ML20138G327
| ML20138G327 | |
| Person / Time | |
|---|---|
| Issue date: | 11/23/1982 |
| From: | Allen T NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Cameron C NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20138G271 | List: |
| References | |
| FOIA-84-827 NUDOCS 8512160289 | |
| Download: ML20138G327 (1) | |
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!!DTE TO: Chip Cameron, Regulatory Policy Analyist Regulatory Analysis Branch Division of Risk Analysis, RES FROM:
Tom Allen, Section Chief Power Reactor SG Licensing Branch Division of Safeguards, IUdSS
SUBJECT:
FIT!!ESS FOR DUTY RULE W
l.'e have revieued the 0:G supporting statement ycu sent concerning the fitness for duty rule. We are unable to concur in the statement as presently worded for the follo ting reasons:
1.
The suppcrting state.mnt does not recognize the potential impact of the Insider Rule package in the fitness for duty area. There is a significt.at possibility that the fitness for duty function could be subsuwd by the behavioral observation portion of that package.
2.
The supporting statement inaccurately reflects the number of procedures that t:ould have to be developed by the industry.
Specifically, ue believe that once a licensee has developed procedures for one unit at a given site, those procedures trould apply to all units on the site.
3.
h'e question the estimate of 120 man hours per year to maintain written procedures and records for program clients. lie believe that the estim-te should be substantially higher.
I will be happy to assist you in codifying the draft supporting statemsat in order to resolve the aforementioned problems.
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Tom Allen, Section Chief Power Reactor SG Licensing Branch Division of Safeguards, i:F.SS cc:
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