ML20072K368

Comment Opposing Proposed Rule Change for 10CFR26 Re Consideration of Changes to fitness-for-duty Requirements. Util Suggests NRC Retain Current Scope of 10CFR26 as Is

ML20072K368
Person / Time
Site:	Beaver Valley
Issue date:	08/09/1994
From:	George Thomas DUQUESNE LIGHT CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR24373, RULE-PR-26 59FR24373-00025, 59FR24373-25, NUDOCS 9408300031
Download: ML20072K368 (2)

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Beaver Va ley Pow t n SNppingport. PA 15077-0004 (412) 393-5206 y yd (412) 643-8069 F AX W E 19 P4 :50 GEORGE S THOMAS Dwision Vice President Nuclear Services August 9, gylCE OF C7CPE TARY Nuclear Power Owision DOCXEIlNG & syjeg BR A hcM" U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Services Branch

Subject:

10 CFR Part 26, Request for Information and Comments on Consideration of Changes to Fitness-For-Duty Requirements Duquesne Light Company (DLC) is responsible for the operation of Beaver Valley Power Station Units 1 and 2. DLC is submitting the following comments ~ for consideration in response to the Nuclear i Regulatory Commission's (NRC) request for information and comments which was published in the May 11, 1994 Federal Register (59 FR I 24373). The NRC is requesting comments in consideration of changes to the Fitness-For-Duty (FFD) requirements. Specifically, the NRC is evaluating its approach concerning the designation of persons subject to random drug testing at nuclear power plants, particularly whether employees without direct safety-related duties (e.g., clerical staff) l I must be subject to random testing.

After careful review of the summary, DLC recommends that the NRC retain the current scope of the random testing requirements of 10 CFR j Part 26, which requires that all persons granted unescorted access to I protected areas at nuclear power plants be subject to random drug testing.

Recommendations to retain the current program are based upon:

1. All emplcyees at Beaver Valley Power Station are held responsible for the safe operation of the plant regardless of whether their job is or is not directly safety related.

2. All employees have a personal responsibility to their employer and fellow employees to maintain a drug free workplace.

3. Administration of the options presented to exclude and/or to limit certain workers from the random drug testing program would be cumbersome and time consuming.

4. Random testing has been shown to have a deterrent effect on substance abuse. This is supported by objective data reported by licensees' which shows a decrease in confirmed positive test results since the acceptance of 10 CFR 26.

9408300031 940B09 PDR PR 26 59FR24373 PDR l

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10 CFR Part 26 Comments on Consideration of Changes to Fitness-For-Duty Page 2

5. Although DLC knows of no data which establishes a relationship between substance abuse, impairment, and inadvertent acts, DLC agrees that human error becomes more significant with drug use, which can impair an employee's motor skills and judgment thereby increasing the risks to plant and general public safety.

Thank you for the opportunity to comment on this issue.

Sincerely,

1. fC e 3 George S. Thomas l

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