ML20034G597
| ML20034G597 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 03/01/1993 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9303100207 | |
| Download: ML20034G597 (19) | |
Text
8 PHILADELPHIA ELECTRIC COMPANY 10CFR26.71(d)
NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.
WAYNE, PA 19087-5691 (215) 640-6000 March 1, 1993 Docket Nos. 50-277 50-278 m -ra,
rustrMEE 50-352 s
50-353 License Nos. DPR-44 DPR-56 NPF-39 NPF-85 1
1 1i i
2 U.S. Nuclear Ret y
'n-i Attn:
Document Col.
'.o.
Washington, DC 20555 i
SUBJECT:
Peach Bottom 7.
tion, Units 2 and 3
+
Linetick Gener nits 1 and 2 l
Fitness-for-r u.
m '
2.
nance Data for 5I amber 1992 I
the PericC l
J.
Dear Sir:
1
}
As required by 10 CFR 26.
- letter submits the orogram for the period July j
performance data for our Fitne'.
r j
1992 through December 1992.
Th
{
'2r Peach Bottom Atomic
]
Power Station (PBAPS), Units 2 a.
erick Generating Station (LGS), Units 1 and 2, sites are ed in Attachments 1 and 2.
1 Data for our Corporate Office ant
,le. - Group Headquarters specimen collection sites (i.e., 2301 Ma
.e 3treet Philadelphia, PA and 955-l 65 Chesterbrook Boulevard, Wa,,
respeccively) are also provided j
in Attachment 3.
i The data are reported on the J.Tuary 1992 revision of the Fitness-for-Duty (FFD) Performance Data form provided by the Nuclear j
i Management and Resources Council (NUMARC), and include the following.
4
)
Drugs tested for and cut-off levels.
Workforce population tested.
Numbers of tests and results by population and type of test QgQ1 (i.e, pre-access, for-cause, random, follow-up, and other types of tests.) j Substances identified. j Attachments 1, 2, and 3 also include the following. 12 5 080112 Summary of management actions. 9303100207 930301 PDR ADOCK 05000277 R PDR.
PD U 2/3 & LGS U 1/2 March 1, 1993 FFD Performance Data for' Page 2 July 1992 - December 1992 Analysis of the data and appropriate actions that have been or will be taken. Random testing rate. During this period, there were two events which were reportable under 10 CFR 26.73. The details of the events are discussed in Attachments 1 and 2. If you have any questions or require additional information, please contact us. Very truly yours, ,f/f <c'f 0 % G. J. Beck, Manager ( Licensing Section Attachments cc: T. T. Martin, Administrator, Region I, USNRC w/ attachments J. J. Lyash, UENRC Senior Resident Inspector, PBAPS w/ attachments T. J. Kenny, USNRC Senior Resident Inspector, LGS w/ attachments C l 1
ATTACHMENT 1 Fitness for Duty Program ~ Performance Data Personnel Subject to 10CFR 26 \\ l Philadeltbia Electric Co=n=nY 0T/01/92 - w/V /o? a wes 1.L3 l co o r Peach Bottom Atomic Power Station 1:caim David M. Sarley (215)Shl-5T03 Comaet kame Facw M.4 aces :xej ~ ~ CutoMs: Screen /Confirrnation (ng/ml) O Appendi: Ato 10CFR,26 1.tarijuana 100 / 15 Amphetamines 1000 f 00 f Cocaine 300 # 150-Fhencyclidine 25 1 25 1 Opiates 300 / 300 Mcoholl% BAC) 0.oh 5 * / ~ 1 LorpTerm Shof.-Tt:ra . Testing Fiesells Ucensee Employees ContractorPersennel Cort:ar.crFe:sennti Average Number witt-2928
- 203h *
~ Unescorted Access 8 i t Categories Tested Pche Tested Positive Ter.ed P: @ e k 1098 12 Pre-Access Post accident 2 2 0 Observed behsvior 1 1 2
- 1 l
Random 638 2 - 6hl 1 ~ Fo!!cw-up 30 1** 1 Other 30 3 705 Total 4 17g7 yg
- Includes individuals with dual-site access at PBAPS and LGS.
o o* Test was conducted at LGS for Technical Assistant with limited REV.1/92 SRO license at PBAPS and LGS.
Pracu noTToM Atonic rLArrt 07/01/92 - 12/31/92 Brcnkdown of Confirmed Positive Tests for Specific Substances Ampho-Phoney. Rofusal Marijuana Cocaino Opiatos taminos clidino Alcohol to Tost 1 2 3 4 5 1 Licensoo Employees 2 Lon0-Torm Contractors A 2 3 Simrt-Torm Contractors 9 3 20 3 3 Total 9 5 9 0 e e e --****e-m een, ea 4 .n .-,----+n + a w-n m a ,________m
i Page 1 ATTACHMENT 1 Summary of Data Analysis and Management Actions Peach Bottom Atomic Power Station i July - December 1992 L l I. Initiatives Taken The following summarizes the results of sweeps conducted by Philadelphia Electric Company's (PECo's) drug sniffing canine teams at Peach Bottom Atomic Power Station (PBAPS) during this period. A. July 28, 1992 - General team search of vehicles entering the Protected Area. Results: Six activations. No drugs found or forensic samples taken. B. August 17, 1992 - For cause team search of a private vehicle. Results: Four activations. No drugs found or forensic samples taken. Investigation verified off-site drug abuse. Contractor's plant access denied. C. August 17, 1992 - For cause team search of private vehicle. Results: One activation. No drugs found or forensic samples taken. D. August 20, 1992 - For cause team search of a private vehicle. Results: Three activations. No drugs found or forensic samples l taken. Open bottle of whiskey discovered in the vehicle. Contractor's plant access denied. E. August 20, 1992 - For cause team search of a private vehicle. Results: Three activations. No drugs found or forensic samples taken. Investigation verified previous off-site drug abuse and current association with drug users. Contractor's plant access denied. F. August 21, 1992 - For cause team search of a private vehicle. Results: Two activations. No drugs found or forensic samples taken. G. August 27, 1992 - General team sweep of a private vehicle. Results: Two activations. No drugs found or forensic samples taken. H. August 27, 1992 - For cause team search of a private vehicle. Results: One activation. No drugs found or forensic samples taken. Investigation verified off-site association with drug j users. Individual placed on accelerated testing by PECo Medical. I. August 31, 1992 - For cause team search of a private vehicle. Results: Two activations. No drugs found or forensic samples taken. l
r l Page 2 J. August 31, 1992 - For cause team search of a private vehicle. i Results: Four activations. No drugs found or forensic samples taken. Investigation verified previous off-site drug abuse. l i Contractor's plant access denied. 4 K. September 16, 1992 - For cause team search of a private vehicle. Resnits: Two activations. During search of the vehicle, enspected marijuana was found in the ash tray. Laboratory analysis confirmed the substance to be marijuana. Contractor's 4 plant access denied. ] t L. October 28, 1992 - General team sweep of Health Physics Field [ Office. Results: Sixteen activations. No drugs found or forensic samples taken. M. December 22, 1992 - General team sweep of Instrumentation and Controls Shop Area. Results: Ten activations. No drugs found or forensic samples taken. l II. Management Actions During the period, three PECo employees tested positive at PBAPS. Two employees tested positive on random tests.- Both employees were provided treatment / rehabilitation through PECo's Employee Assistance i Program (EAP). Unescorted access has been reinstated for one of the a employees. The third employee tested positive as a result of a for-cause test that was ordered based on observed behavior. The employee j was provided treatment / rehabilitation through PECo's EAP. There was a fourth employee who tested positive as a result of a follow-up j test. The test was performed at LGS. This positive test result is j i also included in the PBAPS data since, the employee held Senior Reactor Operators (SRO) License limited to fuel handling at both PBAPS and Limerick Generating Station (LGS). During the period, fourteen contractor employees (i.e., twelve pre-access, one for-cause/ observed behavior, and one random) tested positive at PBAPS. Unescorted access has been denied for those contractor employees in accordance with PECo's Fitness-For-Duty (FFD) Specifications for Contractors. III. Events Reported Under 10CFR26.73 The following is a summary of events which were reportable under 10 4-CFR 26.73 for the period of July 1, 1992 through December 31, 1992. On August 5, 1992, a PBAPS Health Physics Shift Supervisor, had a Medical Review Officer (MRO) confirmed positive, random drug test for cocaine. The individual's security clearance was revoked.- The employee was sent to the corporate medical office for further evaluation and treatment. A review was conducted of the individual's previous work activities to ensure there were no unreviewed safety concerns. No safety concerns were identified as a result of this review.
Page 3 Subsequent to successful completion of a drug rehabilitation program, the individual's security clearance was reinstated and l the employee was permitted to return to work in a non-supervisory capacity on October 6, 1992. This individual is currently in the Fitness-for-Duty (FFD) Follow-Up Testing ) Program. On September 23, 1992, a Technical Assistant within the PECo Nuclear Group Headquarters who, at that time, held a SRO i License, limited to fuel handling for both PBAPS and LGS, had an MRO confirmed positive follow-up drug test for marijuana. The l follow-up test was conducted at LGS. However, the event is being reported for both PBAPS and LGS because the employee held i a dual license. The individual's security clearance was revoked. The employee was sent to the corporate medical office for further evaluation and treatment. A review was conducted of the individual's l previous work activities to ensure there were no unreviewed safety concerns. No safety concerns.were identified. The i details of this event were included in our letters to the NRC i dated October 5 and November 17, 1993. ] I Subsequent to successful completion of a drug rehabilitation program, the individual was permitted to return to work. He was not permitted to perform any safety related activities. The individual's security clearance continues to be revoked. This individual is currently in the FFD Follow-Up Testing Program. l IV. Nuclear Quality Assurance Audit ) j During the period, a performance based audit of the FFD program was completed to assess the program's implementation. i The auditors concluded that the FFD program adequately addresses the performance objectives of 10 CFR 26. The audit concluded that "since the last audit, a marked improvement was identified in the area of on-site collection and testing. The following strengths and weaknesses were identified. Strengths On-site testing facility Site Managers were well qualified and knowledgeable of testing procedures. Also, detailed, well maintained logs were available to document collection and testing activities. Collection site personnel were well trained and knowledgeable of their duties and responsibilities. The Laboratory Director and the HHS-certified laboratory was extremely knowledgeable in drug abuse problems and the drug testing process and protocols. i
f Page 4 i i The laboratory staff of the HHS-certified laboratory was knowledgeable of the regulatory requirements and was dedicated to strict observance of process procedures and manuals. The HHS-certified laboratory collection / chemical testing procedures were consistent with the requirements set forth by 10 C.'R 26 and PECo. MRO activities were well documented and readily retrievable j personnel. Marked improvement regarding on-site collection / testing implementation by PECo contracted personnel was identified. l The professionalism and expertise exhibited by PECo FFD staff } during the audit provided reasonable assurance of continued t compliance to 10 CFR 26 requirements. f Weaknesses Documentation deficiencies were noted in a for-cause test of a j courier. i Identification of FFD training deficiencies were not consistently provided to PECo employing officers and contractor management. Documentation of the transfer of three specimens collected at l Nuclear Group Headquarters was incomplete. l Medical Department copies of forms documenting suspension of unescorted access were not properly secured. Corrective actions have been implemented to resolve the weaknesses i which were identified. V. Random Testing Rate PECo conducts random testing at an annualized rate of 100%. While PECo maintains separate testing " pools" for employees and contractors, the " average number with unescorted access" includes personnel badged at both PBAPS and LGS. VI. Additional Information On July 1, 1992, barbiturates and benzodiazepines were deleted from the test panel based on a previously conducted review. The review identified that during the two-year period of 1989 and 1990, PECo conducted 22,958 drug tests. Of the 989 presumptive initial (i.e., EMIT) positives, 268 (i.e., 27%) were for barbiturates or benzodiazepines. Of those, only 14 were declared positive by the MRO (i.e., a positive rate of 0.06%). Based on this review, we have concluded that barbiturates and benzodiazepines are not an abuse problem within our workforce.
ATTACHMENT 2 Fitness for Duty Program Performance Data Personnel Subject t010CFR 26 07/01/92 - 12/31/92 Philadelphia Electric Conr;nny 8 kbr.r.:Ering Corr $ ey Limerick Generating Station i Loca:en (215) 8hl-5703 David M. Sarley Prew TMA rea exe) Contac Name Cutoff s: Scr e en/ Confirmation (ng/mt) Cl Appendix Ato 10CFR 26 lAarijuana 100 / 15 Amphetamines 1000 f 500 f / Cocaine 300 150-Phencyclidine 25 1 25 1 Opiates 300 / 300 Alcohol (% BAC) 0.0h % / Long-Term Short-Te m Testing Results Ucensee Empicyees Contractor Personnel Contractor Personnel Average Number wilt 203h
- Unesconed Access 2928 *-
Categories Tested Poshive Tes'ed Positive Tes'.ed Positive h11 5 33 1 Pre-Access 3 10 A Post accident 0 1 Observed behavior Random 505 38T 1 Fo!!ow-up 23 1 6 1 O'.her 7 Total 579 2 80T T i REV.1/92
- Includen individuals with dual-site access at PBAPS & LGS.
l'
_ 07/01/92 - 12/31/9f~ ~ - ~~~ Limerick Generating Station $renkdown of Confirmed Positive Tests for Specific Substances Ampho-Phoncy-Rofusal Marijuana Cocaino Optates taminos clidino Alcohol to Tost 1 2 3 4 5 LIconsoo Employees 1 1 Long-Yorm Contractors 3 1 Short-Torm Contractors 3 3 1 10 1 h h 1 Total 4 6 e 6 ..-.,.-..-m .. - -, - - - - -, -. - -,, - - - - ~,. - < - - -. =.. - - -. e Page 1 ATTACHMENT 2 l Summary of Data Analysis and Management Actions Limerick Generating Station i July - December 1992 I. Initiatives Taken l The following summarizes the results of sweeps conducted by i Philadelphia Electric Company's (PECo's) drug sniffing canine teams at Limerick Generating Station (LGS) during this period. A. July 24, 1992 - General team sweep of the Unit 2 Reactor Building, Main Control Room and Radwaste Control Room. Results: No activations. No drugs found or forensic samples taken. B. July 24, 1992 - For-cause team search of a private vehicle. Results: No activations. Investigations verified significant criminal record. Contractor's plant access denied. C. July 31, 1992 - For-cause team search of a private vehicle. Results: No activations. Employee is in the Fitness-for-Duty (FFD) Follow Up Program. D. August 14, 1992 - General team sweep of contractors' vehicles in parking lot. Results: One activation. Thirty-six milligrams of marijuana was discovered in a landscape contractor truck. l Employees routinely accessing this truck do not possess l unescorted access. Remedial action: Contractor ordered to provide additional training to their staff regarding PECo Drug / Alcohol Policy. E. September 14, 1992 - A general team sweep of the Spray Pond Pump House. Results: No activations. No drugs or forensic samples j taken. F. October 21, 1992 - For cause team search of a private vehicle. Results: No activations. Investigation confirmed employee attempted to pass a fraudulent prescription for a narcotic. Employee evaluated and suspended from work. G. November 30, 1992 - General team sweep of the contract Health Physics Support Building and the Second Floor of the Graham Leitch Building. Results: One activation. No drugs found or forensic samples taken. II. Management Actions During the period, two PECo employees (i.e., one follow-up, one pre-access) tested positive at LGS. Both employees were provided with treatment / rehabilitation through PECo's Employee Assistance Program (EAP). The pre-access test was conducted for a current PECo employee seeking unescorted nuclear access. Unescorted access has been denied for both employees. i I v
I i Page 2 i t In accordance with PECo's FFD Specification for Contractors, j unescorted access has been denied for seven (7) contractor employees j (five pre-access, one random, one follow-up) who tested positive i during the period. j i 1 I III. Events Reported Under 10CFR26.73 { The following is a summary of events which were reportable under 10 CFR 26.73 for the period of July 1, 1992 through December 31, 1992. On September 23, 1992 a Technical Assistant within the PECo Nuclear Group Headquarters who, at that time, held a Senior Resident Operators (SRO) License, limited to fuel handling for j 1, both Peach Bottom Atomic Power Station (PBAPS) and LGS, had an { j Medical Review Officer (MRO) confirmed positive follow-up drug j test for marijuana. The follow-up test was conducted at LGS. However, the event is being reported for both Peach Bottom l Atomic Power Station (PBAPS) and LGS because the employee held a [ dual license. The individual's security clearance was revoked.. The employee was sent to the corporate medical office for further evaluation I and treatment. A review.was conducted of the individual's previous work activities to ensure there were no unreviewed safety concerns. No safety concerns were identified. The details of this event were included in our letters to the NRC dated October 5 and November 17, 1993. i \\ Subsequent to successful completion of a drug rehabilitation program, the individual was permitted to return to work. He was l ] not permitted to perform any safety related activities. The j individual's security clearance continues to be revoked. This ) individual is currently in the FFD Follow-Up Testing Program. 1 IV. Nuclear Quality Assurance Audit During the period, a performance based audit of the Fitness-For-Duty program was completed to assess the program's implementation. The auditors concluded that the FFD program adequately addresses the l performance objectives of 10 CFR 26. The audit concluded that "since the last audit, a marked improvement was identified in the area of on-site collection and testing. The following strengths and weaknesses were identified. Strengths On-site facility Site Managers were well qualified and knowledgeable of testing procedures. Also, detailed, well maintained logs were available to document collection and testing activities. 1 .. - -. - - - -.. - ~. ~ -, - ..i
l l a i Page 3 j Collection site personnel were well trained and knowledgeable of their duties and responsibilities. i i The Laboratory Director of the HHS-certified laboratory was i j j! extremely knowledgeable in drug abuse problems and the drug l testing process and protocols. The laboratory staff of the HHS-certified laboratory was knowledgeable of the regulatory requirements and was dedicated to strict observance of process procedures and manuals. The HHS-certified laboratory collection / chemical testing j procedures were consistent with the requirements set forth by 10 CFR 26'and PECo. The MRO activities were well documented and readily retrievable. l 1 i Marked improvement regarding on-site collection / testing j implementation by PECo contracted personnel was identified. The professionalism and expertise exhibited by PECo FFD staff during the audit provided reasonable assurance of continued compliance to 10 CFR 26 requirements. l l Weaknesses ) Documentation deficiencies were noted in a for-cause test of a i courier. l i Identification of FFD training deficiencies were not { j consistently provided to PECo employing officers and contractor l 9 management. u Documentation of the transfer of three specimens collected at Nuclear Group Headquarters was incomplete. Medical Department copies of forms documenting suspension of j unescorted access were not properly secured. Corrective action' have been implemented to resolve the weaknesses which were identitled. a V. Random Testing Rate PECo conducts random testing at an annualized rate of 100%. While PECo maintains separate testing " pools" for employees and contractors, the " average number with unescorted access" includes personnel badges at both PBAPS and LGS. j i \\ l 1 i .n.. ,,... _..,. ~. _.,.,
j Page 4 VI. Additional Information On July 1, 1992, barbiturates and benzodiazepines were deleted from l the test panel based on a previously conducted review. The review identified that during the two-year period of 1989 and 1990, PECO conducted 22,958 drug tests. Of the 989 presumptive initial (i.e., EMIT) positives, 268 (i.e., 27%) were for barbiturates or benzodiazepines. Of those, only 14 were declared positive by the MRO (i.e., a positive rate of 0.06%). Based on this review, we have concluded that barbiturates and benzodiazepines are not an abuse problem within our workforce. l l f I
I ATTACHMENT 3 Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 Phihdelphia Electric Company 07/01/02 - 19/91/09 c m any a wei U.<-3 Corporate and Nuclear IIcadqual-ters Lccaion David M. Sarley (215) 8hl-5703 Contac1 hame Ptsv (rd.de a ea c=ce) Cutoffs: Screen /Confittnatio n (ng/ml) O Appendix A to 10CFR 26 Marijuana 100 / 15 Amphetamines 1000 f 500 f Cocaine 300 / 150-Phencyclidine 25 / p5 / Opiates 300 / 300 Alechol(% BAC) 0.0h y / Lorg-Term Shor!-Term Testing Results Licensee Employees Contractor Personnel Cen:racter Personnel Average Number witt Unescorted Access 2928
- 203h
- Categories Tested Pestive Tested Positive Tested PosRive Pre-Access 17 3
[ Post accident h 0 Obser.>ed behavior 2 j Random 330 1 37 Follow-up 12 1 Cf.her 11 Total 376 2 ho o,
- Includes individuals with dual-site access at PIMPS & LGS.
REV.1/92
Corporate and Wuclear IIcadquarters 0T/01/92 - 12/31/92 Breakdown of Confirmed Positive Tests for Specific Substances I Ampho-Phoncy-Rofusal Marijuana Cocaino Opiatos taminos clidino Ncohol to Tost 1 2 3 4 5 1 Uconsoo Employees 1 Long-Torm Contractors A Simst-Torm Contractors 2 1
- Total 1
I e 4 e e 9 9
\\ l Page 1 ATTACHMENT 3 Summary of Data Analysis and Management Actions Corporate and Nuclear Group Headquarters July - December 1992 1. Initiatives Taken The following summarizes the results of sweeps conducted by Philadelphia Electric Company's (PECo's) drug sniffing canine teams at Corporate and Nuclear Group Headquarters during this period. A. September 21,-1992 - General team sweep of Chesterbrook Building 965, Wing A, Third Floor. Results: No activations. No drugs found or forensics samples taken. l l B. December 15, 1992 - General team sweep of Chesterbrook Building 955, Wing B, Second Floor. Results: No activations. No drugs or forensic samples taken. II. Management Actions During the period,. two PECo employees tested positive. The first employee tested positive as a result of a follow-up test. Unescorted access was denied and employment was later terminated. The second r employee tested positive as the result of a random test. Unescorted access was denied. ) III. Events Reported Under 10CFR26.73 There were no events other than those reported for Peach Bottom Atomic Power Station (PBAPS) and Limerick Generating Station (LGS) i reported to the NRC under 10 CFR 26.73 during the period July 1, 1992 l through December 31, 1992. s IV. Nuclear Quality Assurance During the period, a performance based audit of the Fitness-For-Duty (FFD) program was completed to assess the program's implementation. l The auditors concluded that the FFD program adequately addresses the performance objectives of 10 CFR 26. The audit concluded that "since l the last audit, a marked improvement was identified in the area of on-site collection and testing. The following strengths and weaknesses were identified. Strengths On-site testing facility Site Managers were well qualified and knowledgeable of testing procedures. Also, detailed, well maintained logs were available to document collection and testing activities.
Page 2 Collection site personnel were well trained and knowledgeable of their duties and responsibilities, j The Laboratory. Director of the HHS-certified laboratory was extremely knowledgeable in drug abuse problems and the drug testing process and protocols. The laboratory staff of the HHS-certified laboratory was knowledgeable of the regulatory requirements and was dedicated to strict observance of process procedures and manuals. l The HHS-certified laboratory collection / chemical testing procedures-were consistent with the requirements set forth by 10 CFR 26 and PECo. Medical Review Officer (MRO) activities were well documented and readily retrievable. j Marked improvement regarding on-site collection / testing implementation by PECo contracted personnel was identified. j The professionalism and expertise exhibited by_PECo FFD staff during the audit provided reasonable assurance of continued compliance to 10 CFR 26 requirements. j i Weaknesses i Documentation deficiencies were noted in a for-cause test of a courier. Identification of FFD training deficiencies were not consistently provided to PECo employing officers and contractor i management. Documentation of the transfer of three specimens collected at the Nuclear Group Headquarters were incomplete. J l l Medical Department copies of forms documenting suspension of unescorted access were not properly secured. Corrective actions have been implemented to resolve the weaknesses which were identified. V. Random Testing Rate PECo conducts random testing at an annualized rate of 100%. While PECo maintains separate testing " pools" for employees and contractors,.the " average number with unescorted access" includes personnel badged at both PBAPS and LGS. I l i -.m I
- _ - =.. l .o I l Page 3 e i VI. Additionally Information On July 1, 1992, barbiturates and benzodiazepines were deleted from I the test panel based on a previously conducted review. The' review identified that during the two-year period of 1989 and 1990, PECo conducted 22,958 drug tests. Of the 989 presumptive initial (i.e., EMIT) positives, 268 (i.e., 27%) were for barbiturates or i benzodiazepines. Of those, only 14 were declared positive by the MRO i j (i.e., a positive rate of 0.06%). Based on this review, we have i concluded that barbiturates and benzodiazepines are not an abuse l problem within our workforce. i - i i I ) h i i t t i . i yv.,--- ,c.,. ,,,.,.-y. 3,, ,,-w ,-..w., y .,,,,.,,o,., ,w -}}