ML20212P460
| ML20212P460 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/24/1986 |
| From: | Tom Ryan NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Rosano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20212P163 | List: |
| References | |
| FOIA-87-90 NUDOCS 8703160117 | |
| Download: ML20212P460 (15) | |
See also: IR 05000424/1986091
Text
.
24 September 1986
ISPUT T0: Richard P. Rosano
Operating Reactor Programs Branch
Division of Safeguards & Inspection Programs, IE
FF.CM: Thomas G. Ryan
Reactor Risk Branch
Division of Reactor System Safety, RES
S'.5 JECT : IhPUT TO REPORT ON THE ADEQUACY OF V0GTLE, GA GENERATING STATION
(GEORGIA POWER) FITNESS FOR DUTY PROGRAM
.
Tre purpose of this document is to bring together information and data derived
through employee / consultant interviews and program documentation reviews
of fitness for duty programs and policies, at Georgia Power headquarters,
Atlanta, GA, and at its Vogtle Generating Station located approximately 35
t.les southeast of Augusta, GA. The material presented in this document is
irtended to support preparation of Alcohol-Drug Program Inspection Report
SC-42/86-91.
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- cocument is divided into three sections. The first section presents a
- ilation and discussion of employee and contractor interview data. The
.6 section presents findings concerning the utility's employee assistance
-pur,itive) element to its fitness for duty program, as implemented at the
.. .:e site. The third section presents findings concerning fitness for duty
.
frectack for monitoring program effectiveness and serving as a basis for making
p ogram revisions, j
1
EPPLOYEE/ CONSULTANT INTERVIEWS
During the inspection team (Rosano, Ryan, Brownlee, Tobin) visit to the Vogtle
site, structured interviews were conducted, on a one-to-one basis, with a. total
8703160117 870311
BAUMAN87-90 PDR
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cf 54 Georgia Power and contractor supervisors and employees. Additional, non-
structured interviews were conducted with fitness for duty program managers,
censultants, ano law enforcement officers. Information accuired from fitness
for duty program manager and consultant interviews is discussed in the
following sections of this document. Interview data collected from. law
enforcement agencies is not addressed herein since the undersigned was not
involved in their collection.
As stated above, structured interviews were conducted with 54 Vogtle site
personnel (31 Georgia Power and 23 contractor) utilizing the interview form
attached as Enclosure 1). Completed interiew forms accompany this document as
a separate package). Structured interviews were conducted as follows. Each
interviewee was initially asked to describe the site fitness for duty program
as he/she understood it. The purpose of this non-prompted segment of the
interview was to obtain an unfettered indication of interviewee knowledge
vis-a-vis program guidelines (published in August 1985, by the Edison Electric
Institute [EEI], and sanctioned by the Commissioners). Next, interviewees were
asked about any EE1 guidelines omitted earlier to obtain a prompted indication
of their knowledge when the guideline was brought to their attention. The
third step in the interview process was to obtain from each interviewee an
indication of how he/she had obtained information on the program
(briefings / training, literature, public notice, word of mouth). The fourth
and final step in the interview process, was to obtain from each interviewee
-, coments (pro, con) on the program and recommendations for improvements. ,
'-t.le 1 presents tallies cf interview results. For this purpose interviewees
,3 rc divided into eight groups as indicated by the Row A of Table 1. Group (1)
J.uces Georgia Pcwer Employees managing the Vogtle site; Group (2) includes
L Power employees serving as first-line supervisors at the Vogtle site;
r.rcu;. (3) includes Georgia Power non-supervisory employees assigned to the
B' .atle site. Groups (4), (5) and (6) include contractor personnel supporting
- r e operatior.s side of the Vogtle site. Group (4) consists of managers; Group
.
(5) first-lina supervisurs; and Group (6) non-supervisory personnel. Groups
(7) and (E) include first-line supervisors and non-supervisory personnel
respectivel) who are employed by contractors supporting the construction side
of the Vogtle site. The last column in Row A indicates total number of
.
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TABLE 1
Tallies of Vogtle Persernel Interview Responses
,
Row Entries :
A 3 Vogtle Groups Ops Contr Groups Const Contr Groups Row Totals
'
'(1) (2) (3) (4) (5) (6) (7) (8)
5 Written Policy: .
hP 1 10 14 2 1 4 3 5 40
.
,
P 1 4 - - -
2 -
4 11
C Top Management Support:
i;P ' 2, 5 1 2 -
1 - -
11
P, .i 1 9 12 -
1 4 3 7 37
D Effective Policy Communication:
NP L1 5 4 1 -
2 1 1 15
P 1 6 8 -
1 2 2 5 25
u
E Behavioral Observation Training for Supervisors:
NP 1 1 - - - - - - 2
- .0 P -
12 2 - - - 1 2 17
. :,
7 j .- F Policy Irnplementation Training for Supervisors:
!"- gp y1 F 4 2 - - - - -
7
3 4 22
'
P. - 8 6 -
1 -
T-
G Lnion briefing: i
NP 1. 1 -
1 - - - -
3
P 1 - 2 - - - 3 3 9
f ontractor Notification:
' n- g,; 1 - - - - - - -
1
P -
2 5 -
1 - 3 3 14
, .;j ' 1 Law Enforcement Licison:
II hP 1 - - - - - - - 1
8
ld P - 4 1 - -
1 2 -
Y7 J Chemical Testing of Body Fluids:
O NP 1 13 7 2 1 3 1 5 33
-
P 1 1 4 - -
2 2 4 14
.1 -. . . - _ . -. . .. -- .-, _ . .
-
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TABLE 1 (cont'd)
Tallies of Vogtle Personnel Interview Responses
Row Entries :
-A Vogtle Groups Ops Contr Groups Const Contr Groups Row Totals
(1) (2) (3) (4) (6) (6) (7) (8)
K Employee Assistance Programs:
NP 1 3 2 1 - - - -
7
P 1 10 5 - - -
1 -
17
L Confidentiality:
NP 1 5 - - - - - -
6
P 1 7 8 - - -
3 2 21
h Employee Reporting Systems:
hP 1 3 2 -
1 2 -
2 11
P 1 7 10 - -
3 3 5 29
h Searches:
hP 1 3 - - -
1 -
1 6
P 1 11 14 -
1 5 3 7 42
0 Briefings / Training:
P 1 11 8 2 1 3 3 8 37
"
"
F Literature:
P 1 9 8 1 1 4 3 8 35
Put,lic Notice:
P 1 4 2 - -
1 -
1 9
- rd-of-Mouth
1- - 6 7 1 -
3 3 7 29
5 f.nowledge of Others Programs:
P -
5 N/A 2 1 N/A 3 N/A 11
i Liaison with Other Programs:
P -
2 N/A - 1 N/A 2 N/A 5
U Total Interviewees in Group:
3 14 14 2 1 6 3 11 54
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respnses across groups for Rows B through U. Rows 6 through K indicate the 10
EEI suidelines for Alcohol-Drug Programs. The indicators NP and P associated
with each row indicate non-prompted and prompted interviewee responses. Rows L
thrcugh N indicate additional program elements determined important by NRC-IE
(cor.fidentiality, employee reporting systems, searches). Rows 0 through R
indicate program communication media. Rows 5 and T indicate Georgia Power and
contractor managers and supervisors knowledge of other party programs, and
means for coordinating alcohol-drug related incidents involving personnel
acrcss utility / contractor lines. Finally, Row U indicates total number of
interviewees in each group. Column / row (cell) entries indicate the number of
interviewees responding (non-prompted, prompted) to that iten.
No attempt will be made here to do a comprehensive interpretation of interview
data contained in Table 1. That is left to team members responsible for
writing up specific EEI/NRC-IE guideline-related sections of the report.
Rather, some general observations are made concerning the data. First,
interview data represent just one medium for collecting information on the
Georgia Power /Vogtle program. Second, the interview sample size (31 of
approximately 1600 Georgia Power employees onsite [2%], and 23 of approximately
11,000 contractor employees onsite [less than 1%)) is adequate for pattern
analysis, especially given the stratified random sampling technique used to
achieve the sample. Third, Table 1 (Rows B, C, D. J, M, N) entries indicate
thi.t the more punitive aspects of the program are much better known to
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interviewees of all groups when compared with its non-punitive aspects (Row K).-
Finally, it is clear from the interview data that both Georgia Power and
tcrtrcctor emp1 gees at the Vogtle site are well aware of the utility's
"ive policy regarding alcohol and drugs (Row B).
.
ht k E presents a listing of interviewee value judgements concerning the
tr T an. In genercl, they tend to support Table 1 data, and findings gained by
mears other than the structured interviews.
EMPLOYEE ASSISTANCE ELEMENT (EEI Guidelines No.10)
A detailed review of the Employee Assistance element of the Georgia
Power /Vogtle Fitness for Duty Program was undertaken by the investigation team.
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TABLE 2
Interviewee Comments on Vogtle Fitness for Duty Program
Positive Coments Comenting Group and: Number
1. Feel comfortable with program. (Group 1, 1)
2. Have seen improvement in plant atmosphere. (Group 1,1),(Group 2,4)
(Group 3, 1), (Group 8, 5)
3. have gotten alot out of supervisor training. (Group 2, 2)
4. Appreciate clear punitive policy on alcohol- (Group 2,1), (Group 3, 3),
drugs. (Group 4,1),(Group 5,1),
(Group 6,1),(Group 7,2)
(Group 8,2)
5. The program is effective. (Group 2,6),(Group 3,1)
6. The chemical testing is crucial to program. (Group 2, 1)
7. Appreciate company support of program. (Group 3, 1)
8. EAP is a good aspect of the program. (Group 3, 3)
9. I believe in the program. (Group 3,3)
10. I believe that the program is managed (Group 4,1)
f airly.
11. I support chemical testing. (Group 6, 1)
--
hegative Coments Comenting Group and Number -
I did not receive behavioral observation (Group 2,4),(Group 4,1)
training.
. have not been informed on EAP. (Group 2, 1), (Group 3, 1)
' s.as not tested for alcohol-drug when I (Group 2, 1)
cent to wcrk at Vogtle.
4 Georgia Power has not done a good job of (Group 2,1)
communicating the program to employees.
5. Vogtle does not do enough chemical testing. (Group 2, 1), (Group 4, 1)
6. Vogtle does not conduct enough searches. (Group 2, 1)
7. Chemical tests are not accurate and some- (Group 2, 1), (Group 5, 1)
times convict innocent people. (Group 6, 1)
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Negative Coments (cont'd) Commenting Group and Number
8. Program emphasized drugs too much over (Group 3, 3)
alcohol.
9. Confidentiality is not maintained. (Group 3, 1)
10. Chemical tests are not accurate. (Group 3,1) .
11. The call-in hotline is abused. (Group 3,1),(Group 8,1)
12. Program is too hard on alcohol abusers. (Group 3,1)
13. There is not enough training on the (Group 7,1)
program for contractors.
14. Program is too hard on both alcohol and (Group 8,1)
drug abusers; they should be given at least
a second chance.
Recomendations Recomending Group and Number
1. That Vogtle conduct periodic random (Grcup 2,1), (Group 3, 2)
chemical tests for alcohol and drugs. (Group 4,1),(Group 7,1)
(Group 8, 3)
2. That Vogtle increase training on all (Group 7,1),(Group 8,1)
aspects of the program.
3. That more information be provided on EAP. (Group 3,2)
4. That offenders be given a second chance. (Group 8,1)
5. That searches be conducted of persons and (Group 6, 2), (Group 7, 1)
-- autos both entering and leaving '.he plant. (Group 8, 1) ,
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Information and data were gathered through documentation reviews (accompanying
this document as a separate package), structured and unstructured interviews
with utility and consultant personnel, reviews of actuarial data on employee
assistance cases since Janucry 1986 (Enclosures 2 and 3), and a detailed review
of an audit of the VoStie Prcgram conducted by Bensinger, Dupont & ssociates
(April 1986). It is concluded from these reviews that the employee assistance
element of the program is well documented and is in general conformance with
EEI Guideline No.10 (except for clear policies concerning Return to Duty, and
Recidivism). It is also concluded, regarding existing policy in this area, j
that the Vogtle program does not fully meet the intent or spirit of EEI
Guideline No. 3 (Policy Communication).
With regard to policy issues of Return to Duty and Recidivism; it is concluded
based on unstructured interviews with Vogtle program coordinators and medical
providers, that clear policy governing these issues does not exist. Return to
Duty refers to granting unescorted access to protected and vital areas of an
cperating plant to employees undergoing treatment for alcohol or drug abuse.
Vogtle program policy is required regarding the decision process to be followed
jointly by the employee's supervisor, treatment facility professionals, etc.,
in devising a return to duty " plan and schedule" which takes proper account of
public health and safety. Clear policy is also required to deal with incidents
cf Recidivism, frequently occurring in these cases, after the employee's return
to duty (cases where the employee requiring remedial treatment). How many
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relapses should an employee with access to vital areas of an operating plant be"
e' forded?
-l regard to policy communication issues; it is concluded based on structured
_
e views with Georgia Power and contractor employees, and reviews of
c.urial data on employee assistance services to Vogtle and the Bensinger, et.
?. aWit of the program, that a non-punitive or preventive apprpaqb..to
alcohol-drug abuse may not be a high priority,at Vogtle_. Data from structured
'
intesiEGTab'l'e 1, Row K) indicate that only 6 of 31 Georgia Power employees
were able to discuss the content of employee assistance policy regarding
alcohol-drugs, without being prompted. Seven of 31 were not able to discuss
same even with prompting. An interview with the medical provider suggests a
potential lack of understanding for the safety implications of unescorted
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access to protected and vital areas of an operating nuclear pcwer plant. A
comparative review of 1986 actuarial data on accusations of alcohol or drug
abuse invoking punitive measures at Vogtle (Enclosure 2), with data on those *
invoking non-punitive or employee assistance measures (Enclosure 3), indicates
the following. Between January and the end of August 1986, 510 repgrted
incidents involving alcohol and drugs were experienced at Vogtle. However,
during the period, no Georgia Power personnel assigned to the Vogtle site were
referred, because of alcohol or other drugs, to the employee assistance
pro 5 ram. During this same period 19 alcohol-drug referrais were made
throughout Georgia Power, or approximately 11% of the total referrals.
Finally, the Vogtle program audit completed by Bensinger & Associates (April
1986) does not even address its employee assistance elements. A copy of the
Bensinger audit is included in the September 15, 1986, Georgia Power handout to
the NRC investigation team.
In sumary, it is concluded that clear policies regarding employee Return to \,
Duty and Recidivism should be established to bring Vogtle into full compliance j
with EE1 Guideline No.10, and that a vigorous effort is required at Vogtle to
comrunicate employee assistance policies and programs to affected employees and
to establish closer comunication with medical providers on the safety-related
nature of the work environment (for full compliance with EEI Guidelines No. 3,
Effective Policy Comunication)..
- SYSTEM FEEDBACK ,
. 'O cugh not explicitly stated in the EEI guidelines, the NRC investigation
l n.rs feels that collection and interpretation of actuarial information and
to the operability of a fitness for duty program are crucial to program
l
. tiveness. In that regard, investigation team members met with Vogtle
- eg lyees tracking several program indicators suggested by the Bensinger &
Asscciates audit. The investigation team lauds the Vogtle effort to collect
i
cnt interpret such Cata, however, has three concerns regarding their possible
use. First, neither correlational or cause and effect relationships between l
indicatur data being collected, and program elements, have been established.
I
If these indicator data are to be used successfully as linchpins for prcsram
modifications, an understanding of the aforementioned relationships is \
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necessary. Second, graphing of indicator data such as number of employee
allegations, employee assistance case-load or positive urinalysis testing, on a
month to month basis, can of ten be misleading with regard to program i
effectiveness and trends. Careful consideration should be given to data
presentation so as not to mislead data users, i.e., plant and utility
management. Third, many of the decisions regarding program element additions,
terminations and revisions will require significant funding. It is important,
therefore, that these decisions are taken based on real need. Actuarial data
collected to support decisions concerning the Vogtle Fitness for Duty Program,
in the area of alcohol-drugs, should be subjected to quantification using
appropriate inferential statistical techniques.
4 , ' td
Thomas G. Ryan
RAB-DRSS-RES
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Enclosures: As stated
cc: Virgil Brownlee, Region II, without separate packages
-. William Tobin, Region II, without separate packages ,
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FITNESS FOR DUTY INTERVIEW FORM
EMPLOYER: JOB TITLE:
INTERVIEWEE: RO/5RO/ Contractor /Other
First name only Utility / plant / contractor
ALL INTERVIEWEES: Are you aware of the utility / company fitness for duty procram?
Yes No
ALL INTERVIEWEES: How would you describe the utility / company fitness for duty program?
Management Support Policy
Mentions: Written Policy
Communication "@
Yes/No Yes/No
Beh Obsv Training Policy Implemen- Union Briefing
Supervisors Yes/No tation Supervisors Yes/No Yes/No
Contractor Law Enforcement Chemical
Notification Yes/No liaison Yes/No Testing Yes/No
Employee Assist Employee Reporting Searches
Programs Yes/No System Yes/No Yes/No
Confidentiality Other Elements (Description
Yes/No E'
Yes/No S
)
S
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NOTES: .,
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(Before leaving this ites, each program glement not mentioned extemporaneous 1y by the interviewee should be
raised by the interviewer to determine M it is unknown by the interviewee or merely missed in his/her
non-prompted description.)
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ALL INTERVIEWEES: How did you come by your knowledge of the utility / company fitness for duty program?
Briefing / training Literature Public Notice Word of mouth
UTILITY / CONTRACTOR SUPERVISORY /hANAGEMENT PEPSONNEL ONLY: Are you aware of a utility / contractor (s) fitness for
duty program (s)?
Yes No Don't know:
Other
(e.g., identification as user, hotline, allegation)
ALL INTERVIEWEES: How adequate do you feel the utility / contractor fitness for duty program is for achieving an
alcohol / drug free workplace?
NOTES:
UTILITY / CONTRACTOR SUPERVISOR / MANAGEMENT PERSONNEL ONLY: How is liaison accomplished between your program and
the utility's/ contractor's?
"
NOTES:
1
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. Enclosura 2
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EMPLOYEES REPORTED
PEOPLE
f hOTHER
1so gnoru~ecms
.
125
100
}
75 -
-
~
50
dillbli
JAN FEB HAR APR HAY
1986
JUN JUL AUG'
,
i
0
-. - - - - , - - -~ , , , .
.c.. - - , --
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o Enclosure 3
GEORGIA POWER COMPANY
Employee Assistance Program Participation
Due to Alcohol and/or Drug Problems
GPC Total Vogtle Vogtle Construction
A D B A D B A D : 8
1985 37 11 18 0 0 1 1 0 2
.__________________________________________________________________________________________
January '86 4 0 1 0 0 0 0 0 0
February 1 0 5 0 0 0 0 0 0
March 1 0 0 0 0 0 0 0 0
April 3 4 2 0 0 0 0 0 0
May 1 3 8 0 0 0 0 0 0
June 5 1 0 0 0 0 0 0 0
July 1 4 1 0 0 0 0 0 0
August 1 2 2 0 0 0 0 0 0
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A. Alcohol
D-Drug
B-Both Alcohol and Drug
09-19-86