ML20072K320

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Comment on Proposed Rule 10CFR26 Re Changes to Fitness for Duty Requirements.Recommends That Present Scope of Coverage & Detail of Random Testing Requirements Be Retained
ML20072K320
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 08/05/1994
From: Fitzpatrick E
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR24373, RULE-PR-26 59FR24373-00023, 59FR24373-23, AEP:NRC:0508AF, AEP:NRC:508AF, NUDOCS 9408300010
Download: ML20072K320 (2)


Text

,g indiana Michigan Po2er Company P O Box 16631 Columtms OH 43216 00CKEIED USNRC g 73 INDIANA 94 AUG 17 P137 MICHIGAN POWER OFFICE OF SECRETARY DCCKETihG e SEF lice bR ANC'i AEP:NRC:0508AF Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 DOCKET NUMBER License Nos. DPR-58 and DPR-74 PROPOSED RULE N N PROPOSED RULE CHANCES TO FITNESS FOR DUTY (FFD)

REQUIREMENTS pg gg Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Docketing and Services Branch August 5, 1994

Dear Mr. Secretary:

Volume 59, No. 90 of the Federal Register includes proposed rule changes to 10CFR Part 26 FFD requirements. The following are our comments regarding the proposed rulemaking and changes to 10CFR Part 26.

We recommend that the present scope of coverage and detail of the random testing requirements be retained. The current program provides consistent requirements for all personnel within the Plant regardless of their job responsibilities. Although cost savings may be realized by removing certain groups of workers from FFD (i.e., based on access to protected or vital areas or position descriptions), the maintenance of the random test pool would become administrative 1y more burdensome. Also, the possibility of inadvertently not including personnel in the pool would increase due to the ever-changing status of personnel. The reduction from 100% to 50% population random test requirement has significantly reduced the cost of the testing program and further reduction may impact upon assuring a drug free work environment.

9408300010 940805 PDR PR 26 59FR24373 PDR OP0

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Mr. Secretary AEP:NRC:0508AF We further recommend that the present method of testing (i.e. , urinalysis) be continued due to worker acceptability as well as the well-documented accuracy of results since the implementation of the FFD rule on January 3, 1990. Although the proposed performance-based testing has a sensitivity to impairment, it would not determine that an individual was impaired due to substance abuse nor would it detect illicit substance abuse if there was no observed impairment.

Sincerely, 0/

Arf E . E . Fitzpatrick Vice President cc: A. A. Blind - Bridgman G. Charnoff J. B. Martin - Region III ,

NRC Resident Inspector - Bridgman NFEM Section Chief J. R. Padgett l

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