ML20080P822
| ML20080P822 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 02/27/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9503080145 | |
| Download: ML20080P822 (20) | |
Text
- - - _ _ _ _-
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Station Support DepratmInt g
W PECO ENERGY ecco e" 'av cc-a "v Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne, PA 19087 5691 February 27,1995 Docket Nos. 50-277 50-278 50-352 50-353 License Nos. DPR-44 DPR-56 NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Dottom Atomic Power Station, Units 2 and 3 Umerick Generating Station, Units 1 and 2 Fitness-for-Duty Program Performance Data for the Period July 1994 through December 1994 Gentlemen:
As required by 10CFR26.71(d), this letter submits the performance data for our Fitness-for-Duty (FFD) program for the period July 1994 through December 1994. The data for our Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and Limerick Generating Station (LGS), Units 1.
and 2, sites are provided in Attachments 1 and 2. Data for our Corporate Office and Nuclear Group Headquarters specimen collection sites (i.e.,2301 Market Street, Philadelphia, PA, and 955-65 Chesterbrook Boulevard, Wayne, PA, respectively) are provided in Attachment 3.
The data are reported on the January 1992 revision of tlw FFD Performance Data form provided by the Nuclear Energy Institute (NEI), formetty the Nuclear Management and Resources Council (NUMARC), and include the following.
Drugs tested for and cut-off levels.
Workforce population tested.
Numbers of tests and results by population and type of test (i.e, pre-access, for-cause, random, follow-up, and other types of tests).
Substances identified.
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February 27,1996 Page 2
'l Attachments 1,2, and 3 also include the following.
A summary of mano9ement actions.
Analysis of the data and appropriate actions that have been taken.
Random testing rate.
)
1 4
During this period, there were no events reported to the NRC in accordance with 10CFR26.73.
l If you have any questions or require additional information, please contact us.
Very truly yours, h-o G. A. Hunger, J.,
Director - Licensing Attachments
- cc:
. T. T. Martin, Administrator, Region 1, USNRC (w/ attachments)
W. L Schmidt, USNRC Senior Resident inspector, PBAPS (w/ attachments)
N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments).
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ATTACHMENT 1' J
Peach Bottom Atomic Power Station Units 2 and 3 Fitness-for-Duty Performance Data
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July 1994 through December 1994 d.
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ATTACHMENT'l
. Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 s
PECO Energy Company December 31, 1994 Company 8 Monma Endine Peach Bottom Atomic Power Station Locaico David M. Sarley (215) 841-5703 Contac Narne Phone (indude eren code)
Cutoff s: Screen / Confirmation (ng/ml)
O Appendix A to 10CFR 26 Marijuana 50
/
15 Amphetamines 1000
/ '500
-/
Cocaine 300
/ 150 Phencyclidine 2i
/
25
./
Opiates 300
/ 300 Alcohol (% BAC) 0.04%
/
~
Long-Terrn Short-Term Testing Results Licensee Employees Contractor Personnel Contractor Personnel Average Number with Unescorted Access 2648 1709 Categories Tested Positive Tested Positive Tested Positive Pre-Access 9
0 1140 18 k
Post accident 21 1
8 0
e h
Observed behavbr 5
1 4
1 R2ndom 283 0
277 0
Follow-up 45 4
40 0
Other 9
0 3
0 Total 372 6
1472'
-19 Includes individuals with dual-site access at PBAPS and LGS.'
g
1 Breakdown of Confirmed Pcsitive Tests for Specific Substances Amphe-Phency-
- Refusal Marijuana Cocaine Cplates tamines clidine.
Alcohol to Test -
1 2
3:
4 5
Licensee Employees t'
3 2
0 0'
O 1'
0
, Long Term Contractors t
A.
Short-Term Contractors 13' 4
1-0' 0
l' 2
Total 16 6
1 0
0 2
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l Summary of Data Analysis and Management Actions Peach Bottom Atomic Power Station July - December,1994 I.
Initiatives Taken 4
The following summarizes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams at Peach Bottom Atomic Power Station (PBAPS) during the period.
'A.
July 11, 1994 - For cause team sweep of an employee's private vehicle, Results:
Three activations.
Marijuana and drug paraphernalia ~
discovered. Employee arrested by Pennsylvania State Police, plant access denied and employment terminated.
B.
July 12,1994 - For cause team sweep of an employee's private vehicle.
Marijuana residue discovered.
Employee's plant access suspended.
Referred to Employee Assistance Program (EAP) for treatment and 3
returned to work on September 9,1994.
C.
July 12,1994 - For cause team sweep of an employee's private vehicle.
Results: Three activations'. Employee admitted off site marijuana use.
]
Employee tested positive, plant access denied and employment terminated.
D.
July 19,1994 - For cause team sweep of Laydown Area between "C" and "D" cooling tovers. Results: One activation. No drugs found or forensic samples taker..
E.
August 5,1594 - For cause team sweep of an employee's private vehicle.
Results: Two activations. Employee admitted off site cocaine use. Plant access denied, emgoyment terminated.
4 F.
September 7,1994 - For cause team sweep of a contractor employee's i
vehicle. Drug paraphernalla discovered. Contractor admitted previous 4
off site drug use. Plant access denied.
G.
September 12, 1994 - General team sweep of Maintenance Tool Room.
Results:
Thirteen activations.
No drugs found or forensic samples taken.
H.
September 12, 1994 - For cause team sweep of an employee's private vehicle. Results: Three activations. No drugs found or forensic samples taken, however, a prohibited offensive weapon was discovered. Employee was disciplined.
I.
September 13, 1994 - For cause team sweep of a contractor employee's private vehicle. Results: Three activations. Marijuana discove ed.
Plant access denied.
J.
September 13, 1994 - For cause team sweep of a contractor employee's private vehicle. Results: Two activations. Contractoradmitted previous off site marijuana use. Plant access denied.
a 1
i K. -
September 13, 1994 - For cause team sweep of a contractor employee's private vehicle. Results: Two activations. No drugs found or forensic" samples taken.-
f L.
September 23,1994 - General team sweep of the north substation complex.
j' Results: Six activations. No drugs found or forensic samples taken.
j M.
September 21, 1994 - For cause team sweep of a contractor employee's-i private vehicle. Results: Three activations. : Contractor admitted off site
[
. marijuana and cocaine use in addition to cocaine distribution. Plant access i
denied.
N.
October 3,-1994 - For cause team sweep of a contractor employee's private j
i vehicle. Results: Three activations.: Contractor admitted previous off '
site marijuana use. Plant access denied.
s O.
November :18,1994
. ' General team sweep of contractor trailer!and :
1 contractor's vehicles. ? Results: Eleven activations. No drugs found or -
j.
forensic samples taken.~.
1 j-II.
Management Actions i
During the period, six PECO Energy employees (i.e., four follow-up, one post i
accident, one observed behavior) tested positive at PBAPS. The employees were provided treatment / rehabilitation thrdugh the PECO Energy Employee Assistance Program. Unescorted access was denied for all six employees. Five of the j
employees - (i.e., three. voluntary - separation,. one resignation, and one discharged) have subsequently been terminated. The remaining employee has i
q transferred to a position which does not require unescorted access.
During the period, nineteen contractor employee's (i.e., eighteen pre-access and one observed behavior) tested positive at PBAPS. Unescorted access has been denied for those contractor employees in accordance with PECO Energy's Fitness-For-Duty (FFD) Specification for Contractors.
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III.
Events Reported Under 10 CFR 28.73 i
During the period, there were no significant FFD events reported by PBAPS.
IV.
Nuclear Quality Assurance Audit During the period, a performance based audit of the FFD program was completed.
to assess the program's implementation. The assessment determined that PECO i
Energy is effectively implementing the FFD program in compliance with 10 CFR part 26. Noted as significant strengths were:
4 A highly competent FFD Staff A well-run and responsive Laboratory (DrugScan, Inc.)'
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Self-assessment activities.
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o Weaknesses identified were: -
i Documentation deficiencies' regarding the medical decision to restore -
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unescorted access to individuals previously denied.
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Laboratory process for validating the screening controls :
=
l Corrective actions have been completed.
1; V.
Random Testing Rate 4
l PECO Energy reduced the random testing rate to 50% effective 02/01/94.- While' PECO Energy maintains separate testing " pools" for employees and contractors, -
i the " average number with unescorted access" includes personnel badged at j
o I
VI.
Additional Information q
Lower Cut Off Levels On September 1,1994, PECO Energy reduced the immunoassay screening cut off 1
level for marijuana to 50 ng/ml. Since the reduced cut off level was implemented J
there have been twelve confirmed positive test results for marijuana at PBAPS.
j It is estimated that only four positive tests for marijuana would--have. been; identified using the 100 ng/ml. cut off level.
Attempted Substitution 1
i On July. 11,1994 an employee subject to follow-up testing provided'a' specimen l
which had a temperature of 104.2 degrees F. z When requested to provide another i
j specimen under direct observation, the employee asked the observer to provide.
i a sample as he "had done something over the weekend." The observer refused.
and reported the incident. A specimen was collected under direct observation and both specimens were sent for testing. The first_ specimen was reported as negative. The specimen collected under direct observation'was reported as j
js positive for marijuana. During the course of the investigation the individual i
admitted to substituting a specimen which he had obtained from his son. The H
[
employee was discharged.
j
- As a result of this incident the following program enhancements are planned:
4 1
1.
Provide a collection site within the protected area at each site. This has -
4 both business and FFD implications. From a business perspective, it will mean less time away from the job, and from the FFD aspect, it may i
diminish an individuals ability / options to attempt subversion of the testing.
7 2.
Reduce / minimize the notification time. This also should help diminish an p
individuals ability / options to attempt subversion of the testing.
I
[
.1 3.
Enhance Supervisory FFD training to further emphasize recognition of persons who may attempt to subvert testing. This enhanced training will 3
provide supervisors with additional information around behaviors and i
other signs / symptoms which may indicate a person is preparing to attempt j
subversion of a FFD test.
1 4.
Periodically reinforce with collection site personnel the need to be.
j' constantly on the alert for attempted subversion efforts. This was done
. immediately following the incident and should be done routinely in order-to keep detection skills as sharp as possible.
4 j
The following information regarding contractor positives is provided:
2 Craft l Vital / Protected Area Access Inng/ShortTenn 5
Pipefitter Vital Granted.
Short i
Engineer Vital Requested -
Long.
Pipefitter Vital Requested Short Electrician Vital Requested -
Short Engineer Vital Requested Short
(
Laborer Vital Requested-Short
' j 3
Diver-Vital Requested Short i
j Asbestos Worker -
Vital Requested Short Pipefitter Vital Requested
. Short
)
Electrician Vital Requested -
Short l
Pipefitter Vital Requested Short Pipefitter Vital Requested.
Short Pipefitter Vital Requested Short i
1 Scaffold / Carpenter Vital Requested -
Short i
Laborer Vital Requested Short -
Laborer Vital Raquested Short i
Clerical Protected Requested Short Sprinkler fitter Vital Requested Short j
Laborer Vital Requested Short i
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i ATTACHMENT 2 i
i Umerick Generating Station i
1 Units-1 and 2 Fitness-for-Duty Performance Data.
July 1994 through December 1994 h
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r-ATTACHMENT 2 Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 i
l PECO Energy Company December 31, 1994 compaq s Waew Ending l
Limerick Generating Station Locanon i
Da Ad M. Sarley (215) 841-5703 Con e Nvne Phone (include area code) l Cutoffs: Screen /Confirmatio n (ng/mi)
O Appendix A to 10CFR 26 i
M:rijuana 50
/
15 Amphetamines 1000
/
500
/
I l
Coca_ine 300
/ 150 Phencyclidine 2 5.'
f 25 j
Opiates 300 f 300 0.04%
Alcohol (% BAC) j l
Long-Term Short-Term Testing Results Licensee Employees Contractor Personnel Contractor Personnel Average Number with Unescorted Access 2648 1709 Categories Tested Positive Tested Positive Tested Positive Pre-Access 21 0
339 9
k Post accident 22 1
10 0
O h
Observed behavior 3
1 5
2 i
Random 287 1
187 3
Follow up 57 1
30 0
Other 4
0 1
0 Total 394 4
572 14
Breakdown of Confirmed Positive Tests for Specific Substances Amphe-Phency-Refusal Marijuana Cocaine Opiates famines clidine
' Alcohol to Test 1
2 3-4 5
l Licensee Employees 2
0 1
0 0
1 0
Long-Term Contractors Short-Term Contractors 5.
5 0
0 0
5-1~
A Total 7
5 1
0 0
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. Attachment 2 Summary of Data Analysis and Management Action Limerick Generating Station July - December,1994 I.
Initiatives Taken The following summarizes the results of sweeps conducted by PECO. Energy Company's drug sniffing canine teams at Limerick Generating Station (LGS).
during the period.
A.
July 27,1994 - General team sweep of the Control Room and 4th Floor of the Administration Building. Results: No activations.. No drugs found or forensic samples taken.
B.
September 27,1994 - General team sweep of the Limerick Training Center office and classrooms. Results: No activations. No drugs found or forensic samples taken.
C.
December 6,1994 - General team sweep of the Main Warehouse and Office Area. Results: One activation. No drugs found or forensic samples taken.
II.
Management Actions During the Period ~, four PECO Energy employees (i.e., one post-accident, one observed behavior, one random, one follow-up) tested positive at LGS. The employees were provided treatment / rehabilitation through the PECO Energy Employee Assistance Program.
Unescorted access was denied for all four employees. The four employees (i.e., one resigned, one voluntarily separated, two discharged).were terminated.
During the period, fourteen contractor employees (i.e., nine pre-access, two.
observed behavior, three random) tested positive'at LGS. Unescorted access has been' denied for those contractor employees in accordance with PECO Energy's Fitness-For-Duty (FFD) Specification for Contractors.
III.-
Events Reported Under 10 CFR 26.73 -
During the period their were no significant FFD events reported by LGS.
IV.
Nuclear Quality Assurance Audit During the period, a performance based audit of the FFD program was completed to assess the program's implementation. The assessment determined that PECO Energy is effectively implementing the FFD program in compliance with 10 CFR part 26. Noted as significant strengths were:
A highly competent FFD Staff A well-run and responsive Laboratory (DrugScan, Inc.)
Self-assessment activities,
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l Weaknesses identified were:
Documentation deficiencies regarding the medical decision.to restore 3
unescorted access to individuals previously denied..
i Laboratory process for validating the screening controls.
4 Corrective actions have been completed.
l
{
V.
Random Testing Rate
' PECO Energy reduced the random testing rate to 50% effective 02/01/94. While PECO Energy maintains separate testing " pools" for employees and contractors, the " average number._with unescorted. access" includes personnel badged at i
VI.
Additional Information' 4
i j
Lower cutoff levels -
j j
On September 1,1994, PECO Energy reduced the immunoassay cutoff level for marijuana to 50 ng/ml. Since the reduced cut off level was implemented there have been three confirmed positive test results for marijuana at LGS. Itis' estimated that only one positive test for marijuana would have been identified using the 100 ng/ml cut off.
j Attempted Substitution On July 11,1994 an employee subject to follow-up testing provided n specimen '
i l
at PBAPS which had a temrerature of 104.2 degrees F._ When requested to i
provide another specimen under direct observation, the employee asked the i
5 observer to provide a sample as he "had done something over the weekend." The i
observer refused and reported the incident. A specimen was collected under.
direct observation and both specimens were sent for testing..The first specimen was reported as negative. The specimen collected under direct observation was reported as positive for marijuana. During the course of the investigation the individual admitted to substituting a specimen which he had obtained from his son. The employee was discharged.
As a result of this incident the following program enhancements are' planned:
1.
Provide a collection site within the protected area at each site. This has I
i both business and FFD implications. From a business perspective, it will mean less time away from the job, and from the FFD aspect, it may-l diminish an individuals ability / options to attempt subversion of the testing.
l 2.
Reduce / minimize the notification time. This also should help diminish an individuals ability / options to attempt subversion of the testing.
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.. m.
3.
Enhance Supervisory FFD ' training to further emphasize recognition of persons who may attempt to subvert testing. This enhanced training will.
provide supervisors with additional information around behaviors. and other signs / symptoms which may indicate a person is preparing to attempt subversion of a FFD test.
4.
Periodica11yareinforce with collection site personnel the need.to be constantly on the alert for attempted subversion efforts. This was done immediately following the incident and should be done routinely in order to keep detection skills as sharp as possible.
The following information is provided regarding contractor positive tests:
Craft Vital / Protected Area Access Inng/ShortTerm Technician-Vital Granted Short Iron Worker
' Protected Granted Short Pipe Fitter Vital Requested Long.
1
- Engineer Vital Requested Short Painter Vital Granted Short Carpenter Vital Requested Short l
Clerical Protected Requested Short t
Carpenter Protected Requested Long-i Carpenter Protected Requested Short Carpenter Protected Requested Long j
Carpenter.
Vital Requested Short -
Painter Protected Requested Short -
i Technician Vital Granted Short Carpenter Vital Granted Short j
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ATTACHMENT 3 i
Corportte and Nuclear Group Headquarters l
Fitness-for-Duty Performance Data July 1994 through Deu riber 1994 I
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4 ATTACHMENT 3
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Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 PECO Energy Company December 31, 1994 i
Company a Mones Endng Corporate and Nuclear Group Headquarters Locanon David M. Sarley (215) 841-5703
_j Contac: Name Pmne (include area code) l Cutoffs: Scre en/ Confirmation (ng/rn!)
O Appendix A to 10CFR 26 l
Marijuana 50
/
15 Amphetamines 1000 / "500
/
Cocaine 300
/ 150 Phencyclidine 25 /
25
/
Oplates 300
/ 300 Alcohol (% BAC) 0.'04%
/
Long-Term Short-Term Testing Results Ucensee Employees Contractor Personnel Contractor Per5cnnel Average Number with Unescoded Access 2648 1709 i
l
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Categories Tested Positive Tested Positive Tested Positive Pre-Access i
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Post accident 3
0 1
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Observed behavior 2
0 0
0 Random 120 1
19 0
Follow-up 12 1
0 0
Other-7 0
0 0
Total 145 2
20 0
0--Includes individuals with_ dual-site access at PBAPS and LGS.
k Breakdown of Confirmed Positive Tests for Specific Substances -.
Amphe-Phency.
Refusa!-
Marijuana ~ Cocaine Opiates famines clidine Alcohol to Test
-1 2
3
-- 4
- 5 Licensee Employees 1
1 0
0 0
0 0-
=.
Leng-Term Contractors Short-Term Contractors 0-0 0
0
~0 0
0 A
Total 1
1 0
0 0
0 0
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Summary of Data Analysis and Management Action -
i Corporate and Nuclear Group Headquarters 1
July - December,1994 I.
Initiatives Taken I
The following summarizes the results 'of. sweeps conducted by PECO' Energy'_
Company's drug sniffing canine teams at Corporate' and Nuclear Group Headquarters during the period.
A.
September 26,1994 - Genaral team sweep of the 965 Building, 3rd Floor, l-Engineering Division. Results: No activations. No drugs found or forensic isamples taken.
4 B.
December 8,1994 - General team sweep of the 965 Buildings 2nd Floor, i
Nuclear Information Systems, Human Resources, and VP Support Offices.
l i
Results: No activations. No drugs found or forensic samples taken.
1 II.
Management Aetions 4
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During the period, two PECO Energy Employses (i.e., one follow-up, one
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. random) tested positive. The employees were provided treatment / rehabilitation
. J through the PECO Energy Employee Assistance Program. Unescorted access was denied and the one employee was transferred to a position which did not require -
f unescorted access. The second employee was reinstated to Emergency Operation i
Facility duties following completion of the prescribed treatment program..
III.
Events Reported Under 10 CFR 26.73,-
There were no events reported during the period.
i IV.
Nuclear Quality Assurance Audit During the period, a performance based audit of the FFD program was completed to assess the program's implementation. The assessment determined'that PECO j
Energy is effectively implementing the FFD program in compliance with 10 CFR part 26. Noted as significant strengths were:
t d
A highly competent FFD Staff e
A well-run and responalve Laboratory (DrugScan, Inc.)
Self-assessment activities.
l Weaknesses identified were:
Documentation deficiencies regarding the medical decision to restore 3
unescorted access to individuals previously denied.
Laboratory process for validating the screening controls
{
Corrective actions have been completed.
i i-i tj
V.
Random Testinst Rate PECO Energy reduced the random testing rate to 50% effective 02/01/94. While PECO Energy maintains separate testing " pools" for employees and contractors, the " average number with unescorted access' includes personnel badged at PBAPS and LGS.
VI.
Additional Actions Lower cutoff levels On September 1,1994, PECO Energy reduced the immunoassay cutoff level for marijuana to 50 ng/ml. Since the reduced at off level was implemented there was one confirmed positive test for marijuana at the Nuclear Group Headquarters. It is estimated that the positive test for marijuana would not have been identified using the 100 ng/ml cut off.
Attempted Substitution On July 11,1994 an employee subject to follow-up testing provided a specimen at PBAPS which had a temperature of 104.2 degrees F. When requested to provide another specimen under direct observation, the employee asked the observer to provide a sample as he "had done something over the weekend." The observer refused and reported the incident. A specimen was collected under direct observation and both specimens were cent for testing. The first specimen was reported as negative. The specimen collected under direct observation was reported as positive for marijuana. During the course of the investigation the individual admitted to substituting a specimen which he had obtained from his son. The employee was discharged.
As a result of this incident the following program enhancements are planned:
1.
Provide a collection site within the protected area at each site. This has -
both business and FFD implications. From a business perspective, it will mean less time away from the job, and from the FFD aspect, it may diminish an individuals ability / options to attempt subversion of the testing.
2.
Reduce / minimize the notification time. This also should help diminish an individuals ability / options to attempt subversion of the testing.
3.
Enhance Supervisory FFD training to further emphasize recognition of persons who may attempt to subvert testing. This enhanced training will provide supervisors with additional information around behaviors and other signs / symptoms which may indicate a person is preparing to attempt subversion of a FFD test.
4.
Periodically reinforce with collection site personnel the need to be constantly on the alert for attempted subversion efforts. This was done immediately following the incident and should be done routinely in order to keep detection skills as sharp as possible.
.-