ML20235D770
| ML20235D770 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/13/1987 |
| From: | Russell Gibbs TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 71400, 71400-V07-R03, 71400-V7-R3, NUDOCS 8902210038 | |
| Download: ML20235D770 (29) | |
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6-EMPLOYEE CONCERNS SPECIAL PROGRAM 1
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VOLUME 7 MANAGEMENT AND PERSONNEL CATEGORY SUBCATEGOR'Y REPORT 71400 DRUGS 1
UPDATED L
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0 TVA NUCLEAR POWER
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TVA EMP!4 TEE CONCERNS REPORT NUMBER: 71400
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SPECIAL PROGRAM REPORT TYPE: Managessent and Personnel Subcategory REVISION NUMBER: 3 PAGE 1 0F 13 TITLE: Drugs REASON FOR REVISION:
f Incorporation of final TAS editorial comuments.
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PREPARATION j.2 3, if
/ SIGNATURE DATE REVIEWS PEER:
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SIGNATURE DATE TA l'
SIGNATURE
/ A ATE i.
CONCURRENCES I
CEG-H:
- 7 Mn SRPt \\ -- A R &Wb 6 3*87 SIGNATURE DATE SIGNATURES DATE APPROVED BY:
--h.6. Mk 63!TO N/A p ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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'I TVA EMPLOYER CONCERNS REPORT NUMBER:. 71400 SPECIAL PROGRAM FRONT MATTER REY: 3 5
PAGE i 0F viil' Preface
.This subcategory report is one of a series of reports prepared for.the i
Employee Concerns Special Program (ECSP).of the Tennessee Valley Authority j
(TVA). The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) d employee concerns filed before February 1, 1986.. Concerns filed after'that date are handled by the ongoing ONP Employee Concerns Program (ECP).
j The ECSP addressed over 5800 employee concerns. Each of the concerns was a j
formal, written description of a circumstance or circumstances that an 1
employee thought was unsafe, unjust, inefficient or inappropriate. The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns-and to report the results of those investigations in a form accessible to ONP employees, the NRC, and the general public. The results 'of these investigations are consnunicated by four levels ot ECSP reports:
element, subcategory, category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restart of Sequoyah Nuclear Plant's reactcc unit 2.
An element consists of one or more closely related issues. An issue is a potential problem identified by.ECTG during the evaluatiru frocess as having been raised in one or more concerns. For efficient hundling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself. Consequently, some elements did include only.
one issue, but often the ECTG evaluation found more than one issue per element.
Subcategory reports sunsaarize the evaluation of a number of elements.
However, the subcategory report does more.than collect element level evaluations. The subcategory level overview of element findings leads to an integration of information that cannot take place.at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not. fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report: a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms..
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i Additionally, at the end of each subcategory report will be a Subcategory Summary Table that includes the concern numbers; identifies other subcategories that share a concern;-designates. nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Sunsaary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.
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TYA EMPLOYEE CONCERNS REPORT NUMBER: 71400 l
SPECIAL PROGRAN FRONT KATTER REY: 2
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PAGE 11 0F vill The subcategories are themselves summarized in a series of eight category reports. Each category report reviews the major findings and collective significance o.f the subcategory reports in one of the following areas:
l management and personnel relations industrial safety
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construction material control
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operations quality assurance / quality control welding engineering i
A separate report on employee concerns dealing with specific contentions of i
intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the catc6ery reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.
l A final report will integrate and assess the information collected by all of the lower level reports prepared for the ECSP, including the Inspector j
General's report.
j For more detafl on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual. The Manual spells out the program's objectives, scope, organization, and responsibilities. It also specifies the procedures that were followed in the investigation, reporting, and closeout of the issues raised by employee concerns.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 71400 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE ill 0F vili ECSP GLOSSARY OF REPORT TERMS
- classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A: Issue cannot be verified as factual i
Class B: Issue is factually accurate, but what is described is not a j
problem (i.e., not a condition requiring corrective action) l Class C: Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue
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was undertaken-Class D: Issue is factual and presents a problem for.which corrective i
d action has been, or is being, taken as a result of an evaluation l
Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
collective significance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see " employee concern")
corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence, criterion (plural: criteria) a basis for Afining a performance, behavior, or quality which ONP imposes on itself (see also " requirement"),
element or element report an optional level of ECSP report, below the subcategory 3evel, that deals with one or more issues.
employee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a X-form or a form equivalent to the X-form.
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evaluator (s) the individual (s) assigned the responsibility to assess a speelfic grouping of employee concerns.
findings includes both statements of f act and the judgments made about those l
facts during the evaluation process; negative findings require corrective action.
1 issue a potential problem, as interpreted by the ECTG during the evaluation process.. raised in one or more concerns.
K-form (see " employee concern")
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requirement a standard of performance, behavior, or quality on which an evaluation judgment or decision may be based.
root cause the underlying reason for a problem.
- Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear safety-related, unreviewed safety-significant question).
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v TVA EMPLOYEE CONCERNS REPORT NUMBER: 71600 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE y OF viii
.Acronyma AI Administrative Instruction l
l AISC American Institute of Steel Construction ALARA As Low As Reasonably Achievable ANS American Nuclear Society' ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society.for Testing and Materials.
AWS American Welding Society BFN Browns Ferry-Nuclear Plant i
BLN Bellefonte Nuclear Plant CAQ Condition Adverse to Quality CAR Corrective Action ReportL 1
CATD Corrective Action Tracking Document j
CCTS Corporate Commitment Tracking System CEG-H Category Evaluation Group Head l
CFR Code of Federal Regulations i
CI Concerned Individual 1
CNTR Certified Material Test Report C0C Certificate of Conformance/ Compliance DCR Design Change Request DNC Division of Nuclear Construction (see also NU CON)
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u TVA EMPLOYEE CONCERNS REPORT NUMBER:
71400 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE vi 0F vill DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality' Assurance DNT Division of Nuclear Training i
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DOE Department of Energy DP0 Division Personnel Officer DR Discrepancy Report or Deviation Report ECN Engineering Change Notice ECP Employee Concerns Program ECP-SR Employee Concerns Program-Site Representative ECSP Employee Concerns Special Program
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ECTG Employee Concerns Task Group
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EEOC Equal Employment Opportunity Commission EQ Environmental Qualification EMRT Emergency Medical Response Team EN DES Engineering Design
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ERT Employee Response Team or Emergency Response Team FCR Field Change Request FSAR Final Safety Analysis Report FY Fiscal Year
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GET General Employee Training HCI Hazard Control Instruction HVAC Heating, Ventilating. Air Conditioning II Installation Instruction INPO Institute of Nuclear Power Operations t-IRN Inspection Rejection Notice I
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i TVA EMPLOYEE CONCERNS REPORT NUMBER: 71400 SPECIAL PROGRAN FRONT MATTER REY: 2 PAGE vii 0F vill L/R Labor Relations Staff M&AI Modifications and Additions Instruction MI Maintenance Instruction MSPD Merit Systems Protection' Board MT Magnetic Particle Testing NCR Nonconforming Condition Report NDE Nondestructive Examination NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear Procedures System NQAM Nuclear Quality Assurance Manual 1
i NRC
' Nuclear Regulatory Commission NSB Nuclear Services Branch NSRS Nuclear Safety Review Staff l
NU CON Division of Nuclear Construction (obsolete abb'reviation, see DNC)
NUMARC Nuclear Utility Management and Resources Committee OSHA Occupational Safety and Health Administration (or Act) l ONP Office of Nuclear Power OWCP Office of Workers Compensation Program PHR Personal History Record PT Liquid Penetrant Testing QA Quality Assurance
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QAP Quality Assurance Procedures
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l QC Quality Control d
QCI Quality Control Instruction l
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a TVA EMPLOYEE CONCERNS REPORT NL 'BER: 71400 SPECIAL PROGRAM
.J FRONT KATTER REY: 2 1
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I QCP Quality Control Procedure
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QTC' Quality Technology Company RIF Reduction in Force l
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RT' Radiographic Testing SQN Sequoyah Nuclear Plant i
SI Surveillance Instruction 1
i SOP Standard Operating Procedure l
I SRP Senior Review Panel 1
SWEC Stone and Webster. Engineering Corporation TAS Technical Assistance Staff 1
l T&L Trades and Labor f
TVA Tennessee Valley Authority TVTLC Tennessee Valley Trades and Labor Council UT Ultrasonic Testing VT Visual Testing WBECSP Watts Bar Employee Concern Special Program WBN Watts Bar Nuclear Plant I.
WR Work Request or Work Rules WP Workplans l
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i DRUGS Subcategory Report 71400 Exec.utive Summary This subcategory includes 23 employee concerns which raised three issues. The issues are the adequacy of the drug testing program, alleged abuse of the Employee Assistance Program (EAP), and a questioning of the legality of proposed random testing.
The findings indirectly support the need for a more comprehensive drug testing program as a prudent precaution. Although the current program was not proven to be inadequate, neither was it proven to be' adequate. TVA's percentage of.
detected drug abusers is lower than the naticnal average; however, it is not certain whether the lower porcentage is becausa there are fewer drug abusers within TVA or because TVA has a less effective Lusling. program.
Management effectiveness in identifying drug users in the workplace has historically been poor throughout the nation. A more impersonal and objective approach is badly needed. Managers and supervisors also need more training in the identification and handling of apparent drug abusers. Employee effectiveness is impeded it drug abusers avoid detection and if nonusers perceive that management tolerates or ignores drug abusers.
l TVA's drug testing program will be expanded to include all employees. Random testing will be initiated for all personnel with unescorted access to vital plant areas. Trair;ing programs are being developed to increase the effectiveness of the Fitness for Duty Program. Supervisors will be better trained in identifying and handling drug abusers.
Employees wl11 be better informed on drug policy and the EAP through the Drug Awareness Program Training Handbook, which will be issued to each employee during General Employee Training.
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REPORT NUMBER:L71400 TVA EMPLOYEE CONCERNS SPECIAL PROGRAN
.. REVISION NUMBER: 3
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-1.0 CHARACTERIZATION OF ISSUES j
This report covers.23 employee concerns addressing the use and control of i
drugs and alcohol'at Watts Bar Nuclear Plant'(WBN). The 23. employee.
.j concerns raised three issues'about a) the drug testing program (21
-l concerns); b)'the Employee: Assistance Program (l' concern); and c) the
. legality'of'a proposed random drug testing' program (1 concern).- These issues are characterized as-follows.'
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1.1 Issue 71401 - Adecuacy of Drua Testina Proaram Most of'the concerns that make up this-issue' expressed or implied l
the need for more comprehensive drug testing procedures. Some of the concerned individuals perceived drug abuse to be widespread _at
.WBN'and other ONP sites. This perception raised questions.about the effects of drug abuse.on plant safety. One individual stated that employees are reluctant to report' drug users for fear of reprisal.
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Issue 71402 - Atuse of Employee Assistance:Proaram q
One cencern alleged that con'struction workers report to work under the influence of drugs. They are allegedly allowed to contiriue j
working and continue using drugs if they tell TVA they are enrolled I
in a drug abuse program.. Additionally, these drug abusers are l
alleged to be retained at layoff time at the expense of non-abusers.-
1.3 Issue 71403 - Leaality of Random Testina j
One concern argued that random testing for drugs would be a J
violation of the constitutional right to privacy.
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1 To locate the issue in which a particular concern is evaluated, consult i
the following attachments:
Attachment A, Subcategory Summary Table l
Attachment B. List of Concerns by Issue All Management and' Personnel Category concerns having a technical component (including all concerns designated Nuclear Safety-Related) are shared with the appropriate technical category for. investigation l
and resolution of that technical component.. Report (s) sharing a concern with this report are identified in the entry for that 1
concern on Attachment A.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:.71400 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 3 0F 13 l.
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1 2.0 SUNNARY 7..
l 2.1 Summary of Issues There are three issues contained in the 23 employee concerns addressing drug use. The first issue (with a total of 21 concerns) expressed or implied the need for a more comprehensive drug testing program at WBN. One issue implied abuse of the Employee Assistance Program (EAP). One issue questioned the legality of random testing for drugs: does such testing violate the constitutional right of privacy and the avoidance of search without probable causef i
2.2 Summary of Evaluation Process
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The evaluator has reviewed all the information available on the concerns in this subcategory. The information pertinent to the evaluation of the issues has been considered and incorporated in this report.
1 Interviews were conducted with top level people in the field, both inaide and outside of TVA, to develop background data. This data, coupled with a review of current literature, provided an informational base sufficient to evaluate the issues.
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2.3 Summary of Findings
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The findings' indirectly suppert the need for a more comprehensive J
drug testing program as a prudent precaution. No evidence of abuse of the EAP was found. The legality of random testing is a question that can be decided only by the courts.
2.4 Summary of Collective Stanificance Although no evidence was found that employee drug use is currently a
- Janificant problem, prudence dictat,es that measures b6 taken to p?4rd acJnst drug abuse in the future. Failure to identify and
' reform drug abusers could lead to serious safety and morale problems at nuclear facilities.
2.5 Summary of Causes l
The current drug testing program is not perceived by the CIs as being comprehensive enough to catch or deter potential drug abusers.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 71400 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 4 0F 13
?.6 Summary of Corrective Action TVA's drug testing program will be expanded to include all employees, regardless of position.
Random testing will be initiated for all personnel with unescorted access to vital plant areas.
Training programs are being developed to increase the effectiveness
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of the Fitness for Duty program. Supervisors will be better trained in identifying and handling drug abusers. Employees will be better informed of the availability of the Employee Assistance Program and of the consequences of continued drug abuse.
3.0 EVALUATION PROCESS 3.1 General Methodology The evaluation of this subcategory was conducted according to the i
Evaluation Plan for the Employee Concerns Task Group and The
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Evaluation Plan for the Management and Personnel Category. The j
concern case files were reviewed. Source documents were reviewed to establish the regulatory requirements or management mandates that apply to the circumstances descelbed in the issues covered in this j
subcategory. The issues were evaluated against the established
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requirements or management policies. From this evaluation, findings were determined. The findings were then analyzed for their collective significance. Causes were identified for the negative findings. The responsible organizations were identified and corrective actions were initiated for the negative findings.
3.2 Specific Methodology TVA's current drug testing requirements were compared to programs outside and inside the utility industry to establish TVA's position with respect to program implementation (See Attachment C for sources consulted).
Interviews were conducted with five TVA employees and one knowledgeable person outside TVA to gather background data and determine TVA's short and long-term approach to the drug use problem i
in the workplace (See Attachment C for a list of those interviewed). One line management investigative report was reviewed; its findings were in accord with the findings reported in section 4.0.
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TVA EMPLOYEE CONCERNS REPORT NUMBE2: 71400 SPECIAL PROGRAM REVISION NUMBER: 3 1
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3.3 Investigative Focus for Each Issue r-i l
3.3.1 Issue 71401 - Adequacy of Drug Testing Program (a) What are the advantages / disadvantages of having random drug testics as a part of the drug program?
(b) Is there a::y evidence directly linking drug use to poor work quality ind/or the creation of hazardous situations?
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(c) What specifically do employees fear from identifying a drug user / abuser?
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.3.3.2 Issue 71402 - Abuse of Employee Assistance Program (EAP)
(a) What are the controls to prevent participants in the EAP i
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(b) What controls exist that would prevent employees from continuing to use drugs.while participating in a non-TVA drug abuse program?
(c) Are control: necessary to ensure that those in the FAP I
do not receive preferential treatment?
3.3.3 Issue 71403 - Legality of Random Testing (a) What is the legal opinion on random testing across the industry?
(b) 'What is TVA's position (per Office of General Counsel)?
l 3.4 Current ONP Drua Proaram Requirements-
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i The requirements of the program (Nuclear Power Procedure 0905.01.04)
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currently in place within ONP state:
i Discharge is the standard penalty for the illegal use, sale, or possession of narcotics, drugs, or controlled substances, while on the job or on TVA property.
Off-the-job illegal drug use which could adversely affect an employee's job performance or which could jeopardize the safety of other employees, the public, or TVA equipment is proper cause for disciplinary action up to and including termination.
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9 TVA EMPLOYEE CONCERNS R2 PORT NUMBER: 71400 SPECIAL PROGRAM l
REVISION NUMBER: 3 PAGE 6 0F 13 When an employee is arrested for off-the-job drug activities,
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management will consider the underlying factual basis for the l
arrest in determining any disciplinary action or other action i
that may be warranted.
j The drug and alcohol testing process used by ONP is handled as follows:
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Testing is invoked in cases where there is reasonable suspicion that the employee is intoxicated or under the influence of drugs or alcohol. Reaaonable suspicion is a belief based on behavioral observations sufficient to lead a prudent supervisor to suspect that the employee is under the influence of drugs or alcohol (e.g., slurred speech, alcohol on breath, inability to walk a straight line, and inattentive or inappropriate behavior).
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Testing will be used routinely for:
I Outside applicants and:;ransferees into positions requiring unescorted access clearance.
TVA employees who are being transferred and must obtain an initial unescorted access clearance, j
i An employee who is suspected to be in possession of illicit i
drugs or alcohol or when 1111 cit drugs or alcohol are found l
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in an employee's workplace.
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I Contractors or vendor employees requiring unescorted access l
clearance.
4.0 FINDINGS The' discussion of the subject of a drug and alcohol testing program within TVA would probably be better understood in the context of recent activities and current ONP drug program requirements.
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Before 1983. No Identification Proaram l
Before 1983, TVA's work rulee specifically prohibited the use of drugs onsite; however, there was no program in effect to identify drug users / abusers.
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.SPECIAL PROGRAN-I REVISION' NUMBER:'3 i
PAGE 7 0F 13 The. initial.esposure of TVA's nuclear-program to comprehensive. drug j
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testing requirements was in October 1982, when.the Nuclear Regulatory l
Commission (NRC) proposed their " Fitness for Duty Rule" to the' nuclear
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Subseauent Milestones j
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' Subsequent milestones in the last 43 months are as follows:
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March 1983
- TVA implemented the Drug Awareness Program.
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ONP supervisors'were trained on policy and behavioral q
observation.
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6 NRC decided to delay rule-making on fitness for duty J
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for two years. TVA committed, with other utilities i
through Nuclear Utility Management and Resource Committee (NUMARC), to have a basic Fitness for Duty Program implemented in its nuclear program by February 1985.
The Institute-of Nuclear Power Operations (INPO)
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January 1985 issued fitness for duty performance objectives.in 1
Performance Objectives and Criteria for Operating and
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Near-Term Operating License Plants.
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.i INPO revised corporate fitness for duty performance August 1985 objectives and criteria and. issued Performance J
Obiectives and Criteria for Coroorate Evaluations.
Edison Electric Institute (EEI) revised and issued U I, Guide to Effective Drug and Alcohol Fitness for Duty Poliev Developmepl.
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ONP changed the Drug Awareness Program to the Fitness
'for Duty Program and included alcohol and drug screening tests of prospective employees, which also included transfers, employees requesting initial clearance, and contractors.
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Supervisory and Employee Training Programs were l
1 revised and retraining was initiated at all locations.
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TVA EMPLOYEk CONCERNS REPORT NUMBER: '71400 SPECIAL PROGEAN REVISION NUMBER: 3 PAGE 8 0F 13-4.1 Generic Findinas 4.1.1 Issue 71401 - Adequacy of Drug Testing Program Discussion i
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Need for Improved Testina Procedure.
A study was done by an Edison Electric ~ Institute'(EEI) task force. The chairman was Michael R. Tuosto. Public Service Electric and Gas Company (PSE&G) general gaanager of personnel and equal opportunity. The study concluded that the utility industry was experiencing drug-related problems "no worse, but no better" than industry in general.
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The consens"us of the EEI task force, though not absolute, is that upwards of 7 percent of the nation's work force is involved with the misuse of drugs. Checks of l
potential employees at one major northern utility has revealed that 8 to 11 percent of new applicants were misusing drugs. TVA's experience with new applicants and transferring employees has been that 4 to 5 percent are drug abusers.
1 It is unclear why.TVA's percentage of detected drug abusers is lower than the national average.
It may be l
lower because the testing procedure is inadequate (as the CI's contend), but it may also be lower because TVA has fewer drug abusers.
ONP is developing a random drug testing program. It is more comprehensive in at least two areas than programs initiated by the Department of Defense (civilian employees), U.S. Air Force, U.S. Navy, South Carolina Electric & Gas, and Detroit Edison. The principal areas where ONP's program exceeds the others are in the number j
of employees to be tested and in the number of drugs that 4
can be identified.
l The programs of outside organizations used for comparison with ONP canged fetim random screenin4 of critical positions only, to testing all personnel annually. By inspection, the first situation would esclude quite a few employees and the second would.not be particularly valid since all employees would know when their screening would be scheduled. ONP tests for seven (7) groups of drugs as compared to a cross-section of government and private companies that test for two (2).
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Comparisons between various. programs can be misleading and should be approached with some caution. However, r-such comparisons' provide an additional perspective from which to gauge the overall merit of ONP's drug testing I,.
program.
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Plant Safety The basis of most of the concerns about the drug testing
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1 program is that drug abuse could result in poor work performance. However, based on discussions with personnel officer (s) and construction management, no situations have been identified at WBN (where most of the f
concerns originated)'in'which any employee made a safety-related mistake or created a hazardous situation that could be attributed to drug uso. Certainly, some employees have been detected as drug users and rehabilitated or released; nevertheless, their work records have not indicated any safety-related abnormalities.
The possib.ility that the work records failed to document safety abnormalities.is also being guarded against. An j
extensive. study is being performed by a company called EG&G on the welding program at WBN; meanwhile, Stone and.
Webster Engineering Corporation (SWEC) is evaluating QA-related areas. Since these programs are comprehensive
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in nature, defective welds or inspections will be identified as a result of these efforts.
C.
Fear of Reprisal Employees are indeed reluctant to turn in fellow employees for drug abuse on the job. Discussions with a number of TVA employees have revealed that identifying follow employees as drug users / abusers could mark them
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for retribution ranging from peer ostracism to
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unwarranted supervisory actions, depending on whom they identified. However, no specific instances of reprisals were found.
Conclusion Efforts to combat drug use with the current level of testing (i.e., only on transfer or for initial clearance) were I
considered to be ineffective by the majority of concerned I
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 71400 SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 1-0 0F 13-individuals (CI's) who addressed this issue. This contention could'not be verified as factually accurate. However, a
' random testing program currently under development should help strengthen the program and alleviate the perceptions of inadequacy (see section 7.1).
4.1.2 ' Issue 71402'- Abuse of Employee. Assistance Program l
. Discussion This issue raised three questions about the EAP.
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A.
Do employees in'EAP continue'to use druas?
Controls.to prevent employees in the EAP from continuing to use drugs are in place and are strictly enforced..
-They:are described in the Division of Medical Services',
Standardized Procedures for-EAP Monitorina of Nuclear Power Employees after a Positive Drua Screen. An individual participating in the EAP would not be able to.
continue' drug use for any length of-time since a random screening program is initiated for each EAP participant and-a second positive screening would result in-the.
employee's immediate. dismissal.
Employees who.
l participate in the drug abuse program are well aware of.
the restrictions they are subject to'and, in fact.must
. sign a statement that outilnes those. restrictions.
B.
Can employees in outside drua oroarams still use druas?
Employees can participate in a drug abuse program'without TVA's knowledge; however, if they communicate this information to their supervisor for any reason,.they will be referred by the supervisor to the EAP counselor'for an interview to assess the quality of the employee's involvement with his/her program. The fact that an employee would then be associated with drug use and possibly be required to submit to a drug screen should provide a sufficient deterrent to prevent employees from using their involvement in an outside program as an escuse to continue to uso drugs.
C.
Do employees in the EAP receive preferential treatment?
Centrols that govern the retention of employees during layoffs are negotiated as part of the contracts TVA has with the various unions.
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.v TVA EMPLOYEE CONCERNS REPORT NUNBER: 71400 SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 11 0F 13 e-i The personnel groups that' develop seniority lists during layoffs are not informed of.an employee's participation I
in the EAP; In fact, the names of EAP participants are kept confidential. Under these circumstances it would.be-impossible to favor one employee or groupfor employees l
I over another.
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factually accurate. However, the questions raised do; reveal
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.a lack of understanding by employees of'how the EAP works.
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.4.1.3 Issue 71403 - Legality of Random Testing Discussion e
The opponents'of random testing point to a citizen's right to 1
avoid " search without probable cause" by a government I
agency. The Constitution of the United States prohibits l
governmental organizations from imposing " searches" on private citizens without probable cause. Nongovernmental organizations will not have to defend their actions on.this point; however, they will be required to' offer a defense l'
against the " invasion of privacy" argument..TVA will probably be required to defend its' actions in both areas.
]
TVA's Office of General Counsel is currently evaluating these l
questions. The final determination should eventually be made l
by the courts.
Conclusion
.]
This issue could not be verified'as factually accurate.
4.2' Site-Specific Findinas
- [
None.
5.0 COL!.ECTIVE SIGNIFICANCE The Employee Concerns Special Program has received a total of 23 concerns about the use and control of drugs and alcohol at WBN and other ONP l
1L L
1 I
TVA EMPLOYER CONCERNS REPORT NUMBER: 71400 SPECIAL PROGRAM-REVISION NUMBER: 3.
PAGk 12 0F 13 sites. Since there were over 5,000 concerns from over 2.000 individuals, I
one might fairly conclude that drug and alcohol abuse is not seen as a serious problem by ONP employees. However. prudence dictates that measures be taken to make sure that a problem in this area does not develop in the future. That need for prudence accounts for two potential problem areas that became apparent through the' evaluation of this subcategory.
(1) Management effectiveness in identifying drug userr/ abusers in the workplace has historically been poor throughout tha nation. A more impersonal and objective approach to this process is badly needed.
Managers and supervisors also need more training in the identification and handling of apparent drug users / abusers.
However, the determination that'an employee is a drug abuser is a professional clinical judgment to be made by medical personnel.
(2) Employee effectiveness is impeded if nonusers perceive that management tolerates or ignores drug abuse. A drug abuse program widely perceived as effective helps nonsbusers' morale even as it protects against the possibility of bad work by actual abusers.
6.0 CAUSES 6.1-Perception of Inadeauste Drug Testing Procedures The drug testing procedures in place at the time these concerns were filed were not perceived as comprehensive enough to detect all drug abusers quickly. Consequently, the procedures were not seen to be an effective deterrent to potential drug use on the job.
6.2 Misunderstanding of the EAP I
The Employee Assistance Program (EAP) is intentionally promoted and administered to maintain a low profile. A consequence of this approach is inadequate awareness on the part of employees about the-program and the rules that govern it.
However, some responsibility for this lack of awareness must be borne by the employees since the information is readily available.
1 7.0 CORRECTIVE ACTION 7.1 Previousiv Initiated Corrective Action A random drug testing program for all personnel with clearance to work unescorted in vital plant areas is under development. The i
1
m 1
TVA EMPLOYEE CONCERNS REPORT NUMBER: 71400
)
SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 13 0F 13
~
research of_drua testing programs undertaken for this evaluation j
argues thag ogram w1AA oui,tr svuu v.
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found to assure e $ oyeu,.and the p lic ha ON uc
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environmeQCATD 714 'N 4-e i. -
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7.2 Corrective Action Resultina from This Evaluation I
l The ONP Training snd Development Staff is, revising the training previously administered under the former Drug Awareness Program.
}
Training on the Employee Assistance Program will be made a part of I
i.
General Employee Training (GET 3.1) for all nuclear plant l
personnel. The revised program will include content on the rules which govern the EAP and training on the behavioral changes in employees which should be recognized and reported to supervisors.
The Power Operations Training Center (POTC) staff is coordinating the new GET 3.1 curriculum (CATD 714-NPS-02),
f i
8.0 ATTACHMENTS Attachment A, Subcategory Summary Table Attachment B. List of Concerns by Issue Attachment C. List of Interviewis and Supporting Documents l
I i
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~ - - -
~ - - - - - - - - _ _... _ _.
4 ATTACHMENT B DRUGS List of Concerns by Issue addresses 23 employee concerns about This Subcategory Report (71400)
These the use and control of drugs at Watts Bar Nuclear Plant.
concerns raised three issues, as outlined below.
71401 - Adequacy of Dru6 Testing Program IN-85-663-004 EX-85-030-001 IN-85-750-002 EX-85-117-004 IN-85-871-001 I
I-86-111-8FN IN-85-947-XO9 I-86-112-SQN IN-86-082-001 IN-85-004-004 IN-86-293-001 IN-85-041-002 WBM-86-013-003 IN-85-294-003 WI-85-071-001 IN-85-408-001 WI-85-081-010 IN-85-473-001 XX-85-065-002 IN-85-551-001 IN-85-558-001 71402 - Abuse of Employee Assistance Program IN-85-272-005 71403 Le5ality of Random Testing IN-85-954-002 Page 1 of 1
- - - - - - - - - ~ _ _ _ _ _ _ _ __
a e
t ATTACHMENT C Supporting Documents 1.1 TVA Code VIII, HEALTH SERVICES 1.2 TVA Instruction III, ALCOHOL AND DRUG ABUSE 1.3 Edison Electric Instituto Guide to Drug and Alcohol / Fitness for Duty Policy Development, 1985 1.4 Informal memorandum, from L. O. Holliman to C. C. Mason, dated January 13, 1986 1.5 Nuclear Power Alcohol and Drug Screening Program Procedure 0905.01.04 1.6 Memorandum from L. O. Holliman to C. C. Mason, dated January 17, 1986 (LO786001109530) 1.7 Medical Services, Standardized Procedures for Employee Assistance Program (EAP) Monitoring of Nuclear Power Employees After A Positive Drug Screen 1.8 NUMARC Commitments on Fitness For Duty as presented by memorandum from Jack T. Pate, INPO to James P. Darling, dated November 20, 1984 1.9 WBN Standard Practice. WB2.2.3, Section C " Drug Awareness Program" Interviews 2.1 Dr. Richard K. McGee, Chief Health Counseling and Rehabilitation Branch, Division of Medical Services 2.2 L. O. Holliman, Chief. Personnel Staff, Office of Nuclear Power 2.3 Cal Bailey, Employee Assistance Program, Coordinator, Division of Medical Services 2.4 Michael R. Tuosto (phone interview). General Manager, Personnel and Equal Opportunity Public Service and Gas Company 2.5 Richard Gutokurst (phone interview). Staff Attorney TVA, Office of General Counsel 2.6 Charles Kline, Personnel Officer, WBN Construction, Office of Employee Relations r
L_______________________