ML20126A955
| ML20126A955 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 12/15/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9212210313 | |
| Download: ML20126A955 (3) | |
Text
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Commonw:alth Edison 1400 opus Place X'
'v' Downers Grove, Illinois 60515 December 15,1992-U.S. Nuclear Regulatory Commission Washington, DC 00555 Attention:
Document Control Desk
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50-254/92006; 50-265/92006 NRC Docket Nos. 50-254 and 50-265
References:
a.
L.R. Gre er letter to Cordell Reed dated April 8,1992 transmitt NRC Inspection Report 50-254/92006; 50-265/92 06 I
b.
T.J. Kovach letter to USNRC dated June 12,1992 L
c.
C.E. Norelius letter to C. Reed dated October 12,1992 Reference (a) transmitted a Notice of Violation (NOV) associated with Commonwealth Edison's (C staff to reconsider theCECO) For-Cause Tes By reference (b), CECO requested the NR aroposed NOV. Upon reconsideration, NRC determined the violation to as valid and requested a written response. Enclosed is our response to the NOV.
If your staff has any questions or comments concerning this transmittal, please refer them to Jim Watson, Compliance Engineer at (708) 515-7205.
Sincerely,
$.kb T.J. Kovach Nuclear Licensing Manager
-Attachments cc:
A.B. Davis, Regional Administrator - Region lli C. Patel, Project Manager, NRR T. Taylor, Senior Resident inspector 210081 h
9212210313 921215 PDR ADOCK 050oo234 i
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t Response to Notice of Violation NRC Inspection Report 50-254/92006;50-265/92006 VJolation 25.4sLi5)l9200E-91 During an NRC inspection conducted between February 10 and March 17,1992, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below:
10 CFR 26.24(a)(3) requires, in past, testing for cause should be init!ated as soon as por ible following an observed behavior indicating possible suLstance abuse or after receiving crdble information that an individual is abusing elcohol.
Contrary to the above, on January 23,1992, a for-cause test was not conducted on a contractor em 31oyee after the odor of alcohol was detected and confirmed on the worker by six ndividuals.
This is a Severity Level IV Violation (Supplement Vil).
REAS.ON FOR VIOLATION CECO acknowledges the violation.
In regard to the incident at Quad Cities, once informed by Station Security of the report of the odor of elcohol on the contractor, the contractor supervisor spent about 30 minutes interviewing the employe. During this behavioral observation, no staggering, speech impairment or abnormal actions were noted which would have indicated a need to conduct a For-Cause Test. Additionally, the Security Sergeant who observed the contractor changing out of RWP clothing, conducting a radiation frisk and dressing, stated the contractor did not appear impaired. Based on this behavioral observation, a decision was made by the contractor supervisor that no impairment was evident and it was determined the contractor in question was fit for duty. The contractor supervisor's actions were in accordance with the guidance provided in CNSG No. 207. The determinat%n of Fitness For Duty was made in accordance with both CECO and the contractor firm's policies and training.
COBBERTIVELSIEES_TAKEN AND RES11LIS ACHIEVED During the time period this violation was being reconsidered by NRR, Commonwealth Edison was requested to inform Region ill of any occurrence when the detection of the odor of alcohol on a licensed operator or a supervisor did not result in a for-cause test.
This request was communicated to all CECO nuclear stations on April 28,1992. There were no occurrences required to be reported to the Region during this time period.
This instruction remains in effect at this time.
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2 COBBECIIME_SIEPS_T11ATEILLBE TAKEN TO AVOlD FURTHER VIOLATIONS 1.
Concurrent with submittal of this response, interim instruction will be provided to all CECO Nuclear Station Managers that the detection of alcohol confirmed by a supervisor is " Probable Cause" and will result in a For-Cause drug und alcohol test.
2.
Each contracting firm with a Commonwealth Edison approved Fitness for Duty Program will be notified of the revised requirement to conduct a for-cause test upon supervisory confirmation of the detection of the odor of alcohol on a contractor employe.
3.
Corporate Nuclear Security Guideline No. 207 - Testing For-Cause will be revised to reflect that supervisory confirmation of the odor of alcohol alone, without further observed Impairment or degradation in performance, will result in a for-cause drug and alcohol test.
l DATE_WH E N_EU LLCOM ELIANC E_WJ Lk B EACHIEVED Full compliance will be achiend prior to the end of the first quarter of 1993, subsequent to notification of nuclear station and contr' actor manegement of the revised requirements and subsequent to the revision, publication, on-site review and implementation of CNSG No. 207.
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