ML18032A294
| ML18032A294 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/13/1987 |
| From: | Ensworth F, Martin M TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML18032A274 | List: |
| References | |
| 71400, 71400-R03, 71400-R3, NUDOCS 8706040290 | |
| Download: ML18032A294 (50) | |
Text
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
71400 REPORT TYPE:
Management and Personnel Subcategory REVISION NUMBER:
3 TITLE:
Drugs PAGE 1
OF 13 REASON FOR REVISION:
Incorporation of final TAS editorial comments.
PREPARED BY:
PREPARATION SIGNATURE REVIEWS 0~%
SIGNATURE g->g-g DATE DATE SIGNATURE CONCURRENCES ATE SIGNATURE DATE CEG-H:
SRP:
SIGNATURE" 5-(3-81 DATE APPROVED BY:
~CSP MANA ER DATE N/A MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY)
DATE
~SRP Secretary's signature denotes SRP concurrences are in files.
~
8706040 H, 05000259
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUHBER:
71aOO FRONT HATTER REV' PAGE i OF viii Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (TVA).
The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1, 1986.
Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns.
Each of the concerns was a
formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate.
The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the
- NRC, and the general public.
The results of these investigations are communicated by four levels of ECSP reports:
- element, subcategory,
- category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restart of Sequoyah Nuclear Plant's reactor unit 2.
An element consists of one or more closely related issues.
An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns.
For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself.
Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.
Subcategory reports summarize the evaluation of a number of elements.
- However, the subcategory report does more than collect element level evaluations.
The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report:
a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms (terms formed from the first letters of a series of words).
Additionally, at the end of each subcategory report the reader will find at least two attachments.
The first is a Subcategory Summary Table that includes the following information; the concern
- number, a brief statement of the concern, and a designation of nuclear safety-related concerns.
The second attachment is a listing of the concerns included in each issue evaluated in the subcategory,
I 0.
, t
TVA EMPLOYEE CONCERNS SPECIAL PROGRAH REPORT NUMBER; 71400 FRONT HATTER REV:
2 PAGE ii OF viii The subcategories are themselves summarized in a series of eight category reports.
Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations industrial safety construction material control operations quality assurance/quality control welding engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the category reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.
A final report will integrate and assess the information collected by all of the lower level reports prepared for the
- ECSP, including the Inspector General's report.
For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual.
The Manual spells out the program's objectives,
- scope, organization, and responsibilities.
It also specifies the procedures that were followed in the investigation, reporting, and closeout of the issues raised by employee concerns.
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
71400 FRONT MATTER REV:
2 PAGE iii OF viii ECSP GLOSSARY OF REPORT TERMS~
classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A:
Issue cannot be verified as factual Class B;
Issue is factually accurate, but what is described is not a
problem (i.e., not a condition requiring corrective action)
Class C:
Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D:
Issue is factual and presents a problem for which corrective action has
- been, or is being, taken as a result of an evaluation Class E:
A problem, requiring corrective action, which was not identified by an employee
- concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
t collective si nificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective, concern (see "employee concern")
corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence, criterion lural:
criteria a basis for defining a performance,
- behavior, or quality which ONP imposes on itself (see also "requirement" ).
element or element re ort an optional level of ECSP report, below the subcategory level, that deals with one or more issues.
em lo ee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
71400 FRONT HATTER REV:
2 PAGE iv OF viii evaluator(s) the individual(s) assigned the responsibility to assess a specific grouping of employee concerns.
~findin s includes both statements of fact and the judgments made about those facts during the evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECTG during the evaluation
- process, raised in one or more concerns.
K-form (see "employee concern")
evaluation judgment or decision may be based.
root cause the underlying reason for a problem.
"Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.ges generic, specific, nuclear safety-related, unreviewed safety-significant question).
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
71400 FRONT MATTER REV:
2 PAGE v OF viii Acronyms AI AISC ALARA ANS ANSI ASME ASTM AMS BFN BLN CA/
CAR CATD CCTS CEG-H CFR CI CMTR COC DCR DNC Administrative Instruction American Institute of Steel Construction As Low As Reasonably Achievable American Nuclear Society American National Standards Institute American Society of Mechanical Engineers American Society for Testing and Materials American Melding Society Browns Ferry Nuclear Plant Bellefonte Nuclear Plant Condition Adverse to Quality Corrective Action Report Corrective Action Tracking Document Corporate Commitment Tracking System Category Evaluation Group Head Code of Federal Regulations Concerned Individual Certified Material Test Report Certificate of Conformance/Compliance Design Change Request Division of Nuclear Construction (see also NU CON)
0 0
TVA EHPLOYEE CONCERNS SPECIAL PROGRAH REPORT NUHBER:
71400 FRONT HATTER REV:
2 PAGE vi OF viii DNQA DNT DOE DPO DR ECN ECP ECP-SR ECSP ECTG EEOC EQ EMRT EN DES ERT FCR FY GET HCI HVAC INPO IRN Division of Nuclear Engineering Division of Nuclear Quality Assurance Division of Nuclear Training Department of Energy Division Personnel Officer Discrepancy Report or Deviation Report Engineering Change Notice Employee Concerns Program Employee Concerns Program-Site Representative Employee Concerns Special Program Employee Concerns Task Group Equal Employment Opportunity Commission Environmental Qualification Emergency Hedical Response Team Engineering Design Employee
Response
Team or Emergency
Response
Team Field Change Request Final Safety Analysis Report Fiscal Year General Employee Training Hazard Control Instruction Heating, Ventilating Air Conditioning Installation Instruction Institute of Nuclear Power Operations Inspection Rejection Notice
TVA EMPLOYEE CONCERNS SPECIAL PROGRAH REPORT NUHBER:
71400 FRONT HATTER REV:
2 PAGE vii OF viii L/R HMI HI MSPB NCR NDE NPP NPS NQAH NRC NSB NSRS NU CON Labor Relations Staff Modifications and Additions Instruction Haintenance Instruction Merit Systems Protection Board Magnetic Particle Testing Nonconforming Condition Report Nondestructive Examination Nuclear Performance Plan Non-plant Specific or Nuclear Procedures System Nuclear Quality Assurance Hanual Nuclear Regulatory Commission Nuclear Services Branch Nuclear Safety Review Staff Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUHARC Nuclear UtilityManagement and Resources Committee OSHA ONP OMCP PHR PT QAP QC QCI Occupational Safety and Health Administration (or Act)
Office of Nuclear Power Office of Morkers Compensation Program Personal History Record Liquid Penetrant Testing Quality Assurance Quality Assurance Procedures Quality Control Quality Control Instruction
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
71400 FRONT MATTER REV:
2 PAGE viii OF viii QCP QTC RIF SQN SI SOP SRP SWEC TAS TSL TVA TVTLC UT Quality Control Procedure Quality Technology Company Reduction in Force Radiographic Testing Sequoyah Nuclear Plant Surveillance Instruction Standard Operating Procedure Senior Review Panel Stone and Webster Engineering Corporation Technical Assistance Staff Trades and Labor Tennessee Valley Authority Tennessee Valley Trades and Labor Council Ultrasonic Testing Visual Testing MBECSP Watts Bar Employee Concern Special Program WR Watts Bar Nuclear Plant Mork Request or Work Rules Morkplans
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER:
3 PAGE 2
OF 13 1.0 CHARACTERIZATION OF ISSUES This report covers 23 employee concerns addressing the use and control of drugs and alcohol at Watts Bar Nuclear Plant (WBN).
The 23 employee concerns raised three issues about a) the drug testing program (21 concerns);
b) the Employee Assistance Program (1 concern);
and c) the legality of a proposed random drug, testing program (1 concern).
These issues are characterized as follows.
1.1 Issue 71401 - Ade uac of Dru Testin Pro ram Most of the concerns that make up this issue expressed or implied the need for more comprehensive drug testing procedures, Some of the concerned individuals perceived drug abuse to be widespread at WBN and other ONP sites.
This perception raised guestions about the effects of drug abuse on plant safety.
One individual stated that employees are reluctant to report drug users for fear of reprisal.
1.2 Issue 71402 - Abuse of Em lo ee Assistance Pro ram One concern alleged that construction workers report to work under the influence of drugs.
They are allegedly allowed to continue working and continue using drugs if they tell TVA they are enrolled in a drug abuse program.
Additionally, these drug abusers are alleged to be retained at layoff time at the expense of non-abusers.
1.3 Issue 71403 Le alit of Random Testin One concern argued that random testing for drugs would be a
violation of the constitutional right to privacy.
h To locate the issue in which a particular concern is evaluated, consult the following attachments:
Attachment A, Subcategory Summary Table Attachment B, List of Concerns by Issue All Management and Personnel Category concerns having a technical component (including all concerns designated Nuclear Safety-Related) are shared with the appropriate technical category for investigation and resolution of that technical component.
Report(s) sharing a
concern with this report are identified in the entry for that concern on Attachment A.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER:
3 PAGE 3
OF 13 2.0
SUMMARY
2.1 Summar of Issues There are three issues contained in the 23 employee concerns addressing drug use.
The first issue (with a total of 21 concerns) expressed or implied the need for a more comprehensive drug testing program at WBN.
One issue implied abuse of the Employee Assistance Program (EAP).
One issue questioned the legality of random testing for drugs:
does such testing violate the constitutional right of privacy and the avoidance of search without probable cause?
2.2 Summar of Evaluation Process The evaluator has reviewed all the information available on the concerns in this subcategory.
The information pertinent to the evaluation of the issues has been considered and incorporated in this report.
Interviews were conducted with top level people in the field, both inside and outside of TVA, to develop background data.
This data, coupled with a review of current literature, provided an informational base sufficient to evaluate the issues, 2.3 Summar of Findin s
The findings indirectly support the need for a more comprehensive drug testing program as a prudent precaution.
No evidence of abuse of the EAP was found.
The legality of random testing is a question that can be decided only by the courts.
2.4 Summar of Collective Si nificance Although no evidence was found that employee drug use is currently a
significant problem, prudence dictates that measures be taken to guard against drug abuse in the future.
Failure to identify and reform drug abusers could lead to serious safety and morale problems at nuclear facilities.
2.5 Summar of Causes The current drug testing program is not perceived by the Cis as being comprehensive enough to catch or deter potential drug abusers.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER' PAGE 4
OF 13 2.6 Summar of Corrective Action TVA's drug testing program will be expanded to include all employees, regardless of position.
Random testing will be initiated for all personnel with unescorted access to vital plant areas, Training programs are being developed to increase the effectiveness of the Fitness for Duty program.
Supervisors will be better trained in identifying and handling drug abusers, Employees will be better informed of the availability of the Employee Assistance Program and of the consequences of continued drug abuse.
3.0 EVALUATION PROCESS 3.1 General Methodolo The evaluation of this subcategory was conducted according to the Evaluation Plan for the Employee Concerns Task Group and The Evaluation Plan for the Management and Personnel Category.
The concern case files were reviewed.
Source documents were reviewed to establish the regulatory requirements or management mandates that apply to the circumstances described in the issues covered in this subcategory.
The issues were evaluated against the established requirements or management policies.
From this evaluation, findings were determined.
The findings were then analyzed for their collective significance.
Causes were identified for the negative findings.
The responsible organizations were identified and corrective actions were initiated for the negative findings.
3,2 S ecific Methodolo TVA's current drug testing requirements were compared to programs, outside and inside the utility industry to establish TVA's position with respect to program implementation (See Attachment C for sources consulted).
Interviews were conducted with five TVA employees and one knowledgeable person outside TVA to gather background data and determine TVA's short and long-term approach to the drug use problem in the workplace (See Attachment C for a list of those interviewed).
One line management investigative report was reviewed; its findings were in accord with the findings reported in section 4.0.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 7la00 REVISION NUMBER' PAGE 5
OF 13 3.3 Investi ative Focus for Each Issue 3.3.1 Issue 71401 Adequacy of Drug Testing Program (a)
What are the advantages/disadvantages of having random drug testing as a part of the drug program?
(b)
Is there any evidence directly linking drug use to poor work quality and/or the creation of hazardous situations?
(c)
What specifically do employees fear from identifying a drug user/abuser?
3.3.2 Issue 71402 - Abuse of Employee Assistance Program (EAP)
(a)
What are the controls to prevent participants in the EAP from continuing to use drugs?
(b)
What controls exist that would prevent employees from continuing to use drugs while participating in a non-TVA drug abuse program?
(c)
Are controls necessary to ensure that those in the EAP do not receive preferential treatment?
3.3.3 Issue 71403 Legality of Random Testing (a)
What is the legal opinion on random testing across the industry?
(b)
What is TVA's position (per Office of General Counsel)?
3.4 Current ONP Dru Pro ram Re uirements The requirements of the program (Nuclear Power Procedure 0905.01.04) currently in place within ONP state:
Discharge is the standard penalty for the illegal use,
- sale, or possession of narcotics,
- drugs, or controlled substances, while on the job or on TVA property.
Off-the-job illegal drug use which could adversely affect an employee's job performance or which could jeopardize the safety of other employees, the public, or TVA equipment is proper cause for disciplinary action up to and including termination.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER:
3 PAGE 6
OF 13 When an employee is arrested for off-the-job drug acti vities, management will consider the underlying factual basis for the arrest in determining any disciplinary action or other action that may be warranted, The drug and alcohol testing process used by ONP is handled as follows:
A.
Testing is invoked in cases where there is reasonable suspicion that the employee is intoxicated or under the influence of drugs or alcohol.
Reasonable suspicion is a belief based on behavioral observations sufficient to lead a prudent supervisor to suspect that the employee is under the influence of drugs or alcohol (e.g.,
slurred
- speech, alcohol on breath, inability to walk a straight line, and inattentive or inappropriate behavior),
B.
Testing will be used routinely for:
Outside applicants and transierees into positions requiring unescorted access clearance.
TVA employees who are being transferred and must obtain an initial unescorted access clearance.
An employee who is suspected to be in possession of illicit drugs or alcohol or when illicitdrugs or alcohol are found in an employee's workplace.
Contractors or vendor employees requiring unescorted access clearance.
4.0 FINDINGS The discussion of the subject of a drug and alcohol testing program within TVA would probably be better understood in the context of recent activities and current ONP drug program requirements.
Before 1983 No Identification Pro ram Before 1983, TVA's work rules specifically prohibited the use of drugs onsite;
- however, there was no program in effect to identify drug users/abusers.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER' PAGE 7
OF 13 The initial exposure of TVA's nuclear program to comprehensive drug testing requirements was in October
- 1982, when the Nuclear Regulatory Commission (NRC) proposed their "Fitness for Duty Rule" to the nuclear industry.
Subse uent Milestones Subsequent milestones in the last 43 months are as follows:
March 1983 TVA implemented the Drug Awareness Program.
September 1983 -
ONP supervisors were trained on policy and behavioral observation, October 1984 NRC decided to delay rule-making on fitness fox duty for two years.
TVA committed, with other utilities through Nuclear Utility Management and Resource Committee (NUMARC), to have a basic Fitness for Duty Program implemented in its nuclear program by February 1985.
January 1985 The Institute of Nuclear Power Operations (INPO) issued fitness for duty performance objectives in Performance Ob'ectives and Criteria for 0 eratin and Near-Term 0 eratin License Plants.
August 1985
INPO revised corporate fitness for duty performance objectives and criteria and issued Performance Ob'ectives and Criteria for Cox orate Evaluations.
Edison Electric Institute (EEI) revised and issued EEI Guide to Effective Dru and Alcohol Fitness for Dut Polic Develo ment.
ONP changed the Drug Awareness Program to the Fitness for Duty Program and included alcohol and drug screening tests of prospective employees, which also included transfers, employees requesting initial clearance, and contractors.
Supervisory and Employee Training Programs were revised and retraining was initiated at all locations.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER:
3 PAGE 8
OF 13 4.1 Generic Findin s
4.1.1 Issue 71401 - Adequacy of Drug Testing Program Discussion A.
Need for Im roved Testin Procedure A study was done by an Edison Electric Institute (EEI) task force.
The chairman was Michael R. Tuosto, Public Service Electric and Gas Company (PSESG) general manager of personnel and equal opportunity.
The study concluded that the utility industry was experiencing drug-related problems "no worse, but no better" than industry in general.
The consensus of the EEI task force, though not absolute, is that upwards of 7 percent of the nation's work force is involved with the misuse of drugs.
Checks of potential employees at one major northern utility has revealed that 8 to 11 percent of new applicants were misusing drugs.
TVA's experience with new applicants and transferring employees has been that 4 to 5 percent are drug abusers.
It is unclear why TVA's percentage of detected drug abusers is lower than the national average.
It may be lower because the testing procedure is inadequate (as the CI's contend),
but it may also be lower because TVA has fewer drug abusers.
ONP is developing a random drug testing program. It is more comprehensive in at least two areas than programs initiated by the Department of Defense (civilian employees),
U.S. Air Force, U,S. Navy, South Carolina Electric S Gas, and Detroit Edison.
The principal areas where ONP's program exceeds the others are in the number of employees to be tested and in the number of drugs that can be identified.
The programs of outside organizations used for comparison with ONP ranged from random screening of'ritical positions only, to testing all personnel annually.
By inspect~on, the first situation would exclude quite a few employees and the second would not be particularly valid since all employees would know when their screening would be scheduled.
ONP tests for seven (7) groups of drugs as compared to a cross-section of government and private companies that test for two (2).
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER:
3 PAGE 9
OF 13 Comparisons between various programs can be misleading and should be approached with some caution.
- However, such comparisons provide an additional perspective from which to gauge the overall merit of ONP's drug testing program.
B.
Plant Safet The basis of most of the concerns about the drug testing program is that drug abuse could result in poor work performance.
- However, based on discussions with personnel officer(s) and construction management, no situations have been identified at WBN (where most of the concerns originated) in which any employee made a
safety-related mistake or created a hazardous situation that could be attributed to drug use.
Certainly, some employees have been detected as drug users and rehabilitated or released; nevertheless, their work records have not indicated any safety-related abnormalities.
The possibility that the work records failed to document safety abnormalities is also being guarded against.
An extensive study is being performed by a company called EGSG on the welding program at WBN; meanwhile, Stone and Webster Engineering Corporation (SWEC) is evaluating QA-related areas.
Since these programs are comprehensive in nature, defective welds or inspections will be identified as a result of these efforts.
C.
Fear of Re risal Employees are indeed reluctant to turn in fellow employees for drug abuse on the job.
Discussions with a number of TVA employees have revealed that identifying fellow employees as drug users/abusers could mark them for retribution ranging from peer ostracism to unwarranted supervisory actions, depending on whom they identified.
- However, no specific instances of reprisals were found, Conclusion Efforts to combat drug use with the current level of testing (i.e., only on transfer or for initial clearance) were considered to be ineffective by the majority of concerned
0
TVA EMPLOY'EE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER; 3
PAGE 10 OF 13 individuals (CI's) who addressed this issue.
This contention could not be verified as factually accurate.
- However, a
random testing program currently under development should help strengthen the program and alleviate the perceptions of inadequacy (see section 7.1),
4.1.2 Issue 71402 Abuse of Employee Assistance Program Discussion This issue raised three questions about the EAP.
A.
Do em lo ees in EAP continue to use dru s?
Controls to prevent employees in the EAP from continuing to use drugs are in place and are strictly enforced.
They are described in the Division of Medical Services',
Standardized Procedures for EAP Monitorin of Nuclear Power Em lo ees after a Positive Dru Screen.
An individual participating in the EAP would not be able to continue drug use for any length of time since a random screening program is initiated for each EAP participant and a second positive screening would result in the employee's immediate dismissal.
Employees who participate in the drug abuse program are well aware of the restrictions they are subject to and, in fact, must sign a statement that outlines those restrictions.
B.
Can em lo ees in outside dru ro rams still use dru s?
Employees can participate in a drug abuse program without TVA's knowledge; however, if they communicate this information to their supervisor for any reason, they will be referred by the supervisor to the EAP counselor for an interview to assess the quality of the employee's involvement with his/her program.
The fact that an employee would then be associated with drug use and possibly be required to submit to a drug screen should provide a sufficient deterrent to prevent employees from using their involvement in an outside program as an excuse to continue to use drugs.
C.
Do em lo ees -in the EAP receive referential treatment?
Controls that govern the retention of employees during layoffs are negotiated as part of the contracts TVA has with the various unions.
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER:
3 PAGE 11 OF 13 The personnel groups that develop seniority lists during layoffs are not informed of an employee's participation in the EAP.
In fact, the names of EAP participants are kept confidential.
Under these circumstances it would be impossible to favor one employee or group of employees over another.
Conclusion The issue of abuse of the EAP could not be verified as factually accurate.
- However, the questions raised do reveal a lack of understanding by employees of how the EAP works.
4.1.3 Issue 71403 - Legality of Random Testing Discussion The opponents of random testing point to a citizen's right to avoid "search without probable cause" by a government agency.
The Constitution of the United States prohibits governmental organizations from imposing "searches" on private citizens without probable cause.
Nongovernmental organizations will not have to defend their actions on this point; however, they will be required to offer a defense against the "invasion of privacy" argument.
TVA will probably be required to defend its actions in both areas.
TVA's Office of General Counsel is currently evaluating these questions.
The final determination should eventually be made by the courts.
Conclusion This issue could not be verified as factually accurate.
4.2 Site-S ecific Findin s
None.
5.0 COLLECTIVE SIGNIFICANCE The Employee Concerns Special Program has received a total of 23 concerns about the use and control of drugs and alcohol at WBN and other ONP
n
0 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER; 71400 REVISION NUMBER' PAGE 12 OF 13 sites.
Since there were over 5,000 concerns from over 2,000 individuals, one might fairly conclude that drug and alcohol abuse is not seen as a
serious problem by ONP employees,
- However, prudence dictates that measures be taken to make sure that a problem in this area does not develop in the future.
That need for prudence accounts for two potential problem areas that became apparent through the evaluation of this subcategory, (1)
Mana ement effectiveness in identifying drug users/abusers in the workplace has historically been poor throughout the nation.
A more impersonal and objective approach to this process is badly needed.
Managers and supervisors also need more training in the identification and handling of apparent drug users/abusers,
- However, the determination that an employee is a drug abuser is a
professional clinical judgment to be made by medical personnel, (2)
Em lo ee effectiveness is impeded if nonusers perceive that management tolerates or ignores drug abuse.
A drug, abuse program widely perceived as effective helps nonabusers'orale even as it protects against the possibility of bad work by actual abusers.
6.0 CAUSES 6.1 Perce tion of Inade uate Dru Testin Procedures The drug testing procedures in place at the time these concerns were filed were not perceived as comprehensive enough to detect all drug abusers quickly.
Consequently, the procedures were not seen to be an effective deterrent to potential drug use on the job.
6.2 Misunderstandin of the EAP The Employee Assistance Program (EAP) is intentionally promoted and administered to maintain a low profile.
A consequence of this approach is inadequate awareness on the part of employees about the program and the rules that govern it.
- However, some responsibility for this lack of awareness must be borne by the employees since the information is readily available.
7.0 CORRECTIVE ACTION 7.1 Previousl Initiated Corrective Action A random drug testing program for all personnel with clearance to work unescorted in vital plant areas is under development.
The
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 71400 REVISION NUMBER:
3 PAGE 13 OF 13 research of drug testing programs undertaken for this evaluation argues that such a program will both control drug abuse and be perceived as effective by most personnel.
Should random drug testing be disallowed by the courts,
- however, other means must be found to assure employees and the public that ONP's nuclear facilities are constructed and operated in a drug free work environment (CATD 714-NPS-Ol).
7.2 Corrective Action Resultin from This Evaluation The ONP Training and Development Staff is revising the training previously administered under the former Drug Awareness Program.
Training on the Employee Assistance Program will be made a part of General Employee Training (GET 3.1) for all nuclear plant personnel.
The revised program will include content on the rules which govern the EAP and training on the behavioral changes in employees which should be recognized and reported to supervisors.
The Power Operations Training, Center (POTC) staff is coordinating the new GET 3.1 curriculum (CATD 714-NPS-02),
8.0 ATTACHMENTS Attachment A, Subcategory Summary Table Attachment B, List of Concerns by Issue Attachment C, List of Interviews and Supporting Documents
FEREtlCE ECPS132J-ECPS132C EQUEWCY REQUEST P
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ISSUES TENNESSEE EY AUTHORITY AT tEHT A OFFlCE OF tlUCLEAR PO11ER EHPLOYEE CONCERtl PROGRAN SYSTEH (ECPS)
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tl H
2 HO HA HA HA 02 tlP 71001 S
BFH 1
tt N
H N
2 NA tlA tlA tlA 86-112-SQN 01 IH 60300 S
SQH 1 tl H
Y tl 2
HA tlA HO HA 02 HP 71601 S
SQH 1 tl tl tl H
2 tlA HA tlA NA I -8500600~)01 t1P 71601 tl HBtl 1
H N
W H
T50015 2 tlA NA HA HA QTC HSRS HSRS QTC REACTOR OPERATORS SHOULD HAVE TO GO THROUGH CHEt'1ICAL TESTS AtlD BLOOD TES TS NOWTHLY.
tlUCLEAR POllER COWCERtl.
CI HAS HO ADDITIOtlAL IWFORt1ATIOtt.
-GEtlERIC COtlCERtl-CITIZEN ACTION LINE CALL ALLEDGIHG C OCAIHE USE AT BFtl.
CALL REFERRED TO OGC BY It(FORthATIOtl OFFICE.
tlSRS DO ES tlOT CONSIDER THIS TO BE SAFETY-RE LATED AHD DOES HOT PLANT TO IWVESTIG ATE SItlCE OGC IS HAtlDLItlG THE EHPLOY EE MISCONDUCT.
AWOtlYHOUS CALL REPORTED DRUG DEALING AT SQtl TO CITIZEtl ACTIOtl LINE.
CRA VEW CROHELL FORHARDED TO OGC AHD tlSR S.
tlSRS DOES tlOT COtlSIDER THIS A SA FETY-RELATED CONCERN AWD IS HOT PLAN tlIWG At) IWVESTIGATIOtl AT THIS TIt1E.
HIDESPREAD DRUG USE BY HORKERS AT HA TTS BARp BOTH UttITSz ESPECIALLY BY T VA HAWAGEt'1EtlT AtlD CRAFT SUPERVISIOtl.
HO SPECIFICS OR tlAHES GIVEN.
COWCERtlS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY tlUHBER.
FEREHCE ECPSi32J-ECPS132C EQUEIICY
- REQUEST P
ISSS RIN EGORY:
thP t1GT.
8t PERS.
ISSUES TEtltlESSEE LEY AUTHORITY OFFICE OF NUCLEAR POWER EtIPLOYEE COIICERtl PROGRAt1 SYSTEII (ECPS)
ENPLOYEE CONCERN ItJFORHATIOII BY CATEGORY/SUBCATEGORY SUBCATEGORY~ 716 ADEQUACY OF DRUG TESTING PROGRAH PA 2
RUN TINE 10~06:39 RUtl DATE - 03/10/87 S
H SUB R PLT OIICERtl HUI1BER CAT CAT D LOC 1
RLPORT APPL 2 SAF RELATED BF BL SQ WB HISTORICAL CONCERN REPORT ORIGIN CONCERN DESCRIPTIOW REF.
SECTION CAT NP SUBCAT 716 Ohl-00201 IH 60600 S
WBH T50198 02 HP 71401 S
WBH 1
W W
tl W
2 tlA tN WA HA EX-85-052-005 QTC SUPERVISIOtl IGtlORItlG UNAUTHORIZED Hf DICATIOW Otl"SITE RESULTIHG IH IWDIVI DUALS WOT BEING ABLE TO PERFORI1 REQU IRED TASKS.
IE-OTHERS ARE REQUIRED TO TAKE UP SLACK BECAUSE Atl IWDIVID UAL IS SO HEAVILY DRUGGED THAT IF TH EY WEtlT ItlTO THE FIELD THEY WOULD HU RT THEMSELVES OR OTHERS.
COtlSTRUCTI OH DEPT.
COtlCERtl.
CI DECLItlED TO PR OVIDE AHY FURTHER IWFORt1ATIOtl.
"85-272-00501 IH 60300 S
WBN 1
T502<i 0 2
02 t1P 71002 S
WBN 1 tl N
tl N
2 tN HA tlA HA
'85-29<i-00301 IH 60300 S
WBN 1
T50258 2
02 MP 71401 S
l'IBN 1 tl H
N tl 2 tN NA tlA tlA QTC QTC COtlSTRUCTIOtl I'IORKERS (CRAFT KNOHII)
R EPORT TO WORK UtlDER THE IWFLUEIICE OF DRUGS.
THEY ARE ALLOWED TO COWTIIIU E WORKING AWD TO CONTINUE USING DRUG S IF THEY TELL TVA THAT THEY ARE EIIR OLLED IW A DRUG ABUSE PROGRAH.
TVA SHOULD SCREEtl EVERYOtlE Otl SITE, BUT INSTEAD OF KEEPItlG GOOD WORKERS AT L
AY OFF TIIIEi TVA KEPT THE SUBSTAtlCE ABUSERS.
CI DECLItlED TO PROVIDE FUR THER IWFORHATIOII.
CONSTRUCTION DEPT COHCERtl.
tl0 FOLLOW UP REQUIRED.
CONTROLLED SUBSTANCES ARE USED WIDEL Y AT WBtlP, BUT AT PRESEIIT EIIPLOYEES WHO ARE WORRIED ABOUT REPRISALS ARE RELUCTANT TO CONTACT PUBLIC SAFETY W
ITH SPECIFIC AtlD TIMELY ItlFORHATIOII.
ALSO'CREEtlItlG FOR DRUGS HAS tlOT BEEtl EXTEtlDED TO ALL EtIPLOYEES.
THE PROPER USE OF CONTROLLED SUBSTAtlCES COULD HURT PLAtlT SAFETY IF PERSOHtlE L PERFORt'IItlG KEY FUtlCTIOll HAVE SLOHE D ACTIONS OR DISORIEWTATIOW.
CI HAS HO FURTHER IWFORt1ATIOtl OR SPECIFICS tlUCLEAR POWER COHCERtl.
CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY tlUHBER.
FEREtlCE ECPS132J-ECPS132G EQUEtlCY REQUEST P
ISSS Rllt 1 EGORY:
t1P tlGT. 8 PERS.
ISSUES TENNESSEE LEY AUTHORITY OFFICE OF NUCLEAR POllER Et1PLOYEE COWCERtl PROGRAM SYSTEtl (ECPS)
EMPLOYEE COtlCERtl INFORMATIOtl BY CATEGORY/SUBCATEGORY SUBCATEGORYi 714 ADEQUACY OF DRUG TESTING PROGRAM PA RUW TIME 10-00.-39 RUtl DATE - 03/10/87 OWCERtl NUMBER CAT S
lt SUB R PLT CAT D
LOC 1
REPORT APPL 2
SAF RELATED BF BL SQ llB HISTORICAL COtlCERH REPORT ORIGIN CONCERN DESCRIPTIOW REF.
SECT IOtl CAT t1P SUBCAT 71'85-608-00101 T50022 thP 71601 tl HBH 1 tl tl tl tl 2
HA tlA tlA tlA QTC INDIVIDUAL HAD A GEtIERIC CotlCERW ABO UT "POT" St10KItlG Otl-SITE.
IWDIVIDUA L RELATED ItlCIDEHT HHEREItl "POT" llAS BEING USED (NOTICED SMELL NEVER S
All USAGE).
INDIVIDUAL HAS llITH GEtlE RAL FOREMAN 8t AFTER A SEARCH THEY CO ULD WOT LOCATE SOURCE 673-00101 MP 71601 tl HBH 1 tl tl tl H
T50037 2 tlA WA HA HA 551-00101 MP 71601 H HBtl 1 tl N
W H
T500<i9 2 tN tN tN HA 558-00101 MP 71601 N
'HBH 1
W tl tl tl T500<i8 2 lN HA tlA tlA "85-663-00<i01 IH 60300 S
HBH 1
T50238 2
02 tlP 71401 S
HBH 1 tl tl tl tl 2
HA tlA NA HA t 750-00201 MP 71001 tl IlBW 1
W W
tl H
T50077 2 tlA HA tlA HA QTC QTC QTC IH-85-663-006 QTC
- QTC, ALL Et1PLOYEES SHOULD HAVE BLOOD/URIH E TESTS TO DETECT USERS OF COWTROLLE D SUBSTAtlCES.
THERE SHOULD BE A DRUG PROGRAM FOR E
t'1PLOYEES AT HATTS BAR.
DRUG TESTING SHOULD BE INITIATED AT HBtlP.
TVA'S UPPER tIAtlAGEMEHT (OFF-SITE)
HA S
OWLY PERMITTED SCREENING WEW HIRES p
TRANSFERS AtlD RE-HIRES FOR DRUGS A
HD ALCOHOL.
DESPITE RULES PROHIBITI HG ALCOHOL AtlD DRUGS'HEY ARE HIDEL Y AVAILABLEOtl SITE AT 'tlBttPi BECAUSE PUBLIC SAFETY DOES tIOT CHECK LUNCH BOXES AT THE BEGItHlItlG OF THE SHIFT.
llHEW A PUBLIC SAFETY OFFICER REPOR TED LIQUOR It( Atl EtlPLOYEE'S CAR~
HE llAS TRAtlSFERRED AtlD THE OFFEtlDER COtl TItlUED TO llORK FOR TVA.
CO-HORKERS COVER UP FOR CHROtlIC SUBSTANCE ABUSE RS AtlD MAtlAGEHENT TOLERATES OPEN TVA SHOULD TEST ALL PERSONNEL FOR DR UG USAGE.
COtlCERWS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY WUtlBER.
.EREWCE ECPS132J-ECPS132C
.QUENCY REQUEST ISSS - Rl<tl
=GORY:
MP MGT.
8t PEi<S.
ISSUES TEWtlESSEE EY AUTHORITY OFFICE OF tlUCLEAR POIIER EMPLOYEE COIICERtk PROGRAM SYSTEM (ECPS)
EMPLOYEE COtlCERW IIIFORIPATIOII BY CATEGORY/SUBCATEGORY SUBCATEGORY~ 716 ADEQUACY OF DRUG TESTItIG PROGRAM RUtt TIME " 10: 04:39 RUtl DATE 03/10/87 S
SUB R PLT
)tICERtl HUtlBER CAT CAT D LOC 1
REPORT APPL 2 SAF RELATED BF BL SQ MB HISTORICAL COtICERtl REPORT ORIGIN CONCERN DESCRIPTIOH REF.
SECTION CAT t'1P SUBCAT " 716
-85 "871-00101 llP 71401 W lIBW T50255 1
tl N
II H
2 WA IIA WA HA QTC CI FEELS A
DRUG SAMPLIIIG PROGRAM FOR llBWP IIOULD It'IPROVE THE NOTICEABLE D RUG PROBLEM It) THE FIELD.
tlO SPECIF ICS PROVIDED.
tlUCLEAR POINTER DEPARTtl EtIT COtlCERW.
WO ADDITIOtIAL ItIFORI'IAT IOW AVAILABLEIW FILE. 947-X0901 MP 71<)01 tl IIBII 1
H tl W
tl T50233 2 tlA WA WA HA 956-00201 MP 71603 W llBtl 1
W W
tl W
T50104 2 IIA IIA tlA tlA 082-00101 MP 71401 W llBH 1
!I tl H
tl T50117 2
WA tlA WA HA "86"293-00101 tlP 71601 N
14BN 1
W H
N tl T50151 2 tlA WA WA WA QTC QTC QTC QTC SOME OF THE PEOPLE It( UPPER MAIIAGEIPE HT (HAtlES KtlOHtl) HAVE ALCOHOLIC PROB LEtlS.
THEY ARE SUPPOSED TO SET AW f XAMPLE TO EMPLOYEES.
THEY ARE UWQUA LIFIED TO HOLD THEIR POSITIONS..
COW STRUCTIOtl DEPARTMEtlT COWCERtl.
CI HA S
WO FURTHER IHFORI'1ATIOtl.
WO FOLLOH UP REQUIRED.
tlAHDATORY URINALYSIS TESTS ARE At( Itl VASIOII OF INDIVIDUAL'S PRIVACY.
At(
INDIVIDUAL SHOULD OWLY BE MADE TO TA KE THESE TESTS IF THEY ARE SUSPECTED OF DRUG/ALCOHOL ABUSE.
CI HAS WO tl ORE ItlFORtlATIOtl.
tl0 FOLLOll UP REQUI RED.
THE USE OF DRUGS OW SITE AWD THE LAC K OF CONTROL OF DRUGS IS A COtlCERtl.
CI HAS WO tlORE IIIFORI1ATIOW.
tlUCLEA R
POIIER COtlCERW.
WO FOLLOI4 UP REQUI RED.
CI FEELS THE USE OF MARIJUAtlA AHD OT HER DRUGS IS UtlSAFE III THE IIOPK PLAC E.
CI HAD DETECTED THE PRESEtICE OF tlARIJUAtlA It( THE PLAIIT AtlD SUSPECTS THE USE OF OTHER DRUGS.
CI FEELS A
PROGRAM FOR SCREENING DRUGS WOULD IM PROVE THE EXISTIWG CotlDITIOW It> THE PLAtlT.
CI HAS tl0 ADDITIOtlAL ItlFORtlA TIOW.
COIISTR.
DEPT.
CONCERN.
CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.
~p 0
.EREtlCE ECPS132 J-ECPS13ZC
- -QUEWCY REQUEST ISSS RHH
"=GORY:
thP thGT.
8 PERS.
ISSUES TEtltlESSEE
~
LEY AUTHORITY OFFICE OF NUCLEAR POllER EthPLOYEE COtlCERH PROGRAth SYSTEth (ECPS)
EHPLOYEE COtlCERtl ItlFORthATIOtl BY CATEGORY/SUBCATEGORY SUBCATEGORYi 716 ADEQUACY OF DRUG TESTItlG PROGRAth PAG 5.
RUtl TIthE - 10:04:39 RUtl DATE 03/10/87
')tlCERtl HUtlBER CAT S
H SUB R PLT CAT D
LOC 1
REPORT APPL 2 SAF RELATED BF BL SQ HB HISTORICAL COtlCERtl REPORT ORIGIN COtlCERtl DESCRIPTIOtl REF.
SECTION t
CAT tlP SUBCAT 714 1-86-013-00301 T50275 thP 71601 tl HBtt 1 tl H
H tl 2
HA tlA tlA HA QTC A SPECIFIC EthPLOYEE (tlAtlE KttOHW) IS Atl ALCOHOLICp ILLITERATE, AtlD IWCOthP ETENT.
tlUCLEAR PONER COtlCERH.
CI H
AS WO FURTHER IHFORMATIOW. 071-00101 lhP 71il01 H HBtl 1 tl tt tl N
T50168 2
WA tlA tlA tlA
'85-081-01001 MP 71<i01 tl llBtl 1 tl tl tl tl T50237 2
WA HA WA tlA
-85 065 00201 IH 60ii00 S
BFtl I tl tl tl H
T50159 2
02 thp 71601 S BFtl 1 tl tl tl tl 2
HA WA tlA WA 03 QA 80209 S BFtl 1 Y tl tl tl 2
tlO NA tlA WA 23 CONCERNS FOR CATEGORY thP SUBCATEGORY 716 QTC QTC CI REPORTED THERE IS WIDESPREAD DRUG USE AtlD SALE OF DRUGS ON SITE.
CI SUGGESTED TVA PERFORth URIWAWALYSIS T ESTS OH ALL TVA EfhPLOYEES (ItlCLUDItlG ALL thAtlAGEt1EtlT) llITH tl0 PRIOR llARtlI tlG GIVEN TO EthPLOYEES.
CI FURTHER S
UGGESTED URIWAtlALYSIS TESTS BE GIVEtl COHTItlUALLY Otl A RAttDOth BASIS llITH WO PRIOR HARHIHG.
NUCLEAR POllER COW CERt(.
(DEPT.
KtlOHW TO QTC AHD HITHH ELD TO NAIWTAIN CotIFIDEHTIALITY).
C I HAS HO FURTHER ItlFORHATIOtl.
tl0 FO LLOllUP REQUIRED.
CI STATED THAT SEVERAL llELDIHG IHSPE CTORS STAYED HIGH Otl POT DURING THE SHIFT.
CI DECLINED TO PROVIDE AtlY A DDITIOHAL IHFORHATIOH.
COHSTRUCTIOH DEPARTHEHT CONCERtl.
tlO FOLLOW UP R
EQUIRED.
DURItlG SUththER 1983 OUTAGE AT BRONtlS FERRY> C/I OBSERVED ISI ItlSPECTORS
(
WANE Ktl01ltl) Itl BASE LItlE GROUP CONIW G
TO HORK DRUtlK OR EXTREthELY HUNG OV ER.
C/I FEELS THIS SITUATIOtl CASTS DOUBT OH THE IHSPECTIONS PERFORtlED B
Y THESEISI ItlSPECTORS.
SUPERVISOR 0
F GROUP (WANE KWOlltl)p ALSO A HEAVY D RIHKERp ALLOllED THIS TO GO Otl.
COtlS TRUCTIOtl DEPT.
CONCERN.
Ct'I NOULD W
OT PROVIDE AWY ADDITIOtlAL SPECIFICS.
tl0 FOLLOHUP REQUIRED.
COtlCERHS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUthBER.
ATTACHHENT 8 DRUGS List of Concerns by Issue This Subcategory Report
{71400) addresses 23 employee concerns about the use and control of drugs at Watts Bar Nuclear Plant.
These concerns raised three issues, as outlined below.
71401 Adequacy of Drug, Testing Program EX-85-030-001 EX-85-117-004 I-86-111-BFN I-86-112-SQN IN-85-004-004 IN-85-041-002 IN-85-294-003 IN-85-408-001 IN-85-473-001 IN-85-551-001 IN-85-558-001 IN-85-663-004 IN-85-750-002 IN-85-871-001 IN-85-947-X09 IN-86-082-001 IN-86-293-001 WBH-86-013-003 WI-85-071-001 WI-85-081-010 XX-85-065-002 71402 Abuse of Employee Assistance Program IN-85-272-005 71403 - Legality of Random Testing IN-85-954-002 Page 1 of 1
t
ATTACHMENT C Su ortin Documents 1.1 TVA Code VIII, HEALTH SERVICES 1.2 TVA Instruction III, ALCOHOL AND DRUG ABUSE 1.3 Edison Electric Institute Guide to Drug and Alcohol/Fitness for Duty Policy Development, 1985 1.4 Informal memorandum, from L. 0. Holliman to C.
C. Mason, dated January 13, 1986 1.5 Nuclear Power, Alcohol and Drug Screening Program Procedure 0905,01.04 1.6 Memorandum from L, O. Holliman to C.
C. Mason, dated January 17, 1986 (L0786001109530) 1.7 Medical Services, Standardized Procedures for Employee Assistance Program (EAP) Monitoring of Nuclear Power Employees After A Positive Drug Screen 1.8 NUMARC Commitments on Fitness For Duty as presented by memorandum from Jack T. Pate, INPO, to James P. Darling, dated November 20, 1984 1.9 WBN Standard Practice, WB2.2.3, Section C, "Drug Awareness Program" Interviews 2.1 Dr. Richard K. McGee, Chief, Health Counseling and Rehabilitation Branch, Division of Medical Services 2.2 L. O. Holliman, Chief, Personnel Staff, Office of Nuclear Power 2.3 Cal Bailey, Employee Assistance
- Program, Coordinator, Division of Medical Services 2.4 Michael R. Tuosto (phone interview), General
- Manager, Personnel and Equal Opportunity, Public Service and Gas Company 2.5 Richard Gutekurst (phone interview), Staff Attorney, TVA, Office of General Counsel 2.6 Charles Kline, Personnel Officer, VBN Construction, Office of Employee Relations
a