NLS2017053, Submittal of 30-Day Report Per 10 CFR 26.719(c), Blind Performance Testing

Submittal of 30-Day Report Per 10 CFR 26.719(c), Blind Performance Testing

ML17163A175
Person / Time
Site:	Cooper
Issue date:	06/02/2017
From:	Higginbotham K Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Security and Incident Response
References
NLS2017053
Download: ML17163A175 (4)

Text

H Nebraska Public Power District 1

Always there when you need us NLS2017053 10 CFR 26.719(c)

June 2, 2017 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001

Subject:

Submittal of 30-Day Report per 10 CFR 26.719(c)

Cooper Nuclear Station, Docket No. 50-298, DPR-46

Dear Sir or Madam:

. In accordance with 10 CFR 26.719(c), "Drug and alcohol testing errors," Nebraska Public Power District is providing the attached report on an issue related to blind performance testing for Cooper Nuclear Station.

As required by 10 CFR 26. 719(c), this report is being submitted within 3 0 days of completing an investigation of any testing errors or unsatisfactory performance discovered in performance testing at either a licensee testing facility or a Health and Human Services (HHS)-certified laboratory, in the testing of quality control or actual specimens. This report does not pertain to an actual testing error, but rather to the makeup of blind performance test samples submitted to the HHS-certified laboratory. The investigation associated with this issue was completed on May 17, 2017. The attached report includes a description of the issue, investigation results, and associated corrective actions.

This letter contains no regulatory commitments.

Should you have any questions regarding this matter, please contact Jim Shaw, Licensing Manager, at (402) 825-2788.

Sin~

Ke~eth HiJnbotham Vice-President Nuclear and Chief Nuclear Officer

/lb

Attachment:

30-Day Report per 10 CFR 26.719(c)

COOPER NUCLEAR STATION PO Box 98 /Brownville, NE 68321-0098 Telephone: (402) 825-3811 /Fax: (402) 825-5211 wwwnppd.com

NLS2017053 Page 2 of2 cc: Regional Administrator w/attachment USNRC - Region IV Senior Resident Inspector w/attachment USNRC-CNS NPG Distribution w/attachment CNS Records w/attachment l

NLS2017053 Attachment Page 1 of2 30-Day Report per 10 CFR 26.719(c)

Description of Issue Cooper Nuclear Station (CNS) failed to submit positive blind performance test samples to the Health and Human Services (HHS)-certified laboratory for all drugs and drug metabolites that are required by 10 CFR 26. l 68(b). Specifically, for positive opiate specimens, CNS did not submit specimens that were positive for the opiate metabolites codeine and 6-acetylmorphine (6-AM) as required.

10 CFR 26.168(b) requires "Approximately 60 percent of the blind performance test samples submitted to the laboratory must be positive for one or more drugs or drug metabolites per sample and submitted so that all of the drugs for which the FFD program is testing are included at least once each calendar quarter.... "

Investigation On April 18, 2017, the CNS Fitness for Duty (FFD) staff was informed of an inspection finding at another utility regarding submittal of blind performance test samples. The issue specifically related to the failure to submit blind opiate specimens that were positive for each of the opiate metabolites.

The FFD staff reviewed CNS blind specimen submittals for the past three years and found that each positive blind specimen submitted for the opiate drug only contained positive metabolites for morphine. Blind specimens containing opiate metabolites for codeine and 6-AM were not provided to the HHS-certified laboratory.

This issue was limited to opiate metabolites. CNS has been meeting the requirement for the number of blind performance test samples for marijuana metabolites, cocaine metabolites, and amphetamines (amphetamines and methamphetamines).

The cause of this error was due to a differing interpretation of 10 CFR 26.168(b). The CNS FFD staff understood the regulation to require the submittal of blind performance test samples for each of the drugs that the FFD program tests for, rather than each of the drug metabolites.

The Medical Review Officer (MRO) for CNS was contacted regarding this issue and performed a review of the testing process for blind samples sent to the HHS-certified laboratory. He determined that blind samples that were positive for opiates were sent for testing as required and all did test positive for opiates (initial test) and morphine (confirmatory test). The MRO concluded that we would not have missed any positive opioid drug tests due to codeine or heroin as a result of testing only the opiate/morphine blind sample.

NLS2017053 Attachment Page 2 of2 Corrective Actions CNS entered the identified deficiency into the Corrective Action Program. The following actions have been taken or planned:

• The FFD staff identified a blind specimen provider used in the industry that can supply opiate blind specimens which are positive for morphine, codeine, and 6-AM and a Purchase Order has been initiated.

• A positive opiate blind performance sample has been ordered that is positive for all three required metabolites and will be sent to the HHS-certified laboratory upon its arrival at CNS.

• Security Services Procedure 2.0, FFD Program Implementation, and the FFD deskguide for blind specimen testing will be revised to reflect that blind performance samples for each drug and drug metabolite that CNS tests for will be submitted per the requirements in 10 CPR 26. l 68(b).