ML20206M495
| ML20206M495 | |
| Person / Time | |
|---|---|
| Site: | 05000083 |
| Issue date: | 11/17/1988 |
| From: | Vernetson W FLORIDA, UNIV. OF, GAINESVILLE, FL |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR36795, RULE-PR-26 53FR36795-00292, 53FR36795-292, NUDOCS 8812010025 | |
| Download: ML20206M495 (2) | |
Text
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NUCt. EAR ENGINEERIND SCIENC3 DEPARTMENT p.
Nuclear Reactor Facility University of Flotidd i
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'ei November'17, 1988"1 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
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Reference:
Proposed Rulemaking on a Fitness-for-Duty Program, 10 CFR Part 26 Federal Register Vol. 53, No. 184 Centlement Although the proposed "Fitness-for-Duty Program" rule published in the Fed-eral Register on 22 September 1988 addresses power reactors, we would like to comment on item 10 of the "Discussion" section of the notice which requests com-ments on the extension of fitness-for-duty regulations to non-power reactors used in academic and research applications. For our University of Florida Train-ing Reactor (UFTR) f acility and most non-power (research and training) reactors the staffing, operation and level of potential hazards differ significantly from power reactors, rendering the basis and rationale for the proposed rule non-ap-plicable; alternatives exist which assure adequate fitness-for-duty at non-power reactors.
The staff size of non-power reactors is small and usually a day shift op-eration. Large numbers of temporary employees art, not used in the facility and the senior staf f typically experience = low turnover. The combination of these phenomena allow management to be in close proximity to the staff and maintain surveillance of behavior patterns. Our management already reviews individual li-ceased operators every two years when certifying them as part of our requalifi-cation program. Failure to conduct oneself in a proper manner is readily identi-fied.
The working environment of such non-power reactors involves nearly continu-ous, inherent surveillance of staf f for fitness-for-duty. Operations involve frequent startups, shutdowns, power level changes and movements of experiments and devices. This variety of activities reduces the potential for boredom. The resultant variety of work fosters a collegial atmosphere where the small staff and facility size as well as our single shift operation assures interaction a:nong all levels of the staf f. All these f actors assure safe operations as en-dorsed by the absence of incidents related to degraded fitness-for-duty at our facility.
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O Secretary of 1.he Commission November 17, 1988 Page Two The recently enacted Omnibus Anti-Drug Abuse Act of 1988 apparently re-e,aires all institutions receiving federal grants or contracts to have a drug policy. Our University is already considering its options for establishing a drug policy for its employees, including those at our facility. F.mergency plan-ning already has shown that hazards from such reactors are of limited signifi-cance and confined to a small area relative to hazards related to other accepted operations and practices that may exist on our campuses or in our communities; therefore, we feel that adequate protection of the health and safety of workers and the general public already exists without additional fitness-for-duty regu-lations for power reactors being extended to cover non-power reactors such as the University of Florida Training Reactor.
A significant burden would be imposed on non-power reactor facilities such as the UTTR in establishing and maintaining a separate fitness-for-duty program; it could restrict access for students and faculty to research and instructional facilities, could be costly to maintain and would constitute a significant ad-ministrative workload which could be one more inducement to shut down such fa-cilities. Such a program could stifle the contribution of our reactor to aca-demic instruction impe-tant to science and engineering education. Ve believe that adequate inherent f actors exist such that a formal separate program is not necessary. For these reasons we respectfully request that the Commission not ex-tend consideration of the fitness-for-duty rule to non-power reactors.
Thank you for your consideration.
Sincerely, A
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William G. Vernetson l
Director of Nuclear Facilities WCV/ps cc Reactor Safety Review Subcommittee
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