ML20055F000

Comment Opposing Proposed Rule 10CFR55 Re Operator Licenses. Proposed Rule Unnecessary & Can Only Adversely Impact Safe Operation of Nuclear Power Facilities by Negatively Affecting Morale of Licensed Operators

ML20055F000
Person / Time
Site:	San Onofre
Issue date:	06/20/1990
From:	Dominguez D AFFILIATION NOT ASSIGNED, SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-55FR14288, FRN-56FR32066, RULE-PR-55 55FR14288-00013, 55FR14288-13, AD55-2, AD55-2-10, NUDOCS 9007130170
Download: ML20055F000 (2)

Text

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June 20, 1990 Secretary U.S. Nuclear Regulatory Comission Washington, DC 20555

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Docketing and Services Branch Muco Dear Sirst I am writing in response to your request for written coments concerning the proposed rule that would incorporate the fitness-1 for-duty requirements into operator licenses.

If the proposed rule's intent is to provide a basis for the comission to take enforcement action against licensed operators for fitness-for-duty violations, then the proposed rule is unnecessary. The current regulation 555.61(b)(3) & (4) already i

Provides a basis for taking enforcement actions against licensed operators f or violation of any rule or regulation of the comission (i.e. 10 CFR part 26).

10 CFR Part 26 was written to make fitness-for-duty equally applicable to all personnel with unescorted access to the protected area. The way the proposed rule is written it would place more stringent requirements on licensed operators. Singling out licensed operators for more stringent treatment without justifiable reason is not only unnecessary, but would be detrimental to their morale.

As a Reactor Operator (RO) at SONGS I am quite familiar with the ef f ects of morale problems. I have seen how problems with morale at SONos have resulted in chronic licensed operator retention problems. The accelerated hiring of replacements in order to keep up with attrition has seen our experience ' level plumet. I know that we (SONOS) are not alone in our problenw with retaining licensed operators, other nuclear f acilities throughout the country are in a similar predicament. Implementing the proposed rule can j

only exacerbate the problem.

1 The commission states that the purpose for implementing the proposed rule is to "... assure a saf e operational environment f or i

the performance of all licensed activities by providing a clear understanding to licensed operators of the severity of violating requirements governing drug and alcohol use and of the impact of substance abuse." As an RO, and a professional, I am very aware of

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the gravity of violating the fitness-for-duty requirements. I do J

not think that their is an NRC licensed operator that is not aware i

of 10 CFR Part 26 requirements or of the severity of violating i

those requirements. Implementing the proposed rule can only prove detrimental to the morale of licensed operators and that in turn will be counter productive to the comission's goal of " assuring a safe operational environment",

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9007130170 900620l PDR PR l

55 55FR14288 PDR

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In sununary the proposed rule is unnecessary and can only adversely impact the saf e operation of nuclear power f acilities by negatively affecting the morale of licensed operators, sincerely, t

Daniel Dominguet /

Reactor Operator SONOS 2/3 l

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