IR 05000277/1987006

Fitness for Duty Program Insp Repts 50-277/87-06 & 50-278/87-06 on 870202-06.Observations Noted:Util Written Policies Do Not Address Features of Commission Policy Statement or EEI Guide & No Overall Audit Performed

ML20213G774
Person / Time
Site:	Peach Bottom
Issue date:	03/23/1987
From:	Bailey R, Bush L, Liza Cunningham, Keimig R, Rosano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
References
50-277-87-06, 50-277-87-6, 50-278-87-06, 50-278-87-6, NUDOCS 8705180442
Download: ML20213G774 (14)

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U.S. NUCLEAR REGULATORY COMISSION 0FFICE OF INSPECTION AND ENFORCEMENT AND REGION I Report Nos.: 50-277/87-06 and 50-278/87-06 Docket Nos.: 50-277 and 50-278 License Nos.: DPR-44 and DPR-56 Licensee: Philadelphia Electric Company ATTN: Mr. Joseph W. Gallagher Vice President, Nuclear Operations 2301 Market Street Philadelphia, Pennsylvania 19101 Facility ikme: Peach Bottom Atomic Power Station Inspection at: Philadelphia, Delta, and Willow Grove, Pennsylvania

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Inspection Conducted: February 2-6, 1987 i Type of Inspectio : Ann n'ced Special Inspection of Fitness for Duty Program ' Inspectors: gen L. Bush, Jr., Senior Security Specialist

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g Richard P. Rosano, Security Specialist i 3kdh? Date DivisionopesFe ion Progyanrs] ,

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         .F/7-87 Date f ) Safe a s Sectio,n, I Roland J. Baile

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Operating Reactor Programs Branch ' Division of Inspection Programs Office of Inspection and Enforcement

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8705180442 870323 PDR G ADOCK 05000277, PDRe8

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cc w/ enclosure: Mr. Eugene J. Bradley Mr. R. A. Heiss, Coordinator Assistant General Counsel Pennsylvania State Clearinghouse Philadelphia Electric Company Governor's Office of State Planning 2301 Market Street and Development Philadelphia, Pennsylvania 19101 Post Office Box 1323 Harrisburg, Pennsylvania 17120 Troy B. Conner, Jr. , Esquire 1747 Pennsylvania Avenue, Mr. Thomas M. Gerusky, Director Washington, D.C. 20006 Bureau of Radiation Protection Pennsylvania Department of Thomas A. Deming, Esquire Environmental Resources Assistant Attorney General Post Office Box 2063 Department of Natural Resources Harrisburg, Pennsylvania 17120 Annapolis, Maryland 21401 Mr. Albert R. Steel, Chairman Mr. R. Fleishmann, II, Manager Board of Supervisors Peach Bottom Atomic Power Station Peach Bottom Township R. D. #1 R. D. #1 Delta, Pennsylvania 17314 Delta, Pennsylvania 17314 Mr. G. M. Leitch, Manager Mr. Edward G. Bauer, J Nuclear Generation Department Vice President and General Counsel South 7-1 Philadelphia Electric Company Philadelphia Electric Company 2301 Market Street 2301 Market Street Philadelphia, Pennsylvania 19101 Philadelphia, Pennsylvania 19101 Mr. Anthony J. Pietrofitta, General Manager Power Production Engineering Atlantic Electric Post Office Box 1500 1199 Black Horse Pike Pleasantville, New Jersey 08232 William N. Alden Engineer-in-charge ~ Licensing Section South 7-1 Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station Post Office Box 399 Delta, Pennsylvania 17314 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406

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, Inspection Summan Areas Inspected: Included review of policies, procedures, and practices of the Fitness for Duty (FFD) Program and the Employee Assistance Progran: (EAP)

applicable to Philadelphia Electric Company (PECo) employees and contractors; comparison of the FFD and EAP programs with the program elements recommended in the EEI Guide; and evaluation of supplemental program elements not specifically addressed in the EEI Guid Significant observations included: PEco's written policies do not address some of the features contained in the Cammission's Policy Statement or recommended by the EEI Guid Most of these observations relate to sanctions not being described or being less stringent than recommende . Employee and supervisory training needs improvement. For example, six of seventeen shift supervisors have not been trained, employee awareness was somewhat limited despite recent measures to inform employees, training with respect to the hazards associated with alcohol and drug abuse has not been provided to all employees, and contractor personnel, with few exceptions, have not received trainin . Chemical testing of body fluids is used for preemployment, for cause, and followup testing of PECo employees in the EAP. Currently, PECo testing does not include contractors. Random or periodic tests are not conducte Additionally: Retention on the job after violations of the policies is based upon a medical evaluation and performance factors, and may not always include chemical testing, PECo's cutoff limits for some drugs vary significantly from that recommended by several organizations including PECo's testing laborator Collected urine samples are not protected as forensic evidenc . There is no designated manager responsible for the FFD program either at Corporate headquarters or at the sit . Statistical data are not routinely assembled, analyzed, and reported to managemen . No overall audit has been done of the progra . Contractors are not formally notified of need to abide by PECo's policies on alcohol and drug . The PECo EAP program appears to be effectiv . . Key Persons Contacted i Corporate Headquarters .. J. W. Gallagher, Vice President, Nuclear Operations A. J. Weigand, Vice President, Electric Production S. J. Kowalski, Vice President, Engineering and Research J.-McGinley, Manager,-Personnel and Industrial Relations W. F. Hushion, M.D., Medical Director G. M. Leitch, Manager, Nuclear Generation Department J. D. McGoldrick, Manager, Claims Security Division C. H. Rush, Manager, Engineering and Research M. J. Cooney, Manager, Wuclear Support Division R. H. Logue, Assistant to Manager, Nuclear Support Division J. C. Kienlen, Senior Medical Assistant /EAP E. J. Bradley, Associate General Counsel J. M. Lange, President, IGA

*M. H. Ewer, Superintendent, Training, Fossil-Hydro
* J. Deneen, Director, Security
* J. Weindorfer, Director, Nuclear Security Peach Bottom
**D. Smith, Superintendent - Operations
**J. C. Oddo, Chief, Security Coordinator
**S. Tharpe, Nuclear Security Specialist
**W. Syska, Physician's Assistant, Peach Bottom Station
**T. Johnson, NRC Senior Resident Inspector Several other supervisory and nonsupervisory personnel were interviewed, including contractors on site and personnel at the testing laborator Entrance and Exit Meetings The inspectors met with the licensee representatives, as indicated above, at PECo Headquarters on February 2 and 6, 1987 to summarize the scope of the inspection and the inspection observation Approach The inspection team ccmpared the PEco Fitness for Duty Program to each of the Key Program Elements recommended by the "EEI Guide to Effective Drug and Alcohol / Fitness for Duty Policy Development," revised August 1985 (hereinafter referred to as the EEI Guide). The PECo program was also compared to miscellaneous features contained in the EEI Guide. In addition, the team reviewed the PECo 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 site. The format of the report reflects this approac * Denotes those who attended the exit meeting onl ** Denotes those not present at entrance or exit meeting . .
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4 Implementation of the EEI Guide s Following are the inspectors' observations with respect to the implementation of each of the Key Program Elements recommended by the EEI Guid . Written Policy PECo staff reported that they undertook a major project in the Fall of 1986 to revise and upgrade their company wide policy to meet the EEI Guide. An October 10, 1986 bulletin announcing the revised policies was distributed in booklet form on December 19, 1986. The Nuclear Plant Rules, which are applicable to the nuclear sites and summarize the company wide policies on alcohol and drugs, were revised on January 7, 198 PECo written policies and rules do not address some of the features characterized in the Commission's Policy Statement or recommended by the EEI Guide, as follows:

- Discharge is not required for the illegal sale of narcotics, drugs, or controlled substances when off duty and when off company premise Sanctions for any off-duty and off-company premises involvement with illegal drugs are not specifie If such involvement results in on-the-job impairment, PECo's policy states that immediate suspension may resul Sanctions for the abuse of legal drugs within the protected area are not describe Although both the PECo policy and plant rules prohibit use of alcoholic beverages on the job and on Company property, neither prohibits sal Only the plant rules prohibit possession of alcoholic beverages on station property, except that unopened containers are permitted in vehicles in the parking lot at Peach Bottom.

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- Violations of PEco's policies result in possible recommendation for termination; the EEI Guidelines recommend that on duty or onsite violations will result in discharge (i.e., termination); the Commission's Policy Statement expects that violations of policy concerning illegal drugs on site will result in discharge from nuclear plant duties. In practice, violation of policies on use, sale or possession of illegal drugs or use of alcoholic beverages on the job or on company property do result in discharge from nuclear plant duties. However, in the event l of impairment caused by off-site use of alcohol or drugs, management i retains the prerogative, based upon medical evaluation (not necessarily

! including a chemical test) and performance factors, to determine whether retention or termination is appropriat Immediate revocation of access to Vital Areas is not addressed, nor is immediate removal from a designated position. PECo management believes that these matters are addressed in that the policy states that violations shall result in immediate suspensio . -

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 - Employees in designated positions who are involved with illegal drugs off duty and off company premises are not required to be immediately removed from their job assignment and tested for the presence of illegal drugs. PECo's policy says such employees shall not be permitted to work and shall be immediately referred to the Medical Departmen Rehabilitation is not mandated prior to reinstatement, nor is retention in the designated position contingent on passing tests to verify abstention although this appears to be done in practic Policy does not inform employees that appropriate measures will be taken to determine the scope of the problem, which is interpreted to include an investigation to determine the source of the drugs and coworkers who may be involve . Top Management Support The inspectors concluded that top management is supporting the FFD and EAP programs. However, it was noted that a Substance Abuse Committee has not been established, there is no program manager designated at either Corporate Headquarters or at the site, and supervisory responsibilities are not assigned in writin Management enforcement of the policies was reported as being equitable and fair by those employees who were interviewed. Although PEco's policies specify immediate suspension for violations, the inspectors learned during interviews that exercise of that sanction does not occur in all cases, primarily because first line supervisors have handled problems outside the policie . Effective Policy Communication During the entrance briefing, PECo management reported that their Employee Awareness Training had been weak and that they had taken measures to correct that problem. As a result of interviews of many licensee and contractor employees, the inspectors confirmed that there had been recent efforts

, to improve employee awareness of fitness for duty. However, it appears that additional efforts should be taken, particularly with respect to contractor PECo employees reported that the policy booklet that was provided them recently and related discussions did much to heighten awareness of PECo's policies on alcohol and drug abuse, however, their awareness of FFD was based primarily on those recent activities. During Site Orientation i Training, PEco employees are given copies of the policy bulletins, and i the Nuclear Plant Rules pertaining to alcohol and drugs are read to them.

, FFD policies are not included in the General Employee (refresher) Trainin ! A summary of the plant rules is given to all persons entering the site j and can be read as each individual desire ! l l Contractor line employees interviewed had not received any training and 1 were generally unfamiliar with PECo's FFD program. Most had heard ( discussions of PECo's policy directives during the past few weeks. Many -

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were familiar with the contractor's work rules pertaining to alcohol and

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drugs which were more restrictive than PEco's policie All believed that a the FFD program should be better publicize All licensee and contractor employees indicated that training in the hazards associated with alcohol and drug abuse would be of great benefi National Medical Services, Inc. (PECo's chemical testing laboratory) informed the inspectors that they can provide such training for their client Articles in company sponsored publications, such as " Current News" and special reports, have endeavored to inform employees of PEco's policies on alcohol and drugs. Employees stated that posters on drug abuse are seen from time to time, although none were evident during the inspectio PECo staff reported that bumper stickers and other approaches are used to communicate the programs and policies. However, no signs are posted at the site entrance warning that alcoholic beverages and drugs are prohibited from company work locations and that individuals under the influence can be denied acces . Behavioral Observation Training of Supervisors PECo is responsible for training both PEco and contractor supervisor Most of the PEco supervisors interviewed had been trained and appeared to be knowledgeable of the program. Only one of the contractor supervisors interviewed had been trained or briefed concerning the program (Catalytic's Site Program Manager). The majority of PECo and contractor supervisors interviewed, as with the line employees, believed that more and better training was needed. Many believed guidance was needed in several areas, particularly, how a problem should be handled on the back shifts when the medical staff is not available. The supervisory training program includes 4 hours on policy implementation, identification of aberrant behavior, and the EAP. The training program beyond the initial phase is still being develope A disturbing fact was that the operations staff seemed to be the least knowledgeable of the PECo policies and the EAP. Three of the five Shift Supervisors interviewed reported that they had not been trained in Behavioral Observation Techniques or how they are expected to implement the policy. Records indicate that six of seventeen Shift Supervisors have not been trained. Furthermore, PECo has no policy as to who should be trained, when newly appointed supervisors must be trained, or when retraining is neede . Policy Implementation Training for Supervisors See paragraph D.4 abov . Union Briefing The Independent Group Association (IGA), representing PECo employees, participated in the development of the FFD program and policie IGA stated that latitude in the policy could cause problems in the future, however, they believed problems could be worked out since IGA and PECo management have worked well together in the pas . . .. _

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g t Contractor Notification ,

' At the time of the' inspection, PEco had not been formally notifying contractors and vendors of the need for their employees to abide-by PECo's rules on drugs and alcohol. However, PEco plans to use the " Vendor Safety Guideline Manual" dated 1/12/87 to notify vendors of PEco's expectations with respect to alcohol and controlled substances. Although the PEc drug and alcohol policies, which are more comprehensive than the Safety

Guideline, state .that their provisions apply to all contract employees, the contract' employees are not provided the policies (see paragraph D.3). Law Enforcement Liaison The agency primarily responsible for law enforcement in the Peach Bottom and: surrounding area is the Pennsylvania State Police unit at York, Pennsylvania. When questions of. onsite drug use are raised, site security ' supervisory personnel contact corporate security personnel and the latter decides whether to involve the State Police. . No written agreements exist, , although verbal agreements have been made that call for State Police - cooperation in (1) investigation of alleged drug use, (2) disposition / analysis of confiscated drugs, and (3) reporting the departure of impaired personnel from the site who refuse assistance offered by PECo to ensure their safet The verbal agreements seem well known to key personnel, but the absence  ; of written procedures may complicate the handling of a case by those '

: without previous experience.

, Chemical Testing of Body Fluids Chemical tests of body fluids are used for pre-employment screening of

e PECo employees only and followup-testing of PECo employees in the EA All people employed on site are subject to testing for cause, although

the circumstances are not specifically described. Random or periodic tests are not conducted. Confirmatory tests are conducted on all presumptive

positive screening tests. The testing is primarily urinalysis, but may include use of a breathalyzer when appropriate. Tests of blood are not-g

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conducte Many PECo employees have never been tested because they were hired before the pre-employment testing was initiated and were grand-fathered. PECo management reported they had concluded that contractor

~; employees should be given a " pre-employment" screening test prior to working on site and may revise the PECo FFD program accordingly. PECo

, management believes that, otherwise, contractor employees are not likely to be tested.at all since behavioral observations, which could stimulate testing for.cause, is not likely to be effective for the short periods contractors are on site.

. -For cause testing is one of several diagnostic tools available to the medical staff, however, interviews indicated that there have been situations where testing for cause was not used to diagnose a problem or to confirm an allegation. (The medical staff confirmed that testing is done on a case by case ~ basis only when there is a valid medical reason determined by the Medical Director.)

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If allegations are received concerning an individual's involvement with drugs or alcohol, or if the individual reports for work in what appears to be an impaired state, the individual will be referred to the Medical Department for an evaluation, including a decision on whether chemical testing is needed. During the day shift, the individual may be seen by the physician's assistant onsite or sent to the corporate headquarters medical staff. After normal work hours, the Medical Director will examine the individual at the headquarters or at the sit Based upon the examination / interview and a review of attendance history and performance evaluations, a decision is made on whether the person is impaired or if there is a basis for the allegation. Further investigation may be initiated to substantiate the allegation (see paragraph F.5.c). If the employee is impaired on the job, the usual practice is to test the employee for caus If chemical testing for cause is determined to be appropriate, a urine sample may be drawn at the site or at headquarters. There is no written procedure specifying conditions under which chemical testing is expected or require l Collection of Sample Urine samples are collected under direct observation by the medical staff to assure validity and prevent compromise of the sampl Control and Transfer of the Sample The sample is put in a plastic container and two seals are applie The inspectors noted that both seals were easily removable without evidence of tampering, and that evidence tape would be more suitable.

< No chain of custody is established to protect the sample as. forensic evidence; in addition, the sample is not properly secured to protect it while awaiting shipment. Samples taken at the site are mailed to corporate headquarter Those taken at headquarters, and those received by mail from the site, are picked up by courier and delivered to National Medical Services (NMS) laboratories for processing. They are not accompanied by hand receipts to ensure traceability, although the courier is an employee of NM . Testing of the Sample NMS is not notified which samples are pre-employment screening and which are for cause. Each sample is initially screened for alcohol and a number of controlled substances, first by thin-layer chroma-tography (TLC), followed by enzyme-multiplied immunoassay (EMIT) test 'Any sample that exceeds cutoff limits established by PECo is auto-matically subjected to confirmatory testing by gas chromatography coupled with mass spectrometry (GC/MS). This confirmatory test is intended only to verify the presence of the substance in question, not to verify the quantity (above cutoff) of the drug or metabolite identified in the initial screening tes If the presence of the substance is confirmed in any quantity, the sample is reported as being tested positiv The inspectors noted that the PEco cutoff limits significantly varied from that recommended by Duo Research for the National Institute-7-

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on Drug Abuse-(NIDA), the American Counsel for Drug Education, and V the Department of Defense, as follows:

 (1) THC~is 75 ng/ml (recommended standard:   20 ng/ml). The Medical Director stated the cutoff limit would be restored to 50 ng/ml; (2) cocaine is 1000 ng/ml (recommended standard:   300 ng/ml);
 (3) PCP is 1000 ng/ml-(recommended standard:   25 ng/ml).

These cutoff limits would probably detect heavy users who are addicted to the drugs in question, however, they may not detect

 " casual" or occasional us .

l Reporting Results NMS contacts PECo by telephone, within one day of receipt of the sample, of a positive finding during initial screening. Notification of the results of the confirmatory test is also made, usually within a.few days of the initial test, and followed up with a written repor Samples testing negative are retained by NMS for 3 weeks and those testing positive.for 6 month These samples are refrigerated (not i-frozen) and controlled while being retaine . Employee Assistance Programs The EAP program has existed since 1970 and has achieved credibility with the employees. The FFD program, on the other hand, appears to be an add- [ ' on to EAP (particularly in terms of implementation), rather than the two being integrated into one comprehensive program. Contractors are expected to develop their own EAP. The EAP program at PECo is intended to provide all employees and their families with confidential professional assistance

' in resolving personal problems. Corporate statistics (separate data are not available for the nuclear sites) indicate that the program is used by-an appreciable number of employees,.for reasons such as mental / emotional stress, family / relationship problems, job related stress, alcohol, drugs, and legal problems. The data also show that an appreciable number (65-70%) were referred by supervisors, indicating that, corporate wide, supervisors are detecting impaired or troubled employees. No data were provided concerning the degree of impairment, therefore, no conclusion could be drawn about the ability to detect marginal impairmen The corporate statistics appear to indicate that, generally, the EAP-goal of early intervention is being achieved in most case The PEco employees interviewed were generally familiar with the EAP and how to avail themselves of its services. . The EAP was strongly supported by employees because of its successes that are generally know Professional counseling services are available at headquarters and appear to be adequat _- _ _ _ _ _ _ _ _ _ _ _ _

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 - Miscellaneous EEI Guide Features        l t

Following are the inspectors' observations with respect to miscellaneous features of the EEI Guide.

Substance Abuse Committee A Substance Abuse Committee has not been established, however, key people do fulfill some typical committee functions on an ad hoc basi . Periodic Audits There has been~one " critique" of the PECo program; the PECo QA staff emphasized that the critique, which compared PECo's policies with the EEI Guide, was not intended to audit the effectiveness of the program as implemented.

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The QA staff also stated that there have been some audits of the contractors' access screening programs, which includes some FFD program element Some of these audits are conducted by other subscribers to the Nuclear Employee Data System (NEDS), are accepted by PECo, and are not subject to separate audit by PECo. Furthermore, several contractors have gone several years without audits because there is no schedule specifying how often each contractor will be audite ' Records and Reports , A system of records and reports to assist PEco in managing the program has not been developed. Program data were being kept, but-because they had not been computerized, they were not analyzed and are not routinely

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reported to management. However, the medical staff, in response to

  . questions raised by the inspectors, assembled the program data referred to in paragraph D.10, above.

  -The PECo staff reported that, based upon statistical analysis of employment problems, pre-employment drug testing was-implemented before the EEI Guide was develope Supplemental Program El_ements - Not in EEI Guide The NRC Policy Statement and EEI Guide describe a general approach to the design of fitness for duty programs. 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 guidance. It is emphasized that the following description of areas reviewed is not an indication that such program elements are or may become requirements.

. Written Procedures a 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 actions. Procedures would also reduce the likelihood that the actions would be mishandle :

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Other than a few procedures or guidelines provided for such matters s

.as obtaining urine samples and enabling the Medical Staff to determine whether nuclear access should be restricted, no written procedures have been developed to implement the policy. As indicated in paragraph above, many comments were received from supervisors that written procedures need to be develope . Professional Counseling Services Professional counseling services would manage and carry out the program, and provide initial diagnosis of the problem and referral to the proper professional care. This would be particularly important in the diagnosis and treatment of substance abuse and emotional instabilit Professional counseling services are provided at PECo headquarter . 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 user without adequate evidence of rehabilitation. The practices would include background investigations, psychological tests, interviews, and periodic rescreenin Pre-employment 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, contracts, and union agreements meet legal requirements concerning fitness for dut Legal reviews have covered standard contract specifications used for all contractors. No cases were reported which caused adjustments in the progra . Proactive Measures to Detect the Presence of Drugs On Site These measures are intended to provide evidence of onsite drug problems before they would be manifested in observable aberrant behavior. These measures could also provide a deterrent to onsite drug us Chemical Testing of Body Fluids Chemical testing of body fluids is a powerful tool for the detection and prevention of drug abuse. See paragraph D.9, above for a detailed discussion of PECo's chemical testing progra Searches There have been three searches of the workplace in the last two years; drug dogs were use'd during each of the searches. The deterrent effect of such efforts appeared to have been lost, because very few
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of the PECo or contractor employees interviewed were aware of these

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. *= searche c. Investigations When necessary, investigations are conducted by the corporate Claims /

Security Division with the assistance of law enforcement agencie They are initiated in response to leads, such as allegations and information received from informants and law enforcement authoritie d. Mechanism for Discreet Expression of Concerns There is an employee hot line available, although interviews with PECo and contractor employees suggested that awareness of the telephone number may not be widesprea e. Information from Law Enforcement Authorities Law enforcement authorities may provide information concerning offsite drug activity that may ultimately affect employee performance on the jo See paragraph F.5.c abov .

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