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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210U4531999-08-12012 August 1999 Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide (Ki) in Emergency Plans.Urges NRC to Retain Current Policy for Ki Usage GO2-97-089, Comment Supporting Proposed Rule 10CFR73 Re Changes to Power Plant Security Requirements1997-05-0707 May 1997 Comment Supporting Proposed Rule 10CFR73 Re Changes to Power Plant Security Requirements ML17292A7151997-02-25025 February 1997 Comment Supporting Proposed Generic Communications, Effectiviness of Ultrasonic Testing Sys in ISI Program. ML20134L3351997-02-14014 February 1997 Order Imposing Civil Monetary Penalty Re Licensee Activities Conducted from 960628-960904 ML17291A9101995-07-0707 July 1995 Comment on Review of NRC Insp Rept Content,Format & Style. NRC Insp Repts Should Provide Balanced Perspective, Reflecting Licensee Strengths & Positive Aspects of Programs & Activities Reviewed GO2-95-080, Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Util Believes That Ability to Justify Actuator Capability by Analysis Should Not Be Restricted to Population of Small Valves1995-04-26026 April 1995 Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Util Believes That Ability to Justify Actuator Capability by Analysis Should Not Be Restricted to Population of Small Valves GO2-94-187, Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements1994-08-0808 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements ML20058L9561993-07-26026 July 1993 Decommissioning Trust,Consisting of Asset Summary for Period Ending 930630,asset Summary Adjusted for Accurals for Period Ending 930630 & List of Assets as of 930630 ML20045D7551993-06-18018 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule W/Listed Exceptions ML20044E1511993-05-30030 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercises from Annual to Biennial ML17290A3901993-05-21021 May 1993 Comments on Proposed Insp Procedure 38703, Commercial Grade Procurement Insp. ML17289A9151992-10-0909 October 1992 Comment on Proposed Changes to SALP Program.Util Supports Comments Being Filed by NUMARC & Legal Firm of Winston & Strawn GO2-92-164, Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Detailed Comments Submitted by Numarc,As Representing Licensee Views1992-07-10010 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Detailed Comments Submitted by Numarc,As Representing Licensee Views GO2-92-136, Comment Supporting Proposed Rules 10CFR19 & 20 Re Extension of Implementation Date Concerning 10CFR201992-06-0404 June 1992 Comment Supporting Proposed Rules 10CFR19 & 20 Re Extension of Implementation Date Concerning 10CFR20 ML20091D1631992-04-0303 April 1992 Comment Opposing Proposed Rule 10CFR2 Re Policy & Procedure for Enforcement Actions.Concerned That Policy Seems to Be Creating New Requirements Through Examples Given ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML17289A2931992-01-24024 January 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data ML17289A2541992-01-0606 January 1992 Comment on Draft Reg Guide Task DG-8004 Re Radiation Protection Programs.Reg Guide Provides Good Guidance for Maintaining Effective Radiation Protection Programs Aimed at Achieving Occupational Doses That Are ALARA GO2-91-103, Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery1991-05-16016 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery GO2-90-181, Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty. Rev Would Restrict Licensee from Taking Appropriate Action on Preliminary Positive Test1990-10-30030 October 1990 Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty. Rev Would Restrict Licensee from Taking Appropriate Action on Preliminary Positive Test ML17285B3701990-07-0505 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Frequency of FSAR Revs,Per 10CFR50.71(e)(4) Requirements GO2-89-115, Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Plant Structures,Sys & Components. Util Accepts NUMARC Comments1989-07-0606 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Plant Structures,Sys & Components. Util Accepts NUMARC Comments ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons ML17279A8041987-10-19019 October 1987 Endorsement 28 to Nelia Policy NF-270 ML20098C8851984-08-24024 August 1984 Undated marked-up Transcript of Jj Stein Testimony Re Util Financial Qualifications to Design & Construct Nuclear Reactor ML20082K0471983-10-14014 October 1983 Show Cause Petition Requesting Revocation of CP & Denial of OL ML20082K0301983-10-13013 October 1983 Affidavit of Sandler in Support of Coalition for Safe Power 831014 Show Cause Petition ML20072N4411983-07-0808 July 1983 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20072H2981983-03-25025 March 1983 Brief in Opposition to Coalition for Safe Power Appeal from ASLB 830222 Memorandum & Order Dismissing 820223 Petition to Intervene.Petitioner Failed to Particularize & Support Contentions.Certificate of Svc Encl ML20069D3441983-03-10010 March 1983 Brief Supporting Appeal from ASLB 830222 Memorandum & Order. ASLB Erred in Concluding Petitioner Failed to Show Dilatory Conduct by Util & Was Not Entitled to Hearing on CP Extension.Certificate of Svc Encl ML20069D2761983-03-10010 March 1983 Notice of Appeal of ASLB 830222 Memorandum & Order on Issue of Util Delay ML20070M6521983-01-24024 January 1983 Response in Opposition to Coalition for Safe Power 820223 Request for Hearing on Amend to CPPR-93.Petitioner Failed to Establish Interest in Proceeding or How Interest Will Be Affected by Proceeding.Certificate of Svc Encl ML20028C7851983-01-10010 January 1983 Suppl to Request for Hearing & Petition for Leave to Intervene,Listing Contentions.Certificate of Svc Encl ML20070J0401982-12-22022 December 1982 Response Supporting Coalition for Safe Power 821209 Motion for 1-wk Delay of Prehearing Conference Scheduled for 830119-20.Applicant Does Not Concede That Basis for Request Constitutes Good Cause.Certificate of Svc Encl ML20070D0001982-12-0909 December 1982 Motion for Delay of 830119 & 20 Prehearing Conference. Schedule Burdensome Due to Two Major Holiday Periods.Four Days of Preparation Lost.Certificate of Svc Encl ML20049J2331982-03-10010 March 1982 Answer Opposing Coalition for Safe Power 820223 Request for Hearing on CP Amend.Cp Amend Involves No Significant Hazards Consideration.Alternatively,Petitioner Failed to Meet Interest,Affects & Aspect Stds.Certificate of Svc Encl ML20049H5231982-02-22022 February 1982 Requests for Public Hearing Re Order Extending Const Completion Date.States Interest & Specific Aspects & Contentions Affecting Petitioners.Certificate of Svc Encl ML20009E3061981-07-23023 July 1981 Response Opposing Porter County Chapter Intervenors' 810519 Fourth Request for Production of Documents.Request Is W/O Merit & Should Be Denied ML20098D0881980-04-25025 April 1980 MOU Between WPPSS & Doe,Acting by & Through BPA Re Roles & Responsibilities Under Project Agreements Concerning Const & Operation of Net Billed Projects ML17272A8861980-02-0606 February 1980 Transcript of 800206 Briefing to NRC in Bethesda,Md Re Sacrificial Shield Wall,Pipe Whip Restraints & Related Structures.Pp 1A-122 ML19261C0571979-02-15015 February 1979 Util Opposes Petitioners Darby,Garrett & Hanford Conversion Project Addl Contention & Legal Argument.Intervention Petition Should Be Disposed of on Basis of Existing Record as Previously Stipulated.Certificate of Svc Encl ML19274D7801979-02-0606 February 1979 Applicant'S Proposed Corrections to Transcript of 790125 Prehearing Conference.Certificate of Svc Encl ML19263C4481979-02-0101 February 1979 Addl Contention & Legal Argument Pursuant to ASLB 790125 Permission.Contends Inadequate Assessment of Safety Risks. Certificate of Svc Encl ML17272A2691979-01-19019 January 1979 Applicant Answer in Opposition to Petitioners Darby Garrett & Hanford Conversion Project Request for Waiver of 10CFR2.708(b).W/encl Certificate of Svc ML19261A6791979-01-10010 January 1979 Second Amended Petition to Intervene,Supplementary Except Where Noted,To 781115 Petition.Addresses Contentions Re Need for Power,Alternatives.Notice of Withdrawal,Affidavit & Certificate of Svc Encl ML19261A6841979-01-10010 January 1979 Requests Waiver of double-spacing Requirement for Filed Documents Because of Added Expense.Assures That Documents Will Be Legible.W/Encl Certificate of Svc ML17272A2231978-12-15015 December 1978 Applicant'S Answer in Opposition to Amended Petition for Leave to Intervene Submitted by SM Garrett,H Vozenilek & Hanford Conversion Project.Asserts That Latter Has No Legal Interest in Proceedings.Certificate of Svc Encl ML20062G4631978-12-14014 December 1978 NRC Staff'S Response to Amended Petition to Intervene Submitted by SM Garrett,H Vozenilek & Manford Conversion Proj.Asserts That Only Manford Conversion Proj Has Met Interest Criteria of 10CFR2.714.Cert of Svc Encl ML20062E0581978-11-15015 November 1978 Amended Petition for Leave to Intervene. Indicates That Intervenors Have Evidence That Has Dev Since 1973 & Other Info Not Considered in the Constr Permit Proc Held in 1973. W/Encl 781107 Appl for Membership in Hanford ML20062E0601978-11-15015 November 1978 Memo in Support of Amended Petition for Leave to Intervene Presents Evidence Dev Since 1973 & Other Info Not Considered in Those Constr Permit Proc.Cert of Svc Plus Insert to Amended Petition for Leave to Intervene. Encl 1999-08-12
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20210U4531999-08-12012 August 1999 Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide (Ki) in Emergency Plans.Urges NRC to Retain Current Policy for Ki Usage GO2-97-089, Comment Supporting Proposed Rule 10CFR73 Re Changes to Power Plant Security Requirements1997-05-0707 May 1997 Comment Supporting Proposed Rule 10CFR73 Re Changes to Power Plant Security Requirements ML17292A7151997-02-25025 February 1997 Comment Supporting Proposed Generic Communications, Effectiviness of Ultrasonic Testing Sys in ISI Program. ML17291A9101995-07-0707 July 1995 Comment on Review of NRC Insp Rept Content,Format & Style. NRC Insp Repts Should Provide Balanced Perspective, Reflecting Licensee Strengths & Positive Aspects of Programs & Activities Reviewed GO2-95-080, Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Util Believes That Ability to Justify Actuator Capability by Analysis Should Not Be Restricted to Population of Small Valves1995-04-26026 April 1995 Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Util Believes That Ability to Justify Actuator Capability by Analysis Should Not Be Restricted to Population of Small Valves GO2-94-187, Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements1994-08-0808 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements ML20045D7551993-06-18018 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule W/Listed Exceptions ML20044E1511993-05-30030 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercises from Annual to Biennial ML17290A3901993-05-21021 May 1993 Comments on Proposed Insp Procedure 38703, Commercial Grade Procurement Insp. ML17289A9151992-10-0909 October 1992 Comment on Proposed Changes to SALP Program.Util Supports Comments Being Filed by NUMARC & Legal Firm of Winston & Strawn GO2-92-164, Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Detailed Comments Submitted by Numarc,As Representing Licensee Views1992-07-10010 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Detailed Comments Submitted by Numarc,As Representing Licensee Views GO2-92-136, Comment Supporting Proposed Rules 10CFR19 & 20 Re Extension of Implementation Date Concerning 10CFR201992-06-0404 June 1992 Comment Supporting Proposed Rules 10CFR19 & 20 Re Extension of Implementation Date Concerning 10CFR20 ML20091D1631992-04-0303 April 1992 Comment Opposing Proposed Rule 10CFR2 Re Policy & Procedure for Enforcement Actions.Concerned That Policy Seems to Be Creating New Requirements Through Examples Given ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML17289A2931992-01-24024 January 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data ML17289A2541992-01-0606 January 1992 Comment on Draft Reg Guide Task DG-8004 Re Radiation Protection Programs.Reg Guide Provides Good Guidance for Maintaining Effective Radiation Protection Programs Aimed at Achieving Occupational Doses That Are ALARA GO2-91-103, Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery1991-05-16016 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery GO2-90-181, Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty. Rev Would Restrict Licensee from Taking Appropriate Action on Preliminary Positive Test1990-10-30030 October 1990 Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty. Rev Would Restrict Licensee from Taking Appropriate Action on Preliminary Positive Test ML17285B3701990-07-0505 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Frequency of FSAR Revs,Per 10CFR50.71(e)(4) Requirements GO2-89-115, Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Plant Structures,Sys & Components. Util Accepts NUMARC Comments1989-07-0606 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Plant Structures,Sys & Components. Util Accepts NUMARC Comments 1999-08-12
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6 COCiGT NUMBER 1 PROPOSED RULE N 15 _
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WASHINGTON PUBLIC POWER SUPPkh' SYSTEM no. n isa . w>oacap wamngnm way . ac<nans, washinston 993s2.o968
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Bh ASU August 8,1994 l GO2-94-187 Docket No. 50-397 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Docketing and Service- Branch
Dear Mr. Chilk:
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Subject:
col @1ENTS REGARDING CO$'51DERATION OF CHANGES TO FITNE5S-FOR-DUTY (FFD) REQ (HREMENTS The Washington Public Power Supply System (Supply System) hereby submits comments regarding the consideration of changes to Fitness-For-Duty (FFD) requirements in 10 CFR 26, as requested in the May 11,1994 Federal Register (59 FR 24373).
We believe that the Supply System, our employees, and other workers have benefitted from the current scope of drug testing and that a reduction in the scope of testing is not warranted. Our current Fitness-For-Duty (FFD) Program, including pre-employment and random drug testing, has created an essentially drug-free workplace. Our staff has accepted that testing and the resulting drug-free environment are necessary and do contribute to personnel and public health and sarety. A reduction in testing scope could be taken to indicate that the NRC and/or individual licensees have become less concerned with drugs in the workplace.
The Supply System estimates that a reduced scope of random testing would not result in significant savings, since any savings may be offset by an increased administrative effort to i
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establish and maintain separate testing groups We believe that any savings do not justify the possible additional risk in personnel and public health and safety.
As an alternative to a reduced testing scope, the Supply System suggests a performance-based l I
system using the current scope of testing. Licensees which have established a history of good performance, i.e, a low rate of positive tests, could reduce the rate of testing while maintaining the current testing scope. We feel that this would accomplish an appropriate reduction in licensee burden where justified by performance, with a smaller chance of impacting successful FFD Programs.
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L Page 2 COMMENTS REG ARDING CONSIDERATION OF CII ANGES TO FITNESS-FOR-DUTY (FFD) REQUIREMENTS Additional specific comments in response to the questions posed in the request for comments (59 FR 24373) are attached.
The Supply System appreciates this opportunity to share our views with the Commission. Please contact Mr. Douglas Coleman at (509) 377-4342 should you have any questions or wish to discuss this matter further, Sincerely,
. . fGmt
. V. Parrish (Mail Drop 1023)
Assistant Managing Director, Operations HEK/ JAG /kd Attachment cc: U Callan - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office NS Reynolds - Winston & Strawn JW Clifford - NRC DL Williams - BPA/399 NRC Sr. Resident Inspector - 901 A l
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SUPPLY SYSTEM COMMENTS REGARDING CONSIDERATION OF CHANGES TO FITNESS-FOR-DUTY (FFD) REOUIREMENI'S.
NRC OuestionsJam 59 FR 24373 Ouestion:
- 1. Should the Commission retain the current scope of the random drug testing requirements in 10 CFR Part 26, which requires that all persons granted unescorted access to protected areas at nuclear power plants be subject to random drug testing? (Option 1)
Supoly System Response:
Yes, the current scope should be retained. The Supply System believes that reducing the current scope of random drug testing would be detrimental to Fitness-For-Duty (FFD) P:ograms as discu< sed in the pieceding cover letter.
Ouestion:
2.a. Should the Commission...[e]xclude from . :adom drug testing certain groups of workers (e.g., clerical, administrative) who have unescorted access to protected areas but not vital areas [?] (Option 2)
Supply System Respong:
No, these workers should be retained in the scope of random testing. Many, if not most or all, of these workers have access to important (but not vital) plant equipment. The Supply System believes that removing these workers fron3 random testing could well be viewed as decreased NRC and/or licensee interest in maintaining a drug-free environment for nuclear plants, which may lead to additional drug use and/or impairment. Additional drug use or impairment could then lead to an increased risk to personnel and public health and safety.
If increased drug use occurs among these workers, their continual proximity to those workers with vital area access could also influence additional drug use in the vital area workers.
1 Ouestion:
2.b. Should the Commission...[1]imit random drug testing to only those workers who have unescorted access to vital areas of nuclear power plants [?] (Option 3)
Sgmly_ System Response:
No, the current scope of random testing should be retained. The rationale for this response is as that for Question 2.a.
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SUPPLY SYSTEM COMMENTS REGARDING CONSIDERATION OF CHANGES TO FTTNESS-FOR-DUTY (FFD) REOUIREMENTS (continued)
Questipl1:
2.c. Should the Commission...[1]imit random drug testing to workers whose jobs involve safety- or security-related functions regardless of whether these workers have unescorted access to protected areas [7] (Option 4)
Sxpply System Resoonse:
No, the current scope of random testing should be retained. The rationale for the response to Question 2.a. applies to this respense. In addition, defining and maintaining a list of workers with safety-related functions would be extremely difficult. And most importantly, some employees not performing safety- or security-related functions and therefore outside the scope of random testing,(i.e.,
those with an increased risk of impairment) might have access to vital areas and/or other safety-related equipment.
Question:
2.d. Should the Commission...[a]Ilow use of alternative testing methods in lieu of urinalysis for certain groups of workers...[?] (Option 5)
Sunoly System Respmo:
No, the current scope and methods of random testing should be retained. The' rationale for the response to Question 2.a. also applies to this response, given that known alternative testing methods will not detect as reliably. Therefore, we believe they will not deter drug use as effectively. However, we believe that an alternate method of using a performance-based system to determine the testing rate, rather than the testing scope or methods, would not reduce the deterrence effect of random testing.
Question:
- 3. For each of the four approaches above (2.a-2.d), what are the potential effects on risk to public health and safety or on vt'!nerability of nuclear power plants resulting from accidental acts and deliberate acts such as sabotage or vandalism?
Will vulnerability or risk increase or decrease to any significant degree, or will.
they remain unchanged? ,
Suoply System Response:
Although the current FFD Program has been a success in helping create an essentially drug-free environment, there is no proven correlation in testing scope 2 ,
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SUPPLY SYSTEM COMMENTS REGARDING CONSIDER ATION OF CR$JiGES TO FITNESS-FOR-DUTY (FFD) REOUIREMENTS !
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(continued) and substance use/ employee impairment. However, the Supply System believe:,
that, in general, a reduced scope of testing will result in more substance use and an increased likelihood of employee impairment, which in turn increases the risk to personnel and public health and safety. We feel that reducing the current scope of FFD Programs would aggravate this situation more than having originally selected a smaller scope. This reduction may impart a message that drug use is of lesser concern to the NRC and the licensee. This rationale applies to Approaches 2.a through 2.d, with the vulnerability and risk increase for each approach proportional to the number of workers removed from the current testing scope.
Questiori:
- 4. What would be the expected effect on the need for random drog testing under each of the four approaches above (2.u2.d) if vital area access controls are reduced (e.g., allowing certain vital area doors to normally be unlockul, but be capable of (i) being remotely locked ca demand in the event of a security contingency, and (ii) generating an alarm if a vital area door is opened without an authorized keycard)?
Supply System Resoonse:
Reducing access controls for vital areas is predicated on the premise of trustworthiness and reliability of those individuals having access to those areas:
An industry proposal has been made to reduce security controls at vital area portals, taking credit for scrutiny under the unescorted access program including FFD.
However, if FFD requirements are relaxed or modified to exclude portions of the plant population, the rational for this proposal may be weakened. It appears relaxing security access requirements an.d FFD requirements may not be mutuall?
consistent.
Specifically, we also believe that remotely locking doors on demand may create an unjustified risk to personnel safety by possibly limiting egress from dangerous areas, and to public health and safety by impeding prompt responses by the unit staff.
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l SUPPLY SYSTEM COMMENTS REGARDING CONSIDERATION OF CHANGFS TO FITNESS-FOR-DUTY (FFD) REOUIREMENTS (continued)
Question:
- 5. Does substance abuse increase the probability of a person committing a deliberate act such as sabotage or vandalism? These acts might be caused by indirect influences of drugs on a person's attitude or susceptibility to being influenced by others. What data exist to show a relationship between substance abuse and deliberate acts? Is random drug testing an appropriate means to control the risk of deliberate acts associated with substance abuse and, at the same time, not encroach unreasonably into individual privacy expectations?
Supoly System Rescops_e:
We are aware of no data showing a relationship between substance abuse and committing deliberate acts of sabotage or vandalism, although the possibility of such acts being influenced by abuse-induced impaired judgement exists. Other factors, such as mental duress, stress, or employment actions a more probable precursors to deliberate acts of sabotage, =ndalism, or violence.
An expectation of individual privacy at a workplace is predicated upon the mture of the work. Workers at a nuclear power plant are consistently held to a higher degree of responsibility than in other types of work. Due to the sensitive nature of working at nuclear power plants, and the reduction to 50% random testing, the Supply System does not believe there is an unreasonable invasion of privacy in requiring a random chemical test.
Question:
- 6. Does the Commission's policy in 10 CFR Part 26 deter the introduction of illegal substances into protected areas of nuclear power plants? Is so, what aspect (s) of the FFD program creates this deterrent effect? If not, should the Commission required licensees to implement measures to cause this deterrent effect, and what type of measures should be required?
Sunolv System Resoonse:
Random drug testing under 10 CFR 26 is an appropriate, cffective means of deterring the use and possession of dmgs and alcohol by the plant population, The mere chance of random selection for drug testing deters both the use and possession of illegal substances. The Supply System's policy is a drug-free workplace; modifying the testing program may be contrary to this policy.
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