L-2013-187, Annual Fitness-For-Duty Program Report - Revised
| ML13189A140 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/13/2013 |
| From: | Katzman E Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Security and Incident Response |
| References | |
| L-2013-187 | |
| Download: ML13189A140 (7) | |
Text
0June 13, 2013 FPL.
L-2013-187 10 CFR 26 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Annual Fitness-For-Duty Program Report - Revised On February 21, 2013, in accordance with 10 CFR 26.717, Florida Power & Light Company (FPL) forwarded FPL letter L-2013-077, fitness-for-duty program performance data for 2012. The purpose of this letter is to provide an updated section of the report; 10 CFR Part 26, Subpart I, Annual Fatigue Results. This correspondence supersedes FPL letter L-2013-077 in its entirety.
During a recent FPL internal audit of the Fitness-for-Duty and Access Program, including work hour controls, it was identified that a number of work hour waivers related to the same emergent plant issue were omitted in the 2012 performance data. The inadvertent omission of data was entered into the St. Lucie corrective action system for evaluation and associated action.
As part of the follow-up actions, attached are the revised forms for the 2012 Annual Fatigue Results. The increased number of waivers being reported did not have an effect on the performance objectives for work hours controls.
This omission was discussed with Mr. Siva Lingham - NRR Project Manager, on May 29, 2013.
Please contact us should you have any questions regarding this submittal.
Sincerely, Eric S. Katzman Licensing Manager St. Lucie Plant ESK/DLC Attachments Florida Power & Ught Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2013-187 Attachments Fitness-For-Duty Program Performance Data (3 pages) 10 CFR Part 26, Subpart I - Annual Fatigue Results (2 pages)
FITNESS FOR DUTY PROGRAM PERFORMANCE DATA Florida Power & Light Co.
Company St. Lucie Nuclear Plant Location 2012 Annual Reporting Period Robert L. Boskey (772) 467-7003 Contact Name Phone Number Cutoffs: Screen/Confirmation (ng/ml) & Alcohol (% BAC)
X 10 CFR 26 Levels identified in Sections 26.103 and 26.163 Testing Results Licensee Employees Contractor Personnel Average number with Unescorted Access 1184 2079 Total: 3282 Categories Tested Positive Tested Positive Follow-Up 34 0
220 1
For Cause -
Observed Behavior 2
0 6
1 For Cause -
Post Event 0
0 8
0 Pre-Access 224 0
2600 8
Random 674 0
1119 4
Total 934 0
3953 14 During the reporting period of 2012, Florida Power & Light Co./St. Lucie Nuclear Plant conducted 4907 drug and alcohol tests in accordance with 10 CFR Part 26. Random test rates are as follows:
Reporting Period POOLS 2012 St. Lucie Nuclear Plant 54.9%
Page 1 of 3 Annual Fitness for Duty Report SY-AA-100-1006-FO1 Rev 0 10/2010
BREAKDOWN OF CONFIRMED POSITIVE TESTS Amphe-Phency-Refusal St. Lucie Nuclear Marijuana Cocaine Opiates tamines clidine Alcohol to Test/
Plant SSubversion Plant__Adulteration Licensee Employees 0
0 0
0 0
0 0
Contractors 1
9 1
1 1
01 1
1 0
141 0
Total 1 9*1 1
101 1"
0 141 0
115
- One individual tested positive for both marijuana and amphetamines Manaaqement Actions For the reporting period of 2012, fourteen (14) individuals were denied unescorted access authorization after testing positive for drugs or alcohol. By test type, one (1) follow-up test was positive, one (1) for cause - observed behavior tests was positive, eight (8) pre-access tests were positive, and four (4) random tests were positive.
Follow-Up Positive Test One (1) contractor employee tested positive for alcohol. The individual was denied access.
For Cause - Observed Behavior Positive Test One (1) contractor employee tested positive for alcohol. The individual was denied access.
Pre-Access Positive Test Four (4) initial contractor employees tested positive for marijuana. One (1) initial contractor employee tested positive for both marijuana and amphetamines. Two (2) reinstatement 31-365 contractor employees tested positive for marijuana. One (1) reinstatement less than 30 day contractor employee who was selected under 26.65(e)(2)(i) requirements tested positive for marijuana. These individuals were denied access.
Random Positive Test Two (2) contractor employees tested positive for alcohol. One (1) contractor employee tested positive for marijuana. One (1) contractor employee tested positive for cocaine.
These individuals were denied access.
Page 2 of 3 Annual Fitness for Duty Report SY-AA-100-1006-FO1 Rev 0 10/2010
Additional Comments
- 1. There were no subversion attempts during the 2012 reporting period.
- 2. One (1) licensee employee tested positive for presence of alcohol. The individual was denied access for failure to meet the requirements of the individual's conditional access agreement.
- 3. Two (2) individuals appealed positive results. In both cases, the positive result was confirmed by the Medical Review Officer based on the result received from the appeal laboratory.
- 4. On June 5, 2012, five (5) specimens were lost in transit to the DHHS Laboratory. The five (5) individuals were retested with negative results. The incident was entered into the site corrective action program.
- 5. On August 28, 2012, five (5) specimens were lost in transit to the DHHS Laboratory.
Four (4) individuals were retested with negative results. The fifth individual was not re-tested as the individual had already been terminated. The industry database was flagged. The incident was entered into the site corrective action program.
- 6. For the 2012 reporting period, all blind specimens submitted to St. Lucie Nuclear Plant's HHS-certified laboratory yielded expected results.
Reportable Events St. Lucie Nuclear Plant had no reportable events as defined in 10 CFR Part 26.719 during this reporting period.
Page 3 of 3 Annual Fitness for Duty Report SY-AA-100-1006-FO1 Rev 0 10/2010
Facility Name R
rtPerid 10 CFR Part 26, Subpart I - Annual Fatigue Results St.
2012 Summary of Waiver Issuance - 26.203(e)(1)(i-ii)
Number of Waivers Issued (Note: At least one of the cells in this table should have a non-negative value)
Operating or on-site directing of the Performing health physics or chemistry Performing duties of a fire bngade Performing maintenance or onsite Performing security operations of systems as described in duties as described in 26.4(a)(2) member, as described in 26.4(a)(3) directing of maintenance, as described in duties as described in 26.4(a)(5)
Work Hour Controls 26.4(a)(1)
Operuting O
Otal Toktoualntol (days 1-6)
(after dlay oa Total60)
Outage tdays Outage (ufter Outage (atter Outage tufter Outage tufter Outage taller Operating 1-60) day 60)
Operating Outage day 60)
Operating Outage day 60)
Operating Outage day 60)
Operating -
Outage day 60)
Exceed 16 work hrs in any Daily Work 24hr period I
I 0
0 Ho rs Exceed 26 work hirs in any 26.205(d)(1) d4 hr perid Exceeded 72 work hrs in any 7 day period 0
0 Less than 10 hr break bit successive work periods (for 8 hr break Rest Breaks accommodating scheduled transition 26.205(d)(2t bit shifts) 0 0
Less than 34 hr break in any 9 day period 0
0 Avg of less than I day off per week for 8-hour shifts while operating 0
0-0 Avg of less than 2 days off per week Minimum for 10-hour shifts while operating 0
y*
o Days Off Per Avg of less than 2.5 days off per Shift Cycle week for 12-hour shifts while 26.205(d)(3) operating Avg of less than 2 days off per week for 12-hour maintenance shifts Avg of less than 3 days off per week, for 12-hour security shifts Less than 3 days off per successive Minimum 1,*day period Days Off for Outage Activities Less than 1 day off per 7-day period 26 205(d)(4) for maintenance personnel and 2ad205(d}t5}
Less than 4 days off per successive
= 15-day period for security personnel 0
Altemate to Minumum Days Off J
26.205(d)(7) 54 hour6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> maximum average TOTALI
' NOTE: For individuals performing fire brigade duties and other duties, please count them only under the fire brigade column. Do not double count these individuals.
I
I 10 CFR Part 26, Subpart I - Annual Fatigue Results I
Facility Name St. Lude Report Period V
2012 V
Distribution of Waiver for Individuals in Each Category - 26.203(e)(1)(iii)
I Number of Employees Issued Waivers Operating or on-Performing Performing Performing site directing of health physics duties of a fire maintenance or Performing the operations or chemistry onsite directing security duties Number of Waivers brigade member o aneac sdsrbdi of systems. as duties as as described in of maintenance as described in described in describedin 26.4(a)(3) as described in 26.4(a)(5) 26.4(a)(1) 26.4(a)(2) 26.4(a)(4) 1 2
3 4
5 6
7 8
9 10 11-20 More than 20 171 Total Number of Employees Issued Waivers 0
0 0
0 101 Most Waivers Provided to a Single individual 3
Note Fo wdtiduaste petfoen*V (he rite brigade duties. ease p
oltntf them o.4 under fre brtgade oolumn. Do not double 0ount these ttdkduafs Summary of Corrective Actions - 26.203(e)(2)
I Analysis of Waiver Assessment Data:
There were 171 Security-duty waivers approved for 101 Security personnel associated with an emergent plant issue in 2012. In January 2012, during the St. Lucie Unit 2 extended power uprate outage, significant degradation of intake cooling water piping was identified.
This led to a plant management decision to grant Security force waivers to mitigate a condition adverse to safety. The work hour limit exceeded was the MDO on-line reports lAW with 10CFR 26.205(d)(3). In order to affect repairs, Security perimeter fencing had to be removed requiring additional Security resources. In addition to other mitigation efforts, the Security force implemented additional fatigue measures during a portion of the waiver period that included post standing watch checks, welfare checks, radio checks and face-to-face FFD checks performed on each of the officers. Fatigue assessments were performed for each waiver in accordance with 26.207(a)(1)(ii).
Analysis of Fatigue Assessment Data:
A review of 2012 fatigue assessments were performed for seven (7) cases of "For Cause". six (6) for Security for "Self Declared" and seventeen (17) for Security for "Post-Event" cases. Each case reviewed identified that apprepriate actions were taken. Eachofthe individuals were performing pre-outage activities at the time of self-declaration or a condition resulting in a fatigue assessment, therefore, no additional management actions resulted from these assessments. Additionally, Face-to-Face assessments were performed for the 171 Security Force waivers granted to support the emergent plant issue related to the degradation of intake cooling water piping.
==
Conclusions:==
There were a total of 171 waivers issued in 2012 related to the same emergent plant issue. In addition to the fatigue assessments that were performed for the 171 waivers for the one-time event, there were seven (7) "For Cause" assessments, six (6) "Self-Declared" assessments, and seventeen (17) "Post Event" assessments. The intake cooling water event discussed above was a one-time unanticipated emergent plant condition in which additional fatigue considerations were provided to the Security force during the waiver period.
Summary of Status of Corrective Actions:
There were no additional corrective actions taken in response to the use of waivers and the conduct of fatigue assessments in 2012.