ML053080117

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Comment (21) Submitted by Jim Pulley on Proposed Rule PR-026, Re Fitness for Duty Programs
ML053080117
Person / Time
Site: Clinton Constellation icon.png
Issue date: 10/29/2005
From: Pulley J
- No Known Affiliation
To:
NRC/SECY
Ngbea E S
References
70FR50442 00021, PR 26
Download: ML053080117 (3)


Text

DOCKETED USNRC To: The NRC November 2, 2005 (3:57pm)

From: Jim Pulley OFFICE OF SECRETARY RR#1 Box 219A RULEMAKINGS AND a

Warrensburg,11.62573 ADJUDICATIONS STAFF pullir@webaroonie.net Subj: Nuclear Plant worker fatigue and proposed changes tolOCFR26.

10-29-05 (off I

0f I am a rotating shift worker at the Clinton Power Station in the operations department. I have been infomned by one of my Supervisors that we will be going to a twelve hour rotating schedule because of the changes coming in the near future with the IOCFR26 regulations because of the NRC's concerns with worker fatigue.

I am pleased that the NRC is concerned about workers and fatigue they experience, but after review of the draft proposed changes I am concerned that your fix falls short of accomplishing it's goal.

Many case studies have been performed in our lifetime by Medical Professionals that conclude that after 10 consecutive hours of work, all human functions diminish.

The NRC's proposed changes only address the tailend of the fatigue cycle. Your proposed changes should also address limiting the consecutive number of hours worked to Ten Hours. DOT regulations put into effect within the last five years have addressed this concern with over the road truck drivers. Work at a Nuclear Power Plant does require workers be physically and mentally alert. The NRC needs to address this issue completely to best assure the goal of all workers at Nuclear Facilities are not fatigued while engaged with work activities is attained.

Fernplafe - SecY.-o070

CY - Comment letter on FFD proposed rule Page 1 I I

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Carol Gallagher Evangeline Ngbea Wed, Nov 2, 2005 11:12 AM Comment letter on FFD proposed rule

Van, Attached for docketing is a comment letter on the above noted proposed rule from Jim Pulley that I received on 10/29/05.

Carol

emp\\GW)O0001.TMP Page l Mail Envelope Properties (4368D639.7EA: 3: 886)

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Comment letter on FFD proposed rule 11/2/05 10:07AM Carol Gallagher CAG @nrc.eov Recipients nrc.gov owf5_po.OWFNN_DO ESN (Evangeline Ngbea)

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Size 627 24576 Date & Time 11/02/05 10:07AM 11/02/05 09:58AM None Standard No None No Standard