July 14, 2023

Performance Monitoring Program: Developing Comparative Metrics for Fitness-for-Duty Programs


To comply with U.S. Nuclear Regulatory Commission (NRC) regulations, licensees and entities authorized under Title 10 of the Code of Federal Regulations (CFR) Part 26 Section 26.3 (§ 26.3) are required to have fitness-for-duty (FFD) programs. Under § 26.3, the expectation of these FFD programs is to provide reasonable assurance that individuals who are granted unescorted access to nuclear power reactor protected areas and Category I fuel cycle facility material control areas are trustworthy, will perform their tasks in a reliable manner, are not under the influence of any substance, legal or illegal, that may impair their ability to perform their duties, and are not mentally or physically impaired from any cause that can adversely affect their ability to safely and competently perform their duties. Pacific Northwest National Laboratory (PNNL) was tasked with developing a performance monitoring program to risk inform NRC inspection and policy regarding quantitative FFD performance data. To meet this need, PNNL developed methodologies that could be implemented within a performance monitoring program. Throughout this report, these methodologies are referred to as comparative metrics. The NRC provided PNNL with 2016–2019 data from annual reporting forms and single positive test forms provided by licensees and other entities. For most of the comparative metrics, the analyses required customized processing, such as creating filtering fields, adding data fields and summaries, and joining datasets. The comparative metrics developed include: • random testing rate • random policy violation rate • pre-access policy violation rate • subversion attempt rate • number of policy violations by labor category. The comparative metrics can be used for parsing and visualizing FFD program data and monitoring FFD performance at the labor category, facility, licensee, and industry levels to risk inform NRC inspection and policy with regard to the FFD data currently collected from licensees and other entities that implement Part 26 requirements. Furthermore, these developed comparative metrics allow a more in-depth look at the FFD programs for the industry to discern trends and patterns that may warrant changes at an industry level and to inform policy decisions. These analyses should be refreshed as new FFD data become available.

Published: July 14, 2023


Condon C.A., P. Mirick, J.A. Baweja, and A.L. Bunn. 2022. Performance Monitoring Program: Developing Comparative Metrics for Fitness-for-Duty Programs Richland, WA: Pacific Northwest National Laboratory.