ML20045D755
| ML20045D755 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| 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) | |
Text
.
15 ~.
.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 Secretary of the Commission y,j
~
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 The Washington Public Power Supply System has reviewed the proposed rulemaking cited in l
j the reference which modifies current Fitness-for-Duty requirements. The following comments l
are provided for your consideration.
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 decision is based on the premise that the positive rate for this population is twice that oflicensee 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 (509) 377-4342.
Sincerely
/E70
.V. Parrish, (Mail Drop 1023)
Assistant Managing Director, Operations l
cc:
NS Reynolds, W&S i
DL Williams, BPA ~'
h 9306300025 930618 PDR PR PDR
.26 5B FR15810 ~.
-