ML17262A423

Responds to NRC 910325 Ltr Re Violations in Insp Rept 50-244/91-04 Re Specimen Collection Procedures.Fitness for Duty Program Procedures Implemented as Controlled Document & Distributed to Key Personnel

ML17262A423
Person / Time
Site:	Ginna
Issue date:	03/26/1991
From:	MECREDY R C ROCHESTER GAS & ELECTRIC CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9103290193
Download: ML17262A423 (6)

See also: IR 05000244/1991004

Text

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i'raI;,'I jiI PI 4J'iki7i, ROCHESTER GAS AND ELECTRIC CORPORATION

r Toe%ttate~89 EAST AVENUE, ROCHESTER N.Y.14649.0001

ROBERT C MECREDY Vice Pretident Cinna Nuclear Production

TELEPHONE AREA CODE 7t6 546'2700 March 26, 1991 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Subject: Reply to a Notice of Violation NRC Inspection

Report No.50-244/91-04

R.E.Ginna Nuclear Power Plant NRC Docket No.50-244 Dear Sir: This letter is in response to the February 25, 1991 letter from James H.Joyner, Chief, Facilities

Radiological

Safety and Safeguards

Branch, to Robert C.Mecredy, Vice President, Ginna Nuclear Production.

This letter provides the reply to the Notice of Violation, pursuant to 10 CFR Part 26, as well as, infrequent

unescorted

site access (UNR 50-244/91-

04-01).RE TATEMENT F VI LATI N's a result of the inspection

conducted on January 23-25, 1991, and in accordance

with the"General Statement of Policy and Procedure for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C (Enforcement

Policy 1990), the following violation was identified:

Appendix A, Subpart B, Paragraph 2.4,"Specimen Collection

Procedures," Subparagraph (g)(24)states that the collection

site person shall enter in the permanent record book all information

identifying

the specimens.

The collection

site person shall sign the permanent record book next to the identifying

information.

Appendix A, Subpart A, Paragraph 1.2, DeGnitions, of 10 CFR Part 26 de6nes the"Permanent

Record Book" as a permanently

bound book in which identifying

data on each specimen collected at a collection

site are permanently

recorded in the sequence of collection.

Contrary to the above, on January 24, 1991, the inspector determined

that the licensee's

collection

site staff was not maintaining, in the Permanent Record Book, identifying

data on each specimen collected at the collection

site, in the sequence of collection.

Only contractor

personnel specimen collections

were being entered in a record book;licensee personnel specimen collections

were being maintained

in a computer based records system.This is a Severity Level IV Violation.(Supplement

VII)REPLY T THE VI LATI N 1.Th R nfr h Vil in Rochester Gas and Electric Corporation (RG&E)concurs that the stated violation occurred.Since.developing

the FFD program, a computerized

system for tracking each individual

tested, including contractor

employees, has been maintained.

This computer program could, if necessary, print a list in chronological

order.We also retained a copy of each chain-of-custody

form to use as a record signed by the employee being tested, which listed all information

identifying

the specimens.

We believed that the combination

of the computerized

tracking system and a copy of the chain-of-custody

form would adequately

serve as a permanent record.2.Th rr iv Th Hv B k n Th R'Ahiv RG&E purchased three (3)permanently

bound books, one for each collection

site.The Site Collection

Officer enters the identifying

information

of the individual

tested and specimen collected and the individual

signs his/her name.'esults of this action assure that a permanent record book is in place at each collection

site to account for all employees, including contractor

employees, of the tests performed and specimens collected with identifying

information.

3.1v WillB TknT Avi F hrVi 1 i n On March 1, 1991, the RG&E Fitness For Duty Program Procedures

were implemented

as a controlled

document and distributed

to key personnel.

The process for utilizing the permanent record book is included in procedure number FFD-9 titled,"Collection

Process and Chain of Custody."

Th D WhnF11 m lin WillB iv FuH compliance

with 10 CFR Part 26, Appendix A, Subpart B, Paragraph 2.4,"Specimen Collection

Procedures," Subparagraph (g)(24)was achieved on January 24, 1991.On that date, the permanent record book was purchased and the process for entering the required information

was activated.

244 1--TE TIN FEMP YEE WITH INFRE NT ITEA E All employees who have infrequent

access to the site are covered by the Company's Fitness For Duty testing program and must adhere to all provisions

of the corporate Drug and Alcohol Abuse Policy.Therefore, we do not believe any additional

policies or procedures

are necessary.

However, RG&E has developed an interim practice for testing of non-RG&E personnel with infrequent

site access.We are currently using this interim practice for a trial period to assist us in determining

the best method for reaching these individuals.

Based on the results of the interim practice during this trial period, an approved procedure will be implemented

and included in the RG&E Fitness For Duty Program.Very truly yours, Robert C.Mecredy~IC Mr.Thomas T.Martin Regional Administrator

Region 1 475 Allendale Road King of Prussia, PA 19406 Mr.Thomas Moslak USNRC Senior Resident Inspector Ginna Station 1503 Lake Road Ontario, NY 14519

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