10 CFR 26, Final Rule, Reg Analysis, Appendix 2

Exhibit A2 - 1
Activity
Equation
Parameter Description
FFD Program Personnel Subject to the Rule

Individuals Subject to the FFD Program
Parameter

Value

Source
Subpart A

2
25%

Assumption
Assumption

6.0 hr

Assumption

Section
26.4(g)

These parameters are used in the equations below:
Number of MROs per program
% multiplier to spread compliance costs across all programs

NUM mros
PER compliance

Industry Practices: One-time cost per program to subject MROs to pre-access drug and alcohol testing to comply with the former rule
No additional parameters
Industry Practices: One-time cost per program to pay for MRO travel to a licensee collection facility to comply with the former rule
Hours of MRO travel, waiting, and specimen collection time
HOURS travel

Industry Practices: One-time cost per program to conduct FFD training and to administer the comprehensive examination on their MROs to comply with the former rule
Length of FFD program training for MROs
HOURS training
2.0 hr

Assumption

Industry Practices: Annual cost per program to administer a random drug and alcohol testing program for FFD program personnel to comply with the former rule
% tested by a random drug program per year
PER random
50%

Rule requirement

Industry Practices: Annual cost per program to pay for MROs selected for random drug and alcohol testing to travel to the specimen collection facility and provide a specimen to comply with the former rule
% tested by a random drug program per year
PER random
50%
Rule requirement
Hours of MRO travel, waiting, and specimen collection time
HOURS travel
6.0 hr
Assumption

Individuals Subject to Another Acceptable Program

Subpart A

26.4(j)

These parameters are used in the equations below:
Annual number of applicants for initial authorization covered by other federal or state
program per unit
% of fed or state programs that qualify

NUM applicants
PER covered

Annual savings per program from bypassing pre-access drug and alcohol testing for the percentage of applicants covered by an acceptable program
No additional parameters
Annual savings per program from bypassing the training and examination requirement for the percentage of applicants covered by an acceptable program
Length of non-supervisory level training
HOURS non-supervisory
Length of comprehensive examination
HOURS examination

10

Assumption

50%

Assumption

2.00 hr
0.5 hr

Assumption
Assumption

Annual savings per program from requiring fewer contracted trainer hours to conduct trainings and examinations on the percentage of applicants who are covered by an acceptable program
Length of non-supervisory level training
HOURS non-supervisory
2.00 hr
Assumption
Length of comprehensive examination
HOURS examination
0.5 hr
Assumption
Hours of training preparation and examination grading
HOURS preparation
2.0 hr
Assumption
Annual savings per program from not conducting remedial training and reexamining the percentage of applicants who are covered by an acceptable program and fail the comprehensive examination
Length of remedial supervisory-level training
HOURS remedial
0.75 hr
Assumption
Length of comprehensive examination
HOURS examination
0.5 hr
Assumption
% failing comprehensive exam
PER failing
10%
Assumption
Annual savings per program from requiring fewer contracted trainer hours to conduct remedial training and reexamining those applicants covered by an acceptable program that fail the comprehensive examination
Length of remedial supervisory-level training
HOURS remedial
0.75 hr
Assumption
Length of comprehensive examination
HOURS examination
0.5 hr
Assumption
% failing comprehensive exam
PER failing
10%
Assumption
Annual savings per program from not subjecting existing employees who are covered by an acceptable program to a duplicative random drug and alcohol testing program
Annual number of existing employees covered by another federal or state program
NUM employees
40
% tested by a random drug program per year
PER random
50%

Assumption
Rule requirement

Activity
Equation
Parameter Description
Background Checks, Psychological Evaluations, Credit History, Criminal History

Parameter

Value

Source
Subpart B

Base annual savings per program from eliminating the requirement to update background checks every three years
Base number of FFD program personnel per unit for each program
NUM personnel-base
Cost of updating background investigation
COST background investigation update
Factor to adjust the periodic cost (every three years) to an annual cost
PER annualized-1

1.5
$150
33.3%

Assumption
Assumption
Calculated

Additional savings per program from performing fewer background check updates for programs with onsite testing
Additional number of FFD program personnel per facility with onsite testing
NUM personnel-onsite testing
Cost of updating background investigation
COST background investigation update
Factor to adjust the periodic cost (every three years) to an annual cost
PER annualized-1

1
$150
33.3%

Assumption
Assumption
Calculated

0.5

Assumption

$150
95.0%

Assumption
Assumption

33.3%

Calculated

1.5
$300
$50
13.3%

Assumption
Assumption
Assumption
Calculated

Additional savings per program from performing fewer background check updates for programs with onsite collection
NUM personnel-onsite collection
Additional number of FFD program personnel per facility for programs with onsite
collection
Cost of updating background investigation
COST background investigation update
Percentage of facilities with onsite collection per program
PER collection
Factor to adjust the periodic cost (every three years) to an annual cost

PER annualized-1

Base annual savings per program from reducing the frequency of the psychological evaluation and criminal history and credit check update
Base number of FFD program personnel per unit for each program
NUM personnel-base
Cost of updating psychological evaluation
COST psychological evaluation update
Cost of updating individual's credit and criminal history
COST criminal/credit update
Factor to adjust the periodic savings to an annual savings
PER annualized-2

Additional per program savings from reducing the frequency of the psychological evaluation and criminal history and credit check update for programs with onsite testing
Additional number of FFD program personnel per facility with onsite testing
NUM personnel-onsite testing
1
Cost of updating psychological evaluation
COST psychological evaluation update
$300
Cost of updating individual's credit and criminal history
COST criminal/credit update
$50
Factor to adjust the periodic savings to an annual savings
PER annualized-2
13.3%
Additional savings per program from reducing the frequency of the psychological evaluation and criminal history and credit check update for programs with onsite collection
Additional number of FFD program personnel per facility for programs with onsite
NUM personnel-onsite collection
0.5
collection
Cost of updating psychological evaluation
COST psychological evaluation update
$300
Cost of updating individual's credit and criminal history
COST criminal/credit update
$50
Percentage of facilities with onsite collection per program
PER collection
95.0%
Factor to adjust the periodic savings to an annual savings

PER annualized-2

13.3%

DOT-Approved Specimen Collection Facilities
Annual savings per program from allowing MROS and other offsite contracted personnel to utilize facilities conforming to DOT requirements
Number of MROs per program
NUM mros
% tested by a random drug program per year
PER random
% of contracted FFD personnel that live closer to a DOT-approved collection facility than PER distance
to a licensee's standard collection facility
MRO hours of saved travel, waiting and specimen collection
HOURS travel

Section
26.31(b)(1)(i)

Assumption
Assumption
Assumption
Calculated

Assumption
Assumption
Assumption
Assumption
Calculated

Subpart B
2
50.0%
33.3%

Assumption
Rule requirement
Assumption

2.0 hr

Assumption

26.31(b)(2)

Exhibit A2 - 2
Activity
Equation
Parameter Description
Policy and Procedure Revisions - Overall Program

Written Policies and Procedures
Parameter

Value

Source
Subpart B

One-time cost per program to account for FFD manager and clerical personnel time and to contract a legal consultant to revise FFD policies and procedures
Hours of FFD program manager labor to develop and revise policies and procedures
HOURS manager
370.0 hr
Hours of clerical personnel support of revision of policies and procedures
HOURS clerical
95.0 hr
Hours of legal assistance to review and revise policies and procedures
HOURS legal
95.0 hr

Assumption
Assumption
Assumption

One-time cost per program to account for facility supervisor time to implement the corporate policies at the facility level
Hours of facility supervisor time to implement revised corporate policies and procedures HOURS facility supervisor

Assumption

40.0 hr

Licensee Testing Facility Policy and Procedure Revisions
One time costs per FFD program with onsite testing
Hours FFD manager
Hours Lab supervisor
Hours Clerical
Hours Legal

Subpart E
HOURS FFD manager
HOURS lab supervisor
HOURS clerical
HOURS legal

120.0 hr
160.0 hr
40.0 hr
40.0 hr

Assumption
Assumption
Assumption
Assumption

HOURS FFDmanager

20.0 hr

Assumption

HOURS FFDmanager

20.0 hr

Assumption

NRC Implementation - One-time Revision of Inspection Procedures
One-time cost for NRC to revise inspection procedures
Time for FFD manager to revise the drug and alcohol testing / access authorization
inspection procedures
Time for FFD manager to write fatigue inspection procedures

Section
26.27(a)

26.127

Exhibit A2 - 3
Activity
Equation
Parameter Description
Revise and Implement Training, Including Behavioral Observation

Training and Examinations
Parameter

Value

Source
Subpart B

These parameters are used in the equations below:
Number of training sessions per unit

NUM sessions

% of cost applied to a given facility
% of employees trained at the non-supervisory level under the former rule
Length of FFD program training
Length of comprehensive examination

PER cost
PER non-supervisory
HOURS training
HOURS examination

50

Assumption

25%
85%
4.00 hr
0.5 hr

Assumption
Assumption
Assumption
Assumption

20.0 hr

Assumption

HOURStraining manager

2.0 hr

Assumption

HOURSmanager

2.0 hr

Assumption

HOURSclerical

4.0 hr

Assumption

60.0 hr

Assumption

8.0 hr

Assumption

One-time cost per program associated with revising the training program and training materials to account for new FFD provisions in the final rule
Hours of trainer time per program to revise the training program and training materials
HOURStrainer
Hours of training manager time per program to revise the training program and training
materials
Hours of FFD program manager time per program to revise the training program and
training materials
Hours of clerical personnel to support the revision of the training program and training
materials

One-time cost per program associated with revising the training program to include fatigue KAs
Hours of FFD program manager time per program revise the training program to include HOURS ffd manager-fatigue
fatigue KAs
Hours of clerical personnel to support the revision of the training program to include
HOURS clerical-fatigue
fatigue KAs
One-time costs per program to retrain existing employees on the fatigue-related KAs
Length of training increment addressing the fatigue-related KAs
Length of comprehensive examination increment addressing the fatigue-related KAs

HOURS training-fatigue
HOURS examination-fatigue

1.00 hr
0.08 hr

Assumption
Assumption

One-time costs per program for trainers to adminster the training on the fatigue-related KAs
Length of training increment addressing the fatigue-related KAs
Length of comprehensive examination increment addressing the fatigue-related KAs
Hours of preparation and examination grading

HOURS training-fatigue
HOURS examination-fatigue
HOURS preparation-fatigue

1.00 hr
0.08 hr
0.50 hr

Assumption
Assumption

Annual costs per program for incoming employees to take the training for fatigue-related KAs
Length of training increment addressing the fatigue-related KAs
Length of comprehensive examination increment addressing the fatigue-related KAs

HOURS training-fatigue
HOURS examination-fatigue

1.00 hr
0.08 hr

Assumption
Assumption

Annual costs per program for trainers to administer the training course for fatigue-related KAs
Length of training increment addressing the fatigue-related KAs
Length of comprehensive examination increment addressing the fatigue-related KAs

HOURS training-fatigue
HOURS examination-fatigue

1.00 hr
0.08 hr

Assumption
Assumption

0.50 hr

Assumption

Annual cost per program for employees to take the refresher training increment addressing fatigue-related KAs
Length of fatigue-related KA refresher training modules
HOURS training-fatigue

Section
26.29(a)

Activity

Value

Source

Annual cost per program for trainers to administer the refresher training increment addressing fatigue-related KAs
Length of fatigue-related KA refresher training modules
HOURS training-fatigue
Hours of training preparation and examination grading for fatigue-related increment
HOURS preparation-fatigue

Equation

Parameter Description

Parameter

0.50 hr
1.50 hr

Assumption

Annual costs per program for employees to take the comprehensive challenge examination increment addressing the fatigue-related KAs
Length of comprehensive examination increment addressing the fatigue-related KAs
HOURS examination-fatigue
% of employees taking the challenge examination
PER examination

0.08 hr
80%

Assumption

Annual costs per program for trainers to administer the comprehensive challenge examination
Length of comprehensive examination increment addressing the fatigue-related KAs
Hours of examination grading
% of employees taking the challenge examination

0.08 hr
0.08 hr
80%

Assumption

12.0 hr

Assumption

2.0 hr

Assumption

2.0 hr

Assumption

4.0 hr

Assumption

HOURS examination-fatigue
HOURS grading
PER examination

Pre-Order Baseline: One-time cost per program associated with revising the training program
Hours of FFD program manager time per program to make knowledge and abilities
HOURS trainer
revisions to training program
Hours of training manager time per program to review knowledge and abilities revisions to HOURStraining manager
training program
Hours of FFD program manager time per program to review knowledge and abilities
HOURS ffd manager
revisions to training program
Hours of clerical personnel time to support training program revisions process
HOURS clerical

Section

Pre-Order Baseline: One-time cost per program for employees not previously trained at the supervisory level to take updated supervisory-level training and a comprehensive examination
No additional parameters
Pre-Order Baseline: One-time cost per program for trainers to administer supervisory-level training on those employees not previously trained at the supervisory level
2.0 hr
Hours of training preparation and examination grading
HOURS preparation
Assumption
Pre-Order Baseline: Annual cost per program for incoming employees to take the longer supervisory-level training course
Length of supervisory-level training
HOURS supervisory
Length of non-supervisory-level training
HOURS non-supervisory

4.00 hr
2.00 hr

Assumption
Assumption

Pre-Order Baseline: Annual cost per program for trainers to administer the longer supervisory-level training course on incoming employees
Length of supervisory-level training
HOURS supervisory
Length of non-supervisory-level training
HOURS non-supervisory
Hours of training preparation and examination grading
HOURS preparation

4.00 hr
2.00 hr
2.00 hr

Assumption
Assumption
Assumption

Pre-Order Baseline: Annual cost per program for employees to take the longer supervisory-level refresher training
% of employees taking the refresher training course
PER refresher
Length of supervisory-level refresher training
HOURS supervisory
Length of non-supervisory-level refresher training
HOURS non-supervisory

20%
4.0 hr
2.0 hr

Assumption
Assumption
Assumption

Pre-Order Baseline: Annual cost per program for trainers to administer the longer supervisory-level refresher training
% of employees taking the refresher training course
PER refresher
Length of supervisory-level refresher training
HOURS supervisory
Length of non-supervisory-level refresher training
HOURS non-supervisory

20%
1.5 hr
2.0 hr

Assumption
Assumption
Assumption

Urine and Alcohol Collector Training
One time cost per facility
Number of collectors per collection site
Duration of training course
Number of training courses per facility
On-site Training of Collection Personnel, supplied by commercial vendor

Subpart E
NUM collectors
HOURS collector training
NUM courses per facility
COST training course

4
8.0 hr
1
$

Assumption
Assumption
Assumption
1,000 Assumption

Initial Validity Testing - Onsite Licensee Testing Facilities
One time cost per onsite licensee testing facility
Number of laboratory technicians per licensee testing facility
Duration of training course
Number of training courses per licensee testing facility
Cost per training course

Subpart F
NUM technicians
HOURS technician training
NUM courses per facility
COST training course

$

26.85(a),(b)

4
4.0 hr
1
500.00

Assumption
Assumption
Assumption
Assumption

26.131(b)

Activity
Equation
Parameter Description
Comprehensive Examination

Parameter

Value

Source
Subpart B

PER failing
PER non-supervisory
HOURS remedial

10%
85%
0.75 hr

Assumption
Assumption
Assumption

Section
26.29(b)

These parameters are used in the equations below:
% employees failing exam
% of employees trained at the non-supervisory level under the former rule
Length of remedial supervisory-level training

One-time cost per program for employees to take remedial training after failing the initial comprehensive examination when updating their training
No additional parameters
One-time cost per program for trainers to administer remedial training on those employees who fail the initial comprehensive examination when updating training
No additional parameters
Annual cost per program for applicants to take remedial training after failing the initial comprehensive examination
No additional parameters
Annual cost per program for trainers to administer remedial training on applicants who fail the initial comprehensive examination
No additional parameters

Comprehensive Examination in Lieu of Refresher Training
These parameters are used in the equations below:
% of employees choosing to take comprehensive refresher exam in lieu of refresher
training
Length of comprehensive examination

Subpart B
PER examination

80%

Assumption

HOURS exam

0.5 hr

Assumption

HOURS preparation
HOURS grading

1.0 hr
0.5 hr

Assumption
Assumption

Annual savings per program for those employees choosing to take the shorter comprehensive examination in lieu of non-supervisory-level refresher training
% of employees trained at the non-supervisory level under the former rule
PER non-supervisory
Length of non-supervisory-level refresher training
HOURS non-supervisory

85%
2.0 hr

Assumption
Assumption

Annual savings per program for those employees choosing to take the shorter comprehensive examination in lieu of supervisory-level refresher training
% of employees trained at the supervisory-level under the former rule
PER supervisory
Length of supervisory-level refresher training
HOURS supervisory

15%
4.0 hr

Assumption
Assumption

Trainer time to prepare for training course
Trainer time to prepare for exam and grade

Annual savings per program from reduced training costs due to employees choosing to take the shorter comprehensive examination in lieu of non-supervisory-level refresher training.
% of employees trained at the non-supervisory-level under the former rule
PER non-supervisory
85%
Assumption
Length of non-supervisory-level refresher training
HOURS non-supervisory
2.0 hr
Assumption
Annual savings per program from reduced training costs due to employees choosing to take the shorter comprehensive examination in lieu of supervisory-level refresher training.
% of employees trained at the supervisory-level under the former rule
PER supervisory
15%
Assumption
Length of supervisory-level refresher training
HOURS supervisory
4.0 hr
Assumption

NRC Implementation - One-time Training
Cost to develop NRC staff training workshop
Hours of NRC staff time to develop training workshop curriculum and materials

NRC Staff Hours

Cost to train NRC staff from Rockville Headquarters
Hours to train NRC staff reviewers and inspectors
Number of local NRC staff participating in training (including instructor)
Cost to train NRC staff from regional NRC offices
Hours to train NRC staff reviewers and inspectors
Cost of roundtrip travel
Cost of lodging and per diem per night
Number of nights of lodging for auditor to complete focused audit
Hours of roundtrip auditor travel per audit
Number personnel from NRC regional offices

40.0 hr

Assumption

NRC HQ Staff Hours
NUM NRC HQ staff

24 hr
3

Assumption
Assumption

HOUR training
COST travel
COST lodging & food
NUM nights hotel
HOURS travel
NUM NRC regional staff

24 hr
$500
$150
3
8 hr
4

Assumption
Assumption
Assumption
Assumption
Assumption
Assumption

26.29(c)(2)

Exhibit A2 - 4
Activity
Equation
Audit Frequency

Parameter Description

Audits, Inspections, Certifications and Corrective Action
Parameter

Value

Source
Subpart B

PER annualized
COST travel
COST lodging

50.0%
$300
$150

Calculated
Assumption
Assumption

HOURS auditor-base
HOURS manager-base
HOURS clerical-base

25.0 hr
13.0 hr
5.0 hr

NRC staff estimate
NRC staff estimate
NRC staff estimate

12.0 hr
7.0 hr
0.0 hr
5.0 hr
2.0 hr

NRC staff estimate
NRC staff estimate
NRC staff estimate
NRC staff estimate
NRC staff estimate

5.0 hr
0.0 hr
0.0 hr
2.0 hr
1.0 hr
95.0%

NRC staff estimate
NRC staff estimate
NRC staff estimate
NRC staff estimate
NRC staff estimate
Assumption

1
3
4.0 hr

Assumption
NRC staff estimate
Assumption

Additional annual savings per program that accrue due to reduced auditor travel to facilities with onsite testing laboratories
Additional number of auditors per program with onsite testing laboratories
NUM auditors-onsite testing
Additional number of overnights per program with onsite testing
NUM nights-onsite testing

1
1

Assumption
NRC staff estimate

Additional annual savings per program that accrue due to reduced auditor travel to facilities with onsite collection facilities
Additional number of auditors per program with onsite collection facilities
NUM auditors-onsite collection
Additional number of overnights per program with onsite collection
NUM nights-onsite collection

0
0

Assumption
NRC staff estimate

These parameters are used in the equations below:
% multiplier to yield annualized savings
Cost of roundtrip travel
Cost of lodging and per diem per night
Annual base saving per program from the reduced audit frequency
Contracted auditor hours at facility with offsite collection and testing
FFD program manager hours at facility with offsite collection and testing
Clerical personnel hours at facility with offsite collection and testing

Additional annual savings per program from audit frequency reduction that accrue to programs with onsite testing
Contracted auditor hours saved at facility with onsite testing
HOURS auditor-onsite collection
FFD program manager hours saved at facility with onsite testing
HOURS manager-onsite collection
Clerical personnel hours saved at facility with onsite testing
HOURS clerical-onsite collection
Laboratory manager hours saved at facility with onsite testing
HOURS laboratory manager
Laboratory staff hours saved at facility with onsite testing
HOURS laboratory staff
Additional annual savings per program from audit frequency reduction that accrue to programs with onsite collection
Contracted auditor hours saved at facility with onsite collection
HOURS auditor-onsite testing
FFD program manager hours saved at facility with onsite collection
HOURS manager-onsite testing
Clerical personnel hours saved at facility with onsite collection
HOURS clerical-onsite testing
Collection manager hours saved at facility with onsite collection
HOURS collection manager
Collection staff hours saved at facility with onsite collection
HOURS collection staff
Percentage of facilities with onsite collection per program
Base annual savings per program from reduced audit frequency
Base number of auditors per program audit
NUM auditors-base
Number of auditor overnights saved at facility with offsite collection and offsite testing
NUM nights-base
Contracted auditor hours traveling
HOURS travel

Annual cost per program to conduct focused audits addressing problem areas of the FFD program
Hours of contracted auditor time conducting a focused audit
Hours of FFD program manager time during a focused audit
Hours of clerical personnel time during a focused audit
Number of auditors per program audit
Cost of lodging and per diem per night
Cost of roundtrip travel
Number of nights of lodging for auditor to complete focused audit
Hours of roundtrip auditor travel per audit

HOURS auditor
HOURS manager
HOURS clerical
NUM auditors
COST lodging
COST travel
NUM nights-focused
auditor travel time

$
$

4.0 hr
3.0 hr
1.0 hr
2
150.00
300.00
1
4.0 hr

NRC staff estimate
NRC staff estimate
NRC staff estimate
Assumption
Assumption
Assumption
NRC staff estimate
Assumption

Section
26.41(b)

Activity
Equation
Parameter Description
Elimination of Audit Duplication of HHS-Certified Laboratories
Annual savings per program from eliminating audit duplication
Hours of contracted auditor time saved annually per program in elimination of audit
duplication
Hours of FFD program manager time saved annually in elimination of audit duplication
Hours of clerical personnel time saved annually in elimination of audit duplication

Parameter

Value

Source
Subpart B

HOURS auditor

7.0 hr

Assumption

HOURS manager

4.0 hr

Assumption

HOURS clerical

1.0 hr

Assumption

Forensic Toxicologist Review of More Stringent Cutoff Levels
One time cost per program to employ more stringent cutoff level(s) for drugs
Hours of review by forensic toxicologist of more stringent cut-off levels for drug testing
Hours of time for the forensic toxicologist to produce a certification statement regarding
the more stringent cut-off levels
Percentage of FFD programs that use more stringent cut-off levels for drug testing
Percentage of FFD programs who use more stringent cut-off levels for drug testing, but
have not reported to the Commission
Hours of time spent by FFD program manager to review the results of the forensic
toxicologist's evaluation per FFD program

Subpart B
HOURS toxicologist

3.5 hr

Assumption

HOURS certification

0.5 hr

Assumption

PERmore stringent cutoffs
PER non-report

10%
25%

Assumption
Assumption

HOURS manager

0.5 hr

Assumption

Pre-Award Inspections of HHS-Certified Laboratories
Annual costs per FFD program
Hours per pre-award inspection for an HHS-certified lab conducted by licensee personnel HOURS inspection
or a designate
Percentage of FFD programs that must change to a new HHS lab because their current PER decertification
HHS-lab loses HHS certification
Percentage of instances in which a replacement HHS-certified lab is being used by
PER known
another FFD program (a "known" HHS lab)

Subpart G
100 hr
10%

Discussion with NEI staff, May 23,
2003
Assumption

50%

Assumption

Section
26.41(c)(2)

26.31(d)(3)

26.153(e)

Exhibit A2 - 5
Activity
Equation
Parameter Description
Initial Authorization
Self-Disclosure for Initial Applicants

Authorizations
Parameter

Value

Pre-Order Baseline: Annual savings per program from reduced facility worker labor burden for those initial applicants who qualify for the self-disclosure relaxation
% of applicants for initial authorization qualifying for relaxation
PER qualifying
50%
Facility worker hours saved in foregone self-disclosure
HOURS worker
0.25 hr

Source

Section

Subpart C

26.55(a)(1)

Assumption
NRC staff estimate

Pre-Order Baseline: Annual savings per program from reduced clerical personnel labor burden because fewer self-disclosures submitted by initial applicants need to be processed
% of applicants for initial authorization qualifying for relaxation
PER qualifying
50%
Assumption
Clerical personnel hours saved in foregone self-disclosure
HOURS clerical
0.25 hr
NRC staff estimate

Suitable Inquiry for Initial Applicants

Subpart C

Pre-Order Baseline: Annual savings per program from not conducting the suitable inquiry on initial applicants qualifying for relaxation
% of applicants for initial authorization qualifying for relaxation
PER qualifying
HR personnel hours saved in exempted suitable inquiry under the former rule, but prior to HOURS hr
the AAO
Pre-Order Baseline: Annual savings per program due to reduced suitable inquiry coverage period and scope for those applicants qualifying for the relaxation
HR personnel hours saved due to reduced suitable inquiry coverage period and a
HOURS hr
reduction in the number of employers that must be contacted
% of applicants for initial authorization per year who do not qualify for the relaxation under PER not qualifying
subparagraph 23.63(a) in the final rule
% of initial applicants who have no potentially disqualifying FFD information to disclose PER non-PDFFDI
Industry Practices: Annual cost per program to conduct a more thorough suitable inquiry on applicants for initial authorization to comply with the former rule
Additional HR personnel hours required to conduct a suitable inquiry compliant with forme HOURS hr
rule

50%
1.0 hr

Assumption
NRC staff estimate

0.5 hr

NRC staff estimate

50%

Assumption

95%

Assumption

26.55(a)(2)

0.2 hr
Assumption

Pre-Access Testing for Initial Applicants

Subpart C

26.55(a)(3)

Pre-Order Baseline: Annual savings per program from not administering a pre-access drug and alcohol test on initial applicants covered by a behavioral observation and arrest-reporting program throughout the period of interruption
% applicants of applicants for initial authorization qualifying for pre-access drug test
relaxation

PER qualifying

25%

Assumption

Pre-Order Baseline: Annual savings per program from bypassing required worker labor in the administration of a pre-access drug and alcohol tests for initial applicants covered by a behavioral observation and arrest-reporting
Facility worker hours saved at facility with onsite testing laboratory
Facility worker hours saved at facility with offsite testing laboratory
% of initial applicants qualifying for pre-access drug test relaxation

HOURS onsite
HOURS offsite
PER qualifying

4.0 hr
8.0 hr
25%

Random Testing Pool for Initial Applicants

Assumption
Assumption
Assumption

Subpart C

Annual costs per program from the implementation of a random drug and alcohol testing program on initial applicants in applicant status
% of initial applicants selected for random drug and alcohol testing
PER random

1%

Authorization Updates
Self Disclosure for Update Applicants

Assumption

Subpart C

Pre-Order Baseline: Annual savings per program from reduced facility worker labor burden for those applicants for updated authorization who qualify for the self-disclosure relaxation
% of applicants for authorization updates qualifying for relaxation

PER qualifying

50%

Facility worker hours saved in foregone self-disclosure

HOURS worker

0.25 hr

Assumption
NRC staff estimate

Pre-Order Baseline: Annual savings per program from reduced clerical personnel labor burden because fewer self-disclosures submitted by applicants for updated authorization will need to be processed
% of applicants for authorization updates qualifying for relaxation
Clerical personnel hours saved in foregone self-disclosure

PER qualifying
HOURS clerical

50%
0.25 hr

26.55(a)(4)

Assumption
NRC staff estimate

26.57(a)(1)

Activity
Equation
Parameter Description
Suitable Inquiry for Update Authorization

Parameter

Value

Pre-Order Baseline: Annual savings per program from not conducting the suitable inquiry on applicants for updated authorization qualifying for the relaxation
% of applicants for authorization updates qualifying for relaxation
PER qualifying
HR personnel hours saved in exempted suitable inquiry under the former rule, but prior to HOURS hr
the AAO

Source
Subpart C

50%
1.0 hr

Section
26.57(a)(2)

Assumption
NRC staff estimate

Pre-Order Baseline: Annual savings per program due to reduced suitable inquiry coverage period and scope for applicants for updated authorization qualifying for the relaxation
% of applicants for updated authorization not qualifying for relaxation
PER non qualifying
50%
Assumption
% of applicants for updated authorization who have no potentially disqualifying FFD
PER non-PDFFDI
98%
Assumption
information to disclose
HR personnel hours saved due to reduced suitable inquiry coverage period and a
HOURS hr
0.5 hr
NRC staff estimate
reduction in the number of employers that must be contacted
Industry Practices: Annual cost per program to conduct a more thorough suitable inquiry on applicants for updated authorization to comply with the former rule
0.2 hr
Additional HR personnel hours required to conduct a suitable inquiry compliant with forme HOURS hr
rule

Pre-Access Testing for Update Applicants

Assumption

Subpart C

26.57(a)(3)

Pre-Order Baseline: Annual savings per program from not administering a pre-access drug and alcohol test on update applicants covered by a behavioral observation and arrest-reporting program throughout the period of interruption
% applicants for authorization updates qualifying for pre-access drug test relaxation

PER qualifying

25%

Assumption

Pre-Order Baseline: Annual savings per program from bypassing required worker labor in the administration of a pre-access drug and alcohol tests for update applicants covered by a behavioral observation and arrest-reporting
Facility worker hours saved at facility with onsite testing laboratory
Facility worker hours saved at facility with offsite testing laboratory
% applicants for authorization updates qualifying for pre-access drug test relaxation

HOURS onsite
HOURS offsite
PER qualifying

4.0 hr
8.0 hr
25%

Random Testing Pool for Update Applicants

Assumption
Assumption
Assumption

Subpart C

26.57(a)(4)

Annual costs per program from the implementation of a random drug and alcohol testing program on update applicants in applicant status
% of initial applicants selected for random drug and alcohol testing

PER random

1%

Authorization Reinstatements with Interruptions
Self-Disclosure for Reinstatement Applicants with 31-365 Day Interruption

Assumption

Subpart C

26.59(a)(1)

Pre-Order Baseline: Annual savings per program from reduced facility worker labor burden for those applicants for authorization reinstatement who qualify for the self-disclosure relaxation
Facility worker hours saved in foregone self-disclosure

HOURS worker

% of applicants for authorization reinstatement qualifying for self-disclosure relaxation

PER qualifying

0.25 hr
50%

NRC staff estimate
Assumption

Pre-Order Baseline: Annual savings per program from reduced clerical personnel labor burden because fewer self-disclosures submitted by applicants for authorization reinstatement will need to be processed
Clerical personnel hours saved in foregone self-disclosure

HOURS clerical

% of applicants for authorization reinstatement qualifying for self-disclosure relaxation

PER qualifying

0.25 hr
50%

Suitable Inquiry for Reinstatement Applicants with 31-365 Day Interruption

NRC staff estimate
Assumption

Subpart C

Pre-Order Baseline: Annual savings per program from not conducting the suitable inquiry on applicants for authorization reinstatement qualifying for the relaxation
HR personnel hours saved in exempted suitable inquiry under the former rule, but prior to HOURS hr
1.0 hr
NRC staff estimate
the AAO
% of applicants qualifying for the suitable inquiry relaxation
PER qualifying
50%
Assumption
Pre-Order Baseline: Annual savings per program due to reduced suitable inquiry coverage period and scope for applicants for authorization reinstatement qualifying for the relaxation
HR personnel hours saved due to reduced suitable inquiry coverage period and a
HOURS hr
0.5 hr
NRC staff estimate
reduction in the number of employers that must be contacted
Assumption
% of applicants not qualifying for the suitable inquiry relaxation
PER covered
50%
% of update applicants who have no potentially disqualifying FFD information to disclose PER non-pdffdi
99%
Assumption
on their self-disclosures
Industry Practices: Annual cost per program to conduct a more thorough suitable inquiry on applicants for authorization reinstatement to comply with the former rule
Additional HR personnel hours required to conduct a suitable inquiry compliant with forme HOURS hr
0.2 hr
rule

Assumption

26.59(a)(2)

Activity
Equation
Parameter Description
Pre-Access Testing for Reinstatement Applicants with 31-365 Day Interruption

Parameter

Value

Source
Subpart C

Section
26.59(a)(3)

Pre-Order Baseline: Annual savings per program from allowing reinstatement applicants covered by a random drug and alcohol testing program throughout the period of interruption to forego pre-access drug and alcohol testing
% of applicants for authorization reinstatement covered by a random drug and alcohol
testing program

PER qualifying

25%

Assumption

Pre-Order Baseline: Annual savings per program from reducing the number of hours of lost worker productivity for reinstatement applicants covered by both a random drug and alcohol testing program and a behavioral observation and
arrest reporting program
Facility worker hours saved at facility with onsite testing laboratory
Facility worker hours saved at facility with offsite testing laboratory
% of applicants for authorization reinstatement covered by a random drug and alcohol
testing program

HOURS onsite
HOURS offsite

PER qualifying

4.0 hr
8.0 hr
25%

Assumption
Assumption
Assumption

Pre-Order Baseline: Annual savings per program resulting from this group of applicants not having to await verification of negative results before granting authorization
Facility worker hours saved at facility with onsite testing laboratory
HOURS onsite
Facility worker hours saved at facility with offsite testing laboratory
HOURS offsite
% of applicants for authorization reinstatement not covered by a random drug and alcohol PER not qualifying
testing program

4.0 hr
8.0 hr
75%

Random Testing Pool for Reinstatement Applicants with 31-365 Day Interruption

Assumption
Assumption
Assumption

Subpart C

Annual costs per program to conduct random drug and alcohol tests on applicants randomly selected while awaiting the granting of authorization
% of initial applicants selected for random drug and alcohol testing
PER random

1%

Self-Disclosure (and Suitable Inquiry) for Reinstatement Applicants with Less than 31 Day Interruption

26.59(a)(4)

Assumption

Subpart C

26.59(c)(1)

Pre-Order Baseline: Annual savings per program from reduced facility worker labor burden for those applicants for authorization reinstatement who qualify for the self-disclosure relaxation
% of reinstatement applicants qualifying for relaxation

PER qualifying

50%

Facility worker hours saved in foregone self-disclosure

HOURS worker

0.25 hr

Assumption
NRC staff estimate

Pre-Order Baseline: Annual savings per program from reduced clerical personnel labor burden because fewer self-disclosures submitted by applicants for authorization reinstatement will need to be processed
% of reinstatement applicants qualifying for relaxation

PER qualifying

50%

Clerical personnel hours saved in foregone self-disclosure

HOURS clerical

0.25 hr

Assumption
NRC staff estimate

Pre-Order Baseline: Annual savings per program from not conducting suitable inquiries on applicants for authorization reinstatement with an interruption of not more than 30 days
HR personnel hours saved in exempted suitable inquiry under the former rule, but prior to HOURS hr
the AAO

1.0 hr

NRC staff estimate

Industry Practices: Annual cost per program for applicants for authorization reinstatement with interruptions of not more than 30 days to submit self-disclosures to comply with self-disclosure requirements
Facility worker hours required to complete and submit self-disclosure
HOURS worker
0.25 hr
NRC staff estimate
% cost applied to each program
PER cost
50%
Assumption
Industry Practices: Annual cost per program for clerical personnel to process additional self-disclosures for applicants for authorization reinstatement with interruptions of not more than 30 days to comply with self-disclosure requirements
Clerical personnel hours required to process received self-disclosures
% cost applied to each program

HOURS clerical
PER cost

0.25 hr
50%

NRC staff estimate
Assumption

Industry Practices: Annual cost per program to conduct suitable inquiries on applicants for authorization reinstatement with an interruption of not more than 30 days to comply with the former rules
Additional HR personnel hours required to conduct a suitable inquiry as required by forme HOURS hr
1.0 hr
NRC staff estimate
% cost applied to each program
PER cost
50%
Assumption
Industry Practices: Annual cost per program to conduct a more thorough suitable inquiry on applicants for authorization reinstatement with an interruption of not more than 30 days to comply with the former rule
Additional HR personnel hours required to conduct a suitable inquiry compliant with forme HOURS hr
rule

0.2 hr
Assumption

Pre-Access Testing for Reinstatement Applicants with Less than 31 Day Interruption

Subpart C

26.59(c)(2)

Pre-Order Baseline: Annual savings per program from not administering a pre-access drug and alcohol test on applicants for authorization reinstatement with an interruption of 5 days or less
No additional Parameters

No Parameters

Pre-Order Baseline: Annual savings per program from bypassing worker labor in the administration of a pre-access drug and alcohol test for authorization reinstatements with an interruption of 5 days or less
Facility worker hours saved at facility with onsite testing laboratory
Facility worker hours saved at facility with offsite testing laboratory

HOURS onsite
HOURS offsite

4.0 hr
8.0 hr

Assumption
Assumption

Pre-Order Baseline: Annual savings per program from allowing reinstatement applicants who have been covered by a behavioral observation and arrest-reporting program throughout the period of interruption to forego the pre-access drug
and alcohol test
% of applicants qualifying for the relaxation

PER covered

50%

Assumption

Pre-Order Baseline: Annual savings per program from bypassing required worker labor in the administration of a pre-access drug and alcohol tests for reinstatement applicants who have been covered by a behavioral observation and
% of applicants qualifying for the relaxation
PER covered
50%
Assumption
Facility worker hours saved at facility with onsite testing laboratory
HOURS onsite
4.0 hr
Assumption
Assumption
Facility worker hours saved at facility with offsite testing laboratory
HOURS offsite
8.0 hr
Pre-Order Baseline: Annual savings per program from allowing reinstatement applicants who have not been covered by a behavioral observation and arrest-reporting program throughout the period of interruption but who have not been
randomly selected for pre-access testing to forego the pre-access drug and alcohol test
% of applicants not qualifying for the relaxation
% of applicants subject to random testing but not selected

PER not covered
PER not selected

50%
98%

Assumption
Assumption

Pre-Order Baseline: Annual savings per program from reducing the number of hours of lost worker productivity for reinstatement applicants who are not covered and are not selected for random pre-access drug and alcohol testing
PER not covered
% of applicants not qualifying for the relaxation
50%
Assumption
% of applicants subject to random testing but not selected
PER not selected
98%
Assumption
Facility worker hours saved at facility with onsite testing laboratory
HOURS onsite
4.0 hr
Assumption
Assumption
Facility worker hours saved at facility with offsite testing laboratory
HOURS offsite
8.0 hr
Industry Practices: Annual cost per program to comply with existing pre-access drug and alcohol testing provisions
Facility worker hours saved at facility with onsite testing laboratory
HOURS onsite
Facility worker hours saved at facility with offsite testing laboratory
HOURS offsite
% of cost applied to a given program due to non-compliance
PER compliance

4.0 hr
8.0 hr
50%

Assumption
Assumption
Assumption

Industry Practices: Annual cost per program of increased lost worker productivity awaiting negative test result verification to comply with existing pre-access drug and alcohol testing provisions
Facility worker hours saved at facility with onsite testing laboratory
HOURS onsite
4.0 hr
Assumption
Assumption
Facility worker hours saved at facility with offsite testing laboratory
HOURS offsite
8.0 hr
% of cost applied to a given program due to non-compliance
PER compliance
50%
Assumption

Random Testing Pool for Reinstatement Applicants with Less than 31 Day Interruption

Subpart C

Annual costs per program to subject applicants for authorization reinstatement to one-time random selection for a pre-access drug and alcohol test
% rate of random test selection
PER randomly selected
2%
Assumption
% rate of random test selection
PER randomly selected
1%
Assumption
Annual costs per program from reduced labor productivity to subject applicants for authorization reinstatement to one-time random selection for a pre-access drug and alcohol test
% rate of random test selection
PER random
2%
Assumption
Assumption
Facility worker hours saved at facility with onsite testing laboratory
HOURS onsite
4.0 hr
Assumption
Facility worker hours saved at facility with offsite testing laboratory
HOURS offsite
8.0 hr

26.59(c)(3)

Exhibit A2 - 6
Activity
Equation
Parameter Description
Reasonable Effort to Track Randomly Selected Individuals for Testing

Activities Related to Potential Policy Violations
Parameter

Annual costs per program from requiring greater effort to track individuals selected for random drug and alcohol testing
% tested by a random drug program per year
PER random
% of randomly selected employees per year that are unavailable for the scheduled test PER unavailable
Hours of FFD program manager tracking time per randomly selected employee
unavailable for the scheduled test

HOURS manager

Value

Source
Subpart B

50.0%
25%

Rule requirement
Assumption

0.25 hr

Assumption

Behavioral Observation

Subpart B

This parameter is used in the equations below:
% increase in for-cause tests/referrals per year

PERI for-cause

10%

Assumption

Annual cost per program to review additional for-cause referrals
Hours of FFD program manager review per for-cause referral
Hours of facility worker hours under review per for-cause referral

HOURS manager
HOURS worker

4.0 hr
4.0 hr

Assumption
Assumption

5%

Assumption

1%

Assumption

Section
26.31(d)(2)

26.33

Annual cost per program to conduct additional drug and alcohol tests due to increased for-cause referrals
No additional parameters
Annual cost per program to conduct additional pre-access drug and alcohol tests yielding positive results due to increased for-cause referrals
No additional parameters
Annual cost per program to retest confirmed positive drug test results at a second HHS-certified laboratory at the request of the donor
Percentage of urine specimens with confirmed positive, adulterated, substituted, dilute, or PER retest
invalid validity and/or drug test results retested at the request of the donor at a second
HHS-certified laboratory
Annual costs per program for the percentage of workers with confirmed positive test results who initiate an appeals process
Percentage of workers with confirmed positive test results that initiate appeals process
PER appeals

Disclosure requirements positive test results
Annual costs per program to provide individuals with easier access to personal documents
% of employees with positive test results who request records
Additional clerical personnel hours copying, packaging, and shipping records per
disclosure request
Cost of mailing (express mail) one performance data report to each licensee

Subpart B
PER requesting
HOURS clerical
COSTMailing

50%
1.0 hr
$

Assumption
Assumption
10.00 Assumption

Review of FFD Policy Violations

Subpart B

Annual cost per program to require FFD policy violations to be reviewed by more than one individual both of whom must be unaffiliated with FFD program administration
Additional hours of non-FFD manager review of FFD policy violations
HOURS manager
4.0 hr

Definition of "Potentially Disqualifying Information"
10%

Assumption

5%

Assumption

Annual savings per program from the reduction in the number of determinations of fitness requiring SAE review
SAE hours of review per determination of fitness
HOURS sae

2.0 hr

Assumption

Annual savings per program from the reduction in the number of determinations of fitness requiring FFD program manager review
FFD program manager hours of review per determination of fitness
HOURS manager

2.0 hr

Assumption

Annual savings per program from the reduction in the number of determinations of fitness requiring clerical personnel support
Clerical personnel hours to support determination of fitness
HOURS clerical

2.0 hr

Assumption

Face-to-Face Determinations of Fitness

Subpart H

Annual costs per program from requiring that a determination of fitness that is conducted for-cause be conducted face-to-face with the individual under review
Hours of worker time required per face-to-face determination of fitness

HOURS worker

2.0 hr

26.39(c)

Assumption

Subpart H

These parameters are used in the equations below:
% of applicants for authorization requiring a determination of fitness based on potentially PER PDFFDI-former
disqualifying FFD information under the former rule
% of applicants for authorization requiring a determination of fitness based on potentially PER PDFFDI-final
disqualifying FFD information under the final rule

26.37(d)

Assumption

26.189(b)(3)

26.189(c)

Exhibit A2 - 7
Activity
Equation
Parameter Description
Urine Collection: Donors Without Adequate ID

Urine Specimen Collections
Parameter

Annual savings per FFD program per year
Percentage of individuals without identification
Time a donor without ID would spend to leave the collection site, obtain appropriate ID,
and return to the collection site to be drug and alcohol tested

PER no-ID
HOURS worker

Value

Source
Subpart E

1.0%
0.75 hr

Assumption
Assumption

Urine Collection: Eliminate Listing Medications on the CCF Form and add description of testing process
Annual savings per FFD program per year
Time per collection to list medications on CCF
Time per collection for collector to explain testing process to donor

Subpart E

HOURS saved
HOURS added

0.033 hr
0.013 hr

Urine Collection: Inspecting Contents of Donor's Pockets
Annual costs per FFD program per year
Time to inspect contents of a donors pockets per test

0.033 hr

Urine Specimen Quantity: Minimum Quantity of 30 mL
6.7%
25.0%

4.22.03 Wall Street Journal article,
see RA
Assumption

1.50 hr

Assumption

Urine Specimen: At Least 30 mL, but Less than Predetermined Quantity
Annual costs per FFD program with onsite testing facility
Percentage of urine specimens at least 30 mL in volume, but less than the licensee or
C/Vs predetermined quantity of urine

Subpart E
PER not predetermined quantity

1.0%

Shy Bladder Medical Evaluation
Annual costs per FFD program
Number of urine collections unable to be completed because of inadequate specimen
volume per facility per year

Cost of a medical evaluation and written report from a licensed physician (per shy bladder COST medical evaluation
event)
Time per medical evaluation (including travel to and from the physician's office)
HOURS medical evaluation
Time for a FFD manager per incident where an employee is unable to provide the
HOURS FFD manager
minimum quantity of urine after 3 hours
MRO time to select a physician, instruct the physician on the medical evaluation that must HOURS MRO
be conducted, and review and communicate the medical evaluation results

1

$

Assumption

300.00

26.109(a)

26.109(b)(2)

Assumption

Subpart E
NUM shy bladder

26.105(b)

Assumption

Subpart E

Annual savings per FFD program
Percentage of collections considered to be of inadequate quantity under the former
PER low quantity
requirements
Percentage decrease in the number of inadequate specimens resulting from reduction in PERD low quantity
the minimum specimen quantity from 60 mL to 30 mL
Time per test saved because donor can provide a sufficient specimen under the new rule HOURS saved

26.89(b)(3)

Assumption

Subpart E
HOURS inspection

Section
26.89(b)(2)

Assumption

1.50 hr

Assumption

2.0 hr

Assumption

2.0 hr

Assumption

26.119

Exhibit A2 - 8
Activity
Equation
Parameter Description
Blood Collection for Confirmatory Alcohol Testing

Alcohol Testing
Parameter

Annual savings per FFD program per year
Number of blood tests per FFD program per year
Hours MRO to review test result & communicate with employee and donor
Hours lost worker productivity resulting from receiving a blood test

NUM blood
HOURS mro
HOURS worker

Value

Source
Subpart E

1
0.75 hour
0.75 hour

NEI data
Assumption
Assumption

Purchase of EBT and Calibration Equipment and Related Training
This parameter is used in the equations below:
Percentage of collection sites that will purchase an EBT meeting the specifications in
paragraph 26.91(c).

Subpart E
PER purchased

One time equipment purchases per facility
Number of compliant EBTs purchased per collection site

NUM EBTs

One time training cost per facility
Cost of alcohol collector training course on purchased EBT
Number of alcohol collectors per collection site
Length of alcohol collector training course

COST training course
NUM collectors
HOURS collector training

50%

Assumption

2

Assumption

$

PER compliant, final rule

0.033 hour

Assumption

50%

Assumption

One Breath Specimen Collection for Initial Alcohol Test
Annual savings per FFD program per year
Savings in collection time from one fewer breath collection per breath test

Subpart E
HOURS breath collection

0.033 hour

Lowering Initial BAC Requiring Confirmatory Test to BAC 0.02
20%

Assumption

0.05 hour
2.5 hour

Assumption
Assumption

FFD Manager Determines Confirmed Positive Test for Alcohol (BAC 0.02 < 0.04)

Time per test result for FFD manager to determine the length of time an employee has
been in work for BACs equal to or greater than 0.02 and less than 0.4

Subpart E
PERI CPAT

HOURS FFD management

20%

0.25 hour

26.91(c)

26.95(c)

Assumption

Subpart E

Annual costs per FFD program per year
Percentage increase in number of initial positive alcohol tests under the lower screening PERI IPAT
level BAC
Time to conduct a confirmatory alcohol test under the final rule
HOURS CAT
Hours of FFD manager time associated with personnel activities and administrative
HOURS FFD manager
actions resulting from a confirmed positive alcohol test result

Annual costs per FFD program per year
% increase in the number of confirmed positive breath alcohol tests per FFD program
under the BACs in the final rule

Assumption

Subpart E
HOURS saved

26.91(b)

250 Assumption
4
2 hours

Required Use of an EBT on the NHTSA CPL for Confirmatory Testing
Annual savings per FFD program per year
Time per test to set-up a second EBTs (locate the EBT, turn on the equipment) to
conduct confirmatory testing
Percentage of collections sites that will use a compliant EBT for all collections

Section
26.83(a)

Assumption. Note: this is the same
rate as in 26.97(b) PERI IPAT
Assumption

26.99(b)

26.103

Exhibit A2 - 9
Drug and validity testing (licensee testing facilities and HHS-certified laboratories)
Activity
Equation
Parameter Description
Parameter
Value
Validity Testing (On-site Licensee Testing Facilities and HHS-Certified Laboratories)

Source
Subpart F
Subpart G

Section
26.131(b)
26.161(b)(1)

Cost to Conduct Daily Calibration Validity Testing Equipment at Onsite Licensee Testing Facility
Number of days per year a licensee testing facility operates

NUMdays

365 days

Assumption

Costs for confirmed positive drug tests and confirmed adulterated, substituted, or invalid validity test results
Percentage of initial validity tests with dilute, adulterated, substitued, or invalid test results PER dilute, adulterated, substituted, or
invalid - initial valdiity testing

2.69%

Equals the sum of the percentage of
dilute, adulterated, and invalid
specimens - see Exhibit A2-12)

Percentage of Dilute Specimens drug positive at LOD testing

PER positive LOD

33%

Assumption

Percentage of initial Adulterated, Substituted (0-<2 mg/dL creatinine), and Invalid test
results that remain adulterated, substitued, or invalid on confirmation

PER adulterated, substituted, Invalid
confirmed

100%

Assumption

Percentage of specimens collected under direct observation as a result of an initial
specimen with a confirmatory validity test result of invalid that test positive for drugs

PERdrug positive 2nd collection

33%

Assumption

Initial Validity Testing - Onsite Licensee Testing Facilities

Subpart F

This parameter is used in multiple equations in 26.131(b) calculations:
Percentage of urine specimens with confirmed positive, adulterated, substituted, dilute, or PER retest
invalid validity and/or drug test results retested at the request of the donor at a second
HHS-certified laboratory
Percentage of workers with confirmed positive test results that initiate appeals process

PER appeals

5.0%

Assumption

1.0%

Assumption

Change Cutoff Levels for Marijuana and Opiates - Onsite Testing Facilities
Change Cutoff Levels for Marijuana and Opiates - HHS-Certified Laboratories

Subpart F
Subpart G

Percentage increase in marijuana positive drug tests resulting from reduced cutoff level in PERI marijuana
new rule
Percentage decrease in opiate positive drug tests resulting from the increased cutoff level PERD opiate
in the new rule

40%

Assumption

75%

Assumption

Quality Control Specimens in Each Analytical Run - Onsite Testing Facilities
Annual costs per unit with onsite testing facilities
Percentage cost increase per average urine specimen

Subpart F
PERI cost

10%

Unidentified Interfering Substance/Adulterant - Contact MRO and Specimen Retesting
Annual costs per FFD program
Number of urine specimens per facility per year suspected of having a new adulterant or NUM new adulterant
interfering agent that could make a test result invalid that are sent to a second HHScertified laboratory
Time per specimen for an MRO to speak with the HHS-certified laboratory and determine HOURS MRO
whether a specimen is to be retested at a second HHS-certified laboratory, and the time
to review the results of validity testing at the second HHS-certified laboratory

Percentage of urine specimens with confirmed positive, adulterated, substituted, dilute, or PER retest
invalid validity and/or drug test results retested at the request of the donor at a second
HHS-certified laboratory
Percentage increase in retesting of confirmed positive urine specimens based on the new PERI retest
rule provision to afford retesting of single specimens

26.133
26.163(a)(1)

26.137(e)(6)

Assumption

Subpart G
1

Assumption

0.50 hr

Assumption

5%

Assumption

10%

Assumption

Retesting of Single Collection Specimens with Confirmed Positive Drug and/or Validity Test Results

26.131(b)

Subpart G

26.161(g)

26.165(b)

Activity
Equation
Parameter Description
Blind Sample Testing - 1st Quarter of Contract with a HHS-Certified Laboratory
Annual savings per FFD program which conduct all drug tests at an HHS-certified lab
Percentage of urine specimens that must be blind test specimens submitted in initial 90
days of a contract with an HHS-certified lab, former rule
Maximum number of blind specimens to be submitted in the first 90 days of a contract
with an HHS-certified lab, former rule

Parameter

PER blind specimens, initial 90 days, former
rule
NUM blinds, max, initial 90 days, former rule

Value

50%
500

Source
Subpart G
Former rule requirement, 2.8(e)(2)
of Appendix A
Former rule requirement, 2.8(e)(2)
of Appendix A

Percentage of urine specimens that must be blind test specimens submitted in the first 90 PER blind specimens, initial 90 days, new
days of a contract with an HHS-certified lab - new rule
rule
Maximum number of blind specimens to be submitted in the first 90 days of a contract
NUM blinds, max, initial 90 days, new rule
with an HHS-certified lab, new rule
Minimum number of blind specimens to be submitted in the first 90 days of a contract with NUM blinds, min, initial 90 days, new rule
an HHS-certified lab, new rule

20%

Final rule requirement

100

Final rule requirement

30

Final rule requirement

Percentage of years that a FFD program enters contracts with a different HHS-certified
lab
Number of quarters in a year

10%

Annual costs per FFD program which conducts initial drug testing at an on-site licensee testing facility
Percentage of specimens analyzed by a licensee testing facility that must be QA
specimen

PER FFD programs change HHS lab
NUM quarters

Assumption

4

PER QA specimens

10.0%

Licensee testing facilities include 10
percent of total specimens analyzed
as controls, complying with former
rule 2.7(d) of Appendix A

Percentage of QA specimens that must be a blind specimen
Percentage of blind specimens that must be positive under former requirements

PER QA specimens, blinds
PER Blind specimens, positive

10.0%
20.0%

Percentage of negative initial drug test result specimens submitted to a HHS-certified
laboratory for initial drug testing

PER neg. urine specimens to HHS

1.0%

Assumption
Former rule requirement, 2.8(e)(3)
of Appendix A
Assumption

Blind Sample Testing - Contracts with HHS-Certified Laboratories Older Than 90 Days
Annual savings per FFD program which conduct all drug tests at an HHS-certified lab
Percentage of urine specimens that must be blind test specimens submitted per quarter
for an existing contract with an HHS-certified laboratory - former rule
Maximum number of blind specimens to be submitted in the first 90 days of a contract
with an HHS-certified lab, former rule
Percentage of urine specimens that must be blind performance test specimens submitted
per quarter for an existing contract with an HHS-certified laboratory - new rule

Subpart G
PER blind specimens, per quarter, former
rule
NUM blinds, max, per quarter, former rule

10%

PER blind specimens, per quarter, new rule

1%

Former rule requirement, 2.8(e)(2)
of Appendix A
Former rule requirement, 2.8(e)(2)
of Appendix A
Final rule requirement

100

Final rule requirement

10

Final rule requirement

Maximum number of blind specimens to be submitted per quarter for an existing contract NUM blinds, max, per quarter, new rule
with an HHS-certified lab, new rule
Minimum number of blind specimens to be submitted per quarter for an existing contract NUM blinds, min, per quarter, new rule
with an HHS-certified lab, new rule
Maximum percentage of urine specimens that must be blind specimens submitted per
PER cap on min. num. blinds per quarter
quarter for an existing contract with an HHS-certified laboratory (if total number of
specimens submitted is less than 10 specimens), new rule

Increase in the cost per blind performance test specimen due to the change in the mix of PERIcost blind specimen
the positive to negative ratio of blind specimens in the final rule

Section
26.168(a)(1)

250

25%

75%

Final rule requirement. The number
of blind specimens per quarter is
Final at a minimum of 3 percent (up
to a maximum of 25 percent) or 10
blinds specimens, whichever is
greater.
Assumption, cost increase by 75%
because of change in mix of blind
performance test samples (former
rule required 80% of samples to be
negative, final rule requires 60% of
samples to be positive, 10% false
negative challenge, 10%
adulterated, substitued, or dilute)

26.168(a)(2)

Activity

Equation

Parameter Description

Parameter

Value

Source

PER QA specimens

10.0%

Licensee testing facilities include 10
percent of total specimens analyzed
as controls, complying with former
rule 2.7(d) of Appendix A

Percentage of QA specimens that must be a blind specimen
Percentage of blind specimens that must be positive under former rule

PER QA specimens, blinds
PER Blind specimens, positive, former rule

10.0%
20.0%

Percentage of negative initial drug test result specimens submitted to a HHS-certified
laboratory for initial drug testing

PER neg. urine specimens to HHS

1.0%

Assumption
Former rule requirement, 2.8(e)(3)
of Appendix A
Value under Section 26.167(h)(1),
cell E727

Annual costs per FFD program which conducts initial drug testing at on-site licensee testing facility
Percentage of specimens analyzed by a licensee testing facility that must be QA
specimens (controls)

Section

Exhibit A2 - 10
Activity
Equation
Parameter Description
FFD Programs: Performance Data Reporting and Review

Reporting Requirements
Parameter

Value

Source
Subpart N

Annual savings per program by reducing reporting requirements
FFD program manager hours saved in frequency reduction

HOURS manager

20.0 hr

NRC staff estimate

Savings from NRC reviewing fewer licensee reports
NRC clerical personnel hours saved in reduction in reporting frequency
NRC manager hours saved in reduction in reporting frequency

HOURS clerical
HOURS manager

24.0 hr
20.0 hr

NRC staff estimate
NRC staff estimate

Subpart N
Number of licensee to whom each C/V submits performance data to under the former rule NUM licensees
Cost of mailing (express mail) per information disclosure request

COSTMailing

C/V manager labor burden reduced by only having to produce consolidated report for submission to NRC
Hours of C/V manager time to compile one licensee performance data report
HOURS manager
% savings achieved by consolidating performance data into a single report submitted to PER consolidation
NRC
Reduced Mailing costs
No additional parameters
No Additional Parameters

9
$

Section
26.717(e), (f)

26.717(g)

Assumption
10.00 Assumption

30.0 hr
25%

Reporting and Review of Reportable Events Due to New Validity Testing Requirements

Assumption
Assumption

Subpart N

This parameter is used in the equations below:
Percentage of tested staff covered by 26.203(b)(2)

PER staff

15%

Assumption

Annual cost per unit due to new validity testing requirements
FFD program manager hours required to investigate, analyze, and report an event

HOURS manager

4.0 hr

Assumption

Subpart N
Increase in NRC manager labor to review increased number of reportable events
NRC manager hours required to review a reported event

HOURS manager

3.0 hr

NRC staff

Increase in NRC clerical labor due to increased number of reportable events
NRC clerical hours required to process a reported event

HOURS clerical

1.0 hr

NRC staff

Filing of Forensic Toxicologist's Evaluation

Subpart N

26.719(b)

26.719(b)

26.713(g)

One-time cost per program from clerical support to file and store the forensic toxicologist’s evaluation of the FFD program’s more stringent cutoff levels.
Hours of clerical personnel to file and store the forensic toxicologist’s evaluation of the
FFD program’s more stringent cutoff levels per program
Percentage of FFD programs that use more stringent cut-off levels for drug testing
Percentage of FFD programs who use more stringent cut-off levels for drug testing, but
have not reported to the Commission

HOURSClerical
PERmore stringent cutoffs
PER non-report

0.25 hr
10%
25%

Memorandum to HHS-Certified Laboratory for Incorrect CCF Form

Subpart G

Annual costs per FFD program
NUM memoranda
Number of memoranda per year a collection site used by a facility will write because it
uses an expired Federal custody-and-control form or a non-Federal custody-and-control
form was used for a specimen collection
Time for collection staff to draft a memorandum
HOURS collector

2

Assumption

0.25 hr

Assumption

Licensee Testing Facility Reporting of Testing Data to FFD program (Monthly to Annually)
Annual savings per FFD program with Licensee Testing Facility
Time for a laboratory supervisor per licensee testing facility to prepare a monthly
statistical summary report of urinalysis testing data
Time for a laboratory supervisor per licensee testing facility to prepare an annual
statistical summary report of urinalysis testing data
Number of monthly reports per licensee testing facility per year

Assumption
Assumption

Subpart F
HOURS monthly report

1.50 hr

Assumption

HOURS annual report

4.00 hr

Assumption

NUM monthly reports

12

Number of months in a year.

26.153(g)

26.139(d)

Activity
Equation
Parameter Description
HHS-Certified Laboratory Reporting of Testing Data to FFD program (Monthly to Annually)

Parameter

Time to generate and send an annual or monthly statistical summary report per facility

HOURS lab tech

Number of reports per month per facility
Number of reports that will no longer be sent to a facility

NUM reports per month
NUM reports

Cost to send an annual or monthly statistical summary report via the U.S. Postal Service COSTpostage

Value

Source
Subpart G

0.50 hour

Assumption

1
11
$

NRC Review of Fatigue Information in Annual FFD Performance Reports

former requirement
Final requirement to move from
montly to annual reporting
2.00 Assumption

Subpart I

Annual cost to NRC to review and summarize annual reports on fatigue
NRC clerical hours per year to assist in reviewing and summarizing the additional
information addressing fatigue
NRC manager hours per year to review and summarize the additional information
addressing fatigue

Section
26.169(k)

HOURS Clerical

24.0 hr

Assumption

HOURS Manager

24.0 hr

Assumption

26.203(e)

Exhibit A2 - 11:
Hourly Wage Rates
Hourly Wage Rate
(2002 $)

Worker Type
C/V manager
Clerical

$

15.75 /hour

Collection Site Supervisor

Hourly Wage Rate
(Adjusted 2006 $)

Source/Comments

$

50.00 /hour

Assumption

$

17.52 /hour

Model Facility Data from NEI Jan to May 2002

$

50.00 /hour

Assumption

Collector or Collection Site Personnel

$

22.78 /hour

$

25.34 /hour

Model Facility Data from NEI Jan to May 2002

EAP

$

28.85 /hour

$

32.09 /hour

Model Facility Data from NEI Jan to May 2002

$

70.00 /hour

Assumption

$

35.57 /hour

Model Facility Data from NEI Jan to May 2002

FFD Staff

$

30.00 /hour

Assumption

Forensic Toxicologist

$

93.75 /hour

Derived from quote from a drug testing expert

HR personnel

$

50.00 /hour

Assumption

$

64.52 /hour

Model Facility Data from NEI Jan to May 2002

$

50.00 /hour

Assumption

$

29.52 /hour

Model Facility Data from NEI Jan to May 2002

$

100.00 /hour

Assumption

$

111.24 /hour

Model Facility Data from NEI Jan to May 2002

NRC Clerical

$

40.00 /hour

NRC staff , 2004

NRC Staff

$

87.00 /hour

NRC staff , 2004

$

32.09 /hour

Same as SAP wage rate

Trainer

$

50.00 /hour

Assumption

Training Manager

$

55.00 /hour

Assumption

Facility Supervisor
FFD Program Manager

Contractor/Vendor Worker

$

$

31.98 /hour

58.00 /hour

Lab supervisor
Lab Technician

$

26.54 /hour

Legal
MRO

SAE

$

$

100.00 /hour

28.85 /hour

Facility Worker (weighted average facility workers & C/Vs)

$

55.14 /hour

$

61.34 /hour

Model Facility Data from NEI Jan to May 2002

Facility Worker (not weighted)

$

36.21 /hour

$

40.28 /hour

Model Facility Data from NEI Jan to May 2002

2002 dollars have been adjusted to 2006 using implicit price deflators for GDP in the Survey of Current Business, as reported by the U.S. Department of
Commerce, Bureau of Economic Analysis. Obtained at http://bea.gov/bea/pubs.htm.

Exhibit A2 - 12:
Testing and Applicant Information
Parameter Description
Drug & Alcohol Testing Information
Total Number of Drug Tests per year for all FFD
Programs

Value

Source

135,702 2005 Information Notice, NRC
Table 1. Test results for each test category

Total Number of Drug Tests per Reactor per year

1,280 tests/reactor Calculated

Total Number of Alcohol Tests per year for all FFD
Programs

135,702 2005 Information Notice, NRC
Table 1. Test results for each test category
(one alcohol test and one drug test
conducted for each testing event)
1,280 tests/reactor Calculated

Total Number of Alcohol Tests per year per
Reactor
Total Number of Random Drug and Alcohol Tests
per year for all programs

50,286 2005 Information Notice, NRC
Table 1. Test results for each test category

Total Number of Random Drug and Alcohol Tests
per year per reactor

474 tests/reactor Calculated

Negative Random Drug and Alcohol Test Rate in
2005
Positive Random Drug and Alcohol Test Rate in
2005

99.71% Calculated

Number of confirmed positive alcohol tests per year
for all FFD programs
Number of confirmed positive alcohol tests per
reactor per year
Number of positive drug test results per year for all
FFD programs

0.29% Calculated

196 2005 Information Notice, NRC
Table 5. Number of confirmed positives by
substance
1.85 tests/reactor Calculated

755 2005 Information Notice, NRC
Table 5. Number of confirmed positives by
substance

Number of positive drug test results per reactor
Positive drug test result rate in 2000

7.12 tests/reactor Calculated
0.56% Calculated

Number of marijuana positive drug test results per
year for all FFD programs

432 2005 Information Notice, NRC
Table 5. Number of confirmed positives by
substance
4.08 tests/reactor Calculated

Number of marijuana positive drug test results per
reactor
Positive marijuana drug test result rate in 2000
Number of opiate positive drug test results per year
for all FFD programs
Number of opiate positive drug test results per
reactor
Positive opiate drug test result rate in 2000

0.32% Calculated
16 2005 Information Notice, NRC
Table 5. Number of confirmed positives by
substance
0.15 tests/reactor Calculated
0.01% Calculated

Exhibit A2 - 12:
Testing and Applicant Information
Parameter Description
Value
Drug & Alcohol Testing Information (continued)
Annual number of drug and alcohol tests yielding
positive results for all programs

Source
979 2005 Information Notice, NRC
Table 3. 2005 Test results by test category

Annual number of drug and alcohol tests yielding
positive results per reactor
Annual number of positive pre-access drug and
alcohol test results for all programs

9.24 tests/reactor Calculated

Annual number of positive pre-access drug and
alcohol test results per reactor

6.11 tests/reactor Calculated

Annual number of positive random drug and
alcohol test results for all programs
Annual number of positive random drug and
alcohol test results per reactor
Annual number of positive post-event drug and
alcohol test results for all programs
Annual number of positive post-event drug and
alcohol test results per reactor
Annual number of follow-up drug and alcohol test
results for all programs
Annual number of follow-up drug and alcohol test
results per reactor
Annual number of positive other drug and alcohol
test results for all programs
Annual number of positive other drug and alcohol
test results per reactor
Annual number of for-cause referrals for all
programs
Annual number of for-cause referrals per reactor
Annual number of for-cause tests yielding positive
test results
Positive for-cause testing rate in 2005

648 2005 Information Notice, NRC
Table 3. 2005 Test results by test category

147 2005 Information Notice, NRC
Table 3. 2005 Test results by test category
1.39 tests/reactor Calculated

1 2005 Information Notice, NRC
Table 3. 2005 Test results by test category
0.01 tests/reactor Calculated

31 2005 Information Notice, NRC
Table 3. 2005 Test results by test category
0.29 tests/reactor Calculated

47 2005 Information Notice, NRC
Table 3. 2005 Test results by test category
0.44 tests/reactor Calculated

1,161 2005 Information Notice, NRC
Table 2 - Test Results for Each Test
Category and Work Category
10.95 tests/reactor Calculated
106 2005 Information Notice, NRC
Table 2 - Test Results for Each Test
Category and Work Category
9.13% Calculated

Exhibit A2 - 12:
Testing and Applicant Information
Parameter Description
Validity Test Data
Percentage of adulterated, substitued, dilute, and
invalid validity test results (total)
Percentage of specimens - Dilute (>5 and <20
mg/dL creatinine)
Percentage of specimens - Dilute (2 - 5 mg/dL
creatinine)
Percentage of specimens - Substituted (<2 mg/dL
creatinine)
Percentage of specimens - Adulterated

Percentage of specimens - Invalid

Value

Source

2.691% Consists of the sum of dilute (2-5, 5-20
mg/dL), substituted, adulterated, and
invalid
2.60% Quest Diagnostics, n=435,309, likely a
quarter's data for all Quest Labs
(presented 2/2003)
0.015% DHHS National Laboratory Certification
Program, data from 7/01-6/02 based on
n=5,266,000
0.016% DHHS National Laboratory Certification
Program, data from 7/01-6/02 based on
n=5,266,000
0.025% DHHS National Laboratory Certification
Program, data from 7/01-6/02 based on
n=5,266,001
0.035% DHHS National Laboratory Certification
Program, data from 7/01-6/02 based on
n=5,266,002

Applicant information
Annual number of applicants for authorization for
all programs
Annual number of applicants for authorization per
reactor
Annual number of reportable events for all
programs
Annual number of reportable events per reactor

65,845 NEI Estimate
621 Calculated

135,702 2005 FFD Performance Reports
1,280 Calculated

Annual number of applicants for initial and updated
authorization for all programs
Annual number of applicants for initial and updated
authorization per reactor

20,509 NEI Estimate

Annual number of applicants for initial authorization
for all programs
Annual number of applicants for initial authorization
per reactor

17,869 NEI Estimate

193.48 Calculated

168.58 Calculated

Exhibit A2 - 12:
Testing and Applicant Information
Parameter Description
Applicant information (continued)
Annual number of applicants for updated
authorization for all programs
Annual number of applicants for updated
authorization per reactor

Value

Source
2,640 NEI Estimate
24.91 Calculated

Annual number of applicants for authorization
reinstatement with an interruption of 30 days or
less for all programs
Annual number of applicants for authorization
reinstatement with an interruption of 30 days or
less per reactor
Annual number of applicants for authorization
reinstatement with an interruption of 5 days or less

26,068 NEI Estimate

Annual number of applicants for authorization
reinstatement with an interruption of 6-30 days

204.94 Calculated

Annual number of applicants for authorization
reinstatement with an interruption of between 31
and 365 days for all programs
Annual number of applicants for authorization
reinstatement with an interruption of between 31
and 365 days per reactor

19,268 NEI Estimate

Number of applicants per training session

245.92 Calculated

40.99 Calculated

181.77 Calculated

20 Assumption

Exhibit A2 - 13:
Drug and Alcohol Testing Data (in 2006 $)

Drug and Alcohol Specimen Collection - LABOR COSTS (Source: Model Facility Data from NEI Jan to May 2002)
Time per activity for a drug and alcohol collection

Time
0.60 hr

Activity

Activity definitions

Worker travel time (to test and back to work)

w

w= worker

ID Worker

0.03 hr

w, c

c= collector

Complete Initial Paperwork

0.09 hr

w, c

0.09 hr
0.18 hr
Time for collection
(drug & alcohol)

w, c
w, c

0.39 hr

$

Perform Alcohol Test
Perform Drug Screen
Labor costs for a drug and alcohol collection
Labor collector - per testing process (one urine collection - initial breath collection)

Wage rate

Cost per test
25.34

$

9.84

Labor worker - per testing process (one urine collection - initial breath collection)
0.99 hr
$
55.14 $
Labor costs of drug and alcohol specimen collection (collector & worker) $
Time per activity for a drug specimen collection
Activity
Activity definitions
Time
Worker travel time (to test and back to work)

0.60 hr

w

w= worker

ID Worker

0.03 hr

w, c

c= collector

0.09 hr
0.18 hr
Time for collection
(drug & alcohol)

w, c
w, c

Complete Initial Paperwork
Perform Drug Screen
Labor costs for a drug specimen collection
Labor collector - per testing process (one urine collection)
Labor worker - per testing process (one urine collection)

Wage rate

0.30 hr
$
25.34 $
0.90 hr
$
55.14 $
Labor costs of drug specimen collection (collector & worker) $

54.70
64.54

Cost per test
7.59
49.81
57.40

NEGATIVE TEST RESULTS - SUMMARY OF COSTS (labor, equipment and specimen testing costs)
Negative Result - Alcohol test and Drug test (onsite testing) former rule
Labor costs of drug and alcohol collection (collector & worker)
Equipment cost for alcohol testing (initial test - 2 breath collections)

$
$

Initial drug test - onsite licensee testing facility

$

FFD manager labor per negative test result

$
Total per test $
Negative Result - Alcohol test and Drug test (all testing at HHS certified lab), former rule
Labor costs of drug and alcohol collection (collector & worker)

$

Equipment cost for alcohol testing (initial test - 2 breath collections)

$

Drug testing (initial & confirmatory when necessary) - HHS certified laboratory (all licensee
testing conducted at HHS lab)
$
FFD manager labor per negative test result
$
Total per test $

Description
Costs
include: (1) travel time of worker; (2) collection of
64.54
drug
and
alcohol specimens (the labor of collector and
0.20
worker, collection materials), (3) onsite licensee testing
26.98 costs per urine specimen for drugs; (4) labor of FFD
manager to process negative test results paperwork
3.56
95.28 /test
Description
64.54 Costs include: (1) travel time of worker; (2) collection of
drug and alcohol specimens (the labor of collector and
0.20 worker, collection materials), (3) HHS-certified lab costs
per urine specimen for drugs; (4) labor of FFD manager
22.88 to process negative test results paperwork
3.56
91.18 /test

Negative Result - Alcohol test and Drug & Validity test (onsite testing facility), final rule
Labor costs of drug and alcohol collection (collector & worker)

$

64.54

Equipment cost for alcohol testing (initial test - 1 breath collection)

$

0.10

Validity Testing (onsite) - Total Labor and Reagents cost per specimen
Initial drug test - onsite licensee testing facility

$
$

26.98

$
Total per test $

3.56
99.40 /test

FFD manager labor per negative test result

4.22

Negative Result - Alcohol test and Drug & Validity test (all testing at HHS lab) - final rule
Labor costs of drug and alcohol collection (collector & worker)

$

Equipment cost for alcohol testing (initial test - 1 breath collection)

$

Validity testing incremental (at HHS-certified lab - initial and confirmatory testing)

$

Drug testing (initial & confirmatory when necessary) - HHS certified laboratory (all licensee
testing conducted at HHS lab)
$
FFD manager labor per negative test result
$
Total per test $

Description
64.54 Costs include: (1) travel time of worker; (2) collection of
drug and alcohol specimens (the labor of collector and
0.10 worker, collection materials), (3) HHS-certified lab costs
1.50 per urine specimen for drugs & validity; (4) labor of FFD
manager to process negative test results paperwork
22.88
3.56
92.58 /test

MRO Testing - Negative Result - Alcohol test and Drug & Validity test (at onsite testing facility) - final rule
Labor costs of drug and alcohol collection (collector )

$

9.84

Equipment cost for alcohol testing (initial test - 1 breath collection)

$

0.10

Validity Testing (onsite) - Total Labor and Reagents cost per specimen

$

4.22

Initial drug test - onsite licensee testing facility

$

24.25

FFD manager labor per negative test result

$

3.56

Total per test $

41.97 /test

$

Equipment cost for alcohol testing (initial test - 1 breath collection)

$

Validity testing incremental (at HHS-certified lab - initial and confirmatory testing)
Drug testing (initial & confirmatory when necessary) - HHS certified laboratory (all licensee
testing conducted at HHS lab)
FFD manager labor per negative test result

$

9.84 Same cost as:
Negative Result - Alcohol test and Drug & Validity test
0.10 (all testing at HHS lab) - final rule, no MRO labor for
1.50 travel or the collection process, the labor is accounted
for separately

$
$

22.88
3.56

Total per test $

37.88 /test

MRO Testing - Incremental Cost for Alcohol and Drug Specimen Collection at a Non-Licensee Collection Facility
Additional drug and alcohol specimen collection and shipping costs from non-licensee
collection facilities

$

Description
Same cost as:
Negative Result - Alcohol test and Drug & Validity test
(onsite testing facility), final rule, no MRO labor for travel
or the collection process, the labor is accounted for
separately

Description

MRO Testing - Negative Result - Alcohol test and Drug & Validity test (all testing at HHS lab) final rule
Labor costs of drug and alcohol collection (collector only)

Description
Costs include: (1) travel time of worker; (2) collection of
drug and alcohol specimens (the labor of collector and
worker, collection materials), (3) onsite licensee testing
costs per urine specimen for drugs & validity; (4) labor of
FFD manager to process negative test results
paperwork

Description
Twice the labor cost of drug and alcohol collection
30.00 (collector only) plus shipping cost

Positive (DRUG/VALIDITY/ALCOHOL) TEST RESULT - LABOR COSTS
Subsequent actions - positive drug/validity/alcohol test result
Labor MRO
FFD manager
Worker

Time
0.42 hr

$

2.58 hr
$
0.47 hr
$
Total cost subsequent actions per confirmed positive drug/validity/alcohol test result

Appeal of positive drug/validity/alcohol (no change former rule or final rule)
FFD manager (average labor per result)
Worker

Wage rate
$
$

35.57
55.14

Total cost per appeal (positive drug/validity/alcohol test result)

Wage rate
Source
111.24 Model Facility Data from NEI
35.57 Jan to May 2002
55.14
164.14
Units
12.50 hr
2.00 hr

Source
Discussion with NEI staff,
May 23, 2003

$555 /appeal

Positive (DRUG/VALIDITY/ALCOHOL) TEST RESULT - SUMMARY OF COSTS (labor, equipment and specimen testing costs)
Positive Result - Alcohol/Drug/Validity test - (onsite testing facility), final rule
Labor costs of drug and alcohol collection (collector & worker)

$

64.54

Equipment cost for alcohol testing (initial test - 1 breath collection)

$

0.10

Validity Testing (onsite) - Total Labor and Reagents cost per specimen

$

4.22

Initial drug test - onsite licensee testing facility
Drug testing (intial & confirmatory when necessary) at HHS-certified lab (after initial positive
drug/questionable validity test result at licensee testing facility)

$

26.98

$

35.25

Validity testing incremental (at HHS-certified lab - initial and confirmatory testing)

$

1.50

$
Total per test $
Positive Result - Alcohol/Drug/Validity test - (all testing at HHS certified lab) - final rule

164.14
296.73 /test

Subsequent actions - positive drug/validity/alcohol test result

Labor costs of drug and alcohol collection (collector & worker)

$

64.54

Equipment cost for alcohol testing (initial test - 1 breath collection)

$

0.10

Validity Testing (onsite) - Total Labor and Reagents cost per specimen

$

4.22

Initial and confirmatory (when necessary) drug test

$

22.88

Subsequent actions - positive drug/validity/alcohol test result

$

164.14

Total per test $

255.89 /test

Description
Costs include: (1) travel time of worker; (2) collection of
drug and alcohol specimens (the labor of collector and
worker, collection materials), (3) onsite licensee testing
costs per urine specimen for drugs; (4) HHS-certified lab
cost per specimen for drugs and validity; (5) cost of
subsequent actions resulting from a confirmatory
positive drug/validity test result.

Description
Costs include: (1) travel time of worker; (2) collection of
drug and alcohol specimens (the labor of collector and
worker, collection materials), (3) HHS-certified lab costs
per urine specimen for drugs and validity; (4) cost of
subsequent actions resulting from a confirmatory
positive drug/validity test result.

VALIDITY TESTING (labor & equipment) - Onsite Licensee Testing Facility - Final Rule
time/test
Validity testing - Lab Techinican Labor costs per urine specimen
Time per urine specimen for validity testing
pH test
0.02 hr
creatinine
0.02 hr
one adulterant assay
0.03 hr
Validity testing (onsite) - Total Assay Labor cost per specimen

wage rate
$
$
$
$

29.52
29.52
29.52
1.97 /specimen
Cost per test

Validity testing - Reagants Cost - per urine specimen
Reagent costs of validity testing per urine specimen
pH test
creatinine
one adulterant assay

$
$
$
Validity Testing (onsite) - Total Reagents cost per specimen $
Validity Testing (onsite) - Total Labor and Reagents cost per specimen $

0.25
1.00
1.00
2.25 /specimen
4.22 /specimen

time/calibration
Validity testing - Lab Techinican Labor Costs - Daily Calibration of Equipment
Daily calibration of validity testing equipment
pH test
0.08 hr
$
creatinine
0.17 hr
$
one adulterant assay
0.17 hr
$
Validity Testing (onsite) - Total Labor cost per day to calibrate equipment

wage rate

Validity testing - Reagants Cost - Daily Calibration of Equipment
Reagent costs of validity testing per urine specimen
pH test
$
creatinine
$
$
one adulterant assay
Validity Testing (onsite) - Total Reagent Costs per Daily Calibration $
Cost
Validity Testing - pH meter & accessories per Licensee Testing Facility

Cost per test

ph meter
ph meter probe

$
$

600.00
150.00

29.52
29.52
29.52
$ 12.30 /day

0.50 / day
1.00 / day
1.00 / day
2.50 / day
Equipment life
6.0 years
2.0 years

Annualized cost
$
$

100.00
75.00

VALIDITY TESTING - HHS-certified laboratory - Final Rule
Validity testing incremental (at HHS-certified lab - initial and confirmatory testing)

$

Source
1.50 /test Assumption, range of testing costs from $0.00 to $3.00.

DRUG TESTING - LICENSEE TESTING FACILITY
Source
Drug test (initial) - at onsite licensee testing facility

26.98 /test Model Facility Data from NEI Jan to May 2002

$

DRUG TESTING - HHS- CERTIFIED LABORATORY
Test Type
Drug testing (intial & confirmatory when necessary) at HHS-certified lab (after initial positive
drug/questionable validity test result at licensee testing facility)

Cost/test
$

Source
35.25 /test Model Facility Data from NEI Jan to May 2002

Drug testing (initial & confirmatory when necessary) - HHS certified laboratory (all licensee testing
conducted at HHS lab)

$

22.88 /test Model Facility Data from NEI Jan to May 2002

Dilute Specimen (>=2-20 mg/dL Creatinine) Testing - GC/MS Level of Detection Testing (LOD)

$

75.00 /test Assumption

Cost of retesting - a confirmed positive drug/adulterated or substitued validity test specimen at second
HHS-certified lab (includes specimen preparation and shipping costs)

$

62.50 /test Assumption, range of testing costs from $50.00 to $75.00

Retesting a specimen at a second HHS lab when the initial HHS lab could not identify a suspected
interfering substance/adulterant (includes specimen preparation, packaging, and shipping)

$

125.00 /test Costs for to analyze for adulterants at a second HHS-certified
lab (cost ranges from $50.00 to $200.00 depending on the
contract with the lab)

ALCOHOL TESTING EQUIPMENT
Evidential Breath Testing Device (EBT) - purchase
EBT - compliant with § 26.91(c) in the final rule - included printer and carrying case

Source
2,250 Equipment manufacturer of NHTSA certified EBT (fuel cell)

$

EBT Calibration Equipment

Source

Regulator (to attach calibration canister to EBT)

$

100.00 Equipment manufacturer of NHTSA certified EBT (fuel cell)

Calibration canister

$

75.00 Equipment manufacturer of NHTSA certified EBT (fuel cell)

EBT Exhalent tubes (source: discussion with NEI staff, May 2003)

Unit cost

# of tubes

Cost per test

Exhalent tubes (per test = 2 breath specimens) - former rule

$

0.10 /tube

2

$

0.20

Exhalent tubes (per test = 1 breath specimen) - final rule

$

0.10 /tube

1

$

0.10

Blood Alcohol testing - Existing Rule
Blood alcohol testing - cost per blood specimen to conduct laboratory analysis

$

Cost per blood test for a phlebotomist/RN to arrive at the onsite collection site and conduct the blood draw $

31.98 Model Facility Data from NEI Jan to May 2002
100.00 Assumption

BLIND PERFORMANCE SAMPLE & TESTING COSTS

Subpart G

Cost per blind perfomrance sample & testing - former rule (all testing at HHS-lab)
Cost per blind specimen, former rule: purchased from a vendor, prepared, and shipped to the
HHS-certified laboratory for testing, and FFD manager follow-up to check results (former rule)
Drug testing (initial & confirmatory when necessary) - HHS certified laboratory (all licensee
testing conducted at HHS lab) (former rule)

26.168(a)(1)
26.168(a)(2)

$

Source
29.34 /test Model Facility Data from NEI Jan to May 2002

$

22.88 /test Model Facility Data from NEI Jan to May 2002

Total per test $
Cost per blind performance sample & testing - final rule (all testing at HHS-lab)
Cost per blind specimen, former rule: purchased from a vendor, prepared, and shipped to the
$
HHS-certified laboratory for testing, and FFD manager follow-up to check results (former rule)

52.22
Source
29.34 /test Model Facility Data from NEI Jan to May 2002

Increase in the cost per blind performance test specimen due to the change in the mix of the
positive to negative ratio of blind specimens in the final rule

$

22.00 /test Assumption, 75 percent increase in cost of blind
performance test sample

Drug testing (initial & confirmatory when necessary) - HHS certified laboratory (all licensee
testing conducted at HHS lab)

$

22.88 /test Model Facility Data from NEI Jan to May 2002

Validity testing incremental (at HHS-certified lab - initial and confirmatory testing)

$

1.50 /test Assumption

Total per test $
75.72
Cost per blind performance sample & testing - former rule (for FFD programs with onsite licensee testing facilities)
Source
Cost per blind specimen, former rule: purchased from a vendor, prepared, and shipped to the
$
29.34 /test Model Facility Data from NEI Jan to May 2002
HHS-certified laboratory for testing, and FFD manager follow-up to check results (former rule)
Drug testing (intial & confirmatory when necessary) at HHS-certified lab (after initial positive
drug/questionable validity test result at licensee testing facility) (former rule)

35.25 /test Model Facility Data from NEI Jan to May 2002

$

Total per test $

64.59

Source
Cost per blind performance sample & testing - final rule (or FFD programs with onsite licensee testing facilities)
Cost per blind specimen, former rule: purchased from a vendor, prepared, and shipped to the
$
29.34 /test Model Facility Data from NEI Jan to May 2002
HHS-certified laboratory for testing, and FFD manager follow-up to check results (former rule)
Increase in the cost per blind performance test specimen due to the change in the mix of the
positive to negative ratio of blind specimens in the final rule

$

22.00 /test Assumption, 75 percent increase in cost of blind
performance test sample

Drug testing (intial & confirmatory when necessary) at HHS-certified lab (after initial positive
drug/questionable validity test result at licensee testing facility)

$

35.25 /test Model Facility Data from NEI Jan to May 2002

Validity testing incremental (at HHS-certified lab - initial and confirmatory testing)

$

1.50 /test Assumption

Total per test $

88.09

PAPER WORK REQUIREMENTS - Drug and Alcohol Testing
Information Collection Burden Activities - Negative and Positive Test Results

Source
0.05 hr

Assumption

File paperwork per positive drug and/or alcohol test result

0.25 hr

Assumption

File paperwork per appealed positive drug and/or alcohol test result

0.50 hr

Assumption

File paper work per negative drug and/or alcohol test result

Exhibit A2 - 14:
FFD Programs
Number of
Facilities per
Program

Number of
Units per
Program

On-Site or
Off-Site Testing

Number of
Employees
per Unit

Ameren UE

1

1

On-site

949

949

AmerGen Energy Company

3

3

On-site

949

2,846

Arizona Public Service Company

1

3

On-site

949

2,846

Carolina Power & Light

3

4

Off-site

949

3,795

Constellation Energy

3

5

Off-site

949

4,744

Detroit Edison Company

1

1

Off-site

949

949

FFD Program/Licensee

Total Number of
Employees per
Program

Dominion Generation

4

7

Off-site

949

6,642

Duke Energy Power Company, LLC

3

7

Off-site

949

6,642

Energy Northwest

1

1

On-site

949

949

Entergy Nuclear Operations, Inc.

8

10

Off-site

949

9,488

Exelon Generation Co., LLC

7

14

On-site

949

13,283

FirstEnergy Nuclear Operating Co.

3

4

Off-site

949

3,795

Florida Power Corp.

1

1

Off-site

949

949

FPL Group

4

6

Off-site

949

5,693

Indiana/Michigan Power Co.

1

2

On-site

949

1,898

Nebraska Public Power District

1

1

Off-site

949

949

Nuclear Management Co.

4

6

Off-site

949

5,693

Omaha Public Power District

1

1

Off-site

949

949

Pacific Gas & Electric Co.

1

2

Off-site

949

1,898

PPL Susquehanna, LLC

1

2

On-site

949

1,898

PSEG Nuclear, LLC

2

3

On-site

949

2,846

South Carolina Electric & Gas Co.

1

1

Off-site

949

949

Southern California Edison Co.

1

2

On-site

949

1,898

Southern Nuclear Operating Co.

3

6

On-site

949

5,693

STP Nuclear Operating Co.

1

2

Off-site

949

1,898

Tennessee Valley Authority

3

5

Off-site

949

4,744

TXU Generation Company, LP

1

2

Off-site

949

1,898

Wolf Creek Nuclear Operating Corp.

1

1

Off-site

949

949

Westinghouse

2

2

Off-site

750

1,500

Inpo

1

1

Off-site

250

250

BWX Technologies

1

1

Off-site

811

811

Nuclear Fuel Services

1

1

Off-site

300

300

MOX Facility

1

1

Off-site

400

400

Exhibit A2-15
Activity
Equation
Policy and Procedures

Parameter Description

Fatigue Inputs
Parameter

Value

Source
Subpart I

Section
26.203(a)-(b)

One-time costs per program to account for FFD manager and clerical personnel time and to contract a legal consultant to implement fatigue provisions into the written policies and procedures
Hours of FFD program staff to develop and revise policies and procedures for fatigue
provisions per program
Hours of labor of various managers to review and approve policies and procedures for
fatigue provisions per program
Hours of legal assistance to review and revise policies and procedures for fatigue
provisions
Hours of clerical personnel to support revision of policies and procedures for fatigue
provisions

HOURS ffd_staff

80.0 hr

Assumption

HOURS manager-fatigue

40.0 hr

Assumption

HOURS legal-fatigue

20.0 hr

Assumption

HOURS clerical-fatigue

40.0 hr

Assumption

160.0 hr

Assumption

One-time costs per program to provide additional facility supervisor time to implement the corporate policies on the management of fatigue at the facility level
Hours of facility supervisor time to implement revised corporate policies and procedures
for fatigue

HOURS facility supervisor-fatigue

Training

Subpart I
The following variables are used in several of the equations in this section
Length of training addressing the fatigue-related KAs per session

HOURS Training-Fatigue

1.0 hr

Assumption

Length of comprehensive examination increment addressing the fatigue-related KAs

HOURS Examination-Fatigue

0.2 hr

Assumption

HOURS Preparation-Fatigue

0.5 hr

Assumption

HOURS Consultant

2.6 hr

Assumption

Hours of incremental preparation and examination grading per session addressing the
fatigue-related KAs
One-time cost per program associated with revising the training program to include fatigue KAs
Hours of industry consultant time per program to develop generic training materials for
use by the entire industry
Hourly wage for industry consultant to develop generic training materials for use by the
entire industry

WAGE Training_Consultant_Loaded

HOURS Trainer
Hours of training time per program to revise the training materials to address fatigue KAs
Hours of training manager time per program to revise the training materials to address
HOURS Training Manager
fatigue KAs
Hours of FFD proram manager time per program to revise the training program to
HOURS Manager
address fatigue KAs
Hours of clerical personnel time to support the revision of the training program to address HOURS Clerical
fatigue KAs

$

90.00 /hour
8.0 hr

Assumption

2.0 hr

Assumption

2.0 hr

Assumption

4.0 hr

Assumption

50

Assumption

25%

Assumption

20

Assumption

20%
1.00 hr

Assumption
Assumption

One-time costs per program to retrain existing employees on the fatigue related KAs
No additional parameters
One-time costs per program for trainers to administer the training on the fatigue-related KAs
Number of workers per training session per facility

NUM Sessions

Annual cost per program for incoming employees to take the training course increment for fatigue-related KAs
Turnover Rate (e.g., new hires including outage workers) covered by fatigue provision per PER Applicants
facility per year
Annual cost per program for trainers to administer training course for fatigue-related KAs
Number of workers per training session per facility

NUM Sessions

Annual costs per program for employees to take the refresher training increment addressing fatigue-related KAs
Percentage of employees taking refresher training
PER Refresher
Length of fatigue-related portion of refresher training course
HOURS Fatigue Training

26.203(c)

Activity

Equation

Parameter Description

Parameter

Annual costs per program for trainers to administer the refresher training increment addressing fatigue-related KAs
Number of workers per training session per facility
NUM Sessions
Length of fatigue-related refresher training course

HOURS Fatigue Training

Value
20
1.00 hr

Retaining Fatigue Records

see Appendix 2, Exhibit A2-3

26.203(d)

Assumption
Assumption
Assumption

12.0 hr

Assumption

1.0 hr

Assumption

Summarize Waiver Data

Section

Assumption

Subpart I

Annual cost per program to physically place the documentation required under 26.197(d)(1), (2), (4), and (5) into the appropriate filing cabinets or storage facilities
Annual number of hours per facility to store individuals' work hours under final rule
HOURS Work Hours
40.0 hr
Annual number of hours per facility to store work hour reviews under final rule
HOURS Reviews
4.0 hr
Annual number of hours per facility to store fatigue assessment documentation under final HOURS Assessments
10.0 hr
rule
Annual savings per program as a result of fewer waivers being issued
Annual number of hours per facility to file deviation authorizations under existing licensee HOURS WaiverTS
technical specifications
Annual number of hours per facility to file waivers under final rule
HOURS WaiverNew

Source

Subpart I

26.203(e)(1)

Annual cost per program to review documentation for the waived individual work hour controls in 26.205(d)(1)-(5)(i) from the previous calendar year, categorize the instances of waivers as required, and report the data and frequency
distribution in the FFD program performance report
Annual hours of clerical worker labor to tally the annual number of waivers of each type, HOURS Clerical
separate operating waivers from outage waivers, produce a frequency distribution, and
report these data in the FFD program report
Annual hours of managerial labor to review the waivers data included in the FFD program HOURS Manager
report

25.0 hr

Assumption

25.0 hr

Assumption

Summarize Corrective Actions
Annual cost per program to report corrective actions, if any, resulting from the analyses of waiver documentation.
Annual number of clerical labor hours to produce a summary of corrective actions and
HOURS Clerical
report this information in the FFD program report
Annual number of FFD staff labor hours to produce a summary of corrective actions and HOURS FFD staff
report this information in the FFD program report
Annual number of manager labor hours to review and summarize corrective actions
HOURS Manager
included in the FFD program report

Subpart I
1.0 hr

Assumption

4.0 hr

Assumption

1.0 hr

Assumption

Fatigue Management Audits
Annual cost per program to audit fatigue management as part of the overall FFD program audit required under 26.41
HOURS Auditor
Annual number of auditor labor hours to audit the management of worker fatigue
HOURS Clerical
Annual number of clerical labor hours to assist with the audit of fatigue management
Annual number of manager labor hours to assist with the audit of fatigue management
HOURS Manager
program
Multiplier to yield annualized costs
PER Annualized

Subpart I
40.0 hr
16.0 hr
16.0 hr

Assumption
Assumption
Assumption

50%

Calculated

26.203(e)(2)

26.203(f)

Activity
Equation
Parameter Description
Calculating Work Hours

Parameter

Value

Source
Subpart I

Section
26.205(b)

One-time cost per program to modify existing timekeeping systems in order to record, track, and document the actual hours worked by individuals covered under the individual work hour controls of paragraph 26.205(d)
One-time cost per facility to modify existing timekeeping systems, or develop new
COST System
$50,000
Exhibit A2-16
systems, to record and track work hour data
Annual costs per program associated with monitoring and managing the hours actually worked by individuals, including filing or backing up work hour records
HOURS Supervisor_Annual
200.0 hr
Annual hours of supervisor labor to monitor and manage the hours actually worked by
individuals at one facility, including filing or backing up work hour records
Annual hours for clerical labor to monitor and manage the hours actually worked by
HOURS Clerical_Annual
50.0 hr
individuals at one facility, including filing or backing up work hour records

Scheduling Work Hours

Assumption
Assumption

Subpart I

One-time cost per program to renegotiate collective bargaining agreements in order to address issues related to the assignment of overtime
One-time hours needed for licensee management to work with union representatives in HOURS Management
collective bargaining
One-time hours needed for licensee legal staff to work with union representatives in
HOURS Legal
collective bargaining
Percentage of licensees whose schedule modifications lead to revisions to collective
PER Negotiation
bargaining agreements or to discussions with employee committees
Annual costs per program to prepare modified work schedules on an ongoing basis for all employees covered by the rule
Annual hours needed for workers to support supervisors in reviewing, analyzing, and
HOURS Scheduler
modifying schedules

60.0 hr

Assumption

40.0 hr

Assumption

26.205(c)

Assumption
100%

2,080 hr

Outage Day-off Requirements
The following variables are used in several of the equations in this section

Assumption

Subpart I

Number of weeks in modeled refueling outage
Number of outage work hours permitted under the former rule
Number of outage work hours permitted under the final rule for operators and HP/Chem

WEEKS Outage
HOURS Outage Pre-Rule
HOURS Outage Post-Rule

6
72.0 hr
67.2 hr

Adjustment factor to annualize modeled outages at single unit sites that do not occur
annually
Adjustment factor to annualize modeled outages at dual unit sites that do not occur
annually
Adjustment factor to annualize modeled outages at triple unit sites that do not occur
annually
Number of single unit facilities
Number of dual unit facilities
Number of triple unit facilities

FACTOR Single Unit Site Outage

0.55

Assumption

FACTOR Dual Unit Site Outage

1.1

Assumption

FACTOR Triple Unit Site Outage

2

Assumption

NUM Single Unit Facilities
NUM Dual Unit Facilities
NUM Triple Unit Facilities

29
34
2

NRC Information Digest
NRC Information Digest
NRC Information Digest

26.205(d)(4)-(6)

Exhibit A2-16
Assumption
Assumption

Annual costs to pay for in processing of additional contract maintenance staff during outages to replace lost outage work hours from permanent operator staff at single and multi-unit sites
Average number of permanent operators at a single unit site (pre-rule)
NUM Baseline Operators
90
Work hours data collection
The average cost to conduct in-processing of one contract maintenance or engineering COST Process_Maintenance/Engineer
$1,000
Exhibit A2-16
worker
Annual costs to pay for in processing of additional contract HP/Chem staff during outages to replace lost outage work hours from permanent HP/Chem staff at single and multi-unit sites
Average number of HP/Chem workers per single unit site (pre-rule)
NUM Baseline HP/Chem
45
Data from four single-unit sites
The average cost to conduct in-processing of one contract HP/Chem worker
COST Process_HP/Chem
$1,000
Exhibit A2-16
Annual costs to pay for in processing and wages of additional contract HP/Chem staff during outages to replace lost outage work hours from contract HP/Chem staff at single and multi-unit sites
Average number of Contract HP/Chem workers per reactor (pre-rule)
NUM Baseline Contract HP/Chem
46
Assumption
The average cost to conduct in-processing of one contract HP/Chem worker
COST Process_HP/Chem
$1,000
Exhibit A2-16
The weekly cost of one contract HP/Chem worker
WCOST Contract_HP/Chem
$4,040
Is equal to the regular wage * 40 +
the overtime wage * 27.2

Annual costs to pay for in processing of additional contract maintenance staff during outages to replace lost outage work hours from permanent operator staff who are added to the skeleton crew for the operating unit at multi-unit sites
NUM Replacements for Operators_Outage
4
NRC data collection
Number of additional contract maintenance workers needed at a dual-unit site to
Unit (Dual)
compensate for the lost work hours of a permanent operator based at a co-located
operating unit
NUM Replacements for Operators_Outage
8
Assumption
Number of additional contract maintenance workers needed at a triple-unit site to
Unit (Triple)
compensate for the lost work hours of a permanent operator based at a co-located
operating unit

Activity

Equation

Parameter Description

Parameter

Value

Source

Section

Annual costs to pay for in processing of additional contract maintenance staff during outages to replace lost outage work hours from permanent maintenance staff who are added to the skeleton crew for the operating unit at multi-unit sites
NUM Replacements for
3
NRC data collection
Number of additional contract maintenance workers needed at a dual-unit site to
compensate for the lost work hours of a permanent maintenance workers based at a co- Maintenance_Outage Unit (Dual)
located operating unit
Number of additional contract maintenance workers needed at a triple-unit site to
NUM Replacements for
6
Assumption
compensate for the lost work hours of a permanent maintenance workers based at a co- Maintenance_Outage Unit (Triple)
located operating unit

Annual costs to pay for in processing of additional contract HP/Chem staff during outages to replace lost outage work hours from permanent HP/Chem staff who are added to the skeleton crew for the operating unit at multi-unit sites
Number of additional contract HP/Chem workers needed at a dual-unit site to compensateNUM Replacements for HP/Chem_Outage
2
NRC data collection
for the lost work hours of permanent HP/Chem workers based at a co-located operating Unit (Dual)
unit
NUM Replacements for HP/Chem_Outage
4
Assumption
Number of additional contract HP/Chem workers needed at a triple-unit site to
Unit (Triple)
compensate for the lost work hours of permanent HP/Chem workers based at a colocated operating unit
Annual costs to pay for in processing of additional contract maintenance staff during outages to replace lost outage work hours from permanent operator staff who are part of the non-skeleton crew staff that continues to support the outage
at multi-unit sites
Number of operators on the non-skeleton crew currently at a dual unit site
NUM Baseline Operators - Non Skeleton
60
Assumption
Crew (Dual)
Number of operators on the non-skeleton crew currently at a triple unit site
NUM Baseline Operators - Non Skeleton
120
Assumption
Crew (Triple)
Annual costs to pay for in processing of additional contract HP/Chem staff during outages to replace lost outage work hours from permanent HP/Chem staff who are part of the non-skeleton crew staff that continues to support the outage at
multi-unit sites
Number of HP/Chem on the non-skeleton crew currently at a dual unit site
NUM Baseline HP/Chem - Non-Skeleton
32
Assumption
Crew Dual Unit site
Number of HP/Chem on the non-skeleton crew currently at a triple unit site
NUM Baseline HP/Chem - Non-Skeleton
64
Assumption
Crew Triple unit site
Pre-Order Baseline: Annual Costs to pay for in-processing of additional outage security staff
The average pre-order number of affected permanent security staff per facility
Average number of weekly work hours per security worker pre-order
Average number of weekly work hours per security worker post-rule
The average cost to conduct in-processing of one contract security staff person
Annualizing factor for outage frequency - all sites

NUM Perm_Sec
HOURS Sec_Outage_pre-order
HOURS Sec_Outage_post-rule
COST Process_Sec
FACTOR Outage

77
72
60
$1,000
0.9

Assumption
Assumption
Assumption
Exhibit A2-16
Assumption

Activity
Equation
Parameter Description
Waivers from Individual Work Hour Limits
Annual cost per program to conduct and document a fatigue assessment
Number of weeks per year during which facilities experience outage conditions (refueling
and unplanned outages)
The costs per week under outage conditions incurred by facilities as a result of their
restricted ability to grant waivers
Number of weeks per year during which facilities experience full power conditions
The costs per week under at-power conditions incurred by facilities as a result of their
restricted ability to grant waivers

Parameter

Value

WEEKS Outage
WEEKLYCOSTS Outage

Appendix 3

WEEKS Power
WEEKLYCOSTS Power

44
$1,087

Exhibit A2-16
Appendix 3

Subpart I
NUM Waivers
PER Self-Declare

Annual management cost per program to call in replacement workers to substitute for any workers who are sent home to rest following a fatigue assessment
Supervisor hours expended to identify and call in a replacement worker
HOURS Supervisor
Annual cost per program due to the extra turnover associated with the replacement worker and other lost productivity
Labor hours resulting from an additional turnover due to the replacement of a fatigued
HOURS Turnover
worker with a substitute worker
Annual incremental labor costs associated with the replacement worker
Average number of hours worked by the replacement worker per incident

HOURS Substitute

15

Assumption

10%

Assumption

0.5 hr

Assumption

1.0 hr

Assumption

6.0 hr

Assumption

Work Hour Control Reviews
Annual cost per program to conduct work hour control reviews
Annual number of times a facility will review the control of work hours for individuals who
are subject to this subpart
Time per participating supervisor to review overtime hours under final rule, per review
Number of supervisors participating in the review
Annual time for manager to review overtime hours under existing technical specifications

Subpart I
NUM Reviews
HOURS Review
NUM Manager
HOURS former_Review

Section
26.207

Exhibit A2-16
8
$25,689

Self-Declarations of Fatigue
The following variables are used in several of the equations in this section
Total annual number of persons, per site, granted waivers from the requirements
contained in 26.205(d)(1) - (5)(i)
Percentage of NUM Waivers that self-declare to a condition of fatigue

Source
Subpart I

1

Assumptions

4.0 hr
4
4.0 hr

Assumption
Assumption
Assumption

26.209

26.205(e)

Activity
Equation
Parameter Description
Fatigue Assessments
The following variables are used in several of the equations in this section
Total annual number of fatigue assessments per reactor, including those conducted forcause, self-declared, post-event, and follow-up
Percentage of fatigue assessments that result in a finding of fatigue

Parameter

NUM Assessments
PER Fatigue

Annual cost per program to conduct a fatigue assessment for cause, for self-declaration, post-event, and follow-up
Hours needed to complete one fatigue assessment
HOURS Assessment

Value

Source
Subpart I

50

Assumption

37.5%

Assumption

0.5 hr

Assumption

Section
26.211(a)-(d)

Annual cost per program to resolve challenges that may be brought by workers who, after self-declaring to a state of fatigue, object to negative results from their fatigue assessment
Annual number of self-declarations of fatigue per facility
Percent of annual number of self-declarations of fatigue per facility where the results of
the fatigue assessment are negative
Percent of negative fatigue assessment results that are challenged by workers
Amount of worker time to raise and resolve one incident
Number of hours of Employee Concerns Manager time to raise and resolve one incident

NUM Self-Declarations
PER Not_Fatigued

20
50%

Assumption
Assumption

PER Object
HOURS Worker
HOURS ECM

30%
0.5 hr
2.5 hr

Assumption
Assumption
Assumption

Number of hours of supervisor time to raise and resolve one incident

HOURS Supervisor

1.0 hr

Assumption

Post-Fatigue Assessment Controls and Conditions
The following variables are used in several of the equations in this section
Total annual number of fatigue assessments per reactor, including those conducted forcause, self-declared, post-event, and follow-up
Percentage of fatigue assessments that result in a finding of fatigue

Subpart I
NUM Assessments
PER Fatigue

Annual cost per program to call in replacement workers to substitute for any workers who are sent home to rest following a fatigue assessment
Supervisory hours expended to identify and call in a replacement worker
HOURS Supervisor
Annual cost per program resulting from extra "turnover" of duties to the replacement worker and other lost labor productivity
HOURS Turnover
Labor hours resulting from an additional turnover due to the replacement of a fatigued
worker with a substitute worker
Annual costs per program associated with the replacement worker
Average number of hours worked by the replacement worker per incident

HOURS Substituted

50

Assumption

37.5%

Assumption

0.5 hr

Assumption

1.0 hr

Assumption

6.0 hr

Assumption

Documenting Fatigue Assessments

Subpart I

26.211(e)

26.211(f)

Annual costs per program to document the results of any fatigue assessments conducted, the circumstances that necessitated the fatigue assessment, and any controls and conditions that were implemented
Total annual number of fatigue assessments per reactor, including those conducted for- NUM Assessments
50
Assumption
cause, self-declared, post-event, and follow-up
Time needed to document a fatigue assessment
HOURS Document
0.33 hr
Assumption

Summarize Fatigue Assessment Data

Subpart I

26.211(g)

Annual cost per program to report the number of fatigue assessments conducted during the previous calendar year, the conditions under which each fatigue assessment was conducted, and the management actions, if any, resulting from
Annual number of clerical labor hours to review and tally the number of fatigue
HOURS Clerical
20.0 hr
Assumption
assessments conducted during the previous calendar year, identify the conditions under
which each fatigue assessment was conducted, and report the management actions, if
any, resulting from each fatigue assessment included in the FFD program report
Annual number of manager labor hours to review the summary information to be sent to
NRC

HOURS Manager

10.0 hr

Assumption

Exhibit A2 - 16:
Fatigue Input Data
FATIGUE - SECURITY COMPENSATION AND HIRING COSTS
Data Element
COST/Sec_Hire_Contract - The one-time cost to hire, process, and conduct
initial training of an outage security worker

Estimate

Source

$1,000

Assumption

Estimate
$1,000

Assumption

FATIGUE - MAINTENANCE COMPENSATION AND HIRING COSTS
Data Element
COST/Process_Maint - The average cost to conduct in-processing of one
contract maintenance worker

Source

FATIGUE PROVISIONS - IMPLEMENTATION COST VARIABLES
Cost/System - One-time cost per facility to modify existing timekeeping systems, or develop new systems, to record and track work hour data
PLANT
Estimate
Source Data
Comments
Source data were provided by six facilities.
A
$500
B
$250,000
C
minimal
D
TBD
E
no estimate
F
$50,000
$50,000
Cost/System
Data Element
Estimate
Source Data
Comments
Average U.S. Nuclear Refueling Outage: NEI - Plant Performance data, in
5.71
Accessed 1/5/2005
weeks
Rounded Estimate
6
WEEKS/Outage - Number of weeks per year during which facilities experience outage conditions (refueling and unplanned outages)
Data Element
Estimate
Source Data
Assuming capacity factor of 85%
7.80
Rounded Estimate
8
WEEKS/Power - Number of weeks per year during which facilities experience full power conditions
Data Element
Estimate
Source Data
Assuming capacity factor of 85%
44.20
Rounded Estimate
44

Comments
Multiply 15% by 52 weeks

Comments
Multiply 85% by 52 weeks

FATIGUE - HP/CHEM COMPENSATION AND HIRING COSTS
Data Element
one contract HP/Chem worker

Estimate
$1,000

Source
Assumption

Crosswalk Index of Subpart Sections and Exhibits
Subpart

Section

Section Description

Exhibits

NA
NA

NA
NA

Subpart A

26.4(g)

NRC Implementation - One-time Training
NRC Implementation - One-time Revision of Inspection
Procedures
FFD Program Personnel Subject to the Rule

Subpart A

26.4(j)

Individuals Subject to Another Acceptable Program

Subpart B

26.33

Behavioral Observation

Subpart B
Subpart B

26.27(a)
26.29(a)

Subpart B
Subpart B

26.29(b)
26.29(c)(2)

Policy and Procedure Revisions - Overall Program
Revise and Implement Training, Including Behavioral
Observation
Comprehensive Examination
Exhibit A2 - 3: Training and Examinations
Comprehensive Examination in Lieu of Refresher Training Exhibit A2 - 3: Training and Examinations

Subpart B

26.31(b)(1)(i)

Subpart B

26.31(b)(2)

Subpart B

26.31(d)(2)

Subpart B

26.31(d)(3)

Subpart B

26.37(d)

Subpart B

26.39(c)

Subpart B

26.41(b)

Subpart B

26.41(c)(2)

Subpart C
Subpart C
Subpart C
Subpart C
Subpart C
Subpart C
Subpart C
Subpart C
Subpart C

26.55(a)(1)
26.55(a)(2)
26.55(a)(3)
26.55(a)(4)
26.57(a)(1)
26.57(a)(2)
26.57(a)(3)
26.57(a)(4)
26.59(a)(1)

Subpart C

26.59(a)(2)

Subpart C

26.59(a)(3)

Subpart C

26.59(a)(4)

Subpart C

26.59(c)(1)

Subpart C

26.59(c)(2)

Subpart C

26.59(c)(3)

Background Checks, Psychological Evaluations, Credit
History, Criminal History
DOT-Approved Specimen Collection Facilities

Exhibit A2 - 2: Written Policies and Procedures
Exhibit A2 - 3: Training and Examinations
Exhibit A2 - 1: Individuals Subject to the FFD
Program
Exhibit A2 - 1: Individuals Subject to the FFD
Program
Exhibit A2 - 6: Activities Related to Potential Policy
Violations
Exhibit A2 - 2: Written Policies and Procedures
Exhibit A2 - 3: Training and Examinations

Exhibit A2 - 1: Individuals Subject to the FFD
Program
Exhibit A2 - 1: Individuals Subject to the FFD
Program
Reasonable Effort to Track Randomly Selected Individuals Exhibit A2 - 6: Activities Related to Potential Policy
for Testing
Violations
Forensic Toxicologist Review of More Stringent Cutoff
Exhibit A2 - 4: Audits, Inspections, Certifications and
Levels
Corrective Action
Disclosure requirements positive test results
Exhibit A2 - 6: Activities Related to Potential Policy
Violations
Review of FFD Policy Violations
Exhibit A2 - 6: Activities Related to Potential Policy
Violations
Audit Frequency
Exhibit A2 - 4: Audits, Inspections, Certifications and
Corrective Action
Elimination of Audit Duplication of HHS-Certified
Exhibit A2 - 4: Audits, Inspections, Certifications and
Laboratories
Corrective Action
Self-Disclosure for Initial Applicants
Exhibit A2 - 5: Authorizations
Suitable Inquiry for Initial Applicants
Exhibit A2 - 5: Authorizations
Pre-Access Testing for Initial Applicants
Exhibit A2 - 5: Authorizations
Random Testing Pool for Initial Applicants
Exhibit A2 - 5: Authorizations
Self Disclosure for Update Applicants
Exhibit A2 - 5: Authorizations
Suitable Inquiry for Update Authorization
Exhibit A2 - 5: Authorizations
Pre-Access Testing for Update Applicants
Exhibit A2 - 5: Authorizations
Random Testing Pool for Update Applicants
Exhibit A2 - 5: Authorizations
Authorization Reinstatements with Interruptions: SelfExhibit A2 - 5: Authorizations
Disclosure for Reinstatement Applicants with 31-365 Day
Interruption
Authorization Reinstatements with Interruptions: Suitable Exhibit A2 - 5: Authorizations
Inquiry for Reinstatement Applicants with 31-365 Day
Interruption
Authorization Reinstatements with Interruptions: PreExhibit A2 - 5: Authorizations
Access Testing for Reinstatement Applicants with 31-365
Day Interruption
Authorization Reinstatements with Interruptions: Random Exhibit A2 - 5: Authorizations
Testing Pool for Reinstatement Applicants with 31-365 Day
Interruption
Authorization Reinstatements with Interruptions: SelfExhibit A2 - 5: Authorizations
Disclosure (and Suitable Inquiry) for Reinstatement
Applicants with Less than 31 Day Interruption
Authorization Reinstatements with Interruptions: PreExhibit A2 - 5: Authorizations
Access Testing for Reinstatement Applicants with Less
than 31 Day Interruption
Authorization Reinstatements with Interruptions: Random Exhibit A2 - 5: Authorizations
Testing Pool for Reinstatement Applicants with Less than
31 Day Interruption

Crosswalk Index of Subpart Sections and Exhibits
Subpart

Section

Subpart E

26.103

Subpart E
Subpart E

Section Description

Exhibits

26.119
26.127

FFD Manager Determines Confirmed Positive Test for
Alcohol (BAC 0.02 < 0.04)
Shy Bladder Medical Evaluation
Licensee Testing Facility Policy and Procedure Revisions

Exhibit A2 - 8: Alcohol Testing
Exhibit A2 - 7: Urine Specimen Collections
Exhibit A2 - 2: Written Policies and Procedures

Subpart E

26.105(b)

Urine Collection: Inspecting Contents of Donor's Pockets

Exhibit A2 - 7: Urine Specimen Collections

Subpart E
Subpart E

26.109(a)
26.109(b)(2)

Exhibit A2 - 7: Urine Specimen Collections
Exhibit A2 - 7: Urine Specimen Collections

Subpart E
Subpart E
Subpart E
Subpart E

26.83(a)
26.85(a),(b)
26.89(b)(2)
26.89(b)(3)

Subpart E

26.91(b)

Subpart E

26.91(c)

Subpart E
Subpart E

26.95(c)
26.99(b)

Subpart F

26.133

Subpart F

26.131(b)

Urine Specimen Quantity: Minimum Quantity of 30 mL
Urine Specimen: At Least 30 mL, but Less than
Predetermined Quantity
Blood Collection for Confirmatory Alcohol Testing
Urine and Alcohol Collector Training
Urine Collection: Donors Without Adequate ID
Urine Collection: Eliminate Listing Medications on the CCF
Form and add description of testing process
Purchase of EBT and Calibration Equipment and Related
Training
Required Use of an EBT on the NHTSA CPL for
Confirmatory Testing
One Breath Specimen Collection for Initial Alcohol Test
Lowering Initial BAC Requiring Confirmatory Test to BAC
0.02
Change Cutoff Levels for Marijuana and Opiates - Onsite
Testing Facilities
Initial Validity Testing - Onsite Licensee Testing Facilities

Subpart F

26.131(b)

Subpart F

26.131(b)

Subpart F

26.137(e)(6)

Subpart F

26.139(d)

Subpart G

26.153(e)

Subpart G

26.161(b)(1)

Subpart G

26.161(g)

Subpart G

26.163(a)(1)

Subpart G

26.165(b)

Subpart G

26.168(a)(1)

Subpart G

26.168(a)(2)

Subpart G

26.169(k)

Subpart H

26.189(b)(3)

Subpart H

26.189(c)

Subpart I
Subpart I
Subpart I
Subpart I
Subpart I
Subpart I

26.207
26.209
26.203(a)-(b)
26.203(c)
26.203(d)
26.203(e)

Subpart I
Subpart I

26.203(e)(1)
26.203(e)(2)

Exhibit A2 - 9: Drug and validity testing (licensee
testing facilities and HHS-certified laboratories)
Exhibit A2 - 9: Drug and validity testing (licensee
testing facilities and HHS-certified laboratories)
Quality Control Specimens in Each Analytical Run - Onsite Exhibit A2 - 9: Drug and validity testing (licensee
Testing Facilities
testing facilities and HHS-certified laboratories)
Licensee Testing Facility Reporting of Testing Data to FFD Exhibit A2 - 10: Reporting Requirements
program (Monthly to Annually)
Pre-Award Inspections of HHS-Certified Laboratories
Exhibit A2 - 4: Audits, Inspections, Certifications and
Corrective Action
Validity Testing (On-site Licensee Testing Facilities and
Exhibit A2 - 9: Drug and validity testing (licensee
HHS-Certified Laboratories)
testing facilities and HHS-certified laboratories)
Unidentified Interfering Substance/Adulterant - Contact
Exhibit A2 - 9: Drug and validity testing (licensee
MRO and Specimen Retesting
testing facilities and HHS-certified laboratories)
Change Cutoff Levels for Marijuana and Opiates - HHSExhibit A2 - 9: Drug and validity testing (licensee
Certified Laboratories
testing facilities and HHS-certified laboratories)
Retesting of Single Collection Specimens with Confirmed Exhibit A2 - 9: Drug and validity testing (licensee
Positive Drug and/or Validity Test Results
testing facilities and HHS-certified laboratories)
Blind Sample Testing - 1st Quarter of Contract with a HHS- Exhibit A2 - 9: Drug and validity testing (licensee
Certified Laboratory
testing facilities and HHS-certified laboratories)
Blind Sample Testing - Contracts with HHS-Certified
Exhibit A2 - 9: Drug and validity testing (licensee
Laboratories Older Than 90 Days
testing facilities and HHS-certified laboratories)
HHS-Certified Laboratory Reporting of Testing Data to FFD Exhibit A2 - 10: Reporting Requirements
program (Monthly to Annually)
Definition of "Potentially Disqualifying Information"
Exhibit A2 - 6: Activities Related to Potential Policy
Violations
Face-to-Face Determinations of Fitness
Exhibit A2 - 6: Activities Related to Potential Policy
Violations
Waivers from Individual Work Hour Limits
Exhibit A2-15: Fatigue Inputs
Self-Declarations of Fatigue
Exhibit A2-15: Fatigue Inputs
Policy and Procedures
Exhibit A2-15: Fatigue Inputs
Training
Exhibit A2-15: Fatigue Inputs
Retaining Fatigue Records
Exhibit A2-15: Fatigue Inputs
NRC Review of Fatigue Information in Annual FFD
Exhibit A2 - 10: Reporting Requirements
Performance Reports
Summarize Waiver Data
Exhibit A2-15: Fatigue Inputs
Summarize Corrective Actions
Exhibit A2-15: Fatigue Inputs

Subpart I
Subpart I

26.203(f)
26.205(b)

Fatigue Management Audits
Calculating Work Hours

Exhibit A2 - 8: Alcohol Testing
Exhibit A2 - 3: Training and Examinations
Exhibit A2 - 7: Urine Specimen Collections
Exhibit A2 - 7: Urine Specimen Collections
Exhibit A2 - 8: Alcohol Testing
Exhibit A2 - 8: Alcohol Testing
Exhibit A2 - 8: Alcohol Testing
Exhibit A2 - 8: Alcohol Testing
Exhibit A2 - 9: Drug and validity testing (licensee
testing facilities and HHS-certified laboratories)
Exhibit A2 - 3: Training and Examinations

Validity Testing (On-site Licensee Testing Facilities and
HHS-Certified Laboratories)
Initial Validity Testing - Onsite Licensee Testing Facilities

Exhibit A2-15: Fatigue Inputs
Exhibit A2-15: Fatigue Inputs

Crosswalk Index of Subpart Sections and Exhibits
Subpart

Section

Section Description

Exhibits

Subpart I
Subpart I
Subpart I
Subpart I
Subpart I
Subpart I
Subpart N
Subpart N

26.205(c)
26.205(d)(4)-(6)
26.205(e)
26.211(a)-(d)
26.211(e)
26.211(f)
26.713(g)
26.717(e), (f)

Scheduling Work Hours
Outage Day-off Requirements
Work Hour Control Reviews
Fatigue Assessments
Post-Fatigue Assessment Controls and Conditions
Documenting Fatigue Assessments
Filing of Forensic Toxicologist's Evaluation
FFD Programs: Performance Data Reporting and Review

Exhibit A2-15: Fatigue Inputs
Exhibit A2-15: Fatigue Inputs
Exhibit A2-15: Fatigue Inputs
Exhibit A2-15: Fatigue Inputs
Exhibit A2-15: Fatigue Inputs
Exhibit A2-15: Fatigue Inputs
Exhibit A2 - 10: Reporting Requirements
Exhibit A2 - 10: Reporting Requirements

Subpart N

26.717(g)

FFD Programs: Performance Data Reporting and Review Exhibit A2 - 10: Reporting Requirements

Subpart N

26.719(b)

Subpart N

26.719(b)

Reporting and Review of Reportable Events Due to New
Validity Testing Requirements
Reporting and Review of Reportable Events Due to New
Validity Testing Requirements

Exhibit A2 - 10: Reporting Requirements
Exhibit A2 - 10: Reporting Requirements