|
|
(One intermediate revision by the same user not shown) |
Line 3: |
Line 3: |
| | issue date = 04/22/2016 | | | issue date = 04/22/2016 |
| | title = LTR-16-0219 Mark Macnichol, President, International Brotherhood of Electrical Workers Union 627, E-mail SECY-15-0149, ML16063A268 - Role of Third Party Arbitrators in Access Authorization and Fitness-For-Duty Determination Reviews | | | title = LTR-16-0219 Mark Macnichol, President, International Brotherhood of Electrical Workers Union 627, E-mail SECY-15-0149, ML16063A268 - Role of Third Party Arbitrators in Access Authorization and Fitness-For-Duty Determination Reviews |
| | author name = MacNichol M | | | author name = Macnichol M |
| | author affiliation = International Brotherhood of Electrical Workers (IBEW), Local Union No 627 | | | author affiliation = International Brotherhood of Electrical Workers (IBEW), Local Union No 627 |
| | addressee name = Burns S G | | | addressee name = Burns S |
| | addressee affiliation = NRC/Chairman | | | addressee affiliation = NRC/Chairman |
| | docket = 05000335, 05000389 | | | docket = 05000335, 05000389 |
Line 17: |
Line 17: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:CHAIRMAN Resource From: Sent: To: Cc: | | {{#Wiki_filter:CHAIRMAN Resource From: 627ibew@gmail.com Sent: Friday, April 22, 2016 1:00 AM To: CHAIRMAN Resource Cc: Anna Jerry |
|
| |
|
| ==Subject:== | | ==Subject:== |
| | [External_Sender] SECY-15-0149 |
|
| |
|
| ==Dear Chairman Bums:== | | ==Dear Chairman Bums:== |
| 627ibew@gmail.com Friday, April 22, 2016 1:00 AM CHAIRMAN Resource Anna Jerry [External_Sender]
| | |
| SECY-15-0149 RE: SECY-15-0149, ML 16063A268 Role of Third Party Arbitrators in Access Authorization
| | RE: SECY-15-0149, ML16063A268 Role of Third Party Arbitrators in Access Authorization & Fitness-for-Duty Determination Reviews at Nuclear Power Plants I am Mark MacNichol, President of IBEW LU #627, Fort Pierce, FL. I represent the bargaining unit at the St. |
| & Fitness-for-Duty Determination Reviews at Nuclear Power Plants I am Mark MacNichol, President of IBEW LU #627, Fort Pierce, FL. I represent the bargaining unit at the St. Lucie Nuclear Plant owned by Florida Power and Light. I have reviewed the SECY-15-0149. | | Lucie Nuclear Plant owned by Florida Power and Light. |
| I am hoping by me writing this letter to you that I can explain why I think if the NRC adopts the proposal it would be completely unfair to nuclear workers. I started working at St. Lucie Nuclear Plant on March 6, 1989. Over the past 27 years I have witnessed the company wrongfully deny access to several employees. | | I have reviewed the SECY-15-0149. I am hoping by me writing this letter to you that I can explain why I think if the NRC adopts the proposal it would be completely unfair to nuclear workers. |
| Through the arbitration process, several of those employees have been able to return to work. Once they returned to work they have given the company several more years of professional workmanship. | | I started working at St. Lucie Nuclear Plant on March 6, 1989. Over the past 27 years I have witnessed the company wrongfully deny access to several employees. Through the arbitration process, several of those employees have been able to return to work. Once they returned to work they have given the company several more years of professional workmanship. The reason for the employees to be able to return to work is because they could arbitrate without limitations or restrictions. This is the only way that an employee can defend himself against an employers wrongful access authorization or fitness for duty determination. Now that I have said that, I am asking you to disapprove the SECY-15-0149. |
| The reason for the employees to be able to return to work is because they could arbitrate without limitations or restrictions. | | Just like the NRC, the IBEW is committed to protecting the security of all nuclear sites. Through our Code of Excellence we enforce the importance of public safety at our nuclear sites and encourage nothing but the most professional workmanship. The IBEW has absolutely no interest in protecting anyone that has made a genuine threat. What I have actually seen over the years with the cases we have arbitrated are issues that came forth from minor infractions and minor off-duty conduct. These cases have had nothing to do with security of the nuclear sites. |
| This is the only way that an employee can defend himself against an employers wrongful access authorization or fitness for duty determination. | | I have some apprehensive thoughts on a couple of things if you allow SECY-15-0149. The first thought is, what protection would the employee have if the employer just wanted to discharge an employee if you take the option of unrestricted arbitration away. On the surface it looks like the employer wants to deny access but that usually leads to termination. My second thought is, by removing the unrestricted arbitration from the employee, how likely would the employee want to raise nuclear and safety concerns. I feel the employee would be scared of retribution by losing their right to unrestricted arbitration. |
| Now that I have said that, I am asking you to disapprove the SECY-15-0149. | | In closing, I would like to add that I do not feel the public will be any safer if the NRC adopts SECY 0149. Both the company and the union have trusted and agreed to the decisions of arbitrators for a very long time. I am not sure why the companies would worry about going to arbitration on Access Authorization or Fitness for Duty, if they have a good reason to deny either, I am sure the arbitrator would rule in their favor. |
| Just like the NRC, the IBEW is committed to protecting the security of all nuclear sites. Through our Code of Excellence we enforce the importance of public safety at our nuclear sites and encourage nothing but the most professional workmanship. | | Thank You, Mark MacNichol 1 |
| The IBEW has absolutely no interest in protecting anyone that has made a genuine threat. What I have actually seen over the years with the cases we have arbitrated are issues that came forth from minor infractions and minor off-duty conduct. These cases have had nothing to do with security of the nuclear sites. I have some apprehensive thoughts on a couple of things if you allow SECY-15-0149. | | |
| The first thought is, what protection would the employee have if the employer just wanted to discharge an employee if you take the option of unrestricted arbitration away. On the surface it looks like the employer wants to deny access but that usually leads to termination. | |
| My second thought is, by removing the unrestricted arbitration from the employee, how likely would the employee want to raise nuclear and safety concerns. | |
| I feel the employee would be scared of retribution by losing their right to unrestricted arbitration. | |
| In closing, I would like to add that I do not feel the public will be any safer if the NRC adopts SECY-15-0149. Both the company and the union have trusted and agreed to the decisions of arbitrators for a very long time. I am not sure why the companies would worry about going to arbitration on Access Authorization or Fitness for Duty, if they have a good reason to deny either, I am sure the arbitrator would rule in their favor. Thank You, Mark MacNichol 1 | |
| President, IBEW LU #627 2}} | | President, IBEW LU #627 2}} |
|
---|
Category:E-Mail
MONTHYEARML24254A2562024-09-0606 September 2024 NRR E-mail Capture - (External_Sender) Psl Monthly Turtle Report for August 2024 ML24248A2422024-09-0404 September 2024 Acceptance Review for St. Lucie, Unit 2 - Relief Request (RR) 14: Limited Coverage Exams Due to Impractical Inservice Inspection Requirements - Fourth Ten-Year Inservice Inspection Program Interval ML24246A0152024-08-12012 August 2024 NRR E-mail Capture - (External_Sender) Psl Monthly Turtle Report for July 2024 ML24194A1222024-07-11011 July 2024 NRR E-mail Capture - (External_Sender) Psl Monthly Turtle Report for June 2024 ML24192A2302024-07-10010 July 2024 003 Radiation Safety Baseline Inspection Information Request ML24176A1612024-06-15015 June 2024 NRR E-mail Capture - (External_Sender) May 2024 FPL Marine Turtle Removal Monthly Report ML24150A2192024-05-29029 May 2024 (E-Mail) St. Lucie, Unit 2 - License Amendment Request, Updated Spent Fuel Pool Criticality Analysis - Acceptance Review ML24149A3532024-05-24024 May 2024 Change in Estimated Review Schedule for Nextera Common Emergency Plan Amendment ML24134A0142024-05-10010 May 2024 NRR E-mail Capture - (External_Sender) Pasl Monthly Turtle Report for April 2024 ML24122C6922024-05-0101 May 2024 NextEra Fleet EP Amendment - Demonstration Drill ML24113A0372024-04-22022 April 2024 NRR E-mail Capture - Acceptance Review - Turkey Point 3 and 4 and St. Lucie 2 - Request to Use Later Code of ASME (L-2024-LLR-0024) ML24101A2202024-04-0808 April 2024 NRR E-mail Capture - (External_Sender) Psl Monthly Turtle Report for March 2024 ML24074A4262024-03-12012 March 2024 NRR E-mail Capture - (External_Sender) Psl Monthly Turtle Report for February 2024 ML24177A2512024-02-12012 February 2024 Acceptance Review for RR 7-Proposed Alternative - Extension of Inspection Interval for St. Lucie Unit 1 Reactor Pressure Vessel Welds from 10 to 20 Years ML24036A2152024-02-0505 February 2024 NRR E-mail Capture - (External_Sender) Psl Monthly Turtle Report for January 2024 ML24031A5472024-01-13013 January 2024 NRR E-mail Capture - (External_Sender) December 2023 FPL Marine Turtle Removal Monthly Report ML24002A7272023-12-16016 December 2023 NRR E-mail Capture - (External_Sender) November 2023 FPL Marine Turtle Removal Monthly Report ML23332A0352023-11-27027 November 2023 Conversion to Improved Technical Specifications Change in Estimated Review Schedule ML23326A0252023-11-20020 November 2023 NRR E-mail Capture - (External_Sender) October 2023 FPL Marine Turtle Removal Monthly Report ML24008A1582023-11-14014 November 2023 NRR E-mail Capture - (External_Sender) Psl Monthly Turtle Report for October 2023 ML23254A2852023-09-11011 September 2023 NRR E-mail Capture - (External_Sender) August 2023 FPL Marine Turtle Removal Monthly Report ML23243A9862023-08-31031 August 2023 NRR E-mail Capture - Draft RAIs for EP Staff Augmentation Times LAR (L-2022-LLA-0166) ML23243A9182023-08-31031 August 2023 NRR E-mail Capture - Re Audit Plan - St. Lucie ITS Conversion LAR - Setpoints ML23228A1482023-08-16016 August 2023 NRR E-mail Capture - Acceptance Review Results - St. Lucie Nuclear Plant, Unit 2 Alternative PSL2-I5-RR-01 (L-2023-LLR-0038) ML23226A0762023-08-14014 August 2023 NRR E-mail Capture - Request for Additional Information - St. Lucie Plant, Units 1 and 2 - Adopt 10 CFR 50.69 (L-2022-LLA-0182) ML23226A0692023-08-12012 August 2023 NRR E-mail Capture - (External_Sender) July 2023 FPL Marine Turtle Removal Monthly Report ML23223A0152023-08-11011 August 2023 NRR E-mail Capture - Acceptance Review Results - St. Lucie Nuclear Plant, Unit 2 Alternative PR-10 (L-2023-LLR-0039) ML23191A1952023-07-10010 July 2023 NRR E-mail Capture - (External_Sender) June 2023 FPL Marine Turtle Removal Monthly Report ML23216A1412023-06-30030 June 2023 August 2023 RP Inspection Document Request ML23248A1292023-06-29029 June 2023 NRR E-mail Capture - St Lucie 50.69 - Additional Audit Questions ML23173A1522023-06-22022 June 2023 Request for Additional Information NextEra Fleet Emergency Plan Amendment Request ML23198A0662023-06-22022 June 2023 NRR E-mail Capture - (External_Sender) Green Turtle Nest on Canal Bank, June 2023 ML23198A0642023-06-12012 June 2023 NRR E-mail Capture - (External_Sender) Loggerhead Nest on Canal Bank, May 2023 ML23163A1732023-06-10010 June 2023 NRR E-mail Capture - (External_Sender) May 2023 FPL Marine Turtle Removal Monthly Report ML23163A1222023-05-30030 May 2023 NRR E-mail Capture - (External_Sender) Nest on Intake Canal Bank ML23138A0212023-05-17017 May 2023 Telephone Record, Call with Florida Power and Light Regarding Decommissioning Funding Plan Update Dated March 30, 2021 ML23137A0942023-05-17017 May 2023 NRR E-mail Capture - Audit Plan - St Lucie Plant, Units 1 and 2 - 10 CFR 50.69 LAR ML23135A0292023-05-12012 May 2023 NRR E-mail Capture - (External_Sender) April 2023 FPL Marine Turtle Removal Monthly Report ML23129A8312023-05-0808 May 2023 NRR E-mail Capture - Audit Plan - St. Lucie ITS Conversion LAR - Setpoints ML23109A1862023-04-19019 April 2023 and Turkey Point Acceptance of Requested Licensing Action Proposed Alternative to Asme Section XI Authorizing Implementation of Asme Code Case N-752-1 ML23198A1592023-04-0707 April 2023 NRR E-mail Capture - (External_Sender) March 2023 FPL Marine Turtle Removal Monthly Report ML23074A2292023-03-15015 March 2023 NRR E-mail Capture - (External_Sender) February 2023 FPL Marine Turtle Removal Monthly Report ML23041A2262023-02-10010 February 2023 NRR E-mail Capture - (External_Sender) January 2023 FPL Marine Turtle Removal Monthly Report ML23065A1142023-02-0101 February 2023 NRR E-mail Capture - (External_Sender) FPL St. Lucie Plant Biological Opinion SERO-2019-03494 - Submittal ML23254A4022023-01-24024 January 2023 RP Inspection_2023-001_Document Request ML23019A0142023-01-18018 January 2023 NRR E-mail Capture - (External_Sender) Regarding St. Lucie Olive Ridley Capture 1/3/2023 ML23006A1822023-01-0606 January 2023 NRR E-mail Capture - (External_Sender) Psl Smalltooth Sawfish Capture 1/5/23 ML23006A1882023-01-0606 January 2023 NRR E-mail Capture - (External_Sender) December 2022 FPL Marine Turtle Removal Monthly Report ML23006A0242023-01-0505 January 2023 NRR E-mail Capture - (External_Sender) Psl Olive Ridley Capture 1323 ML23019A2052022-12-24024 December 2022 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors - Acceptance Review 2024-09-06
[Table view] Category:License-Fitness for Duty (FFD) Performance Report
MONTHYEARML24060A2632024-02-29029 February 2024 Annual Report Form for Drug and Alcohol Tests for 2023 ML24037A2142024-02-0606 February 2024 Annual Fatigue Report Form for 2023 ML24012A1092024-01-12012 January 2024 Single Positive Test Form Collected on 02/07/2023 ML24012A1082024-01-12012 January 2024 Single Positive Test Form Collected on 02/03/2023 ML24012A1102024-01-12012 January 2024 Single Positive Test Form Collected on 02/14/2023 ML24012A1182024-01-12012 January 2024 Single Positive Test Form Collected on 02/21/2023 ML24012A1172024-01-12012 January 2024 Single Positive Test Form Collected on 02/21/2023 ML24012A1112024-01-12012 January 2024 Single Positive Test Form Collected on 02/15/2023 ML24012A1212024-01-12012 January 2024 Single Positive Test Form Collected on 10/16/2023 ML24012A1192024-01-12012 January 2024 Single Positive Test Form Collected on 01/13/2023 ML24012A1202024-01-12012 January 2024 Single Positive Test Form Collected on 09/20/2023 ML24012A1162024-01-12012 January 2024 Single Positive Test Form Collected on 02/16/2023 ML24012A1072024-01-12012 January 2024 Single Positive Test Form Collected on 01/30/2023 ML23051A0012023-02-20020 February 2023 Annual Fatigue Report Form for 2022 ML23046A0502023-02-15015 February 2023 Single Positive Test Form Collected on 08/28/2022 ML23046A0572023-02-15015 February 2023 Single Positive Test Form Collected on 02/09/2022 ML23046A0522023-02-15015 February 2023 Single Positive Test Form Collected on 08/28/2022 ML23046A0552023-02-15015 February 2023 Single Positive Test Form Collected on 08/31/2022 ML23046A0582023-02-15015 February 2023 Single Positive Test Form Collected on 07/27/2022 ML23046A0562023-02-15015 February 2023 Single Positive Test Form Collected on 09/02/2022 ML23046A0642023-02-15015 February 2023 Single Positive Test Form Collected on 05/11/2022 ML23046A0682023-02-15015 February 2023 Single Positive Test Form Collected on 08/18/2022 ML23046A0672023-02-15015 February 2023 Single Positive Test Form Collected on 08/03/2022 ML23046A0652023-02-15015 February 2023 Single Positive Test Form Collected on 08/17/2022 ML23046A0632023-02-15015 February 2023 Single Positive Test Form Collected on 04/04/2022 ML23046A0662023-02-15015 February 2023 Single Positive Test Form Collected on 09/15/2022 ML23046A0702023-02-15015 February 2023 Single Positive Test Form Collected on 05/18/2022 ML23046A0692023-02-15015 February 2023 Single Positive Test Form Collected on 05/18/2022 ML23046A4552023-02-15015 February 2023 Annual Report Form for Drug and Alcohol Tests for 2022 ML23046A0712023-02-15015 February 2023 Single Positive Test Form Collected on 08/23/2022 ML23046A0492023-02-15015 February 2023 Single Positive Test Form Collected on 8/24/2022 ML23046A0512023-02-15015 February 2023 Single Positive Test Form Collected on 08/28/2022 ML23046A0622023-02-15015 February 2023 Single Positive Test Form Collected on 08/17/2022 ML23046A0482023-02-15015 February 2023 Single Positive Test Form Collected on 03/09/2022 ML23046A0542023-02-15015 February 2023 Single Positive Test Form Collected on 08/30/2022 ML22104A1472022-04-14014 April 2022 Single Positive Test Form Collected on 04/04/2022 ML22056A3982022-02-25025 February 2022 Single Positive Test Form Collected on 03/31/2021 ML22056A3972022-02-25025 February 2022 Single Positive Test Form Collected on 09/15/2021 ML22056A3942022-02-25025 February 2022 Single Positive Test Form Collected on 04/21/2021 ML22056A3952022-02-25025 February 2022 Single Positive Test Form Collected on 08/10/2021 ML22056A3992022-02-25025 February 2022 Single Positive Test Form Collected on 03/31/2021 ML22056A3962022-02-25025 February 2022 Single Positive Test Form Collected on 11/10/2021 ML22056A4072022-02-25025 February 2022 Annual Report Form for Drug and Alcohol Tests for 2021 ML22056A4062022-02-25025 February 2022 Single Positive Test Form Collected on 06/24/2021 ML22056A4052022-02-25025 February 2022 Single Positive Test Form Collected on 04/13/2021 ML22056A4042022-02-25025 February 2022 Single Positive Test Form Collected on 04/06/2021 ML22056A4032022-02-25025 February 2022 Single Positive Test Form Collected on 08/26/2021 ML22056A4022022-02-25025 February 2022 Single Positive Test Form Collected on 02/24/2021 ML22056A4012022-02-25025 February 2022 Single Positive Test Form Collected on 04/04/2021 ML22056A4002022-02-25025 February 2022 Single Positive Test Form Collected on 08/20/2021 2024-02-06
[Table view] |
Text
CHAIRMAN Resource From: 627ibew@gmail.com Sent: Friday, April 22, 2016 1:00 AM To: CHAIRMAN Resource Cc: Anna Jerry
Subject:
[External_Sender] SECY-15-0149
Dear Chairman Bums:
RE: SECY-15-0149, ML16063A268 Role of Third Party Arbitrators in Access Authorization & Fitness-for-Duty Determination Reviews at Nuclear Power Plants I am Mark MacNichol, President of IBEW LU #627, Fort Pierce, FL. I represent the bargaining unit at the St.
Lucie Nuclear Plant owned by Florida Power and Light.
I have reviewed the SECY-15-0149. I am hoping by me writing this letter to you that I can explain why I think if the NRC adopts the proposal it would be completely unfair to nuclear workers.
I started working at St. Lucie Nuclear Plant on March 6, 1989. Over the past 27 years I have witnessed the company wrongfully deny access to several employees. Through the arbitration process, several of those employees have been able to return to work. Once they returned to work they have given the company several more years of professional workmanship. The reason for the employees to be able to return to work is because they could arbitrate without limitations or restrictions. This is the only way that an employee can defend himself against an employers wrongful access authorization or fitness for duty determination. Now that I have said that, I am asking you to disapprove the SECY-15-0149.
Just like the NRC, the IBEW is committed to protecting the security of all nuclear sites. Through our Code of Excellence we enforce the importance of public safety at our nuclear sites and encourage nothing but the most professional workmanship. The IBEW has absolutely no interest in protecting anyone that has made a genuine threat. What I have actually seen over the years with the cases we have arbitrated are issues that came forth from minor infractions and minor off-duty conduct. These cases have had nothing to do with security of the nuclear sites.
I have some apprehensive thoughts on a couple of things if you allow SECY-15-0149. The first thought is, what protection would the employee have if the employer just wanted to discharge an employee if you take the option of unrestricted arbitration away. On the surface it looks like the employer wants to deny access but that usually leads to termination. My second thought is, by removing the unrestricted arbitration from the employee, how likely would the employee want to raise nuclear and safety concerns. I feel the employee would be scared of retribution by losing their right to unrestricted arbitration.
In closing, I would like to add that I do not feel the public will be any safer if the NRC adopts SECY 0149. Both the company and the union have trusted and agreed to the decisions of arbitrators for a very long time. I am not sure why the companies would worry about going to arbitration on Access Authorization or Fitness for Duty, if they have a good reason to deny either, I am sure the arbitrator would rule in their favor.
Thank You, Mark MacNichol 1
President, IBEW LU #627 2