IR 05000454/1993015

Insp Repts 50-454/93-15 & 50-455/93-15 on 930928-30.No Violations Noted.Major Areas Inspected:Ffd Program,Policies, Procedures,Ffd Organization & Mgt Control,Training,Chemical Testing Program & FFD Audit Program

ML20058P408
Person / Time
Site:	Byron
Issue date:	10/15/1993
From:	Belanger J, Creed J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058P391	List: IR 05000454/1993015 ML20058P388
References
50-454-93-15, 50-455-93-15, NUDOCS 9310250028
Download: ML20058P408 (6)

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h U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-454-93015(DRSS); 50-455/93015(DRSS)

Dockets No. 50-454; 50-455 Licenses No. NPF-36; NPF-66

Licensee: Commonwealth Edison Company-i Opus West III

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1400 Opus P1 ace

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Downers Grove, IL 60515 Inspection At: Corporate Offices, Downers Grove, IL

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Corporate Offices, Chicago, IL Byron Station Facility Name: Byron Nuclear Power Station, Units 1 and 2 Inspection Dates:

September 28-30, 1993 Type of Inspection: Routine, Announced Fitness For Duty Date of Previous Fitness For Duty Inspection: January 22-25, 1991 (Initial)

Inspector:

Gnu b

/dbb spes L. Belanger Date

$ehior Physical Security Inspector Approved By:

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g/JapesR. Creed, Chief Date a'feguards Section-i

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Inspection Summary

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Inspection on September 28-30. 1993 (Reports No. 50-454/93015 (DRSS): 50-455/93015(DRSS))

Areas Inspected:

Routine, announced inspection of the licensee's Fitness-for-Duty (FFD) program required by 10 CFR Part 26. This review was conducted in

accordance with Inspection Procedure 81502.

Specifically, the inspection

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addressed significant changes in the areas of FFD Program, Policies, and Procedures; FFD Organization and Management Control, Training; Chemical

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Testing Program; and FFD Audit Program.

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Results: No violations of NRC requirements were identified.

Two significant l

program strengths were identified:

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The extensive experience of the Medical Review Officer in the area

e of substance abuse treatment.

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9310250028 931015 PDR ADDCK 05000454 l

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A comprehensive, effective fitness-for-duty training program.

• The fitness for duty program has continued to receive strong corporate senior management support.

Permanent testing and collection facilities were established at the Downers Grove Corporate offices and the Byron site. These facilities have improved the efficiency, professionalism, and privacy aspects of the collection and testing process.

The effectiveness of the administration of the MRO and FFD training elements of the program was significantly enhanced by two new staff positions: the MRO Administrator and the FFD/ DOT Training Coordinator.

One program weaknesses was identified:

A program to test the intrusion detection system of the Byron

station collection / testing facility was not established.

The quality verification and Employee Assistance Program (EAP) components of

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the FFD program were determined to be effective.

Quality verification audit reports indicated that thorough, comprehensive reviews of the FFD program were

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conducted.

In 1992 EAP referrals to treatment for substance abuse and self-help groups declined but referrals for counseling and other forms of help

rose.

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A significant procedural change pertaining to testing for cause when the odor of alcohol is detected was required as a result of a violation identified at

the Quad Cities Station. This change was incorporated also into the training program.

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DETAILS 1.

Key Persons Contacted In addition to the key members of the licensee's staff listed below, the inspector interviewed other licensee employees and members _of the FFD organization.

The asterisk (*) denotes those present'at the Exit Interview conducted at the Downers Grove corporate' offices on September 30, 1993.

• G. Toleski, FFD Program Administrator P. Laird, Director Corporate Security E. Zittle, Station Security' Administrator, Byron Station

• P. Welsh, Assistant FFD Program Administrator G. Mouzon, Medical Review Officer M. Whitmore, Assistant Security Administrator, Byron Station D. LaBelle, Coordinator, EAP Services

• B. Saunders, Nuclear Security Operations D. Ringo, Senior Nuclear Security Specialist B. Pierson, Nuclear Security specialist R. Khan, FFD/ DOT Training. Coordinator N. Gannon, MR0 Administrative Assistant 2.

Entrance and Exit Interviews a.

At the beginning of the inspection, Mr. G. Toleski, FFD Program Administrator, was informed of the purpose of this inspection, its scope and the topical areas to be examined.

b.

The inspector met with the licensee representatives denoted in Section 1 at the conclusion of inspection activities. A general description of the scope and conduct of the inspection was provided.

Briefly listed below are the findings discussed during the exit interview. The details of each. finding are referenced, as noted, in the report.

(1)

Personnel were advised that no violations of NRC requirements were identified.

(2)

Program strengths were noted regarding the experience and qualifications of the Medical Review Officer, and the -

quality of the FFD training program' (refer to Sections 3.b and 3.c respectively, for details).

(3)

A program weakness was noted regarding the absence of a.

testing program for the intrusion detection system protecting the site collection facility (refer to Section 3.d for details).

(4)

The inspector commented favorably on'the upgrade to the collection / testing facilities at both the Downers Grove

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corporate office and at the Byron Station locations.

The inspector also acknowledged the effectiveness of the licensee's quality verification and Employee Assistance programs as they relate to fitness for duty.

3.

Fitness For Duty Proaram (IP 81502)

The objective of this inspection was to determine what changes'have been

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made to the licensee's fitness for duty inspection since the initial program review conducted January 22-25, 1991 under Temporary Instruction 2515/106 and to determine whether these changes (a) meet commitments to resolve previously id2ntified issues or NRC requirements, and (b) did not adversely affect the overall operation of the licensee's FFD Program.

Two significant program strengths and a program weakness were identified as a result of this review. Additionally, several positive

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observations regarding the program were noted.

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a.

FFD Procram. Policies and Procedures

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A significant change to the licensee's for cause testing

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procedures was made as a result of a Severity Level IV violation at Quad Cities Station, involving the failure to conduct a For-

Cause drug and alcohol test when the odor of alcohol was detected.

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Inspection showed that FFD training program lesson plans and l

Corporate Guideline 207:

Testing For-Cause, were revised to state that when the odor of alcohol has been detected on an individual

and a supervisor has confirmed the odor of alcohol, a for-cause j

test for dugs and alcohol will be conducted and that no medical

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cpinion is required. An interview with the Byron FFD coordinator

confirmed that this individual was aware of this procedural t

change.

f A second significant change to the program was the added

responsibility in 1991 of administering a separate FFD testing l

program to meet the Department of Transportation regulations.

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(Vehicle operators at the Byron and Braidwood stations that drive

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vehicles in excess of 26,000 pounds must meet DOT FFD

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requirements.

Less than 50 individuals at both sites are

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affected.)

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FFD Oraanization and Manaaement Control

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The MRO's que'ifications and experience were identified as a

program strength. The current MRO began her duties in December

1991.

She is a licensed physician with extensive knowledge Hof

substance abuse disorders.

She is currently a medical director of

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an area drug treatment facility, and has been a certified i

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addictionist since 1987.

Her qualifications and experience help to assure the integrity of the testing process in terms of interpreting and reporting test results.

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Two new full time staff positions were established in the FFD organization, specifically that of MRO Administrative Assistant and the FFD/ DOT Training Coordinator.

These positions increased the effectiveness of the FFD organization by reducing the administrative workload of the MRO and increasing the effectiveness of the FFD training program (see subparagraph c).

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Trainina The licensee's new video FFD training program was identified as a program strength. The inspector reviewed the training lesson plans and viewed selected portions of the video tape presentations. The inspector concluded that they were of excellent professional quality, and based on written post-training critiques by employees, the training program was effective in communicating, in depth, the licensee's FFD policies. The apparent success of the current program was attributed by the inspector to the dedication and professionalism of the FFD/ DOT Training Coordinator, d.

Chemical Testina Proaram A security related issue pertaining to the new collection / testing facility at Byron Station was identified.

The licensee established new, well-equipped and well administered collection and testing facilities at the corporate offices in Downers Grove, Il and at Byron Station subsequent to the initial NRC inspection. These facilities provided a professional and orderly environment for the collection of specimens.

During an j

observation of the collection process at Byron Station on l

September 29, 1993, the inspector noted that program personnel

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followed the required procedures carefully and professionally.

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The licensee had sufficient security measures to control access to

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the testing facilities to ensure that no unauthorized personnel handle specimens or gain access to areas where records and split j

samples are stored. Access to these secured areas was limited to j

specifically authorized individuals.

i The security measures at the Byron Station permanent testing facility included an alarm system; however, discussions with the

licensee's FFD coordinator disclosed that there was no program to

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regularly test the system. This deficiency was considered a

.I program weakness. The licensee acknowledged the weakness.

The licensee indicated that they intend to test the alarm system on an interim basis and will develop and implement a permanent procedure

by October 29, 1993.

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FFD Audit Proaram i

i The inspector examined the licensee's audit reports of the FFD

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program, since the initial inspection, and determined that the l

focus of the Quality Verification-(QV) audits was the

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effectiveness of the. program. The results of these audits were i

documented and reported to senior corporate and' site management.

i The QV audit program appeared to be effective identifying

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weakness.

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