ML20205Q914
| ML20205Q914 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/20/1988 |
| From: | Carter C INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR36795, RULE-PR-26 53FR36795-00006, 53FR36795-6, NUDOCS 8811090395 | |
| Download: ML20205Q914 (2) | |
Text
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O LocalUnion No. 51 International Brotherhood of E ectn& Wor <ers 301 E. Soruce Street
- Springfield, Illinois 62703
- Phone 217/544 8481 48- -
'88 OCT 24 P2:43 October 20, 1988 fohh $$ -.',,,i/
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PA0P0a......E Secretary of the Cornission NJN ATT Docketing and Service Branch U.S. Nuclear Regulatcry Cornission Washington, DC 20555 Ret 51 FR 27921 - Cornission's Policy Statement on Fitness for Duty of Nuclear Power Personnel
Dear Cormissioner:
As the Union Representative of IBEW employees at the Illinois Power Company Clinton Nuclear Station, I would like to response to several areas of concern with the proposed rule-l making on Fitness for Duty.
1 First, those employees represented by IBEW at Clinton Power Station are presently subject to random testing.
It is noted this was achieved through collective bargaining and, as adnini-stared, is a valuable working practice.
Therefore, we are not opposed to the idea of random testing, recognizing such policy must also function with behavior observation.
Testing is done randomly on a daily basis with a predetermined nurber tested each day.
That number being 5% of the work or af fected group.
This is a deterrent as odds sre 1 in 20 days individuals are subject to testing.
Our present policy has been in effect since October 1985 and first time positivas are f ar below average, having had only six first-time positives, threa seconds and one third since testing began.
>x What is of primary ccncern to th'a NRC Fitness for Duty Policy, is not the tolerance levels or to whom it shall apply.
Primary concern is testing only for illegal drugs, all drug abuse should be screened if it is to be offactive at all.
Those with access to unescorted vital areas are proper concerns.
Due to the f ailure of society today to educate the mass, we are now facing the greatest war of all.
If society is to prevail, rehabilitation and cducation must be the strong point 8811090393 00 #
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International Brotherhood of Electrical Workers Loco? Unior. No. 51 Secretary of the Cornission ATT Docketing and Service Branch October 20, 1988 U.S. Nuclear Regulatory Co# mission Page 2 l
to insure a drug or alcohol free workplace.
E.A.P.
programs must be mandated to cover all treatments and given the oppor-tunity to work as designed.
Past history will show that most of those who respond *o rehabilitation programs relapse after the treatment and most I
often, a second effort is mandatory to maintain true concurrence with abstaining f rom the substance.
Therefore, I wish to oppose l
the rule in the area of VI (numbers of positive tests).
.I suggest two (2) positives be allowed prior to any sufficient restrictions.
More proper would be a five (5) day ban on the first with a ten (10) day ban on the second.
Evaluations and treatments by the E.A.P.
is consistent with these bans, as is determination by medical authority prior to return.
The proposed removal of three (3) years for a second is unrealistic.
Most companies would terminate this employee as unavailable for work, causing great hardships and not doing anything toward rehabilitation or resolving this society's drug problems.
As stated before, through collective bargaining, Local Union 51 and Illinois Power Company have established a comprehensive Fitness for Duty Policy for those employed at our nuclear facility.
It is tough, fair and workable.
Any rulemaking by the NRC should recognize these existing plans and make allowances (such as grandfather clauses).
It is requested you reconsider your of forts and review said administrative statement prior to issuing your final rule.
Sincerely, f
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C.
E. Carter. Jr.
Assistant Business Manager CEC:ngf opeiu #167
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