ML20077R270

Rev 2 to Calvert Cliffs Nuclear Power Plant Fitness-for-Duty Manual

ML20077R270
Person / Time
Site:	Calvert Cliffs
Issue date:	08/31/1991
From:	Creel G, Files J BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20077R268	List: ML20077R266 ML20077R270
References
PROC-910831, NUDOCS 9108220214
Download: ML20077R270 (89)

Text

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CALVERT CLIFFS -

NUCLEAR POWER PLANT r

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~ FITNESS FOR DUTY MANUAL- .

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AUGUST 1991 REVISION 2 I

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM Policy Statement To promote a safe, healthy, and accident froo work environment for all workers, BG&E maintains a Fitness For Duty (FFD) Progt am which includes: employee medical assistanco servicesi random, pre-access, follow-up, and for-cause testing. For cause testing for drugs and alcohol follows any observed behavior indicating possiblo substanco abuso, an accident or noar miss accident where there is a reasonablo suspicion that an individual's behavior contributed to the occurrence, receipt of credible information that an individual has been using drugs or alcohol or there is actual or potential degradation of the level of safety of the plant related to the individual, or admission that alcohol has been consumod within five hours of being called in for unscheduled duty. Any examination performed under the Fitness For Duty Program may include one or more of the following: a detailed medical history, physical examination, testing for drugs and/or alcohol, psychological testing, or other testing which may includo a test of vision and hearing.

The objectives of the Baltimore Gas & Electric Company's (BG&E) Calvert Cliffs Nuclear Power Plant (CCNPP) Fitness for Duty (FFD) Program are to provido reasonable measures for the early detection of persons who are not fit to perform activitios under the scopo of 10 CFR 26.10(b), to achieve a drug froo workplace and a workplace froo of the offects of such substances, and to provide reasonable assuranco that personnel granted unoscorted access, and those noted in Section 2.1 of the Fitness For Duty Manual:

are reliable and trustworthy.

are not under the influence of any substance legal or lilegal that in any way adversely affects their ability to safely and competently perform their duties.

are not montally or physically impaired from any cause such as mental stress, fatigue or illnesses which in any way could adversely affect their ability to safely and competently perform their duties.

do not consume alcohol within fivo (5) hours of any scheduled work tour.

are aware that the consumption of alcohol, illegal drugs, or abuse of legal drugs is l prohibited during the period of any working tour, refrain from the use, salo, transportation, and possession of illegal drugs.

Violators of these fitness for duty requirements may have their unescorted access terminated.

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Approved: [ v

. G. Creel, Vice# resident-Nuclear Energy Division i

Approved: *A J. MiFiles, Vice-President-Management Services Division 1 .J  :

Program Effective Date: January 3,1990 i Revision 2 Effective Date: August 20,1991 f

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CALVERT CLIFFS NUCLEAR POWER PLNR FlYtdESS FOR DUTY PROGRNA TABLE OF CONTENTS SECTION PAGE 1.0 Introduction 1 1.1 General 1 1.2 Program Objectives and Policies 1 2.0 Applicability 2 2.1 inclusions 2 2.2 Exclusions 3 3.0 Definitions 3 4.0 Responsibilities 9 ,

4.1 Vice Pres; dent Management Services Division 9 4.2 Vice President Nuclear Energy Division 10 4.3 Managers of Covered Individuals and Individuals Badged for Unescorted Access at Calvert Cliffs Nuclear Power Plant 10 4.4 Manager Neelear Quality Assurance Department 10 4.5 Manager Nuclear Support Services Department 11 4.6 Manager Employee Services Department 11 4.7 Manager-Safety and Medical Services Department 12 4.8 Fitness For Duty Program Manager 13 4.9 Medical Review Officer (MRO) 14 4.10 Supervisor Psychological and Employee Assistance Services 15 4.11 General Supervisor Calvert Cliffs Security Operations 16 4.12 Supervisor Security Screening 17 4.13 Assistant General Supervisor-Administrative Services (Nuclear Support Sewicos Department) 18 4.14 General Supervisor Employment (Emplcyee Services Department)

(Non Nuclear Energy Division) 19 4.15 Supervisor Contract Administration (Nuclear Support Sves. Dept.) 19 4.10 Assistant General Supervisor-Facilities Operations (Facilities Management Department-Calvert Cliffs) 20 4.17 Supervisor Technical Training Unit 20 4.18 Random Coordinator 21 4.19 Director Purchasing and Materials Management Dept. (P&.MM) 22 4.20 Supervisor Emergency Planning 24 4.21 Operational Support Ctr. (OSC), Emergency Operations Fac. (EOF)

Directors, and the Media Center (MC) Technical Advisor 24 4.22 Access Requesters 24 4.23 BG&E Supervisors 26 l

4.24 Employees 28 l

4.25 Contractors and Vendors 29 4.26 Escorts (Protected! Vital Areas) 30 Revision 2 August 1991 Page ll 1

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t TABLE OF CONTENTS [

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5.0 Operational Policies and Procedures 31 l

5.1 General 31  !

5.2 Procedure For Behavior Observation (BO) 32 5.3 Fitness For Duty Examinations 53 i 5.4 For-Cause Drug and AlcoholTesting 35  ;~

5.5 Random Testing For Drugs and Alcohol 35 5.6 Follow up Testing 36  ;

5.7 Pre-Access (Pre-Badging) Testing 37 i 5.8 Procedures For Urine Collection and Alcohol Testing 37 i 5.9 Notificatien of Drug and Alcohol Results 41 .j 5.10 Call in Notifications 41 -

5.11 Emergency Response Call-in Procedures 42 6.0 Training 43 6.1 General 43  !

6.2 Supervisor Fitness For Duty Training 43 ,

6.3 Supervisor Fitness For Duty Retraining 44 t 6.4 Awareness and Escort Fitness For Duty (AEFFD) Training 45 6.5 Awareness and Escort Fitness For Duty (AEFFD) Retraining 46 6.6 Course Presentations, Completion and Scheduling 46 6.7 Training Records 47 6.8 Lesson Plan Approval 47

- 7.0 Contractors and Vendors 47 r

8.0 Chemical Testing 49 8.1 General 49 8.2 Types of Testing 49 8.3 Testing Specifications 50  ;

9.0 Employee Medical Assistance Services (EMAS) 51 j I

9.1 General 51 9.2 Referrals 52 ,

9.3 Confidentiality 52 9.4 Reports to Management 52 ,

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9.5 Contractors and Vendors 52 9.6 Consultation 53  ;

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CALVERT CLIFFS NUCLEAR POWER PLANT Fl1 NESS FOR DUTY PROGRAM ,

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- TABLE OF CONTENTS 1

SECTION PAGE l i

10.0 Management Actions and Sanctions 53 10.1 Denial of Unescorted Access 53 I 10.2 Suspension of Unescorted Access 53 i 10.3 Romoval from Protected Area 54 ,

i O.4 Revocation of Unescorted Access 55  !

10.5 Considoration for Reinstatement of Unescorted Access 55 11.0 Appeals 55 12.0 Protection of Information 56

( 12.1 Procedures for Rotention and Protection of Records  !

l and Information 56  ;

12.2 Disclosure of Forsonal Information for Suitable Inquiry 56 '

l 12.3 BG&E's Right to Withhold Personal Information 57 12.4 Administrative Responsibilities 57  ;

13.0 Inspections, Recordkeeping, Roporting Requirements, l and Severity Categories 57 l

13.1 Inspections 57 -

13.2 Recordkeeping Requirements 57 13.3 Roporting Requirements .

63 13.4 Severity Categories (10 CFR 2 Appendix C, Supplomont Vil) 63 i 14.0 Audits 64 15.0 Control Procedures 65 16.0 References 66 -

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TABLE OF CONTENTS {

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Appm.iclx 1 - Emergency Rosponse Plan Named Positions Roquired To Meet CCNPP/FFD Requirements 68 l

Appendix 2 - Random Selection Form (You Have Boon Selected for Random i-Drug and Alcohol Testing Under The Calvert Cliffs t Fitness For Duty Program) 69 Appendix 3 - Forms for Reporting to Nuclear Regulatory Commission  ;

FFD Program Performanco Data Personnel Subject to 10 CFR 26 .

Random Testing Program Results/ t Confirmed Positive Tests for Specific Substancos FFD Program Porformance Data Personnel Subject to 10 CFR 26 71 Appendix 4 - Call-in Reporthg Checklist Form 78 Apperdix 5 - Supervisor Behavior Observation Report 80 f Appendix 6 - Notification to Contractor or Vendor of Positive Test Results 81 Appendix 7 - Prevention Of Subversion of Testing 82 [

Appendix 8 - Emergency Response Call-In Form 63 I

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM LIST OF EFFECTIVE PAGES PaaoRev Dato Roy # PaaeRov Datq Rev #

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM 1.0 Introduction 1.1 Gonoral The Nuclear Rogulatory Commission Rulo (10 CFR 26) requires each liconsoo to Imptomont a Fitnoss For Duty (FFD) Program. The objectivo of the Baltimoro Gas & Electric Company (BG&E) Fitness For Duty Program is to promoto a drug fico workplaco and to provido for the early dotoction of individuals who are not fit for duty. The Calvert Cliffs Nuclear Power Plant (CCNPP) Fitnoss for Duty (FFD) Program is to provido reasonablo assurance that nuclear power plant personnot granted unescorted access:

- are rollable and tru ;tworthy;

- are not under the influence of any substanco, legal or illogal;

- are not mentally or physically impaired from any cause such as monial stress, fatigue or illnesses which in any way could adversely affect their ability to safely and compolontly perform their dutlos;

- have not consumod alcohol within fivo (5) hours of any scheduled work tour;

- are awaro that the consumption of alcohol, lilogal drugs, or abuse of legal drugs is prohibitod during the period of any Plant working tour; and

- promoto a drug froo workplaco.

1.2 Program Objectives and Policios 1.2.1 The objectivo of the CCNPP/FFD Program is to croato an environment which is free of alcohol and drugs ar.d the offects of such substancos within the protected areas of the nuclear power plant and/or where personnel granted unescorted access perform or direct work portaining to nuclear power plant oporations or maintenanco.

1.2.2 This program is part of a well-integrated corporate approach to maintaining a reasonable measure for the early detection of persons who are not fit to perform activitios within this program and a work placo and work forco free of licit and lilicit substancos, and to provent the dangers imposed by impaired workers granted unoscorted access to the protected areas.

1.2.3 The use of illegal drugs and abuse of legal drugs, including alcohol, whether during or outsido of work hours, constitutes a safety throat to

!' BG&E employees, contractors, vondors, the surrounding community,

! the gonoral public, and BG&E facilities, and is not acceptable.

Specifically, overy BG&E employso, contractor and vendor is obligated to:

- report to work fit for duty, drug and alcohol-free; 1

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM l

report physical or mental factors such as montal stress, fatigue, and illnesses which could impact their fitness for duty during regularly scheduled wotk tours and/or when recolving call-in roquests from Supervisors;  ;

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not use or havo la their possession lilegal drugs, whether on or ,

off the job;

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not uso prescription drugs or ovor tho-counter drugs in any way I which may affect job performanco; }

not uso alcohol in any way which affects job performanco, nor  !

consume alcohol within fivo (5) hours proceding any scheduled  !

work tour or during work hours at the Calvert Cliffs Nuclear Power t Plant; and i 1.2.4 In addition to alcohol and drugs, other factors that could affect fitness  ;

for duty (such as mental stress, fatigue and illnesses) are to be part i of the responsiollities of behavior observation conducted by BG&E Supervisors, Contractor Supervisors and Access Roquestors, and will also be ovaluated during all fitness for duty examinations, t i 1.2.5 BG&E may revoko the unescorted access of any covered personnel who,in the opinion of BG&E, violates those requirements. With  ;

regard to BG&E employees, disciplinary action will be taken as j deemed appropriate by BG&E up to and including termination of employment, ,

2.0 Applicability l l l i 2.1 Inclusions j l

BG&E's CCNPP/FFD Program applies to: ,

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all persons granted unescorted access to protected areas of the Calvert Cliffs Nuclear Power Plant; l

- all covered personnel required to physically report to the Technical f L Support Conter (TSC), Emergency Oporations Facility (EOF), and the f Media Center (MC) in accordance with Calvert Cliffs Emergency  ;

Responso Plan implementation Procedures (as listed in Appendix 1); i t

- all persons assigned activities within the scope of 10 CFR 26;  ;

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- Nuclear Regulatory Commission (NRC) contractor personnel not specifically covered by the NRC FFD, ,

Off site Supervisors of covered personnel.  ;

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM 2.2 Exclusions This CCNPP/FFD Program does not apply to:

- law enforcement personnel or off site omorgency, fire, and modical responso personnel whils responding on.sito.

any escorted individual.

Nuclear Regulatory Commission (NRC) employoos. If there is reasonablo belief that an NRC employoo is under the influence of any substance or otherwise unfit for duty, access to the protocted area will not be donled, but the individual will be escorted from the Protected Area and the appropriate BG&E Management will be notified, who will ensure the NRC Regional Administrator is notified.

- State and local representativos, if BG&E personnel bollevo one of their individuais is under the influence of any substance or otherwise unfit for duty, they will be donled access to tho Emergency Oporations Facility (EOF), Technical Support Contor (TSC), and/or-Media Contor (MC) as appropriato, and senior BG&E Management will be notified.

3.0 Dofinitions 3.1 " Access Requester"is a Baltimore Gas and Electric Company individual who requests unoscorted access for covered personnel. This individual servos as liaison between BG&E and certain contractor /vondor employees in regard to the CCNPP/FFD Program. The Access Requester acts as or ensures thoro are properly trained BG&E personnel to act as behavior observers of contractor and vendor personnelin the absence of trained contracto< and vendor Supervisors.

3.2 " Aliquot" means a portion of a urine specimen used for testing.

3.3 "BAC"is the abbreviation for Blood Alcohol Concontration, which can be measured directly from blood or derived from a measure of the concentration of alcoholin a breath specimen. BAC is a measure of the mass of alcoholin a volume of blood such that an Individual with 100 mg of alcohol por 100 ml of blood nas a BAC of 0.10 percent.

l 3.4 " Background Checks" consist of the following clomonts: employment, education and criminal histories; military service check; character and reputation checks; verification of identity; and a credit check. (See NUMARC 89-01 " Industry Guidelines For Nuclear Power Plant Access Authorization Program" for retroactive years for each element and a special provision for craft and trade workers.)

3.5 " Behavior Observation (BO)" means techniques used by Supervisors, escorts and others to detect degradation in performanco, impairment or changes in a badged individual's behavior which may indicate the nood to evaluate an individual's fitness for duty. 80 also refers to training programs in those techniques. Allindividuals are subject to behavior observation including cortain individuals responding to the Emergency Operations Facility (EOF) and the Media Conter; m

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM l

3.6 *BG&E" means the Baltimoto Gas and Electric Company.

3.7 " Call in" is overtimo for which notico to report was Olvon to the individual attor the end of his or her last period of timo reported as Work Timo or Timo Off (other  :

than Vacation), provided that at the timo the notico was given, the individual was j not already on Com)any promisos awaiting the start of the next schodulod starting time. Each ndividual will be required to make a statomont (Appendicos 4 and 8 as appropriato) as to whether he or sho has consumed alcohol within the previous five hours of the request to respond to the plant.

3.8 " Chain-of Custody" means procedures to account for tho Integrity of each l specimon by tracking its handling and storage from the point of specimen  ;

collection to final disposition of the specimon. l 3.9 " Code of Fodoral Regulation (CFR)"is a codification of the general and }

permanent rules established in the Fodoral Registor b/ the executivo F departments and agenclos of the Federal Government. Title 10 of the codo, l Energy, Chaptor 1, NRC, Parts 0 through 109, perialns to the Nucioar Regulatory 1 Commission.

3.10 ' Collection Facility"is a placo designated by BG&E whero individuals prosent themselves for the purpose of providing a voluntary specimon of their urino, [

broath, and blood (if requestod by the individual after a positivo broath tost) to be analyzed for the presenco of drugs and/or alcohol.

3.11 " Collection Facility Person" moana a person designated by BG&E who instructs  !

and assists individuals at a collection facility and who recolves and makes an i inillal examination of the specimens provided by those Individuals and performs j i alcohol testing. A collection facility person shall have successfully completed ,

training to carry out those functions or shall be a licensed modical professional  :

or technician who is provided instructions for collection under this program and cortifies completion as required herein. In any case whero a urino specimen collection is observed or a urine specimen collection is r anitored by non-modical personnel, the collection facility person must be of the same gendar as i the individual providing the urine specimen.

l 112 " Confirmation" means the process of using a second analytical proceduro to i

! Identify the presence of a specific drug or metabol!to which is independent of tho  :

initial test and which uses a different technique and chemical principio from that i of the initial test in order to ensure reliability and accuracy, j 3.13 " Confirmatory tests" (urino and broath) means a second analytical procedure to ,

l identify the presence of a specific drug or drug metabolito, wnich is indopondent of the initial scrooning test. For urine, a different technique and chemical .

principio is used from that of the initial screening test in order to ensure reliability  ;

and accuracy. (At this time, gas chromatography / mass spectrometry [GC/MS) is the only authorized confirmation method for detecting cocaine, marijuana,  ;

I opiates, amphetaminos, phoneyclidino.) For dotormining blood alcohollevels, a 3

" confirmatory test" means a second test using another breath alcohol analysis  ;

device. Further confirmation upon the individual's request will be by gas

, chromatography analysis of blood. ,

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CALVERT CLIFFS NUCLEAR POWER PLAMT FITNESS FOR DUTY PROGRAM 3.14

• Confirmed positive test" means the result of a confirmatory test that has establishod the presence of drugs, drug motabolites,in a speelmon at or above the cut-off lovel, and that has boon doomod positivo by tho Medical Review Officer (MRO) attor an ovaluation (which includes an Intervlow if the indiv', dual is availablo and avails him or horsolf to it). A 'confirmod positivo test" for alcohol can also bo obtained as a result of a confirmation of b ood alcohollovels with a .

socond broath analysis without MRO evaluation.

3.15

• Contract Administrator" means a BG&E employoo charged with the responsibility of monitoring the work product o' contractors or vondors in assuring adoquato oxocution of the contract for sorvicos of those contractors or vondors.

3.16 *ContractorNondor" means any Company or Individual with which BG&E has contractod for work or service to bo performed insido the protected area ,

boundary, olthor by contract or purchase order. ContractorsNondors may be charged with behavior observat.on and/or escort dutlos at Calvert Cliffs.

3.17 *Covorod Personnol" moans employee, contractor /vondor ndividuals to whom 10 CFR 20 is applicablo, 3.18

• Cut off Loyol" means tho valuo sot for designating a test resuh as positivo.

3.19 *Donlod" (unescorted access) means unoscorted access will not be grantod at a particular timo duo to various reasons (Soction 10.1),

3.20

• Discharge Confotonce" means a group of key managomo vol personnel who

, review the facts and circumstances of cortain incidents to dowmlno tho l- disposition of an individual as it relatos to their unoscorted access and/or continued employment. ,

3.2* *Employeo* means an individual hired by BG&E for work that is generally expocied to be ongoing for the forosocable futuro, Employou also implios an individual charged with escort dulles at CCNPP, 3.22 " Escort" means any individual granted unoscorted access to the protocted area and who has satisfied the training roc utromonts for accompanylng individuals who do not have unescorted access n the protected area, 3.23 ' Fitness For Duty" means reporting for work in a physical or montal condition which does not compromise or in any way jeopardize tho gonoral public, or other workers and does not compromise tho intogrity of the plant or its personnol and promotos public health and safety. Specifically, this means reporting for work in a condition which is free of alcohol and/or illegal drugs, and the effects of thoso substancos, including conditions caused by the uso of prescription and over tho counter drugs which could compromiso public health

!. and safety.

l 3.24 ' Fitness For Duty Examlriation" means an ovaluation as ordered by the Manager.

Safety and Medical Services Department which may includo, among other 3 things, a detailed medical history; a physical examination test of vision and hearing; drug, alcohol and psychological screening; or any other tests doomed i appropriate to determine if the Individualis fit for duty, t

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 3.25 " Follow up testing" means drug and/or alcohol testing at unannounced intervals which helps to ensure that an employee who has referred him or horself or has been referred for medical assistanco due to substance abuse is maintaining abstinence form the abuse of drugs or alcohol. -

3.26 "For Cause testing" means drug and alcohol testing of an individual who shows behavioral changes or other evidence of probable alcohol or drug use. This testing is conducted due to referral by a Supervisor, an individua', a contract administrstor or oscort following degradation of performance or any other indicators which may question the individual's fitness for duty.

3.27 "HHS"is the abbreviation for the U.S. Dopartmont of Health and Human Sorvices.

3.28 "HHS certified Laboratory" means a urino and blood testing laboratory that maintains cortification to perform drug testing unrior the Dopartment of Health and Human Sorvices (HHS)

• Mandatory Guidelines for Federal Workplaco Drug Testing Programs" (53 FR 11970).

3.29 " Illegal drugs" means those drugs included in Schedules I through V of the Controlled Substances Act (CSA), but not when usoci pursuant to a valid prescription or when usod as otherwise authorized by law.

3.30 "impalrod" means reporting for work in a condition which is affected by the use of alcohol and/or Ologal drugs; the misuso of ovor the-counter or prescription drugs; and/or the prosonce of physical or montal factors such as montal stress, fatigue or illness.

3.31 " Infrequent Access" means individuals graniod unescorted access to the protectoo/ vital areas of the plant but who enter the plant on an unscheduled basis, occasionaHy, or intermittently, such as : nod service and vending machino suppliers, telephono ropalt persons, and/or photocopior repair persons who are not under a licensee approved behavior observation program, and not uJizing their badge within a 60 day period. Due to the random nature of this Program, individuals completing a test are immediately eligible for another unannounced ,

test.

3.32 " initial Testing Procedurosa moans the initial test or screoning test wb!ch 4 used to identify those specimens which are negative for the prosonce of drugs or drug motabolitos. These specimens nood no further examination and nood not undergo a more costly confirmatiori tost.

3.33 " Initial or screening tests" means an immunoassay screen for drugs or drug metabolitos or the first breath test for alcohol initial screening may be portormed at the BG&E testing facility (for-cause testing only). A second scroon and confirmation testing for drugs r'r drug metabolites must be conducted by a HHS-certified laboratory.

3.34 " Institute of Nuclear Powot Operations (INPO)'is an industry funded organization that conducts evaluations of and offors assistance to member utilities. Major programs are evaluation programs, accreditation and training programs, event analysis and informatien exchange programs, and assistance programs.

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OALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM f

3.35 "Modical Review Officer (MRO)" means a licensed physician responsible for  !

recolving laboratory results generated by BG&E's drug and alcohol testing program. The MRO must also have knowledge of substanco abuso disorders and has appropriato medical training to interpret and ovaluato an individual's positivo 16st result together with his or her medical history and any other relevant biomedicalintormation.

3.36 *NationalInstitute of Drug Abust. i llDA)" means tho Fodotal Agency responsible for cortifying laboratorios that mwt the requirements of tho Mandatory Guidelinos for Federal Workplace Drug Testing, Subpart C - Certification of Laboratories Engaged in Urino Drug Testing for Federal Agenclos, whoso standards woro incorporated into 10 CFR 26.

3.37 *Nood to know" me;ns a dolormination by a person having responsibility for protecting information collected and retainod under 10 CFR 26 requiromonts; that a proposed recipiont's access to this information is nocossary in the performance of official, contractual, or licensos duties of employmont in  ;

imptomonting the FFD Program.

I 3.38 " Nuclear Management and Resourcos Council (NUMARC)" means nuclear licensoo funded group that providos a unified industry approach on gonoric nuclear regulatory and technicalissues and interacts with the NRC, or other +

Government agenclos as appropriate on those issues. NUMARC has a full time staff to address cortain _ issues and, at times, assembles working groups or AD Hoc subcommittoos to work on specific programs.

3.39 " Nuclear Regulatory Commission (NRC)" means the United States Nuctoar -

Regulatory Commission, the agoney established by Title 11 of the Energy Reorganization Act of 1974, as amended. ,

3.40 *NRC Rulo" means the Nuclear Regulatory Commission's Fitness For Duty Rule,  !

codified at 10 CFR 26 et soq, which was effectivo January 3,1990. ,

3.41 "Permanont record book" means a permanontly bound book in which identifying data on each specimen collected at a collection facility are permanontly secorded in the soquence of collection.

3.42 " Pre Access Testing"(Pro-Badging) means testing of covorod personnel who  :

havo not boon tested within the last sixty days who are requesting unoscorted i access to the protected area, t

3.43 " Pro Employment Tosting" means the practice of conducting alcohol and urine  ;

drug testing on BG&E applicants. This same test can be considered a " pro- [

access tost"if conducted withir; sixty days of an individual being granted unescorted access.

3.44 "Prosumptive Positive" means a positivo screening or immunoassay test for b drugs and drug metabolites is preliminary and then shall be confirmed by a different, more specific test at a NIDA-certified laboratory. 't 3.45 - Protected area" means the area at Calvert Cliffs Nuclear Power Plant )

encompassed by physical barriers and to which access is controlled as  ;

described in the Calvert Cliffs Security Plan. i

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i CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 3.46 " Random tost" means a system of unannouncod alcohol end $ug testing which is administorod in a statistically random manner to a group so that all persons  :

within that group havo an equal probability of soloction ovory timo a soloction is mado, 3.47 *Roason to bollevo" means reason to believo that a acular individual may alter i or substituto a urino specimon.

3.48 "Rovokod" as used in the context of tho FFD and Access Authorization Programs, means an individual's unescorted access to the protectod/ vital areas is annulled and mado invalid due to noncomplianco, or a violation of the FFD or Access Rulo requiromonts. l 3.49 "Scrooning" Soo initial Testing Procodoro (Section 3.32).

3,50 "Solf refor" moans reporting to supervision or to professionals within tho Safety and Medical Sorvicos Dopartmont Section of one's problems such as the  !

oxcossivo use of alcohol, tho uso of illogal drugs, the misuso of over tho-countor drugs, and any other physical or montal factors such as montal stress, fatiguo or illnoss which could impact on a worker's fitnoss for duty.

3.51 " Split sample" means a potilon of a urino specimen stored by a contract NIDA-approvod laboratory for a specified porlod of time to be testod in the event of an appeal.

3.52 "Sultablo Inquiry" means best-offort verification of employmont history for the past fivo years but not loss than throo years. Vorification should be obtained through contacts with previous employers to dolormino 11 a person was in the ,

past tested positive for lilogal drugs, subject to a plan for treating substanco i i abuso, or removed from or mado inelig blo for activitios within the scope of 10  ;

CFR Part 26. This includos a person denied unescorted access at any other ,

l nuclear power plant or other employment in accordanco with a fitnoss for duty l ,

policy.

3.53 " Supervisor"in the context of this program means a supervisor or work loador who is responsible for Behavior Observation. This means any individual who has  ;

i completed Supervisor Fitness For Duty Training and is responsible for conducting behavior observation of individuals granted unoscorted access to t

the protected area or responding to the EOF and/or Modia Contor. A Fitness For Duty Supervisor does not nocessarily havo to be a Supervisor by job tTM.  ;

l '

3.54 "Suspendod" means unoscorted access to the protectod/ vital areas has been temporarily withdrawn ponding the resolution of a particular situation. Such individuals may not bo escorted into the protected area without prior opproval of the Supervisor-Socurity Scrooning.

3.55 "Torminatod" (unescorted access) means previously granted unoscorted access has been withdrawn duo to noncomplianco with requirements of the BG&E j' Fitness For Duty Program, termination of contract, completion of contract, or l other reasons.

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CALVERT CLIFFS NUCLEAR POWER PLRNT FITNESS FOR DUTY PROGRAM 1

3.56 "Tosting facility" means a drug testing facility operated by BG&E or operated l under contract to BG&E by an outsido laboratory servico provider to perform the l initial and confirmatory testing of urino specimens and to puform broath tosts for alcohol.

3.57 *Unoscorted Access Authoritatipf means an administrativo determination that an individual has completed all access authorization (10 CFR 73.56) and fitness for duty (10 CFR 26) requirements, and is oligible to be granted unoscorted access.

3.58 " Unescorted Access (Badged)" applies to the methodology or mechanism (e.g.

keycard) that providos a means of controlling unoscorted personnel access to protectod and/or vital areas.  ;

l 4.0 Responsibilities (may be dologated to BG&E attornates) 4.1 Vico President-Management Services Division is responsible for:

4.1.1 Jointly with the Vice President Nuclear Energy Division approving the Calvert Cliffs Nuclear Power Plant FFD Program and ensuring that all aspects of the program comply with BG&E and NRC requiromonts; 4.1.2 Reviewing results of Fitness For Duty Program audits and recommendations,if any; 4.1.3 Furnishing necessary resources to ensure the program is implemented and conducted in a professional manner; 4.1.4 Maintaining copios of letters of commitment to the NRC concerning this program; 4.1.5 Roviewing self assessments and NRC inspections.

4.2 Vice President Nuclear Energy Division is responsible for:

4.2.1 Jointly with the Vice President Management Services approving the Calvert Cliffs Nuclear Power Plant FFD Program and ensuring that all aspects of the program comply with the BG&E and NRC requirements; 4.2.2 Reviewing results of Fitness For Duty Program audits and recommendations,if any; 1

1 4.2.3 Ensuring communications with the NRC, NUMARC and INPO are coordinated and provido a consistent corporato position; L

4.2.4 Reviewing self-assessments and NRC Inspections.

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM i

4.3 Managers of Covered Individuals are respontblo for: 5 4.3.1 Adherenco to and implomontation of the CCNPP/FFD Program; i 4.3.2 Ensuring appointed Supervisors of Calvort Cliffs of covered personnel  !

badged employoos recolvo Supervisor Fitness For Duty Training j within 60 days of the appointment,  ;

4.3.3 Notifying individuals of their soloction for Random Tosting and '

completing the Random Selection Form (Appondix 2)If tho individual's Supervisor is not available; 4.3.4 Notifyng Security Scrooning of the results of an individual's dischargo conference. Security Screening will tako appropriato  :

action based upon the results of tho dischargo conference to '

reinstate or revoke the susponded access of that individual; i

4.3.5 Ensuring that the next higher supervisor assumes the behavior .

observation responsibilitios when tho designated observor is no i longer accomplishing this function due to expiration of tralning,  !

transfer, for cause, or extended leave of absence, etc ;

4.3,6 Ensuring non-badged, off.sito supervisors of badgod employcos, -

complete supervisors fitness for duty training and retraining:

4.3.7 Establish policy to ensure the filing of the Call in Roporting Checklist  ;

(Appendix 4).

4.4 Managor-Nuclear Quality Assuranco Department is responsible for:

4.4.1 Conducting audits of the CCNPP/FFD Program overy 12 months; l 14.2 Dotormining whether or not the quality of an individual's work should be evaluated when that Individual's unescortod access has boon suspended or revoked due to a violation of the Fitness For Duty .

Program. If an ovaluation of an Individual's work is deemed necessary, tho Manager will direct the appropriato personnel to  !

perform the evaluation. This ovaluation should ensure that the work was performed satisfactorily and had no adverso impact on quality '

and safety of the plant; 4.4.3 Maintaining records as describod in Section 13.2.1.

4.5 Manager-Nuclear Support Services Department is responsible for:

4.5.1 Ensuring that initial awareness and oscort, Supervisor and annual ,

rcfresher training are conducted in accordance with this proceduro,  ;

with the assistance of subject mattor exports, as appropriate; Revision 2 August 1991 Paga to

T' CAI. VERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 4.5.2 Scheduling training for personnel required to participato in FFD training.

4.6 Managor-Employee Services Department is responsible for:

4.6.1 Ensuring the strict adherence to stated Management ac%ns and sanctions as required by this Program; 4.6.2 Ensuring consistont treatmont of employees under this Program; 4.6.3 Tracking and recording appeals involving BG&E employees of positive alcohol and drug dolorminations; 4.6.4 Reviewing and resolving appeals of BG&E employcos who had boon dolormined to have confirmed positivo alcohol or confirmed positivo drug determinations; 4.6.5 Representing BG&E Management for the purposes of meeting the NRC rule raquirements [10 CFR 26.24(o)) that licensco management must be notified within 10 days of a presumptivo positive test or follow up testing; 4.6.6 Ensuring that internal department line management verification (self-assessment) of quality is conducted; ,

4.6.7 Ensuring revision of department unit task level Fitness For Duty procedures are forwarded to the Fitness For Duty Program Managor; 4.6.8 Maintaining records as described in Section 13.2.2.

4.7 Managor Safety and Medical Services Department is responsiblo for:

4.7.1 Pronding trained and cortified Medical professionals to perform medical roviews, employee assistanco counseling, collection facility dulles, and perform fitness for duty testing; 4.7.2 Appointing Medical Revlow Officers (MRO's);  !

4.7.3 Ensuring strict adherence to procedures consistent with established professional standards concerning chain-of-custody of biological -

specimens provided by participants in this Program; I

4.7.4 Coordinating activities related to providing specimens to the NIDA-l' cortified testing laboratories and to receiving test results; t

4.7.5 Ensuring that losting for drugs and alcohol conforms to requirements of Federal, Stato and local regulations; 1

Revision 2 August 1991 Page 11

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUYY PROGRAM 4.7.6 Ensuring testing / collection for all substances described by 10 CFR l 26; 4.7.7 Tracking and requesting follow up tests on those individuals who i have had their unescorted access reinstated in accordance with 10 CFR 26.27. Dotormining the frequency and selection for follow up r drug testing of covered personnel with unescorted access or those ,

individuals otherwise covered by CCNPP/FFD; l 4.7.8 Notifying the Managor Employee Services Department (employoos) prior to or simultaneously with notifying the individual's Manager (or  ;

alternato) if an Individual has been dolormined to be unfit for duty;  !

4.7.9 Approving contract and ensuring certified laboratories are inspectod; 4.7.10 Ensuring departmont staff personnel act as bt7navior observors for contractor collection facility Individuals;  !

I 4.7.11 Ensuring that internai department line management cortification (self-assessment) of quality is conductod; 4.7.12 Ensuring that Supervisors, co-workers and relativos of the Individual i bein0 testod do not perform any collection assessment or ovaluation 1 of the individual; 4.7.13 Ensuring that approp lato BG&E Supervisors are notified when an '

individual falls to participato in any portion of the random drug and '

alcohol testing regimen; t

4.7.14 EnsurinD revision of department unit task lovel Fitness For Duty procedures are forwarded to the Fitnoss For Duty Program Managor; i

4.7.15 Maintaining records as described in Section 13.2.3; 4.7.16 Designating the Fitross For Duty Manager; 4.7.17 Ensuring collection facility personnel are familiar with Fitness For 7 Duty Proceduros 008,009,010.

4.8 Fitness For Duty Program Mariager is responsible for:  ;

4.8.1 Conducting an annual compliance self assessment evaluation of the Program; I

L 4.8.2 Revising the Fitness For Duty Manual, as appropriato; l.

l 4.8.3 Retaining the record copy of the FFD Manual; I

4.8,4 Transmitting the semi-annual Fitness For Duty Performance Data  ;

Report to the Nuclear Rogulatory Commission (Appendix 3);

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM

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i 4.8.5 Intortacing with the Nuclear Rogulatory Commission, Instituto of Nuclear Power Operations, and the Nuclear Quahty Assuranco ,

Departmont during applicable ovaluations, self assessments, and [

inspections or surveys of the FFD program; j 4.8.6 Preparing correspondonce to the NRC and acting as the BG&E primary point of contact with the NRC concerning this program; i

4.8.7 Ensuring key unit personnot have an opportunity to analyzo and  ;

contributo to the Fitness For Duty Program semi-annual report; 4.8.8 Rovlowing analysis of semi annual fitness for duty data and taking ,

appropriato action (s) to correct program weaknessos; j i'

4.8.9 Porlodically informing BG&E management of cortain aspects of tho .

program; I l

4.8.10 Rocolving information from MRO and Security on current drugs being r abused in the area; l

4.8.11 Submitting blind samplos to appropriato laboratorios; i

4.8.12 Submitting the reports to the NRC as toquirod in 10 CFR 26 and as defined in Section 13.3; 4.8.13 Maintaining records as describod in Soction 13.2.4; 4.8.14 Ensuring that background investigations, suitablo inquirlos, and psychological ovaluations are completed on Individuals prior to ,

assignment of any task (s) associated with this program and aro  ;

updated every throo (3) years; 4.8.15 Maintaining the Program implomontation Chart that Idontifies who has l boon tralned, when background investigations and psychological investigations, etc. aro comploted, and when the throo (3) year  ;

updatos are to occur; 4.8.16 Ensuring alcohol tests are conducted during drills and mass l l

cmorgoney call-ins on Individuals who indicato alcohol has boon >

consumed within the previous five (5) hours; l 4.8,17 Ensure the Random Coordinator develops procedures addressing f soloction of personnel, receipt of test results, notifications and  ;

records kooping, etc.

l

. t 4.9 Modical Review Officer (MRO)  !

is responsible for:

1

( 4.9.1 Reviewing and interpreting biological test results;

• 4.9.2 Conducting additional examinations, interviews and/or counseling, as f necessary, to ascertain hny facts germano to dolormining whether a ,

situation coratitutos covered personnel's failure to be fit for duty;  !

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i cal. VERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM l

4.9.3 Notifying the Manager-Safety and Medical Servicos or Medical  !

attornato and the Random Coordinator if the individualis unfit for  !

duty;  ;

4.9.4 Notifying the Managor Employoo Services Department (employoos)  ;

prior to or simultaneously with notifying tho individual's Manager (or f attornato)if an individualis unfit for duty; r 4.9.5 Communicating with the Manager-Safoty and Medical Services, and appropriato BG&E supervision in the case of covered personnel  !

being determined to be unfit for duty; 4.9.6 f. laking the requirod notifications in the ovent that a coli ection facility person advises them that an individual departed the collection facility without completing the drug testing process; 4.9.7 Notifying the Random Coordinator immodlatol/ of allindividuals (covorod personnel) with confirmed positive alcohol or confirmatory  ;

dru0 testt; 4.9.8 Participating in and providing all nocessary information to the +

Individual (s) reviewing and resolving appeals by employees and f contractors of positive alcohol or drug dstorminations; 4.9.9 Tracking and recording appeals of selontific/ aspects of positive alcohol or drug dotorminations involving contractor and vendor personnot:  ;

4.9.10 Receiving and reviewing satisfactory modical assurance documentation that any individual seeking reinstatomont of  !

unescorted access has abstalnod from drugs for at least throo (3) [

years prior to reinstatement of unescorted access; 4.9.11 Contacting hospitals and the local medical community to identify those substances being used/ abused in the local area and furnishing i this information to the Program Managor; 4.9.12 Monitoring procedural revisions, oversooing collection manual changes, distributing and retalning revisions, as required. The MRO will ensure that Laboratory Procedures Manual changes are dissom!nated to appropriate individuals; j 4.9.13 Reviewing and annotating the Supervisor Bohavior Observation i Report (Appendix 5) and forwarding it to the Supervisor-Security  !

Scrooning in a confidential manner:

4.9.14 Conducting an investigation and notifying the NRC, through the FFD i Program Manager, of any unsatisfactory performance testing results of falso positive errors on blind urino specimens; i

4.9.15 Ordoring a reanalysis of the original urino specimen after a timely [

request from the individual tested;  ;

Revision 2 August 1991 Page 14 t

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM 4.9.16 Ensuring revision of department unit tas' lovel Fitness For Duty t proceduros aro forwarded to the Fitness For Duty Program Manager; 4.9.17 McIntaining records as described in Section 13.2.5. j 4.10 Supervisor-Psychological and Employoo Assistanco Sorvices [

is responsible for: i 4.10.1 Providing Employeo Medical Assistanco Services to employoos who  :'

refer themselves or are referred for treatment or counsoling by their Supervisor, a medical providor, or cc worker; [

4.10.2 Informing the Manager Safoty and Medical Services Department of any covered personnel whose condition constitutes a hazard to him or horself or others (dotorminod as a result of self referral to Psychological and Employoo Assistanco Services) and for whom denial or revocation of unescorted access should result; 4.10.3 Publicizing programs which are available to employees desiring assistance in managing personal problems, which may include drugs, alcohol, montal stress, fatiguo or illnesses, and could affect an  ;

employoo's fitness for duty; 4.10.4 Providing assistance in a call-in situation as a consultant to '.ho f Supervisor and medical staff in determining if an individual is fit to perform the task (s) he or she was called in to perform; i

4.10.5 Assisting in the development and approval of fitness for duty lesson plans; f

4.10.6 Ensuring revision of do aartment unit task level Fitness For Duty proceduros are forwarced to the Fitness For Duty Program Manager; 4.10.7 Maintaining records as described in Section 13.2.6.

4.11 General Supervisor Calvert Cliffs Security Oport.tions is responsible for:

4.11.1 Ensuring alcohol tests are conducted on individuals callod in during non-omergency conditions who indicate alcohol has been consumed within the previous five (5) hours, and reporting test results to .

Medical; e

4.11.2 Furnishing information to the FFD Program Manager or alternato in a  ;

timely manner to expedite tho reports to the NRC as required in 13.3; j i

l 4.11.3 Consulting with local law enforcement agencies to determine l

substances that currently are being used/ abused in the area, and ,

advising the MRO and the Program Manager of any pertinent i information; t

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. r CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRNA .?

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4.11.4 Ensuring that responding members of the Emergency Response Plan .!

receive and complete the Emergency Response Call-in Form -.

(Appendix 8) prior to reporting to their work location, and directing 4 those individuals to the' medical dispensary, with their forms, who - l Indicats they have coneumed alcohol v'tNn the previous five (L) -!

hours, and forwe ^ , emaining

, forms pon-consumption) to the i L Fitness For Du,y Program Manager; j i

4.11.5 Ensuring revision of department unit task level Fitness For Duty j procedures are forwarded to the Fitness For Duty Program Manager;- j i

4.11.6 Ensuring breatha'yzer trained security personnel are available on -

backshifts, weekends and holidays to test call-ins; j f

4.11.7 Receives the confidential names of individuals to be tested on the -!

't backshifts, weekeds and holidays; 4.11.8- - Maintaining recore; as described in Section 13.2.7;  ;

I 4.11.9 Ensuring Security Shift Supervisors are familiar with Fitness For Duty  :

Procedures 009,009,010. g i

4.12 Supervisor Security Screening  !

is responsible for:

4.12.1 En.+ 'ng that unescorted access to Calvert Cliffs is withheld unless th6 .dividual has successfully completed alcohol and drug testing no ,

more than 60 days prior to initial granting of unescorted access; i

'4.12.2 Denying, sus'pending, or revoking unescorted access of any covered-personnel determined to be un,it for duty; ,

4.12.3 Revoking or suspending as appropriate mescorted access of any -

covered porsonnel determined to have us: auccessfully completed

' training as required under this Program; 4.12.4 Notifying info r ition Systems Department of individuals who j possess malmrairc access (password) when their unescorted access -i has been cuspended or revoked resulting from a fitne:s for duty _ -!

- determination; n .

}

-4.12.5 Conducting a suitable inquiry on a best-efforts basis to determine if q l  ;

L candidates for unescorted access (covered personnel) hcve ever -

tostad positive for drugs c r use of alcohol that resulted in on-duty b .

impairment or were subject to a plan for treating substance abuse _- 1 (except self-referral), or removed from activities for being unfit-for . . .

- duty, or denied unescorted access at any other nuclear power plant l

or other employment in accordance with a fitness for duty policy; j i

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Revision 2 ' August 1991_ Page 16

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CALVERT CLIFFS NUCLEAR POWER PLANT HTNESS FOR DUTY PROGRAhf 4.12.6 Based on a signed release forrn, BG&E will transfer the results of the ,

individual's suitable inquiry to roquesting licencoes or agents of licenseos when the individual has been granted unoscorted access or ever denied unescorted access or removed under the provisions of a Fitness For Duty Program and the circumstances for such denial ,

or removal, including tost results;

{

4.12.7 Obtaining a written statement from the individual as to whethor ,

unescorted access has been denied by any licensee or other '

emp' yment in accordance with a fitness for duty policy prior to granting initial unescorted access to the protected area and permission to transfer the abovo (4.12.6) information to requesting i licensees or agents of licensoes; .

4.12.8 Noiifying the Access Roquestor/ Supervisor of any contractor or vendor individuals whose roquest for unescorted access at CCNPP -

has been denied, suspended or revoked under this Program; j 4.12.9 Ensuring there is a " Letter of Agreement" on file from each -

contractor / vendor prior to granting unescoded access (contractor / vendor employee); ,

4.12.10 Maintaining current revisions of too " Contractor Requirements For Unescortad Access to Calvert Cliffs Nuclear Power Plant" and furnishing copies to the Director of Purchasing for subsequent distribution to contractors; 4 12.11 Ensuring revision of department unit task level Fitness For Duty procedures are forwarded to the Fitnoss For Duty Program Manager; '

4.12.12 Inactivate the protected area badges of contractors / vendors who access the plant on an infrequent basis who have been randomly selected for drug and alcohol testing; 4.12.13 Notifying the Manager Nuclear Quality Assurance la a confidential manner of each individual whose unescorted access was suspended

- or revoked duo to non-compliance with the FFD Program. The '

Manager-Nuclear Quality Assurance will then make a determination whether or not the quality of the Individual's work must be evaluated; -

4.12.14 Determining Il an individual whose unescorted accota has been '

suspended, denied, revoked, or terminated may 5 escorted for a specific period of time; 4.12.15 On a monthly basis providing Technical Training with a list of designated Supervisors for behavior observation responsibility, as ,

derived from information containcJ in the Supervisor's Fitness For Duty Behavior Observation Verification Report; ,

4.12.16 Confirming that the individual (s) responsible for Behavior Observation has been trained; l ,

! 4.12.17 Mcintaining records as described in Section 13.2.8. ,

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i 1 . Revision 2 August 1991 Page 17 i

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRBU 4.12.18 Security Screening shall maintain Supervisor Behavior Observation Reports (Appendix 5) and documentation of action taken in the individual's personal security file.

4,13 Assistant General Supervisor-Administrative Services (Nuclear Support Services Department) is responsible for:

4.13.1 Notifying newly appointed Supervisors (unbadged) and their Supervisors that they must complete initial Supervisor Fitness For Duty Training prior to assignment of duties (supervising behavior observation) under the Fitness For Duty Program; 4.13.2 Notifying newly appointed / badged Supervisors and their Supervisors of the requirement that the newly appointed Supervisor receive training within sixty days of the notification. If the newly appointed individual's Supervisor has not reccived training, he must also undergo Fitness For Duty Supervisor Training within 60 days of the subordinate's notificetion; 4.13.3 Forwarding to Technical Training the names of those individuals in the Nuclear Energy Division newly assigned to Supervisory positions.

This information must be forwar ded within five (5) days of the notification of the new assignment; 4.13.4 Ensuring revision of department unit task level Fitness For Duty procedures are forwarded to the Fitness For Duty Program Manager; 4.13.5 Maintaining records as described in Section 13.2.9.

4.14 General Supervisor-Employment (Emplone Services Department) (Non-Nuclear Energy Division) is responsible for:

4.14.1 Notifying newly appointed Supervisors (unbadged) and their Supervisors that they must complete initial Supervisor Fitness For Duty Training prior to assignment of duties (supervising behavior observation) under the Fitness For Duty Program;

'4.14.2 Notifying newly appointed badged Supervisors of the recuirement to complete Supervisor Fitness For Duty training within sixty days of the notification; 4.14.3 Ensuring that notification is made to Technical Training and Security Screening within five (5) days of any non-Nuclear Energy Division individuals appointed to Supervisory positions who are or will be responsible for the behavior observation of individuals granted unescorted access to the protected area; 4.14.4 Notifying Supervisors within five (5) days nf individu'Is appointed to Supervisocr positions requiring unescorted access to the protected area, EOF and Media Center; j

Revision 2 August 1991 Page 18

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM ,

4.14.5 Ensuring revision of department unit task level Fitness For Duty procedures are forwarded to the Fitness For Duty Program Manager; ,

4.14.6 Maintaining records as described in Section 13.2.10.

4.15 Supervisor Contract Administration (Nuclear Support Services Department) ,

is responsible for:

4.15.1 Receiving correspondence from Purchasing and Materials  ;

Management that idemi'ies contractor / vendor Supervisors for behavior observation of their employees at CCNPP; ,

4.15.2 Providing a list of the full names and social secunty numbers of the i designated individuals who will be responsible fu supervising behavior observation to the appropriate BG&E Supervisors and Technical Training and (nalntaining a copy for files. This notification will remind the recipient that the individual (s) must be trained prior to or within 60 days of being designated as a Supervisor; I l 4.15.3 Ensuring revision of department unit task level Fitness For Duty 2 procedures are forwarded to the Fitness For Duty Program Manager.

4.16 Assistant General Supervisor-Facilities Operations (Facilities Management Department-Calvert Cliffs)  ;

is responsible for: ,

4.16.1 Receiving correspond 9nce from Purchasing and Materials Management that ider.tifies contractor / vendor Supervisors for behavior observation of their employees; 4.16.2 Ensuring that unbadged contractor / vendor Fitness For Duty Supervisors complete Supervisor Fitness For Duty Training prior to assignment of duties (supervising behavior observation) under this Program. Badged individuals newly appointed as Supervisors for fitness for duty must complete the training within 60 days of the appointment; i

4.16.3 Ensuring that bG&E or contractor fitness for duty trained supervisors observe covered personnel;  ;

4.16.4 Ensuring that co.1 tractor /vendo; Supervisors (behavior observation) receive snnual retraining as required;  ;

i 4.16.5 Ensuring revision of department unit task level Fitness For Duty procedures are forwarded to the Fitness For Duty Program Manager.

417 Supervisor-Technical Training Unit is responsible for:

4.17.1 Coordinating development of Fitness For Duty Training; i

Revision 2 August 1991 Pags 19 7

C ALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 4.17.2 Presenting Awareness and Escort and Annual Refresher Fitness For Duty Training concurrently with General Orientation Training (GOT);

4.17.3 Presenting Supervirar Fitness For Duty and Behavior Observation-and annual Refmsher Training concurrent with General Orientation Retraining; 4.17.4 Developing all! . ss For Duty lesson plans and Annual Fitr'ess For Duty Retraining with subject matter experts from Psychological and Employee Assistance Services, Security, and others as required; 4.17.5 Scheduling all fitness for duty training programs; 4.17.6 Updating the Security Screer.ing Data System to reflect individuals completing fitness for duty training programs; 4.17.7 Maintaining master copies of the fitness for duty training lesson plans; 4.17.8 initiating issue Reports to Manager-Nuclear Quality Assurance when desigriated Behavior Observation individuals fail to attend or complete behavior observation training within 60 days and notifying Security Screening; 4.17.9 Ensuring revision of department unit task level Fitnass For Duty procedures are forwarded to the Fitness For Duty Program Manager; 4.17.10 Maintaining records as described in Section 13.2.11; 4.17.11 Providing instructors for fitness for duty training classes.

4.18 Random Coordinator is responsible for:

4.1 ? I 5+hting covered personnel for random testing for ' rugs and alcohol ihwugh computer programs at a rate of 100% of the work force; 41e/ Randomizing the time of day selected covered personnel report for testing; 4.18.3 Notifying Managers / alternates of covered personnel selected for testing; 4.18.4 Notifying, by letter, covered personnel of negative random test results; 4.18.5 Scheduling appointments with the Medical Review Officer for covered personnel who have confirmatory positive tests; 4.18.6 Notifying the Supervisor-Security Screening of covered personnel

who have confirmed positive drug and/or alcohol tests or who are l otherwise determined to be unfit for duty. This must be l accomplished prior to or simultaneously with notifying the individual; l

Revision 2 August 1991 Page 20

CALVERT CLIFFS NUCLEAR P' AR PLANT FITNESS FOR DUTY PROGRAM 4.18.7 Collecting and compiling Fitness For Duty Program Performance

- Data on Appendix 3 and submitting the form to the Calvert Cliffs Fitness For Duty Program Manager within 30 days of the end of each six month period; 4.18.8 Preparing a response to the NRC regarding the recordkeeping burden imposed by the Fitness For Duty Final Rule; 4.10.9 Conducting verification audit of covered personnel selected for random testing for drugs and alcohol against work records to help ensure compliance with the random selection testing program:

4.18.10 Upon notification by an Access Requester that a contractor or vendor with infrequent access is not available for testing, notify the Supervisor Security Screening to inactivate the protected area badge and notify the Fitness For Duty Program Administrator of the individual's name and Social Security Number; 4.18.11 Making notifications as required in Section 5.9.;

4.18.12 Ensuring revision of department unit task level Fitness For Duty procedures are forwarded to the Fitness For Duty Program Manager; 4.18.13 Maintaining records as described in Section 13.2.12.

4.19 Director-Purchasing and Materials Management Department (P&MM) is responsible for:

4.19.1 Ensuring adequate language in all Purchase Orders for labor and services to communicate BGSE's CCNPP/FFD policy and goals of a drug and alcohol-free work place; 4.19.2 Distributing current revisions of the " Contractor Requirement for Unescorted Access to the Calvert Cliffs Nuclear Power Plant";

4.19.3 Retaining Written Agreements with contractors and vendors as to their adherence to 10 CFR 26 and BG&E CCNPP/FFD requirements; 4.19.4 Furnishing to Supervisor-Security Screening a copy of each Written Agreement between the contractors / vendors and BG&E; 4.19.5 Obtaining from each contractor or vendor a plant site and home office point of contact (name, office, and home telephone number) and furnishing it to the Supervisor-Security Screening; 4.19.6 Obtaining from the contractor / vendor the name and social security number of his or her on site Supervisor (s) If npf,;icable (Supervisors for behavior observation under the requiremer.a of 10 CFR 26).

Furnishing the name and social security n ..nber to the appropriate Contract Administrator. Note: Some contractors and vendors may not have a Supervisor on-site, and in that situation, the BG&E Access Requester or Supervisor would aciume the behavior observation responsibility; Revision 2 August 1991 Page 21

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRNA 4.19.7 Ensuring that Purchasing and Material Management Department I (P&MMD) will notify the contractor that they will be required to identify individuals for Supervisor Fitness For Duty Training using the following phrases:

4.19.7.1 For Request For Quotations: i For the purpose of meeting NRC Rule 10 CFR 26 as it applies to unemical testing, the successful ef.,ntractor will ,

be required to furnish the name, home, and office telephone number of their principal point of contact working at Calvert Cliffs and at the home office, in addition, contractor is to identify to the Baltimore Gas and Electric Company, by full name and social security number, an appropriato number of individuals who will  !

receive BG&E Supervisors Fitness For Duty training and will act as behavior observers of their (and subtier) employees while they are working at the Calvert Cliffs plant. A minimttn of one individual per work crew, unit, group, project or contract shculd be trained so that the behavior observer can periodically observe each individual. Contractor will promptly notify the appropriate BG&E Contract Administrator with the full name and social security number of the replacement behavior observer when their trained behavior observer leaves the site for an extended period or if their unescorteJ access is terminated.

l 4.19.7.2 For Purchase Cders:

In addition, contractor is to identify to the Baltimore Gas and Electric Company, by full name and social security number, an appropriate number of individuals who will receive BG&E Supervisor Fitness For Duty training and will act as behavior observers of their (and subtier) employees while they are working at the Calvert Cliffs plant. A j minimum of one individual per work crew, unit, group, project, or contract should be trained so that the behavior observer can periodically observe each individual.

Contractor will promptly notify the appropriate BG&E l

Contract Administrator with the full name and social security number of the replacement behavior observer when their trained behavior observer leaves the sit

• r an extended period or if their unescorted access is terminated.

4.19.8 Ensuring that Purchasing and Materials Management notes all requests for quotations (RFO's), Purchase Orders, and contract / agreements issued by Purchasing and Materials

Management Department for the performance of unescorted work or service inside the Protected Area as quoted in 4.19.7.1 or 4.19.7.2, as appropriate; Revision 2 August 1991 Page 22

CALVERT CLIFFS NUCLEAR POWER PLAMT FITNESS FOR DU1Y PROGRAM 4.19.9 Ensuring that Purchasing and Materials Management forwards the contractor's/ vendor's full name and social security number to the appropriate Co-+ract Administ:ator or responsible Supervisor; 4.19.10 Ensuring re' i department unit task level Fitness For Duty procedures , rorwarded to the Fitness For Duty Program Manager; 4.19.11 Maintaining records as described in Section 13.2.13.

4.20 Supervisor-Emergency Planning is responsible for:

4.20.1 Informing Security Screening and Technical Training of covered personnel and other Individuals reporting to the EOF and Media Center who are identified with responsibilities under the Calvert Cliffs Nuclear Power Plant Emergency Response Plan to facilitate compliance with ad requirements under the Fitness For Duty Program; 4.20.2 Ensuring that individuals occupying positions identified in Appendix 1, as appropriate, attend the required fitness for duty training; i

l 4.20.3 Ensuring revision of department unit task level Fitness For Duty L procedures are forwarded to the Fitness For Duty Program Manager; .

4.20.4 Maintaining records as described in Section 13.2.14.

4.21 Operational Support Center (OSC) and Emergency Operation Facility (EOF)

Directors, and the Media Center (MC) Technical Advisor are responsible for:

4.21.1 Determining if or when on Emergency Response Plan call-in member who has consumed alcotol and/or has registered a Blood Alcohol Content of 0.04% or grea:er (as indicated by Breathalyzer readings) l-can remain a member of he work force because of position criticality.

j Where such individuals s.re critical to the operation, the OSC Director, i

EOF Director, or the MG Technical Advisor (in the Lbsence of the Individual's Supervisor / behavior observer) will identify a responsible individual to escort the Response Plan member at all times during his/her work.

4.22 Access Requesters 1

are responsiHe for.

4.22.1 Serving as liaisons for BG&E to coordinate and integrate contractor / vendor personnel and their Supervisors into all aspects of the FFD Program; Revision 2 August 1991 Page 23

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y FROGRAM 4.22.2 Completing the Access Request Form to indicate:

4.22.2.1. That the individual needs Supervisor Fitness For Duty Training 4.22.2.2 The name of the individual who will be responsible for behavior observation (BG&E or contractor) 4.22.3 Ensuring contractor and vendor personnel and their site Supervisors have received appropriate fitness for duty training; 4.22.4 Notifying contractor and vendor personnel of selection for Random testing; 4.22.5 Notifying the contractor / vendor individuals of the MRO's offer for an interview concerning alcohol and/or drug test (s). The Access Requester will complete Appendix 6; 4.22.6 Ensuring that unbadged contractor / vendor Fitness For Duty Supervisors complete Supervisor Fitness For Duty Training prior to assignment of duties (supervising behavior observation) under this Piogram. Badged individuals newly appointed as Supervisors for fitness for duty must complete the training within 60 days of the appointment:

4.22.7 Ensuring that BG&E fitness for duty trained Supervisors observe contractor / vendor personnelin the absence of a contractor / vendor trained individual; 4.22.8 Acting as behavior obsetvers pending on site contractor and vendor Supervisors completing Supervisor Behavior Observation Training; l

l 4.22.9 Ensur'n2 the availability of BG&E FFD-trained Supervisors to observe contracton, and vendors in the absence of trained contractor / vendor Supervisors; 4.22.10 Conducting, as appropriate, behavior observation of contractors and vendors to datect degradation in performance, impairment or L changes in an individual's behavior which could impact or' their I

fitness for duty; 4.22.11 Advising the Random Coordinator of the expected return date of

contractors and vendors (if known)If they were selected for random l testing and were absent from the plant (see infrequent Access);

l 4.22.12 If a sen%< :omractor or vendor on-site or Headquarters contact -

person cav.at be ce".' acted within one-hcur of not ce of an event, the BG&E Supervisor or Access Requester will obtain permission of a General Supervisor or higher to direct contractors and vendors to submit to for-cause urine and alcohol tests. If they are unable to contact a General Supervisor or higher, they will have the contractor removed from the Protected Area; Revision 2 August 1991 Page 24 .

OALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 4.22.13 Attending Supervisor Fitness For Duty Training within sixty (60) days of becoming an Access Requester-4.22.14 Ensuring that the Supervisor's Fitness For Duty Behavior Observation Verification Report is updated on a monthly basis and returned to Security Screening, who then forwards it b Technical Training.

4.23 BG&E Supervisors are responsible for:

4.23.1 Conducting, as appropriate, Behavior Observation of covered personnel to detect degradation in performance, impairment or changes in an individual's behavior and completing Supervisor Behavior Observation Reports (Appendix 5), and forwarding the original to the MRO in a confidential manner; 4.23.2 Ensuring that appropriate unit and contractor / vendor personnel attend required fitness for duty training Non-badged, off site supervisors of badged employees are required to meet supervisor training requirements; I

4.23.3 Understanding his/her role and responsibilities in implementing the Fitness For Duty Program; 4.23.4 Recognizing drugs and indications of the use, sale, or possession of drugs and abuse of legal and over-the-counter drugs; 1

4.23.5 Understanding the roles and responsibilities of Calvert Cliffs Fitness l For Duty Program Manager, Employee Services, Safety and Medical

. Services, Psychological and Employee Assistance, Nuclear Quality Assurance, Nuclear Support Services, Technical Training, Security Screening, and the MRO; 4.23.6 Ensuring that contractor and vendor personnel are fit for duty, drug and alcohol-free, and free from physical or mental factors such as mental stress, fatigue or illnesses which could impact their fitness for duty during regularly scheduled work tours; 4.23.7 Attempting to discern if there is reasonable suspicion to believe that l

off-duty individuals involved in official work-relatad conference calls, or individual calls, are not fit for duty in rendering information, or making decisions based on the informr,!on received from these I individuals; 4.23.8 Obtaining a statement using Appendix 4 from each person who j responds to a call-In. If necessary, request consultative assistance L

from the Supervisor-Psychological and Employee Assistance l

Services to help make the determination of whether covered personnel are fit to respond. Reasonable effort should be made to l

identify another individual for the call-in who is alcohol free; Revision 2 August 1991 Page 25

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l CALVERT CLIFFS NUCl. EAR POWER PLANT FITNESS FOR DU1Y PROGRAM \

4.23.9 Taking appropriate action in the case of observed behavior changes or deficiencies (through Behavior Observation) (Appendix 5) which may require referral to Employee Medical Assistance Services (for employees) or to their employer (for contractors / vendors);

4.23.10 Ensuring that newly (unbadged) appointed Supervisors (BG&E or contractor / vendor) within their purview complete Fitness For Duty Supervisor Training prior to assignment of duties (supervisory behavior observation) under the Fitness For Duty Program; 4.23.11 Ensuring that BG&E behavior observer trained Supervisors observo contractor / vendor personnelin the absence of trained contractor / vendor observers; 4.23.12 Ensuring that badged Supervisors within their purview or who will observe individuals with unescorted access complete initial and annual Supervisor Fitness For Duty Behavior Observation Training, Supervisor's initial training should be completed within 60 days of the notice of designation / promotion to Supervisor; 4.23.13 Referring covered personnel to Safety and Medical Services Department for fitness for duty examinations, and complete Supervisor Behavior Observation Report (Appendix 5);

4.23.14 Filing the Call-ln Reporting Checklist (Appendix 4);

4.23.15 Completing the Random Selection Form (Appendix 2) for individuals selected for random testing as required; 4.23.16 Ensuring that Purchasing and Materials Management notes all requests for quotations (RFO's), Purchase Orders, and contract / agreements issued by Purchasing and Materials Management Department for the performance of unescorted work or service inside the Protected Area as quoted in 4.19.7.1 or 4.19.7.2; 4.23.17 Maintaining records as described in Section 13.2.15; 4.23.18 If a senior contractor or vendor on-site or headquarters contact -

person cannot be contacted within one-hour of notice of an event, the BG&E Supervisor or Access Requester will obtain permission of a General Supervisor or higher to direct centractors and vendors to submit to for-cause urine and alcohol tests. If they are unable to contact a General Supe visor or higher, they will have the contractor removed from the Protected Area.

4.24 Employees are responsible for:

4.24.1 Understanding and complying with the BG&E CCNPP/FFO Program, its policies and procedures, and the methods to implement the program; Revision 2 August f Y Page 26

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 4 24.2 Notifying their Supervisor when they believe they are affected by physical or mental factors such as rnental stress, fatigue or illness which could impact on their fitness for duty during regularly scheduled work tours and/or when responding to call-in requests; 4.24.3 Notifying their Supervisor when their physical or mental condition caused by the use of prescription and over-the-counter drugs is such that they may be unfit for duty; 4.24.4 Advising a caller on official work-related business that they are not fit for duty to make decisions or respond to caller's questions. This statement is warrarded during all official calls relating to work at Calvert Cliffs; 4.24.5 Attending required fitness for duty training and retraining; 4.24.6 Reporting to work fit for duty; 4.24,7 Not having in their possession alcohol or illegal drugs valle on BG&E properly; 4.24.8 Not using alcohol in an abusive way which affects job oerformance, nor consuming it within five hours preceding any scheduled work tour or during working hours; 4.24.9 Reporting any alcohol consumption (within the preceding Ove (5) hour period) and any other physical or mental factors which could impact on their fitness for duty when receiving call-in reques:s from Supervisors for work at Ca! vert Cliffs Nuclear Power olant; i

l 4.24.10 Notifying supervision of all arrests and convictions that may impact i

upon his/her trustworthiness and reliability; 4.24.11 Referring themselves to Psycheogical and Employee Assistanco Services when they believe they have a problem that may make it-unsafe to work within the protected area; 4.24.12 Reporting any perceived fitness for duty problems or incidents of theirs or othera to their Supervisor or to Nuclear Security supervision, as appropriate to assist in achieving a safe and drug free workplace; 4.24.13 Completing Supervisor Fitness For Duty Training prior to assignment of supervisory duties (behavior observation) under this program if not currently possessing unescorted access. Official behavior observation can not be accomplishe:f until the individual has completed supervisor training; 4.24.14 Completing Supervisor Fitness For Duty and Behavior Observation

[

Training within 60 days of the notification of promotion / designation to l Supervisor if they already possess unescorted access; i

!. 4.24.15 Acting as escorts for persons not badged for unescorted access as i described in Section 4.26; I

t Revision 2 August 199i Page 27 l

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM r

4.24.16 Understanding that the effects of an overindulgence of alcohol may 1 carryover to within the five hour abstinence period as well as into the scheduled work period and impair the individual's ability to perform his or her work in a safe manner.

4.25 Contractors and Vendors are responsible for adherence to BG&E's CCNPP/FFD Program, including:

4.25.1 Understandi;g and complying with the CCNPP/FFD policies, requircments and procedures and the methods to implement the  ;

program, 4.25.2 Notifying their Supervisor and/or Access Requester when their physical or mental condition is such that they may be unfit for duty; ,

4.25.3 Attend:ng required fitness for duty training and retraining; i

4.25.4 Reporting to work fit for duty; 4.25.5 Not consuming or having in their possession any illegal drugs or ,

alcohol white on BG&E property; 4.25.6 Not using prescription drugs in any way which affects job i

. performance;  ;

4.25.7 Not using alcohol in an abusive way which affects job performance, nor consuming it within five hours preceding any scheduled work tour at Calvert Cliffs Nuclear .>ower Plant and or during working hours; e

4.25.8 Reporting any alcohol consumption (within the preceding five (5) hour period) and any other physical or mental factors which could impact on their Fitness for duty For Duty when receiving call-in

• requests from Supervisors for work at Calvert Cliffs Nuclear Power Plant; 4.25.9 Advising a caller on official work-related business that they are not fit for duty to make decisions or respond to caller's questions. This e statement is warranted during all official calls relating to work at Calvert Cliffs; ,

4.25.10 Completing required testing (alcohol / drug) and providing voluntary i specimens, as required; 4.25.11 Referring themselves to their site Supervisor, Access Requester, or  :

i their employer's assistance program point of contact when they

believe they have a FFD problem that may make it unsafe to work within the protected area

4.25.12 Acting as escorts for persons not badged for unescorted access as described in Section 4.26.; ,

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Revision 2 August 1991 Page 28

CRLVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 4.25.13 Attending Supervisor Fitness For Duty (Behavior Observation)

Training,if applicable, within 60 days of the notification cf the

- designation of Supervisor for fitness for duty purposos. This applios to individuals already possessing unescorted access; 4.25.14 Informing their appropriato level of supervision no later than the beginning of their next scheduled base tour if their vehicle driver's license has been confiscated, susponded, or revoked as a result of alleged driving while intoxicated or under the influence of alcohol, This applies only if BG&E or private vehicles are operated for BG&E business; 4.25.15 If required, designate individuals to receive Supervisor Fitness For Dut'; Training and act as behavior observers of contractor and sub-tier contractor individuals prior to assuming behavior observation duties; 4,25.16 Notifying supervision of all arrests and convictions that may impact l upon his/her trustworthiness and reliability. l

[ l 4.26 Escorts (ProtectsdNital Areas) are responsible f or: l l

4.26.1 Recelting required fitness for duty training, including escort training; l

4.26.2 To the best of their ability, employing methods for recognizing drug abuse n the work place, including indications of the use, misuse, L

sale, or possession of drugs, and reporting these observations to Supervisors; 4.26.3 Recognizing, to the best of their ability, aborrant behavior, and reporting suspected problems to Supervision and/or Security, as applicable.

Revision 2 - August 199f Page 29

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CALVERT CLIFFS NUCl EAR POWER PLANT FITNESS FOR DUTY PROGRAM ,

t 5.0 Operationai Policies and Procedures 5.1 General Section 5.0 describes procedures used in meeting NRC requirements for fitness for duty programs specific to BG&E covered personnel who have unescorted ,

access to Calvert Cliffs. For specific procedures pertaining to Calvert Cliffs contractor and vendor personnel, see Section 7. ,

5.1.1 Prior to granting initial unescorted access to the protected area, ,

Security Screening will obtain a written statement from the individual as to whether unescorted access has over been denied by any licensee or other employment in accordance with a fitness for duty i program.

5.1.2 BG&E's Fitness For Duty Policy, as it applies to alcohol, maintains that all covered personnel subject to the NRC Rule are prohibited from consuming alcohol within an abstinence period of at least five hours preceding any scheduled working plant tour and during working hours. ,

5.1.3 Supervisors are to be constantly alert for any circumstances whicn raise questions about an individual s fitness for duty, and must act prompt!y to remove the employee from the job. Supervisors should contact the MRO in Safety and Medical Services Department for advice on beiderline situations. -

5.1A Fitness for duty examinations, pre-access testing, for-cause testing, follow-up testing and random testing are considered a work assignment. If an individualis unavailable due to any of the following listed reasons, it shall be considered an approved excuse for not participating in random or follow-up drug and alcohol testing. If the individual is away from work at the time of notification, approved reasons include, but are not limited to:

illr'ess or injury Approved personal time off Approved RX time off  :

- Vacation Military training or reserve duty

' Jury duty Leave of absence Company or personal choice holiday ,

Training off company properties  ;

Company business outside State of Maryland  ;

- Absence due to normally scheduled off day I

j Refusal by an individual to submit to any part of a fitness for duty examination, for-cause, follow-up, or random testing for drugs and ,

alcohol or any attempt by covered personnel to influence drug and alcohol test results will lead to denial or revocation of unescorted access. Refusal by an employee to submit to random, for-cause, follow-up testing or a fitness for duty examination will also result in disciplinary action up to and including discharge.

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I Revision 2 August 1991 Page 30 l:

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l CALVERT CLIFFS NUCLEAR POWER l'LANT FITNESS FOR DUTY PROGRAM l

! 5.1.5 When a drug or alcohol test performed on an employoo is a confirmed positivo, the MRO notifies the Manager of Employoo Services, the operating Department Manager and the Random Coordinator. The Manager of Employoo Solvices and the operating Dopartment Manager w;!! determine the appropriate disciplinaly action up to and including discharge.

5.1.6 When a drug or alcohol test performed on a contractor is a confirmod  !

positivo, the MRO notifies the operating Department Manager and '

the Random Coordinator. The Random Coordinator will notify l Security Screening. A contractor's employment decision is made by ,

the contractor's employer.

5.1.7 Personnel responsible for administering the testing program (e.g.,

collection facility persons, laboratory technicians, Medical Review  !

Officor, Random Coordir:ator) shall be carefully selectod and I monitored to ensure the highest standards of honesty and intogrity. j l At a minimum, BG&E williollow the Guidelines for Nuclear Power l l Plant Drug and Alcohol Testing Programs, as contained in 10 CFR 26 i and Appendix 7.  ;

i 5.2 Procedure For Behavior Observation (BO) 5.2.1 Supervisors and Accors Roquesters have the primary responsibility  ;

l for implementing this procedure. Additionally, covered personnel j assigned escort duties in the protected area are responsible for  ;

observing covered personnel and visitors entrusted to them. i 5.2.2 Based on Behavior Observation, Supervisors may refer company I employees for Employee Medical Assistanco Services,if appropriate.

Contractors will be referred to their employer.

5.2.3 Any individual must notify Nuclear Security and his or her Supervisor upon discovery of drugs, drug paraphernalia, or alcohol on Company property, ll

$24 Responding To Unusual or Aberrant Behavior Ah indMdual who observes unusual or aberrant behavior must report ,

R to Supcrvision.

l Upon receiving a report of or observing an individual exhibiting unusual /aborrant behsvior, the Supervisor will-

1. l t.2.4.1 Remove the individual from the work assignment.

5.2.4.2 Discuss with the individual the reported or observed i behavior, asking the individual for an explanation of the j behavior.

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i Revision 2 August 1991 Page 31 l

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 5.2.4.3 Consult with the Manager-Safety and Medical Services or the physician alternate if circumstances raise questions about the individual's fitness for duty. The Manager-Safety and Medical Services will confer with the Manager-Employee Services and the Manager of the operating department. If it has been determined there is a need for a fitness for di'ty examination, the individual's Supervisor or employer reprosentative will escort the individual to Safety and Medical Services Department for a fitness for duty examination.

5,2.4.4 Document any observed or reported unueual or aberrant behaviors on the Supervisor Behavior Observation Report (Appendix 5) and forward to the MRO, who will annotate it and subsequently forward to the Supervisor-Security Screening in a confidential manner.

5.2.4.5 Contact Supervisor-Security Screening or if that office is closed, the Security Shift Supervisor to suspend unescorted access,if appropriate.

5.2.4.6 If the Medical Office is closed, contact the on-call Medical Services person or Staff Physician who will cdvise the E apervisor on the appropriate action and,if necessary, waere the individual can be taken for testing. Refer to the Emergency Notification List contained in the company phone book.

5.2.4.7 If the Manager-Safety and Medical Services Department or Staff Physician orders testing at an off-site facility, document where the individual was taken, at whose direction, and the name of the escort / driver, as applicable.

5.2.5 The Supervisor will review with the Depadment Manager and/cr Access Requester the referral of the covered personnel for a fitness for duty examination.

5.2.t. Supervisors and Access Requesters after observing and documenting unusual behavior in contractois and vendors will forward the original of the Supervisor Behavior Observation Report to the MRO in a confidential manner who will annotato it and forward it to the Securi./ Screening Unit.

5.3 Fitness For Duty Examinations 5.3.1 Supervisors have the primary responsibility for implementing this procedure, including monitoring their personnel w nugh Behavior Observation to ensure they are fit for duty.

5.3.2 BG&E Supervision may identify those contractors and vendors requiring fitness for duty examinations.

Revision 2 August 1991 Page 32 '

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PPOGRAM 5.3.3 Upon referral of a worker for a fitness for duty examination, BG&E Medical Director will make the determination as to those physical and mental examinations to which the worker will be required to submit.

5.3.4 BG&E Safety and Medical Serviene will conduct employee fitness for duty urine collection and alcohol testing on-site in accordance with the provisions in References 16.23,16.24,16.25 and 16.27. The Random Coordinator will notify Security ScreerCng of any covered personnel suspected to have violated any provision of the Fitness For Duty Program. Security Screening willimmediately suspend the unescorted access of that individual pending further evaluation.

5.3.5 When the MRO confirms that the employee has violated policies prohibiting the use of alcohol or drugs as set forth in this policy, the Manager-Employee Services shall be notified. The Manager-Employee Services and the employee's Department Manager will confer and determine if there is any reason not to discharge the employee immediately. Where the two Managers agree that discharge is consistent with this policy, the Department Manager or alternate will inform the employee that he or she is being discharged.

The Medical Review Officer willinform the Random Coordinator of the confirmed positive test; the Random Coordinator will notify Security Screening.

5.3.5.1 When a drug or alcohol test is performed on a contractor and is confirmed positive, the MRO notifies the Department Manager and/or representative and the Random Coordinator who, in turn, notifies Security Screening, who will then notify the contractor's Supervisor /

l Access Requestor of the final determination.

L 5.3.6 The refusal of an individual to submit to a, f por' ion of a fitness for duty examination will be referred to the Manager-Safety and Medical Services and the employee's Manager, at which time the employee will be suspended pending a discharge conference. Refusal will be recorded as removai 'for-cause" (Appendix 3), and will result in loss of unescorted access.

5.3.7 Following the discharge conference, the Department Manages or alternate will notify Security Screening of the results. Security Screening will take appropriate action, based upon the results of the discharge conference for employees, to reinstate or termina'e the unescorted access of that Individual.

. 5.3.8 Security Screening shall maintain Supervisor Behavior Observation Reports (Appendix 5) and documentation of action taken in the inciividual's personal security file.

5.3.9 in the event of a determination that the individual is fit for duty, the Department Manager will review the Supervisor Behavior Observation i Report with the individual's Supervisor and attempt to determine whether the matter constitutes a performance problem.

L Revision 2 August 1991 Page 33

CM. VERT CLIFFS NUCLEAR POWER PL ANT FITNESS FOR DUTi PROGRAM 5.4 For Cause Drug and AlcoholTesting 5.4.1 For-cause drug and alcohol testing is conducted upon the direction of the Managor of Safety and Medical Sorvices following a referral by a Supervisor, Access Roquestor, an individual, a contract administrator or oscort following degradation of porlormance or other

! Indicators which may raise concerns about the individual's fitness for duty.

l 5.4.2 BG&E Safety and Medical Services Department will conduct for-  !

cause urine drug and alcohol testing on. site of ecvored personnelin j accordance with reforonces identified in References 16.23,16.24, l 16.25 arid 16.27. If a need "for-cause" testing is demonstratsd, the Manager-Safoty and Medical Services will advise the Supervisor where the person should be taken for the evaluations.

The Supervisor (or alternato if deemed necessary) escorts the individual to tno testing facility.

Urine spor; men collection in accordance with Reference 16.23 is conducted where the need is indicated by medical history and physical examination.

- Alcohol testing is administered in compliance with Reference 16.25 where the need is indicated by medical history and physical examination.

l 5.4.3 For-cause urino drug screens, whether positive or negativo, will be l sent to the cortified testing laboratories, as appropriato, for further testing and confirmation.

!- 5.4.4 The MRO will notify the Random Coordinator and the Manager of Safety and Medical Services of presumptive positive urine drug tests;

- the Random Coordinator will notify Security Screening.

5.4.5 The Mariager-Safety and Medical Services will contact the Manager-Employeo Services, and a final decision on the disposition of the employee will not be made until a confirmed positive test result is received.

5.4.6 To initiate a for-cause ntness for duty test or examination during L backshifts and weekends, Supervisors and Access Roquesters will l

refer to the BG&E telephone diroctory (see Emergency Notification List Medical Services) for the phone numbers of the Medical Service physicians.

5.5 - handeni Testing For Drugs and Alcoho!

5.5.1 The Random Coordinator-Safety and Medical Services Department is responsible for the random selection of indiviouals to ensure a 100%

random testing rate for drug and alcohol testing at a rate equal to at least 100% of the work force. The test (s) must be administered so that an individual completing a test is immediately eligible for another

, unannounced test.

l Revision 2 August 1991 Page 34 l

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DULY PROGRAM l

5.5.2 The Random Coordinator will notify the Department Manager or i

attornate of covered personnel assigned to the Departmont who havo boon selected for random testing for drugs and alcohol and the time l they are to report to the collection facility.

5.5.3 The Manager of tho individual solocted will notify the individual's Superv!sor that the individualis to be tested. The Manager will notify the Access Roquester for those contractor or vondor personnot selected for random testing. Participation in random testing for drugs and alcohol is mandatory unless the individual meets the approved reasons in Section 5.1.4.

L 5.5.4 The Random Coordinator will record the namos and reasons for each

! individual solocted for randone testing for drugs and alcohol, who, for whatever reason are not lostod, and will verify through a review (audit) of Corporato documents to discern any impropriotios. The Access Roquestors and/or behavior observation supervisors will be periodically surveyed to verify and corroborate the reasons given as to why contractor individuals were not available for testing. The Random Coordinator will periodically review tost selection and response to ensure enough individuals have been tested to moet the 100% rate requirement.

i 5.5.5 Supervision will direct each individual to report to the collection I facility for testing as soon as possible, but no later than one (1) hour following the Supervisor's notification. The Supervisor will indicate to which collection facility to report by giving the individual a copy of the r Random Selection Form (Appendix 2) with the facilihJ noted on the reverse side. Supervisor must sign and note time individual was notified on appropriate lines of Random Selection Form. Individuals must bring appropriate identification to the collection facility as indicated in Section 5.8.2.1.

5.6 Follow up Testing 5.6.1 Follow-up testing at unannounced intervals is designed to ensure that an empicyee who has self-referred or been referred for medical l

assistance and has boon tested for substanco abuse by BG&E is maintaining abstinence from the use of drugs or abuse of alcohol.

5.6.2 BG&E Safety and Medical Services Department will conduct l

individual follow-up urino drug collection and alcohol testing in l

accordance with References 16.27 and 16.25.

5.6.3 The Manager-Safety and Medical Services Department will maintain a I.

list of employees with unescorted access or otherwise covered by L

CCNPP/FFD who have participated in substance abuse rehabilitation programs.

t 5.6.4 The Manager-Safety and Medical Services Department will be l

responsible for the frequency and selection of follow-up drug testing of the employees identified in Section 5.6.1.

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Revision 2 August 1991 Pago 35 L_

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM 5.6.5 Supervision will direct each employee to report to the collection facility for testing within one hour of notification. Individuals must bring appropilate identification to the collection facility as indicated in Section 5.8.2.1.

5.6.6 The collection facility person will collect urine specimens as indicated in Section 16.23. Alcohol testing, where necessary, will be administered as Indicated in Reference 16.25.

5.6.7 Results of follow-up drug testing will be evaluated in accordance with 5.9.

5.7 Pre-Access (Pre-Badging) Testing 5.7.1 Pre-Access alcohol and drug testing is administered as part of the access authorization process.

5.7.2 Allindividuals seeking unescorted access to Calvert Clifft Nuclear Power Plant must successfully complete drug and alcohol testing no more than 60 days prior to initial granting of unescorted access.

Security Screening v.ill refer all individuals applying for unescorted access to the collection facility to provide urine specimens and undergo alcohol tests prio'r to granting unescorted access Urine specimens will be collected as indicated in Reference 16.23.

5.8 Procedures For Urine Collection and AlcoholTesting 5.8.1 General

[ At a minimum, procedures for urine collection and alcohol testing will lJ comply with policies, practices and guidelines as specified in the L CG&E Urine Ccilections Procedures Manual; BG&E Forensic Blood Alcohol Collection Procedures Manual; BG&E Breath Alcohol Testing Standard Operating Procedures Manual; and NRC Guidelines.

Collection facility personnel shall not conduct alcohol analysis or urine specimen collections on their relatives, co-workers, or Supervisors.

5.8.2 Preparation 5.8.2.1 For all drug and alcohol testing, individuals must bring to the collection facility:

BG&E photo identification card (Calvert Cliffs photo identification card in the case of contractors and vendors);

or Driver's license (or acceptable alternative);

w amployer's representative and Social Security number (card not required);

Revision 2 August 1991 Page 36

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM Where the individual lacks an appropriate picture identification card, the individual's employment representative may be used to provide positive identification of the Individual reporting for testing. The individual's employment representative must b3 identified with photographic identification.

5.8.2.2 The individual will report to the designated collection facility and complete a consent / release form and undergo drug and alcohol testing in accordance with these and referenced procedures.

5.8.2.3 Collection facility personnel wN collect urine for drug testing by a certified laboratory and perform alcohol testing on-site during the same visit to the collection facility.

5.8.2.4 If an individual falls to participate in any portion of the urine collection and alcohol testing regimen, the collection facility person will advise the MRO who, in turn, will make the required notifications. The collector will advise the individual to remain at the collection facility. In the event the individual departs the area without completing the drug testing process, the collector will notify Nuclear Security to inactivate the individual's badge.

5,8.2.5 The collection facility person will follow all procedures referenced in this program necessary to assure absolute accuracy of testing results. Further, the collection facility person will strictly adhere tc procedures necessary to maintain an inviolable chain-of-custody of the specimen provided by individuals selected for testing.

5.8.2.6 The collection f acility person will review the items specified in Section 5.8.2.1 to verify the identity of the individual present for testing. 'ihe collection facility person will retain the photo identification card to confirm information until processing has been completed.

5.8.2.7 The collection facility person will request the individual read and complete the following forms: Consent / Release Form and Che-of-Custody (COC) Form 5.8.2.8 Tm collection facility person will give the individual an yportunity to list all prescription and over-the-counter medications that have been taken within the last thirty (30) days, 5.8.2.9 The collection facility person will conduct urine specimen collection and alcohol breath analysis using appropriately calibrated equipment as descr*ed in Reference 16.25.

Revision 2 August 1991 Page 37 l

. .1

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTV PROGRAM 5.8.3 Urine Specimen Collection for Drug Testing Procedure In accordance with procedures referenced in Section 16.23, collection facility personnel will instruct the individual to:

5.8.3.1 Remove any unnecessary o.Jter garments, such as coat or jacket, and empty contents of pockets before entering the bathroom. The individual may retain wallet and loose money.

5.8.3.2 Wash and dry hands prior to urination.

5.8.3.3 Fill container with at least 60 cc of urine.

5.8.').4 Give the specimen to the collection facility person within four (4) minutes to ensure a valid specimen.

5.8.3.5 When the individual returns the specimen, Safety and Medical Services Department will perform visual examination and temperature testing of the specimen to determine whether tampering has occurred.

5.8.3.6 11 there is evidence of tampering, the individual will be asked to submit a second specimen, observed by a culection facility person of the same gender. (A higher level medical person must approve any observed specimen collection.)

5.8.3.7 When the collection facility person is certain that no i tampering has occurred, the collection fac5ty person will I then seal the specimen with the chain 4 custody signed adhesive seals.

5.8.3.8 The collection facility person will then allow the individual to wash his or her hands, return the individual's photo identification card, answer appropriate questions posed by the individual, enter the specimen into the tracking system .

5.8.3.9 Specimens will be transported to a certified laboratory, maintaining the chain-of-custody.

5.8.4 Alcohol Testing Procedure 5.8.4.1 Alcohol testing (two tests) will be performed using breath alcohol test equipment. A second confirmatory test will be .

conducted on a different breath measurement instrument if the first breath alcohol test indicates a blood alcohol concentration of 0.04 percent or greater, if after two breath alcohol tests the level is determined to be 0.04 percent or greater, the individual may request a confirmation of the tests by a gas chromatography analysis of blood. -

Revision 2 August 1991 Page 36

CALVERT CLIFFS NUCLEAR POWER PLANT FITNEV FOR DUTY PROGRNA 5.8.4.2 Safety and Medical Servicos Department will complete the random testing for drugs and then notify the Manager-Employee Services and the Random Coordinator if the alcohol test was positivo. (Following notification by the  ;

Managor-Safety and Medical Services Departmont, the Supervisor-Security Screening will notify the Access Requestor in the case of a contractor or vendor.) The Manager-Employoo Services will contact the individual's Manager and instruct the Manager to make arrangements to escort the individual off-site or take the individual home, following completion of the random testing for drugs and alcohol. Reasonable efforts will be made to ensure that individuals determined to be unfit for duty are not permitted to drive themselves from the plant site, 5.8.4.3 The Supervisor-Security Screening will suspend or revoko unescorted access as the situation dictates.

5.8.4.4 The Manager Employeo Services will notify the employee's l Manager to initiate appropriate discip!inary measures, in l the case of an employee. For enntractors, the Supervisor- )

Security Screening will notify the individual's Access Requester. Security Screening may olnstate unoscorted access depending on the results of the fitness for duty examination.

5.8.4.5 If the alcohol breath analysis test shows the presence of alcohol at less than 0.04 percent and the individual 1- exhibits aberrant behavior:

The collection facility person will seek direction from Safety and Medical Services Department or the Medical Review Officer.

- Safety and Medical Services Department will determine i the individual's fitness for dJty and will notify the Manager-l Employee Services in the case of an employee. The l Manager-Safoty and Medical Services will notify the Random Coordinator, who will notify Security Screening to suspend or terminate the individual's unoscorted access, as appropriate. The Supervisor-Security Scrooning will notify the Access Requester of the determination.

L The Manager-Employoo Services will contact the individucl's Manager and instruct the Manager to make arrangements to take the individual off-site or home following completion of the random tests for drugs and alcohol. .he Supervisor-Security Screening will notify the Access Roquestor to remove the contractor /vondor from  :

the site. j i

Revision 2 August 1991 Page 39

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 5.9 Notification of Drug and Alcohol Results 5.9.1 The Medical Review Officer will review the results of all tests, both negative and positivo.

5.9.2 Random Coordinator will recolvo ali drug tosting results and will filo and maintain all reports.

5.9.3 The Medical Review Officor, following proceduros dota' lod in the National Institute on Drug Abuse Medical Review Officer Manual, will offer to interview all individuals with confirmatory positive tests and determino those which constituto a confirmed positive test.

5 9.4 The Medical Review Officer will notify the Manager-Safoty and Medical Services immediately of any individuals with coni.rmed positivo drug and alcohol test results. The Manager-Safety and Medical Sorvices will, in turn, notify the Managor-Employoo Services in cases involving employoos and the Random Coordinator.

5.9.5 The Random Coordinator will notify Security Scrooning immediately of any confirmed positivo drug anc' alcohol test results. This must be accomplished prior to or simultaneously with the individual's notification of his or her unoscorted access denial or revocation. (For notification procedures for contractors and vendors testing positivo, see Section 7.9.)

5.9.6 The Random Coordinator will notify by mail within fivo (5) work days ,

all covered personnel whose drug test results are negativo and will  :

l send notifications of positive '9sts within 30 days to the last known address in accordance with the Maryland Stato Notification Law *

(Hoalth Articio of the Maryland Annotated Codo Section 17-214.1(c)). ,

5.10 Call in Notifications 5.10.1 A call-in is overtime for which notico to report was given to the employoo after the end of his or iier last period of timo reported as Work Time or Time Off (other than Vacation), provided that at the time the notico was given, the employoo was not already on Company prombos awaiting the start of the next schoduled starting time, i l 5.10.2 Consumption of alcohol during the abstinence period shall not, by

( itself,~ proclude use of an individual needed to respond to an

! omergency provided tnat the individual judges him or horself to be fit .

L for duty.

• i 5.10.3 Supervisors, upon calling covered personnel to romort for an i

unscheduled working tour, must ask the individuai if he or she has consumed alcohol within the five (5) hour pre duty abstinenco porlod.

, Additionally, Supervisors should inquire if the individual is froo ' rom L physical cr montal factors such as mental stress, fatiguo, or illnessos l which could impact on safety and his or her fitness for duty when responding. Supervisors will complete Appendix 4.

l l

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Pavision 2 August 1991 Page 40 7

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CALVER) CLIm' uGC!, EAR POWER PLANT FITNESS FOR DUTY PROGRAM 5/i0.3.1 if the inJividual responds affirmatively to questions .

i reg'arding the consumption of alcohol, but feels ho or she

- is iit for duty, the Supervisor should ask the individual to report to:

. . Medical for a breathalyzer test if during hours (Monday through  !

Friday /6 AM 10 PM)

}

- _ Nuclear Security Shift Supervisor (NSSS) for a broathalyzer test if

- during evening, night or weekend hours, j NOTE: The Supervisor will contact the NSSS to notify him/her of the 1 Individual's need for a breathalyzer test.

7 The General Supervisor-Calvert Cliffs Security Operations will ensure f trained security personnel conduct the tests in accordance with l BG&E Breath Alcohol Testing Procedures (Reference 16.25),if no collection personnel are available.  ;

-1

- The NSSS will r.otify the Supervisor / escort immediately of any j positive test result and instruct the Supervisor to mako arrangements '

a to send the ind;vidual home, 5.10.3.2 If the individual responds affirmatively but feels he or she f is unfit for duty, the Supervisor should tell the individual  ;

not to report to work. Supervisors should keep records, consistent with tVr Department's practices, cf individuals who repeatedly clan to be unable to respond to call in l

due to alcohol use; ptterns should be reviewed for i W possible Disciplinary Aunn or rcferral to Medical for  !

fitness for duty examinatior,. -

5.10.3.3 tif the individual's response is negative to both the use of alcohol and other physical and mental factors which  ;

include mental stress, fatigue, or illness, ask the individual ,

to report to work.  :

5.11 Emergency Response Call-in Procedures j 5.11.1 l .During an Emergency (as defined by the Emergency Response Plan,,  !

covered personnel of BG&E designated to respond will be contacted

= and should make a personal judgement as to whether tney are fit for-duty, including whether they are fit to operate e motor vehicle and -

respond to the emergency, .

'5.11.2 Upon arrival at all access points to the plant, Em'ergency Operations 5

Facility (EOF) and the Media Center, Nuclear Security will hand each individual a statement regarding his or her fitness for duty and further  :

' instructions for individuals not meeting the five (5) hour abstinence rule (see Appendix 8).

[

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p i I L f l ' Revision 2 August 1991 Page 41  :

t CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUW PROGRAM i 5.11.3 Each individual must complete the Emergency Response Call-in l Form and indicate on it if he or she is free from drugs and physical or l mental factors such as mental stress, fatigue, or illnesses which could impact on safety and his or her fitness for duty to work and return the form to Nuclear Security prior to reporting to his/her assigned work i location.

l 5.11.4 Nuclear Security will deny unescorted access to the protected area, EOF and Media Center to any individual who has not completed the  !

Emergency Response Call-in Form.

5.11.5 Where an individual indicates that he/she does not meet the five hour ,

alcohol abstinence rule, the Nuclear Security ',hift Supervisor will ensure that an alcohol test is conducted on the individual. Safety and Medical Services personnel will conduct alcohol tests during emergency call ins.

5.11.6 Nuclear Security will deny unescorted access to any individual whose tests indicate a blood alcohol concentration of 0._04 percent or  :

greater, with the only exception being given in Section 5.11.7. ,

i 5.11.7 When an Individu;l does not meet the five (5) hour alcohol  !

abstinence rule or has a blood alcohol concentration of 0.04 percent or greater, Medical Staff personnel or Nuclear Security, in the ,

absence of the Supervisor or behavior observer, will consult with the OSC Director, EOF Director, as appropriate, or the Technical Advisor at the Media Center to determine whether the individual is critical to i tne Emergency Hesponse Plan, if either of the Directors or the Technical Advisor determines that the individualis critical to the  ;

Emergency Response Plan, the individual will be allowed to proceed to his/her work location, but only with an escort at all times. t t

6.0 Training j 6.1 General [

Four (4) fitness for duty training courses are required under this program:

Supervisor Fitness For Duty Training; Supervisor Fitness For Duty Retraining:

Awareness and Escort Fitness For Duty Training; and Annual Awareness and i Escort Retraining.

i 6.2 Supervisor Fitness For Duty Training (See Section 3.53 for definition of Supervisor as it applies to behavior observation) i 6.2.1 Training Requirements: This section applies to covered personnel Supervisors with unescorted access; those Supervisors who do not  ;

possess unescorted access but supervise individuals with  ;

j unescorted access; and those individuals who are designated  ;

o Behavior Observation Supervisors.

A. All Behavior Observation Supervisors shall undergo initial I Supervisor Fitness For Duty Training.

[

k Revision 2 August 1991 Page 42 .

CALVERT CLIFFS NUCLEAR POh'ER PLANT FITNESS FOR DU1Y PROGRAM B. Newly designated or promoted Behavior Observation Supervisors (do not currently possess unescorted access) must complete Supervisor Fitness For Duty Training prior to assignment of duties (observing behavior) under this Program.

C. Covered personnel promoted, temporarily promoted, or hired to the position of Supervisor with unescorted access or who will supervise (behavior observer) individuals with unescorted access must complete Supervisor Fitness For Duty / Behavior Observation Training within 60 days of initial supervisory assignment, unless prior approvalis received from the FFD Program Manager to complete the training within 3 months.

6.2.2 Course Development: Initial Supervisor Fitness For Duty Training lesson plans shall be developed by Technical Training with assistance from subject matter experts from the Psychological and Employee Assistance Services Unit (PEAS) and Security Screening and

- approved by Psychological and Employee Assistance Services.

6.2.3 Course

Description:

Supervisor Behavior Observation Fitness For Duty Training shallinclude:

- The course content for " Awareness and Escort Fitness For Duty Program" (Section 6.4.3).

Supervisory role and responsibi'! ties, and any distinctions between procedures for BG&E versus contract employees.

! - Role and responsibility of Safety and Medical Services Department, Psychological and Employee Assistance Services, and Security-Screening.

- Techniques for recognizing drugs including use, saio, possession and distribution.

- Behavior observation techniques for detecting degradation in performance, impairment, or changes in individual behavior.

- Procedures for initiating appropriate action, to include referral to the Employee Medical Assistance Services program and to appropriate medical professionals in the case of contractors and vendors.

- Procedure for initiating a referral for a fitness for duty examination 6.2.4 Training documentation relative to this program shall be maintained by Technical Training.

6.3 Supervisor Fitness For Duty Retraining 6.3.1 Training Requirements: Supervisors shall be retrained in the requirements of this section annually.

Revision 2 August 1991 Page 43

CALVERT CLIFFS NUCLEAR POWER PLANY FITNESS FOR DUTY PROGRNA 6A2 Course Development: Technical Training, in conjunction with subject matter exports from Psychological and Employee Assistance Services and Security Screening, shall develop curriculum for annual retraining.

6.3.3 Course

Description:

Supervisor Fitnoss For Duty /Bohavior Observation Retraining shall consist of those items listed in Section 6.2.3.

6.3.4 Training Documentation relative to this program shall bo maintained  ;

by Technical Training.  ;

6.4 Awareness and Escort Fitness For Duty (AEFFD) Training 6.4,1 Training Requirements: All individuals who are at or support Calvert Cliffs Nuclear Power Fiant who require unoscorted access to the  ;

protected area, EOF or Media Center must complete initial >

Awareness and Escort Fitness For Duty Training, i f

All new covered personnel shall receive initial Fitness For Duty l Training prior to any unescorted job assignment inside the protected i area at Calvert Cliffs Nuclear Power Plant.

6.4.2 Course Development: Technical Training, in conjunction with subject  ;

matter experts from Psychological and Employee Assistance Services  !

(PEAS) personnel and Security Screening shall develop curriculum  !

for this training.

6.4.3 Course

Description:

Awareness and Escort Fitness For Duty Training ,

shall contain: >

l - Review of BG&E policies and procedures on Fitness For Duty,  ;

l including distinctions between BG&E employees, contractors, and l vendors. i

- Details on health and safety hazards associated with drug and ,-

alcohol abuse.  ;

- The effects of prescription, over-the-counter drugs and dietary

• conditions on job performance and chemical testing.

- Techniques for recognizing drugs including use, sale, possession  !

and distribution,  ;

- Techniques for recognizing aberrant behavior.

- The role of the Calvert Cliffs Fitness For Duty Program Manager. l

- The role of the Safety and Medical Services Department.

l

- The role of the Medical Review Officer.

- The role of Security Services.

l - The role of BG&E Employee Medical Assistance Services.

I Revision 2 August 1991 Page 44

- - _ _ _ - . , -. . - - - . - ~ _ . - . - - . _ - - - .- . . . -

CALVERT CLIFFS MUCLEAN POWER PLAh7 FITNESS FOR DU1Y PROGRAM

- Options available to cor*cetor and vendor personnel.

- Individual expectatir,ns concerning the Fitness For Duty Policy.

- Consequences that will result from lack of adherence to this Program.

- Method for reporting problems to supervision and security.

6.4.4 Training Documentation relative to this program shall be maintained by Technical Training.

6.5 Awareness and Escort Fitness For Duty (AEFFD) Retraining 6.5.1 Training Requirements: Allindividuals granted unescorted access shall attend AEFFD retraining annually.

6.5.2 Course Development: Technical Training, in conjunction with subject matter experts from Psychological and Employee Assistance Services and Security Screening, shall develop curriculum for annual retraining.

6.5.3 Course

Description:

AEFFD Retraining shall consist of those items -

listed in Section 6.4.3.

6.5.4 Training Documentation relative to this program shall be maintained by TechnicalTraining.

6.6 Course Presentations, Completion and Scheduling 6.6.1 Initial Awareness and Escort Fitness for Duty Training

- Initial AEFFD Training is included as a module in GOT Part i Initial Training.

- Individuals must satisfactorily complete the Awareness and Escort Fitness For Duty quiz to pass Awareness and Escort Fitness For Duty Laining

- Training is scheduled through Technical Training.

6.6.2 Awareness and Escort Fitness For Duty Retraining

- AEFFD Retraining is provided during GOT Part i Retraining.

- Individuals must satisfactorily complete the Awareness and Escort Fitness For Duty test to pass Awareness and Escort Fitness For Duty Retraining.

- Training is scheduled through Technical Training.

Revision 2 August 1991 Page 45

- - -. - - .. . ==.-- -.-. - . _ . . .- . -

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 6.6.3 initial Supervisor Fitness For Duty / Behavior Observation Training Initial Supervisor Training must be completed within 60 days of the notice of promotion to Supervisor and/or designation as a Fitness For Duty Behavior Observer Supervisor.

- Initial Supervisor FFD/BO training is presented by instructors designated by the Fitness For Duty Program Manager.

- Individuals must satisfactorily complete the Supervisor Fitness For Duty and Behavior Observation quiz administered at the conclusion of training to pass the course.

Training is scheduled through Technical Training.

6.6.4 Supervisor Fitness For Duty / Behavior Observation Retraining

- Supervisor FFD/BO retraining is presented after GOT Retraining as a separate module (self study or lecture).

- Individuals must satisfactorily complete the Supervisor Fitness For Duty and Behavior Observation Quiz administered at the conclusion of training to pass the course.

Training is scheduled through Technical Training.

6.7 Training Records 6.7.1 Fitness For Duty class rosters and tests will be maintained by Technical Training.

6.7.2 The Technical Training clerk shall update training information upon receipt of completed rosters (Security Screening Data System -

SSDS).

6.7.3 Technical Training is responsible for ensuring training records are maintained in accordance with Section 13.2.11.1 -

6.8 Lesson Plan Approval All fitness for duty lesson plans and training materials shall be approved by the

- Supervisor-Psychological and Employee Assistance Services.-

7.0 Contractors and Vendors 7.1 All contractor and vendor personnel granted unescorted access to CCNPP must comply with the requirements of 10 CFR 26 and the BG&E CCNPP/FFD Program.

i Revision 2 August 1991 Page 45 t

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 7.2 Contractors r ust furnish a Written Agrooment to Purchasing and Materials Management asserting that its employees and subcontractors will adhere to BG&E's CCNPP/FFD Program, or portions thereof, or a BG&E approved program that moots the requirements of 10 CFR 26 and BG&E furnished requirements. Written agreements between BG&E and its contractors and vendors will clearly show that:

BG&E is responsible to the NRC for maintaining an effective fitness for duty program in accordance with 10 CFR 26; Contractors are prohibited from knowingly requesting unemorted access for employees or subcontractor employees who have been denied access or had their unescorted access revoked at a nuclear power plant for violation of a fitness for duty program, or other employment within the scope of 10 CFR 26 without the knowledge and consent of BG&E.

I i l 7.3 Contractors and vendors who conduct their own fitness for duty programs must l have them approved by BG&E.

74 Contractor and vendor programs must meet the requirements of 10 CFR 26 and the BG&E CCNPP/FFD.

7,5 The BG&E Employee Medical Assistance Service (EMAS) is not available to j contractor or vendor personnel. Contractor and vendor firms are encouraged to q provide information to each individual on where they may seek assistance  !

conceming fitness for duty-type problems. j 7.6 Contractor and vendor personnel are subject to the same training and testing I requirements as BG&E employees.-

7.7 _ Contractor and vendnr BG&E approved programs are subject to audit by BG&E and may share audit results with other NRC licensees or accept en audit conducted by another NRC licensee.

7.8 Refusal of a contractor or vendor to wbmit to random testing for drugs 'nd alcohol will result in termination of unescorted access. Any attempt by a contractor or vendor to influence test results will result in termination of I

unescoded access.

7.9 When a drug test performed on a contractor or vendor is a confirmed positive test as determined by the Medical Review Officer, the Random Coordinator will notify Supervisor-Security Screening who will notify the BG&E Access Requester. Security Screening will terminate the individual's unescorted accessc l The Access Requester will notify the contractor or vendor in accordance with l Appendix 6.

L l 7.10 When an alcohol test performed on a contractor or vendor is a confirmed I

positive test as determined by the MRO, the Random Cocrdinator will notify Supervisor-Security Screening who will notify the BG&E Access Requester.

Security Screening will deny or revoke the individual's unescorted access as appropriate. The Access Requester will notify the contractor or vendor in accordance with Appendix 6.

l -

Revision 2 August 1991 Page 47

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. C&LVER T CLIFFS NUCLEAR POWER PLAMT FITNESS FOR DUTY PROGRAM 7.11 Contractors and vendors assigned escort duties in the protected and vital areas <

are responsible for observing contractors and vendors entrusted to them.

7.12- All contractors and vendors are required to have pre-access alcohol and drug testing conducted by BG&E prior to the granting of unescorted access to protected areas at Calvert Cliffs, except where unescorted access screening clearances have been transferred between nuclear licensees within 60 days and the chemical tests were conducted within 60 days of the date unescorted access was granted at CCNPP, Where another nuclear licensee transfers such testing information, individuals who fail to meet a more stringent standard will be treated as if they failed the NRC standards.

7.13 Contractors and vendors, along with the Written Agreement, must fumish BG&E ,

Purchasing and Materials Management a Calvert Cliffs plant point of contact (name, office telephone, home/ motel telephone number) and a home office point of contact with the same information.

7.14 Contractors and Vendors at the request of BG&E must ensure an appropriate number of their employees (sub-tier contractors) complete the Supervisor Fitness For Duty Training (See Section 3.53 and 6.2) which will permit them to conduct behavior observation of their individuals. Trained replacement behavior observers must be identified to BG&E prior to the departure of the primary observer.

7.15 Due to the nature of a fitness for duty event, if the contractor / vendor point of contact cannot be contacted within one hour of the initiating event, the BG&E Supervisor / Behavior Observer will obtain permission from a BG&E General Supervisor or higher to direct the contractor / vendor personnel to submit to FFD test (s).

j- 8.0 Chemical Testing 8.1 General Chemical testing is a viable n,.ans to deter and detect substance and alcohol abuse and misuse. The Safety and Medical Services Department is responsible

. for conducting all fitness for duty tests. Only individuals with a need-to-know have access to confirmatory test results.

For testing integrity, details of breath and urine testing procedures are contained in BG&E Safety and Medical Services Department procedures, referenced in Section 16.0.

- 8.2 Types of Testing I

Revision 2 August 1991 Page 48

. CALVERT CLIFFS NUCLEAR POWER PLhMY FITNESS FOR DUTY PROGIMM

- Four types of tests as applicable will be conducted on covered personnel under the CCNPP/FFD; Pre-Access (Pre-Badging) Drug and Alcohol Testing

- For-Cause Drug and Alcohol Testing Follow i Random Testing For Drugs and Alcohol

- Random Testing of Drugs and Alcohol 8.3 Testing Specifications 8.3.1 Individuals will have a urine specimen collected and a breath test conducted during the same visit to the collection facility.

8.3.2 Pre-access testing will be accomplished within 60 days prior to the authorization of unescorted access by BG&E. BG&E will conduct pre-access drug testing of covered personnel using a Federally-certified testing laboratory. BG&E will conduct preaccess alcohol l testing of those individuals at a BG&E collection facility.

8.3.3 Random testing selections are accomplished through a confidential, computer-generated, random selector based system. Random testing will be conducted at a rate equal to at least 100 percent of the work force (covered personnel subject to this program). The tests are administered so that a person completing a test is immediately l eligible for another unannounced test.  !

8.3.4 For-Cause testing of covered personnel will be conducted as soon as possible following:  ;

- any observed aberrant behavior;

- after any on-theijob accident or near miss situation where circumstances raise questions about the employee's fitness for duty; .

l- - in a case involving radiation exposure or release of radioactivity in l excess of regulatory limits, or actual or potential substantial l degradation of safety of the plant,if there is reasonable suspicion

! that the worker's behavior contributed to the event; or  ;

- after receiving credible information that an individualis abusing l drugs or alcohol.

Refusal to give a specimen under random testing and resignation prior to removal for violation of the Company's Fitness For Duty Policy concerning drugs will be recorded as a removal for-cause.

Revision 2 August 1991 Page 49

r t

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGFWA i 8.3.5 .As part of follow-up testing on an inoividual who has been determined to be fit for duty following completion of a substance  ;

abuse rehabilitation program, the individual will be required to provide a specimen prior to reinstatement of unescorted access and i periodically thereafter as datermined by the Manager-Safety and Medical Services Department.

8.3.6 Follow-up testing on an unannounced basis will be conducted on  !

those individuals whose unescorted access has been reinstated after -!

they were removed from the Fitness For Duty Program for three or i more years. Follow-up testing will be conducted in accordance with 10 CFR 26.27 (b)(4). 1 8.3.7 Drug and alcohol testing as a minimum will conform with 10 CFR 26.

f 8.3.8 Individuals who fail to meet a more stringent standard (such as one  !

set by another NRC licensee) will be treated as if they had failed the NRC standards.

8.3.9 The selection of individuals to be tested, the test, results of the tests  ;

and the MRO review wi'l be conducted confidentially.  ;

8.3.10 The operational aspects of the program are addressed in Safety and -

Medical Services Department Procedures. >

8.3.11 Observed specimens will be permitted only with the approval of the '

MRO when there is reason to believe that a particular individual may attempt to alter or substitute the specimen provided. Reasons would  ;

be:

l - The individual has presented a urine specimen that falls outside the normal temperature range, and the individual declines to provide a measurement of oral body temperature by sterile thermometer, or  ;

the oral temperature does not equal or exceed that of the specimen. ,

- The last urine specimen provided by the individual (i.e., on a previous occasion) was determined by the laboratory to have a  ;

specific gravity of less than 1.003 or a creatinine concentration below

.2 g/L  ;

The collection facility person observes conduct clearly and unequivocally indicating an attempt to substitute or adulterate the sample. ,

- The individual has previously been determined to have used a [

substance inappropriately or without medical authorization,- and the  !

particular test is being conducted as part of a rehabilitation program  !

l or on return to service after evaluation and/or treatment for a i confirmed positive test result. .

- if the collection facility person has reason to suspect tampering I

for various reasons such as Indication of blueing agent in specimen,

• individual taking longer than four minutes to return specimen, or  :

individual flushing toilet prior to submitting specimen.  :

Revision 2 August 1991 Page 50

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 9.0 - Employee Medical Assistance Services (EMAS) 9.1 General BG&E maintains Employee Medical Assistance Services (EM/S) as a part of a strong Corporate policy on fitness for duty, including substance and alcohol abuse. The EMAS offers assessment, short-term counseling, referral services, and treatment monitoring to BG&E employees with drug or alcohol-related problems, personal and/or other behavioral problems.

9.2 Referrals

9.2.1 Self-Referral

Employees concerned about alcohol, drug problems, mental stress, fatigue or illnesses may obtain counseling and treatment by contacting Psychological and Employee Assistance Services, Safety and Medical Services Department.

9.2.2 Supervisor Referral: Supervisors who observe circumstances which raise questions about employees' fitness for duty should refer employees to Safety and Medical Services Department. At the discretion of the Manager Safety and Medical Services Department, the employee may be referred for treatment through EMAS.

9.2.3 Medical Referral: When, during the course of interaction with an cmployee, either through a health treatment visit or physical examination conducted in conjunction with a required testing program, a Medical care provider identifies medical symptoms or disorders commonly associated with an alcohol or substance abuse, behavioral, or emotional problem, the Medical provider will consult with the employee to discuss the symptoms or disorder and arrange referral to a provider associated with Employee Medical Assistance Services.

9.3 Confidentiality Employees who seek treatment, counseling or referral services will receive confidential service unless the employee's condition,in the opinion of the Manager-Safety and Medical Services, constitutes a hazard to himself or herself or others, in which case Section 9.4 applies. Confidentiality will be provided in a manner consistent with the. highest standards of medical ethics and provider-patient relationship.

9.4 Reports to Management While every effort is made to protect the confidentiality of employees who seek treatment through EMAS, Management will be advised of any employees who, in the opinion of the Manager-Safety and Medical Services, represent a hazard to themselves or others. The Supervisor-Psychological and Employee Assistance will report such potential hazards posed by employees to the Manager-Safety and Medical Services Department who willinform Manager of Employee Services, even in cases of self-referral, and will notify the Random Coordinator who in turn will notify the Supervisor-Security Screening to suspend or revoke the individuals unescorted access.

Revision 2 August 1991 Page 51

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM

- 9.5 Contractors and Vendors

. Where a contractor or vendor poses potential hazards in the opinion of the .!

Manager-Safety and Medical Services, the Random Coordinator will be notified l who will in turn notify the Supervisor-Security Screening who will suspend or l revoke, as appropriate, the individual's unescorted access.

9.6 Consultation Professionals from the Safety and Medical Services Department are available for consultation on a round-the-clock basis where Supervisors or behavior observers have questions regarding an individual's fitness for duty when responding to a call-in situation. Emergency telephone numbers for these professionals are available on the Emergency Notification Ust located in the BG&E Telephone Directory.

10.0 Management Actions and Sanctions 10.1 Denial of Unescorted Access Denial of unescorted access will result in the event of:

10.1.1 A confirmed positive drug and/or alcohol test within 60 days of requesting unescorted access.

10.1.2 Prior involvement in the sale, use, or possession of illegal drugs in the protected area of a nuclear power plant.

10,1.3 Unfavorable psychological evaluation or unfavorable background investigation (suitable inquiry) as determined by BG&E.

10.1.4 Failure to successfully complete required training or provide a pre-employment / pre-access specimen.

10.1.5 involvement in the following within the past three (3) years:

- any positive drug test conducted pursuant to DHHS Mandatory Guidelines for Federal Workplace Drug Testing Programs, April 11, 1988, or as they may be modified.

- alcohol use resulting in on-duty impairment.

- enrollment in a substance abuse treatment plan (other than self-referral).

- denial, removal, or revocation of unescorted access at any other nuclear power plant relating to FFD Program.

- use, sale, or possession of illegal drugs on or off the plant site.

- denial of employment in accordance with a fitness for duty policy.

The abovementioned items are examples and by all means not all encompassing.

Revision 2 August 1991 Page 52

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i 1

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUYY PROGRAM i

-t 10.2 Suspension of Unescorted Access  ;

Suspension of unescorted access may result in the event of:  ;

10.2.1 Confirmed misuse of alcohol, valid prescription and over-the-counter drugs, any of which results in on-duty impairment.

10.2.2 Letter of Agreement not in receipt within five (5) work days of granting  ;

unescorted access. j 10.2.3 Failure to successfully complete training or retraining requirements I

under the Fitness For Duty Rule.

i 10.2.4 A Supervisor of badged individuals failing to complete Supervisor j training or retraining as required, unless the next higher trained  !

Supervisor in the chain of command assumes this responsibility.  ;

i 10.2.5 -An Individual being referred by a Supervisor for a fitness for duty examination. The Manager-Safety and Medical Services notifies the  !

Random Coordinator who in turn notifies the Supervisor-Security I Screening who then suspends the individuals unescorted access l pending a final determination by the MRO.

10.2.6 An individual's failure to supply accurate and complete information ,

regarding: }

- a past positive drug test j i

- alcohol use resulting in on-duty impairment  ;

- prior subjection to.a substance abuse treatment plan

- denial, removal, or termination of unescorted access at any other _

nuclear power plant and the reasons for such actions t

l - dental of employment in accordance with a Fitness For Duty Policy ,

i 10.2.7 Individuals failing to report any arrest that may impact upon his/her [

trustworthiness to their BG&E behavior observer, or contractor l behavior observer.

10.3 Removal from Protected Area l

-?

10.3.1 Impaired workers or those whose fitness for duty is questionable  :

shall be removed from the protected area, and shall not return to  ;

work until they successfully complete a fitness for duty evaluation. j 10.3.2 Lacking any other evidence to indicate the use, sale, or possession  :

of illegal drugs on site, a confirmed positive test result must be F presumed to be an off-site drug usa and the individual will be }

removed from the site.  ;

i i

Revision 2 August 1991 Page 53 t

CALVERT CLIFFS NUCLEAR POWER PLANT FITM ' .:OR DUTY PROGRAM L t

i 10.3.3 Any individual determined to have been involved in the sale, use, or r possession of illegal drugs while within the protected area will be i removed from nuclear activities. [

s

-10.4 Revocation of Unescorted Access Revocation of Unescorted Access will resu4 in the event of: f A confirmed positive drug test.  ;

Individual involvement in the sale, use, or possession of illegal drugs  !

on or off site, j Refusal to provide a specimen for testing or submit to a breathalyzer test.  ;

Resignation prior to removal for violation of the Fitness For Duty i Policy. j A confirmed positive alcohol test and resultant Management decision.  !

105 Consideration for Reinstatement of Unescorted Access -

10.5.1 Eligibility -,

i 10.5.1.1 Individual's unescorted access may be reinstated after a ,

suspension, provided the MRO determines the individual i is fit to safely and competently perform activities within the ;

scope of this program. l 10.5.2 Restrictions If found positive for drug use, the individual's (contractor / vendor) unescorted access will be terminated, and will not be restored. In the  ;

case of a BG&E employee, the individual will be discharged. j 11.0. Appeals 11.1 All confirmed posi$ve alcohol or drug determinations may be appealed in conjunction with '.his program including pre-employment tests.

11.2 BG&E employees may appeal a positive alcohol or drug determination through l the Company's grievance procedures contained in the Employee Benefits and Policies Handbook or through the Company's Open Door Policy.

Upon receipt of a positive drug and alcohol test notification from BG&E, 11.3 contractors and vendors may initiate an appeal of a positive alcohol or drug r determination by following procedures outlined in the BG&E notification letter as required and provided by Maryland State Law (Section 17-214.1(c), Health i Article of the Maryland Annotated Code).

h i

Revision 2 August 1991 Page 54

5 CALVERT CLIFFS NUCl EAR POWER PLANT FITNESS FOR DUTY PROGRAM l

t

, 11.4 Contractors and vendors will provide, through their own procedures, an l l opportunity for their employer to appeal a positive alcohol or drug determination.

Each individual whose test (s) results were positive will be mailed (to last known  ;

address) a letter of notification to this effect. The BG&E point of contact for- l contractor appeals is the Medical Review Officer (MRO). I i

11.5 individuals may request a reanalysis of the original specimen of the confirmatory i positive after notification by the MRO.  !

i 11.6 During all reviews, the individual's unescorted access to the protected and vital l areas will be suspended.  !

i 1EO Protection of Information 12.1_ Procedures for Retention and Protection of Records and Information L 12.1.1 Fitness for duty records shall be retained in accordance with ,

t o CFR 26.71.

L l

12.1.2 Files that contain confideritial information shall: _j Be stored in a locked container or secured area when not in use or attended. ,

- Have the key or combination controlled.

Have limited accessibility to protect confidentiality. l l

l 12.2 Disclosure of PersonalInformation for Suitable Inquiry 4 12.2.1 BG&E shall not disclose personal information to anyone other than ,

those parties listed in Section 12.2. j

1222 Authorized NRC licensee utility representatives and assigned Medical Review Officers who are legitimately seeking information for i unescorted access decisions can receive personal information

- provided they have obtained a signed release from the worker, j l

12.2.3 Individuals who have a legitimate need to have access to the  !

information are: ,

. NRC representatives Law enforcement officials under court order

- The individua! who is the subject of the information

- Utility representatives performing assigned duties (i.e., audits of p BG&E's CCNPP/FFD)  ;

- Individuals deciding matters on review or appeal (i.e., BG&E.  ;

Attomeys and MRO's etc.) j 4

i' i L ,

Revision 2 August 1991 Page 55 l

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 12.2.4 Security Screening will transfer, at the request of another licensco contractor or vendor and supported by a signed release from the individual, the following information: identity of the person (s) denied unescorted access or removed from unescorted access and the circumstances for such denial or removal, including test results.

Security Screening maintains reciprocity with other licensees.

12.2.5 The individual's representative, upon written approval by the individual concerned, may obtain the information.

12.2,6 Any individual who is subject to a drug or alcohol test under 10 CFR 26 will, upon written request, have access to personal suitable inquiry information and have access to any records relating to his/her tests and any records relating to the results of any relevant laboratory certification, review or revocation of certification proceedings.

12.3 BG&E's Right To Withhold PersonalInformation Personal information will be withheld:

if a legitimate need is not established; and/or

- if disclosure would compromise a source requesting confidentiality.

12.4 Administrative Responsibilities The Supervisor-Security Screening will review all requests for information and will determine those requests for information which meet the criteria set forth above.

13.0 Inspections, Recordkeeping, Reporting Requiremerits, and Severity Categories 13.1 Inspections it is understood that the NRC or its authorized representatives may inspect, copy, or take away copies of BG&E's and or contractor / vendor reccrds and inspect its premises, activities, and personnel as may be necessary to insure compliance with 10 CFR 26. Written agreements between BG&E and contractors / vendors should include the above information for BG&E-approved contractor programs.

13.2 Recordkeeping Requirements (the times indicated are not less than) 13.2.1 The Manager Nuclear Quality Assurance will:

13.2.1.1 Retain records of independent internal audits of the Fitness For Duty Program for three (3) years.

13.2.1.2 Retain records of evaluations of work performed by individuals whose unescorted access was terminated due to a violation of the Fitness For Duty Program for five (5) years, or after the next NRC FFD inspection, whichever comes first.

4 Revision 2 August 1991 Page 56

l

( CRLVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR OU1Y PROGRlM i

13.2.2 The Manager-Employee Services will ensure that:

13.2.2.1 Records of employee personnel actions related to confirmed positive test results are retained for five (5) years.

13.2.2.2 Records of employees who resigned prior to removal for violation of the Company's Fitness For CJty Policy are retained until' e Commission terminates the license.

13.2.3 The Manager-Safety and Medical Services Department will ensure that:

13.2.3.1 Training records of collection facility personnel and non-medical collection facility peaonnel involved in specimen collection, alcohol tests and the drawing of blood for a gas chromategraphy analysis of blood for three (3) years are retained.

13.2.3.2 Chain of Custody form with confirmed positiv6 test results are retained until the Commission terminates the license.

On negative test results, destroy the Chain of Custody form after receiving the results from the certified laboratory.

13.2.3.3 Records of confirmed positive test results which are confirmed by the MRO are retained for five (5) years.

13.2.3.4 Records of individuals made ineligib!o for three (3) years or longer due to confirmed positive test resutts leading to the presumption of off site drug use due to the absence of any other evidence to indicate the use, sale, or possession of illegcl drugs on-site are retained for five (5) years.

13.2.3.5 Records of individuals removed for periods of three (3) or more years due to the sale, use, or possession of illegal drugs while within the protected area and whose unescorted access was subsequently reinstated are retained until the Commission terminates the license.

13.2.3.S Records of individuals removed for periods of three (3) or more years due to their refusal to provide a specimen for tasting are retained until the NRC terminates the license.

13.2.4 The Fitness For Duty Program Manager will:

13.2.4.1 Retain current revisions of the Fitness For Duty Manual until the Commission terminates the * ,ense and maintaining superseded revisions for three (3) years after each change.

l Revision 2 August 1991 Page 57

+

CALVER f CLIFFS NUCLEAR POWER PLAMT FITNESS FOR DUTY PROGRAM I 13.2.4.2 Retain a copy of selected unit task-level procedures that

• implement the Fitness For Duty Program for three (3) >

years after each revision.

13.2.4.3 Retain records of blind sample submissions and the laboratory results for two (2) years.

t 13.2.4.4 Retain copies of MRO investigations of unsatisfactory laboratory testing results for two (2) years, l 13.2.4.5 Retain the Program implementation Chart for three (3) [

years after each initial and/or update entry This includes information on three (3) year updates on background  ;

investigations and psychological evaluations.

13.2.4.6 Retain permanent log book record of those individuals  !

entering collection facility until the Commission terminates the license plus three (3) years.

13.2.4.7 Ensure the notification and dispensary arrival time of the testee is transferred from the individual's Appendix 2 to the {

permanent log book. '

13.2.4.8 Retain completed copies of Appendix 8 until the next NRC inspection. v t

13.2.5 The Medical Review Officer will:

13.2.5.1 Retain records of forensic / scientific appeals / reviews by employees and contractors for five (5) years.

13.2.5.2 Retain documents until the Commission terminates the license concerning individuals whose unescorted access j was reinstated after they had allegedly abstained from drugs for the three (3) previous years. l

~

T 13.2.5.3 Retain records for five (5) years of individuals who were denied unescorted access or had their unescorted access  !

revoked due to confirmed positive test results. F F

13.2.5.4 Retain records of individuals made ineligible for I unescorted access for three (3) years or more until the Commission terminates the license.

13.2.5.5 Ensure the notification and the dispensary arrival time of the testoe is transferred from the individual's Appendix 2 to i the permanent log book.  !

4 13.2.5.6 Retain superseded revision of the MRO/ Medical Procedures Man ual for three (3) years. r

! l t

t Revision 2 August 1991 Page 58

CALVERT CLIFFS NUCLEAR POWER PLAMT FITNESS FOR DUTY PROGRAM 13.2.6 The Supervisor - Psychological and Employee Assistance Services will:

13.2.6.1 Retain records for five (5) years of notifications to the Manager-Safety and Medical Services of individuals judged to constitute a hazard to himself or herse;f, or others.

13.2.7 The General Supervisor-Calvert Cliffs Security Operations will:

13 2.7.1 Retain record for two (2) years or until after the next NRC FFD inspection of consultations with local law enforcement officials and the subsequent sharing with the MRO and Program Manager. ,

13.2.8 The Supervisor-Security Screening will:

13.2.8.1 Retain for five (5) years from the date of last access, records of those individuals denied unescorted access, whose unescorted access was suspended or revoked.

13.2.8.2 Retain for the period of unescorted access the consent / release form to conduct the suitable inquiry and five (5) years after termination of unescorted access.

13.2.8.3 Retain records for five (5) years of attempts to subvert testing as described in Appendix 7.

i l 13.2.8.4 Retain a record of notifications to Access Requestors of contractors whose request for unescorted access has i been denied and also of suspensions and revocations. .

13.2.8.5 Retain contractor Letter of Agreements with BG&E for the

• life of the contract, plus three (3) years.

13.2.8.6 Retain for five (5) years a list of names of the individuals forwarded to Quality Assurance whose unescorted access was terminated due to noncompliance with the Fitness For Duty Program. j[

!. 13.2.8.7 Retain notifications to Technical Training of individuals j whose unescorted access has been terminated for one (1) year or the next NRC inspection, whichever comes first.

13.2.8.8 Retain bimonthly reconciliation lists of behavior observers '

with those observed and forwarded to technical training for one (1) year, or until the next NRC inspection.

13.2.8.9 Retain for the period of unescorted access plus five (5) i years after termination of access the Supervisor's Behavior Observation Report (Appendix 5). ,

4 CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM 13.2.8.10 Retain for the period of unescorted access plus five (5) years, the Notification to Contractor or Vendor of Test Results (Appendix 6).

13.2.8.11 Retain records until the NRC terminates each license of Individuals made ineligible for unescorted access for a period of three (3) years or longer who were determined to have been involved in the sale, use, or possession of l Illegal drugs or alcohol within the protected area of any ,

nuclear plant. (Lacking any other evidence to indicate the l use, sale, or possession of illegal drugs on-site, a j confirmed positive test result must be presumed to be an i indication of off-site drug use.)

l 13.2.8.12 Until the NRC terminates the license, retain records of individuals who retired or resigned prior to removal for violation of the CCNPP/FFD Policy concerning drugs or alcohol.  ;

13.2.8.13 Retain records of suitable inquiries (background l investigations) that resulted in the granting of unescorted access to protected areas for five (5) years followinD l termination of the access authorization.  !

13.2.8.14 Retain until the NRC terminates the license (See 10 CFR  !

26.27 (b)(4) for full explanation), retain records of -

individuals granted unescorted access who were previously removed from unescorted access for three or 0 more years and subsequently permanently denied access.

13.2.8.15 Retain documentation for five years concerning receipt E and/or transmittal of information to/from utilities -i conceming suitable inquiries. i 13.2.8.16 Security Screening shall maintain Supervisor Behavior :

Observation Reports (Appendix 5) and documentation of action taken in the individual's personal security file for a period of five (5) years.

13.2.9 The Assistant General Supervisor Administrative Services will:

13.2.9.1 Retain records of the notification of individuals in the Nuclear Energy Division who are newly assigned as supervisor, and that are furnished to Technical Training.

Retain for one (1) year or until the next NRC inspection, whichever comes first.

13.2.10 The General Supervisor-Employment will:

13.2.10.1 Retain records of the riotification of individuals (non-l Nuclear Energy Division) requiring Supervisor fitness for i duty training fcr two (2) years or until the next NRC inspection.

l Revision 2 August 1991 Page 60

._ - - .- -. . . - - - - . n. ,

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 13.2.10.2 Retain records notifications to Technical Training and Security Scrooning of non-Nuclear Division indiv4 duals >

requiring Supervisor's training. Maintain records for two '

(2) years or until the next NRC inspection, whichever comes first. {

13.2.11 The Supervisor Technical Training Unit will:

13.2.11.1 Retain and maintain records in accordance with OAP 7.

13.2.12 The Random Coordinator will:

13.2.12.1 Retain records of selectees, those tested and not tested, random testing periods, and notification to Managers and/or representatives. Retain records for five (5) years.

I 13.2.12.2 Retain records of verifications for five (5) years of 10% of those individuals not available for testing.

13.2.12.3 Retain records of those selected for one (1) year or until the individual is tested within the year, whichever comes first. This is to accommodate tilose with infrequent access.

13.2.12.4 Retain for two (2) years the monthly statistical report from the certified laboratories.

13.2.12.5 Retain for two (2) years the summary of negative findings I based on scientific insufficiency by the certified laboratories, 13.2.12.6 Retain records (date and time) of notifications (date and time) to Security Screening of individuals determined to be i- unfit for duty whose badges are to be inactivated. Retain l for five (5) years.

l 13.2.12.7 Collect and compile FFD Program Performance Data on a standard form for submission to the NRC (Appendix 3) within 60 days of the end of each six (6) month reporting period (January - June and July - December). Data will be analyzed to identify program weaknesses. Data analysis and transmittal letter will be retained for three (3) years.

i 13.2.13 Purchasing and Materials Management will retain for life of the contract Written Agreements between BG&E and contractors, consultants, and vendors of their adherence _to the requirement of 10 CFR 26 and the BG&E Calvert Cliffs Nuclear Power Plant Fitness For Duty Program, t

Revision 2 August 1991 Page 61

- - .-. . , . _ . .-= __ .- - .. . -

- CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM

~ ,_  ;

,f 13.2.14 The Supervisor Emergency Planning will: i 13.2.14.1 Retain records for one (1) year or until the next NRC  !

inspection i

• duals' names furnished to the Technical Training t Security Screening who need to comply with certali 3 for duty requirements.

13.2.15 The BG&E Supervisors will: ,

13.2.15.1 Retain for three (3) years the Call-in Reporting Checklist (Appendix 4).  !

t 13.3 ' Reporting Requirements i i

The Fitness For Duty Manager is responsible for submitting the information listed below  ;

as described by the Code of Federal Regulations to the NRC, ,

13.3.1 10 CFR 26.27(d): Notify the NRC Regional Administrator if an NRC employee or NRC contractor is believed to be under the influence of }

any substance or otherwise unfit for duty.

13.3.2 10 CFR 26.73(a) Sianificant events involving the (1) sale, use, or possession of illegal drugs within the protected area; l (2) any acts by a licensed operator or any Supervisor assigned to pmiorm duties within the scope of 10 CFR 26:  !

(a) involving the sale, use, or possession of a controlled j j substance,  !

i (b) resulting in a confirmed positive test (s) on such persons,  ;

(c) involving use of alcohol within the protected area, or f i

resulting in a determination that the individual is unfit for i (d) scheduled work due t::, the consumption of alcohol. .

13.3.3 10 CFR 26.73(b): Notification must be made to the NRC Operations i Center by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery by the licensee. [

13.4 Severity Categories (10 CFR 2, Appendix C, Supplement Vil) f Usted below are the NRC enforcement actions as pertaining to the Fitness For Duty - i Program.

1 A. Severity 1: Failure to substantially implement the required Fitness For j Duty Program.  ;

t

?

i f Revision 2 August 1991 Page 62

_ - ~ .

-- ~- . - - -~ -- .~,- - - . - - ..

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM B. Severity 11: (6) Failure to remove an individual from unescorted access ,

who has been involved in the sale, use, or possession of illegal drugs l within the protected area or to take action for on duty misuse of alcohol, 3 prescription drugs, or over the-counter drugs; (7) Failure to test for cause ,

when observed credible information concerning activities within the  !

protected area indicates possible unfitness for duty based on drug or alcohol use; or (8) Deliberate failure of the licensee's Employee  !

Assistance Program to notify licensee's management when EAP's staff is aware that an individual's condition may adversely affect safety related activities. l C. Severity 111: (6) Failure to complete a suitable inquiry on the basis of 10 l CFR Part 26, keep records concoming the denial of access, or respond .

to inquiries conceming such denials sucn that, as a result of the failure, a person previously denied access for fitness for duty reasons was i improperly granted access; (7) Failure to take the required action for a l person confirmed to have been tested positive for illegal drug use or take i action for on-site alcohol use; not amounting to a Severity Level 11  :

violation; (8) Failure to assure, as required, that contractors or vendors have an effective fitness for duty program; or (9) Breakdown in the .

Fitness For Duty Program involving a number of violations of the basic elements of the Fitness For Duty Program that collectively reflect a significant lack of attention or carelessness towards meeting the 3 objectives of 10 CFR 26.10. l D. Seve;!ty IV: (4) Isolated failures to meet basic elements of the Fitness t For Duty Program not involving a Severity Level I, il, or 111 violation; (5)

Failure to report acts of licensed operators or Supervisors pursuant to 10 ,

CFR 26.73.

E. Severity V: (4) Minor violations of fitness for duty requirements. j 14.0 Audits -

14.1 BG&E Ouality Assurance will audit the Fitness For Duty Program every 12 months. BG&E may accept audits of contractors and vendors conducted by  !

other licensees and need not re-audit the same contractor or vendor for this ,

same period of time. In the case of shared audits, BG&E shall maintain a copy l of the audit report, including findings, recommendations and corrective actions.  ;

BG&E assumes responsibility for the effectiveness of contractor and vendor  ;

programs where the programs have been formally accepted by BG&E, and  !

retains responsibility for implementation of appropriate corrective actions.  ;

i 14.2 Audits will focus on the effectiveness of the program. Audits will be conducted I by individuals qualified in the subject (s) being audited and independent of both fitness for duty program management and personnel directly responsible for  ;

implementation of the Fitness For Duty Program. }

14.3 The audit result, along with recommendations, if any, must be documented and reported to the Vice President-General Services Division, VP-Nuclear Energy Division, Manager Facilities Management Department, and the Calvert Cliffs  :

i Fitness For Duty Program Manager. The resolution of the audit findings and [

l corrective actions will be documented. Audit documents will be retained for  !

l three (3) years.

L I  !

u  ;

Revision 2 August 1991 Page 63 l

T CALVER T CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 14.4- Safety r.qd Medical Services Department shall audit approved laboratories at least ci te every 12 months and report results to Management and the Calvert Cliffs r iness For Duty Program Manager. The Manager-Safety and Medical Servic,es Departmont will audit annually contractor and vendor medical review officer functions in accordance with 10 CFR 26, Appendix A.

14.5 The Calvert Cliffs Fitness For Duty Program Manager will initiate a yearly review of this Program to make changes to reflect:

Organizational changes which impact on responsibilities listed in this i Program ,

Regulatory changes which dictate technical changes in this Program s

Policy changes ,

The Calvert Cliffs Fitness For Duty Program Manager will obtain any and all I technical staff services to ensure appropriate revisions to this Program.

15.0 Control Procedures j 15.1 Fitness For Duty Program Manager is responsible for: i 15.1.1 Development, maintenance, and coordination of the Fitness For Duty  ;

Manual.

{

15.1.2 Implementation of the Fitness For Duty Manual. i 15.1.3 Revisions to the Fitness For Duty Manual. [

15.2 Distribution and Control 15.2.1 The Fitness For Duty Program Manager is responsible for distribution  ;

and control of the Fitness For Duty Manual. 3 r

l- 15.2.2 This is not a controlled document, consequently no distribution list is i l maintained.

15.3 Review and Revision

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15.3.1 Revisions must be reviewed by designated Departmental Managers; 15.3.2 Revisions to the Fitness For Duty Manual must be jointly approved by the Vice Prf sident-Nuclear Energy and Vice-President Management .

I Services.

15.3.2.1 Short revisions shall be denoted by a vertical line in the right hand margin of the Manual.

r 15.3.2.2 Extensive revisions and large numbers of page shifts will  !

not be denoted by verticallines. The letter of transmittal  !

on revisions will bring this to the attention of the recipient.  !

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM 15.3.3 The Fitness For Duty Manual shall be reviewed by the Fitness For Duty Program Manager on an annual basis for changes.

15.3.4 Documentation of the review shall be maintained in the Fitness For Duty Program Manager for three (3) years from the date of review or revision.

16.0 References 16.1 54 FR 24494. Fitness for Duty (10 CFR 26), June 7,1989.

16.2 53 FR 11970. Department of Health and Human Services (HHS),

Mandatory Guidelines for Federal Workplace Drug Testing Programs, (April 11,1988). i 16.3 NationalInstituto on Drug Abuse, Department of Health and Human Services (NIDA/HHS), Medical Review Officer Manual: A Guide to Evaluating Urine Drug Analysis, September 1988.

16.4 Edison Electric Institute (EEI), Guide to Effective Drug and Alcohol Policy Development.

i 16.5 Edison Electric Institute (EEI), Manual on Fitness For Duty Program l Development, August 1989. )

16.6 NUREG/CR 5227, Fitness For Duty in The Nuclear Power Industry: A 1 Review of Technical issues, September 1988.  :

16.7 NUREG/CR 5227, Fitness For Duty in The Nuclear Power industry: A Review of Technical Issues - Supplement 1, May 1989.

16.8 NUREG - 0903, Survey of Industry and Government Programs to l Combat Drug and Alcohol Abuse, April 1982.-

16.9 NUREG/CR 2075, Standards for PsychologicafAssessment of -

! Nuclear Facility Personnel, July 1981.

l 16.10 NUREG/CR 2076, Behavioral Reliability Program for the Nuclear Industry, July 1981.

16.11 NUREG/CR 3196, Drug and Alcohol Abuse: The Basis for Employee Assistance Programs in the Nuclear Utilities Industry, July 1983.

16.12 NUREG - 1385, Fitness For Duty in the Nuclear Power industry:

Responsive to implementation Questions, October 1989.

16.13 10 CFR 73.56, Nuclear Power Plant Access Authorizatiore Program (Proposed).

16.14 BG&E Access Authorization Manual, September 1987.

16.15 BG&E Calvert Cliffs Security Plan, March 1989.

l Revision 2 August 1991 Page 65

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM l 16.16 BG&E Ouality Assurance Procedure (OAP) 01, Review and Audits of -

Quality Assurance Program. ,

16.17 BG&E Ouality Assurance Procedure (OAP) 20 - Training. I 16.18 Calvert Cliffs instruction (CCl) 130, Plant Access Request and .

Authorization.  ;

i 16.19 L Calvert Cliffs instruction (CCl) 155, NRC Reporting Requirements, 16.20- Calvert Cliffs Instruction (CCl) 602, General Orientation Training.

16.21 BG&E Employee Policios Manual. [

t 16.22- BG&E Employee Benefits and Policies Handbook.

16.23 BG&E Random Urine Collection Procedures Manual.  ;

16.24 3G&E Forensic Blood Alcohol Collection Procedures Manual, f 16.25. BG&E Breath AlcoholTesting Standard Operating Procedures  ;

Manual. l

-t 16.26 BG&E Contractor Fumished information. -

i 16.27 BG&E State of Maryland Certified Laboratory Safety and Standard [

Operating Procedures Manual. l 16.28 BG&E Ouality Assurance Procedure (OAP) 7 Records Management. l 16.29 NUMARC 89-01, Industry Guidelines For Nuclear Power Plant Access Authorization Programs. j 16.30_ Calvert Cliffs instruction (CCl) 116, identification and Control of l Nonconformance Conditions. j 16.31 NUREG 1354, Fitness For Duty in the Nuclear Power Industry: [

Responses to Public Comments, October,1989. .

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CALVERf CLIFFS MUCLEAR POWER PL% FITNESS FOR DUTV PROGRAM .

Appendix 1 -;

Emergency Response Plan Named Positions Required To Meet CCNPP/FFD Requirements

< The Calvert Cliffs Fitness For Duty Program applies to the following positions (alternates)-

who are required to report to the Emergency Operations Facility (EOF) and/or Media . ,

Center (MC) in the event of a plant emergency. Normally, the everyday responsibilities of the personnel performing these functions may not require them to have unescorted access to the plant.

l. Emergency Operations Facility.

1. Recovery Officer

2. Environmental Assessment Director -

II. Media Center

- Public Information Support Manager Corporate Spokesperson Technical Advisor -i Public Information Representative Nuclear information Representative Public Affairs Representative +

Administrative Coordinator  !

Designated Support Staff Personnel Media Liaison lil Designated Personnel _

- 1. Administrative Support Plan (EOF) I Administrative Support Manager

. Designated Facilities Maaagement Personnel  ;

Designated Information Systems Personnel  ;

Designated Purchasing and Materials Management Personnel  :

Designated Transportation Personnel l,

-2 Telecommunications Support Plan (EOF)- 1 Telocommunications Support Manager j

, Recovery Coordinatord ,

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t CALVERT CLIFFS HUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM t

i Appendix 2  :

Random Selection Form .

YOU HAVE BEEN SELECTED FOR RANDOM DRUG AND ALCOHOL TESTING l UNDER THE CALVEPT CLIFFS FITNESS FOR DUTY PROGRAM ,

1 NAME: TEST DATE: ,

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a WHY RANDOM SCREENING 7 f

This program adds to the ettorts to maintain a safe, healthy and drug-free environment .f at Calvert Cliffs Nuclear Power Plant. Random Testing For Drugs and Alcoholis just one  ;

element of our Fitness for Duty Program, which includes pre-employment pre badging  ;

(pre-access), formause testing following performance or behavioral changes, post-  :

accident testing, and follow-up testing, where indicated. Fitness for duty programs help provide for public and workplace safety, while helping to assure that individuals are fit to [

perform their jobs. ,

~ HOW WAS I SELECTED? f You were selected through a totally random computer process. Your selection is '

unrelated to job performance or any other behavicts.

i WHAT WiLL HAPPEN?

L Report to the testing location indicated on ine rever,te of this form. Bring your: 1) ',

BG&E photo identification card (Calvert Cliffs identificat:on card for Calvert Clitis

- contractors or vendors); 2) Driver's license; and 3) Socia. Security number (you need not '

bring the card as long as ycu know the number). The enhee process will be explained and i- you will be asked to sign forrns. You will t'e asked questions about your current l prescriptions and over the-counter medications. 7 1

I L HOW IS ALCOHOL TESTING DONE?

The collection facility person will instruct you to blow into a tube attached to a l breathalyzer. Each test requires two breath specimens. If the results of the first breathalyzer test indicate a blood alcohol concentration of .04 percent or greater, a _ +

second test on a different breathalyzer wlit be performed. This second test is the confirmatory test, if you demand further confirmation, you may request a third test (gas chromatography analysis of blood) to confirm the breathalyzer results. ,

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CALVERT CLIFFS NUCLEAR POWER PLANT FlYNESS FOR DUYY PROGRAM l HOW IS DRUG TESTING DONE7 You will be instructed to wash and dry your hands, and ba given a specimen container.

You will bo directed to a privato lavatory, flgiurn your_ optcimen to the_gojiggliom f acility ,

person withir11our (4) mintites_gLurlpajlon r to ensure a valid,s_arnple. The collection r

facility person will perform a visual examination and temperature check of the specimon.

The collection facility person will seal the container and ask you to sign tho soal placed on the containor. This onsures that there has boon continuous control over the contonts of No container, ensuring accurato test results. You will then bo permitted to return to work.  ;

WH8T HAPPENS NEXT?

Your specimon will bo tostod by a cortified losting laboratory, if your spocimon is found to be negative for any evidence of drugs, ygy will bg sent wfjiten notification olth91 fact i yvithin five (5) work!qg. stays. For BG&E employoos,if your samplo is testod and found to be positivo for any evidence of drugs, your Ma]ager will bg_nollfled thaLYau will be Lequired to meet with the Medical Review Officeri as_pganned by_your ManeggL i Calvert Cliffs contractors and vendola wilLbe_ notified t?y their access Requgster and offered a,Lgpportunity for an Interview with the MRO, WHAT HAPPENS IF I REFUSE TO PARTICIPATE IN TESTING 7 Employoos, contractors and vendors who refuso to participato in Cc!vort Cliffs scrooning willlose their unoscorted access. Employees who refuse to participato in tho ,

Calvort Cliffs Random Testing Programs may, accordino to Comppny_polley, lose their jobs.

l REPORT TO THE TESTING LOCATION INDICAkED BELOW: ,

[] BG&E's Calvert Cliffs Dispensary

[] BG&E's Main Medical Dispensary,1500 G&E Building

[] BG&E's Ft. Smallwood Dispensary ,

[] Other Timo Sont: By:

Timo Arrivod: Dy:

Site Collector YOU MUST REPORT FOR TESTING WITHIN ONE (1) HOUR OF NOTIFICATION OR YOUR UNESCORTED ACCESS MAY BE SUSPENDED (Form may be destroyod after the dato and timo SENT and ARRIVED is transferred to the permanent log book.)

Revision 2 August 1991 Pago 69

CALVERT CLIFFS NUCLEAR POWER PUWT FITNESS FOR DUTY PROGRAM Appendix 3 Forms for Reporting to the Nuclear Regulatory Commission Revised. August 20,1991 FM NESS FOR DUTV PERFORMANCE DATA FORM EXPLANATION First Shoot (will be completed soml annually):

1. Company Enter:

• Baltimore Gas and Electric Company"

2. Six Months Ending This form will be completed on a semi annual basis covering the periods of January 1 to Juno 30 and July 1 to December 31. Each report must be submitted to the NRC within 60 days of the end of each 6 month reporting period.

J. Location Enter: " Culvert Cliffs Nuclear Power Plant"

4. Contact Namo . Enter the name of the Calvert Cliffs Fitness For Duty Program Managor.

5. Telophone Number Enter the Company telephono number for the Calvert Cliffs Fitness For Duty Program Manager.

6. Cutoffs: Screen / Confirmation (ng/m!) Mark the box labelod Appendix A to 10 CFR 26 sinco the NRC standard c _tof:lovels aro used.

7. Avorago Number With Unoscorted Access -Thore are two (2) blanks to record the average number of licensoo employoos and contractor personnel unoscorted access test population. The contractor personnelin tho unoscorted access tos' population includos those in contractor approved programs, as well as personnelin the BG&E's program. In each category, the number ontored is the average number of peoplo in the random testing pool during the six-month reporting period (January 1 through June 30 or July 1 through December 31); it is the sum of the average wookly random test populations divided by the number of weeks in the reporting peri.,d.

8. Categorios Those blanks contain the number of urine specimons and broath samples tested in each category and the number of confirmed positivo tests in each category reported by the Medical Review Officer during the six-month reporting period.

- The pro-access testing category is for curront employees who are being moved into a position in the company requiring unoscorted access to the Protected Area. This also applios to cont, actors / vendors requesting unescorted access who woro tested within the last sixty (60) days.

The " pre employment" testing category results would be timited to those persons sooking a job with BG&E at Calvort Cliffs Nuclear Power Plant.

I Revision 2 August 1991 Pago 70

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM i

- The afor cause" testing category is for results of tests based on [

behavior observation programs or results based on recolving crediblo  !

Information that an individualis abusing drugs or alcohol. This may  !

includo individuals referred for drug and alcohol testing following an l accident. 4 Tho " follow-up" testing category results portains to those tests f administered because of the roturn to work of an individual who self-  !

reforted for substanco abuso and is plecod on a regimon of random i follow-up testing to dolormino continued abstinenco.

i The ' random" testing category is for results of tho randomly solected j end conducted drug and alcohol testing of all employees and j contractors /vondors subject to random tosting due to access to the protected araa of the plant.  ;

i Only those categorios toquired by the rule (pro-badging, for causo, tant m, and i follow up) will be included in the data colloction spaces, j L

The *# tostod"In each category is the number of urino/ breath specimens i provided for testing purposes. An individual may provido soveral specimens  !

during the period; each occasion is countod.

The "# positivo"In each category is the number of confirmod positivo for drugs and number of confirmed positivo for alcohol; thoso will be recorded separately for both BG&E and contractor /vondor personnel, t

9. # Referred to EAP Record tho total number of licensoo employcos referred to [

l an Employeo Assistanco Program (EAP) because of tosting positive on sny ,

alcohol or drug test for the six-month reporting period. This number nood not bo  :

the same as the total number of positivos, because of factors such as, the  !

individual resigned, refused EAP,is a repoat offendor, etc. Tho shaded areas E are not intended to be used. j

10. # Access Rostored - The rulo requires that unescorted access to the Protected i Area be denied to any person who the Medical Roview Officer has dotormined to ,

have a confirmed positivo test. The "# Access Rostorod" space is for recording the number of BGCE employoos who have had a confirmed positivo test and  :

who have done whatever the company policy toquires in ordor to have their l unescorted access status restored. The shadtd c.f eas are not intended to bo  ;

used.

Socc nd Sheet (this is a fivo (5) year record incorporating data from the soml annual records): f

11. Random Testing Program Rosults This section providos space fer recording [

the results of tho semi-annual random testing for drugs / alcohol data for a period t of up to five (5) years. The upper portion has spaces to record the soml annual i values of the number of individuals tested (individuals may be testod more than l onco during the period) and the confirmed positivo test results (rocorded as one i por occasion that an individual is testod even if that individual was positivo for  :

I more than one of the substancos listed under Confirmed Positivo Test for Specific Substancos [soo item 12]). The lower portion is a fivo (5) year trond I graph used to plot the total percent positivo during each six-month reporting  ;

porlod (plotted semi annually), j Revision 2 August 1991 Pago 71

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CALVERT CLIFFS NGCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM

10. The Confirmed Positive Test for Specific Substances . This section providos spaces for the number of confirmed positive tests, recorded by substance and other drugs, during each semi-annual reporting porlod. This must include test results for those substances listed and other drugs lostod for during the six (6) month reporting period. Please note that there is no direct correlation betwoon the sum of those numbers and the number of positivos ontored in llom 11; multiple positivos por individualin ltom 11 are recorded as separato items in this table.

Third Sheet (not provided with the form, but required for final rule roporting purposos):

The final rulo requires this data to be submitted to the Commission within 60 days of the end of each six-month teporting period, in addition to the information provided by the standard form, the Random Coordinator will submit a summary of management actions. This willinclude: Initiativos takon,lossons learned, effectiveness evaluation, etc., as appropriate. The data will be analyzed and appropriate actions taken to correct program weaknossos.

A summary listing of events reported by tolophono under 10 CFR. 26.73 la also required to be includod. The brief summary willinclude the date of the ovont, the posit in of the individual (e.g. Auxiliary Operator, Security Guard, etc.), how discovered (e.g. random testing), substance detected, and management actions taken (e.g. referred to EAP) in that reporting period, i

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CALVERT CLIFFS NUCLEAR FOV' u CAM "':n? ,%"!%ir Fr.OGRAM REPLACE WITH DOCUMthfT FROM OTHER FILZ (prol W RI':

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i CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUW PROGRAM i i

REPLACE WITH DOCUMENT F ROM OTHER FILE (FFDPERf2 FFD)

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CALVERT CLIFFS NUCLEAR POWER PLAM7 FITNESS FOR DU1Y PROGRAM i

Fitness for Duty Program Performance Data Personnel Subject to 10 CFR 26 Summary of Management Actions:

Including Initiatives taken, lessons learned, effectiveness evaluation, etc., to correct program weaknesses.

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Summary of Telephone Reported Events Date of the Event:

Position of the Individual:

How Discovered:

Substance (s) Detected:

Management Actions Taken:

Revision 2 August 1991 Pago 75

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CALifERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM

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Dato of the Event: i-I Position of the individual:

How Discovorod:

Substanco(s) Detected:

i Managomont Actions Taken:

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Dato of the Event

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t Position of the Individual: i i

How Discovorod:

Substanco(s) Detectod: ,

Management Actions Taken: l l

l [ nie of the Event: f Position of the Individual: [

How Discovered:

Substance (s) Detected:

Management Actions Taken:

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Date of the Event:  !

Position of the Individual:  !

How Discoverod: _

l Substanco(s) Detected:

i Management Actions Taken:

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1 l Revisign 2 August 1991 Pago 76 l t

I CALVERT CLIFFS MUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM I j

Appendix 4 i Call in Reporting Checklist l l

t To support efforts to promote public and workplace safoty, the Calvert Cliffs Nuclear Power Plant Fitness For Duty Program (CCNPP/FFD) aims to creato an l environment which is free of alcohol and drugs and the effects of such substances ,

within the protected areas of the plant The use of illegal drugs and abuse of legal ,

drugs, including alcohol, and including the use and/or abuse of these substances I outside of work hours, constitutes a safety and public threat to BG&E employees, l contractors and vendors, and BG&E facilities, and will not be tolerated.  !

All covered personnel are obligated to not abuso alcohol in any way which .I affects job performance, not consume it during the five (5) hours preceding any -

scheduled work tour and during working hours. BG&E Supervisors are responsible for. j onsuring that individuals on call in assignments meet the five (5) hour abstinence rule. -l Reasonable effort should be made to identify an individual for call in who is alcohol free.

l Supervisors / Access Requestors are to use the attached worksheet to document  ;

covered personnel contacted for call-ins. Initial appropriate blocks and mako notes or  ;

comments to document employees' response to call-!n questions. Supervisors are responsible for retalning Call-In Reporting Checklists for three (3) years,  ;

i jThis checklist is not to bs used during tisfist no (2) hoursif a plant personnel jecall (Alerti  !

Estage) for emergency / drill recalls (See Appendix 8). '

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CALVERT CLIFFS NUCLEAR POWER PLANY FITNESS FOR DUTY PROGRAM Appendix 4 CALL-IN REPORTING CHECKLIST DATE: TIME:

SUPERVISOR:

INDIVIDUAL'S NAME: PHONE NUMBER:

1. Individual's Response to Fitness For Duty Inquiry A. _- Are you fit for duty?

- YES NO 11 YES, proceed to B.

If NO, advise the individual not to report to work and document as a failure to respond to a call in and provide explanation.

Explanation:

B. Have you consumed any alcohol within YES NO

.the last five (5) hours?

If YES, advise the individual to report to Medical / Security for a breathalyzer test prior to reporting to work.

L If NO, proceed to C.

C. _ Are you free from drugs (legal, illegal, over the-counter, etc.), physical and mental factors such as mental stress, fatigue, or illnesses which could impact .

! on safety and your ability to satisfactorily and safely perform the required

_. tasks? YES NO if YES, request the individual to report to the plant.

If NO, attempt to identify another individual to respond to the call-in.

II. Supervisor's Assessment of Fitness For Duty-Based on the telephone inquiry, the individual is:

Fit for duty Z Fit for duty pending breathalyzer results Not fit for duty Signed:

(Supervisor making the call)

NOTE: File in department files for each Individual called-in.

Revision 2 - August 1991 Page 78

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM Appendix 5 Supervisor Behavior Observation Report Name of Individual Social Security Number Company Date Behavior Observed Describe incident and/or behavior:

Describe action taken:

Supervisor Name(print) Signature Date Medical Review Officer Comments:

MRO Name (print) MRO Signature Date Send originalin a confidential manner to the Medical Review Officer (MRO). Retain one copy in

department file if desired.

Revision 2 August 1991 Page 79

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CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM Appendix 6 Notification to Contractor or Vendor of Positive Test Results Individual's Namo: Soc Soc No:

(First Maddio initial, Last) individual's Current Addr .ss:

(Local Mailing Address or whero individual receives mail)

ContractorNondor Company:

Notification Roccived from Supervisor Security Scrooning: (Timo) (Dato)

When a drug test has boon doemod a confirmatory positivo, or alcohol tost results are determined to bo positivo, the individual's badge will be temporarily inactivated pending final verification by the Medical Review Officer (MRO).

The Access Roquestor should initial cach item discussed with the contractor or vendor (bolow).

The Access Roquestor will contact the contractor or vendor and notify the contractor or vendor of each of the following:

the initial drug or alcohol test was determined to bo positivo and the confirmatory test was dotormined to be positivo; the contractor or vendor will be glvon the opportunity to moot with tho MRO (234-6117) to discuss the results on a specified dato and timo (within a week). At such a mooting, the indivictual will be able to present any facts which could impact on the ultimato dolormination made by the MRO; offective immediately, the contractor's or vendor's badge will bo inactivatod; failure to report to the MRO at the specified dato and timo will constituto an unwillingness to comply with the requirements of the Fitness For Duty Rulo and will result in a determination of removal for cause for purposes of responding to suitablo inquirlos from other nuclear licensoos; a letter indicating the test results and the offer to moet with the MRO will bo sont to the contractor or vendor. A letter will be sont to the contractor or vendor with writton notification of drug test results (as required by the Stato of Maryland). The letter will be sont to the last known address of the contractor or vendor, if the individual could not be contacted, explain attempts to contact in one or two sontoncos.

Notification by: Dato:

(Must be signtd by Access Roquestor)

Time Notified: How Notified: (e.g., tolophone, personal interview)

Send original to Security S;reening in a confidential manner. Mako no copios.

Revision 2 Augnt 1991 Pago 80

CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DU1Y PROGRAM Appendix 7 Prevention Of Subversion of Testing BG&E shall carofully soloct and monitor persons responsib'o for adr,1inistering tho testing prograrn (e.g., DG&E collection facility persons, and thoso selecting Lnd notifying personnel to be testod, including the Random Coordinator (s)), based upon tho highest standards for honesty and intogrity, and shall implomont measures to ensulo that theta standards are maintainod. As a minimum, those measures shall one.uro that the integrity of such persons is not compromised or subject to offorts to compromiso due to personal relationships with any individuals subject to testing.

The persons in tho following positions will be subject to thoso requirements:

Managor-Safoty and Medical Services Department Modical Review Officer Attornato Medical Review Officers Supervisor-Psychological and Employoo Assistanco Services Supervisor Modical Sorvices Unit Information Systems Data Base Administrator /Alternato Fitness For Duty Analyzer Fitness For Duty Clork Safety and Medical Clerk Fitnoss For Duty Administrator Socurity Scrooning Employoos Fitneso For Duty Program Manager Clinical Psychologist Employoo Medical Assistance Counsellor Random Coordinator Physicians

• Assistants Occup Ttional Health Nurso Specimon Collectors Unit Support Clerk, Psyche'agical and Employoo Medical Assistance Services Individual (s) charged with maintenance of the Random Selection System As a minimum:

1. Supervisors and co workers of the individual being tested shall not perform any collection, assessment or evaluation procedures.

2. Appropriate background checks and psychological ovaluations shall be completed prior to assignment of any tasks associated with tho administration of the Fitness For Duty Program, and shall be conducted at least once overy throo (3) years.

3. Persons responsible for administering the testing program shall be subjected to behavior observation to assuro that they continue to meet the highest standards for honesty and intognty.

4. BG&E employees responsible for administering the testing program shall bo subject to random testing for drugs and alcohol.

Revision 2 August 1991 Pago 81

l CALVERT CLIFFS NUCLEAR POWER PLANT FITNESS FOR DUTY PROGRAM Appendix 8 Emergency Response Call in Form )

i All covered personnel and other individuals responding to a " call-in" must indicate l whether or not they are Fit For Duty and if they meet the five (S) hour alcohol  !

abstinence period before proceeding to their emergency reporting location. Check  ;

each item below in the applicable block, sign, date the Form, and return the Form to the appropriate representative BEFORE PROCEEDING TO YOUR REPORTING LOCATION.  !

Failure to comply with these instructions will result in suspension of your unescorted ,

access and possible rernoval from site.

Upon site arrival, complete and submit to Nuclear Security (either a_t the Emergency l Operations Facility (EOF) or the Security Processing Building (SPB). If reporting to the Nuclear Engineering Facility (NEF), submit to NEF Director (First Floor-NEF Conference Room).

Individual's Response to Fitness For Duty inquiry A. (1) Are you Fit For Duty? YES NO  ;

(2) Are you free from drugs (legal, illegal, or over the counter)?  :

YES NO l (3) Are you free from physical and mental factors such as montal stress, fatigue, or illnesses which could impact on SAFETY and your ability to .

satisfactorily portorm your job?

YES NO If YES to any of the above, proceed to B. ["

If NO to any of the above, proceed to B and C.

Bi Have you consumed any alcohol within the last five (5) hours?

YES NO  ;

i if YES, report to Nuclear Security Shift Supervisor / Medical Services as directed.

Individuals indicating that they have consumed alcohol within the five hours previous to responding to the emergency / drill recall Will be required to submit to a Breathalyzer Test ,

at the Collection Facility, if NO, proceed to C. [

E C. Report to Security Shift Supervisor ar d 6'vait further instructions. (At the e

discretion of the MRO, test for drugs may sMo be accomplished.) ,

SIGNATORE TIME DATE ,

NOTE 1 - Forward forms indicating non-consumption to the rappropriate supervisor. 1 i

NOTE 2 Safety & Medical Services / Security Shift Supervisor after compk tion of tests forward  !

to appropriate supervisor in a confidential roanner.

I Revision 2 ' August 199 f Page C2 t

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