ML031611033
| ML031611033 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 06/02/2003 |
| From: | O'Connor T Public Service Enterprise Group |
| To: | Collins S Office of Nuclear Reactor Regulation |
| References | |
| EA-03-038, LRN-03-0248 | |
| Download: ML031611033 (3) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hanoocks Bridge, New Jersey 08038-0236 JUN 0 ?l03 LRN-03-0248 Q PSEG Mr. Samuel J. Collins, Director Nuclear LLC Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 Salem Units I and 2 Docket Nos. 50-272 and 50-311 Facility Operating Licenses DPR-70 and DPR-75, Hope Creek Generating Station Docket No. 50-354 Facility Operating License No. NPF-57
Subject:
Answer, Response and Request for Clarification in Response to April 29, 2003, Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Securiy Force Personnel (EA-03-038)
Dear Mr. Collins:
By this letter PSEG Nuclear LLC (PSEG) hereby answers the April 29, 2003, Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel (EA-03-038) (Order).
Pursuant to Section IV of the Order and 10 CFR §2.202, PSEG requests an extension of time in which to submit information in response to the Order and to request a hearing. In addition, PSEG requests the NRC provide certain information to ensure PSEG fully understands the underlying bases of the Order and, therefore, can most effectively implement its individual requirements.
Section II of the Order states that, "[t]he Commission has determined that the security measures addressed by the enclosed compensatory measures are required to be implemented by licensees as prudent measures to address issues that may arise from work-hour related fatigue of nuclear facility security force personnel." The Order does not explain the bases for the specific limits and other requirements described in the Order in sufficient detail for PSEG to understand the rational for the requirements. PSEG therefore requests that the NRC provide: the bases for the specific limits prescribed in the Order; the bases upon which it relied to establish a linkage between the specific limits chosen and any causal relationship to fatigue that would otherwise occur if those individual or group work hour limits were to be exceeded; and information pertaining to any events or incidents where the NRC has determined that fatigue was the cause or a major contributing factor in those events or incidents.
95-2168 REV. 7199
Mr. Samuel Collins, Director JUN 0 2 2003 LR-N03-0248 As provided for in Section IV of the Order, good cause for granting an extension of time to respond to the Order and to request a hearing is shown in that no basis or rationale for the Order has been demonstrated. Thus, PSEG requests that the Director, Nuclear Reactor Regulation extend the time periods for responding to the Order (including, specifically, Sections B.1 and 2) and for requesting a hearing from the time period specified in the Order until 35 days after the date that the NRC provides the bases for the work hour limits in the Order. Section 1II. C. of the Order requires that "[a]ll licensees shall within thirty-five (35) days of the date of this Order, submit to the Commission a schedule for achieving compliance with each requirement described in Attachment 2 of the Order. Subject to the foregoing request for information concerning the bases for the Order and the request for an extension of time in accordance with Section IV, PSEG will achieve compliance with all applicable requirements not later than October 29, 2003.
PSEG also hereby confirms its understanding that the Commission intends to exercise enforcement discretion to accommodate issues which may arise as licensees, in good faith, take reasonable actions to implement the specific requirements of this Order. We further understand that the Commission will exercise enforcement discretion for the period necessary to resolve such issues or questions, and to integrate the requirements of this Order with the orders issued February 25, 2002, as well as with other pertinent regulatory requirements, and our safeguards contingency plans, security plans and security officer training and qualification plans.
Should you have any questions, please contact Robin Ritzman at (856) 339-1445.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 4
Si rel Vic tresident - Operations JCN
Mr. Samuel Collins, Director LR-N03-0248 C
Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Robert Fretz, Project Manager - Salem U. S. Nuclear Regulatory Commission Mail Stop 08B2 Washington, DC 20555-0001 Mr. Richard Ennis, Project Manager - Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08B2 Washington, DC 20555-0001 USNRC Resident Inspector Office (X24)
Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P.O. Box 415 Trenton, NJ 08625 JUN 0 i
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