ML18298A058

From kanterella
Revision as of 12:52, 20 October 2019 by StriderTol (talk | contribs) (Created page by program invented by StriderTol)
Jump to navigation Jump to search
2018/10/25 Vogtle COL Docs - Pre-submittal Presentation for Request for Exemption Part 26 Visitor Access Requirements
ML18298A058
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/25/2018
From:
NRC
To:
NRC/NRO/DLSE/LB4
References
Download: ML18298A058 (15)
v • d • e


Text

Vogtle PEmails From: Hoellman, Jordan Sent: Thursday, October 25, 2018 6:40 AM To: Vogtle PEmails

Subject:

Pre-submittal Presentation for Request for Exemption RE: Part 26 Visitor Access Requirements Attachments: Presentation_Part 26.pdf Attached is the pre-submittal presentation for SNCs Exemption Request RE: Part 26 Visitor Access Requirements for the Nov. 1 public meeting. The attachment does not contain any SUNSI.

Jordan Hoellman Project Manager NRO / DLSE / LB4 U.S. Nuclear Regulatory Commission office: OWFN 08-C18 phone: (301) 415-5481 email: Jordan.Hoellman2@nrc.gov 1

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 381 Mail Envelope Properties (SN6PR0901MB2366251F76B46A101A3782B5D5F70)

Subject:

Pre-submittal Presentation for Request for Exemption RE: Part 26 Visitor Access Requirements Sent Date: 10/25/2018 6:40:11 AM Received Date: 10/25/2018 6:40:15 AM From: Hoellman, Jordan Created By: Jordan.Hoellman2@nrc.gov Recipients:

"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>

Tracking Status: None Post Office: SN6PR0901MB2366.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 429 10/25/2018 6:40:15 AM Presentation_Part 26.pdf 568761 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Request for Exemption Request for Exemption from 10 CFR 26 for FFD Requirements for Visitors Technical Exchange and Presubmittal Meeting November 1, 2018

Agenda

  • Background
  • Problem Statement
  • Regulatory Considerations
  • Issue Resolution
  • Proposed Exemption Schedule

5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Background

  • 10 CFR 26.4(f) 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, requirements.

- Alternatively, licensees with plant under construction may follow the 10 CFR 26 Subparts A - H, N, and O, which includes all operating requirements with the exception of fatigue management requirements.

  • Subpart K was established and intended to provide reasonable assurance that individuals involved in the construction of a nuclear power plant who perform specified duties at the site are fit for duty, trustworthy, and reliable. (ref. 73 Fed. Reg. 16993, March 31, 2018).



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Background

  • Subpart K provides no provisions (i.e. does not allow) for escorting visitors which results in a hardship because this is more limiting than operating units.

- Subpart K requirements for construction was intended to be less stringent and provide greater flexibility than that required for operating plants (ref. 73 FR 16994, 16996, March 31, 2018).



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Problem Statement Application of 10 CFR Part 26 Subpart K to visitors for short duration construction activities presents an undue hardship and are not necessary to meet the underlying purpose of this regulation.



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Proposed Resolution

  • SNC is seeking to allow visitor access to technical and vendor experts to construct or direct the construction of safety- or security-related SSCs for a limited period of time (14 days or less in a 30-day period) under the control of an escort subject to the FFD requirements of 10 CFR Part 26 during the construction phase (prior to the 10 CFR 52.103(g) finding).
  • In lieu of requiring technical and vendor experts who construct or direct the construction of safety- or security-related SSCs for a limited period of time to be subject to the 10 CFR Part 26 requirements, they would be escorted by an individual(s) who is subject to the requirements of 10 CFR Part 26.
  • This request is consistent with the use of escorts at operating plants.



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Regulatory Considerations

  • The proposed visitor escort allowance requires:

- An Exemption to 10 CFR 26.4 (f) in accordance with the provisions of 10 CFR 26.9:

The Commission may grant 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.

- The exemption to 10 CFR 26.4(f) will provide the basis for an exception to the current commitment to NEI 06-06 to clarify that the construction FFD Program does not apply to escorted construction visitors.

  • Application of Subpart K to visitors for a limited period of time presents an undue hardship as escorts are allowed for operating plants.



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Scope

  • The exemption scope applies to technical and vendor experts who construct or direct the construction of safety- or security-related structures, systems, and components for a duration of 14 days or less in a 30-day period.
  • Those individuals will require an escort that is subject to the requirements of the 10 CFR Part 26 FFD Program.



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Issue Resolution (Licensing Path for Changes):

Exemption Request to 10 CFR Part 26:

- Request an exemption allow technical and vendor experts that construct or direct the construction of safety- or security-related SSCs access as a visitor for a limited period of time (14 days or less in a 30-day period) under the control of an escort subject to the FFD requirements of 10 CFR Part 26 during the construction phase (prior to the 10 CFR 52.103(g) finding).

Licensing Basis Exception:

- Will provide an exception to the NEI 06-06 commitment to allow escorted visitors to work on safety- or security-related SSCs.

  • Licensing basis will provide definitions for visitors and escorts, procedural controls for visitors, and requirements for escorts.



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Technical Basis for Exemption:

1. Individuals are trustworthy and reliable as demonstrated by the avoidance of substance abuse;
2. Individuals are not under the influence of any substance, legal or illegal, or mentally or physically impaired from any cause, which in any way adversely affects their ability to safely and competently perform their duties;
3. Measures are established and implemented for the early detection of individuals who are not fit to perform their duties;
4. The construction site is free from the presence and effects of illegal drugs and alcohol; and,
5. The effects of fatigue and degraded alertness on an individuals ability to safely and competently perform their duties are managed commensurate with maintaining public health and safety.



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Technical Basis for Exemption (cont):

  • Responsibility for adherence to the construction FFD program for each construction visitor would be assigned to a construction escort.
  • Construction Site (CCA) escorts will be badged under one of the following:

o10 CFR 26 Sections A-H, N, and O, or o10 CFR 73.56 Unescorted Access process

  • Escorts will obtain training to perform escort duties that includes behavioral observation
  • Escorts will have general knowledge of the construction activities to be performed by the construction visitor



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

Controls:

5HTXLUHPHQWVIRUFRQWURORIFRQVWUXFWLRQYLVLWRUVDQGFRQVWUXFWLRQHVFRUWVZLOOEH

EDVHGRQUHTXLUHPHQWVIRUYLVLWRUVDQGHVFRUWVDWDQRSHUDWLQJIDFLOLW\WKDWPHHW

WKHDSSOLFDEOHLQWHQWRI&)5 J  L $) DQGLQFOXGH

  • 3URFHGXUHUHTXLUHPHQWVIRUSURFHVVLQJHVFRUWLQJDQGFRQWUROOLQJFRQVWUXFWLRQ

YLVLWRUV

  • &KHFNLQJDJDLQVWLQGXVWU\GDWDEDVHVIRUGHQLHGDFFHVV
  • 3URFHGXUHVIRUWUDLQLQJDQGFRQWUROOLQJFRQVWUXFWLRQHVFRUWV



5HTXHVWIRU([HPSWLRQIURP&)5IRU))'5HTXLUHPHQWVIRU9LVLWRUV

3URSRVHG([HPSWLRQ6FKHGXOH

- Submittal - December 7, 2018

- Requested Approval Date - June 7, 2019



Retrieved from "https://kanterella.com/w/index.php?title=ML18298A058&oldid=1920415"