ML18149A564
"Draft Meeting" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.
| ML18149A564 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/29/2018 |
| From: | NRC |
| To: | NRC/NRO/DNRL/LB4 |
| References | |
| Download: ML18149A564 (21) | |
Text
1 Vogtle PEmails From:
Hoellman, Jordan Sent:
Tuesday, May 29, 2018 2:44 PM To:
Vogtle PEmails
Subject:
Draft LAR 18-018, re: Fitness-for-Duty Commitment Change for Pre-Submittal Meeting on May 31, 2018 Attachments:
ND-18-0754_LAR-18-018_Changes to Constr FFD Commitments_Presubmittal Draft.pdf The attached draft Request for License Amendment: Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018), has been provided for NRC staff review in support of a requested pre-submittal meeting on Thursday, May 31, 2018.
This draft letter contains no proprietary or security-related information, and may be made available to the Public.
Hearing Identifier:
Vogtle_COL_Docs_Public Email Number:
286 Mail Envelope Properties (SN6PR09MB2608AA42E8794776A54AF4C2D56D0)
Subject:
Draft LAR 18-018, re: Fitness-for-Duty Commitment Change for Pre-Submittal Meeting on May 31, 2018 Sent Date:
5/29/2018 2:44:22 PM Received Date:
5/29/2018 2:44:28 PM From:
Hoellman, Jordan Created By:
Jordan.Hoellman2@nrc.gov Recipients:
"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>
Tracking Status: None Post Office:
SN6PR09MB2608.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 360 5/29/2018 2:44:28 PM ND-18-0754_LAR-18-018_Changes to Constr FFD Commitments_Presubmittal Draft.pdf 1123097 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
B. H. Whitley Southern Nuclear Director Operating Company, Inc.
Regulatory Affairs 42 Inverness Center Parkway Birmingham, AL 35242 Tel 205.992.7079 Fax 205.992.5296
[DATE]
Docket Nos.: 52-025 ND-18-0754 52-026 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for License Amendment:
Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018)
Ladies and Gentlemen:
In accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests an amendment to the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP)
Units 3 and 4 (License Numbers NPF-91 and NPF-92, respectively). The requested amendment would revise commitments related to the construction fitness-for-duty (FFD) program described in the VEGP 3 and 4 Updated Final Safety Analysis Report (UFSAR). The change would involve the creation of a new type of FFD Authorization (FFDA) that would allow construction workers temporary access to the construction site pending completion of all pre-access FFD requirements but prior to assignment to work on safety-or security-related structures, systems, and components (SSCs).
Specifically, SNC proposes to take an exception to its current commitment to Regulatory Guide (RG) 5.84, Fitness-for-Duty Programs at New Reactor Construction Sites [ADAMS Accession Number ML15083A412]. RG 5.84 endorses NEI 06-06, Fitness for Duty Program Guidance for New Nuclear Power Plant Construction Sites, (April 2013) [ADAMS Accession Number ML13093A340]. The proposed exception would modify NEI 06-06 guidance to allow for a temporary access authorization for construction workers under 10 CFR Part 26, Subpart K.
Changes to NEI 06-06 commitments would be identified in UFSAR Section 13.7, Fitness for Duty, and documented in UFSAR Appendix 1A, Conformance with Regulatory Guides. Because the proposed exceptions from NEI 06-06 are considered a reduction in commitment, the proposed changes require prior NRC approval. provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination) and environmental considerations for the proposed changes. identifies the requested changes and provides markups depicting the requested changes to the VEGP Units 3 and 4 licensing basis documents.
DRAFT ND-18-0 10 CFR 50.9 Operating Company ng Company erating Plant Units 3 and 4 Units 3 an r License Amendment:
ment:
ess-for-Duty (FFD) Commitments (LAR-ess-for-Duty (FFD) Commitme 1
AF 50.90, Southern Nuclear Operating Comp ern Nuclear Operating Com ined licenses (COLs) for Vogtle Electric OLs) for Vogtle Electric Numbers NPF-91 and NPF-92, respectively Numbers NPF-91 and NPF-92, ments related to the construction fitness-fo ments related to the constructio 4 Updated Final Safety Analysis Report (U 4 Updated Final Safety Analysis R a new type of FFD Authorization (FFDA) th a new type of FFD Authorization (FF cess to the construction site pending comple cess to the construction site pending comp to assignment to work on safety-or s assignment to work on safety-or s ents (SSCs).
SCs).
ecifically, SNC proposes to take an exceptio cifically, SNC proposes t RG) 5.84, RG) 5.84, Fitness-for-Duty Programs at N Fitness-for-Duty P Number ML15083A412]. RG 5.84 endor Number ML15083A412]. RG 5.8 New Nuclear Power Plant Construc New Nuclear Power Plant Cons ML13093A340]. The proposed ex The proposed ex temporary access authorization authorization Changes to NEI 06-Ch 06 06 commitm co and documented in UFSAR and documented in UFS proposed exceptions from proposed exceptions fro anges require prior N anges require prior N ure 1 provid ure 1 provid nt Haz nt Haz h
U.S. Nuclear Regulatory Commission ND-18-0754 Page 2 of 4 SNC also expects to seek a No Objection determination from the NRC Staff by submittal of a Preliminary Amendment Request (PAR) following this LAR submittal. The No Objection determination is necessary to gain efficiencies related to nonsafety-related and nonsecurity-related construction activities at the VEGP 3 and 4 site.
This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.
SNC requests NRC staff approval of the requested license amendment by XXXX XX, 2018, to support continued construction of non safety-and security-related SSCs. Delayed approval of this license amendment could result in a significant loss of efficiency related to construction activities involving safety-and security-related SSCs. SNC expects to implement this proposed amendment within 30 days of approval of the requested changes.
In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia by transmitting a copy of this letter and its enclosures to the designated State Official.
Should you have any questions, please contact Wesley A. Sparkman at (205) 992-5061.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the [Day] of
[Month Year].
Respectfully submitted, Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company Enclosures
- 1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
- 2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes to Licensing Basis Documents (LAR-18-018)
DRAFT No No nd nd non no viewed and determined viewed a FT FT ndment by ndment X
X XX, 2018
, 2
, to ted SSCs ted S
. Delayed approval of approv of efficiency related to construction of efficiency related to constructio C expects to implement this C expe proposed oposed changes.
chang the State of Georgia by transmitting a copy he State of Georgia by t tate Official.
fficial.
ntact Wesley A. Sparkman at (205) 992-506 Sparkma he foregoing is true and correct.
he foregoing is true and correct. Executed H. Whitley ector, Regulatory Affairs ctor, Regulatory Affairs Southern Nuclear Operating Company Southern Nuclear Operating C Enclosures
- 1) Vogtle Electric Vogtle Electric Amendment men Commitm omm
- 2) Vogtl
) Vogt to to
U.S. Nuclear Regulatory Commission ND-18-0754 Page 3 of 4 cc:
Admin: Use Distribution for non-SUNSI information.
DRAFT
Southern Nuclear Operating Company ND-18-0754 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018)
(This Enclosure consists of 11 pages, including this cover page) ing Plant (VEGP) Units 3 and 4 GP) Units st for License Amendment Regarding ense Amendment Regarding Construction Fitness-for-Duty (FFD) Co Fitness-for-Duty (FFD) Co (LAR-R-18 18-018 01 )
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 2 of 11 Table of Contents
- 1.
SUMMARY
DESCRIPTION
- 2.
DETAILED DESCRIPTION
- 3.
TECHNICAL EVALUATION
- 4.
REGULATORY EVALUATION 4.1.
Applicable Regulatory Requirements/Criteria 4.2.
Precedent 4.3.
Significant Hazards Consideration 4.4.
Conclusions
- 5.
ENVIRONMENTAL CONSIDERATIONS
- 6.
REFERENCES DRAFT eria eria ion ERATIONS RATIONS
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 3 of 11 In accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.
- 1.
SUMMARY
DESCRIPTION The proposed changes would revise the Combined Licenses (COLs) in regard to commitments described in the VEGP 3 and 4 Updated Final Safety Analysis Report (UFSAR) related to fitness-for-duty (FFD) requirements for construction workers defined in 10 CFR 26.4(f) who are subject to Part 26, Subpart K (Subpart K workers).
SNC proposes to take an exception to its current commitment to Regulatory Guide (RG) 5.84, Fitness-for-Duty Programs at New Reactor Construction Sites, Revision 0, [ADAMS Accession Number ML15083A412]. RG 5.84 endorses Nuclear Energy Institute (NEI) guidance NEI 06-06, Fitness for Duty Program Guidance for New Nuclear Power Plant Construction Sites, (April 2013)
[ADAMS Accession Number ML13093A340]. The exception would modify NEI 06-06 guidance to allow for temporary, pre-assignment1 access authorization for individuals defined in 10 CFR 26.4(f) who are subject to an FFD program that meets the requirements of 10 CFR Part 26, Subpart K. Exceptions to NEI 06-06 commitments noted in UFSAR, Section 13.7, Fitness for Duty would be documented in UFSAR, Appendix 1A, Conformance with Regulatory Guides.
- 2.
DETAILED DESCRIPTION As described in UFSAR Section 13.7, Fitness for Duty, the construction FFD program is consistent with NEI 06-06, Revision 6. NEI 06-06 establishes FFD program requirements for new plant construction sites that meet the requirements of 10 CFR Part 26. 10 CFR 26.4(f) requires that individuals who construct or direct the construction of safety-or security-related structures, systems, and components (SSCs) shall be subject to an FFD program that meets Subpart K of 10 CFR Part 26. 10 CFR 26.405 states that individuals identified in 10 CFR 26.4(f) shall be subject to drug and alcohol testing under the following conditions: Pre-assignment. Before assignment to construct or direct the construction of safety-or security-related SSCs.
NEI 06-06 provides guidance to meet the requirements of Part 26 for construction workers by establishing a fitness-for-duty authorization (FFDA) that is granted after the worker has completed all elements of the construction worker FFDA. These elements include signing a consent form, completing identity verification, passing a pre-assignment drug and alcohol test, and receiving training on FFD policies, sanctions, and FFD program expectations. Because results of the pre-assignment drug testing may take several days, construction workers are prevented from gaining FFDA, even when their work would be limited to non safety-or security-related SSCs (i.e., pre-assignment). As a result, SNC is requesting an amendment to change the FFD program 1 Pre-assignment means Before assignment to construct or direct the construction of safety-or security-related [structures, systems and components] SSCs.
DRAFT hereby r hereby for Vogtle Ele for Vo COLs) in regard to commitments COLs) in regard to commitm s Report (UFSAR) related to fitness-s Report (UFSAR) related to fitnes ned in 10 CFR 26.4(f) who are subject ned in 10 CFR 26.4(f) who are subject commitment to Regulatory Guide (RG) 5.8 ommitment to Regulato nstruction Sites on Sites, Revision 0, [ADAMS Acce Revision Nuclear Energy Institute (NEI) guidance NE rgy Institute w Nuclear Power Plant Construction Sites lant Con A340 A340].]. The exception would modify NEI 0 The exception would mo mentt1 access authorization for individuals d access authorization for individua FD program that meets the requirements gram that meets the requirements EI 06-06 commitments noted in UFSAR, S mmitments noted in UFSAR, d in UFSAR, Appendix 1A, endix 1A, Conformance wi Conformance wi ESCRIPTION ESCRIPTION FSAR Section 13.7, FSAR Section 13.7, Fitness for Duty r Duty, the co 06, Revision 6. NEI 06-06, Revision 6. NEI 06 06 establishes FF shes F n sites that meet the requirements of 10 C sites that meet the requirements of 10 C als who construct or direct the construct o construct or direct the construct ems, and components (SSCs) shall be subj ponents (S 0 CFR Part 26. 10 CFR 26.405 states th 0 CFR Part 26. 10 CFR 2 sub subject to drug and alcohol testing unde ject to drug and alcohol tes b
assignment to construct or direct the co assignment to construct or direct th NEI 06-06 provides guidance to m es guidance to m establishing a fitness-for-duty au establishing a fitness-for-all elements of the construct all elements of the const completing identity verific completing identity verif ining on FFD policie ining on FFD policie nment drug tes nment drug tes even wh even wh sig sig
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 4 of 11 requirements contained in NEI 06-06 to allow for a limited FFDA that would authorize access for construction workers pending results of drug testing but prior to being assigned to construct or direct the construction of safety-or security-related SSCs. All other NEI 06-06 FFDA elements would have been completed. Construction workers granted a limited FFDA would be administratively prevented from constructing or directing construction of safety or security-related SSCs.
UFSAR, Appendix 1A, provides an evaluation of the degree of compliance with Division 1 regulatory guides VEGP 3 and 4 site-specific design, construction and/or operational aspects.
UFSAR Subsection 1.9.1.3, Division 5 Regulatory Guides - Materials and Plant Protection, describes the applicability to Division 5 Regulatory Guides. UFSAR Appendix 1A, Conformance with Regulatory Guides, states that conformance with RG 5.84, which endorses NEI 06-06, Revision 6 (April 2013), is without exception. NEI 06-06 contains requirements for granting an FFDA for construction workers, which consist of four elements:
- 1. Signing a consent;
- 2. Verifying identity;
- 3. Successfully passing a pre-assignment drug and alcohol test; and
The requested amendment proposes to add an exception to the UFSAR, Appendix 1A, entry for RG 5.84 which would allow the granting of a temporary limited FFDA to allow workers to construct non safety-and security-related SSCs pending the determination of the results of the pre-assignment drug test. Other conforming changes to licensing documents are described in the table below (Detailed markups of proposed changes to licensing documents are presented in.):
Licensing Basis Change Descriptions:
Proposed Licensing Basis Changes Text, Table, or Figure Description of the Proposed Change UFSAR Subsection 1.9.1.3 The degree of compliance with Division 5 Regulatory Guides is revised to address an exception to RG 5.84 in the form of an exception to NEI 06-06 that provides an allowance for granting temporary limited FFDAs.
UFSAR Appendix 1A, Entry for RG 5.84 An entry for RG 5.84 is added to take exception to NEI 06-06 as follows:
A definition is added to Section 4 to define a Limited Fitness-for-Duty (FFD) Authorization DRAFT orize ac orize a ned to constru ned to 06-06-06 06 FFDA elemen F
limited FFDA would be limited FFDA n of safety or security-related n of safety or securit ree of compliance with Division 1 ree of compliance with Division nstruction and/or operational aspects.
nstruction and/or operational aspects.
Guides Guides - Materials and Plant Protection s and Plant Protection, Guides.
Guides. UFSAR Appendix 1A, Append Conformanc ce with RG 5.84, which endorses NEI 06 ith RG 5.84, which NEI 06-06 contains requirements for gran 6 contains req ist of four elements:
nts:
re-assignment drug and alcohol test; and nment drug and alcohol test; and FFD policy, sanctions and FFD program ex sanctions and FFD program e nt proposes to add an exception to the UFS t proposes to add an exception to the UFS allow the granting of a temporary limited FFD allow the granting of a temporar ecurity-related SSCs pending the determi ecurity-related SSCs pending th g test. Other conforming changes to licens g test. Other conforming changes to Detailed markups of proposed changes to Detailed markups of proposed changes 2.):):
censing Basis Change Descriptions:
ensing Basis Change Des DR Proposed Propo Text, Table, or Figu Table, or Figu UFSAR Subsection 1.9 secti SAR SAR
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 5 of 11 (FFDA) as an authorization granted for a limited period of time to potential 10 CFR 26.4(f) workers that have not completed all elements of FFDA for individuals subject to 10 CFR Part 26 Subpart K.
Workers granted a Limited FFDA shall be administratively prevented from constructing or directing construction of safety-or security-related structures, systems, and components (SSCs).
Section 6.2.1, Pre-Assignment, is clarified to allow an individual to have limited access to the construction site under the conditions specified in Section 9.3.
Section 8, Reviewing Official, the first paragraph is revised to clarify that FFDA determinations include limited FFDA.
Section 9.2, Types of FFDA, is revised to add a fourth type - Limited FFDA Section 9.3 is revised to add an introductory paragraph that reads:
A construction site entity may grant a limited FFDA for a period of up to one working week (i.e. 7 calendar days) upon successful completion and documentation of the elements specified in Section 9.1, as appropriate, except the requirement for documentation of a passed drug test.
UFSAR Section 13.7 UFSAR Section 13.7 is revised to refer to Appendix 1A for exceptions to NEI 06-06.
- 3.
TECHNICAL EVALUATION 10 CFR Part 26 establishes requirements, in part, for FFD programs for holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g), except that 10 CFR Part 26, Subpart K applies during the construction phase. 10 CFR 26.4(f) establishes the category of worker that is subject to the FFD program requirements of Subpart K. 10 CFR 26.4(f), in part, requires that any individual who is constructing or directing the construction of safety-or security-related SSCs shall be subject to an FFD program that meets the requirements of Subpart K. 10 CFR 26.405(c)(1) states that individuals identified in 10 CFR 26.4(f) shall be subject to drug and alcohol testing pre-assignment, i.e., Before assignment to DRAFT for a lim for a lim R 26.4(f) worke R 26.4(f) ments ments of o FFDA for R Part 26 Subpart K.
R Part 26 S d FFDA shall be d FFDA shall be ted from constructing ed from constructing or n of n of safety afe - or security rity-related rela ms, and components (SSCs).
ms, and components (SSCs).
,, Pre Pre-Assignment A
, is clarified to allow low al to have limited access to the al to have limited acc ction site under the conditions specified in tion site under the cond on 9.33.
Section 8, Reviewing Official iewing Off
, the first parag is revised to clarify that FFDA determina y that FF include limited FFDA.
include limited FFDA.
Section 9.2, Section 9.2, Types of FFDA Types of FFDA, is re
, is r fourth type fourth type - Limited FFDA Limited FF Section 9.3 is revised to Section 9.3 is revised to paragraph that reads:
aragraph A construction cons FFDA for a p DA fo (i.e. 7 cale 7 ca comple comple spec spec th UFSAR Section 13.7 AR Section 13.7 3.
- 3.
TECHNICAL EVALUA TECHNICAL EVA 0 CFR Part 26 establis 0 CFR Part 26 establi nse under 10 CF nse under 10 CF (g), except (g), except tablis tablis
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 6 of 11 construct or direct the construction of safety-or security-related SSCs. 10 CFR Part 26.401(b) requires that licensees who implement an FFD program under Subpart K submit a description of the FFD program and its implementation as part of the license application. The VEGP 3 and 4 FFD program description was submitted and approved as part of the combined license (COL) application and is described in UFSAR Section 13.7, Fitness for Duty. UFSAR Section 13.7 states that the construction FFD program is consistent with NEI 06-06, Revision 6 (April 2013), which is endorsed by Regulatory Guide 5.84, Revision 0.
NEI 06-06 provides regulatory guidance for establishing and implementing an FFD program for evaluating and maintaining the authorization of personnel for whom access to the construction site has been requested. This approach ensures consistent application of regulations and is intended to serve as the construction FFD program description for construction site entities.
Consistent with operational FFD programs, NEI 06-06 sets FFD requirements for site access authorization, which is conservative relative to 10 CFR Part 26 requirements for construction FFD programs. 10 CFR Part 26 requires construction workers to be subject to an FFD program before constructing or directing the construction of safety-or security-related SSCs.
While 10 CFR Part 26 FFD requirements for operating facilities require that FFD requirements be met before granting an individual covered under the requirements of Part 26 access to the facility, Subpart K FFD requirements must be met before constructing or directing construction of a safety-or security-related SSC. Thus, Subpart K FFD requirements are not required to be met before granting an individual access to the construction site. The proposed changes to the commitments related to NEI 06-06 would allow a construction worker access to the construction site for a period not to exceed one working week (i.e. 7 calendar days) pending results of the pre-assignment drug test. All other pre-assignment FFD requirements would be met before granting the temporary access authorization, e.g., inclusion in the pool of construction workers eligible for random drug and alcohol testing. Construction workers granted access to the site under a temporary access authorization would be administratively prevented from working on safety-or security-related SSCs by being issued a uniquely designated badge and uniquely identified personal protection equipment. Personnel granted a limited FFDA and their work supervision would be informed of their work limitations. Personnel granted a limited FFDA would be tracked using the site access application. Access authorization training programs would be revised to include methods of controlling temporary access authorization and limits on the types of work such construction workers may be allowed to perform.
The proposed changes are consistent with the Commissions intent when Subpart K was incorporated into Part 26. The Statements of Consideration for the Part 262 Rule that incorporated Subpart K into Part 26 state in part, Therefore, the Subpart K requirements provide a licensee or other entity listed in § 26.3(c) of the final rule greater flexibility in implementing FFD programs for construction than the rule permits for FFD programs at operating plants.
2 FR Vol. 73, No. 62/Monday, March 31, 2008 Page 16996 DRAFT R Part 26 R Part bmit a descriptio bmit a d
- n. The VEGP 3 and
- n. The combined license (COL) combined lic UFSAR Section 13.7 states UFSAR Section 1 Revision 6 (April 2013), which is Revision 6 (April 2013), w and implementing an FFD program for and implementing an FFD program for nnel for whom access to the construction nnel for whom access to the construction consistent application of regulations and consistent application o gram description for construction site ent description for con NEI 06-06 sets FFD requirements for site sets FFD req e to 10 CFR Part 26 requirements for constru 26 requi struction workers to be subject to an FFD pr struction workers to be subject ction of safety-or security-related SSCs.
on of safety-or security-related SSC rements for operating facilities require that F for operating facilities require that F ual covered under the requirements of Part under the requirements of Pa ts must be met before constructing or directi efore constructing or directi
. Thus, Subpart K FFD requirements are
. Thus, Subpart K FFD requir l access to the construction site. The propo l access to the construction site 06 would allow a construction worker acces 06 would allow a construction worke one working week (i.e. 7 calendar days) pen one working week (i.e. 7 calendar days) her pre-assignment FFD requirements wou er pre-assignment FFD requirements wou authorization, e.g., inclusion in the pool of c zation, e.g., inclusion in the pool of c lcohol testing. Construction workers grante
- g. Construction workers grante thorization would be administratively preve horization would be adm SSCs by being issued a uniquely designat SSCs by being issued a unique equipment. Personnel granted a limited equipment. Personnel granted a l their work limitations. Personnel gra their work limitations. Personnel gra application. Access authorizatio ss authorizatio controlling temporary access controlling temporary ac workers may be allowed to p workers may be allowed he proposed change he proposed change porated into Par porated into Par K into Pa K into Pa y list y list
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 7 of 11 Thus, revising commitments related to construction worker FFD requirements continue to meet Subpart K requirements.
The proposed changes do not affect the radiological source terms (i.e., amounts and types of radioactive materials released, their release rates and release durations) used in the accident analyses. The proposed changes do not affect safety-related equipment or a fission product barrier. No system or design function or equipment qualification is adversely affected by the proposed changes. The changes do not result in a new failure mode, malfunction or sequence of events that could adversely affect a radioactive material barrier or safety-related equipment.
The proposed changes do not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures.
No SSCs are affected by this license amendment request, thus no SSCs which are used to contain, control, channel, monitor, process or release radioactive and non-radioactive materials are affected. The types and quantities of expected effluents are not changed, and no effluent release path is adversely affected by the proposed changes. Therefore, neither radioactive nor non-radioactive material effluents are affected by the proposed changes.
Plant radiation zones (as described in UFSAR Section 12.3), controls under 10 CFR Part 20, and expected amounts and types of radioactive materials are not affected by the proposed changes.
Therefore, individual and cumulative radiation exposures do not change.
The change activity has no adverse impact on the emergency plan or the physical security plan implementation, because there are no changes to physical access to credited equipment inside the Nuclear Island (including containment or the auxiliary building) there is no adverse impact to plant personnels ability to respond to any plant operations or security event.
Summary The proposed changes to SNCs commitment to NEI 06-06 guidance which would allow temporary access to the construction site for construction workers pending the results of FFD pre-assignment requirements continue to meet the requirements of 10 CFR Part 26. The above proposed changes would not adversely affect any safety-related or security-related equipment or function, design function, radioactive material barrier or safety analysis.
DRAFT continue continu
, amounts and types o amounts ions) used in the accident ions) used in th quipment or a fission product uipment or a fission ion is adversely affected by the ion is adversely affected by ure mode, malfunction or sequence ure mode, malfunction or sequenc al barrier or safety-related equipment.
al barrier or safety-related equipment.
roduct release path, result in a new fission roduct release path, result in a new fission ence of events that would result in significan nce of events that would ndment request, thus no SSCs which are est, thus no ss or release radioactive and non-radioactiv ss or release radioactive an s of expected effluents are not changed, a s of expected effluents are not c by the proposed changes. Therefore, neith he proposed changes. Therefore, n s are affected by the proposed changes.
ected by the proposed changes.
scribed in UFSAR Section 12.3), controls un AR Section 12.3), controls u pes of radioactive materials are not affecte pes of radioactive materials are not affecte nd cumulative radiation exposures do not c nd cumulative radiation exposu ty has no adverse impact on the emergenc ty has no adverse impact on the e
, because there are no changes to physica
, because there are no changes to ph Island (including containment or the auxilia sland (including containment or the auxilia sonnels ability to respond to any plant oper els ability to respond to any plant oper mary D
The proposed changes to The proposed changes to SNCs commi S
temporary access to the construction site temporary access to the construct assignment requirements continue to assignment requirements continue proposed changes would not adver s would not adver function, design function, radioa function, design function
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 8 of 11
- 4.
REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR Part 26, Fitness for Duty Programs, establishes requirements, for FFD programs, in part, for holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g), except for 10 CFR Part 26, Subpart K, which applies during the construction phase. 10 CFR 26.4(f) establishes the category of worker that is subject to the FFD program requirements of Subpart K. 10 CFR 26.4(f), in part, requires that any individual who is constructing or directing the construction of safety-or security-related SSCs shall be subject to an FFD program that meets the requirements of Subpart K. Because the proposed changes to SNCs commitment to NEI 06-06 guidance continue to ensure construction workers who construct or direct the construction of safety-or security-related SSCs are subject to an FFD program, the requirements of 10 CFR Part 26, Subpart K, are met.
4.2 Precedent No precedent is identified.
4.3 Significant Hazards Consideration The proposed changes would revise the Vogtle Electric Generating Plant (VEGP) 3 and 4 Updated Final Safety Analysis Report (UFSAR) commitment related to the construction worker Fitness-for-Duty (FFD) program to include a limited FFD Authorization (FFDA) to allow workers to construct nonsafety-and non-security-related SSCs pending the determination of the results of the pre-assignment drug test. There is no physical change to the plant itself.
An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:
4.3.1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response
No.
The proposed changes to the Vogtle Electric Generating Plant (VEGP) 3 and 4 Updated Final Safety Analysis Report (UFSAR) commitment related to the construction worker Fitness-for-Duty (FFD) program do not affect the design of a system, structure, or component (SSC) used to meet the design bases of the nuclear plant. Nor do the changes affect the construction or operation of the nuclear plant itself, so there is no change to the probability or consequences of an accident previously evaluated. Changing the VEGP 3 and 4 FFD program DRAFT ements, for FFD programs ements, for FFD 52 after the Commission has 52 after the Commis CFR Part 26, Subpart K, which CFR Part 26, Subpart K, w
) establishes the category of worker
) establishes the category of work of Subpart K. 10 CFR 26.4(f), in part, of Subpart K. 10 CFR 26.4(f), in part, or directing the construction of safety-or or directing the construction of safety-or FFD program that meets the requirements o FFD program that meets es to SNCs commitment SNCs commitment to NEI 06-06 guida s who construct or direct the construction of struct or direct t ct to an FFD program rogram, the requirements o t
ed.
Hazards Consideration deration changes would revise the Vogtle Electric Ge changes would revise the Vogt nal Safety Analysis Report (UFSAR) comm nal Safety Analysis Report (UFS itness-for-Duty (FFD) program to include a itness-for-Duty (FFD) program to inc workers to construct nonsafety-and n workers to construct nonsafety-and termination of the results of the pre-mination of the results of the pre-as assignm signm to the plant itself.
ant itself.
An evaluation to determine whether or An evaluation to dete with the proposed amendment was c with the proposed amen in 10 CCFR FR 50.92, 50 Issuance of am ssuance 4.3.1 Does the propo Does the propo probability or proba
Response
onse D
The prop he pro Upda Upda co co
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 9 of 11 commitments do not affect prevention and mitigation of abnormal events (e.g.,
accidents, anticipated operational occurrences, earthquakes, floods, or turbine missiles) or their safety or design analyses. No safety-related SSC or function is adversely affected. The changes neither involve nor interface with any SSC accident initiator or initiating sequence of events, so the probabilities of the accidents evaluated in the UFSAR are not affected. Because the changes do not involve any safety-related SSC or function used to mitigate an accident, the consequences of the accidents evaluated in the UFSAR are not affected.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
4.3.2 Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response
No.
The proposed changes to the VEGP 3 and 4 UFSAR commitment related to the construction worker FFD program do not affect the operation of any systems or equipment that may initiate a new or different kind of accident or alter any SSC such that a new accident initiator or initiating sequence of events is created. The changes do not affect the design of an SSC used to meet the design bases of the nuclear plant. Nor do the changes affect the construction or operation of the nuclear plant. Consequently, there is no new or different kind of accident from any accident previously evaluated. The changes do not affect safety-related equipment, nor do they affect equipment that, if it failed, could initiate an accident or a failure of a fission product barrier. In addition, the changes do not result in a new failure mode, malfunction, or sequence of events that could affect safety or safety-related equipment.
No analysis is adversely affected. No system or design function or equipment qualification is adversely affected by the changes. This activity will not allow for a new fission product release path, nor will it result in a new fission product barrier failure mode, nor create a new sequence of events that would result in significant fuel cladding failures.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?
Response
No.
DRAFT mal even mal eve
, floods, or tu
, floods ted SSC or function ted SS interface with any SSC interface wit so the probabilities of the so the probabilitie
- d. Because the changes do not
- d. Because the changes sed to mitigate an accident, the sed to mitigate an accident, the UFSAR are not affected.
the UF es not involve a significant increase in the es not involve a significant increase in the cident previously evaluated.
cident previously evalua endment create the possibility of a new o the pos m any accident previously evaluated?
m any accident previously ev changes to the VEGP 3 and 4 UFSAR com the VEGP 3 and 4 UFSAR com worker FFD program ogram doo not affect the op not affect the op nt that may initiate a new or different kind o t that may initiate a new or dif hat a new accident initiator or initiating sequ hat a new accident initiator or in nges do not affect the design of an SSC us nges do not affect the design of a nuclear plant. Nor do the changes affect nuclear plant. Nor do the changes a nuclear plant. Consequently, there is no nuclear plant. Consequently, there is no accident previously evaluated. Th accident previously evaluated. Th equipment, nor do they affect equip quipment, nor do they affect equi or a failure of a fission product b failure of new failure mode, malfunctio new failure mod safety-related equipment.
safety-related equip No analysis is advers o analysis is adver qualification is adv ficatio new fission pro issio failure mode re mo fuel cladd el clad There There dif dif
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 10 of 11 The proposed changes to the VEGP 3 and 4 UFSAR commitment related to the construction worker FFD program do not alter any safety-related equipment, applicable design codes, code compliance, design function, or safety analysis.
Consequently, no safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the proposed change, thus the margin of safety is not reduced.
Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.
Based on the above, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Pursuant to 10 CFR 50.92, the requested change does not involve a Significant Hazards Consideration.
- 5.
ENVIRONMENTAL CONSIDERATIONS The proposed changes would revise the Vogtle Electric Generating Plant (VEGP) 3 and 4 Updated Final Safety Analysis Report (UFSAR) commitment related to the construction worker Fitness-for-Duty (FFD) program to allow workers to construct nonsafety-and non-security-related SSCs pending the determination of the results of the pre-assignment drug test. There is no physical change to the plant itself.
This review has determined the proposed change requires an amendment to the COL. However, a review of the anticipated construction and operational effects of the requested amendment has determined the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:
(i)
There is no significant hazards consideration.
As documented in Section 4.3, Significant Hazards Consideration, of this license amendment request, an evaluation was completed to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment. The Significant Hazards Consideration determined that (1) the requested amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) the requested DRAFT nt relate nt relat related equipm related on, or safety analysi on, or s ceptance limit/criterion is ceptance limi us the margin of safety is not us the margin of saf t involve a significant reduction in a t involve a significant reduction in proposed amendment does not involve a proposed amendment does not involve a e standards set forth in 10 CFR 50.92(c), an standards set forth in 10 azards consideration is justified.
consideration is considerations discussed above, (1) there onsiderations discussed above, (
and safety of the public will not be endange afety of the public will not be endang (2) such activities will be conducted in activities will be conducted in tions, and (3) the issuance of the amendme the issuance of the amendm nse and security or to the health and safety se and security or to the health and safety the requested change does not inv the requested change do
- n.
- n.
NMENTAL CONSIDERATIONS NMENTAL CONSIDE osed changes would revise the Vogtle El ed changes would revise the Vogtle El d Final Safety Analysis Report (UFSAR) co Safety Analysis Report (UFSAR) co ess-for-Duty (FFD) program to allow workers FD) progra SCs pending the determination of the resu SCs pending the determina physical change to the plant itself.
physical change to the plant itsel This review has determined the propo This review has determined the prop a review of the anticipated constru icipated constru determined the requested ame determined the requeste forth in forth 10 CFR 51.22(c)(9),
2(c)(
i)
There is no signi i)
There is no sign As documen As documen amendme amendme ific ific
ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)
Commitments (LAR-18-018)
Page 11 of 11 amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) the requested amendment does not involve a significant reduction in a margin of safety. Therefore, it is concluded that the requested amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.
(ii)
There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
The proposed change to the VEGP 3 and 4 UFSAR commitments related to the construction worker FFD program is unrelated to any aspect of plant construction or operation that would introduce any change to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, and other effluents), or affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed change does not affect any effluent release path or diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. Therefore, it is concluded that the requested amendment does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.
(iii)
There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed change to the VEGP 3 and 4 UFSAR commitments related to the construction worker FFD program would not affect plant radiation zones (addressed in UFSAR Section 12.3) or controls under 10 CFR Part 20 that preclude a significant increase in occupational radiation exposure. Therefore, the requested amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.
Based on the above review of the requested amendment, it has been determined that anticipated construction and operational effects of the requested amendment do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed exemption is not required.
- 6. REFERENCES None.
DRAFT ccident fr ccident does not invol does n ded that the requeste ded that n under the standards set n under the st of no significant hazards of no significant ant increase in the amounts of any ant increase in the amounts of any d 4 UFSAR commitments related to the d 4 UFSAR commitments related to the elated to any aspect of plant construction ted to any aspect of ange to effluent types (e.g., effluents conta effluent types (e m effluents, and other effluents), or affect a and other ef fluent release quantities. Furthermore, th fluent release quantities.
uent release path or diminish the functionality ent release path or diminish the fu are credited with controlling the release o credited with controlling the releas e, it is concluded that the requested amendm oncluded that the requested amendm n the types or a significant increase in the a r a significant increase in the ed offsite.
nificant increase in individual or cumulative nificant increase in individual o oposed change to the VEGP 3 and 4 U oposed change to the VEGP 3 and truction worker FFD program would not af ruction worker FFD program would not a FSAR Section 12.3) or controls under 1 R Section 12.3) or controls under 1 increase in occupational radiation exposu n occupational radiation exposu not involve a significant increase in not involve a signif exposure.
exposure.
Based on the above review of the reque Based on the above review of the re construction and operational effects operational effects hazards consideration, (ii) a signi on, (i of any effluents that may be of any effluents that ma cumulative occupational ra cumulative occupational ligibility criteria for cate ligibility criteria for cate CFR 51.22(b), an CFR 51.22(b), an ed exempti ed exempti EN EN
Southern Nuclear Operating Company ND-18-0754 Vogtle Electric Generating Plant Units 3 and 4 Proposed Changes to Licensing Basis Documents (LAR-18-018)
Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Omitted text is identified by three asterisks ( * * * )
(This Enclosure consists of five pages, including this cover page.)
DRAFT erating Plant Units 3 and 4 t Units 3 an d Changes to Licensing Basis Document to Licensing Basis Document (LAR-AR-18 1 -018 018)
)
serti serti
ND-18-0754 Proposed Changes to Licensing Basis Documents (LAR-18-018)
Page 2 of 5 UFSAR Subsection 1.9.1.3 is revised to reflect that UFSAR Section 13.7 states that the construction FFD program is consistent with NEI 06-06, Revision 6 (April 2013) with exceptions.
1.9.1.3 Division 5 Regulatory Guides-Materials and Plant Protection Appendix 1A also provides an evaluation of the degree of conformance with the Division 5 regulatory guide (5.84) related to construction fitness-for-duty (FFD) programs. The VEGP 3 and 4 construction FFD program is described in UFSAR, Section 13.7. UFSAR Section 13.7 states that the FFD program is consistent with endorsed NEI 06-06, Revision 6 (April 2013) with exceptions.
DRAFT ates ates T
April 2013 April 20 T
rotection rotection nformance with the Division 5 nformance with the Division 5 uty (FFD) programs. The VEGP 3 uty (FFD) programs. The VEGP 3 R, Section 13.7. UFSAR Section 13.7 R, Section 13.7. UFSAR Section 13.7 rsed NEI 06-06, Revision 6 (April 2013) rsed NEI 06-06, Revisio with T
ND-18-0754 Proposed Changes to Licensing Basis Documents (LAR-18-018)
Page 3 of 5 UFSAR Appendix 1A entry for Regulatory Guide (RG) 5.84 is revised to reflect the exceptions taken to NEI 06-06, Revision 6 (April 2013).
Note: This markup reflects current UFSAR text that was incorporated by a non-LAR departure that was evaluated per 10 CFR Part 52, Appendix D, Section VIII.B.5 criteria and determined to not require prior NRC approval Reg. Guide 5.84, Rev. 0, 7/15 - Fitness-for-Duty Programs at New Reactor Construction Sites Conformance with programmatic and/or operational aspects is documented below.
General 10 CFR Part 26 NEI 06-06 Rev. 6 (April 2013)
Conforms Exception Exceptions to guidance provided in NEI 06-06 Rev. 6 (April 2013) are as described below:
A definition is added to define a limited FFD authorization as follows:
Limited Fitness-for-Duty (FFD)
Authorization (FFDA) - An authorization granted for a limited period of time to potential 10 CFR 26.4(f) workers that have not completed all elements for FFDA for individuals subject to 10 CFR Part 26 Subpart K. Workers granted a Limited FFDA shall be administratively prevented from constructing safety-or security-related structures, systems, and components (SSCs).
Section 6.2.1, Pre-Assignment, is clarified to allow an individual to have limited access to the construction site under the conditions specified in Section 9.3 DRAFT o re o re T
rated by a non-rated by T
ix D,Section VIII.B.
ix D, Se T
t New Reactor Construction t New Reactor Constructi ects is documented below.
ects is d tion A
Exceptions to guidance provided in Exceptions to guida FT NEI 06 NEI 0 -06 Rev. 6 (April 2013)
Rev. 6 are a AFT de described below:
scribed belo AF A definition is added to finition define AF FFD authorization as follow thorizat AF Limited Fitness ness-for for-Dut AF Authorization (FFDA Authorization (FFDA AF authorization gran authorization gran A
period of time period of time t A
26.4(f) worke 26 4(f) worke A
completed A
individu A
Subp A
FF A
ND-18-0754 Proposed Changes to Licensing Basis Documents (LAR-18-018)
Page 4 of 5 Section 8. Reviewing Official, the first sentence of the first paragraph is revised to read:
The construction site entity or as applicable, approved C/V, is required to designate in writing one or more individuals as a reviewing official to make FFDA (including Limited FFDA) determinations relative to a potential construction site workforce members trustworthiness and reliability and fitness for duty.
Section 9.2, Types of FFDA, is revised to add a fourth type - Limited FFDA Section 9.3, Granting FFDA and FFDA Elements, is revised to add an introductory paragraph that reads:
A construction site entity may grant a limited FFDA for a period of up to one working week (i.e. 7 calendar days) upon successful completion and documentation of the elements specified within Section 9.1, as appropriate, except the requirement for documentation of a passed drug test.
raph aph T
e entity or as e entity T
ved C/V, is required ved C/V, T
writing one or more writing one o T
s a reviewing official to s a reviewing offici T
A (including Limited FFDA)
(including Limited FF FT nations relative to a potential nations relative to a potential FT tru truction site workforce members ction site workforce members FT ustworthiness and reliability and ustworth FT fitness for duty.
fitness FT Section 9.2, Se Types of FFDA Types o
, is revised FT to add a fourth type to add a fourth typ
- Limited FFDA AFT Section 9.3, ection 9.3, Granting FFDA and G
AF Elements ments, is revised to add an
, is AF introductory paragraph ctory pa that AF A construction site entit tion site AF limited FFDA for a pe limited FFDA for a p AF working week working wee (i.e.
e A
upon successfu upon successfu A
documentatio documentatio A
specified w A
appropr A
docu A
ND-18-0754 Proposed Changes to Licensing Basis Documents (LAR-18-018)
Page 5 of 5 The second paragraph UFSAR Section 13.7 is revised to clarify that the construction FFD program is consistent with NEI 06-06 Revision 6 (April 2013) with exceptions.
The construction FFD program is consistent with NEI 06-06 (Reference 201) as endorsed by NRC Regulatory Guide 5.84, Revision 0, as amended by the exceptions documented in Appendix 1A, and the pre-access provisions for reinstatement described in 10 CFR 26.65.
NEI 06-06 applies to persons constructing or directing the construction of safety-and security-related structures, systems, or components performed onsite where the new reactor will be installed and operated. Management and oversight personnel, as further described in NEI 06-06, and security personnel prior to the receipt of special nuclear material in the form of fuel assemblies (with certain exceptions) will be subject to the operations FFD program that meets the requirements of 10 CFR Part 26, Subparts A through H, N, and O. At the establishment of a protected area, all persons who are granted unescorted access will meet the requirements of an operations FFD program.
DRAFTT
- 01) as endorsed by
- 01) as e s documented in s documente T
bed in 10 CFR 26.65.
bed in 10 CFR 26 ction of safety-and security-on of safety-and sec here the new reactor will be here the new reactor will be l, as further described in l, as fur ecial nuclear material in the form of ecial nuclear material in the form of to the operations FFD program that to the o A through H, N, and O. At the A through H, N, and O are granted unescorted access will meet th re granted unescorted