ML20114C142
| ML20114C142 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/24/1992 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NSD920617, NUDOCS 9209010237 | |
| Download: ML20114C142 (9) | |
Text
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i GENERALOFHCE 4
P O DOW 499. COLUMBU$, NCBRASKA fMiObO4D9 I
Nebraska Public Power District "WEPs%**
. swnnmmmmmewwweamemassem~==~~www==mmw~waw==uauman NSD920617 August 24, 1992 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk l
Washington, D. C. 20555 Centlemen:
Subject:
Semi annual Fitness For Duty Performance Report and Corrections to 1991 Reports Cooper Nuclear Station-NRC Docket 50 298, DPR 46
References:
-1.
Letter form C. R. Horn (NPPD) to NRC dated August 14, 1991,
" Semi-annual Fitness For-Duty Performance Report" 2.
Letter = form C. R. Horn To NRC Dated January 28, 1992, " Semi-annual-Fitness +For Duty Performance Report" In accordance with the Provisions of 10 CFR 26.71(d).. attached is the Nebraska Public Power District's (DJstrict's) Fitness-For Duty (FFD) program semi-annual performance report for the period January 1, 1992 - June 30, 1992.
This report has been prepared using the January,1992 NUMARC form and accompanying instructions, In addition, -attached are corrected versions of the semi-annual FFD Performance Reports for the periods January 1,1991 June 30,1991, and July 1 1991 - December' 31, 1991. These reports were transmitted to the NRC previously by letters dated August 14,1991 (Reference 1) and January 28, 1992 (Reference 2) respectively, in accoroance with 10 CFR 26.71(d). However,
-during a recent internal Quality Assurance Department audit, the District identified errors in the reported data.
Therefore, the District is transmitting the attached corrected FFD Performance reports for your information and in accordance with 10 CFR 50.9, " Completeness and Accuracy of
'Information."
During'the District's Quality Assurance Department audit, the District identified a deficiency in its-FFD test-type accounting methods which led to
--inaccurately reporting three tests as "For Cause" in-the FFD Performance Report for the siemonth period ending June 30, 1991, submitted to the NRC-
.with Reference-1. The District determined.that the three drug tests reported
-as "For Cause" tests in the Reference 2 report were actually "MRO retests."
The-District's FFD procedures allow the Medical Review Officer (MRO) to request a retest-if initial test results indicate that the specimen collected Vy 9209010237 920824 A
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' U. S, Nuclear Regulatory Commission f
August 24, 1992 Page 2 of 3 i
could have been potentially adulterated, e.g., the specimen had low specific gravity or creatine levels.
In such instances, at the discretion of the District's MRO, a retest may be ordered, requiring the collection of an additional specimen.
The District has revised its applicable FFD program administrative procedure to add a unique identifying code for "MRO retests,"
and the District now includes "MRO retests" in the "Other" test category.
The
- corrected FFD performance data report for the period January 1,1991 - June 30, 1991-is attached.
For the performance report submitted with Reference 2 (six month period ending December 31, 1991), the District identified three positive test results that were erroneously reported as Short Term Contractor "For cause" tests; these positive tests. vere actually " Pre Badging" positive tests.
These test results were incorrectly reported as "For Cause" tests because three contractors undergoing initial access training were directed to report to the site i
collection facility as they were saspected of being under the influence of a substance. ' Although these individuals tested _ positive, it was determined that E
these test results hould have been categorized as " Pre-Badging" test results,
- as the three individuals had not, as of that time, been granted unescorted access.. Therefore, the attached corrected report for the reporting period July'1, 1991 - December 31, 1991 accurately reflects one "For-Cause" positive test result for Short Term Contractor Personnel in lieu of four, and twelve
" Pre Badging" positive test results for Short Term Contractor Personnel in lieu of nine. The District believes that this reporting error was a one-time occurrence, and with recent internal communications which have stressed the
- importance of accurate test result accounting, the District is confident that this error.will.not recur.
The July 1, 1991 - December 31, 1991 report also erroneously reported a
. positive "For Cause"-test for a licensen' employee. This "For Cause" test was actually_ administered to a ' District employee who does not possess unescorted 4
access-to Cooper Nuclear-Station; this' employee was tested under the.
- District's broader FFD program, and should not have been' reported-to the NRC under 10 CFR 26.71(d);.
Since the District does require certain other company
-employees not associated with.its nuclear program to submit to the District's FFD program, the District will revise its FFD administrative procedures to add t
- a unique identifying code to the tracking number for such tests, which will preclude ~ future reporting of non nuclear test results.
This item also contributed to an extra alcohol positive test result-reported on page two'of the July 1,1991 December.31,1991 report. - Therefore, the attached corrected report accurately identifies zero For-Cause tests conducted for licensee employees, and "three" positive alcohol tests in lieu of "four."
In addition, following the aforementioned Quality Assurance Department audit,.
the. District conducted further review -of-the drug-test data reported for the-two. reporting periods in 1991. - This review determined that while the numbers and types-of. positive test results reported were correct on the July 1,1991 -
December 31, 1991.tegort except as: qualified above, the actual numbers of tests administare?.wera inro: rect. Accordingly, these numbers have-been revised on the attached sorrected report.
The District has determined that i
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4 U. S. Nuclear Regulatory Commission August 24, 1992 Page 3 of 3 these errors resulted from a large FFD program administration staff turnover which occurred during this time frame, compounded by a lack of detailed guidance in the FFD administrative procedures for preparing the performance reports.
Therefore, the District is revising its FFD administ.rative procedures to provide better guidance for preparing the FFD Performance Data i
reports. Accordingly, the District is confident that future FFD performance Data reports will be accurate in all material respects.
Pleasc contact me if you have any questions on the above or the attached, or if you require any additional information.
Sincfrel b
G.
llorn Nuc ear Power Group Hanager At tac}unents cc: NRC Regional Administrator
-Region IV Arlington, TX NRC Resident Inspector Cooper Nuclear Stat. ion 4
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l Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 i
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k Nebraska Public Power District June 30, 1992 l
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Cooper !!uelear Station P.O. Box 98. Brevnville. fiebraska 68371 immeon Deborah A. Jones, Fitness for Duty Technician Corporate Security Departrnent (402) 825-5698 comact Name Phone enctuoe eroe cose)
Cutoff s: ScreerVConfirmation (nyml)
Q Appendix A to 10CFR 26 8
00 / 200 Marijuana
-100 /
15 Amphetamines -
1000 / 500 B"*
di'* "i"*'
/
Cocaine 300 / 150 Phencyclidine 25 / 25-300 300 Propo m hen
. Alcohol (% BAC)
,ogg 300 /
Opiates 300 300 200 Long-Term Short. Term Testing Results t.icensee Employees Contracter Personnel Contractor Personnel-Average Number wat.
Unesconec Access 644 78 176 Categories Tested Postuve Tested Posnive
- %sted Positive Pre Access' 28 0
0 0
43 0
3 Post accident 0
0 0
0 0
0 e
n L
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500 0
80 0
59 0
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0 0
0 0
0 i
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0 0
0 1
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0 103 0
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[ Total 1.
REv.1/92
SUtitiARY OF liANAGDIEllT ACT10!iS To date for 1997, the District implemented the following measures to enhance the overall effectiveness of it's program.
The measures are as follows:
(1)
Identified the NIDA minimum requirements of 30 milliliters for the urine specimen test to eliminate unnecessary employee delays during the drug screening process. This also maintains minimium tenting levels required by the drug ter ting f acility.
(2)
Etiminated unnecessary administrative delays during the breath alcohol testing.
(3)
Identified a more accurate tracking methodology by using a person's Social Security Number versus an administrative directed file number.
SUMMARY
OF EVENTS There were no evento during this time period that were reportable under 10 CFR, Part 26.73.
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Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 Nebraska Public Power District June 30, 1991 c,vneany a w reteorg Cooper Nuclear Station, Brovnville, Nebraska 68321 umm JaNay Oestmann - Lead Fitness For Duty Analyst Corporate Security Department (402) 825-5596 contact Name N= omuo. area axm Cutoff s: Screen / Confirmation (nyml)
G Appendix A to 10CFR 26 Manjuana 100 / 15 Ampnetamines 1000 / 500 Barbiturate' 300 / 200 Cocaine PhencycliGine
/
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- 300 150 25 25 300 / 300 Cpiates -
/
Alcohol (% BAC)
.047.
Propoxyphene 300 / 200 l
300 300 Long Term -
Shen Term Testing Results Contractor Contractor Licensee Employees Personnel Personnel Average Numcerwah j j
[
Unescorted Access 1
624 80
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12 0
49 0
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Fitness for Duty Program Performance Data Personnel Subject to 10CFR 26 Nebraska Public Power District December 31, 1991 c=oey a w new Enors Cooper Nuclear Station lirownville, Nebraska 68321 i
Locamen 1
Deborah A. Jones, Fitness for Duty Technician l
Corporate Security Department (402) 825-5698 canwame s* = tra m =+e mo.>-
Cutoffs: ScreervConfirmation (ng/mi)
'3 Appendix A to 10CFR 26 Manjuana 100 / 15 Amphetamines 1000 / 500 f
Barbituates Cocaine
/
Phencyc!! dine 300 150 25 25 300 / ?00 Opiates 0
300 300 300 200 Long Term Short Term Testing Results Contrac:or Contractor Licensee Employees Personnel Personnel Average Numoer wrth Unesconed Access 707 42 560 y
Referred Access Categories.
Tested Pernive to EAP Restored Tested Posnive Tested Pos:tive Pre employment
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u Pre badging 94 i
0 2
10 0
813 12 T
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0 0
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0 0
0 0
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60 0
I 156 0
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! Total 579 0.
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