IR 05000237/1991017
| ML17174A785 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Braidwood, Zion, LaSalle  |
| Issue date: | 06/26/1991 |
| From: | Belanger J, Christoffer G, Creed J, Kniceley J, Madeda T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17174A784 | List: |
| References | |
| 50-237-91-17, 50-249-91-16, 50-295-91-13, 50-304-91-13, 50-373-91-12, 50-374-91-11, 50-456-91-16, 50-457-91-14, NUDOCS 9107110267 | |
| Download: ML17174A785 (14) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Repoit No. 50-456/91016(DRSS); 50-457/91014(DRSS)
50-237/91017(DRSS); 50-249/91016(DRSS)
50-373/91012(DRSS); 50-374/91011(DRSS)
50-295/91013(DRSS); 50-304/91013(DRSS)
Docket Nos. 50-456; 50-457 50-237; 50-249 50-373; 50-374 50-295; 50-304 licensee:
Commonwealth Edison Company Opus West III 1400 Opus Place Downers Grove, IL 60515 Licenses No. NPF-72; NPF-77 NPR-19; DPR-25 NPF-11; NPF-18 DPR-39; DPR-48 Inspection At:
Corporate Offices, Downers Grove, Illinois, June 11 and 13, 1991 Braidwood, Dresden, LaSalle and Zion Stations on June 12, 1991 Inspectors:
S. L ~~
J. l. Belanger Senior Physical Security Inspector
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./'if. M. Christoffer Physical Security Inspector q.~ fu~
J. R. KniceleYd Physical Security Inspector T. J. Madeda Physical Security Inspector Approved By:
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James R. Creed, Chief Safeguards Section 9107110267 910627 PDR ADOCK 05000237 Q
PDR Date f;/;J,(7/r/
Date Date Date
- Inspection Summary Inspection on June 11-13, 1991 (Report Nos. 50-456/91016(DRSS);
No. 50-457/91014(DRSS); No. 50-237/91017(DRSS); No. 50-249/91016(DRSS);
No. 50-373/91012(DRSS); No. 50-374/91011(DRSS); No. 50-295/91013(DRSS);
No. 50-304/91013(DRSS))
.
Scope:
This special, announced inspection reviewed the licensee's Fitness-for-Duty ( FFD) program required by 10 CFR Part 2 The review was conducted in accordance with Temporary Instruction (TI)2515/10 Specifically, the inspection included the licensee's drug and alcohol abuse policies and procedures; program administration; employee awareness and understanding of the program; selection and notification for random testing; documentation; sanctions and appeals; audits; specimen collection facilities and pnJcedures; training program; and reported FFD event Results:
Based on the selective examination of key elements of the licensee's Fitness-for-Duty.Program it was concluded that the licensee is satisfying the general performance objectives of 10 CFR 26.1 Several program strengths were identifie Program strengths included the strong management support for the program and the ample number of personnel resources devoted to the corporate and site Fitness-for-Duty staffs.
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- DETAILS Key Persons Contacted In addition to the persons listed below, the inspectors interviewed other licensee employees and contractor personnel *. The asterisk(*) denotes those present at the Exit Interview conducted on June 13, 1991 *.
P. Laird, Director Corporate Security, Commonwealth Edison Company (CECO)
- G. Toleski, Fitness for Duty (FFD) Program Administrator, CECO
- R. Haley, Medical Review Officer, CECO
- R. Van Ham, Industrial Relations Manager, Nuclear Operations, CECO D. LaBelle, Coordinator, Employee Assistance Services, CECO
- E. Pierard, Engineering and Construction, FFD Coordinator, CECO
- J. Zucchi, FFD Analyst, CECO
- P. Welsh, Assistant FFD Program Administrator, CECO
- M. Balster, Engineering and Construction, CECO
- F. Kanwischer, Services Director~Dresden, CECO
- A. Torrez, Assistant Security Administrator-Zion, CECO
- R. Barla, Assistant Security Administrator, LaSalle, CECO
- R. Mau, Assistant Security Administrator, Braidwood, CECO R. Brown, Station FFD Supervisor, Dresden, CECO
- S. Trubatch, Attorney, Sidley and Austin
- R. Kyrouac, Nuclear Quality Programs (NPQ) Supervisor, CECO J. Mayer, Dresden, Station Security Administrator, CECO M. Pluth, Employee Assistance Program Coordinator, Nuclear Station Division, CECO G. Diederich, LaSalle Station Manager, CECO J. Walkington, LaSalle Service Director, CECO R. Morley, Jr., LaSalle Station Security Administrator, CECO M. West, LaSalle Industrial Relations Supervisor, CECO
- R. Milne, Zion Station Security Administrator, CECO T. Broccolo, Zion Services Director, CECO S. Roth, Braidwood Station Security Administrator, CECO Entrance and Exit Interview At the beginning of the inspection, Mr. Pat Laird and other members of the licensee's staff were advised of the purpose of the visit and the functional areas to be inspecte The inspectors met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on June 13, 1991, and advised the representatives that the inspection had been a selective examination of their Fitness-for-Duty (FFD) program utilizing TI 2515/106 to determine whether it meets regulatory requirement Our review concluded that the FFD program had been adequately developed, implemented and monitored, and was meeting the general performance *
objectives of 10 CFR 26.10. Additionally, there was an ample number of knowledgeable personnel resources devoted to implementing the progra *-*
- The inspectors also pointed out that the Braidwood onsite testing facility, currently under construction, represents a notable program upgrad Inspection Approach (MC0610)
By letters dated April 3, 1991, the licensee was notified of the dates and scope of this inspectio They were requested to provide the latest revisions of the required FFD policies and procedures, which were reviewed in-office prior to the onsite inspectio The inspectors also reviewed the licensee 1 s semi-annual report of program performance data for the period ending May 31, 199 The results of the Resident Inspectors* evaluations of the initial training sessions conducted at the Braidwood, Dresden, LaSalle and Zion stations were also reviewe Onsite inspection activities included interviews of the key individuals responsible for program implemented and included, for example, the Medical Review Officer, the FFD Program Administrator, the Coordinator - Employee Assistance Program Services, and specimen collection personnel at the Braidwood, Dresden, LaSalle and Zion stations.. Additionally, approximately 6 randomly selected personnel, to include supervisors and non-supervisors, were interviewed at each of the four station The inspectors also conducted a tour of the onsite specimen collection facilities at each statio Record storage areas and protective measures at the licensee 1s corporate office were also reviewe Several audit reports, suitable inquiry files and other FFD related records were also reviewed by the inspector.
Written Policies and Procedures (TI 2515/106-05.0lC)
The licensee 1 s written policies and procedures were reviewed and compared to the requirements of 10 CFR Part 26 to assure that they were comprehensive and of sufficient clarity and detail to support the implementation of the progra The inspectors had the following observations:
A written comprehensive policy of Fitness-for-Duty was found in Nuclear Operations Policy (NOP)-OA.5 entitled 11Commonwealth Edison Fitness-for-Duty Policy 11 and Corporate Nuclear Security Guideline No. 200 entitled 11Commonwealth Edison Fitness for Duty Program.
A copy of the policy is distributed to each employee and contractor during General Employee Trainin Interviews with employees indicated that the policy was effectively communicated through trainin Written procedure~ were developed which adequately detail responsibilities for important aspects of the program involving, but not limited to, the treatment of presumptive positive tests, selection and notification of individuals for testing, collection and processing of specimens, and the medical review officer's review of tests and notificatio *
- Program Administration (TI 2515/106-05.02a):
No violations or unresolved items were identifie The overall program administration was effectively monitored with several strengths note The Fitness-for-Duty Program Administrator was extremely knowledgeable of program requirements, procedur~l guidance, and interdepartmental responsibilitie The FFD Program Administrator appeared to be an effective focal point to resolve FFD issues and established effective liaison with all nuclear stations and supporting department A high level of consistency in FFD program implementation existed between the corporate offices and the licensee 1 s nuclear stations. The assistant FFD Program Administrator also displayed an excellent knowledge of program requirements and function The program oversight and monitoring as described above by the FFD staff was considered a program strengt Program responsibilities are clearly described in the licensee 1s procedures and major FFD program functions have been appropriately assigne The FFD program is centralized at the Corporate office, under the Director of Securit The key FFD staff members have the necessary training and experience to fulfill their program responsibilitie Key members of the licensee 1 s FFD organization were interviewed by the inspectors and found to be very knowledgeable of their responsibilities. Licensee management support for the FFD program was eviden Corporate level managers and supervisors were assigned program responsibilitie One member of the corporate staff (the FFD Program Administrator) was assigned to perform overall program coordination and monitoring on a full-time basi The appeals Review Board consists of an impartial, internal management group appointed and chaired by the Senior Vice President for Nuclear Operations or his designe The MRO was interviewed by the inspectors on June 11, 199 He is a licensed physician tn the State of Illinoi He has been involved with the licensee 1 s*drug and alcohol program since its inception in 198 In 1990, he ~ttended the 11Medical Review Officer Training Course for Urine Drug Testing 11 sponsored by the American College of Occupational Medicin The MRO is a full time licensee employee and maintains an office adjacent to the FFD Program Administrato The MRO is responsible for determining confirmatory drug test results at or above the cut-off level as positive or negative by evaluation of the disclosures on the consent form, review of medical history of the person tested, verification of prescriptions, and communications with the person teste This determination is accomplished within 10 days of completion of the initial presumptive positive tes The MRO stated that his evaluation included a review of chain-of-custody documentation.
- Worker Awareness (TI 2515/106-05.02c):
The inspectors interviewed a total of 24 randomly selected persons, including supervisors, and licensee and contractor employees, 6 at each sit The personnel interviewed generally believed that the FFD selection process for testing was random in nature, in that supervisors could be selected for testing just as frequently as nonsupervisors and that contractors are tested as frequently as company employee No "Safe periods" for drug abuse were identified in that the personnel believed that random testing could be conducted at any time to include backshifts, weekends, and holiday The licensee personnel interviewed were familiar with the EAP services available to them and believed such services would be provided in a confidential manne Contractor personnel interviewed indicated that they were aware of the Commonwealth Edison company 11Get Well Program" provided to individuals who are denied access for a violation cf the FFD progra Completion of the program could provide them an opportunity to have their eligibility for unescorted access restore.
Program Elements (TI 2515/106-05.02c): Selection and Notification for Random Testing The FFD Program Administrator and site FFD security personnel control the random drug and alcohol testing using procedures identified in the Corporate Nuclear Securities Guideline Random testing is conducted at an annual rate equal to at least 100% of all individuals with unescorted access to the protected area and EOF responder The list of individuals with unescorted access is continuously update Personnel are selected in a statistically random manner so that all personnel eligible for testing have an equal probability of being selected. A person completing a random test is immediately eligible for another random tes The percent of workers selected each week from each established pool is sufficient to obtain an average of 2% per week per poo Testing is administered on at least a weekly frequency and at various times during the day with limits and conditions on the time allowed for personnel to report to the collection sit Interviews with FFD personnel disclosed that all personnel in the random selection pools are subject to the same testing criteria regardless of frequency of access to the sit Perceptions of safe periods are countered by testing periodically on backshifts, weekends and holiday The FFD Program Administrator is responsible for notifying specimen collection personnel and FFD site personnel of the test dates, places, and times in advance of test date On test dates, supervisors are contacted with names and times of personnel to be teste Workers are notified by their supervisor that they have been selected for testing as close as possible to the actual collection tim Personnel failing to report to the collection site at their scheduled time are reported to the FFD coordinator and their immediate superviso *
Random Selection Reports (RSRs) are produced at printer terminals that are ~ontrolled locations and access to the selection reports is limited to FFD staff personne The licensee maintains confidentiality of these reports until all testing of personnel on the report has been completed or properly excused from testing based on established criteria. Worker scheduled test dates are completed the day of the selettion and workers are not advised of their selection for testing until a few hours before their testing tim Random Selection Reports (RSRs) may be generated on various days of a week and may also be generated two or more times within a wee The licensee has contracted with CSM Mobile, Ltd. for collection and testing service CSM Mobile, Ltd. is located in Lisle, Illinoi The licensee uses Bio-Analytical Technologies, Chicago, Illinois, as their Health and Human Service~ (HHS) certified laborator The licensee's testing cutoff levels are the same as those listed in 10 CFR P~rt 26, Appendix A, except for marijuana metabolites for which their test level is 50 ng/ml for the initial sample, which is more conservative than the Regulation The confirmed test is the same as identified in the regulatio Documentation The licensee has developed adequate systems for documenting the key elements of the FFD program and for assuring the protection of information. The licensee's policy fer limiting access to information to those with a clear need-to-know is identified in Corporate Nuclear Security Guidelines. Selection lists, chain-of-custody forms, tests results, the permanent log, and individual FFD files are carefully protected. The design of the various records is adequate to assure that all relevant information is collected and can be retrieved when neede An inspection of a sample of the records showed them to be legible and complet Physical security for the records is adequat Files are kept in locked cabinets. The FFD program personnel were knowledgeable concerning the data storage requirements outlined in the rul Sanctions and Appeals The licensee's Policy and FFD Procedures are consistent with required actions identified in 10 CFR 2 These procedures indicate that the first confirmed positive drug test results in denial of unescorted protected area access for a minimum of 14 days and referral to the Employee Assistance Program (EAP).
Any subsequent confirmed positive test results in denial of access for three year Any individual involved in the sale, use or possession of illegal drugs within the protected area will result in the person's denial of access for five years.
The rule does not identify sanctions for abuse of alcohol, valid prescriptions or over-the-counter drug However, impaired workers
- are removed from work activities, their access authorization is denied, and mandatory medical review and/or rehabilitation is required prior to reinstatemen Shou1d a person be retained after an initial FFD policy violation, sanctions imposed are in accordance with the rul Licensee Employee Assistance Program referral is not provided to contractor personnel, so their drug or alcohol abuse normally results in deni a 1 of unescorted access and referral' to their employer for whatever actions the employer deems appropriat The licensee does provide contractors a 11get well program" to allow individuals who are denied access for violation of the FFD program an opportunity to have their eligibility for unescorted access restore The specific 11get well" requirements are deterrnined on a case-by-case basis as the individual requests participation in the progra The requirements of the program cover m1n1mum non-eligibility period, rehabilitation program, and follow-up test requirement The licensee's appeal process for a positive alcohol or drug determination has been established in procedures and meets or exceeds r~le requirement The MRO notifies the individual of a confirmed positive test results and offers an opportunity to discuss the results prior to notifying the FFD Administrato The individual is given the opportunity to request that the reserve sample be screened and confirmed by the laboratory.
The licensee has established a Review Board comprised principally of senior management and medical personnel.* The Review Board is responsible for overseeing the appeal determinations made by the Director of Corporate Security. At least three CECo management representatives must be present for the Review Board to conduct business and will meet as often as necessary to decide appeals and petitions in a timely manne The inspectors determined that this appeal process with senior management participation and oversight is a program strengt Audits The annual audit required by 10 CFR.26.80 was conducted under contract by Bensinger, DuPont and Associates (BOA) between February 22 and March 13, 199 Dr. Jerry Leiken of Rush Presbyterian St. Luke's Medical Center participated on May 11, 199 Bensinger, DuPont and Associates audited the overall program, focusing on company policy, implementing p~ocedures and FFD training of licensee and contractor employee Dr. Leiken audited on-site specimen collection and testing and audited laboratory activities at Bio-Analytical Technologie In addition to the annual audit, the licensee's Quality Assurance department has performed some administrative and implementation surveillances of the FFD implementation practice The auditors concluded that the Commonwealth Edison Company FFD program meets or exceeds the requirements outlined in 10 CFR 26 including Appendix * The inspectors concluded that the licensee's audits were thorough and were successful in identifying and correcting weaknesses in their FFD progra Specimen Collection Facility (TI 2515/106-05.02dl On June 12, 1991, the inspectors conducted a tour of the specimen collection facilities at Braidwood, Dresden, LaSalle and Zion Station The facilities at Braidwood, Dresden and Zion Stations consisted of converted trailer The facility at LaSalle consisted of a mobile va These facilities were adequate in meeting the needs of a collection locatio The permanent on site collection facility at Braidwood should be functional at the end of June 199 The facilities are routinely locked when not in use and*access to the facilities is recorde~ on a lo Keys to the facilities are controlled and access to them is limited to personne1 with FFD related responsibilities. Adequate security measures were observe Effective measures were implemented to prevent subversion of specimen Blueing agent was used in the toilet facility, and the sink area used for hand washing was easily visible to the personnel performing the specimen collection proces Administrative forms such as chain~of-custody forms and the Permanent Record Book were readily available. Additionally, a locked contai~er was available in the specimen collection facility to store collected specimen The inspect6rs interviewed the collection personnel during a ~alk-through of the specimen collection proces The collection personnel were knowledgeable of their dutie Personnel were sensitive to the need to prevent potential tampering with the specimen, and the need to conduct the collection in a professional manner that assures the modesty and privacy of the individual being teste Interviews with the FFD Program Administrator confirmed that the specimen collection personnel for all sites had background investigations completed using the criteria for unescorted access authorizatio The inspectors reviewed approximately 10 randomly selected personnel records for site and corporate collection personnel and found them to be accurate and complet.
Training Program (TI 2515/106-05.0la)
The licensee's awareness training conducted prior to the January 3, 1990 effective date of the Rule was reviewed by the Resident Inspectors and evaluated using TI 2515/10 The training was found to be acceptabl During this inspection, a limited sampling of employees and contractors were interviewed and found to be knowledgeable of the FFD Program and their individual responsibilitie The FFD training program is
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administered by the licensee's training department. Also noted was the fact that the EAP Services Coordinator has instructed portions of the training program for the purpose of fostering a better understanding and acceptance of the EAP service The inspectors reviewed a selected small sample of records to assure that individuals with access to the protected area had received FFD training, and that supervisors had received continuous observation training. It was also determined that a system is in place to identify when refresher training is neede All workers interviewed appeared to be generally supportive of the FFD program and its goal They appeared to have a high level of ccrrfid2nce in the integrity of the onsite collection and testing process and the FFD personne The licensee maintains an Employee Assistance Program (EAP) that is available to all Commonwealth Edison (CECo) employee Employees are encouraged to use the EAP as needed. A review of usage statistics indicates that employees do make use of the EA They appeared confident that their confidentiality would be maintaine Interviews with plant staff indicated both a willingness to use the EAP and a willingness to refer others to the EA The licensee has-had an EAP program since 197.
Reported FFD Events (TI 2515/106-05.0la) Braidwood Events Reported:
A random test conducted on January 29, 1990, resulted in a confirmed positive test for a licensee supervisor. Unescorted access was denied immediately. This event was reported to USNRC Headquarters on January 30, 199 Management determined this individual did not direct or perform safety related or licensed activities. After EAP Counseling and evaluation, unescorted access was reinstated, no treatment was recommende The sanctions imposed were in accordance with the licensee's FFD policy and 10 CFR Part 2 Dresden Events Reported Non LaSalle Events Reported (1)
(2)
A random test conducted on January 12, 1990, resulted in a confirmed positive test for a contractor superviso Unescorted access was denied and this event was reported to the NR A work performance evaluation disclosed that this individual did not work on any safety related equipmen On April 17, 1991, a random drug test resulted in the identification of a Licensed Operator with a confirmed positive for cocain On April 23, 1991, Region III informed the
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licensee of an allegation that Control Room Operators use cocaine and could ctrcumvent the Drug Testing Progra The licensee conducted an investigation into the allegation and determined that random drug tests are being conducted on the control room operators and that station -employees are not-aware when testing will be conducted. There was no evidence developq that control room operators use illegal drugs and have knowledge when random testing will be don The sanctions imposed on the licensed operator who tested positive were in accordance with the licensees FFD policy and 10 CFR Part 2 The event was adequately reported to the NR While investigating the above allegation, a random drug test identified a nuclear station supervisory employee, who tested positive for an illegal substance and violated their FFD policy. Unescorted access was denied and this event was reported to the NR The sanctions imposed were in accordance with the licensee's FFD policy and 10 CFR Part 2 In each of the reported events, the licensee conducted a work investigation and concluded that all safety related work performed by the individuals did not disclose any performance concern Zion Events Reported (1)
A random test of a. contractor supervisor conducted on May 1, 1990, resulted in a positive test determinatio Unescorted access was denied on May 8, 1990, and the event was also reported to the USNRC Headquarters on this date. A work performance investigation concluded that this individual was not engaged in safety related activities~
(2)
On March 19, 1990, a random test produced a positive test result for a licensee superviso Unescorted access was denied on March 26, 1990,*upon confirmation of the positive test resul USNRC He~dquarters was notified on March 26 199 An investigation disclosed no work performanc~ concern EAP Rehabilitation ~equirements were completed and unescorted access was reinstated with the provision of unannounced follow-up testin An unannounced follow-up test of this Licensee supervisor conducted on July 30, 1990, resulted in a confirmed positive test resul USNRC Headquarters was notified on August 3, 199 An investigation disclosed no work performance concerns. This was the second FFD violation for this individual and resulted in permanent revocation of unescorted access on August 3, 199 (3)
On February 10, 1991 a controlled substance was found in the protected are The licensee denied unescorted access to two individuals for failure to cooperate and lack of truthfulnes USNRC Headquarters was notified on February 11, 1991. * The licensee's investigation report of this incident is currently being evaluated by Region II.,
Program Performance Data Braidwood For the period July 1, through December 31, 1990, 409 random tests were conducted on licensee employee This number combined with 429 similar tests conducted during the first reporting period totaled 838 and produced a random annual test rate of 103% of an average 813 station assigned licensee employees with unescorted acces For the second reporting period 1990, 250 random tests were conducted on contractor employees. This number combined with 405 similar tests conducted during the first period totaled 655 end produced a random annual test rate of 108% of an average 607 station assigned contractors with unescorted acces In 1991 for the period of January 1, 1991 through May 31, 1991, the licensee has conducted 384 random tests for licensee employees and 380 tests for contractor employee Thirty six positive tests for the reporting period ending *June 30, 1990 and the one for th reporting period ending December 31, 1990 resulted in either denial or revocation of the individuals'
unescorted acces Additionally, in the period ending June 3G, 1990 two revocations of unescorted access resulted after two individuals refused to participate in "For Cause" testing as a result of behavioral observatio For the period of January 1, 1991 to May 31, 1991, Braidwood had twenty positive tests that resulted in either denial or revocation of the individual's unescorted acces Dresden c.
Dresden Station, for the period January 3, 1990 to December 31, 1990, 1088 random tests were conducted on station assigned licensee workforce pool averaging 1046 employee This resuited in a random test rate of 104 percent for 199 For the same period 765 random tests were conducted in a contractor workforce pool averaging 728 employees. This resulted in a random test rate of 105 percent for the year 1990. Thirty eight positive tests resulted in either denial or revocation of the individual's unescorted acces For the period January 1, 1991 to May 31, 1991, 494 random tests WP.re conducted on station assigned licensee personnel pool averaging 1069 employee This resulted in a random test rate of 47 percen Sixteen positive tests resulted in denial or revocation of individual's unescorted access for the first five months of 199 LaSa 11 e For the period July 1, 1990 through December 31, 1990, 439 random tests were conducted on licensee employee This number combined with 490 similar tests conducted during the first reporting period
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totaled 929 and produced a random annual test rate of 102% of an average 914 station assigned licensee employees with unescorted acces For the second reporting period 1990, 286 random tests were conducted on contractor employee This number, combined with 468 similar tests conducted during the first period, totaled 754 and produced a random annual tes~ rate of 103% of an average 731 station assigned contractors with unescorted acces Each of the 33 positive tests resulted in either denial or revocation of the individuals unescorted acces For the period January 1, 1991 through May 31, 1991, 964 random tests were conducted on licensee and contractor personne Each of the 18 positive tests resulted in either denial or revocation of the individuals unescorted acces The licensee 1 s testi~g rate and reports appear adequate to meet the requirements of 10 CFR Part 2 Zion For the period July 1, 1990 through December 31, 1990, 423 random tests were conducted on licensee employee This number combined
~ith 532 similar tests conducted during the first reporting period totaled 955 and produced a random annual test rate of 112% of an average 853 station assigned licensee employees with unescorted acces For the second reporting period 1990, 389 random tests were conducted on contractor employee This number combined with 574 similar tests conducted during the. first period totaled 963 and produced a random annual test rate of 115% of an average 840 station assigned contractors with unescorted acces In 1991 for the period of January 1, 1991 through May 31, 1991, the licensee has conducted 415 random tests for licensee employees and 410 tests for contractor employee The licensee is 39 tests short of the number needed to achieve the yearly quota for mid-yea Sixty positive tests for the reporting period ending June 30, 1990 and 11 for the reporting period ending December 31, 1991 resulted in either denial or revocation of the individual 1 s unescorted acces Additionally, the in period ending June 30, 1990, one revocation of unescorted access resulted when an individual refused to participate in 11 For Cause 11 testing required due to behavioral observation Also, unescorted access was denied when an individual failed to report for a test required to receipt of a dilute specimen on a previous tes **
For the period of January 1, 1991 to May 31, 1991, Zion had 13 positive tests that resulted in either denial or revocation of the individual 1 s unescorted acces