ML20100L469: Difference between revisions

From kanterella
Jump to navigation Jump to search
VisualWikitext
StriderTol Bot insert
 
StriderTol Bot change
 
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:. . . . - -  -            .. . - .        .-    ._ . . . .
{{#Wiki_filter:....
Ctation support Department 10CFR26.71(d) eccoco<9xce-aer PECO ENERGY                                                          Nuclear Group Headquarters                 .
Ctation support Department 10CFR26.71(d)
965 chesterbrook Boulevard                 l Wayne, PA 19087 5691                     -!
PECO ENERGY c
February 27,1996               .;
eccoco<9x e-aer Nuclear Group Headquarters 965 chesterbrook Boulevard l
r Docket Nos. 50-277 50-278             !
Wayne, PA 19087 5691 February 27,1996 r
50-352 50-353           .
Docket Nos. 50-277 50-278 50-352 50-353 t
t License Nos. DPR-44                 !
License Nos. DPR-44 DPR-56 NPF-39 NPF 85 ~
DPR-56 NPF-39 NPF 85 ~           ;
i U.S. Nuclear Regulatory Commission
i U.S. Nuclear Regulatory Commission
                ' Attn: Document Control Desk .
' Attn: Document Control Desk.
* Washington, DC 20555                                                                                               ,
Washington, DC 20555


==SUBJECT:==
==SUBJECT:==
Peach Bottom Atomic Power Station, Units 2 and 3 Umorick Generating Station, Units 1 and 2                                                         '
Peach Bottom Atomic Power Station, Units 2 and 3 Umorick Generating Station, Units 1 and 2 Fitness-for-Duty Program Performance Data for the Period July 1995 through December 1995 i
Fitness-for-Duty Program Performance Data for the Period July 1995 through December 1995                                                       i Gentlemen:
Gentlemen:
              ' As required by 10CFR26.71(d), this letter submits the performance data for our Fitness-for-Duty (FFD) program for the period July 1995 through December 1995. The data for our Peach Bottom                       ;
' As required by 10CFR26.71(d), this letter submits the performance data for our Fitness-for-Duty (FFD) program for the period July 1995 through December 1995. The data for our Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and Umerick Generating Station (LGS), Units 1 and 2, sites are provided in Attachments 1 and 2. Data for our Corporate Office and PECO Nuclear Headquarters specimen collection sites (i.e., 2301 Market Street, Philadelphia, PA, and 955-65 Chesterbrook Boulevard, Wayne, PA, respectively) are provided in Attachment 3.
Atomic Power Station (PBAPS), Units 2 and 3, and Umerick Generating Station (LGS), Units 1                         ,
The data are reported on the January 1992 revision of the FFD Performance Data form provided by the Nuclear Energy Institute (NEI), formerly the Nuclear Management and Resources Council (NUMARC), and include the following
and 2, sites are provided in Attachments 1 and 2. Data for our Corporate Office and PECO Nuclear Headquarters specimen collection sites (i.e., 2301 Market Street, Philadelphia, PA, and 955-65 Chesterbrook Boulevard, Wayne, PA, respectively) are provided in Attachment 3.
)
The data are reported on the January 1992 revision of the FFD Performance Data form provided by the Nuclear Energy Institute (NEI), formerly the Nuclear Management and Resources Council                           l (NUMARC), and include the following
Drugs tested for and cut-off levels.
                                                                                                                                    )
Workforce population tested.
                            -    Drugs tested for and cut-off levels.
?
?                          -    Workforce population tested.
Numbers of tests and results by population and type of test (i.e, pre-access, for.
                            -    Numbers of tests and results by population and type of test (i.e, pre-access, for.
.cause, random, follow-up, and other types of tests).'
4
4 Substances identified.
                                .cause, random, follow-up, and other types of tests).'
040050; 99 y
Substances identified.
..9603040240 960227
040050; 99
'I PDR ADOCK - 05000277l '
                        ..                                                                                  y
R-PDRn
        ..9603040240 960227                                                                                 '
                                                                                                                'I PDR       ADOCK - 05000277l '
R-                       PDRn


fl. '   February 27,1996
fl. '
  . 'M     ' Paget Attachmerts 1, 2, and 3 also include the following
February 27,1996
                      -        A summary of management actions.
'M
                      -        Analysis of the data and appropriate actions that have been taken.
' Paget Attachmerts 1, 2, and 3 also include the following A summary of management actions.
                      -        Random testing rate.
Analysis of the data and appropriate actions that have been taken.
1 During this period, there were.DQ si0 nificant events reported to the NRC in accordance with '
Random testing rate.
During this period, there were.DQ si nificant events reported to the NRC in accordance with 0
10CFR26.73.
10CFR26.73.
If you have any questions or require additional information, please contact us.
If you have any questions or require additional information, please contact us.
Very truly yours, Aa.Iher.f.
Very truly yours, Aa.Iher.f.
G. A. Hunger, Jr.                                                                            .
G. A. Hunger, Jr.
Director - Licensing Attachments I
Director - Licensing Attachments cc:
cc:     T. T. Martin, Administrator, Region I, USNRC (w/ attachments)                         '
T. T. Martin, Administrator, Region I, USNRC (w/ attachments)
W. L Schmidt, USNRC Senior Resident inspector, PBAPS (w/ attachments)
W. L Schmidt, USNRC Senior Resident inspector, PBAPS (w/ attachments)
N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments) l l
N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments) l l
1 l
1
l l


_ _ .              _ _ . - . . - - . _ .          . . .~ _ ,. _ __ _ . _                  .. _ _ . _ . _ . . .- . _ _ _ _ _ . _
...~ _,. _ __ _. _
s ..
s s
s i
i
: i. .                                                                                                                                           ;
: i..
c s                                                                                                                                            .i; i
c
i                                                                                                                                               ;
.i s
i i
l' f
l' f
i
i
+                                                                                                                                               ?
+
i                                                                                                                                               !
?
I 4
i I
:                                                                                        ATTACHMENT 1 Peach Bottom Atomic Power Station
4 ATTACHMENT 1 Peach Bottom Atomic Power Station Units 2 and 3 Fitness-for-Duty Performance Data i
:-                                                                                        Units 2 and 3 Fitness-for-Duty Performance Data i
July 1995 through December 1995 t
July 1995 through December 1995 t
d e
d e
4 i
4 i
+
+
1 i-i ..
1 i-i..
9 l~
9 l~
o 4
o 4
Line 88: Line 84:
4 4
4 4


Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 PECO ENERGY COMPANY                                                               DECEMBER 31,1995 Comoany 8 Mones Endog PEACH BGTTOM ATOMIC POWER STATION Locanon David M. Sarley                                                 (215) 841-5703 Conuc: Name Phone Onc!wde ares code)
Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 PECO ENERGY COMPANY DECEMBER 31,1995 Comoany 8 Mones Endog PEACH BGTTOM ATOMIC POWER STATION Locanon David M. Sarley (215) 841-5703 Conuc: Name Phone Onc!wde ares code)
Cutoff s: Scre en/ Confirmation (ng/ml)     O Appendix A to 10CFR 26 Marijuana               50 / 15           Amphetamines         1000 / 500                                         /
Cutoff s: Scre en/ Confirmation (ng/ml)
Cocaine           300 / 150               Phencyclidine         '25 / 25                                         /
O Appendix A to 10CFR 26 Marijuana 50 / 15 Amphetamines 1000 / 500
Opiates           300 / 300                                     0.04 Alcohol (% BAC)                                                           /       ;
/
                                                                                                      ~
Cocaine 300 / 150 Phencyclidine
Long-Term                   Short-Term         l Testing Results                             1.lcensee Employees       Contractor Personnel         Contractor Personnel Average Number with Unescorted Access                                 2360                                                     1567
'25 / 25
                                                        #            8          #            #              5 Categories                                                                                                             #
/
Tested     Positive       Tested     Positive       Tested         Positive Pre-Access                                     48           0                                     1301               24 k     Post accident                           11           0                                           2               0 9
Opiates 300 / 300 Alcohol (% BAC) 0.04
      $      Observed behavior                       3           1 5               5 Random 254           0     -
/
202                     I 0
Long-Term
Follow-up                                     25
~
,                                                                0                                        45                 0 Other                                         12           0                                           1               0 Total                                       353           1 1556               29   :
Short-Term Testing Results 1.lcensee Employees Contractor Personnel Contractor Personnel Average Number with Unescorted Access 2360 1567 8
REV.1/92
5 Categories Tested Positive Tested Positive Tested Positive Pre-Access 48 0
1301 24 k
Post accident 11 0
2 0
9 Observed behavior 3
1 5
5 Random 254 0
202 0
Follow-up 25 0
45 0
Other 12 0
1 0
Total 353 1
1556 29 REV.1/92


Attachment 1 Summary of Data Analysis and Management Actions Peach Bottom Atomic Power Station July - December 1995
Summary of Data Analysis and Management Actions Peach Bottom Atomic Power Station July - December 1995 1.
: 1. Initiatives Taken The following summarizes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about illicit activities at Peach Bottom Atomic Power Station (PBAPS) during the period.
Initiatives Taken The following summarizes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about illicit activities at Peach Bottom Atomic Power Station (PBAPS) during the period.
: a.       July 20,1995 - General team sweep outside operator's office area. Results: Six activations. Unidentified pills found in a plastic bag. Employee interviewed. Analysis indicated the pills were over-the-counter medication.
a.
: b.       July 27,1995 - For cause term sweep of a contractor's private vehicle. Results: Three activations. Canine responded to empty plastic bag found in vehicle; investigator discovered empty alcoholic beverage containers. Contractor admitted his friends had used manjuana in the vehicle and that he had also used manjuana in the past.
July 20,1995 - General team sweep outside operator's office area. Results: Six activations. Unidentified pills found in a plastic bag. Employee interviewed. Analysis indicated the pills were over-the-counter medication.
b.
July 27,1995 - For cause term sweep of a contractor's private vehicle. Results: Three activations. Canine responded to empty plastic bag found in vehicle; investigator discovered empty alcoholic beverage containers. Contractor admitted his friends had used manjuana in the vehicle and that he had also used manjuana in the past.
Contractor denied unescorted access.
Contractor denied unescorted access.
: c.       August 10,1995 - For cause search (no dog used) of a contractor's private vehicle based upon detectable breath alcohol. Search revealed no alcoholic beverage containers. In a subsequent interview, the contractor admitted to excessive alcohol consumption, as well as two previous DUI arrests. This information was provided to PECO Energy Occupational Health and Safety. Contractor denied unescorted access.
c.
: d.       August 17,1995 - For cause search of contractor's private vehicle. Results: Four activations. Discovered an unidentified pill inside an empty film canister. Contractor denied drug use, however, revealed his friends had smoked manjuana in the vehicle.
August 10,1995 - For cause search (no dog used) of a contractor's private vehicle based upon detectable breath alcohol. Search revealed no alcoholic beverage containers. In a subsequent interview, the contractor admitted to excessive alcohol consumption, as well as two previous DUI arrests. This information was provided to PECO Energy Occupational Health and Safety. Contractor denied unescorted access.
d.
August 17,1995 - For cause search of contractor's private vehicle. Results: Four activations. Discovered an unidentified pill inside an empty film canister. Contractor denied drug use, however, revealed his friends had smoked manjuana in the vehicle.
Contractor admitted to using presenption medication without a valid presenption.
Contractor admitted to using presenption medication without a valid presenption.
Analysis of the pill indicated an over-the-counter medication. Contractor denied unescorted access.
Analysis of the pill indicated an over-the-counter medication. Contractor denied unescorted access.
: e.       August 24,1995 - For cause team sweep of contractor's private vehicle. Results: Two activations. No drugs found or forensic samples taken. Contractor disclosed previous termination (1989) from oil refinery due to positive alcohol test. This information was provided to PECO Energy Occupational Health and Safety. Contractor granted access and placed on accelerated testing.
e.
: f.       August 31,1995 - General team sweep of Maintenance Tool Room, North Issue Counter and Receiving Area. Results: No activations.
August 24,1995 - For cause team sweep of contractor's private vehicle. Results: Two activations. No drugs found or forensic samples taken. Contractor disclosed previous termination (1989) from oil refinery due to positive alcohol test. This information was provided to PECO Energy Occupational Health and Safety. Contractor granted access and placed on accelerated testing.
: g.       August 31,1995 - For cause team sweep of contractor's pnvate vehicle. Results:
f.
Three activations. No drugs found or forensic samples taken. Contractor admitted past drug use and recent association with drug users. Contractor denied unescorted access.                                .
August 31,1995 - General team sweep of Maintenance Tool Room, North Issue Counter and Receiving Area. Results: No activations.
: h.       September 7,1995 - For cause team sweep of contractor's private vehicle. Results:
g.
August 31,1995 - For cause team sweep of contractor's pnvate vehicle. Results:
Three activations. No drugs found or forensic samples taken. Contractor admitted past drug use and recent association with drug users. Contractor denied unescorted access.
h.
September 7,1995 - For cause team sweep of contractor's private vehicle. Results:
Two activations. No drugs found or forensic samples taken. Contractor admitted cocaine use within past year. Contractor denied unescorted access.
Two activations. No drugs found or forensic samples taken. Contractor admitted cocaine use within past year. Contractor denied unescorted access.


                          .      .      . , .                      .~                                   -.
.~
: i. September 7,1995 - For cause team sweep of a contractors private vehicle. Results:
i.
Two activations. No drugs found or forensic samples taken. Contractor admitted             i cocaine and manjuana use within the past month. Contractor denied unescorted access.
September 7,1995 - For cause team sweep of a contractors private vehicle. Results:
: j. September 8.1995 - For cause team sweep (no dog used) of employee's private vehicle based upon a previous positive alcohol test. No alcoholic beverage containers found. Medical restriction removed and unescorted access reinstated,
Two activations. No drugs found or forensic samples taken. Contractor admitted i
: k. September 12.1995 - For cause team sweep of a contractor's private vehicle based following a positive alcohol test. Results: Two activations. No alcoholic beverage containers found, however, suspected drug paraphernalia found in vehicle. Vehicle was owned by another individual seeking unescorted access. Contractor denied access based upon positive alcohol test.
cocaine and manjuana use within the past month. Contractor denied unescorted access.
: l. September 12,1995 - For cause team sweep of a contractor's private vehicle. Results:
j.
Two activations. Suspected drug paraphemalia discovered in vehicle. Contractor denied drug use however, admitted his friends had smoked marijuana in the vehicle this past spnng. Manager, FFD, advised and requested to perform additional testing based upon the discovery. HHS certified laboratory reported detectable levels of         i manjuana. Contractor denied unescorted access.
September 8.1995 - For cause team sweep (no dog used) of employee's private vehicle based upon a previous positive alcohol test. No alcoholic beverage containers found. Medical restriction removed and unescorted access reinstated, k.
: m. September 13,1995 - For cause team sweep (no dog used) of a contractors private vehicle following a positive alcohol test. Search was negative for any alcoholic l
September 12.1995 - For cause team sweep of a contractor's private vehicle based following a positive alcohol test. Results: Two activations. No alcoholic beverage containers found, however, suspected drug paraphernalia found in vehicle. Vehicle was owned by another individual seeking unescorted access. Contractor denied access based upon positive alcohol test.
                  'everages or containers. Contractor admitted excessive alcohol consumption prior to reporting to work. Contractor denied unescorted access.
l.
1
September 12,1995 - For cause team sweep of a contractor's private vehicle. Results:
: n. September 13,1995 - For cause team sweep of a contractors friends vehicle. Results:       l No activations. Contractor admitted to borrowing the vehicle due to known use of           i narcotic canines by PECO Energy. Contractor admitted recent drug use including manjuana, cocaine. methamphetamine and '' magic mushrooms" (hallucinogens).
Two activations. Suspected drug paraphemalia discovered in vehicle. Contractor denied drug use however, admitted his friends had smoked marijuana in the vehicle this past spnng. Manager, FFD, advised and requested to perform additional testing based upon the discovery. HHS certified laboratory reported detectable levels of i
manjuana. Contractor denied unescorted access.
September 13,1995 - For cause team sweep (no dog used) of a contractors private m.
vehicle following a positive alcohol test. Search was negative for any alcoholic
'everages or containers. Contractor admitted excessive alcohol consumption prior to reporting to work. Contractor denied unescorted access.
1 n.
September 13,1995 - For cause team sweep of a contractors friends vehicle. Results:
No activations. Contractor admitted to borrowing the vehicle due to known use of i
narcotic canines by PECO Energy. Contractor admitted recent drug use including manjuana, cocaine. methamphetamine and '' magic mushrooms" (hallucinogens).
Contractor denied unescorted access.
Contractor denied unescorted access.
: o. September 18.1995 - For cause team sweep of a contractors pnvate vehicle based upon alcohol-related concerns. Results: No activations
o.
: p. September 22,1995 - Management requested canine sweep of a contractor's tool trailer which was acquired from a non-nuclear site. Results: Multiple activations. No drugs found or forensic samples taken.
September 18.1995 - For cause team sweep of a contractors pnvate vehicle based upon alcohol-related concerns. Results: No activations p.
: q. October 22,1995 - General team sweep of the Low Level Radwaste Storage Facility.         I I
September 22,1995 - Management requested canine sweep of a contractor's tool trailer which was acquired from a non-nuclear site. Results: Multiple activations. No drugs found or forensic samples taken.
Results: One Activation. No drugs found or forensic samples taken.
q.
: r. November 19,1995 - Suspected drug paraphemalia discovered at the Training Building       ;
October 22,1995 - General team sweep of the Low Level Radwaste Storage Facility.
Annex parking lot. Results: One activation. Suspected paraphernalia was confiscated.
I Results: One Activation. No drugs found or forensic samples taken.
r.
November 19,1995 - Suspected drug paraphemalia discovered at the Training Building Annex parking lot. Results: One activation. Suspected paraphernalia was confiscated.
No employees or contractors implicated. The parking lot is also used by the general public for fishing.
No employees or contractors implicated. The parking lot is also used by the general public for fishing.
: s. November 21,1995 - General team sweep of Construction Trailers within the Protected Area and the owner controlled area. Results: Three activations. No drugs found or i
s.
November 21,1995 - General team sweep of Construction Trailers within the Protected Area and the owner controlled area. Results: Three activations. No drugs found or i
forensic samples taken.
forensic samples taken.
I
 
: t.       December 29,1995 - General team sweep of Receiving Building and two delivery trucks. Results: Two activations in the building. No drugs fnund or forensic samples taken.
t.
: 11. Manaaement Actions During the period, one PECO Energy employee tested positive at PBAPS based upon a For Cause test. The employee was denied unescorted access. The employee was provided treatment and rehabilitation through the PECO Energy Employee Assistance Program. The employee was subsequently discharged.
December 29,1995 - General team sweep of Receiving Building and two delivery trucks. Results: Two activations in the building. No drugs fnund or forensic samples taken.
11.
Manaaement Actions During the period, one PECO Energy employee tested positive at PBAPS based upon a For Cause test. The employee was denied unescorted access. The employee was provided treatment and rehabilitation through the PECO Energy Employee Assistance Program. The employee was subsequently discharged.
Dunng the penod, twenty-nine contractor employees (i.e., twenty-four pre-access and five for cause) tested positive at PBAPS. Unescorted access was denied for all twenty-nine contractor employees.
Dunng the penod, twenty-nine contractor employees (i.e., twenty-four pre-access and five for cause) tested positive at PBAPS. Unescorted access was denied for all twenty-nine contractor employees.
Ill. Events Reported Under 10 CFR 26 73 There were no significant FFD events reported by PBAPS during the penod.
Ill.
IV. Audits / Inspections The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the penod. The audit found that the FFD program is being effectively implemented, in accordance with 10 CFR Part 26. Strengths were identified in the following areas:
Events Reported Under 10 CFR 26 73 There were no significant FFD events reported by PBAPS during the penod.
IV.
Audits / Inspections The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the penod. The audit found that the FFD program is being effectively implemented, in accordance with 10 CFR Part 26. Strengths were identified in the following areas:
Strong performance of collection and on-site testing staff during high volume, pre-outage conditions.
Strong performance of collection and on-site testing staff during high volume, pre-outage conditions.
Medical Review Officer qualifications.
Medical Review Officer qualifications.
Effective management oversight of the testing process.
Effective management oversight of the testing process.
One Deviation-level Corrective Action Request was issued as a result of the Audit. The Deviation concerned an overdue background investigation and an overdue psychological evaluation for two sample collection personnel. The FFD rule requires that background checks and psychological evaluations be completed every three years for persons who administer the FFD program, including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.
One Deviation-level Corrective Action Request was issued as a result of the Audit. The Deviation concerned an overdue background investigation and an overdue psychological evaluation for two sample collection personnel. The FFD rule requires that background checks and psychological evaluations be completed every three years for persons who administer the FFD program, including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.
V. Random Testino Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random             ,
V.
testing is conducted at an annualized rate of 50%. The " average number with unescorted           I access" includes personnel granted unescorted access at both PBAPS and LGS.
Random Testino Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and LGS.
VI. Additional information On-site screenina error                         .
VI.
On Wednesday, September 20,1995, a specimen collected for pre access screening was tested and reported as " Negative" by the on-site testing facility. The specimen was included in the group of 10% negative quality control specimens forwarded to the HHS-certified for testing.
Additional information On-site screenina error On Wednesday, September 20,1995, a specimen collected for pre access screening was tested and reported as " Negative" by the on-site testing facility. The specimen was included in the group of 10% negative quality control specimens forwarded to the HHS-certified for testing.
1


i 1
i
                                                                                                                                                  )
)
Late on Friday, September 22,1995, the HHS-certified laboratory reported the specimen as
Late on Friday, September 22,1995, the HHS-certified laboratory reported the specimen as
        " positive for manjuana metabolites." The positive report was retrieved from the printer at approximately 8 am on Monday, September 25,1995, the discrepancy noted, and the Manager, FFD was notified.                                                                                                               !
" positive for manjuana metabolites." The positive report was retrieved from the printer at approximately 8 am on Monday, September 25,1995, the discrepancy noted, and the Manager, FFD was notified.
After determining that the individual had not been granted access, an investigation into the                                             l testing of the specimen was initiated. The HHS-certified laboratory was directed to rerun the specimen. All other specimens collected and screened at the on-site screening facility on the 20th were transported to the HHS-certified laboratory for screening. The results indicated no other discrepancies. An aliquot of the original sample was also sent back to the on-site facility for reanalysis. The results of the re-analysis by the on-site facility were positive for                                                 l cannabinoids.                                                                                                                             j l
After determining that the individual had not been granted access, an investigation into the testing of the specimen was initiated. The HHS-certified laboratory was directed to rerun the specimen. All other specimens collected and screened at the on-site screening facility on the 20th were transported to the HHS-certified laboratory for screening. The results indicated no other discrepancies. An aliquot of the original sample was also sent back to the on-site facility for reanalysis. The results of the re-analysis by the on-site facility were positive for cannabinoids.
Inspection of the specimen by personnel at the HHS-certified laboratory identified a large amount of sediment in the specimen container which had appeared to clump at the bottom.
j Inspection of the specimen by personnel at the HHS-certified laboratory identified a large amount of sediment in the specimen container which had appeared to clump at the bottom.
Microscopic evaluation of a sample of the sediment indicated " red / amber crystals consistent in morphology with uric acid."
Microscopic evaluation of a sample of the sediment indicated " red / amber crystals consistent in morphology with uric acid."
It is believed that during the initial on-site screening, a large amount of the sediment was injected into the analyzer probe causing the inaccurate readings.
It is believed that during the initial on-site screening, a large amount of the sediment was injected into the analyzer probe causing the inaccurate readings.
A review of the on-site screening records indicated all controls and calibrators were within the designated tolerances. The on-site Syva ETS report for the specimen in question, revealed values greater than 20% lower than the negative controls for all substances. An extensive study of results from the on-site facility showed that greater than 95% of all negative specimens have values within 10% of the negative control.
A review of the on-site screening records indicated all controls and calibrators were within the designated tolerances. The on-site Syva ETS report for the specimen in question, revealed values greater than 20% lower than the negative controls for all substances. An extensive study of results from the on-site facility showed that greater than 95% of all negative specimens have values within 10% of the negative control.
l As a result of these findings the procedures have been revised to direct that any specimen with values greater than 10% lower than the negative control for any of the five substances will centnfuged and re-analyzed. If the value for any of the five substances continues to be greater than 10% lower than the negative control, the specimen will be sent to the HHS-certified                                                 l laboratory for analysis.
As a result of these findings the procedures have been revised to direct that any specimen with values greater than 10% lower than the negative control for any of the five substances will centnfuged and re-analyzed. If the value for any of the five substances continues to be greater than 10% lower than the negative control, the specimen will be sent to the HHS-certified laboratory for analysis.
Actions Taken based upon Unconfirmed On-site Screenino PECO Energy has decided to temporanly suspend access for individuals as permitted by 10 CFR 26.24(d).
Actions Taken based upon Unconfirmed On-site Screenino PECO Energy has decided to temporanly suspend access for individuals as permitted by 10 CFR 26.24(d).
Dunng the previous 6-month reporting penod, (i e., January - July 1995),100 percent of the specimens which were determined to be presumptively positive for cocaine as a result of preliminary on-site screening tests were subsequently reported as positive by the HHS-certified laboratory. The confirmation rate for marijuana was less than the required 85 percent, therefore, no action was taken on specimens identified as presumptive positive for marijuana.
Dunng the previous 6-month reporting penod, (i e., January - July 1995),100 percent of the specimens which were determined to be presumptively positive for cocaine as a result of preliminary on-site screening tests were subsequently reported as positive by the HHS-certified laboratory. The confirmation rate for marijuana was less than the required 85 percent, therefore, no action was taken on specimens identified as presumptive positive for marijuana.
Line 170: Line 201:
The MRO venfied the fourteen specimens as. positive. Administrative actions were not taken until after the MRO determinations and only against the individuals with the confirmed positive tests.
The MRO venfied the fourteen specimens as. positive. Administrative actions were not taken until after the MRO determinations and only against the individuals with the confirmed positive tests.


    ..                                                                                                          t Reduced Marijuana Cut-off Level                                                               i Dunng the period, there were nineteen confirmed positive tests for marijuana at PBAPS. None of the specimens would have tested positive using the 100 ng/mi immunoassay cut-off level.
t Reduced Marijuana Cut-off Level i
(Some specimens are sent directly to the HHS-laboratory without on-site screening.)           j Contractor Information The following information regarding contractor positive tests is provided:
Dunng the period, there were nineteen confirmed positive tests for marijuana at PBAPS. None of the specimens would have tested positive using the 100 ng/mi immunoassay cut-off level.
Craft                   Vital / Protected Area Access           Lono/Short Term Laborer                           Vital Granted                           Short Turbine Tech                     ~ Vital Requested                       Short Boilermaker                       Vital Granted                           Short Laborer                           Vital Requested                         Short Pipefitter                       Vital Requested                         Short Pipefitter                       Vital Requested                         Short Laborer                           Vital Requested                         Short Laborer                           Vital Requested                         Short Laborer                           Vital Requested                         Short Custodial                         Protected Requested                     Short Specialty Vendor                 Vital Requested                         Short Pipefitter                       Vital Requested                         Short Laborer                           None Requested                         Short Pipefitter                       None Requested                         Short Specialty Vendor                 Vital Requested                         Short Asbestos Worker                   Vital Requested                         Short Laborer                           None Requested                         Short Laborer                           Vital Requested                         Short Laborer                           None Requested                         Short Laborer                           Vital Requested                         Short NDE/ISI inspector                 Vital Requested                         Short NDE/ISI Inspector                 Vital Requested                         Short Electncian                       Vital Requested                         Short Electncian                       Vital Requested                         Short Pipefitter                       Vital Requested                         Short Pipefitter                       None Requested                         Short Diver                             Protected Requested                     Short Diver                             None Requested                         Short Diver                             Protected Requested                     Short I
(Some specimens are sent directly to the HHS-laboratory without on-site screening.)
l
j Contractor Information The following information regarding contractor positive tests is provided:
Craft Vital / Protected Area Access Lono/Short Term Laborer Vital Granted Short Turbine Tech
~ Vital Requested Short Boilermaker Vital Granted Short Laborer Vital Requested Short Pipefitter Vital Requested Short Pipefitter Vital Requested Short Laborer Vital Requested Short Laborer Vital Requested Short Laborer Vital Requested Short Custodial Protected Requested Short Specialty Vendor Vital Requested Short Pipefitter Vital Requested Short Laborer None Requested Short Pipefitter None Requested Short Specialty Vendor Vital Requested Short Asbestos Worker Vital Requested Short Laborer None Requested Short Laborer Vital Requested Short Laborer None Requested Short Laborer Vital Requested Short NDE/ISI inspector Vital Requested Short NDE/ISI Inspector Vital Requested Short Electncian Vital Requested Short Electncian Vital Requested Short Pipefitter Vital Requested Short Pipefitter None Requested Short Diver Protected Requested Short Diver None Requested Short Diver Protected Requested Short


l s .
l s
I
I
                                                                        \
\\
I f
I f
ATTACHMENT 2 1
ATTACHMENT 2 1'
Umerick Generating Station Units 1 and 2 Fitness-for-Duty Performance Data July 1995 through December 1995 1
Umerick Generating Station Units 1 and 2 Fitness-for-Duty Performance Data July 1995 through December 1995 1
I l
I l
l l
l w.
I l
: w.                                                 -


Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 PECO ENERGY COMPANY                                                         DECEMBER 31, 1995 Company                                                       a Mont.s Ending i
Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 PECO ENERGY COMPANY DECEMBER 31, 1995 Company a Mont.s Ending i
LIMERICK GENERATING STATION Locanon David M. Sarley                                             (215) 841-5703 Conue Name Phone (include area exe)
LIMERICK GENERATING STATION Locanon David M. Sarley (215) 841-5703 Conue Name Phone (include area exe)
Cutoff s : Scre e rvConfirmatio n (ng/ml)   O Appendix A to 10CFR 26 Marijuana           50 / 15               Amphetamines     1000 /500                                               /
Cutoff s : Scre e rvConfirmatio n (ng/ml)
Cocaine           300 / 150               Phencyclidine       25 / 25                                             /
O Appendix A to 10CFR 26 Marijuana 50 / 15 Amphetamines 1000 /500
Opiates           300 / 300               Alcohol (% BAC)   0.04                                                   /
/
                                                                                                  ~
Cocaine 300 / 150 Phencyclidine 25 / 25
Long-Term                       Short-Term Testing Results                             Licensee Employees     Contractor Personnel         Contractor Personnel Average Number with 2360                                               1567 Unescorted Access A         #            #                $                #
/
Categories                                   Tested     Positive   Tested       Positive         Tested           Positive Pre-Access                                   60           1                                     359               10 k     Post accident                           16           0                                           9               0 9
Opiates 300 / 300 Alcohol (% BAC) 0.04
h    Observed behavior                         3         0                                           1               0 Random                                     240           1     -
/
157                 0 Follow up                                     48           0                                         17               0 Other 4         0                                         3               0 Total 371           2                                     546                 10
Long-Term
~
Short-Term Testing Results Licensee Employees Contractor Personnel Contractor Personnel Average Number with 2360 1567 Unescorted Access A
Categories Tested Positive Tested Positive Tested Positive Pre-Access 60 1
359 10 k
Post accident 16 0
9 0
9 h
Observed behavior 3
0 1
0 Random 240 1
157 0
Follow up 48 0
17 0
Other 4
0 3
0 Total 371 2
546 10


Attachment 2 Summary of Data Analysis and Management Actions                                         .
Summary of Data Analysis and Management Actions Limenck Generating Station j
Limenck Generating Station                                                 j July - December 1995
July - December 1995 l.
: l.       Initiatives Taken The following summanzes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about i! licit activities at Limenck Generating Station (LGS) dunng the period.
Initiatives Taken The following summanzes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about i! licit activities at Limenck Generating Station (LGS) dunng the period.
f
f a.
: a.       July 17-.1995 General team sweep of the Administration Building, second floorc                     '
July 17-.1995 General team sweep of the Administration Building, second floorc Results: Two activation. No drugs found or forensic samples taken.
Results: Two activation. No drugs found or forensic samples taken.
b.
: b.       August 30,1995 - Pennsylvania State Police (PSP) counter-drug operation discovered manjuana growing on Company owned right-of-way adjacent to LGS. Plants were confiscated by the PSP. No employees or contractors implicated. No arrests made.
August 30,1995 - Pennsylvania State Police (PSP) counter-drug operation discovered manjuana growing on Company owned right-of-way adjacent to LGS. Plants were confiscated by the PSP. No employees or contractors implicated. No arrests made.
: c.       September 8,1995 - General team sweep of the Sewage Treatment Facility. Results:
c.
September 8,1995 - General team sweep of the Sewage Treatment Facility. Results:
No activations.
No activations.
: d.       October 18,1995 - General team sweep of the Scaffold Shop. Results: No activations.
d.
e         November 7,1995 - General team sweep of the Technical Support Center, first floor.
October 18,1995 - General team sweep of the Scaffold Shop. Results: No activations.
Results: No activations.                                                                           l l
e November 7,1995 - General team sweep of the Technical Support Center, first floor.
: f.         December 13,1995 - For cause team sweep of an employee's private venicle following positive test. Results: Two activations Forensic samples taken. Laboratory analysis                 ;
Results: No activations.
proved negative. Employee was returning-to-duty following rehabilitation. Unescorted                 i access subsequently reinstated,
l l
: 11.       Manaaement Actions Dunng the penod. two employees (i e., one pre-access, one random) tested positive at LGS.
f.
Unescorted access was denied both employees. The employees were referred to the                                 l Employee Assistance Program for evaluation and treatment. Unescorted access was                                 l subsequently reinstated for the employee who tested positive on the random test The other                       I employee was transferred to a position which did not require unescorted access.
December 13,1995 - For cause team sweep of an employee's private venicle following positive test. Results: Two activations Forensic samples taken. Laboratory analysis proved negative. Employee was returning-to-duty following rehabilitation. Unescorted access subsequently reinstated, 11.
Manaaement Actions Dunng the penod. two employees (i e., one pre-access, one random) tested positive at LGS.
Unescorted access was denied both employees. The employees were referred to the Employee Assistance Program for evaluation and treatment. Unescorted access was subsequently reinstated for the employee who tested positive on the random test The other I
employee was transferred to a position which did not require unescorted access.
Dunng the penod, ten contractor employees tested positive on pre-access tests at LGS.
Dunng the penod, ten contractor employees tested positive on pre-access tests at LGS.
Unescorted access was denied for the ten contractor employees.
Unescorted access was denied for the ten contractor employees.
Ill.     Events Reported Under 10 CFR 26 73 During the penod there were no significant FFD events reported by telephone under 10 CFR 26.73 by LGS.
Ill.
IV       Audits / Inspections                           ,
Events Reported Under 10 CFR 26 73 During the penod there were no significant FFD events reported by telephone under 10 CFR 26.73 by LGS.
The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the                           l penod. The audit found that the FFD program is being effectively implemented, in accordance with 10 CFR Part 26. Strengths were identified in the following areas:
IV Audits / Inspections The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the penod. The audit found that the FFD program is being effectively implemented, in accordance with 10 CFR Part 26. Strengths were identified in the following areas:
I


l   .
l Strong performance of collection and on cite testing staff dunng high volume, pre-outage conditions.
Strong performance of collection and on cite testing staff dunng high volume, pre-outage conditions.
Medical Review Officer qualifications.
Medical Review Officer qualifications.
Effective management oversight of the testing process.
Effective management oversight of the testing process.
One Deviation-level Corrective Action Request was issued as a result of the Audit. The Deviation concerned an overdue background investigation and an overdue psychological evaluation for two sample collection personnel. The FFD rule requires that background checks and psychological evaluations be completed every three years for persons who administer the FFD program, including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.
One Deviation-level Corrective Action Request was issued as a result of the Audit. The Deviation concerned an overdue background investigation and an overdue psychological evaluation for two sample collection personnel. The FFD rule requires that background checks and psychological evaluations be completed every three years for persons who administer the FFD program, including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.
V. Random Testina Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and LGS.
V.
VI. Additional information Actions Taken based upon Unconfirmed On-site Screenina PECO Energy has decided to temporarily suspend access for individuals as perm;tted by 10 CFR 26.24(d).
Random Testina Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and LGS.
VI.
Additional information Actions Taken based upon Unconfirmed On-site Screenina PECO Energy has decided to temporarily suspend access for individuals as perm;tted by 10 CFR 26.24(d).
Dunng the previous 6-month reporting period, (i.e., January - July 1995),100 percent of the specimens which were determined to be presumptively positive for cocaine as a result of preliminary on-site screening tests were subsequently reported as positive by the HHS-certified laboratory The confirmation rate for manjuana was less than the required 85 percent, therefore, no action was taken on specimens identified as presumptive positive for manjuana.
Dunng the previous 6-month reporting period, (i.e., January - July 1995),100 percent of the specimens which were determined to be presumptively positive for cocaine as a result of preliminary on-site screening tests were subsequently reported as positive by the HHS-certified laboratory The confirmation rate for manjuana was less than the required 85 percent, therefore, no action was taken on specimens identified as presumptive positive for manjuana.
Dunng this reporting penod there were three specimens identified as presumptive positive for cocaine as a result of on-site screening. The three specimens were also screened positive and reported as confirmed positive by the HHS-certified laboratory. The MRO venfied the three specimens as positive following discussion with the individuals. The three specimens were collected as part of pre-access testing, therefore the temporary suspension of access was not applicable.
Dunng this reporting penod there were three specimens identified as presumptive positive for cocaine as a result of on-site screening. The three specimens were also screened positive and reported as confirmed positive by the HHS-certified laboratory. The MRO venfied the three specimens as positive following discussion with the individuals. The three specimens were collected as part of pre-access testing, therefore the temporary suspension of access was not applicable.
Dunng this reporting penod there were eleven specimens identified as presumptive positive for manjuana as a result of on-site screening. Eight of those specimens screened positive and were reported as confirmed positive by the HHS-certified laboratory. The MRO venfied the l             eight specimens as positive following discussion with the individuals. Administrative actions were not taken until after the MRO determinations and only against the individuals with the confirmed positive tests.                                                                       l Reduced Mantuana Cut-off Level                 .
Dunng this reporting penod there were eleven specimens identified as presumptive positive for manjuana as a result of on-site screening. Eight of those specimens screened positive and were reported as confirmed positive by the HHS-certified laboratory. The MRO venfied the l
Dunng the penod, there were eight confirmed positive tests for marijuana at LGS. Five of the     i specimens would not have tested positive using the 100 ng/mi immunoassay cut-off level.
eight specimens as positive following discussion with the individuals. Administrative actions were not taken until after the MRO determinations and only against the individuals with the confirmed positive tests.
                                                                                                                ]
l Reduced Mantuana Cut-off Level Dunng the penod, there were eight confirmed positive tests for marijuana at LGS. Five of the i
specimens would not have tested positive using the 100 ng/mi immunoassay cut-off level.
]
1
1


          -. . ~ - . - . . .             .     ~.    --.         .    .-      -. .   .     _ . . - - . . . .      ~ - . . . . . - . .
~ -...
l l-8         -
. ~ -. -...
~.
l l-8
(-
(-
,                            Contractor Information The following information regarding contractor positive is provided:
Contractor Information The following information regarding contractor positive is provided:
Craft                   Vital / Protected' Area Access           Lona/Short Term Ciencal                           None Requested                                 Short .                     !
Craft Vital / Protected' Area Access Lona/Short Term Ciencal None Requested Short.
Specialty Vendor                   Protected Requested                           Short                       ,
Specialty Vendor Protected Requested Short Specialty Vendor Protected Requested Short '
4                          Specialty Vendor                   Protected Requested                           Short '                     ,
4 Specialty Vendor Vital Requested Short l
  ,                            Specialty Vendor                 Vital Requested                                 Short                       l'
Technician Vital Requested Short l
;                            Technician                         Vital Requested                               Short l                           Laoorer                           Protected Requested                           Short                       i Specialty Vendor               ' Vital Requested                               Short '                     +
Laoorer Protected Requested Short i
Diver                             Vital Requested                               Short Rigger                           None Requested                                 Short                       i Specialty Vendor                 Vital Requested                                 Short l
Specialty Vendor
' Vital Requested Short '
+
Diver Vital Requested Short Rigger None Requested Short i
Specialty Vendor Vital Requested Short l
i
i


            . ..    - - - . _ . . ..  . - . . . -      - . .  . -    .      . . - .- ..- - _ . . ~ . . .
- _.. ~...
s   .
s E
E i
i n
n i
i 4
4 4                                                                                                          r I
4 r
I i
i i
i i
2 i
2 J
J
.I l
.I                                                                                                         !-
i I
l i
4 i
I 4                                                                                                           ,
ATTACHMENT 3 Corporate and Nuclear Group Headquarters Fitness-for-Duty Performance D?.ta July 1995 through December 1995
i ATTACHMENT 3                                       -
)
Corporate and Nuclear Group Headquarters                               i Fitness-for-Duty Performance D?.ta July 1995 through December 1995 1
                                                                                                              )
l I
l I


Fitness for Duty Program
Fitness for Duty Program
                                                      , Performance Data Personnel Subject to 10CFR 26 Pren turncy enMPANY company nECFMRrn 11- IbOS a Montu Ending CORPORATE AND NUCLEAR GROUP HEADOUARTERS Locanon David M. Sarley (215) 841-5703 Conue Name Phone (include area coce)
, Performance Data Personnel Subject to 10CFR 26 Pren turncy enMPANY nECFMRrn 11-IbOS company a Montu Ending CORPORATE AND NUCLEAR GROUP HEADOUARTERS Locanon David M. Sarley (215) 841-5703 Conue Name Phone (include area coce)
Cutetts: Screen /Cenfirmation (ng/ml)     O Appendix A to 10CFR 26 Marijuana       50   / 15           Amphetamines           1000 / 500                                           /
Cutetts: Screen /Cenfirmation (ng/ml)
Cocaine         300   / 150           Phencyclidine
O Appendix A to 10CFR 26 Marijuana 50
                                                                      '25 / 25                                             /
/ 15 Amphetamines 1000 / 500
Opiates         300   / 300 Alcohol (% BAC)           0.04
/
                                                                                                                            /
, Cocaine 300
Testing Results                                                           Long-Term                       Short-Term         .
/ 150 Phencyclidine
Licensee Employees         Contractor Personnel         Contractor Personnel Average Number witt-Unescorted Access                               2360 1567 S             #            #
'25 / 25
Categories                                                                                             #                #
/
Tested     Positive       Tested     Positive         Tested           Positive Pre-Access                                 8             0 4                 0     ;
Opiates 300
k    Post accident                         2             0 2
/ 300 Alcohol (% BAC) 0.04
i 0
/
9                                                                                                                              {
Testing Results Long-Term Short-Term Licensee Employees Contractor Personnel Contractor Personnel Average Number witt-Unescorted Access 2360 1567 S
        !     Observed behavior i             o t
Categories Tested Positive Tested Positive Tested Positive Pre-Access 8
o                 o Random 69             0     -
0 4
13                 0 Follow-up 5             0 0                 0 Other 1             0 0                 0 Total                                   86-             0 19                 0 REVml/92---
0 k
Post accident 2
0 i
2 0
{
9!
Observed behavior t
i o
o o
Random 69 0
13 0
Follow-up 5
0 0
0 Other 1
0 0
0 Total 86-0 19 0
REVml/92---


t     .
t j
j i
i l
Attachment 3                                        l Summary of Data Analysis and Management Actions Corporate and Nuclear Group Headquarters July - December 1995
Summary of Data Analysis and Management Actions Corporate and Nuclear Group Headquarters July - December 1995 1.
: 1.     Initiatives Taken The fo!!owing summanzes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about illicit activities at Corporate and Nuclear Group Headquarters during the pened.
Initiatives Taken The fo!!owing summanzes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about illicit activities at Corporate and Nuclear Group Headquarters during the pened.
: a.       September 21,1995 - General team sweep of the 965 Building, 3rd Floor, Nuclear Review Board, Sr. Nuclear Management, Information Systems, and Human Resources areas. Results: No activations. No drugs found or forens c samples taken,
a.
: b.       December 14,1995 General team sweep of the 965 Building, 2nd floor, Licensing, Fuels and Engineenng areas. Results: No activations. No drugs found or forensic samples taken.
September 21,1995 - General team sweep of the 965 Building, 3rd Floor, Nuclear Review Board, Sr. Nuclear Management, Information Systems, and Human Resources areas. Results: No activations. No drugs found or forens c samples taken, b.
II. Manaaement Actions There were no positive tests reported during the period.
December 14,1995 General team sweep of the 965 Building, 2nd floor, Licensing, Fuels and Engineenng areas. Results: No activations. No drugs found or forensic samples taken.
1 111. Events Reported Under 10 CFR 26.73 There were no events reported dunng the penod.
II.
IV. Audits / Inspections The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the penod. The audit found that the FFD program is being effectively implemented, in accordance l                 with 10 CFR Part 26. Strengths were identified in the following areas:
Manaaement Actions There were no positive tests reported during the period.
1 111.
Events Reported Under 10 CFR 26.73 There were no events reported dunng the penod.
IV.
Audits / Inspections The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the penod. The audit found that the FFD program is being effectively implemented, in accordance l
with 10 CFR Part 26. Strengths were identified in the following areas:
Strong performance of collection and on-site testing staff during high volume, pre-outage conditions.
Strong performance of collection and on-site testing staff during high volume, pre-outage conditions.
Medical Review Officer qualifications.
Medical Review Officer qualifications.
Effective management oversight of the testing process.
Effective management oversight of the testing process.
!                  One Deviation-level Corrective Action Request was issued as a result of the Audit. The l                 Deviation concemed an overdua background investigation and an overdue psychological
One Deviation-level Corrective Action Request was issued as a result of the Audit. The l
;                  evaluation for two sample collection personnel. The FFD rule requires that background checks
Deviation concemed an overdua background investigation and an overdue psychological evaluation for two sample collection personnel. The FFD rule requires that background checks l
'                  end psychological evaluations be completed every three years for persons who administer the FFD program including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.
end psychological evaluations be completed every three years for persons who administer the FFD program including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.
I
I V.
!          V.     Random Testina Rate                                                     ,
Random Testina Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and LGS.
PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and LGS.


t d   ..- .                                                                                                ,
t d
          - VI.. Additional information                                                                             ,
- VI..
i Actions Taken based upon Unconfirmed On-site Screenino                                             i t
Additional information i
                                                                                                                      )
Actions Taken based upon Unconfirmed On-site Screenino i
Specimens collected at the Corporate and Nuclear Group Headquarters are forwarded directly to the HHS-certified laboratory for testing. On-site screening is not conducted.                 .i t
t
)
Specimens collected at the Corporate and Nuclear Group Headquarters are forwarded directly to the HHS-certified laboratory for testing. On-site screening is not conducted.
.i t
RghJced Mantuana Cut-off Level i
RghJced Mantuana Cut-off Level i
There were no confirmed positive tests for manjuana dunng the penod.                               i i
There were no confirmed positive tests for manjuana dunng the penod.
i i
l I
l I
[
[
t                         -
t
:l                                                                                                                     .
:l r
r t
t e
e 5
5 I
I 4
4 i
i I}}
I}}

Latest revision as of 05:36, 13 December 2024

Forwards Performance Data for FFD Program for Period Jul-Dec 1995 for Plants,Per 10CFR26.71(d)
ML20100L469
Person / Time
Site: Peach Bottom, Limerick  
Issue date: 02/27/1996
From: Hunger G
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9603040240
Download: ML20100L469 (18)
v • d • e


Text

....

Ctation support Department 10CFR26.71(d)

PECO ENERGY c

eccoco<9x e-aer Nuclear Group Headquarters 965 chesterbrook Boulevard l

Wayne, PA 19087 5691 February 27,1996 r

Docket Nos. 50-277 50-278 50-352 50-353 t

License Nos. DPR-44 DPR-56 NPF-39 NPF 85 ~

i U.S. Nuclear Regulatory Commission

' Attn: Document Control Desk.

Washington, DC 20555

SUBJECT:

Peach Bottom Atomic Power Station, Units 2 and 3 Umorick Generating Station, Units 1 and 2 Fitness-for-Duty Program Performance Data for the Period July 1995 through December 1995 i

Gentlemen:

' As required by 10CFR26.71(d), this letter submits the performance data for our Fitness-for-Duty (FFD) program for the period July 1995 through December 1995. The data for our Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and Umerick Generating Station (LGS), Units 1 and 2, sites are provided in Attachments 1 and 2. Data for our Corporate Office and PECO Nuclear Headquarters specimen collection sites (i.e., 2301 Market Street, Philadelphia, PA, and 955-65 Chesterbrook Boulevard, Wayne, PA, respectively) are provided in Attachment 3.

The data are reported on the January 1992 revision of the FFD Performance Data form provided by the Nuclear Energy Institute (NEI), formerly the Nuclear Management and Resources Council (NUMARC), and include the following

)

Drugs tested for and cut-off levels.

Workforce population tested.

?

Numbers of tests and results by population and type of test (i.e, pre-access, for.

.cause, random, follow-up, and other types of tests).'

4 Substances identified.

040050; 99 y

..9603040240 960227

'I PDR ADOCK - 05000277l '

R-PDRn

fl. '

February 27,1996

'M

' Paget Attachmerts 1, 2, and 3 also include the following A summary of management actions.

Analysis of the data and appropriate actions that have been taken.

Random testing rate.

During this period, there were.DQ si nificant events reported to the NRC in accordance with 0

10CFR26.73.

If you have any questions or require additional information, please contact us.

Very truly yours, Aa.Iher.f.

G. A. Hunger, Jr.

Director - Licensing Attachments cc:

T. T. Martin, Administrator, Region I, USNRC (w/ attachments)

W. L Schmidt, USNRC Senior Resident inspector, PBAPS (w/ attachments)

N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments) l l

1

...~ _,. _ __ _. _

s s

i

i..

c

.i s

i i

l' f

i

+

?

i I

4 ATTACHMENT 1 Peach Bottom Atomic Power Station Units 2 and 3 Fitness-for-Duty Performance Data i

July 1995 through December 1995 t

d e

4 i

+

1 i-i..

9 l~

o 4

i i

4 4

Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 PECO ENERGY COMPANY DECEMBER 31,1995 Comoany 8 Mones Endog PEACH BGTTOM ATOMIC POWER STATION Locanon David M. Sarley (215) 841-5703 Conuc: Name Phone Onc!wde ares code)

Cutoff s: Scre en/ Confirmation (ng/ml)

O Appendix A to 10CFR 26 Marijuana 50 / 15 Amphetamines 1000 / 500

/

Cocaine 300 / 150 Phencyclidine

'25 / 25

/

Opiates 300 / 300 Alcohol (% BAC) 0.04

/

Long-Term

~

Short-Term Testing Results 1.lcensee Employees Contractor Personnel Contractor Personnel Average Number with Unescorted Access 2360 1567 8

5 Categories Tested Positive Tested Positive Tested Positive Pre-Access 48 0

1301 24 k

Post accident 11 0

2 0

9 Observed behavior 3

1 5

5 Random 254 0

202 0

Follow-up 25 0

45 0

Other 12 0

1 0

Total 353 1

1556 29 REV.1/92

Summary of Data Analysis and Management Actions Peach Bottom Atomic Power Station July - December 1995 1.

Initiatives Taken The following summarizes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about illicit activities at Peach Bottom Atomic Power Station (PBAPS) during the period.

a.

July 20,1995 - General team sweep outside operator's office area. Results: Six activations. Unidentified pills found in a plastic bag. Employee interviewed. Analysis indicated the pills were over-the-counter medication.

b.

July 27,1995 - For cause term sweep of a contractor's private vehicle. Results: Three activations. Canine responded to empty plastic bag found in vehicle; investigator discovered empty alcoholic beverage containers. Contractor admitted his friends had used manjuana in the vehicle and that he had also used manjuana in the past.

Contractor denied unescorted access.

c.

August 10,1995 - For cause search (no dog used) of a contractor's private vehicle based upon detectable breath alcohol. Search revealed no alcoholic beverage containers. In a subsequent interview, the contractor admitted to excessive alcohol consumption, as well as two previous DUI arrests. This information was provided to PECO Energy Occupational Health and Safety. Contractor denied unescorted access.

d.

August 17,1995 - For cause search of contractor's private vehicle. Results: Four activations. Discovered an unidentified pill inside an empty film canister. Contractor denied drug use, however, revealed his friends had smoked manjuana in the vehicle.

Contractor admitted to using presenption medication without a valid presenption.

Analysis of the pill indicated an over-the-counter medication. Contractor denied unescorted access.

e.

August 24,1995 - For cause team sweep of contractor's private vehicle. Results: Two activations. No drugs found or forensic samples taken. Contractor disclosed previous termination (1989) from oil refinery due to positive alcohol test. This information was provided to PECO Energy Occupational Health and Safety. Contractor granted access and placed on accelerated testing.

f.

August 31,1995 - General team sweep of Maintenance Tool Room, North Issue Counter and Receiving Area. Results: No activations.

g.

August 31,1995 - For cause team sweep of contractor's pnvate vehicle. Results:

Three activations. No drugs found or forensic samples taken. Contractor admitted past drug use and recent association with drug users. Contractor denied unescorted access.

h.

September 7,1995 - For cause team sweep of contractor's private vehicle. Results:

Two activations. No drugs found or forensic samples taken. Contractor admitted cocaine use within past year. Contractor denied unescorted access.

.~

i.

September 7,1995 - For cause team sweep of a contractors private vehicle. Results:

Two activations. No drugs found or forensic samples taken. Contractor admitted i

cocaine and manjuana use within the past month. Contractor denied unescorted access.

j.

September 8.1995 - For cause team sweep (no dog used) of employee's private vehicle based upon a previous positive alcohol test. No alcoholic beverage containers found. Medical restriction removed and unescorted access reinstated, k.

September 12.1995 - For cause team sweep of a contractor's private vehicle based following a positive alcohol test. Results: Two activations. No alcoholic beverage containers found, however, suspected drug paraphernalia found in vehicle. Vehicle was owned by another individual seeking unescorted access. Contractor denied access based upon positive alcohol test.

l.

September 12,1995 - For cause team sweep of a contractor's private vehicle. Results:

Two activations. Suspected drug paraphemalia discovered in vehicle. Contractor denied drug use however, admitted his friends had smoked marijuana in the vehicle this past spnng. Manager, FFD, advised and requested to perform additional testing based upon the discovery. HHS certified laboratory reported detectable levels of i

manjuana. Contractor denied unescorted access.

September 13,1995 - For cause team sweep (no dog used) of a contractors private m.

vehicle following a positive alcohol test. Search was negative for any alcoholic

'everages or containers. Contractor admitted excessive alcohol consumption prior to reporting to work. Contractor denied unescorted access.

1 n.

September 13,1995 - For cause team sweep of a contractors friends vehicle. Results:

No activations. Contractor admitted to borrowing the vehicle due to known use of i

narcotic canines by PECO Energy. Contractor admitted recent drug use including manjuana, cocaine. methamphetamine and magic mushrooms" (hallucinogens).

Contractor denied unescorted access.

o.

September 18.1995 - For cause team sweep of a contractors pnvate vehicle based upon alcohol-related concerns. Results: No activations p.

September 22,1995 - Management requested canine sweep of a contractor's tool trailer which was acquired from a non-nuclear site. Results: Multiple activations. No drugs found or forensic samples taken.

q.

October 22,1995 - General team sweep of the Low Level Radwaste Storage Facility.

I Results: One Activation. No drugs found or forensic samples taken.

r.

November 19,1995 - Suspected drug paraphemalia discovered at the Training Building Annex parking lot. Results: One activation. Suspected paraphernalia was confiscated.

No employees or contractors implicated. The parking lot is also used by the general public for fishing.

s.

November 21,1995 - General team sweep of Construction Trailers within the Protected Area and the owner controlled area. Results: Three activations. No drugs found or i

forensic samples taken.

t.

December 29,1995 - General team sweep of Receiving Building and two delivery trucks. Results: Two activations in the building. No drugs fnund or forensic samples taken.

11.

Manaaement Actions During the period, one PECO Energy employee tested positive at PBAPS based upon a For Cause test. The employee was denied unescorted access. The employee was provided treatment and rehabilitation through the PECO Energy Employee Assistance Program. The employee was subsequently discharged.

Dunng the penod, twenty-nine contractor employees (i.e., twenty-four pre-access and five for cause) tested positive at PBAPS. Unescorted access was denied for all twenty-nine contractor employees.

Ill.

Events Reported Under 10 CFR 26 73 There were no significant FFD events reported by PBAPS during the penod.

IV.

Audits / Inspections The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the penod. The audit found that the FFD program is being effectively implemented, in accordance with 10 CFR Part 26. Strengths were identified in the following areas:

Strong performance of collection and on-site testing staff during high volume, pre-outage conditions.

Medical Review Officer qualifications.

Effective management oversight of the testing process.

One Deviation-level Corrective Action Request was issued as a result of the Audit. The Deviation concerned an overdue background investigation and an overdue psychological evaluation for two sample collection personnel. The FFD rule requires that background checks and psychological evaluations be completed every three years for persons who administer the FFD program, including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.

V.

Random Testino Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and LGS.

VI.

Additional information On-site screenina error On Wednesday, September 20,1995, a specimen collected for pre access screening was tested and reported as " Negative" by the on-site testing facility. The specimen was included in the group of 10% negative quality control specimens forwarded to the HHS-certified for testing.

i

)

Late on Friday, September 22,1995, the HHS-certified laboratory reported the specimen as

" positive for manjuana metabolites." The positive report was retrieved from the printer at approximately 8 am on Monday, September 25,1995, the discrepancy noted, and the Manager, FFD was notified.

After determining that the individual had not been granted access, an investigation into the testing of the specimen was initiated. The HHS-certified laboratory was directed to rerun the specimen. All other specimens collected and screened at the on-site screening facility on the 20th were transported to the HHS-certified laboratory for screening. The results indicated no other discrepancies. An aliquot of the original sample was also sent back to the on-site facility for reanalysis. The results of the re-analysis by the on-site facility were positive for cannabinoids.

j Inspection of the specimen by personnel at the HHS-certified laboratory identified a large amount of sediment in the specimen container which had appeared to clump at the bottom.

Microscopic evaluation of a sample of the sediment indicated " red / amber crystals consistent in morphology with uric acid."

It is believed that during the initial on-site screening, a large amount of the sediment was injected into the analyzer probe causing the inaccurate readings.

A review of the on-site screening records indicated all controls and calibrators were within the designated tolerances. The on-site Syva ETS report for the specimen in question, revealed values greater than 20% lower than the negative controls for all substances. An extensive study of results from the on-site facility showed that greater than 95% of all negative specimens have values within 10% of the negative control.

As a result of these findings the procedures have been revised to direct that any specimen with values greater than 10% lower than the negative control for any of the five substances will centnfuged and re-analyzed. If the value for any of the five substances continues to be greater than 10% lower than the negative control, the specimen will be sent to the HHS-certified laboratory for analysis.

Actions Taken based upon Unconfirmed On-site Screenino PECO Energy has decided to temporanly suspend access for individuals as permitted by 10 CFR 26.24(d).

Dunng the previous 6-month reporting penod, (i e., January - July 1995),100 percent of the specimens which were determined to be presumptively positive for cocaine as a result of preliminary on-site screening tests were subsequently reported as positive by the HHS-certified laboratory. The confirmation rate for marijuana was less than the required 85 percent, therefore, no action was taken on specimens identified as presumptive positive for marijuana.

Dunng this reporting penod there were sixteen specimens which were identified as presumptive positive for manjuana as a result of on-site screening. Fourteen of those specimens screened positive and were confirmed as positive by the HHS-certified laboratory.

The MRO venfied the fourteen specimens as. positive. Administrative actions were not taken until after the MRO determinations and only against the individuals with the confirmed positive tests.

t Reduced Marijuana Cut-off Level i

Dunng the period, there were nineteen confirmed positive tests for marijuana at PBAPS. None of the specimens would have tested positive using the 100 ng/mi immunoassay cut-off level.

(Some specimens are sent directly to the HHS-laboratory without on-site screening.)

j Contractor Information The following information regarding contractor positive tests is provided:

Craft Vital / Protected Area Access Lono/Short Term Laborer Vital Granted Short Turbine Tech

~ Vital Requested Short Boilermaker Vital Granted Short Laborer Vital Requested Short Pipefitter Vital Requested Short Pipefitter Vital Requested Short Laborer Vital Requested Short Laborer Vital Requested Short Laborer Vital Requested Short Custodial Protected Requested Short Specialty Vendor Vital Requested Short Pipefitter Vital Requested Short Laborer None Requested Short Pipefitter None Requested Short Specialty Vendor Vital Requested Short Asbestos Worker Vital Requested Short Laborer None Requested Short Laborer Vital Requested Short Laborer None Requested Short Laborer Vital Requested Short NDE/ISI inspector Vital Requested Short NDE/ISI Inspector Vital Requested Short Electncian Vital Requested Short Electncian Vital Requested Short Pipefitter Vital Requested Short Pipefitter None Requested Short Diver Protected Requested Short Diver None Requested Short Diver Protected Requested Short

l s

I

\\

I f

ATTACHMENT 2 1'

Umerick Generating Station Units 1 and 2 Fitness-for-Duty Performance Data July 1995 through December 1995 1

I l

l w.

Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 PECO ENERGY COMPANY DECEMBER 31, 1995 Company a Mont.s Ending i

LIMERICK GENERATING STATION Locanon David M. Sarley (215) 841-5703 Conue Name Phone (include area exe)

Cutoff s : Scre e rvConfirmatio n (ng/ml)

O Appendix A to 10CFR 26 Marijuana 50 / 15 Amphetamines 1000 /500

/

Cocaine 300 / 150 Phencyclidine 25 / 25

/

Opiates 300 / 300 Alcohol (% BAC) 0.04

/

Long-Term

~

Short-Term Testing Results Licensee Employees Contractor Personnel Contractor Personnel Average Number with 2360 1567 Unescorted Access A

Categories Tested Positive Tested Positive Tested Positive Pre-Access 60 1

359 10 k

Post accident 16 0

9 0

9 h

Observed behavior 3

0 1

0 Random 240 1

157 0

Follow up 48 0

17 0

Other 4

0 3

0 Total 371 2

546 10

Summary of Data Analysis and Management Actions Limenck Generating Station j

July - December 1995 l.

Initiatives Taken The following summanzes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about i! licit activities at Limenck Generating Station (LGS) dunng the period.

f a.

July 17-.1995 General team sweep of the Administration Building, second floorc Results: Two activation. No drugs found or forensic samples taken.

b.

August 30,1995 - Pennsylvania State Police (PSP) counter-drug operation discovered manjuana growing on Company owned right-of-way adjacent to LGS. Plants were confiscated by the PSP. No employees or contractors implicated. No arrests made.

c.

September 8,1995 - General team sweep of the Sewage Treatment Facility. Results:

No activations.

d.

October 18,1995 - General team sweep of the Scaffold Shop. Results: No activations.

e November 7,1995 - General team sweep of the Technical Support Center, first floor.

Results: No activations.

l l

f.

December 13,1995 - For cause team sweep of an employee's private venicle following positive test. Results: Two activations Forensic samples taken. Laboratory analysis proved negative. Employee was returning-to-duty following rehabilitation. Unescorted access subsequently reinstated, 11.

Manaaement Actions Dunng the penod. two employees (i e., one pre-access, one random) tested positive at LGS.

Unescorted access was denied both employees. The employees were referred to the Employee Assistance Program for evaluation and treatment. Unescorted access was subsequently reinstated for the employee who tested positive on the random test The other I

employee was transferred to a position which did not require unescorted access.

Dunng the penod, ten contractor employees tested positive on pre-access tests at LGS.

Unescorted access was denied for the ten contractor employees.

Ill.

Events Reported Under 10 CFR 26 73 During the penod there were no significant FFD events reported by telephone under 10 CFR 26.73 by LGS.

IV Audits / Inspections The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the penod. The audit found that the FFD program is being effectively implemented, in accordance with 10 CFR Part 26. Strengths were identified in the following areas:

l Strong performance of collection and on cite testing staff dunng high volume, pre-outage conditions.

Medical Review Officer qualifications.

Effective management oversight of the testing process.

One Deviation-level Corrective Action Request was issued as a result of the Audit. The Deviation concerned an overdue background investigation and an overdue psychological evaluation for two sample collection personnel. The FFD rule requires that background checks and psychological evaluations be completed every three years for persons who administer the FFD program, including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.

V.

Random Testina Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and LGS.

VI.

Additional information Actions Taken based upon Unconfirmed On-site Screenina PECO Energy has decided to temporarily suspend access for individuals as perm;tted by 10 CFR 26.24(d).

Dunng the previous 6-month reporting period, (i.e., January - July 1995),100 percent of the specimens which were determined to be presumptively positive for cocaine as a result of preliminary on-site screening tests were subsequently reported as positive by the HHS-certified laboratory The confirmation rate for manjuana was less than the required 85 percent, therefore, no action was taken on specimens identified as presumptive positive for manjuana.

Dunng this reporting penod there were three specimens identified as presumptive positive for cocaine as a result of on-site screening. The three specimens were also screened positive and reported as confirmed positive by the HHS-certified laboratory. The MRO venfied the three specimens as positive following discussion with the individuals. The three specimens were collected as part of pre-access testing, therefore the temporary suspension of access was not applicable.

Dunng this reporting penod there were eleven specimens identified as presumptive positive for manjuana as a result of on-site screening. Eight of those specimens screened positive and were reported as confirmed positive by the HHS-certified laboratory. The MRO venfied the l

eight specimens as positive following discussion with the individuals. Administrative actions were not taken until after the MRO determinations and only against the individuals with the confirmed positive tests.

l Reduced Mantuana Cut-off Level Dunng the penod, there were eight confirmed positive tests for marijuana at LGS. Five of the i

specimens would not have tested positive using the 100 ng/mi immunoassay cut-off level.

]

1

~ -...

. ~ -. -...

~.

l l-8

(-

Contractor Information The following information regarding contractor positive is provided:

Craft Vital / Protected' Area Access Lona/Short Term Ciencal None Requested Short.

Specialty Vendor Protected Requested Short Specialty Vendor Protected Requested Short '

4 Specialty Vendor Vital Requested Short l

Technician Vital Requested Short l

Laoorer Protected Requested Short i

Specialty Vendor

' Vital Requested Short '

+

Diver Vital Requested Short Rigger None Requested Short i

Specialty Vendor Vital Requested Short l

i

- _.. ~...

s E

i n

i 4

4 r

I i

i i

2 J

.I l

i I

4 i

ATTACHMENT 3 Corporate and Nuclear Group Headquarters Fitness-for-Duty Performance D?.ta July 1995 through December 1995

)

l I

Fitness for Duty Program

, Performance Data Personnel Subject to 10CFR 26 Pren turncy enMPANY nECFMRrn 11-IbOS company a Montu Ending CORPORATE AND NUCLEAR GROUP HEADOUARTERS Locanon David M. Sarley (215) 841-5703 Conue Name Phone (include area coce)

Cutetts: Screen /Cenfirmation (ng/ml)

O Appendix A to 10CFR 26 Marijuana 50

/ 15 Amphetamines 1000 / 500

/

, Cocaine 300

/ 150 Phencyclidine

'25 / 25

/

Opiates 300

/ 300 Alcohol (% BAC) 0.04

/

Testing Results Long-Term Short-Term Licensee Employees Contractor Personnel Contractor Personnel Average Number witt-Unescorted Access 2360 1567 S

Categories Tested Positive Tested Positive Tested Positive Pre-Access 8

0 4

0 k

Post accident 2

0 i

2 0

{

9!

Observed behavior t

i o

o o

Random 69 0

13 0

Follow-up 5

0 0

0 Other 1

0 0

0 Total 86-0 19 0

REVml/92---

t j

i l

Summary of Data Analysis and Management Actions Corporate and Nuclear Group Headquarters July - December 1995 1.

Initiatives Taken The fo!!owing summanzes the results of sweeps conducted by PECO Energy Company's drug sniffing canine teams as well as investigations and interviews used to confirm information about illicit activities at Corporate and Nuclear Group Headquarters during the pened.

a.

September 21,1995 - General team sweep of the 965 Building, 3rd Floor, Nuclear Review Board, Sr. Nuclear Management, Information Systems, and Human Resources areas. Results: No activations. No drugs found or forens c samples taken, b.

December 14,1995 General team sweep of the 965 Building, 2nd floor, Licensing, Fuels and Engineenng areas. Results: No activations. No drugs found or forensic samples taken.

II.

Manaaement Actions There were no positive tests reported during the period.

1 111.

Events Reported Under 10 CFR 26.73 There were no events reported dunng the penod.

IV.

Audits / Inspections The annual FFD audit was conducted by Nuclear Quality Assurance personnel during the penod. The audit found that the FFD program is being effectively implemented, in accordance l

with 10 CFR Part 26. Strengths were identified in the following areas:

Strong performance of collection and on-site testing staff during high volume, pre-outage conditions.

Medical Review Officer qualifications.

Effective management oversight of the testing process.

One Deviation-level Corrective Action Request was issued as a result of the Audit. The l

Deviation concemed an overdua background investigation and an overdue psychological evaluation for two sample collection personnel. The FFD rule requires that background checks l

end psychological evaluations be completed every three years for persons who administer the FFD program including collection site personnel. Immediate corrective actions were initiated, and both conditions were resolved before completion of the audit.

I V.

Random Testina Rate PECO Energy maintains separate testing " pools" for employees and contractors. Random testing is conducted at an annualized rate of 50%. The " average number with unescorted access" includes personnel granted unescorted access at both PBAPS and LGS.

t d

- VI..

Additional information i

Actions Taken based upon Unconfirmed On-site Screenino i

t

)

Specimens collected at the Corporate and Nuclear Group Headquarters are forwarded directly to the HHS-certified laboratory for testing. On-site screening is not conducted.

.i t

RghJced Mantuana Cut-off Level i

There were no confirmed positive tests for manjuana dunng the penod.

i i

l I

[

t

l r

t e

5 I

4 i

I

Retrieved from "https://kanterella.com/w/index.php?title=ML20100L469&oldid=4309588"