ML092680190

Project, Units 1 and 2 - Comments, Draft Request for Exemption from Certain Requirements of Revised 10 CFR 26.205(c) and (D) During Severe Weather Conditions (TAC Nos. ME2259 and ME2260)

ML092680190
Person / Time
Site:	South Texas
Issue date:	09/24/2009
From:	South Texas
To:	Office of Nuclear Reactor Regulation
Thadani, M C, NRR/DORL/LP4, 415-1476
Shared Package
ML092680178	List: ML092680182 ML092680190
References
TAC ME2259, TAC ME2260
Download: ML092680190 (1)

Text

Comments on STP Nuclear Operating Company's Draft Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue.

Following are NRC comments on draft request for exemption from requirements of 10 CFR Part 26, regarding managing fatigue.

• Please state if your request is for temporary exemption. After the rule is revised to address severe weather, would the exemption end?

• The request should state that the exemption is allowed by law.

• On page 10, under justification of exemption, criterion 1, 10 CFR 26.9 is cited as authorizing law. 10 CFR 26.9 is NRC rule. Atomic Energy Act of 1954, as amended is the law.

• The request should discuss precedents, e.g. how Turkey Point managed Andrew and how River Bend managed Katrina and Rita. What was NRC's response to licensee's actions?

• Include an environmental assessment as required under Section 21 of Part 51.