Similar Documents at Ginna |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20198Q4261998-12-14014 December 1998 Order Approving Application Re Restructuring of Rg&E Corp by Establishment of Holding Company Affecting License DPR-18, Ginna NPP ML17265A3931998-07-31031 July 1998 Request for Consent to Corporate Reorganization.Rg&E Is Restructuring to Adopt Holding Company Form of Corporate Organization as Authorized by New York State PSC ML20202D2301997-11-24024 November 1997 Comment Opposing Proposed Change to 10CFR50.55a(h) to Incorporate Requirements of IEEE Std 603-1991,effective 980101 ML17309A6161997-06-19019 June 1997 Comment on Proposed NRC Bulletin 96-001,Suppl 1, Control Rod Insertion Problems. ML17263A9531995-02-28028 February 1995 Comments on Proposed Suppl 5 to GL 88-20 Re Reduction in Seismic Hazard to Majority of Us NPP ML20077M8071995-01-0303 January 1995 Comment Supporting Proposed Rule 10CFR50 Re Shutdown & Low- Power Operations for Nuclear Power Reactors ML20059F6811993-12-28028 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Clear Definition of Commerical Grade Items 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 ML17309A4711992-01-29029 January 1992 Comments on Draft Rev 1 to NUREG-1022, Event Reporting Sys, 10CFR50.72 & 50.73. ML17262A2311990-10-24024 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML17262A2111990-10-12012 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20245K8781989-04-25025 April 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Urges NRC to Consider Allowing Sufficient Time to Assess Impact of Current Maint Upgrade Efforts at Plant ML20235V6641989-03-0101 March 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Proposed Rule May Be Detrimental to Safety by Discouraging Potentially Superior Maint Practices ML20206M7861988-11-21021 November 1988 Comments Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program Re Substance Abuse.Urges Commission to Adopt Suggested Specific Changes Indicated by NUMARC Comments ML20196B3431988-06-20020 June 1988 Joint Motion to Stay Proceedings for 90 Days & Order Thereon.* Stay of Proceedings,Including Time to File Suppl to Petition for Leave to Intervene Requested.W/Certificate of Svc ML20154H4571988-03-30030 March 1988 Comment Supporting Proposed Rule 10CFR50 Re Alternative Method for Leakage Rate Testing.Suggests That Rulemaking Should Simply Establish Acceptability of Mass Point Method & Allow Analysis of Data to Determine Length of Testing IR 05000244/19860161986-11-12012 November 1986 Board Exhibit B-26,consisting of 861023 Insp Rept 50-244/86-16 & 861103 Forwarding Ltr ML20094C2341984-08-0303 August 1984 Motion to Terminate Proceeding Based on ML Slade 840724 Withdrawal of Outstanding Contentions.No Contentions Remain to Be Heard or Decided.Proceeding Should Be Terminated. Certificate of Svc Encl ML20090H6421984-07-24024 July 1984 Withdrawal of Contentions by Intervenor.Certificate of Svc Encl ML20093D5771984-07-13013 July 1984 Interrogatories Propounded to Intervenor MR Slade Re Contentions A,E & K.Certificate of Svc Encl.Related Correspondence ML20085H7221983-09-0909 September 1983 Response to ASLB 830819 Order Re Mi Slade 830715 Status Rept.All Regulatory Correspondence Provided to Slade or Available in Pdr.Proceeding Need Not Be Renoticed.No Basis Exists for Intervenor Reimbursement.Certificate of Svc Encl ML20076M3041983-07-15015 July 1983 Status Rept as of 830715.Util Has No Further Issuances.Nrc Has Two Issuances Expected by 830901.Author Expects to File Revised/Addl Contentions.Prehearing Conference Unnecessary. Certificate of Svc Encl.Related Correspondence ML20076L6821983-07-15015 July 1983 Memorandum of Law Supporting Licensee Position Re Need to Renotice Opportunity to Intervene.Aslb Should Not Order Renotice,Since Neither Law Nor Policy Counsel Favor Renotice.Certificate of Svc Encl ML20076L6731983-07-15015 July 1983 Response to ASLB 830615 Order,Recommending That Period of Discovery Not Commence Until All Future Issuances Re Integrated Plant Safety Assessment Rept (NUREG-0821) Available ML20073P9891983-04-25025 April 1983 Request to Amend Svc List.Certificate of Svc Encl ML20071K7711982-07-30030 July 1982 Response to ASLB 820708 Order Re Status of Hearing. Discussion of Matters Re Discovery,Prehearing Conferences & Hearings Are Premature & Should Be Postponed Pending Issuance of Documents.Certificate of Svc Encl ML20055B1041982-07-16016 July 1982 Order Extending Time Until 820721 for Commission to Act to Review 820522 Director'S Decision ML20054M7721982-07-0909 July 1982 Order Extending Time Until 820716 for Commission to Act to Review 820522 Director'S Decision ML20054M1921982-07-0808 July 1982 Order Directing Parties to Confer Re Further Proceedings & Directing Each Party Submit Status Rept to ASLB by 820731 on Listed Matters ML20054L2981982-07-0202 July 1982 Order Extending Time Until 820709 for Commission to Act to Review 820523 Director'S Decision ML20054G6401982-06-18018 June 1982 Transcript of 820618 Special Investigative Proceeding in White Plains,Ny.Pp 1,126-1,253 ML20054E6561982-06-0909 June 1982 Order Extending Time Until 820702 for Commission to Act to Review 820522 Director'S Decision ML17258A6371982-03-11011 March 1982 Petition for Order to Show Cause Why OL Should Not Be Suspended or Why Permission to Restart Reactor Should Not Be Withheld.Affidavit,Factual Basis for Petition & Excerpt of Weekly Info Rept for Wk Ending 820212 Encl ML17250A3281980-06-0202 June 1980 Status Rept in Response to ASLB 800429 Order.Recommends Schedule for Findings,Safety Evaluation Suppl,Discovery & Further Prehearing Conferences.Recommends Determination of SEP Progress in One Yr ML17250A3211980-05-30030 May 1980 Status Rept by Ny State Energy Ofc in Reponse to ASLB 800429 Order.Recommends That Parties Be Permitted to Identify Addl Contentions & That Prehearing Conference Be Held to Discuss Issues.W/Notice of Appearance & Certificate of Svc Encl ML17249A3491979-12-10010 December 1979 Stipulation Terminating Proceeding as to Rochester Committee for Scientific Info,Inc.Rcsi Agrees That Applicant Has Fulfilled Paragraphs 1 & 4 Requirements of 740312 Stipulation.Certificate of Svc Encl ML17249A2521979-10-31031 October 1979 Notice of Withdrawal of ED Doane,Ae Upton & Hm Babcock as Counsel for Rochester Gas & Electric Corp.Certificate of Svc Encl ML17249A2531979-10-31031 October 1979 Notice of Appearance on Behalf of Rochester Gas & Electric Corp.Certificate of Svc Encl ML20079F4371973-01-0505 January 1973 Petition of State of Ny for Leave to Intervene & Request for Hearing 1998-07-31
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20202D2301997-11-24024 November 1997 Comment Opposing Proposed Change to 10CFR50.55a(h) to Incorporate Requirements of IEEE Std 603-1991,effective 980101 ML17309A6161997-06-19019 June 1997 Comment on Proposed NRC Bulletin 96-001,Suppl 1, Control Rod Insertion Problems. ML17263A9531995-02-28028 February 1995 Comments on Proposed Suppl 5 to GL 88-20 Re Reduction in Seismic Hazard to Majority of Us NPP ML20077M8071995-01-0303 January 1995 Comment Supporting Proposed Rule 10CFR50 Re Shutdown & Low- Power Operations for Nuclear Power Reactors ML20059F6811993-12-28028 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Clear Definition of Commerical Grade Items 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 ML17309A4711992-01-29029 January 1992 Comments on Draft Rev 1 to NUREG-1022, Event Reporting Sys, 10CFR50.72 & 50.73. ML17262A2311990-10-24024 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML17262A2111990-10-12012 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20245K8781989-04-25025 April 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Urges NRC to Consider Allowing Sufficient Time to Assess Impact of Current Maint Upgrade Efforts at Plant ML20235V6641989-03-0101 March 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Proposed Rule May Be Detrimental to Safety by Discouraging Potentially Superior Maint Practices ML20206M7861988-11-21021 November 1988 Comments Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program Re Substance Abuse.Urges Commission to Adopt Suggested Specific Changes Indicated by NUMARC Comments ML20154H4571988-03-30030 March 1988 Comment Supporting Proposed Rule 10CFR50 Re Alternative Method for Leakage Rate Testing.Suggests That Rulemaking Should Simply Establish Acceptability of Mass Point Method & Allow Analysis of Data to Determine Length of Testing 1997-06-19
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November 21, 1988 Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission WaJhingtw.1, D.C. 20555 Attention: Docketing and Service Branch Re: Proposed Rulo - Fitness-for-Duty Program 53 FR 36795 (September 22, 1988)
Recuest fpr Comments
Dear Mr. Chilk:
These comments are submitted on behalf of the Rochester Gas &
Electric Corporation in response to the request of the U.S.
Nuclear Regulatory Commission ("NRC") for comments on the NRC proposed * 'e titled Fitness-for-Duty Program (53 FR 36795).
Rochester As & Electric Corporation owns and operates Ginna Station, a 470 MW PWR nuc3 ear power plant which has been in commercial operation since 1969. The company has a comprehensive Nuclear Fitness-for-Duty Program and has cooperatively supported the efforts of the NRC, NUMARC, INPO, EEI and other utility organizations in developing and enhancing such programs, in-cluding chemical testing, within the industry. RG&E commenced chemical testing in January 1985 and has, with the exception of random drug testing, knowledge and experience with the topics covered in the proposed rule.
Rochester Gas & Electric Corporation supporto the Commission's Policy Statement on Fitness-for-Duty of Nuclear Power Personnel that was published in the Federal Recister on August 4, 1986 and recognizes the desire of the NRC to proceed with a rulemaking to supplement its Policy Statement. In general, RG&E supports the proposed rule. Our submittal has been limited to comments that we believe may not have been fully addressed by NUMARC or other utility organizations submitting comments, or are reflective of our unique history and/or operating environment as relating to Fitness for Duty or chemical testing.
Representatives from RG&E attended and participated in both the NRC Public Hearing on October 17, 1988 and the NUMARC Fitness for Duty Workshop on October 20, 1988. Additionally, our Company has 8012010410 881121 FDR 2 03 R36795 g) gg
2 reviewed both the proposed rule and the NUMARC comments (inclu-ding attachments) regarding the rule which are being submitted to the commission on November 18, 1988. Based upon this review, RG&E concurs whh and supporta the NUMARC comments. As we believe that these comments reflect the consensus of the nuclear industry as represented by NUMARC, we urge the Commission to adopt thn suggested specific changes as indicated, and to address those issues which require further study and deliberation.
Additionally, RG&E submits the following comments for Commission review:
- 1. RG&E wholeheartedly endorses the NUMARC position regarding the inclusion of alcohol in the proposed rule as discussed on page two of the comment cover letter. However, because RG&E does not currently test for alcohol except on a "for cause" basis, we cannot, without farther evidence or study, agree with the NUMARC comment on Page 2A of attachment A, item 5 "(2) Administrative 1y, it would be beneficial to conduct alcohol and drug testing at the same time;". In our opinion, recognizing a problem and taking appropriate action based upon the information are two separate issues and should not, absence further study, be considered as one problem.
- 2. While RG&E supporta the NUMARC comments regarding the appro-priate relationship between the proposed rule and the DHHS
, "Mandatory Guidelines for Federal Workplace Drug Testing Programs" (53 FR11970), requiring such guidelines for those nuclear companies located in states with existing comprehen-sive drug testing laboratory standards, may penalize those companies and cause unnecessary economic and financial hardship. Pursuant to New York State Public Health Law 12 (1) and 574 effective July 1, 1987, drug testing laborator-les must hold a state permit in Forensic Toxicology and are subject to stringent certification and quality assurance standards. As the New York State program generally paral-1els the DHHS Program, RG&E believes there is no compelling reason to provide absolute lab standardization throughout the country.
Due to the high cost of the National Institute of Drug Abuse (NIDA) annual certification program which cost approximates
$20,000 annually, our drug testing laboratory (located in Rochester, New York) has indicated that due to high cost and i
unnecessary and/or redundant quality control requirements, it will not be able to seek such certification. Consequent-ly, RG&E would be forced to stop utilizing the services of a small local, but high quality lab and seek the services of a large, probably out of stats, lab which processes millions of urine samples per year at a probable higher cost to the company.
i l
k , _ _ _ _ _ . _ . _ - -
3 As we believe that the NRC's intent is to not inappropri-ately and materially affect the relationships between the l':ensees and their local and/or state service providers, we recommend that the NRC adopt a provision that authorizes licensees to utilire a drug :sseing lab that either is certified via the DHHS guidelines or is certified under a state program that is generally comparable to the D!IHS program.
- 3. RG&E supports NUMARC's position regarding random sample testing rates but would like to add a comment to the NUMARC discussion on page 3C, Attachment C - Discussion Question 3. Unlike many companies, RG&E has three rather than two sample populations as discussed by NUMARC in the 2nd paragraph. As 60 percent of RG&E's unescorted access authorized employees are not permanent plant site personnel, and only work at the plant on an intermittent basis or only during the annual 1-2 month outages, two sample populations would inappropriately burden the Company in locating and testing such personnel, or would result in considerable over testing of permanent plant personnel.
Consequently, we urge the Commission to provide considerable flexibility to the licensees in determining the methodology fer administering the suggested 100 percent testing rate.
It would appear that one permissible approach should he to allow licensees to administer the test rate, sample popula-tions, etc., based upon site demographics throughout the year and to ensure that all personnel have an equal on site daily probability of being selected for a test during the year.
An example would be to use a 2 percent testing rate sample size por week based on the total number of people (perman-ent, temporary, contractor) with unescorted access estimated
. or determined to be on site during that week. This would l give everyone on site an equal chance per day but would
, provide appropriate weighting based upon the total site time l per year.
l l 4. RG&E concurs with NUMARC's comments regarding disclosure and I confidentiality as discussed on page 12 B-item 36. However, in the response to Discussion Question 5 on pages SC & 6C, RG&E believes that the disclosure restrictions may be too narrow to encompass the needs and situations of all nuclear l plants. While RG&E does not conduct random testing and would be undecided regarding the conducting of on site drug screening, employee relations concerns in a non-union plant environment would require immediate notification of a designated personnel representative who would be involved in any investigation of the case. Consequently, we would urge the NRC to provide flexibility in this area in accordance I
4 with prudent and legal requirements regarding privacy and confidentiality.
We appreciate the opportunity to comment on the proposed rule and would welcome the opportunity to discuss our comments further with appropriate NRC staff personnel. If you have any questions regarding RG&E's comments, please contact Jeffrey W. Peters, Manager - Human Resource Planning & Development at (716) 724-8750.
Very truly y,ours,
/] t)
' 'I i
\ 1 R S t Wilfr d . Schrouder, Jr.
Vice President Vice President Production & Engineering Employee Relations and Public Affairs xc: B. Lee, Jr. - NUMARC R. W. Kober R. C. Henderson J. W. Oberlies !
D. C. Heiligman W. K. Dillon C. H. Griffith, Jr.
D. J. Irish R. C. Mecredy J. W. Peters T. J. Powell B. A. Snow S. M. Spector G. R. Taylor R. E. Wood