ML20207E416
| ML20207E416 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 02/25/1999 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9903100256 | |
| Download: ML20207E416 (24) | |
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4 10CFR26.71(d) i
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1 y-i PECO. NUCLEAR.
eew ce, c-v i-965 Chestert. rook Boulevard
, A Unit of PECO Energy Wayne.PA 190874491 r
1, February 25,1999 i
Docket Nos. 50-277 l
50-278 50-352 l
50-353 i
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License Nos. DPR-44 DPR-56 l
NPF-39 NPF-85 1
i U.S. Nuclear Regulatory Commission Attn: Document Control Desk j
Washington, DC 20555 j
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SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 l
Fitness-for-Duty Program Performance Data for
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the Period July 1998 through December 1998 j
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Dear Sir / Madam:
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As required by 10CFR26.71(d)', this letter submits the performance data for PECO Energy's
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Fitness-for-Duty (FFO) Program for the period July 1998 throu0h December 1998. The data for l
our Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and Limerick Ger'erating -
Station (LGS), Units 1 and 2, sites are provided in Attachments 1 and 2. Data for our Corporate i
Office and Nuclear Group (PECO Nuclear) Headquarters specimen collection sites (i.e.,2301 2
- Market Street, Philadelphia, PA, and Berwyn Transportation Center, Wayne, PA, respectively) are provided in Attachment 3.
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u The data are reported on the January 1992 revision of the FFD Performance Data form provided by the Nuclear Energy Institute (NEI), formerly the Nuclear Management and Resources Council (NUMARC), and include thw following.-
Drugs tested for and cut-off levels.
Workforce population tested.
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l Numbers of tests and results by populatioh and type of test (i.e, pre-access, for-cause, random, follow-up, and other types of tests).
Substances identified.
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.j February 25,1999 Page 2 Attachments 1,2, and 3 also include the following.
A summary of management actions.
Analysis of the data and appropriate actions that have beer *eken.
- Random test'ng rate.
During this period, there were two (2) significant events reported to the NRC in accordance with 10CFR26.73. Additional information regarding these events are contained in Attachments 1 and 2.
If you have any questions or require additional information, please contact us.
Very truly yours, 0
/ Garrett D. Edwards Director-Licensing Attachments
. cc:
H. J. Miller, Administrator, Region I, USNRC (w/ attachments)
A. C. McMurtray, USNRC Senior Resident inspector, PBAPS (w/ attachments)
A. L. Burritt, USNRC Senior Resident inspector, LGS (w/ attachments) g.
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I ATTACHMENT 1 Pese ?fom Atomic Power Station i
Units 2 and 3
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I Fitness-for-Duty Performance Data July through December 1998 h
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Fitness for Duty Program (i
Performance Data Personnel Subject to 10CFR 26 k>
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PECO ENERGY COMPANY DECEMBER 31, 1998 i
company a kbnes Ending PEACH BOTTOM ATOMIC POWER STATION Locanon i
DAVID M. SARLEY (215) 841-5703 f
contac: Name Phone Ondude area code)
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Cutoff s: Screen / Confirmation (ng/ml)
O Appendix A to 10CFR 26 Marijuana 50 / 15 Amphetamines 1000 /500
/
Cocaine 300 / 150 Phencyclidine 25 /25
/
Opiates 300 / 300 Alcohol (% BAC) 0.04
/
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Long-Term Short-Term Testing Results Ucensee Employees Contractor Personnel Contractor Personnel Average Number with Unescorted Access 2184 1232 h
Categories.
Tested Positive Ter.ed Positive Tested Positive
- Pre-Access 74 0
1,080 7
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I d-Post accident 1
0 2
0 e
h Observed behavior 3
0 5
1 Random 392 1
368 1
Fo!!ow up 22 0
61 2
Other 6
0 2
0 Total 498 1
1,518 11 i
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Breakdown cf Confirmed Por.itiva Tests f:r Specific Substances Amphe-Phency-Refusal Marijuana Cocaine Opiates
- tamines eBdine.
Alcohol to Test -
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-_Ucensee Employees 1
0 0l 0
0 0
0 Long Term Contractors Short-Term Contractors
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Attachmer.
Summary of Data Analysis and snagement Actions Peach Bottom Atomic Po r Station July-December 19M l.
Initiatives Taken The following summarizes the results of sweeps conducted during the period by PECO Energy's drug sniffing canine teams as well as investigations and interviews used to confirm information about illicit activities at Peach Bottom Atomic Power Station (PBAPS).
July 7,1998 - For cause interview of a contractor employee working on the spent fuel a.
construction project in the Owner Controlled Area (OCA). (Unescorted access is not required.) The contractor had been uncooperative with drug testing personnel. During the interview the contractor employee disclosed smoking marijuana over the July 4,1998, holiday weekend. The contractor employee refused to submit to drug testing. Site access was
- denied, b.
July 16,1998 - For cause interview of a contractor employee who made suspect comments regarding drug use. During the interview the contractor employee admitted to smoking marijuana on a weekly basis with last use on July 11,1998. Unescorted access was denied.
July 16,1998 - Follow-up team sweep of the Unit 1 Chemistry Laboratory, Oxygen Recharge c.
Room, Maintenance in tructors Office and the Training Counter, Health Physics and Chemistry Laboratory. Results: Four (4) activations. Seven (7) forensic samples taken for analysis. Analysis revealed no presence of controlled substances.
d.
August 4,1998 - For cause interview of a contractor seeking unescorted access. Contractor disclosed 1994 arrest for possession of marijuana and cocaine. Contractor claimed last drug use was November 1994. Contractor submitted to a demand psychological intervis# and was granted unescorted access with accelerated unannounced testing requirement.
August 10,1998 - For cause interview of an eaip oyee after the detection of the odor of e.
alcohol. Employee admitted excessive alcohol consumption on the previous day and disclosed a previous positive drug test. BAC test results at approximately 1' 00a.m. were just 1
under the cut-off level. Search of vehicle was negative for coltraband. Unescorted access granted.
f.
Augus! 31,1998 - For cause interview of a contractor seeking unescorted access.
Contractor disclosed two (2) recent DUI cc 7ictions. During the interview the contractor disclosed additional arrost (one of which was alcohol related - Disorderly Conduct) that were not disclosed on screening affadavit. Contractor claimed last marijuana use was in 1993.
Unescorted access was denied.
g.
September 9,1998 - For cause interview of an employee following breath alcohol test with detectable alcohol less than cut-off level. Employee admitted to alcohol consumption the l
previous evening. The employees vehicle was searched to ensure that no alcoholic beverages were on station property. None were found. Unescorted access was granted.
h.
September 9,1998 - For cause interview of a contractor employee seeking unescorted access. Contractor disclosed 1997 arrest and conviction for possession of drug paraphemalia. Cc;) tractor subsequently tested positive for cocaine. Unescorted access was denW.
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September 19,1998 - For cause interview of a contractor employee seeking unescorted access. Contractor disclosed a history of five (5) DUI arrests and convictions, with the most j
recent occurring April 1997. Contractor provided documentation indicating his alcohol dependence / disease required continual support system on a regular basis; however, no such support system was identified. Contractor submitted to a demand psychological evaluation.
Unescorted access was denied.
J.
September 11,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed two (2) 1997 DUI convictions. Contractor submitted to a demand psychological evaluation and was placed on accelerated drug and alcohol testing program. Unescorted access was granted.
k.
September 11,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed a recent (August 1998) DUI conviction and provided documentation showing completion of a Department of Motor Vehicle First Offender Program.
Unescorted access was granted.
1.
September 14,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed two (2) recent DUI convictions. The contractor employee had not completed a prescribed alcohol education / intervention program. Unescorted access was denied.
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- m. September 15,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed multiple substance and alcohol related convictions, as well as a positive drug test from a previous employer. The contractor also admitted to recent illicit i
drug use. Unescorted access denied.
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- n. September 16,1998 - For cause vehicle search of a contractor's car based upon the observation of what appeared to be a beer keg. Investigators conducted a consensual search and determined that a quantity of beer was still present in the container. A brewery outlet deposit slip bearing the contractors name was also discovered. For cause drug and alccM testing was conducted with negative results. Unescortet access denied.
September 16,1998 - For cause interview of a contractor employee seeking unescuted o.
access. The contractor admitted to multiple drug related offenses and convictions.
Unescorted access denied, p.
September 16, i998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed multiple alcohol and substance related convictions between 1991 and 1996. The contractor submitted to a demand psychological evaluation.
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Unescorted access was denied.
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September 16,1998 - For cause interview based upon a disclosed criminal history of a contractor employee seeking unescorted access. Narcotic canine utili7.ed to search the contractor's vehicle. Results: One (1) activation. No drugs or forensic samples taken. The contractor was subsequently granted unescorted access.
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Sepicmber 17,1998 - For cause interview of a contractor employee seeking unescorted access. CGntractor disclosed multiple alcohol and substance related offenses as well as a 1
March 1996, positive test for marijuana. The contractor claimed to be drug free for the past i
seven months. Unescorted access was denied, i
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September 17.,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed multiple alcohol and substance related convictions including the delivery of a controlled substance. The contractor admitted to abusing prescription pain medication to des with depression. Additionally, the contractor admitted to fleeing the State of Florida due to a DUI arrest. Unescorted access was denied.
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September 17,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed two (2) DUI convictions, as well as a pending (Au90st 1998) DUI arrest. Unescorted access was denied.
- u. September 17,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor admitted a 1990 conviction for Possession of Marijuana and a 1991 arrest for Public Drunkenness. The contractor claimed that last drug use was three (3) years j
ago. The contractor was placed on accelerated testing and granted access.
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September 21,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed recent use of marijuana, as well as pending DUI charges.
Unescorted access was denied.
1
- w. September 21,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor was previously denied access to PECO Energy facilities in 1991. The l
contractor had an extensive history of drug use and heroin addiction. The contractor provided 5
documentation of 1993 rehabilitation program. The contractor submitted to a demand psychological evaluation. The contractor was placed on accelerated tWJng and unescorted i
access was granted.
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Septernber 22,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed two (2) DUI convictions as recent as September 1998. The l
contractor had not completed court ordered rehabilitation. Unescorted access was denied.
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September 22,1998 - For cause interview of a contractor employee seeking unescorted l
access. The contractor disclosed three (3) alcohol related convictions as well as an alcohol-
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related incident in the military. Unescorted access was denied.
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Septe nber 22,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed past drug dealing, drug related convictions and cocaine l
addiction. Contractor provided proof of completing rehabilitation in 1989. The contractor submitted to a demand psychological evaluation. The contractor was placed on accelerated testing and unescorted access was granted.
aa. September 23,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor was ideatified as a former PECO Energy employce who had been j
terminated for drug use. The contractor disclosed a 1993 DUI conviction, as well as failing to complete a 1995 rehabilitation program for methamphetamine abuse. Unescorted access J
was denied.
bb. September 24,1998 - For cause interview of a contractor employee seeking unescorted l
access. The contractor disclosed two DUI convictions and was known to Security based upon a 1996 alcohol-related incident at Peach Bottom. The contractor submitted to a demand i
psychological evaluation. The contractor was placed on accelerated testing and unescorted access was granted.
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cc. September 25,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed four DUI convictions and a 1995 convi:: tion for Possession of Drug Paraphernalia, as well as a violation of probation as the result of a positive drug test.
The individual admitted to relapse and crack cocaine addiction. Unescorted access was denied.
dd. September 25,1998 -General team sweep of the spent fuel construction project site. Three (3) trailers and thirty-nine (39) personal vehicles were searched. Results: Five (5) activations. No forensic samples taken.
ee. September 29,1998 - For cause interview of a contractor eniployee with unescorted access who tested positive for cocaine. The contractor would not cooperate nor answer questions regarding his alleged drug use. The contractor suggested that someone may have put cocaine in his beer. A consensual search of the contractors vehicle was performed with negative results. Unescorted access was denied.
ff. September 29,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed a 1998 positive drug test and DUI conviction. The i
contractor provided proof of rehabilitation. The contractor was placed on accelerated testing and unescorted access was granted.
gg. September 30,1998 - For cause interview of a contractor employee seeking unescorted access. The contractor disclosed four (4) DUI convictions and provided proof of rehabilitation.
The contractor subn#ted to a demand psychological evaluation. The contractor was placed on accelerated teC 1g and unescorted access was granted.
hh. October 1,1998 - For cause interview of a contractor employee seeking unescorted access.
The contractor disclosed previous drug use in 1996. The contractor was placed on accelerated testing and unescorted access was granted.
ii. October 2,1998 - For cause interview of a centractor employee seeking unescorted access.
i The contractor disclosed dated drug use. The contractor was placed on accelerated testing and unescorted access was granted.
jj. October 13,1998 - General team sweep of Seal Team Break / Muster Area, General Electric Offices, and Nuclear Maintenance Division Offices. Results: Two (2) activations. No forensic samples taken.
kk. October 29,1998 - An investigation was initiated based upon the discovery of a suspected hand rolled marijuana cigarette found within the Protected Area. The suspect item was field tested with negative results. No further action was deemed necessary.
II. November 10,1998 - For cause interview of a cc,1 tractor employee assigned to the spent fuel construction project in the Owner Controlled Area (OCA). (Unescorted access is not required for the OCA.) The contractor disclosed a recent arrest for DUI as well as a previous DUI i
conviction. The contractor was placed cri accelerated testing and allowed to continue the work assignment.
mm. November 12,1998 - For cause interview of a contractor assigned to the spent fuel construction project based upon suspected adulteration of a urine sample provided for drug testing. The contractor admitted adulteration of the sample and recent marijuana use, as well as a relapse with alcohol use. Access to the site was denied.
nn. December 8,1998 - For cause Security Recheck Interview of supervisor employee who had i
a confirmed positive test for marijuana November 6,1998. - The individual admitted smoking marijuana at a Halloween Party; however, the individual also revealed he had informed his substance abuse treatment psychologist the positive test was caused by nassive inhalation.
Unescorted acce_ps was denied.
oo. December 9,1998 - General team sweep of the Chemistry Technician's Office, Bartlett Field Office, Maintenance and I & C Office Spaces in the Administration Building, Maintenance Tool Room and the Site Management Building, to include the Telecommunications Room and Plant Engineering spaces. Results: Ten (10) activations and one (1) forensic sample taken. An employee was discovered with what appeared to be numerous expired prescription pain medications. Laboratory results revealed the substance to be a non-prescription medication.
pp. December 30,1998 - For cause interview of an employee who had completed drug and alcohol testing when scheduled (8:50 a.m. on December 23,1998). The employee disclosed excessive drinking the night prior to the test as well as relapsing with alcohol six (6) months after treatment. The employee advised he was worried about the possible FFD test results
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and that this concern led to an asthma attack and an anxiety attack on the date the testing was scheduled. The employer was treated and sent home by Occupational Health clinical personnel who forgot the emply se was to submit to FFD testing. Clinical personnel j
contacted the employee at home and directed him to return to the site for testing. Testing, i
subsequently completed at 3:55 p.m., revealed a BAC of.024 upon initial screening and.023 l
upon confirmation. A demand psychological evaluation found the employee unsuitable for unescorted access. The employee was referred to the employee assistance program.
Unescorted access was denied.
ll.
Manaoement Actions During the period, eleven (11) contractor employees tested positive, i.e., seven (7) pre-access, one (1) random, one (1) for cause, two (2) follow-up, at PBAPS. Unescorted access was denied the contractor employees.
During the period, one (1) employee tested positive on a random test at PBAPS. The employee was referred to the Employee Assistance Program for evaluation and treatment. Unescorted access was denied the employee.
111.
Events Reported Under 10 CFR 26.73 There was one (1) significart FFD event reported by PBAPS during the period. The event involved the confirmed positive urinalysis test for marijuana of a non-licensed PECO Nuclear Maintenance Supervisor.
IV.
Audits / Inspections 1
During the period the Nuclear Quality Assurance Group completed the required annual audit of l
the FFD program. The assessment found that the PECO FFD program is being effectively implemented in accordance with 10 CFR Part 26. Strengths identified include: the on-site i
screening facility, the use of a suspicion-based process for pernicious adulterant - potassium
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nitrite, and the laboratory's strategy for dealing with a commercially available adulterant which is i
mark sted to drug users as a way to mask the presence of marijuana metabolites in urine specimens. The FFD Manager's background and experience was cited for bringing "... continuity to the program and ensurcs consistent application of the program." Corrective actions to previously identified issues were timely and effective in resolving concerns; however, it was noted that data entry of issue responses occasionally lagged behind actual implementation.
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.f The semi-annual reports submitted to the NRC and PECO Energy Management were found to provide a suitable self-assessment of the performance of the FFD program by the FFD Manager.
The NRC provided positive verbal feedback concerning the quality of the reports. In addition to the semi-annual report, continuing self-assessment of the process is provided by the FFD Manager through review of data, testing, and blind performance test specimens.
As a result of this assessment two ( 2) level 3 PEPS were issued which are administrative in nature. The first PEP identified that the calibration on a lab thermometer specified an incorrect calibration frequency. The second PEP identified a weakness in the timeliness of procedure distribution, manual maintenance and exhibit administrative control. The PEP issues were noted to not adversely impact the overall effectiveness of the FFD program.
V.
Random Testina Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is normally conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and Limerick Generating Station (LGS).
During the period, the random testing rate was raised to address concerns identified during the reporting period of January - June 1998. The actual annualized rate during the period for PECO Energy employees was 86%. Contractor personnel were tested at an annualized rate of 103%.
In view of the results identified during this reporting period, the annualized random rate will be reduced to 50% for the reporting period of January - June 1999.
VI.
Additional information Actions Taken based upon Unconfirmed On-site Screenina PECO Energy has elected to temporarily suspend access for individuals as permitted by 10 CFR 26.24(d).
During the previous 6-month reporting period (i.e., January - June 1998),100% of the specimens which were presumptive positive for cocaine as a result of preliminary on-site screening tests were subsequently reported as positive by the HHS-certified laboratory. The confirmation rate for specimens which were presumptive positive for marijuana was 78.5%. Therefore, in accordance with 10 CFR 26.24(d) actions could only be taken during this reporting period on specimens which were presumptive positive for cocaine.
During the current reporting period, nine (9) specimens were reported as presumptlve positive for marijuana as a result of on-site screening at the PBAPS and LGS on-site test;ng facinty. Six (6) of those specimens screened po.sitive and were confirmed as positive by the HHS-certifie.d laboratory. The Medical Review Officer verified the six (6) specimens as positive. No action was taken based upon an unconfirmed presumptive positive test for marijuana since the confirmation rate for specimens which were presumptive positive was less than 85% during the previous reporting period.
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. During the current reporting period, five (5) specimens were reported as presumptive positive for i
cocaine as a result of on-site screening at the PBAP3 and LGS on-site testing facility. All five (5) i spwimens screened positive and were confirmed as positive by the HHS-certified laboratory.
l The Medical Review Officer verified the five (5) specimens as positive. Additionally, three (3)
. Individuals tested positive for cocaine on dilute specimens submitted directly to the HHS-certified laboratory for special processing. Four (4) of the five (5) presumptive positives were the result of prs-access testing. Unescorted access was temporacily suspended as a result of a presumptive rositive follow-up test for one (1) Individual. Unescorted access was subsequently denied following Medical Review Officer verification.
i Reduced Marijuana Cut-off Level i
During the period, there was six (6) confirmed positive tests for marijuana at PBAPS. It is estimated that none of the specimens would not have tested positive using the 100 ng/mi
- immunoassay cut-off level.
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ATTACHMENT 2 Limerick Generating Station Units 1 and 2 Fitness-for-Duty Performance Data-i July through December 1998 i
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Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 l
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i l-PECO ENERGY COMPANY
_ DECEMBER 31. 1998 company a Monms Ending l
l LIMERICK GENERATING' STATION 1
Locanon s
DAVID M. SARLEY (215) 841-5703 contac:Name Phone (ine'une area codel l
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Cutoff s: Screen / Confirmation (ng/ml) -
O Appendix A to 10CFR 26 j
M:rijuana 50/15 Amphetamines 1000 / 500
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Cocaine 300/150 Phencyclidine 55 / 25
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Opiates 300/300-Alcohol (% BAC) 0.04%
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Long-Term Short-Term Testing Results Licensee Employees Contractor Personnel Contractor Personnel Average Number with Unescorted Access 2184 1232 Categories Tested Positive Tested Positive Tested Positive Pre Acces 56 0
344 5
- f l Pos! ECCident i
14 0
4 0
P.
h Observed behavior 2
0 2
0 Random 441 0
224 0
Follow-up
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7 0
Other 11 0
1 0
Total-538 0
582 5
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Summary of Data Analysis and Management Actions Corporate and PECO Nuclear Headquarters July-December 1998 l.
Initiatives Taken The following summarizes the results of sweeps conducted during the period by PECO Energy's drug sniffing canine tears as well as investigations and interviews used to confirm information about illicit activities at ti,e PECO Nuclear Headquarters.
II.
Manaoement Actions There were no positive tests identified during the period.
Ill.
Events Reported Under 10 CFR 26.73 There were no events reported during the period.
IV.
Audits /Inscections During the period the Nuclear Quality Assurance Group completed the required annual audit of the FFD program. The assessment found that the PECO FFD program is being effectively implemented in accordance with 10 CFR part 26. Strengths identified include: the on-site screening faci'ity, the use of a suspicion-based process for pernicious adulterant - potassium nitrite, and the laboratory's strategy for dealing with a commercially available adulterant which is marketed to drug users as a way to mask the presence of marijuana metabolites in urine specimens. The FFD Manager's background and experience was cited for bringing ".. continuity to the program and ensures consistent application of the program." Corrective actions to previously identified issues were timely and effective in resolving concerns; however, it was noted that data antry of issue responses occasionally lagged behind actual implementation.
The semi-annual reports submitted to the NRC and PECO Energy Management were found to provide a suitable self-assessment of the performance of the FFD program by the FFD Manager.
The NRC provided positive verbal feedback conceming the quality of the reports. In addition to the semi-annual report, continuing self-assessment of the process is provided by the FFD Manager through review of data, testing and blind performance test specimens.
As a result of this assessment two ( 2) level 3 PEP's were issued which are administrative in nature. The first PEP identified that the calibration on a lab thermometer specified an incorrect calibration frequency. The second PEP identified a weakness in the timeliness of procedure distribution, manual maintenance and exhibit administrative control. The PEP issues were noted to not adversely impact the overall effectiveness of the FFD program.
V.
flandom Testino Rate l
PECO Energy maintains, separate testing " pools" for employees and contractors. Random testing is normally conducted at an annualized rate of 50%. The " average number with unascorted access" includes personnel gran.ed unescorted access at both Peach Bottom Atomic Power Station (PBAPS) and Limerick Generating Station (LGS).
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- 3 Fitness for Duty Program i
Performance Data Personnel Subject to 10CFR 26 6;.
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PECO ENFRGY COMPANY DECEMBER 31, 1998 Company -
4 Months Ending l
CORPORATE'AND PECO NUCLEAR HEADQUARTERS Locanon DAVID M. SARLEY (215) 841-5703 Con:ac: Name Phone (include area code)
Cutoffs: Screen / Confirmation (ng/ml)
O Appendix A to 10CFR 26 50 15 Amphetamines 1000 / 500 f
Marijuana
/
Cocaine 300/150 Phencyclidine 55 / 25
/
Opiates I
Alcohol (% BAC) 0.04%
I 300 300
-t Long-Term Short-Term Testing Results Licensee Employees Contractor Personnel Contractor Personnel Average Number witt-
,,184 1232 Unescorted Access Categories.
Tested Positive Tested Positive Tested Popive Pre-Access 9
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Post accident 2
0 0
0 9
h Observed behavior 0
0 0
0 Random 114 0
30 0
Follow up 13 0
0 0
Other 3
0 0
0 Total' 141 0
31 0
, prv.1/92
Breakdown of Confirmed Positive Tests for Specific Substances Amphe-Phency-Flefusal Marijuana Cocalno Oplates famines clidino Alcohol to Test 1
2 3
4 5
Ucensee Employees 0
0 0
0 0
0 0
Long-Term Contractors Short-Term Contractors 0
0 0
0 0
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1 ATTACHMENT 3 Corporate and PECO Nuclear Headquarters -
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Fitram-for-Duty Performance Data l.
July through December 1998 i
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Additional information Actions Taken based upon Unconfirmed On-site Screenina PECO Energy has elected to temporarily suspend access for individuals as permitted by 10 CFR 26.24(d).
During the previous 6-month reporting period (i.e., January - June 1998),100% of the specimens which were presumptive positive for cocaine as a result of preliminary on-site screening tests were subsequently reported as positive by the HHS-certified laboratory. The confirmation rate for specimens which were presumptive positive for marijuana was 78.55 Therefore, in accordance with 10 CFR 26.24(d) actions could only be taken during this reporting period on specimens which were presumptive positive for cocaine.
During the current reporting period, nine (9) specimens were reported as presumpti/e positive for marijuana as a result of on-site screening at the PBAPS and LGS on-site testing facility. Six (6) of those specimens screened positive and were confirmed as positive by the HH4 certified laboratory. The Medical Review Officer verified the six (6) specimens as positive. No action was taken based upon an unconfirmed presumptive positive test for marijuana since the confirmation rate for specimens which were presumptive positive was less than 85% during the previous reporting period.
During the current reporting period, five (5) specimens were reported as presumptive positive for cocaine as a result of on-site screening at the PBAPS and LGS on-site testing facility. All five (5) specimens screened positive and were confirmed as positive by the HHS-certified laboratory.
The Medical Review Officer verified the five (5) specimens as positive. Additionally, three (3) individuals tested positive for cocaine on dilute specimens submitted directly to the HHS-certified laboratory for special processing. Four (4) of the five (5) presumptive positives were the result of pre-access testing. Unescorted access was temporarily suspended as a result of a presumptive positive follow-up test for one (1) individual. Unescorted access was subsequently denied following Medical Review Officer verification.
Reduced Marijuana Cut-off Level j
During the period, there were no confirmed positive tests for marijuana at LGS.
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December 16,1998 - Random drug dog sweep of a Tool Building. Results: One (1) r.
activation. No evidence of drugs or forensic samples taken.
II.
Manaaement Actions During the period, five (5) contractor employees tested positive on pre-access tests at LGS.
Unescorted access was denied the five (5) contractor employees.
Ill.
Events Reported Under 10 CFR 26.73 During the period there was one (1) significant FFD event reported by telephone under 10 CFR 73.71 by LGS. The event involved the discovery that a contractor employee had been granted unescorted access based upon the erroneous data entry of the pre-access FFD screening test.
No events were reported undnr 10 CFR 26.73.
IV.
Audits / inspections During the period the Nuclear Quality Assurance Group completed the required annual audit of the FFD program. The assessment found that the PECO FFD program is being effectively implemented in accordance with 10 CFR part 26. Strengths identified include: the on-site l
screening facility, the use of a suspicion-based process for pernicious adulterant - potassium nitrite, and the laboratory's strategy for dealing with a commercially available adulterant which is marketed to drug users as a way to mask the presence of marijuana metabolites in urine i
specimens. The FFD Manager's background and experience was cited for bringing "... continuity to the program and ensures consistent application of the program." Corrective actions to previously identified issues were timely and effective in resolving :oncerns; however, it was noted that data entry of issue responses occasionally lagged behind actual implementation.
The semi-annual Toorts submitted to the NRC and PECO Energy Management were found to provide a suitable self-assessment of the performance of the FFD program by the FFD Manager.
The NRC provided positive verbal feedback conceming the quality of the reports. In addition to the semi-annual report, continuing self-assessment of the process is provided by the FFD Manager through review of data, testing and blind performance test specimens.
As a result of this assessment two ( 2) level 3 PEP's were issued which are administrative in nature. The first PEP identified that the calibration on a lab thermometer specified an incorrect calibration frequency. The second PEP identified a weakness in the timeliness of procedure distribution, manual maintenance and exhibit administrative control. The PEP issues were noted to not adversely impact the overall effectiveness of the FFD program.
V.
Random Testina Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is normally conducted at an annualized rate of 50% The " average number with unescorted access" includes personnel granted unescorted access at both Peach Bottom Atomic Power Station (PBAPS) and LGS.
During the period the random testing rate was raised to address concems identified during the reporting period of January through June 1998. The actual annualized rate during the period for PECO Energy employees was 86% Contractor personnel were tested at an annualized rate of 103 %
in view of the results identified during this reporting period, the annualized random rate will be reduced to 50% for the reporting period of Januaiy - June 1999.
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September 9,1998 - Random drug dog sweep of the Kemper Building,3" floor. Results:
Five (5) activations. No evidence of drugs or forensic samples taken.
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September 15,1998 - For cause interview of an employee, based upon a self-reported DUI incident, to determine circumstances and possible drug or alcohol use. Unescorted access was temporarily suspended during the investigation. The employee admitted to alcohol abuse resulting in the DUI incident. A medical evaluation was conducted and unescorted access was subsequently reinstated.
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October 6,1998 - Random drug dog sweep of the Site Management Building,2* floor.
Results: Four (4) activations. No evidence of drugs or forensic samples taken.
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October 31,1998 - For cause interview of a contractor employee to determine the circumstances and possible drug or alcohol involvement related to an allegation of abuse initiated by the employee's spouse which resulted in Court ordered protection from abuse. No indication of substance abuse was determined. Unescorted access was continued.
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November 16,1998 - For cause interview of a contractor employee who disclosed a drug arrest at the time of application for unescorted access. The contractor admitted to an arrest in 1992, and subsequent court disposition for possession of methamphetamine and DUI. The i
contractor admitted a pattern of use of methamphetamine from 1986 to 1992, but denied any drug use since that time. A demand psychological evaluation was conducted. The contractor was placed on accelerated testing and unescuted access was granted.
- m. Decemoer 2,1998 - For cause interview of contractor as a result of a laboratory report indicating a tampered pre-access urine sample. The contractor admitted to intentionally adulterating his sample to avoid detection of illegal drugs in his system. The contractor had been granted unescorted access as a result of erroneous data entry of the initial screoning test. Subsequent investigation determined no evidence of collusion with the individual responsible for the data entry error. Unescorted accese was denied.
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December 7,1998 - For cause interview of an employee based upon a self-reported DUI incident to determine circumstances and possible alcohol or drug use. Unescorted access was temporarily suspended during the investigation. The employee admitted to abuse of alcohol which resulted in the DUI incident. A medical evaluation was also conceted. The employee was placed on accelerated testing and unescorted access was reinstated.
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December 8,1998 - An unknown white powder packaged in several clear plastic bags was discovered in the desk of a recently terminated employee. The desk was within the Protected Area. A field drug test was performed on the powder with no indication of illegal drugs.
Forensic laboratory analysis of the powder revealed no indication of illegal drugs.
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December 14,1998 - For cause interview of an employee based upon a self-reported DUI incident to determine circumstances and possible alcohol or drug use. Umcorted access was temporarily suspended during the investigation. The employee ad.uM to abuse of alcohol which resulted in the DUl incident A medical evaluation was also conducted. The employee was placed on accelerated testing and unescorted access was reinstated.
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December 14,1998-For cause interview of an employee based upon a self-reported DUI incident to determine circumstances and possible alcohol or drug use. Unescorted access was temporarily suspended during the investigation. The employee admitted to abuse of alcohol which resulted in the DUI incident. A medical evaluation was also conducted. The employee was placed on accelerated testing and unescorted access was reinstated.
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Summary of Data Analysis and Management Actions Limerick Generating Station July-December 1998 1.
Initiatives Taken The following summarizes the results of sweeps conducted during the period by PECO Energy's drug sniffing canine teams as well as investigations and interviews used to confirm information about illicit activities at Limerick Generating Station (LGS).
a.
July 7,1998 - Random drug dog sweep of the Site Services Building,3'S and 4* floor areas.
Results: Twelve (12) activations. No evidence of drugs or forensic samples taken.
b.
July 8,1998 - Following a retum-to-work medical evaluation, and prior to reinstating unescorted access, a for cause interview was conducted with an employee who tested positive on a June 1998, random FFD test. During the interview, the employee admitted to marijuana use prior to the random test and a habitual pattern of marijuana abuse for the previous fifteen (15) years. No evidence of drugs was identified during a consensual search of the employee's personal vehicle. The interview results indicating habitual marijuana use was communicated to management who, in turn administered more severe disciplinary consequence c.
July 16,1998 - For cause interview of an employee to determine the circumstances and possible drug or alcohol involvement related to an allegation of abuse initiated by the employee's spouse which resulted in Court ordered protection from abuse and criminal charges. Unescorted access was suspended during the investigation. No indication of wbstance abuse was identified during the investigation. Unescorted access was reinstated l
9ter the civil and criminal issues were resolved.
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July 22,1998 - Based upon a self-reported DUI incident, a for cause interview of an employee was conducted to determine the circumstances and possible alcohol or drug use.
' Unescorted access was temporarily suspended during the investigation. Unescorted access was subsequently reinstated upon completion of the investigation, j
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July 31,1998 - Random drug dog sweep of the Training Center. Results: Two (2) activations. No evidence of drugs or forensic samples taken.
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August 14,1098 - For cause interview of a Contracted Security Force Member to determine the circumstsnces and possible drug or alcohol involvement related to an allegation of abuse initiated by the contractor's spouse which resulted in Court ordered protection from abuse.
The interview revealed no indication of substance abuse. The court order was subsequently dismissed.
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August 27,1998 - For cause interview of an employee to determine the circumstances and possible drug or alcohol involvement related to a reported Stalking and Harassment charge.
No indication of cicohol or drug involvement was discovered. The charges were subsequently dropped.
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During the period the random testing rate was raised to address concems identified during the
. reporting period of January througn June 1998. The actual annualized rate during the period for PECO Energy employees was 86%. Contractor personnel were tested at an annualized rate of 103%.
In view of the results identified during this reporting period, the annualized random rate will be reduced to 50% for the reporting period of January - June 1999.
VI.
Additional information i
Actions Taken based upon Unconfirmed On-site Screenino i
Specimens collected at the Corporate and PECO Nuclear Headquarters are forwarded directly to the HHS-certified laboratory for testing. On-site screening is not conducted.
Reduced Marijuana Cut-off Level There were no positive tests for marijuana during the period.
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