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> COMSECY-04-0037 SRM
September 1, 2004
| MEMORANDUM TO: |
Luis A. Reyes
Executive Director for Operations |
| FROM: |
Annette L. Vietti-Cook, Secretary /RA/ |
| SUBJECT: |
STAFF REQUIREMENTS - COMSECY-04-0037 - FITNESS-FOR-DUTY ORDERS TO ADDRESS FATIGUE OF
NUCLEAR FACILITY SECURITY FORCE PERSONNEL |
The Commission has disapproved the issuance of orders concerning fitness-for-duty
enhancements to address fatigue concerns for security force personnel at (1) Independent
Spent Fuel Storage Installations, (2) Decommissioning Reactors, (3) Category I Fuel Cycle
Facilities, (4) Gaseous Diffusion Plants, and (5) the Natural Uranium Conversion Facility.
If the staff observes significant fatigue-related issues at these facilities or any other facilities,
the Commission should be informed promptly. Otherwise, the rulemaking process is the
appropriate method to address these potential future concerns for materials facilities because
the process allows for additional public interactions with our stakeholders. The staff should
therefore pursue rulemaking instead of Orders for those materials facilities for which the staff
believes fatigue-related requirements are necessary for appropriate personnel. This
rulemaking effort would be a separate Part 26 rulemaking from the rulemaking currently in
progress to address fatigue-related concerns at power reactors. Since this issue has already
had significant consideration, the staff should proceed to the proposed rule stage without the
need for a formal rulemaking plan. The staff should provide a progress report to the
Commission in April 2005.
| |
(EDO) |
(SECY Suspense: 4/22/05) |
| cc: |
Chairman Diaz
Commissioner McGaffigan
Commissioner Merrifield
OGC
CFO
OCA
OPA
PDR |
|
