ND-18-0961, Supplement to Request for License Amendment: Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018S2)
| ML18191B272 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/10/2018 |
| From: | Whitley B Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of New Reactors, Office of Nuclear Security and Incident Response |
| References | |
| LAR-18-018S2, ND-18-0961 | |
| Download: ML18191B272 (8) | |
Text
Brian H. Whitley Southern Nuclear Director, Regulatory Affairs Operating Company, Inc.
3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 July 10, 2018 Docket Nos.: 52-025 ND-18-0961 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 Supplement to Request for License Amendment:
Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018S2)
Ladies and Gentlemen:
In accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requested 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) by SNC letter ND-18-0754, dated June 15, 2018 [ADAMS Accession Number ML18166A347] and supplemented by SNC letter ND-18-0908, dated June 25, 2018 [ADAMS Accession Number ML18176A141], to 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 involves 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).
In a teleconference held on July 6, 2018, the NRC requested SNC to provide additional detail concerning the proposed changes to the licensing basis as provided in Enclosure 1 of ND-18-0754. The NRC also requested a reviewers aid depicting a recent non-LAR change to the VEGP 3 and 4 UFSAR.
Enclosures 1 and 2 were provided with the original LAR-18-018, SNC letter ND-18-0754. was provided with SNC letter ND-18-0908. provides the requested clarification to the proposed changes to the licensing basis and the requested reviewers aid.
The information provided in this License Amendment Request (LAR) supplement does not impact the scope, technical content, or conclusions of the Significant Hazards Consideration Determination or the Environmental Considerations of the original LAR-18-018 provided in Enclosures 1 and 2 of SNC letter ND-18-0754 or Enclosure 3 of SNC letter ND-18-0908.
This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.
U.S. Nuclear Regulatory Commission ND-18-0961 Page 2 of 4 In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia by transmitting a copy of this letter and its enclosure 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 1 01h of July 2018.
Respectfully submitted, Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company Enclosures 1 and 2)
Previously submitted with the original LAR, LAR-18-018
- 3)
Previously submitted with the supplement to the LAR, LAR-18-018S1
- 4)
Vogtle Electric Generating Plant (VEGP) Units 3 and 4-Supplement to Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018S2)
U.S. Nuclear Regulatory Commission ND-18-0961 Page 3 of 4 cc:
Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosure)
Mr. D. G. Bost (w/o enclosure)
Mr. M. D. Meier (w/o enclosure)
Mr. D. H. Jones (w/o enclosure)
Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosure)
Mr. T. W. Yelverton (w/o enclosure)
Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Mr. F. J. Redwanz Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosure)
Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. T.E. Chandler Ms. P. Braxton Mr. T. Brimfield Mr. C. J. Even Mr. A. Lerch State of Georgia Mr. R. Dunn Oglethorpe Power Corporation Mr. M. W. Price Mr. E. Rasmussen Ms. A. Whaley
U.S. Nuclear Regulatory Commission ND-18-0961 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosure)
Mr. G. Koucheravy (w/o enclosure)
Mr. M. Corletti Mr. M. L. Clyde Ms. L. Iller Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.
Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.
Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham Mr. R. Grumbir, APOG NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light
Southern Nuclear Operating Company ND-18-0961 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018S2)
Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Omitted text is identified by three asterisks ( * * * )
(This Enclosure consists of four pages, including this cover page)
ND-18-0961 Supplement to Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018S2)
Page 2 of 4 In a teleconference held on July 6, 2018, the NRC requested Southern Nuclear Operating Company (SNC) to provide additional clarification concerning proposed changes to the licensing basis. Specifically, the proposed revision to the Vogtle Electric Generating Plant (VEGP) 3 and 4 Updated Final Safety Analysis Report (UFSAR), Appendix 1A, entry for Regulatory Guide 5.84, which documents exceptions to NEI 06-06, Fitness for Duty Program Guidance for New Nuclear Power Plant Construction Sites, (April 2013) [ADAMS Accession Number ML13093A340], does not explicitly describe the proposed changes to NEI 06-06, Section 6.2.1. To address this observation, the markup provided on page 3 of 5 of Enclosure 2 is revised as described below:
Revise the line entry for Section 6.2.1, Pre-Assignment, as follows:
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:
Add the following sentence to the end of Section 6.2.1, Pre-Assignment:
An individual may be eligible for limited access to the construction site under the conditions specified in Section 9.3 [of NEI 06-06 Revision 6 (April 2013)].
ND-18-0961 Supplement to Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018S2)
Page 3 of 4 In addition, the NRC noted that the markup to UFSAR, Section 13.7, Fitness for Duty, depicted the current revision of UFSAR Section 13.7, which had been recently revised, and the NRC reviewer did not have a current copy of the UFSAR. The NRC requested that a mark-up of the current version of the UFSAR, depicting the recent change be provided. A marked-up copy of UFSAR Section 13.7 is provided below as a reviewers aid (changes shown in blue, underline font and red, strike-out font have been incorporated into the current version of the VEGP 3 and 4 UFSAR):
13.7 Fitness for Duty The construction FFD program is consistent with NEI 06-06 (Reference 201), as endorsed by NRC Regulatory Guide 5.84, Revision 0, 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. Prior to issuance of a Combined License, the construction FFD program at a new reactor construction site for those subject to Subpart K will be reviewed and revised as necessary should substantial revisions occur to either NEI 06-06 following NRC endorsement or the requirements of 10 CFR Part 26. The NRC endorsed NEI 06-06 (Reference 201) and the FFD program subject to Subpart K was revised to reflect the changes.
The following site-specific information is provided:
The construction site is defined in the Physical Security Plan, Appendix E and is under the control of SNC. The 10 CFR Part 26 requirements are implemented for the construction site area based on the descriptions provided in Table 13.4-201.
Construction Workers & First Line Supervisors are covered by the SNC FFD Program (elements Subpart K).
SNC employees and personnel contracted for construction management and oversight are covered by the SNC FFD Program (elements Subpart A - H, N and O).
Security personnel are covered by the SNC FFD Program (elements Subpart A - H, N and O). This coverage is applicable from the start of construction activities to the earlier of (1) the receipt of SNM in the form of fuel assemblies, (2) the establishment of a protected area, or (3) the 10 CFR 52.103(g) finding.
FFD Program personnel are covered by the SNC FFD Program (elements Subpart A, B, D -
H, N, O, and C per licensees discretion).
ND-18-0961 Supplement to Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR-18-018S2)
Page 4 of 4 Security personnel protecting fuel assemblies, or the established protected area, or the facility following the 10 CFR 52.103(g) finding are covered by the SNC FFD Program (elements Subpart A - I, N and O).
Personnel required to physically report to the Technical Support Center (TSC) or Emergency Operations Facility (EOF) when that requirement is in effect are covered by the SNC FFD.
The operations phase FFD program is consistent with the applicable subparts of 10 CFR Part 26 (elements Subpart A - I, N, and O, except for individuals listed in §26.4(b), who are not subject to §§26.205 - 209.
13.7.1 References 201.
Nuclear Energy Institute Fitness for Duty Program Guidance for New Nuclear Power Plant Construction Sites, Revision 6, April 2013 (ML13093A342) Revision 5, August 2009 (ML092430016).