ML19030B846

2019/01/30 Vogtle COL Docs - FFD Staff Discussion Topics for Future Public Meeting

ML19030B846
Person / Time
Site:	Vogtle
Issue date:	01/30/2019
From:	NRC
To:	NRC/NRO/DLSE/LB4
References
Download: ML19030B846 (4)

Text

NRC Staff Questions for SNC-requested Exemption - ND-18-1494 PUBLIC VERSION 1 of 2 PUBLIC VERSION By letter dated December 6, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18340A280), the Southern Nuclear Operating Company (SNC) requested that the U.S. Nuclear Regulatory Commission (NRC) approve an exemption from Title 10, of the Code of Federal Regulations, (10 CFR), Part 26, "Fitness for Duty Programs," section 26.4(f). Specifically, SNC requested exemption from 10 CFR 26.4(f) to enable technical and vendor experts to construct or direct the construction of safety- or security-related SSCs for 30 days or less in a 60 day period as a visitor under the control of an escort at the Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Combined License (COL) Numbers NPF-91 and NPF-92, respectively.

Section 26.4(f) states that any individual who is constructing or directing the construction of safety- or security-related structures, systems, and components (SSC) shall be subject to an FFD program that meets the requirements of Subpart K, "FFD Program for Construction," of this part, unless the licensee or other entity subjects these individuals to an fitness-for-duty (FFD) program that meets all of the requirements of this part, except for Subparts I, "Managing Fatigue," and K of this part.

In its letter, SNC stated, in part, that "[e]scorts would be trained and controlled by means meeting the intent of 10 CFR 73.55(g)(8)" and on page 6 of their letter, SNC provided "[i]nformation pertaining to implementing procedures for training and controlling construction

escorts."

1. State whether construction visitors will be under direct observation of the assigned escort(s). If the construction visitors are not under direct observation by the assigned escort, describe how the assigned escort can be expected to stop work if they "identify conditions that adversely affect a safety- or security-related SSC" or provide for

"immediate communication with security if a visitor problem arises." (ND-18-1494, first paragraph, page 6)

2. Summarize how SNC has defined (or described the difference(s) between) individuals directing the construction of safety- or security-related SSCs as used in 10 CFR 26.4(f) and individuals supervising or managing the construction of safety- or security-related

SSCs as used in 10 CFR 26.4(e)(5).

3. Similar to question 2, summarize how SNC will ensure that construction visitors will not perform the duties, responsibilities, or activities described in 10 CFR 26.4(e), with specific focus on paragraphs 26.4(e)(2) and (4) which apply to individuals who perform "quality assurance, quality control, or quality verification activities related to safety- or security-related construction activities" and "[w]itnesses or determines inspections, tests, and analyses certification required under Part 52 of this chapter," respectively.

In its letter, SNC stated, in part, that "[r]equiring such individuals to be subject to a 10 CFR Part 26, Subpart K, FFD program, is a costly and an unnecessary burden." Section 26.9, "Specific exemptions," states that "[u]pon application of any interested person or on its own initiative, the Commission may grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest."

4. If in the public interest, quantitatively summarize the estimated cost savings SNC may realize if the NRC approves the requested exemption.

NRC Staff Questions for SNC-requested Exemption - ND-18-1494 PUBLIC VERSION 2 of 2 PUBLIC VERSION

5. If in the public interest, qualitatively summarize the reduction in burden SNC may realize if the NRC approves the requested exemption.