ML20214B773

Corporate Guidelines Re Conduct of Employees.Related Documentation Encl,Including Supervisory Guidelines for Administering Company Policy on Drug & Alcohol Abuse

ML20214B773
Person / Time
Site:	Vogtle
Issue date:	05/15/1985
From:	GEORGIA POWER CO.
To:
Shared Package
ML20214B690	List: ML20214B688 ML20214B747 ML20214B753 ML20214B773 ML20214B926
References
FOIA-87-90 PROC-850515, NUDOCS 8705200408
Download: ML20214B773 (99)

Text

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Corporate Guidelines N O. pntTrv 5 SUBJECT _ REVISION q_3q.nq CONDUCT OF EMPLOYEES PAGE .- 3 ,p q C

GUIDELINE: This policy outlines the Company's standards and regulations designed to guide officers, employees, and agents in the conduct of their daily business in such a manner as to ensure the highest utilization of ,

the Company's assets and the greatest efficiency of the Company's employees.

I. ILLEGAL DRUGS ,

The possession or use of illegal drugs (defined as any drug or drug-like substance whose sale, use, or possessicn is unlawful) is inconsistent with the Company's objective of operating in a safe and efficient manner. Accordingly, no officer, employee, or agent shall use or have in his or her possession illegal drugs during working hours or on Compan-1 property at any time. Additionally, no officer, employee, or agent shall report to work while under the influence of illegal drugs. The services of any employee who engages in such

.. conduct will be subject to discipline up to and including discharge per vested authority. The only exception is the taking of prescribed drugs'under the direction of a

(( physician.

The unlawful involvement with drugs or narcotics off Company property will constitute grounds for severe disciplinary action, up to and including termination of employment.

II. ALCOHOLIC BEVERAGES ' / 'I

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The use of alcoholic beverages by employees engaged in the construction, operation, or maintenance of the rl '

Company's facilities is inconsistent'with the objectives, L ,

of operating in a safe and efficient manner. Accord- J '

ingly, no officer, employee, or agent shall use alcoholic ,

beverages during working hours nor shall alcoholic ,j-beverages be served at a Company func' tion without prior Os '

approval by the appropriate senior officer of the Company as designated by the Chairman of the Board, Chief Executive Officer. Additionally, no officer, employee, *

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or agent shall report to work, under the influence of alcoholic beverages. Employees in' violation of this policy will be subject to discipline up to and including discharge per vested authority., 'I III. FIREARMS '4 g

(, The possession of firearms on the' Company's property is '

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Corporate Guidelines Georgia Power A SUBJECT N O. Pnt.Try i

CONDUCT OF EMPLOYEES REVISION q_1g_pq .,

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inconsistent with the Company's objective of providing a safe workplace for all employees. In order to avoid any inconsistencies in the Company's objective of providing a safe work environment, no officer or employee, excluding security guards, shall bring onto the Company's property a loaded or unloaded firearm, including handguns, rifles, and shotguns, without prior approval of the appropriate senior officer of the Company as designated by the Chairman of the Board,' Chief Executive Officer.

Employe,es who knowingly violate this policy shall be subject to disciplinary action up to and including discharge per vested authority.

IV. FULL TIME SERVICE The payment of salary and wages by the Company is for the purpose of securing the services of the employee full time during working hours. Therefore, only activities that enhance the conduct of the business shall be engaged in by employees during working hours.

V. ASSETS OF THE COMPANY The assets of the Company are dedicated to the furnishing u' of electric service to our customers. No assets of the

! Company, including labor, materials, and equipment, shall be used by any officer, employee, or agent for their personal benefit unless the manager or custodian of the asset approves in advance and the Company is reimbursed for the use of such assets.

In the event any officer, employee, or agent contracts

~~ with and utill:es the services of another employee to perform personal services outside regular working hours, F the officer, employee, or agent securing such personal s services shall be responsible for assuring himself that the arrangement is totally without Company participation.

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Corporate Guidelines GeorgiaPower1 N O. pot.Tcv SUBJECT REVISION g 1;-Aq

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CONDUCT OF EMPLOYEES PAGE a nr q VI. BUSINESS TRAVEL The Con.pany will not participate in or sponsor any trip for any employee or group of employees when the trip is not related to the conduct'oi'the Company's business, or where the location is notja contributing factor to the meeting, unless approved by the appropriate officer of the Company as designatac!;by the President or the Chairman of the Board,L Chief Executive Officer.

All business travel will be approved in advanc.e, as prescribed ..in General Accounting Procedure (GAP) 62.

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s, SUPERVISORY GUIDELINES FOR ADMINISTERING THE COMPANY POLICY ON DRUG AND ALC0HOL ABUSE These guidelines are for use by supervisors at all levels throughout the Company. They are intended to provide assistance in the administration of the Company's drug and alcohol abuse policy.

1. Each supervisor has a responsibility to assure himself that employees under his supervision are at all times free from the influence of alcohol or illegal drugs.

2. Employees who have a drug problem and who ask for help should be referred immediately to the Company's Employee Assistance Program. This request for assistance may not be used by an employee as a means of avoiding disciplinary action if he or she has violated the Company's drug abuse policy.

3. Each supervisor is responsible for taking appropriate action whenever an employee's demonstrated judgment or performance-seems to be impaired by the possible use of alcohol or drugs.

Wnen a supervisor suspects that an employee is " unfit for duty", he should:

Arrange, if practical, for at least one other supervisor to observe and evaluate the employee's behavior. The employee's supervisor should ask the employee to explain

( why he appears unable to perform his job. If a bargaining unit employee requests that a steward be present, management should comply with the request, assuming it can be' arranged promptly.

Should the employee f ail to explain his impaired condition to the supervisor's satisfaction and it is still the supervisor's determination that drugs or alcohol may

~ be involved, ne should accompany the employee or arrange ,

for him to be taken by another management employee, to the designated Company physician for testing. If the employee refuses to go, he should be warned that he may still be held accountable for his unfit behavior. Addi-tionally, he may be severely disciplined for insubordination pending further investigation. Depending upon his condition, he should then be sent or taken home and told when to report back to work. The supervisor should exercise cauticr. in committing to any specific disciplinary action or how the employee's pay may be handled.

4. When a supervisor observes the use, sale or possession of illegal drugs or alcoholic beverage by employees on the job, the supervisor should take the following steps:

A. Immediately confiscate all alcohol, drugs and/or drug paraphernalia if possible. As soon as time permits, get another supervisor and the Company's Security Department or the designated drug awareness coordinator to participate in the early stages of the investigation. M M

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. E. Separate the employees involved and take them to a location where they can be questioned individually l

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about the incident. -

C. -With another supervisor present, question the employees-individually about the incident. Allow a steward ,

to attend the questioning if the employee requests l it.

! D. Report the incident to your superior, the Company's L

Security Department, and either the Labor Relations or Personnel Department depending on whether the employee is a member of the Union.

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E. While it may be appropriate to conduct a search of the employee's locker, personal effects or clothing, i recognize that certain legal requirements must be met if the search is to be considered valid for any q

future purposes. Consult your local management and the Security Department. They may recommend contacting i local law enforcement authorities.

F. As soon as Steps ( A) through (E) have been completed, 4 turn any confiscated drugs or paraphernalia over to the drug awareness coordinator, the Security Department, '

or appropriate law enforcement authorities. A sighed receipt should be obtained from any outside agency.

b G. If thE employee has not been removed from Company property by law enforcement personnel, send him home or take him there,. depending upon his condition.

If he appears to be under the influence, follow the steps for having a fitness for duty exam administered.

Make no, commitment regarding whether the employee will be paid or what discipline will follow. After

-- the investigation is complete, the employee should

• be given the opportunity to respond to the results of the investigation. After hearing what the employee  !

has to say, the appropriate discipline that man'agement considers consistent with the nature of the offense should be given.

i j 5. Following any incident that might fall under these guidelines, it is essential that the supervisor immediately make a detailed i record of'all actions, observations, statements and other per.tinent facts, to include date, time, location and witnesses to the incident.

6. If an employee has been arrested for a drug related offense off Company property, local. management should attempt'to investigate the nature of the offense before the employee returns to work.

Some serious violations of the law may also require that job' l action be taken. -Consult with Labor Relations or the Personnel Department. Counsel with the employee upon his return.

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7. If drugs or drug paraphernalia are found on Company property and it is not obvious who the owner is, report the incident to your supervisor, the designated drug awareness coordinator or the Security Department. An effort should be made to determine the owner of the property by questioning supervisors who may have been in the immediate area. Upon instructions from the Security Department, the appropriate law enforcement authorities should be contacted and all drugs and illegal drug paraphernalia should be turned over to them. A signed receipt should be obtained from the autharities.

8. If a supervisor receives a report that an employee has violated the Company drug policy, the supervisor should try to obtain as much detailed information as possible from the person reporting the violation. The supervisor's superior, the Security Department, and Labor Relations or Personnel should then be notified.

Unproved allegations of drug policy violations shall be kept highly confidential and shall only be discussed with management level individuals who have a need to know by virtue of their position of responsibility.

SUPERVISORS' QUESTIONS AND ANSWERS ABOUT THE DR ALC0HOL ABUSE PROGRAM Q.

how his can work? I tell when an employee is "not in a condition" to perform A.

An employee's physical appearance, unusual behavior, slurred speech incoherent manner, lack of coordination, etc. Jma indicate that he is "not in a condition" to perform his work.

For specific signs of possible that has been drug use, a supervisor should refer to the training and material supplied.

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under the influence of alcohol or drugs?Is it possible for a fo A.

It is not possible without a chemical analysis for a supervisor to determine In obvious cases, whether however, ana supervisor employee canis under the influence of a specific d if necessary, determine that an employee is "under the influence." , Supervisors should y generall rely on a fitness for duty exam before coming to any conclusion, but in rare circumstances when an exam cannot be administered the supervisor, with the aid of another supervisor's that would be valid for purposes of discipline. observation, can r,each a determina Q.

k Is it possible for an employee to sue me if I accuse him of being drun A.

Yes, if you do so in an arbitrary or capricious manner.

He should ask the employee for an explanation rs whe unfit and should take him to the doctor for an exam.

certain the supervisor may be, he should alwaysNo matter how wait until all the

available taking facts are in before telling an employeehis conclusions and action. ""

in law suits arising from a supervisor's performance of h .

What should I do if an employee comes in smelling of whiskey or beer?

The smell of alcoholic beverages often lasts longer than their effects so the inat presenceisof an employee an alcohol odor alone is not a fool-proof indication intoxicated.

supervisor tions. should keep a close eye on the employee for additiona If the employee comes in repeatedly with an alcohol odor, the supervisor should talk to him both about his hygiene and about the avail-ability of the Employee Assistance Program.

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" unfit should for duty",I but handle I'm notborderline sure? cases where I think the employee may bl l

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2 A. No guidelines can be 50 specific as to cover every situation. Two factors should be kept in mind, however. First, safety is always our primary consideration, and if any doubt exists about an employee's fitness to perform a hazardous task, take him off the job. Second, taking an employee for a fitness for duty exam is not a form of discipline. If the lab reports back that the employee had no foreign substances in his system, he is simply paid for the time he was on administrative suspension and he comes back. Don't be afraid to use the procedure when doubt exists, though don't use it so frequently that employees feel harassed.

Q. Why is it important for a member of supervision to accompany an employee to a fitness for duty exam?

A. Three reasons: a) In most cases, when an employee is unfit to do his job, he is also unfit to drive to the doctor; b) It is important that a fitness for duty exam be administered as soon as possible to get an accurate indication of the employee's condition when he was on the job.

(Some chemical substances are undetectable within just a few hours of their being taken.) c) Supervision should be present and in control of the situation until ~ the employee is completely on his own time.

Q. What should a supervisor do if an employee will not allow him to drive him home?

k A. We should take all reasonable steps to ensure that someone under the influence does not try to drive. If he will not ride with his supervisor, suggest that one of his co-workers take him. If that doesn't work, try to get one of his family members to pick him up.

Q. How long does it take to get the results back from a fitness for duty exam?

A. Usually three to five days. When the doctor takes his samples, he sends them to a laboratory for analysis. It takes that much time for the shipping and lab work. During this time the employee should be placed on administrative suspension.

Wnat should I do if I see a number of employees using drugs and the possibility exists that they may become hostile if confronted?

A. Get help. Depending on the situation, contact other supervisors, the Security Department or local law enforcement. Supervisors should not allow illegal activity on Company property to go unchallenged. They should not, however, subject themselves to unnecessary risk.

Q. What should I do if an employee refuses to surrender a suspicious substance when so instructed?

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- A. Accompany the employee to your office or work station while observing that he does not dispose of the substance. Repeat your instruction in the presence of another supervisor, warning the employee that his refusal is an act of gross insubordination and subject to discipline up to and including discharge. If he still refuses, send him home without connenting on specific discipline, then conduct your investigation.

Be sure to consult with your supervisor and with the Labor Relations or Personnel Department.

Q. How important is it to have another supervisor present when I question an employee?

A. It is essential, especially if the employee chooses to challenge your action later on. It is also helpful if a covered employee exercises his right to have a union representative on hand as his own witness.

Q. What are the legal limitations that apply to searching lockers, desks, or work stations?

A. That depends on the purpose of the search. If the end result will be disciplinary action by the Company, supervision has an almost unrestricted right, since lockers and desks are Company property. Caution must be taken, however, to avoid any searches that are discriminatory or harassing in nature. It is a good idea to have another member of management and

(- a shop steward, if applicable, as witnesses. If the purpose of the search is criminal prosecution, a much higher standard of con' duct applies.

The courts require that " reasonable cause" exist and that a search warrant be issued. For this kind of search the Security Department and/or local law enforcement should be involved.

Q. What should I do with any drugs that I find?

A. Major work locations will have at least one member of management acting" as a drug awareness coordinator. These people are trained by our Security Department in the proper handling of contraband. If you cannot contact the nearest drug awareness coordinator, call your supervisor and the Security Department. Keep the suspicious substance under your direct custody to avoid it being tampered with, and try to hand it over to another authority as quickly as possible.

Q. What if an employee is arrested off Company property for suspected drug activity?

A. Call the Labor Relations or Personnel Department. Many of these cases fall into a grey area and require considerable thought and research l into past practice. We have a limited right to determine that an employee does not have sufficient moral character to remain in our employ. We must be extremely careful, however, in deciding on an employee's guilt or innocence independent of a court finding. If the facts indicate guilt, the Company has a right to take disciplinary action regardless of the outcome of any court action.

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Q. Are our Company doctors aware of our drug and alcohol abuse program?

A. Yes. In fact, the Safety and Health Department and the Company's chief physician assisted in the program's development. They have contacted I all major Company doctors. -

Q. What if an employee says he has been drinking when he is called to come -

, in to work on an off day?

I A. The supervisor should try to ascertain how much the employee has had to drink and when. Ask the employee if he thinks he is in condition to work. If the slightest doubt exists, get someone else to do the job.

Remember, Company policy prohibits working when under the influence.

Consult your supervisor when a difficult judgment call comes up.

Q. What if an employee suspected of being unfit for duty requests union representation, but a steward is not readily available? .

3 A. If the shop or department steward is not on the job he should be called

. in and paid accordingly. If he cannot comit to arrive within a reason-able period of time (within one hour), instruct the employee that he must cnoose another member of the bargaining unit as his representative. Tell Remember, if too much time elapses between the time an employee 4

( him why.

is judged to be unfit and the time he is examined, reliable test results may not be obtainable.

Q. What level of alcohol or other drugs does the Company consider to be "over the limit"?

,, A. The State of Georgia generally considers a blood-alcohol concentration i of 0.1 percent to be legally intoxicated, and this is a good guideline.

• i The Company, however, is not too concerned with specific blood-alcohol

! levels or drug concentrations. In fact, except for alcohol, it is extremely I difficult and expensive to determine quantitative levels of drug concentra-tions. Our concern is the employee's fitness for duty. The purpose of

! the fitness for duty exam is to document and fortify the supervisor's

. observation that an employee is not in shape to do his job. In the case .

of a negative result from the test, it serves to remove doubt about the l employee's involvement with drugs or alcohol. Except in the case of l alcohol, the laboratory will only determine whether or not a drug or i

i dregs were in the employee's system. It is up to the supervisor to put the evidence together and take the appropriate action.

i Q. Does the Company plan to begin random blood or urine screenings?

A. No.

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Behavior and Job Performance l " Warning Signs" Job behavior and work performance should be the concern of the Supervisor.

Expert knowledge about abuse of controlled substances or abused drugs isn't

, necessary, but the Supervisor should remain alert to changes from the normal

! work pattern and/or behavior of the employee.

It's the responsibility of the Supervisor to act in accordance with Company guidelines for administering the policy on drug abuse. It's important to take immediate steps, since delayed action can threaten the safety of others and result in the total deterioration of the abuser.

Listed you will find various " warning signs" that usually appear on the job, indicating some consequences cf abuse. It's impossible to rate all behavioral and work pattem problems that occur in this process of feterioration. They can appear singularly or in combination. They may signify problems other than substance abuse. For example, alcoholism, diabetes, high blood pressure, thyroid disease, psychiatric disorders, emotional problems and certain heart conditions all share some of the same signs. Therefore, it's important to remember that unusualor odd l

behavior may not be connected in any way with drug or alcohol abuse. The role of

• the Supervisor is to recognize and document changes without making any moral i judgement or taking the position of counsellor or diagnostician.

i Signs of Deteriorating Job Performance I

! Physical Signs or Condition Absenteeism Work Pattoms

( Weanness, exhaustion Untidiness Acceleration of absenteeism and tardiness, especially Mondays.

Inconsistency in quality of work High and lou penods of productmty I

I Yawning excessively Fridays, before and after holidays Poor judgement /more mistakes than Blank stare Frequent unreported absences, later usual and general carelessness Slurred speech explained as " emergencies" Lapses in concentration i Sleep: ness (nodding) Unusually high incidence of colds, Difficulty in recalling instructions Unsteady wa!k flu, upset stomach, headaches Difficulty in remembenng own Sunglasses worn at inappropnate Frequent use of unscheduled mistakes times vacation time Using more time to complete work /

Unusual effort to cover arms Leaving work area more than missing deadlines

.. Changes in appearance after necessary (e.g., frequent trips increased difficulty in handling ,

lunch or break to water fountain and bathroom) complex situations ,

Unexplained disappearance frorn Mood the job with difficulty in locating Relationship to Others on the Job Appears to be depressed all the time employee Overreaction to real or imagined or extremely anxious all the time Requesting to leave work early for criticism l v., table vanous reasons Avoiding and withdrawing from peers mcious Complaints from co-workers mo;ains about others Accidents Borrowing rnoney from fellow E mononal unsteadiness Taking of needless risks employees te g . outbursts of crying) Disregard for safety of others Complaints of problems at home, ,

Mood cnanges after lunch or break Higher than average accident rate such as separation, divorce and ,

on and off the job child discipline problems Actions Persistent job transfer requests i Withdrawn or improperly talkative Spends excessive amount of time on the te!ephone Argumentative Has exaggerated sense of

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j Displays violent behavior Georoia p Power l Avoids talking with Supervisor

regarding work issues i

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. e BENSINGER, DUPONT & ASSOCIATES PLANT VOGTLE AUDIT JANUARY -

APRIL 1986

1. PURPOSE OF AUDIT A. POLICY / PROGRAM EFFECTIVENESS B. DRUG TESTING -

RELI ABILITY AND ACCURACY

2. AUDIT TEAM MR. PETER B. BENSINGER DR. RICHARD H. BUCHER DR. LARRY B. HOWARD

, DR. ROBERT E. WILLETTE

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3. AUDIT TIME SCHEDULE (JANUARY -

APRIL 1986)

A. PLANNING AND ASSESSMENT B. ON-SITE VISITATION

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C. AUDIT METHODOLOGY fo~ z M- 7 7- 90 C /t

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i BENSINGER, DUPONT & ASSOCIATES PLANT VOGTLE AUDIT JANUARY -

APRIL 1986 PRINCIPAL AUDIT ISSUES POLICY / PROGRAM A. POLICY CLARI TY B. POLICY COMMUNICATION C. POLICY CONSISTENCY D. POLICY / PROGRAM EFFECTIVENESS DRUG TESTING A. DRUG LABORATORY TESTING METHODOLOGY B. ON-SITE VERSUS OFF-SITE TESTING C. CHAIN OF CUSTODY -

SPECIMEN HANDLING

( D. ACCURACY AND RELI ABILITY OF TEST RESULTS i

. t BENSINGER, DUPONT & ASSOCIATES PLANT VOGTLE AUDIT JANUARY -

APRIL 1986 ASSESSMENT INTERVIEWS

1. GEORGIA POWER PERSONNELL -

PLANT VOGTLE

2. CONTRACTOR PERSONNELL -

PLANT VOGTLE

3. UNION REPRESENTATIVES -

PLANT VOGTLE

4. LOCAL LAW ENFORCEMENT -

WAYNESBORO

5. NRC RESIDENT INSPECTORS -

ATLANTA REGION

6. MEDICAL COLLEGE OF GEORGIA -

AUGUSTA

7. P. S. P. A. LABORATORY -

ATLANTA

8. PLANT VOGTLE SAFETY DEPARTMENT

( 9. AMI OCCUPATIONAL HEALTH CLINIC -

ATLANTA i POLICY / PROGRAM KEY INDICATORS / ISSUES

1. POLICY ENFORCEMENT i

2. ACCIDENTS

3. DRUG DOG SEARCHES

4. UNDERCOVER OPERATIONS I

5. HOT LINE CALL-INS

6. DRUG TESTING IMPACT

7. INTOXIMETER ALCOHOL EMPHASIS

8. SHERIFF'S ASSESSMENT

9. EMPLOYEE AWARENESS AND ANECDOTAL RESPONSE

10. UNION LEADERSHIP PERCEPTION i

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APRIL 1986 PRINCIPAL OBSERVATIONS AND RECOMMENDATIONS 1.* POLICY CLARITY -

EXCELLENT AND UNQUESTIONED

2. POLICY AND DISCIPLINE -

CONSISTENT

3. DRUG TESTING:

A. ACCURATE B. RECOMMEND ALL GPC DRUG TESTING USE AT PLANT VOGTLE ON-SITE GPC FACILITY C. CONTINUE GC/MS CONFIRMATION %M

4. TOP MANAGEMENT SUPPORT -

CO-ORDINATING COMMITTEE TO CONTINUE

5. UTILIZATION OF KEY INDICATORS REPORT

6. HOT LINE 4

GUIDELINES g p Z S~ M h ') M

7. SUPERVISORY TRAINING 4 8. RANDOM TESTING -

CONSIDERATION j 9. ANTI-DRUG PROGRAM -

WELL-MANAGED AND GIVEN PRIORITY:

A. MEASUREABLE RESULTS e FROM OBJECTIVE AND DEMONSTRATE SIGNIFICANT IMPACT AND SUBJECTIVE ASSESSMENT EFFECTIVENESS.

B. PROGRAM HAS PRO-ACTIVE POSTURE WHICH SHOULD CONTINUE.

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PLANT VOGTLE ANTI-DRUG PROGRAM ASSESSMENT l

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~ w BENSINGER, DUPONT & ASSOCIATES 20 North Wacker Drive Chicago, IL 60606 (312) 726-8620

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BENSINGER, DUPONT ar ASSOCIATES, INC.

aO NORTH WACKER DRIVE

{ CHICAOO. ILLINOIS 60606

(:na)7a6-eSa0 April 18, 1986

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! Mr. Charles W. Whitney Georgia Power Company ,

l Plant Vogtle - Project Management Route 2, Box 299-A .

2 Waynesboro, GA 30820

Dear Mr. Whitney:

Enclosed is our Assessment Report of the Vogtle Electric Generating Plant Anti-Drug Program. Our commentary and recommendations relate to 18 different program / policy issues. In summary, the Vogtle anti-drug program has been effective in addressing and significantly reducing the use of drugs on and off the job by the vogtle workforce of both i Georgia Power and contractor employees. Company policy is clearly understood and respected. The drug-testing program

has been a major f actor in deterring drug use. Indicators

) ranging from accident data, hotline calls, canine search l

results, to employee union and craft worker perception, and local law enforcement and resident Nuclear Regulatory Commission inspectors' opinions, provide the basis for C this conclusion.

The Georgia Power Company ef fort at Plant Vogtle benefits from top management attention and support, coordinated l planning, evaluation and action, on-site drug specimen

collection and testing, and certainty of discipline for l rule violations. The program is sound and well managed.

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While drug-testing procedures being used both on site and a-i by outside laboratories do meet the necessary toxicological j standards to assure accuracy of test results, there are i specific steps that should be taken to further enhance the j drug-testing program, both in terms of procedure and policy.

j We recommend: centralizing all drug-testing specimen i " collection at Vogtle under the auspices of the Safety l Department; random testing for the workforce on a computer- ,

i driven, randem-selection oasis for all personnel on site;

! adoption of identical screening level and test confirmation I procedures for Georgia Power and contractor personnel; j ongoing supervisory training for Georgia Power and contrac-For supervisors, including union foremen; implementation of consistent reporting and analysis of a number of key i

drua orogram inoicators, sucn as accident rates, urinalysis j results (by number, not name), hot line report trends, i

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Mr. Charles W. Whitney April 18, 1986 I page 2 l

absenteeism, etc.; increased emphasis, education and enforce-i ment with respect to alcohol; and specific guidelines for

hotline call-ins relating to any individual who may have

! been tested previously as a result of hotline call-ins on a number of occasions with negative results. In addition, there are certain technical recommendations relating

to laboratory procedures. The testing program itself,

! nonetheless, was found to be sound, with necessary drug-i screen test confirmation, chain of custody, technical ,

equipment, and qualified personnel in place. 1 We note in our report that lost time accident rates have decreased from 5.41 accidents per 200,000 manhours in 1981 l to less than 0.5 accidents in 1985; the national average i

accident rate at construction sites is 3.8. This remark-able achievement may not necessarily be attributed to the

, anti-drug program, but increaced supervisory attention, drug policy job-site awareness, extensive drug testing,

and management commitment to the anti-drug program have f- probably been significant contributing factors.

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Sincerely yours, BENSINGER, DUPONT & ASSOCIATES e en e b l PBB/], z ,

1 -o Enclosure , J

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PLANT VOGTLE ANTI-DRUG PROGRAM ASSESSMENT I. VOGTLE PROJECT BACKGROUND II. VOGTLE ANTI-DRUG PROGRAM III. GENERAL PROGRAM / POLICY OBSERVATIONS IV. DRUG-TESTING ISSUES V. RECOMMENDATIONS VI . APPENDIX i

A. METHODOLOGY B. BIOGRAPHICAL DATA OF AUDIT TEAM MEMBERS -

Peter B. Bensinger Dr. Richard H. Bucher Dr. Robert E. Willette Dr. Larry B. Howard be C. INTERVIEW SCHEDULES -

Dr. Richard H. Bucher Dr. Robert E. Willette and Dr. Larry B. Howard Peter B. Bensinger D. PLANT VOGTLE ANTI-DRUG PROGRAM MANUAL--TABLE OF CONTENTS I "' E. NOTIFICATION TO UNION OF INTOXIMETER AND SAFETY ,

STANDARDS - January 20, 1986 F. PLANT VOGTLE NO-ALCOHOL POLICY MEMORANDUM -

January 24, 1986 G. PROJECT VOGTLE ANTI-ALCOHOL POLICY NOTICE -

January 27, 1986 I

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PLANT VOGTLE ANTI-DRUG PROGRAM ASSESSMENT I. VOGTLE PROJECT BACKGROUND.

The Vogtle Project is jointly owned by Georgia Power Company, Oglethorpe Power Corporation, The Municipal Electric Authority of Georgia, and the City of Dalton. The Project consists of two Westinghouse pressurized water reactors, each capable of producing 1,160 megawatts of power.

The Vogtle Project is managed by Georgia Power Company, acting on its own on behalf and as agent for the other co-owners. The chief architects and engineers for the Project are Bechtel Power Corporation and Southern Company Services.

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The Project is located in a rural setting in Burke County, Georgia, approximately 34 miles south of Augusta on the Savannah River. Georgia Power Company employs approxi-

., mately 1,600 employees at the vogtle Site. Contractors at the Site employ an additional 11,900 employees, bringing total employment to 13,500 plus. Approximately 7,000 of these employees are "craf t" workers. There are 13 dif-ferent unions representing these craft employees.

Construction on the Vogtle Project began in 1974.

Shortly af ter work began, construction was halted. Work resumed again in 1977 and has continued, uninterrupted, since that time. During the period of the audit, Unit No.1 of the Project was approximately 914 complete. Unit No.1

l is scheduled for Fuel Load in December, 1986, and for com-mercial operation in June, 1987. Unit No. 2, approximately 554 complete, is scheduled for Fuel Load in March, 1988, i

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and for commercial operation in September, 1988.

During the time of the audit, Georgia Power Company provided management, administration, and quality control 2 to the contractors involved in various activities at the l

> Site. There is a large engineering function, with manpower i

and technical expertise provided by Bechtel, Westinghouse, and S6uthern Company Services. Additionally, the Georgia Power Company Nuclear Operations Department employs approxi-mately 800 employees and is engaged in initial equipment l

testing and in developing procedures for eventual commercial

k operation.

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! II. VOGTLE ANTI-DRUG PROGRAM.

I i Since its inception, the Vogtle Project has maintained

! rules designed to prohibit employees from working on the Project while impaired due to either drugs or alcohol. When constrU'etion t

originally began, Georgia Power Company issued work rules govern-i i

ing conduct on the Project Site. One of those rules prohibited  ;

i employees from use or possession of alcohol while on the Site j

s or from being under the influence of alcohol when reporting i

to work.

j During the late 1970's and early 1980's, Georgia Power

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l Company expanded enforcement of the "no alcohol" rule in response to what it perceived as increased drug use by i

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6 society in general. During this period of time, Georgia Power Company advised unions that it would not tolerate drug activity, that drug users and distributors would be terminated and barred from the Site, and that it would cooperate with local law enforcement regarding unlawful drug activity. Two separate undercover operations were conducted at the Vogtle Project Site, both of which resulted in arrests for of f-site drug use or distribution.

All Project employees implicated in these undercover investigations were terminated and barred from the Site.

In 1982 the International Union of Operating Engineers challenged Georgia Power Company's right to bar employees engaged in off-site, non-working time drug activity. A member of that union had been implicated in an undercover operation i ' for selling marijuana off-site. Georgia Power Company imme- '

diately barred that employee from. working at the Vogtle Project, l and Georgia Power Company's actions were challenged by the i i union in arbitration. The arbitrator in Georgia Power Company--

.o Vogtle Nuclear Project and local Union No. 24, International ,

Union of Operating Engineers, AFofL CIO, 82-2ARB 8474 (McDermott, 1982) ruled in the Company's favor. The arbitrator specifically  ;

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[ found that Georgia Power Company had the right to bar individuals from its property as long as the right was not exercised in an

! arbitrary, capricious, or discriminatory manner. Furthermore, the arbitrator found that any employee engaged in drug distri- J bution presented a potential threat to safety and efficiency, i 1

regardless of where the drug distribution took place, and that a work rule barring these employees was reasonable.

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. o In 1983 Georgia Power Company issued revised work rules, commonly referred to as the " grey book." Under the terms of the " grey book", drug and alcohol use or possession on or near the Site was expressly precluded and resulted in an

! employee being terminated from employment and/or barred from the Site. In a preamble to the " grey book" the Company advised all employees that any activity which could adversely affect safety and efficiency would subject an employee to disciplinary action, regardless of whether the activity took place on or off the Site, or during working hours or off-duty time.

> In April, 1984, Georgia Power Company enhanced the "no 4

drug /no alcohol" rule by means of a new drug policy statement.

l . The drug policy statement was signed by D. O. Foster, then 1

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! Vice President and Project General Manager (a copy is attached I

! hereto as Exhibit 1). The Foster letter explicitly prohibits

] any form of drug distribution, at any time, prohibits drug i

( and alcohol use or possession on the site, prohibits report-1

-- ing to work with drugs or alcohol in an individual's sytem, ,

and provides for several diffferent enforcement mechanisms.

l Some of the enforcement mechanisms detailed in the Foster 1

! letter include the use of drug dogs, individual and automo-j bile searches, work area searches, undercover operations, and urinalysis. Under the terms of the Foster policy state-i ment, urinalysis could be directed by supervisors and any employee either refusing urinalysis or testing positive would j l

i be terminated and barred from the Vogtle Site and from other Georgia Power Company construction sites throughout the State.

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During the period 1984 and 1985, several enhancements were made to the original Foster policy statement. In January, 1985, the policy was expanded to include prescription drugs.

Under this enhancement, employees using prescription or over-the-counter medications were obligated to report the medication to their supervisors. Supervisors could then, if appropriate, adjust work assignments in order to ensure continued job safety i

and efficiency. In March, 1985, the Foster policy statement regarding urinalysis was modified to provide for a one-time across-the-board screening for all non-manual employees at the I Vogtle Site and for prehire screening for all employees assigned to non-manual positions in the future. During this period of time, f

Georgia Power Company's Nuclear Operations Department developed I and f ully implemented its " fitness-for-duty" rules for Nuclear Operations employees. These fitness-for-duty requirements included an initial drug screening test for all Nuclear Operations employees assigned to the Vogtle Project.

During the 1984/1985 time period steps were taken l

i to enhance the Project's ability to enforce the Anti-Drug i

Policy. The Project purchased Syva Emit testing equipment and trained, certified and licensed Project employees in the operation of this equipment. This step allowed greater

! control over the testing process and improved tne efficiency of the process by minimizing work disruption and lost time.

l Additionally, the Project engaged in a major publicity i

j campaign designed to familiarize all Project employees i with the no drug /no alcohol policy. Drug dogs were utilized l l

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4 in parking lot and on-site workplace searches. The Project Security Department increased its enforcement efforts by j means of vehicle and gate personnel searches designed to eliminate the transport of drugs and alcohol onto the Site.

l Steps were taken to ensure that the enhanced program was communicated to the craft unions representing construction workers and to representatives of the International Brotherhood of Electrical Workers, Local 84, the union representing Georgia Power Company Nuclear Operations employees. The construction  !

craft workers agreed to the overall drug and alcohol suppression effort and cooperated in an enhanced publicity effort, including on-site posters and signs, bumper stickes, and hard hat stickers.

! In January, 1986, the Anti-Drug Policy was clarified to

- ensure that all Project employees were aware that the policy included a prohibition against the possession or use of alcohol.

The clarification was by means of a January 20, 1986 memorandum 4

from R. E. Conway, Senior Vice President and Project Executive

-- e-(a copy of which is attached hereto as Exhibit 2), which emphasized that reporting to work after using alcohol, or impaired by alcohol in any way, was prohibited. At the same

time, Georgia Power Company purchased an "Intoximeter" for 1

on-site alcohol testing. As with the drug-testing equipment, all operators were trained, certified, and licensed by the State in the use of this equipment.

4 i At the time of the audit, the Vogtle Anti-Drug / Alcohol

. Program was administered by the Vice President for Administra-

! tion, Vogtle Project. This executive periodically convened i

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i meetings of an " Anti-Drug Coordinating Committee" comprised 1

! of representatives from Project Management, Security, Safety, b Public Information, Licensing, Corporate Human Resources, I Nuclear Operations and Construction Human Resources, and i

4 Project Legal Counsel. Issues involving the anti-drug effort l are discussed at these committee meetings, and recommendations i

i i made to Project Management based upon these discussions.

III. GENERAL PROGRAM / POLICY OBSERVATIONS.

I i A, INTRODUCTION. On January 29-31, 1986 an on-site j assessment at Plant Vogtle was conducted by Bensinger-Dupont j senior associate Dr. Richard Bucher to assess the effectiveness and impact of existing drug and alcohol policy and programs at Plant Vogtle, Burke County, Georgia. The program audit

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j consisted of (1) a review of existing program documentation j (policy statements and communications, training programs, j reporting procedures, etc.); (2) interviews with management, 1

i contractors, Nuclear Regulatory Commission staff, union

! representatives, and craf t and staff from various company 4

I and contractor departments; and (3) review of safety and

! other statistical data. The interviews reflected a cross section of management and company contractor employees from j the major elements of the project, 23 interviews with varying i i levels of management and contractor supervision, 21 craf t and staf f workers selected at random, and interviews were held with

! the Sheriff and Chief Deputy Sheriff of Burke County, Georgia.1 i

! The audit addressed the effectiveness of the current drug i

! 1 Appendix A.

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and alcohol policy / program. Key questions raised included:

1. Has a clear policy been established and made known to all affected personnel?

2. What programs exist in support of this policy?

j 3. Mas an organization been established

< to coordinate and oversee the specific i programs supporting the policy?

4. Is the program consistently being applied?

l 5. Is the drug and alcohol problem on site getting better (or worse), and being effectively controlled, and if so, by virtue of what information,

' indication or reports?

B. POLICY. Clearly-stated policies prohibiting the use, possession or sale of drugs, and the use or.being under the  ;

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l influence of alcohol while on the project or while on project i

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business off site have been promulgated and emphasized since 1982. Policies have been revised and updated, the most recent revision for both drugs and alcohol occuring in i January, 1986. The initial drug and alcohol policies are l applicable to all staff and craft employees of Georgia Power

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f Company and its contractors on site at Plant Vogtle, as well "

as suppliers and others directly associated with the project.

These policies have been given prominence in the BLAZER, the plant newspaper, and widely posted on site bulletin boards.

i As policy amendments and refinements are made, they are

also prominently highlighted in safety meetings and through 4

posters, bulletin boards and memos. Further, drug and alcohol policies are a continuing subject of discussion in " quality" l

j (Q) programs, safety meetings, and general supervisor i 4 i

sessions. Copies of current policies were on all of the bulletin boards (14) which were surveyed during the audit.-

A highway sign, posters, and hard hat stickers are also continuing reminders of the drug policy. Finally, all new employees during site orientation are advised of both the alcohol and drug policies.

C. PROGRAMS IN SUPPORT OF POLICY. There are a family of programs which specifically support the drug and alcohol

policy. These include

1. Pre-employment drug screens for all Georgia Power Company (GPC) employees;

2. Alcohol and drug testing of personnel on site if they display aberrant or unsafe behavior or are discovered or reported to be in possession of drugs or alcohol;

3. Authorization clearance testing for all

! GPC and contractor non-manual employees.

This is in effect an " access" screen for anyone being assigned or reassigned to Plant Vogtle. (Testing of all GPC and contractor non-manual personnel at Plant Vogtle was undertaken with the initiation of " fitness-for-duty" testing.];

4. On-site testing for drugs and alcohol for

.. contractor personnel referred for fitness-for-duty or for-cause testing;

5. Of f-site testing for drugs and alcohol for GPC personnel referred for fitness-for-duty or for-cause testing

6. A professional security program including traditional routine inspections and. searches of lockers, lunch boxes, plant work and storage locations, as well as undercover operations and periodic use of a " sniffer" dog;

7. A 24-hour telephone hotline to receive information on people suspected of using or selling drugs and alcohol on the project or causing safety problems;

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8. Drug testing of workers identified by hotline i

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calls; t.  ;

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9. An on-site breathalizer to providt valid, ,

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immediate results for those tested for alcohol; / s, I

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, 10. A "Q" interf ace wherein the quality control ';  !

section receives notification, of people' whol;; l 1 have tested positive / refused testing so thkt t -

l' any work performed orfsupervised by these , ,

i individuals can-be re-inspected; (6 l '

11. " Fitness-for-duty" training for supervisors;

! 12. An active safety (program which reinforces  ;

the "no drug or alcohol" prograss at all

) levels of the workforce; ,

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! 13. An introductory education effort on the  !

health and safe,ty hazards of drugs and alcohol l was presented to Vogtle management and super-j vision in 1984 and 1985; ,-

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. 14. A permanent updated Policy Mandal for Flan't 1 Vogtle has been maintained,# and amendments, ,

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policy revisions, new rules and policy state-ments are-circulated ,to all Policy Manual j

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holders so that current applicable policy 't is in the hands of management with relevant' background material (a current index of the < (

Anti-Drug Program Policy Manual is attached).  ;

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D. POLICY COORDINATION. All of these prog, tams ar,e ,

in force.

, l To ensure appropriate coordinatic%.  : a Drug >

Program 1 Committee has been established to provide for.the de'velopment '

and coordination of specific programs. Established [inAugust,  !

i 1984, the Committee meets on a regular basis to report on ,

i i program elements and to discuss current program and m Nagement.

issues relating to drug and alcohol abuse prevention and poli,cy '

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enforcement. Committee membership includes key' personnel l from Management, Personnel, Security, Legal Administration, i s Labor Relations and Safety, with other departments represented-as necessary. This team plays a central role in both the

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development and implementation of the individual component

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'\ programs. Formal minutes a're maintained to establish an

! I N. institutional record of activity for both current and future (y , ' reference. Review of the minutes reflects a willingness of

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j this group to discuss and consider a wide range of issues '

j'. related to plant policy and a sensitivity and receptiveness

, to feedback from individuals not on the Committee from the general workforce population,.

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E. PROGRAM IMP'ACT. A. major issue addressed by this i' audit was the impact the program has had on the workforce.

l j i Measurements of this nature, while subjective, can reveal trends and do provide important perspective. Trend data is available. Opinions 1 of'those interviewed provided independent insight to assist us'in our assessment.

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( 1. Awareness of Program. One of the questions  !

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, i asked all 21 craft and staff workers was "what is the drug l 4 j and alcohol policy at Plant Vogtle?" In every instance

! the response was "no drugs or alcohol, period", or words l

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.'. to that effect. All individuals interviewed believed "

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that the policy is clear and that everyone is aware of it.

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! Incidentally,'several craft workers separately mentioned i

! that the policy reputation is well known in their brother-

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hoods and that the hiring halls in Georgia and neighboring

! states are aware of the policy and its consequences. Site policy is reemphasized in safety and supervisor meetings, I'

1 by prominent display on bulletin boards, and enhanced by other responses such as the " Drugs--Don't" stickers l

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, for safety hats that have been passed out by o;.0 of the '

principal contractors.

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2. GPC/ Contractors Commitment. With up to 9,000 workers on site, GPC has made it clear to all of its 42 con-tractors that they must adhere to the company drug and alco-hol policy. Whil',the e emphasis given by contractors varies, j in no insd,ance was there evidence of a contractor giving just " lip service" to the policy. All contractors have (made this policy the subject of safety and supervisor meet-f Several have gone further. One principal contractor j

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(Walsh), fcr instance, has developed a comprehensive program L

f designed not only to prevent drug or alcohol use but to assist  ;

i employees who may be having problems with drugs or alcohol.

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This program includes a company survey, supervisory training,

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- a stringent policy on absenteeism, an " emphasis" meeting with o

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! first- and second-line supervisors at least once a month, and policy reinforcement in safety meetings.

Urine testing is conducted on any' employee involved in an accident if aber-  !

rant behavior is evidenced. This company has gone 2,000,000 i

manhours without an accident in one period of time, and twice

has gone 1,000,000 manhourt without an accident. l

3. Confidence in the Program. While admittedly a

, difficult element to measure, there are several factors which are likely to reflect workforce confidence. The first has

- to do with the fact that the hotline continues to be used by t employees, even to the point of call-backs if obvious action has not yet been taken with the reported employee (although

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1 the company may have already investigated or tested the

j. reported individual without the caller's knowledge) .

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! Callers are continuing to report problems of a bona fide a

nature, with fewer non-job related call-ins, according 4 to " hotline" personnel. A second indication of program

) confidence was given by several GPC employees who urged that urine testing of GPC employees also be done on site, i

since they had confidence in the drug-testing program run by the project (Safety Office), and reported that they were not as comfortable with confidentiality from the local physician off-site drug-test procedures which apply to GPC personnel.

Five of the seven GPC staff interviewed made this suggestion.

i Finally, when both craft and staff were asked if the policy was being fairly administered, no complaints were directed at the competence or administration of the on-site testing program.

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4. Trends. This is a key issue: Is the problem getting better or worse, and how does one know? Again, measure-ments are not precise and often must be imputed. But therd'are several indicators which suggest real and significant progress.

a. Accident Rate. Accident rates are closely related to drug and alcohol use. Studies have shown rates to be three or four times higher on the job and five to six times higher

at home for people who are using drugs or alcohol.2 A close review of project incident rates shows a dramatic decrease over

2 For an extensive discussion of the impact on accident rates, see Preventing Drug Abuse in the Workplace, National Institute on Drug Abuse, Rockville, Maryland, 1982.

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a the past five years. According to the Safety Office, the pro-ject accident-incident rates per 200,000 manhours are:

1981 5.41 1982 2.09 1983 0.91 1984 0.61 1985 0.49 These rates are dramatically lower than the current national average rate of 3.8 per 200,000 manhours for the construction industry. While there are undoubtedly many factors contributing to this reduction, including an enhanced and effective safety program, it is more than coincidental that these rates began to come down in the year (1982) that the Company emphasized its alcohol and drug prevention program and expanded education and prevention and testing efforts. .

( b. Hotline Use. The declining frequency of use in the hotline from 35-40_per month to an average of 20-25 per month can be interpreted to reflect less drug us, on the job. While some of the decrease is attributable

.. to fewer crank calls, much of this decrease reflects an absence of drug use on the job.

c. Frequency of Negative Tests. One contractor (Walsh), which has kept detailed records and has adopted an aggressive drug-prevention program, indicated its analysis of trends for contractor personnel showed the frequency of negative test increasing and the number of refusals decreas-ing, both representative of less use of drugs in our opinion.

l One other contractor (Pullman Power Products) with historical data also reported similar trends. No contractor management interviewed indicated contrary perceptions.

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d. Sheriff's Assessment. Both the Burke County Sheriff and Chief Deputy Sheriff were interviewed.

Each stated that in his opinion the availability and use of drugs at Plant Vogtle had decreased. The Sheriff credits the decrease to joint efforts between GPC and his force and expressed appreciation of the cooperation he received from GPC. He stated that "the major drug problem in the County is now away from Plant Vogtle" (the principal work and employment center). The Chief Deputy independently indicated the problem in and around Vogtle was reduced by 60-65% af ter introduction of the urinalysis program and confirmed the Sheriff's assessment that the County's drug activity lay elsewhere, despite the fact that Plant Vogtle

(, . held by far the greatest concentration of people at work in the County.

e. Anecdotal Responses. During the course of craft and staff interviews, a recurring theme was that

-- drug use had been steadily decreasing for some time. No ,

one reported seeing marijuana smoking on site, an event of limited notice in 1984. The credibility of the policy was universally cited as the reason for this change. The policy 1 has had an impact on lifestyle. Three of those interviewed stated that they had been casual marijuana users, but quit using it because they did not want to jeopardize their jobs.

Several GPC and contractor managers mentioned similar comments have been made to them by staff and craft.

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f. Security Operations. Two drug-specific security projects also suggest significant decrease in drug presence:

(1) Undercover Operations. GPC security has conducted six undercover operations over the life of the project.

From 1980 through 1984,

• tan) early operations identified a number of people either selling, sharing or using drugs. The last four undercover operations came up " dry"; that is, no drugs were found or offered for use or sale. This is a significant indicator with respect to drug use and availability on site.

(2) Sniffer Dog. GPC has used trained dogs to assist in locating drugs both on site and in the parking lots. In no instance have caches of drugs been discovered.

The most recent two canine searches at the plant have turned up negative for drugs. A major parking lot drug search of up to 2,000 cars reported some positive drug indication--residue or ash--in less than one-half of one percent of the cars parked, serving three times that number of workers. Dog handlers reported that lots at similar plant or construction sites where they have worked would have 8 to 10 times more " positive hits."

g. Union Leadership. Three business agents and three shop stewards were interviewed during the course of the audit and all expressed strong support for these programs.

They all agreed that drug and alcohol use on site had decreased.

All agreed that the policy was clear and concise. None com- l plained about inconsistent application of the policy. And none objected to random testing on site as long as everyone (GPC and contractor personnel) was eligible to be tested. l l

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IV. DRUG-TESTING ISSUES i

j A. INTRODUCTION. On January 27 and 30 and February 5 and 6, Drs. Larry B. Howard and Robert E. Willette visited drug-

testing f acilities involved in the Georgia Power Company's Anti-Drug Program, including all directly related to the Plant Vogtle drug testing program. The initial visits were to the PSPA/SKBL Laboratory, which performs the drug testing on urine specimens collected from Georgia Power Company (GPC) employees at Vogtle as well as all other GPC employees, and to the Howell Center of AMI, a clinic that collects urine and blood specimens from GPC employees in central Atlanta. Site visits were also conducted at the Vogtle Project itself, where the company Safety Department collects and screens urine specimens from contractor employees, the Medical College of Georgia, which performs drug testing on positive specimens collected and screened from contractor employees at Vogtle, and to Medical Specialists, Inc. ,

a clinic in Waynesboro that collects specimens from GPC employees at Vogtle.

The assessment visits consisted of: reviews of all steps, and procedures that relate to specimen collection, handling, and testing; examination of representative test results; review of current and proposed policy and procedural issues that relate to drug testing; and interviews with personnel 9

that are directly involved in the drug-testing procedures.

It is Drs. Willette's and Howard's opinion that the drug testing was accurate, meeting all standards required for urinalysis drug tests. Although there are a number t

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of modifications to procedural details and policies that we are recommending, it should be made clear that these 4

are not because of deficiencies that may jeopardize past or present testing activities but to assist in the continuing effort to refine and improve the testing program.

A high level of professionalism and commitment was demon-strated by the Georgia Power Company (GPC) staff responsible for every facet of the Program that was reviewed, particularly at the project management and Safety Department levels.

B. PRINCIPAL OBSERVATIONS

1. Specimen Collection Policy--On Site at Vogtle and Off Site. The current policy provides that GPC employees at Vogtle submit specimens at different locations than tempo-(- rary or contract employees (collectively referred to herein.

as "non-GPC employees"). GPC employees reported greater con-fidence in the on-site specimen collection procedures than for those used off site. Visits to all facilities did not suggest any overt lack of appreciation for the seriousness of the

• collection procedures. In fact, there was a strong recog- l

nition of the importance of the integrity of the specimen and adequate precautions are being taken. However, spe-l cimen collection and handling by Vogtle Safety personnel are conducted under tighter controls'an'd with a consistent uniformity by Company-trained personnel. Furthermore,  !

confidentiality may appear to be in jeopardy when personnel are taken off site for specimen collection. Employee percep-tions are important, and the audit team was told by employees

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that they would rather be tested on site like contractor personnel than taken off site for testing.

2. Specimen Collection and Handling Procedures l at Plant Vogtle. The urine specimen collection procedures employed at Vogtle are sound and well thought out. Adequate precautions are in place to control specimen identification and assure chain of custody.

Fitness-for-duty testing is conducted on all new hires at the Plant Vogtle site and whenever a current Georgia Power employee is transferred to Vogtle. Discretionary ~ testing is drug testing that is ordered by a supervisor based on observed behavior or a hotline call-in.

3. Drug Testing Procedures--Vogtle. The Vogtle

( Safety Department presently screens all specimens collected for discretionary testing (observed behavior or hotline call-in) on site with a Syva EMIT-Qst system. Specimens collected for fitness-for-duty testing (transfers to site or new hires) are not prescreened at Vogtle but forwarded directly to MCG e-for screening and confirmation. The split specimens of those prescreened at Vogtle are sent to MCG for rescreening (for all eight drugs regardless of those detected at Vogtle) and for confirmation testing.

It has been the practice of Vogtle as well as other Georgia Power facilities to collect two bottles of urine at

the time of specimen collection. Both are labeled identically and under observation the individual is asked to fill the first bottle and provide as much urine as possible in the

I second. This second bottle is usually the one that is sealed and placed in the freezer for subsequent testing if necessary.

The on-site screening at Vogtle is conducted by eight Safety Department personnel, seven of whom are licensed Emer- ,

gency Medical Technicians and one of whom is a nurse. They have all received initial and advanced training by the Syva Company.

Because of the paramedical backgrounds, the five operators who were interviewed were knowledgeable about the tests and the precauticas, etc. required in conducting the tests.

They understand the implications as well as operating require-ments of the procedures performed.

Testing at Vogtle is currently performed on an EMIT-Qst instrument using EMIT reagents supplied by the Syva Company.

( It makes use of dry, freeze-driad reagents that can be used

on a single-test basis. The test is run by placing the urine container under a sampling probe, which withdraws an exact quantity of urine, which is then transferred into the reagent

, container along with a measured amount of water. This solu-

-- w tion is sucked into the spectrophotometer, which measures the extent of the antibody interaction and records.the result.

This is compared to the readings for the standards to deter-mine if the sample contained the drug being tested for.

Before any specimens are tested, the operator checks the calibration of the instrument by analyzing the negative, low and medium calibrators for each of the eight drug classes tested for. These results are filed along with a test, consent and chain-of-custody records. The specimens are tested first l

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l for marijuana, then cocaine. If either or both of these are positive, no additional screening is done on that specimen since it will be rescreened for all drugs at MCG. If the first or each of the subsequent tests are negative on any specimen, testing for additional drugs will be conducted.

Only specimens testing positive for one or more drugs are sent to MCG. This approach is sound and reliable.

The detection levels used at Vogtle for marijuana (75 ng/ml) and cocaine (300 ng/ml) are the same as those used at other laboratories serving Georgia Power, MCG and PSPA.

MCG also uses the same EMIT detection levels for the other six drugs (PSPA uses a different screening technique for certain prescription drugs).

The rescreening and confinnation results at MCG show an excellent correlation with the initial screening results at Vogtle. Occasionally a specimen that is screened positive at Vogtle, but very close to the detection level, may or may

.. not rescreen positive at MCG. Two such examples occurred during the time of the visit of Drs. Willette and Howard.

MCG thus provides an excellent quality control check for the on-site testing at Vogtle.

4. Drug-Testing Procedures--Medical College of Georgia.

l The laboratory director, Dr. Lawrence Hendry, was out of town at the time of the audit visit. However, the staff directly responsible for testing were available for interview. The senior chemist, John Craig, has had 19 years experience with mass spectroscopy. The laboratory is very well equipped, well maintained, and well managed. For the past two months, all EMIT screening has been performed on a fully-automated analyzer, the Demand system distributed by Cooper Laboratories.

It provides very fast (400 results per hour, on an 8-drug panel of 50 specimens) and highly precise results eith minimal handling. Furthermore r the results are presented in a semi-quantitative manner, which will provide valuable prevalence data for program analysis.

All samples that exceed the prescribed cutoffs, which are the same as used at Vogtle, go to gas chromatography /

mass spectrometry confirmation. MCG has adapted appropriate procedures for the extraction and derivatization of the urine samples. The specimens are then analyzed on one of the GC/MS instruments under a full-scan mode of operation. Except for the THC metabolite, any presence of drug or its metabolite that exceeds background noise by a ratio of at least 7 to 1 is called positive if it has the same GC retention time and the full-scan mass spectrum is a match of that for the reference compound,

'~

i.e. , marij uana, cocaine, amphetamine, etc. For marijuana, "

a sensitivity standard of 75 ng/ml is injected and compared to the reconstituted mass chromatogram for the three primary ions for the unknown sample. Such procedures are appropriate and accurate and in accordance with accepted analytical and toxicological practices.

GC/MS analyses may be conducted under dif ferent modes of operation. The older and more common method causes the drug molecules to become ionically charged by " bombarding" them with a beam of ions as they emerge from the gas chromatograph.

They need to be ionica11y charged in order for them to be separated by the mass spectrometer. The MS can then be tuned to focus on certain " selected" ions, producing a " selected ion monitoring" or "SIM" mass chromatogram. An optional mode is to record the entire mass spectrum, the so-called " full-scan" mass chromatogram. The SIM method usually is more sensitive, whereas the full-scan mode gives more structural or identifying information. Both can produce forensically acceptable results.

5. Drug-Testing Procedures--PSPA/SKBL. PSPA drug handling and testing is generally acceptable. The audit team has some concern with the specimen-handling procedures within the laboratory, which follow those used for all clinical samples processed each day. The number of people with access to the

(_ specimens at any time is excessive. We suggest alteration in procedures to assure that unassailable security is af forded GPC specimens. The current situation does not jeopardize current or past results since confirmed positives are preserved, but some specific procedural GPC specimen e-guidelines at the laboratory will further assure chain-cf-custody security and limit access to GPC specimens to certain laboratory personnel. We can discuss such access limitations with laboratory management directly if appropriate.

4 .

4 V. RECOMMENDATIONS A. PROGRAM / POLICY CONCLUSIONS AND RECOMMENDATIONS.

Based on the evidence presented to us, through on-site interviews,  ;

discussions with local law enforcement, review of accident data, l i

hotline calls, and other data, we conclude that an effective i l

drug and alcohol prevention program is in place and working l at Plant Vogtle. Historical and statistical data reviewed  ;

l did not establish evidence of a drug problem, although the issue remains an item of legitimate management concern.

The program, as developed, has a solid organizational infra-structure, is clearly understood by all employees, and appears to be administered in a fair and consistent manner.

There are, however, several areas to which attention should be given in order to further strengthen this viable prog ram. They are:

1. Random Testing. Random testing of all site personnel should begin as soon as practical to achieve maximum

drug-use deterrence on site. While the current policy and pediram has had a measurable positive impact limiting drug use, a random-testing program will be the single best ongoing deterrent to drug i

and alcohol use on the job. The combination of an objective standard of measurement, predictable discipline, and an uncertainty as to the occurrence of testing will act as a powerful dissuader of drug use.

This random program need not be inordinately extensive. Forty to fifty tests per month would most likely be sufficient. These tests are not primarily to identify users, but to deter use, hence large numbers are not required . Since all workers on site are badged, t

- , , , , ,.w.. ,

_- ~ . ._. . . - . - - - _

and since each badge has a unique number, developing the random base should be relatively simple. No one interviet during the course of this audit opposed the idea of random testing. The only concern stated by both staff and craft  :

was that the policy be applied to all people on site, including GPC and contractor management.

2. Awareness and Supervisory Training. From discussions held over a period of three days, it became clear that while the awareness of the drug and alcohol policy was universal, the understanding by workers and supervisors of the underlying health and safety hazards and intervention f needs, and the supervisors' role in administering the policy was not. Given the number of people on site, turnover rates, ,

and transfers, establishing an awareness-training program for

i. .

all craft and staff might yield marginal benefits, since the rate of drug use on site appears to be rather low. But for the policy to be ef fectively administered, supervisors must be trained and retrained in both general awareness of the nature and consequences of drug and alcohol use and in identifying and responding to people who may have drug- or alcohol-related problems on or off the job. To this extent, there are several programs in place. GPC has begun a " fitness-for-duty" module that is available to GPC and contractor super-visors, and has been presented four times to approximately 100 supervisors total. At least one of the contractors (Walsh) has given its supervisors additional guidance. But the vast majority of contractor supervisors have received little super-visory training. GPC is currently reviewing this program with

( . - _ . _ _ _ - _ _ , - _ _ _ _ _ _ _ _ _ _ _ _

i the intention of revising the curriculum and making it ,

available to more supervisory contractor and GPC personnel.

We recommend that the supervisory training program be f

I expanded so that all GPC and contractor supervisors," including i

• union foremen, will have skills training in identifying signs and signals of possible drug or alcohol use, and performance, safety problems, and policy procedures to intervene so as to administer the policy in a consistent manner. ,

3. Management. The current infrastructure for the oversight and implementation of the vogtle Plant anti-drug program and policy works well. The Drug Program Coordinating Committee serves as an ef fective vehicle for administering this policy because its membership reflects the major program elements on site and benefits from the direct involvement of the Project General Manager. Further, the GPC policy of having a senior legal advisor on site provides effective facilitation and coordination of policy and programs. The legal advisor is able to provide clear, consistent guidance to all echelons" of GPC senior management. This results in prompt, consistent, and reasonable actions (policy enforcement) which add significantly to the credibility of the program. As policy i

implementation becomes more routine, there may be a tendency

> for the coordination process to be pushed down lower in the organization. That would be unfortunate since the key to an effective drug and alcohol policy is the stated and evident j

commitment of senior management at all levels. At a minimum, the policy coordinator must continue to have direct and continued access to the Project Manager and the membership

O 1 O

l of the Committee should continue to include present senior management representatives. This organizational model should be considered for use throughout the company, including at the corporate level.

4. Indicators. A select family of trend indica-tors should be identified by the Drug Program Coordinating Committee which it would use to assess trends of drug and alcohol use over time, and which could signal shif ts in drug or alcohol use patterns. Indicators could include, but would not necessarily be limited to, the following:

a. Accident rates, by category (i.e.,

lost time, medical attention), with trend lines and analysis by organiza-tion, work category or demographics;

b. Urinalysis rates;

c. EAP referral rate for GPC employees (more referrals do not necessarily i mean more drugs);

d. Security / law enforcement incident

, reports;

' -- e. Hotline trends; ,

f. Survey data; j

g. Absentee data; 1

h. Canine search reports.

Much of this data is already collected and available. What would be new would be its institutional use by all members of the Drug Program Coordinating Committee on a regular, anticipated basis.

Combined with other personnel, security, "Q", and safety reports, the indicators can serve as cues, confirmation signals, or warning flags, for changes in trends.

i i

1

t 1 l

l

5. Hotline Call-In Guidelines. Guidelines are needed with respect to hotline call-ins to provide management discretion when it would appear prank calls are being made identifying an individual who does not appear to be in violation of the company's drug policy and has already proven to be negative for drugs on two or more tests within a recent six-month or one-year time period. Vogtle manage-ment should exercise discretion and not automatically require a drug test without further inquiry and/or observation.

6. Alcohol Emphasis. While there has been much attention focused on the drug policy, the concern with alcohol has also continued. GPC's recent reemphasis of its "no alcohol" d

policy is an important reminder that drinking off site prior to coming on the job is not acceptable. The presence of the "Intoximeter", communication by Project Management to all safety and construction managers, and liaison with union leadership indicate the company's awareness and commitment

> -- in this regard. GPC should remain sensitive to keeping ,

the "no alcohol" policy visible with continuing ongoing reinforcement.

B. DRUG-TESTING RECOMMENDATIONS

1. Specimen Collection Centralization. All Vogtle i

personnel, whether GPC or non-GEC employees, should be proces-j sed for specimen collection at the Safety Department facility.

i Such a move will assure consistency in testing and respond i

to employee perceptions.

I l

second. This second bottle is usually the one that is sealed  ;

and placed in the freezer for subsequent testing if necessary. l The on-site screening at Vogtle is conducted by eight Safety Department personnel, seven of whom are licensed Emer-gency Medical Technicians and one of whom is a nurse. They have all received initial and advanced training by the Syva Company.

Because of the paramedical backgrounds, the five operators who were interviewed were knowledgeable about the tests and the precautions, etc. required in conducting the tests.

They understand the implications as well as operating require-ments of the procedures performed.

Testing at Vogtle is currently performed on an EMIT-Qst instrument using EMIT reagents supplied by the Syva Company.

(,, It makes use of dry, freeze-dried reagents that can be used on a single-test basis. The test is run by placing the urine container under a sampling probe, which withdraws an exact quantity of urine, which is then transferred into the reagent container along with a measured amount of water. This solu-tion is sucked into the spectrophotometer, which measures the extent of the antibody interaction and records the result.

This is compared to the readings for the standards to deter-mine if the sample contained the drug being tested for.

Before any specimens are tested, the operator checks the calibration of the instrument by analyzing the negative, low and medium calibrators for each of the eight drug classes l

I tested for. These results are filed along with a test, consent and chain-of-custody records. The specimens are tested first

l

for marijuana, then cocaine. If either or both of these are positive, no additional screening is done on that specimen since it will be rescreened for all drugs at MCG. If the first or each of the subsequent tests are negative on any specimen, testing for additional drugs will be conducted.

Only specimens testing positive for one or more drugs are sent to MCG. This approach is sound and reliable.

The detection levels used at Vogtle for marijuana (75 ng/ml) and cocaine (300 ng/ml) are the same as those used at other laboratories serving Georgia Power, MCG and PSPA.

MCG also uses the same EMIT detection levels for the other six drugs (PSPA uses a different screening technique for certain prescription drugs).

- The rescreening and confirmation results at MCG show an excellent correlation with the initial screening results at Vogtle. Occasionally a specimen that is screened positive at Vogtle, but very close to the detection level, may or may not rescreen positive at MCG. Two such examples occurred l during the time of the visit of Drs. Willette and Howard.

MCG thus provides an excellent quality control check for l

the on-site testing at Vogtle.

4. Drug-Testing Procedures--Medical College of Georgia.

The laboratory director, Dr. Lawrence Hendry, was out of town l at the time of the audit visit. However, the staff directly responsible for testing were available for interview. The senior chemist, John Craig, has had 19 years experience with mass spectroscopy. The laboratory is very well equipped, 1

well maintained, and well managed. For the past two months,

__ - _ _ __ _.___ _., _.__-21 ___ __ _ _ _ _. __

j

all EMIT screening has been performed on a fully-automated analyzer, the Demand system distributed by Cooper Laboratories.

It provides very fast (400 results per hour, on an 8-drug panel of 50 specimens) and highly precise results with minimal handling. Furthermore, the results are presented in a semi-quantitative manner, which will provide valuable prevalence data for program analysis.

All samples that exceed the prescribed cutoffs, which are the same as used at Vogtle, go to gas chromatography /

mass spectrometry confirmation. MCG has adapted appropriate procedures for the extraction and derivatization of the urine samples. The specimens are then analyzed on one of the GC/MS instruments under a full-scan mode of operation. Except for

( the THC metabolite, any presence of drug or its metabolite that exceeds background noise 'by a ratio of at least 7 to 1 is called positive if it has the same GC retention time and the full-scan mass spectrum is a match of that for the reference compound, e

i.e. , marijuana, cocaine, amphetamine, etc. For marijuana, a sensitivity standard of 75 ng/ml is injected-and compared to the reconstituted mass chromatogram for the three primary ions for the unknown sample. Such procedures are appropriate and accurate and in accordance with accepted analytical and toxicological practices.

GC/MS analyses may be conducted under different modes of operation. The older and more common method causes the drug molecules to become ionically charged by " bombarding" them

) with a beam of ions as they emerge from the gas chromatograph.

They need to be ionica11y charged in order for them to be separated by the mass spectrometer. The MS can then be tuned to focus on certain " selected" lons, producing a " selected ion monitoring" or "SIM" mass chromatogram. An optional mode is to record the entire mass spectrum, the so-called " full-scan" mass chromatogram. The SIM method usually is more sensitive, whereas the full-scan mode gives more structural or identifying information. Both can produce forensically acceptable results.

Drug-Testing Procedures--PSPA/SKBL. PSPA drug 5.

handling and testing is generally acceptable. The audit team has some concern with the specimen-handling procedures within the laboratory, which follow those used for all clinical samples processed each day. The number of people with access to the

-- specimens at any time is excessive. We suggest alteration in procedures to assure that unassailable security is af forded GPC specimens. The current situation does not jeopardize current or past results since confirmed positives are preserved, but some specific procedural GPC specimen guidelines at the laboratory will further assure chain-of-custody security and limit access to GPC specimens to certain laboratory personnel. We can discuss such access limitations with laboratory management directly if appropriate.

I

H V. RECOMMENDATIONS A. PROGRAM / POLICY CONCLUSIONS AND RECOMMENDATIONS.

Based on the evidence presented to us, through on-site interviews, discussions with local law enforcement, review of accident data, hotline calls, and other data, we conclude that an effective drug and alcohol prevention program is in place and working at Plant Vogtle. Historical and statistical data reviewed did not establish evidence of a drug problem, although the issue remains an item of legitimate management concern.

The program, as developed, has a solid organizational infra-structure, is clearly understood by all employees, and appears to be administered in a fair and consistent manner.

There are, however, several areas to which attention should be given in order to further strengthen this viable program. They are:

1. Random Testing. Random testing of all site  ;

personnel should begin as soon as practical to achieve maximum

! drug-use daterrence on site. While the current policy and program has had a measurable positive impact limiting drug use, a random-testing program will be the single best ongoing deterrent to drug and alcohol use on the job. The combination of an objective standard l

of measurement, predictable discipline, and an uncertainty as to the occurrence of testing will act as a powerful dissuader of drug use.

f This random program need not be inordinately extensive. Forty to l

fifty tests per month would most likely be sufficient. These tests are not primarily to identify users, but to deter use, hence large numbers are not required. Since all workers on site are badged,

l and since each badge has a unique number, developing the  !

- random base should be relatively simple. No one intervies 9F I during the course of this audit opposed the idea of random testing. The only concern stated by both staff and craft was that the policy be applied to all people on site, i

! including GPC and contractor management.

2. Awareness and Supervisory Training. From discussior.s held over a period of three days, it became clear that while the awareness of the drug and alcohol policy was universal, the understanding by workers and supervisors of the underlying health and safety hazards and intervention f needs, and the supervisors' role in administering the policy was not. Given the number of people on site, turnover rates, ,

and transfers, establishing an awareness-training program for all craft and staff might yield marginal benefits, since the rate of drug use on site appears to be rather low. But for the policy to be ef fectively administered, supervisors must be trained and retrained in both general awareness of the nature and consequences of drug and alcohol use and in identifying and responding to people who may have drug- or alcohol-related problems on or off the job. To this extent, I there are several programs in place. GPC has begun a " fitness-f or-duty" module that is available to GPC and contractor super-l visors, and has been presented four times to approximately

! 100 supervisors total. At least one of the contractors (Walsh)

! has given its supervisors additional guidance. But the vast majority of contractor supervisors have received little super-visory training. GPC is currently reviewing this program with

- . - - - - . - - , , , - ~ - . - , , _ _ _ , .- ~ - ,,, ,a ., , , - . . - - - - - - - ,,w- . , - - - . - - ..a, , . . - - , -- - .,.

the intention of revising the curriculum and making it available to more supervisory contractor and GPC personnel.

We recommend that the supervisory training program be f

expanded so that all GPC and contractor supervisors, including union foremen, will have skills training in identifying signs and signals of possible drug or alcohol use, and performance, safety problems, and policy procedures to intervene so as to administer the policy in a consistent manner. ,

3. Management. The current infrastructure for the oversight and implementation of the Vogtle Plant anti-drug program and policy works well. The Drug Program Coordinating Committee serves as an effective vehicle for administering this policy because its membership reflects the major program elements on site and benefits from the direct involvement of '

h i the Project General Manager. Further, the GPC policy of having a senior legal advisor on site provides effective facilitation and coordination of policy and programs. The legal advisor w

is able to provide clear, consistent guidance to all echelons of GPC senior management. This results in prompt, consistent, and reasonable actions (policy enforcement) which add i significantly to the credibility of the program. As policy implementation becomes more routine, there may be a tendency for the coordination process to be pushed down lower in the f org aniz ation. That would be unfortunate since the key to an ef fective drug and alcohol policy is the stated and evident commitment of senior management at all levels. At a minimum, the policy coordinator must continue to have direct and continued access to the Project Manager and the membership

t of the Committee should continue to include present senior management representatives.

~

This organizational model should be considered for use throughout the company, including at the corporate level.

4. Indicators. A select family of trend indica-tors should be identified by the Drug Program Coordinating ,

Committee which it would use to assess trends of drug and alcohol use over time, and which could signal shif ts in drug or alcohol use patterns. Indicators could include, but would not necessarily be limited to, the following:

a. Accident rates, by category (i.e.,

lost time, medical attention), with trend lines and analysis by organiza-tion, work category or demographics;

b. Urinalysis rates;

[

c. EAP referral rate for GPC employees (more referrals do not necessarily mean more drugs);

d. Security / law enforcement incident repo rts;

e. Hotline trends; e-l

f. Survey data, ,

I

g. Absentee data;

h. Canine search reports.

Much of this data is already collected and available. What would be new would be its institutional use by all members of the Drug Program Coordinating Committee on a regular, anticipated basis.

Combined with other personnel, security, "Q", and safety reports, the indicators can serve as cues, confirmation signals, or warning flags, for changes in trends.

I

_ _ _ = _ _ . - __ . _ _ _ _ _ _ . _ _ _ . _ . . ._. _ _ _ _ . .

5. Hotline Call-In Guidelines. Guidelines are needed with respect to hotline call-ins to provide management ,

discretion when it would appear prank calls are being made identifying an individual who does not appear to be in violation of the company's drug policy and has already proven to be negative for drugs on two or more tests withir.

a recent six-month or one-year time period. Vogtle manage-s ment should exercise discretion and not automatically require a drug test without further inquiry and/or observation.

6. Alcohol Emphasis. While there has been much attention focused on the drug policy, the concern with alcohol has also continued. GPC 's recent reemphasis of its "no alcohol" policy is an important reminder that drinking off site prior

, s to coming on the job is not acceptable. Tne presence of the "Intoximeter", communication by Project Management to all safety and construction managers, and liaison with union leadership indicate the company's awareness and commitment in this regard. GPC should remain sensitive to keeping ,,

the "no alcohol" policy visible with continuing ongoing reinforcement.

.c B. DRUG-TESTING RECOMMENDATIONS

1. Specimen Collection Centralization. All Vogtle 1

personnel, whether GPC or non-GPC employees, should be proces-l sed for specimen collection at the Safety Department facility.

Such a move will assure consistency in testing and respond I to employee perceptions.

l

2. Drug-Test Handling Procedures:

a. The transfer of all specimens to.the Medical College of Georgia (MCG) should be .in . locked specimen cases.

b. The retained split specimen should be sealed with fragile evidence tape prior to freezing. ,

c. The split specimen that will be tested should be processed as follows:

(1) Fitness for duty: sealed with f ragile-evidence tape and stored in refrigerator (not freezer) until transfer to Medical College of Georgia, which should be within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of collection.'

(2) Discretionary: not sealed until after initial testing by Vogtle Safety Department staff. Specimens should be stored in refri-gerators until testing occurs, which should be as soon as possible and in any event on the day of collection.

3. Drug-Testing Procedures at Vogtle:

a. The on-site screening facility at Vogtle should be maintained. At the present level of testing, the Qst system provides the ability to obtain same-day results on discretionary cases, thus promptly clearing the possibility of drug use when tests are negative, and thus allowing a return to work assignments after testing. Results on specimens sent to MCG take from 4 to 5 days on the average and those from PSPA take up to 7 days or longer. If an increased level of on-site testing takes place at Vogtle, a semi-automated EMIT testing instrument should be acquired. Such equipment will reduce operator handling and time. Secure specimen handling procedures can be readily implemented for continuous assurance of accuracy in testing. Alternatively, all screening could be conducted at MCG, if overnight reporting could be guaranteed.

l 1 - _ _ _ . _ _ -

s . .

f. 4

b. The on-site screening procedure should be

\ modified slightly and conducted as follows: One specimen bottle should be removed frna the refrigerator. No other specimens should remain in the immediate working area.

A small portion of the specimen should be poured into a disposable plastic cup. The specimen bottle should then immediately be capped. The cup containing the specimen should be used to provide samples for the sequence of EMIT-Qst tests. The Teflon-coated probe should be wiped between each sampling. When testing is completed, the cup and its remaining cont'ents should be disposed of. If the specimen tested negative in all tests, the two splits may also be disposed of. If the specimen tests positive, the original split-specimen bottle should be sealed with fragile-( evidence tape and refrigerated until it is transferred to MCG, which should occur within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

I 4. Medical College of Georgia Capacity, Statistical Reporting and Confirmation Procedures:

a. As noted above, if testing is to be increased significantly so as to overtax the EMIT-Qst system at Vogtle, and a semi-automatic EMIT testing machine is not acquired, consideration should be given to arranging for overnight i

screening at MCG on the new Demand unit. The samples can be loaded at the end of the day and the machine can process them overnight, although it will do 30 specimens with controls in an hour. MCG may be able to provide a lower price if the total number of samples were increased.

t

. - - - . - - , - - - , - , - . - . - . ,,- - - - ----. -n - . , - , - - - , .._,,-----,-,,m-,,- - - r , n, -..--m-----. ,em,m ,

b. The new Demand system at MCG generates semi-quantitative results, which would appear on the computer-generated report. This saves labor and provides clear documentation of the results. Caution must be exere,ised to record these concentration values. We recommend that, I at least for the time being, the concentrations be deleted I

by marker and only positive or negative be ascribed to I i

results on the new form with respect to any individual test j l

for company disciplinary or employment purposes. This will i minimize the possibility of information on associated I

detectable levels of drug that fall below the prescribed cut-offs with an individual. The point is that such values have a reduced level of reliability, and, since the appropri-(.

ate cut-off is not reached, could inappropriately misidentify someone as a drug user. However, this is extremely valuable information and should be reported to Vogtle on a quarterly basis in histogram form, such that a profile of actual con-

-- centrations versus number of tests can be obtained (not names, but numbers). This will provide information on the advisability of lowering a cut-off on any particular drug. Until three or six months of this data is available, we suggest that the 75 ng/ml cut-of f for marijuana be retained.

c. All of the confirmation procedures should be the same. There are two choices: (1) all should be run quanti-tatively with appropriate internal standards, calibration curves, etc. and designated cut-of fs; or (2) all should be run under full-scan conditions for drug presence only. The current THC-acid procedure is not truly quantitative. No internal standard is used. MCG has been using a 75 ng/ml sensitivity standard which is inappropriately high. A cut-off of 10 ng/ml is standard, although the military uses 20 ng/ml. When operated in the full-scan mode, this level of sensitivity may not be )

sustained. Fortunately, all of _the marijuana positive speci-l mens have been sufficiently high that all 68 over the past year have been confirmed. Nevertheless, there will be 'pecimens ,

I that will be close to 75 ng/ml that could not be confirmed l I

with the present method. <

Drs. W111ette and Howard recommend that the full-scan method for presence only be used across all drugs. This is the simpler procedure and will require negligible modification of existing procedur"es. In addition to being less troublesome I

and more accurate, it should also save money. The debate over selected ion monitored (SIMs) GC/MS vs. full scan can be resolved, but the production of a properly controlled full-scan spectrogram has considerable evidentiary value. To go to quantification ,

-- i with SIMs will require expensive standards, much effort, etc.w and can be deferred for consideration for specific sampling l l

purpose in the future. To further support current accuracy,  !

l equipment sensitivity levels and limits of detection should i be periodically checked.

5. PSPA/SKBL specimen handling. It is recommended that PSPA establish limited access within their laboratory to Georgia Power Company specimens and that the chain of custody in handling of GPC specimens reflect forensic rather than clinical standards.

1

% s

6. Drug-Testing Facilities and Laboratory Management Meeting. A meeting of laboratory and Vogtle safety personnel responsible for drug-testing procedures, specimen collection, and oversight is recommended. The laboratory director and chief toxicologist, as well as the senior Vogtle on-site safety specimen collection / testing representative, should meet together to assure ongoing understanding of testing guidelines, cut-off levels, chain of custody, report prepara-tion, specimen handling, log-book and record documentation, and specimen-retention requirements, and to discuss these recommendations. Project management at Vogtle, Georgia Power's company management, including Labor Relations and

( the chief legal advisor at Vogtle, could facilitate and direct such a meeting, at which outside experts such as Drs. Willette and Howard, could participate.

I

.- e METHODOLOGY OF ASSESSMENT Bensinger, DuPont & Associates' President Peter Bensin'get and senior associate Dr. Richard Bucher, and toxicologists Dr. Robert Willette (President of Duo Research) and Dr. Larry Howard (Director of the Georgia Bureau of Investigation Crime Laboratory) participated in an in-depth review and assessment of the Georgia Power Company Plant Vogtle Anti-Drug Program.

Mr. Bensinger, Dr. Bucher and Dr. Willette (representing Dr. Howard) met with Georgia Power Company Plant Vogtle project management and corporate labor relations and administration on January 9,1986 to review the assessment objectives.

Messrs. Charles Whitney, Don .'oster, Wyman Lamb and Don Ellis attended this meeting; Mr. Whitney was designated as principal liaison for the review team.

(

It was agreed that al.1 Georgia Pcwer Company designated drug-testing laboratories, clinics, and drug-test collection facilities would be visited by Drs. Willette and Howard,

-- including the Plant Vogtle Safety Department, the AMI Clinic ,

in Atlanta, a local physician's office in Waynesboro, the Medical College of Georgia Laboratory in Augusta, and the Smith-Kline P.S.P.A. Laboratory in Atlanta. Dr. Richard Bucher would make an on-site three-day visit at Plant Vogtle to enable him to interview project management, company employees and supervisors, craf t and trade representatives, union leadership, local law enforcement, and on-site Nuclear Regulatory Commission inspectors. The regional office of the Nuclear Regulatory Commission in Atlanta would be visited Exhibit A

, ~.

by Peter Bensinger, who would, on an informal basis, obtain staf f perceptions f rom the Regional Counsel, Investigations and Allegations Coordinator and Section Chiefs f amiliar with the Plant Vogtle program. i I

Interview procedure was established so that members l of the assessment team would have an opportunity to meet on site with key personnel responsible for the Anti-Drug Program. Dr. Bucher would have an opportunity to review documentation, accident reports, data with respect to hotline and drug-test results, and other reports. Drs. Willette and Howard would review qualifications of staff as well as adequacy of equipment and procedures. The team had two distinct program / policy review elements: policy / program

- review assigned to Dr. Bucher and Peter Bensinger and drug-testing procedure / policy review assigned to Drs. Willette and Howard. Following completion of the on-site interviews by Drs. Willette, Howard and Bucher, and Peter Bensinger,

~~

verbal and draft written reports were prepared and presented e-on March 6, 1986 to Plant Vogtle management representatives Don Foster and Charles Whitney and company Labor Relations Manager Don Ellis. Peter Bensinger was assigned the responsibility of preparing the formal assessment findings and recommendations.

Highlights of the Plant Vogtle Anti-Drug Program Assessment were presented to Vogtle Project Review i Board at Plant Vogtle on April 4, 1986.

NOTE: Interview schedules are attached, Appendix C.

I i

BIOGRAPHY of j

PEIER B. BENSINGER j

Bensinger, DuPont & Associates Peter B. Bensinger is President of Bensinger, DuPont & Associates, a professional consulting firm providing services to private industry, national and cannunity organizations, professional sports, and goverment on drug abuse policy.

Prior to forming this consulting service with Dr. Robert DuPont, Bensinger served as A&ninistrator of the United States Drug Daforcenent Administration. He was Ibrd appointed to this position in January of 1976 by and was confirmed by the Senate, serving over President Gerald R.

5-1/2 years under four different Attorneys General as Director of this major federal investigative agency. The Drug Enforcenent Adninistration is responsible for enforcement of U. S. narcotic and dangerous drug laws and has 4,000 anployees in 160 offices in the United States and 40 foreign countries. The A&ninistrator of the Drug Enforcenent Adninistration is

' responsible for criminal investigations, laboratory services, intelligence, training for federal, state, and local law enforcement, and regulation of l'

the legal manufacture of controlled stbstances for legitimate medical uce.

Durirg Bensirger's tenure, heroin overdose deaths decreased fran 2,000 a year in 1976 to 800 in 1980, while heroin imports fell from 7 tons to (r' under 4 tons per year. Legislation enacted in 1978 provided for the forfeiture of assets derived fran illegal drug trafficking to be seized by the goverment.

Prior to Bensinger's appointment in Washington, he served as Director f l

of the Illinois Department of Corrections with direct responsibility for l

all penitentiaries, reformatories, training schools, and parole supervision.

-- During this period he was elected by directors of other state prison systems as President of the Association of State Correctional Administra- -

tors. He has served as Chairman of the Illinois Youth Counission, Chief of the Crime victims Division of the Illinois Attorney General's Office, and as Executive Director of the Chicago Crime Comnission.

Bensinger held responsible positions with the Brunswick Corporation fran 1958 to 1968, serving as General Sales Manager for Brunswick United i Kingdon in Iondon, England, as General Sales Manager for Europe in Frank-furt, Germany, and as General Merchandise Manager of Brunswick Interna-tional in Chicago.

He was a principal delegate to Interpol for the United States in 1978, was appointed by the International Association of Chiefs of Police to serve on the Executive Caunittee of this 12,000 marber police organization, and was Chairman of its Narcotic and Dangerous Drug Cannittee. He has been honored by the National Sheriffs Association with Honorary Life Menbership and has received honorary Doctor of Law degrees from San Marcos University

' in Lima, Peru, and Dankook University in Seoul, ' Korea, for $utstanding leadership in international drug control.  !

l Exhibit B(1)

4 Peter B. Bensinger page 2

! Bensinger, DuPont and Associates have provided consultation and training services to American Airlines, Boise Cascade Corporation, E. I. du Pont de Nemours & Cmpany, Cormonwealth Edison Co., the F.B.I.

National Academy, Georgia Power, Norfolk Southern Corporation, Edison Electric Institute, Airport Sec'urity Council, American Gas Association, Times Mirror, national associations of parents groups, hospitals and health providers, and major companies in the pharmaceutical, energy, transportation, construction and computer fields. Both the Senate and House of Representatives have sought Mr. Bensinger's testimony, and he has lectured widely throughout the United States on the subject of drug control, drugs in the workplace, and the need for consistency in corporate and goverment policy. He has authored a neber of articles p@lished in the New York Times, The Washington Post, Chicago Tribune, and in other national W international publications on law enforcement and drug abuse, and has appeared on network evening news programs, the Today Show, Good Morning America, Issues and Answers, the MacNeil-Imhrer Report, and Nightline.

Se November-Decenber 1982 issue of the Harvard Business Review featured a Special Report by Bensinger on " Drugs in the Workplace," and he has been quoted on this subject in 1983 arri 1984 cover stories in Time, Newsweek, U.S. News and World Report. ' Mr. Bensinger authored a monograph published by the Washington IAgal Foundation in 1984 entitled Drugs in the Workplace:

( -

Bnployers' Rights and Responsibilities.

Mr. Bensinger has been awarded the Distinguished Service Medal frm the Goverrunent of Peru. He has been the recipient of the U. S. Distin-guished Service Award fra the Coast Guard, the highest award presented to a civilian, and has received special commendation for outstanding leadership in equal employment opportunity fra the Department of Justice.

he John Howard Association awarded Bensinger its highest recognition for

~

outstanding service in the field of corrections in 1971. He was Man-of-the-Year for the Spanish-American Congress of Chicago in 1975 and was awarded the Distinguished Alunni Service Award by the Chicago Latin School-

! in 1978. Mr. Bensinger has served on the Board of Trustees of many civic i ard professional organizations, including the Phillips Exeter Academy, the National Council on Crime and Delinquency, the American Correctional Association, the Juvenile Protective Association, the Chicago Council 3

i for Cmmunity Services, the City Club of Chicago, and the American Bar Asmciation's National Commission on Corrections. He has been a member of the Visiting Cannittee on the Humanities of the University of Chicago and a member of the Illinois Law Enforcement Comission. In 1981 he was General Chairman of the Boy Scouts of America Explorer Scouts National Law Enforcement Conference. From 1973 until 1985, Bensinger has represented j the United States Attorney General on the six-member Board of Directors of Federal Prison Industries, Inc., a $150-million goverment corporation responsible for industry in the Federal Penitentiary System.

Mr. Bensinger, a graduate of Yale University, was born in 1936 and speaks French, Spanish, and Italian. He is married to a physician, Judith S. Bensinger. S ey have four children.

I i

a-.--_----_.--. - - - - - - . - - - - . . . . - - - . . - - - - - . - . . - - - - - - -

RIGIARD B. BLX3tER Bensinger, DuPont and Associates Dr. Richard H. Bucher is the Manager of the Washington, D.C. office of Bensinger, DuPont and Associates and an expert in substance abuse, management systems, and program audit and analysis. Fram 1972 until 1981', he served in senior capacities with the Federal drug abuse prevention prograns under three A&ninistrations. As the Executive Assistant to the Director of the White Bouse Special Action Office for Drug Abuse Prevention . (1972-1975) he was involved with virtually every issue of drug abuse treatment, prevention and research addressed by the Federal government. Staff Director of the Cabinet Cannittee on Drug Abuse Prevention (1975-1977) and Assistant to the Director of the National Institute on Drug Abuse (1975-1978), he coordinated major prevention, research, training, and treatment programs of 17 Federal Depini =nts and Agencies, which included a ocaprehensive Federal drug abuse prevention plan, and the linkage of drug abuse treatment and rehabilitation with vocaticinal training efforts. As a senior ocnsultant to the White House

> office of Drug Policy (1978-1981), he played a major role in identifying programs which effectively linked drug abuse treatment services with other cxmnunity support services such as vocational training, legal assistance,

community mental health centers, medical and social service referrals, )

law enforcement activities and court diversion programs. l As a management consultant (1978-1984), Dr. Bucher has been involved in 1 I projects designed to enhance the ability of management to identify the inpact  !

of drug abuse in the workplace and has established programs of drug testing, prevalence surveys, and managenent audits for various clients. He has been a consultant to industry on the developnent of corporate drug and alcohol policy and progras, and clients included a major multinational pharmaceutical corporation, a national medical service support ocupany, and the National Association of State Alcohol and Drug Abuse Directors. He joined Bensinger, DuPont and Associates in June of 1984.

Dr. Bucher is the co-author of ' Myth and Fact", a drug abuse information primer published by the American Council on Drug Education ard has authored nunerous articles on drug abuse treatment.

He is a graduate of the University of Miri sta (B.A.) and holds master's and doctorate degrees fran Duke University. He lectures regularly at George Washington University in Washington, D.C. and has held faculty appointments l at seven colleges and universities in the United States and Europe. He is on the Editorial Board of the Southern Review of Public A&ninistration and the Advisory Board of the Institute for Social Research, University of Michigan.

Dr. Bucher retired fran the United States Air Force in 1978 with the rank ofmajor.

Exhibit B(2)

PERSONAL RESUME Robert Edmond Willette l l

- Director, Duo Research --.. - -. ... - .

l a division of Research Designs, Inc. -

l 2 Acton Place, Annapolis, Maryland 21401 . i l

EDUCATION: .

l

a. Undergraduate:. Ferris- Institute; Big Rapids, Mi chi gan g-f t - :- -- --

1951-55. Maj or - Pharmacy, Minor - Mathematicst B. S.

(June, 1955).

b. Graduate: University of Minnesota, Minneapolis, Minnesotal 1955-59. Major - Medicinal Chemistry, Minor - Organic Chem-istryl Ph. D. (December, 1960). Thesis

Title:

Structural Studies of Certain Pharma =clogically Active Coumarins Isolated f rom Umbellif erae (Dr. Taito D. Seine, Ad visor ) .

TEACHIN3 EXPERIENCE:

Undergraduate Courses: Medicinal Chemistry (organic and j a.

[' inorganic), organic chem,i stry, general chemistry, drug assay, pharmaceutical cal =ulations.

(.

b. Graduate Courses: Advanced Medicinal Chemistry, covering synthe si s , structure-activity relationships, mechanism of 4 action, metabolism and orug design.

.. RESEARCH APPOINTMENTS: - . ..

e.

a. University of Minnesota, Research Assistant, 1957-59.

b. The Upjohn Company,"Research Asso=iate, June-August, 1960, and June-Detober, 1961.

c. Australian National University, Resea-ch Fellow, 1961-63.

d. Austrait an Commnnwealth Scientific and Industrial Resear=h  !

Organication, Mel b ourne , Research Officer, 1963-64. l

e. University of Michigan, Research Associate, 1965c66.

ACADEMIC HONORS AND FINANCIAL AWARDS: -

m. Rowel Fellow, University of Minnesota, 1957-59.

. Exhibit B(3)

i c .

b. Public Health Service Post-Doctoral Fellowship, 1961-63. i l

1

c. National Cancer Institute Research Grant, 1969-71.

d. University of Connecticut Research Foundation Grant, 1967-68.

i

e. State of Connecticut Research . Foundation Contract, .1969-70. . . .

f. City of New York, Public Health Department Contract, 19.70.

g. National Institute of Mental Health Research Grant, 1971-72.

< . ADMINISTRATIVE. APPOINTMENTS:"" 2 C "' -" "~~ ~ ' ~ ~~J.L l. .'-- ;:_: . */ _.. ...

a. National Institute of Mental Health, Rockville, Maryland 3 Chemist, Biomedical Section, Center f or Studies of Narcotics and Drug Abuse, 1972-73.

b. National Institute on Drug Abuse, Rockville, Marylands Acting Chief, Medici'nal Chemistry and Technology Section, Biomedical Research Branch, Division of Research, 1973-75.

c. Nati onal Institute on Drug Abuse, Rockville, Marylands Chief, Research Technology Branch, Division of Research,

~

1975-81. r i ,

', d. Director, Duo Research division of'Research Designs, Inc.,

Annapolis, Maryland, 1981 - present.

e. Con sul tant , White House /DoD/NIDA Conference on Military Drug Urinalysis Program, May 19E2 - present.

e. Drug Abuse Consultant, Staff of the Assistant Secretary of the Navy (MRA), May 19S2 - present.

.I ,

f. Consultant, Naval Military Personnel Command, U. S. Navy, Canuary 19E3 present.

g. Member, Technical Advisory Board, Performance Diagnostics, July 1983 - June 1994.

h. Consultant, Pr= bat. ion Division, Administrative Dff f == of the U. S. Courts, August 19E3 - present.

f 1. Consultant, Federal Bureau of Prisons, September - December -

i 19E3. l l- Member, Blue Ribbon Panel f or Review of Drug Urinalysis J.

Program, U. S. Army, October - December, 1983.

k. Consultant, Office of the Deputy Chief of Staff for -

! Personnel , U. S. Army, May 1984 - present.

i 9

e

- . ~ - - -

' ~

ADMINISTRATIVE EXPERIENCE:

'a, Current Responsibilities: Consultant to f or-profit and non-profit research firms, private industry, public utilities and government agencies in the general areas of drug-related

- rasearch and employment problems. . These include the. develop .. ...

ment of diagnostic assays,- drug development, alcohol and . - -

drug problems in the work place, urinalysis programs, and basic research. Serve as expert witness in labor arbitra-tion hearings and trials on drug analysis. Writing and 4

editing of research publications, including bool:s and research articles on marijuana.

~

J.- b..' Branch Primary ResponsibilitiWs~ ~a't NIDAt- _- THF supervision c$f.< -! Er- %-

staff of professionals (GS-14), assistants and secre- -

3 taries in the perf ormance of Branch activities. . These included the planning, review and' management'of research l

grants and research and development contracts in the general j areas of all chemical aspects of drugs of abuse. This in-cluded synthesis, SAR studies, metabolism, pharmacokinetics, analytical procedures, drug delivery systems and f ormula-tion, and theoretical studies. Also responsible f or the development and operation of the computericed data system to

, managa the Division's grant and contract programs and Con-l ,

trolled Substance Supply Program. ,

I

c. Spe=1aIS Appofntments:'-r-Chairmarr, ' Interagency Committ'em on" n --

j (' Drug Control (coordinates drug scheduling activities between

( NIDA, DEA and FDA), 1976-79. Chairman, NIDA Abuse Liability l

Task Force, 1975-76. Chairman, NIDA and SACDAP Committee on l

Drug Detection and Urinalysis (resoonsible f or management of f eceral proficiency testing program f or urinalysis labora-l tori es) , 1974-21. Chairman, NIDA Task Force on Drugs and l' Driving and liaison and consultant to National Highway Traf-fic Saf ety Administration, DOT, 1974-B1. Consultant and liaison to . Population..Research Center, .NICHHD, NIH, and Drug .-

Detection Section, Walter Reed Army Research Center. Member of Interagency Committee on New Therapies f or Pain and Dis-comf ort, Public Health Service, 1978-81. Chairman WHO/NIDA Technical Group on Health Strategies f or the Control of Drugs as Related to Traffic Saf ety, 1981. Member of Depart-ment of* Def ense/NIDA Expert Advisory Group on Urinalysis,

! 1952-present.

d. Special Assignments: U.S. representative- to United Nations Laboratory on Narcetics meeting on cannabis research, Geneva, 1973. NIDA representative to IUPAC, Jerusalem, 1975. NIDA representative to International Conf erence on Aluchol, Drugs

) and Traffic Saf ety, Toronto, 1974, and Melbourne, 1977. i

) '

! Consultant to Australian Parliament Senate Committee of l Eocial Welfare, Canberra, 1977. Special witness bef ore the State of New South Wales Joint Parliamentary Committee on - . ,

I Drugs,. Sydney, 1977. NIDA representative to WHO Advisory

• Group on Drug Scheduling, Geneva, 1979..

I e

---A - _ - - . - , - - - , , - - - - - - , - , , - - - , . . - , - - - . - , - - - - -.-,--..--n,------..--,...-------..-,---n.nm. -

,--,-n,-----n, . - . , , , - - , , - - - - - , - , . , , , -

PROFESSIONAL SOCIETIES:

a. American Pharmaceutical Association, active member since 19518 Medicinal Chemistry Section, Academy of Pharmaceuti-cal Sciences, program chairman, 1971-758 Chairman-elect, 1973-74I Chairman 19 74-75. - - - ---- -- - - - . . .

, b. American Chemical Society, member.

c. Rho Chi Honor Society. l

d. Sigma Xi.

RESEARCH EXPERIENCE:

a. Isolation and characteri=ation of natural products. -

b. Syntu sis of peptides. -

j c. Synthesis of arylsulfonyl derivatives as antidiabetic com-pounds (in:.ludes Tolinase) .

4

d. Synthesis of indole analogs as anticonvulsants, antihyper-tensives and psy=hopharmacologic agents. ,

~

e. Synthesiis of aza an'a logs of psycho-active indoles ar d --

other aromatic heterocycles.

(

f. Synthesis aM: physico-chemical characteri=ation of pyrroliz-idines as circinogens and antitumor agents.

g. Synthesis of radiciodinated tumor-lo=alicing agents.

h. Synthesis of ursatu- ated la: tones and esters as anti- .

.. tumor ag ent s.. -- - - -

e-

1. Synthesis and evaluation of long-a: ting narcotic antago-nists and analgestics.

i l J. Quantification of analgetics and narcoti=s* antagonists in pha-sa:eutii=al f ormulations and body fluids.

l k. Pharma =cl ogical evaluation of analgetics and narcotic antagoni sts. -

! 1. Examination of the analgesia ble= king ef f ects of ascorbic acid on morphine. - -

i

m. Comparison and evaluation of assay characteristics f or .

cannabinoi ds.

n. Chemical detection of drug impairment. - -

3 1

PUBLISHED RFSEARCH ARTICLES:

1. Soine, T. D. and R. E. Willette. 1960. The isolation of beta-allocryptopine from Argesone squarrosa, subsp. squar-i rosa. J. Amer. Pharm. Assoc. (Sci. Ed). 49:369-70.

l~ ~ ~

2.' ~ Will ti:h~- R.# E." an'd T. d'.1 Soine "-1962

~ ~

Isd1ation,*puri M ' " ' '

cation and structures of pteryxin and suksdorfin. J. Pharm.

Sci. 51:156-59. ,

3. Wright, J. B. and R. E. Willette. 1962. N-Ary1sufonylsemi-carb azi des. J. Med. Pharm. Chem. 5:B15-22. .

Willette, R.- E. and T. .Or Soiner ;1964- Structui es of

• colum- .* -1 4.

bianidin and columbianin. J. Pharm. Sci. 53:275-79.

5. Keasling, H. H., R. E. Willette and J. S muskovicz. 1964.

The Anticonvulsant activity of 3-acylindoles compared with phenobarbital. J. Ned. Chem. 7:94-96.

6. Albert; A. and R. E. Willette. 1964. Di azaindenes (" A=a-indoles"). Part II. Methyl derivatives of 1,7-dia=ainziones.

J. Chem. Soc. 4063-65.

i

, 7. Willette, R. E. 1965. Dia:aindenes (" A= ai n d ol es" ) . Part III.

S ynth e ti c. .appnca ch es .,(P_r e3. i mi n an y e r esul t s hr.J r.rh em. Soc.9. = :- . .

5 974-7E.- ~ ~ - *- .

( B. Amarego, W. L. F. and R. E. Willette. 1965. Quina:olinos.

Part VI. 2,2'- and 4,4'-Bi qui na=oli nyl s. J. Chem. Soc. 1259-62.

~

j 9. Culvenor, C. C. J. and R. E. Willette. 1966. Ioni=ation

! :onstants of pyrroli:idine alkaloids. Austral. J. Chem. i 19:B25-89. j

,' 10. Counsell, R..E. and 'R. E. Willette. 1966. Synthesis of - -

labeled isomers of dichlorodiphenyldichloroethane LDDD). Js Pharm. 5:1. 55:1012-15.

11. Counsell, R. E., R. E. Willette, and W. Di Guilio. 1967.

Tumor le=alizing agents. II. Radiciodinated analogs of 1,1-Di chl or o-2, 2-bi s- ( c hl orcp h enyl ) eth ane. J. Med. Chem.

10:975-77.

l 12. Counsell, R. E. , E. H. Hong, R. E. Willette and V. V.

Ranade. 1968. Tumor locali=ing agents. V. Radiciodinated I pregnanes. Steroids 11:817-26. ,

13. Counsell, R. E. , V. V. Ranade, P. Pocha, R. E. Willette and-W. DiGuilio. 1968. Tumor localizing agents. VI .

• Radioindi-nated analogs of dichlorodiphenyldichloroethane. - J. Pharm.

~~

Sci. 57:1657-61.. .

8 .

. _ _ ~ , _ . - _ _ _ _ _ _ _ _ . , _ , _ _ _ . _ . _ . _ _ _ . _ _ _ _ . _ _ _ - _ . _ _ . _ . - _

e .

D

'.  : l l 14. Doerr, I. L. and R. E. Willette. 1970. Synthesis of 5-(9-l adenyl)-4-ethyl-3-methyl-5 (M)-f uranone. Tetrahedron Letters. -

pp. 667-68. ,

15. Willette, R. E. and R. C. Driscoll. 1972. 4-Amino-3-bute'n-

. ...-.....a....,.-

1.. .ol ester

. .. s.. --.J . Med. . Chem.--15.

.-  :.110-112

~ . ~ . . . ~ ~ . . - , - - - . . - - -

Willette, R. E. and L. V. Cammarato. 1972. Phytochemical 16.

survey of Connecticut. I. Isolation of monocrataline f r...a Crotalaria sagittalls L. fruit. J. Pharm. Sci. 62:122.

17. Rosenberg, P., L. T. Krem:ner, D. McCreery and R. E. .

Willetta 197.2. Inhibition of. choline acety1transf erase - - .- r . -

activity. in- squid giant- axone--Biochimica Biophysici Acta.

~

. 1 .

~ - -

268:49-60.

, 18. Will ett'e, R. E. and I. L. Doerr. 1973. Beta-Unsaturated i Lactones. I. Condensation of 5-bromo-2(58)-furanones with i .

adenine and uracil derivatives. J. Org. Chem. 3B:3878-87.

19. Jacoby, R. L., K. A. Nief orth and R. E. Willette. 1974.

Structure activity studies on narcotic antagonists. I. N-Substituted ethyl 3-phenylpyrrolidine-3-carboxylates and l ethyl 3-phenylnipecolates. J. Med. Chem. 17:453-55.

i

20. Abbas, R. .3..M Edwards.and.R..Es Wi.11.ette 1.9.7.7 Riper.ib.i. :.e .

dine Derivatives: Synthesis of Potential Analgetics. J.

{

I

s Pharm. Sci. 66

1583-85.

i

21. Irving, J., B. Leeb, R. L. Foltz, C. E. Cook, J. A. Burney .

and R. E. Willette. 1994. Evaluation of Immuncassays f or i

Cannabinoi=s in Urine. J. Anal . Tox. B: 192-196.

.. REVIEWS, MONOGRAPHS AND CHA*TERS: e.

1. Seine, T. D. and R. E. Willette. 1966 and 1971. " Anal gesic  ;

Agents," in Textbook of Organic Pharmaceutical and Medicinal Chemis ry, 5th and 6th Edn. J. B. Lippincott, Philadelphia.

l 2. Willette, R. E. 1969. "Monoac aindoles: The Pyrrolopyri-dines," in Advances in Heterocy=lic Chemistry. Vol . 9.

Academi= Press, New York.

3. Willette, R. EL 1970. Analgetic Drugs. A Reevaluati on.

Amer. J. Pharm. Educ. 34:662-72. . -

4. Mule, S. J., I. Sunshine, M.. Braude and R. E. Wi$lette. -

1974. "Immunoassays f or Drugs Subject to Abuse," CRC Press, 1 Cleveland.

1

5. W111ette, R. E. 1976. Editor, " Narcotic Antagonistal The i Search f or Long-Acting Preparations," NIDA Research Mono- l graph No. 4, Rockvill,e.- .. . . .

A

l . .

.. e

6. Willette, R. E. 1976. Editor, " Cannabinoid Assays in Humans," NIDA Research Monograph No. 7., Rockville.

7. Willette, R. E. 1976. "The Development of Sustained Action Preparations of Narcotic Antagonists," in, " Narcotic Antago . ..

.- .- .nists: Naltrexone.. Progress Report;& NIDA Research" ~ Monograph.- --.

" * - - - ~ ~ ~ ~~'"~~ '~~- " -

~ ~ ~e ~ " "

• No. 7. Roc k'v111 e .-@:' W.'~. S*'--

8. Willette, R. E. 1977-1982. " Analgetic Agents," in Textbook of Organic Pharmaceutical and Medicinal Chemistry, 7th and 8th Edn. J. B. Lippincott, Philadelphia.

9. Willette, . R.- E. - 1977. Editor,*.." Drugs and_ Driving," NIDA 70-

, ~- "~

~

Research .MonogrTph N'o.- n ,. RortWiTI'e, . -, - - - - - - - -e- -

i

10. Stillman, R. C. and R. E. Willette. 1978. Editors, "The Psychopharmacology of Hallucinogens," Plenum Press, New York.

11. Barnett, G. P., M. Trsic and R. E. Willette. 1978. Edi-tors, " Quantitative . Structure-Activity Relationships of Anal gesics, Narcotic Antagonists, and Hallucinogens," NIDA Research Monograph No. 22, Rockville.

12. Barnett, S. P., and R. E. Willette. 1991. Ecitors, " Narco-

- ~ tic Antagonists: Naltrexona:Rharmacochemi.stry...anda Sustained-i .i.dd Release Preparatiens -(Drug Development -Volume V)," NIDA "!"S Research Monograph No. 29, Ro=kville.

13. Willette, R. E. and J. M. Wal sh. 19E3. Editors, " Drugs, Driving, and Traffic Safety," WHO Offset Publication No. 78, World Health D ganication, Geneva. ,

14. Willette," R. E. 19E3. " Cann abi n oi d s , '- Clinical Chemist.ry News, De= ember: E-9.

15. Agurell, S., W. L. Dewey and R. E. Willette. 1994. Edito;p, "The Cannabinoids: Chemical, Pharmacologic and Therapeutic Aspects," Academic Press, New York.

16. Willette, R. E. In premaration. Editor, " Marijuana in the Work Place: Issues and Answers," Academic Press, New York.

INVI =.u PRESENTATIDNE:

1. " Structure-Activity Relationships of Central Nervous System Drugs," Ameri can University, Beirut, 1965. -

2. " Analgetic Drucs - A Re-evaluation. " Joint Session of the section of Teachers of Chemistry. . AACP. and the Academy of."

Pharmaceutica 1' Sciences Section on Medicinal Chemistry, APHA Annual Meeting,. Washington, 1970.. .

O 9

. . . . . . . . _ __ ._. ~ --. .

i s

.v. -

^

5. " Structure-Activity Relationships and Design of Narcotic Amtagonists," Section on Medicinal Chemistry Symposium, APHA Annual Meeting, Houston, 1972.

, '__ 4. " Sustained Release Delivery. Systems f or Narcotic Antago .... . . _ ,

" # nists,,"-

' ' iim, APHA si Industrial-AnnualPharmaceutical--Technology Meeting,- Chicagai 1974. . :-- (Section 1* i-Sympo - - -- .

! 5. "Present and Proposed Policies Regarding Licensure of Labor-atories Performing Drug Urinalysis Determinations," National Drug Abuse Conference, New Orleans, 1975.

6. "Present .and. Proposed Policies Regarding. Li= ensure of Labor- :.: .. -

. . atories Perf orming Drug Urinalysis Determinations," Associa-c w. .--

tion of Drug Detection Laboratories Symposium, New Orleans,

! ~~

1976.-

7. "What NIH Does with a Research Grant Application." AACP

~ ~ -

Secton of Teachers Symposium, Seattle, 1977.

l l S. "An Dverview: Current State of Research in Analgetics and 4

Endorphins," Section on. Medicinal Chemistry Symposium, j Academy of Pharma =eutical Sciences Meeting, Phoenix, 1977.

a 7.._.

9. . " Therapeutic Appl.ications of Tetrahydrocannabinol and Mari- ..

) - .juana," , Oregon State University Conference on- Care of the or -

une Terminally Ill, Corvallis, 1980. .

i( i

10. " Federal Funding Opportunities," University of Mississippi t Conference on Federal Research Support, Oxford, 1981.

l

, 11. " Assays f or Cannabinoids in Urine," Annual Meeting of the l Association of Drug Le ection Laboratories, Austin, Texas, l 19e2.

i** 12. " Urinalysis f or Drugs of Abuse,"- Naval War College,. ,

Newp ort, Rhode Isl and, 19E3. ,

i i 13. "Research and Development of Orphan Drugs,." American i Association of Colleges of Pharmacy Annual Meeting, j Washington, D.C., 1983.

34. " Testing Employees for Al=ohol and D-ugs," Bureau of National Aff airs 2nd Annual Conf erence on Alcohol & Ih-ugs:

{

Issues in the Workplace, Washington, D.C.~,~1994.

i .

15. " Legal Issues in Drug Testing - A Chemist's Perspective,"*-

Annual Meeting of the Association of Drug Detect $on

! Laboratories, Denver, Colorado, 1985.

16. " Employer Legal Rights b Responsibilities," A Workshop on "What to do about Drug Abuse," Centerf or Occupational & . - '

Preventative Medicine, Albuquerque, New Mexico, 1985.

^ - ,. . -.,- --.--- - --. - - - - .-_ - _ - - - - - , , - - . - . - - . - - - . - - - - - -

4 , 6

'r.

17. " Employee Assistance Programs, the Role of Drug Tests,"

International Foundation of Employee Benefit Plans: Public '

Employees Conference, New Orleans, Louisiana, 1985.

~ . _ _ , . . . ..t... .. ____. ..

Z .18.7,. , Laboratory. TestinfMethods:LVal i di ty- and. Reli abi li ty Issues * -~~'

4 **and Laboratory Selection," A Symposium on " Employee Drug 4

Testing: A Dilemma," presented by the American Academy of Occupational Medicine, Chicago, Illinois, 1985. -

~:.~ 4. '. ; ,, :. . .. .. ,. : -

. .. : : . a .; . .. - - - -  :- -

6 E9 s

I I

e

. l i i l . ., .-----.- . .. - - - . - . . - . - . .

-.-.-_--,--.-.\

i . l 9 b IARRY B. HOWARD PRESENF Director, GEORGIA BUREAU OF INVESTIGATION, CRIME IABOBATORY -

I POSITIGi: July 1969-present PROFESSIONAL Southern Police Institute, University of Iouisville, Lecturer on Drug and Poison Deaths, Effacts of Alcohol - 1975 EXPERIENCE:

DEA Lecturer on Drug and Poison Deaths - 1975 Assistant Professor of Clinical Pathology, Snory University - July 1975 IZAA Consultant Forensic Science Research Projects - 1973-1974

, Staff of Anatomy Department, Dnory University - July 1971

Assistant Director of Georgia Crime Laboratory with primary l responsibilities in Toxicology and Medicc>Igal Pathology - 1956-1969

Consultant Toxicologist, Mount Sinai Hospital, M;.nneapolis - 1954-1956 i Teaching and Research Assistant, Medical School, Department of Pharmacology, University of Minnesota - 1950-1956

' EDUCATION: B.S. Bacteriology and Chemistry - University of Montana, 1949 Ph.b. Major: Pharmacology, Minor: Biochemistry - University of Minnesota, 1956

Post Doctorate Pathology, Emory University (Dr. Sheldon), 1956-1957 Medico-Imgal Pathology, Georgia Crime Laboratory, 1956-1961 Armed Forces Institute of Pathology, 1964 Georgia Medico-Imgal Workshops since 1956

Others: Infrared Spectroscopy, Massachusetts Institute of Technology, Stamer Session,1960 I Optical Minerology and Petrography, Georgia State College, 1966-196'

. Neuroanatomy, Neurophysiology, Neuropharmacology Review Courses, Dnory University, 1968 i

SOCIETIES AND American Association for the Advancement of Science

COMMISSIONS

American Academy of Forensic Sciences Chairman of Standards Ccamittee, Toxicology Section, 1967-1973 j

Vice President, 1978-1979 ,

i Program Chairman, 1978-1979 j Southern Association of Forensic Scientists i Program Chairman, 1966-1969 Chairman, 1973-1974 Atlanta Instrument Society i Member Georgia Science and Technology Ccnmission, 1969-1971 j Member Board of Governors, American Society of Crime Laboratory

Directors, 1974-77

) Re-elected to Board, 1978-1981 l Treasurer, 1974-1976

! President, 1976-1977

! Member, American Board of Forensic Toxicology, 1975-1981 j Manber of Board, Ferensic Sciences Foundation, Inc.,1977 i Manber, Criminal Justice Accreditation Council, 1978-1981 l i

j j PERSONAL: Age 51, Married,'Fbur Children.

k 1 i l i

, Exhibit B(4)

sP DR. RICHARD BUCHET ON-SITE VOGTLE INTERVIEW dCHEDULE JANUARY 29, 30 and 31, 1986 C. W. Whitney Legal Counsel

, D. O. Foster V.P., Administration and Support D. Russell Security S. Allen Security R. Schepens NRC H. Livermore NRC B. Walker Safety R. Brown Chief, Security 1

D. Stevens Security V. Agro Nucops V. Cannon Nucops H. Winkler HQ, Labor Relations J. Duffy Walsh Construction D. Frambis Union B/A J. Johnson Union Steward G. Introcaso PPP B. Milligan Williams B. Harbin QA/QC G. Dickerson Cons trus cion/ Safe ty D. Jiles Nucops/ Safety  ;

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/ G. Coursey Sheriff, Burke County B. Posey Chief Deputy Sheriff, Burke County G. Gudger Union B/A F. Williams Union B/A B. Davidson Labor Relations 21 craf t/ staff interviews on job site.

Exhibit C (l)

.4 l

v0GrIE ANTI-DRUG PROGRAM l ERLXM'ESTING PROCEDURES INTERVIEW SGEIXLE DR.10BERT WILLETTE and DR. IARRY HOWARD Jaruary 9,1986 Orientation neeting at Georgia Power Capany office, Atlanta, GA, with Don Foster, Olarles titney, Don Ellis, Wyman Lamb, Peter Bensinger, attended by Dr. Robert Willette Jaruary 27, 1986 Smith-Kline !iedical Lab, P.S.P.A., Atlante, GA, Dr. Jerry Mdian, Laboratory Directcr. Review of drug-testing procedures, equipnent and personnel.

January 28, 1986 AMI Occupational Health Center (Atlanta clinic), Chris Loewenthal, Physical Dept. Supervisor. Additional interviews with three clinic shysicians.

February 5,1986 Plant Vogtle - meetings with Charles Witney; Gordon Didcerson, Supervisor of Construction Safety Dept.; and Bruce Walker, Safety Officer. Review of specimen collection ard screening procedures.

February 6,1986 Medical College of Georgia, Dr. John Craig. Review of drug-testing procedures, laboratory equipnent and personnel.

V Exhibit C(2)._

.o PLANT VOGTLE ANTI-DRUG PROGRAM INTERVIEW SCHEDULE OF REGIONAL OFFICE OF THE NUCLEAR REGULATORY COMMISSION BY PETER BENSINGER January 31, 1986 Brad Jones Regional Counsel Bruno Uryc Investigations / Allegations Coordinator Marvin Sinkule Section Chief (responsible for oversight of Vogtle)

Vince Panciera Deputy Director-Reactor Safety Division i ..

NOTE: All interviews took place at Regional Office of Nuclear Regulatory Commission in Atlanta, GA.

I Exhibit C(3)

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.O TABLE OF CONTENTS ANTI-DRUG PROGRAM POLICY MANUAL TAB Drug Policy . . . . . . . . . . . . . . . . . . . . . . . . 1 Program Coordination Committee . . . . . . . . . . . . . . . 2 Background . . . . . . . . . . . . . . . . . . . . . . . . . 3

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1. IEE Information Notice #82-05, 3/10/85 . . . . . . 3A

2. ANSE Standard 3.3 . . . . . . . . . . . . . . . . . 3B

3. INPO Fitness-for-Duty Program . . . . . . . . . . . 3C 1

Security . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1. Undercover Investigations . . . . . . . . . . . . . . 4A 4

2. Drug Dog Program . . . . . . . . . . . . . . . . . 4B

3. Vehicle Search Program . . . . . . . . . . . . . . 4C

4. Drug Hotline . - . . . . . . . . . . . . . . . . . . 4D Drug Screening . . . . . . . . . . . . . . . . . . . . . . . 5

1. Georgia Power Company Drug and l Alcohol Abuse Procedure . . . . . . . . . . . . . . 5A i

l 2. Georgia Power Company " Fitness for Duty

at Nuclear. Power Plants" Procedures . . . . . . . . 5B

( Union Coordination . . . . . . . . . . . . . . . . . . . . . 6

1. Augusta Building Trades Council . . . . . . . . . . 6A

2. International Brotherhood of Electrical Workers, Local 84 . . . . . . . . . . . 6B t

Management Action Procedures . . . . . . . . . . . . . . . . 7 Policy Dissemination and Publicity . . . . . . . . . . . . . 8 i coordination with Quality Concerns Program , . . . . . . . . 9  ;

l Committee Meeting Minutes . . . . . . . . . . . . . . . . . 10 Arbitration / Court Cases . . . . . . . . . . . . . . . . . . 11 l EMIT Testing . . . . . . . . . . . . . . . . . . . . . . . . 12 l

j Education and Training Program . . . . . . . . . . . . . . . 13 GPC Corporate Drug / Alcohol Program . . . . . . . . . . . . . 14 Construction " Fitness-for-Duty" Screening Procedures . . . . 15 Audit . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 ,

Alcohol Screening Procedure . . . . . . . . . . . . . . . . 17 i

I fahibit D

. _ . . _ , _ . . _ . . . . _ , -_- - . . , ~ ~ . . - - _ ~ ,.. . _ . .,_. . - , _ _ . . _ . _. _-_ , ._ _ . _ _. - .-~ _

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. Georgio Power Comoemy Frotect Womagement Route 7. Son 299A waynescoro, Georgie 30830 Twoonone 404 72441to 404 554 996t January 20, 1986 Vogtle Project All Union Officers .

All Business Agents and Managers All Shop Stewards As you know, in the past employees suspected of reporting to work "under the influence" of alcohol or of using alcohol on the Site were referred to the Safety Trailer for screening. The screening usually involved a blood serum test, administered on Site or at Humana Hospital.

Effective Monday, January 13, 1986, the Vogtle Project obtained a "Intoximeter." The Intoximeter is a highly reliable scientific d'evice which uses breath samples to measure alcohol content.

This is the same device used by the Georgia Highway Patrol, and is accepted as conclusive evidence in Georgia Courts.

We have arranged a demonstration of the Intoximater for all interested union representatives. The demonstration will be held on Wednesday, January 22, at 11:00 a.m. in the Construction Auditorium at Plant Vogtle. During that demonstration we will provide you with

['

additional information regarding equipment, operation and calibration, .

operator training, and accuracy of test results.

Please make sure that each of your members is reminded of the Vogtle work rule prohibiting any individual from reporting to work under the influence of alcohol or using or possessing alcohol on the Project. The "no-alcohol" rule is a very important part of the overall Vogtle Anti-Drug and Alcohol Program. As you know, anyone violating this rule will be terminated from employment and will be barred f.so m all future employment at any Georgia Power Company construction site.

You are aware of my personal commitment to maintenance of a drug and alcohol-free work environment on the Vogtle Project. I have discussed this matter with each of you individually, and know that you are all committed to doing everything possible to assure a safe working environment for your acabers. Please remind each of your members that our purpose is not to " catch" people under the influence of alcohol but rather to make sure that no one under the influence of alcohol reports for work at the Project.

I will look forward to seeing you at the Intoximater i demonstration. In the meantime, if you have any questions, please contact me at 554-9524 or Project Legal Counsel Chuck Whitney at 724-4267.

Again, my thanks for your past a port an for your anticipated future cooperation. ,/ ,

, #, m R. H. Pinson Vice President and Construction Mana RHPtjl Vogtle Project

o w l

J l l RECEP!EC i : 0 3 rj l MEMORANDUM i

! To: All holders of the Project Anti-Drug Program Handbook RE: No-Alcohol Policy DATE: January 24, 1986 a

During the week of January 20, the Vogtle Project took several steps i

to strengthen the "No-Alcohol" prohibitions in its Anti-Drug Program. Those steps included the installation and operation of a "Intoximater," (a breath analysis device used extensively by Georgia Law Enforcement to detect alcohol), meetings with the building trade union representatives to discuss the No-Alcohol Policy and the 3

"Intoximater," and a restatement of the Project's No-Alcohol Policy

! dated January 27, 1986.

, Enclosed is a copy of the January 27, 1986 Policy statement for

inclusion in the Vogtle Project Anti-Drug Program Handbook. The i

Policy should be included under Tab 1, " Policy."

! An independent audit is currently being conducted of the Vogtle Anti-Drug Program at the direction of Project Management. As always, we will keep you informed of all developments in the Anti-Drug

-- Program, and we will advise you as to the results of the audit.

the interim, if you have any questions, please contact charles W.Jn l Whitney at the Vogtle Project, 724-4267.

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Exhibit F - , - - -

Georgo Power Comoeny i

1 Pfthect Mmegement l

Route 2. Boa 290A Waynescoto. Georgia 30830 Istophone 404 7244114 V0GTLE ANTI-AYEOMOL POLICY i

January 27. 1986 y gg

! As you a'_1 know, the Vogtle Project is firmly committed to maintenance of a drug and alcohol-free work 4.nvironment,for employees. The Project's most valuable assets are the people dedicated to completion of construction and operation of the plant.

' our goal is to ensure that those people have a safe work environment and that they are able to perform work of the highest possible quality.

I want to remind each of you of the importance of the Vogtle "no alcohol" rule. Possession or use of alcohol on the i Project Project, at any time, is expressly forbidden. Reporting to work after using alcohol, or impaired by alcohol in any way, is also expressly forbidden. Anyone violating these rules will be subject to immediate termination and.will be barred from future employment on any Georgia Power Company construction site.

i The same security rules apply for alcohol as they do for

drugs. Individuals entering and on the Company property will be I

subject to search. Vehicles, lunch boxes, and storage areas throughout the Site will also be subject to search. In addition, the Company is now using an "Intoximater," which is a breath analyzing device used by the state of Georgia Highway Patrol to measure alcohol l -

in a person's system. The test is very accurate and extremely reliable. Anyone refusing to consent to search or refusing to take the breath analyzer test when directed by supervision will be

! terminated and will be barred from the Vogtle Project and from all i other Georgia Power Company construction sites. Anyone testing

! positive, indicating that the individual reported for work with alcohol in his or her system, will also be terminated and barred.

We are grateful for the strong support that the Anti-Dru'g

! and Alcohol Program has received from Project employees. We believe l

that each of you understand that our objective is not to " catch" and i punish people who use drugs or alcohol. Instead, we are trying to make it clear to those people that if thsy use drugs or alcohol, they should not report to work and endanger themselves and their fellow workers.

! Georgia Power Company, on behalf of the owners of the Vogtle Project, thanks each of you for a job well down. We look forward to your continued efforts in bringing the Project into coarercial operation. By working together, we will ensure a quality project l that will provide service to Georgians for decades to come. '

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. . . . -. 41.u,2_ gg4s REC:j1 R. E. Conway CN L-Senior Vice President M g g g

SUPERVISORY GUIDELINES FOR ADMINISTERING THE l COMPANY POLICY ON DRUG AND ALC0HOL ABUSE l These guidelines are for use by supervisors at all levels throughout I the Company. They are intended to provide assistance in the administration (

I of the Company's drug and alcohol abuse policy.

i

1. Each supervisor has a responsibility to assure himself that employees under his supervision are at all times free from the influence of alcohol or illegal drugs.

2. Employees who have a drug problem and who ask for help should be referred immediately to the Company's Employee Assistance Program. This request for assistance may not be used by an employee as a means of avoiding disciplinary action if he or she has violated the Company's drug abuse policy.

3. Each supervisor is responsible for taking appropriate action whenever an employee's demonstrated judgment or performance seems to be impaired by the possible use of alcohol or drugs.

When a supervisor suspects that an employee is " unfit for duty", he should:

Arrange, if practical, for at least one other supervisor to observe and evaluate the employee's behavior. The employee's supervisor should ask the employee to explain

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why he appears unable to perform his job. If a bargaining unit employee requests'that a steward be present, management should comply with the request, assuming it can be arranged promptly.

Should the employee f ail to explain his impaired condition to the supervisor's satisfaction and it is still the supervisor's determination that drugs or alcohol may

~ be involved, he should accompany the employee or arrange ,

for him to be taken by another management employee, to the designated Company physician for testing. If the employee refuses to go, he should be warned that he may still be held accountable for his unfit behavior. Addi-tionally, he may be severely disciplined for insubordination pending further investigation. Depending upon his condition, he should then be sent or taken home and told when to report back to work. The supervisor should exercise caution in committing to any specific disciplinary action or how the employee's pay may be handled. I 1

4. When a supervisor observes the use, sale or possession of '

illegal drugs or alcoholic beverage by employees on the job, the supervisor should take the following steps:

A. Imediately confiscate all alcohol, drugs and/or drug paraphernalia if possible. As soon as time permits, get another supervisor and the Company's Security Department or the designated drug awareness coordinator to participate in the early stages of the investigation. b M U *fg C/SA

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2 B. Separate the employees involved and take them to a location where they can be questioned individually about the incident.

C. With another supervisor present, question the employees individually about the incident. Allow a steward -

to attend the questioning if the employee requests it.

D. Report the incident to your superior, the Company's Security Department, and either the Labor Relations or Personnel Department depending on whether the employee is a member of the Union.

E. While it may be appropriate to conduct a search of the employee's locker, personal effects or clothing, recognize that certain legal requirements must be met if the search is to be considered valid for any future purposes. Consult your local management and the Security Department. They may recommend contacting local law enforcement authorities.

F. As soon as Steps (A) through (E) have been completed, turn any confiscated drugs or paraphernalia over to the drug awareness coordinator, the Security Department, or appropriate law enforcement authorities. A sig'ned receipt should be obtained from-any outside agency.

b G. If the employee has not been removed from Company property by law enforcement personnel, send him home or take him there,. depending upon his condition.

If he appears to be under the influence, follow the steps for having a fitness for duty exam administered.

Make no commitment regarding whether the employee will be paid or what discipline will follow. After

-- the investigation is complete, the employee should "

be given the opportunity to respond to the results of the investigation. After hearing what the employee has to say, the appropriate discipline that management considers consistent with the nature of the offense should be given.

5. Following any incident that might fall under these guidelines, it is essential that the supervisor innediately make a detailed record of all actions, observations, statements and other pertinent facts, to include date, time, location and witnesses to the incident.

6. If an employee has been arrested for a drug related offense off Company property, local management should attempt to investigate the nature of the offense before the employee returns to work.

Some serious violations of the law may also require that job action be taken. Consult with Labor Relations or the Personnel Department. Counsel with the employee upon his return.

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7. If drugs or drug paraphernalia are found on Company property and it is not obvious who the owner is, report the incident to your supervisor, the designated drug awareness coordinator or the Security Department. An effort should be made to determine the owner of the property by questioning supervisors who may have been in the inrnediate area. Upon instructions from the Security Department, the appropriate law enforcement authorities should be contacted and all drugs and illegal drug paraphernalia should be turned over to them. A signed receipt should be obtained from the authorities.

8. If a supervisor receives a report that an employee has violated the Company drug policy, the supervisor should try to obtain as much detailed information as possible from the person reporting the violation. The supervisor's superior, the Security Department, and Labor Relations or Personnel'should then be notified.

Unproved allegations of drug policy violations shall be kept highly confidential and shall only be discussed with management level individuals who have a need to know by virtue of their position of responsibility.

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1 SUPERVISORS' OUESTIONS AND ANSWERS ABOUT THE DRUG ALC0HOL ABUSE PROGRAM Q.

how his can I tell when an employee is "not in a condition" to perform work?

i nco e e manne ako coor nat ' u usual behavior, slurred speech, n, etc.

is "not in a condition" to perform hi indicate that he c c signs of possible that has beendrug use, a supervisor should refer to the training and material supplied, Q.

under the influence of alcohol or drugs?Is it possible for a fore l

A.

{ It is not possible without a chemical analysis for a supervisor to 3

determine In obvious cases, whether ana employee however, is under the influence of a specific dr supervisor can .

if necessary, determine rely on a fitness for duty exam before coming to any rare circumstances when an exam cannot be administered the supervisor, i with the aid of another supervisor's that would be valid for purposes of discipline.

observation, can r,each a detenninati Q.

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(' Is it possible for an employee to sue me if I accuse him of being drunk?

A.

Yes, if you do so in an arbitrary or capricious manner.

supervisor should never accuse an employee of beirg drunk or on drugs.T He should ask the employee for an explanation when the employee appe unfit and should take him to the doctor for anNo exe.n.

matter how certain the supervisor may be, he should always dt until all the

" available taking action. facts are in before telling an employeehis conclusions and 7 in law suits arising from a supervisor's perfonnance of his .

What should I do if an employee comes in smelling of whiskey or beer?

The smell of alcoholic beverages often lasts longer than their effects so tnatthe presenceisofintoxicated.

an employee an alcohol odor alone is not a fool-proof indication ,

supervisor tions. should keep a close eye on the employee for additiona  !

If the employee comes in repeatedly with an alcohol odor, the supervisor should talk to him both about his hygiene and about the avail-ability of the Employee Assistance Program.

Q.

How

" unfit should for duty", I handle borderline but I'm not sure? cases where I think the employee may be l

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2 A. No guidelines can be so specific as to cover every situation. Two factors should be kept in mind, however. First, safety is always our primary consideration, and if any doubt exists about an employee's fitness to perform a hazardous task, take him off the job. Second, taking an employee for a fitness for duty exam is not a fonn of discipline. If the lab reports back that the employee had no foreign substances in his system, he is simply paid fo'r the time he was on administrative suspension and he comes back. Don't be afraid to use the procedure when doubt exists, though don't use it so frequently that employees feel harassed.

Q. Why is it important for a member of supervision to accompany an employee to a fitness for duty exam?

A. Three reasons: a) In most cases, when an employee is unfit to do his job, he is also unfit to drive to the doctor; b) It is important that a fitness for duty eram be administered as soon as possible to get an accurate indication of the employee's condition when he was on the job.

(Some chemical substances are undetectable within just a few hours of their being taken.) c) Supervision should be present and in control of the situation until~ the employee is completely on his own time.

Q. What should a supervisor do if an employee will not allow him to drive him home?

k A. We should take all reasonable steps to ensure that someone under the influence does not try to drive. If he will not ride with his supervisor, suggest that one of his co-workers take him. If that doesn't work, try to get one of his family members to pick him up.

Q. How long does it take to get the results back from a fitness for duty exam?

A. Usually three to five days. When the doctor takes his samples, he sends them to a laboratory for analysis. It takes that much time for the shipping and lab work. During this time the employee should be placed on administrative suspension.

What should I do if I see a number of employees using drugs and the possibility exists that they may become hostile if confronted?

A. Get help. Depending on the situation, contact other supervisors, the Security Department or local law enforcement. Supervisors should not allow illegal activity on Company property to go unchallenged. They should not, however, subject themselves to unnecessary risk.

Q. What should I do if an employee refuses to surrender a suspicious substance when so instructed?

A. Accompany the employee to your office or work station while observing that ne does not dispose of the substance. Repeat your instruction in the presence of another supervisor, warning the employee that his refusal is an act of gross insubordination and subject to discipline up to and including discharge. If he still refuses, send him home without comenting on specific discipline, then conduct your investigation.

Be sure to consult.with your supervisor and with the Labor Relations or Personnel Department.

Q. How important is it to have another supervisor present when I question an employee?

A. It is essential, especially if the employee chooses to challenge your action later on. It is also helpful if a covered employee exercises his right to have a union representative on hand as his own witness.

Q. What are the legal limitations that apply to searching lockers, cesks, or work stations?

A. That depends on the purpose of the search. If the end result will be disciplinary action by the Company, supervision has an almost unrestricted right, since lockers and desks are Company property. Caution must be taken, however, to avoid any searches that are discriminatory or harassing in nature. It is a good idea to have another member of management and

{ a shop steward, if applicable, as witnesses. If the purpose of the search is criminal prosecution, a much higher standard of con' duct applies.

The courts require that " reasonable cause" exist and that a search warrant be issued. For this kind of search the Security Department and/or local law enforcement should be involved.

Q. What should I do with any drugs that I find?

A. Major work locations will have at least one member of management acting" as a drug awareness coordinator. These people are trained by our Security Department in the proper handling of contraband. .If you cannot contact the nearest drug awareness coordinator, call your supervisor ?nd the Security Department. Keep the suspicious substance under your airect custody to avoid it being tampered with, and try to hand it over to another authority as quickly as possible.

Q. What if an employee is arrested off Company property for suspected drug activity?

A. Call the Labor Relations or Personnel Department. Many of these cases fall into a grey area and require considerable thought and research into past practice. We have a limited right to determine that an employee 1 does not have sufficient moral character to remain in our employ. We must be extremely careful, however, in deciding on an employee's guilt or innocence independent of a court finding. If the facts indicate guilt, the Company has a right to take disciplinary action regardless of the outcome of any court action.

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Q. Are our Company doctors aware of our drug and alcohol abuse program?

A. Yes. In fact, the Safety and Health Department and the Company's chief physician assisted in the program's development. They have contacted all major Company doctors.

Q. What if an employee says he has been drinking when he is called to come in to work on an off day?

A. The supervisor should try to ascertain how much the employee has had to drink and when. Ask the employee if he thinks he is in condition to work. If the slightest doubt exists, get someone else to do the job.

Remember, Company policy prohibits working when under the influence.

Consult your supervisor when a difficult judgment call comes up.

Q. What if an employee suspected of being unfit for duty requests union representation, but a steward is not readily available?

A. If the shop or department steward is not on the job he should be called in and paid accordingly. If he cannot comit to arrive within a reason-able period of time (within one hour), instruct the employee that he must choose another member of the bargaining unit as his representative. Tell him why. Remember, if too much time elapses between the time an employee

( is judged to be unfit and the time he is examined, reliable test results may not be obtainable.

Q. What level of alcohol or other drugs does the Company consider to be "over the limit"?

,, A. The State of Georgia generally considers a blood-alcohol concentration of 0.1 percent to be legally intoxicated, and this is a good guideline, w The Company, however, is not too concerned with specific blood-alcohol levels or drug concentrations. In fact, except for alcohol, it is extremely difficult and expensive to deternine quantitative levels of drug concentra-tions. Our concern is the employee's fitness for duty. The purpose of the fitness for duty exam is to document and fortify the supervisor's observation that an employee is not in shape to do his job. In the case of a negative result from the test, it serves to remove doubt about the employee's involvement with drugs or alcohol. Except in the case of alcohol, the laboratory will only detennine whether or not a drug or drugs were in the employee's system. It is up to the supervisor to put the evidence together and take the appropriate action.

Q. Does the Company plan to begin random blood or urine screenings?

A. No.

I Behavior and Job Performance

" Warning Signs"

Job behavior and work performance should be the concern of the Supervisor.

Expert knowledge about abuse of controlled substances or abused drugs isn't necessary, but the Supervisor should remain alert to changes from the normal

! work pattern and/or behavior of the employee.

! It's the responsibility of the Supervisoi to act in accordance with Company

' guidelines for administering the policy on drug abuse. It's important to take immediate steps, since delayed action can threaten the safety of others and result in the total deterioration of the abuser.

Listed you will find various "waming signs" that usually appear on the job, indicating some consequences of abuse. It's impossible to rate all behavioral and work pattem problems that occur in this process of deterioration. They can appear singularly or in combination. They may signify problems other than substance abuse. For example, alcoholism, diabetes, high blood pressure, thyroid disease, psychiatric disorders, emotional problems and certain heart conditions all share some of the same signs. Therefore, it's important to remember that unusualor odd behavior may not be connected in any way with drug or alcohol abuse. The role of the Supervisor is to recognize and document changes without making any moral l judgement or taking the position of counsellor or diagnostician.

I j Signs of Deteriorating Job Performance ,

Physical Signs or Condition Absenteeism Work Pattoms

( Weariness, exhaustion Untidiness Acceleration of absenteeism end tardiness, especially Mond1/s, inconsistency in quality of work High and low periods of productivity Yawning excessively Fridays, before and after holidays Poor judgement /more mistakes than ,

Blank stare Frequent unreported absences, later usual and general carelessness Slurred speech explained as " emergencies" Lapses in concentration l Sleepiness (nodd.ng) Unusually high incidence of colds, Difficulty in recalling instructions Unsteady walk flu, upset stomach, headaches Difficulty in remembering own l Sunglasses worn at inappropnate Frequent use of unscheduled mistakes  !

times vacation time Using more time to complete work / i Unusual effort to cover arms Leaving work area more than missing deadlines  !

.. Changes in appearance after necessary (e g., frequerst trips increased difficulty in handling ,

lunch or break to water fountain and bathroom) complex situations Unexplained disappearance from Mood the job with difficulty in locating Relettonehlp to Others on the Job Appears to be depressed all the time **P'OY Overreaction to realor imagined or extremely anxious all the time Requesting to leave work earty fo' criticism various reasons l Imtable Avoiding and withdrawing from peers i

- epicious Complaints from eo workers emplains about others Accidents Borrowing money from fellow Emotional unsteadiness Taking of needless risks employees ,

(e g , outbursts of crying) Disregard for safety of others Complaints of problems at home, ,

Mood changes after lunch or break Higher than average accident rate such as separation, divorce and i on and off the job child discipline problems I Actions Persistent job transfer requests l

Withdrawn or improperly talkative  ;

Spends excessive amount of time on the telephone Argumentative Has exaggerated sense of seif e rtana Displays Violent behavior Georoia g Power Avoids talking with Supervisor regarding work issues

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j. DRUG AI'.'SE PROOPJ.M is NS = Non-supervisory Employees [M 2.

i S = Supervisory E=ployees l

i Supervisors vill attend one NS meeting and one S meeting for one hour each.

3cte Day Meeting Location Time j :sov.10 W McDonough-Atkinson 1 7:30 (NS), 8:30 (S),10:30 (NS),12:30 (S), 2:30 (NS)  !

f;ov.10 W Morgan Falls Will meet at McDonough-Atkinson.

! sov. 15 M Scherer I 7:30 (NS), 8:30 (S), 10:30 (NS), 2:00 (S), 3:00 (NS) iov. 16 T Arkvright i

7:00 (NS), 9:30 (S), 2:00 (NS), 3:00 (NS) j :ov. 18 Th Bowen i 7:30 (NS), 8:30 (S), 9:30 (NS), 10:30 (S), 1:00 (NS),

3:00 (NS), 4:00 (S)

ev. 22 M Yates 7:30 (NS), 8:30 (S), 10:30 (NS), 2:00 (S), 3:00 (NS.)  !

ov. 23 T Wansley 7:30 (NS), 8:30 (S),10:30 (NS), 2:00 (S), 3:00 (NS)

! ov. 29 M North Gecrgia 8:00 (NS), 9:00 (S), 2:00 (NS)

{.ov.30 T Mitchell

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30 (NS), 8:30 (S), 10:30 (NS), 2:00 (S), 3:00 (NS) j ec.1 W Hatch 7:30 (NS), 8:30 (S),10:30 (NS), 2:00 (S), 3:00 (NS) ec. 2 Th Hatch 7:30 (NS), 8:30 (S),10:30 (NS), 2:00 (S), 3:00 (NS)

-:. 2 Th - McManus 7:30 (NS), 9:00 (S)

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. I Hatch 1 7:30 (NS), 8:30 (S),10:30 (NS),1:00 (NS), 2:00 (NS),

3:00 (NS)

'. - Ha==ond 7:30 (NS), 8:30 (S),10:30 (NS), 2:00 (S), 3:00 (NS) 7 - Vogtle 8:30 (NS), 10:30 (NS), 1:00 (S) e i ec. 7 -

Wilsen Will meet at Vogtle Power Generation i lsc.E K Har11ee Eranch 7:30 (NS), 8:30 (S),10:30 (NS), 2:00 (S), 3:00 (NS) sc. 8 W Central Georgia Will meet at Har11ee Branch.

l*

Chattahoochee Hydro Will meet with the Columbus Division in February, 1983.

[k *' 9" N Dates will be determined later.

C,

tmercffice Ccrresptndance GeorgiaPower A i

December 15, 1982 4

Mr. G. F. Head:

' RE: Drug and Alcohol Abuse Program The drug and alcohol abuse program has been fully implemented in the power plants with the exception of Bartlett's Ferry, which will be 4

included in one of the Columbus Division meetings. As of December 8, we have conducted a total of 71 employee and supervisory meetings across the state.

4 We reached all but a small minority of employees. This is due to the

• excellent coordination between Power Generation Services and plant manage-ment. In fact, much of the program's success is attributable to the enthusiasm with which the plant managers adopted it. Their time and effort in preparing their portion of the program and the sincerity they 4

were able to convey to their employees added much tL the impact and l

credibility of the message. Also noteworthy was the high level of con-

! sistency in managers' responses to questions both from employees and supervisors. This will help greatly when we find ourselves facing a

' challenge in any forum.

1 Plants where employees displayed the greatest interest in the program i

include Hatch, McDonough-Atkinson, Vogtle, Bowen, McManus, Arkwright and Branch.

l I

Generally, employees responded very well to the program. The large majority clearly appreciate our effort both to present this information and to clean up the plants. Many said it was long overdue and came up to us afterwards to thank us personally. Naturally, we met with cynicism from some, and plant managers frequently identified In soine cases, these individuals these as the ones most likely to run afoul of the policy.

employees asked challenging questions, which actually helped clarify the policy; in other cases they just I, lumped back in their chairs or i looked away. Particularly gratifying, though, was the obvious interest i

most all employees exhibited, even in meetings where questions were raised.

On December 6, the drug and alcohol abuse program was presented to two representatives of N.R.C. I believe that the presentation was well received by our visitors. Both representatives stated that the Company's j

program was one of the best they had reviewed to date.

Several departments made significant contributions to the program.

Safety and Health was involved from the outset and prepared the slide presentation that was used at all the plants. The Security Department provided input to the policy and its administration and conducted an excellent program to train select personnel at each plant to serve as drug awareness coordinators.

l

o

.'Mr. G. F. Head Page 2

b December 14, 1982 f

Cooperation from everyone involved greatly aided in the program's development from its conceptual stage last spring, to final approval by HRAC in October, to implementation during November and December. The result as can best be determined thus far has been gratifying. Please contact )

me if I can provide any further information.

i D. B. Ellis Assistant Manager Labor Relations

) DBE/mk

) cc: Mr. R. P. Head, Jr.

Mr. J. L. Davis, Jr.

Mr. A. W. Benson

! Mr. T. E. Branan Mr. R. H. Bohler

, Mr. W. C. Zachary M

J .

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BENSINGER, DUPONT & ASSOCIATES, INC.

20 NOHTil WA('Kl:H 1) HIVE ClllCAGO, ILLINOIN 0060s f.1121 7 2rt-M020 May 9, 1983 Dr. Larry Howard P.O. Box 1456 Atlanta, GA 30371

Dear Larry:

This will confirm our phone conversation regarding the upcoming health and safety / supervisory training meeting scheduled for Plant Vogele May 26 and 27. Howard Winkler (526-7936) will be in touch with you regarding the logistics and time schedule.

Best regards PETE ER PBB/jz cc Howard Winkler

/ / ~? l l/ (WM \

interoffice Correspondence .F [ Georgia Power d

) '^1' / j 7'Md 1

May 11, 1983 / j MEMO TO: Staff & All Supervisory Personnel gg %94

SUBJECT:

Plant Vogtle - Units I & II Information Meetings - Drug and Alcohol Program Mr. Ron Pinson will be onsite May 26 & 27 to conduct information meetings for all employees to explain the Company's Drug and Alcohol Program. In addition, o representative from the medical profession will be present to discuss the phycical effects of drug and alcohol abuse.

Th$re 'will be two different type of meetings. A general meeting for all per-connel (including supervisors) which will present an overview of the Drug and Alcohol Program, and a separate supervisory meeting which will explain the ad-ministration of the program.

All employees are recuired to attend one of these meetings.

Supervisory personnel must attend both a general session and a supervisory Cossion.

Tha meetings are scheduled in the field office building auditorium as follows:

b' h i Thufsday - May 26, 1983 p p'r 8:30 a.m. A bhift & 5-8 personnel

10

30 a.m. A shift & 5-8 personnel 1:00 p.m. A shift & 5-8 personnel 3:00 p.m. A shift & 5-8 supervisory personnel only 4:30 p.m. A & B shift supervisory personnel only 6:00 p.m. B shift personnel 8:00 p.m. B shift personnel Priday - May 27, 1983 -

8:30 a.m. C shift personnel 10:30 a.m. C shift personnel 4-+4 G p. m . C shift supervisory personnel only I:se i... .a advised that all D shift personnel should plan to attend one of the acevc meetings as it will not be possible to schedule a separate meeting for Lia l E : :. f L .

Please ensure that all personnel under your supervision are scheduled to at-tend one of these mootings.

hO ev'M J.p.Dorough cc Personal File $ X7DD02, P-5981 Mr . R. 11. Pinson, Mr. W. T. Nickerson, Mr.11. Winkler

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Oct,3 $

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veen, ii.ci,,e cener.i.nor i.at May 8, 1984 Georgia Power r,,......,... . , .

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I

) Mr. T. S. Yarbrough, Business Manager l 1 International Brotherhood of Electrical Workers t i Local Union 1579 '

1250 Reynolds Street Augusta, Ga. 30902 l 4

Subject:

Vogtle Electric Generating Plant - Units 1 & 2 i Drug Awareness Program I

4 File No. X7BD03 l l Correspondence No. L-818 ,

4

! Security Code: NC ,

Dear Mr. Yarbrough:

l i As discussed at the April 17, 1984, Labor / Management j Meeting and the Building Trades Meeting on May 1, 1984, I L have scheduled a Drug Awareness Program for 10 a.m. on May 15, l

{

1984. This program will take place in our Training Building, Classroom 1.

Mr. Howard Winkler of Georgia Power Labor Relations

! Department will make the presentation. He will cover drug i identification and use detection techniques.  !

) This will be an informative meeting that will enhance ,

j everyone's knowledge of drugs and their dangers. I hope you  !

d will be able to attend. _

f 4,

Sincerely, l

M. D. Cockrill Site Labor Relations Coordinator i

i MDC/mk i

i xc: D. O. Foster l

H. H. Gregory, III 4 M. H. Googe C. W. Whitney i L. T. Garner

! .. Howard Winkler

• I M. D. Cockrill

Interoffice Correspondence GeorgiaPower A TO: V0GTLE DRUG TASK TORCE FROM: Howard Winkler

SUBJECT:

DRUG TRAINING DATE: July 31, 1984 Ten training courses on drug and alcohol abuse were held for contractor superintendents, general foremen, foremen and shop stewards. During the 90 minute presentations I covered the major drugs of abuse, their long and short term health effects, the faculties impaired by intoxication caused by each of these substances and how to recognize an individual under their influence.

The attendees were shown various drugs and paraphernalia and were acquainted with the odor of marijuana. I discussed the Company's concern for keeping drugs and alcohol off the job and how to help someone with a substance abuse problem. Questions raised an answered dealt mostly with the Company's drug and alcohol policy.

Approximately 800 people attended the June 6, 7, and 8 classes representing Cleveland, Ingalls, Pullman, P.K.F., Walsh, and Williams. Representatives from Research-Cantrell, Fundamental Materials, Nisco, and G.E. attended an earlier presentation for union business agents.

dd l

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i interoffice Correspondence

\

i '. GeorgiaPower b 1

j

1. July 11, 1984 I ,

Memo To: Howard Winkler i

Subject:

1 - Vogtle Electric Generating Plant - Units 1 & 2

! Employee Safety Meeting

} File No. X7BD03 1

l j Correspondence No. L-869 i

] Security Code: NC i  !

) This memo is to confirm our telephone conversation of July 10, j 1984, concerning your participation in our Employee Safety Meetings.  !

8 Theust Au dates 10, 1984. of the meetings are Thursday, August 9, and Friday, '

! Times for the Thursday meetin 8:30 l &f0:00a.m.and1:00,3:30,6:00and7:30p.m.gsare: Friday l i meetings will be at 8:30 and 10:00 a.m. All meetings will be  ;

1 held in the auditorium. t

! The stewards samewill program you used with the superintendents, foremen and be agreeable.  !

the Employee Assistance Program.However, you may want to also cover let me know. Gordon Dickerson and I will be at all of theIf you need any vis!}

)

4 meetings to assist you if needed.  !

I I'm looking forward to workin

j. anything I can help you with,g let with meyou again.

know.

If.there is '

MM Dale Cockrill j

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Site Labor Relations Coordinator l

MDC/mk

)

xc: H. H. Gregory, III

! M. H. Googe i

i D. E. Carter C. W. Whitney G. E. Dickerson M. D. Cockrill E

i