ML20199F424
| ML20199F424 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/17/1986 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| L-86-248, NUDOCS 8606240324 | |
| Download: ML20199F424 (5) | |
Text
4 4J.
P.O. BOX 029100 MI AMI, F L 33102 FLORIDA POWER & LIGHT COMPANY June 17, 1986 L-86-248 l
I i
i James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
- U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Partlow:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Fitness for Duty Policy Development We have reviewed your letter dated May 14, 1986, and the enclosed Inspection Report 50-250/86-23 and 50-251/86-23, regarding the Fitness for Duty policy at FPL and the EEI guide in this area.
e FPL has taken an active role'in the area of Fitness For Duty to ensure a drug free environment at our nuclear plants.
The following is a summary of prior actions pertaining to program development:
A.
FPL has taken a pro-active role in this area even prior to the NUMARC commitment to the NRC in 1984.
The following are some of our early actions in the area of Fitness For Duty:
Power Plant Aberrant Behavior Evaluation Form (1980)
Psychological Evaluation (MPI) For All Operators Entering the Operator Career Path (12/82)
All Supervisors Trained In Drug Awareness (1982-83)
Drug Testing of All FPL Applicants (since 10/83)
Employee Assistance Program - EAP (7/84)
FPL Drug Policy (7/84)
Contractor Drug Policy (7/84)
B.
Our Fitness For Duty program was enhanced in 1985 to i
include formal procedures,
- training, and a behavior observation program.
Training was completed by 7/1/85.
i New supervisors are being trained and requalification training will be done on a 2 year cycle.
t pp 8606240324 860617 PDR ADOCK 05000250 g
G PDR PEOP,LE.. SERVING PEOPLE
James G. Partlow June 17, 1986 Page 2 C.
Although it was felt that the FPL FFD/EAP met the EEI Guide and any regulatory requirements, a FPL Fitness For Duty Quality Task Force (FFD-QTF) was organized in October 1985 to critique the Fitness For Duty program for potential enhancement.
Recommendations for these enhancements are currently being evaluated.
Enclosed is a response addressing each of the seven significant inspection findings in the NRC inspection report, which provides the current status of related FPL actions.
As you will note, the issues identified by the NRC had been addressed by the FFD-QTF prior to the NRC evaluation, and appropriate actions have either been taken or are under current evaluation for implementation.
We appreciate the NRC's recommendations and assure you that we are fully committed to appropriate implementation of the EEI Guide.
While many enhancements are being implemented, we feel that we have met the EEI Guide and NUMARC Fitness for Duty Program elements.
With respect to supplemental program elements not contained in the EEI Guide, as you can appreciate, these involve difficult policy and legal questions which are currently being reviewed by FPL.
If you or your staff have any questions concerning this report, please contact me or Mr. R. E. Habegger at (305) 552-3627.
Sincerely, C
W Group Vice President Nuclear Energy C0W:bg/2:031 Enclosure h
[ -...
FPL FITNESS FOR DUTY (FFD) RESPONSE NRC INSPECTION REPORT 50-250/86-23 and 50-251/86-23 The following is the FPL response to the seven significant inspection findings (pg. 2) on the above inspection.
An FPL Fitness for Duty Quality Task Force (FFD-QlF), as referenced in the report, was organized in October 1985 and was responsible for evaluating the existing and revised FFD/EAP programs.
All items evaluated have been addressed by the FFD-QTF through a detailed analysis of the EEI Guide on Fitness For Duty:
FINDING 1: The written policy does not incorporate all of the important features described in the EEI Guide, i.e.,
many policies and practices are unwritten, offsite and off-duty situations are not covered, and alcohol abuse is not addressed.
Written policy only covers onsite/on-duty drug involvement.
RESPONSE 1: Although FPL's written policy statement on FFD is not comprehensive, as implemented through the Fitness for Duty Manual, supervisory training and current policies and practices (some of which were acknowledged in the NRC evaluation), the FPL program addresses all of the features of the EEI Guide.
The FFD-QTF was in existence at the time of the NRC inspection and has recommended that a comprehensive policy statement entitled " Fitness for Duty" will replace the several policy statements now in effect.
FINDING 2: Supervisory training and awareness appears adequate.
RESPONSE 2: While your finding states that supervisory training and awareness were adequate, it is worth noting that after the training was completed on 7/1/85, new supervisors were and have been trained.
Requalification training of all supervisors is planned for 1987 and will be conducted on a 2 year cycle.
FINDING 3: Employee awareness of the Fitness For Duty program needs improvement.
RESPONSE 3: As acknowledged in the inspection report, FPL has employed a number of methods to inform employees of the FFD program and EAP, including:
1.
Initial EAP briefing of all employees in late 1984, including distribution of a booklet describing EAP.
2.
Briefing of all new employees on FFD/EAP since mid-85 as part of the orientation
- program, including distribution of program materials.
. 3.
Briefings on FFD/EAP at nuclear plant employee meetings conducted at Turkey Point on July 30 and August 7-8, 1985 and at St. Lucie on July 24-25, 1985, including distribution of program materials and acknowledgement by attendees.
4.
Occasional discussion of FFD/EAP at employee monthly safety meetings.
5.
Articles in the employee newspaper, such as:
(a) 1984 article on EAP, stressing the importance of a drug free environment and a phone number that the employee or spouse could call for additional information.
(b) 1986 article on
- FFD, stressing again the importance of program knowledge and a drug free environment.
6.
Video tape by Nuclear Energy Group Vice President presenting management support and expectation of compliance.
FINDING 4: Chemical testing of body fluids is used for pre-employment and for cause; random or periodic testing are not conducted.
RESPONSE 4: The following actions are a
result of the FFD-QTF evaluation:
1.
A survey of all nuclear utilities on EAP and drug testing programs was completed in May 1986. Additional recommendations for improvements in the FPL program are currently being evaluated.
2.
Due to the ramification of any potential changes in the current scope of the chemical testing program, we are currently exploring our legal alternatives in this area.
The program is currently limited to testing for applicants and for cause.
3.
SmithKline Clinical Laboratories and the nuclear plant hiring locations have been audited by our QA group indicating adequate performance (5/86).
4 FINDING 5: There are no follow-up features in the Employee Assistance Program to determine if there should be restrictions on safety-related duties and to verify continued rehabilitation.
RESPONSE 5: With respect to restrictions on safety-related duties of individuals undergoing rehabilitation and verification of continued rehabilitation, as the NRC is aware the situation is complicated by the necessary confidentiality of the EAP program.
An evaluation is made on a case-by-case basis regarding limitation of activities as a result of FFD/EAP issues.
- However, we are implementing an enhanced computer system to track and follow-up on individual cases under the FFD and EAP programs.
This system will be centralized and will track both employees and contractors at both sites.
FINDING 6: There are no proactive measures that would provide evidence of onsite drug problems before they would be manifested in observable aberrant
- behavior, i.e.,
no random or periodic chemical tests of body fluids, no searches of the workplace, no mechanism for employees to discreetly express concerns, and investigations are only reactive.
RESPONSE 6: As descr. Sed in Response #4, a number of additional pro-active measures are being considered.
These include such issues as randem chemical testing.
FINDING 7: EAP program statistical data are very limited, and neither EAP nor FF0 data have been analyzed.
RESPONSE 7: As described in Response #5, an enhanced computer system is presently being implemented.
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