ML12096A488
| ML12096A488 | |
| Person / Time | |
|---|---|
| Issue date: | 04/10/2012 |
| From: | Doug Huyck NRC/NSIR/DSP/RSRLB |
| To: | Kline D Nuclear Energy Institute |
| Chalk W | |
| Shared Package | |
| ML12096A487 | List: |
| References | |
| Download: ML12096A488 (3) | |
Text
April 10, 2012 Mr. Dave Kline, Director, Security Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
STAFF COMMENTS REGARDING NUCLEAR ENERGY INSTITUTES FITNESS FOR DUTY PROGRAM GUIDANCE FOR NEW NUCLEAR POWER PLANT CONSTRUCTION SITES
Dear Mr. Kline:
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Nuclear Energy Institutes (NEI) 06-06, revision 6, Fitness for Duty Program Guidance for New Nuclear Power Plant Construction Sites. The NRC staff conducted a public meeting on the subject of NEI 06-06, revision 6, on November 7, 2011, which was attended by several industry personnel where the staff presented oral comments to those present.
Based on the comments from your staff and industry representatives, it appears that the industry is supportive of NRC staff comments on NEI 06-06, revision 6. However, the industry stated that they will need additional time to fully evaluate all staff comments, in particular those listed below that the staff described as requiring additional clarification or guidance.
- 1. U.S. Department of Transportation collection allowances.
- 2. Alignment of NEIs definition of construction site with site security considerations and whether activities subject to the rule are being conducted within or outside the construction site boundary.
- 3. Whether NEI 06-06 should strictly apply to construction or whether it should also enable the transition of site Fitness for Duty (FFD) program from a Title 10 of the Code of Federal Regulations (10 CFR) Part 26, Subpart K, construction program to an FFD program acceptable for reactor operation.
- 4. Description of how the random testing population is determined.
- 5. Determination and description of sanctions for FFD policy violations.
- 6. Alignment on the conduct of audits.
D. Kline In order to better communicate staff comments to you and members of the public, we inserted these comments and editorial revisions into your document as enclosed. We hope that this initiative benefits common understanding and note that this staff information is draft and is not, nor should be deemed as, an official NRC position, opinion or guidance, or a written interpretation by the General Counsel under 10 CFR 26.7.
After the comments are again evaluated and resolved, as necessary, the staff will make a determination whether to endorse NEI 06-06 through the issuance of a Regulatory Guide.
I am hopeful that you will find the comments beneficial in helping clarify and enhance the document.
Sincerely,
/RA/
Doug G. Huyck, Chief Security Programs Support Branch Division of Security Policy Office of Nuclear Security and Incident Response
Enclosure:
As stated
ML12096A487 OFFICE NSIR/DSP NSIR/DSP NAME WChalk DHuyck DATE 4/9/12 4/10/12