ML20206M782
| ML20206M782 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/21/1988 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR36795, RULE-PR-26 53FR36795-00353, 53FR36795-353, NUDOCS 8812010408 | |
| Download: ML20206M782 (3) | |
Text
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Secretary of the Comission
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U. S. Nucicar Regulatory Comission
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Washington, DC 20555
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SUBJECT:
Virgil C. Sumer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Proposed Rule - Fitness-for-Outy Progrsm (53 Fk 36795)
Gentlemen:
This letter forwards the South Carolina Electric & Gas Company (SCE&G) comments on the Fitress-for-Outy Program Proposed Rule publisted on September 22, 1988 (53 FR 36795).
SCE&G has participated in the Nuclear Management and Resources Council (NUMARC) efforts to respond to this proposed rule and, by this letter, endorses their forthcoming comments.
Furti,ermore SCE&G is fully comitted to establishing a drug-free work envirrnment.
Listed below, however, are minor exceptions to the NL'AARC coments which SCE&G wishes to provide.
It should be noted that trase cements are "stand-alone" coments and are baseo on the language of !6'a Proposed Rule.
1.
Pace 36824. third column. earaaraoh 26.'.1(a). line 3 Substitute the word "information" for the word "training."
Should resq "...provided with appropriate information to ensure they understand..."
Rationale:
The word change provides flexibility in the training program on the methodology and format to be presented to the personnel.
2.
Pace 36825. first column. Daraaraoh 26.21(b)
Delete the paragraph and substitute the following words:
"Information provided must be reviewed prior to assignment to activities within the scope of this part.
This l, formation will be provided on a biennial basis or more frequently where the need is indicated. A record of a person', review of the information shall be retained for a period of three years."
itionale:
The word change makes this paragraph consistent with 26.22(a) in that information is provided instead of training.
Further, a biennial review is considered to be sufficient for iefresher training.
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Secretary of the Commission November 21, 1988 Page 2 of 3 3.
Pace 36825. first column. paraaraoh 26.22(b):
Delete the paragraph and substitute the following words:
"Non-supervisory licensee personnel assianed to the nrntected area shall be provided basic training to familiarize them with the matters contained in 26.22(a)(3), (4) and (5)."
Rationale: Non-supervisory personnel assigned to the protected area should be trained in the matters contained in 26.22(L)(3), (4) and (5). This is so that any Licensee employee can act as an escort and that a separate program for the training of escorts would not i required.
4.
Pace 36825. first column. Daracraoh 26.22(c):
First sentence, change:
"3 months of" to "12 months following."
Second sentence,.Jbstitute the term "biennial" for "annual."
These two sentences should read:
"Initial training must be completed prior to assignment of duties within the scope of this l
part and within 12 months of initial supervisory assignment, as applicable.
Refresher training must be complated on a biennial basis, er more frequently where the need is indicated."
Rationale:
This frequency of training would be consistent with Utility's Personnel Reliability Programs for Access Authorization.
Experience has shown that refresher training every two years is adequate.
5.
Daae 36825. first column. paraaraoh 26.23(al:
Should read:
"(a) the contractor is responsible to the licensee for adherino to the licensee's fitncss-for-duty program."
Rationale: This req:irement would ensure consistency throughout the industry and not allow contractors to have a less effective program than the licensee.
6.
Pace 36825. second column. suboaraaraohs 26.24(a)(2)(1) and (ii) l The two alternatives listed should be deleted and the following l
substitute for subparagraph (a)(2):
"Annual tests will be conducted on personnel granted unescorted access to the proti.::ted areas and to licersee personnel required to respond to a licensee's Technical Support Center or Emergency l
Operations Facility in accordance with licensee emergency plans and procedures.
Random unannounced tests will be in addition to the annual program.
The random tests must be conducted in a nanner that assures at least five percent of the individuals within the scope of the rule are tested each year."
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Secretary of the Commission November 21, 1968 Page 3 of 3 Rationale: The randcm testing provision is only one additional element to supplement existing fitness-for-duty programs. An annual sampling program supplemented by a random unannounced program provides a strong deterrent.
7.
Pace 36825. thi d column. Daracraoh 26.?51 Modify the first sentence to begin:
"Each licensee subject to this part shall make available to their regular full-time employees an Ertployee Assistance Program to strengthen..."
Rationale:
Licensees do not have any obligation towards non-regular full-time employees or contractors other than to remove them from the accesss authorization list should a positive test result occur.
8.
Pace 36827. second column. paraaraoh 26.80(a):
Contrary to the NUMARC position, SCE&G agrees with the Proposed Rule on audits to be performed at least once every 13 rnenths.
Very truly yours h
3.dbb: J
- 0. S. Bradhum I
MDB/058:1cd c:
D. A. Hauman/J. G. Connelly, Jr./0. W. Olxon, Jr./T. C. Nichols, Jr.
E. C. Roberts W. A. Williams, Jr.
M. L. Ernst J. J. Hayes, Jr.
General Managers C. A. Price /R. M. Campbell, Jr.
K. E. Beale W. H. Johnson M. D. Blue NSRC RTS (LTR 880028)
NPCF File (811.02 - 50.019)
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