ML18149A564

COL Docs - Draft LAR 18-018, Fitness-for-Duty Commitment Change for Pre-Submittal Meeting on May 31, 2018

ML18149A564
Person / Time
Site:	Vogtle
Issue date:	05/29/2018
From:	NRC
To:	NRC/NRO/DNRL/LB4
References
Download: ML18149A564 (21)

Text

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.

1

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-18-0 ND-18-0754 52-026 50.9 10 CFR 50.90 U.S. Nuclear Regulatory Commission R

ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operatingng Company AF erating Plant Units 3 and Vogtle Electric Generating an 4 Request forr License Amendment:

ment:

ess-for-Duty (FFD) Commitments Changes to Construction Fitness-for-Duty Commitme (LAR-1 (LAR-18-018)

Ladies and Gentlemen:

In accordance with 10 CFR 50.90, Southern Company ern Nuclear Operating Comp Com (SNC) requests an amendment to the combined ined licenses (COLs)

OLs) for Vogtle Electric Generating Plant (VEGP)

Units 3 and 4 (License Numbers NPF-91 and NPF-92, respectively).

respectively The requested amendment ments related to the construction would revise commitments constructio fitness-for-duty fitness-fo (FFD) program described T

in the VEGP 3 and 4 Updated Final Safety Analysis R Report (UFSAR).

(U The change would involve the creation of a new type of FFD Authorization (FFDA)

(FF th that would allow construction workers cess to the construction site pending comp temporary access comple completion of all pre-access FFD requirements but prior to assignment to work on safety- or security-related s structures, systems, and ents (SSCs).

components SCs).

ecifically, cifically, SNC proposes tto take an exceptio Specifically, exception to its current commitment to Regulatory Guide RG) 5.84, Fitness-for-Duty Programs (RG) P N at New Reactor Construction Sites [ADAMS Accession Number ML15083A412]. RG 5.8 5.84 endor endorses NEI 06-06, Fitness for Duty Program Guidance for New Nuclear Power Plant Cons Construc Construction Sites, (April 2013) [ADAMS Accession Number ML13093A340]. The proposed ex 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-Ch 06 commitments 06-06 co commitm would be identified in UFSAR Section 13.7, Fitness for Duty, D ure 1 provid Enclosure UFS and documented in UFSAR proposed exceptions from anges require prior NRC changes Appendix 1A, Conformance with Regulatory Guides. Because the fro NEI 06-06 are considered a reduction in commitment, the proposed N approval.

provides the description, technical evaluation, regulatory evaluation (including the nt Haz Significant Hazards Consideration Determination) and environmental considerations for the h

proposed changes. identifies the requested changes and provides markups depicting the requested changes to the VEGP Units 3 and 4 licensing basis documents.

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 nd non no nonsecurity-related construction activities at the VEGP 3 and 4 site.

This letter contains no regulatory commitments. This letter has been reviewed viewed and a determined not to contain security-related information.

SNC requests NRC staff approval of the requested license amendment ndment by XXXX X XX, X, 2018, 2018 2 , to ted SSCs support continued construction of non safety- and security-related S SSCs.. Delayed approval approv of R

constructio this license amendment could result in a significant loss of efficiency related to construction C expects activities involving safety- and security-related SSCs. SNC expe to implement this proposed oposed chang amendment within 30 days of approval of the requested changes.

In accordance with 10 CFR 50.91, SNC is notifying the he State of Georgia by ttransmitting a copy of tate Official.

this letter and its enclosures to the designated State fficial.

AF ntact Wesley A. Sparkman Should you have any questions, please contact Sparkma at (205) 992-5061.

992-506 I declare under penalty of perjury that the he foregoing is true and correct. Executed on the [Day] of

[Month Year].

Respectfully submitted, T

Director, ector, Brian H. Whitley ctor, Regulatory Affairs Southern Nuclear Operating Company Enclosures C

1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Request for License Amendment men Regarding Changes to Construction Fitness-for-Duty (FFD)

D Commitments Commitm omm 2)) Vogtle (LAR-18-018)

Vogt Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes Vogtl to Licensing Basis Documents (LAR-18-018)

U.S. Nuclear Regulatory Commission ND-18-0754 Page 3 of 4 cc:

Admin: Use Distribution for non-SUNSI information.

T RAF D

Southern Nuclear Operating Company ND-18-0754 Enclosure 1 ing Plant (VEGP)

Vogtle Electric Generating GP) Units 3 and 4 Requestst for License ense Amendment Regarding Changes to Construction Fitness-for-Duty (FFD) Co Commitments (LAR-R-18 18--018 01 )

(LAR-18-018)

(This Enclosure consists of 11 pages, including this cover page)

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018)

Table of Contents

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1.

4.2.

4.3.

Precedent ion Significant Hazards Consideration T eria Applicable Regulatory Requirements/Criteria R

5.

6.

AF 4.4. Conclusions ENVIRONMENTAL CONSIDERATIONS REFERENCES ERATIONS RATIONS D

Page 2 of 11

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018)

In accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby rrequests an amendment to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Vo Electric Ele Generating Plant (VEGP) Units 3 and 4, respectively.

1.

SUMMARY

DESCRIPTION The proposed changes would revise the Combined Licenses (COLs)COLs) in regard to commitments commitm to Part 26, Subpart K (Subpart K workers).

Fitness-for-Duty Programs at New Reactor Construction Number ML15083A412]. RG 5.84 endorses Nuclear Energy T

described in the VEGP 3 and 4 Updated Final Safety Analysiss Report (UFSAR) related to fitnes for-duty (FFD) requirements for construction workers defined on Sites, nstruction fitness-ned in 10 CFR 26.4(f) who are subject SNC proposes to take an exception to its current commitment ommitment to Regulatory Regulato Guide (RG) 5.84, Sites Revision 0, [ADAMS Acce rgy Institute (NEI) guidance NE 5.8 Accession NEI 06-06, R

Fitness for Duty Program Guidance for New

[ADAMS Accession Number ML13093A340].

26.4(f) who are subject to an FFD AF Subpart K. Exceptions to NEI Duty would be documented 2.

construction 06, Revision 6. NEI 06 with NEI 06-06, ESCRIPTION DETAILED DESCRIPTION A340 1

w Nuclear Power Plant A340].

FD program EI 06-06 commitments FSAR Section 13.7, Fitness forr Duty, As described in UFSAR 06-Duty the co 06 establishes 06-06 shes FFD n sites that meet the requirements of 10 CFR als who individuals o construct or direct the construction ems, and components systems, ponents (SSCs)

(S construct subj shall be subject C

FF F

lant Con

]. The exception would modify mo mentt access authorization for individuals to allow for temporary, pre-assignment Sites (April 2013)

Construction Sites, NEI 006-06 guidance individua defined mmitments noted in UFSAR, Section d in UFSAR, Appendix endix 1A, Conformance wi S

d in 10 CFR gram that meets the requirements of 10 CFR Part 26, 13.7, Fitness for with Regulatory Guides.

construction FFD program is consistent program requirements for new plant Part 26. 10 CFR 26.4(f) requires that of safety- or security-related structures, to an FFD program that meets Subpart K of 100 CFR Part 26. 10 CFR 2 26.405 states ththat individuals identified in 10 CFR 26.4(f) shall be subbject to drug and alcohol testing subject tes unde the following conditions: Pre-assignment. Before under assignment to construct or direct th the co construction of safety- or security-related SSCs.

NEI 06-06 provides es guidance to m meet the requirements of Part 26 for construction workers by establishing a fitness-for-duty fitness-for- au authorization (FFDA) that is granted after the worker has completed D

all elements of the construction 1

nment drug tes assignment FFDA, even wh sig const construct completing identity verif verific worker FFDA. These elements include signing a consent form, verification, passing a pre-assignment drug and alcohol test, and receiving ining on FFD policie training policies, sanctions, and FFD program expectations. Because results of the pre-testing may take several days, construction workers are prevented from gaining 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 Pre-assignment means Before assignment to construct or direct the construction of safety- or security-related [structures, systems and components] SSCs.

Page 3 of 11

ND-18-0754 Enclosure 1 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018) requirements contained in NEI 06-06 to allow for a limited FFDA that would authorize access for orize ac a

construction workers pending results of drug testing but prior to being assigned ned to construct constru or direct the construction of safety- or security-related SSCs. All other NEI 06-06 06-06 FFDA F elements elemen would have been completed. Construction workers granted a limited FFDA would be administratively prevented from constructing or directing construction n of safety or securit security-related SSCs.

with Regulatory Guides, states that conformance T UFSAR, Appendix 1A, provides an evaluation of the degree regulatory guides VEGP 3 and 4 site-specific design, construction ce with Revision 6 (April 2013), is without exception. NEI 06-06 ree of compliance with Division 1 nstruction and/or operational aspects.

UFSAR Subsection 1.9.1.3, Division 5 Regulatory Guides - Materialss and Plant Protection describes the applicability to Division 5 Regulatory Guides. UFSAR Appendix 6 contains requirements req Protection,,

Conformance Append 1A, Conformanc ith RG 5.84, which endorses NEI 06-06, 06 granting an for gran D

FFDA for construction workers, which consistist of four elements:

nts:

1. Signing a consent;

2. Verifying identity;

3. Successfully passing a pre-assignment nment drug and alcohol test; and re-assignment

4. Receiving training on FFD policy, sanctions and FFD program eexpectations.

ex R

The requested amendment ntt proposes to add an exception to the UFSAR, UFS Appendix 1A, entry for RG 5.84 which would allow the granting of a temporary FFDA to allow workers to construct temporar limited FFD non safety- and security-related ecurity-related SSCs pending theth determination determi of the results of the pre-assignment drug licensing documents are described in the g test. Other conforming changes to licens AF table below (Detailed Detailed markups of proposed changes to licensing documents are presented in Enclosure 2.):

):

Licensing ensing Basis Change Descriptions:

censing Des Propo Proposed Licensing Basis Changes Text, Table, or Figu Figure Description of the Proposed Change UFSAR Subsection secti 1.9 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 SAR Appendix 1A, Entry for An entry for RG 5.84 is added to take exception to RG 5.84 NEI 06-06 as follows:

A definition is added to Section 4 to define a Limited Fitness-for-Duty (FFD) Authorization Page 4 of 11

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018)

(FFDA) as an authorization granted for a limited lim period of time to potential 10 CFRR 26.4(f) worke workers ments of that have not completed all elements o FFDA for individuals subject to 10 CFRR Part 26 S Subpart K.

Workers granted a Limited d FFDA shall be ted ed from constructing or administratively prevented n of safety directing construction safety-afe - or security security-related rity--related rela T

an individual construction Section ms, and components (SSCs).

structures, systems, Section 6.2.1,, Pre Pre-Assignment, Pre-

-Assignment A , is clarified to allow al to have limited access 9.3.

on 9.33.

acc tion site under the conditions ction cond to the low specified in R

Section 8, Reviewing iewing Off Official,, the first parag Official paragraph is revised to clarifyy that FFDA FF determinations determina include limited FFDA.

Section 9.2, Types of FFDA, FFDA, is re revised r to add a AF fourth type - Limited FFDA FF Section 9.3 is revised to add an introductory paragraph aragraph that reads:

A cons construction site entity may grant a limited FFDADA fo p for a period of up to one working week cale ca (i.e. 7 calendar days) upon successful completion and documentation of the elements comple specified in Section 9.1, as appropriate, except spec the requirement for documentation of a passed th drug test.

UFSAR AR Section 13.7 UFSAR Section 13.7 is revised to refer to Appendix 1A for exceptions to NEI 06-06.

D 3.

10 TECHNICAL EVA EVALUA EVALUATION 0 CFR Part 26 establi nse under 10 CFR license tablis establis establishes requirements, in part, for FFD programs for holders of a combined CF Part 52 after the Commission has made the finding under 10 CFR (g), except that 10 CFR Part 26, Subpart K applies during the construction phase. 10 CFR 52.103(g),

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 Page 5 of 11

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018) construct or direct the construction of safety- or security-related SSCs. 10 CFR 26.401(b)

R Part 26 requires that licensees who implement an FFD program under Subpart K submit description of bmit a descriptio d

the FFD program and its implementation as part of the license application. n. The VEGP 3 and 4 FFD program description was submitted and approved as part of the combined license lic (COL) application and is described in UFSAR Section 13.7, Fitness for Duty. UFSAR Section 13.71 states that the construction FFD program is consistent with NEI 06-06, Revision 6 (April 2013), wwhich is endorsed by Regulatory Guide 5.84, Revision 0.

intended to serve as the construction FFD program T NEI 06-06 provides regulatory guidance for establishing and implementing an FFD program for evaluating and maintaining the authorization of personnelnnel for whom access to the construction site has been requested. This approach ensures consistent application of o regulations and is gram description for construction req Consistent with operational FFD programs, NEI 06-06 sets FFD requirements con ent site entities.

for site access R

e to 10 CFR Part 26 requi authorization, which is conservative relative constru requirements for construction FFD struction workers to be subject to an FFD pr programs. 10 CFR Part 26 requires construction program before ction on of safety- or security-related SSC constructing or directing the construction SSCs.

rements for operating facilities require that F While 10 CFR Part 26 FFD requirements FFD requirements be AF met before granting an individualual covered under the requirements of PartPa 26 access to the facility, Subpart K FFD requirements ts must be met before efore constructing or directi directing construction of a safety-or security-related SSC.. Thus, Subpart K FFD requir requirements are not required to be met before granting an individuall access to the construction site.

site The proposed propo changes to the commitments related to NEI 06-0606 would allow a construction worke worker acces access to the construction site for a period not to exceed one working week (i.e. 7 calendar days) pendingpen results of the pre-assignment drug her er pre-assignment FFD requirements wou test. All other would be met before granting the temporary zation, e.g., inclusion in the pool of cconstruction workers eligible for random drug access authorization, lcohol testing.

and alcohol g. Construction workers grante granted access to the site under a temporary access thorization horization would be adm authorization administratively preve prevented from working on safety- or security-related SSCs by being issued a unique designat badge and uniquely identified personal protection uniquely designated equipment. Personnel granted a limitedl FFDA and their work supervision would be informed of gra their work limitations. Personnel granted a limited FFDA would be tracked using the site access application. Access ss authorization authorizatio training programs would be revised to include methods of D

controlling temporary ac he proposed changes The porated into Part incorporated Subpart K into Pa y listed other entity access authorization and limits on the types of work such construction p

workers may be allowed to perform.

change are consistent with the Commissions intent when Subpart K was Par 26. The Statements of Consideration for the Part 262 Rule that incorporated Part 26 state in part, Therefore, the Subpart K requirements provide a licensee or list 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 Page 6 of 11

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018)

Thus, revising commitments related to construction worker FFD requirements continue continu to meet Subpart K requirements.

The proposed changes do not affect the radiological source terms (i.e.,, amounts and types o of radioactive materials released, their release rates and release durations) ions) used in the th accident quipment uipment or a fission product analyses. The proposed changes do not affect safety-related equipment barrier. No system or design function or equipment qualificationion is adversely affected by the fuel cladding failures.

No SSCs are affected by this license amendment T

proposed changes. The changes do not result in a new failure ence ure mode, malfunction or sequence sequenc al barrier or safety-related equipment.

of events that could adversely affect a radioactive material roduct release path, result in a new fission The proposed changes do not allow for a new fission product nce of events that would result in significan product barrier failure mode, or create a new sequence ndment request, significant est, thus no SSCs which are used to R

contain, control, channel, monitor, process The change activity ss or release radioactive and non-radioactive material effluentss are affected AF Plant radiation zones (as described expected amounts and types an non-radioactiv ected by the proposed changes.

scribed in UFSAR pes of radioactive materials are not affected nd cumulative radiation exposures Therefore, individual and exposu ty has no adverse impact on the emergenc implementation,, because there are no changes to ph the Nuclear Island mary Summary sonnels e

physica non-radioactive materials are affected. The types and quantitiess of expected effluents are not changed, release path is adversely affected by the c

he proposed changes. Therefore, n neith a no effluent and neither radioactive nor AR Section 12.3), controls under un u 10 CFR Part 20, and affecte by the proposed changes.

do not cchange.

emergency plan or the physical security plan physical access to credited equipment inside sland (including containment or the auxilia auxiliary building) there is no adverse impact to els ability to respond to any plant oper plant personnels operations or security event.

The proposed changes to SNCs S commi commitment to NEI 06-06 guidance which would allow temporary access to the construct 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 changess would not adver adversely affect any safety-related or security-related equipment or function, design function function, radioa radioactive material barrier or safety analysis.

D Page 7 of 11

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018)

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR Part 26, Fitness for Duty Programs, establishes requirements, ements, for FFD programs, programs ,

in part, for holders of a combined license under 10 CFR Part 52 after the Commission Commis has made the finding under 10 CFR 52.103(g), except for 10 CFR Part 26, Subpart K, w which Subpart K. Because the proposed changes T applies during the construction phase. 10 CFR 26.4(f)) establishes the category of work that is subject to the FFD program requirements of Subpart K. 10 CFR 26.4(f), in part, worker 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 es to SNCs commitment to NEI 06-06 guidance continue to ensure construction workerss who construct struct or direct the guida o

t construction of safety-R or security-related SSCs are subject ct to an FFD program, program rogram,, the t requirements o of 10 CFR Part 26, Subpart K, are met.

4.2 Precedent ed.

No precedent is identified.

AF 4.3 Significant Hazards Consideration Updated Final to the plant ant itself.

An evaluation to dete in 10 CFR CFR 50.92, 4.3.1 50 Issuance deration The proposed changes would revise the Vogt ssuance of amendment, Does the propo proba probability am Vogtle Electric Ge nal Safety Analysis Report (UFSAR)

(UFS itness-for-Duty (FFD) program to inc worker Fitness-for-Duty allow workers to construct nonsafety- and n termination mination of the results of the pre-as determination pre-assignm signm pre-assignment comm Generating Plant (VEGP) 3 and 4 commitment related to the construction include a limited FFD Authorization (FFDA) to non-security-related SSCs pending the drug test. There is no physical change determine whether or not a significant hazards consideration is involved with the proposed amendment amen was ccompleted by focusing on the three standards set forth as discussed below:

proposed amendment involve a significant increase in the or consequences of an accident previously evaluated?

D Response:

The Upda onse he proposed pro prop No.

changes to the Vogtle Electric Generating Plant (VEGP) 3 and 4 Updated Final Safety Analysis Report (UFSAR) commitment related to the co 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 Page 8 of 11

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018) commitments do not affect prevention and mitigation of abnormal events (e.g.,

mal eve even accidents, anticipated operational occurrences, earthquakes,, floods, floods or turbine tu missiles) or their safety or design analyses. No safety-related SSC or function is ted SS adversely affected. The changes neither involve nor interface wit with any SSC accident initiator or initiating sequence of events, so the probabilities probabilitie of the accidents evaluated in the UFSAR are not affected.d. Because the changes do not involve any safety-related SSC or function usedsed to mitigate an accident, the Therefore, the proposed amendment does T UF consequences of the accidents evaluated in the UFSAR are not affected.

es not involve a significant increase in the probability or consequences of an accident cident previously evaluated.

evalua R

4.3.2 Does the proposed amendment possibility of a new o endment create the pos or different kind of accident from m any accident previously ev evaluated?

Response: No.

AF The proposed changes to the VEGP 3 and 4 UFSAR com commitment related to the construction worker FFD programogram do o not affect the operation op of any systems or equipment ntt that may initiate a new or different dif kind o of accident or alter any SSC hat a new accident initiator or initiating such that in sequ sequence of events is created. The nges do not affect the design of an changes a SSC us used to meet the design bases of the nuclear plant. Nor do the changes a 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 Th changes do not affect safety-related equipment, quipment, nor do they affect equip equi equipment that, if it failed, could initiate an accident or a failure of a fission product bbarrier. In addition, the changes do not result in a new failure modmode, malfunctio malfunction, or sequence of events that could affect safety or safety-related equipment.

equip Noo analysis is adver advers adversely affected. No system or design function or equipment qualification ficatio is adv adversely affected by the changes. This activity will not allow for a D new fission failure fuel issio product re mode el clad There mo mode, cladd pro cladding failures.

release path, nor will it result in a new fission product barrier nor create a new sequence of events that would result in significant Therefore, the proposed amendment does not create the possibility of a new or dif 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.

Page 9 of 11

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018)

The proposed changes to the VEGP 3 and 4 UFSAR commitment related to the nt relat relate construction worker FFD program do not alter any safety-related related equipment, equipm applicable design codes, code compliance, design function, on, or safety s analysis.

analysi Consequently, no safety analysis or design basis acceptance ceptance limit/criterion limi is challenged or exceeded by the proposed change, thus us the margin of safety saf is not reduced.

margin of safety.

significant hazards consideration under the T Therefore, the proposed amendment does nott involve a significant reduction in a Based on the above, it is concluded that the proposed amendment does not involve a e standards set forth in 10 CFR 50.92(c), and, azards consideration is justified.

accordingly, a finding of no significant hazards an R

4.4 Conclusions onsiderations discussed above, (1)

In conclusion, based on the considerations ( there is reasonable afety of the public will not be endangered assurance that the health and safety endange endang by operation in the proposed manner, (2) such activities will be conducted in compliance with the AF tions, and (3) the issuance of the amendment Commissions regulations, amendm amendme will not be inimical to nse the common defensese and security or to the health and safety of the public. Pursuant to 10 CFR 50.92, the requested change does do inv not involve a Significant Hazards n.

Consideration.

5. NMENTAL CONSIDERATIONS ENVIRONMENTAL CONSIDE osed The proposeded changes would revise the Vogtle Electric El Generating Plant (VEGP) 3 and 4 Updatedd Final Safety Analysis Report (UFSAR) commitment co related to the construction worker ess-for-Duty (FFD)

Fitness-for-Duty FD) progra program to allow workers to construct nonsafety- and non-security-related SCs pending the determina SSCs determination of the resu results of the pre-assignment drug test. There is no itsel physical change to the plant itself.

This review has determined the prop propo proposed change requires an amendment to the COL. However, icipated construction a review of the anticipated constru and operational effects of the requested amendment has requeste amendment determined the requested ame meets the eligibility criteria for categorical exclusion set D

forth in 10 CFR 51.22(c)(9),

i)

(i)

As documen 2(c)( in that:

signi sign There is no significant hazards consideration.

documented in Section 4.3, Significant Hazards Consideration, of this license amendme request, an evaluation was completed to determine whether or not a amendment ific 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 Page 10 of 11

ND-18-0754 Request for License Amendment Regarding Changes to Construction Fitness-for-Duty (FFD)

Commitments (LAR-18-018) amendment does not create the possibility of a new or different kind of accident ccident from fr any accident previously evaluated; and (3) the requested amendment does not n involve invol a significant reduction in a margin of safety. Therefore, it is concluded ded that the requested requeste amendment does not involve a significant hazards consideration n under the standards st set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

(ii)

The proposed change to the VEGP 3 and construction worker FFD program is unrelated operation that would introduce any change chemicals or biocides, sanitary system T

There is no significant change in the types or significant effluents that may be released offsite.

ant increase in the amounts of any d 4 UFSAR commitments related to the ted to any aspect of plant construction or elated ange to effluent types (e.g.,

(e m effluents, and other effluents),

ef containing effluents conta or affect any a plant RAF (iii) radiological or non-radiological effluent exposure.

truction FSAR UFSAR uent change does not affect any effluent fluent release quantities. Furthermore, th ent release path or diminish the functionality or operational features that are credited with controlling the releas e, it is concluded plant operation. Therefore, nificant increase in individual or There is no significant oposed change to the VEGP 3 and 4 UFSAR The proposed R Section 12.3) or controls under 1 increase inn occupational radiation exposure.

not involve a signif exposu fu release o oncluded that the requested amendm n the types orr a significant increase in the a a significant change in ed offsite.

that may be released o cumulative occupational radiation ruction worker FFD program would not affect construction a af U

the proposed of any design of effluents during amendment does not involve amounts of any effluents commitments related to the plant radiation zones (addressed in 10 CFR Part 20 that preclude a significant Therefore, the requested amendment does significant increase in individual or cumulative occupational radiation exposure.

Based on the above review of the re reque requested amendment, it has been determined that anticipated construction and operational effects of the requested amendment do not involve (i) a significant hazards consideration, on, (ii)

(i a significant signi change in the types or significant increase in the amounts D

of any effluents that may cumulative occupational ra proposed ed exemption

6. REFERENCES None.

EN ma be released offsite, or (iii) a significant increase in the individual or ligibility criteria for categorical eligibility cate radiation exposure. Accordingly, the requested amendment meets the exempti is not required.

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 Page 11 of 11

Southern Nuclear Operating Company ND-18-0754 T

Enclosure 2 erating Plantt Units 3 and Vogtle Electric Generating an 4 RAF d Changes to Licensing Basis Documents Proposed (LAR-AR-18 1 -018 018))

(LAR-18-018)

Document D serti 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.)

ND-18-0754 Proposed Changes to Licensing Basis Documents (LAR-18-018) ates that the UFSAR Subsection 1.9.1.3 is revised to reflect that UFSAR Section 13.7 states construction FFD program is consistent with NEI 06-06, Revision 6 (April April 20 2013 2013) with exceptions.

1.9.1.3 Division 5 Regulatory Guides-Materials and Plant Protection rotection and 4 construction FFD program is described in UFSAR, T

Appendix 1A also provides an evaluation of the degree of conformance states that the FFD program is consistent with endorsed exceptions.

nformance with the Division 5 uty (FFD) programs. The VEGP 3 regulatory guide (5.84) related to construction fitness-for-duty R, Section 13.7. UFSAR Section 13.7 rsed NEI 06-06, Revisio Revision 6 (April 2013) with RAF D

Page 2 of 5

ND-18-0754 Proposed Changes to Licensing Basis Documents (LAR-18-018)

UFSAR Appendix 1A entry for Regulatory Guide (RG) 5.84 is revised to o reflect re the exceptions taken to NEI 06-06, Revision 6 (April 2013).

Note: This markup reflects current UFSAR text that was incorporated rated by a non-non-LAR departure that was evaluated per 10 CFR Part 52, Appendix ix D, Section Se VIII.B.5 VIII.B.

criteria and determined to not require prior NRC approval Reg. Guide 5.84, Rev. 0, 7/15 - Fitness-for-Duty Programs att New Reactor Constructi Construction R

Sites Conformance with programmatic and/or operational aspects ects is documented d below.

General 10 CFR Part 26 Conforms Exceptions to guida guidance provided in NEI 06-06 Rev. 6 (April Exception tion NEI 006-06 06 -06 Rev. 6 (April 2013) are a as AF 2013) described de scribed belo below:

A definition finition is added to define a limited FFD authorization thorizat as follow follows:

Limited Fitness Fitness-for-Duty ness--for for-Dut (FFD)

Authorization (FFDA)

(FFDA - An authorization gran granted for a limited period of time tto potential 10 CFR 26.4(f) 26 4(f) worke workers that have not completed all elements for FFDA for T

individuals subject to 10 CFR Part 26 individu Subpart K. Workers granted a Limited Subp FFDA shall be administratively FF 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 D

Page 3 of 5

ND-18-0754 Proposed Changes to Licensing Basis Documents (LAR-18-018)

Section 8. Reviewing Official, the first sentence of the first paragraph raph aph is revised to read:

The construction site e entity or as applicable, approvedved C/V, is required to designate in writing one oro more individuals ass a reviewing official offici to make FFDA A (including Limited FFDA)

FF determinations nations relative to a potential AF construction truction tru ction site workforce members trustworthiness ustworthiness and reliability and ustworth fitness for duty.

Se Section 9.2, Types of o FFDA FFDA,, is revised to add a fourth typ type - Limited FFDA Section ection 9.3, G Granting FFDA and FFDA Elements, Elements ments,, is revised to add an introductory ctory paragraph pa that reads:

T A construction tion site entit entity may grant a limited FFDA for a p pe period of up to one working week wee (i.e.

e 7 calendar days) upon successful successfu completion and documentation of the elements documentatio specified within w Section 9.1, as appropriate, except the requirement for appropr documentation of a passed drug test.

docu Page 4 of 5

ND-18-0754 Proposed Changes to Licensing Basis Documents (LAR-18-018)

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) 01) as endorsed e by NRC Regulatory Guide 5.84, Revision 0, as amended by the exceptions documente in s documented Appendix 1A, and the pre-access provisions for reinstatement described bed in 10 CFR 2626.65.

NEI 06-06 applies to persons constructing or directing the construction ction on of safety- and security-sec related structures, systems, or components performed onsite where here the new reactor will be T

installed and operated. Management and oversight personnel,l, as further NEI 06-06, and security personnel prior to the receipt of special establishment of a protected area, all persons who are requirements of an operations FFD program.

o fur meets the requirements of 10 CFR Part 26, Subparts A through H, N, and O.

described in ecial nuclear material in the form of fuel assemblies (with certain exceptions) will be subject to the operations FFD program that O At the re granted unescorted access will meet th the RAF D

Page 5 of 5