IR 05000255/1987021
| ML18052B371 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/02/1987 |
| From: | Bush L, Drouin B, Randy Erickson, Mcpeek E, Pirtle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18052B370 | List: |
| References | |
| 50-255-87-21, NUDOCS 8711160065 | |
| Download: ML18052B371 (14) | |
Text
Report No.:
Docket No.:
Licensee:
Facility Name:
Inspection at:
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION AND REGION III 50-255/87-21 50-255 Consumers Power Company ATTN:
F. W. Buckman License No:
DPR-20 Vice President, Nuclear Operations 1945 West Parnall Road Jackson, Michigan 49201 Palisades Plant Jackson and Benton Harbor, Michigan Inspection Conducted:
August 24-28, 1987
..
Inspection of Fitness for Duty Program Inspectors:
tl/a./rr oren L. Bush, Jr., Chief, Program Development Date
Approved.By:
and Review Section Division of Reactor Inspection and Safeguards, NRR Eugene: McPeek, Security Specialist Program Development and Review Section Division of Reactor Inspection and Safegu~rds, NRR Inspector Bry
. Drou*n, Physical Security Inspector Safeguards Section, Region III RobelltA:Ercson IChiif Safeguards Branch Divisi~n of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation (-. -*9-=7=-1-=-1~1~a-;-o~o~a~5;;;--;B~7~1~14ior-..ao--. -~
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- Inspection Summary Areas Inspected:
Included review of policies, procedures, and practices of the Fitness for Duty (FFD) Program and the Employee Assistant Program (EAP)
applicable to Consumers Power Company (CPCo) employees and contractors; com-parison of the FFD and EAP programs with the program elements ret;ommended in the EE! Guide; and evaluation of supplemental program elements not_specifically addressed in the~EEI Guid Significant observations included: CPC0 1s written policies differ from some of the features contained in the Commission 1s Policy Statement or recommended by the EE! Guid The August 13, 1987 revision deleted the requirement for employees to report the legal use of prescription drugs and over the counter drugs that may affect an employee 1s ability to perform his jo Some of the differences provide management latitude in handling problems on a case by case basi.
Chemical tests of body fluids are used for preemployment screening of CPCo employees, and follow-up testing of CPCo employees previously tested positiv All people employed on site are subject to testing for cause and unannounced periodic test Cut off limits are very high and may not identify 11casual 11 or occasional use of drug A presumptive positive requires a positive result from both of two different screen tests, each with a different high cutoff leve Only confirmed positive test results are provided to CPCo managemen The.above, collectively, indicate that an employee who has abused drugs may be permitted to remain on the job after initial indications that drugs may have been use...
CPCo supervisors have received FFD program training, however, contractor supervisors had not been traine No refresher training has been conducted or is planne CPCo employees were aware of the policy, however, awareness training for contractor employees was somewhat limite No formal audit program has been develope Statistical data are kept, however, except for EAP data, have not been analyze The CPCo EAP program.appears to be gaining effectiveness.
L Key Persons Contacted F. Buckman, Vice President, Nuclear Operations
- K. Berry, Director, Nuclear Licensing
- J. Dorr, Supervisor, Safety and Health
- H. Cooper, Security Administrator
- G. Slade, Executive Director, Nuclear Assurance W. Mills, Djrector, Industrial Relations
- W. Mosher,*Medical Administrator D. Hoffman, Plant General Manager, Palisades D. Smith, Human Resources Director, Palisades D. Malone, Nuclear Licensing Administrator, Palisades
- S. Cote, Property Protection Supervisor, Palisades The inspectors interviewed 6 CPCo supervisors, 15 CPCo nonsupervisory employees, 15 contractor supervisors, and 27 contractor nonsupervisory employees on site, contract counseling staff, and personnel at state and local law enforcement offices and at both testing laboratorie Entrance and Exit Meetings The inspectors met with licensee representatives at CPCo Headquarters on August 24, 1987 to summarize the scope of the inspectio On August 28, 1987, the inspectors met with licensee representatives at CPCo Headquarters, as indicated above by asterisk, to summarize the observations made during the inspectio Approach The inspection team compared the CPCo Fitness for Duty Program to each of the Key Program Elements recommended by the 11 EEI Guide to Effective Drug and Alcohol/Fitness for Duty Policy Development," revised August 1985 (hereinafter referred to as the EEI Guide).
The CPCo program was also compared to mis-cellaneous features contained in the EEI Guid In addition, the team reviewed the CPCo program for elements not specifically addressed in the EEI Guide which could be used to supplement those recommended in the EEI Guide, including proactive measures to detect the presence of drugs on sit The format of the report reflects this approac Implementation of the EEI Guide Following are the inspectors' observations with respect to the implementation of each of the Key Program Elements recommended by the EEI Guid.
Written Policies CPC0 1 s written policy is intended to -be applied to all company and con-tractor employees provided unescorted access to CPCo nuclear facilitie CPCo written policies differ from some of the features characterized in the Commission's Policy Statement or recommended by the EEI Guide, as follows:
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In addition to sale, use, or possession, CPCo policy includes manu-facture and delivery of controlled substances, which reflects Michigan la *Denotes those present at exit briefing
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Policy does not prohibit being under the influence of controlled substance CPCo believes that determining impairment cannot be accomplished at present state of art, therefore their policy focuses on use instead of impairmen For alcohol, the policy requires that employees not evidence any effects of the consumption of alcoho Evidencing any effects 11 stems from the old policy that-:--was based on mere observation of the effects rather than establishing impairment through a tes Immediate revocation of access to vital areas is not describe Policy states an employee found in violation of policy will have unescorted access revoke Practice is to immediately deny unescorted access and suspend the employee pending determination if the policy was violate Discharge is not specified for the sale, use, or possession of illegal drugs while on the job or on company propert Furthermore, discharge is not specified for the illegal sale of narcotics, drugs, or controlled substances when off duty and when off company premise CPC0 1s policy says that those committing such violations will be sub-ject to discharge, except where the sole offense (of the policy) is the presence of alcohol or a controlled substance as shown by periodic testin Such an employee may be subject to more frequent
~esting, and any subsequent violations result in discharg Alcohol is not prohibited by CPCo policy from the protected area or from company property and operation The policy does prohibit employees from transporting or bringing alcoholic beverages onto company property and from possessing alcoholic beverages while on company propert As written, the policy enables management to permit the use of alcohol during authorized function Handling of drug or alcohol use among employees in designated positions is not described; CPCo believes all employees should be treated the same and does not use designated positions, i.e., there should not be different standards for different categories of employee Testing for drugs is not specified when an employee is involved with drugs off duty and off company premises or as a condition for retentio (The EEI Guide recommends that company policy specify testing for those in designated positions in this instance, however, CPCo does not use designated positions.) CPCo policy requires the employee in this instance to participate in a medical evaluation which may include testin *
The August 13, 1987 revision to CPCo policy deleted the requirement for employees to report the legal use of prescription drugs and over the counter,..drugs that may affect an emp 1oyees 1 ability to perform his job.. This action was taken in response to employee objections to reporting such use other than during a drug test.
- Policy does not inform employees:
o that law enforcement officials will be notified whenever suspected illegal drugs are foun Written procedures do provide for such notification o that appropriate measures will be taken to determine the scope of illegal involvement with drugs, e.g., to identify source of the drugs and other employees who may be involve Furthermore, CPCo procedures do not describe determination of safety significance, particularly with respect to prior work.performe In practice, CPCo has evaluated the safety significance of prior work performe CPCo management stated that their program was designed to place more emphasis on periodic testing than on behavioral observatio This was done because CPCo management believes there is a natural reluctance to confront employees and that such a design would prevent disruption of existing supervisory relationships with employee.
Top Management Support The inspectors concluded that top management supports the FFD and EAP programs, although some elements of program oversight have not been performed, such as audits and analysis of dat The majority of those interviewed believe that management supports the program; a few were of the opinion that management had developed the program, particularly the periodic testing feature, only because (as they believe) it was required by the NR One person observed that if FFD really was a CPCo policy it would cover all employees.
.Management enforcement of the policies was reported by those interviewed as being equitable and fai Adequate funds, resources, and facilities appear to be availabl.
Effective Policy Communication The inspectors interviewed several CPCo and contractor employees and determined that although most CPCo employees were generally knowledgeable of the policy, they regarded the program simply as a urine testing progra Contractor employee knowledge was generally limited to the punitive aspects of the progra CPCo communicated its policy with a series of two hour meetings in the Spring of 198 Each employee attended a meeting, received a copy of the written policy which was discussed, and signed a certificate acknowledging receipt of the policy and having read and understood that polic The General Employee Training (GET) program, which is provided to all new CPCo and contractor employees, includes one hour on FF Articles in company sponsored publications such as 11 Progress,
11CP Weekly,
and 11 Hope 11 have*endeavored to inform employees on drugs and alcohol abus Photographs of Employee Assistance Coordinators were posted to inform the
- employees that confidential counseling was available to them in various problem areas, e.g., marital, legal, drugs, etc.
Interviews confirmed that those employed by CPCo at the time the fitness for duty program was implemented had received awareness trainin However, no additional training or meetings have been provided on fitness for dut For other employees, interviews confirmed that after the initial GET, no subsequent 3wareness training had been provide Behavioral Observation Training for Supervisors CPCo is responsible for training CPCo supervisors; CPCo does not require contractors to train their supervisor CPCo supervisors have received behavioral observation training provided by an offsite contractor specializing in Employee Assistance Program The contractor is Occupational Health Centers of America (OHC).
The OHC training program consisted of eight hours of formal instruction with emphasis toward recognizing employee impairmen No refresher training in behavioral observation had been conducted or is currently planned for CPCo supervisor Newly assigned supervisors generally receive the training within 90 to 120 days after appointment to a supervisory positio CPCo supervisors interviewed were knowledgeabie of program policies, objectives, and their responsibilities in relation to the Fitness for Duty Progra Conversely, Behavioral Observation training for contractor supervisory personnel was not provided by CPCo or required by contract specificatio Such training, if provided, was a part of the contractor's own fitness for duty program and varied in scope and dept Most of the contractor supervisors interviewed confirmed that they had not received Behavioral Observation trainin.
Policy Implementation Training for Supervisors Policy implementation training for CPCo and contractor supervisors was essentially the awareness training provided to employees, as described in paragraph 0.3, abov.
Union Briefing Site and local union representatives were interviewed during the inspectio The draft FFD policy was discussed with the Michigan State Utility Workers Counsel (MSUWC) which represents all 22 union locals in labor negotiation matter The FFD policy was not negotiated with the Utility Workers Union of America (UWUA) prior to implementatio UWUA filed an unfair labor practice with the National Labor Relations Board contending that CPCo's failure to negotiate the policy with them was a violation of the National Labor Relations Ac Also, UWUA filed a grievance concerning loss of pay provisions in the policy and sought an injunction from the Federal District Court of Eastern Michigan to stop the implementation o"f the FFD polic As a result of discussions between CPCo management and UWUA, an agreement has been reached and no legal challenges pertaining to the FFD program were pending at.the time of the inspectio *
The labor/management discussion resulted in changes in the FFD program primarily with respect to paid absence for employee's involvement in EAP rehabilitation and actions taken against employees for the first positive chemical tes The existing policy (dated August 13, 1987) and procedure include the agreed change Union representatives have visited the testing laboratories~and the counseling contractor's facilitie.
Contractor-Notification There is standard language that is referenced in every active contract for work performed at CPCo nuclear plants which informs the contractor of its responsibility for compliance with CPCo's Fitness for Duty Progra CPCo relies soley on their FFD progra Contractors are not required to have their own FFD programs or to have their programs, should they have one, reviewed by CPCo as part of the contracting proces.
Law Enforcement Liaison Written agreements established in accordance with security plan requirements have been developed for the Van Buren County Sheriff's Department and the Michigan State Polic Although there is no specific written support agreement related to drug or alcohol abuse, the Property Protection Supervisor has advised township, county, and appropriate federal law enforcement agencies of the company's objectives in regard to alcohol and drug abuse, and requested notification as legally permissible of drug or alcohol offenses involving known plant employee Assistance in the form of substance field testing has been provided by the local township police department upon request by the security sectio Security section written procedures require appropriate law enforcement be notified of illegal substances found on-site. Confirmation of support agreements with the Sheriff's Department and Michigan State Police is required to be completed every six month The Property Protection Supervisor was aware of the substance abuse investigative capabilities of the local law enforcement agencie Interviews with the law enforcement authorities confirmed these understanding Chemical Testing of Body Fluids Every employee and contractor with unescorted access to nuclear facilities operated by CPCo is subject to chemical tests of body fluid Chemical tests are used for preemployment screening of CPCo employees, for those transferring to a job requiring unescorted access, for those absent from work for more than 30 days, and for follow-up testing of CPCo employees previously tested positive. All people employed on-site are subject to testing for cause and unannounced periodic test CPCo policy requires all employees (and contractors) to be subject to testing for alcohol and drugs without advance notice and not less than once during each six-month perio Althoug~ the licensee tries to test all persons granted unescorted access at least once each six-month period, it appears that some, particularly contractors, have not been teste Confirmatory tests are conducted on all presumptive positive screening test The testing for drugs is by.urinalysis; the testing for alcohol is by breat *
CPCo tests contractor employees during unannounced periodic tests, but does not require preemployment (or prebadging) tests by contractors, except for Burns International Security Services, Inc., the security contracto Implementation of the substance testing portion of the program was delayed approximately four months after the program implementation date to assure that supervisors and employee~-:-t1nderstood the substance testing requirements and the actions CPCo would take if test results wer~ positiv a. Collection of Sample During periodic unannounced tests, urine samples are collected on-site in the presence of a nurse from Garcia Clinical Laboratory (GCL) based in Jackson, Michiga The person providing the sample is in a stall, blue dye is placed in the toilet, and the container is hand checked for warmth to corroborate recent voidin CPCo believes these measures will minimize the possibility of a surrogate or tampered sampl During other tests, such as for cause, hospital or physician 1s office personnel are responsible for collecting samples and ensuring the validity of the sampl To address employee concerns that there may be chemical contamination of the plastic container, the container is sterilized and sealed so that the employee must break the sterility seal prior to us Control and Transfer of the Sample The urine sample is collected directly in a plastic container, sealed and initialed by the person providing the sample and then (if collected by GCL) placed in a locked container and transported to GC In the case of samples collected in a hospital or physician 1s office, the sealed containers are mailed in a sealed box to GC GCL performs the initial screening tests. If the screening tests are positive, GCL sends via Federal Express a portion of the sample to Toxicology Laboratory Center, Inc. (TLC) in Lansing, Michigan, for confirmation testin To address employee concerns about possible collusion and tampering with the sample, CPCo has not established an on-site screening laboratory as many other licensees hav For the same reason, CPCo uses a different lab for confirmation test Chain of custody is established at the time the sample is collected and maintained during the testing processe Both laboratories are providing secure storage of samples in a locked freezer for 30 day Testing of the Sample GCL uses an emzyme-multiplied immunoassay test (EMIT) and thin layer chromatology (TLC) for initial screening of urin The sample must exceed the iutoffs established for both the EMIT and TLC to be considered a presumptive positive. --xrlegative on one of the tests means both are negative; no repeat tests of one negative result are performed..
- - TLC performs a repeat of the EMIT test prior to conducting the confirmation tests, which are gas chromatography coupled with mass spectrometry (GC/MS), except for cocaine, THC, and opiates which are tested by mass spectrometry (MS).
If the presence of the substance is confirmed above the established cutoff, the sample is reported as tested positiv TLC uses the same cutoff levels for_alj*of their clients to avoid the confusion and potentials for error caused in other laboratories that use different cutoffs for each clien The inspectors noted that the CPCo cutqff limits significantly varied from that recommended by Duo Research for the National Institute on Drug Abuse (NIDA), the American Counsel for Drug Education, and the Department of Defens CPC0 1s cutoff limits would probably detect heavy users who are addicted to the drugs in question, however, they may not identify 11casual 11 or occasional us The drugs tested and the respective cutoff levels.are:
Cutoff Levels (Nanograms/ml)
Initial Screen Drug Recommended GCL/EMIT GCL7TLC Confirmation THC
. 20 100 25-50
(marijuana)
Cocaine 300 750 1,000
150 500
Opiates 300 500 1,000 100 Methadone 500 500 200 Methaqualone 750 1,000 150 Amphetamine 500 700 500 100 (applicants only)
ReEorting Results Only confirmed positive test results are reported by GCL (TLC reports to GCL) to CPCo managemen There is no prior contact initiated by either laborator Typically, a written report is delivered to CPCo by GCL seven days after the sample was collected. This is not a problem when the employee has been removed from the site as a result of for cause situation However, since the testing program is designed with high cutoff levels in conjunction with the requirement for dual positive screening tests, it would appear possible that an employee wha has abused drugs is permitted to remain on the job several days after the initial screening results of a periodic unannounced test are known to GC ~------
' Employee Comments on Chemical Testing During interviews of CPCo and contractor supervisors and line employees, some comments were made concerning the testing program:
Most supported the program; Mgst believed the FFD program is only a urine testing program;
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A few believed that tests should be more frequent; Several expressed concern about the testing process and safe-guards, indicating a need for more awareness in this area; Some believed there should be less emphasis on testing and more on supervisory responsibilit One also suggested that employees should be involved in detection and confrontation; Several believed some employees obtained prior information of unannounced tests, and avoided the tests by leaving the site or staying at home; and A few believed direct observation of collecting the sample should be require Statistics on Drug Testing The following information pertains to corporate wide data on tests of employees and contractors with unescorted access to CPCo nuclear facilitie In 1986, CPCo conducted a total of 1662 tests, 454 were of applicants with 33 positives (7 percent).
Employees were given 1093 unannounced tests with 11 positives (1 percent).
Contractors were given 115 tests with 2 positives (1.7 percent).
CPCo has conducted 358 preemployment tests from January through July 198 Thirteen of these were positive (4 percent).
During that same period, 969 unannounced tests were conducted on employees (many employees were tested more than once) with 11 positives (1 percent),
and 48 tests of contractors with 3 positives (6 percent).
Nineteen of the positives were for marijuana, 7 for cocaine, 2 for codeine, and one applicant for amphetamine.
Employee Assistance Programs CPCo has contracted with Occupational Health Centers of America, In (OHC) to administer their EAP at Palisades, to advise Palisades management as appropriate, to assist in the training program, and to provide counseling and rererral service OHC 1s office in St. Joseph, MI provides the primary support, however, some employees choose to use the Kalamazoo office because it is closer to their hom The EAP program is limited to CPCo personnel and dependent Contractors are not required to have an EAP; however, if contractor or employees need assistance it is available
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at their own expens An interest in the availability of an EAP was expressed by contractor personnel interviewed by the inspector A typical clinical interview takes about one hou If the employee appears unstable, psychiatric evaluation is sough If the evaluation concludes that the employee is unstable, immediate action ts _taken to provide inpatient treatment (outpatient treatment is provided where appropriate).
Even though the confidentiality usually provided self-referfals has not been breached to date, OHC stated they would inform CPCo management if an employee was determined to be unfit for duty and constituted a safety concer CPCo management has not informed their*
employees, preferrably in the policy statement, of this practic EAP program performance data indicates that OHC counseled 17 persons from March 1986 (start of the OHC service) to the end of 1986 and 24 in 1987 through the end of Jun The increase in self-referrals (88 percent of those referred to the EAP) reflect the usual maturity of a program and the gaining of acceptance by employee It would appear that the EAP goal of early intervention will be achieved more frequently in the futur The primary problem most frequently identified was family/marital, followed by emotional stres Drugs were involved in eight of the cases; alcohol in three of the case Only 3 of the total 41 cases required inpatient treatmen The inspectors noted that five of the referrals were through management action, including behavioral observatio Although most of the CPCo employees interviewed were aware of the EAP program, they were not aware of how the program functioned or the services provide Many believed that the EAP could be better publicize To foster utilization of the EAP, CPCo has established a system whereby volunteer employees are appointed as Employee Assistance Coordinators (EACs).
CPCo hopes that a troubled employee will be more willing to make initial contact with a fellow employee, especially if known personall Data on contacts and referrals through this system show that company wide, 100 employees contacted the EACs during the second quarter of 1987; all have been referred to EAP counselin This was a 45 percent increase in contacts over the previous quarter, and is attributed by CPCo management to their efforts to train the EACs and acceptance of the EAC program by the employee Miscellaneous EEI Guide Features Following are the inspector 1s observations with respect to miscellaneous features of the EEI Guid.
Substance Abuse Committee 2.
A Substance Abuse Committee has not been established, nor do key people fulfill committee functions on an ad hoc basi Periodic Audits No audit of the FFD program has been performe CPCo has not determined who should conduct the audits subsequent to the August 1987 revision to the polic.
Records and Reports Program records are kept, however, except for EAP data, have not been analyze Only analysis of the EAP has been reported to managemen No adjustments to the program have resulted from systematic a~a!}'sis of dat Supplemental Program Elements - Not in EEI Guide The NRC Policy Statement and EEI Guide describe a general approach to the design of fitness for duty program It is expected that each of the program elements contained in the EEI Guide will be addressed in licensee program In order to gain information on the use and effectiveness of additional practices which might be used by industry in developing an overall program, the inspectors also reviewed selected areas not included in the guidanc It is emphasized that the following description of areas reviewed is not an indication that such program elements are or may become requirement.
Written Procedures Written procedures are intended to implement the policy, define actions to be taken in certain situations, and assign responsibilities to ensure proper accomplishment of the action Procedures would also reduce the likelihood that the actions would be mishandle Written procedures have been developed to cover the most appropriate situation.
Professional Counseling Services Professional counseling services are intended to manage and carry out the EAP program, and provide initial diagnosis of the problem and referral to the proper professional car This would be particularly important in the diagnosis and treatment of substance abuse and emotional instabilit Professional counseling services ~re available off-site through Occupational Centers of America, Inc. (OHC). Employment Screening Practices Employment screening practices are intended to assure that employees are reliable and trustworthy and to eliminate from consideration those known to be unreliable, i.e., a drug abuser without evidence of rehabilitatio The practices would include background investigations, psychological tests, interviews, and periodic rescreenin With minor exceptions, preemployment screening practices appear to be consistent with the proposed industry guidelines for an access authorization progra.
Legal Reviews Legal reviews would assure that company policies and procedures, con-tracts, and union agreements meet constitutional and legal requirements with respect to fitness for dut Attorneys were involved in the development of the program and have reviewed it to ensure legal sufficienc The standard clause inserted into all contracts relating to Fitness for Duty commitments have also had legal revie.
Proactive Measures to Detect the Presence of Drugs On-Site
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These measures are intended to provide evidence of on-site drug problems before they would be manifested in observable aberrant behavio These measures could also provide a deterrent to on-site drug abus Chemical Testing of Body Fluids Chemical testing of body fluids is a powerful tool for the detection and prevention of drug abus CPC0 1s unannounced periodic chemical tests appear to provide a deterrent to drug abuse as stated by many of those interviewe See paragraph D.9, above, for a detailed dis-cussion of CPC0 1s chemical testing progra Searches Searches can be an effective means of discovering any alcohol or other drugs that may have been introduced into the workplace and can be an effective deterren Searches of the workplace, including the use of drug detector dogs, are not conducte CPCo staff reported that a physical search of the workplace was conducted several years ago, and that they were less than satisfied with the result Investigations Investigations are used to determine the facts associated with illegal involvement with drugs, and are an appropriate response to allegations and other investigative lead Investigations are also useful in determining whether there is an existing or potential proble In accordance with CPCo practice, no proactive or covert/undercover investigations are conducted at nuclear facilities, although a covert investigation was conducted at a construction sit Investigations are limited to the circumstances surrounding allegations of the use of drugs by employee CPCo site security staff would initiate on-site investigations, with corporate security staff taking the lead for more complex investigation Mechanism for Discreet Expression of Concerns A mechanism.~for discreet expressions of concern can facilitate unrestricted flow of information from those who, for many reasons, may be reluctant to provide important information to managemen There is a confidential reporting system, (special phone line)
established for persons who want to report their concerns about use of controlled substances or alcoholic beverage Interviews with
L CPCo and contractor employees suggested that they were not generally aware of the purpose and existence of the telephone hot lin Information from Law Enforcement Authorities Law enforcement authorities may provide useful information concerning drug activity in the local community, especially employee involvemen Law enforcement authorities provide information within legal bounds concerning off-site drug activity that may ultimately affect per-formance on the job, but only if they are aware of any employment connection with CPC See paragraph F.5.c, abov The Supervisor, Plant Protection, reviews court proceedings from community newspapers in the areas surrounding the plant where the majority of employees resid The review of court proceedings provides information concerning fitness for duty related violations committed by employee