ML20056D144

30-Day Report for Violation of Fitness for Duty Policy in Accordance with 10 CFR 26.185

ML20056D144
Person / Time
Site:	Wolf Creek
Issue date:	02/18/2020
From:	Benham R Wolf Creek
To:	Document Control Desk, Office of Nuclear Security and Incident Response
References
RA 20-0010
Download: ML20056D144 (3)

Text

W$LFCREEK 'NUCLEAR OPERATING CORPORATION

. Ron Benham Manager Nuclear and Regulatory Affairs February 18, 2020 RA 20-0010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket No. 50-482: 30 Day Report for Violation of Fitness For Duty Policy in accordance with 10 CFR 26.185 To Whom It May Concern:

Pursuant to 10 CFR 26.719, "Reporting Requirements," part (c), "Drug and Alcohol Testing Errors," Wolf Creek Nuclear Operating Corporation (WCNOC) is submitting a 30 day report detailing an investigation into a testing error associated with the non-compliance of the WC NOC Fitness for Duty (FFD) Program requirements stated in 10 CFR 26.185, "Determining a fitness-for-duty policy violation."

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4204.

Sincerely, Ron Benham RDB/rlt Attachment cc: S. A. Morris (NRC), w/a N. O'Keefe (NRC), w/a B. K. Singal (NRC), w/a Senior Resident Inspector (NRC), w/a

)OZL

J5!Jf P.O. Box 411 / Burlington, KS 66839 / Phone

(620) 364-8831 An Equal Opportunity Employer M/F/HCNET

Attachment to RA 20-0010 Page 1 of 2 Fitness For Duty Policy Violation Inspection Results Identification of Error:

On December 16, 2019, a Fitness For Duty (FFD) urine test was performed. On December 19, 2019, the urine test was incorrectly determined to be negative by the Medical Review Officer (MRO).

On January 16, 2020, during the Wolf Creek Nuclear Operating Corporation (WCNOC) Vendor Quality Audit #25012 of Coffey County Medical Center a concern was noted by the audit team in review of MRO notes for urine test December 16, 2019-donor. A donor sample was positive for the presence of drugs or drug metabolites, but the result was marked as negative based on a medication prescribed to the donor. It was later determined that the medication prescribed did not break down to the metabolite detected.

Investigation:

A request was made by WCNOC for the MRO to re-evaluate their determination of the urine sample results on the December 16, 2019-donor specimen.

On January 17, 2020 the MRO provided an addendum for December 16, 2019-donor results:

Patient provided a urine drug screen on December 16, 2019 that came back positive of opioids, in particular, codeine. In light of this, the patient was contacted, and they said that they do take hydrocodone and their prescription did check out; however, this does not break down to codeine. Instead, it breaks down to hydromorphone and so this not an acceptable explanation for the positive opioid test. In light of this, this test will be determined as medically positive.

Based on the original specimen result determination of negative, this individual was granted unescorted access on December 19, 2019. On January 20, 2020, WCNOC received the MRO addendum for the December 16, 2019-donor specimen. Upon receipt of this information, this donor's unescorted access was denied. A review of plant access badge reader logs determined the individual entered the protected area once between December 16, 2019 through January 20, 2020. No vital areas were accessed during this entry.

On January 22, 2020, the MRO's qualifications were terminated, and a request was made to Coffey County Medical Center for the MRO to re-qualify as an MRO due to this event.

Cause:

The MRO made an incorrect decision to change the result of a urine drug test from positive to negative based on a what they believed to be a legitimate medical explanation. The break down of the prescription was incorrectly determined by the MRO. During the investigation, an opportunity for improvement was identified for WCNOC to strengthen the program when medically negative results are identified by the MRO.

Attachment to RA 20-0010 Page 2 of 2 Corrective Actions:

• MRO qualifications were terminated. Training and re-qualification was requested by the licensee.

• Unescorted access was denied for the donor of the December 16, 2019-donor specimen due to a positive FFD test result.

• A process will be implemented between WCNOC and the MRO for the reporting of non-negative FFD test results indications.

• For extent of condition, a review was performed of the last two years FFD test results.

This two year period covers the timeframe since the last audit.

• New requirements will be added to the MRO checklists as follows:

1) A face-to-face meeting will occur between the MRO and the individual when the FFD test result returned is positive for opiates.

2) A verification will ,be required by a second MRO to confirm the *medically non-negative break down is accurately classified as positive or negative.

3) A medical synopsis will be sent to the licensee for all non-negative FFD results that are deemed possible misuse or abuse of prescription drugs.