ML20045D755

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Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule W/Listed Exceptions
ML20045D755
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 06/18/1993
From: Parrish J
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR15810, RULE-PR-26 58FR15810-00017, 58FR15810-17, NUDOCS 9306300025
Download: ML20045D755 (1)


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.h CW F[215ri5 )7 WASHINGTON PUBLIC POWER SUPPLY SYSTEM A p.o sax 968 3000 George washington way . Richland, washington 99352-0968 . c509 72-Docket No. 50-397 June 18,1993 G02-93-162 ,

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Secretary of the Commission -

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATrN: Docketing and Services Branch

Gentlemen

Subject:

MODIFICATIONS TO FITNESS-FOR-DUTY REQUIREMENTS l SUPPLY SYSTEMS COMMENTS ON PROPOSED RULEMAKING

Reference:

Federal Register Vol. 58, No. 55 pp 15810 - 15812, " Modifications to Fitness-for-Duty Program Requirements," dated March 24,1993 l The Washington Public Power Supply System has reviewed the proposed rulemaking cited in j the reference which modifies current Fitness-for-Duty requirements. The following comments are provided for your consideration.

l We concur with the proposal to randomly test licensee employees at an annual rate equal to at least 50% versus the current 100% rate. This is supported by your data which demonstrates a very low positive rate of 0.25% among licensee employees.  ;

You do not propose to reduce the contractor and vendor random testing rate from 100%. Your l decision is based on the premise that the positive rate for this population is twice that oflicensee l

l employees (i.e., >0.50%). We suggest that you reconsider this decision. A positive rate of j less than 1.0% is still sufficiently small to allow a re<luction of the random testing rate.

If the random test results at other plants for contractor and vendor employees persuades you to maintain the 100% random testing rate, we suggest that you consider an alternative which allows a reduction from the 100% rate based on experience at individual plants. The rate might be reduced from 100% if the individual plant experiences a positive rate less than 0.50%, for example.

Should you have any questions regarding this submittal, please contact Douglas W. Coleman at I (509) 377-4342.

Sincerely i

/E70

.V. Parrish, (Mail Drop 1023)

Assistant Managing Director, Operations l cc: NS Reynolds, W&S i DL Williams, BPA ~'

! 9306300025 930618 PDR PR h

_.26 5B_FR15810 ~._

PDR

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