ML17312B424

Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps)

ML17312B424
Person / Time
Site:	Palo Verde
Issue date:	04/23/1997
From:	LEVINE J ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-62FR7811, RTR-REGGD-01.134, RTR-REGGD-1.134, TASK-*****, TASK-RE 102-03915-JML-A, 102-3915-JML-A, 62FR7811-00005, 62FR7811-5, NUDOCS 9705090033
Download: ML17312B424 (11)

Text

CATEGORY 2 REGULRT<O INFORMATION DISTRIBUTION

%STEM (RIDE)i.'A(FESSION NBR:9705090033 DOC,DATE: 97/04/23 NOTARIZED:

NO DOCKET g FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION LEVINE,J.Arizona Public Service Co.(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT, AFFILIATION Division of Freedom of Information

&Publications Services

SUBJECT:

Comment supporting draft RG DG-1068 (proposed Rev 3 to RG 1.134,"Medical Evaluation of Licensing Personnel at NPPs").DISTRIBUTION CODE: DSOSD COPIES RECEIVED:LTR J ENCL L SIZE: TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G T NOTES:STANDARDIZED PLANT Standardized plant.Standardized plant.05000528~05000529 P5PPP530 G RECIPIENT ID CODE/NAME INTERNA ILE CENTER 01 RES/DRA/DEPY EXTERNAL: NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME NMSS/IMOB T8F5 RES DIR RES/DST COPIES LTTR ENCL 1 1 1 1 1 1 D NOTE TO ALL MRIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL 7 k

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&ergy.r~gx zgv/Wk yg,gppg Palo Verde Nuclear Generating Station James M.Levine Senior Vice President Nuclear'EL (602)3934300 FAX (602)3936077 Mail Statio P.O.Box 52034 Phoenix, AZ 85072-2034 102-03915-JML/AKK/KR April 23, 1997 Rules, Review and Directives Branch Division of Freedom of Information and Publication Services Office of Administration U.S.Nuclear Regulatory Commission Washington, D.C.20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3 Docket Nos.STN 50-528/529/530 Comments on Draft Regulatory Guide DG-1068 Arizona Public Service Company (APS)hereby provides as an enclosure to this letter comments to the Draft Regulatory Guide DG-1068 (proposed Revision 3 to Regulatory Guide 1.134,"Medical Evaluation of Licensing Personnel at Nuclear Power Plants").We appreciate the opportunity to comment on the NRC's revised draft.'f you have any questions, please contact Daniel G.Marks, Section Leader, Nuclear Regulatory Affairs, at (602)3934492.Sincerely, P~<E JML/AKK/KR/kr 705090033 970423 PDR REGGD.0i.i34 C~'PDR ill llllllllllfllllllllflllllflf flfllflfl

NRC Rules, Review and Directives Branch Page 2 Comments on DG-1 068 bcc: M.F.Maddix J.C.Velotta R.C.Fullmer N.E.Meador RCTS 042361 1 6106 6156 7992 7636

ENCLOSURE COMMENTS FOR DG-1068 II COMMENTS FOR DRAFT REGULATORY GUIDE DG-1068 The comments are restricted to Section C.REGULATORY POSITION specific to the endorsement of ANSI/ANS 3.4-1 996,"Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants." The requirements contained in ANSI/ANS 3.4-1 996 provide methods acceptable to the NRC staff for determining the medical qualifications of applicants for initial or renewal operator (RO)or senior operator (SRO)licenses.APS requests that the endorsement of ANSI/ANS 3.4-1 996 be subject to the following:

Section 3.2 Facility Licensee's Report (FLR)states that the facility licensee shall forward to the physician a report on each licensed S/RO...prior to the examination.

This report shall address areas such as work performance, attendance, and behavioral changes noted since the previous review.Incidents of ineptness, poor judgment, and lack of physical or emotional stamina should be noted.Unusual cases of absence or lateness, and accident experience, should be recorded.Potential medical or psychological problems that could impair an individual's judgment or ability to perform assignments are more likely to be identified by the physician when this information is provided.APS believes that the requirements of 10CFR26, Fitness for Duty Programs, are better suited as a real-time solution to assessing an S/RO's medical or psychological problems.Per 10CFR26.22(a), managers and supervisors must be provided appropriate training to ensure they understand techniques for recognizing drugs and indications of the use, sale, or possession of drugs, as well as behavioral observation techniques for detecting degradation in performance, impairment, or changes in employee behavior and procedures for initiating appropriate corrective actions.APS believes that waiting until a physician assesses this behavioral information prior to examination is not only untimely, but transfers the burden of responsibility of assessing these problems on to a physician that is not as familiar with each individual's"normal" behaviors.

APS requests that the endorsement of ANSI/ANS 3.4-1996 exclude Section 3.2, removing the additional burden of reporting to a physician behavior problems that are not clinical and already should have been addiessed.

Section 5.3.2 Ears changes the audiometric average threshold loss from c 30 Db in ANSI/ANS 3.4-1 983 to s 25 Db in ANSI/ANS 3.4-1 996.Since 25 Db is considered"normal" hearing, the ANSI requirements are unnecessarily restrictive and provide for additional, as well as expensive, testing (i.e., audiologic evaluation, including a standard speech discrimination test)with a passing score of 80 percent.It is possible that a passing score of 80 percent would still allow an S/RO to perform control room duties with hearing loss>30 Db.

APS requests that the endorsement of ANSI/ANS 3.4-1996 Section 5.3.2 be subject to the original requirements of ANSI/ANS 3.4-1983, in that, if audiometric scores are unacceptable, qualification may be based upon onsite demonstration to the satisfaction of the licensee of the S/RO's ability to safely detect, interpret, and respond to speech and other auditory signals.Section 5.3.5 Cardiovascular provides for an additional stamina evaluation through use of a treadmill, bicycle ergometer, or other valid and reliable testing method for measuring aerobic capacity.Requiring a mandatory stamina evaluation for every S/RO without some other diagnosed indication of cardiovascular problems imposes an unnecessary financial burden on the licensees.

In addition, APS believes that"or other valid and reliable testing method for measuring aerobic capacity" is subject to a physician's interpretation and the chosen testing method may be criticized by the NRC as not satisfying the"intent" of ANSI/ANS 3.4-1 996.APS requests that the endorsement of ANSI/ANS 3.4-1996 Section 5.3.5 be subject to some indication'that the stamina evaluation is necessary prior to performance, such as an individual's age, history of cardiovascular problems, or general physical~health degradation.

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