person's Contacted =

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[In:additionto-thepersonslistedbelow,theinspectors' interviewed ,

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other licensee employees > and members of thei security organization; . The1

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. asterisk (*) denotes those, present~ at the Exit Interview conducted o '

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July 27, 1990;

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• GJ Randolph. General Manager, Nuclear Operations Union Electric;(UE) ~

• C. Naslund.. Manager 0perations Support, UE . '

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• G. Pendergraff, Superintendent, Security, UE ,

t .*M. Evans; Superintendent, Training,' UE '!

!E *W. Stubblefield,, Superintendent, Personnel; UE-- '

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• R. Rist, Assistant Superintendent, Personnel, UE

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.*D. Knoepflein, Supervisor,-' Personnel, UE '

m '*J. Laux, Manager, Quality: Assurance, U '

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• T. Stotler, Supervisory Engineer Quality l Assurance, UE j

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-*E. Thorton; Engineering Evaluator, Quality Assurance, UE - ,f V *P. Davis, Fitness For. Duty Nurse, UE il h-'

• L. ' Smith, Si te- Nurse, UE ,

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- R. Osbourn, M.D. Medical Review Officer- . d O NRC m

• B. - Bartlett, Senior. Resident Inspector . I 4 , '*J. Creed, Chief, Safeguards Section' Region'III

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d q Other Organizations u '

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• J. 0lson, Senior Research Sci:ntist,.Battelle Human Research Center

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h (NRC contractor, participated in the inspection) ,,

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.y Entrance and Exit Interview'(IP 30703) ,

e .. At the beginning of the inspection, Mr. G.! Randolph o'f the licensee's:

. staff was informed of the purpose of this visit and the functional

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d areas to be examine W The inspectors met with the licensee representatives denoted in  ;

- Section 1 at the conclusion.of the inspection on -' July 27, 199 '

The Chief, Safeguards Section, explainert that a newly published  !

b;  ; Temporary Instruction (TI 2515/106) '.<aso ' eing utilized' for- this 1.: inspection, and that the Battelle consultant -had accompanied 'the  :

J inspectors to assist in their use of the TI. They were advised that j this: inspection had been a selective examination of their fitness-for-- -1 duty program to determine whether it meets regulatory requirements, ,

.and that because this was a new intpection initiative all findings .

-would be further reviewed by both R!gion III management and NRR management subsequent to the exit intervie ,

Our review concluded that the licensee's program is satisfying the

. general objectives of 10 CFR Part 26.1 .

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(a) The controls for verifying; the identity?of the courier and the;

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-security lof the9ourier vehicle were weak ;: InLresponse, the licensee y

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implemented a temporary procedure chang'e, effective July 27. 1990, to;

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-address the: issue.J (b)'The printer, used;to: produce.the random testing- ,

n list was located such that generated lists were not wil protected. The  ;

licensee informed Region.III by phone'that the_ printer was moved and better secured on August: 2, ^1990.- (c) Some supervisors did not appear ,

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to;have a good. understanding.of their responsibilities regarding ,

for cause testinga The licensee distributed a memo'on July 27, 1990, to all supervisors explaining ar.d clarifying' their responsibilitie Several licensee strengths were. identified; enmples includeJ:- (1)The assignment;of an FFD program manager who has i .sponsibility for many -

of the departments contributing to the FFD program.- The. individual's position appears appropriate to facilitate coordination ofl activities and; resolution of ' program differences. (2)The_locationand_designofthe onsite collection facility enables the licensee to have_ good controll over .the process. .(3) Early and extensive invulvement of the Quality Assurance -(QA) Department enabled the licensee to effectively implement

. the program.~ (4) The professionalism, qualifications and dedication of the collection facility personne ,

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Subsequent to the exit' interview our review identified an issue pertaining to the licensee's program for testing contractors not immediately  ;

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available that requires further review to determine-if it meets the intent of -10 CFR 26. Mr. W. Stubblefield was notified of this by, .

telephone August 17,1990 (Paragraph 7). , Inspection Approach (MC 0610)

By letter dated June 11, 1990, the licensee was notified of the dates :and scope of the inspection. They were requested to provide the latest revisions of the required FFD policies and_ procedures, which were reviewed in office-prior to the or. site inspection. The inspectors i also reviewed the semi-annual report of-program performance data. The  !

V results of the Resident Inspector's report. dated December 19. 1989, .;

which described his observation of the FFD training sessions were also t reviewe '

Onsite inspection activities began with interviews of the key individuals

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responsible for program implementation.and included, for example:

the Medical Review 0fficer, Fitness-For-Duty Nurse, Manager Operations

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Support, and the Superintendent of Personnel. Inspection activities

also included interviews with 12 employees regarding the understanding of program requirements and protections, i

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The inspectors conducted a tour of the onsite sample collection and testing _ facilities as appropriate. Record storage areas and protective measures were also inspecte p fE- nj l a

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Written Policies and Procedures (TI 2515/106 05.01c)'

y' The. licensee's written FFD policies and procedures were reviewed 'and y compared to the requirements of 10 CFR Part 26.to assure' that they were

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comprehensive and of. sufficient clarity and detail to communicate duties J, and responsibilities and to support the implementation oflthe progra The inspection. team had the following observations:- .;

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'A written, comprehensive policy on fitness for duty was found in Nuclear-

Function Directive (NFD) 15, Revision 2, dated February of the policy were posted in several hallways in a manne6, 199 Copies :)

r that made access to the policy quite easy. Interviews with employees indicated that the policy was effectively commur.icated through trainin !

Written procedures were developed which adequately' detailed.respons-ibilities for important aspects of the prograr "olving: presumptive positive tests, selection and notification of <..viduals for testing, collection and processing of -specimens, on-site testing, and Medical .:

Review Officers' (MRO) review and notificatio The FFD program personnel have worked closely with the Quality Assurance i department in the development of the procedures. The result is a set of procedures that implement theJprogram as required by 10 CFR Part 2 ' Program Administration (TI 2515/106 05.02 a) y The program responsibilities = have been clearly described in' the

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licensee's procedures. There appear to be no gaps in the assignment of responsibilities. 'Maiors FFD program functions have been assigned appropriatel ,

Several organizations were responsible for. the '

developing and implementing of the FFD program. The FFD manager is the Manager Operations Support and the other key FFD individuals are under the Personnel Departmen i Although the key FFD. individuals we*e from various departments, a strong teamwork approach was identifie .A particular strength of the program is the assignment of an individual as FFD program manager who also has line responsibility for many of the- a

. departments contributing to the progra k Management performanc appears to devote adequate attention to monitoring program Upper management within the program is well informed of operational problem Meetings are held a re  :

FFD staff attempt to resolve outstanding .. sues. gular basis where all

.. All of the FFD program personnel had a clear understanding of their own

• responsibilities as well as the responsibilities of others involved in the progra understanding of the details of the program.All of the. personnel inte

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The licensee's key FFD staff have the necessary training and experience

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to perform their function The licensee recognizes the need for having several people qualified for each position within the FFD progra The

licensee's plan to train additional people in specimen collection a,nd operation of the testing the need to maintain adequate equipment demonstrates an understanding of human resource <

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$h , , 6h Worker Awareness (TI 2515/106-05.02b):

.The inspection, team conducted twelve interviews of. licensee and contractor employees. The individuals had a. good unde.rstanding of b , the.FFD policy and the. program elements.that relate to-them." Those intuviewed indicated support for.the program and mentioned they did--

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4; not want to work with someone that was not fit-for dut 'l fi !7; Program Elements (T{ 2515/106-05.02c)

! Random Testina 4

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The' random selection process appears to produce a truly rar. dom selection of individuals for-testing. Selection was conducted '

once a week using a computer generated, random list taken from a pool of all:1.ndividuals with unescorted access to the. protected i area and EOF re'sponders. The list of individuals with unescorted '

access is continuously updated. Once'an individual has been i identified, specific testing times are established by the FFD "

staff based on the knowledge of each individual's work schedule

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for the week. This minimizes the number of cases in'which -

individuals are not present for: testing. . Individuals are notified ,

by a department supervisor generally within w surs of reporting

- for testing. When. corporate ~ personnel are -- d,~one of the 1 i FFD program site staff members dri- .. is.and collects-the~ specimen.-. When contractors are selected but are not onsite' .y

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during that testing week, their badges are tagged with a note that indicates one of the fitness-for-duty collection personnel (by '

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name)shouldbecontacted. When the selected employee returns to *

the site the fitness-for-duty collection personnel are initially notified by guards. They will then implement the normal  ;

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-. notification process. The person is tested when he/she returns

- to the site. The practice of tagging badges to indicate.that ,

- fitness-for-duty personnel should De contacted reduces the random .l

- nature of the test for those select contractors. - The potential ,

exists that the individual could be notified of the test and avoid detection. This method of testing is considered an unresolved item pending further NRC review of the issue to determine ir the practice meets the intent of 10 CFR~-26 (50-483/90014-01).

The selection and notification process was adequate to assure that testing is conducted in a random manner, that all individuals with unescorted access to the protected area and the E0F were included i and subject to testing at essentially equivalent frequencies, that

testing was being conducted on weekends and on backshifts, and that

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the privacy of workers was being protecte The selection process appears to have adequate physical and computer security. Procedures exist for assuring that selection personnel cannot alter the randomly generated list. Quality Assurance personnel do periodic surveillances to assure procedure complianc ?

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One- firiding concerns.the fact that the printer used in generating

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the list isiin an open area. When identified,-the: licensee s ,

committed to moving the printer to' aimoreisecure area to which

&> only members of the FFD staff would have; access. The printer was'

m U ' installed in the controlled area of the' collection facility on

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August-2,-,1990?

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Union Electric has contracted with two HHS certified laboratories;-  :

Pharm Chem Laboratories, Inc. Menlo Park,' California is the primary

. lab and' Smith-Kline Beecham Clinical Laboratory. Chicago, Illinois . ~ .

is the back-up la ,

x The licensee's testing cut off levels are in agreement with o ;

more conservative- than 10 CFR 26-. requirements. Also, barbiturates-.

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'and benzodiazepines have been added to the panel lof substances

for-testin Below are listed the cut off levels that are more j'

conservative than those described in 10 CFR 26 Appendix ' Managements actions, when a person fails a more' stringent standard,= Ai"

are-the same as if the individual failed the NRC standar '

Initial test cut-off level (ng/ml)

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10CFR26 Union Electric d Marijuana metabolites ............ 100 20 i Barbiturates ......................'n/a 300, Benzodiazepines ................... n/a 300 Confirmatory test cut-off level (ng/ml) 10CFR26 "

~ Union Electric Opiates: 3

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Morphine .................... 300 150 Codeine .....................

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300 150 ,

Ba rb i tu ra tes . . . . . . . . . . . . . . . . . . . . . . n/a 250 Benzodiazepines ................... n/a 150 t Documentation The: licensee ~has developed adequate systems for documenting the "

key elements of the FFD program and for assuring'the protection ofL information. The licensee has a-general policy of limiting. access to-information to those with a clear need to know. -Selection- .

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lists, chain of custody. forms, tests results, the permanent loq, )

and individual FFD files are carefully protected. The design of the various records is adequate to assure that all relevant information is collected and can be retrieved when needed. An s inspection of a sample of the records showed them to be legible and complete. Physical security for the records is adequat . Files are kept in locked cabinets in a locked room. There is a systematic and effective means'of limiting and controlling  ;

access to facility keys. The FFD program personnel were knowledgeable concerning the data storage requirements outlined in the rul l Sanctions and Appeals j

The licensee's Policy and Procedures are consistent with required actions identified in 10 CFR 26. These procedures indicate that

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O, the first confirmed positive ' test results in denial: of access for-

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, a~ minimum of 14 days and referral:to the EAP. yAny subsequentL confinned positive test result's in denial of- access for three ,

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years; .Any individus t involved in the sale use or possession of 1 illegal drugs within.the protected area will result .in denial of J access for five years .and discharg Although- the rule does not identify sanctions for alcohol,' valid-

, prescriptions or. over-the-counter- drugs, impaired workers or ~those; whose fitness may be questionable are: removed from work activities

< and.may return to work only after they are* determined to be fit and y" can safely perform assigned duties.. The first occurrence of. identified violation of the alcohol abstinence period,will result

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.u in suspension for- the balance 'of the da Repeated occurrences' of'

( positive alcohol tests will result' in more serious disciplinary K , ections, up to and including discharg '

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The licensee's- appeal process for a' positive alcohol or drug ,

o ' determination has been established in procedures and~ meets o '

• exceeds rule requirements. The MRO notifies the individual of a confirmed-positive test result and offers an ! opportunity to discuss the results prior to notifying the FFD. manage >

The individual'is given the opportunity to request that the.. split A reserve sample be screened and confirmed by an independent *

laborator ~

Contractor employees who have been denied access based upon the ~d first confirmed positive drug test may regain their unescorted - ;

access if they provide evidence of rehabilitation and abstinence of substances and undergo follow-up testing., ~t JAudits ,

The licensee avoears to have'an-adequate audit program, based .

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primarily on:its own QA department. The QA department conducted .

a very thorough pre-implementation audit which was successful 1

~in identifying and correcting a number of program weaknesses, y The QA department conducts ongoing surveillances, and has assigned one QA engineer to have oversight of the FFD program as a primary-responsibility. The licensee is planning a post-implementation audit for October 1990 and is planning to augment the-QA audit team with outside expert QA has also completed two surveillances since program implementation, d in these surveillances, QA looked at-the' randomness-of the selection y

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process, whether testing was being conducted at night, on weekends and on holidays, whether. records were being properly maintained and  ;

protected, and whether the QC program for onsite testing was s adequate. QA found the FFD program to be adequate in the areas s inspecte The involvement and quality of the licensee's QA program in the area of FFD was considered to be a program strength.

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q Sample Collection /Testina' Facility (IP 2515/106-05.02 d)

f' , 4 The' onsite testing facility is a new, well-equipped, and well run -

s ;,. ' Efacility. ~ The personnel operating the breathalzyer and -the-drug; y screening equipment'are well.qualifie3 and clearly: familiar with both I the . licensee's and the' equipment manufacturer's procedures. Access to L

the testing equipment, specimens, reagents, and proficiency testing samples is strictly controlled. -Quality controls!are being'implamented

as required by the rule. . The results-of the' blind proficiency usts

g  ! indicate that the testing process is effectiv i

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Review of personnel files and interviews showed that site collection-

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personnel are well qualified. Facilities provide a professional-and:

orderly environment for the collection of specimens. During the

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.walkthrough of the' collection process,. we noted that. program personnel o

L 'followed the required procedures carefully and professionally. ' Care was taken to. explain the process to the individual. to obtain the -

necessary. signatures. to obtain information on prescription drugs being used, to assess'the specimen for indications of tampering, and .to initiate..the chain of custody process. In addition, it was noted-that :

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the facilities were designed to inhibit specimen tampering. Blueing .

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' was present in'the water, ceiling tiles were secured and su) ply. cabinets-in the collection rooms were inventoried daily and.kept loc (e ,

Specimens were properly packaged, labelled and stored adequately in ,

preparation-for shipmen One finding was identified in this area. The procedures for verifying the identity of the laboratory courier and the security of the courier's :

vehicle while onsite were not evident. A. temporary procedure change was ' t put into effect July 27, 1990, which quickly corrected this deficiency.

p The licensee-has committed to develop and implement more permanent

. procedures, which will require positive identification of i.iis courier 3 i

driver and proper security for the vehicle while onsit ,The licensee's testing facility and personnel are collectively considered a. program strengt '

The program appears to have ample resources. . The onsite collection and u

• : testing facility that was recently constructed demonstrated a willingness on the part of the-licensee to devote appropriate resources to the progra .. Training Program (TI 2515/106-05.01a)  !

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-iThe inspectors did not directly observe any FFD training, but did review-selected curriculum and the results of the . review of the FFD training program sessio'ns which were attended by the resident inspector on

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December 19, 1989. The resident inspector, using TI. 2515/104, evaluated the licensee's FFD supervisor training. The FFD training appeared to be effective as evidenced by the employees' knowledge and support for the !

, FFD progra ,

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The inspectors reviewed a selected small sample of records to assure that individuals with access to the protected area had received FFD

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, a trainingvand that supervisors had received continuous observation training. It was also determined that a system is.in place to= identify

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'when refresher training _is needed.-'In general, training appearsLto be!

s . effective. Interviews with; plant staff indicated knowledge of the rule.

6 and their responsibilities. Supervisors appeared to understand their

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special responsibilities and to have both the-skills and motivation to

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, use their behavior observation trainin ;

One finding was identified.- The supervisors interviewed did not= appear!  :

to be knowledgeable;of their responsibilities as they specifically relate to the'for-cause; testing process. During interviews theyldid not explain -

that they were responsible for-directing that a for-cause-test be give ;

The licensee issued-a letter on July 27, 1990, to-all supervisors in' ,

response to-the inspectors' concern, identifying their responsibilities ,

and the process for supervisor identified for .cause testin All workers interviewed appeared to be generally supportive of the FFD

. program and'its goals. They_ appeared.to have a high level of confidenc ,

in the integrity of the onsite. collection and testing process and the FFD personne The. licensee maintains an Employee Assistance Program (EAP) that-is- -

available'to all Union Electric (UE) employees. Employees .are encouraged -

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to use the EAP as needed. A review of usage statistics indicates that employees make frequent use of the EAP. They appeared confident that  :

their'confidentialitv would be maintained. Interviews with plant staff-

' indicated both a willingness to use.the EAP.and a willingness.to refer-others to the,EAP, Prior to'.-rule implementation, the EAP had been use to successfully refer and monitor drug and alcohol rehabilitation. ' EAP

- services are 'not provided by UE to contractor: employee . Reported FFD Events (TI 2515/106-05.01a).

There have been no events required to be reported to NRC. The-licensee 1 has recently submitted their six month report > on program performance required by 10 CFR_26.71(d). The licensee has not' experienced a  !

.. confirmed positive drug test since the effective date of implementation 'f of the rule, l

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