Information Notice 2005-18, Summary of Fitness-For-Duty Program Performance Reports for Calendar Years 2001, 2002 and 2003

Summary of Fitness-For-Duty Program Performance Reports for Calendar Years 2001, 2002 and 2003

ML051640539
Person / Time
Issue date:	07/15/2005
From:	Hiland P NRC/NRR/DIPM/IROB
To:
McCune, Timothy DNS ,415-6474
References
TAC MC7572 IN-05-018
Download: ML051640539 (29)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001 July 15, 2005 NRC INFORMATION NOTICE 2005-18: SUMMARY OF FITNESS-FOR-DUTY PROGRAM

PERFORMANCE REPORTS FOR CALENDAR

YEARS 2001, 2002 AND 2003

ADDRESSEES

All holders of 10 CFR Part 50 operating licenses for nuclear power reactors, except those who

have permanently ceased operation and have certified that the fuel has been permanently

removed from the reactor vessel.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to report

on lessons learned by licensees from their fitness-for-duty (FFD) program performance reports

for calendar years 2001, 2002 and 2003. It is expected that recipients of this IN will review the

information for applicability to their reactor facilities and consider, as appropriate, the corrective

actions taken to improve the future performance of their FFD programs. However, this IN

should not be construed as representing NRC requirements, and therefore no specific actions

or written responses are required.

DESCRIPTION OF CIRCUMSTANCES

As required by 10 CFR 26.71(d), NRC licensees have submitted their FFD program

performance reports to the NRC within 60 days of the end of each 6-month reporting period

(January - June and July - December). In the past, the NRC summarized and analyzed this

performance data and published an annual volume, NUREG/CR-5758, Fitness for Duty in the

Nuclear Power IndustryAnnual Summary of Program Performance Reports. The IN in

Attachment 1, provides similar FFD program performance data information for the years 2001,

2002 and 2003.

DISCUSSION

Lessons learned, management initiatives and problems, and the associated corrective actions

taken reported by licensees for the years 2001, 2002, and 2003 are summarized below.

(1) Certified Laboratories

Some licensees continue to experience problems with laboratory performance of

equipment malfunctioning and have also identified potential weaknesses in human error.

For example:

For the year 2001:

• One laboratory, determined that blind performance specimens caused test

discrepancies.

• In accordance with 10 CFR 26 Appendix A, paragraph 2.8, one licensee

submitted a letter to the NRC detailing the unsatisfactory performance of a

certified testing laboratory.

For the year 2002:

• One licensee reported that on February 16, 2002, a certified testing laboratory

reported an unsatisfactory positive blind performance urine test sample

containing amphetamine and methamphetamine. This event was investigated by

the laboratory and corrective action was taken. The event was reported to the

NRC as required by 10 CFR Part 26, Appendix A, Subpart 2.8(e)(4).

• One licensee reported an inaccurate laboratory result for a blind specimen that

was reported as negative. The cause of the inaccuracy was due to the sample

being inadvertently diluted. The licensee entered the inconsistency into the

corrective action program for evaluation and statistical trending.

For the year 2003:

• Two licensees reported a discrepancy in recording blind sample test results

because of a laboratory technicians human error in not following procedures.

The problem was corrected by revising the procedures.

• One licensee reported that a laboratorys courier van carrying samples of

specimen to the lab was stolen and the FFD specimen was lost. All samples of

specimen were recollected within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the notification and all samples

tested negative.

• One licensee reported a discrepancy with the blind sample specimens processed

because the laboratory equipment was not within quality control standards.

Corrective action was taken immediately.

• One licensee reported that a blind sample specimen for amphetamines that was

spiked was submitted to a certified laboratory, and the results reported were

negative. It was discovered that the age of the blind sample specimen caused

the level of the amphetamines to degrade below the required positive cutoff level. (2) Random Testing

Several licensees reported minor problems related to the random drug and alcohol

selection process.

For the year 2001:

• One licensee performed an audit and reported problems with the random drug

screening software in which several individuals were omitted from the drug

testing pool for three days. A root cause analysis revealed that the individuals

missing were not included in the file exported from the Security Database to the

random drug screening software from which individuals are selected for random

drug screening.

• One licensee reported that a contract employee tested positive for opiates

because that individual used a prescription drug prescribed to another person.

The employee was referred to the Employee Assistance Program (EAP) and was

denied access to the facility for 14 days. After reassessment, the case was

completed and it was determined the individual did not have a dependency issue.

The employee returned to work and was placed into the follow-up program.

• One licensee discovered deficiencies in the reporting software used to compile

the FFD report. The number of random tests reported for the period was found

to be in error.

• One licensee reported one false negative result for the blind performance

specimens. Notification was sent to the NRC of this unsatisfactory performance.

• One licensee reported that several workers had been improperly excluded from

the random drug testing pool for extended periods, because of software upgrade

interface problems.

For the year 2002:

• One licensee increased the random drug testing rate in order to enhance the

random drug sampling program. This was based on a study that was conducted

by a certified laboratory.

• One licensee identified a program weakness in its laboratory screening because

of an error concerning a low rate of For Cause tests. Corrective action was

taken to ensure that verification of the test results was properly completed prior

to a specimen being destroyed.

For the year 2003:

• One licensee reported that a software change affected the FFD tracking program

and caused several individuals to be excluded from the random drug test pool. (3) Policies and Procedures

Several licensees reported initiatives to improve their FFD program policies and

procedures.

For the year 2001:

• During a routine audit, one licensee found weaknesses in their FFD supervisor

training program. It was discovered that three supervisors did not requalify in

Supervisor FFD and Behavior Observation Programs as required within the

nominal 12 month period.

• One licensee implemented state-of-the-art equipment to enhance its FFD

process for measurement of specimen specific gravity. The results provided a

digital display versus a collectors visual determination of the specific gravity

reading.

• One licensee updated its FFD procedures to reflect revised wording in the chain- of-custody form.

• One licensee reported an event to the NRC in which there was a positive alcohol

test in the followup program due to refusal by a contractor supervisor to complete

the testing.

• One licensee reported that an employee, who tested positive for illegal drugs

during pre-employment testing was denied access to the protected area.

• One licensee reported that three confirmed positive results and two incidents of

adulterated samples were identified during pre-employment testing for the short- term contractor population. The licensee also reported in the For-Cause FFD

testing program for the long-term contractor population, one confirmed positive

sample was detected for two substances.

• One licensee tested three individuals For-Cause, after they reported a

substance abuse related arrest. Subsequently, they were referred to EAP for an

assessment.

• One licensee reported an adulterated sample for a contractor employee during

random testing, resulting in denial of unescorted access to the facility.

• One licensee eliminated its policy of administering a second breath alcohol test

when the first test is negative.

• One licensee reported two positive chemical test results. For the year 2002:

• One licensee reported that during a routine search for contraband via an x-ray

machine, Security personnel discovered a small-unopened bottle of alcohol in an

individuals computer case. Investigation revealed no intent to bring the alcohol

into the protected area. Security confiscated the item. The issue was placed into

the Corrective Action System.

• One licensee reported that a positive test result was not coded properly in the

database, causing the test result not to appear on the report of positives used to

compile statistics for the six-month performance summary report. The licensee

identified the error during the self-assessment period of the FFD program.

Corrective action was taken to revise the code in the database.

• One licensee reported that the contract FFD collector instructed a donor to

provide a smaller urine specimen than the 60 ml called for in 10 CFR Part 26.

However, the smaller specimen did not compromise the accuracy of the test

results.

• One licensee found a weakness in the FFD program, which gave an individual

unescorted access to the protected area without a drug and alcohol test being

completed. The licensee found that the access authorization staff did not

conduct a thorough review of the individuals access authorization file prior to

approval for unescorted access. Appropriate FFD personnel were given written

instruction as a reminder to thoroughly review all access files before granting

approval.

For the year 2003:

• One licensee reported the granting of unescorted access prior to receiving a

negative drug test screen result. This was the result of data entry human error.

The procedure was revised and corrective action was taken.

• One licensee reported a weakness in the notification process to employees

reporting for a FFD test. The procedures were revised and corrective action was

taken.

• One licensee reported that the blind specimens were not submitted in

accordance with 10 CFR Part 26 for two additional drugs. Corrective action was

taken to track the submission of blind samples to ensure that no drug is

excluded.

• One licensee reported nine incidents whereby contractors attempted to subvert

the random drug testing process through adulteration with a synthetic urine

product called Minuteman. These contractor personnel were denied

unescorted access to the protected area for failure to cooperate, falsification of

their chain-of-custody form, and in some cases falsification of their self-disclosure

questionnaire. * One licensee reported a deficiency in the FFD program meeting the reporting

requirements in 10 CFR 26.73 (a)(1) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee revised and

added more detail to their procedures.

• One licensee reported that an individual was randomly tested for FFD and their

blood alcohol content was found to be above the limit. The Medical Review

Officer (MRO) suggested that the individual be relieved of work duty and referred

to the EAP. The substance abuse professional in EAP did not find this

individuals alcohol consumption to be problematic. The individual returned to

work after the pre-access test was completed, and the results were negative.

(4) Program and System Management

In general, most licensees continue to report improvements in their overall FFD program

management.

For the year 2001:

• One licensee planned FFD supervisory training for incoming contractor personnel

during refueling and outage, and development of a common FFD program for its

nuclear sites.

• One licensees canine program continues to remind plant personnel of the

licensees commitment to maintain a drug-free work environment. The canine

unit provides anti-drug presentations to local schools and other community

organizations. The canine unit is also made available upon request to local law

enforcement agencies.

• One licensee re-emphasized during general employee training, the significance

of the sanctions associated with ingestion of hemp products and the

requirements. The instructor accentuates importance of FFD prior to entering the

workplace and not just in the protected area.

• One licensee planned to create an electronic link between the Access

Authorization, FFD, and Emergency Response Organization to improve

coordination and eliminate the potential communication errors.

• One licensee planned FFD supervisory training due to several supervisors

exceeding the site requalification requirement. Corrective actions were taken

(1) to develop a common FFD program for its nuclear sites, (2) increasing

efficiencies in the data gathering process and (3) provide clearer delineation of

short-term, long-term and licensee employees were made.

• One licensee reported administration of For-Cause testing resulting from a

security officer discovering an open container of alcohol in an employees

vehicle. The test results were negative. * To enhance the overall FFD program at the site, one licensee met with the

laboratory, collection site, MROs, EAP staff and psychological assessment

personnel to assure consistent and effective implementation of the FFD program.

The licensees canine program continues to remind plant personnel of the

licensees commitment to maintain a drug-free work environment.

For the year 2002:

• One licensee planned to merge two FFD programs and implement new

programmatic changes at their site.

• One licensee discovered during a self-assessment of the FFD program that the

blind submittal rate did not meet the 10 CFR Part 26 requirements. Corrective

actions were taken to evaluate the appropriate number of blind samples to be

submitted.

• One licensee reported that it initiated communications to re-emphasize the FFD

program requirements for overtime, in order to ensure fitness for duty suitability

prior to authorizing overtime hours.

• Two licensees made FFD program modifications to their procedures in order to

eliminate procedural inefficiencies and to maximize the efficiency of the FFD

program.

• One licensee updated its internal website to enhance the FFD program with user- friendly forms and guidance for supervisors.

• One licensee sent written notification regarding an operating experience of there

being gift baskets containing prohibited substance delivered to site. The licensee

provided FFD awareness information prohibiting alcohol on company property for

all site personnel.

• One licensee found that its employees were not familiar with the For-Cause

testing protocol and requirements. The licensee implemented corrective actions

by supplying additional information to the employees.

For the year 2003:

• Two licensees presented at a FFD workshop to industry peers and FFD staff

concerning the use of adulteration products such as synthetic urine.

• One licensee received notification from a pharmacy concerning a medication

called Protonix, that can cause a false positive urine screen test for marijuana

on a FFD test. All medical personnel reviewed the notification from the

pharmacy for future reference.

CONTACT

This information notice requires no specific action or written response. Please direct any

questions about this matter to the technical contact listed below.

/Mary Jane Ross-Lee for/

Patrick L. Hiland, Chief

Reactor Operations Branch

Division of Inspection Program Management

Office of Nuclear Reactor Regulation

Timothy McCune, NSIR

301-415-6474 E-mail: fitnessforduty@nrc.gov

Attachment: Fitness-for-Duty Statistics

Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

ML051640539 OFFICE NSIR/DNS/LPSS NSIR/DNS/LPSS NSIR/DNS/LPSS NSIR/DNS/NSPP NSIR/DNS

NAME CCollins TMcCune GWest VOrdaz DDorman

DATE 06/23/2005 06/24/2005 07/07/2005 07/11/2005 07/12/2005 OFFICE NRR/DIPM/IROB SC:OES:IROB:DIPM C:IROB:DIPM

NAME EBenner MJRoss-Lee PLHiland (MJRoss-Lee for)

DATE 07/13/2005 07/15/2005 07/15/2005

Attachment Table 1A

2001 Test Results For Each Test Category

2001 TEST CATEGORY NUMBER OF POSITIVE TESTS PERCENT POSITIVE

TESTS

Pre-Access 63,744 720 1.13%

Random 50,080 148 0.30%

For-Cause 730 101 13.84%

Followup 2,649 35 1.32%

Other 1,527 32 2.10%

TOTAL * 118,730 1,036 0.87%

TOTAL without 117,203 1,004 0.86%

OTHER Category

Table 1B

2002 Test Results For Each Test Category

2002 TEST CATEGORY NUMBER OF POSITIVE TESTS PERCENT POSITIVE

TESTS

Pre-Access 73,188 805 1.10%

Random 49,848 114 0.23%

For-Cause 1,072 112 10.45%

Followup 2,892 21 0.73%

Other 1,462 39 2.67%

TOTAL * 128,462 1,091 0.85%

TOTAL without 127,000 1,052 0.83%

OTHER Category

• These totals were calculated using the Other test category. This category includes results

from the periodic testing done by some reporting units during annual physicals or similar

periodic activities. Although some reporting units specified the nature of the Other tests (e.g.,

return to work), most reporting units did not give this information. Table 1C

2003 Test Results For Each Test Category

2003 TEST CATEGORY NUMBER OF POSITIVE TESTS PERCENT POSITIVE

TESTS

Pre-Access 72,988 757 1.04%

Random 49,402 132 0.27%

For-Cause 1,052 126 11.98%

Followup 3,142 42 1.34%

Other 1,201 37 3.08%

TOTAL * 127,785 1,094 0.86%

TOTAL without 126,584 1,057 0.84%

OTHER Category

• These totals were calculated using the Other test category. This category includes results

from the periodic testing done by some reporting units during annual physicals or similar

periodic activities. Although some reporting units specified the nature of the Other tests (e.g.,

return to work), most reporting units did not give this information. Table 2A

2001 Test Results For Each Test Category And Work Category

Test Category Licensee Long-Term Short-Term Total

Employees Contractors Contractors

Pre-Access

Number Tested 8,442 1,641 53,661 63,744 Number Positive 44 16 660 720

Percent Positive 0.52% 0.98% 1.23% 1.13%

Random

Number Tested 36,048 1,697 12,335 50,080

Number Positive 64 4 80 148 Percent Positive 0.18% 0.24% 0.65% 0.30%

For-Cause

Number Tested 326 33 371 730

Number Positive 20 2 79 101 Percent Positive 6.13% 6.06% 21.29% 13.84%

Followup

Number Tested 1,650 70 931 2,649 Number Positive 19 0 16 35 Percent Positive 1.15% 0.00% 1.72% 1.32%

Other

Number Tested 586 305 636 1,527 Number Positive 4 1 27 32 Percent Positive 0.68% 0.33% 4.25% 2.10%

TOTAL

Number Tested 47,052 3,744 67,298 118,730

Number Positive 151 23 835 1,036 Percent Positive 0.32% 0.61% 1.27% 0.87%

TOTAL without

OTHER Category

Number Tested 46,466 3,439 67,298 117,203 Number Positive 147 22 835 1,004 Percent Positive 0.32% 0.64% 1.24% 0.86% Table 2B

2002 Test Results For Each Test Category And Work Category

Test Category Licensee Long-Term Short-Term Total

Employees Contractors Contractors

Pre-Access

Number Tested 8,050 1,257 63,881 73,188 Number Positive 28 10 767 805 Percent Positive 0.35% 0.80% 1.20% 1.10%

Random

Number Tested 35,608 1,298 12,942 49,848 Number Positive 55 1 58 114 Percent Positive 0.15% 0.08% 0.45% 0.23%

For-Cause

Number Tested 458 22 592 1,072 Number Positive 23 1 88 112 Percent Positive 5.02% 4.55% 14.86% 10.45%

Followup

Number Tested 1,789 33 1,070 2,892 Number Positive 11 0 10 21 Percent Positive 0.61% 0.00% 0.93% 0.73%

Other

Number Tested 618 137 706 1,462 Number Positive 6 0 33 39 Percent Positive 0.97% 0.00% 4.67% 2.67%

TOTAL

Number Tested 46,524 2,747 79,191 128,462 Number Positive 123 12 956 1,091 Percent Positive 0.26% 0.44% 1.21% 0.85%

TOTAL without

OTHER Category

Number Tested 45,905 2,610 78,485 127,000

Number Positive 117 12 923 1,052 Percent Positive 0.26% 0.46% 1.18% 0.83% Table 2C

2003 Test Results For Each Test Category And Work Category

Test Category Licensee Long-Term Short-Term Total

Employees Contractors Contractors

Pre-Access

Number Tested 8,309 779 63,900 72,988 Number Positive 41 8 708 757 Percent Positive 0.49% 1.03% 1.11% 1.04%

Random

Number Tested 34,202 1,133 14,067 49,402 Number Positive 61 3 68 132 Percent Positive 0.18% 0.26% 0.48% 0.27%

For-Cause

Number Tested 439 29 584 1,052 Number Positive 23 0 103 126 Percent Positive 5.24% 0.00% 17.64% 11.98%

Followup

Number Tested 1,942 26 1,174 3,142 Number Positive 21 1 20 42 Percent Positive 1.08% 3.85% 1.70% 1.34%

Other

Number Tested 545 59 597 1,201 Number Positive 1 0 36 37 Percent Positive 0.18% 0.00% 6.03% 3.08%

TOTAL

Number Tested 45,437 2,026 80,322 127,785 Number Positive 147 12 935 1,094 Percent Positive 0.32% 0.59% 1.16% 0.86%

TOTAL without

OTHER Category

Number Tested 44,892 1,967 79,725 126,584 Number Positive 146 12 899 1,057 Percent Positive 0.33% 0.61% 1.13% 0.84% Table 3A

2001 Test Results By Test Category

TEST CATEGORY FIRST SECOND YEAR

SIX MONTHS SIX MONTHS

Pre-Access

Number Tested 33,857 29,887 63,744 Number Positive 407 313 720

Percent Positive 1.20% 1.05% 1.13%

Random

Number Tested 25,703 24,377 50,080

Number Positive 80 68 148 Percent Positive 0.31% 0.28% 0.30%

For-Cause

Observed Behavior

Number Tested 226 280 506 Number Positive 53 46 99 Percent Positive 23.45% 16.43% 19.57%

Post-Accident

Number Tested 116 108 224 Number Positive 2 0 2 Percent Positive 1.72% 0.00% 0.89%

Follow-Up

Number Tested 1,381 1,268 2,649 Number Positive 22 13 35 Percent Positive 1.59% 1.03% 1.32%

Other

Number Tested 823 705 1,527 Number Positive 22 10 32 Percent Positive 2.67% 1.42% 2.10%

TOTAL

Number Tested 62,106 56,624 118,730

Number Positive 586 450 1,036 Percent Positive 0.94% 0.79% 0.87%

TOTAL without

OTHER Category

Number Tested 61,283 55,920 117,203 Number Positive 564 440 1,004 Percent Positive 0.92% 0.79% 0.86% Table 3B

2002 Test Results By Test Category

TEST CATEGORY FIRST SECOND YEAR

SIX MONTHS SIX MONTHS

Pre-Access

Number Tested 39,277 33,911 73,188 Number Positive 484 321 805 Percent Positive 1.23% 0.95% 1.10%

Random

Number Tested 25,407 24,441 49,848 Number Positive 66 48 114 Percent Positive 0.26% 0.20% 0.23%

For-Cause

Observed Behavior

Number Tested 336 281 617 Number Positive 68 42 110

Percent Positive 20.24% 14.95% 17.83%

Post-Accident

Number Tested 191 264 455 Number Positive 2 0 2 Percent Positive 1.05% 0.00% 0.44%

Follow-Up

Number Tested 1,485 1,407 2,892 Number Positive 12 9 21 Percent Positive 0.81% 0.64% 0.73%

Other

Number Tested 835 627 1,462 Number Positive 23 16 39 Percent Positive 2.75% 2.55% 2.67%

TOTAL

Number Tested 67,531 60,931 128,462 Number Positive 655 436 1,091 Percent Positive 0.97% 0.72% 0.85%

TOTAL without

OTHER Category

Number Tested 66,696 60,304 127,000

Number Positive 632 420 1,052 Percent Positive 0.95% 0.70% 0.83% Table 3C

2003 Test Results By Test Category

TEST CATEGORY FIRST SECOND YEAR

SIX MONTHS SIX MONTHS

Pre-Access

Number Tested 37,996 34,992 72,988 Number Positive 433 324 757 Percent Positive 1.14% 0.93% 1.04%

Random

Number Tested 25,060 24,342 49,402 Number Positive 75 57 132 Percent Positive 0.03% 0.23% 0.27%

For-Cause

Observed Behavior

Number Tested 359 278 637 Number Positive 68 55 123 Percent Positive 18.94% 19.78% 19.31%

Post-Accident

Number Tested 227 188 415 Number Positive 3 0 3 Percent Positive 1.32% 0.00% 0.72%

Follow-Up

Number Tested 1,577 1,565 3,142 Number Positive 24 18 42 Percent Positive 1.32% 1.15% 1.34%

Other

Number Tested 680 521 1,201 Number Positive 18 19 37 Percent Positive 2.65% 3.65% 3.08%

TOTAL

Number Tested 65,899 61,886 127,785 Number Positive 621 473 1,094 Percent Positive 0.94% 0.76% 0.86%

TOTAL without

OTHER Category

Number Tested 65,219 61,365 126,584 Number Positive 603 454 1,057 Percent Positive 0.92% 0.74% 0.84% Table 4A

2001 Test Results For Licensee Employees And Contractor Personnel

LICENSEE LONG-TERM SHORT-TERM

EMPLOYEES CONTRACTORS CONTRACTORS

TEST FIRST SECOND FIRST SECOND FIRST SECOND

CATEGORY SIX SIX YEAR SIX SIX YEAR SIX SIX YEAR

MONTHS MONTHS MONTHS MONTHS MONTHS MONTHS

Pre-Access

Number Tested 4,453 3,989 8,422 941 700 1,641 28,463 25,198 53,661 Number Positive 24 20 44 13 3 16 370 290 660

Percent Positive 0.54% 0.50% 0.52% 1.08% 0.43% 0.98% 1.30% 1.15% 1.23%

Random

Number Tested 18,441 17,607 36,048 991 706 1,697 6,271 6,064 12,335 Number Positive 38 26 64 3 1 4 39 41 80

Percent Positive 0.21% 0.15% 0.18% 0.30% 0.14% 0.24% 0.62% 0.68% 0.65%

For-Cause

Observed Behavior

Number Tested 96 123 219 9 11 20 121 146 267 Number Positive 11 9 20 1 1 2 41 36 77 Percent Positive 11.46% 7.32% 9.13% 11.11% 9.09% 10.00% 33.88% 24.66% 28.84%

Post-Accident

Number Tested 59 48 107 7 6 13 50 54 104 Number Positive 0 0 0 0 0 0 2 0 2 Percent Positive 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 4.00% 0.00% 1.92%

Followup

Number Tested 790 860 1,650 34 34 68 557 374 931 Number Positive 10 9 19 0 0 0 12 4 16 Percent Positive 1.27% 1.05% 1.15% 0.00% 0.00% 0.00% 2.15% 1.07% 1.72%

Other

Number Tested 296 290 586 171 134 305 356 280 636 Number Positive 3 1 4 1 0 1 18 9 27 Percent Positive 1.01% 0.34% 0.68% 0.58% 0.00% 0.33% 5.06% 3.21% 4.25%

TOTAL

Number Tested 24,135 22,917 47,052 2,153 1,591 3,744 35,818 32,116 67,934 Number Positive 86 65 151 18 5 23 482 380 862 Percent Positive 0.36% 0.28% 0.32% 0.84% 0.31% 0.61% 1.35% 1.18% 1.27%

TOTAL without

OTHER Category

Number Tested 23,839 22,627 46,466 1,982 1,457 3,439 35,462 31,836 67,298 Number Positive 83 64 147 17 5 22 464 371 835 Percent Positive 0.35% 0.28% 0.32% 0.86% 0.34% 0.83% 1.31% 1.17% 1.24% Table 4B

2002 Test Results For Licensee Employees And Contractor Personnel

LICENSEE LONG-TERM SHORT-TERM

EMPLOYEES CONTRACTORS CONTRACTORS

TEST FIRST SECOND FIRST SECOND FIRST SECOND

CATEGORY SIX SIX YEAR SIX SIX YEAR SIX SIX YEAR

MONTHS MONTHS MONTHS MONTHS MONTHS MONTHS

Pre-Access

Number Tested 4,633 3,417 8,050 774 483 1,257 33,870 30,011 63,881 Number Positive 19 9 28 6 4 10 459 308 767 Percent Positive 0.41% 0.26% 0.35% 0.78% 0.83% 0.80% 1.36% 1.03% 1.20%

Random

Number Tested 18,106 17,502 35,608 681 617 1,298 6,620 6,322 12,942 Number Positive 28 27 55 1 0 1 37 21 58 Percent Positive 0.15% 0.15% 0.15% 0.15% 0.00% 0.08% 0.56% 0.33% 0.45%

For-Cause

Observed Behavior

Number Tested 138 105 243 6 2 8 192 174 366 Number Positive 12 11 23 1 0 1 55 31 86 Percent Positive 8.70% 10.48% 9.47% 16.67% 0.00% 12.56% 28.65% 17.82% 23.50%

Post-Accident

Number Tested 79 136 215 7 7 14 105 121 226 Number Positive 0 0 0 0 0 0 2 0 2 Percent Positive 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 1.90% 0.00% 0.88%

Followup

Number Tested 869 920 1,789 10 23 33 606 464 1,070

Number Positive 6 5 11 0 0 0 6 4 10

Percent Positive 0.69% 0.54% 0.61% 0.00% 0.00% 0.00% 0.99% 0.86% 0.93%

Other

Number Tested 328 291 619 110 27 137 397 309 706 Number Positive 3 3 6 0 0 0 20 13 33 Percent Positive 0.91% 1.03% 0.97% 0.00% 0.00% 0.00% 5.04% 4021% 4.67%

TOTAL

Number Tested 24,153 22,371 46,524 1,588 1,159 2,747 41,790 37,401 79,191 Number Positive 68 55 123 8 4 12 579 377 956 Percent Positive 0.28% 0.25% 0.26% 0.50% 0.35% 0.44% 1.39% 1.01% 1.21%

TOTAL without

OTHER Category

Number Tested 23,825 22,080 45,905 1,478 1,132 2,610 41,393 37,092 78,485 Number Positive 65 52 117 8 4 12 559 364 923 Percent Positive 0.27% 0.24% 0.25% 0.54% 0.35% 0.46% 1.35% 0.98% 1.18% Table 4C

2003 Test Results For Licensee Employees And Contractor Personnel

LICENSEE LONG-TERM SHORT-TERM

EMPLOYEES CONTRACTORS CONTRACTORS

TEST FIRST SECOND FIRST SECOND FIRST SECOND

CATEGORY SIX SIX YEAR SIX SIX YEAR SIX SIX YEAR

MONTHS MONTHS MONTHS MONTHS MONTHS MONTHS

Pre-Access

Number Tested 4,477 3,832 8,309 410 369 779 33,109 30,791 63,900

Number Positive 27 14 41 6 2 8 400 308 708 Percent Positive 0.60% 0.37% 0.49% 1.46% 0.54% 1.03% 1.21% 1.00% 1.11%

Random

Number Tested 17,236 16,966 34,202 592 541 1,133 7,232 6,835 14,067 Number Positive 35 26 61 1 2 3 39 29 68 Percent Positive 0.20% 0.15% 0.18% 0.17% 0.37% 0.26% 0.54% 0.42% 0.48%

For-Cause

Observed Behavior

Number Tested 124 108 232 6 6 12 229 164 393 Number Positive 13 9 22 0 0 0 55 46 101 Percent Positive 10.48% 8.33% 9.48% 0.00% 0.00% 0.00% 24.02% 28.05% 25.70%

Post-Accident

Number Tested 111 96 207 9 8 17 107 84 191 Number Positive 1 0 1 0 0 0 2 0 2 Percent Positive 0.90% 0.00% 0.48% 0.00% 0.00% 0.00% 1.87% 0.00% 1.05%

Followup

Number Tested 948 994 1,942 8 18 26 621 553 1,174 Number Positive 9 12 21 1 0 1 14 6 20

Percent Positive 0.95% 1.21% 1.08% 12.50% 0.00% 3.85% 2.25% 1.08% 1.70%

Other

Number Tested 273 272 545 30 29 59 377 220 597 Number Positive 0 1 1 0 0 0 18 18 36 Percent Positive 0.00% 0.37% 0.18% 0.00% 0.00% 0.00% 4.77% 8.18% 6.03%

TOTAL

Number Tested 23,169 22,268 45,437 1,055 971 2,026 41,675 38,647 80,322 Number Positive 85 62 147 8 4 12 528 407 935 Percent Positive 0.37% 0.28% 0.32% 0.76% 0.41% 0.59% 1.27% 1.05% 1.16%

TOTAL without

OTHER Category

Number Tested 22,896 21,996 44,892 1,025 942 1,967 41,298 38,427 79,725 Number Positive 85 61 146 8 4 12 510 389 899 Percent Positive 0.37% 0.28% 0.33% 0.78% 0.42% 0.61% 1.23% 1.01% 1.13% Table 5A

2001 Number Of Confirmed Positives By Substance

FIRST SECOND

SIX MONTHS SIX MONTHS TOTAL

TYPE OF

SUBSTANCE Number Percent Number Percent Number Percent

Marijuana 300 50.85% 219 50.85% 519 50.73%

Cocaine 121 20.51% 102 23.56% 223 21.80%

Opiates 7 1.19% 10 2.31% 17 1.66%

Amphetamines 35 5.93% 15 3.46% 50 4.89%

Phencyclidine 1 0.17% 1 0.23% 2 0.20%

Alcohol 126 21.36% 86 19.86% 212 20.72%

TOTAL 590 433 1,023 Table 5B

2002 Number Of Confirmed Positives By Substance

FIRST SECOND

SIX MONTHS SIX MONTHS TOTAL

TYPE OF

SUBSTANCE Number Percent Number Percent Number Percent

Marijuana 334 53.27% 228 51.01% 562 52.33%

Cocaine 126 20.10% 102 22.82% 228 21.23%

Opiates 14 2.23% 7 1.57% 21 1.96%

Amphetamines 29 4.63% 17 3.80% 46 4.28%

Phencyclidine 3 0.48% 0 0.00% 3 0.28%

Alcohol 121 19.30% 93 20.81% 214 19.93%

TOTAL 627 447 1,074 Table 5C

2003 Number Of Confirmed Positives By Substance

FIRST SECOND

SIX MONTHS SIX MONTHS TOTAL

TYPE OF

SUBSTANCE Number Percent Number Percent Number Percent

Marijuana 291 50.35% 231 50.22% 522 50.29%

Cocaine 130 22.49% 103 22.39% 233 22.45%

Opiates 10 1.73% 7 1.52% 17 1.64%

Amphetamines 32 5.54% 32 6.96% 64 6.17%

Phencyclidine 0 0.00% 0 0.00% 0 0.00%

Alcohol 115 19.90% 87 18.91% 202 19.46%

TOTAL 578 460 1,038 Table 6A

2001 Confirmed Positive Test Results By Substance And Work Category

LICENSEE CONTRACTORS

EMPLOYEES (Long-Term/Short-Term)

TYPE OF Number Percent Number Percent

SUBSTANCE

Marijuana 56 38.10% 463 52.85%

Cocaine 24 16.33% 199 22.72%

Opiates 0 0.00% 17 1.94%

Amphetamines 12 8.16% 38 4.34%

Phencyclidine 0 0.00% 2 0.23%

Alcohol 55 37.41% 157 17.92%

TOTAL 147 876 Table 6B

2002 Confirmed Positive Test Results By Substance And Work Category

LICENSEE CONTRACTORS

EMPLOYEES (Long-Term/Short-Term)

TYPE OF Number Percent Number Percent

SUBSTANCE

Marijuana 47 38.52% 515 54.10%

Cocaine 16 13.11% 212 22.27%

Opiates 1 0.82% 20 2.10%

Amphetamines 1 0.82% 45 4.73%

Phencyclidine 0 0.00% 3 0.32%

Alcohol 57 46.72% 157 16.49%

TOTAL 122 952 Table 6C

2003 Confirmed Positive Test Results By Substance And Work Category

LICENSEE CONTRACTORS

EMPLOYEES (Long-Term/Short-Term)

TYPE OF Number Percent Number Percent

SUBSTANCE

Marijuana 50 35.97% 472 52.50%

Cocaine 25 17.99% 208 23.14%

Opiates 5 3.60% 12 1.33%

Amphetamines 11 7.91% 53 5.90%

Phencyclidine 0 0.00% 0 0.00%

Alcohol 48 34.53% 154 17.13%

TOTAL 139 899 Table 7A

2001 Confirmed Positives Test Results By Substance For Each Worker Category

Licensee Employees Contractors

(Long-Term/Short-Term)

TYPE OF Number Percent Number Percent

SUBSTANCE

Marijuana 55 37.93% 468 52.94%

Cocaine 24 16.55% 201 22.74%

Opiates 0 0.00% 17 1.92%

Amphetamines 12 8.28% 38 4.30%

Phencyclidine 0 0.00% 2 0.23%

Alcohol 54 37.24% 158 17.87%

TOTAL* 145 884

• These numbers include tests results for the Other test category.

Table 7B

2002 Confirmed Positives Test Results By Substance For Each Worker Category

Licensee Employees Contractors

(Long-Term/Short-Term)

TYPE OF Number Percent Number Percent

SUBSTANCE

Marijuana 47 38.22% 515 54.10%

Cocaine 16 13.11% 212 22.27%

Opiates 1 0.82% 20 2.10%

Amphetamines 1 0.82% 45 4.73%

Phencyclidine 0 0.00% 3 0.32%

Alcohol 57 46.72% 157 16.49%

TOTAL* 122 952

• These numbers include tests results for the Other test category. Table 7C

2003 Confirmed Positives Test Results By Substance For Each Worker Category

Licensee Employees Contractors

(Long-Term/Short-Term)

TYPE OF Number Percent Number Percent

SUBSTANCE

Marijuana 50 36.97% 468 52.76%

Cocaine 25 17.99% 203 22.89%

Opiates 5 3.60% 12 1.35%

Amphetamines 11 7.91% 53 5.98%

Phencyclidine 0 0.00% 0 0.00%

Alcohol 48 34.53% 151 17.02%

TOTAL* 139 887

• These numbers include tests results for the Other test category. Table 8 - Significant Fitness-For-Duty Events (1990-2003)

Type of Event 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Total

Reactor Operators 19 16 18 8 7 8 8 9 5 5 5 4 3 6 121 Licensee Supervisors 26 18 22 25 11 16 19 16 10 2 11 9 3 3 191 Contract Supervisors 12 24 28 16 11 10 8 10 10 12 8 12 12 8 181 FFD Program 1 5 0 0 1 0 2 0 3 2 0 0 3 0 17 Personnel

Substances Found 6 8 6 2 0 5 5 4 0 2 3 0 1 2 44 Adulterated 9 9 Specimen

Total 64 69 74 51 30 39 42 39 28 23 27 25 22 28 563

• Reactor Operators- this category refers to licensee reactor operators and to any person licensed under 10 CFR Part 55. Table 9 - Trends in testing by test type (1990 - 2003)

Type of Test 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Total

Pre-Access

Number Tested 122,491 104,508 104,842 91,471 80,217 79,305 81,041 84,320 69,146 69,139 68,333 63,744 73,188 72,988 1,164,7

00

Number Positive 1,548 983 1,110 952 977 1,122 1,132 1,096 822 934 965 720 805 757 13,923 Percent Positive 1.26% 0.94% 1.06% 1.04% 1.22% 1.41% 1.40% 1.30% 1.19% 1.35% 1.41% 1.13% 1.10% 1.04% 1.20%

Random

Number Tested 148,743 153,818 156,730 146,605 78,391 66,791 62,307 60,829 56,969 54,457 51,955 50,080 49,848 49,402 1,186,8

18 Number Positive 550 510 461 341 223 180 202 172 157 140 204 148 114 132 3,534 Percent Positive 0.37% 0.33% 0.29% 0.23% 0.28% 0.27% 0.32% 0.28% 0.28% 0.26% 0.39% 0.30% 0.23% 0.27% 0.30%

For-Cause

Number Tested 732 727 696 751 758 763 848 722 720 736 883 730 1,072 1,052 11,190

Number Positive 214 167 178 163 122 139 138 149 100 120 138 101 112 126 1,967 Percent Positive 29.23% 22.97% 25.27% 21.70% 16.09% 18.22% 16.27% 20.64% 13.89% 16.30% 15.67% 13.84% 10.45% 11.98% 17.58%

Followup

Number Tested 2,633 3,544 4,283 4,139 3,875 3,262 3,262 3,296 2,863 3,008 2,861 2,649 2,892 3,142 45,709 Number Positive 65 62 69 56 50 35 40 31 43 30 49 35 21 42 628 Percent Positive 2.47% 1.75% 1.61% 1.35% 1.29% 1.07% 1.23% 0.94% 1.50% 1.00% 1.71% 1.32% 0.73% 1.34% 1.37%

TOTAL*

Number Tested 274,599 262,597 266,551 242,966 163,241 150,12 147,458 149,167 129,698 127,340 124,032 117,203 127,000 126,584 2,439,5

37 Number Positive 2,377 1,722 1,818 1,512 1,372 1,476 1,512 1,448 1,122 1,224 1,356 1,004 1,052 1,057 20,530

Percent Positive 0.87% 0.66% 0.68% 0.62% 0.84% 0.98% 1.03% 0.97% 0.87% 0.96% 1.09% 0.86% 0.83% 0.84% 0.82%

• Does not include test results from the Other test category. Table 10 - Trends in substances identified (1990-2003)

Substance 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Marijuana 1,153 746 953 781 739 819 868 842 606 672 620 523 562 518 Cocaine 706 549 470 369 344 374 352 336 269 273 251 225 228 228 Alcohol 452 401 427 357 251 265 281 262 212 230 211 212 214 199 Amphetamines 69 31 31 51 54 61 53 49 46 40 50 50 46 64 Opiates 45 24 8 13 11 17 14 39 19 16 32 17 21 17 Phencyclidine 8 11 4 5 1 7 2 0 1 2 1 2 3 0

Total* 2,433 1,762 1,893 1,576 1,400 1,543 1,570 1,528 1,153 1,233 1,168 1,029 1,074 1,026

• These totals do not equal the total number of positives for each year because some positives were for multiple substances and for other

substances than those listed above. Table 11 Trends In Positive Test Rates For Workers With Unescorted Access (1990 - 2003)

Year Positive Test Rate

1990 0.54%

1991 0.47%

1992 0.44%

1993 0.37%

1994 0.48%

1995 0.50%

1996 0.57%

1997 0.54%

1998 0.50%

1999 0.50%

2000 0.70%

2001 0.53%

2002 0.46%

2003 0.56%

• Includes random, for-cause, and follow-up testing results. The reduction in

random test rate from 100% to 50% has been in effect since 1994.