ML24340A045

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NRR E-mail Capture - Acceptance Review for Sequoyah Unit 2 Exemption Request Regarding Requirements of 10 CFR 26.205, Fitness for Duty Programs - Work Hours (L-2024-LLE-0029)
ML24340A045
Person / Time
Site: Sequoyah Tennessee Valley Authority icon.png
Issue date: 12/05/2024
From: Perry Buckberg
NRC/NRR/DORL/LPL2-2
To: Baron J
Tennessee Valley Authority
Buckberg P
References
L-2024-LLE-0029
Download: ML24340A045 (3)


Text

From:

Perry Buckberg Sent:

Thursday, December 5, 2024 8:23 AM To:

Baron, Jesse Shawn; Taylor, Andrew Charles

Subject:

Acceptance Review - Sequoyah Nuclear Plant, Unit 2 - Exemption Request for 10 CFR Part 26 Jesse Baron / Andy Taylor, By letter dated November 27, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24332A119), the Tennessee Valley Authority (TVA or the licensee) submitted an exemption request for Sequoyah Nuclear Plant, Unit 2. The purpose of this email is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the request has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

The proposed exemption would allow the use of the less restrictive work hour limitations described in Title 10 of the Code of Federal Regulations (CFR), Section 26.205(d)(4) to support activities during a specific maintenance window in the ongoing Sequoyah Nuclear Plant, Unit 2 extended turbine generator outage. The regulations in Section 26.205(d)(4) of 10 CFR provide, in part, that During the first 60 days of a unit outage, licensees need not meet the requirements of § 26.205(d)(3) or (d)(7) for individuals specified in § 26.4(a)(1) through (a)(4), while those individuals are working on outage activities. However, the licensee shall ensure that the individuals specified in § 26.4(a)(1) through (a)(3) have at least 3 days off in each successive (i.e., non-rolling) 15-day period and that the individuals specified in § 26.4(a)(4) have at least 1 day off in any 7-day period.

The NRC staff has reviewed your request and concluded that it does provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the requested exemption in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review, as compared to the detailed technical review, there may be instances in which issues that impact the NRC staff's ability to complete the detailed technical review are identified, despite completion of an adequate acceptance review. You will be advised of any further information needed to support the NRC staff's detailed technical review by separate correspondence.

Based on the information provided in your submittal and discussions during the pre-licensing meeting on November 20, 2024, the NRC staff has estimated that this exemption request will take approximately 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> to complete. The NRC staff expects to complete this review by December 31, 2024. If there are emergent complexities or challenges in our review that would cause changes to the initial forecasted completion date or significant changes in the forecasted hours, the reasons for the changes, along with the new estimates, and the contractor resources will be communicated during the routine interactions with the assigned project manager.

These estimates are based on the NRC staff's initial review of the request and they could change, due to several factors including requests for additional information, unanticipated addition of scope to the review, and review by NRC advisory committees or hearing-related

activities. Additional delay may occur if the submittal is provided to the NRC in advance or in parallel with industry program initiatives or pilot applications.

If you have any questions, please contact me at (301)415 1383 or by e-mail at Perry.Buckberg@nrc.gov.

Thanks, Perry Buckberg Senior Project Manager / Agency 2.206 Petition Coordinator U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation office: (301)415-1383 perry.buckberg@nrc.gov Mail Stop O-8B1a, Washington, DC, 20555-0001

Hearing Identifier:

NRR_DRMA Email Number:

2659 Mail Envelope Properties (PH0PR09MB76743782C8417204EDD323859A302)

Subject:

Acceptance Review - Sequoyah Nuclear Plant, Unit 2 - Exemption Request for 10 CFR Part 26 Sent Date:

12/5/2024 8:23:01 AM Received Date:

12/5/2024 8:23:00 AM From:

Perry Buckberg Created By:

Perry.Buckberg@nrc.gov Recipients:

"Baron, Jesse Shawn" <jsbaron@tva.gov>

Tracking Status: None "Taylor, Andrew Charles" <actaylor@tva.gov>

Tracking Status: None Post Office:

PH0PR09MB7674.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 4078 12/5/2024 8:23:00 AM Options Priority:

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