ML20045D746
| ML20045D746 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/21/1993 |
| From: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR15810, RULE-PR-26 58FR15810-00020, 58FR15810-20, PLA-3990, NUDOCS 9306300017 | |
| Download: ML20045D746 (2) | |
Text
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'26 S VFR 15 rIO g
PPaL Pennsylvania ower & Light mpanyt Two North Ninth Streete Allentown, PA 18101-1179 a 215/774-515N
'93 JU" 24 P 3 :43 Robert G. Byram Senior Vice Press 0ent-Nuclear y
215/774 7502 "g
JUN 211993 1
Mr. Samuel J. ChilkPSecretary i
U.S. Nuclear Regulatory Ce m.ission Washington, D.C.
20555 Attn.: Docketing and Service Branch SUSQUEHANNA STEAM ELECTRIC STATION COMMENTS ON PROPOSED REVISION TO 10 CFR 26 : FITNESS FOR DUTY Docket Nos. 50-387 PLA-3990 FILE R41-2 and 50-388 l
Dear Mr. Chilk:
l The following are Pennsylvania Power & Light Company's comments on the proposed revision to 10 CFR 26.24:
o We concur with the specific change that will permit PP&L to reduce the random testing rate for employees to an annual rate equal to at least 50 percent of the workforce.
o We disagree with maintaining the 100 percent rate for contractor and vendor employees.
Based on an industry survey of data from 1990 and 1991, we believe the annual random testing rate for contractors / vendors should also be reduced to 50 percent of the workforce.
Employees and contractors / vendors are subject to the identical access authorization and fitness-l for-duty requirements, including behavioral observation.
1 o In response to the NRC's interest as to whether certain positions critical to the s? operation of a nuclear power plant, such as licensed reactor operators, should be excludeu ' rom any reduction of the random testing rate, it is PP&L's position that all employees should be tested l
at the same annual rate as defined in the proposed change, i.e.,50 percent of the workforce.
We believe our random testing program is an effective deterrent and that no single group or combination of positions should be excluded from the proposed reduction.
Very truly yours, 1
R.
vr-9306300017 930621 PDR PR 26 5BFR15810 PDR d
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. FILE R41-2 PLA-3990 Mr. S. J. Chilk cc:
NRC Document Control Desk (original)
NRC Region I Mr. G. S. Barber, NRC Sr. Resident inspector - SSES Mr. R. J. Clark, NRC Sr. Project Manager - Rockville
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