ML20055F452
| ML20055F452 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/29/1990 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR14288, FRN-56FR32066, RULE-PR-55 55FR14288-00030, 55FR14288-30, AD55-2-47, NUDOCS 9007170067 | |
| Download: ML20055F452 (2) | |
Text
w NKET NUMBER
. South Cirilin I r
^"!e S. Brodham -
-i-P O Box 88 - -
($5/R NM) Vee Pr:sio:nt Jensonsville. SC 29065 Nuclear Operations (903) 345 4040 SCEAG-00CKEIED 4
U2NHC m._ _
June 29, 1990
'90 JL -6 P3 :47
..a.....---.-,r
,w Mr. Samuel'J. Chilk Secretary, U.S. Nuclear Regulatory. Commission
' Washington 0.C.
20555
Subject:
Virgil C. Summer Nuclear Station License No. NPF-12 Docket No. 50/395 Comments on Proposed Rule on Licensed Operator Fitness-for-Duty
Dear Mr. Chilk:
l South Carolina' Electric & Gas Company (SCE&G) has reviewed the proposed rule, l
" Operators' Licenses 10CFR Part 55 Modification for Fitness-For-Outy" (55 FR l
- 14288, April 17, 1990), and provides the following comments. SCE&G concurs
.j
'with the comments provided by NUMARC that conclude the NRC' proposed rule is i
L unnecessary and singles out licensed operators for no justifiable purp se.
,SCE&G believes that the existing regulations (10CFR55 and'10CFR26) allt.v for
.NRC enforcement action against licensed operators for violation'of the i
fitness-for-duty rule.
1 W
iSome additional concerns / questions about the proposed rule are provided in
.the. attachment.
If you have any questions, please contact April Rice at-L(803).345-4232.
i Very truly yours, 1
O. S. Bradham
=
ARR/OSB: led Attachment c:
'O. W. Dixon, Jr./T. C. Nichols, Jr.
-E. C. Roberts I
,R. V. Tanner 1
J. J. Hayes, Jr.
- t General Managers--
i C. A. Price G. F.-Gibson D. L. Arthur NSRC NPCF RTS' (PR900005) j Files (855.00AA,'811.02 (50.019), 812.16) t[
.9007170067 900629 p
PDR-PR PDR;N 55'55FR14288 pSl0
3: n
.j.
Attachment.to Mr. Samuel J. Chilk Letter
_.,i June 29, 1990-l Page 1 of 1 1.
-If the purpose of the rule change is to " establish a new condition of an operator's license which will prohibit conduct of licensed duties while under the influence of alcohol or_any prescription, over-the-counter er.
illegal substance which would adversely affect performance of licensed duties" in order to " subject them to enforcement action" then the NRC should simply state in 10CFR55.that any violation of 10CFR26' requirements (by a-licensed operator) would subject them to special enforcement regarding their license (there is no need to reiterate or add to the requirements of 10CFR26).
2.
What is the basis or need for the rule change? Is there any indication of an_ industry-wide problem / trend that requires this change?
3.
SCE&G believes that the requirements of 10CFR26 and supervisory observation and assessment of physical and/or emotional stability are sufficient to prevent'the'use of drugs / medicine from becoming a unique licensed operator _ problem.
4.
'How willLoperators who do not report medicine use be treated? Will a special program such as having a percentage of the crew tested prior to going on shift be etquired?
If so, what method of testing should be i
used and what rt 1e of prescription and over-the-counter medicines should be teste/
,