ML25168A079
| ML25168A079 | |
| Person / Time | |
|---|---|
| Issue date: | 08/09/1983 |
| From: | Ray J Advisory Committee on Reactor Safeguards |
| To: | Palladino N NRC/Chairman |
| References | |
| Download: ML25168A079 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 Honorable Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission Washington, DC 20?55
Dear Ur. Palladino:
August 9, 1983
SUBJECT:
ACRS REPORT ON THE RULE CONCERNING FITNESS FOR DUTY OF NUCLEAR POWER PLANT PERSONNEL During its 280th meeting, August 4-6, 1983, the ACRS reviewed the proposed final rule concerning fitness for duty of personnel in nuclear power plants.
This matter was also discussed with the NRC Staff during a meeting held by our Subcommittee on Human Factors on August 3, 1983.
The proposed rule would require licensees to have written procedures to provide assurance that no one under the influence of alcohol or drugs, or otherwise unfit for duty, will be permitted unescorted access to protected areas of nuclear power plants.
The rule is intended as a general set of requirements leaving it to individual licensees and the industry to develop details of implementation.
We believe that the rule, as presented to the Committee, is an appropriate means to deal with this matter of fitness for duty.
Tne proposed rule does not apply to workers during the construction of a plant.
While we agree that the concern regarding the fitness for duty of workers during construction is less than the concern for those covered by the proposed rule, we believe a potential for undiscovered substandard work makes this a significant issue also.
We believe the NRG and the industry should pay continuing attention to effective control of the fitness for duty of workers during construction.
Ue note that the rule, as proposed, would not apply to NRC inspectors.
In light of the principle that the licensee has ultirnate responsibility for safe operation of the plant, we believe that such an exemµtion is inapµropriate.
If the µroposed rule cannot be adapted to be totally inclusive, and apply to NRC inspectors as ~,ell as to employees of the licensee and subcontractors, then another rule or µrocecture should be developed to cover NRC inspectors.
He believe that efforts should be made to ensure that information on inci-dents involving on-duty abuse of alchohol or drugs by nuclear power plant personnel is accessible to the NRC.
These data are necessary to document the extent and nature of the problem as well as to judge the adequacy of licen-sees' fitness for duty programs.
2507
Honorable Nunzio August 9, 1983 With the comments above, we endorse the final rule concerning fitness for duty and urge its expeditious implementation.
The NRC Staff indicated they do not intend to develop a Regulatory Guide or other more detailed guidance on how the rule is to be implemented.
We understand that the Edison Electric Institute is to prepare guidelines for licensees to use in implementation of this rule.
We would like the opportunity to review these guidelines at an appropriate time.
Sincerely,
~CE, J. J. Ray~
Chairman 2508