IR 05000424/1986091
| ML20213G484 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/29/1986 |
| From: | Brownlee V, Mckee P, Rosano R, Tom Ryan, Tobin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| Shared Package | |
| ML20213G460 | List: |
| References | |
| FRN-54FR24468, RULE-PR-2, RULE-PR-26 50-424-86-91, AC81-2-088, AC81-2-88, NUDOCS 8611180150 | |
| Preceding documents: |
|
| Download: ML20213G484 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT AND REGION II Report No.:
50-424/86-91 Docket No.:
50-424 License No.: CPPR-108 Licensee:
Georgia Power Company
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P.O. Box 4545 t
Atlanta, Georgia 30302
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Facility Name: Vogtle Project Inspection at: Augusta and Atlanta, Georgia Inspection conducted:
September 15-19, 1986 Type of Inspection: Announced Special Inspection of Fitness for Duty Program Inspectors:
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Richard P. Rosano, Security. Specialist Dat6
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Willism J. TQb in, Sdnior Security Date
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Inspectoh, Region II 4)
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ThomasG.Ryan,Seniorggipering Date Psychologist, RES b
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Approved by:
. Philip F. McKee7 Chief Date
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Inspection Summary
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Areas Inspected:
Included review of policies, procedures, and practices of the Fitness for Duty (FFD) Program and the Employee Assistance Program (EAP)
applicable to Vogtle employees and contractors and evaluation of program elements that go beyond the EEI Guide.
The licensee was advised that key elements of its FFD program are in place but certain areas still need improvement. The disciplinary provisions of the written policy and their communication to the employees were particularly strong, as was the support for the program from top management. The unions and contractor were involved in the development of the program, and supported it, and the licensee had an effective working arrangement with the local law enforcement authorities.
Certain of the major elements of the EEI Guide were not satisfied by the licensee's FFD program. Significant observations included:
1.
Training of supervisors in behavioral observation and policy implementation was found deficient in several areas.
For example:
(a) it is offered as one-time only training, (b) not all GPC super-visors have been trained and may not be until June 1987, and (c) approximately 50% of the contractor supervisors have not been trained.
2.
The following conditions were found in the chemical testing program: (a) contractor employees and GPC employees hired before the initiation of the program, including some who may be in sensitive positions, are exempt from the preemployment screening; and (b) no periodic or random testing is done. As a result, a number of the employees have never been subject to a chemical test for drugs and would not be subject to testing in the future.
3.
The EAP is inadequately stressed, particularly as a non-punitive approach to preventing drug problems onsite.
4.
There is no clear policy concerning recidivism or an individual's ret 1rn to duty following rehabilitation.
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A.
Key Persons Contacted
- R. E. Conway, Senior Vice President and Vogtle Project Director J. P. O'Reilly, Senior Vice President, Nuclear Operations
- D. O. Foster, Vice President, Project Support, Vogtle
- J. T. Beckham, Vice President and General Manager, Nuclear Operations
- J. W. Averett, Vice President, Human Resources
- J. H. Lukehart, Manager, Nuclear Security P. D. Rice, Vice President, Engineering R. H. Pinson, Vice President, Construction C. W. Hayes, QA Manager G. Buckhold, Plant General Manager
- V. J. Agro, Superintendent of Plant Administration
- D. B. Ellis, Manager, Labor Relations
- T. J. McHenry, Manager, Nuclear Support
- J. O. Dorough, Manager, Administrative Operations, Construction
- G. E. Dickerson, Construction Safety Supervisor P. Bensinger, Consultant, DuPont, Bensinger, & Associates
C. W. Whitney, Legal Counsel, Troutman, Sanders,
Lockerman, and Ashmore R. Brown, Site Security Manager D. Stevens, Site Security Investigator B. Luke, Allegations Clerk G. Corsey, Burke County Sheriff
". Longley, EAP Provider L. Owens, FFD Coordinator for Construction R. Hughes, FFD Coordinator for Operations A number of other individuals were contacted, including five contractor managers, three business managers from the local unions, and a total of 54 employees and first-line supervisors.
B.
Exit Interview The inspectors met with the licensee representatives, as indicated above, at the GPC corporate offices on September 19, 1986 to summarize the inspection results. The licensee was advised that key elements of its Fitness for Duty Program are in place. There were a number of strengths identified, particularly in the areas of the formulation and communication of the policy, support of top management, the union briefing, contractor notification, and law enforcement liaison. There were several observations noted relative to supervisor training, chemical testing of body fluids, and the communication of the advantages of the Employee Assistance Program to the employees. These are discussed in greater detail in the following sections.
Denotes those present at the entrance briefing at GPC Corporate offices.
- Denotes those present at the exit briefing at GPC Corporate offices.
- Denotes those present at the entrance and exit briefings at Corporate offices.
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C.
Approach The inspection team compared the Vogtle 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 as the EEI Guide). The Vogtle program was also compared to miscellaneous features contained in the EEI Guide.
In addi-tion, the team examined the Vogtle program for elements that would supple-ment those recommended in the EEI Guide, particularly those that would be included in proactive measures to detect the presence of drugs onsite.
The report is formatted to reflect this approach.
D.
Implementation of the EEI Guide Following are the inspectors' observations with respect to the implementa-tion of each of the Key Program Elements recommended by the EEI Guide.
1.
Written Policy The inspectors reviewed the Corporate Policy Statement, liuclear Operations Department Policy and Instruction (September 5, 1986),
Vogtle Project Drug Policy (April 25,1984), and Vogtle Anti-Alcohol Policy (January 27,1984), and interviewed members of the corporate staff and Vogtle project managers responsible for the development of the policy.
It was concluded that the licensee has formulated a clear and defini-tive corporate policy which implements the standards set by the EEI Guide.
It includes sanctions for onsite and offsite use of drugs and includes alcohol abuse among the proscribed behaviors.
Penalties for
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violation of the policy and application of the sanctions are made clear.
The licensee's policies concerning nonpunitive approaches to dealing with drug / alcohol abuse and application of the EAP are discussed in Section D.10.
It was concluded that the licensee has a corporate policy which addresses the company's responsibilities, standards, and commitments, and meets the intent of the EEI Guide.
2.
Top Management Support l
The team interviewed 54 supervisors and employees selected at random from day and swing shifts from GPC, Vogtle Project, and the contractor
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organizations. Throughout these interviews, strong support for the fitness for duty program was evident from the highest levels of the corporate organization down to the first-line supervisors. The fact i
that GPC has policy statements bearing the signatures of senior managers such as the Chairman of the Board and Chief Executive Officer underscores the philisophy that safety is the issue upon which the anti-drug / alcohol program was based, with the primary purpose being the establishment of a safe working environment.
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The team learned that top corporate management had visited the site,
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talked with employees, answered questions concerning the program, and
ensured fair and impartial enforcement of the policy. Employees ran-
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domly interviewed by the team verified this conclusion, and showed that they were encouraged by the results of a safer working environment.
In conclusion, the licensee's management support of the drug / alcohol
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policy satisfies the intent of the EEI Guide.
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3.
Effective Policy Communication The team read copies of policy statements, reviewed posters and signs, and noted the numerous methods used to communicate the policy to the employees. Employees interviewed during the course of the inspection were questioned concerning the policy to determine the extent of their understanding.
The licensee's policy is reiterated in several documents, e.g., the Corporate Policy Statement, Nuclear Operations Department Policy and Instruction (September 5,1986), Vogtle Project Drug Policy (April 25, 1984), and Vogtle Anti-Alcohol Policy (January 27,1984).
In addition, several publications are used to communicate the policy directly to employees, e.g., " Health and Safety Information on Alcohol and Drug Abuse" (Blue Book), " Rules of Conduct ard Safety for
Generating Plant Construction and Maintenance Projects" (Gray Book),
and " Project Agreement...between Georgia Power Company, its Con-tractors...and International and Local Unions..." (Red Book). To en-sure that all employees see these various iterations of the policy, each new hire signs for and receives an employment package containing, among other things, the Vogtle Project Drug Policy and Anti-Alcohol Policy. Also available are booklets on the Employee Assistance Program and a Supervisor's " Manual on Anti-Drug and Alcohol Program."
The utility newsletter (Blazer) which is distributed to all employees has included some articles in which the policy was described and explained, payroll flyers have transmitted the policy to employees, and posters, signs, and bumper stickers have served to remind employees and visitors to the site of the company policy concerning drug and alcohol use.
Interviews indicated that greater than 90% of the employees had a clear understanding of the punitive aspects of the Fitness for Duty Program.
Problems associated with the communication of the licensee's nonpunitive approaches to deal with drug / alcohol abuse and the EAP are discussed in section D.10.
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The team determined that the company has satisfied the intent of the EEI Guide.
4.
Behavioral Observation Training for Supervisors The team reviewed schedules of training, examined curricula used, j
spoke to individuals responsible for organizing the training of-4-
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supervisors, and interviewed a number of persons with supervisory responsibilities.
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The team was concerned about the training provided, primarily in terms of the number of supervisors who had not yet received training.
Not all GPC supervisors have been trained, and some are not scheduled to complete this training until June 1987. The training offered
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thus far has been one-time only, and a number of supervisors received their training as much as 2 years ago.
No refresher training or re-certification training has been scheduled.
As for contractor supervisors, the same situation exists, in part due to the failure to implement a periodic training program. All contractor supervisors were trained in mid-1984, but interviews
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with training coordinators indicate that due to turnover, a number of current supervisors have not been trained.
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Policy Implementation Training for Supervisors
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(See Section 4, above)
6.
Union Briefing
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The team held discussions with the GPC Labor Relations Official,
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l Business Agents of the Augusta Building Trades Council, and Inter-
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national Brotherhood of Electrical Workers Plant and Shop Stewards, i
and reviewed the Plant Vogtle Project Agreement, subsequent Rules of Conduct and Safety, correspondence and chronology of events related to labor relations coordination.
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From this, the team concluded that appropriate union leadership briefings relative to the Fitness for Duty Program did occur prior to program implementation and communication to employees and super-visors, and the licensee satisfied all aspects of this element of the EEI Guide.
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7.
Contractor Notification The team spoke to the five major onsite contractor managers, reviewed i
the general and specific conditions of standard inquiry purchase order packages, and interviewed a number of contractor employees.
The licensee has made it clear to the onsite contractors that their
employees will be terminated if found in violation of the company j
rules on drug and alcohol use.
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The contractors endorse the GPC Drug and Alcohol / Fitness for Duty Policy and Program and impose its requirements on their employees
at the time of employment processing via employment package documents and briefings.
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The team concluded that the licensee has satisfied all aspects of i
this element of the EEI Guide.
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8.
Law Enforcement Liaison The Sheriff of Burke County was interviewed concerning the licensee's liaison and cooperation with the various police departments in the community. The Sheriff noted that his department has worked closely with the licensee's security department on investigations, searches, and apprehensions.
Furthermore, he and his deputies have toured the facility.
The Sheriff considered the licensee to have an aggressive anti-drug /
alcohol program which has resulted in most abusers having been dis-charged from employment. Of note was the Sheriff's statement that drug availability has declined at Vogtle when compared to a few years ago and that his informants tell him that the reason for this decline is the licensee's implementation of an active chemical screening program. The Sheriff expressed familiarity with several investiga-tions, the " anonymous tip line" and several personalities involved in the anti-drug / alcohol campaign at the site.
In summary, the team concluded that the licensee has a useful rela-tionship with the LLEA and uses state and county law enforcement to assist its efforts. The program satisfies all aspects of this element of the EEI Guide.
9.
Chemical Testing of Body Fluids The licensee has purchased its own equipment for chemical testing of body fluids and housed it in a trailer on the site. This provides the unique opportunity to test suspected drug and alcohol abusers locally with minimal time lost from work.
It also increases employee respect for the program because it communicates the level of support of management. The current program is well financed and carried out in a professional manner by its staff. The handling of samples, controls, and the procedures for maintaining the integrity of the samples are good.
Initial sampling and testing are conducted onsite at the licensee's lab, and all samples initially testing positive for drugs are sent to the Medical Coilege of Georgia for confirmation testing.
Nevertheless, the team made observations about some aspects of the application of the chemical testing program. There is no periodic or randcm testing at Vogtle and GPC employees are subject to preemployment screening and testing "for cause" only. However, many employees were " grandfathered" when the program was first implemented and therefore have never been tested for drug use.
Similar contractor employees are subject only to testing for cause and, therefore, without preemployment screening many of these have also never been tested.
A broader application of the chemical testing program, especially to cover those individuals who have not yet been subject to that type of screening, would increase the ability of the licensee to identify drug use onsite and serve the preventive aspects of the FFD program.
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The team also questioned the use of the 75 nanogram per milliliter
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(ng/ml) cutoff set for the detection of marijuana use when using the licensee's equipment (Syva Emit). The manufacturer recommends 50.ng/ml and the licensee agreed that 20 - 25 ng/ml is the generally accepted industry standard.
Finally, the team was concerned that the 0.01 limit set for a positive alcohol test was too conservative, especially in light of the fact that the margin of error for that type of analyzer (Intoximeter 300)
is also 0.01.
(NOTE: The Georgia State legal limit applied to questions of DWI is 0.10.)
10.
Employee Assistance Programs Information and data were gathered through document review; inter-views of contractor and Vogtle Project employees, Vogtle FFD coordin-ators, and the EAP counselor under contract to GPC; reviews of employee assistance cases since January 1986; and a detailed review of an audit of the Vogtle Program conducted by Bensinger, Dupont & Associates (April 1986). The team concluded that the EAP is well documented and in general conformance with the EEI Guide, although some weaknesses we e identified.
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Specific concerns related to the lack of a policy for an individual's return to duty following rehabilitation for drug / alcohol abuse. There is no guidance regarding the followup program and the coordination between the employee's supervisor and treatment facility professionals.
A " plan and schedule" is lacking which would take proper account of public health and safety, including controls placed on the employee concerning job placement. These steps are considered crucial for ensuring that the employee's supervisor knows, as a minimum, the nature of the employee's problem, whether the problem has been solved, what may be needed to verify continued rehabilitation, whether there should be restrictions on safety-related duties, and whether past safety-related work needs to be checked.
Similarly, there is no clear policy established concerning how to deal with an individual who resumes substance abuse after his/her return to duty although there is a high incidence of recidivism among drug and alcohol abusers nationwide.
Interviews with medical personnel associated with the EAP and with the plant employees, and a review of the DuPont, Bensinger, & Associates audit indicated that the nonpunitive or preventive approaches to alcohol / drug abuse are inadequately stressed it Vogtle.
In interviews, employees showed great familiarity with the punitive aspects of the Fitness for Duty Program but often were poorly informed about the EAP and other nonpunitive preventive options. As noted in Section D.3, booklets explaining the EAP were provided to employees, but the licensee did not followup to ensure that the information was understood by the employees.
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During interviews, the GPC and site supervisors stressed their commit-
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ment to the confidentiality of sources and the identities of those seeking assistance. This commitment was verified by the number of employees who mentioned it in their interviews.
The team concluded that clear policies had not been established con-cerning recidivism and return to duty following rehabilitation as described above, and employees and contractors were not well informed of the opportunities offered for nonpunitive resolution of drug and alcohol problems among plant employees.
E.
Miscellaneous EEI Guide Features
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Following are the inspectors' findings with respect to miscellaneous features of the EEI Guide.
1.
Substance Abuse Committee
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The licensee has convened a substance abuse committee composed of key managers from the corporate offices and the Vogtle Project. This committee meets monthly and topics relating to the progress of the FFD are discussed. Of note is the fact that the members of this committee represent a broad spectrum of responsibility within the licensee organizational structure and possess the authority to take
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action on the decisions made by the committee.
2.
Audits
The team noted that only one audit of the program had been conducted to date, by DuPont, Bensinger & Associates. Without additional audits being scheduled, and without some mechanism for signalling problems that may arise, the licensee has insufficient means of measuring the
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continuing success of the Fitness for Duty Program.
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Records and Reports Team members met with Vogtle employees responsible for tracking statistics related to the success of the program as suggested by the
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DuPont, Bensinger & Associates audit, and identified several concerns
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with respect to the use of the data.
Although reports and data on the implementation of the FFD program are presented to the Substance Abuse Committee for decisions concerning the future of the program, there appears to be no l
statistical approach for adequately documenting the program's
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success.
F.
Supplemental Program Elements Not In EEI Guide following are the inspectors' findings with respect to program elements that would supplement those recommended in the EEI Guide, particularly preventive measures to detect the presence of drugs onsite,
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1.
Written Procedures
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i 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 mishandled.
I The team reviewed a number of procedures developed by GPC corporate staff and the Vogtle Project staff. The procedures are primarily i
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designed for use by the supervisors, and address such topics as:
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- what to do when an individual is suspected of using drugs;
- how to deal with an individual who refuses to take a chemical test;
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- har.dling detection and sale of drugs; and
- notifying LLEA.
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As discussed in preceding sections, procedures relating to the i
implementation of the non-punitive aspects of the program were less detailed, and in some cases omitted.
2.
Proactive Measures to Prevent / Detect Drug Abuse These measures are intended to provide evidence of onsite drug problems before they would be manifested in observable aberrant i
behavior. These measures could also provide a deterrant to onsite
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drug abuse.
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Proactive measures to prevent or detect drug abuse include continuing i
education for employees; random and periodic drug testing; investi-gations; confidential means to report concerns; and searches of the workplace, vehicles, and employees entering the site.
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Other than the various publications made available to the employees, there is no formal attempt to educate them on the dangers of drug or alcohol abuse or the impact of such behavior on the safe operation of
the plant. As noted in Section D.4 above, concerns were raised about
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the training offered to supervisors.
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Investigations are primarily conducted by the Burke County Sheriff's j
office and were discussed in Section D.8.
The absence of random and
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periodic chemical testing was discussed in Section D.9.
The licensee has an " anonymous tip line" and averages about one call per day. The
information collected on this line is kept confidential, but the substance of the report is shared with the appropriate level of management within GPC or its contractors.
While the licensee's use of drug search dogs has not resulted in the discovery of significant amounts, this technique is one of the many
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proactive measures utilized. The Security Investigator spends about
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half his time now working leads on drug use. Drugs confiscated at
the site are surrendered to the Crime Laboratory, Georgia Bureau of Investigation.
3.
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 instability. Professional counseling services are available through the offsite EAP contractor.
4.
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 rehabili-tation. The practices could include background investigations, psycho-logical tests, interviews, and periodic rescreening.
Although the licensee's preemployment screening practices were judged to be adequate, the varying programs utilized by contractors, especially the smaller ones, did not allow the inspectors to conclude that they
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provided an equivalent level of confidence regarding the applicant's reliability and trustworthiness.
5.
Legal Reviews Legal reviews would assure that company policies and procedures, contracts, and union agreements meet legal requirements concerning fitness for duty. The inspectors determined that legal reviews of the above are sufficient and that bid responses are reviewed to assure that commitments to a FFD program are made.
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