ML020710704
| ML020710704 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 02/27/2002 |
| From: | Gallagher M Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| FOIA/PA-2003-0351 | |
| Download: ML020710704 (17) | |
Text
ExelIn.
Exelon Nuclear www.exelonCOTp.COM Nucear 2oo Exelon Way Kennett Square, PA 19348 1 OCFR26.71 (d)
February 27, 2002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 & 3 Facility Operating License Nos. DPR-44 and 56 Docket Nos. 50-277 and 50-278 Limerick Generating Station, Units 1 & 2 Facility Operating License Nos. NPF-39 and 85 Docket Nos. 50-352 and 50-353
Subject:
Fitness-for-Duty Program Performance Data for the Period July 2001 through December 2001
Dear Sir/Madam:
As required by 10CFR26.71 (d), this letter submits the performance data for Exelon's Fitness for-Duty (FFD) Program for the period July 2001 through December 2001. The data for our Peach Bottom Atomic Power Station (PBAPS), Units 2 & 3, and Limerick Generating Station (LGS), Units 1 & 2, sites are provided in Attachments 1 and 2. Data for our Corporate Office and Mid-Atlantic Regional Operating Group Headquarters specimen collection sites (i.e., 2301 Market Street, Philadelphia, PA, and Kennett Square, PA, respectively) are provided in.
The data is 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 includes 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).
Substances identified.
Fitness for Duty Performance Data February 27, 2002 Page 2 Attachments 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 no significant FFD events reported.
If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, M. P. Gallagher Director - Licensing Mid-Atlantic Regional Operating Group Attachments cc:
H. J. Miller, Administrator, Region I, USNRC (w/attachment)
A. L. Burritt, USNRC Senior Resident Inspector, LGS (w/attachment)
A. C. McMurtray, USNRC Senior Resident Inspector, PBAPS (w/attachment)
Peach Bottom Atomic Power Station Units 2 and 3 Fitness-For-Duty Performance Data July 2001 through December 2001
FITNESS FOR DUTY PERFORMANCE DATA PERSONNEL SUBJECT TO 10 CFR 26 Exelon Nuclear Company Peach Bottom Atomic Power Station Location December 31, 2001 Six Months Ending Dolly Adams Contact Name 610-765-5014 Phone (include area code)
Screen/Confirmation (ng/ml)
I-- Appendix A to 10 CFR 26 Marijuana 50/15 Amphetamines 1000 / 500 Cocaine 300 / 150 Phencyclidine Opiates 300 / 300 Alcohol (% BAC)
Average Number with Unescorted Access Pre-Access 16 25/25 0.04 1961 0
1679
/
/
755 32 9
0 3
0 o
Post accident S2 0
5 2
M Observed behavior Random 161 0
99 1
Follow-up 36 0
30 0
Other 1
0 0
0 Total 225 0
1816 35 Cutoffs:
Breakdown of Confirmed Positive Tests for Specific Substances:
Peach Bottom Atomic Power Station -- July 1 - December 31, 2001 Marijuana Cocaine Opiates Amphe-Phency-Alcohol Refusal tamines clidine To Test Licensee Employees 0
0 0
0 0
0 0
Long -Term Contractors 0
0 0
0 0
0 0
Short -Term Contractors 20 12 2
0 0
2 2*
A Total 20 12 2
0 0
2 2
38**
- Includes an adulterated specimen One individual tested positive for more than one substance Summary of Data Analysis and Management Actions Peach Bottom Atomic Power Station July - December 2001
- 1.
Initiatives Taken The new Exelon Fitness For Duty procedures for the MAROG went into effect on August 17, 2001.
1I.
Management Actions During the period, thirty-five (35) contractor employees (i.e., thirty-two (32) pre-access, two (2) for-cause and one (1) random) tested positive at PBAPS. In accordance with company policy, the thirty-five (35) contractor employees were denied unescorted access. One (1) pre-access employee refused a test and subsequently, in accordance with company policy, was also denied access.
Ill.
Events Reported Under 10 CFR 26.73 There were no significant FFD events reported by PBAPS during the period.
IV.
Audits/Inspections During the period, an assessment to evaluate the Fitness For Duty program was conducted by Nuclear Oversight personnel. The assessment found that the Exelon FFD program is and remains strong in accordance with 10 CFR Part 26.
There were no findings generated during the period.
There were five (5) Condition Report (CRs) generated during the assessment period.
- 1.
CR 74737 - New Exelon FFD procedures do not address all the aspects of the testing process including but not limited to specimen collection and alcohol testing. There was no change in the procedure. The contractor utilizes a standard protocol for drug/alcohol testing. There was no impact of the FFD testing activities that were performed.
- 2.
CR 74316 - The FFD Collection Person (CP) was not familiar with the newly issued Exelon FFD program procedures and policies. Based upon a review of the individual's qualifications and a review of the collection activities performed, it was determined that the individual was performing the collection and alcohol testing activities satisfactorily.
- 3.
CR 75854 - FFD Drug Testing Quality Control procedure does not state the minimum percent of the work force population which is to be tested. A review of the FFD performance indicators for Limerick, Kennett Square and Peach Bottom determined that Exelon is testing a minimum of 50% of the work force population; however, the requirement was inadvertently deleted from the new procedure.
- 4.
CR 76777 - Exelon FFD procedure no. SY-MA-102-226 "Drug Testing Quality Control Procedure" does not address the frequency of submitting blind specimens to be tested to the HHS certified laboratory.
Nuclear Oversight (NOS) verified that the In-Processor/FFD is submitting blind test specimens to DrugScan on a quarterly basis and records are being maintained which support the frequency and control over blind specimens.
- 5.
CR 74316 - Exelon's Medical Review Officer (MRO) was not provided with the new Exelon Medical Review Requirements procedure in a timely manner. NOS compared the previous PECO MRO procedure responsibilities with the new procedure and determined that the requirements and reporting responsibilities have not changed. There was no impact of the MRO's activities being performed.
(continued)
V.
Random Testing Rate Exelon Nuclear MAROG Corporate Office, LGS and PBAPS maintain 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. Actual random testing during the period equaled an annualized rate of 50.8% for employees and 51.1 % for contractors.
VI.
Additional information Actions Taken based upon Unconfirmed On-site Screening The Peach Bottom and Limerick sites have decided to temporarily suspend access for individuals as permitted by 10 CFR 26.24(d).
During the previous 6-month reporting period, i.e., January - June 2001, 100 percent of the specimens identified as presumptive 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 specimens identified as presumptive positive for marijuana was 85.7%. Therefore, according to the rule, action could be taken during the current reporting period on specimens identified as presumptive positive for cocaine and marijuana.
During the current reporting period, i.e., July-December 2001, twelve (12) specimens were reported as presumptive positive for cocaine as a result of on-site screening at PBAPS and/or LGS. The twelve (12) specimens screened positive and were confirmed as positive by the HHS-certified laboratory. The Medical Review Officer verified the twelve (12) specimens as positive. Of the twelve (12) specimens reported as presumptive positive as a result of on-site screening, one (1) was for-cause testing and eleven (11) were for pre-access testing.
Unescorted access was temporarily suspended in the case of one (1) Exelon individual pending confirmation and Medical Review Officer verification. Unescorted access was subsequently denied once the Medical Review Officer verification was received. The Exelon employee's unescorted access was suspended and the employee referred for treatment/rehabilitation.
During the current reporting period, i.e., July - December 2001, twenty-four (24) specimens were reported as presumptive positive for marijuana as a result of on-site screening at PBAPS and/or LGS. Twenty-two (22) of those specimens screened positive and were confirmed as positive by the HHS-certified laboratory. In addition, one (1) contractor specimen reported as a suspected adulteration was reported as adulterated by the HHS certified laboratory.) The MRO verified twenty-two (22) specimens as positive. Unescorted access was temporarily suspended in the case of one (1) Exelon individual pending confirmation and Medical Review Officer verification. Unescorted access was subsequently denied once the Medical Review Officer verification was received. The Exelon employee's unescorted access was suspended and the employee referred for treatment/rehabilitation.
Reduced Mariiuana Cut-off Level During the period, there were twenty (20) confirmed positive tests for marijuana at PBAPS. It is estimated that only one of the specimens would have tested positive using the 100 ng/ml immunoassay cut-off level.
Limerick Generating Station Units 1 and 2 Fitness-For-Duty Performance Data July 2001 through December 2001
FITNESS FOR DUTY PERFORMANCE DATA PERSONNEL SUBJECT TO 10 CFR 26 Exelon Nuclear Company Limerick Generatingq Station Location Dolly Adams Contact Name December 31. 2001 Six Months Ending 610-765-5014 Phone (include area code)
Screen/Confirmation (ng/ml)
FD AppendixAto 10 CFR 26 Marijuana 50/15 Amphetamines 1000 / 500 Cocaine 300 / 150 Phencyclidine Opiates 300 / 300 Alcohol (% BAC)
Average Number with Unescorted Access Pre-Access 33 25/25 0.04 1961 0
/
/
755 127 1
S1 0
8 0
0 Post accident C) 4 0
2 0
~
Observed behavior Random 212 0
78 0
Follow-up 27 1
10 0
Other 13 0
3 0
Total 290 1
228 1
Cutoffs:
Breakdown of Confirmed Positive Tests for Specific Substances:
Limerick Generating Station -- July 1 - December 31, 2001 Marijuana Cocaine Opiates Amphe-Phency-Alcohol Refusal Tamines clidine To Test Licensee Employees 1
0 0
0 0
0 0
Long -Term Contractors 0
0 0
0 0
0 0
Short -Term Contractors 1
0 0
0 0
0 1
- A Total 2
0 0
0 0
0 1
3
- Includes an adulterated specimen.
Summary of Data Analysis and Management Actions Limerick Generating Station July - December 2001 Initiatives Taken The new Exelon Fitness For Duty procedures for the MAROG went into effect on August 17, 2001.
II.
Management Actions During the period, one (1) contractor employee and one (1) Exelon employee tested positive at LGS. In accordance with company policy, the contractor employee was denied unescorted access. Unescorted access was temporarily suspended in the case of the one (1) Exelon individual pending confirmation and Medical Review Officer verification. Unescorted access was subsequently denied once the Medical Review Officer verification was received. The Exelon employee's unescorted access was suspended and the employee referred for treatment/rehabilitation. (In addition, one (1) contractor specimen reported as presumptive positive for marijuana was reported as adulterated by the HHS-certified laboratory.)
Ill.
Events Reported Under 10 CFR 26.73 There were no significant FFD events reported by LGS during the period.
IV.
Audits/Inspections During the period, an assessment to evaluate the Fitness For Duty program was conducted by Nuclear Oversight personnel. The assessment found that the Exelon FFD program is and remains strong in accordance with 10 CFR Part 26.
There were no findings generated during the period.
There were five (5) Condition Reports (CRs) generated during the assessment period.
- 1.
CR 74737 - New Exelon FFD procedures do not address all the aspects of the testing process including but not limited to specimen collection and alcohol testing. There was no change in the procedure. The contractor utilizes a standard protocol for drug/alcohol testing. There was no impact of the FFD testing activities that were performed.
- 2.
CR 74316 - The FFD Collection Person (CP) was not familiar with the newly issued Exelon FFD program procedures and policies. Based upon a review of the individual's qualifications and a review of the collection activities performed, it was determined that the individual was performing the collection and alcohol testing activities satisfactorily.
- 3.
CR 75854 - FFD Drug Testing Quality Control procedure does not state the minimum percent of the work force population which is to be tested. A review of the FFD performance indicators for Limerick, Kennett Square and Peach Bottom determined that Exelon is testing a minimum of 50% of the work force population; however, the requirement was inadvertently deleted from the new procedure.
- 4.
CR 76777 - Exelon FFD procedure no. SY-MA-102-226 "Drug Testing Quality Control Procedure" does not address the frequency of submitting blind specimens to be tested to the HHS certified laboratory.
Nuclear Oversight (NOS) verified that the In-Processor/FFD is submitting blind test specimens to DrugScan on a quarterly basis and records are being maintained which support the frequency and control over blind specimens.
- 5.
CR 74316 - Exelon's Medical Review Officer (MRO) was not provided with the new Exelon Medical Review Requirements procedure in a timely manner. NOS compared the previous PECO MRO procedure responsibilities with the new procedure and determined that the requirements and reporting responsibilities have not changed. There was no impact of the MRO's activities being performed.
(continued)
V.
Random Testing Rate Exelon Nuclear MAROG Corporate Office, LGS and PBAPS maintain 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. Actual random testing during the period equaled an annualized rate of 50.8% for employees and 51.1% for contractors.
VI.
Additional information Actions Taken based upon Unconfirmed On-site Screening The Peach Bottom and Limerick sites have decided to temporarily suspend access for individuals as permitted by 10 CFR 26.24(d).
During the previous 6-month reporting period, i.e., January - June 2001, 100 percent of the specimens identified as presumptive 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 specimens identified as presumptive positive for marijuana was 85.7%. Therefore, according to the rule, action could be taken during the current reporting period on specimens identified as presumptive positive for cocaine and marijuana.
During the current reporting period, i.e., July - December 2001, twelve (12) specimens were reported as presumptive positive for cocaine as a result of on-site screening at PBAPS and/or LGS. The twelve (12) specimens screened positive and were confirmed as positive by the HHS-certified laboratory. The Medical Review Officer verified the twelve (12) specimens as positive. Of the twelve (12) specimens reported as presumptive positive as a result of on-site screening, one (1) was for-cause testing and eleven (11) were for pre-access testing.
Unescorted access was temporarily suspended in the case of one (1) Exelon employee pending confirmation and Medical Review Officer verification. Unescorted access was subsequently denied once the Medical Review Officer verification was received. The Exelon employee's unescorted access was suspended and the employee referred for treatment/rehabilitation.
During the current reporting period, i.e., July - December 2001, twenty-four (24) specimens were reported as presumptive positive for marijuana as a result of on-site screening at PBAPS and/or LGS. Twenty-two (22) of those specimens screened positive and were confirmed as positive by the HHS-certified laboratory. In addition, one (1) contractor specimen reported as a suspected adulteration was reported as adulterated by the HHS certified laboratory.) The MRO verified twenty-two (22) specimens as positive. Unescorted access was temporarily suspended in the case of one (1) Exelon employee pending confirmation and Medical Review Officer verification. Unescorted access was subsequently denied once the Medical Review Officer verification was received. The Exelon employee's unescorted access was suspended and the employee referred for treatment/rehabilitation.
Reduced Mariiuana Cut-off Level During the period, there were two (2) confirmed positive tests for marijuana at LGS. It is estimated that none of the specimens would have tested positive using the 100 ng/ml immunoassay cut-off level.
Mid-Atlantic Regional Operating Group Headquarters (Kennett Square)
And Corporate (2301 Market Street, Philadelphia, PA)
Fitness-For-Duty Performance Data July 2001 through December 2001
FITNESS FOR DUTY PERFORMANCE DATA PERSONNEL SUBJECT TO 10 CFR 26 Exelon Nuclear Company December 31, 2001 Six Months Ending Corporate and Mid-Atlantic Reaional Ooeratina Group Headauarters Dolly Adams Cutoffs:
Marijuana Cocaine Opiates Location Contact Name Screen/Confirmation (ng/ml) 50/15 Amphetamines 300 / 150 Phencyclidine 300 / 300 Alcohol (% BAC) 610-765-5014 Phone (include area code)
D 1000/500 25/25 0.04 Average Number with Unescorted 1961 Access Pre-Access 4
0 Appendix A to 10 CFR 26
/
/
/
755 251 0
0 0
0 0
0 Post accident 1
0 0
0
,rz Observed behavior Random 75 1
4 0
Follow-up 8
0 0
0 Other 1
0 0
0 Total 89 1
255 0
Breakdown of Confirmed Positive Tests for Specific Substances:
Corporate and Mid-Atlantic Regional Operating Group Headquarters -- July 1 - December 31, 2001 Marijuana Cocaine Opiates Amphe-Phency-Alcohol Refusal tamines clidine To Test Licensee Employees 0
1 0
0 0
0 0
Long -Term Contractors 0
0 0
0 0
0 0
Short -Term Contractors 0
0 0
0 0
0 0
Total 0
1 0
0 0
0 0
A Summary of Data Analysis and Management Actions Corporate and Mid-Atlantic ROG Headquarters July - December 2001 Initiatives Taken The new Exelon Fitness For Duty procedures for the MAROG went into effect on August 17, 2001.
II.
Management Actions There was one (1)
Ill.
Events Reported Under 10 CFR 26.73 There were no significant FFD events reported by the Corporate and Mid-Atlantic ROG Headquarters during the period.
IV.
Audits/Inspections During the period, an assessment to evaluate the Fitness For Duty program was conducted by Nuclear Oversight personnel. The assessment found that the Exelon FFD program is and remains strong in accordance with 10 CFR Part 26.
There were no findings generated during the period.
There were five (5) Condition Reports (CRs) generated during the assessment period.
- 1.
CR 74737 - New Exelon FFD procedures do not address all the aspects of the testing process including but not limited to specimen collection and alcohol testing. There was no change in the procedure. The contractor utilizes a standard protocol for drug/alcohol testing. There was no impact of the FFD testing activities that were performed.
- 2.
CR 74316 - The FFD Collection Person (CP) was not familiar with the newly issued Exelon FFD program procedures and policies. Based upon a review of the individual's qualifications and a review of the collection activities performed, it was determined that the individual was performing the collection and alcohol testing activities satisfactorily.
- 3.
CR 75854 - FFD Drug Testing Quality Control procedure does not state the minimum percent of the work force population which is to be tested. A review of the FFD performance indicators for Limerick, Kennett Square and Peach Bottom determined that Exelon is testing a minimum of 50% of the work force population; however, the requirement was inadvertently deleted from the new procedure.
- 4.
CR 76777 - Exelon FFD procedure no. SY-MA-102-226 "Drug Testing Quality Control Procedure" does not address the frequency of submitting blind specimens to be tested to the HHS certified laboratory.
Nuclear Oversight (NOS) verified that the In-Processor/FFD is submitting blind test specimens to DrugScan on a quarterly basis and records are being maintained which support the frequency and control over blind specimens.
- 5.
CR 74316 - Exelon's Medical Review Officer (MRO) was not provided with the new Exelon Medical Review Requirements procedure in a timely manner. NOS compared the previous PECO MRO procedure responsibilities with the new procedure and determined that the requirements and reporting responsibilities have not changed. There was no impact of the MRO's activities being performed.
(continued)
V.
Random Testinq Rate Exelon Nuclear MAROG Corporate Office, LGS and PBAPS maintain 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. Actual random testing during the period equaled an annualized rate of 50.8% for employees and 51.1 % for contractors.
VI.
Additional information Actions Taken based upon Unconfirmed On-site Screening Specimens collected at the Corporate and Mid-Atlantic ROG Headquarters are forwarded directly to the HHS certified laboratory for testing. On-site screening is not performed.
Reduced Marijuana Cut-off Level There were no confirmed positive tests for marijuana at Corporate and Mid-Atlantic ROG Headquarters during the period.