2018/10/25 Vogtle COL Docs - SNC draft Request for ... · Part 26 PaVisitor Access ReVisitor 2)Vogtle Electric GeneVogtle Electric Gen Licensing Documecensing Docume. U.S. Nuclear

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Vogtle PEmails

From: Hoellman, JordanSent: Thursday, October 25, 2018 6:37 AMTo: Vogtle PEmailsSubject: SNC draft Request for Exemption RE: Part 26 Visitor Access RequirementsAttachments: ND-18-XXXX_Part 26 Visitor Exemption Draft.pdf

Attached is the draft 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: [email protected]

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 380 Mail Envelope Properties (SN6PR0901MB2366676BF49AD308B0242F01D5F70) Subject: SNC draft Request for Exemption RE: Part 26 Visitor Access Requirements Sent Date: 10/25/2018 6:36:30 AM Received Date: 10/25/2018 6:36:39 AM From: Hoellman, Jordan Created By: [email protected] Recipients: "Vogtle PEmails" <[email protected]> Tracking Status: None Post Office: SN6PR0901MB2366.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 398 10/25/2018 6:36:39 AM ND-18-XXXX_Part 26 Visitor Exemption Draft.pdf 982077 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 3535 Colonnade Parkway

Birmingham, AL 35243Tel 205.992.7079

[DATE]

Docket Nos.: 52-025 ND-18-XXXX52-026 10 CFR 26.9

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Southern Nuclear Operating CompanyVogtle Electric Generating Plant Units 3 and 4

Request for Exemption:Part 26 Visitor Access Requirements

Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 26.9, Specific Exemptions, Southern Nuclear Operating Company (SNC) requests an exemption from the requirements of 10 CFR 26.4(f). 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. The requested exemption would permit SNC to use technical and vendor experts to construct or direct the construction of safety-or security-related SSCs for a limited period of time as a visitor under the control of an escort subject to the FFD requirements of 10 CFR Part 26.

The exemption is necessary because SNC expects to require the use of numerous technical and vendor experts to provide direction,expertise, and oversight during the inspection and testing phases of the project. Because many of the inspections and tests will occur before Vogtle Electric Generating Plant (VEGP) 3 and 4 enter the operating phase following the 10 CFR 52.103(g) finding, individuals who are needed for a short period of time (fourteen days or less in a thirty day period) to support the successful completion of an inspection or test are required to be subject to a 10 CFR Part 26, Subpart K, FFD program. These individuals would be allowed to come onsite under an escort following the 10 CFR 52.103(g) finding. Requiring such individuals to be subject to a 10 CFR Part 26, Subpart K, FFD program, prior to the 10 CFR 52.103(g) finding, is costly and an unnecessary burden.

SNC requests termination of this exemption after the Commission makes its finding under 10 CFR 52.103(g) for VEGP for each unit.

The exemption is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest.

Enclosure 1 provides the background and supporting basis for the requested exemption.

Enclosure 2 is a reviewer’s aid that identifies the changes that will be implemented to incorporate the approved exemption into the VEGP 3 and 4 licensing documents. These changes are

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Plant Units 3 and 4Plant Units 3 and 4Exemptionmption:

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AFof 10 CFR 0 CFR 26.926.9,, Specific Sp ExemptionExemptiests an exemption from the requiremenxemption from the requiremen

ls who construct or direct the constructruct or direct the construand components (SSCs) to be subjents (SSCs) to be subje

FR Part 26, Subpart K, requirements. TFR Part 26, Subpart K, requhnical hnical and vendor and vend experts to construct rts to

SSCs for a limited period of time as a SSCs for a limited period of timeD requirements of 10 CFR Part 26.D requirements of 10 CFR Part 26.

on is necessary because SNC expects necessary because SNC expects perts to provrovide directionide direct ,expertisetise, anan

of the project. Because many of the insof the project. Becauseerating Plant (erating Plant (VEGPVE )) 3 and 4 enter th3 and

ding, individuals ding, individuals who are needed for a swho are needed periodperiod) to support the successful comp) to support the successful coma 10 CFR Part 26, Subpart K, FFD pa 10 CFR Part 26, Subpart K, FFD punder an escort following the 10 Cunder an escort following th

a 10 CFR Part 26, Subpart a 10 CFR Part 26, Subpanan unneunnecessary burdenburde

uests terminatiouests terminatior VEGPr VEGP ff

U.S. Nuclear Regulatory CommissionND-18-XXXXPage 2 of 4

expected to be incorporated through the use of a non-license amendment request change process.

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

SNC requests NRC staff approval of the exemption by [DATE], to support inspection and testing activities. Delayed approval of this exemption could result in unnecessary delays of critical inspection and testing activities. SNC expects to implement this proposed exemption within 30 days of approval.

Should you have any questions, please contact Corey Thomas at (205) 992-5221.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the [Day] of [Month Year].

Respectfully submitted,

_______________________

Brian H. WhitleyDirector, Regulatory AffairsSouthern Nuclear Operating Company

Enclosures 1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 – Exemption Request: Part 26 Visitor Access Requirements

2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 – Reviewers Aid: Licensing Document Changes Supporting the Exemption RequestDRAFT

inspection aninspeccessary delays of cessary

oposed oposed exemptionexem withi

asas aat (205) 992t ( -52211.Tue and correct.ue and Executed on the he yy[Day

___

AffairsAffairsOperating CompanyOperating Company

ress 11)) Vogtle Electric Generating Ptle ElectPart 26 Pa Visitor Access ReVisitor

2) Vogtle Electric GeneVogtle Electric GenLicensing Documecensing Docume

U.S. Nuclear Regulatory CommissionND-18-XXXXPage 3 of 4

cc:

Admin: Use Distribution for 2 Enclosures which do not contain SUNSI information.

DRAFTT

Southern Nuclear Operating Company

ND-18-XXXX

Enclosure 1

Vogtle Electric Generating Plant (VEGP) Units 3 and 4

Request for Exemption

Part 26 Visitor Access Requirements

(This Enclosure consists of [XX] pages, including this cover page)

DRAFTg Plant (VEGP) Units 3 and 4(VEGP) Units

Request for est f ExemptionExemption

Part 26 Visitor Access RequirementsAccess Requirements

ND-18-XXXXEnclosure 1Exemption Request: Part 26 Visitor Access Requirements

Page 2 of 14

Table of Contents

1. PURPOSE

2. BACKGROUND

3. TECHNICAL JUSTIFICATION OF ACCEPTABILITY

4. JUSTIFICATION FOR EXEMPTION

4.1 Authorized by Law

4.2 Will not Endanger Life or Property or the Common Defense and Security

4.3 In the Public Interest

5. RISK ASSESSMENT

6. PRECEDENT EXEMPTIONS

7. SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL CONSIDERATIONS

8. CONCLUSION

9. REFERENCES

DRAFTmmon Defense and mmon D Security

ETERMINATION AND ENVIRONMENTRMINATION AND ENVIRONME


Page 3 of 14

1. PURPOSE

In accordance with the provisions of 10 CFR 26.9, Specific Exemptions, Southern Nuclear Operating Company (SNC) requests an exemption from the requirements of 10 CFR 26.4(f). 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. The requested exemption would permit SNC to use technical and vendor experts to construct or direct the construction of safety- or security-related SSCs for a limited period of time as a visitor under the control of an escort subject to the FFD requirements of 10 CFR Part 26. The definitions for a construction escort and construction visitor are provided below:

Construction Escort – An individual subject to the construction FFD program assigned to escort and observe a construction worker engaged in constructing or directing construction of a safety- or security-related SSC and is not subject to the construction FFD program.Construction Visitor – An individual determined by the construction entity to have expertise needed to support the construction or supervision of construction of a safety-or security-related SSC for fourteen days or less in a thirty day period and authorized by a first line supervisor or greater, but who is not subject to the construction FFD program.

The exemption is necessary because SNC expects to require the use of numerous technical and vendor experts to provide direction, expertise, and oversight during the inspection and testing phases of the project. Because many of the inspections and tests will occur before Vogtle Electric Generating Plant (VEGP) 3 and 4 enter the operating phase following the 10 CFR 52.103(g) finding, individuals who are needed for a short period of time (fourteen days or less in a thirty day period) to support the successful completion of an inspection or test are required to be subject to a 10 CFR Part 26, SubpartK, FFD program. These individuals would be allowed to come onsite as a construction visitor under an escort following the 10 CFR 52.103(g) finding. Requiring such individuals to be subject to a 10 CFR Part 26, Subpart K, FFD program, prior to the 10 CFR 52.103(g) finding, is costly and an unnecessary burden. Reviews of safeguards design information is not in the scope of this exemption request as these badging requirements are implemented in accordance with 10 CFR 73.57.

2. BACKGROUND

10 CFR 26.4(f) establishes the category of worker that is subject to the FFD program requirements of Subpart K, unless the licensee subjects these individuals to an FFD program that meets all of the requirements of Part 26, except for subparts I and 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

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ementsemenect the constect the

(SSCs) (SSCs to be subjeubpart K, requirements. ubpart K, req

and vendor nd ven experts to construcexpertsSCs SC for a limited period of time as for a limited period

he FFD requirements of 10 CFR Part he FFD requirements of 10 CFconstruction visitor are provided belowconstruction visitor are provided belo

ct ct to the construction FFD program assto the construction FFD program assorker engaged in constructing or directer engaged in cons

related SSC and is not subject to the coSSC and is not

idual determined by the construction eidual determined by the consrt the construction or supervision of conhe construction or supervision o

or fourteen daysrteen days or less in a thirty day or less in a thirty dayor or greaterter, but who is not subject to t, but who is not subject to t

s necessary because SNC expects ts necessary because SNCvendor evendo xperts to provide directionperts to provide di ,

and testing phases of the project. Becaand testing phases of the project. ur before Vogtle Electric Generating Pr before Vogtle Electric Generating P

e followingowing the 10 CFR 52.103(g) findthe 10 CFR 52.103(g) finderiod of time (e (fourteenfourteen days or less ini

completion of an inspection or test are completion of an inspectK, FFD program. K, FFD program These individuahese invisitor under an escort following er an escort followinto be subject to a 10 CFR Paro a 10 CFR Parfinding, is costly and an uny andis not in the scope ois not in the scopimplemented in accoimplemented in acc

GROGRO


Page 4 of 14

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 construct or direct the construction of safety- or security-related SSCs.” 10 CFR Part 26.401(b) requires that licensees who implement an FFD program under Subpart K submit a description of the FFD program and its implementation as part of the license application. The VEGP 3 and 4 FFD program description was submitted and approved as part of the combined license (COL) application and is described inUpdated Final Safety Analysis Report (UFSAR) Section 13.7, Fitness for Duty. UFSAR Section 13.7 states that the construction FFD program is consistent with the Nuclear Energy Institute (NEI) guidance document, NEI 06-06, Fitness for Duty Program Guidancefor New Nuclear Power Plant Construction Sites, Revision 6 (April 2013), which is endorsed by Regulatory Guide (RG) 5.84, Revision 0.

During the development of NEI 06-06, the industry submitted a draft of NEI 06-06(Revision 6, May 2012 version) that contained provisions which addressed the use of visitors. Specifically, the guidance stated, “The construction site entity may permit individuals onto the construction site as “visitors.” An individual designated as a visitor may be any individual the construction site entity determines to have a need to enter the construction site for a period of up to fourteen continuous days or less. An individual in a visitor status is not required to meet the provisions of 10 CFR 26 but, must be clearly identifiable as a visitor and escorted by a construction site entity designated individual subject to the construction site entity’s FFD program. If the needs of the individual exceed the fourteen continuous days, then the individual must meet the appropriate section of 10 CFR 26.” However, during the NRC review of NEI 06-06, Revision 6 (May 2012) [ADAMS Accession Number ML13039A117], the staff provided a comment that requested the provisions regarding visitors be removed. The NRC agreed that the concept of escorting visitors at construction sites is warranted; however it could not support this option in NEI 06-06 given 10 CFR 26.401(a) which states, in part, that the requirements of Subpart K shall be applied to the individuals specified in Section 26.4(f)..

During the operations phase [post-103(g)], requirements for visitors are defined in 10 CFR 73.55, Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage. Specifically, 10 CFR 73.55(g)(7) permits individuals access to protected and vital areas who have not been granted unescorted access in accordance with the requirements of 10 CFR 73.56 and 10 CFR Part 26 provided the requirements of 10 CFR 73.55(g)(7), are met. Standard operating practice in operating plants is to allow escorted visitor access to protected and vital areas to work on safety-related SSCs for a limited period of time (typically not to exceed fourteen continuous days).

The Statements of Consideration for the 2009 Security Rule change note that the NRC considered changes to the rules related to visitors; however, based on an observation that licensee-escorted access programs have been in place for years without incident, the

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implementatioimplemdescription was submdescriptio

plication and is describedplication and i13.7, 3.7, Fitness for Dutys for Du . UFSAR

ram is consistent with ram is consistent with the Nuclear the06, 06, Fitness for Duty Program GuidancFitness for Duty Program Guid e

SitesSites,, Revision 6 (April 2013), whichRevision 6 (April 2013), whichevision 0. evision

, the industry submitted a draft of Nindustry submitcontained provisions which addresseprovisions

nce stated, “The construction site ennce stated, “The construon site as “visitors.” An individual desin site as “visitors.” An individu

onstruction site entity determines to havuction site entity determines to hiod of up to to fourteen fourteen continuous days ocontinuous days o

quired to meet the provisions of 10 Cet the provisions of 10 Csitor and escorted by a construction ssitor and escorted by a con

nstruction site entity’s FFD program.nstruction site entity’s FFD p Ifcontinuous days, then the individual mucontinuous days, then the individ

However, during the NRC review of NEHowever, during the NRC review of ion Number ML13039A117], the n Number ML13039A117], the staffstaff

isions regarding visitors be removedegarding visitors be removed. T. Tsitors at construction sites is truction s warrante

0606--06 given 10 CFR 26.401(a) w06 given 10 CFR 26.4 hichshall be applied to the individuals shall be applied to the individ

During the operations phase erations phase [[73.55, Requirements for phmentagainst radiological saboagainst radiological to protected and vitalto protected and vitwith the requiremewith the requirem

CFR 73.55(CFR 73.55(ed vised vis


Page 5 of 14

NRC chose not to modify the rules regarding escorted visitors1. The Statements of Consideration for the Part 262 Rule that incorporated Subpart K into Part 26 state in part, “Therefore, the Subpart K requirements provide a licensee or other entity listed 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.”

Thus, SNC is requesting a limited exemption from 10 CFR 26.4(f) to exclude escorted visitors who perform work for fourteen days or less in a thirty day period from the requirement to be subject to 10 CFR Part 26 Subpart K.

To implement the exemption, an exception to the current commitment to NEI 06-06 would be modified to allow escorted visitors who perform work for fourteen days or less in a thirty day period to the construction site and to allow the escorted visitors to work on security-and safety-related SSCs. Access control administrative procedures would be modified to control visitors by means meeting the intent of 10 CFR 73.55(g)(7)(i)(A-F). Escorts would be trained and controlled by means meeting the intent of 10 CFR 73.55(g)(8).

Changes to VEGP 3 and 4 licensing documents are depicted in Enclosure 2.

3. TECHNICAL JUSTIFICATION OF ACCEPTABILITY

The underlying purpose of 10 CFR Part 26, Subpart K, is to meet the performance objectives of 10 CFR 26.23. As outlined in NEI 06-06, Subsection 5.1.1, the statedobjectives are:

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 individual’s ability to safely and competently perform their duties are managed commensurate with maintaining public health and safety.

Under the proposed exemption, responsibility for adherence to the construction FFD program for the construction visitor would be assigned to the construction escort who would be subject to the construction FFD program; trained on the duties of a construction

1 Federal Register (FR) Vol. 74, N0. 58/Friday, March 27, 2009 Page 139312 Federal Register (FR) Vol. 73, No. 62/Monday, March 31, 2008 Page 16996

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26.4(f) to 26.4(f) to exclude e esca thirty day period a thirty day per from th

rrent commitment to NEI 06rrent commitment to NEI 06--006 would 6m work for m work fourteen days or less in a this in a th

w the escorted visitorsw the escorted visito to work on sececadministrative procedures would be moministrative procedu

ntent of 10 CFR 73.55(g)(7)0 CFR 73.55( (i)(A-F). Esmeeting the intent of tent of 10 CFR 73.55(g)(1

sing documents are depicted in Enclossing documents are depicted i

ON OF ACCEPTABILITYF ACCEPTABILIT

se of 10 CFR Part 26, Subpart K, isR Part 26, Subpart K, isFR 26.FR 26.232 . As outlined in NEI 06utlined in -06,6

duals are trustworthy and reliable asduals are trustworthy and reliabstance abuse;bstanc

Individuals are not under the influencviduals are not under the influencor physically impaired from any csically impaired from any cability to safely and competentability to safely a

3. Measures are establishedMeasures are establwho are not fit to perforare not fit to perfo

4. The construction snstrualcohol; and, and

5.5. The effects effectsand comand commaintamainta


Page 6 of 14

escort; trained on behavior observation techniques; and would be generally knowledgeable of the construction visitor’s assigned duties.

Requirements for control of construction visitors and construction escorts would be based on requirements for visitors and escorts at an operating facility that meet the applicable intent of 10 CFR 73.55(g)(7)(i)(A-F), which provides requirements for the control of visitors. To provide controls for the proposed use of escorted visitors at the VEGP 3 and 4 construction site, an additional exception to the UFSAR, Appendix 1A, entry for RG 5.84 compliance would be implemented. The new controls will provide provisions that:

Implement procedure requirements for processing, escorting, and controlling construction visitors:

o Confirmation of identityo Checking against industry databases for denied accesso Maintenance of a visitor control registero Issuance of a visitor badgeo Requirement that all construction visitors be escorted within the construction

siteo Authorization by a first line supervisor or greater that the construction

visitor(s) have expertise needed to support the construction or supervision of construction of a safety- or security-related SSC

Implement procedures for training and controlling construction escorts:o Require escorts to hold a FFDA for the construction siteo Require understanding of responsibilities to perform escort dutieso Require general knowledge of the construction activities to be performed by

the construction visitorConstruction Site (CCA) escorts will be badged as an FFDA and meet one of the following :

Red Badged which meets the requirements of 10 CFR 26 Sections A-H, and N&O, orAny individual vetted under SNC’s Fleet Unescorted Access Authorization process, that has met all 10 CFR 26 and 10 CFR 73 related requirements for an operational site (Vogtle 1&2, Hatch, and/or Farley), and has been verified and issued an FFDA “equivalency” Red Badge to the construction site.

An additional exception to NEI 06-06 would be taken to define a construction visitor and a construction escort and to clarify that the construction FFD program does not apply to escorted construction visitors. Also, UFSAR Section 13.7, Fitness for Duty, would be revised to clarify that control of construction visitors and construction escorts would be outlined in the exceptions to NEI 06-06 defined in UFSAR Appendix 1A. The proposed changes to the UFSAR would be made under a licensing document change that would not require NRC review and approval, because the change would be based in its entirety

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ases for denied accessses for denied accesrol registerister

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first line supervisor or greater that the cst line supervisor or greater that xpertise needed to support the construce needed to support the constru

of a safety- or securityor security-related SSCrelated SSC

edures for training and controlling consedures for training and controlling consrree escorts to hold a FFDA for the constescorts to hold a FFDA fo

quirquiree understanding of responsibilities understanding of responRequire general knowledge of the consRequire general knowledge of the the construction visitorthe construction vis

onstruction Site (CCA) escortsuction Site (CCA) escorts will bewill befollowing :

Red Badged Red Badged which w meetsN&ON&O, or,Any individual vettny individual vettprocess, that hacess,an operationaperaand issuedd issu

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Page 7 of 14

upon the approved exemption. Markups of the planned revisions to the UFSAR are provided in Enclosure 2 as a reviewer’s aid.

The overall performance objectives of 10 CFR 26.23 would continue to be met because, the SNC FFD program adheres to NEI 06-06, Revision 6 (April 2013), which provides reasonable assurance that the stated objectives of 10 CFR 26.23 are met. The SNC organization and implementing procedures are designed and implemented to provide assurance that guidance contained in NEI 06-06 is met. The site construction security and emergency preparedness manager is responsible for construction site access authorization programs and is functionally aligned with SNC corporate FFD management for administration of the details of the FFD program, (Reference Nuclear Development Quality Assurance Manual (NDQAM), Version 18.0) [ADAMS Accession Number ML18079A532]. SNC is also responsible for administration of site access and FFD programs for contractor/vendor (C/V) construction workers subject to Part 26 requirements. Additional details of the site access authorization and FFD programs whichalign with Part 26 performance objectives are provided below.

The SNC Construction FFD Policy Statement is a comprehensive policy statement that describes the purpose, applicability, responsibilities, and actions required of the SNC FFD program. The policy statement states that all employees and subcontractors with unescorted access authorization to the Vogtle 3 and 4 construction site are expected to be reliable, trustworthy, fit for duty, free from the influences of any substance, legal or illegal, and neither mentally nor physically impaired from any cause which in any way might adversely affect their ability to safely and competently perform their duties. The policy statement prohibits the use, sale, purchase, transfer, dispense, distribution, manufacture or possession of illegal drugs on or off Company time or property; the unauthorized possession, sale, or use of controlled substances on or off Company time or property; and the abuse/misuse of prescription or non-prescription drugs on or off Company time or property. The policy statement outlines potential sanctions that may be taken should an individual fail to meet the provisions of the FFD program. The policy statement also describes the Behavior Observation Program (BOP), which identifies that individuals have a personal responsibility to report FFD concerns about another individual’s behavior to any supervisor, manager, or Medical and FFD Services personnel. Appropriate sanctions for failure to meet expectations of the BOP are also outlined. The policy statement describes various forms of drug and alcohol testing including pre-access, random, for cause, post-accident, and follow-up testing. The policy statement also outlines an individual’s responsibility to report, before entering the construction site, legal actions taken against the individual. All construction workers are trained on the policy statement and are required to sign a statement that they were provided a copy of the FFD Policy Statement.

The SNC FFD program for construction workers is implemented through implementing procedures. The principal implementing procedure contains the high-level requirements

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sion 18.0) [ADAMS Accession Numsion 18.0) [ADAMS Accession Nume for administration of site access anfor administration of

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ectives are provided below.ectives are provided belo

Policy Statement is a comprehensive picy Statement is a comprehenslicability, responsibilities, and actions rey, responsibilities, and actions r

statement states that all employees states that all employeeuthorization to the Vogtle 3 and 4 consthe Vogtle 3 and 4 cons

worthy, fit for duty, free from the influenorthy, fit for duty, free fromther mentally nor physically impaired ther mentally nor physically

sely affect their ability to safely and csely affect their ability to safely aatement prohibits the use, sale, puatement prohibits the use, sale, p

facture or possession of illegal drugsure or possession of illegal drugsauthorized possession, sale, or use of possession, sale, or use of

or property; and the abuse/misuse ofor property; and the aCompany time or property. The polCompany time or propertytaken should an individual fail totaken should an individual fastatement also describes the o describes the individuals have a persove aindividual’s behavior to aindividual’s behaviorAppropriate sanctionAppropriate sanctiopolicy statement dpolicy statement d

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Page 8 of 14

for program application. The purpose of the procedure is to provide reasonable assurance that personnel can perform their tasks in a reliable and trustworthy manner. Accordingly, it is the policy of SNC that all employees and contractors are reliable, trustworthy, fit for duty, free from the influence of any substances, legal or illegal, and not mentally or physically impaired from any cause, including fatigue, which in any way might adversely affect their ability to safely and competently perform their duties. The FFD program is also designed to provide measures for the early detection of persons who are not fit to perform their job duties. Adherence to the procedure ensures compliance with 10 CFR Part 26 requirements applicable to nuclear plant construction activities and NEI 06-06.

These procedures apply to SNC VEGP 3&4 employees; Southern Company employees; VEGP 3&4 construction contractors; and direct contractor/vendors (C/V) of either SNC VEGP 3&4, VEGP 3&4 construction contractors, or Southern Company Affiliate Companies.

The procedure defines the responsibilities of individuals, supervisors, and managers in regard to the FFD program. All SNC employees, Southern Company employees, direct C/V, and Construction contractors/subcontractors are responsible for:

1. Conforming to the requirements of the Fitness-for-Duty Program by reporting for duty free from the effects of fatigue and substances that might impair the individual’s ability to perform his/her duties.

2. Not consuming alcohol within a minimum period of at least five hours preceding any scheduled work shift. Employees shall report any consumption of alcohol within the previous five hours if they are called in to perform work.

3. Reporting any FFD concerns about another individual’s behavior to his/her supervisor, manager, or Medical and FFD Services Department personnel.

4. Reporting to their supervisors any prescription or over-the-counter medication that they are taking which might impair their ability to perform their assigned duties.

5. Submitting proof of physician care and/or a valid prescription for the reported medication upon request by the [Medical Review Officer] MRO during review of FFD drug screen results. SNC employees are also responsible for submitting medical documentation as requested by the MRO or SNC Vogtle 1 - 4 Medical site [registered nurses] RNs for case management purposes.

6. Exercising reasonable diligence and following prudent medical advice to maintain their personal health and medical conditions to ensure their fitness for duty and ability to perform their jobs.

7. Managing their off time to maintain fitness for duty and readiness for work assignments and when experiencing fatigue, self-declaring fatigue to supervision.

trustrusand not and no

ny way might any way. The FFD program i. The FF

sons who are not fit to perfosons who are nocompliance with 10 CFR Part 26 compliance with 10 C

activities and NEI 06activities and NEI 06--06.06.

loyees; Southern Company employeesloyees; Southern Company employct contractor/vendors (C/V) of either Sct contractor/vendors (C/V) of either S

ontractors, or Southern Cntractors, or Southe ompany A

ibilities of individuals, supervisors, andviduals, SNC employees, Southern Company eSNC employees, Southern C

tors/subcontractors are respors/subcontractors are responsible fornsib

requirements of the Fitnessments of the Fitness--forf -Duty Puty Pthe effects of fatigue and substanof fatigue and substan

ability to perform his/her duties.bility to perform his/her duti

suming alcohol within a minisuming alcohol within a min mum perioscheduled work shift. Employees shascheduled work shift. Employee

thin the previous five hours if they are cthin the previous five hours if they are

Reporting any FFD concerns aboporting any FFD concerns abosupervisor, manager, or Medical avisor, manager, or Medical a

4.4. Reporting to their supervisorsReporting to their they are taking which mighhey are taking which

5. Submitting proof of ptting proof of pmedication upon reion uFFD drug screeg smedical docual doc[registered[registered

ExercExerchehe


Page 9 of 14

8. Reporting any legal actions taken against them to Access Authorization prior to entering the construction controlled area (CCA) on their first day back to work.

The procedure defines the types of drug and alcohol testing that is part of the FFD program which are:

1. Pre-access;

2. Random;

3. For cause;

4. Post-accident; and

5. Follow-up.

The procedure also requires that individuals will be placed in the random pool at the time of their pre-access test. The procedure also describes the software program that will be used to track FFD data generated in the FFD and Access program. The procedure describes potential sanctions and discipline that may be taken in the event that FFD program violations occur. Sanctions and disciplinary aspects described in the implementing procedures would not be affected by the proposed use of escorts. The procedure also describes FFD program training requirements. The procedure describes the BOP and training requirements.

Based on the above, SNC concludes that the proposed changes will have no significant adverse impacts on safety and security, because of the defense-in-depth measures SNC has implemented described above. These measures include the use of trained escortswho are knowledgeable of the work performed by construction visitors, and verification of the quality of work in accordance with SNC’s quality assurance program. Verification that safety- and security-related SSCs have been constructed in accordance with the design is provided through inspections, tests, analyses, and acceptance criteria (ITAAC). In addition, verification that safety- and security-related SSCs will perform their intended function will be provided during pre-operational and start-up testing. Reviews of safeguards design information is not in the scope of this exemption request as these badging requirements are implemented in accordance with 10 CFR 73.57.

4. JUSTIFICATION FOR EXEMPTION

10 CFR 26.9, Specific Exemptions, states that the NRC may grant exemptions from the requirements of the regulations provided three conditions are met: 1) the exemption is authorized by law; 2) the exemption will not endanger life or property or the common defense and security; and 3) the exemption is in the public interest.

1. This exemption is authorized by law

The NRC has authority under 10 CFR 26.9 to grant exemptions from the requirements of NRC regulations. Specifically, 10 CFR 26.9 states that the NRC may

DRAFT

of the of the

als will be placed in the random pool at will be placed in thee also describes the software programscribes the s

in the FFD and Access program. Tnd Accnd discipline that may be taken in thend discipline that may be ta

Sanctions and disciplinary aspectsanctions and disciplinary aspwould not be affected bnot be affected by the proposey the propose

es FFD program training requirements. gram training requirement requirements.

oveove,, SNC concludes that tSNC concludes that the proposedhctscts on safety and security, because of on safety and security, beca

mented described above. These measmented described above. These me knowledgeable of the work performedknowledgeable of the work performed

quality of work in accordance with SNC’of work in accordance with SNC’afety- and securitycurity--related SSCs have rela

is provided through inspections, testis provided through inspaddiadd tion, verification that safetyn, verification that sa -function will be provided durl be provided dusafeguards design informatisign informatibadging requirements aremen

JUSTIFICATION FOJUSTIFICATION FO

0 CFR 0 CFR 2626.9, Sp.9, Sprementsrements

eded


Page 10 of 14

grant exemptions from the requirements of 10 CFR Part 26 upon a proper showing. No law exists that would preclude the changes covered by this exemption request. Additionally, granting of the proposed exemption does not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission’s regulations.

Accordingly, this requested exemption is “authorized by law,” as required by 10 CFR 26.9.

2. This exemption will not endanger life or property or the common defense and security

The proposed exemption from the requirements of 10 CFR 26.4(f) would permit SNC to use technical and vendor experts to construct or direct the construction of safety-or security-related SSCs for a limited period of time, as a visitor under the control of an escort subject to the FFD requirements of 10 CFR Part 26.

The proposed exemption does not introduce any new industrial, chemical, or radiological hazards that would present a public health or safety risk, nor does it modify or remove any design or operational controls or safeguards intended to mitigate any existing on-site hazards. Furthermore, the proposed exemption would not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in fuel cladding failures. Accordingly, this proposed exemption does not present an undue risk from any existing or proposed equipment or systems.

Therefore, the requested exemption from 10 CFR 26.4(f) would not present an undue risk to the health and safety of the public.

3. This exemption is in the public interest

The Commission’s values guide the NRC in maintaining certain principles as it carries out regulatory activities in furtherance of its safety and security mission. These principles focus the NRC on ensuring safety and security while appropriately considering the interests of the NRC's stakeholders, including the public and licensees. These principles include Independence, Openness, Efficiency, Clarity, and Reliability. Whether the grant of an exemption to the requirement to require all construction workers constructing or supervising the construction of safety- or security-related SSCs to be subject to the construction FFD program rather than allowing the FFD program requirements to be maintained by a construction-escort would be in the public interest depends on the consideration and balancing of the foregoing factors.

DRAFT

a via vigulationsgulatio

,” as required by ,” as re

operty or the common defense and operty or the common defense a

uirements of 10 CFR ements of 10 CFR 26.4(f)2 would perm to construct truct or direct the construction or direct t

mited period of timetime,, as a visitor under tasrequirements of 10 CFR Part 26.requirements of 10 CFR Par

n does not introduce any new industrials not introduce any new industrihat would present a public health or sa present a public health or sa

any design or operational controls or saoperational controls or sasting onsting on-site hazards. Furthermore, therds. Furth

a new fission product release path, resa new fission product releaslure mode, or create a new sequence olure mode, or create a new sequ

ng failures. Accordingly, this proposed eng failures. Accordingly, this proposefrom anyom any existing or proposed equipmng or proposed equipm

Therefore, the requested exemption fthe requested exemption fundue risk to the health and safetyundue risk to the hea

3.3 This exemption is in the puxemption is in the

The Commission’s valueission’s valuecarries out regulatoryegulThese principles fociplesconsidering theconsidering thelicensees. licensees. TT

nd Reliand Reliatrtr


Page 11 of 14

Concerning Efficiency, the public has an interest in the best possible management and administration of regulatory activities. Regulatory activities should be consistent with the degree of risk management they achieve. Where several effective alternatives are available, the option that minimizes the use of resources should be adopted. Regulatory decisions should be made without undue delay. As applied to using a construction escort to satisfy FFD requirements rather than requiring all safety- and security-related construction workers to meet FFD requirements, the underling means for achieving FFD performance objectives are equivalent andprovides both an effective and an efficient alternative for meeting FFD performance objectives.

Concerning Reliability, once established, regulations should be perceived to be reliable and not unjustifiably in a state of transition. Regulatory actions should always be fully consistent with written regulations and should be promptly, fairly, and decisively administered so as to lend stability to the nuclear construction and planning processes. Here, where the method by which construction FFD performance objectives are met is equivalent, the substantive requirements upon the construction entity are unchanged with the granting of the exemption. Further, the public has an interest in reliability in terms of the stability of the nuclear planning process. This exemption aids planning by allowing escorted construction workers to construct or direct the construction of safety- and security-related SSCs similar to methods used by operating facilities to escort workers to perform work on safety-related SSCs. Thus, regulatory processes are similar between construction and operational phases leading to effective regulatory compliance planning processes.

Concerning Clarity, there should be a clear nexus between regulations and agency goals and objectives whether explicitly or implicitly stated. Agency positions should be readily understood and easily applied. For the reasons explained above, the use of escorted construction workers to meet construction FFD requirements is sufficient for meeting the construction FFD performance objectives and is sufficient to meet the construction FFD requirements. The exemption accordingly recognizes that the use of escorted construction workers is suitable to accomplish the regulatory purpose underlying the requirements of 10 CFR 26.4(f).

The exemption is also consistent with the principles of Independence and Openness; the exemption request considers the regulatory interests involved and explicitly documents the reasons for requesting the exemption.

Accordingly, on balance the exemption is in the public interest.

5.0 RISK ASSESSMENT

DRAFT

ffeffesources source

delay. delay. As appher than her than requiring al

et FFD requirementset FFD requirem , the ectives ectives are equivalentuivalen and

ve for ve fo meeting FFD performance D perfor

regulations should be perceived to be regulations should be perceived to be of transition. transiti Regulatory actions shouldegulato

en regulations and should be promptly, ations and sholend stability to the nuclear o the nuc construction

here the here t method by which construction which ce met is met is equivalentequivale , the substantive reqbstantiv

nchanged with thenged with the granting of the exemgranting of the exet in reliability in terms of the stabilityty in terms of the stability of f

emption aids planning by allowing anning by allowing escoescoectect the cothe construction of safetynstruction of safet - and sec

ed by operating facilities to escort worked by operating facilities to eSSCs. Thus, regulatory processes are sSSCs. Thus, regulatory processe

tional phases leading to effectitional phases leading ve regule reg

Concerning Clarity, there should be a cning Clarity, there should be a cgoals and objectives whether explicitobjectivesbe readilybe readily understood and easily erstoodof escorted construction workescorted construction for meeting the constructioning the constructioconstruction FFD requiren FFD requireof escorted constructiconsunderlying the reqthe re

The exemptioThe exemptiohehe exempexemp

umeume


Page 12 of 14

A risk assessment was not determined to be applicable to address the acceptability of this proposal.

6.0 PRECEDENT EXEMPTIONS

None.

7.0 SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL CONSIDERATION

The proposed exemption has been evaluated against the criteria of 10 CFR 51.21, Criteria for and identification of licensing and regulatory actions requiring environmental assessments, and has been determined to meet the categorical exclusion criteria of 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, as described below, which evaluates the change against the criteria of 10 CFR 51.22(c)(25).

The requested exemption, which seeks to change FFD requirements for construction workers, does not make any changes to the facility or operating procedures and:

i) Does not involve a significant hazards consideration [10 CFR 51.22(c)(25)(i)]. The standards set forth in 10 CFR 50.92(c) were used to determine whether the requested exemption involved a significant hazards consideration:

(1) Does the proposed licensing action involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed exemption from the requirements of 10 CFR 26.4(f) would allow the Licensee to use escorted construction workers to construct or direct the construction of safety- or security-related structures, systems, and components (SSCs). The requested exemption does not alter the design, function, or operation of any plant equipment.

Therefore, granting this exemption would not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Does the proposed licensing action create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

DRAFTONMENTAL ONMENTAL

nst the criteria of 10nst the CFRR 51.21, 51.21,gulatory actions requiring environmentagulatory actions requiring environmen

eet the categorical exclusion criteria of eet the categorical exclusion criteria of clusion; identification of licensing and usion; identification o

al exclusion or otherwise not requiring ion or otherwisbelow, which evaluates the change agaevaluate

which seeks to change seeks to change FFD requiremenFFD requiremeany changes to the facility or operating ges to the facility or operating

e a significant hazards consideration e a significant hazards consideration forth in 10forth in 10 CFRC 50.92(c) were used to d2(c) we

involved a significant hazards considerinvolved a significant hazards

oes the proposed oes the proposed licensing actionlicensing actioprobability or consequences of an arobability or consequences of an a

Response:onse: No.No

DRThe proposed exemption fromThe proposed exethe Licensee to e Licensee to use escoruse econstruction of safetyruction of safety--(SSCs). The requesTheoperation of any n of

Therefore, gefore, probabilitprobabilit

DoeDoe


Page 13 of 14

The requested exemption does not alter the design, function, or operation of any plant equipment. The requested exemption does not create any new failure mechanisms, malfunctions, or accident initiators.

Therefore, granting this exemption does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Does the proposed licensing action involve a significant reduction in a margin of safety?

Response: No.

The requested exemption does not affect an SSC, SSC design function, or method of performing or controlling a design function. Construction FFD requirements are not related to or used to establish the design bases of an SSC nor are they considered in the safety analyses. Furthermore, the requested exemption does not exceed or alter a design basis or safety limit.

Therefore, granting this exemption does not involve a significant reduction in a margin of safety.

Therefore, it is concluded that the requested exemption does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of “no significant hazards consideration” is justified.

ii) Does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite [10 CFR 51.22(c)(25)(ii)]. The requested exemption does not alter the design, function, or operation of any plant equipment. There are no changes to effluent types, plant radiological or non-radiological effluent release quantities, any effluent release path, or the functionality of any design or operational features credited with controlling the release of effluents during plant operation or construction.

Therefore, it is concluded that the proposed exemption does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

iii) Does not involve a significant increase in individual or cumulative public or occupational radiation exposure [10 CFR 51.22(c)(25)(iii)]. There are no changes to plant radiation zones, nor any change to controls required under 10 CFR Part 20which preclude a significant increase in occupational radiation exposure.

Therefore, it is concluded that the proposed exemption does not involve a significant increase in individual or cumulative public or occupational radiation exposure.

DRAFT

sibility of a nesibility valuated.valuate

a significant reduction in a significant re

ect an SSC, SSC design function, or ect an SSC, SSC design function, or a design function.design function. Construction FFD Co

or used to to establish the design bases ofestablish thee safety analyses. yses. Furthermore, the reqFur

d or alter a design basis or safety limit.d or alter a design basis or

his exemption does not involve a significxemption does not involve a sign

oncluded that the requested exemption cluded that the requested exemption deration under the standards set forth ideration under the standard

y, a finding of “no significant hazards coy, a finding of “no significant h

not involve a significant change in tnot involve a significant change inounts of any effluents that may be relents of any effluents that may be rele

equested exemption does not alter thed exemption does not alter thequipment. There are no chang. There are no changnonnon--radiological effluent releaseradiological efffunctionality of any design or opfunctionality of any desof effluents during plant operaents during plant o

Therefore, it is concludeit is concludechange in the types oe tybe released offsited offs

)) Does not inDoes not inoccupationoccupation

nt rant ra


Page 14 of 14

iv) Does not involve a significant construction impact [10 CFR 51.22(c)(25)(iv)]. The requested exemption does not alter the materials or methods of constructing or testing any SSCs. No change to the construction of the facility is being made as a result of this exemption.

Therefore, it is concluded that the proposed exemption does not involve a significant construction impact.

v) Does not involve a significant increase in the potential for or consequences from radiological accidents [10 CFR 51.22(c)(25)(v)]. The requested exemption does not alter the design, function, or operation of any plant equipment. There are no changes to plant radiation zones, nor any change to controls required under 10 CFR Part 20 which preclude a significant increase in occupational radiation exposure.

Therefore, it is concluded that the proposed exemption does not involve a significant increase in the potential for or consequences from radiological accidents.

vi) Involves employment suitability requirements related to fitness for duty as obtaining a fitness-for-duty authorization is a prerequisite for working on or directing work on safety- and security-related SSCs. [10 CFR 51.22(c)(25)(vi)(E)].

Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(25). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this exemption.

8.0 CONCLUSION

The requested exemption would permit SNC to use technical and vendor experts to construct or direct the construction of safety- and security-related SSCs for a limited period of time as a visitor under the control of an escort subject to the FFD requirements of 10 CFR Part 26. The exemption is necessary because SNC expects to require the use of technical and vendor experts to provide direction, expertise, and oversight during the inspection and testing phases of the project.

The exemption request meets the requirements of 10 CFR 26.9, Specific Exemptions, in that the requested exemption is authorized by law and will not endanger life or property or the common defense and security and is in the public interest.

9.0 REFERENCES

NoneDRAFT

d

not involve a signot inv

ntial for or consequences fromtial for or consequThe requested exemption does not The requested exemption

ant equipment. ant equ There are no changes re no chcontrols required under 10control CFRCFR PartPa 2

cupational radiation exposure.cupational radiatio

posed exemption does not involve a siged exemption doessequences from radiological accidents.s from radiolo

ty requirements related to fitness for duty requirements related to fion is n is a prerequisite for working on a prerequisite for working o

ed SSCs. SCs [10[10 CFRCFR 51.22(c)(25)(vi)(51.22(c)(25)(vi)(EE((( )]E

sed exemption meets the eligibility criteon meets the eligibility crit100 CFRC 51.22(c)(25). Therefore, c)(25). Ther pursurs

pact statement or environmental assespact statement or environmeh the issuance of this exemption.h the issuance of this exempti

SIONSION

requested exemption would permit Sted exemption would permit Sonstruct or direct the construction of safnstruct or direct the co

of time as a visitor under the control of time as a visitor underCFR Part 26. CFR Part 26. The exemption is nThe exemptiotechnical and vendor experts d vendor expertsinspection and testing phasetesting phase

The exemption request The exemption requthat the requestthat the requested exed ehe common defehe common defe

ERENCEERENCE

Southern Nuclear Operating Company

ND-YY-XXXX

Enclosure 2

Vogtle Electric Generating Plant Units 3 and 4

Reviewers Aid: Licensing Document Changes Supporting the Exemption Request

Insertions Denoted by Blue Underline and Deletions by Red StrikethroughOmitted text is identified by three asterisks ( * * * )

(This Enclosure consists of [XX] pages, including this cover page)

DRAFT

enerating Plant Units 3 and 4Units 3 a

ocument Changes Supporting the Exemcument Changes Supporting the Exem

ertions Denoted by rtions Denoted by Blue Underlin

DROmitted text is identifiOmitted text

ND-18-0754Enclosure 2Reviewers Aid: Licensing Document Changes Supporting the Exemption Request

Page 2 of 5

The UFSAR Appendix 1A entry for conformance with Regulatory Guide (RG) 5.84 is revisedto reflect the exceptions taken to NEI 06-06, Revision 6 (April 2013).

Note: This markup reflects text which was incorporated into the current version of the UFSAR and further revised by LAR-18-018.

Reg. Guide 5.84, Rev. 0, 7/15 – Fitness-for-Duty Programs at New Reactor Construction Sites

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

General 10 CFR Part 26NEI 06-06 Rev. 6 (April 2013)

Exception Exceptions to guidance provided in NEI 06-06 Rev. 6 (April 2013) are as described below:The third paragraph of Section 2.1, Construction, is revised to read:

The FFD program for construction applies to individuals specified in 10CFR 26.4(f) who are constructing or directing the construction of safety-or security-related SSCs, unless the construction site entity chooses to subject these individuals to a full FFD program that meets all of the requirements in 10 CFR Part 26, except Subparts I and K, or are escorted by a qualified individual subject to the construction FFD program. Thus, the FFD program for construction applies to individuals who perform the following types of activities:A definition is added to define a limited FFD authorization as follows:Limited Fitness-for-Duty (FFD) Authorization (FFDA) - An authorization granted for a limited period of time to potential 10 CFR 26.4(f) workers that have not completed all elements for FFDA for individuals subject to 10 CFR Part 26 Subpart K. Workers granted a Limited FFDA shall be administratively prevented from constructing or directing construction of safety- or

DRAFT

urrurr

Reactor ConstructReacto

documented below.documented below.

xceptions to guidance provided in xceptions to guidance provided in NEI 06NEI 0 -06 Rev. 6 (April 2013) are as v. 6 (April 2013) are as described below:described below:The third paragraph of Section The third parag

AFTConstruction, is revised to reConstruction

AFThe FFD program for coFFD p

AFapplies to individuals s to ind

AFCFR 26.4(f) who aCFR 26.4(f) whoAFdirecting the condirecting the conAFor securityor security--rerAconstructiouctioAsubject tAprogrAreqA


Page 3 of 5

security-related structures, systems, and components (SSCs).A definition is added to define a construction escort as follows:Construction Escort – An individual subject to the construction FFD program assigned to escort and observe a construction worker engaged in constructing or directing construction of a safety- or security-related SSC and is not subject to the construction FFD program.A definition is added to define a construction visitor as follows:Construction Visitor – An individual determined by the construction entity to have expertise needed to support the construction or supervision of construction of a safety- or security-related SSC for fourteen days or less in a thirty day period and authorized by a first line supervisor or greater, but who is not subject to the construction FFD program.Insert additional required procedures to Section 5.2, Procedures as follows:

14. Procedures for processing, escorting, and controlling construction visitors to include:a. Confirmation of identityb. Checking against

industry databases for denied access

c. Maintenance of a visitor control register

d. Requirement that all construction visitors be escorted within the construction site

15. Procedures for training and controlling construction escorts to include:

DRAFT

dede

Ts follows follo

Tort ort –– An individA

Tconstruction FFD constructTsigned to escort and signed to escoTa construction worker construction workTed in constructing ed in constructing or directing or dire

FTstruction structio of a safety- or securityr securi -

FTelated SSC elated S and is not subjectct to the to th

FTconstruction FFD program.construction FFFTA definition is added to define a A definition is addFTconstruction visitor as follows:construction vi

AFT

Construction Visitor onstructio – An in

AFdetermined by the constrmined

AFto have expertise neee expert

AFthe construction or the construction AFconstruction of aconstruction of aAFrelated SSC related SSC foAin a thirty din a thirty dAa first lineAwho isAFFDA


Page 4 of 5

a. Requiring escorts to hold a FFDA for the construction site

b. Requiring understanding of responsibilities to perform escort duties

c. Requirement to be generally knowledgeable of the construction activities to be performed by the construction visitor

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. 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)].Section 8. Reviewing Official, the first sentence of the first paragraph is revised to read:The construction site entity or as applicable, approved contractors/vendors (C/V), is required to designate in writing one or more individuals as a reviewing official to make FFDA (including Limited FFDA) determinations relative to a potential construction site workforce member’s trustworthiness and reliability and fitness for duty.Section 9.2, Types of FFDA, is revised to add a fourth type – Limited FFDASection 9.3, Granting FFDA and FFDA Elements, is revised to add an introductory paragraph that reads:A construction site entity may grant a Limited FFDA for a period of up to five business days upon successful completion and documentation of the elements specified within Section 9.1,

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ng ng

Terstanding erstand

Tsponsibilitiessponsi to

Tperform escort dutieperform Tc.c. Requirement to be RequiremeTgenerally generally Tknowledgeable of the geable o

FTconstruction activities to n activit

FTbe performed by the by the

FTconstruction visitorconstruction visitorFTSection 6.2.1, Section 6.2.1, PrePr -Assignment- , isclarified to allow an individual tclarified to allolimited access to the construimited acceunder the conditions specder the cSection 9.3on 9.3. An individ. eligible for limited acor limiteconstruction site uconstruction site specified in Secspecified in SecRevision 6 (ARevision 6 (ASection 8sentenrev


Page 5 of 5

as appropriate, except the requirement for documentation of a passed drugtest.

DRAFT


Page 6 of 5

The site-specific information of UFSAR Section 13.7 is revised to clarify that escorted construction workers may construct or direct the construction of safety or security-related SSCs.

The construction FFD program is consistent with NEI 06-06 (Reference 201) as endorsed by NRC Regulatory Guide 5.84, Revision 0, as amended by the exceptions documented in Appendix 1A, 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. 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) except when escorted by a construction escort.Control of construction visitors and construction escorts is described in the UFSAR Appendix 1A entry for Regulatory Guide 5.84.

* * *

DRAFT

201) as endorsed201) aons documented in ons docume

cribed in 10 CFR 26.65. NEIcribed in 10 CFRon of safetyon of s - and securitynd secu -

where the new reactor will be where the new reactor willnnel, as further described in NEI 06nnel, as further described in NEI -

nuclear material in the form of fuel nuclear material in the form of fuel o the operations FFD program that meeo the operations FFD program that mee

hrough H, N, and O. ough H, N, and O. At the establishmeAescorted access will meet the requiremeed access will me

d NEI 06-06 (Reference 201) and the F6 (Referencthe changes.

n is provided:provided:d in the Physical Security Plan, AppendPhysical Security Plan, Append

R Part 26 requirements are implementequirements are implemenriptions provided p in Table 13.4in Table 13 -201.

s & First Line Supervisors are covered s & First Line Supervisors art K) t K) except when escorted by a construexcept when escorted by a

RAtruction visitors and construction escortruction visitors and construction eRAA entry for entry Regulatory Guidelatory Guide 5.84.RA* ** *

Documents

2018/10/25 Vogtle COL Docs - SNC draft Request for ... · Part 26 PaVisitor Access ReVisitor 2)Vogtle Electric GeneVogtle Electric Gen Licensing Documecensing Docume. U.S. Nuclear