Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity| ML20055E987 |
| Person / Time |
|---|
| Site: |
Grand Gulf, Arkansas Nuclear, Waterford  |
|---|
| Issue date: |
06/29/1990 |
|---|
| From: |
Cavanaugh W
ENTERGY OPERATIONS, INC. |
|---|
| To: |
Chilk S
NRC OFFICE OF THE SECRETARY (SECY) |
|---|
| References |
|---|
| FRN-55FR14288, FRN-56FR32066, RULE-PR-55 55FR14288-00015, 55FR14288-15, AD55-2, AD55-2-07, AD55-2-7, NUDOCS 9007130151 |
| Download: ML20055E987 (3) |
|
|
|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
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[Table view]
Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20141D7351997-06-19019 June 1997
Comment Supporting Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Reactor Operating W/Framatome Cogema Fuels Mark-B Fuel Requested to Be Excluded from Final Bulletin Suppl
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Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission
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Comment on Proposed Rule 10CFR72 Re Notification of Events at Isfsi.Believes General Licenses Should Not Be Required to Use New 10CFR72.75
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Comment Opposing NRC Draft GL 89-10,suppl 6
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Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety
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ML20055E9871990-06-29029 June 1990
Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity
ML20043D4781990-05-19019 May 1990
Comments on Notice Re Grand Gulf Document Collection
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Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements.
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Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Existing Regulations,Codes & Stds Including Industry Procurement Improvement Activities Are Adequate
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1997-06-19
[Table view] |
Text
, .
a -
DB 55
-:-: E nterg - Q W" p g gg j g ggy rai-w on u.as ia..
j r Operat ons i Xht;ED 05Nt'C William Chvanaugh lli
'90 AL -2 P 6 :20 ,
.~ 1 ryQ
June 29, 1990 .g;,yui Mr. Samuel J. Chilk -
Secretary of the Commission U. S. Nuclear Regulatory Commission l Washington, D. C. 20555 Attention: Docketing and Service Branch
Subject:
Proposed Rule Amendment, ;
Operators? Licenses 10CFR part 55 Modification for Fitness-for-Duty 55 Federal Register 14288 AECM90-0202
Dear Mr. Chilk:
t Entergy Operations, the licenuee for Arkansas Nuclear One, Grand Gulf Nuclear Station and Waterford Steam Electric Station, Unit 3, has reviewed the subject proposed rule amendment, and are pleased to provide the following general comments. We have also participated.in the development and review of the comments provided by the Neclear Management and Resources Council (NUMARC) and fully support their submittal.
Entergy operations believes in setting and achieving high standards of health and f.itness-for-duty of all employees as this requisite is vital in assuring safe facility operation. The proposed rule amendment however is unnecessary and unjustifiably focuses on licensed operators.
The NRC states in the Federal Register that the purpose of amending the current reguletions is to provide a basis for taking enforcement against licensed operators. ilowever,10CFR Part 26 anct 10CFR part 55 currently provide adequate regulation regarding fitness-for-duty programs and licensed operators.
The NRC has not provid*d any basis to establish that licensed operators as a group reprep*,r,t a heipntened risk due to substance abuse or health impairment.
In addit!,on, although the tasks performed by operators are critically important, other tasks performed by other groups, for example, maintenance and security personnel, are equally important. Therefore, there is no justifiable need to single out licensed operators.
9007130151 900629.
PDR PH 55 55FR14pga PDR.
NRCLTRS/JEXFLR-4 DSID <
cm 3
Proposed Rule Amendment, Operators' Licenses 10CFR Part 55 Modification for Fitness-for-Duty 55 Federal' Register 14280 June 29, 1990 Page 2 We have tremendous pride'in the experience, capabilities, and professionalism
' demonstrated by licensed operators at Entergy Operations facilities. . We believe that high standards of conduct will continue to be best achieved and maintained by Licensee initiatives and programs that address-integrity and-excellence and not by regulations that emphasize punitive measures; We appreciate the opportunity to comment on this matter.
Sincerely,
/l /
/ /s /(-
WC/sep cc: S. D. Ebneter, NRC Region II Li R. D. Martin, NRC Region IV !
D. L. Wigginton, NRC-NRR T. W. Alexion,.NRC-NRR '
C. Posluany, NRC-NRR L. L. Kintner, NRC-NRR -
NRC Resident tospectors. Office (Waterford-3).
NRC Resident Inspectors Office (GGNS)
NRC Resident Inspectors' Office (ANO)f q l
-1 1
JNRCLTRS/JEXFLR-5 1
W
.. ,, . , ,,-',,--.l...- ,-',.,...,,.,.h---
, . .\ ,
Proposed Ri m Amendment, Operators' Licenses 10CFR Part 25 Modification for Fitness-for-Duty 55 Federal Register 14288 June 29, 1990 Page 3 bec: D. C. Hintz R. P. Barkhurst N. S. Carns W. T. Cottle T.11. Cloninger J. G. Dewease R. J. Landy G. W. Muench R. F. Burski J. G. Cesare J. J. Fisicaro M. J. Moisnor R. B. McGehee
- d. S. Reynolds W. A. Cross E. L. Blake W. M. Stevenson G. A. Ellis R. W. Lailhougue
- 11. L. Thomas C. R. Hutchinson E. C. Ewing J. F. Colvin (NUMARC)
Records Contor (Waterford-3)
Administrative Support (Waterford-3)
Licensing Library (Waterford-3)
Sito Licensing Support File (Waterford-3)
File (RPTS) (GGNS)
File (LCTS) (GGNS)
Filo (NL) (GGNS)
Filo (Central) (GGNS)
Document Control Center (DCC) (ANO)
File (Contral) [3)
NRCLTRS/JEXFLR-6
_ _ _ _ _ . - _ . - .