ML17265A555
| ML17265A555 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/25/1999 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9903050032 | |
| Download: ML17265A555 (5) | |
Text
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SUBJECT:
Informs that util is in process of revising fitness-for-duty program, developed in accordance with 10CFR26.Uitl will continue to use Dept of Health
&, Huam Svcs certified test facility for majority of tests during yr.
DISTRIBUTION CODE: A021D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: "Semiannual Fitness for Duty Program Performance Rept/Data" 10CFR26.7@
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NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
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. al REGULATORY INFORMATION DZSTRIBUTZ N SYSTEM (RIDS)
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ACCESSION NBR:9903050032 DOC.DATE: 99/02/25 NOTARIZED: NO DOCKET ¹ FACIL:50@44 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH:NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas 8 Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S.
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N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DZSTR1BUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:
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ANO ROCHESTER GAS ANDELECTRIC CORPORATION.89 EASTAVENUE, ROCHESTER, N.Y. 14649-0001 AREA CODE 716-546-2700 ROBERT C. MECREDY Vice President Nudeor Operotions February 25, 1999 U.S. Nuclear Regulatory Commission Document Control Desk, Attn:
Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555
Subject:
Proposed revision to 10 C.F.R. Part 26 Fitness-for-Duty Program
Dear Mr. Vissing:
RG&E is in the process ofrevising our Fitness-for-Duty Program, developed in accordance with 10 C.F.R. Part 26. One change we are contemplating would be to utilize, in very limited cases, the Niagara Mohawk Power Corporation drug testing facility, located at the Nine MilePoint Unit 2 site, to perform initial screening tests for drugs for contractors who would be working at our Ginna facility. We believe that such change would bring significant benefits, and our use ofthat facilityfor that purpose would not be inconsistent with the governing NRC regulations. This would be used only prior to and during refueling outages, when a large number ofpersonnel would need to be tested in a short time period. We would continue to use a Department ofHealth and Human Services certified test facilityfor the majority ofour tests during the year.
Appendix AofPart 26 defines "licensee's test facility" as a "drug testing facilityoperated by the licensee...to perform the initial testing ofurine samples...."
Since RG&E is a licensee ofNine MilePoint g
1 Unit 2, we believe this definition should be interpreted to include RG&E. Paragraph 26.24(d) (2) and 26.24ift refer to onsite testing for the initial screening tests.
Since RG42E is a licensee ofNine Mile Point Unit 2, it should also be considered that the Nine MilePoint site is also an RG&E site. As discussed below, by virtue ofthe geographic proximityofthe sites and because ofthe arrangements for direct delivery ofthe sample to the laboratory, we believe the situation is analogous to one permitted by the regulations,~e, the use ofmultiple collection sites and analysis ofsamples collected at such locations at an onsite laboratory.
There are significant safety and economic benefits associated with this proposed change to RG&E's Fitness-for-Duty Program. Currently, urine specimens are collected at the Ginna site, prepared for transportation, and delivered to an airport for transportation to a laboratory in Minnesota. In Minnesota, the specimens are off-loaded and transported to an HHS-certified drug testing laboratory, which conducts initial screening and confirmatory testing.
This process results in a delay between the collection ofa urine sample and notification ofboth an initial screening positive and a confirmed positive or a negative. This delay can be approximately three days.
During this time, RG&E must escort all workers until the results ofthe drug test are received. This results in an inefficient use ofcontractor and licensee resources.
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Under the contemplated changes, urine specimens willstill be collected at the Ginna site under existing
'procedures; however, they willthen be transported directly by courier to the Nine MilePoint Unit 2 site (which is approximately 65 miles from Ginna Station) for initial screening.
Screening results can be available the same day as the test, often within hours.
Specimens which screen positive willthen be sent to an HHS-certified drug testing laboratory for a repeat ofthe screening and further confirmatory testing, consistent withNRC requirements.
Use ofsuch a revised process willresult in several benefits. Positive initial screening results can be known the same day, allowing RG&E to remove from normal duties and deny unescorted access to a person who has a positive result from the initial screening for marijuana or cocaine.
This willensure that persons who fail drug tests are more promptly removed from the site. The improved turnaround time for test results willalso reduce the inefficiency associated with the requirement for escorts.
RG&E previously provided a technical expert to participate in an audit ofthe Niagara Mohawk Power Corporation Fitness-for-Duty Program.
The scope ofthis audit included the Niagara Mohawk onsite program and onsite testing facility. This audit concluded that the Niagara Mohawk program complies with the requirements of 10 C.F.R. Part 26. Prior to RG&E's use ofthe Niagara Mohawk facilityfor initial screening tests, RG&E would conduct an external audit ofthe Niagara Mohawk drug testing facility. In addition, the Niagara Mohawk facilitywould conform to the requirements ofparagraph 2.8(e) ofSubpart B ofAppendix A to 10 C.F.R. Part 26, and would increase the total number ofsamples sent to the HHS-certified laboratory per these requirements.
Although RG&E believes that use ofthe Nine MilePoint Unit 2 drug testing facilityto screen personnnel who willbe working for RG&E at the Ginna site is permissible and warranted for the reasons cited above, we understand that such use has not occurred in the nuclear industry. We are therefore interested in obtaining NRC concurrence that such use would be consistent with 10 C.F.R. Part 26.
Very truly yours, Robert C. Mecredy XC:
Mr. Guy S. Vissing (Mail Stop 14B2)
Project Directorate I-1 Division ofReactor Projects - MI Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King ofPrussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector