ML20203L872
| ML20203L872 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/27/1998 |
| From: | Terry C NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NMP1L-1291, NUDOCS 9803060280 | |
| Download: ML20203L872 (7) | |
Text
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i NIAGARA MOHAWK GENERATlON NINE WILE POINT NUCLEAR STATIOMtAKE ROAD, P O BOX fa L YCOMiNG. NEW YORK 13093/ TELEPHONE (315) 344 7263 BUSINESS GROUP
"'**'5 CARLO TERRY February 27,1998 Vice Presdent Nuclear SWety Assessment and Support NMPIL 1291 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 RE:
Niae Mile Point Unit 1 Nine Mile Point Unit 2 Docket No. 50-220 Docket No. 50-410 DPR-63 NPF-69
Subject:
Miness For Duty Pmgmm (FFD) Perfonnance Data Report Gentlemen:
In accordance with the requirements set forth in 10CFR26.71(d), Niagara Mohawk Power Corporation has compiled and is submitting the enclosed semiannual Fitness For Duty Performance Data Report covering the period July 01,1997 through December 31,1997.
Very truly yours, n
Carl D. Terry Vice President Nuclear Safety Assessment and Support CDT/bmb Enclosure
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...vaau xc:
Mr. H. J. Miller, NRC Regional Administrator Mr. S. S. Bajwa, Director, Project Directorate I-1, NRR Mr. B. S. Norris, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR Fitness for Duty lfllfhllflllf[f[ljllflll llllll Records Management 9803060280 980227
, DR ADOCK 05000220 R
FITNESS FOR DUTY PROGRAM PERFORMANCE DATA PERSONNEL SUBJECT TO 10CFR26
~
l Niagara Mohawk Power Corporation December 31. 1997 Company 6
Months Ending Nine Mile Point Nuclear Facility Location Beth Menikheim 315-349-4410 Contact Person Phone Cutoffs:
Screen / Confirmation (ng/ml)
E3 Appendix A to 10CFR26 Marijuana 100 / 15 Amphetamines 1000 / 500 Cocaine 300 / 150 Phencyclidine 25 / 25 Opiates 300 / 300 Alcohol
( % BAC )
.04%
Long-Term Short-Term Testing Results Licensee Contractor Contractor Employees Personnel Personnel Average Number with Unescorted Access 1377 N/A*
396 I
Categories Tested Positive Tested Positive Tested Positive Pre-Access 60 0
N/A N/A 221 1
For Post 3
0 N/A N/A 0
0 Cause Accident Observed 4
0 N/A N/A 1
0 Behavior Random 278 0
N/A N/A 161 1
Follow-up 8
0 N/A N'A 6
0 Other **
19 0
N/A 44 0
Tote.1 372 0
N/A N/A 433 2
NMPC does not differentiate between long and short term contractors.
All contractors badged at Nine Mile Point are considered short tern.
Refers primarily to tests conducted for Infrequent Access and samples determined to be hydrated or observed samples.
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\\
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l l
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l Breakdown of Confirmed Positive Test.s for Specific Substances Marijuana Cocaine Opiates Amphe-Phency-Alcohol Refusal 2
3 4
5 tamines clidine
/Other Licensee 0
0 0
0 0
0 0
Employees Long-Term **
N/A N/A N/A N/A N/A N/A N/A Contractors Short-Term 1
1 1
0 0
0 0
Conti.:ctors Total 1
1 1
0 0
0 0
3*
For details see Situation Descriptions (A).
The total number of confirmed positives for specific substances differs from the total confirmed employees and contractors test results due to an individual testing positive for l
more than one substance.
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NMPC does not differen;iate between long and short term contractors.
All contractors badged at Nine Mile Point are considered short term.
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FITNESS FOR DUTY (FFD) PROGRAM PERFORMANCE DATA REPORT July 01 - December 31, 1997 BECTION I.
Process Stage Data Since early in 1991, Niagara Mohawk Power Corporation (NMPC) has conducted on-site drug screening using a SYVA ETS PLUS instrument.
During this time, all tests found to be "non-negative" have been sent to our Department of Health and Human Services - certified laboratory fo.- both screening and confirmacory testing as applicable.
To monitor our accuracy and increase the integrity of our on-site laboratory, NMPC has participated in proficiency testing, provided by the College of American Pathologist (CAP), since 1992.
SECTION II.
Summary of Management Actions, NRC Reportable Events, and Appeals A.
M untion Descrintions 1.
One contractor tested positive for marijuana and opiates as a result of a pre-access drug and alcohol test.
2.
One contractor tested positive for cocaine as a result of a random drug and alcohol test.
B.
Management Actions in response to situations A.1 and A.2.
The following describes the actions taken by management as a result of the above situations.
1.
Unescorted access was in. mediately denied or removed cad the appeals option was explained to both individuals wha tested positive.
2.
FFD Staff recommended the contractors seek an evaluation to determine proper treatment.
3.
For the individual granted unescorted access prior to the confirmed positive test, supervision implemented a review of safety-related work performed by the employee; no remedial actions were required.
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'C.
'NRC REPORTABLE EVENTS PER 10CFR PART 26.73 There were no reportable events during this repe ting period.
D.
&PPEALS The contractor who tested positive for cocaine appealed the confirmed positive drug results.
The Appeals Officer denied the appeal due to the fact that a).1 procedures were fcllowed and evidence to overrule the Medical Review Officer's ducision was not established.
SECTION III.
FFD Program Modifications and Lessons Learned During this reporting period, the following items were addressed:
+
NMPC FFD completed a procedure validation process which was followed by procedurs revisions.
The validation consisted of completing a comparison between regulatory (10CFR26) requirements and Final Safety Analysis Report (FSAR) commitments, and verifying the requirements were implemented by lower tier procedures.
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FFD continued to compile substance abuse literaturc and videoF for employees and their families.
+
A FF0 representative attended a Region 1 biannual Fitness For Duty Association meeting.
The meeting was hosted by Rochester Gas & Electric, in Rochester, New York.
The presentations consisted of information on potential regulatory changes and good laboratory practices.
Our Association supports bench-marking and sharing of ideas and concerns, which can improve our FFD programs.
SECTION IV Data Assessment and Program Evaluation 2
A review of the data contained in this report indicates a lower incidence of drug and alcohol use at Niagara Mohawk Power CorporaLion's Nine Mile Point Nuclear Station than previous reporting periods.
Statistically, the data for this time period shows that the positive test rate for NMPC employees was 0% (or 0 out of 372 tests) and for contractors was.46% (or 2 out of 433 tests).
The cumulative 'since J an.
1, 1990) positive rate for NMPC cmployees and contractors separately is.29% and 1.04%,
respectively.
The co2bined rate for employees and contractors is
.25% (or 2 out of 805 tests) for this time period and.64% (or 186 out of 29,033 tests) since the inception of the program.
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'In analyzing the data compiled for this report, we discovered that due to a calculation error prior to the end of 1997, we did not achieve the annual random test rate of at least 50% of the work force.
Our end of the year calculations show that we achieved a 47% test rate for the work force.
To compensate for the lower than expected test rate, we immediately increased our selection in the current reporting period to assure that the test rate will be sufficient to achieve the annual random test rate of at least 50%
for the work force.
This increased selection and testing resulted in a random testing rate of 50.5% for the workforce for the period 01FEB97 to 31JAN98.
Preliminary investigation of this issue also identified a related problem stemming from an administrative change in March 1995, at which time NMPC implemented a higher selection rate for contractor personnel (i.e.,
100%) than for employees. The higher selection rate for contractors was imposed due to our assessment of prior confirmed positive test results and accidents in that subgroup as stated in our Ferformance Data Report, section III, for the period ending June 30, 1995.
Prior to the March 1995 change, employees and contractors were treated as a single work force and were selected for testing such that the annual test rate for the work force was at least 50% as required by the regulation.
When we implemented the higher selection rate on contractors, we failed to properly segregate the two subgroups (employees and contractors) and monitor actual random test rates to assure that each subgroup was being tested at the 50% level.
Recalculating the work force and subgroup test rates for 1995 through 1997 revealed the following:
1995 1996 1997 Work Force 54.4%
52.7%
(47.4%)
NMPC Employees 50.1%
(45.0%)
(39.8%)
Contractors 63.6%
77.1%
69.8%
While the work force test rate met the 50% annual test rate until this year, the employee subgroup annual random test rate was below 50% in both 1996 and 1997.
When the subgroup monitoring problem came to light, additional corrective actions were taken to assure the annual 50% random test rate for subgroups would also be met for the next reporting period.
In particular, we formalized monitoring by subgroup on a monthly basis and in:reased our emplcyee subgroup selection and testing.
Further corrective actions may be taken as we complete our investigation.
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A
' Further, we reviewed the Performance Data Reports submitted to the Commission since the administrative change in March 1995 to assess report accuracy.
Except for a single statement in the header of each report, and the corresponding statement in the Performance Data Reports' text for 1995, the reports are accurate.
These statements that referred to the annual random testing rate for employees and contractors were intended to inform the Commission that our annual random test rate would equal at least 50% for the work force and that we were selecting the contractors at a higher rat.o.
The statements inappropriately mixed test and selection rate gomls, and consequently were probably misleading.
Farther review is in progress to thoroughly evaluate this issue within our Corrective Action Program.
Despite NMPC's failure to maintain required levels for the annual and subgroup random testing rate, the deterrent effect of the random testing program was not significantly impaired by the lower testing rate since the work force was unaware of the slightly reduced likelihood of selection for random testing.
Accordingly, NMPC's FFD Program has continued to maintain a reasonable assurance that personnel will perform their tasks in a
reliable and trustworthy manner.
NMPC's FFD Program has provided and continues to provide a consistent deterrent effect against the use of mind i
altering substances and contributes to a "orkplace free from such substances.
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