f .0 CFP 26.71(d)'

,

'

l'IllLADEI l' Illa El.ECTitIC COMi%NY. -

'

NUCl. EAR GROllP llEADQUARTERS955-65 CifESTERilROOK HIND.

WAYNE, PA 19087 569)

(215) 640-6000

NUC(EAR 1:NGINf1 RINO & si RVICIS DE PART MI:NT

August 27, 1991

Docket Nos. 50-35250-35350-27750-278

License Nos. NPF-39NPF-85OPR-44OPR-56

DirectorOffice of Nuclear Reactor RegulationUS Nuclear Regulatory CommissionWashington, DC 20555

SUBJECT: Limerick Generating Station, Units 1 and 2Peach Bottom Atomic Power Station, Units 2 and 3Fitness-For. Duty Program Performance Datafor the Period January 1991 Through June 1991

Dear Sir:

As required by 10 CFR 26.71(d), this letter submits the performance data forour fitness-for-duty program for the period January 1991 chrough June 1991. Thedata for our Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, andLimerick Generating Station (LGS), Units 1 and 2, sites are provided inAttachments 1 and 2, Data for our corporate office and Nuclear GroupHeadquarters specimen collection sites (i.e., 2301 Market Street, Philadelphia,PA and 955-65 Chesterbrook Boule,ard, Wayre PA respectively) are also providedin Attachment 3.

The data are reported on a form acceptable to the NRC as documented in theJuly 31, 1989 letter from J. M. Taylor (NRC) to J. F. Colvin (Nuclear Managementand Resources Council), and include the following.

Drugt tested for and cut-off levels, including tests for other drugs.

(i.e., barbiturates and benzodiazepines).

Workforce population tested..

910905o223 910827 pf-

7 - **u;7 .,,

-,

;e e

Qffice of Nuclear Reactor Regulation Page 2US Nuclear Regulatory Commission,

.

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

andging, random, for-cause, pre-employment, periodic post-accident,follow-up, and other types of tests). ;

Substances identified..

1

!

Attachments 1, 2, and 3 also include the following.t

Summary of management actions..

Analysis of the data and appropriate actions that have been or will be.

takeit.,

A list of events reported. (Note that there was one event which was.

:reportable in accordance with 10CFR26.73 during this period.)

,

Random testing rate,,

,

Note that the results of drug sweeps at our corporate office and NuclearGroup Headquarters are not available at this time and will be included inthe next periodic report of performance data.

,

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

i

Very truly yours,

& |G. J. Beck ,

'ManagerLicensing Section

RMK:eas

Attachments

cc: T. T. Martin, Administrator, Region I, USNRC w/ attacoments IT. J. Kenny, USNRC Senior Resident inspector, LGS w/ attachmentsJ. J. Lyash, US NRC Senior Resident inspector, PBAPS w/ attachments

.

h

t

F

. - - - , . , , _ . . . . - . , . - , _ __- _ - - _ . _ . . _ - . - - - - -_ -

- - - - - - - - ._-

T

.1 ATTACHMENT 1 |,

:.

:..

.. . ..

FITNESS FOR DUTY PROGRAM : |

Performance Data :

Personne Subjectto :.0CFR26 ||

Philadelphia Electric Company Junc 30. 199L_co wANY 6 MONTHS [NDeNG

{t

Peach Bottom Atomic Power Station ;LOCATION N

D. M. Sarley (215) 841-5703CONTACT NAME PHONE (INCLUDC AREA CODI)

l

CUTOFFS: SCREEN / CONFIRMATION (ng/ml) b APPENDIX A TO 10CFR 26i

t

300 300 ,turates *

MARIJUANA 100 / 15 AMPHETAMINES 1000 / 500 /

!

ECOCAINE 300 /150 PHENCYCLlDINE 25 / 25 Benndiaz eoines 300/300

OPIATES 300 /300 ALCOHOL (% BAC) 0.04%BAC /

f

.

LONG TEiiM S'kORT. TERM !

CONTRACTOR CONTRACTORTESTING RESULTS LICENSEE EMPLOYEES PERSONNEL PERSONNEL

hihf[j$j$jk-AVERAGE NUMBERWITH UNESCO 3TED tt :i d .' 'v F; .c m J-ACCESS 2931* un 2543*-

# ## # REFERRED ACCESS # # # # >

CATEGonlES TESTED POSITIVE TO EAP RESTORED TESTED POSITIVE TESTED POSITIVE ;

!-.. ,

,

PRE EMPLOYMEtn 20 1 4,n , 1,208 14 j'-

~'m .,. ..

PRE-BADGING 14 0 }{;, , 0 0 ;'

@%.;.

0 0.

PERIODIC 18 0 ..

sp,e .FOR CAUSE 1 1 d. p. 2 0

;cw .

{,%[f[f,'

~

0 0POST ACCIDEtn 0 O

hif,[d,$ N:c 879 4RANDOM 791 1

'

}ps 1:,wajyfjgygf.f , . 0 0;c. s .

FOLLOW-UP 23 0

OTHER 18 0,h.;b -

uu.; :

$ '.2 , j 20 0 L~? oj., ,

'TOTAL 885 3 2 1 2109 18

*Includesindivibualswithdual-siteaccessatPBAPSandLCS fn ues_ . _ _ _ _.

. wis ;' - _ T ' ,., , | |

I|. 1jll|!lIil

*.= -

. 5 - )I 4g ,:4 ; ,

3k _ - ;;. ,c. -

*

~ -

.~

C RB B A P A O C M O %G % # TI AE Ne a L H M P O A N ?' R P P SD Nn r C E P A C R F OP

! A O O TM Dz b O N H T A U Io i H C E E !

U R I H S S E OS

A N V F VIT DDIN T T

I

U Md t O h T S E A M O I

V A TIi u La r J' ,M A E E E E L

I D S Ez a De t I N Sp e N E P # Ti s E S O I

T Nn S ES G .e I _

s T T

-- R

_

1 2 3 4 5 E P _I

V D , OE -

TE n - G

RS - A .

.1 1 T 1

0 1 1 o 1 5 S -1 -

- 4 M.

_0 1 2 1F 1 1 R _

O % 5 ER 9 1 S .

- - = 9 U .

.

S .

8 L ._P -

E - =l / 9 T .

.

1 SC 00 _I

0 0 0 0 2 o 9 7 F . 1 _I 7 3 .C I

3 7 __

S % 1 .

_U - .

B-1I t i -

0

-

ST 1 iI . 5,

A 30 0 2 0 1 1 5 1

N-

.- 8 1

C . % 3.

E _ 0_

. 7 1_S _.;

9 .

9 _

0ii

01I . 1

0 0 1 0 1 o 5 3 0 _

9 1% 1 .

5 _5

.

_

.

~.

0 51

1 1 3 0 1 3 4 2 30 1% 6

7 .

_- 0 1-

991

_

.

_.- .

.

-.

_.

..

'.

_, ,

~ _

1 ..9 _9 .

2 _

_

_

* _.

,.

..

_.

1 ,

,_

;1 9 ..

9 ,

_ ,,

3 _

_.

,

7- .

.

/.t ,

_

_ 31/

_

89

_ ': 9 -_

~

_ -' ', . ' '; j i i' - ' "i ] |I|!i '|, 1,

. _ - _ - - _ _ _ _ _ _ _ - _ - _ _ _ _ _ . _ _ . . _ _ _ . _ . _ _ ._ . _ _ _ _ _ _ _ - _ _

f '

,

t

25 ng/ml. The contractor identified the problem onFebruary 22, 1991 and immediately ceased PCP screeninguntil the correct calibrator was received from themanufacturer (i.e., Syva). Contact with PECo's certified

,

laboratory (i.e., DrugScan, Inc.) indicated that Drug Scanwas using the preper screen.

Investigation revealed that the contractor began using theEmit d.a.u. calibrator at our Limerick Generating Station(LGS) on August 21, 1990, and at PBAPS on October 24, *

1990, in an attempt to ensure consistency between the *

on-site lab ard the certified lab. Investigation revealed'that the on-site lab supervisors failed to recognize the

different calibration levels indicated within theliterature accompanying the calibration reagents. [

During the period, the on-site testing facility had ;correctly identified all blind proficiency operimenssubmitted. We also noted that one of the quality controlspecimens (i.e., 10% of negative screens) submitted to thecertified lab was identified as a falso negative.

,

All on-site testing technicians were retrained in theproper methods of calibration reagent preparation and in >

following instructions contained in the accompanyingliterature.

;

IV. Random Testing Rate

PEco conducts random testing at the annualized rate of 100%. The" average number with unescorted access" includes personnel badged atboth LGS and PBAPS. PECo maintains separate testing " pools" foremployees and contractors.

,

V. Policy Revision

on April 1, 1991, the company revised its separate Drug and AlcoholPolicies into a single combined Drug and Alcohol Policy and Program. 1

V1. Action Taken to Improve Program

A. The PECo Human Resources D9partment is being reorganized. As .

part of this process, the position of FFD Program Manager isbeing established. The FFD Program Manager will have clearresponsibility for the FFD Program and will report to theDirector, occupational Health and Safety.

B. All collection sito personnel have been retrained withadditional emphasis placed on attention to details.

C. A separate secured access area has been established to ensureaccess to test results and random testing lists is restricted.

- . .

f|

.

.

~ K. June 13, 1991 - Ran ',<. search of private vehicles parked nearthe "A" cooling towers. Re sulte no activations.

L. June 26, 1991 - Random team search of the Site ManagementBuilding and various rooms in Unita 2 and 3. Results: oneactivation in the Cable Spreading Room, one activation in theMedical Room Elevation 135. No drugs or forensic samples

taken.

II. Management Actions

During the period, two (2) PEco employees (1 Random /1 For-eause) andone (1) applicant tested positive at PDAPS. The two (2) employees

were referred to the Employee Assistance Program (EAP) and treatmentprovided as necessary. Unescorted access was subsequently

reinstated for the employee testing positive on the random testafter evelaation by the Medical Review Officer. The employee tested

for cause has not at this time oeon reinstated.

During the period, eighteen (18) contractors tested positive (14pre-employment. 4 random). In accordance with PECo'sPitnesa-f or-Duty (FFL) Specification for cos ;ractor's, unescortedaccess was denied for the fourteen (14) pre-employments. Unescorted

access was tern._ tated for the four (4) contractors who testedpositive on the random tests.

III. Events Reported under 10CFR26.73

A. There were no events which required reporting in accordancewith 10CFR26.73 at PBAPS during the reporting period.

B. During the period, the following potentially reportable eventswere evaluated as not reportable.

1. During a routine check of training records on January 22,1991, PEco identified that a number of individuals, listedas supervisors, may not have completed either the initialFFD Supervisory Training within three months ofassignment, or the annual refresher training. Immediatenotification was made to the Site Support Managers,

security Coordinator, and the Nuclear Support Manager.Resolution of the issue was accomplished through the

following actions: supervisory designation was removedfrom those not actually performing supervisory duties;access was temporarily suspended for those actuallyinvolved in supervisory duties until training wascompleted; and in some cases, posting completed trainingto the tracking system.

2. On February 26, 1991, the contractor performing on-siteimmunoassay screening notified the FFD Coordinator thatscreening for the chemical "PCF," had not been completedproperly. The contractor had been using a PCP screen

(i.e., Emit-d.a.u.) calibrated at 75 ng/ml as opposed to

_ _ _ - - - -______

T

._

e

ATTACHMINT 8 a l.

.

Summary of Data Analysis and Management ActionsPeach Bottom Atomic Power Station

January - June 1991 ;

i

I. Initiatives Taken

Thu sollowing summarireo the results of sweepe conducteo by thePhiladelphia Electric Company's (PECo's) drug sniffing canine teamsat 3 Peach Bottom Atomic Power Station (PDAPS) during the period.

A. January 18, 1991 - For-cause team search of a private vehicle.Results: multiple activations. Discovery of 50 mg. of suspectsubstance. Laboratory analysis revealed substance to bemarijuana. Plant access revoked.

D. January 28, 1991 - Random team search of vehicles entering the

Protected Area (PA). Results: no activationo.

C. January 29, 1991 - Random team sweep of Plant ServicesBuilding, Hodification Building (second floor), Access control

!Center, Installation Tool Room and Security ManagementBuilding. Results: six responses in the too) room; no drugs ,

found ot forensic samples taken.|'

D. February 1, 1991 - For-cauce team nearch of a private vehicle.Reaultot tuo activations. No drugs found or forensic samples ,

taken. Follow-up investigation verified previous off-site drug'

involvement, as well as the present abuse of alcohol. Plant

access revoked.

E. February 1, 1991 - For-cause team nearch of a private vehicle.Results: two activations. No drugs found or forensic samplestaken. Follow-up investigation verified the individual useddrugs off-uite from 1974 through 1990. Plant access revoked.

F. February 28, 1991 - Random Team search of vehicles entering thePA. Reesults: no activations.

G. March 28, 1991 - Random team cearch of vehicles entering the |

PA. Results: no activations.i

H. March 28, 1991 - Random team nearch of the first and fourth *

floors of the Administration Building within the PA, ,

Installation Tool Room, Maintenance offices adjacent to theriver, and six PECo vehicles. Results: one activation to PECovehicle outside the PA. No drugs found or forensic samplestaken.

I. April 30, 1991 - Random team search of the Maintenance Shop andall vehicles inside the PA. Results: no activations.

J. June 12, 1991 - Random team search of vehicles entering the PA.Results no activations.

_ - - - . ,_ - . _ . ___ _ _ _, _ __ .

'

ATTACllMENT 2 .

, ;, ,,

-.

. .

FTTNESS FOR DUTY PROGRAM*

Performance DataPersonne: Subject to 10CR 26

,

Philadelphia Elcetrice June _.30 J 11___e uomis at:omocowam

Limerick Generatin L tation |SftocAfbN

D. H. SARLEY : (215) 841-5703Chn A01 NAM (

PHONt pNCWDC ARLA COD ()

CUT 0FFS: SCREEN /CONFIRMAll0N (ng/ml) O APeEN0ix A TO iOC7R 2er

MARIJUANA 100 / 15 AMPHETAMINES 1000 / $00 P>arbitu u ten 300 / 300

COCAINE 300 /150 PHENCYCLIDINE 25 / 25 .lenzodi nepines 300 / 300i

OPIATES 300 /300 ALCOHOL (% BAC) 0.04%BAC /

.

: .LONG-T ERM SHORT TERM

CONTRACTOR CONTRACTOR

TESTING RESULTS LICENSEE EMPLOYEES PERSONNEL PERSONNEL-, _.

,

$ N + k. 'AVERAGE NUMBER

hi. ,(-} 'h2. 3-[J )4 \VT ESCORTED 2931* /5J a,

. 7.-

# # REFERRED ACCESS # # # #'

CATEGORIES TESTED POSITIVE TO EAP RESTORED TESTED POSITIVE TESTED POS111VE'

&;j.)X'(i@ ~Q,;s|;$.!*, Jh MC

. P 4: 968 13PRE EMPLOYMENT S 0 g |,;

h' , h kN. 0 0PRE BADGING 49 0

Lys p,, :,. . . - , , ,

PERIODIC 0 0 $M.;. :. .M/^ f 0 0.

(4ay2, v $p,!f ;- 3 0o. .

.j3pj,QFOR CAUSE 1 1,

f3Q.yf "O: .cs.c aPOST ACCIDENT 01 0 gqd .#4% F 2 0

'

ingp ;g 1.~ a.RANDOM 704 2 @)yyVi3 Ok;.;Rd #

.646 3

FOLI.0W UP 13 0 p$; O O

m 9.. c a:4[W JT

@yjp cp {r .% o oOTHER .T2 .o .

,

.-_

TOTAL 777 3 3 ~ 3 1619 16

* Includes indiv'iduals with dual-site access at PBAPS and LGS ggyeg,

i,

. -- - - . - . - - - _ _ _ - - _ . - - - _._ - _ - _ _ .--______ _ _ - _ _ _

, i u. IiI|!!|Ll|

|' h t

+ !| -,

t ,'

* g

~

'> j- 1 ' , 5 -. . ~

C RA P A O C M O %G % # TI A

IR ENE B L H M P O A N P P- P SD Ne a C E P A C R F OA O O TIV Dn r O N H T A U I P

SiH S S EI Oz b H C E E !N U Ro i O Y T S E A M I C I

T DDTI

I

MT Ud t L C A N V F V V A Ti u U M A E E E E La r D S Ez a D I

N Se t IN E P # Tp e E S O T NI

i s Sm mn G. e Ps ^4 2 3 4 5V m RE OT -- GE - R-ST 0 1 A

. 5 M4 3 S. i! 7 24 0 0 O 5 2 3 8

F - 3 0 RO _-

I 22 6 E

R 1 S_ 9 US

- 7 8 L-

P4_-

.

9 T- SE 1C 3

#_01 8 I

0 0 0 O 0 1 4 F _ + -

C @.-7 1I

9 6.-

S c .. % 4_ 6gyU

B.

S4T 0

0 1 1 O 0 1 2 5 A'tI , 3

-

N 2 1C % 2E 4 1S 9 9|

90

0 21 12 0 1 0 1 0 2 1

1 1'

'

9 0% 3

!; 7

_iI

~

50 0 4 0 0 0 8 7

{i,' 0

4 1% 3

[50 1

991

-

1' 99

7 2

'

|i

i'

.

.-

1! 9

9. 3

.

7/

,

2 .2/ I'

89

|. , '

-.

, ,.

'' ;e.'

- I; b\ ||j

1I ||' j ! Jl il1lIl|l1

_ _ _ _ . - _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ __ - _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _

ATTACHMENT 3' '

.

bs.

summary of Data Analysis and Management Actions {Limerick Generating Station '!

January - June 1991 !

r

1. Initiatives Taken f!

The following summarizes the results of sweeps conducted by the i

Philadelphie Electric company's (PEco's) drug sniffing canine teams fat the Limerick Gb. Terr. ting Station (LGS) during the period. i

!h. February 5, 4,'' - For cause team search of a contractor's

vehicle. Results: three activations. A field test of |suspected controlled substance was negative.

|

B. February 28, 1991 - Random team sweep of LGS Personnel'[

Processing Center. Results: ten activations. One activation I

resulted in the location of a prescription drug. No other |drugs were found or forensic samples taken. _|

r

C. March 27, 1991 - Random team sweep of-Receiving Warehouse, fResults: twelve activations. No drugs found or forensicsamples-taken.

|

ID. April 9, 1991 - For cause team search of bathroom in the

,

Protected Area (PA) where a plastic bag was found taped to theinside of a stall. Results no activations or forensic I

samples taken.. [!

E. April 29, 1991 - For cause team search of a leased vehicle !brought onto site property. Results: three activations. A :

field test of ash residue was negative. ;

L

F. May 25, 1991 - Random team sweep of the first floor of the LGS i

Site Support Building. Results: ten activations. No drugsfound or forensic samples taken.

G- June 14, 1991 - For cause team search of a contractor's i

vehicle. Results three activations. No drugs found orforensic samples taken.

II, Management Actions !

During the period, three (3) PEco employees tested positive at LGS.Two (2) of the engloyees tested positive as a result of randomtesting. The third was the. result of a "For cause" test. [

As this was the first occurrence for each of these employees, their ,

unescorted access was suspended for the fourteen (14) days required.They were referred to PECo's Employee Assistance Program (EAP) forassessment and treatment, as necessary.- Following treatment, theindividuals were evaluated by the Medical Review Officer (MRO) forreturn tc nuclear work. All subsequently passed drug and alcohol ;

testingil and were cleared by the MRO. They subsequently obtainedmanagement approval and unoscorted access was regranted. j

i-

>

h

!

, . , _ _ - _ . . , , - - , - - - . . _ m _ _ _ . . . . _ . _ . __ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _

_ _ _ _ _ - . .. . _ _ _

. .

.

During the period a total of sixteen enntractors tested positive (13preemployment/3 random). In accordance wit h PEco's Fitnese-f or-Duty

(FFD) opecification for contractors, unescorted access was deniedfor the thirteen individuale seeking uneocorted access. Access wasterminated for the three individuals testing poultive through therandom testing process.

III. Events Reported under 10CFR26.73

A. There was one event reported to the NRC under 10CFR26.73 duringthe first six months of 1991. ,

,

on April 5, 1991, a contractor supervisor working in ourTraining Division randonly tested positive on an alcoholbreathalizer. Blood test confirmed on April 9, 1991, that

alcohol levela exceeded acceptable limits. On April 5, 1991,

access was denied to the protected area of the plant. On April9, 1991, the contractor employee was denied access to any PECoproperty and remains forbidden to do work for PECo.

,

i'

D. During the period, the following potentially reportable eventawere evaluated as not re port able .

1. During a routine check of training recordo on January 22,1991, PEco identified that a number of individuale, listedas supervisors, may not have completed either the initialFFD Supervisory Training within three months ofassignment, or the annual refresher training. Immediatenotification was made to the Site Support Managere,Security Coordinators, and the Nuclear Support Manager.Resolution of the issue was accomplished through thefollowing actions supervisory designation was removedfrom those not actually performing supervisory duties;acceus was temporarily suspended for thoso actuallyinvolved in supervisory duties until training wascompleted: and in some cases, posting completed trainingto the tracking system. .

2. On February 26, 1991, the contractor performing on-siteimmunoassay screening notified the FFD Coordinater that [nereening for the chemical "PCP," had not been completed ,

properly. The contractor had been using a PCP ocreen t

(i.e., Emit-d.a.u.) calibrated at 75 ng/ml as opposed to25 ng/nl. The contractor identified the problem onFebruary 22, 1991, and immediately ceased acreening until i

tuo correct calibrator was received from the manufacturer

| (i.e., Syva). Contact with PECo's certified laboratoryI (i.e., Drugscan, Inc.) indicated that Drug Scan was uning

the proper screen. [

.

1

- . . _ . - __ _ _ - - - - _ . . _ _ _ . .

_

/*c.*

.

4

e

Investigation revealed that the contractor began using theEmit d.a.u. calibrator at LOS on August 21, 1990, and at

the Peach Bottom Atomic Power Station (PDAPS) on October24, 1990, in an attempt to ensure consistency between theon-site tecting facility and the certified lab.Investigation revealed that the lab supervisors failed torecognize the different calibration levels indicatedwithin the literature accompanying the calibrationreagents.

During the period, the *in-site testing faciltty hadcorrectly identified all blind proficiency specimens

-submitted. We also noted that one of the quality coritrol

specimena (i.e., 10% of negative screens) submitted to thecertified lab was identified as a falso negative.

All on-site testing technicians were tetrained in theproper methods of calibration reagent preparation and infollowing instructions contained in the accompanyingliterature.

IV. Random Testing Rate

PECo conducts random testing at the annualized rate of 1001. The" average r. umber with unescorted _ access" includes personnel badged atboth 't and PDAPS. PECo maintains separate testing " pools" forempivjz a and contractors.

V. Policy Revision

On April 1, 1991, the company revised its ceparate Drug and AlcoholPolicies into a single combined-Drug and Alcohol Policy and Program.

VI. Action Taken to Improve Program

A. The PEco Human Resources Department is being reorganized. AsI part of this process, the position of FFD Program Manager.is{ being established. The FFD program Manager will have clear

responsibility for the FFD Program and will report to theDirector, Occupational Health and Safety.

,

D. All' collection site personnel have been retrained withadditional emphacio placed'on attention to details.

__.

C. A separate secured access area has been established to ensure. access to test results and' random testing lists is restricted.

_ ___ _ ___ - ___ - _ _ _ _ _ __ - .-

ATTACilMENT 3 ;.,,

i. , 1

FITNESS FOR DUTY PROGRAM ;,

Performance DataPersonne: Subjec" to 10CFR 26

.

,

iPhiladelphia Electrice Company June 30, 1991

COMPA/4y 6 MON 1HS INDING

Corporate and Nuclear Group lleadquarterstoCAtl0N ,

D. H. SARLEY (215) 841-5703 !

cout Act NAvt PHONE UNCLvet Antacooti ,

'

4

CUTOFFS: SCREEN / CONFIRMATION (ng/ml) b APPENDIX A TO 10CFR 26

MARUUANA 100 / 15 AMPPETAMINEL 1000 / 500 Barbiturates 300/ 300,

Ben Manpines 300 300COCAINE 300 / 150 PHENCYCLIDINE 25 / 25 j

!

OPIATES 300 / 300 ALCOHOL (% DAC) 0.04%BAC / .,

_. ,

,

LONG TERM SHORT TERMCONTRACTOR CONTRACTOR

TESTING RESULTS LICENGEE EMPLOYFES PERSONNEL PERSONNEL |

fhkh.:aAIE!7.[h4hAVERAGE NUMBERWITH UNESCORTED 931* i e.l 2543* i

ACCESS *b' 'r -

*

# ## # REFERRED ACCESS # # # # !

CATEGORIES TESTED POSITIVE TO EAP RESTORED TESTED POSITIVE TESTED POSITIVE !

g. e.,-

hpD ''i2 ,8 2

...'

PRE EMPLOYMENT 49 1 / j

. .e !

$e:- f, , 0 0. .

~

f4 LPRE BADGING 18 0

% ', |.. ,

PERIODIC 1 0 $7",. 0 0

. !

m(v.4 [ 'i, 0 0 lKFOR CAUSE O O!

.;..

POS'. ACCIDENT 0 0 (.p' S ; 1 0 0'

_

,

h,fh'[fb h,_ ,.RANDOM 268 0 11 0'

gg.'fuuo. ':1., x)FOLLOW UP 15 1 g #p., .g.. 0 0

Y,, '.;e ..

$,ff," } 0 0 fOTHER 10 0

!-

TOTAL |361 2 1 0 19 '2 [

ti

-

* Includes personnel with dual-site access at PBAPS and LGS 7 m /e9 i

'

_ . __ . _ . . _ _ _ _ _ .__ __ . _ _ _ .

+-

,

., .< . > - - ; ,. - - - - - - - - - - - , - - --

, < - - - ,, , ,,. g .g-,

'

,

i * 1,

, .s t. . . *. _i* o

O '

h' O $ # % 45W YN }e" @ B B 3 Gy l

R a s '

oR # z ? j $ BoH C O m o c.

h U h M..

e ;E 3 :,

n a. . ,

wr M W 4 U1

h -

uW H C O O f4 ts Y

m u&

7--tia>D d

l ec' EO | u

tD U ' Uu o o o N m vW - H @

lh

bM O CD C W GO N

-IH LAW p. ..

O *

8.;

'

O

Y YO O Z~ O O M Ntt M

N

e

o oO O W O O O N N O

& %

* r8-

a

_ ,.--

6> %

%

--meeis

- 8w

-, .

! >Gn.

8.

I w

.

f

... . _ . , -. . . . - . . . ~ . . . . . _ _ _ _ . , .-. . . . . . . ~ , , . - . _ . , , _ ~ . . - , . , . _ , . _ . . _ _ . _ . , , - . . . , _ , . . . . . _ , , , _ . , _ . -._.m. ~ . ...

_ - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

ATTACKMENT 3. .

r

Summary of Data Analysis and Hanagement ActionsCorporate Office and Nuclear Group Headquarters

January - June 1991

1. Initiatives Taken

Sweepn by drug sniffing canines were conducted at the Philadelphia'

Electric Company's (PECo's) corporate office and Nuclear GroupHeadquarters during the period. Reports of these sweeps are notavailable at this time and will be included in the next periodicreport of performanco data.

5

on February 19, 1991, a collection site was established at theNuclear Group Headquarters in Wayne, Pennsylvania. This facilitywas established to reduce the lost-time impact for individuale :

!aelected to participate in the random testing program.

II. Management Actions [

During the period, one (1) PEco employes (follow-up) and one (1) j

applicant tested positive. The applicant who tested positive wasnot hired. The employee testing positive was in the follow-up r

program as a result of two (2) previous positive tests. Unescorted !

access for the individual had previously been denied. The employee '

was subsequently terminated. !I

Two (2) contractor applicants also tested positive and were not !

hired or granted acceec. !

,!

III. Events Reported under lOCFR26.73

A. No events occurred during the period that require reportingunder 10CFR26.73. ;

;'

B. During the period, the following potentially reportable eventswere evaluated as not reportable.

1. During a routine check of training records on January 22,1991, PECo identified that a number of individuals, listedas supervisors, may not have completed either the initialFitness-for-Duty (FFD) Supervisory Training within threemontha o( assignment, or the annual refresher training.

'Immediate notification was made to the Site Support

Managers, Secucity coordinators, and the Nuclear Support '

Manager. Resolution of the issue was accomplished thrcugh ;

the following actions: supervisory designation wasremoved from those not actually performing supervisoryduties; access was temporarily suspended for those i

actually involved in supervisory duties until training was. completed; and in some cases, posting completed training

,

to toe tracking system.

!

i

!

e

.

*w e e. - - .p.w. v.. . . ,%,, . . , ,. , , , . _

.___ __ _ _ _ - _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ - .

.

. .

1-

1

I*

!

2. On February 26, 1991, the contractor performing on-siteimmunoassay screening notified the FFD Coordinator that !

screening the chemical "PCP," had not been completedproperly. The contractor had been using a PCP screen(i.e., Emit-d.a.u.) calibrated at 75 ng/ml as opposed to25 ng/ml. The contractor identified the problem on j

February 22, 1991 and immediately ceased PCP screening i

until the correct calibrator was received from the !

manufacturer (i.e., Syva). Contact with PEco's certified hlaboratory (i.e., DrugScan, Inc.) indicated that Drug Scan {was using the proper scroon. |

!

Investigation revealed that the contractor began using the !Emit d.a.u. calibrator at the Limerick Generating Station !(LGS) on August 21, 1990, and at the-Peach Bottom Atomic jPower-Station (PBAPS) on October 24, 1990, in an attempt >

to ensure consistency between the on-site testing facility -

and the certified lab. Investigation revealed that the |lab supervisors f ailed to recognize the dif ferent :

calibration levels indicated within the literature ;

"secompanying the calibration reagents. [I

.During the period,- the on-site testing facility had icorrectly identified all blind proficiency specimens |

aubmitted. We also noted that one of the quality control j

specimens (i.e., 10% of negative screens) submitted to the f

certified lab'was ider.tified as a falso negative. -

t

!All on-site testing technicians were retrained in the j

' proper methods of calibration reagent preparation and in jfollowing instructions contained in the accompanying j

literature. j

_IV.. Random Testing Rate_ _ _

f.PEco conducts random testing at the annualized ~ rate of-100%. The" average number with unetcorted acceus" includes personnel badged at [both LOS and PBAPS. PEco maintains menarate testing " pools" for i

employees.nnd contractors. I-|

V. Policy Revision [

On April 1, 1991, the company revised its separate Drug and AlcoholPolicies into a single combined Drug and Alcohol Policy and Program. Ii

?t- ,

_ VI . - Action Taken to Improve Program

A. The PEco Human Resources Department is being reorganized. Aspart of this process, the position of FFD Program Manager is ;being established. The FFD Program Manager will have clear )

responsibility for the FFD Program and will report to the [Director, occapctional Health and Safety. [

: >

. . .

|- [

!

!

!-

. _

. . I

.< s

*.

a

D.- All collection site personnsi have been retrained withadditional emphasis placed on attention to details.

C. A separate secured access area has boon established to ensureaccess to test results and random testing lists is restricted.

I

f

i

i

1___ (

f8it

I!iit

:

:

i;

i

ifrIt!

!t

!i

-

i

ItiEI

-

,

-

I,

i?

!

Y

t:1

T

ri

.

--....-s- . ~ . . _ _ _ _ _ _ . . _ . . _ . . _ . ~ _ . ..__,...--_.__--_...__________________.-.-~..-______-..-_.~--.!