View source for Information Notice 2006-30, Summary of Fitness-for-Duty Program Performance Reports for Calendar Year 2004 and 2005

{{Adams
| number = ML062010365
| issue date = 12/21/2006
| title = Summary of Fitness-for-Duty Program Performance Reports for Calendar Year 2004 and 2005
| author name = Case M
| author affiliation = NRC/NRR/ADRA/DPR
| addressee name = 
| addressee affiliation = 
| docket = 
| license number = 
| contact person = Skarpac E, NSIR/DSO/DDSP/LPSB 415-5361
| document report number = IN-06-030
| document type = NRC Information Notice
| page count = 28
}}
{{#Wiki_filter:UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001 December 21, 2006 NRC INFORMATION NOTICE 2006-30:                  SUMMARY OF FITNESS-FOR-DUTY PROGRAM

PERFORMANCE REPORTS FOR CALENDAR

YEARS 2004 AND 2005

==ADDRESSEES==
All holders of operating licenses for nuclear power reactors, and licensees authorized to

possess or use or to transport formula quantities of strategic special nuclear material.

==PURPOSE==
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to report

lessons learned by licensees from their fitness-for-duty (FFD) program performance reports for

2004 and 2005. The agency expects that recipients of this IN will review the information for

applicability to their reactor facilities and consider, as appropriate, taking corrective actions to

improve the future performance of their FFD programs. However, suggestions contained in this

Information Notice are not NRC requirements and, therefore, no specific actions or written

responses is required.

==DESCRIPTION OF CIRCUMSTANCES==
As required by Title 10 of the Code of Federal Regulations (10 CFR) Section 26.71(d), NRC

licensees have submitted their FFD program performance reports to the NRC within 60 days of

the end of each 6-month reporting period (January-June and July-December). In the past, the

NRC summarized and analyzed the performance data and published an annual volume, NUREG/CR-5758, Fitness for Duty in the Nuclear Power IndustryAnnual Summary of

Program Performance Reports. The IN in the enclosure provides similar FFD program

performance data information for 2004 and 2005.

==DISCUSSION==
Licensees reported the following lessons learned, management initiatives and problems, and

the associated corrective actions taken for 2004 and 2005.

(1)     Certified Laboratories

Some licensees continue to experience problems with laboratory performance involving

equipment malfunctions and have also identified potential weaknesses related to human

error.

For example, licensees reported the following for 2004:
        *        One licensee reported that a primary laboratory erroneously returned

negative results for a specimen that was actually positive for morphine

and codeine. The primary laboratory determined a crimped reagent line

to be the most likely cause of the error. The laboratory has revised its

daily maintenance procedures to include inspection of the lines to the

reagent valves.

*        One licensee reported that a laboratory returned a negative result for a

sample that was actually positive. The licensee entered the issue into the

plants corrective action program. The discrepancy resulted from an

isolated, individual human error in which the extraction technician may

have failed to add the appropriate amount of urine specimen to the empty

test tube before adding the internal standard.

*        One licensee reported that a performance sample, spiked for both

secobarbital and phenobarbital, tested positive for only phenobarbital at

the laboratory. The laboratory reported that testing of the performance

sample showed secobarbital 1000 nanograms/milliliter (ng/ml), but the

laboratory staff inadvertently entered the data into the laboratory

computer as 100 ng/ml. The laboratory advised that it would provide

additional training to the certifying scientists on accurately entering

results.

*        One licensee reported that results took an inappropriate amount of time

to arrive from the laboratory. Therefore, the laboratorys responsible

person will change the requirements to release results to within 5 working

days.

*        One licensee reported a typographical error in the field containing the

donor identification as reported on the laboratory drug test report.

Corrected reports were issued and processed according to applicable

internal procedures.

In addition, licensees reported the following for 2005:
        *        One licensee reported that the certifying scientist signed a certified true

copy of a chain-of-custody form with a negative test result for a

performance sample spiked with secobarbital and phenobarbital. The

Department of Health and Human Services (HHS) certified laboratory

identified the error and provided a corrected chain-of-custody form

without prompting.

*        One licensee reported that the HHS laboratory announced negative

results for a positive blind quality assurance (QA) sample.

*        One licensee reported that the HHS laboratory announced negative

results for two positive blind QA samples sent in the same batch. *      One licensee reported a false negative on a blind performance test

sample containing amphetamine/methamphetamine. The error occurred

because (1) the confirmation analyst entered the original data incorrectly, and (2) the certifying scientist overlooked the error of the confirmation

analyst. Both individuals received counseling on the error and retraining.

*      One licensee reported that although the HHS laboratory returned no

incorrect results, Hurricane Katrina caused a disruption with its services.

(2) Random Testing

Several licensees reported minor problems related to the random drug and alcohol

selection process.

For example, licensees reported the following for 2004:
            *      One licensee discovered that the FFD random testing pool excluded 25 individuals. The issue was thoroughly investigated and all individuals

involved were identified, and they completed an administrative FFD test

without any disqualifying outcomes.

*      One licensee reported that one short-term contractor was granted

unescorted access but was not subject to random selection. The

individuals name was not entered into the random selection pool in time

for that individual to be subject to random selection. On discovery, the

individuals name was immediately entered into the random testing pool, and he was chemically tested under the other category, with negative

results. The licensee entered the problem into the corrective action

process.

*      One licensee reported that because a manual step was skipped, the

random testing pool excluded 18 individuals for a 4-day period. Upon

discovery, the licensee took the steps necessary to update the random

testing pool accordingly. The licensee no longer uses the manual step in

the random selection process.

*      One licensee reported that three workers were not entered into the

random testing pool because of a combination of overconfidence based

on previous experience, substandard performance of the task, and failure

to understand certain actions. The lessons learned from this situation

were reviewed with the appropriate staff, and relevant management

reports were developed to monitor performance in this area.

*      One licensee reported that a failure to perform a self-check resulted in

the incorrect coding of a pre-access FFD collection such that the worker

was not placed in the random testing pool. The error was detected and corrected before the worker was granted unescorted access. The staff

has been coached on self-checking and peer-checking techniques, including the use of validation reports during peak processing periods.

In addition, licensees reported the following for 2005:
            *        Five licensees reported that individuals were not placed in the random

testing pool following pre-access drug and alcohol testing as intended.

Upon discovery, the licensees identified the affected individuals and

manually placed their names in the random testing pool. The affected

individuals did not know that they were not in the random FFD pool.

*        One licensee reported that two names were not entered into the random

testing pool in time for random selection. Upon discovery, the individuals

names were immediately entered into the random test testing pool, and

they were chemically tested under the other category, with negative

results.

*        One licensee reported that two chemical tests were conducted for two

long-term contractor employees who had been inadvertently terminated

from the unescorted access database and removed from the FFD

random testing pool. Upon discovery, the individuals names were

immediately entered into the random test selection pool, and they were

chemically tested under the other category, with negative results.

(3) Policies and Procedures

Several licensees reported initiatives to improve their FFD program policies and

procedures.

For example, licensees reported the following for 2004:
            *        Two licensees did not meet the 10 percent blind sample submittal

requirement. They are implementing corrective actions and follow-up

actions to prevent future recurrence.

*        One licensee reported that it listed all the for-cause tests administered

under the subcategory observed behavior, although it should have listed

the for-cause test for a particular licensee employee under the

sub-category post-accident.

*        One licensee reported that a supervisor did not effectively implement the

FFD for-cause testing procedure for an employee who displayed problem

behavior. The licensee entered this issue into the plants corrective

action program. The supervisor was required to review the FFD for- cause testing procedure with his manager and received counseling on

management expectations for use of the procedure. In addition, the

supervisor was required to attend and complete the initial FFD training class. The licensee distributed information about this event via email to

all supervisors and managers. In addition, the supervisors and managers

who received the email were required to review the FFD program for- cause testing procedure and confirm by return email that they had read

and understood the testing requirements.

* One licensee reported that beer was found in the plant owner controlled

area, outside the protected area, during this reporting period. No

individual was in the area at the time of discovery. Five days after the

discovery of the beer, a contract worker admitted to his supervisor that

this beer was his and that he had consumed two cans of beer by himself.

Given that the individual had violated site policies regarding bringing

alcohol on site and drinking the beer on site, the licensee revoked his

unescorted access.

* One licensee reported that a contract employee who did not hold

unescorted access attempted to subvert his pre-access urine specimen

test, which resulted in a positive test for illegal drugs. The contractor was

denied unescorted access to the protected area.

* One licensee reported a contractor employees intentional falsification of

the chain-of-custody form during the pre-access testing process.

* One licensee reported that two for-cause tests were administered on

visitors for alcohol discovered in their vehicle during a security search

prior to entering the protected area.

* One licensee reported that an individual experienced a confirmed positive

test for a single substance based on medication obtained out of the

country that is not considered legal in the United States without a

prescription.

* One licensee reported that four individuals were tested after alcohol was

discovered in their vehicle at the owner controlled area access control

point. All tests were negative.

* One licensee reported that an employee and a contractor were tested for- cause after finding marijuana in a coin purse in the protected area.

Initially, the coin purse was thought to belong to the contractor so that

individual was tested first. However, the licensee employee admitted to

inadvertently bringing the coin purse into the protected area, stating that

it belonged to his son. The licensee employee and the contractor both

tested negative.

* One licensee discovered that it had not submitted its semi-annual FFD

performance data report to the NRC. It took immediate action to

electronically submit the report to the applicable representative. In addition, licensees reported the following for 2005:
        *        One licensee reported that follow-up testing had not been completed

when an individuals increased test frequency had not been implemented

as required by the Medical Review Officer (MRO). The apparent cause

was that the FFD program staff did not update the follow-up tracking

sheet to show the increase. To address this issue, the licensee (1) made

FFD program staff aware of the issue and (2) developed and

implemented a work instruction, including a checklist.

*        One licensee reported that two FFD tests were lost between the courier

and the laboratory.

*        One licensee reported that it sent an insufficient number of positive blind

specimens to the laboratory as required by site procedures. Although the

number of blind specimens submitted did meet regulatory requirements, the site procedural requirements were more restrictive.

*        One licensee did not meet the 10 percent blind sample submittal

requirement because of the large number of contractors brought in to

support the outage during the last weeks of the third quarter. A condition

report was generated and addition blind samples were sent to the

laboratory in the beginning of the fourth quarter to raise the average

above 10 percent.

*        One licensee reported that two individuals were tested after alcohol was

discovered in their vehicle at the entrance to the protected area.

*        One licensee reported that additional denials were issued for falsification

of their chain-of-custody form, and in some cases falsification of their

self-disclosure questionnaires.

*        One licensee reported that one contractor was asked to provide a second

sample during pre-access testing because of his behavior during the

collection. The individual started the process and then refused to

complete the second collection.

*        One licensee reported that a contractor discovered a can of beer that had

been inadvertently placed in his lunch-box. The individual was escorted

off site and security was notified. The individual was interviewed by the

FFD program manager, who determined that the introduction of alcohol

was not intentional.

*        One licensee determined that a non-supervisory, station contract

employee was incorrectly granted access to the protected area.

*        One licensee reported that it overstated the number of tests originally

reported as for-cause. *      One licensee reported that two steroid tests were conducted on an

individual per MRO recommendation. Both tests results were negative.

*      One licensee reported that during compilation of the semiannual data, it

identified that a computer error had persisted throughout 2005 and

invalidated the report. The licensee submitted a revision.

*      One licensee reported that United Parcel Service delivered three

packages to the plant. When a clerk in the administration building, located in the main protected area, opened the packages, the clerk

discovered that they contained unopened wine bottles. The clerk notified

plant security and removed all three packages from the plant protected

area and later removed the material from the plant site. It was

determined that all the wine bottles were unopened and no one

consumed any wine inside the plant protected area.

*      One licensee reported that it misrepresented a return-to-duty test for a

long-term contractor following a positive alcohol result as a follow-up test.

*      One licensee reported that on two occasions the Collection Site Person

failed to administer breath tests as required, as a result of inexperience.

*      One licensee identified instances in which unescorted access was

erroneously granted. The licensee is conducting an evaluation to

determine the cause of the error and to take corrective action.

(4) Program and System Management

In general, most licensees continue to report improvements in their overall FFD program

and its management.

For example, licensees reported the following for 2004:
            *      One licensee met with the laboratory, collection site, MRO, employee

assistant program, and psychological assessment personnel to ensure

consistent and effective implementation of the FFD program.

*      One licensee recertified collection personnel for proficiency in urine

specimen collection and breath alcohol measurement, continued cross- training with the In-Processing Center, attended quality improvement

program testing to help align access authorization and FFD programs, revised office instructions and protocols, and is implementing a new

computer program that will benefit access authorization and FFD

activities.

*      Ten licensees reported more restrictive cut-off levels for marijuana. *        Two licensees reported more stringent cut-off levels for alcohol.

*        One licensee reported more stringent cut-off levels for opiates.

*        Two licensees reported more stringent cut-off levels for amphetamines.

*        One licensee tests for two additional substances (names of substances

not listed).

*        One licensee reported improving the electronic database used for

initiating and approving working-hour deviation requests.

In addition, licensees reported the following for 2005:
        *        One licensee reported more stringent cut-off levels for opiates.

*        Ten licensees reported more stringent cut-off levels for marijuana.

*        Two licensees reported more stringent cut-off levels for amphetamines.

*        Two licensees reported more stringent cut-off levels for alcohol.

*        One licensee reported testing for two additional substances (substances

not named).

*        Two licensees reported testing for four additionally substances

(barbiturates, benzodiazepines, methadone, and propoxyphene).

*        One licensee reported meeting with laboratory staff, collection site staff, MROs, employee assistance program staff, and psychological

assessment staff to assure consistent effective implementation of the

FFD program.

*        One licensee met with the MROs to assure consistent effective

implementation of the FFD program.

==CONTACT==
This information notice requires no specific action or written response. Please direct any

questions about this matter to the technical contact listed below.

/RA by Theodore Quay for/
                                              Michael J. Case, Director

Division of Policy and Rulemaking

Office of Nuclear Reactor Regulation

===Technical Contact:===

===Eric Skarpac, NSIR===
                      301-415-5361 E-mail: fitnessforduty@nrc.gov

Enclosure: Tables for Fitness-for-Duty (FFD) 2004-2005 Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

ML062010365
* see previous concurrence

OFFICE       NSIR/DSO/LPSB            Tech Editor         NSIR/DSO/LPSB       NSIR/DSO/LPSB

NAME            CCollins*          HChang (by email)*         TMcCune*           ESkarpac*
  DATE           07/31/2006             08/08/2006             08/10/2006         08 /10/2006 OFFICE       NSIR/DSO/LPSB           DD:NSIR/DSO            D:NSIR/DSO              NSIR

NAME             GWest*                 RWay*                 DDorman*         RZimmerman*
  DATE           08 /14/2006            08/18/2006             09/01/2006          09/01/2006 OFFICE          LA:PGCB                 PGCB                  BC:PGCB              D:DPR

NAME            CHawes*               JRobinson              CPJackson        TQuay for MCase

DATE           09/13/2006             11 /272006               12 /15/2006       12/21/2006

IN 2006-30
                                                                                         Enclosure

TABLES FOR FITNESS-FOR-DUTY (FFD) 2004-2005 Table 1A

2004 Test Results for Each Test category

TEST CATEGORY         NUMBER OF TESTS            POSITIVE TESTS       PERCENT POSITIVES

Pre-Access                            76,119                  737                         0.97%
  Random                                51,239                  127                         0.25%
  For-Cause                               1,159                 139                        11.99%
  Follow-Up                               3,752                   31                        0.83%
  Other                                   1,221                   41                        3.36%
  TOTAL*                               133,490                1,075                         0.81%
  TOTAL without

OTHER Category                       132,269                1,034                         0.78%
*These totals were calculated using Other test category. This category includes results from

the periodic testing done by some reporting units during annual physicals or similar periodic

activities. Although some reporting units specified the nature of the Other tests (e.g., return to

work), most reporting units did not give this information.

Table 1B

2005 Test Results for Each Test category

TEST CATEGORY         NUMBER OF TESTS            POSITIVE TESTS       PERCENT POSITIVES

Pre-Access                            79,005                  648                         0.82%
  Random                                50,286                  147                         0.29%
  For-Cause                               1,161                 106                         9.13%
  Follow-Up                               4,057                   31                        0.76%
  Other                                   1,193                   47                        3.94%
  TOTAL*                               135,702                  979                         0.72%
  TOTAL without

OTHER Category                       134,509                  932                         0.69%
*These totals were calculated using Other test category. This category includes results from

the periodic testing done by some reporting units during annual physicals or similar periodic

activities. Although some reporting units specified the nature of the Other tests (e.g., return to

work), most reporting units did not give this information.

IN 2006-30 Table 2A

2004 Test Results for Each Test Category and Work Category

(January through December 2004)
TEST CATEGORY         LICENSEE         LONG-TERM        SHORT-TERM        TOTAL

EMPLOYEES       CONTRACTORS       CONTRACTORS

Pre-Access

Number Tested                7,661              1,095           67,363        76,119 Number Positive                 35                  8              694            737 Percent Positive            0.46%              0.73%            1.03%          0.97%
Random

Number Tested              34,723               1,399           15,117        51,239 Number Positive                 51                  6               70            127 Percent Positive            0.15%              0.43%            0.46%          0.25%
For-Cause

Number Tested                  458                 46              655          1,159 Number Positive                 23                  1              115            139 Percent Positive            5.02%              2.17%           17.56%        11.99%
Follow-Up

Number Tested                2,058                 55            1,639          3,752 Number Positive                 14                  0               17             31 Percent Positive            0.68%              0.00%            1.04%          0.83%
Other

Number Tested                  630                117              474          1,221 Number Positive                  4                  0               37             41 Percent Positive            0.63%              0.00%            7.81%          3.36%
TOTAL

Number Tested              45,530               2,712           85,248       133,490
Number Positive                127                 15              933          1,075 Percent Positive            0.28%              0.55%            1.09%          0.81%

===TOTAL without===
OTHER Category

Number Tested              44,900               2,595           84,774       132,269 Number Positive                123                 15              896          1,034 Percent Positive            0.27%              0.58%            1.06%          0.78%

IN 2006-30 Table 2B

2005 Test Results for Each Test Category and Work Category

(January through December 2005)
TEST CATEGORY         LICENSEE         LONG-TERM        SHORT-TERM        TOTAL

EMPLOYEES       CONTRACTORS       CONTRACTORS

Pre-Access

Number Tested                8,210                767           70,028        79,005 Number Positive                 28                 12              608            648 Percent Positive            0.34%              1.56%            0.87%          0.82%
Random

Number Tested              33,587               1,533           15,166        50,286 Number Positive                 60                  5               82            147 Percent Positive            0.18%              0.33%            0.54%          0.29%
For-Cause

Number Tested                  509                 59              593          1,161 Number Positive                 19                  2               85            106 Percent Positive            3.73%              3.39%           14.33%          9.13%
Follow-Up

Number Tested                2,099                 79            1,879          4,057 Number Positive                 15                  0               16             31 Percent Positive            0.71%              0.00%            0.85%          0.76%
Other

Number Tested                  548                 87              558          1,193 Number Positive                  2                  0               45             47 Percent Positive            0.36%              0.00%            8.06%          3.94%
TOTAL

Number Tested              44,953               2,525           88,224       135,702 Number Positive                124                 19              836            979 Percent Positive            0.28%              0.75%            0.95%          0.72%

===TOTAL without===
OTHER Category

Number Tested              44,405               2,438           87,666       134,509 Number Positive                122                 19              791            932 Percent Positive            0.27%              0.78%            0.90%          0.69%

IN 2006-30 Table 3A

2004 Test Results by Test Category

(January through December 2004)
TEST CATEGORY         FIRST                SECOND         YEAR

SIX MONTHS             SIX MONTHS

Pre-Access

Number Tested                38,390                37,729       76,119 Number Positive                 381                   356           737 Percent Positive             0.99%                 0.94%         0.97%
Random

Number Tested                25,465                25,774       51,239 Number Positive                  54                    73           127 Percent Positive             0.21%                 0.28%         0.25%
For-Cause

===Observed Behavior===
Number Tested                   344                   357           701 Number Positive                  68                    66           134 Percent Positive            19.77%                18.49%       19.12%
Post-Accident

Number Tested                   211                   247           458 Number Positive                   2                     3             5 Percent Positive             0.95%                 1.21%         1.09%
Follow-Up

Number Tested                 1,825                 1,927         3,752 Number Positive                  18                    13            31 Percent Positive             0.99%                 0.67%         0.83%
Other

Number Tested                   681                   540         1,221 Number Positive                  18                    23            41 Percent Positive             2.64%                 4.26%         3.36%
TOTAL

Number Tested                66,916                66,574      133,490
Number Positive                 541                   534         1,075 Percent Positive             0.81%                 0.80%         0.81%

===TOTAL without===
OTHER Category

Number Tested                66,235                66,034      132,269 Number Positive                 523                   511         1,034 Percent Positive             0.79%                 0.77%         0.78%

IN 2006-30 Table 3B

2005 Test Results Test Category

(January through December 2005)
TEST CATEGORY       FIRST                  SECOND         YEAR

SIX MONTHS              SIX MONTHS

Pre-Access

Number Tested               45,885                  33,120        79,005 Number Positive                 373                    275           648 Percent Positive             0.81%                  0.83%         0.82%
Random

Number Tested               28,866                  23,420        50,286 Number Positive                  70                     77           147 Percent Positive             0.26%                  0.33%         0.29%
For-Cause

===Observed Behavior===
Number Tested                   352                    319           671 Number Positive                  68                     37           105 Percent Positive           19.32%                  11.60%        15.65%
Post-Accident

Number Tested                   233                    257           490
Number Positive                   0                      1             1 Percent Positive             0.00%                  0.39%         0.20%
Follow-Up

Number Tested                 2,114                  1,943         4,057 Number Positive                  15                     16            31 Percent Positive             0.71%                  0.82%         0.76%
Other

Number Tested                   545                    648         1,193 Number Positive                  20                     27            47 Percent Positive             3.67%                  4.17%         3.94%
TOTAL

Number Tested               49,129                  36,287        85,416 Number Positive                 476                    356           832 Percent Positive             0.97%                  0.98%         0.97%

===TOTAL without===
OTHER Category

Number Tested               75,450                  59,059       134,509 Number Positive                 526                    406           932 Percent Positive             0.70%                  0.69%         0.69%

IN 2006-30 Table 4A

2004 Test Results for Licensee Employees and Contractor Personnel

(January through December 2004)
                        Licensee Employees               Long-Term Contractors          Short-Term Contractors

TEST CATEGORY     First Six  Second Six     Year     First Six Second Six   Year    First Six  Second Six     Year

Months       Months                 Months     Months             Months      Months

Pre-Access

Number Tested         4,183         3,478    7,661         476         619   1,095    33,731       33,632    67,363 Number Positive          22            13       35           2           6       8        357         337        694 Percent Positive     0.53%         0.37%    0.46%       0.42%       0.97%   0.73%      1.06%       1.00%      1.03%
Random

Number Tested       17,613        17,110    34,723         594         805   1,399      7,258       7,859    15,117 Number Positive          24            27       51           1           5       6         29          41         70
Percent Positive     0.14%         0.16%    0.15%       0.17%       0.62%   0.43%      0.40%       0.52%      0.46%
For-Cause

===Observed Behavior===
Number Tested           139           127      266           7          11      18        198         219        417 Number Positive          13            10       23           0           0       0         55          56        111 Percent Positive     9.35%         7.87%    8.65%       0.00%       0.00%   0.00%    27.78%       25.57%    26.62%
Post-Accident                                                                                                    238 Number Tested           108            84      192           8          20      28         95         143          4 Number Positive           0             0        0           1           0       1          1           3     1.68%
Percent Positive     0.00%         0.00%    0.00%      12.50%       0.00%   3.57%      1.05%       2.10%

IN 2006-30 Table 4A

2004 Test Results for Licensee Employees and Contractor Personnel Continued

(January through December 2004)
                        Licensee Employees                 Long-Term Contractors              Short-Term Contractors

TEST CATEGORY   First Six   Second Six     Year     First Six   Second Six     Year    First Six    Second Six      Year

Months       Months                Months        Months               Months        Months

Follow-Up

Number Tested          986         1,072     2,058          22            33         55       817            822      1,639 Number Positive           8            6        14            0            0          0        10              7         17 Percent Positive    0.81%         0.56%     0.68%       0.00%         0.00%     0.00%      1.22%          0.85%      1.04%
Other

Number Tested          331           299       630          76            41        117       274            200        474 Number Positive           4            0         4            0            0          0        14             23         37 Percent Positive    1.21%         0.00%     0.63%       0.00%         0.00%     0.00%      5.11%         11.50%      7.81%
TOTAL

Number Tested       23,360        22,170   45,530        1,183         1,529      2,712    42,373         42,875     85,248 Number Positive         71            56       127            4           11         15       466            467        933 Percent Positive    0.30%         0.25%     0.28%       0.34%         0.72%      0.55%     1.10%          1.09%      1.09%
TOTAL w/o OTHER

Category

Number Tested       23,029        21,871   44,900        1,107         1,488      2,595    42,099         42,675     84,774 Number Positive         67            56       123            4           11         15       452            444        896 Percent Positive    0.29%         0.26%     0.27%       0.36%         0.74%      0.58%     1.07%          1.04%      1.06%

IN 2006-30 Table 4B

2005 Test Results for Licensee Employees and Contractor Personnel

(January through December 2005)
                          Licensee Employees                 Long-Term Contractors              Short-Term Contractors

TEST CATEGORY    First Six    Second Six    Year      First Six   Second Six     Year    First Six   Second Six      Year

Months        Months                 Months       Months                Months        Months

Pre-Access

Number Tested         4,827          3,383     8,210         404           363        767    40,654        29,374      70,028 Number Positive          19              9        28            5            7         12       349            259        608 Percent Positive     0.39%          0.27%     0.34%       1.24%         1.93%      1.56%     0.86%          0.88%      0.87%
Random

Number Tested        17,897         15,690   33,587          753           780      1,533     8,216          6,950     15,166 Number Positive          30             30        60            2            3          3        38             44         82 Percent Positive     0.17%          0.19%     0.18%       0.27%         0.38%      0.33%     0.46%          0.63%      0.54%
For-Cause

===Observed Behavior===
Number Tested           155            154       309            8            8         16       189            157        346 Number Positive          11              8        19            0            2          2        57             27         84 Percent Positive     7.10%          5.19%     6.15%       0.00%        25.00%    12.50%     30.16%        17.20%      24.28%
Post-Accident

Number Tested           106             94       200          20            23         43       107            140        247 Number Positive            0             0         0            0            0          0          0             1          1 Percent Positive     0.00%          0.00%     0.00%       0.00%         0.00%      0.00%     0.00%          0.71%      0.40%
Follow-Up

Number Tested         1,054          1,045     2,099          39            40         79     1,021            858      1,879 Number Positive            6             9        15            0            0          0          9             7         16 Percent Positive     0.57%          0.86%     0.71%       0.00%         0.00%      0.00%     0.88%          0.82%      0.85%

IN 2006-30 Table 4B

2005 Test Results for Licensee Employees and Contractor Personnel Continued

(January through December 2005)
                       Licensee Employees                Long-Term Contractors          Short-Term Contractors

TEST CATEGORY   First Six  Second Six     Year     First Six  Second Six    Year    First   Second Six      Year

Months       Months                 Months     Months                Six      Months

Months

Other

Number Tested          281          267       548          36          51        87     228          330         558 Number Positive           1           1         2           0           0         0       19          26          45 Percent Positive    0.36%        0.37%     0.36%       0.00%       0.00%     0.00%   8.33%        7.88%       8.06%
TOTAL

Number Tested       24,320       20,633    44,953       1,260       1,265     2,525  50,415       37,809     88,224 Number Positive         67           57       124           7          12        19     472          364         836 Percent Positive    0.28%        0.28%     0.28%       0.56%       0.95%     0.75%   0.94%        0.96%       0.95%
TOTAL w/o OTHER

Category

Number Tested       24,039       20,366    44,405       1,224       1,214     2,438  50,187       37,479     87,666 Number Positive         66           56       122           7          12        19     453          338         791 Percent Positive    0.27%        0.27%     0.27%       0.57%       0.99%     0.78%   0.90%        0.90%       0.90%

IN 2006-30 Table 5A

2004 Number of Confirmed Positives by Substance

(January through December 2004)
               FIRST SIX MONTHS            SECOND SIX              TOTAL

MONTHS

TYPE OF        Number      Percent     Number     Percent    Number     Percent

SUBSTANCE

Marijuana        275      50.74%          239     46.32%        514     48.58%
   Cocaine         115       21.22%         132     25.58%        247     23.35%
   Opiates           8        1.48%           6      1.16%         14       1.32%
Amphetamines        34        6.27%          26      5.04%         60       5.67%
Phencyclidine       1        0.18%           0      0.00%          1       0.09%
   Alcohol         109       20.11%         113     21.90%        222     20.98%
   TOTAL           542                      516                 1,058 Table 5B

2005 Number of Confirmed Positives by Substance

(January through December 2005)
               FIRST SIX MONTHS            SECOND SIX              TOTAL

MONTHS

TYPE OF        Number      Percent     Number     Percent    Number     Percent

SUBSTANCE

Marijuana        240      44.86%          192     46.15%        432     45.43%
   Cocaine         140       26.17%         106     25.48%        246     25.87%
   Opiates           7        1.31%           9      2.16%         16       1.68%
Amphetamines        40        7.48%          19     40.57%         59       6.20%
Phencyclidine       1        0.19%           1      0.24%          2       0.21%
   Alcohol         107       20.00%          89     21.39%        196     20.61%
   TOTAL           535                      416                   951

IN 2006-30 Table 6A

2004 Confirmed Positive Test Results by Substance and Work Category

(January through December 2004)
                             LICENSEE EMPLOYEES                                 CONTRACTORS

(Long-Term/Short-Term)
TYPE OF SUBSTANCE       Number                   Percent                Number                 Percent

Marijuana                           43                   33.82%                    471                 50.81%
Cocaine                             23                   17.56%                    224                 24.16%
Opiates                              3                    2.29%                     11                   1.19%
Amphetamines                         5                    3.82%                     55                   5.93%
Phencyclidine                        0                    0.00%                      1                   0.11%
Alcohol                             57                   43.51%                    165                 17.80%
TOTAL                              131                                             927

IN 2006-30 Table 6B

2005 Confirmed Positive Test Results by Substance and Work Category

(January through December 2005)
                            LICENSEE EMPLOYEES                                  CONTRACTORS

(Long-Term/Short-Term)
TYPE OF SUBSTANCE       Number                   Percent                Number                  Percent

Marijuana                          35                    29.66%                    397                  47.66%
Cocaine                            22                    18.64%                    224                  26.89%
Opiates                              3                    2.54%                      13                  1.56%
Amphetamines                         6                    5.08%                      53                  6.36%
Phencyclidine                        0                    0.00%                       2                  0.24%
Alcohol                            52                    44.07%                    144                  17.29%
TOTAL                             118                                              833

IN 2006-30 Table 7 Significant Fitness-for-Duty Events (1990-1999)
Type of Event         1990    1991    1992    1993   1994    1995   1996    1997  1998  1999  Total

Reactor Operators        19      16      18       8       7      8      8       9     5     5  103 Licensee Supervisors     26      18      22      25      11     16     19      16    10     2  165 Contract Supervisors     12      24      28      16     11      10      8      10    10    12  141 FFD Program Personnel     1       5       0       0       1      0      2       0     3     2   14 Substances Found          6       8       6       2       0      5      5       4     0     2   38 Adulterated Specimen                                                                              0
Total                    64      71      74      51     30      39     42      39    28    23  461 Significant Fitness-for-Duty Events (2000-2005) Continued

Type of Event                                        2000    2001   2002    2003  2004  2005  Total

Reactor Operators                                         5      4      3       6     9     5   32 Licensee Supervisors                                     11      9      3       3     7    13   46 Contract Supervisors                                      8     12     12       8     4    14   58 FFD Program Personnel                                     0      0      3       0     0     1     4 Substances Found                                          3      0      1       2     9     9   24 Adulterated Specimen                                                            9    23    29   61 Total                                                   27      25     22      28    52    71  225

IN 2006-30 Table 8 Trends in testing by test type (1990-1999)
Type of Test      1990      1991      1992      1993      1994       1995      1996    1997    1998    1999      Total

Pre-Access

Number Tested    122,491 104,508   104,842    91,471    80,217     79,305    81,041  84,320  69,146  69,139   888,480
Number Positive    1,548     983      1,110      952       977      1,122     1,132   1,096     822     934     10,676 Percent Positive  1.26%   0.94%      1.06%    1.04%     1.22%      1.41%     1.40%   1.30%   1.19%   1.35%      1.20%
Random

Number Tested    148,743 153,818   156,730   146,605    78,391     66,791    62,307  60,829  56,969  54,457   985,640
Number Positive      550     510        461      341       223        180       202     172     157     140      2,936 Percent Positive  0.37%   0.33%      0.29%    0.23%     0.28%      0.27%     0.32%   0.28%   0.28%   0.26%      0.30%
For-Cause

Number Tested        732     727        696      751       758        763       848     722     720     736      7,453 Number Positive      214     167        178      163       122        139       138     149     100     120      1,490
Percent Positive 29.23%  22.97%     25.27%   21.70%    16.09%     18.22%    16.27%  20.64%  13.89%  16.30%     20.00%

IN 2006-30 Table 8 Trends in testing by test type (1990-1999) Continued

Type of Test        1990           1991      1992      1993      1994      1995     1996    1997    1998    1999      Total

Follow-up

Number Tested         2,633       3,544     4,283     4,139     3,875     3,262    3,262   3,296   2,863   3,008     34,165 Number Positive          65          62        69        56        50        35       40      31      43      30        481 Percent Positive     2.47%      1.75%      1.61%     1.35%     1.29%     1.07%    1.23%   0.94%   1.50%   1.00%      1.41%
  TOTAL*
  Number Tested      274,599     262,597    266,551  242,966    163,241  150,121  147,458  149,167 129,698 127,340  1,913,738 Number Positive       2,377       1,722     1,818     1,512     1,372     1,476    1,512   1,448   1,122   1,224     15,583 Percent Positive     0.87%       0.66%     0.68%     0.62%     0.84%     0.98%    1.03%   0.97%   0.87%   0.96%      0.81%
* Does not include test results from the Other test category.

IN 2006-30 Table 8 Trends in testing by test type (2000-2005) Continued

Type of Test        2000       2001      2002       2003       2004    2005     Total

Pre-Access

Number Tested      68,333     63,744    73,155     72,988    76,119   79,005  433,344 Number Positive       965        720       805        757        737     648    4,632 Percent Positive   1.41%      1.13%     1.10%      1.04%      0.97%   0.82%    1.07%
  Random

Number Tested      51,955     50,080    49,741     49,402    51,239   50,286  302,703 Number Positive       204        148       114        132        127     147       871 Percent Positive   0.39%      0.30%     0.23%      0.27%      0.25%   0.29%    0.29%
  For-Cause

Number Tested         883        730     1,072      1,052      1,159   1,161    6,053 Number Positive       138        101       112        126        139     106       721 Percent Positive  15.67%     13.84%    10.45%     11.98%    11.99%    9.13%   11.91%
  Follow-up

Number Tested       2,861      2,649     2,892      3,142      3,752   4,057   19,314 Number Positive        49         35        21         42         31      31       209 Percent Positive   1.71%      1.32%     0.73%      1.34%      0.83%   0.76%    1.08%
  TOTAL*
  Number Tested    124,032    118,730    128,321   127,785   132,269   134,509  764,701 Number              1,356      1,036     1,091      1,094      1,034     932    6,538 Positive

Percent            1.09%      0.87%     0.85%      0.86%      0.78%   0.69%    0.85%
  Positive

* Does not include test results from the Other test category.

IN 2006-30 Table 9 Trends in Substances Identified (1990-1999)
  Substance        1990    1991     1992   1993      1994     1995   1996    1997    1998     1999 Marijuana        1,153     746      953     781      739      819    868     842     606      672 Cocaine            706     549      470     369      344      374    352     336     269      273 Alcohol            452     401      427     357      251      265    281     262     212      230
  Amphetamines        69      31       31      51       54       61      53     49      46       40
  Opiates             45      24        8      13       11       17      14     39      19       16 Phencyclidine        8      11        4       5        1        7       2      0       1        2 Total*           2,433   1,762    1,893   1,576    1,400    1,543  1,570   1,528   1,153    1,233
* These totals do not equal the total number of positives for each year because some positives

were for multiple substances and for other substances than those listed above.

Table 9 Trends in Substances Identified (2000-2005) Continued

Substance                                         2000      2001   2002    2003    2004    2005 Marijuana                                            620     523     560    518      514     432 Cocaine                                              251     225     228    228      247     246 Alcohol                                              211     212     214    199      222     196 Amphetamines                                          50       50     47      64      60       59 Opiates                                               32       17     21      17      14       16 Phencyclidine                                          1        2       3      0       1        2 Total*                                            1,168 1,029 1,069 1,026 1,056              951
* These totals do not equal the total number of positives for each year because some positives

were for multiple substances and for other substances than those listed above.

IN 2006-30 Table 10
Trends in Positive Test Rates For Workers With Unescorted Access (1990-2005)*
                      Year                          Positive Test Rate

1990                                0.54%
                      1991                                0.47%
                      1992                                0.44%
                      1993                                0.37%
                      1994                                0.48%
                      1995                                0.50%
                      1996                                0.57%
                      1997                                0.54%
                      1998                                0.50%
                      1999                                0.50%
                      2000                                0.70%
                      2001                                0.53%
                      2002                                0.46%
                      2003                                0.56%
                      2004                                0.51%
                      2005                                0.49%

* Includes random, for-cause, testing results. The reduction in random

test rate from 100% to 50% has been in effect since 1994.}}

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