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Fitness for Duty Programs10 CFR Part 26
“FFD Performance”
Nuclear Energy Institute Annual ConferenceJuly 25, 2016
Discussion Topics
1. Overall Industry Performance
2. FFD Performance Data
3. Reportable Events
4. Where Positive Test Results Occurred
5. FFD Performance Trends
6. Heroin
7. Multi-Substance Positives
8. Subversions
9. Questions and Feedback
Slide 2NEI Annual Conference – 2016
Overall Industry Performance, 2015 (DRAFT)
73 FFD programs (2 fewer than in 2014; Vermont Yankee and Zion)
163,398 Individuals drug & alcohol tested (down 2% from 2014)
1,199 Individuals tested positive for a drug, alcohol, or refused a test66.1% identified at pre-access testing18.7% identified at random testing
0.73% Industry overall positive rate up from 0.68% in 20140.26% LE positive rate up from 0.23% in 20140.95% C/V positive rate up from 0.88% in 2014
0.35% Industry random positive rate up from 0.34% in 20140.14% LE positive rate same in 2013 and 20140.62% C/V positive rate same in 2014
Slide 3
All results MRO verifiedLE – licensee employeesC/V – contractor/vendors
DRAFT InformationNEI Annual Conference – 2016
[Positive results include testing refusals]
89% of positives are from contractor/vendors (1,068 of 1,199)
Positives by employment type is very different by Test CategoryPre-access (CVs = 70.5%; LEs = 29.0%)Random (CVs = 16.0%; LEs = 41.2%)For-Cause (CVs = 7.9%; LEs = 16.8%)
Slide 4
Results by Test Type and Employment Category, 2015 (DRAFT)
NumberTested
NumberPositive
Percent Positive
NumberTested
NumberPositive
Percent Positive
NumberTested
NumberTested Positive
PercentPositive
Pre-Access 9,709 38 0.39% 78,884 753 0.95% 88,593 791 0.89%Random 37,504 54 0.14% 27,251 171 0.63% 64,755 225 0.35%For Cause 181 22 12.15% 473 84 17.76% 654 106 16.21%Post-Event 236 3 1.27% 780 14 1.79% 1,016 17 1.67%
Followup 3,481 14 0.40% 4,899 46 0.94% 8,380 60 0.72%Total 51,111 131 0.26% 112,287 1,068 0.95% 163,398 1,199 0.73%
Test Category
Licensee Employees (LEs) Contractor/Vendors (CVs) Total
DRAFT InformationNEI Annual Conference – 2016
Contractor/Vendors(112,287 tested, 1,068 individuals positive)
Licensee Employees (51,111 tested, 131 individuals positive)
Slide 5
Results by Employment Type, 2015 (DRAFT)
DRAFT InformationNEI Annual Conference – 2016
Effectiveness of Lower Cutoff Levels for Alcohol Testing, 2015 (DRAFT)
Slide 6
• 32% of alcohol positives due to time dependent cutoff levels implemented in the 2008 final rule (BAC < 0.04)
• This effectiveness trend has remained steady from 2013-2015 (31-32% of positives at BAC <0.04 levels)
• Random and Followup testing positives above 0.04 BAC is a concern (evaluate BOP)
DRAFT InformationNEI Annual Conference – 2016
24-Hour Reportable Events, 2015 (DRAFT)
33 Reportable Events under 10 CFR 26.719
17 Events: Supervisors • 11 Licensee employees (9 alcohol; 1 marijuana; 1 refusal)• 6 Contractor/vendors (4 alcohol; 1 amphetamines; 1 refusal)
8 Events: Prohibited items in the Protected Area (PA)• 6 events associated with alcohol (beverage container(s) discovered) • 1 event - discovery of subversion paraphernalia at security check • 1 event – prohibited item not described in the licensee report
7 Events: Licensed Reactor Operators (4 alcohol; 1 cocaine; 1 marijuana; 1 marijuana & cocaine)
1 Event: Consumption of alcohol in the PA
Slide 7
DRAFT InformationNEI Annual Conference – 2016
Where Positive Test Results Occurred, 2015 (DRAFT)
Slide 8
Where is most testing conducted in 2015 (>90% of tests)?Licensee Employees Contractor/Vendors
Pre-access 19.0% Pre-access 70.3%Random 73.4% Random 24.3%Followup 6.8% Followup 4.4%
99.2% 98.9%
Where were most drug and alcohol testing violations identified in 2015 (>90% of positives)?Licensee Employees Contractor/Vendors
Pre Access 29.0% Pre-access 70.5%Random 41.2% Random 16.0%
For Cause 16.8% ForCause 7.9%Followup 10.7% 94.4%
97.7%
DRAFT InformationNEI Annual Conference – 2016
Slide 9
Positive Rates by Employment Category (Pre-Access, Random, and For Cause Testing)
DRAFT InformationNEI Annual Conference – 2016
(2015 DRAFT)
Detection Trends – NRC Testing Panel, 1990-2015Percentage of Total Positives by Substance Tested
Slide 10
(2015 DRAFT)
DRAFT InformationNEI Annual Conference – 2016
Other Detection Trends (2015 DRAFT)
Multi-year trends:• Amphetamine and
methamphetamine (increased detection)
• Subversion attempts(high prevalence)
Year Amphetamines & Methamphetamines
Percentageof Total Positives
Subversion Attempts
Percentageof Violations
2012 6.2% 15.8%2013 8.9% 14.7%2014 10.6% 16.5%2015 9.8% 19.3%
Multi-substance positives (2012−2015)• 34-61 individuals per year tested positive for more than one substance• 83-93% of these individuals each year tested positive for amphetamines,
methamphetamines, and/or cocaine
24-hour reportable events (10 CFR 26.719) for critical group(reactor operators, supervisors), 2012 to 2015• 6-14 Licensed Operators and 16-27 Supervisors per year
Slide 11
DRAFT InformationNEI Annual Conference – 2016
Heroin Test Results, 2010-2015 (2015 DRAFT)
Slide 12
2015: 5 positive results (3 sites)Pre-Access
• C/V; Outage worker; HR/RP; Reinstatement (6-30 days) [6-AM]• C/V; Outage worker; Maintenance; Reinstatement (31-365 days) [6-AM, morphine]• C/V; Maintenance; Initial Authorization [6-AM, codeine, morphine]
Random • C/V; Outage worker; Maintenance [6-AM, cocaine, morphine]• Licensee employee; Engineering [6-AM, codeine, morphine]
2014: 2 positive results (both Pre-Access tests) – 2 sites• C/V; Maintenance; Initial Authorization [6-AM]• C/V; Maintenance [6-AM]
2013: 1 positive result (Pre-Access test) – C/V, Maintenance [6-AM, morphine]
2012: None
2011: 2 positive results (both Post-Event tests) – 2 sites• C/V, Maintenance [6-AM]; No information provided on reason for test.• C/V, Security [6-AM, morphine] “Employee struck a road sign on company property with his vehicle. When
asked by the supervisor who was responsible, the employee did not speak up. Later in the day the employee told the supervisor he was responsible for the incident.
2010: 1 positive result – (Pre-Access Tests) – Maintenance; Initial Authorization [6-AM, morphine]; Subversion attempt identified by temperature of 1st specimen.
DRAFT InformationNEI Annual Conference – 2016
Multi-Substance Positive Results, 2009-2015(2015 DRAFT)
Slide 13
2009 2010 2011 2012 2013 2014 2015
Positive results covered by e-reporting 28.9% 69.7% 85.0% 90.0% 96.8% 100.0% 100.0%
Sites with multi-substance positive result(s) 5 11 23 18 14 18 23
Number of multi-substance positive results(contractor/vendors)
8 19 37 38 32 47 55
Number of multi-substance positive results(licensee employees)
2 1 2 2 2 1 6
Industry Total 10 20 39 40 34 48 61Number of multi-substance positive results
(V.C. Summer 2&3; Voglte 3&4)0 3 6 9 17 23 23
Percentage of Multi-Substance Positive ResultsAccounted for by Construction Sites
0% 15% 15% 23% 50% 48% 38%
Percentage of multi-substance positive results at Pre-Access Testing
70% 90% 64% 73% 47% 60% 52%
Percentage of multi-substance positive results after unescorted access authorization granted
(Random, For-Cause, Post-Event, Follow-up tests)30% 10% 36% 28% 53% 40% 48%
DRAFT InformationNEI Annual Conference – 2016
Construction sites
Multi-Substance Positive Results, 2015 (DRAFT)
Slide 14
Substances Pre-Access Random For Cause Post-Event Followup Grand TotalAmphetamines; Marijuana 4 1 5Amphetamines; Methamphetamines 10 6 4 2 22Amphetamines; Methamphetamines; Cocaine; Marijuana 1 1Amphetamines; Methamphetamines; Marijuana 1 2 3Amphetamines; Methamphetamines; Other: Benzodiazepines 1 1Cocaine; Alcohol 1 1Cocaine; Marijuana 8 2 1 1 12Cocaine; Methamphetamines; Marijuana 1 1Cocaine; Methamphetamines; Opiate: Morphine 1 1Cocaine; Opiate: Morphine 1 1 2Methamphetamines; Marijuana; Opiate: Codeine 1 1Opiate: 6-AM; Opiate: Codeine; Opiate: Morphine 1 1 2Opiate: 6-AM; Opiate: Morphine 1 1Opiate: 6-AM; Opiate: Morphine; Cocaine 1 1Alcohol; Marijuana 1 1 2Opiate: Codeine; Opiate: Morphine 1 1Opiate: Morphine; Marijuana 1 1Opiate: Morphine; Opiate: Codeine 1 1 2Other: Fentanyl; Other: Oxycodone; Other: Oxymorphone 1 1
Grand Total 32 13 12 2 2 61
61 of 1,199 testing violations in 2015 were associated with more than one substance55 of 61 were C/Vs and 23 of 61 were associated with the construction sites
23 of 73 sites reported at least on multi-substance positive in 2015DRAFT Information
NEI Annual Conference – 2016
Subversion Trends, 2012-2015 (2015 DRAFT)
Subversion attempt is any act or attempted act to subvert the testing process (e.g., refuse to provide a specimen, provide or attempt to provide a substituted or adulterated specimen).
Subversion Attempts2012 177 of 1,114 violations = 15.8% subversions2013 148 of 1,007 violations = 14.7% subversions2014 187 of 1,133 violations = 16.5% subversions2015 231 of 1,199 violations = 19.3% subversions
In 2015• 46 sites reported at least 1 subversion attempt
5 highest sites: 7, 22, 16, 19, and 8
• 76% of subversions attempts occurred at pre-access testing (176 of 231)
• 95% of subversion attempts by contractor/vendors
Slide 15DRAFT Information
NEI Annual Conference – 2016
Positive Results for Subversion Attempts where a Donor Provided a Specimen under Direct Observation, 2015 (DRAFT)
Slide 16
Test Result Pre-Access Random For Cause Post-Event Followup TotalMarijuana 40 10 2 52Cocaine 4 1 1 6Amphetamines; Methamphetamines 2 1 1 4Cocaine; Marijuana 3 3Alcohol; Marijuana 1 1Amphetamines; Marijuana 1 1Amphetamines; Methamphetamines; Cocaine; Marijuana 1 1Amphetamines; Methamphetamines; Marijuana 1 1Cocaine; Opiate: Morphine 1 1Opiate: Morphine 1 1Opiate: Morphine; Marijuana 1 1Other: Buprenorphine 1 1
Total 55 13 3 1 1 73
Slide 16
DRAFT InformationNEI Annual Conference – 2016
Of the 231 individuals identified as subverting a test in 2015,73 provided specimens under direct observation, 73/231 = 31.6%
Questions and Feedback
Slide 17
Questions?
Feedback?
NEI Annual Conference – 2016
Fitness for Duty Program Staff
U.S. Nuclear Regulatory CommissionOffice of Nuclear Security and Incident ResponseDivision of Security PolicyFuel Cycles and Transportation Security Branch
Paul Harris, Senior Program [email protected] (301-287-9294)
Will Smith, Security Specialist [email protected] (301-287-3541)
Brian Zaleski, FFD Program [email protected] (301-287-0638)
Slide 18NEI Annual Conference – 2016