ML18100A376
| ML18100A376 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 05/07/1993 |
| From: | Albert R, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18100A371 | List: |
| References | |
| 50-272-93-11, 50-311-93-11, 50-354-93-07, 50-354-93-7, NUDOCS 9305180173 | |
| Download: ML18100A376 (6) | |
See also: IR 05000272/1993011
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/93-11
50-311/93-11
Report Nos.: 50-354/93-07
50-272
50-311
Docket Nos.: 50-354
License Nos.:
Licensee:
Public Service Electric and Gas Company
Facility Name:
Salem and Hope Creek Generating Stations
Inspection At:
Hancocks Bridge. New Jersey
Inspection Conducted:
April 5-7. 1993
Inspector:
Approved By:
Jht!b--C;IHJl!!"J'Saf eguards Section
Safety and Safeguards
0'5-os-?3
Date
~f/.J
ate
Areas Inspected: Follow-up of Previously Identified Fitness-for-Duty (FFD) Program Items; and
Overview of FFD Program Activities.
Results: The licensee's FFD program was directed toward public health and safety. However,
an apparent violation was identified in that 20 supervisors with responsibilities for implementing
certain aspects of the FFD program were not trained in a timely fashion. Additionally, an
apparent deviation was cited for failing to meet a commitment made to the NRC with regard to
personnel with infrequent unescorted station access.
-
9305180173 930507
ADOCK 05000272
G
DETAILS
1.0
Key Personnel Contacted
2.0
1.1
Licensee
- R. Binetti, Psychological Services Administrator (Acting)
- R. Brown, Principal Engineer
- M. Butz, General Manager - Human Resources/ Administrative Services
- R. Fisher, Screening and Badging Supervisor
- J. Fleming, Senior Staff Engineer
- L. Krajewski, Site Access Administrator
- S. Mannon, Licensing Engineer
- R. Mounts, Medical Supervisor (Acting)
- D. Renwick, Nuclear Security Manager
- M. Samuels, Medical Administrator (Acting)
- R. Savage, Lead Auditor
1.2
Contractor
- J. Rainear, Medical Assistant, Alternative Health Care
1.3
U.S. Nuclear Reeulatory Commission - Region I
- S. Barr, Resident Inspector
- S. Pindale, Resident Inspector
- denotes those present at the exit meeting
The inspector also interviewed other licensee and contractor personnel who did not attend
the exit meeting.
Follow-up of Previously Identified Fitness-for-Duty <FFDl Proeram Items
During a previous inspection that was conducted on February 1-5, 1993, the inspector
reviewed the licensee's annual security program audit report, no.92-031, and the
licensee's annual FFD program audit report, no.92-035. Based on those reviews, the
inspector determined that the licensee had experienced recurring FFD program problems,
specifically in ensuring that (1) personnel with infrequent unescorted station access meet
required aspects of the FFD program and (2) training for supervisors with responsibilities
for implementing certain aspects of the FFD program was conducted in a timely manner.
Licensee actions to resolve those problem areas were considered unresolved issues
(URis), pending further review during a subsequent NRC inspection.
During this
inspection, licensee actions in regard to those issues were reviewed by the inspector and
found as follows:
--1
3
2.1
Personnel with Infrequent Unescorted Station Access
URI 50-272/93-05-01, 50-311/93-05-01, and 50-354/93-05-01: As identified in
the security program audit report no.92-031 (for the audit conducted June 1-12,
1992), unescorted station access was not being revoked for individuals not
permanently assigned to the nuclear facilities who did not access the protected
area over a 60-day period. During the initial NRC FFD program inspection
conducted on March 12-15, 1990, the NRC determined that the licensee's
approach to random testing for personnel with infrequent unescorted station access
did not meet the spirit and intent of 10 CFR Part 26. In a January 29, 1991,
letter to the NRC, the licensee committed to the following:
"Individuals permanently assigned to nuclear department facilities
are available for random testing. All other individuals granted
unescorted access must either: access the site protected area at
least once every 60 days, QI make themselves available for random
testing. Failure to comply with these requirements will result in
loss of unescorted access. Affected individuals must satisfy all
normal access requirements to regain unescorted access.
Our
policy begins March, 1991.
11
During this inspection, the inspector determined that the licensee's initial
implementation of this commitment was predicated upon the security department
generating a report every 30 days that identified those individuals with unescorted
station access who had not entered the protected area within a 60-day period.
The inspector also determined that between March 1, 1991, and June 19, 1992,
such reports were not generated during 11 separate months. The longest span
without a report was for over 5 months, June 7 through November 26, 1991.
The licensee contended that the reports were not consistently run because it was
a labor intensive, cumbersome process that was overshadowed by back-to-back
outages, which overextended the personnel necessary to generate the report.
By not generating the report, the licensee did not identify those personnel who
should have had their access suspended. As a result, personnel who were not
available for random testing in excess of 60 days were allowed to continue
unescorted access to the station.
However,
the inspector verified that the
licensee had consistently generated the report every 30 days since June 19, 1992,
and revoked unescorted station access for personnel who had not accessed the
protected area within 60-days.
Even though the licensee identified this matter in an audit, it is being cited
because of the length of time the commitment was not met without notification
being made to the NRC.
The licensee's failure to identify personnel with
infrequent unescorted station access is a deviation from a commitment that was
4
made to the NRC (DEV 50-272/93-11-01, 50-311/93-11-01 and 50-354/93-07-
01).
This apparent deviation administratively closes URI 50-272/93-05-01,
50-311/93-05-01, 50-354/93-05-01.
2.2
Supervisory Trainin&
URI 50-272/93-05-02, 50-311/93-05-02, and 50-354/93-05-02: A review of the
annual FFD program audit (report no.92-035), conducted March 2-13, 1992,
resulted in the inspector finding that the licensee had not trained 20 newly
appointed supervisors who were responsible for implementing certain aspects of
the FFD program in a timely manner, i.e., before or within 3 months of
appointment. This finding was also identified in the licensee's previous annual
FFD audit, conducted in March 1991, (report no.91-035), indicating that the
licensee's corrective measures in response to that finding were not effective.
The licensee's corrective measure after the audit finding in 1992 was to train
everyone with unescorted station access to the required supervisory FFD training
level beginning on October 22, 1992, and annually thereafter. All such persons
were to have been trained by October 1993.
However, during the NRC's February 1993 inspection, the inspector pointed out
to the licensee that since the training was being conducted as personnel cycled
through annual requalification, a potential still existed for newly appointed
supervisors not to be trained in a timely manner. Supervisory personnel who
were appointed with more than 3 months remaining before their FFD training
expired would have to be identified and trained, until July 31, 1993. At that time
the requalification cycle would be within 3 months of completion.
Anyone
appointed after that time would automatically receive training at the supervisory
level.
During this inspection, the inspector determined that the licensee, in response to
the concern expressed by the inspector in February, 1993, had implemented an
informal method to identify and track FFD training for newly appointed
supervisors. The licensee provided the inspector with documentation to show that
115 such supervis9rs had been identified since February. The inspector reviewed
the documentation and determined that, as of April 6, 1993, all of those
supervisors had satisfactorily completed training.
As a result of this inspection, the following apparent regulatory issues were
identified with regard to supervisory training:
2.2.1 The licensee did not establish a viable method to identify and track newly
appointed supervisors when they were assigned responsibilities for
implementing certain aspects of the FFD program. Because of the way
5
the program was implemented, the potential for newly appointed
supervisors not to be trained in a timely manner has existed since
implementation of the FFD program.
2.2.2 The licensee did not implement effective corrective measures when
supervisory training issues were first identified during audit no.91-035 in
March 1991.
2.2.3 The licensee did not implement adequate corrective measures when
supervisory FFD training issues were again identified in audit no.92-035,
conducted March 2-13, 1992.
Part 26, Fitness-for-Duty Programs, Section 22, Training of Supervisors and
Escorts, of Title 10 of the Code of Federal Regulations requires, in part, that
managers and supervisors who are responsible for implementing the Fitness-for-
Duty program must be provided appropriate training to ensure that they
understand: (1) their roles and responsibilities; (2) the roles and responsibilities
of others, such as personnel, medical, and employee assistance program (EAP)
staffs; (3) techniques for recognizing drugs and indications of the use, sale, or
possession of drugs; (4) behavioral observation techniques for detecting
degradation in performance, impairment, or changes in employee behavior; and
(5) procedures for initiating appropriate corrective action to include referral to the
EAP. Initial training in those areas must be completed prior to assignment or
within 3 months of being assigned those duties.
Contrary to the above, in March of 1992, 20 newly appointed supervisors were
identified during a licensee audit who did not receive appropriate training before
or within 3 months of being assigned those duties. This is an apparent violation
(VIO 50-272/93-11-02, 50-311/93-11-02, and 50-354/93-07-02). Although the
licensee identified the apparent violation, it is being cited because of the apparent
regulatory issues identified above. This apparent violation administratively closes
URI 50-272/93-05-02, 50-311/93-05-02, and 50-354/93-05-02.
3.0
Overview of FFD Proeram Activities
During the inspection, the inspector met with key personnel in the FFD program, toured
the collection and testing facilities, and observed various FFD program activities. Based
on interviews and observations, the inspector determined that the licensee continued to
maintain a comprehensive FFD program that was committed to the goals of the NRC's
FFD Rule. Aside from the two apparent problems discussed in Section 2.0 of this
report, other aspects of the FFD program appeared to be well managed.
The licensee continued to maintain an employee assistance program (EAP) to provide
rehabilitation treatment for individuals with alcohol and drug related problems.
In
6
addition, the EAP appeared sensitive to other personnel issues that could impact an
individual's fitness-for-duty.
Since the initial NRC program inspection in March 1990, the licensee made some
personnel changes within the FFD program. Based on interviews with those individuals,
the inspector determined them to be knowledgeable of their duties and responsibilities.
The licensee also continued to maintain an effective auditing program. Audit findings
were reported to appropriate levels of management. However, it was not clear' that
. . management had a full appreciation for audit findings that indicated potential violations
of regulatory requirements or that it was aggressive in pursuing effective corrective
action. Even though the problems discussed in Section 2.0 had been identified in the
semi-annual report of FFD performance data, covering the period January 1 through
June 30, 1992, as programmatic weaknesses, the weaknesses still existed in February
1993.
4.0
Exit Interview
The inspector met with the licensee representatives indicated in Section 1.0 at the
conclusion of the inspection on April 7, 1993. At that time, the purpose and scope of
the inspection were reviewed and the findings were presented.
The licensee
representatives present acknowledged the findings.