ML20248H239

Requests Exemption from Requirements of 10CFR26 Re Fitness for Duty Programs Based on Present & Future Operational Configuration

ML20248H239
Person / Time
Site:	Rancho Seco
Issue date:	10/06/1989
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AM-NUC-89-062, AM-NUC-89-62, NUDOCS 8910110227
Download: ML20248H239 (5)

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sMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street, P.O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA AGM/NUC 89-062 October 6, 1989 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 EXEMPTION FROM FITNESS FOR DUTY PROGRAMS, 10 CFR 26 ,

Attention: George Knighton -

The District hereby requests an exemption from the requirements of 10 CFR 26, Fitness for Duty Programs. This regulation was published in the Federal Register on June 7, 1989, and becomes effective on January 3, 1990. Exemption is requested per 10 CFR 26.6, Exemptions.

Exemption from enforcement of 10 CFR 26 is requested based on Rancho Seco's present and future operational configuration. The District General Manager ordered Rancho Seco to cease operation on June 7, 1989; the facility has been in cold shutdown since June 10, 1989. Defueling is scheduled to begin in the last quarter of 1989.

Since Rancho Seco will be defueled prior to implementation of 10 CFR 26, it is the District's position that the er.;;'ing Fitness for Duty program is adequate to protect the health and safety cf the public in the program's goal to achieve a work place free from the effect of drugs and alcoholic substances.

The District presently has an effective Fitness for Duty program (Standard District Procedure 606-14, Fitness for Duty Policy). The existing program requires mandatory drug and alcohol screening for potential employees and once site access is granted, employees are subject to "For Cause" Urinalysis and Medical Clarification Examinations. Persons whose screening reveals illicit substances in their system are rejected for badging for unescorted access at Rancho Seco and/or are subject to disciplinary action up to and including termination of employment. Depending upon the circumstances, District personnel may be eligible for the Employee Assistance Program or rehabilitation. More detailed information about the District's Fitness for Duty program is provided in the attachment.

8910110227 891006 * ' \

PDR ADOCK 05000312 P PDC RANCHO SECO NUCLEAR GENERATING STATION D 1444o Twin Cities Road, Herald, CA 95638-9799;(2o9) 333-2935

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4 George Knighton. AGM/NUC 89-062 i

h Members of your staff with questions requiring additional information or L-clarification may contact Mr. Dave Swank at (209) 333-2935, extension 4920.

Sincerely, Dan R.' Keuter-Assistant General Manager Nuclear Attachment cc w/atch: J. B. Martin, NRC, Halnut Creek A. D'Angelo, NRC, Rancho Seco

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, ATTACHMENT General Description Sacramento Municipal Utility District Fitness For Duty Program Sacramento Municipal Utility District's (SMUD) policy is to have a work environment free from the effects of drug and alcohol use. j This policy is summarized in Standard District Procedure SDP 606-14 (Fitness for Duty Policy) and implemented at Rancho Seco by four Inter Departmental Procedures. The following para-graphs describe SMUD's Fitness for Duty (FFD) program. )

i On and off-duty Use of Druas/ Alcohol  !

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Use of drugs (other than as directed by a physician) or alcohol I while on duty, during a meal break, while representing the Dis- '

trict, or on District premises may result in disciplinary action up to and including termination.

Off-duty involvement with illegal drugs may also result in disci-plinary action up to and including termination. The District reviews off-duty involvement to determine if the involvement impairs an employee's work performance, damages District proper-ty, jeopardizes an employee's safety, or undermines the public's confidence in the District.

Pre-emoloyment Testina The District requires candidates for employment at Rancho Seco to undergo a screening for drugs and alcohol (including urinalysis) as part of the hiring process. The District sends the samples to an independent laboratory for analysis.

The designated laboratory performs a preliminary test on the sample. If it yields positive results, the lab automatically conducts a confirmation test on the sample using a similar tech-nology (gas chromatography / mass spectrometry). The only test results reported to SMUD as positive are those from a confirma-tion test. The District rejects for employment personnel whose results are positive for either drugs or alcohol.

For Cause Testina SMUD's FFD policy requires that an employee undergo a drug / alcohol I screening in cases where:

1. An employee is involved in an on-the-job accident requiring medical treatment bcyond first aid that is recordable under provisions of the Occupational Safety Health Act.

2. An employee's job performance or behavior suggests the employee may be under the influence of drugs / alcohol.

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3. SMUD receives information or allegations which, after inves-  ;

L tigation, provide reasonable cause to believe the employee i may be involved with drugs / alcohol.

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l Rancho Seco realizes that 'for cause' screening is highly depen-

! dent on the ability of managers, Security, and the regular medical staff to identify employees who are at risk. Addition- '

ally, 'for cause' screening requires strong support from management.

Medical Clarification Examination j Rancho Seco also uses 'for cause' and unannounced Medical Clari- l fication Exams (MCE) to augment its FFD policy. The District i requires these exams for employees who work on or operate vital equipment or who directly support / supervise those employees. The MCE evaluates fitness for duty of the whole person. It incorpor-ates physiological evaluations of chemical dependency, along with physical and psychological status evaluations.

The MCE establishes evidence of chemical use or dependency by using eye evaluation techniques. The individual's skin, nose, and mouth are examined, neurological reflexes are evaluated, and components of the standard field sobriety test are administered.

The MCE. evaluates all body systems for drug dependency or dimin-ished physical and mental status. Also, an interview process elicits the individual's perception of their health, work, and  ;

family issues. '

The District rejects for badging and unescorted access those persons whose screening shows drugs or alcohol in their system.

Those personnel are also subject to disciplinary action up to and including termination of employment. District employees who are scheduled for a screening may volunteer for immediate parti-cipation in the District's Alcohol and Drug Abuse Rehabilitation Program.

Behavior observation Rancho Seco trainers provide managers with FFD training and behavior observation training. SMUD has monthly educational meetings with the Medical Chemical Dependency Consultant. Super-visors may use the on-site MCE practitioner as a resource in the evaluation of employees who clearly are not performing.

The appropriate supervisor is notified when one of their employ-ees is selected for a random MCE and may state any concerns about .

the individual. The practitioner then asks appropriate questions i in the interview and evaluates the employee's perception of the supervisor's stated concern. All discussions are confidential and the practitioner makes appropriate referrals.

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l l Employee Assistance l Rancho Seco uses Employee Assistance Programs (EAP) both on and L off-site to assist those employees experiencing personal problems which are affecting their work performance. EAP referrals may be made for the employee, after 'for cause' incidents, by supervisors or medical staff, as a result of the MCE, and after the Medical Chemical Dependency Specialist has examined an individual who tested positive.

Employee Awareness Rancho Seco feels employee awareness and education contributes to a drug-free workplace. Fitness for Duty is discussed in safety classes and other related new employee orientation. An FFD hand-book is provided to all employees and contractors.

One component of the MCE educational program has evolved in which the practitioner gives the employee information in light of a family history of drug abuse and is a resource guiding the employee to confront his substance abuse problem.

Withdrawal of Authorization for Unescorted Access Rancho Seco assesses an individual for potential substance abuse as soon as a urinalysis is confirmed as positive. Rancho Seco classifies individuals into one of three categories:

1. Category I -- Casual user identified via urinalysis. Will be returned to work, required to undergo 12 months of random surveillance screening and drug education program.

2. Category II -- Individual is not necessarily addicted, but at significant risk. Required to go to Chemical Dependency Counseling.

3. Category III -- Fully addicted individual. Required to undergo rehabilitation.

The individual is then placed on sick leave, their access badge pulled, and sent to the Chemical Dependency Physician for assessment.

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