ML20212M721

Responds to 861208 Ltr Re Allegations of Drug & Alcohol Abuse at Facility Const Site.Chronology of Licensee Activities Aimed at Combating Substance Abuse on Site Encl. Document Supports Commission Position on Drug Free Environ

ML20212M721
Person / Time
Site:	Seabrook
Issue date:	01/20/1987
From:	Zech L NRC COMMISSION (OCM)
To:	Markey E HOUSE OF REP., ENERGY & COMMERCE
Shared Package
ML20212M723	List: ML20212M721 ML20212M833 ML20212M895 ML20212M947 ML20212N013
References
CON-#187-2377 OL, NUDOCS 8701300213
Download: ML20212M721 (4)

Text

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' NUCLEAR REGULATORY COMMISSION

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% . . , , , *# HDenton Docket 50-443 January 20, 1987 BHayes OCA CHAIRMAN OGC TMurley, RI JAllan WKane The Honorable Edward J. Markey, Chairman SCollins Subcommittee on Energy Conservation and Power EWenzinger Committee on Energy and Commerce TElsasser United States House of Representatives Washington, D.C. 20515

Dear Mr. Chairman:

I am responding to your letter of December 8, 1986 regarding allegations of drug and alcohol abuse at the Seabrooi, construction site. You indicate that the Commission's earlier letter to you on this subject reflects a cavalier attitude

• toward alcohol and drug abuse. The Commission strongly disagrees.

In your letter you state your belief that, " allegations of widespread substance abuse suggest an environment that may have created construction deficiencies." I am enclosing a brief chronology of the licensee's activities at the Seabrook facility aimed at combating substance abuse on site. The NRC has recently reviewed these activities as part of an inspection, and the results of that inspection have been sent to you. As stated in the conclusion concerning the allegations of extensive use of drugs at the plant site, the NRC staff believes that the licensee enhanced the substance control program and took appropriate corrective actions where instances of abuse were identified. The report also outlines the steps that the NRC has taken to ensure that the licensee is attempting to create a drug-free environment and that the quality of construction has not been jeopardized as a result of substance abuse. Therefore, the Commission cannot agree that our approach leads to an environment which creates construction deficiencies.

You also believe that an alleger bears the almost impossible burden of proving a nexus between substance abuse and deficient construction. The NRC staff asks that an alleger provide any specific information he or she may possess to give the investigators a starting point to establish any rotential link between substance abuse and construction quality. Broad allegations, such as those referenced in your letter, often do not provide syfficient specificity so that allegations that construction of the facility was compromised can be effectively investigated. Efforts by the NRC to establish the link between substance abuse and construction deficiencies have been directed at determining the job activities of alleged current or terminated abusers in order to identify trends. For instance, a concentration of allegations in one specific area of quality activity would be indicative of an area requiring review or Originated: RI:Elsasser R

f, reinspection by NRC inspectors. The approach taken was to review both past allegations received by the NRC and Public Service of New Hampshire (PSNH), as well as the nature of the work accomplished by terminated workers. This review failed to identify a concentration of substance abusers in any one area of work activity. In fact, the majority of substance abusers were found in crafts or trades least likely to affect quality.

While the Commission has not issued rules at this time regarding substance abuse by workers during the construction phase of nuclear power plants, it does not follow that the Commission is indifferent toward such problems. The Commission has urged the industry to take the initiative in combating this problem and has issued the Commission's Fitness for Duty Policy Statement.

PSNH voluntarily formulated and implemented an anti-drug and alcohol program at the Seabrook site. As early as 1976, project rules were issued which dealt with the issue of drug and alcohol abuse at Seabrook. This activity was initiated far in advance '

of subsequent industry or NRC initiatives regarding fitness for duty. The program was upgraded as the project expanded and specific needs arose.

The NRC is concerned with any potential for drug and alcohol abuse to adversely affect the quality of nuclear power plant construction. Our inspection program focuses on those attributes that give an objective measure of the quality of construction. The NRC inspection program is directed toward identifying defects which could compromise the adequacy of nuclear plant construction, regardless of the source of the activity which may have caused the defect. To that end, the NRC staff expended over 21,000 inspection hours during the construction of the Seabrook facility. The licensee has consistently demonstrated high performance ratings in the NRC staff's periodic Systematic Assessment of Licensee Perforamnce (SALP). Consistently high ratings in the SALP process indicate strong and effective licensee management. The substance control program voluntarily instituted and implemented by PSNH and consistently high ratings in the SALP process indicate to the NRC staff that the quality of construction at Seabrook has not been adversely affected.

I would like to address two other issues raised in your letter.

The first of these has to do with the apparent discrepancy in the number of contractor terminations as reported during the on-site survey conducted by NRC Region I in March, 1983.

Further inquiry by the NRC resident inspectors indicates that at the time of the survey, the actual number of terminations due to substance abuse was probably closer to 100 than "approximately 52" as stated. In the staff's view, this discrepancy is attributed to the general nature of the survey. The purpose of the question when asked was to measure the general effectiveness of the PSNH program, not to evaluate precisely the number of terminations. With respect to Security Incident Reports, NRC

I ~3-inspectors do not routinely review these reports, prepared during the construction phase, since they are not required by NRC regulation. Specific reports involving incidents that could impact activities regulated by the.NRC were reviewed by the Resident Inspector in selected instances during the construction of Seabrook.

The Commission shares the heightened awareness of the problems of substance abuse and its implications for the safe operation of nuclear facilities. We believe that the efforts described above, as well as inspection material you have received recently, address the concerns you raised. However, the Commission will be pleased to respond to a request for a briefing should you continue to desire it.

Commissioner Asselstine will provide his views in a separate letter.

~

Sincerely, d416e W, k Lando W. Ze , Jr

Enclosure:

As Stated ,

cc: Rep. Carlos Moorhead

i ENCLOSURE BRIEF CHRONOLOGICAL LOG 0F SEABROOK DRUG /ALC0HOL ACTIVITIES July 14th, 1976 Project Rule #7 issued which prohibited the use of drugs and alcohol at Seabrook Station. A volunteer program based on Alcoholics Anonymous principles started shortly afterward.

Spring of 1979 Employee Assistance Program (EAP) recognized by Seabrook Station Management for helping employees with drug / alcohol problems.

1980 Vehicle / personnel search program implemented for anyone entering Seabrook Station.

May, 1981 Trainin of Supervision on EAP (including foremen .

September, 1981 Construction Management began putting greater emphasis on the EAP program for use by employees.

December, 1981 Implemented use of dogs to perform random drug searches at the Station.

1983 NHY Employee Assistance Program established specifically for NHY personnel.

January, 1985 Employee Allegations Resolution Office established.

March, 1986 Fitness for Duty Policy established which included chemical screening, observation and training.

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