Text

Rev 11 to Procedure VPAP-0105, Fitness for Duty Program
	ML20236H563
Person / Time
Site:	North Anna
Issue date:	02/10/1998
From:	; VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	;
Shared Package
ML20236H449	List: ML20236H447; ML20236H508; ML20236H531; ML20236H539; ML20236H554; ML20236H556; ML20236H563; ML20236H570;
References
	VPAP-0105, VPAP-105, NUDOCS 9807070261
	Download: ML20236H563 (71)
	v • d • e

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iS6 VA. POWER N.ANr#A ADMIN. LOBBY P.9/10 VIRsfilli@NR PROPERTY Thio drousent is the yrsporty cf FOR INFORIAAT103 VIRGINI1 Potrra and in to ha returned uponreq aest.No permissien ts granted ta pub 1; sh, re e, tranesit. or ticoles>t inforestion mname .

Station Admm.is. trative

t. .

VIRGINIA POWER Procedure 1

.. C 1998 by %rges. Power. All Raghes Reserved l

Title:

Fitness For Duty Program j

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! Process / Program Owner: Manager - Nuclear Security and Administrative , '

! ' Services ~

Procedure Number Revision Number Effective Date i VPAP'-O'1 05 11 02 -/O-E l

Revlulen Summary The following changes were made in response to DR S-97-3435, DR N-97-3309, &

DR S 97-3440 (Supervisors Missing Fitness For Duty Supervisor Training):

. Added Supervisor 3.2.2 Training)- DRs S-97-3435, N-97-3309, & S 97-3440 (Supervisors Missing

. Added 5.1.15 (urider Fitness For Duty Program Manager responsibilities) " Ensurin i

Nuclear Business Unit. Managers receive Fitness For Duty Supervisor training in a 6.1.12.b. [ Commitment 3.2.2]" ,

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. Revised 5.2, Nuclear Business Unit Managers- new title (formerly Station !Wanager) l Added 5.2.5 " Ensuring that new supervisors within their departments receive

! Supervisor training in accordance with 6.1.12.b [ Commitment 3.2.2]"

l Revised 6.1.12.b - added instructions for completion of Supervisor Training

[ Commitment 3.2.2]

The following changes were made due to reengineering:

. Revised 6.3.3.b title change: " Nuclear Administrative Services" to " Nuclear Secu Administrative Services" l

Revised 6.7.10.a - changed " Personal Representative" to "HR Representative" '

l The following changes were made for clarification

Revised 4.7, Follow Up Testing - changed " employee" to " individual"

. Revised 6.1.1.b, Random Testing - rewrote definition {

. Revised 6.1.1.i.2, third bullet - changed "The Licensing Submittal is prepared for time notification manner" of the NRC" to "NL&OS is notified so that they may notify the NRC ~

TRevision Summary continued on Page 2)

Approvals on File 9807070261 990630 PDR ADOCK 050 38

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. VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 2 OF 71 Revision Summary (continued)

. Revised 6.1.2.f.1 - changed " Medical Review Officer's review has been completed and the FFDA has been notified" to " Medical Review Officer has completed his review and notified the FFD Administrator" Revised 6.1.6.1 - changed " Virginia Power employees who refuse to cooperate with the random

- testing program" to " Virginia Power employees who refuse to cooperate during the chemical

' testing portion of the Fitne'ss for Duty Program

. Revised 6.1.9.c.1 - changed "to maintain" to "for maintaining"

. Revised 6.3.3 - to clarify policy for contractor and vendor employees that travel between Virginia !

. Power Nuclear Stations (Surry and North Anna)

. Revised 6.4.2. NOTE - added "or if for-cause testing should have been performed but was not" and !

"and for cause testing (if applicable)"

Revised 6.4.9 - changed " drug and alcohol testing" to " Fitness for Duty specimen collection process"

. Revised 6.4.11 - changed "Upon completion of the For Cause testing process" to "Upon receipt of -

the test results"

. Revised 6.7.10 - changed " continual" to " consecutive"

. Revised 6.8, Self Reporting - reformatted to 6.8.1 & 6.8.2 and reworded

. Revised Attachment 5, Fitness For Duty /Self-Reporting Notification l-Revised Attachment 6, Fitness For Duty Record Request /Checidist b

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VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 3 OF 71 TABLE OF CONTENTS Section Page 1.0 PURPOSE 5 2.0 SCOPE 5

3.0 REFERENCES

/ COMMITMENT DOCUMENTS 5 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 8 6.0 INSTRUCTIONS 15 6.1 Fitness For Duty Program Administration 15 6.1.1 ChemicalTesting 15 61.2 Operation of Specimen Collection Sites and Testing Facilities 18 6.1.3 HHS Certified Laboratory 21 6.1.4 QC Program for Testing Process 23 6.1.5 Employee Assistance Program 23 6.1.6 Management Actions and Sanctions 24

' 6.1.7 Appeals 27 6.1.8 Protection ofInformation 28 6.1.9 Inspections 29 6.1.10 Record keeping 30 6.1.11 Reporting Requirements 31 6.1.12 Training Requirements 32 6.1.13 Contractor and Vendor Fitness For Duty Requirements 33 6.1.14 Pre-Access Testing by Contractors / Vendors 34 6.1.15 Audits 35 6.1.16 Program Self-Assessment 36

VIRGINIA -

VPAP-0105 POWER REVISION 11 PAGE 4 OF 71 TABLE OF CONTENTS (continued)

Section Page i

6.2 Random Drugand AlcoholTesting 37 I 6.3 Pre-Access Drug and Alcohol Testing 42 1

6.4 For Cause Drug and Alcohol Testing 43 6.5 Follow-Up Drug and Alcohol Testing 48 6.6 Detection of Aberrant Behavior 50 4 1

6.7 Continual Behavioral Observation Program 53 i 6.8 Self Reporting 56 6.9 Fitness For Duty Call-Out Process 56 6.10 Emergency Response Fitness For Duty Requirements 58 7.0 RECORDS 60 ATTACHMENTS 1 Fitness For Duty Management Action Report - 730721(July 96) 61 2 1 Preli;9 Nary Alcohol Concentration Chart - 730722(Jan 97) 63 3 Fitness For Duty Continual Behavioral Observation Event Report - 730719(July 96) 65 ;

4 Unescorted Access Authorization Activity / Fitness for Duty Certification - 720684(July 96) 67 5 Fitness For Duty /Self-Reporting Notification - 722847(Oct 97) 69 6 Fitness For Duty Record Request / Checklist - 72248G(Oct 97) 71 4

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VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 5 OF 71 1.0 PURPOSE 1.1 This procedure establishes '.he requirements, responsibilities, and methodology to provide reasonable assurance that Nuclear Powet personnel perform their tasks in a reliable and trustworthy manner and are not under the influence of any substance, legal or illegal, or mentally impaired from any cause, which in any way adversely affects their ability to safely and competently perform their duties. [ Commitment 3.2.1]

1.2 This procedure provides reasonable measures for the deterrence and early detection of persons who are not fit to perform their duties. ,

i 1.3 This procedure establishes the process for a drug-free and alcohol-free workplace and a - I workplace free of the effects of such substances.

2.0 SCOPE 2.1 This procedure applies to Virginia Power employees, contractors, and vendors who are granted unesccited access at North Anna Power Station and Suny Power Station.

2.2 This procedure applies to Virginia Power employees, contractors, and vendors who are !

required to physically report to the Technical Support Center (TSC) or the Emergency Operations Facility (EOF) in accordance with emergency plans and procedures.

2.3 This procedure does not apply to NRC employees, or to law enforcement, offsite emergency fire or medical, or state emergency services response personnel while responding on-site.

3.0 REFERENCES

/ COMMITMENT DOCUMENTS 3.1 References 3.1.1 10 CFR 26. Fitness-For-Duty Program 3.1.2 10 CFR 73.56. Personnel Access Authorization Requirements for Nucicar Power Plants 3.1.3 NUREG-1385, Fitness for Duty in the Nuclear Power Industry: Responses to implementation Questions 3.1.4 NRC Regulatory Guide 5.66, Access Authorization Program for Nuclear Power Plants 3.1.5 NUMARC 91-03, Nuclear Power Plant Access Authorization Data Exchange Guidelines j 3.1.6 ASNS-0105, Fitness For Duty 3.1.7 ASCP-0001, Fitness For Duty Program Administrators 3.1.8 Nuclear Access Requirements for Virginia Power Nuclear Contractors and Vendors 1

VIRGINIA VPAP-0105 POWER REVISION 11

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3.2 Commitment Documents

-3.2.1 10 CFR 26, Fitness-For-Duty Program 3.2.2 DRs S-97-3435, N-97-3309, & S-97-3440 (Supervisors Missing Fitness For Duty Supervisor Training) 4.0 DEFINITIONS l 4.1 Aliquot A ponion of a specimen used for testing.

4.2 Confirmatory Test A second analytical procedure to identify the presence of a specific drug or drug metabolite which is independent of the initial screening and which uses a different technique and chemical principle from that of the initial screening test in order to ensure reliability and accuracy. For determining blood alcohol levels, a confirmatory test means a second test using another breath alcohol analysis device. Further confirmation upon demand will be by gas chromatography )

l analysis of blood.

! 4.3 Confirmed Positive Test l

The result of a confirmatory test that has established the presence of drugs, drug metabolites, or alcohol in a specimen at or above the cut-off level, and that has been deemed positive by the Medical Review Officer (MRO) after evaluation. A confirmed positive test for alcohol can also be obtained as a result of blood alcohol levels with a second breath analysis without MRO evaluation.

4.4 - Cut-Of/ Level

The value set for designating a test result as positive.

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. 4.5 Driver Controllable Vehicle Accident l A vehicle accident involving failure in performance by the driver due to negligence (e.g.,

backing accident, rear-end collisions, and other accidents which could have been prevented through the actions of the driver). The driver may be an employee or contractor driving either j a company vehicle or a company leased vehicle.

4.6 Failure in Individual Performance A human error caused by an individual's deviation (e.g., carelessness, imprudence, poor judgment) from the expected standards of behavior.

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VIRGINIA VPAP-0105 POWER- REVISION 11 PAGE 7 OF 71 4.7 Follow-Up Testing Chemical testing at unannounced intervals, to ensure that an individual is abstaining from the [

l abuse of drugs or alcohol.

4.8 HHS-Certified Laboratory A urine and blood testing laboratory that maintains certification to perform drug testing under the Department of Health and Human Services (HHS)" Mandatory Guidelines for Federal l Workplace Drug Testing Programs".

4.9 Illegal Drugs Those drugs included in Schedules I through V of the Controlled Substances Act, but not when used pursuant to a valid prescription or when used as otherwise authorized by law.

4.10 Initial or Screening Tests An immunoassay screen for drugs or drug metabolites to eliminate negative urine specimens from further consideration or the first breathalyzer test for alcohol. Initial screening may be performed at Virginia Power's testing facility; a second screen and confirmation testing for drugs or drug metabolites must be conducted by a United States Department of Health and Human Services (HHS) cenified laboratory.

4.11 Medical Review Officer (MRO)

A licensed physician responsible for receiving laboratory results generated by Virginia Power's Fitness For Duty Program who has knowledge of substance abuse disorders and has appropriate medical training to interpret and evaluate an individual's positive test result together with their medical history and any other relevant biomedical information.

4 4.12 Observed Behavior An individual's behavior, actions, appearance, or conduct which provides a reasonable suspicion that the individual is potentially under the influence of drugs or alcohol or is affected j by other mental or physical problems.

4.13 On Duty Any work period arising out of and in the course of employment in which an individual performs duties at the direction of Virginia Power. These duties may be performed either at the individual's normal place of work or at a remote location.

VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 8 OF 71 4.14 Point of Contact A Virginia Power, contractor, or vendor employee designated as the point of contact for the Fitness For Duty Administrator. The Point of Contact notifies participants who have been selected to undergo Random drug and alcohol testing.

4.15 Random Test A system of unannounced drug testing administered in a statistically random manner to a group so that all persons within that group have an equal probability of selection.

5.0 RESPONSIBILITIES 5.1 Fitness For Duty Program Manager (Manager Nuclear Security and Administrative Services)

The Fitness For Duty Program Manager is responsible for the overall development, coordination, and implementation of the Fitness For Duty Program. Specific responsibilities include, but are not limited to the following:

5.1.1 Administering the random selection process for chemical testing.

5.1.2 Col!ecting and analyzing test specimens.

5.1.3 Collecting and reporting performance data to senior management.

5.1.4 Analyzing performance data and corrective actions for possible program enhancements. -

5.1.5 Protecting personal information collected in the administration of the Fitness For Duty Program.

5.1.6 Coordinating the management sanction appeals process.

5.1.7 Reviewing and approving contractor / vendor Fitness For Duty Programs.

5.1.8 Reviewing and approving Virginia Power Nuclear Training Programs for Fitness For Duty.

5.1.9 Ensuring that violations of the Fitness For Duty Program are reported to the NRC, when applicable.

5.1.10 Conducting background investigations of employees prior to granting clearance for unescorted access.

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 9 0F 71 5.1.11 Ensuring accurate interface between the Corporate Security Information System (CSIS) and the Random Testing pools.

5.1.12 Providing certification that an individual on loan or visiting from another licensee retains unescorted access authorization.

5.1.13 Evaluating inforrnation reported or revealed during the CBO process for impact on unescorted access authorization.

5.1.14 Ensuring contractor / vendor compliance with and adherence to Virginia Power Nuclear. -

Fitness for Duty Program requirements. .

5.1.15 Ensuring that new Nuclear Business Unit Managers receive Fitness For Duty j Supervisor training in accordance with 6.1.12.b. [ Commitment 3.2.2] !

5.2 Nuclear Business Unit (NBU) Managers NBU Managers of personnel subject to 10 CFR 26 Fitness For Duty requirements are responsible for implementation of the Fitness For Duty Program. Specific responsibilities include the following:

5.2.1 Determining appropriate actions following Fitness For Duty Program violations.

5.2.2 Implementing a Continual Behavioral Observation Program.

5.2.3 Implementing a process under which personnel who are call-outs may perform work I after consuming alcohol.

1 5.2.4 Ensuring that Points of Contact are assigned for participants in the Fitness For Duty Program.

5.2.5 Ensuring that new supervisors within their departments receive Fitness For Duty Supervisor training in accordance with 6.1.12.b. [ Commitment 3.2.2]

j 5.3 Fitness For Duty Administrator -

l The Fitness For Duty Administrator is responsible for coordination of activities required to t

j achieve effective implementation of the Fitness For Duty Program. Specific responsibilities include:

5.3.1 Notifying Points of Contact of individuals selected for random and follow-up testing.

5.3.2 Scheduling specimen collections.

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VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 10 OF 71 l

5.3.3 Resolving unavailability of selected individuals.

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5.3.4 Performing follow-up activities for:

. Test refusals

Confirmed positive test results

. Abstinence follow-up testing Suspension of unescorted access l . Behavioral observation reports l

5.3.5 Maintaining the random testing population pool.

5.3.6' Collecting performance data, reportable events, and summaries of corrective actions.

l 5.3.7. Coordinating activities among management, supervision, Employee Health Services, Security, Training, Employee Relations, Fitness For Duty Program Manager, contractors and vendors.

5.3.8 Collect samples and maintain chain of custody as needed.

5.4 Medical Review Officer (MRO)

The Medical Review Officer is responsible for the following:

5.4.1 Reviewing and interpreting positive test results.

l 5.4.2 Examining alternative medical explanations for any positive test result.

5.4.3 Verifying positive test results.

4 5.4.4 Notifying the Fitness For Duty Administrator of confirmed positive test results within 10 days of the initial positive screening test.

5.4.5 Providing liaison with Employee Assistance Program (EAP) administrators.

5.4.6 Determining frequency for Follow-Up Testing, i

l : 5.4.7 Reporting failure to cooperate incidents to the appropriate management.

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VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 11 OF 71 5.5 Station Personnel Station personnel, who are described in 2.0, including employees, contractors, and vendors, are responsible to report for work drug and alcohol-free, fit to perform their duties in a reliable and trustworthy manner, and not under the influence of any substance, legal or illegal, which in any way might adversely affect their ability to safely and competently perform their duties. Specific responsibilities include the following:

5.5.1 Reporting to work with no detectable presence of alcohol or prohibited drugs in their system. .

5.5.2 Abstaining from alcohol for at least 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months preceding scheduled work.

5.5.3 Notifying their supervisor of any problems such as mental stress, fatigue, or illness which may affect their fitness for duty.

5.5.4 Seeking assistance for any problems which may affect their ability to safely and competently perform their duties.

5.5.5 Reporting to their supervisor the legitimate use of prescription or over the counter drugs which may adversely affect their ability to perform.

5.5.6 Preventing and reporting actions which threaten harm to the company or co-workers.

5.5.7 Reporting any previous denial of unescorted access under a fitness for duty program.

5.5.8 Reporting any felony or misdemeanor conviction or any arrest which may impact their trustworthiness. All arrests, with the exception of traffic violations for which the individual is released after signing a summons, must be reported, 5.5.9 Cooperating fully in the Pre Access, Random, For Cause, and Follow-up Testing Programs.

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5.5.10 i& Cap.icine symptoms of potential drug and alcohol abuse in co-workers and reporting these syr'ri;hemseltation management.

5.6 Superintendent Security %

The Superintendent Security is responsible for the following:

5.6.1 Escorting individuals offsite, when they display aberrant behavior.

VIRGINlAl POWER VPAP-0105 REVISION 11 PAGE 12 OF 71 5.6.2 Suspending unescorted access to individuals displaying aberrant behavior as directed by the Station Manager or his designee.

5.6.3 Providing a security officer of the same gender as a participant to observe specimen collection, when required.

5.7 Station Supervisors Station Supervisors are responsible for the following:

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5.7.1 Ensuring that personnel under their supervision are fit for duty.

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5.7.2 Ensuring that personnel under their supervision report to the collection site when selected for Fitness For Duty testing.

5.7.3 Observing personnel for behavioral traits and patterns which may reflect adversely on their trustworthiness or reliability and report those observations to management for appropriate corrective action.

5.7.4 Referring personnel to the Employee Assistance Program (EAP), as appropriate.

5.7.5 Determining when For Cause testing is required.

5.7.6 Reporting incidents made known to them by employees under the requirements of the Continual Behavioral Obsen ation (CBO) Program.

5.7.7 Notifying Nuclear Access Services in accordance with 6.7.10. when an individual will be away from a CBO Program for more than 30 consecutive days.

5.8 Manager If uman Resources Employ ee Services / Safety & Ilealth The Manager Human Resources Employee Services / Safety & Health is responsible for administering the Employee Assistance Program and the activities of the Medical Review

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Officer.

5.9 Employee Assistance Program (EAP) Administrator The EAP Administrator is responsible for the following:

5.9.1 Providing confidential assessment. .shon-tenn counseling, referral services, and treatment monitoring to employees with problems related to fitness for duty.

5.9.2 Informing management when a determination has been made that an individual's condition constitutes a hazard to himself or herself or others.

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VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 13 OF 71 5.10 Manager Nuclear Oversight The Manager Nuclear Oversight is responsible for performing periodic audits of the Fitness For Duty Program.

5.11 Manager Nuclear Training The Manager Nuclear Training is responsible for the development, implementation and maintenance of the FFD Training Program for all Nuclear personnel and Nuclear supervisors.

5.12 Superintendent Nuclear Training The Superintendent Nuclear Training is responsible for providing:

FFD training and escort training to all Nuclear personnel who have unescorted access to North Anna or Surry Power Station

. FFD Supervisor Training to all Nuclear supervisors and others required to perform CBO on workers with unescorted access 5.13 Supervisor FFD Testing The Supervisor FFD Testing is responsible for the following:

5.13.1 Ensuring that all activities performed in support of the Fitness for Duty program at the collection and testing facilities are performed in accordance with 10 CFR 26, Appendix A. and all applicable procedures.

5.13.2 Reporting to the FFDA the following:

Negative test results as soon as available

. Any failure of a participant to cooperate during the collection process, or the failure of a participant to repon for testing at his/her scheduled time (MRO also to be notified in failure to cooperate cases)

. Any evidence of tampering with specimens

. Any breaches of facility security 5.13.3 The review and interpretation of test results.

5.13.4 Ensuring that calibration and preventative maintenance is performed as required on all FFD instrumentation at the collection and testing facilities.

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 14 OF 71

5.14- Director Emergency Planning The Director Emergency Planning is responsible for ensuring that controls are established in the event that individuals responding to an emergency have consumed alcohol within the 5 l hour abstinence period.

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VIRGLNIA VPAP-0105 POWER REVISION 11 I

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6.0 INSTRUCTIONS 6.1 Fitness For Duty Program Administration I The Fitness For Duty Program shall be developed, implemented, and administered to ensure that the following objectives are achieved:

Personnel are fit to safely and competently perform their duties

. Personnel who are unfit to perform their duties are detected and corrective actions are taken

! ' A drug-free and alcohol-free workplace is achieved r .

In order to accomplish these objectives, the Fitness For Duty Program snall consist of the following elements:

l 6.1.1 Chemical Testing Chemical testing shall be an element of the Fitness For Duty Program to provide a means to deter and detect substance abuse. Chemical testing shall consist of the following elements:

a. Pre-Access Testing:

Individuals shall be tested within 60 days prior to the initial granting of unescorted.

access to North Anna or Surry Power Station.

b. Random Testing:

l Unannounced drug and alcohol testing imposed in a statistically random and unpredictable manner so that all persons in the population subject to testing have an equal probability of being selected and tested.

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1. Testing shall be administered so that a person completing a test is immediately eligible for another unannounced test.

2. Testing shall be administered on a nominal weekly frequency and at various tiines during the day.

3. Testing shall be conducted at an annual rate equal to at least 50 percent of the workforce badged for unescorted access.

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VIRGINIA VPAP 0105 POWER REVISION 11 PAGE 16 OF 71

c. For Cause Testing: Individuals shall be tested for cause, as soon as possible following any of the following occurrences:

1. Observed Behavior indicating possible substance abuse or otherwise raising a l question regarding an individual's fitness for duty.

2. Failure in Individual Performance resulting in actual or potential degradation of safety whetu r .not an accident occurred; or if there is reasonable suspicion that an indi /idual's behavior contributed to an on-duty accident resulting in one of the fdiowing:

. A fatality

. A personal injury when off-site medical Featment is required

. Property damage where employee discipline may be required

. Radiation exposure or release of radioactivity in excess of regulatory limits

. Actual or potential substantial degradation of the level of safety of the Station

3. Receipt of Credible Information that an individual is abusing drugs or alcohol.

4. A Driver Controllable Vehicle Accident.

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d. Follow-up Testing: Individuals shall be tested on an unannounced basis to verify I l

continued abstention from the abuse of drugs or alcohol. '

e. Testing for drugs and alcohol must conform. as a minimum, to the cut off and confirming levels of nanograms (ng) to milliliters (ml) imposed in Table 1, Drug and AlcoholTesting Requirements.

TABLE 1 DRUG AND ALCOHOLTESTING REQUIREMENTS DRUGS / ALCOHOL l TYPE CUT OFF LEVELS CONFIRMATORY LEVELS l MARIJUANA 50 ng/ml 15 ng/ml f COCAINE 300 ng/ml 150 ng/ml

! . OPIATES 300 ng/ml 300ng/ml !

AMPHETAMINES 1000 ng/mi '

500 ng/ml PHENCYCLIDINE 25 ng ml 25 ng/mi ALCOHOL .(M% BAC

.04% BAC

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 17 OF 71

f. Initial screening tests of an aliquot may be conducted prior to sending the specimen to a laboratory certified by the United States Department of Health and Human Services (HHS). The initial screening process is subject to the following requirements:

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1. The staff performing the initial screening shall possess documented qualifications of their training and skills.

2. Blind performance test specimens and a sample of negative initial screenings shall be submitted to the HHS-certified laboratory for processing and -

l confirmation of results. .

3. Results of the initial screening tests shall be limited to the Medical Review Officer (MRO), the Supervisor FFD Testing, and as appropriate, EHS staff.

4. The MRO shall review the HHS-certified test results and notify the Fitness For Duty Administrator of the results within 10 days of the initial screening test.

g. Testing of specimens, with the exception of the initial screenings described in 6.1.1.f. shall be performed by an HHS-certified laboratory.

h. Testing for alcohol shall be pexformed using a breath analysis device which meets the standards imposed by the National Highway Traffic Safety Administration (NHTSA). Alcohol tests shall be subject to the following requirements:

1. Breath alcohol content indicating a blood alcohol concentration (BAC) which meets or exceeds 0.04 percent shall be considered a positive test result.

2. Confirmatory tests for alcohol shall be performed with a breath analysis device other than the one used for the initial test.

3. Upon request by the individual being tested, a further confirmation may be performed using a gas chromatography analysis of blood.

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 18 OF 71

i. Adding or Deleting Substance Tests

1. The Manager Human Resources Employee Services / Safety & Health shall be responsible for adding to or deleting drugs from the list of drugs to be tested and changing test cutoff levels. This shall be accomplished by:

. Maintaining contact with appropriate authorities so that Virginia Power is aware of the use of other substances with abuse potential in Richmond and in the geographic areas of the nuclear stations

. Conducting evaluations to include additional tests

Conducting evaluations for removal of tests from the list

. Notifying the FFD Program Manager of planned testing changes so that procedure and standard changes are made, and timely notification is made to the NRC

2. The FFD Program Manager shall ensure that: l

. Changes are implemented to Nuclear Standards and Nuclear Administrative Procedures

. Changes are made to training / retraining programs, if necessary

. NL&OS is notified so that they may notify the NRC in a timely manner [

. Employee Relations is notified to inform the union of the change 6.1.2 Operation of Specimen Collection Sites and Testing Facilities The FFD Program Manager is responsible for ensuring the operati.on of the collection site and testing facilities in accordance with 10 CFR 26, Virginia Power Nuclear l j

Standards, and Nuclear Administrative Procedures. :

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a. Facility Security and Access Contrcl

1. The testing facility is to be maintained secure and locked when collection site personnel are not in the facility.

2. The collection site is to be maintained secure and locked when collection site personnel or FFDA are not in the facility.

3. Participants in the collection site shall be under direct control of collection site '

personnel.

4. Participants are not allowed in the testing facility.

. VIRGINIAi VPAP-0105 POWER REVISION 11 PAGE 19 OF 71

5. _ Virginia Power employees, contractors, and vendors requiring access to the collection site in the performance of their duties are to be escorted by collection site personnel or a FFDA.

6. Virginia Power employees, contractors, and vendors requiring access to the testing facility in the performance of their duties shall be escorted by collection 4 site personnel. i jl

. 7. Security and supervisory personnel escorting a participant to a collection site for

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a for-cause test shall remain in the waiting area unless requested by the .

collection site person to maintain control of a potentially belligerent and ,

hazardous participant. i l

8.' Duly authorized NRC inspectors are allowed access to the collection site and testing facility.

- b. Collection Site and Testing Facility Maintenance The FFD Program Manager shall ensure maintenance of all test equipment within the collection sites and testing facilities, including applicable preventive

. maintenance and instrument calibration, and appropriate maintenance on the collection site and testing facility.

c. Specimen Integrity The FFD Program Manager shall ensure the implementation of collection site procedures and the qualification and training of collection site personnel, emph'asizing that collection site personnel are to ensure:

1. The integrity of the specimen collection and transfer process.

2. That urine specimens are not adulterated or diluted during the collection E

process. i

3. That there can be no substitution of or tampering with blood sample or breath i exhalant tubes. i

4. That the information on the specimen container and the record book can identify l L

the individual from which the specimen was collected. !

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POWER VPAP-0105 REVISION 11 PAGE 20 OF 71

d. Respect for Participants' Privacy and Sensibilities

1. The FFD Program Manager shall ensure that collection site personnel ensure the modesty and privacy of the person being tested and to avoid any conduct or remarks which might be construed as accusatory or otherwise offensive or inappropriate.

2. Procedures for collecting urine specimens shall allow individual privacy unless there is reason to believe the participant may alter or substitute the specimen to be provided. Attempted adulteration or previous adulteration constitutes

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sufficient reason for waiver of privacy rights.

3. Upon return to duty following successful treatment for an FFD violation for substance abuse, the giving of urine shall be observed.

e. Representation Representation at the collection site is permitted.

1. Testing shall not be delayed for representation.

2. Representatives shall not be permitted access to " restricted access" areas of the collection site.

3. Representatives shall not be permitted to interfere with or impede testing procedures.-

. f. Reporting Criteria

1. The Manager Human Resources Employee Services / Safet & Health shall implement procedures to ensure that within ten days of an initial presumptive positive screening test the Medical Review Officer has completed his review and notified the FFD Administrator.

2. The Manager Human Resources Employee Services / Safety & Health shall 1

report staffing changes affecting the staff that administers the Nuclear FFD I

Program.

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VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 21 OF 71

g. Qualification of Collection Site and Testing Facility Personnel The FFD Program Manager shall ensure collection site and testing facility personnel are selected based on the highest standards for honesty and integrity, and that the integrity of collection site and testing facility personnel is not compromised l- or subject to efforts to compromise due to personal relationship with any individuals subject to testing.

h. Testifying at Proceedings The FFD Program Manager shall ensure collection site personnel are available to ,

testify in administrative or disciplinary proceedings when that proceeding is based ,

on positive breath analysis, blood collection, chain of custody, or urinalysis results reported by the collection site and testing facility.

6.1.3 H,HS Certified Laboratory

a. The Manager Human Resources Employee Services / Safety & Health shall maintain a purchase order with an HHS-certified laboratory to perform:

Initial screening tests on urine specimens

Confirmatory tests on urine specimens which are screened as presumptive positive at a Virginia Power testing facility or the HHS-certified laboratory

. Confirmatory testing of blood specimens voluntarily provided by individuals testing positive for alcohol on a breath test

b. The following test techniques shall be used:

Type of Test Test Technique Urine Screening l Immunoassay Urine Confirmatory l Gas Chromatography /

l Mass Spectrometry Blood Alcohol Confirma- ! Gas Chromatography tory j

c. The lab shall test for the following substances using Virginia Power and NRC cutoff levels for the screening and confirmatory test. (See 6.1.1 (e), Table 1)

- - - - - - - - - - - - - - _ - - _ - - - - - - - - - - - - - - - _ - - - - - - - - - _ - - - - - - . - - - - - - - - - - - - - _ - - - - - - - - - _ _ u

VIRGINIA VPAP-0105 POWER REVISION 11

PAGE 22 OF 71 .s .

if x-

d. The Manager Human Resources Employee Services / Safety & Health shall:

l. Ensure the performance of pre-award inspections and evaluations of the

{'

procedural aspects of the laboratory's drug testing operation.

2. Confirm that the laboratory meets all requirements of 10 CFR 26 with respect to specimen integrity, performance of testing, quality assurance, procedural controls, protection of personal information, storage of samples, control and retention of records, personnel qualifications and training, and subcontracting.

3. Establish methods and procedures to ensure that personalinformation is protected in correspondence and communications between the laboratory and Virginia Power and that specimen integrity is maintained during transport to the laboratory.

4. Ensure that the lab facilities and records are available for inspections by the NRC, including unannounced inspections, and by duly authorized Virginia Power representatives such as Nuclear Oversight, MRO, FFDA, and Internal Auditing in the performance of their duties.

5. Ensure that qualified laboratory personnel are available to testify in administrative or disciplinary proceedings when that proceeding is based on a urinalysis or blood analysis reported by the laboratory.

6. Ensure that specimens are transported to the laboratory, are analyzed by the laboratory, and reports are returned by the laboratory to allow sufficient time for the MRO to complete a review and make a determination within ten days after a presumptive positive screening test.

7. Investigate unsatisfactory test performance, follow up on laboratory corrective actions, and prepare repons on unsatisfactory test performance, investigative findings and corrective actions.

8. Immediately notify the FFD Program Manager on discovery of unsatisfactory test performance and submit reports on determinations of cause and corrective actions to the FFD Program Manager within twenty days of discovery of the unsatisfactory performance testing result. If the investigation or corrective action process is not complete at the time of the first report, follow-up reports shall be submitted at thirty day intervals thereafter.

VIRGINLA VPAP-0105 POWER REVISION 11 PAGE 23 OF 71

9. Ensure that participants, upon written request, shall have access to laboratory .

l records relating to the participant's test and any records relating to the results of

]

any relevant laboratory certification, review, or revocation of certification proceeding.

! I 6.1'4 QC Program for Testing Process

a. Initial Screening Tests at the Collection Site and Testing Facility

1. The FFD Program Manager shall ensure that the collection site and testing facility personnel: ,

L -

Process blind performance test specimens as required

+ Forward a sampling of specimens screened as negative from each test run to j l the HHS certified laboratory as required I Perform periodic performance tests on breath analysis equipment

b. HHS-Certified Laboratory

! 1. The FFD Program Manager shall implement a program to provide blind performance test samples to the HHS-certified laboratory.

2. The Manager Human Resources Employee Services / Safety & Health shall

! ensure that the HHS-certified laboratory implements the QC Program.

c. Evaluations and Reports The FFD Program Manager shall evaluate the HHS-certified laboratory QC f 1

programs and implement corrective actions. l 6.1.5 Employee Assistance Program The Fitness For Duty Program shall contain as one ofits elements an Employee Assistance Program (EAPL The EAP shall consist of the following: )

a. Assessment, short term counseling, referral services, and treatment monitoring for employees with problems which could adversely affect their ability to perform their duties in a safe and competent manner.

- b. Provisions for early intervention and confidential assistance.

c. Requirements to notify the Fitness For Duty Program Manager and the individual's manager when a determination has been made that the individual's condition constitutes a hazard to himself or herself or others. This requirement includes individuals who have self-referred.

. _ _ . - - - . _ _ _ - _ _ _ _ _ _ - _____ ___ -_ _ _ _ _ _ _ _. __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ ~

VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 24 0F 71

d. Personal information obtained from an employee participating in the FFD Program shall be neated as confidential unless the EAP Administrator determines that the participant is a hazard to himself or others; or the participant has been referred to the EAP as a required corrective action of the FFD Program or by the employee's supervisor,

e. Disclosure of personal information shall be in accordance with the Protection of Information section of this procedure.

6.1.6 Management Actions and Sanctions Virginia Power Management shall ensure that proper preventive actions, corrective actions, and sanctions are imposed to maintain the integrity of the Fitness For Duty Program. The following activities shall be performed:

a. The Manager Nuclear Security and Administrative Services shall investigate individuals prior to the initial granting of clearances for unescorted access, to determine the following:

. Was the individual ever tested positive for drugs or alcohol that resulted in on-duty impairment

. Was the individual ever subject to a plan for treating substance abuse (except for self-referral)

Was the individual ever removed from activities or denied unescorted access at any nuclear power plant for violation of a Fitness For Duty Pplicy l

b. As part of the above investigation, the Manager Nuclear Security and Administrative Services shall obtain a written statement from the individual which provides a testimonial response to these items prior to granting unescorted access.

, c. The Manager Nuclear Security and Administrative Services shall evaluate I information concerning individuals with unescorted access authorization who have been arrested for reasons that may impact their tmstworthiness.

VIRGINIA VPAP-0105 POWER REVISION 11 l' PAGE 25 OF 71 1

d. In the event that an individual was ever denied unescorted access to any nuclear power plant for abuse of alcohol or legal drugs, the granting of unescorted access or assignment of duties associated with North Anna or Surry Power Station may only be allowed based upon the Manager Nuclear Security and Administrative Services and the Medical Review Officer determination of fitness for duty. The following requirements shall apply:

1. The Medical Review Officer must attest that the individual is medically fit to perform duties safely and competently.

2. The individual must participate in unannounced follow-up tests on a frequency ,

l to be determined by the Medical Review Officer.

e. Virginia Power supervisors and security personnel who test positive for illegal

, drugs in a confirmed test result shall be terminated. Contractors or vendors who test positive for illegal drugs in a confirmed test result shall have their unescorted access denied.

f. Virginia Power employees, other than supervisors and security personnel, who test positive for illegal drugs shall be placed on a 30 day unpaid disciplinary suspension, suspended from unescorted access and subject to the following:

1. The individual shall be referred to EAP for assessment and counseling during l the suspension period. If the individual fails to contact EAP within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the !

individual shall be terminated.

2. Plans for treatment. follow-up testing, future employment, and appropriate rehabilitation programs must be initiated during the suspension period.

i

3. The Medical Review Officer must attest that the individual is medically fit to perform duties safely and competently prior to return to work.

4. The individual shall participate in a follow-up testing program for abstinence verification.

5. Any subsequent confirmed positive test for alcohol, illegal drugs, or abuse of legal drugs during the participation in a follow-up testing program shall result in termination.

g. Virginia Power employees who contribute to a fatality and test positive for illegal drugs shall be terminated.

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 26 OF 71

h. Individuals who are determined to have been involved in the illegal off-duty or on-duty use, possession, distribution, manufacture, or sale of drugs shall be terminated if they are a Virginia Power employee or have their unescorted access denied if they are a contractor or vendor,

i. Virginia Power employees who test positive for alcohol, equal to or greater than 0.04 BAC, or abuse or illegal use of prescription or over the counter drugs shall be suspended from unescorted access and subject to the following:

1. The individual shall be referred to EAP for assessment and counseling during the suspension period. If the individual fails to contact EAP within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the individual shall be terminated.

2. Plans for treatment, follow-up testing, future employment, and appropriate rehabilitation programs must be initiated during the suspension period.

3. The Medical Review Officer must attest that the individual is medically fit to perform duties safely and competently prior to retum to work.

4. The individual shall participate in a follow-up testing program for abstinence verification.

5. Any subsequent confirmed positive test for alcohol, illegal drugs, or abuse of legal drugs during the follow-up testing program shall result in termination.

j. Contractors or vendors who test positive for abuse or illegal use of prescription drugs or who test positive for alcohol, equal to or greater than 0.04 BAC, shall have their unescorted access denied.

k. Contractors or vendors w ho are tested for cause and whose test detects alcohol less

, than 0.04 BAC, and such alcohol presence results in unsafe or unfit workplace behavior, shall have their unescorted access denied.

1. Virginia Power employees w ho refuse to cooperate during the chemical testing portion of the Fitness for Duty Program shall be terminated; contractors or vendors shall have their unescorted access denied,

m. Individuals who are determined to be impaired or whose fitness may be questionable shall be removed from their duties and have their unescorted access denied until it has been determined that they are fit to safely and competently perform their duties.

f

. VIRGINIA - VPAP-0105 l POWER REVISION 11 l PAGE 27 OF 71

n. Station Management shall immediately notify the NRC Regional Administrator (NRC Operations Center during other than normal working hours) by telephone if there is a reasonable belief that an NRC employee may be under the influence of any substance, or otherwise unfit for duty. Access for the NRC employee shall not be' denied, but the individual shall be escorted.

6.1.7 Appeals Individuals shall have the right to appeal positive test results or management sanctions.

The process of appeals is as follows: ,

l, a.. Positive Test Result Appeal .

l 1. The individual shall obtain an Appeals Request form from the Fitness For Duty I Administrator and submit the completed request to the Medical Review Officer

_ . (MRO) within 10 days of the notification of the confirmed positive test result.

L l 2. The MRO shall investigate the matter thoroughly in order to resolve the issue.

The investigation may include, but is not limited to the following:

[ . Interview with individual's personal physician l

Review of individual's medical history records

!

Follow-up interview with individual t

3. The MRO shall determine if the appeal is sustained or denied and notify the individual and the Fitness For Duty Administrator of the results.

! 4. The Fitness For Duty Administrator shall maintain the appeal documentation in

' the Fitness For Duty Program files.

b. Management Sanction Appeal

1. Virginia Power hourly employees shall notify (verbal or written) their supervisor requesting an appeal, which will be processed through the Collective Bargaining Agreement grievance process.

2. Virginia Power salaried employees shall submit a written statement to their manager requesting an appeal.

3. The employee's manager shall process appeals from salaried (administrative and supervisory) employees through the Administrative Grievance Process.

I

( ___ ____________ _____________ _ _ _ o

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE28 OF 71

4. The employee's manager shall notify the Fitness For Duty Program Manager of appeals.

5. The Fitness For Duty Program Manager shall coordinate required actions and provide guidance and administrative support to the employee's manager during the appeal process.

6. The employee's manager shall investigate the matter in order to resolve the issue.

7.- The employee's manager shall determine if the appeal is sustained or denied and notify the Fitness For Duty Program Manager.

8. The Fitness For Duty Program Manager shall document the appeal decision in the Fitness For Duty Program records.

9. The employee's Manager shall forward a written response to the employee documenting the appeal decision.

10. Contractors and vendors may appeal a Fitness For Duty sanction through their respective companies.

6.1.8 Protection ofInformation Information collected during the administration of the Fitness For Duty Program shall be maintained in a system which protects the confidentiality of the information. This system shall be subject to the following requirements: >

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 29 OF 71

a. Personal information shall not be disclosed to persons other than the following:

Assigned MROs

Security Employee Health Services

. EAP Staff

. Fitness For Duty Program Staff Employee Relations Staff

. Other Nuclear Power Plant licensees or their authorized representatives (provided a release from the individual has been obtained) ,.

. NRC representatives

. Law enforcement officials under court order

, . Fitness For Duty Program auditors

. The subject individuals or their authorized representatives

b. The Fitness For Duty Program Manager shall review other requests to determine if information should be released.

c. Information specified on a Fitness For Duty Record Request Checklist, Attachment 6, regarding an individual shall be released upon presentation of a

' written request from the subject individual or his or her representative to the FFD Program Manager.

l 6.1.9 Inspections Authorized NRC representatives shall have access to the records, premises, activities, and personnel associated with the Fitness For Duty Program. The Fitness For Duty Program Manager shall ensure the following:

a. NRC representatives shall be allowed to inspect, copy, or take away copies of records generated as a result of the Fitness For Duty Program.

b. NRC representatives shall be allowed to inspect, copy, or take away copies of contractor or vendor records generated as a result of contractor or vendor fitness for duty programs.

L L____ _ _ __ _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 30 0F 71 c., Written agreements between Virginia Power and contractors or vendors shall clearly indicate the following:

1. Virginia Power is responsible for maintaining an effective Fitness For Duty l Program.

2. NRC representatives will be allowed to inspect, copy, or take away copies of Virginia Power, contractor, or vendor records and reports generated as a result of the Fitness For Duty Program.

6.1.10 Record keeping The Fitness For Duty Program Manager shall ensure that records generated as a result of the Fitness For Duty Program are retained in the Fitness For Duty Program files.

Specific requirements include the following:

a. Records of inquiries that result in the granting of unescorted access to protected areas shall be retained until 5 years following termination of the access authorizations.

b. Confirmed positive test results which are concurred with by the MRO and the I J

related personnel actions shall be retained for a minimum of 5 years.

c. Records ofindividuals denied unescorted access at North Anna or Surry Power Station shall be retained until the NRC terminates each license under which the records were created. .

d. Fitness For Duty Program performance data shall be collected and compiled on a i standard form. The data shall include the following: I

. Random testing rate

. Drugs tested for and cut-off levels

. Workforce populations tested

. Numbers of tests and results by population and type of test (i.e., pre-access, random, for-cause, follow-up)

. Substances identified

. Summary of management actions-3

. A list of events reported '

-VIRGINIA - VPAP-0105 POWER - REVISION 11 PAGE 31 OF 71

c. Fitness For Duty Program performance data shall be analyzed and appropriate actions taken to correct program weaknesses.-

f. Fitness For Duty Program performance data and analysis shall be retained for a minimum of 3 years.

g. Fitness For Duty Program audits, audit findings, and resolutions shall be retained for a minimum of 3 years. This applies to both the Virginia Power Fitness For Duty Program as well as contractor or vendor fitness for duty programs. ,

l

h. Fitness For Duty Program training records shall be maintained for life of plant plus ' 4 10 years.

, i. Collection Site and Testing Facility personnel files will be retained for at least 3 years following termination of employment or removal from FFD Program-related duties.

6.1.11 Reporting Requirements -

The Fitness For Duty Program Manager shall ensure that Fitness For Duty Program performance data and any significant Fitness For Duty events are reported to the NRC.

The following reports shall be submitted:

a. Fitness For Duty Program performance data shall be submitted to the NRC within 4

' 60 days of the end of each 6 month reporting period (January-June and July-December). !

b. The Fitness For Duty Administrator shall notify the Station Manager and the Fitness For Duty Program Manager immediately if any of the following events ;

occur:

1. The sale, use, or possession ofillegal drugs within the protected area. l

2. Any acts by a licensed Reactor Operator, Senior Reactor Operator, or any supervisory personnel as follows-

. Sale, use, or possession of a controlled substance

. A confirmed positive test result on such persons

. The use of alcohol within the Protected Area

. A violation of the Fitness For Duty Program due to alcohol consumption

' c. The Station Manager shall ensure that the NRC Operations Center is notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of any event described in 6.1.11.b.

VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 32 OF 71 6.1.12 Training Requirements !

The training programs shall consist of the following:

a. Nuclear Fitness For Duty Program Training The Nuclear Fitness For Duty training program shall be completed prior to badging ;

for unescorted access and shall: l l

1. Describe Virginia Power's policy and procedures and the methods used to implement the policy and procedures.

2. Describe the personal, public health, and safety hazards associated with the abuse of drugs and alcohol.

3. Describe the effects of prescription and over the counter drugs on job performance.

l

4. Describe chemical test results and the role of the MRO.

5. Describe the responsibilities of individuals, including reports of any arrest and/

or conviction which may impact their trustworthiness, and the consequences which may result as a lack of adherence to their responsibilities.

6. Provide for refresher training on a nominal 12 month frequency,

b. Training of Supervisors

1. Training for new supervisors shall be completed as follows)

[ Commitment 3.2.2}

. New employees hired into supervisory positions, and supervisors of personnel outside the NBU who are subject to the Nuclear FFD program, must complete the training prior to supervising employees subject to the FFD program or activities within the scope of the FFD rule

. Nuclear employees who are promoted into supervisory positions must complete the training within three months of their promotion 1

w _ _. _ _ _ _ _ _ _ _ _ _ - _

, VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 33 OF 71

2. The training program for supervisors shall address the following:

l Describe the responsibilities of supervisors and escorts Describe techniques for recognizing drugs and indications cf the use, sale, or possession of drugs i

. Describe behavioral observation techniques for detecting degradation in performance, impairment, or changes in individuals' behavior

. Describe processes for initiating corrective action, including referral to EAP.

Provide for refresher training on a nominal 12 month frequency

c. Training of Escorts .

i The training program for escorts shall: l

1. Describe techniques for recognizing drugs and indications of the use, sale, or possession of drugs. !

2. Describe techniques for recognizing aberrant behavior.

3. Describe processes for reponing problems to supervisory or security personnel.

i

4. Provide for refresher training on a nominal 12 month frequency.

6.1.13 Contractor and Vendor Fitness For Duty Requirements Contractors and vendors who have unescorted access to the protected area of the nuclear stations or who are required to report to the Technical Support Centers or the EOF must comply with Virginia Power's FFD Program requirements. They shall be subject to either Virginia Power's Fitness For Duty Program or to their own program which has been approved by Virginia Power and meets the requirements of 10 CFR 26. The following requirements apply:

a. Written agreements between Virginia Power and contractors or vendors shall clearly show the following:

1. The contractor or vendor shall adhere to Virginia Power's Fitness For Duh-Program or to their own program which has been approved by Virginia Puwer and meets the requirements of 10 CFR 26.

L____.__________m_ . _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ . . . _ _ . _ _ _ _ _ _ _ _ . _ _ _ _m . . _ _ _ . . _ _ . . _ _ . _ _ _ . _ _ _

_ . _ _ ___ .___ __ _ _____.___._______.._.__________.__m

-VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 34 OF 71

2. Contractor or vendor personnel who have been denied unescorted access at any other nuclear power plant for violations of a fitness for duty program shall not be assigned to work at North Anna or Surry Power Station without the consent of Virginia Power.

b. Virginia Power may elect to allow the contractor or vendor to perform pre-access tcsting of their own employees. The Fitness For Duty Program Manager shall perform the following:

1, Request that Nuclear Oversight perform an audit or review recent audits of the contractor or vendor Fitness For Duty Program for compliance with 10 CFR 26 -

requirements.-

2. Review results of audit or review.

3. Provide the contractor on vendor written approval allowing the pre-access testing of their own employees.

6.1.14 Pre-Access Testing by Contractors / Vendors I

a. In the special case where a contractor or vendor firm wishes to perform pre-access chemical testing under its own Chemical Testing Program, a written request must be submitted to the FFD Program Manager.

b. The FFD Program Manager may appmve the request provided:

1. The contractor / vendor Chemical Testing Program complies fully with the requirements of 10 CFR 26.24, Chemical Testing, except 10 CFR 26.24 (a.2, a.3, and a.4).

2. The contractor / vendor Chemical Testing Program tests for all substances in the

, Virginia Power Chemical Testing Program.

i l 3. The contractor / vendor Chemical Testing Program complies fully with the recordkeeping and corrective action requirements of 10 CFR 26.71,

! Recordkeeping.

4. The contractor / vendor agrees to transmit to Virginia Power the FFD Program Performance Data (required by 10 CFR 26.71.d) relating to pre-access tests conducted on individuals requesting access to the Virginia Power Nuclear ..

Stations, q

{

_________-___:_-__=________.

VIRGINIA POWER VPAP-0105 REVISION 11 r

PAGE 35 OF 71

5. The contractor / vendor agrees to provide Virginia Power Nuclear Access Services with certification of acceptable chemical test results for each applicant,

! including the date tested.

6. The contractor / vendor pre-access test must occur within the 60 days prior to the granting of unescorted access.

7. An audit of the contractor / vendor Chemical Testing Program is conducted or another licensee's audit is reviewed and approved by the Virginia Power Nuclear Oversight Department. -

8. A written agreement is executed between Virginia Power and the contractor / '

vendor certifying the above listed requirements.

6.1.15 Audits The Manager - Nuclear Oversight shall audit the Fitness For Duty Program in accordance with the following requirements:

a. The Fitness For Duty Program shall be audited nominally every 12 months.

b. Contractor or vendor fitness for duty programs, relied upon in v,nole orin part, shall be audited nominally every 12 months.

i

1. Virginia Power may accept audits of contractors or vendors conducted by other licensees and need not re-audit the contractor or vendor for the same period of time.

2. Virginia Power shall maintain a copy of other licensees' audit reports, including findings, recommendations, and corrective actions.

3. Virginia Power shall retain ultimate responsibility for the effectiveness of contractor or vendor fitness for duty programs and implementation of appropriate corrective action.

c. Audits shall focus on the effectiveness of the program and be conducted by qualified individuals who are independent of the Fitness For Duty Program management and personnel directly responsible for the implementation of the i Fitness For Duty Program.

d. Audit results and recommendations shall be documented and submitted to the Fitness For Duty Program Manager, r

1 1

l

1 VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 36 OF 71 l

1

e. Resolution of audit findings shall be documented and maintained in the Fitness For :

Duty Program files.

6.1.16 Program Self-Assessment

a. Nuclear Security and Administrative Services

1. Nuclear Security and Administrative Services shall collect and analyze program data by reviewing trends and comparing quantitative results to criteria established as goals; including the random testing rate, drugs tested for and cutofflevels, workforce population tested, numbers and types of tests, substances found, summary of management actions, and reported events.

2. Nuclear Security and Administrative Services shallinitiate and coordinate corrective actions for identified program deficiencies and initiate and coordinate program improvements, if desired, to reverse adverse trends and meet program goals.

3. Nuclear Security and Administrative Services shall establish Quality Control measures for the collection sites, testing facilities, and the HHS-certified laboratory.

b. Human Resources Employee Services, Safety & Health Human Resources Employee Services / Safety & Health shall:

. Immediately notify the FFD Program Manager ofidentified program deficiencies

. Coordinate corrective actions for identified program deficienc'ics

. Initiate and coordinate program improvements, if desired to reverse adverse trends and meet program goals

c. Supervisor Fitness for Duty Testing

l. The Supervisor Fitness for Duty Testing shall analyze QC program results and test summary reports and shall analyze program data by reviewing trends and comparing quantitative results to criteria established as goals.

2. The Supervisor Fitness for Duty Testing shall summarize testing results from the collection sites and testing facilities and from the HHS-certified laboratory and develop required reports.

1 1

VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 37 OF 71

d. Nuclear Training Responsibilities The Manager Nuclear Training shall evaluate Fitness For Duty Training / Retraining programs in accordance with Nuclear Training procedures.

6.2 Random Drug and Alcohol Testing The Fitness For Duty Program Manager shall implement a random drug and alcohol testing program. This program shall be designed to deter and detect the abuse of drugs and alcohol.

Collection sites shall be established under the supervision of the Fitness For Duty Program Manager. -

6.2.1 Nuclear Security shall maintain a listing ofindividuals who are badged for unescorted access. These individuals are participants in the Fitness For Duty Program.

6.2.2 The Corporate Fitness For Duty Administrator ensures that individuals involved in the administration of the FFD program are also participants in the Program.

6.2.3 The computer software program selects participants at random and generates lists which are provided to the Fitness For Duty Administrators.

6.2.4 The Fitness For Duty Administrator contacts the participant's Point of Contact to )

schedule the participant to report for drug and alcohol testing at a scheduled time. The i

following are the only acceptable reasons for a participant to miss a random test when scheduled:

l l

1' E-_------------------------ - - . - - - - - - - - - . - - - - . - - - - - . - - -- - - - - - - -

VIRGINTA VPAP-0105 POWER REVISION 11

PAGE 38 OF 71 NOTE: The Fitness For Duty Program Manager is allowed to authorize additional reasons, on a case by case basis, to justify missing a scheduled test.

Illness

. Approved personal time off

. Vacation l

. Military training or Reserve duty

. Jury Duty

. Leave of absence

. Training at locations requiring more than approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (one way) travel to a designated Collection Site as determined by the Fitness For Duty Administrator i I

. Company business at locations requiring more than approximately I hour (one way)

J travel to a designated Collection Site as determined by the Fitness For Duty I Administrator

. Emergencies, as determined by the Fitness For Duty Administrator j l

. Normally scheduled day off

. Contractors not called in, when theyework on a callin basis only I 6.2.5 The Point of Contact instructs the designated participant to report to the collection site I for drug and alcohol testing at the scheduled time.

a. If the participant refuses to repon for testing, the following actions shall occur:

4

1. The participant's supersisor shall warn the panicipant of the penalties of termination or denial ot' unescorted access.

2. If the panicipant continues to refuse to report. the supervisor shall contact the Fitness For Duty Administrator to advise of the participant's refusal.

3. The Fitness For Duty Administrator shall contact the Station Manager to have the participant escorted offsite and to suspend unescorted access privileges.

4. The Station Manager shall direct the Superintendent Security to have the participant escorted offsite and to suspend unescorted access privileges.

L----------

VIRGINIA POWER '

VPAP-0105 REVISION 11 PAGE 39 OF 71

5. The Superintendent Security shall have the participant escorted from the site j and shall suspend his unescorted access privileges. -I

6. The Station Manager shall initiate termination of employment for Virginia Power employees or denial of unescorted access for contractors or vendors.

7. The Fitness For Duty Administrator shall complete appropriate reports and update the Fitness For Duty Program records.

I

b. If the panicipant is unavailable, the Point of Contact shall notify the Fitness For l Duty Administrator of the unavailability immediately.

'c. The Point of Contact shall notify the Fitness For Duty Administrator within a l

mutually agreed upon time to confirm contact with the participant.

6.2.6 If a Point of Contact fails to notify a participant or fails to make the participant av'ailable for testing, the Fitness For Duty Administrator shall document the circumstances in a memo to the Fitness For Duty Program Manager and the Point of Contact's manager or company representative.

6.2.7 The participant reports to the collection site, completes the required forms, and L cooperates in the drug and alcohol testing process. Once the specimen collection process has begun, the participant shall remain at the collection site until the process l is' complete, as determined by the Fitness For Duty Administrator or che collection site

! staff.

6.2.8 The testing shall be performed in accordance with the requirerrents of this procedure.

These requirements shall ensure, as a minimum, the following:

a. The Fitness For Duty Program Manager shall maintain a list ofindividuals I

authorized to be in the collection site. Unauthorized personnel shall be escorted while in the collection site.

b. A single member of the collection site staff shall conduct only one specimen collection at any given time.

c. Individual privacy shall be given to the participant providing the specimen, unless there is reason to believe that the participant may alter or substitute the specimen to be provided.

[-

I VIRGINIA l POWER VPAP-0105 l l REVISION 11 l PAGE 40 OF 71 l l

l

d. The specimen shall remain under direct control of the collection site staff from 1

delivery through its sealing in a mailing pouch or otherwise secured for shipment.

i l

e. Precautions shall be taken to ensure the following:

l 1.

Urine specimens are not adulterated or diluted during the collection process.

2. Blood samples or breath exhalant tubes are not tampered with or substituted.

3. Information on the specimen container and in the record book can identify the participant from whom the specimen was collected.

f. Control and accountability of each specimen from the point of collection to final disposition of the specimen is maintained.

I g. Collection site personnel shall arrange to transfer the collected specimens to the drug testing laboratory.

1

h. Refusals to cooperate with the specimen collection or breath analysis process are treated in accordance with 6.2.5.a.

6.2.9 The collection and testing facility staff may perform initisl screenings of the l

specimens at the onsite testing facility, or ensure transport of the specimens to the

! HHS-certified laboratory in the event that testing onsite is unavailable. Ifinitial j screenings are performed, the following shall apply:

a. Negative results shall be recorded .

b. Participants will not be notified of negative results,

c. A portion of the negative specimens shall be retained for potential inclusion in a sampling to be forwarded to the HHS-certified laboratory.

d. Positive results shall be recorded and the specimens shall be immediately forwarded to the HHS-certified laboratory for screening and confirmation testing.

e. The collection and testing facility staff shall notify the MRO of an initial onsite positive screening.

VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 41 OF 71 NOTE:

Only the Medical Review Officer, the Supervisor FFD Testing and, as appropriate, Employee Health Services personnel are notified of an initial onsite positive screenin test.

6.2.10 The HHS-certified laboratory shall perform the following:

a. Conduct initial screening tests. i'

b. Conduct confirmatory tests.

I

c. Notify the MRO of the results within 5 working days of receipt of the specimen.

6.2.11 The MRO shall perform the following:

a. Review confirmed positive test results. l I

b. Notify the Fitness For Duty Administrator of confirmed positive test results within

{

10' days of the initial positive screening test. !

6.2.12 The Fitness For Duty Administrator shall immediately notify the Station Manager of a confirmed positive test result.

6.2.13 Station Manager determines appropriate corrective action based upon notification of confirmed positive test result. The corrective action shall be based upon the requirements of 6.1.6. Corrective action may include, but is not limited to the following:

. Termination of employment

. Denial of unescorted access for contractor or vendor

. Referral to EAP for assessment and counseling

. Suspension of duties and unescorted access for predetermined period 6.2.14 The Fitness For Duty Administrator shall update the records of the Fitness For Duty Program and notify the Fitness For Duty Program Manager for required reporting.

___ _ - _ _ - _ _ ~

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 42 OF 71 6.3' Pre-Access Drug and Alcohol Testing New personnel who require unescorted access to the Station shall adhere to the requirements of the Fitness For Duty Program. This requirement applies to Virginia Power employees, contractors, and vendors. Specific requirements regarding Fitness For Duty are as follows:

6.3.1 Supervisors of new personnel shall ensure that individuals receive Fitness For Duty training and undergo drug and alcohol testing prior to granting unescorted access.

6.3.2 New personnel shall notify their supervisor of any event which resulted in denial of unesconed access at any other nuclear power plant.

6.3.3 When contractor or vendor employees travel between Virginia Power Nuclear Stations (Surry and North Anna) or change employers (if both employers have adopted the Virginia Power Nuclear Access Requirements):

a. If the transfer is accomplished within 30 days or if unescorted access is maintained at the previous Station, pre-access testing is not required.

b. Nuclear Security and Administrative Services shall track the 30 day lapse period. l NOTE: In the event that an individual was denied unescorted access at any other nuclear power plant under a fitness for duty program, the grandng of unescorted access or assignment of duties associated with North Anna or Surry Power Station is only allowed based upon the Fitness For Duty Program Manager and the Medical Review Officer determination of fitness for duty.

6.3.4 New personnel shall receive initial training on Virginia Power's Fitness For Duty Program, including their responsibilities as specified in 5.5.

NOTE: INPO employees are exempt from Virginia Power Pre-Access Fitness For Duty I testing. Employees of other licensees may be exempt from Pre-Access testing based r upon the requirements of the procedure. Virginia Power may elect to allow contractors or vendors to perform pre-access testing of their own employees in accordance with 6.1.14.

l 6.3.5 The individual's supervisor shall ensure that Fitness For Duty testing for new personnel is scheduled with the Fitness For Duty Administrator.

? l 1

L_____________________.._.__. _ . _ _ _ _ _ . .

VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 43 OF 71 NOTE: The drug and alcohol testing must occur within 60 days prior to the initial granting of unescorted access.

6.3.6 New personnel shall undergo testing in accordance with 6.2.5 through 6.2.11. ;

6.3.7 The Fitness For Duty Administrator shall be notified by the collection site staff or the I MRO, as applicable, of acceptable results.- l 6.3.8 The Fitness For Duty Administrator shall post acceptable results.

NOTE: Security badgs are not issued to individuals until Station Security has been notified +

that an individaal has tested negative for drugs and alcohol.

6.4 For Cause Drug and Alcohol Testing Individuals may be tested For Cause under the Fitness For Duty Program. 1 6.4.I' For Cause Testing shall be initiated as soon as possible for the following reasons: i i

a. Observed Behavior indicating possible substance abuse or otherwise raising a :

question regarding an individual's fitness for duty.

b. Failure in Individual Performance resulting in actual or potential degradation of safety whether or not an accident occurred; OR,if there is reasonable suspicion that an individual's behavior contributed to an on-duty accident resulting in one of the following:

. A fatality

. A personal injury when off-site medical treatment is required

. Property damage where employee discipline may be required

. Radiation exposure or release of radioactivity in excess of regulatory limits

. Actual or potential substantial degradation of the level of safety of the Station

c. Receipt of Credible Information that an individual is abusing drugs or alcohol.

l d. A Driver Controllable Vehicle Accident.

6.4.2 If any of the above listed events occur, the individual's supervisor shall be notified immediately.

t L.i__________________ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . . . . _ _ . . _ _ _ _ _ _

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 44 0F 71 NOTE: If circumstances prevent the supervisor from performing his/her responsibilities to investigate the accident because the accident is outside the service area, orif for-cause testing should have been performed but was not, the supervisor shall forward a memo to the Fitness For Duty Administrator detailing the event and the circumstances which prevented performance of supervisory responsibilities and for-cause testing (if applicable).

6.4.3 The supervisor shall investigate and review the event to determine if For Cause Testing is required,

a. If For Cause Testing is not required, the supervisor shall inform the individual that he/she may retum to work.

b. If For Cause Testing is required, the supervisor shall determine the classification of the event through review and investigation. For Cause Testing events are classified as follows:

. Observed Behavior

. Failure in Individual Performance

. Receipt of Credible Information

. A Driver Controllable Vehicle Accident NOTE: If the supervisor determines that Observed Behavior is combined with any other .

classification such as Driver Controllable Vehicle Accident plus O' bserved Behavior, Lt hen the event shall be classified as Observed Behavior.

, 6.4.4 Upon determination of the classification of the event, the supervisor shall contact a Fitness for Duty Administrator (FFDA).

NOTE: A Fitness for Duty Administrator must be contacted prior to initiating For-Cause Testing.

a. If the event has occurred during normal dayshift working hours, the supervisor shall contact an FFDA at the following phone numbers:

1 Tie Line Office Number Surry 798 (757) 365-2777 I North Anna 794 (540) 894-2573 l

l w___________-_-_-_____-___-___ - _ _ _ _ _ _

VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 45 OF 71 Innsbrook 730 (804) 273-3598

b. If the event has occurred during backshift or weekend working hours, or if the supervisor is unable to contact an FFDA, the supervisor shall contact Security at the following phone numbers:

Tie Line Office Number Surry 798 (757) 365-2346 North Anna 794 (540) 894-2224 .

Innsbrook 730 (804) 273-3157

c. The supervisor may call any of the three security numbers for assistance.

d. The Security department will contact an FFDA, who will then contact the supervisor initiating this procedure.

6.4.5 The FFDA will provide guidance, determine where the testing will be performed, and (if applicable) assist with required notification of Security and Station Management.

NOTE: In all cases of For Cause Testing events classified as Observed Behavior for Virginia Power employees, the supervisor shall ensure that a medical examination is performed in addition to drug and alcohol testing.

6.4.6 Station Security shall provide a member of the Station Security force to assist in 1

escorting the individual throughout the For Cause testing process as follows. I

a. An escort shall always be provided when testing for Observed Behavior and :

1 Receipt of Credible information.

1

b. An escort may be provided when testing for Driver Controllable Vehicle Accidents l

and Failure in Individual Performance events when the supervisor believes the i

event may have been caused by drug or alcohol abuse.

l 1

j c. An escort shall be provided when requested by the supervisor or the FFDA.

6.4.7 The Station Manager shall notify Station Security to suspend the individual's unescorted access based upon the following criteria:

a. If For Cause Testing is based upon Observed Behavior, the Station Manager shall notify Station Security to suspend the individual's unescorted access.

l l

VIRGINIA VPAP-0105 i POWER REVISION 11 PAGE 46 OF 71

b. If For Cause Testing is based upon Receipt of Credible Information, the Station Manager shall notify Station Security to suspend the individual's unescorted access.

c. If For Cause Testing is based upon a Failure in Individual Performance event, and the supervisor believes the event may have been caused by drug or alcohol 1 abuse, the Station Manager shall notify Station Security to suspend the individual's unesconed access.

d. If For Cause Testing is based upon A Driver ControHable Vehicle Accident, and the supervisor believes that the occurrence may have been caused by drug or alcohol abuse, the Station Manager shall notify Station Security to suspend the individual's unescorted access.

NOTE: When the individual is within the Protected Area and the individual's unescorted access has been suspended, Security shall escort the individual out of the Protected l Area. Security shall escort the individual to either the site collection facility or the )

offsite medical facility if requested by the supervisor. !

1 I

6.4.8 The supervisor shall escort the individual to either the site collection facility or the i offsite medical facility, as determined by the Fitness For Duty Administrator, for drug and alcohol testing. The following guidance applies:

a. If testing is to be performed at the site collection facility, the collection facility staff !

shall test the individual for drugs and alcohol in accordance with 6.2.5 through 6.2.11.

b. If testing is to be performed at an offsite medical facility, the supervisor shall:

1. Obtain an Fitness For Duty Kit from Security.

c 2. Request that the Fitness For Duty Administrator assist in arranging a medical exam to be conducted at an offsite medical facility,if required.

3. Accompany the individual to one of the offsite medical facilities approved by the Manager Human Resources Employee Services / Safety & Health.

4. - Provide the Fitness For Duty Kit to the medical facility staff and request that drug and alcohol testing be performed in accordance with the instructions contained within the Fitness For Duty Kit.

VIRGINIA -

POWER VPAP-0105 REVISION 11 PAGE 47 OF 71 6.4.9 Upon completion of the Fitness for Duty specimen collection process and any required l

medical examination, the supervisor shall perform the following:

a. If the individual's unescorted access has been suspended, arrange transportation for the individual to return home.

b. If the individual's unescorted access has not been suspended, inform the individual that he/she may return to work.

6.4.10 The supervisor shall provide the Station Manager and the Fitness For Duty Administrator with the following information on a Fitness for Duty Management Action Report, Attachment 1:

. An evaluation of the individual's behavior

. An assessment of the individual's fitness for duty

. A record of any safety related work performed by the individual that was unsupervised or directly involved the incident resulting in the For Cause test, as determined by the supervisor or cognizant manager 6.4.11 Upon receipt of the test results, the following shall be performed:

l

a. If the specimen was analyzed on site, and the results are negative, the following applies:

1. The collection site staff shall notify the FFDA of the results.

2.. The FFDA shall document the results on a Management Action Report.

b. If the specimen was analyzed off site, the MRO shall interpret the test results and -

l if applicable, the medical examinations.

6.4.12 The Fitness For Duty Administrator shall notify the Station Manager,if access has

']

been suspended or the test results are positive, and the individual's supervisor of the I test results, and if applicable, the MRO's medical opinion of fitness for duty.

6.4.13 If the MRO determines a confirmed positive test result, the following actions shall be performed: '

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 48 OF 71

a. The Station Manager shall determine appropriate corrective action based upon notification of confirmed positive test result. The corrective action shall be based l upon the requirements of 6.1.6. Corrective action may include, but is not limited to the following:

. Termination of employment

. Denial of unescorted access for contractor or vendor

. Referral to EAP for assessment and counseling

. Suspension of duties and unescorted access for predetermined period

b. The Fitness For Duty Administrator shall complete appropriate reports and update the records of the Fitness For Duty Program.

c. The Fitness For Duty Administrator shall notify the Fitness For Duty Program Manager and the Station Manager for any required reporting to the NRC which meets the criteria of 6.1.11.

6.4.14 If the test results are negative, the following actions shall be performed:

a. If unescorted access has been suspended, the Station Manager and the MRO shall jointly determine if the mdividual shall be allowed to return to work at the Station.

1. If the individual is allowed to return to work, the Station Manager shall have Station Security reinstate the individual's unescorted access and shall direct the individual to return to work. -

2. If the individuals not allowed to return to work, the Station Manager initiates appropriate corrective action. Corrective action may include, but is not limited

, to the following:

. EAP counseling

Suspension of duties and unescorted access for predetermined time

b. If unescorted access has not been suspended, the Fitness For Duty Administrator shall document the negative test results in the Fitness For Duty Program files.

6.5 Follow-Up Drug and Alcohol Testing Follow-Up Drug and Alcohol testing shall be performed on an unannounced basis to verify that an individual who previously tested positive for drugs or alcohol is abstaining from drug and alcohol abuse.

VIRGINIA POWER VPAP-0105 REVISION 11 1

PAGE 49 OF 71 6.5.1 Follow-Up testing shall be performed in accordance with the following requirements:

a. Participants shall be tested in accordance with 6.2.4 through 6.2.11.

b. Participants shall be scheduled for testing in accordance with ASCP-0001, Administration of the Fitness For Duty Program.

6.5.2 individuals shall be subject to Follow-Up testing under the following circumstances:

i

a. Virginia Power employees who test positive for alcohol, illegal drugs, or legal

{

drugs for the first time shall be subject to Follow-Up testing as follows: ' i

1. The frequency and scheduling of the Follow-Up testing shall be determined by the Medical Review Officer (MRO) and the Fitness For Duty Program Manager. As a minimum, the employee shall participate in the Follow-Up S

, testing program at least once a month for the first 4 months and thereafter at least once every 3 months for the next 2 years and 8 months.

2. A confirmed positive test during panicipation in the Follow-Up testing program shall result in termination.

b. Individuals who had a first offense positive test for alcohol or legal drugs under another utility's 10 CFR 26, Fitness For Duty Program, and are granted unescorted access to North Anna or Surry Power Station shall be subject to Follow-Up testing.

The following restrictions apply:

l. The frequency and scheduling of the Follow-Up testing shall be determined by the Medical Review Officer (MRO) and the Fitness For Duty Program Manager. As a minimum, the individual shall participate in the Follow-Up testing program at least once a month for the first 4 months and thereafter at least once every 3 months for the next 2 years and 8 months. Credit may be given for time spent in another utility's Follow-Up testing program.

2. A confirmed positise test during participation in the Follow-Up testing program shall result in demal of unescorted access and possible termination.

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VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 50 OF 71 6.6 Detection of Aberrant Behavior Aberrant behavior is an indication that an individual is potentially under the influence of drugs or alcohol. Personnel should be aware of the symptoms of drug and alcohol abuse displayed i through abnormal behavior. The early detection ofindividuals who are under the influence of drugs or alcohol will be increased through an awareness of outwardly manifested symptoms.

6.6.1 Personnel who have reason to suspect that an individuals under the influence of drugs or alcohol shall notify the individual's supervisor. Examples of aberrant behavior, provided in 6.6.2 through 6.6.8 should assist personnel in the recognition of drug or alcohol abuse.

6.6.2 Narcotics Narcotics or opiates are substances that decrease the user's physical senses.

Individuals who are under the influence of narcotics or opiates may exhibit one or more of the following symptoms:

Drowsiness Nausea Constricted pupils

. Clammy skin Needle marks / track marks e

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VIRGINIA POWER VPAP-0105 REVISION 11 i

PAGE 51 OF 71 6.6.3 Depressants Depressants or sedatives are substances that slow down and relax the user's central nervous system. Individuals who are under the influence of depressants or sedatives mc.y exhibit one or more of the following symptoms:

. Disorientation l

Drowsiness

! . Slurred speech lethargy

. Unsteady walk Fainting

. Memory loss

6.6.4 Stimulants i i

)

Stimulants are substances that speed up the user's central nervous system. Individuals l who are under the influence of stimulants may exhibit one or more of the following ,

symptoms:

i Hyperactivity l

. Sudden mood swings Very talkative

. Profuse sweating

. Dilated (enlarged) pupils 6.6.5 Hallucinogens Hallucinogens are substances that radically distort the user's perception of reality.

Individuals who are under the influence of hallucinogens may exhibit one or more of

. the following symptoms:

. Hallucinations (visual or auditory)

. Distorted sense of time or distance

. Dilated (enlarged) pupils

. Psychotic behavior L

I

VIRGINIA .

VPAP-0105 POWER REVISION 11 PAGE 52 OF 71 -

6.6.6 Cannabis Cannabis or marijuana are substances that distort the user's perceptions of time, space, or distance. Individuals who are under the influence of cannabis or marijuana may exhibit one or more of the following symptoms:

. Drowsiness

. Loss of memory

. Confusion

. Reddened eyes 6.6.7 Inhalants Inhalants are substances that cause sudden loss of control over the user's thought process and motor activities. Individuals who are under the influence ofinhalants may J exhibit one or more of the following symptoms:

. Confusion

. Slurred speech

. Dizziness Loss of muscle control Loss of coordination 6.6.8 Alcohol Alcohol is a substance that slows down and relaxes the user's central nervous system. i Individuals who are under the influence of alcohol may exhibit one or more of the d following symptoms:

. Slurred speech l

. Unsteady walk ;

Reddened eyes

. Impaired. coordination l'

VIRGINIA

. POWER VPAP-0105 REVISION 11 PAGE 53 OF 71.

6.7 Continual Behavioral Observation Program A Continual Behavioral Observation Program shall be established to recognize changes

- individual employee behavior over a period of time to detect symptoms which may indica substance abuse or other mental or physical problems which could adversely affect job

. performance or safety.

6.7.1 The Station Manager shall establish and implement a Continual Behavioral Observation Program.

6.7.2 Station supervisors shall receive training on the detection techniques utilized within the Continual Behavioral Obsenation Program.

6.7.3 Station supervisors shall observe individuals under their supervision for indications of -

potential substance abuse or other mental or physical problems. Symptoms of abuse or

~

problems are as follows:

a. Job Performance

. Change in individual's quality or quantity of work Decrease in individual's decision' making capability.

- Decrease in individual's efficiency

. Decrease in individual's ability.to concencate - I Increase in individual's absenteeism

. Increase in individual's lack of presence in work area for long, unexplained periods '

. Exhibits disregard for company policies and procedures

Exhibits overcautious behavior Exhibits overzealous behavior

. Decrease in individual's' cooperation with fellow workers I

. Exhibits lack of respect for supervision or authority i

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VIRGINIA . VPAP-0105 I POWER REVISION 11 PAGE 54 OF 71

b. Social Relationships

. Exhibits unsociable behavior

. Exhibits excessive socializing

. Changes in individual's choice of friends

. Changes in manner that fellow workers treat individual

. Changes in individual's financial activities t

. Exhibits violent reactions toward others '

. Exhibits attempts to manipulate others '

l . Changes in speech patterns or content

+

Increase in individual's complaints

c. Personal Health ,

. Exhibits moody or nervous behavior .

l . Change in individual's opinions on alcohol or drugs

+ Increase in lingering or unusual illness

. Exhibits confusion frequently

. Changes in daily habits or routines

. Change in individual's energy level

. Change in individual's overall physical condition

. Exhibits cardiovascular or pulmonary difficulties 6.7.4 Station supervisors shall contact the Fitness For Duty Administrator ifindividuals under their supervision exhibit numerous symptoms or singular symptoms of an excessive nature. '

, 6.7.5 The Fitness For Duty Administrator shall provide advice and guidance relative to the Continual Behavioral Observation Program.

E VIRGINIA' POWER VPAP-0105 REVISION 11 PAGE 55 OF 71 !

6.7.6 Station supervisors shall initiate corrective action ifindividuals continue to

~

demonstrate symptoms described in 6.7.3. Corrective action may include, but is not limited to the following:

i

. Discussions between individual and supervisor For Cause testing under Fitness For Duty Program j

. Referral to EAP

'

Suspension of duties and unescorted access for predetermined period *

. 6.7.7 Station supervisors shall note any unusual or aberrant behavior, which if repeated could lead to For-Cause Testing, on a Continual Behavioral Observation Event Report

- Attachment 3. The Continual Behavioral Observation Event Report should be maintained by the Supervisor for future reference if the behavior is repeated and For-Cause Testing is necessary.

6.7.8 The Fitness For Duty Administrator shall record the event in the Fitness For Duty Program files.

6.7.9 The FFD Program Manager shSil evaluate information concerning individuals with unescorted access authorization who have been arrested for reasons which may impact their trustworthiness.

NOTE: ~ An employee is not considered to be away from a CBO program if he/she is on vacation, sick leave or military leave.

6.7.10 Individuals who have been away from a CBO program for more than 30 consecutive l

. days must be evaluated for reinstatement into the program. The following should occur when the individual returns:

a. The HR Representative responsible for reinstating the employee shall have the l

employee complete an Unescorted Access Authorization Activity / Fitness for Duty Certification form (Attachment 4).

' b. The completed form shall be forwarded to Nuclear Access Services for evaluation to determine if the activities listed have the potential of affecting the CBO program requirements.

p

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 56 OF 71 6.8 Self Reporting 6.8.1 Allindividuals subject to the Virginia Power Nuclear Fitness for Duty Program shall: l

a. Report to work with no detectable presence of alcohol or prohibited drugs in their system

b. Report to supervision any felony or misdemeanor conviction and any arrest which l may impact their trustworthiness. This includes all arrests, except for traffic offenses for which the individuals released after signing a summons

c. Prevent and report to supervision any threat of harm to the public, Company, and/

or co-workers (includes reporting personnel with symptoms of substance abuse)

d. Report to supervision any previous unescorted access denial, positive chemical test, and/or involuntary participation in a substance abuse treatment program 6.8.2 If 6.8.1.b. or c. above is reported to a supeivisor, the supervisor shall immediately notify (by telephone) Station Security and/or the Manager-Nuclear Security &

Administrative Services, and will complete and submit a Fitness for Duty Self Reporting Notification (Attachment 5) as soon as possible. The supervisor shall follow the instructions listed on the form for its completion and disposition.

6.9 Fitness For Duty Call-Out Process 1

The Fitness For Duty Call-Out process is utilized in the event that an extraordinary, unanticipated need arises where a particular individual's skill or knowledge mandates that Station supervisors request the individual to work even though the individual has consumed alcohol within the specified pre-duty abstinence time period. Station supervisors should attempt to minimize the frequency of such occurrences by exhausting all other options prior to l

the Call-Out of an individual who has consumed alcohol. Call-Outs usually occur outside of normal working hours, which places the primary responsibility upon the supervisor to determine if the individual should report to and perform work. When the Call-Out of an individual who has consumed alcohol cannot be avoided, the following process shall be followed:

6.9.1 The individual shall inform the supervisor whether he/she has consumed alcohol

withiu the previous 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months and whether he/she feels capable to perform work.

l f . . __

l VIRGINIA POWER VPAP-0105 '

REVISION 11 PAGE 57 OF '1 1

6.9.2 If the individual has consumed alcohol within the previous 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months , but feels capabl of performing the work, the supervisor shall proceed as follows:

a. Determine a preliminary assessment of the individual's fitness for duty by completing the Preliminary Alcohol Concentration Chart (PACC), Attachment 2.

b. The supervisor shall determine if a breath analysis is warranted based upon the results of the PACC. Guidelines which shall be employed by the supervisor are as follows:

1. Blood Alcohol Concentration less than 0.04:

. The individual may report to work. .

. A breath analysis is required.

. The individual may perform normal duties if a Blood Alcohol Concentration less than 0.04 is confirmed.

2. Blood Alcohol Concentration equal to or greater than 0.04 the individual shall be advised to remain at home.

6.9.3 If the PACC indicates a Blood Alcohol Concentration less than 0.04, the following activities shall be performed:

i

a. The supervisor shall contact Station Security and request a breath analysis to be -

performed.

l

b. Station Security shall contact the Fitness For Duty Administrator to arrange to have a breath analysis performed by the collection site staff. I

c. Upon the individual's arrival at work, the supervisor shall ensure that a breath I analysis is performed and shall review the test results with the test administrator.

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 58 OF 71 NOTE: Individuals who have been requested to report to work even though their Blood Alcohol Concentration is equal to or greater than 0.04 are not subject to the sanctions of the Fitness For Duty Program.

d. The supervisor shall determine if the individual is fit for duty based upon the results of the breath analysis. Guidelines which shall be employed by the supervisor are as follows:

Blood Alcohol Concentration less than 0.04 the individual may perform normal duw .

+ Blood Alcohol Concentration equal to or greater than 0.04 the individual shall not be allowed to perform work until a Blood Alcohol concentration less than 0.04 is confirmed.

6.9.4 The supervisor shall perform the following for any Call-Out when the individual has consumed alcohol within the 5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months abstinence period:

a. Document the decision regarding the individual's fitness for duty and any required controls on a Management Action Report, Attachment 1.

b. Attach the Breath Analysis Results card to the Management Action Report.

c. Forward a copy of the Management Action Report, Breath Analysis Results card, and Preliminary Alcohol Concentration Chart to the Station Manager and the Fitness For Duty Administrator.

6.10 Emergency Response Fitness For Duty Requirements Individuals required to respond to the EOF, TSC, or the Station in the event of an emergency shall not be prohibited from reporting simply due to alcohol consumption during the 5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months abstinence period. However, the individual should use discretion and consider whether he/she is fit for duty prior to responding to an emergency based upon the amount of alcohol consumed.

The following controls shall apply:

I 1

o

VIRGINIA POWER VPAP-0105 REVISION 11 PAGE 59 OF 71 6.10.1 If an individual has consumed alcohol during the 5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months abstinence period, and is summoned to respond to an emergency, the individual shall proceed as follows:

a. Perform a self assessment of his/her Blood Alcohol Concentration by completing a Preliminary Alcohol Concentration Chart (PACC), Attachment 2. The following guidelines shall apply:

1. Blood Alcohol Concentration less than 0.04 the individual may respond to the emergency.

2. Blood Alcohol Concentration equal to or greater than 0.04 the individual should contact his/her management for further evaluation.

6.10.2 If the individual decides to respond to the emergency, the individual shall immediately report the alcohol consumption upon arrival to the following:

a.' The Station Emergency Manager or designee upon arrival at the TS'I

b. The Recovery Manager or designee upon arrival at the LEOF.

6.10.3 A determination of the individual's fitness for duty shall be performed by the Station Emergency Manager, the Recovery Manager, or their designees by reviewing the Preliminary Alcohol Concentration Chart (PACC) completed by the individual. The following guidelines shall apply:

i i

a. Blood Alcohol Concentration less than 0.04 the individual may perform required duties during the emergency.

b. Blood Alcohol Concentration equal to or greater than 0.04 the individual may perform required duties with approval of the Station Emergency Manager or the Recovery Manager.

NOTE: As emergencies may last for several hours, an individual originally determine i to be unfit for duty, may participate in the emergency after a subsequent determination using the PACC indicates that the individual is fit for duty.

i 6.10.4 The determination of fitness for duty shall be recorded on a Management Action I

Report, Attachment 1, by the Station Emergency Manager, the Recovery Manager, or their designees.

l

VIRGINIA: .VPAP-0105 POWER REVISION 11 PAGE 60 OF 71 6.10,5 Upon termination of the emergency, the Management Action Report and the PACC shall be forwarded to the Fitness For Duty Program Manager.

7.0 RECORDS 7.1 Documentation and records generated in the performance of this procedure are Fitness For Duty records and Non-Quality Assurance records as defined by VPAP-1701, Records Management.

7.2 Due to the Protection of Information requirements associated with the Fitness for Duty Program, Fitness For Duty records are maintained in the Fitness For Duty files, not by Records Management. Fitness For Duty records shall be retained in accordance with 6.1.10 of this procedure.

t 6

e l

--_-._._____._,__.___m_____._ _ - _ _ _ _ _ _ _ _ . . _ _ . . _

VPA P-0105 REVL,f0N 11 PAGE 61 OF 71

) Fitness For Duty

__ Management Action Report VPAP-0105 - Attachment 1 Name (Print)

Social Security Number Date Company (Name)

D<*scription of Fitness For Duty Event O

E L

i l

Corrective Action Taken l

l I

save.ual Completing The. ,.rm iams (Print) Signature Date Title Company (Name) suem., o.

l .ete. ,m . . ,,t,,e.. ,o, ,ty .. m..t,a

- Form No 730721 July 961

i VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 62 OF 71 intentionally Blank i

i

VPAP-0105 REVISION 11 PAGE 63 OF 71 L

PreliminaryAlcohol l WIURGAulf4 P00eER Concentration Chart VPAP-0105 - Attachment 2 l

Instructions Supervisor shall complete this section.

1. Call-Out individual (Name - Please Print) 1 j 2. Supervisor (Name. Please Print)

3. Date

4. Time of Day i

O A M. O P.M.

l Irntructions Supervisor shall ask the Call-Out Individual the questions in Section A and perform the calculations in Section B.

A Questions .

in. How many drinks has the individual consumed?

NOTE: One drink equals 1.25 oz of hard liquor,12 oz. of beer, or 4 oz, of wine.

22. How much does the individual weigh (in pounds)?

33. How many hours have elapsed since the individual 114 tits drinking?

9. Calculanons .

"~ ~ ~ ~ ~ ~ ~~ ~

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Blood Alcohol Concentration (BAC) Table .

1 .04 .04 .03 .03 .02 .02 .02 .02 2 .09 07 .06 .06 .05 .04 .04 .04 3 .13 .11 .09 .08 .07 .07 .06 .06 4 .18 .15 .13 .11 .10 .09 .08 .07 Number of Drinks - 5 .22 .18 .16 .14 .12 .11 .10 .09 From Question 1a 6 .26 .22 .19 .17 .15 .13 .12 .11 7 .31 .26 .22 .19 .17 .15 .14 .13 8 .35 .29 .25 .22 .20 .18 .16 .15 9 .40 .33 .28 .25 .22 .20 .18 .17 10 .44 .37 .31 .28 .24 .22 .20 .18 100 120 140 160 180 200 220 240 Body Weight (Pounds)- From Question 2a NOTE: Blood Alcohol Concentration (BAC) is reduced by .01 for each hour that has passed since the individual began drinking.

1b. Enter Blood Alcohol Concentration from Chart above (Number of Drinks / Body Weight):

2b. Multiply answer to Question 3a by .01:

(e.g.,1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 01,2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . 02. 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 03) 3b. Subtract 2b from 1b to determine Preliminary Blood Alcohol Concentration (BAC)*:

a. Supervisor (Signature)

For individual to be Fit for Duty, BAC must be less than .04

)

i Form No 73J722(Jan 97) I

VIRGINIA VPAP-0105 POWER REVISION 11 PAGB 64 OF 71 i

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REVISION 11 PAGE 65 OF 71 i

Fitness For Duty '

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i.an== ro ContinualBehavioral Observation Event Report VPAP-0105 - Attachment 3 Ntme (Pnnt) 1 i

Tnis Company (Name)

Data of Event Time of Event i

Locrtion of Event l

I Dssenption of Event 1

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l IhblPNfhtermmvsmfas:wu 1:me (Print) Sgnature Date Titis Company (Name)

Porm NO /WMWWuty Mbj

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 66 OF 71 1

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VPAP-0105 REVISION 11 PAGE 67 0F 71

' Unescorted Access Authorization

""*** * "*" Activity / Fitness For Duty Certification VPAP-OtOS - Attachment 4 Name Social Secuirty Number i understand that I must provide certification of my activities during my absence from Virginia Power's Continual C:havioral Observation Program.

Sign one of the following statements I have not been involved in any activity that could adversely affect my trustworthiness or reliability during my absence. ,

Signature Date I have been involved in activities, described below, that could potentially affect my trustworthiness or reliability during my absence.

A i

Signature Date son one of the followmq statements.

I osrtify that I have never tested positive for drugs or use of alcohol that resulted in on-duty impairment; been subject to a plan for treating substance abuse (except for self-referral); or been removed f rom activities or denied unescorted access at any nuclear plant for violation of a Fitness For Duty policy, or otherwise been denied access to or been removed from activities in a protected area of a nuclear f acility.

l Apphcant (Signature)

Date i cannot certify that I have never tested positive for drugs or use of alcohol that resulted in on-duty impairment; been subject to a plan for traating substance abuse (except for self-ref erral): or been removed from activities or denied unescorted access at any nuclear plant for violation of a Fitness For Duty policy for the following reasons:

Apphcant (Signature) Date Employment History -.

I rlso understand that prior to my reinstatement Virginia Power must contact firms with whom I have been employed during my absence to psriorm a Fitness For Duty Suitable inquiry.

List *d below are the firms with whom I have been employed since termination of my access authorization at Virginia Power.

Company Name Telephone Number Address Period of Employment ampany Name Telephone Number Address Period of Employment Form No 720684Woly 96)

- VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 68 OF 71 Intentionally Blank 3

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VPAP-0105 REVISION 11 PAGE 69 OF 71 O Fitness For Duty / Self-Reporting vmamarossen Notification VPAP-0105 - Attachment S l

in:truction '

To be completed and maintained by supervisor, with reporting as specified.

Parteipant (Name) Social Securrty Number Company (Name) Date Location of Event .

Please tniscate the type of event. .

e. .

O Individual reported felony or misdemeanor conviction, or arrest that may impact his/her trustworthiness.

O Individual reported actions that threaten harm to Virginia Power or co-workers.

1f cither of the above event descriptions are checked, the event must be reported immediately (by telephone) to Station Security and/or the Manageri Nuclear Security and Administrative Services. This form must be completed and sent to the M: nager Nuclear Security and Administrative Services as soon as possible following the event.

Dindividual reported information regarding another individual who may be abusing drugs or alcohol, or involved in illegal activity. (The l supervisor shall report this information immediately to station management and the Manager - Nuclear Security and Administrative Services, and will retain this information for future reference.)

O lndividual reported mental stress, f atigue, illness, or other f actors which may affect his/her fitness for duty. This information is to be ratained by the supervisor for future reference.

U ndividual l reported legitimate use of prescription or over the-counter drug which may adversely affect his/her ability to perform his/her duties. (This information should be retained by the Supervisor for future reference.)

Description of Event (Please attach any supporting documents.)

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inehvidual Completing This Form Name (Print) Title

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Company (Name) Date Form Peo 722647(Oct 97)

VIRGINIA VPAP-0105 POWER REVISION 11 PAGE 70 OF 71 l Intentionally Blank 4

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G) Fitness For Duty Record mamuromme Request / Checklist VPAP-0105 - Attachment 6 trutructions

1. P:rticipant completes Section 1 and submits form to FFD Program Manager.

2. Fitness For Duty Administration willprovide all available and applicable records.

Section 1 - Participant Request c

1. Participant (Name) 2. Social Security Number

3. Company / Department 4. Work Location 5. Telepnone Number

6. I request that records of my Fitness For Duty test conducted on / / be sent toO meO my representative i

(name) at the following a rddress.

7. Street Address

8. City 9. State 10. Zip Code

11. Signature 12. Date Section 2- Transmittal Checkilst :-

13. Records Transmittal (Check "Yes" if applicable and transmitted. Check "N/A" if not used.)

instructions for Participants in the NRC Fitness For Duty Chemical Testing Program (Form No. 730671) O Yes N/A Drug and Alcohol Testing Consent and Chain of Custody (Form No. 730678) Yes O N/A Breath AlcoholTest Results Yes N/A Positive Breath Test Notification (Form No. 730672) Yes N/A Blood Alcohol Consent and Chain of Custody (Form No. 730677) N/A C Yes initial Screening Results Yes N/A HHS Laboratory Chain of Custody Yes O N/A HHS Laboratory Screeing and/or Confirmatory Test Resutts O Yes O N/A MRO Positive Chemical Test Checklist (Form No. 730808) Yes N/A Confirmed Positive Chemical Test Results Notification (Form No. 730670)) O Yes N/A MRO Fitness For Duty Appeals Checklist (Form No. 730723) Yes N/A

14. Comments l

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15. Date Information Sent to Participant 16. Nudear Securty and Administrative Services Personnel Providing information (Print Name)

. Nuclear Security and Administrative Services Personnel Providing information (Signature) 18. Date l

e.,.

Kry: FFD-Fitness For Duty; HHS-U.S. Department of Health and Human Services; 7224ssioci eri MRO-Medical Review Officer; NRC-Nuclear Regulatory Commission I

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ML20236H563

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