IR 05000454/1987030

Special Fitness for Duty Program Insp Repts 50-454/87-30 & 50-455/87-28 on 870713-17.Major Areas Inspected:Policies, Procedures & Practices of Fitness Duty Program & Employee Assistance Program

ML20235S149
Person / Time
Site:	Byron
Issue date:	08/31/1987
From:	Bush L, Creed J, Drouin B, Randy Erickson, Mcpeek E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20235S148	List: IR 05000454/1987030 ML20235S144
References
50-454-87-30, 50-455-87-28, NUDOCS 8710080342
Download: ML20235S149 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF NUCLEAR REACTOR REGULATION

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AND REGION III Report Nos.: 50-454/87-30 and 50-455/87-28 50-454 and 50-455 License Nos.: NPF-37 and NPF-66 Docket Nos.:

Licensee: Commonwealth Edison Company .'

ATTN: Mr. Cordell Reed Senior Vice President, Nuclear Operations P. O. Box 767 Chicago, Illinois 60690 i

Facility Name: Byron Station \

Inspection at: Chicago and Byron, Illinois Inspection Conducted: July 13 - 17, 1987 Type of Inspecti .

sAnnounced Special Inspection of Fitness for Duty Program EJ//g7

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! Inspectors: cu - [ Date

@ren L. Bush, Jr. , OfiiEf, Program Development and Review Section Division of Reactor Inspection and Safeguards, NRR A L1 Wt Y Eugep. McFeek, Security S'pecialist

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l Program Development and Review Section l

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Division of Reactor Inspection and Safeguards, NRR

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O .Yh fVames R. Creed, Chief 8k&fB7

~ Date Safeguards Section, Region III w" l WWF7 r an Drouin, Physical Security Inspector ' Date afeguards Section, Region III

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Approved By: M ~

'Dat'e Robelyt A. Erickso'n, Chief Safetuards Branch Division of Reactor Inspection and Safeguards .

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Office of Nuclear Reactor Regulation 8710080342 870922 4 DR ADOCK 0500

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Insoection Summary Areas Inspected: Included review of policies, procedures, and practices of the Fitness for Duty (FFD) Program and the Employee Assistance Program (EAP)

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applicable to Commonwealth Edison Company (Ceco) employees and contractors;

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comparison of the FFD and EAP programs with the program elements recommended in

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the EEI Guide; and evaluation of supplemental program elements not specifically q addressed in the EEI Guid i l

Significant observations included: l 1.- Ceco's written policies differ from some of the features contained in th Commission's Policy Statement or recommended by the EEI Guid Most of the differences appear to result from no site policies being promulgated by Byron to expand upon company wide policie Some of the differer.ces provide management latitude in handling problems on a case by case basi . Chemical tests of body fluids are used for reemployment screening of Ceco employees, and follow-up testing of Ceco employees in the EAP. All people employed on site are subject to testing for cause. Random or periodic tests are not conducte CECO does not test contractor employees; rather Ceco expects that contractors will conduct the tests, Many CECO and long term contractor employees have never been tested because they were hired before reemployment testing was initiated, Urine is collected under direct observatio ' Cut off limits are suitably conservativ . CECO supervisors have been trained, however, contractor supervisors had not been traine . Ceco employees were aware of the policy, however, awareness training for contractor employees was somewhat limited, No formal audit program has been develope . Statistical data are kept and analyzed, resulting in some significant changes to the progra . The CECO EAP program appears to be effectiv ,

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, Key Persons Contacted C. Reed, Senior Vice President, Nuclear Operations D. Galle, Vice President, BWR Operations J. P. Sanders, Vice President, Industrial Relations f *H. Dellsy, Vice President and General Counsel

• N. Wanoke, Assistant Vice President R. E. Querio, Byron Station Manager '

W. L. Duke, Administrative Services Director

• R. W. Stobert, Director of Quality Assurance (Operations)

T. Poppinga, Supervisor Personnel Development G. Parento, Company Attorney K. A. Ainger, Nuclear Licensing Administrator W. C. Roberts, Industrial Relations Manager R. G. Haley, MD, Senior Staff Physician N. J. Bresemann, Jr. , Senior Industrial Relations Advisor, Byron Station M. J. Wallace, Manager of Projects J. R. Fancher, Senior Staff Engineer, Quality Assurance K. Bartindale, Engineer, Administrative Services P. Laird, Director of Corporate Security G. L. Toleski, Nuclear Security Administrator J. L. Roulo, Administrative Assistant, Corporate Security

• D. Scott, Nuclear Stations Divisions - Staff At Byron Station Only: a R. Ward, Services Superintendent W. Burkamper, Quality Assurance Superintendent I M. Snow, Regulatory Assurance Superintendent G. K. Schwartz, Assistant Superintendent, Maintenance R. R. Lucas, Security Administrator A. S. Chernick, Training Supervisor

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The inspectors interviewed 11 CECO supervisors, 17 CECO nonsupervisory 5 employees, 5 contractor supervisors, and 18 contractor nonsupervisory i employees on site, counseling staff at the District Office, and personnel at the Sheriff's Office and at both testing laboratorie Entrance and Exit Meetings

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The inspectors met with licensee representatives at Ceco Headquarters on July 13, 1987 to summarize the scope of the inspection. On July 17, 1987, the inspectors met with licensee representatives at Ceco Headquarters, as indicated

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i above, to summarize the observations made during the inspectio l I Approach l

The inspection team compared the Ceco Fitness for Duty Program to each of the

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Key Program Elements recommended by the "EEI Guide to Effective Drug and

Denotes those present at exit briefing only

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Handling of drug or alcohol use among employees in designated positibns is not described; Ceco believes all employees should be treated the same and does not use designated positions, i.e., different standards for different categories of employee Testing for drugs is not specified when an employee is involved with drugs off duty and off company premises or as a condition for reten-tion. (The EEI Guide recommends that company policy specify testing for those in designated positions in this instance, however, Ceco does not use designated positions.) CECO practice is for the Staff Physician, in response to aberrant behavior reported by the stations, to determine if testing is appropriate for redical diagnosi Employees are advised, not required, to report legal use of con-trolled substances as prescribed by a licensed physicia Employees are not informed that appropriate measures will be taken to determine the scope of illegal involvement with drugs, i.e. to identify source of the drugs, and other employees who may be involve . Top Management Support The inspectors concluded that top management supports the FFD and EAP programs. Top managers are present at many meetings. They are able to discuss FFD with knowledge. Several employees reported that the Plant Manager is actively involved. The employees also reported that most contractor managers and supervisors do not actively support the policy, support it only when necessary, and then their actions are very reactive in natur Management enforcement of the policies was reported by those interviewed as being equitable and fair, however, several Ceco and contractor employees believed that the disciplinary discretions applied to Ceco employees should also be applied to contractor employees, including use of the EAP. Some believed that there should be a higher standard for those in sensitive position During interviews of CECO and Contractor supervisors and line employees, some additional comments of interest were provided:

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Management should provide on-site resources to resolve questions quickly and early on. An example would be the saliva test to deter-mine the presence of alcoho Contractor supervisors have handled problems outside the policie This was confirmed by Ceco managemen Contract supervisors and employees reported they were reluctant to report fellow contractor

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Alcohol / Fitness for Duty Policy Development," revised August 1985 (hereinafter referred to as the EEI Guide). The Ceco program was also compared to miscellaneous features contained in the EEI Guide. In addition, the team reviewed the CECO program for elements not specifically addressed in the EEI Guide which could be used to supplement.those recommended in the EEI Guide, including proactive measures to detect the presence of drugs on site. The format of the report reflects this approac Implementation of the EEI Guide Following are the inspectors' observations with respect to the implementation of each of.the Key Program Elements recommended by the EEI Guid . Written Policies i

CECO written policies are intended to be applied corporate wid Corporate management expects each nuclear site to implement a ten part

" Fitness for Duty" program conducted in accordance with the company's policy manual. Byron has not issued any written site policies or procedures to capture site specific conditions not covered by Ceco policies. CECO written policies differ from some of the features characterized in the Commission's Policy Statement or recommended by the EEI Guide, as follows:

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Immediate revocation of access to vital areas is not described, but is the practic Discharge is not specified for the sale, use, or possession of illegal drugs while on the job or on company property. Furthermore, discharge is not specified for the illegal sale of narcotics, drugs, or controlled substances when off duty and when off company premise CECO's policy says such acts are a dischargeable offense. Management considers the facts on a case by case basis when deciding what action to take. The practice is that temporary loss of unescorted access results pending management decisio Impairment is limited to being under the influence of alcoho Ceco believes that determining drug impairment cannot be accomplished at present state of art, therefore their policy should focus on use of drugs instead of impairmen Alcohol is not prohibited by Ceco policy from the protected area or from company property and operations, although possession or consumption is prohibited on the job. This does not prohibit the consumption of alcohol in parking lots, which was reported during interviews. It should be noted that signs posted alongside the site access road do prohibit alcohol among other thing :

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i employees for FFD infractions because contractors normally did not I have an EAP and such matters called for mandatory discharg Adequate funds, resources, and facilities appear to be availabl ! Effective Policy Communication The inspectors interviewed several Ceco and contractor employees and determined that while Ceco employees were quite knowledgeable of FFD, contractor employee knowledge was generally limited to, " Don't do drugs or you'll be fired."

CECO has communicated its FFD policy not only to their soployees, but also to their families by means of brochures and pamphlets sent to employees homes and distributed at work. Several meetings have been held that included fitness for duty tapes (some safety meetings included film or video tapes on the subject). Training sessions such as General Employee j Training (although the scope of FFD is somewhat limited during these training sessions) are given each yea Contractors are expected to communicate their policies (acceptable to CECO; most simply use CECO's policy) to their employees. Typically, con-tractor employees are asked to read the policy statement, receive the 4 General Employee Training, and may attend meetings and receive literature intended for Ceco employee . Behavioral Observation Training for Supervisors CECO is responsible for training CECO supervisors; Contractors are responsible for training their supervisor The quality of this trait,ing is very important because the success of CECO's program depends on the l ability of supervisors to detect changes in an employee's behavio CECO provides centralized training for all company supervisory parsonne Although not a written policy, CECO practice is to train all new supervisors 3 to 9 months after appointment. Retraining is planned for every two years. All CECO supervisors interviewed had been trained, were knowledgeable of the program, and understood their responsibilitie Contractor supervisors do not receive training from CECO or their j employer. Typically, " training" was limited to a reading of their company '

policy on FFD and receiving communications as described in paragraph above. None of the contractor supervisors interviewed had received Behavioral Observation or Policy 1 implementation Trainin This may be one of several factors contributing to several statements made by those interviewed that contractor supervisors handle problems outside CECO policie . Policy Implementation Training for Supervisors I

See paragraph D.4 abov ,

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• Union Briefing CECO Fitness for Duty (FFD) policy was reviewed in April 1982, and July 1984, with the System Council which is comprised of one member from each of the 17 individual unions of the International Brotherhood of Electrical Workers that Ceco has contracts with. In addition, during the development of the policy several discussions were held with the Chairman of the System Counci . Contractor Notification There is standard language inserted into every contract for work performed at Byron site informing the contractor of the Ceco Fitness for Duty (FFD)

program and requiring compliance with it. Contractors submit copies of their FFD program plans as part of their proposal. Ceco reviews these plans as part of the contracting process. During a review of an l allegation (No. RIII-86-A-0198) it was determined that Power Cutting, Inc.

I had not developed and submitted an " official" drug and alcohol policy to CECO, nor had such a program been implemented prior to the contractor being allowed on Ceco property. The situation was apparently overlooked by CECO, and follow-up by Ceco management was inadequate on a Ceco staff l inspection that originally identified the proble . Law Enforcement Liaison The Sheriff of Ogle County was interviewed about the licensee's liaison concerning FFD matters with his department. The Sheriff noted that his department has worked closely with the licensee's security department on a wide range of activities. Although the Sheriff has legal restriction l against divulging all infractions he may develop, publicly releasable information is available. The Sheriff does assist CECO in determining

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sources of drugs and identifying co-workers who may be involve CECO representatives stated that similar liaison has been established with other agencies having jurisdiction where Byron employees resid . Chemical Testing of Body Fluids Chemical tests of body fluids are used for reemployment screening of CECO employees and follow-up testing of CECO employees in the EAP. All people employed on-site are subject to testing for cause. The circumstances for requesting a test are not specifically described. Random or periodic tests are not conducted. Confirmatory tests are conducted on all presumptive positive screening tests. The testing for drugs is by urinalysis; the testing for alcohol (for cause only) is by bloo CECO does not test contractor employee Rather, CECO expects (but not in writing) that its contractors will test contractor employees before they are provided unescorted access to the site, or for any situation that establishes a cause for testin ,

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Many CECO. employees have never been tested because they were hired before'

the reemployment testing was initiated. The same is true for long term contractor employees. Although reemployment testing was initiated in June 1982, none of the 51 persons interviewed believed they had been so tested. (The test may have been part of a reemployment physical and no chain of custody established or notification of purpose of test provided -

both technical errors.)

All CECO employees being tested (for cause only) are automatically removed from duty pending results of the test. This includes those enrolled in the EAP who are receiving periodic unannounced follow-up tests, Collection of Sample Urine' samples are collected under direct observation of the medical staff to assure validity and prevent compromise of the sampl Control and Transfer of the Sample The urine sample is collected directly in a plastic container, sealed and initialed by the person providing the sample, placed into a mail-ing pouch, and mailed to the Chrometrics Laboratories, Inc. (CLI) in Park Ridge, 111. for the initial screening test. If the screening test is positive, CLI sends a portion of the sample to METPATH in Wood Dale, Ill. for confirmation testin Although chain of custody is established at the time the sample is collected, there may be some problems associated with the transfer from CLI to METPATH. Both laboratories are providing secure storage of samples in a freezer for one year. CECO is considering a 3 year retention by the laboratorie Testing of the Sample CLI uses an enzyme-multiplied immunoassay test (EMIT) for initial screening of urine. Established cutoffs are 20 nanograms per milliliter for THC, 75 for PCP and 300 for cocaine, amphetamines, barbiturates, narcotics, opiates, and methaqualone. Test results above the cutoff levels are considered presumptive positive, subject to confirmatio l l

All confirmation tests are by gas chromatography coupled with mass spectrometry (GC/MS). If the presence of the substance is confirmed in any quantity, the sample is reported as being tested positiv Reporting Results .

CLI promptly reports presumptive positive tests to CECO medical 4 staf The initial report of a presumptive positive is made by !

telephone to the CECO corporate medical staff in one to five days )

after the sample was collected. Results of confirmation tests are l 7 1 l

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received initially by telephone about one day after the sample was

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received by METPATH. The written report is usually received about I one week after HETPATH's telephone repor As noted above, CECO employees are automatically removed from duty pending results of the test. The medical staff, after considering all factors, may restore an employee to duty on the basis of a tele-phone report that the test was negative. If the initial screening test is a presumptive positive, the medical staff may decide to pursue the matter at that point and the employee may be asked to provide additional sampics, especially if the drug was THC. The employee may be referred to the EAP. In all cases, negative test results are required before an employee is permitted to return to his jo Should there be a confirmed positive test reported, CECO management will initiate administrative or disciplinary action on the basis of the telephone cal Employee Comments on Chemical Testing During interviews of Ceco and contractor supervisors and line employees, several comments were made concerning the testing program:

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Several supervisors and employees believe that random testing is an effective deterrent and should be implemente A few of those interviewed were concerned that routine tests would be give They believed testing should be limited to "for cause only."

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Many believed that efforts to enhance employee awareness of the testing procedures would eliminate fears of the technology and the accuracy of the testing, and thereby promote the progra Analysis of Statistics on Drug Testing The only statistics of drug testing that were provided pertain to replacement examinations. CECO has conducted a total of 4,851 reemployment tests from June 1982 through December 1985; 637 (1 percer,t) were positive. Of note is that when the cutoff limit for THC was dropped from 100 to 20 ng/ml on June 1, 1983, the percent positive rose from 9.8 percent to 15.5 percent. Ceco permits applicants who have tested positive on THC only to repeat the drug test within 10 day Since June 1982, 157 of the repeat tests were negative and 370 were positive; 110 did not take the test afte indicating that they woul Since 22 percent of applicants who had been accepted after passing the second drug test were found in trouble (i.e. , a disciplinary problem, drugs, fired, etc.) within two years, it was decided to stop the second test in June 1985. Those who had passed the second test before it was halted have been retained as Ceco employees, and are subject to the FFD polic _ _ _ _ _ _ - _ - _ - - _ _ _ _ _ _ . _ _ _ ._

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1 Employee Assistance Programs The EAP program has existed since 1979 and has achieved credibility with the employees. Contractor employees reported that two of the contractors on-site had an EAP program. The EAP program at Ceco provides all employees and their families with confidential professional assistance in

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I resolving personal problem The CECO employees interviewed were generally aware of the EAP, but did not appear to be familiar with its goals, how it worked, or how to avail themselves of its service Professional counseling services for the Byron Station are available at the division headquarters in Rockford and in Ceco's corporate office <

Corporate statistics indicate that the program has been utilized by 1,577 employees and dependents from 1979 through 1986, and another 151 from January 1 through March 31, 1987. These corporate wide statistics

. indicate that the program is well utilized by Ceco employees. The data shows that there were 114 self referrals in the Nuclear Division but only ;

43 supervisory referrals. Byron had 26 self referrals and 9 supervisory '

referrals out of 49 total EAP cases. CECO believes that the relatively low percentage of supervisory referrals are because many self referrals may be the result of supervisory pressure, or medical referrals as a result of behavioral observations referred to the Medical Department (24 of'1atter cases for the Nuclear Division). Of interest is that 120 of the 1,577 corporate wide cases were referred to EAP by family members. Two o these were by dependents of Byron employees, 18 by dependents of those employed in the Nuclear Division. This indicates that the EAP has achieved some credibility with dependents, an important feature of a j successful program, J The statistics appear to indicate that, generally, the EAP goal of early intervention is being achieved in most case Miscellaneous EEI Guide Features Following are the inspectors' observations with respect to miscellaneous ;

features of the EEI Guid '

, Substance Abuse Committee A Substance Abuse Committee has not been established, nor do key people fulfill committee functions on an ad hoc basi . Periodic Audits j

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Ceco conducted a special audit of the FFD programs at their six operating

. nuclear stations during the third quarter of 1986. The Ceco security staff conducts audits of the contractor FFD programs to ensure that employees are tested. No formal audit program has yet been develope )

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l The licensee's management has not yet determined whether Quality Assurance or Industrial Relations will do the audit and whether the audits will ,

include contractors. CECO management is considering the need to train '

their auditors or to obtain expertise to assist in the audi . Records and Reports Program records are kept, analyzed, and results reported to managemen '

As a result of this process, some significant changes to the program have been made:

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Direct observations of the collection of urine samples were reestablished for three divisions where the number of positives on reemployment testing was inconsistent with that reported elsewhere in the company (i.e., 6 - 10 percent as opposed to 33 - 47 percent with a company wide average of 22 percent). After direct observation was established, as CECO had expected in the first place, the statistics at those three divisions were consistent with the company wide experience. This appears to substantiate the need for direct observation of the collection of urin The second reemployment test was discontinued after 22 percent of accepted applicants were found to be in trouble (i.e., a disciplinary problem, drugs, fired, etc.) within two years of employmen One change caused a significant increase in the rate of positive tests and is therefore of interest: the number of positive reemployment tests rose from 9.8 percent to 15.5 percent after the cutoff limit for THC was dropped from 100 to 20 ng/m .

1 Supplemental Program Elements - Not in EEI Guide The NRC Policy Statement and EEI Guide describe a general approach to the design of fitness for duty programs. It is expected that each of the program elements contained in the EEI Guide will be addressed in licensee programs. In order to gain information on the use and effectiveness of additional practices which might be used by industry in developing an overall program, the inspectors also reviewed selected areas not included in the guidance. It is emphasized that the following description of areas reviewed is not an indication that such program elements are or may become requirement . Written Procedures Written procedures are intended to implement the policy, define actions to be taken in certain situations, and assign responsibilities to ensure '

proper accomplishment of the actions. Procedures would also reduce the likelihood that the actions would be mishandle '

Other than a few procedures or guidelines, written procedures have not been developed to implement the policy. Those that have been developed, 1 10

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generally, have not been issued as an authoritative documen Rather, (

they are typically in the form of training material I Professional Counseling Services l

Professional counseling services are intended to manage and carry out the program, and provide initial diagnosis of the problem and referral to the proper professional care. This would be particularly important in the diagnosis and treatment of substance abuse and emotional instabilit Professional counseling services are provided at the division headquarters ;

and at CECO headquarter . Employment Screening Practices Employment screening practices are intended to assure that employees are reliable and trus'. worthy and to eliminate from consideration those known to be unreliable, i.e., a drug abuser without evidence of rehabilitatio The practices would include background investigations, psychological tests, interviews, and periodic rescreenin With minor exceptions, reemployment screening practices appear to be con-sistent with the proposed industry guidelines for an access authorization progra Reemployment screening is conducted by each contractor in ac-cordance with the CECO " Personnel Security Screening Requirements for Access." Legal Reviews Legal reviews would assure that company policies and procedures, contracts, and union agreements meet constitutional and legal requirements with respect to fitness for dut Attorneys were involved in the development of the program and have reviewed it to ensure legal sufficienc Legal representatives have re-viewed the standard language inserted into all contracts relating to Fitness for Duty commitment . Proactive Measures to Detect the Presence of Drugs On-site

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These measures are intended to provide evidence of on-site drug problems before they would be manifested in observable aberrant behavior. These measures could also provide a deterrent on on-site drug abus Chemical Testing of Body Fluids Chemical testing of body fluids is a powerful tool for the detection and prevention of drug abuse. As applied by CECO, chemical testing does not provide a deterrent to drug abuse. See: paragraph D.9, above, for a detailed discussion of CECO's chemical testing progra '

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'. Searches Searches can be an effective means of discovering any alcohol or other drugs that may have been introduced into the workplac Searches can be an effective deterren There have been several searches of the workplace in the last few years; drug dogs were used during each of the searches. The deterrent effect of such efforts have been very positive, because almost without exception Ceco and contractor employees interviewed ,

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were aware of these searche Investigations Investigations are used to determine the facts associated with illegal involvement with drugs, and are an appropriate response to allegations and other investigative leads. Investigations are also useful in determining whether there is an existing or potential proble CECO Station Security Administrator investigates into the circumstances relating to an incident and coordinates other company efforts as necessar The Sheriff's office can be called in to provide expert assistance, Mechanism for Discreet Expression of Concerns A mechanism for discreet expressions of concern can facilitate unrestricted flow of information from those who, for many reasons, may be reluctant to provide important information to managemen There is no employee " hot line" provided. Most Ceco and contractor employees interviewed stated they would seek confidential assistance through their supervisor and seemed unaware of the posting of the EAP telephone numbe Information from Law Enforcement Authorities i

Law enforcement authorities may provide useful information concerning drug activity in the-local community, especially employee

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'O Law enforcement authorities provide information, within legal bounds, concerning off-site drug activity that may ultimately affect employee performance on the job. See paragraph F.5.c abov :

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