ML19271F435
| ML19271F435 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/21/1984 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-84-098, KMLNRC-84-98, NUDOCS 8407020261 | |
| Download: ML19271F435 (1) | |
Text
July 9, 1984 DCS MEMORANDUM FOR:
Robert M. Bernero, Director Division of Risk Analysis and Operations, RES FROM:
J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs, IE
SUBJECT:
DRAFT RECOMMENDATIONS TO EDO CONCERNIN", WHETHER AND HOW TO CONTINUE WITH THE FITNESS FOR DUTY ONG0ING RULEMAKING SPONSORED BY RES-We concur with the draft recommendations to the EDO regarding proceeding with the rulemaking concerning Fitness for Duty at operating nuclear power plants.
Regarding the specific proposal to develop a Reculatory Guide, we agree that licensees should have a document that describes what the NRC expects as a result of the rule. There have been suggestions that the NRC rely on the EEI Guide to Effective Drug and Alcohol Policy Development or the NUREG-0903 Survey of Industry and Government Programs to Combat Drug and Alcohol Abuse.
While each of these documents contain valuable biformation about the elements of a good program, neither could be used as authoritative guidance from the NRC regarding how the Fitness for Duty Rule should be implemented.
The NRC should issue a Guide that describes an acceptable program.
The EEI document goes beyond such a description and gets into areas that are outside the jurisdiction of the NRC; for example, the chapter on briefing the union involves labor relations which are beyond the NRC's authority.
The NUREG document describes programs which contain controversial details such as use of polygraphs and psychological testing.
It talks abuut what various companies are doing but does not outline a basic, acceptable program.
PRlGINAL SIGNED @yl 1 NELSON GRACg J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs. IE cc:
R. Burnett, NMSS Distribution T)CS SMPB reading QASIP reading L. Cobb, IE J. Partlow, IE J. Grace, IE
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