ML20207P494
| ML20207P494 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/12/1987 |
| From: | Conway R GEORGIA POWER CO. |
| To: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| GN-1318, NUDOCS 8701160189 | |
| Download: ML20207P494 (8) | |
Text
Georgia Power Companv f*
333 Piedmont Avenue A"anta Georgta 3030d
' e-Telephone 404 526 6724 Mad.ng Address-Post Offce Box 4545 Atianta, Georgta 30302 Jhnuary 12, 1987
- tw soutnern sectre syuern R.E.Conway Senter Vee Prescent United States Nuclear Regulatory Commission File: -X7BG10 Office of Inspection and Enforcement Log:
GN-1318 Division of Inspection Programs Washington, D.C.
20555
Reference:
Vogtle Electric Generating Plant - Units 1 & 2, 50-424, 50-425; NRC Audit - Vogtle Fitncss for Duty l
Inspection Report 50-424/86-91 Attention: Mr. James G. Partlow:
By letter dated November 13, 1986, you provided us with the inspection report prepared by the NRC Team reviewing the Vogtle Fitness For Duty. (FFD)
Program.
We have reviewed the team's comments, the current Vogtle Program, the Edison Electric Institute Guide, have compared the Vogtle Program with programs offered by other utilities, and have sought the advice of FFD consultants and experts.
Based upon these reviews, we offer the attached information in response to the NRC team inspection report.
Georgia Power Company is committed to maintenance of a drug and alcohol-free work environment.
We will continue to monitor the program in order to make sure that it is effective in meeting our commitnent.
While we do not meet verbatim compliance with every provision of the EEI Fitness For Duty guidelines, we have confidence in the effectiveness of our program.
Hopefully, the information presented has been responsive to issues raised in Inspection Report 50-424/86-91.
As always, if l
I can provide you with any additional information or assistance, please do not hesitate to contact me.
Very truly yours, R. E. Conway Senior Vice Pre ident and Project Director REC:jl 7
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1.
TRAINING:
The audit team noted.that:
" Training of supervisors in behavioral observation and policy implementation was found-deficient in several areas.' For example:
(a)itisoffered as one-time only training, (b) not all GPC supervisors have been trained and may not be
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uncil June,1987, and (c) approximately 50% of the contractor supervisors have not been
]
trained."
When the Vogtle Anti-Drug and Alcohol Policy was revised and
. reissued ' in conjunction with the expanded urinalysis testing program in' April, 1984, every Vogtle Project supervisor was thoroughly F
indoctrinated and trained regarding both behavioral observation L
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and the Policy-and its implementation.
Turnover in the construction area, and the addition of new supervisory positions in Nuclear Operations created after April, 1984, resulted in a' number of supervisors who had not received this initial training.
These individuals -were notified of the Policy as part of the normal new-employee and/or new-supervisor orientation.
During the period June through August,1986, Project Management began planning for additional and on-going supervisory training in both the Construction and Nuclear Operations areas.
Some of this training had, in fact, taken place at, or shortly before, the time of the-NRC team inspection.
The training program began in July,1986, and is scheduled to be conducted again once during each calendar quarter in 1987.
All new supervisors will, therefore, be trained within 90 days of their date of hire and/or promotion.
Six training sessions were held in September,1986, for a total of 111 participants, and eight sessions were held in November,1986, for 275 participants, for a total of 386 supervisory participants in training during the last quarter of 1986.
Fifty-three (53) of these individuals were Nuclear Operations supervisors, with the balance being employed in the Construction area.
Nuclear Operations is also developing a special training program
' designed to ensure that its supervisors are familiar with all aspects of the Vogtle FFD Program.
The proposed program will include Policy awareness and implementation, and identification and management of aberrant behavior.
The proposed program will include a one-hour video tape presentation, four to six hours of classroom instruction, and continuous retraining.
t 6_
Page 2;
- The' one-hour - video tape presentation' will be given to all new supervisors within 90 days Mter reporting to work.
Additional-classroom instruction will be f.cheduled within six to nine months after an individua1' assumes supervisory responsibilities.
- All current Georgia Power Company Nuclear Operations supervisors will complete the four to ' six-hour training course on or before June 1987.-
Thereafter, new supervisors will receive the one-hour j
tape presentation within ninety days -and the advanced training within six to nine months after their initial assignment.
F 2.
CHEMICAL TESTING:
In the inspection sumaary, the NRC Team noted that:
"The following conditions were found in the chemical testing program: (a) contractor employees e
and.GPC employees hired before-the initiation of the program, including some who may be in sensitive positions, are exempt from the pre-employment screening: and (b) no pariodic l
or random testing is done. As a result, a number
~ f the employees have never been subject to a o
chemical test for crugs and would not be subject to testing in the future."
i-L Since April, 1984, all Georgia Power Company employees and all contractor non-manual staff employees have been subject to i
required urinalysis testing prior to beginning employment at Plant l
Vogtle.
-Beginning in January, 1985, all contractor employees in
- the Nuclear Operations Department have been required to submit to drug. screening.
Employees working in Nuclear Operations prior to
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April 30,1984, have not been subject to a drug screening test.
L Contrary to the Team's findings, each of these employees will l
be subject to possible future screens.
Each employee is subject j'
to the. provisions of the Vogtle Anti-Drug Policy, which includes provisions for supervisory directed urinalysis screening.
In the i
Vogtle procedure, a supervisor would be required to send an individual for screening if aberrant behavior is observed or if information r
is received indicating possible drug use.
l Georgia Power Company believes that the existing elements of r
l our Fitness For Duty ' Program provide adequate assurance that the individuals who have not undergone pre-employment urinalysis testing
[
at Plant Vogtle have been properly oriented, are aware of the rules regarding drug and alcohol use, and comply with those rules.
We also' feel that existing elements of our Program also negate the need for random testing.
There is no reason to believe that any of these individuals are unfit for duty, or present any risk to c
the Company's ability to safely operate Plant Vogtle.
Page 3 3.
EMPLOYEE ASSISTANCE PROGRAM:
In its report the NRC audit Team noted that:
"The EAP is inadequately stressed, particulartly as a non-punitive approach to preventing drug problems on site."
Georgia Power Company has made a considerable effort in 1982 to enhance employee awareness of the Employee Assistance Program.
In July, 1986, the Company began a major effort to improve management, supervisory, and employee understanding of the EAP.
This Program began with announcements and communications with Human Resources and Safety & Health employees, management, and union representatives regarding the EAP.
In July and August,1986, these initial communications were followed by announcements directed to employees and retirees and by separate articles on the Employee Information Board.
On October 27, 1986, another EAP article appeared on the Employee Information Board.
Georgia Power Company's Corporate Safety Department, which monitors and administers the EAP, is committed to a continuing effort l
to ensure that every Company employee is aware of EAP.
Increased attention has been given to the structure of the EAP and the relationship between EAP providers and the Project.
A special meeting was held for all EAP counselors on December 15, 1986, with emphasis on increased communication between the Company l
and the providers.
Coordination of the EAP with the Corporate Safety
& Health Department should ensure more consistent and effective l
communication with employees and more complete integration with the EAP into the general employee benefit program.
Finally, the Company's request, the EAP provider has prepared a proposal for inclusion of all contractor craft workers in the EAP.
This proposal is being given to Union business agents who administer Union " health & welfare" programs.
The Vogtle Project will cooperate with these Unions in implementation of any EAP they choose to adopt on a
member contribution basis or on a
non-contributory basis within the existing health & welfare plans.
6 Page 4 4.
REHABILITATION AND RECIDIVISM:
The NRC Inspection Team observed that:
"There is no clear policy concerning recidivism or an individual's return to duty following rehabilitation."
In order to preserve the integrity and importance of the EAP Program, Georgia Power Company does not feel that a written policy on rehabilitation is appropriate.
However, the practices currently utilized in returning individuals to work are as follows:
A.
During treatment, supervisors coordinate with the EAP provider to monitor the employee's progress and to offer appropriate assistance.
B.
After rehabilitation, tha provider is generally asked to certify that the employee has successfully completed the rehabilitation process and, if, appropriate, to provide information regarding future expected treatment and follow up. At this step, individuals undergoing rehabilitation for drug or alcohol dependency would be required to demonstrate, through urinalysis or medical testing, that they are drug-free.
C.
Job duties and work assignments are evaluated prior to return to work.
If an employee is in a " sensitive" position, he or she would be returned to a non-sensitive position for a period of time to allow for readjustment, reorientation to policies and proedures, and close supervisory observation.
D.
The employee would be counseled during this reorientation period regarding Project expectations and compliance with the Anti-Drug and Alcohol Policy, and would be advised that he or she would be subject to random, unannounced testing on a frequent (weekly) basis for the first 30 days of re-employment and on a less frequent (monthly) basis during the next six to twelve months of employment.
E.
After reorientation in a non-sensitive position, the employee can be returned to his or her normal work duties.
Supervision would be directed to observe and monitor the employee's physical appearance and work performance. Any indication of substance abuse would result in invocation of the Vogtle Anti-Drug and Alcohol Policy and immediate urinalysis testing.
Page 5 Georgia Power Company also does.not plan to establish any formal policy regarding ridivism.
Company Drug Program consultants have indicated that our Policy, which has no provision for a second change if violated, provides a clear message to employees and strong motivation for participation and success in a rehabilitation program.
At the present time, a recidivist substance abuser at the Vogtle Project who violates the Project's Anti-Drug and Alcohol Policy would be subject to termination.
Nuclear Operations management indicates that they would be prepared to permit an individual who has not been found in violation of this Policy to participate in the EAP rehabilitation program no more than two tir..es.
Construction Department management has indicated that Construction Department employees could participate in formal rehabilitation one time, based upon the advice of the Company's Drug Program consultants and EAP providers.
5.
MISCELLANE0US ISSUES:
Several other miscellaneous issues were raised in the NRC Assessment.
These
- issues, while not included as significant observations, nevertheless require response.
A.
Testing Limits:
The Team questioned the 75 nanagram cutoff for detection of marijuana and the 0.01 limit for positive alcohol tests.
Both of these limits had been reviewed by Company management, and the advice of outside consultants has been solicited.
The 75 nanogram marijuana level was selected in order to give additional assurance, particularly to participating
- Unions, of accuracy and reliability of test resuslts.
An informal survey taken at the Edison Electric Institute Substance Abuse Conference held in Baltimore, Maryland, in October,1986, indicated that approximately equal numbers of utilities tested at or above 75 nangrams and at or below 20 nanagrams.
Given that testing levels have been subject to prolonged and intense discussion and negotiation, and are known and relied upon by employees and Union representatives, Georgia Power Company will maintain current testing limits.
However, the Trending Program, described above will incorporate information concerning the presence of THC negative below the 75 nanagram level.
~
Page 6 The alcohol testing limit has been established at 0.02, rather than the 0.01 indicated in the inspection report.
The Vogtle Project Anti-Alcohol Policy prohibits an employee from reporting to work with alcohol in his or her - system at any level.
The Policy does not refer to " impairment" or "being under the influence," which are the standards utilized by the State of Georgia in establishing legal limits for DUI. _ The equipment manufacturer has assured Project management that the equipment is accurate at the 0.02% limit.
B.
Audits:
The NRC Assessment Team noted that additional audits of the Vogtle. Fitness For Duty Program had not been scheduled.
In addition 1
to routine management review, the. substance abuse committee, which was noted by the NRC Team provides a mechanism for insuring that the Program is constantly and uniformly administered and that management of the Program is consistent.
The INP0 evaluation program l
also reviews the Vogtle Fitness For Duty Program approximately every 15 months.
C.
Records and Repoets:
L l
The Audit Team noted that a prior private audit had-identified i
concerns regarding the use of data and recommended a statistical l
approach for documenting the Program success.
These recommendations have been incorporated into the Program.
The Project is implementing a comprehensive " Trending Program" l
designed to identify potential Fitness For Duty problems and enable management to take pro:npt and decisive corrective action.
The l
Trending Program incorporates accident rates, urinalysis
- rates, EAP referrals security / law enforcement reports, hotline trends, l
absentee data, and canine search reports.
This Program will allow management to react to a potential problem, particularly within l
the Nuclear Operations area.
Individuals who have not been subject to pre-employment testing will be included in the population reviewed for trend analysis.
D.
Proactive Measures:
l The Audit Team noted several proactive measures were being taken by the Vogtle Project in order to ensure that the Site remains l
drug-free and that employees are fit for duty.
l One of the task force recommendations includes formal education for employees on the dangers of drug and alcohol abuse.
This type of training has been incorporated into the formal training described above.
Additionally, the danger of drug and alcohol abuse was l
incorporated into the Employee Information Meeting held for all l
Nuclear Construction Department employees on June 25, 1986.
l Management attention will be directed to ensuring that communication i
and/or training continue to take place regarding the dangers of l~
drug and alcohol abuse.
l
Mr. James G. Partlow January 12, 1987 c:
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555
'H. G. Baker D. R. Altman L. T. Gucwa J. P. O'Reilly P. R. Bemis C. W. Hayes i
G. F. Head J. A. Bailey G. A. McCarley P. D. Rice
- 0. Batum R. W. McManus R. H. Pinson G. Bockhold Sr. Resident (NRC)
C. W. Whitney C. E. Belflower C. C. Garnett (0PC)
B. M. Guthrie J. F. D'Amico J. E. Joiner (TSLA)
D. E. Dutton W. D. Drinkard D. Feig (GANE)
R. A. Thomas E. D. Groover NORMS Melanie A. Miller
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