PLA-3990, Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule in Part & Opposes Rule in Part
| ML20045F797 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/21/1993 |
| From: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR15810, RULE-PR-26 58FR15810-00027, 58FR15810-27, PLA-3990, NUDOCS 9307090024 | |
| Download: ML20045F797 (2) | |
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, Pennsylvania Power'& Light Company 27 Two North Ninth Street
- Allentown. PA 18101-1179
- 215/77& 5151 W
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~ccert G. Bvram lentor vice Presroent-Nuc: ear 215/774.7502 JUN 211993 Mr. Samuel J. Chilk. Secretary 11.S. Nuclear Regulatory Commission Washington. D.C.
20555 Attn.: Docketing and Service Branch
$USQUEllANNA STEAM ELECTRICSTATION
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COMMENTS ON l'ROPOSED REVISION TO 10 CFR 26 : FITNESS FOR DUTY Docket Nos. 50-387 Pl. A-3990 Fil.E R41-2 and 50-388 1
Dear Mr. Chilk:
The following are Pennsylvania Power & Light Company's comments on the proposed revision to 10 CFR 26.24:
o We concur with the specific change that will permit PP&L to reduce the random testing rate for employees to an annual rate equal to at least 50 percent of the workforce.
o We disagree with maintaining the 100 percent rate for contractor and vendor employees.
l Based on an industry survey of data from 1990 and 1991, we believe the annual random testing rate for contractors / vendors should also be reduced to 50 percent of the workforce.
7 Employees and contractorsivendors are subject to the identical access authorization and fitness-for-duty requirements, including behavioral observation.
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o in response to the NRC's interest as to whether certain positions critical to the safe operation I
of a nuclear power plant, such as licensed reactor operators, should be excluded from any reduction of the random testing rate, it is PP&L's position that all employees should be tested at the same annual rate as defined in the proposed change, i.e., 50 percent of the workforce.
r We believe our random testing program is an effective deterrent and that no single group or combination of positions should be excluded from the proposed reduction.
t Very truly yours.
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l 9307090024 930621
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26 58FR15810 PDR
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? FILE R41-2 PLA-3990 Nir. S. 3. Chilk NRC Document Control Dest (original) cc:
NRC Region 1 l
Nir. G. S. Barber. NRC Sr. Resident inspector - SSES Nir. R. J. Clark. NRC Sr. Project hianager - Rockville l
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