ML20064A964

Submits Summary of Util Position Re Unresolved Item in Audit of fitness-for-duty Program at Catawba

ML20064A964
Person / Time
Site:	Catawba
Issue date:	09/25/1990
From:	Gill R DUKE POWER CO.
To:	Jabbour K NRC
References
NUDOCS 9010030126
Download: ML20064A964 (2)

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Septenbe" 26, 1990 h 1acsid.la:

301/492-0259 E

Mr. K. Jabbour NRC'ProjectManager U. $. Nuclear Regulatory Commission 4

. Washington, DC-20555 RE:. ' Unresolved Issue

Dear Mr. Jabbour:

< The lfollowing brief explanatien is being submitted.in response to your request during our telephone call that we provide you with e summary of our.

L position with respect to the NRC Staff's-unresolved item arising out oflits L

, audit si the Company's Fitness-for Duty program as implemented.at the Catawba Nuclear Station.- As we understand it,- the unresolved ites: arises out of what-

has ' been characterized as the. Company's- _" treatment of L self-referrals as positive tests."

While such 4-chars:terizaticn may be -ha ipful to = some in o

understanding the operation of the Conipany's prcgram, it say also'be somewhat misleading.

The Company, which has'had-a dru3 screening program inl place I

since 1986, affords an employee with a drug problem one. opportunity for L

rehabilitation..

Only one op employee comes to the Company'portunity is afforded : regardless of howe the s Emplo.ies Assistance Program - whether as the result'of a gositive drug test or through a self-referrel.

A self-referral.

thus' " counts as an employee's char:e for rehabilitation.

- A subsequent positive test will result in the enployee's discharge just as a 1second

. positive test will result in the discharge of an employee who-has come to the EAP as the result of a positive test.

It is in this sense that a

,;b "self-referral is ~ treated as. a positive."

B) contrasti in _ response to a wm

" suitable inquiry" frosa prospective employer, an onployee-who has

$8' self-referred -is not reported as haring had - a-positive test.

It islour

'SS position ~that this approach is in compliance with the Commission's

oso Fitness-for-Duty rule and that-our program both complies.with the rule and

.g provides reasonable assurance that the public health and safety are protected.

30 Se have, however, reviewed our progran, with particular attention being paid

-to the self-referral issue. As a resalt of this review we have elected to amend our program to permit the possibility of one additional opportunity for og rehabilitation upon a self-referral, provided the individual self-referring has not'previously had a positive teet..

Individuals self-raferring will, of A G ] M-

/.

u i e L

~.. _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

I Mr. K. Jabbour-

- Page 2:.

September 26,1990 course, still be expected to coopera':e with the Employee Assistante Program in the rehabilitation effort and a subsequent positive test may be considered a.fallere to cooperate. As noted above, our position is that our program is and has been in full-compliance with the applicable statutory and regulatory requirements.

Very truly yours.

j DUKE P Y l

'f.u-5 R

f obert L. 41 1 Technical System Manager Re'ulatory Comp 11ance

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