ML20154G135

Comment on Proposed Rules 10CFR50 & 73 Re Proposed Policy Statement on Nuclear Power Plant Access Authorization Program.Commission Urged to Establish Access Authorization Through Rulemaking Procedure

ML20154G135
Person / Time
Site:	Saint Lucie, Turkey Point, 05000000
Issue date:	05/05/1988
From:	Holliday C INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR7534, RULE-PR-50, RULE-PR-73 53FR7534-00027, 53FR7534-27, NUDOCS 8805240250
Download: ML20154G135 (2)

Text

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SYSTIM COUNC 1 U4---13 IW REPRESENilNG LOCAL UN6ONS: 359, 622, 627, 641, 159, 820, 1042, 1066, 1191, 1263, 1906 PHONE: (305) 737 8811 432 West Boyn'on Beoch Blvd., Boynton Beocgorgf yp7 $9

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May 5, 1988 F' KE .

• 5 t-00CM T K t. Ce a BRANCH Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn Docketing and Service Branch Re: 10CFR Parts 50 and 73, Nuclear Power Plant Access Authorization Program Policy Statement.

I

Dear Sir:

This office represents the Bargaining Unit group on the property of the Florida Power and Light Company which ,

includes Turkey Point and St. Lucie Nuclear Generating Stations. ,

We are all to f amiliar with INPO, NUMARC, EEI and with the various groups and committees responsible to them.

We recognize that these organizations were formed by the Utilities themselves, in part, for the purpose of  ;

monitoring, regulating and operating their own industry in an effort to minimize regulation by legislation. We do not disagree with this intent by the industry.

We do disagree with the results of these efforts in many instances, specifically as regards maintenance and I

operations of Nuclear generating stations.

We do not question the integrity of- the management involved however we see various programs that fall short of their obvious goal, in part, because of insufficient manpower and time dedicated to make programs effective.

The most significant cause for the limited success of i these prograns is management's failure to include the I Bargaining Unit in the discussion on an area of concern.

A program is formulated and, in many cases, implemented without including Bargaining Unit Representatives in any phase of formulation or implementation. Obviously, this ,

all to often, places the Union in dispute with management j in those areas that conflicts with the negotiated j contract. l I

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, i As the representatives of the Bargaining Unit members on this property, we filul that "Policy" and/or "Guidelines" are subject to interpretation and/or application by individuals or varyirg circumstances. We are opposed to a policy statement as they are not definitively and consistently applied.

Based on our own experience, we urge that the Commission i

establish Access Authorization ttrough the rule making procedure. The rule must be definitive. Each party must be responsible to jointly implement and administer the rule in a consistent manner applicable to all who are affected.

It is noted that Fitness For Duty is interrelated with Access Authorization and must be addressed with this same concern in this same rule. This would be consistent with other established Access Authorization rules.

System Council U-4, IBEW with some 5300 members, supports the objective of a drug free work place. We do advocate a reasonable and fair approach to accomplish this goal.

In this regard, we positively oppose "Random Testing".

We do support testing for reasonable cause.

In closing, we again wish to emphasize that we are firmly convinced that the public, industry and employee will be best served by an established Access Authorization Rule.

Conversely, a "Statement of Policy" would be a disservice to all parties concerned.

Respectfully, 0 kg f C. A. Holliday Business Manager CAH/ct opoiu-128 afl-cio Pile