ML19193A071

NRC Presentation on 10 CFR Part 26 FFD Program Operating Experience in 2018, NEI Access Authorization-FFD Workshop (July 10-11, 2019)

ML19193A071
Person / Time
Issue date:	07/10/2019
From:	Harris P, Brian Zaleski NRC/NSIR/DPCP/FCTSB
To:
Brian Zaleski 301-287-0638
References
Download: ML19193A071 (46)

Text

Presentation to the Nuclear Energy Institutes Annual Access Authorization/Fitness For Duty Conference Operating Experience in 2018 and Status of Regulatory Issues 10 CFR Part 26, Fitness-for-Duty Programs A Direct Contribution to Safety and Security July 10-11, 2019

Disclaimer The information in this presentation is provided as a public service and solely for informational purposes and is not, nor should be deemed as, an official NRC position, opinion or guidance, or "a written interpretation by the General Counsel" under 10 CFR 26.7, on any matter to which the information may relate. The opinions, representations, positions, interpretations, guidance or recommendations which may be expressed by the NRC technical staff during this presentation or responding to an inquiry are solely the NRC technical staff's and do not necessarily represent the same for the NRC. Accordingly, the fact that the information was obtained through the NRC technical staff will not have a precedential effect in any legal or regulatory proceeding.

Slide 2

Operating Experience in 2018 Slide 3

Overall Industry Performance [Draft]

2018 2017 Change Individuals Tested 145,798 148,741 2,943 Individuals Testing Positive* 1,186 1,165 21 Identified at Pre-access Testing 69.8% 64.3% 5.5%

Identified at Random Testing 17.7% 22.5% 4.8%

Industry Positive Rate - All Tests 0.81% 0.78% 0.03%

Licensee Employee (LE) 0.28% 0.24% 0.04%

Contractor/Vendors (CVs) 1.06% 1.04% 0.02%

Industry Positive Rate - Random Tests 0.37% 0.44% 0.07%

LE Positive Rate 0.17% 0.14% 0.03%

CV Positive Rate 0.68% 0.89% 0.21%

• Positive = Positive drug and alcohol tests, adulterated and substituted validity test results, and refusals to test All results in this presentation are MRO verified Slide 4

Results by Test and Employment Categories, 2018

[DRAFT]

Licensee Employees Contractor/Vendors (C/Vs) Total

% of Total Test Category Percent Percent Percent Tested Positive Tested Positive Tested Positive Positives Positive Positive Positive Pre-Access 8,291 36 0.43% 72,934 791 1.08% 81,225 827 1.02% 69.8%

Random 34,676 59 0.17% 22,221 151 0.68% 56,897 210 0.37% 17.7%

For Cause 132 11 8.33% 302 65 21.52% 434 76 17.51% 6.4%

Post-Event 148 - 0.00% 348 2 0.57% 496 2 0.40% 0.2%

Follow-up 2,859 21 0.73% 3,887 49 1.26% 6,746 70 1.04% 5.9%

Total 46,106 127 0.28% 99,692 1,058 1.06% 145,798 1,185 0.81% 100.0%

Where were the most tests conducted in 2018 (>90% of tests)?

Licensee Employees Contractor/Vendors Pre-access 18.0% Pre-access 73.2%

Random 75.2% Random 22.3%

Follow-up 6.2% Follow-up 3.9%

99.4% 99.3%

Where were most drug and alcohol testing violations identified in 2018 (>90% of positives)?

Licensee Employees Contractor/Vendors Pre Access 28.3% Pre-access 74.8%

Random 46.5% Random 14.3%

For Cause 8.7% For Cause 6.1%

Follow-up 16.5% 95.2%

100.0%

Slide 5

Detection Trends 1990-2018, NRC Testing Panel Percentage of Total Positives by Substance Tested

[Draft]

Since at least 2014, this chart under reports the substances used by individuals with a drug testing violation. This is because of the high number of subversion attempts each year, and because in at least 60% of these subversion attempts, no specimens were tested.

Slide 6

Results by Employment Category, 2018

[DRAFT]

Licensee Employees Contractors/Vendors (46,113 tested; 127 individuals positive) (99,685 tested; 1,059 individuals positive)

PCP Alcohol Alcohol 0.1% 15.3%

Other 42.1% Refusal to Test 1.5% 19.4%

Refusal to Test 8.3% Opiates 1.6%

Amphetamines Opiates 11.1%

1.5%

Amphetamines Cocaine 6.0% 10.4%

Marijuana 30.8%

Cocaine Marijuana 9.8% 42.2%

n = 133 n = 1,126 Slide 7

Substances Detected by Labor Category, 2018

[DRAFT]

Slide 8

Measuring Effectiveness of Lower Cutoff Levels for Alcohol, 2018 [DRAFT]

• 42% of alcohol positives (BAC < 0.04) are the result of time dependent cutoff levels, which have been required since 2008

• 32-60% of positive alcohol results per test category were BAC < 0.04 Slide 9

Testing for Additional Substances In 2018, eight facilities conducted expanded panel testing in two ways:

• Tested all specimens collected for barbiturates, benzodiazepines, methadone, and propoxyphene (four facilities, one FFD program)

• Tested follow-up, for cause, and post-event testing specimens for benzodiazepines (i.e., alprazolam, clonazepam, and lorazepam), and hydromorphone, hydrocodone, and oxycodone (four facilities, one FFD program)

Typically, a few facilities each year conduct testing for one or more additional substances when ordered by the MRO (e.g., for-cause or follow-up test).

Slide 10

Additional Substance Test Results, 2011-2018

[Draft]

Substance 2011 2012 2013 2014 2015 2016 2017 2018 Total Benzodiazepines 1 2 1 1 1 1 7 Buprenorphine 1 1 1 3 Fentanyl 1 1 Hydrocodone 1 1 1 3 Hydromorphone 1 1 2 Methadone 1 1 1 1 4 Norbuprenorphine 1 1 Oxycodone 1 1 1 1 1 5 Oxymorphone 1 1 1 1 1 5 Propoxyphene 1 1 Tramadol 1 1 Total 2 6 4 7 7 1 4 2 33 The 33 test results in this table reflect positive results for 25 individuals (see next slide). That is, some individuals test positive for more than one substance in the same testing event Slide 11

Additional Substance Results by Test Category (2011-2018) [Draft]

Substances Pre-Access Random For Cause Follow-up Total Benzodiazepines 1 1 2 4 Benzodiazepines; Amphetamine; Methamphetamine 2 2 Benzodiazepines; Amphetamine; Methamphetamine; Marijuana 1 1 Benzodiazepines; Cocaine 1 1 Benzodiazepines; Marijuana; 1 1 Benzodiazepines; Methadone; Marijuana 1 1 Buprenorphine 1 1 Buprenorphine; Norbuprenorphine 1 1 Hydrocodone 1 1 Hydrocodone; Hydromorphone; Amphetamine; Marijuana 1 1 Hydrocodone; Hydromorphone; Amphetamine; Methamphetamine 1 1 Hydrocodone; Oxycodone; Oxymorphone 1 1 Methadone 1 1 2 Oxycodone; Oxymorphone 3 3 Oxycodone; Oxymorphone; Fentanyl 1 1 Propoxyphene; Marijuana 1 1 Tramadol 2 2 Total 4 2 17 2 25

• 68% of individuals (17 of 25) tested positive on for cause testing

• 36% of individuals (9 of 25) also tested positive for a substance in the NRCrequired testing panel Slide 12

Subversion Attempt Trends [Draft]

Subversion attempt is any willful act or attempted act to cheat on a required test (e.g., refuse to provide a specimen, alter a specimen with an adulterant, provide a specimen that is not from the donors body)

Sanction for a subversion attempt is a permanent denial of unescorted access (10 CFR 26.75)

Subversion Attempt Trends (last 5 years) 2014 - 187 subversions (21.2% of drug testing violations) 2015 - 232 subversions (21.2% of drug testing violations) 2016 - 305 subversions (32.4% of drug testing violations) 2017 - 301 subversions (33.5% of drug testing violations) 2018 - 298 subversions (31.0% of drug testing violations)

Subversion Attempts in 2018:

• 70.0% facilities with at least 1 subversion attempt (50 of 71)

• 77.5% identified at Pre-Access testing (231 of 298)

• 95.6% by contractor/vendors (285 of 298)

Slide 13

Subversion Attempts, 2018 (draft)

Positive Results for Specimens Collected under Direct Observation Test Result Pre-Access Random For Cause Follow-up Total Marijuana 39 5 2 1 47 Cocaine 3 1 2 6 Amphetamine; Methamphetamine 3 3 Cocaine; Marijuana 3 3 Amphetamine; Marijuana 1 1 2 Amphetamine; Methamphetamine; Marijuana 2 2 Amphetamine 1 1 Amphetamine; Methamphetamine; Cocaine 1 1 Cocaine; 6-AM; Codeine; Morphine; PCP 1 1 Methamphetamine 1 1 Morphine 1 1 Total 54 7 4 3 68

• 298 individuals identified as subverting a test in 2018

• 68 provided specimens under direct observation (68/298 = 22.8%)

Slide 14

Limit of Detection (LOD) Testing of Dilute Specimens 10 CFR 26.163(a)(2) permits a licensee to require the HHS-certified laboratory to conduct confirmatory drug testing to LOD for a substance if:

1. Validity test result = Dilute, and

2. Immunoassay response is equal to or greater than 50% of cutoff

• 66 of 71 sites maintained the optional LOD testing policy in 2018

• 422 dilute specimens were tested to LOD in 2018, with 17 individuals testing positive

• 35% sites (23 of 66) conducted at least one 26.163(a)(2) test in 2018 Slide 15

LOD Testing of Dilute Specimens (2010-2018) - 10 CFR 26.163(a)(2)

Slide 16

HHS-Certified Laboratory Testing Errors, 2018 10 CFR 26.719 (30-day event reports)

1) A blind performance test sample (BPTS) formulated to return an adulterated validity test result (due to low pH) was reported with negative drug test results. The forensic processing technician did not properly aliquot all of the original specimen to the correct sample cup, which caused the incorrect result.

2) A donor specimen was reported as negative dilute. Two days later, the laboratory updated the result to negative. It was determined that the Screening Technician did not load the specimen on the refractometer consistent with the Standard Operating Procedure, which resulted in an incorrect specific gravity value. A second aliquot of the sample consistent with the applicable procedure determined the specimen was not dilute.

Slide 17

HHS-Certified Laboratory Testing Errors, 2018 10 CFR 26.719 (30-day event reports)

3) A BPTS formulated to return an adulterated validity test result was submitted for testing. Initial validity testing indicated general oxidants were above normal and required confirmation. However, the laboratorys confirmatory oxidant testing equipment (ion chromatograph instrument) was out of service. The laboratory sent the specimen to a second HHScertified laboratory for additional adulterant testing, but that laboratory was not the licensees authorized backup laboratory. That specimen was then sent to the licensees authorized backup laboratory, but the specimen was empty upon receipt and was reported as invalid.

4) A BPTS formulated to test positive for marijuana was reported by the HHS-certified laboratory as negative. The BPTS was a false negative challenge sample formulated at between 130 and 155 percent of the initial testing cutoff concentration for marijuana). The licensee determined the unexpected results were related to the BPTS supplier's preparation and/or preservation of the samples.

Slide 18

HHS-Certified Laboratory Testing Errors, 2018 10 CFR 26.719 (30-day event reports)

5) A licensee sent two donor specimens for testing to the HHScertified laboratory, and both specimens were reported as "rejected for testing" due to the Bottle B specimens being switched. The licensee and the laboratory conducted investigations, with conflicting conclusions reached.

• The laboratory reported the accessioner identified a switch in the bottle B specimens for the two donors and the accessioner's supervisor verified the bottle switch.

• The licensee concluded that it was likely that the Bottle B specimens were switched at the laboratory because the licensee only allows for one collection to be performed at a time and that the donor certifies the Bottle A and B specimens and observes the sealing of the specimens in the tamperevident bag. In addition, in one of the two cases, the specimen was monitored by another member of management that observed the process from beginning to end, including sealing of the tamper evident bag.

Slide 19

Status of Regulatory Issues Slide 20

Status of Regulatory Issues

• Staff-proposed Part 26 / 2008 HHS Guidelines rulemaking

• HHS Guidelines (Oral Fluid & Hair)

• Cannabidiol, Hemp, and Marijuana

• Enforcement on Individuals

• Reporting of Alcohol-related Events

• Submission of FFD Forms containing PII Slide 21

Part 26 Proposed Rule 2019

• SRM-SECY-17-0027: Proposed Rulemaking: Fitness-for-Duty Drug Testing Requirements (RIN 3510-AI67), ADAMS No. ML19154A539 (June 3, 2019)

• Key highlights:

- Testing panel changes

- Subversion attempt detection enhancements

- Donor protections and process improvements Slide 22

Part 26 Proposed Rule 2019 NRC Standard Drug Testing Panel Changes Testing Cutoff Levels (ng/mL)

Drugs or drug metabolites Initial Confirmatory Marijuana metabolites 50 15 Cocaine metabolites 300150 150100 Opiate metabolites: 2000 Codeine 2000 Morphine 2000 6-acetylmorphine (6-AM)1 10 10 Phencyclidine 25 25 Amphetamines: 1000500 Amphetamine 500250 Methamphetamine 5002502 MDMA3 500 250 MDA4 500 250 1 Confirmatory testing for 6-AM performed only when morphine concentration exceeds 2,000 ng/mL 2 To be reported positive for methamphetamine, a specimen must also contain amphetamine at a concentration equal to or greater than 200100 ng/mL 3 Methylenedioxymethamphetamine 4 Methylenedioxyamphetamine Slide 23

Proposed Rule Information:

Subversion Attempt Enhancements Special analyses testing under 26.163(a)(2):

• Require testing of dilutes (before optional)

• Add specimens collected under direct observation when indications of a subversion attempt on initial collection

• Change drug concentration on initial test that triggers special analyses testing (from 50% of cutoff to 40% of cutoff)

• Change confirmatory testing to Limit of Quantitation (LOQ) from the Limit of Detection (LOD)

Slide 24

Proposed Rule Information:

Other Notable Changes

• Donor protections:

- Verbal request for retest (MRO document request)

- MRO review of invalid specimens 9.0 to 9.5 (handling conditions)

• Hydration monitor: permit FFD program personal to monitor donor hydrating (currently, the collector who started the collection process must stay with donor)

• Will concurrently publish a draft regulatory guide (limited information specific to current rulemaking)

• Will include a question on 2017 HHS Guidelines in proposed rule Slide 25

Cannabidiol, Hemp, and Marijuana 10 CFR 26.185(j) - Review of opiates, prescription and OTC medications (4)(ii) There can be a legitimate medical explanation only with respect to a drug that has a legitimate medical use.

(5) The MRO may not consider consumption of food products, supplements, or other preparations containing substances that may result in a positive confirmatory drug test result, including, but not limited to supplements containing hemp products or coca leaf tea, as a legitimate medical explanation for the presence of drugs or drug metabolites in the urine specimen above the cutoff levels specified in § 26.163 or a licensees or other entitys more stringent cutoff levels.

Marijuana = Cannabis sativa L. = Cannabis Indica = Hemp Slide 26

Cannabidiol, Hemp, and Marijuana Date: May 26, 2015 From: Katherine Archuleta, Director, U.S. Office of Personnel Management

Subject:

Federal Laws and Policies Prohibiting Marijuana Use Federal law on marijuana remains unchanged. Marijuana is categorized as a controlled substance under Schedule I of the Controlled substance Act.

Thus knowing or intentional marijuana possession is illegal, even if an individual has no intent to manufacture, distribute, or dispense marijuana. In addition, Executive Order 12564, Drug-Free Federal Workplace, mandates that (a) Federal employees are required to refrain from use of illegal drugs; (b) the use of illegal drugs by Federal employees, whether on or off duty, is contrary to the efficiency of the service Slide 27

Cannabidiol, Hemp, and Marijuana Date: November 22, 2017 From: Ron Flegal, B.S., MT (ASSCP), M.S., Director, HHS/SAMHSA/DWP

Subject:

Use of Marijuana Oils or Marijuana Infused Commercial Products Marijuana products, including CBD, are classified as Schedule I controlled substances under the Controlled Substances Act and, thus, are illegal under federal law.

CBD is chemically distinguishable from THC and will not cause a positive drug test result under the current drug testing panel but is a Schedule I drug.

However, CBD products may contain other cannabinoids such as THC, therefore, use of CBD oils and marijuana-derived products may result in a positive urine drug test for THCA.

Slide 28

Sec 7606 of the Agricultural Act of 2018 (Farm Bill)

• Permits agricultural research pilot programs to grow industrial hemp

• The term industrial hemp includes the plant Cannabis sativa L. and any part or derivative of such plant, including seeds of such plant, whether growing or not, that is used exclusively for industrial purposes (fiber and seed) with a tetrahydrocannabinols concentration of not more than 0.3 percent on a dry weight basis

• The term tetrahydrocannabinols includes all isomers (CBD), acids, salts, and salts of isomers of tetrahydrocannabinols Slide 29

Enforcement Policy Revision SRM-SECY-17-0059 Proposed Enforcement Policy Revision for Processing Fitness-For-Duty Cases Resulting from Site Fitness-For-Duty Drug and Alcohol Violations by Individuals (ADAMS Accession Nos. ML16355A048 and ML19108A476)

Federal Register Notice Processing Fitness-for-Duty Drug and Alcohol Cases 84 FR 34363; May 28, 2019; Office of Enforcement Revision to the NRC Enforcement Policy, Section 4.1, Considerations in Determining Enforcement Actions Involving Individuals:

For FFD violations involving non-licensed individuals who violate drug and alcohol provisions of site FFD programs, which are explicitly described in § 26.75, Sanctions, the NRC will not typically consider FFD drug and alcohol-related violations for enforcement action unless there is an apparent deficiency in the licensees FFD program to take the required sanctions against the individual(s) or deficiencies in implementation of the licensee FFD program.

Slide 30

Reporting of Alcohol-related Events 10 CFR 26.719 (b) Significant FFD policy violations or programmatic failures. The following significant FFD policy violations and programmatic failures must be reported to the NRC Operations Center by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the licensee or other entity discovers the violation:

(1) The use, sale, distribution, possession, or presence of illegal drugs, or the consumption or presence of alcohol within a protected area (2) Any acts by any person licensed under 10 CFR parts 52 and/or 55 to operate a power reactor, as well as any acts by SSNM transporters, FFD program personnel, or any supervisory personnel who are authorized under this part, if such acts (iii) Involve the consumption of alcohol within a protected area or while performing the duties that require the individual to be subject to the FFD program Slide 31

Reporting of Alcohol-related Events Response to NEI question on the reporting of alcohol-related occurrences to the NRC Headquarters Operation Center (HOC) pursuant to 10 CFR 26.719(b)(1) and (b)(2)(iii):

Licensees should report to the NRC HOC alcohol-related events when they involve a liquid having an alcohol concentration equal to or greater than 0.5 percent alcohol by volume (ABV), as measured by the licensee or other entity, or a container labeled pursuant to the United States Department of the Treasury, Alcohol and Tobacco Tax and Trade Bureau under 27 CFR Part 16, Alcoholic Beverage Health Warning Label.

Posted on the FAQ website on June 13, 2019 (https://www.nrc.gov/docs/ML1908/ML19084A144.html)

Slide 32

Reporting of Alcohol-related Events Additional Guidance

1. Alcohol is a substance intended for human consumption with a molecular formula of C2H5OH. Alcohol is typically in a liquid form (e.g., liquor, beer, wine) but can come in many forms (used as an ingredient in a marinade, sauce, or extract; infused into a solid such as a cake; converted to a powder form; vaporized; prescription and over-the-counter medications).

2. An empty can, bottle, box with a label indicating at least 0.5 percent ABV alcohol that is identified in a PA should be reported to the HOC. If the licensee or other entity determines the product was not recently used (e.g.,

container was covered with dust, cobwebs, etc.) the event should not be reported.

Slide 33

Reporting of Alcohol-related Events Additional Guidance

3. For consumable products, including over-the-counter and prescription medications, that list alcohol as an ingredient, but do not have a Federal alcohol label, licensees and other entities should use their site processes and procedures to determine if a report to the NRC HOC is needed.

4. Products with denatured alcohol such as Listerine, Purell hand sanitizer, or cosmetics, are not alcohol under 10 CFR Part 26.

Slide 34

Submission of FFD Forms containing PII Be aware when submitting FFD program performance reports (Single Positive Test Forms) the NRC using the NRCs Electronic Information Exchange (EIE)

EIE saves both the licensee-designated "File Name" and "Document Title" entered for each FFD form uploaded and submitted to the NRC.

DO NOT include any personally identifying information or medical information in the File Name" or "Document Title" fields, such as a person's name, initials, social security number, or site badge number.

Slide 35

Operational Experience Slide 36

Operational Experience (OpE) Topics Topic 1: Follow-up testing Topic 2: Testing of remote location personnel Topic 3: Alternative specimens Topic 4: Gender identity and observed collections Topic 5: Random testing Slide 37

OpE Topic 1 -

Follow-up testing 26.31(c)(4)

Performed because of:

• A prior positive 10 CFR Part 26 drug/alcohol test Did you know?

• Potentially disqualifying FFD information 20142018 results Purpose: Positive rate for

• Detection (confirms continued abstinence) followup testing is

• Deterrence double that for random testing Operational issues impacting:

• Not onsite on a regular basis (e.g., contractor) ~6,800 - 8,400

• Meeting testing schedule followup tests were

• Transfers from licensee programs performed annually

• Testing plan information Slide 38

OpE Topic 2 -

Testing of Remote Location Personnel Can a hospital or other location meeting U.S. DOT 49 CFR Part 40 requirements collect specimens for a 10 CFR Part 26 FFD program?

Yes, but only for FFD program personnel and only under limited circumstances. Section 26.31(b) permits use of a 49 CFR Part 40 compliant location to collect alcohol and drug testing specimens from FFD program personnel who are:

1) involved in day-to-day operations (as defined in licensee procedures)

AND

2) whose duties require access OR who perform activities listed in 26.4(g)

Note: Subpart K (construction sites also can utilize 49 CFR Part 40 collection sites)

Slide 39

OpE Topic 3 -

Alternate Specimen Collections Licensees and other entities can collect an alternate specimen in three circumstances:

1) Shy-bladder medication condition highly likely to prevent the donor from providing a sufficient amount of urine for a very long or indefinite period - 26.119(g)(3)

2) Invalid specimen with an acceptable medical explanation and an invalid result similarly would affect the testing of another urine specimen - 26.185(f)(2)

3) Medical condition that makes collection of breath, oral fluids, or urine specimens difficult or hazardous - 26.31(d)(5)(i)

Slide 40

OpE Topic 4 -

Gender Identity and Observed Collections 26.115 Collecting a urine specimen under direct observation.

(e) The collector shall ensure that the observer is the same gender as the individual. A person of the opposite gender may not act as the observer under any conditions.

Part 26 is silent on how the gender of an individual is to be determined.

HHS --Urine Specimen Collection Handbook for Federal Agency Workplace Drug Testing Programs (pages 26-27, 10/01/2017)

The observers gender must be the same as the donors gender, which is determined by the donors gender identity.The donors gender identity may be the same as or different from the donors sex assigned at birth.

Slide 41

OpE Topic 5 -

Random Testing 26.31(c)

• Random number generator, equal probability of selection

• Random testing pool incomplete

• Testing on weekends limited Slide 42

Random Testing Positive Rates [Draft]

Site-Specific Distributions, 2018 Slide 43

Random Testing Positive Rates [Draft]

Site-Specific Distributions, 2014-2018 Licensee Employee C/V Positive Rate Range (%)

2014 2015 2016 2017 2018 2014 2015 2016 2017 2018 0 39 35 34 37 29 23 32 32 32 28

> 0% - 0.25% 20 21 19 20 22 2 4 2 1 4

> 0.25% - 0.5% 11 15 15 12 16 17 12 10 10 14

> 0.5% - 0.75% 3 1 3 2 4 18 13 10 13 6

> 0.75% - 1% 4 3 8 6 10

> 1% - 1.25% 1 1 3 4 2 4 5

> 1.25% - 1.5% 4 2 2 1 1

> 1.5% - 1.75% 3 3 4 2 2

> 1.75% - 2% 1 3 1

> 2% 2 1 Sites (with at least 1 test) 74 72 72 71 71 75 73 73 72 71 Sites (no tests performed) 1 1 1 1 0 0 0 0 0 0 Total Sites 75 73 73 72 71 75 73 73 72 71 Slide 44

Random Testing (Days of the Week) 10 CFR 26.31(c)(2)(i)(B) requires random testing to be conducted on an unpredictable schedule, including weekends, backshifts, and holidays. . .

Percentage of Positive* Tests Results by Day of Collection Year Mon. Tues. Wed. Thur. Fri. Sat. Sun.

2018 21.0% 28.1% 18.6% 20.0% 10.0% 1.9% 0.5%

2017 19.8% 24.4% 25.2% 17.6% 12.2% 0.4% 0.4%

2016 14.6% 24.2% 20.0% 25.8% 10.8% 3.1% 1.5%

2015 17.2% 28.9% 25.9% 14.7% 12.9% 0.4% 0.0%

2014 22.6% 20.8% 25.8% 19.9% 9.0% 1.4% 0.5%

• Positive = Positive drug and alcohol tests, adulterated and substituted validity test results, and refusals to test Slide 45

NRC Fitness for Duty Program Staff U.S. Nuclear Regulatory Commission Office of Nuclear Security and Incident Response Paul Harris, Senior Program Manager Paul.Harris@nrc.gov (301-287-9294)

Brian Zaleski, Fitness-for-Duty Program Specialist Brian.Zaleski@nrc.gov (301-287-0638)

Slide 46