ML17220A183

Email on Inconsistencies in 2015 Submission (10 CFR 26.717) - Pilgrim

ML17220A183
Person / Time
Site:	Pilgrim
Issue date:	07/19/2016
From:	Draper C Entergy Nuclear Generation Co
To:	Brian Zaleski NRC/NSIR/DPCP/FCTSB
ZALESKI, BRIAN
Shared Package
ML17220A182	List: ML17220A183 ML17220A184 ML17220A185
References
Download: ML17220A183 (2)

Text

Zaleski, Brian From: Draper, Cheryl <cdrape1@entergy.com>

Sent: Tuesday, July 19, 2016 2:51 PM To: Zaleski, Brian

Subject:

[External_Sender] RE: NRC Review - Pilgrim FFD submissions (26.717) - calendar year 2015 [questions]

Attachments: 2015_SPTF_Pilgrim__PNP-2015-12__ML16055A490.pdf; 2015

_SPTF_Pilgrim__PNP-2015-19__ML16055A498.pdf Brian Please see the attached corrected Single Positive forms. Sorry, we got a little confused with the subversion attempts.

Thank you Cheryl Draper Sr. Security Coordinator Pilgrim Station 600 Rocky Hill Road Plymouth, MA 02360 Phone: 508-830-8816 Fax 508-830-8885/8052 From: Zaleski, Brian [1]

Sent: Tuesday, July 19, 2016 10:38 AM To: Draper, Cheryl

Subject:

NRC Review - Pilgrim FFD submissions (26.717) - calendar year 2015 [questions]

EXTERNAL SENDER. DO NOT click links if sender is unknown. DO NOT provide your user ID or password.

Good morning Cheryl, We completed a receipt review of the FFD forms submitted for Pilgrim for calendar year 2015 drug and alcohol test results. This review helps ensure that the docket is correct to support our inspectors and assessment of industry performance.

We have two items we wanted to follow up with you about. Each form referenced in this email is attached for your reference.

Item 1 - Reporting of Substituted Validity Test results (2 subversion attempts). Based on the subversion descriptions provided in each Single Positive Test Form (SPTF), the determination that these individuals subverted the testing process does not appear to be based on a laboratory validity test result of Substituted, instead, each was based on donor action and information collected at the collection site (donor admission to subversion attempt, donor refused to provide a specimen).

Section 26.161(d) describes a substituted validity test result as the following: The laboratory shall report a specimen as substituted when the specimen's creatinine concentration is less than 2 mg/dL and its specific gravity is less than or equal to 1.0010, or equal to or greater than 1.0200, on both the initial and confirmatory creatinine tests (i.e., the same colorimetric test may be used to test both aliquots) and on both the initial and confirmatory specific gravity tests (i.e., a refractometer is used to test both aliquots) on two separate aliquots.

1

PNP201512 Subversion description "specimen provided had a temperature of 104.7, also plastic tubing was observed by collector along the individuals pant line" Subversion attempt checkbox(es):

o Refused to provide second specimen o Specimen temperature (out of range) o Specimen paraphernalia identified

[To more accurately reflect this subversion determination, please change Was this collection refused to Yes, given that the donor refused to provide the second specimen]

PNP201519 Subversion description "SPECIMEN TEMP WAS BELOW RANGE, INDIVIDUAL ADMITTED TO HAVING A BOTTLE OF FAKE URINE TO TRY TO SUBVERT THE TEST" Subversion attempt checkbox(es): Specimen temperature (out of range)

[To more accurately reflect this subversion determination, please change Was this collection refused to Yes, given that the donor admitted to the attempt to subvert the testing process. The donor admitted to having a bottle of fake urine, did they provide that bottle to you? If so, please update the subversion attempt checkbox for specimen paraphernalia identified]

Item 2 - Mismatch in the Reason for Testing reported for each testing event. We compare information in the SPTFs submitted and the summary information in the Annual Reporting Form for Drug and Alcohol Test Results (ARF). We identified the following inconsistencies in the Reason for Testing counts:

27 SPTFs: 17 Preaccess; 5 Random; 0 PostEvent; 5 Followup 27 ARF: 18 Preaccess; 4 Random; 1 PostEvent; 4 Followup (attached is a spreadsheet containing the information from the SPTFs)

[Unclear which information may need to be updated so that the Reason for Testing for each event is consistent between the reports provided.]

To update a form , please select the green Locked button in the lower left hand corner of the form, unlock the form, select the Submission Update checkbox in the upper left hand corner of the form, and make the appropriate corrections. Prior to submission, please ensure that the form is Validated & Locked.

Thanks for taking a look at our questions and I look forward to hearing back from you. Please call or email if you have questions that I can assist you with.

Brian Brian Zaleski l Fitness For Duty Specialist l 301.287.0638l office: 3WFN 8A9l brian.zaleski@nrc.gov U.S. Nuclear Regulatory Commission l Office of Nuclear Security and Incident Response 2