ML18332A443

11/1/2018 Summary of Public Meeting with Southern Nuclear Operating Company to Discuss Issues Associated with Safety Review of Licensing Actions for Snc'S Vogtle Electric Generating Plant (VEGP) Units 3 and 4

ML18332A443
Person / Time
Site:	Vogtle
Issue date:	12/04/2018
From:	Jordan Hoellman NRC/NRO/DLSE/LB4
To:	Jennifer Dixon-Herrity NRC/NRO/DLSE/LB4
HOELLMAN J/415-5481
References
Download: ML18332A443 (10)

Text

December 4, 2018 MEMORANDUM TO: Jennifer L. Dixon-Herrity, Chief Licensing Branch 4 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors FROM: Jordan Hoellman, Project Manager /RA/

Licensing Branch 4 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors

SUMMARY

OF A PUBLIC MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY ON NOVEMBER 1, 2018 The U.S. Nuclear Regulatory Commission (NRC) staff held a Category 1 public meeting with Southern Nuclear Operating Company (SNC) on November 1, 2018. The purpose of the meeting was to discuss issues associated with the safety review of licensing actions for SNCs Vogtle Electric Generating Plant (VEGP) Units 3 and 4.

The meeting notice can be found in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML18263A189. The meeting notice is also posted on the NRC public website. Enclosures 1 and 2 are the meeting agenda and attendance list for the meeting, respectively. The other documents referenced during the discussion can be found at the ADAMS Accession Nos. given below:

• SNCs Intent to Submit an Exemption Request from Title 10 of the Code of Federal Regulations (10 CFR), - ML18295A591 Part 26, Fitness-for-Duty Programs, paragraph 26.4(f)

• Draft Request for Exemption regarding Part 26 Visitor Access Requirements - ML18298A056

• Pre-Submittal Presentation for Request for Exemption Regarding Part 26 Visitor Access Requirements - ML18298A058 CONTACT: Jordan Hoellman, NRO/DLSE (301) 415-5481

Summary of Meeting:

On November 1, 2018, staff from the NRC conducted a public meeting with representatives from SNC to discuss issues associated with the safety review of licensing actions for SNCs VEGP Units 3 and 4. Specifically, the meeting discussed SNCs draft request for exemption from 10 CFR 26.4(f), which requires individuals who construct or direct the construction of safety- or security-related structures, systems, and components (SSCs) to be subject to a fitness-for-duty (FFD) program that meets 10 CFR Part 26, Subpart K, FFD Program for Construction, requirements.

SNC walked through the pre-submittal presentation, noting that 10 CFR Part 26 requires application of 10 CFR Part 26, Subpart K, during the construction phase, which provides no provisions for escorting visitors, while 10 CFR 73.55, Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage, allows escorted visitor access at operating plants. There was a free exchange of information in order for the staff to better understand SNCs draft exemption. Safeguards Information (SGI) was not discussed. Staff from the NRCs Office of Nuclear Security and Incident Response (NSIR) discussed and noted the following topics with representatives from SNC. No commitments were made by either SNC or NSIR staff during this meeting.

1. The staff noted that SNCs draft request paralleled the escorting requirements in 10 CFR 73.56(g). Based on a preliminary technical review, it appeared that SNC made reference to Regulatory Guide (RG) 5.76, Physical Protection at Nuclear Power Plants (SGI). The staff and SNC discussed generalities associated with:

a. Procedure for processing, escorting and controlling visitors

b. Confirming true identify

c. Maintaining a visitor control register

d. Badging for visitor and escorts. Clearly identifying as a visitor and escort required

e. Escorting responsibilities: continuous visual observation; visitors under effective control of the escort; escorts understanding the SSCs being constructed; escorts empowered to stop work; escorts provided with timely and effective means to report issues to Security; escorts effectively trained/briefed/informed of SSC(s) being worked, responsibilities, behavioral observation training (NANTL), etc.

2. The staff noted that the justification for the specified limited period of time for allowing visitor access under control of an escort (14 days or less in a 30-day period) was not provided in the draft request. The staff and SNC discussed consideration of (1) operating reactor experience and RG 5.76 and (2) long-term intermittent visitors -

beyond 30 days for activities such as non-destructive examination, welding, recurrent visits over a long period of time (activities that could be performed by a single contractor over a long period of time).

3. The staff noted that provisions to escort vehicles was not provided in the draft request.

The staff and SNC discussed consideration of construction vehicles under escort - e.g.,

truck-mounted cranes, lifts, and diggers.

4. The staff and SNC discussed the use of 10 CFR 52.103(g) as a milestone instead of the transition of the SNC construction FFD/access program to a full FFD/access program -

e.g., based on a licensee-determination/designation of the Protected Area or the 10 CFR 52.103(g) finding.

5. The staff discussed that the construction site work force is different from an operating unit work force, and FFD data indicates differences. SNC noted that they continue to implement a defense-in-depth program with oversight, work controls, training, etc.

6. The staff and SNC discussed denial of access, if denied in the Personnel Access Data System (PADS), and how SNC reviews Entergy and NextEra PADS-like information.

SNC noted that they are leveraging the 10 CFR 73.56 access authorization process with 10 CFR 73.57 considerations and that construction databases (VEGP Units 3 and 4) are separate from, but will be merged with, operating databases (VEGP Units 1 and 2).

7. The staff and SNC discussed consideration of visitors/escorts performing security-related construction activities. SNC noted that they determine when an SSC or information becomes SGI or requires a Need-to-Know. This determination is dependent, in part, on the Protected Area designation.

8. The staff and SNC discussed Security Interface to understand guidance, instruction, training, etc. provided to Security personnel to inform them of new escort program.

9. The staff noted that the estimated size of the escort service was not provided in the draft request. SNC noted that the size of escort service is management controlled and noted that construction activities are similar to, but not equivalent to operating reactor outage activities.

10. The staff noted that the escort-to-visitor ratio was not provided in the draft request. The staff and SNC discussed a performance-based ratio based on the work being performed and the effectiveness of escort to perform escort duties and responsibilities. SNC noted that the power reactor (RG 5.76) ratio is not entirely applicable to construction-type activities.

11. The staff and SNC discussed Occupational Safety and Health Administration (OSHA)-

based protections, and SNC noted that the escort program will have considerations for workers performing confined or hazardous space activities.

12. The staff and SNC discussed routine trending and monitoring of performance (i.e.,

corrective actions).

SNC noted that they understood the staffs comments and questions and stated that they would revise the exemption request, as necessary, to address the comments and questions. The NSIR staff stated that they would be open to addition discussions if requested by SNC and noted that they would perform its detailed review once the exemption request is formally submitted.

At the end of the meeting, there was an opportunity for the public to provide comments and ask questions. There were no comments or questions from members of the public.

Docket Nos.: 052-025 and 052-026

Enclosure:

As stated cc w/encls: See next page

ML18332A443 *via e-mail NRC-001 OFFICE PM: DLSE/LB4 LA: DLSE/LB4 PM: NSIR/ BC: DLSE/LB4 PM: DLSE/LB4 DPCP/FCTSB NAME JHoellman (c) RButler (c) PHarris (c) JDixon-Herrity (c) JHoellman (s)

DATE 12/3/18 11/29/18 12/3/18 12/4/18 12/4/18 AGENDA FOR PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION (NRC)

Thursday, November 1, 2018 9:00 a.m. - 10:00 a.m.

PURPOSE: To discuss issues associated with the safety review of licensing actions for Southern Nuclear Operating Companys (SNC) Vogtle Electric Generating Plant (VEGP) Units 3 and 4.

OPEN Time Topic Led By 9:00 a.m. Opening Remarks NRC 9:05 a.m. Discussion of draft Request for NRC/SNC Exemption regarding Part 26 Visitor Access Requirements 10:00 a.m. Opportunity for Public Comment PUBLIC/NRC 10:00 a.m. Adjourn Enclosure 1

PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION Thursday, November 1, 2018 9:00 a.m. - 10:00 a.m.

List of Attendees Name Organization Representing the Nuclear Regulatory Commission Jordan Hoellman NRO/DLSE/LB4 Chandu Patel NRO/DLSE/LB4 Paul Harris NSIR/DPCP/FCTSB Brian Zaleski NSIR/DPCP/FCTSB Niry Simonian NSIR/DPCP/FCTSB Randy Patterson

• RII/DRS/PSB Representing Industry Corey Thomas Southern Nuclear Operating Company (SNC)

Chuck Pierce

• SNC Amy Aughtman

• SNC Wes Sparkman

• SNC Neil Haggerty SNC Kelli Roberts

• SNC Amanda Pugh

• SNC Lindsey Grissom

• SNC Stephanie Agee

• SNC Lee Doby

• SNC Representing Public N/A

• = participated via teleconference Enclosure 2

Vogtle Units 3 & 4 Mailing List (Revised 08/16/2018) cc:

Office of the Attorney General Resident Inspector 40 Capitol Square, SW Vogtle Plant Units 3 & 4 Atlanta, GA 30334 8805 River Road Waynesboro, GA 30830 Resident Manager Oglethorpe Power Corporation Mr. Barty Simonton Alvin W. Vogtle Nuclear Plant Team Leader 7821 River Road Environmental Radiation Program Waynesboro, GA 30830 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company, Inc. 4244 International Parkway, Suite 120 Document Control Coordinator Bin N-226-EC Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 George B. Taylor, Jr.

2100 East Exchange Pl Anne F. Appleby Atlanta, GA 30084-5336 Olgethorpe Power Corporation 2100 East Exchange Place Brian H. Whitley Tucker, GA 30084 3535 Colonnade Parkway, Bin N-226-EC 42 Inverness Center Parkway, BIN B237 County Commissioner Birmingham, AL 35243 Office of the County Commissioner Burke County Commission Mr. Michael Yox Waynesboro, GA 30830 Site Regulatory Affairs Director Vogtle Units 3 & 4 Mr. Wayne Guilfoyle 7825 River Road, Bin 63031 Commissioner District 8 Waynesboro, GA 30830 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334 Page 1 of 3

Vogtle Units 3 & 4 Mailing List Email acchambe@southernco.com (Amy Chamberlian) agaughtm@southernco.com (Amy Aughtman)

ALPUGH@southernco.com (Amanda Pugh) awc@nei.org (Anne W. Cottingham) becky@georgiawand.org (Becky Rafter) bhwhitley@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) bjadams@southernco.com (Brad Adams) bwwaites@southernco.com (Brandon Waites) castelca@westinghouse.com (Curtis Castell) comerj@westinghouse.com (James Comer) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dgbost@southernco.com (Danny Bost) dlfulton@southernco.com (Dale Fulton) drculver@southernco.com (Randy Culver) durhamdc@westinghouse.com (David Durham) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David) erg-xl@cox.net (Eddie R. Grant) fdhundle@southernco.com (Forrest Hundley) fhwillis@southernco.com (Fred Willis)

G2NDRMDC@southernco.com (SNC Document Control) graysw@westinghouse.com (Scott W. Gray) jadwilli@southernco.com (J.D. Williams) james1.beard@ge.com (James Beard) jannina.blanco@pillsburylaw.com (Jannina Blanco) jantol1dj@westinghouse.com (David Jantosik) jenmorri@southernco.com (Jennifer Buettner)

JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)

John.Bozga@nrc.gov (John Bozga)

Joseph_Hegner@dom.com (Joseph Hegner) jpredd@southernco.com (Jason R. Redd) jranalli@meagpower.org (Jerry Ranalli) karen.patterson@ttnus.com (Karen Patterson) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) markus.popa@hq.doe.gov (Markus Popa)

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Vogtle Units 3 & 4 Mailing List Matthew.Williams@hq.doe.gov (Matthew Williams) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)

Melissa.Smith@Hq.Doe.Gov (Melissa Smith)

Michael.Kuca@hq.doe.gov (Michael Kuca) mike.price@opc.com (M.W. Price)

MKWASHIN@southernco.com (MKWashington) mlgraves@southernco.com (Michelle Graves)

MSF@nei.org (Marvin Fertel) myox@southernco.com (Mike Yox) nirsnet@nirs.org (Michael Mariotte)

Nuclaw@mindspring.com (Robert Temple) patriciaL.campbell@ge.com (Patricia L. Campbell)

Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) r.joshi15@comcast.net (Ravi Joshi)

RJB@NEI.org (Russell Bell)

Ronald.Jones@scana.com (Ronald Jones) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) sara@cleanenergy.org (Sara Barczak) sblanton@balch.com (Stanford Blanton)

Shiva.Granmayeh@hq.doe.gov (Shiva Granmayeh) sjackson@meagpower.org (Steven Jackson) skauffman@mpr.com (Storm Kauffman) sroetger@psc.state.ga.us (Steve Roetger) stephan.moen@ge.com (Stephan Moen) stephen.burdick@morganlewis.com (Stephen Burdick) tom.miller@hq.doe.gov (Tom Miller)

TomClements329@cs.com (Tom Clements)

Vanessa.quinn@dhs.gov (Vanessa Quinn) vcsummer2n3@gmail.com (Brian McIntyre) wasparkm@southernco.com (Wesley A. Sparkman) wayne.marquino@gmail.com (Wayne Marquino) weave1dw@westinghouse.com (Doug Weaver) x2gabeck@southernco.com (Gary Becker) x2kmseib@southernco.com (Kristin Seibert)

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