Text

Correction to Annual Fitness for Duty Program Performance Reports for 2019, 2020, 2021, and 2022
	ML24241A276
Person / Time
Site:	Wolf Creek
Issue date:	08/28/2024
From:	Hamman D; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Security and Incident Response
References
	000567
	Download: ML24241A276 (16)
	v • d • e

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831 Dustin T. Hamman Director Nuclear Regulatory Affairs August 28, 2024 000567 U.S. Nuclear Regulatory Commission Attn: NRC Document Control Desk Washington, DC 20555-0001

References:

1) Letter RA 20-0016 (NRC ADAMS No. ML20063J237), Electronic Submittal of Annual Fitness for Duty Program Performance Report and Annual Fatigue Report for 2019, dated February 27, 2020 from R. Benham, WCNOC, to USNRC

2) Letter RA 21-0018 (NRC ADAMS No. ML21056A560), Electronic Submittal of Annual Fitness for Duty Program Performance Report and Annual Fatigue Report for 2020, dated February 25, 2021 from R. Benham, WCNOC, to USNRC

3) Letter RA 22-0018 (NRC ADAMS No. ML22053A082), Electronic Submittal of Annual Fitness for Duty Program Performance Report and Annual Fatigue Report for 2021, dated February 21, 2022 from R. Benham, WCNOC, to USNRC

4) Letter RA 23-0016 (NRC ADAMS No. ML23059A470), Electronic Submittal of Annual Fitness for Duty Program Performance Report and Annual Fatigue Report for 2022, dated February 28, 2023 from D. T. Hamman, WCNOC, to USNRC

Subject:

Docket No. 50-482:

Correction to Annual Fitness for Duty Program Performance Reports for 2019, 2020, 2021, and 2022 Commissioners and Staff:

The References submitted the Wolf Creek Generating Station (WCGS) Annual Fitness for Duty (FFD) Program Performance Reports and Annual Fatigue Reports for 2019, 2020, 2021, and 2022.

Subsequent to the submittal of the above Reference reports, Access Screening completed an internal program review which identified that one Follow-Up FFD test personnel record was not in compliance with conditions for comprehensive Follow-Up testing in 10 CFR 26.31(c), which requires Licensees to administer both drug and alcohol tests to individuals who are subject to the subparts. Alcohol Only tests were administrated and documented correctly, however as required by 10 CFR 26.31(c), a comprehensive test including both a drug and alcohol test was not completed for Follow-Up testing, which invalidated the administered Follow-Up tests. While

000567 Page 2 of 2 P.O. Box 411 l Burlington, KS 66839 l 620-364-8831 data collected was complete and accurate, and documented correctly for the testing conducted, a process error was identified for the testing which invalidated the results. As a result, this impacts the previously reported Follow-Up testing data included in the 2021 and 2022 Annual Fitness for Duty Reports. Condition report (CR) 10030134 was generated in the WCGS Corrective Action Program to document that Follow-Up testing was performed as Alcohol Only which did not align with the requirements of 10 CFR 26.31(c).

Additionally, Access Screening identified an administrative reporting error associated with five tests from 2019, one test from 2020, and one test from 2021 identified as Alcohol Only in the Security Screening Information System (SSIS). It was determined that each test was administered completely and accurately, but the type of test (For-Cause) was entered incorrectly into SSIS as Alcohol Only, causing the tests to remain listed on the Open FFD Tests Report. As a result, the number of test reports tallied in the associated FFD Annual Report was incorrect. CR 1003018 was generated in the WCGS Corrective Action Program to document the change from Alcohol Only to For-Cause tests, and the need to correct the 2019, 2020, and 2021, Annual Fitness for Duty Reports.

The Enclosures include a summary of changes, as well as amended copies of the 2019, 2020, 2021, and 2022 NRC Form 891, and Annual Reporting Form for Drug and Alcohol Tests.

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

Sincerely, Dustin T. Hamman DTH/jkt Enclosure I:

Summary of Changes to 2019, 2020, 2021, and 2022 Amended NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (1 Page)

Enclosure II:

Copy of Amended 2019 NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (2 Pages)

Enclosure III:

Copy of Amended 2020 NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (2 Pages)

Enclosure IV:

Copy of Amended 2021 NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (2 Pages)

Enclosure V:

Copy of Amended 2022 NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (2 Pages) cc: S. S. Lee (NRC), w/e J. D. Monninger (NRC), w/e G. E. Werner (NRC), w/e Senior Resident Inspector (NRC), w/e Licensing Correspondence - RA 24-000567, w/e

Enclosure I to 000567 Summary of Changes to 2019, 2020, 2021, and 2022 Amended NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (This enclosure contains 1 Page)

Summary of Changes to Amended Reporting Forms This enclosure provides the summary of changes to 2019, 2020, 2021, and 2022 Amended NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests.

1. 2019 - Added For Cause test because they were incorrectly entered as Alcohol Only

2. 2020 - Added For Cause test because they were incorrectly entered as Alcohol Only

3. 2021 - Added For Cause test because they were incorrectly entered as Alcohol Only and deleted Follow-Up test because they were incorrectly administered and don't classify as Follow-Up test.

4. 2022 - Deleted Follow-Up test because they were incorrectly administered and don't classify as Follow-Up test.

Enclosure II to 000567 Copy of Amended 2019 NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (This enclosure contains 2 Pages)

FFD Program Performance Data Reporting System NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (EIE General Submission Portal)

APPROVED BY OMB: CLEARANCE NO. 3150-0146 EXPIRES: 04/30/2021 Estimated burden per response to comply with this collection request is 108 hours0.00125 days 0.03 hours 1.785714e-4 weeks 4.1094e-5 months . This form is a voluntary means of reporting the information required under 10 CFR 26.417(b)(2) and 26.717. The information is required by NRC to obtain on an annual basis site specific fitness-for-duty (FFD) program performance data on drug and alcohol programs from licensees and other entities. Send comments regarding burden estimate to the FOIA, Privacy and Information Collection Branch (T5-F53), U.S. Nuclear Regulatory Commission, Washington DC 20555-0001, or by e-mail to Infocollects.Resource@NRC.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-1020, (3150-0146), Office of Management and Budget, Washington DC 20503. If a means used to impose information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1) All fields required unless marked 'optional'

2) Use of Adobe Reader 8 or later is required

3) Mouse over fields for additional information Facility Wolf Creek [50-482]

Submission Update Period of Report 2019 Please explain the change(s) to the form Reason For Testing was incorrectly documented as "Alcohol Only", corrected to "For Cause" Tests Conducted in the Calendar Year Reason For Testing Total Number of Tests Conducted Total Number of Positive, Adulterated, Substituted, and Refusal to Test Results Licensee Employees Contractors/Vendors Pre-Access 49 855 5

Random 418 199 1

For Cause 5

3 0

Post-Event 1

0 0

Follow-up 5

25 0

Total (Calculated) 478 1,082 6

FFD Program Random Testing Population and Rate Average number of licensee employees 866 Average number of contractors/vendors 295 Total size of the random testing pool throughout the period (Calculated) 1,161 Annual random testing percentage achieved for the testing pool 53 Laboratory Testing Does your program use a Licensee Testing Facility? No (Yes / No)

Does your program terminate an individual's authorization or take administrative action on initial marijuana or cocaine positive test results from your licensee testing facility (26.717(d))? (Yes / No)

Please Select HHS-Certified Laboratory (Primary)

Clinical Reference Laboratory HHS-Certified Laboratory (Backup)

Quest Laboratory Identify your Blind Performance Test Sample supplier(s) ElSohly Laboratory 26.717(d) Reporting Positive Initial Drug Test Results (Marijuana and Cocaine) - Licensee Testing Facility (LTF)

Enter values into this table if your program terminates an individual's authorization or takes administrative action on the initial positive test result.

Substance LTF Results HHS Laboratory Results MRO Determinations Marijuana Cocaine Total (Calculated)

Substances Tested Did your program only test for NRC-required substances AND at the NRC-specified minimum cutoff levels? (Yes / No)

Yes Does your program conduct LOD testing permitted in 26.163(a)(2)? (Yes / No)

Yes Special Analyses Testing Results Total Number of "Dilute" Specimen Test Results (Optional)

Total Number of Dilute Specimens (Special Analyses Testing Conducted)

Substance Use NRC Cutoffs?

Initial Cutoff Confirmatory Cutoff Limit of Detection (LOD) Testing?

Comment (Optional)

Alcohol Yes Not Applicable Cocaine Yes Yes Marijuana Yes Yes Amphetamines Yes Yes Opiates Yes Yes PCP Yes Yes Annual Report Form (version 1.8.0 - April 2018)

- Page 1 of 2 -

NRC Form 891 (12/2014) 0

Summary of Management Actions - 26.717(b)(8)

Summarize actions implemented to improve FFD program performance. As applicable, reference in the topic description audit reports, 30-day reports, and/or corrective action reports. If reporting information on more than three topics, select "Others" for Topic 3 to report any additional topics.

Topic 1 Other(s)

Please elaborate:

FFD collector files provide evidence that individuals are competent and trained to perform FFD testing.

Topic 1 Description QA audit 18-09-FFD/FM identified that FFD collector files did not contain required documentation per 10 CFR Part 26.85. (e) Files - Collection site personnel files must include each individual's resume of training and experience; certification or license, if any; references; job descriptions; records of performance evaluations and advancement; incident reports, if any; results of tests to establish employee competency for the position he or she holds, including, but not limited to, certification that collectors are proficient in administering alcohol tests consistent with the most recent manufacturer's instructions for the instruments and devices used; and appropriate data to support determinations of honesty and integrity conducted under § 26.31(b).

FFD collector files were organized to be consistent to contain the same data in the same order for each FFD collector. (Reference CR 00127474)

Add an additional Topic Person(s) Responsible for Information Provided Person 1 (required):

PAMELA First Name BLACK Last Name ACCESS SPECIALIST Position Title PABLACK@WCNOC.COM Company Email Address Person 2 (optional):

SONYA JONES SUPERVISOR ACCESS SOJONES@WCNOC.COM SCREENING First Name Last Name Position Title Company Email Address Final Step (Required) - NRC will consider this form authentic in accordance with 10 CFR 26.11 only when the Validate & Lock button has been selected and all errors (i.e., those highlighted in red) have been corrected. The Validate & Lock button will change to Locked after the data validation process has been successfully completed and the form is ready for submission.

Form Locked On: Jun 20, 2024 at 12:35:38 PM Annual Report Form (version 1.8.0 - April 2018)

- Page 2 of 2 -

NRC Form 891 (12/2014)

Substances Tested - continued Print this Report Save to Local PC Locked

Enclosure III to 000567 Copy of Amended 2020 NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (This enclosure contains 2 Pages)

FFD Program Performance Data Reporting System NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (EIE General Submission Portal)

APPROVED BY OMB: CLEARANCE NO. 3150-0146 EXPIRES: 04/30/2021 Estimated burden per response to comply with this collection request is 108 hours0.00125 days 0.03 hours 1.785714e-4 weeks 4.1094e-5 months . This form is a voluntary means of reporting the information required under 10 CFR 26.417(b)(2) and 26.717. The information is required by NRC to obtain on an annual basis site specific fitness-for-duty (FFD) program performance data on drug and alcohol programs from licensees and other entities. Send comments regarding burden estimate to the FOIA, Information Services Branch (T6-A10M), U.S. Nuclear Regulatory Commission, Washington DC 20555-0001, or by e-mail to Infocollects.Resource@NRC.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-1020, (3150-0146), Office of Management and Budget, Washington DC 20503. If a means used to impose information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1) All fields required unless marked 'optional'

2) Use of Adobe Reader 8 or later is required

3) Mouse over fields for additional information Facility Wolf Creek [50-482]

Submission Update Period of Report 2020 Please explain the change(s) to the form Reason For Testing was incorrectly documented as "Alcohol Only", corrected to "For Cause" Tests Conducted in the Calendar Year Reason For Testing Total Number of Tests Conducted Total Number of Positive, Adulterated, Substituted, and Refusal to Test Results Licensee Employees Contractors/Vendors Pre-Access 74 166 4

Random 419 129 0

For Cause 1

2 0

Post-Event 1

1 0

Follow-up 31 4

0 Total (Calculated) 526 302 4

FFD Program Random Testing Population and Rate Average number of licensee employees 826 Average number of contractors/vendors 213 Total size of the random testing pool throughout the period (Calculated) 1,039 Annual random testing percentage achieved for the testing pool 52.7 Laboratory Testing Does your program use a Licensee Testing Facility? No (Yes / No)

Does your program terminate an individual's authorization or take administrative action on initial marijuana or cocaine positive test results from your licensee testing facility (26.717(d))? (Yes / No)

Please Select HHS-Certified Laboratory (Primary)

Clinical Reference Laboratory HHS-Certified Laboratory (Backup)

None Identify your Blind Performance Test Sample supplier(s) ElSohly Laboratory 26.717(d) Reporting Positive Initial Drug Test Results (Marijuana and Cocaine) - Licensee Testing Facility (LTF)

Enter values into this table if your program terminates an individual's authorization or takes administrative action on the initial positive test result.

Substance LTF Results HHS Laboratory Results MRO Determinations Marijuana Cocaine Total (Calculated)

Substances Tested Did your program only test for NRC-required substances AND at the NRC-specified minimum cutoff levels? (Yes / No)

Yes Does your program conduct LOD testing permitted in 26.163(a)(2)? (Yes / No)

Yes Special Analyses Testing Results Total Number of "Dilute" Specimen Test Results (Optional)

Total Number of Dilute Specimens (Special Analyses Testing Conducted)

Substance Use NRC Cutoffs?

Initial Cutoff Confirmatory Cutoff Limit of Detection (LOD) Testing?

Comment (Optional)

Alcohol Yes Not Applicable Cocaine Yes Yes Marijuana Yes Yes Amphetamines Yes Yes Opiates Yes Yes PCP Yes Yes Annual Report Form (version 1.9.0 - January 2020)

- Page 1 of 2 -

NRC Form 891 0

Summary of Management Actions - 26.717(b)(8)

Summarize actions implemented to improve FFD program performance. As applicable, reference in the topic description audit reports, 30-day reports, and/or corrective action reports. If reporting information on more than three topics, select "Others" for Topic 3 to report any additional topics.

Topic 1 Other(s)

Topic 1 Description Access Authorization / FFD failed to successfully implement a psychological reassessment and reinvestigation process for Fitness for Duty Program Personnel. (MRO and MRO staff members)

Please elaborate:

Licensee identified NCV - medical review officer (MRO) expired reassessment and reinvestigation dates Condition Report #143387 - implemented electronic process within SSIS application to provide 90 day, 60 day, and 30 day notifications for Fitness for Duty Program Personnel.

Add an additional Topic Person(s) Responsible for Information Provided Person 1 (required):

Pamela First Name Black Last Name Access Specialist Position Title Pam.Black@evergy.com Company Email Address Person 2 (optional):

Sonya First Name Jones Last Name Supervisor Access Screening Position Title Sonya.Jones@evergy.com Company Email Address Final Step (Required) - NRC will consider this form authentic in accordance with 10 CFR 26.11 only when the Validate & Lock button has been selected and all errors (i.e., those highlighted in red) have been corrected. The Validate & Lock button will change to Locked after the data validation process has been successfully completed and the form is ready for submission.

Form Locked On: Jun 20, 2024 at 2:03:19 PM Annual Report Form (version 1.9.0 - January 2020)

- Page 2 of 2 -

NRC Form 891 Substances Tested - continued Print this Report Save to Local PC Locked

Enclosure IV to 000567 Copy of Amended 2021 NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (This enclosure contains 2 Pages)

FFD Program Performance Data Reporting System NRC Form 891, Annual Reporting Form for Drug and Alcohol Tests (EIE General Submission Portal)

APPROVED BY OMB: CLEARANCE NO. 3150-0146 EXPIRES: 09/30/2024 Estimated burden per response to comply with this collection request is 106 hours0.00123 days 0.0294 hours 1.752645e-4 weeks 4.0333e-5 months . This form is a voluntary means of reporting the information required under 10 CFR 26.417(b)(2) and 26.717. The information is required by NRC to obtain on an annual basis site specific fitness-for-duty (FFD) program performance data on drug and alcohol programs from licensees and other entities. Send comments regarding burden estimate to the FOIA, Library, and Information Collections Branch (T-6 A10M), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e_mail to Infocollects.Resource@NRC.gov, and the OMB reviewer at: OMB Office of Information and Regulatory Affairs, (3150-0146), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th Street NW, Washington, DC 20503; e-mail: oira_submission@omb.eop.gov. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid OMB control number.

1) All fields required unless marked 'optional'

2) Use of Adobe Reader 8 or later is required

3) Mouse over fields for additional information Facility Wolf Creek [50-482]

Tests Conducted in the Calendar Year Submission Update Period of Report 2021 Please explain the change(s) to the form Reason For Testing was incorrectly documented as "Alcohol Only", corrected to "For Cause" Follow-up test not completed correctly. Should not be counted as Follow-up test.

Reason For Testing Total Number of Tests Conducted Total Number of Positive, Adulterated, Substituted, and Refusal to Test Results Licensee Employees Contractors/Vendors Pre-Access 44 865 8

Random 397 202 5

For Cause 2

2 0

Post-Event 3

2 0

Followup 19 24 0

Total (Calculated) 465 1,095 13 FFD Program Random Testing Population and Rate Average number of licensee employees 801 Average number of contractors/vendors 216 Total size of the random testing pool throughout the period (Calculated) 1,017 Annual random testing percentage achieved for the testing pool 58.8 Laboratory Testing Does your program use a Licensee Testing Facility? No (Yes / No)