ML20154Q257
| ML20154Q257 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/19/1998 |
| From: | Zwolinski J NRC (Affiliation Not Assigned) |
| To: | Keenan J CAROLINA POWER & LIGHT CO. |
| References | |
| TAC-M99047, NUDOCS 9810230184 | |
| Download: ML20154Q257 (5) | |
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Mr. J. S. Keenan, Vice President Carolina Power & Light Company Brunswick Steam Electric Plant Post Office Box 10429 Southport, North Carolina 28461
SUBJECT:
FITNESS FOR DUTY TESTING UNDER UNIQUE MEDICAL CONDITION -
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 (TAC NO. M99047)
Dear Mr. Keenan:
This is in response to Carolina Power & Light Company's (CP&L's) letter of May 15,1997, proposing, for a specific employee, the use of blood analysis as an alternative to urinalysis in the fitness-for-duty (FFD) evaluation process. The proposal addresses a situation where a certified Medical Review Officer has performed an evaluation of the employee's medical condition and determined that there is a medical reason for the individual's inability to produce a urine specimen consistent with the FFD testing guidelines in Appendix A to 10 CFR Part 26.
In lieu of a urine specimen, the proposed alternative calls for the collection and processing of a blood specimen in accordance with 10 CFR 26, Appendix A, Section 2.4, as applicable. CP&L believes that the blood specimen analysis achieves FFD evaluation results comparable to those produced by urinalysis for illegal drugs. CP&L states that it is aware of the limitations present with analyzing a blood specimen (i.e., a shorter half-life limits detection and no correlation exists to the thresholds established for urinalysis), but believes that this alternate evaluation process in conjunction with the current Continual Behavioral Observation Program, which the individual has been and continues to be subject to, provides reasonable assurance that a violation of the FFD program would be detected.
The NRC recognizes that there are medical conditions that may make the collection of urine specimens difficult or hazardous to the patient. Also, there are medical problems, such as super obesity, that could result in abnormal specimens of body fluids. As a result, the NRC has previously provided guidance regarding acceptable actions to be taken for individuals unable to provide urine specimens as a result of medical conditions. The NRC expects that the licensee's medical staff, in consultation with the Medical Review Officer, will evaluate these problems, on f
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a case-by-case basis, to determine the appropriate alternative to urinalysis and that the results of these evaluations will be appropriately documented. On this basis, the NRC staff concludes that the above-described alternative, as proposed by CP&L, is acceptable and consistent with the intent of both 10 CFR Part 26 and the FFD testing guidelines in Appendix A to 10 CFR Part 26. Thus, pursuant to paragraph 1.1 of 10 CFR Part 26, Appendix A, the NRC approves the use of blood analysis as an alternative to urinalysis in the FFD evaluation process in the specific case described by CP&L in its letter of May 15,1997.
If you have any questions regarding this matter, please contact Mr. David Trimble at (301) 415-2019.
Sincerely,
/s/
John A. Zwolinski, Acting Director Division of Reactor Projects -l/II Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324 cc: See next page DISTRIBUTION:
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a case-by-case basis, to determine the appropriate alternative to urinalysis and that the results of these evaluations will be appropriately documented. On this basis, the NRC staff concludes that the above-described alternative, as proposed by CP&L, is acceptable and consistent with the intent of both 10 CFR Part 26 and the FFD testing guidelines in Appendix A to 10 CFR Part 26.. Thus, pursuant to paragraph 1.1 of 10 CFR Part 26, Appendix A, the NRC approves the use of blood analysis as an alternative to urinalysis in the FFD evaluation process in the specific case described by CP&L in its letter of May 15,1997.
If you have any questions regarding this matter, please contact Mr. David Trimble at (301) 415-2019.
Sincerely,
/s/
John A. Zwolinski, Acting Director Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324 cc: See next page DISTRIBUTION:
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a case-by-case basis, to dete,rmine the appropriate alternative to urinalysis and that the results of these evaluations will be appropriately documented. On this basis, the NRC staff concludes that the above-described alternative, as proposed by CP&L, is acceptable and consistent with the intent of both 10 CFR Part 26 and the FFD testing guidelines in Appendix A to 10 CFR 1
Part 26. Thus, pursuant to paragraph 1.1 of 10 CFR Part 26, Appendix A, the NRC approves the use of blood analysis as an alternative to urinalysis in the FFD evaluation process in the specific case described by CP&L in its letter of May 15,1997.
If you have any questions regarding this matter, please contact Mr. David Trimble at (301) 415-2019.
Sincerely, John A. Zwolinski, Acting Director Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation i
Docket Nos. 50-325 and 50-324 cc: See next page l
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Mr. J. S. Keenan Brunswick Steam Electric Plant i
Carolina Power & Light Company Units 1 and 2 cc:
Mr. William D. Johnson Ms. Karen E. Long Vice President and Senior Counsel Assistant Attorney General Carolina Power & Light Company State of North Carolina Post Office Box 1551 Post Office Box 629 Raleigh, North Carolina 27602 Raleigh, North Carolina 27602
' Mr. Jerry W. Jones, Chairman Mr. Robert P. Gruber Brunswick County Board of Commissioners Executive Director Post Office Box 249 Public Staff-NCUC Bolivia, North Carolina 28422 Post Office Box 29520 Raleigh, North Carolina 27626-0520 Resident inspector U.S. Nuclear Regulatory Commission 8470 River Road Director Southport, North Carolina 28461 Site Operations Brunsw,ck Steam Electric Plant Regional Administrator, Region ll Post Office Box 10429 U.S. Nuclear Regulatory Commission Southport, North Carolina 28461 Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. William H. Crowe, Mayor City of Southport Mr. Mel Fry, Director 201 East Moore Street Division of Radiation Protection Southport, North Carolina 28461 N.C. Departnent of Environment and Nr.tural Resources Mr. Dan E. Summers 3825 Barrett Dr.
Emergency Management Coordinator Raleigh, North Carolina 27609-7721 New Hanover County Department of Emergency Management 1
Mr. J. J. Lyash Post Office Box 1525 Plant Manager Wilmington, North Carolina 28402 Carolina Power & Light Company Brunswick Steam Electric Plant Ms. D. B. Alexander Post Office Box 10429 Manager Southport, North Carolina 28461 Performance Evaluation and Regulatory Affairs CPB 9 Public Service Commission Carolina Power & Light Company State of South Carolina Post Office Box 1551 Post Office Drawer 11649 Raleigh, North Carolina 27602-1551 Columbia, South Carolina 29211 Mr. K. R. Jury l
Chief, Reactor Projects Branch 4 Manager - Regulatory Affairs U. S. Nuclear Regulatory Commission Carolina Power & Light Company Atlanta Federal Center Post Office Box 10429 61 Forsyth Street, SW, Suite 23T85 Southport, NC 28461-0429 c
l Atlanta, Georgia 30303
.