ML20055F453
| ML20055F453 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/29/1990 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR14288, FRN-56FR32066, RULE-PR-55 161-03307-WFC-G, 161-3307-WFC-G, 55FR14288-00032, 55FR14288-32, AD55-2-46, NUDOCS 9007170088 | |
| Download: ML20055F453 (2) | |
Text
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USNHC Arizona Public Service Company P O. BOX 63999 e PHOENIX. ARIZONA B5072-3999
% Jll -6 P3 :51 WILLIAM F. CoNWAY 161-03307-WFC/GW tucutgegrootut June 29, 1990 n g.t y 3.g UCXI 1,#9G A Sli(V!Cl UkANLH Docket Nos. STN 528/529/530 Mr. Samuel Chilk Secretary U. S. Nuclear Regulatory Commission Washington, D.
C.
20555 Attention:
Docketing and Se W ices Branch DeGr Mr. Chilk:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2&3 Proposed Rule - Operators' Licenses Modification for Fitness-for-Duty 55 Fed. Reg. 14288 Request for Comments File: 90-056-026 These comments are submitted by Arizona Public Service Company (APS) in response to the request of the U. S.
Nuclear Regulatory Commission (NRC) for comments on the proposed rule " Operators' Licenses Modification for Fitness-for-Duty" (55 Fed. Reg. 14288 -
April' 17, 1990).
APS is fully committed to maintaining a work environment which is free of drugs and alcohol and the effects of these substances.
To that end, a rigid fitness-for-duty program which meets or exceeds the' requirements of the 10 CFR part 26 Fitness-for-Duty program has been implemented at - the Palo Verde Nuclear Generating Station (PVNGS).
Th'is program applies to AH personnel granted unescorted access to protected areas, including licensed operators, to ensure that PVNGS is operated and maintained by individuals who are able to safely and competently perform their duties.
The proposed rule is unnecessary, and singles out licensed operators from other nuclear power plant personnel for no justifiable purpose.
APS is striving to develop an atmosphere of trust that supports professionalism for all personnel in positions that are responsible for safe operations of PVNGS.
There is no basis to single out licensed operators to be treated any differently from other plant personnel with unescorted access; to do so may undermine the trust i
and professionalism we are striving to develop.
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. Mr. Samuel Chilk-161-03307-WFC/ GAM Secretary Jure 29,1990-
' U.S. Nuclear Regulatory Commission
- Page 2-APS endorses the comments which are being submitted by the Nuclear Management and Resources -Council '(NUMARC) in response to this proposed ru hi.
The current regulat. ions. provide the basis for enforcement actions against licensed operators and for fitness-for-duty requirements for all. employees with unescorted access to PVNGS.
Therefore, tais proposed rule is unnecessary.
Further, it
'may: adversely affect the morale of licensed operators, which is a r
matter.cf great importance to APS and to the commission.
i APS appreciates the opportunity to comment on the proposed rule.
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If there-are any questions or comments regarding-this submittal, please' contact R.
A.
Bernier of my. staff at (602) 340-4295.
l-Sincerely, y.
WFC/ GAM /rw o
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