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MONTHYEARLR-N09-0248, Request for Exemption from Physical Security Requirements2009-11-0303 November 2009 Request for Exemption from Physical Security Requirements Project stage: Request LR-N09-0249, Request for Exemption from Physical Security Requirements (Non-Safeguards Version)2009-11-0303 November 2009 Request for Exemption from Physical Security Requirements (Non-Safeguards Version) Project stage: Request ML0932000702009-11-12012 November 2009 Email Documenting Conference Call on Part 73 Exemption Requests for Hope Creek and Salem - TACs ME2525, ME2526 and ME2527 Project stage: Other ML0934405582009-12-10010 December 2009 Notice of Closed Meeting with PSEG Nuclear LLC (PSEG) to Discuss Exemption from Schedular Requirements of 10 CFR 73.55 for Hope Creek Generating Station and Salem Nuclear Generating Station, Unit Nos. 1 and 2 Project stage: Meeting LR-N09-0314, Request for Scheduler Exemption from Certain Aspects of the New Physical Security Requirements2009-12-22022 December 2009 Request for Scheduler Exemption from Certain Aspects of the New Physical Security Requirements Project stage: Request ML0935006442009-12-28028 December 2009 Summary of Closed Meeting with PSEG Nuclear LLC, Regarding Request for Exemption from Schedular Requirements of 10 CFR 73.55 for Hope Creek and Salem Nuclear Generating Station, Unit Nos. 1 and 2 (TAC Nos. ME2525, M2528 and ME2527 Project stage: Meeting ML1000603672010-01-0606 January 2010 Acceptance Review for TACs ME2525, ME2526 and ME2527 - Hope Creek and Salem 1 and 2 - Exemption from Part 73 Project stage: Acceptance Review ML1000500392010-01-29029 January 2010 and Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Environmental Assessment and Finding of No Significant Impact Project stage: Other ML1000500542010-01-29029 January 2010 FRN: General Notice. Hope Creek Generating Station & Salem Nuclear Generating Station, Unit Nos. 1 and 2 Environmental Assessment and Finding of No Significant Impact Project stage: Request ML1001203072010-02-25025 February 2010 and Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Exemption from the Requirements of 10 CFR Part 73, Section 73.55 Project stage: Approval LR-N10-0171, Stations Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 102010-05-25025 May 2010 Stations Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 10 Project stage: Other 2009-12-28
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Category:Letter type:LR
MONTHYEARLR-N23-0079, Special Report 23-02-00 Pursuant to the Requirements of Salem Unit 1 Technical Specification 3.3.3.7, Action 10, for the Unit 1 Main Steam Line Rad Monitor Inoperable for Greater than Seven Days2023-12-0707 December 2023 Special Report 23-02-00 Pursuant to the Requirements of Salem Unit 1 Technical Specification 3.3.3.7, Action 10, for the Unit 1 Main Steam Line Rad Monitor Inoperable for Greater than Seven Days LR-N23-0077, Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - Annual Report 2023 & 30 Day Report for Salem Unit 1 Upflow Conversion2023-11-29029 November 2023 Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - Annual Report 2023 & 30 Day Report for Salem Unit 1 Upflow Conversion LR-N23-0072, Core Operating Limits Report Cycle 302023-11-0101 November 2023 Core Operating Limits Report Cycle 30 LR-N23-0065, Submittal of 2023 Annual 10 CFR 50.46 Report2023-10-0202 October 2023 Submittal of 2023 Annual 10 CFR 50.46 Report LR-N23-0045, and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement2023-09-0808 September 2023 and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement LR-N23-0055, Special Report 272/23-01-00, Pursuant to the Requirements of Technical Specification 3.3.3.1, Action 23, for the Vent Noble Gas Rad Monitor Inoperable for Greater than Seven Days2023-08-0303 August 2023 Special Report 272/23-01-00, Pursuant to the Requirements of Technical Specification 3.3.3.1, Action 23, for the Vent Noble Gas Rad Monitor Inoperable for Greater than Seven Days LR-N23-0052, Retest Schedule for Drywell to Suppression Chamber Vacuum Breakers Per Technical Specification 4.6.2.12023-07-31031 July 2023 Retest Schedule for Drywell to Suppression Chamber Vacuum Breakers Per Technical Specification 4.6.2.1 LR-N23-0054, In-Service Inspection Activities2023-07-26026 July 2023 In-Service Inspection Activities LR-N23-0042, Spent Fuel Cask Registration2023-07-12012 July 2023 Spent Fuel Cask Registration LR-N23-0046, Emergency Plan Document Revisions Implemented June 28, 20232023-07-10010 July 2023 Emergency Plan Document Revisions Implemented June 28, 2023 LR-N23-0005, License Amendment Request to Amend Technical Specifications (TS) 6.8.4.f for Permanent Extension of Type a and Type C Leak Rate Test Frequencies2023-06-23023 June 2023 License Amendment Request to Amend Technical Specifications (TS) 6.8.4.f for Permanent Extension of Type a and Type C Leak Rate Test Frequencies LR-N23-0035, 2022 Annual Radioactive Effluent Release Report (ARERR)2023-04-27027 April 2023 2022 Annual Radioactive Effluent Release Report (ARERR) LR-N23-0034, 2022 Annual Radiological Environmental Operating Report (AREOR) - Salem Nuclear Generating Station, Unit Nos. 1 and 2 and Hope Creek Generating Station2023-04-27027 April 2023 2022 Annual Radiological Environmental Operating Report (AREOR) - Salem Nuclear Generating Station, Unit Nos. 1 and 2 and Hope Creek Generating Station LR-N23-0033, Core Operating Limits Report Cycle 272023-04-26026 April 2023 Core Operating Limits Report Cycle 27 LR-N23-0010, License Amendment Request Revision of Technical Specification (TS) to Delete TS Section 5.5 - Meteorological Tower Location2023-04-21021 April 2023 License Amendment Request Revision of Technical Specification (TS) to Delete TS Section 5.5 - Meteorological Tower Location LR-N23-0009, License Amendment Request (LAR) to Revise the Hope Creek Trip and Standby Auto-start Logic Associated with Safety Related Heating, Ventilation and Air Conditioning (HVAC) Trains2023-04-18018 April 2023 License Amendment Request (LAR) to Revise the Hope Creek Trip and Standby Auto-start Logic Associated with Safety Related Heating, Ventilation and Air Conditioning (HVAC) Trains LR-N23-0024, Submittal of Hope Creek Generating Station Technical Specification Bases Changes2023-03-29029 March 2023 Submittal of Hope Creek Generating Station Technical Specification Bases Changes LR-N23-0006, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-24024 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations LR-N23-0019, and Salem Generating Station, Units 1 and 2 - Guarantees of Payment of Deferred Premiums2023-03-21021 March 2023 and Salem Generating Station, Units 1 and 2 - Guarantees of Payment of Deferred Premiums LR-N23-0016, and Salem Generating Station, Units 1 and 2 - Report of Changes, Tests, and Experiments2023-02-28028 February 2023 and Salem Generating Station, Units 1 and 2 - Report of Changes, Tests, and Experiments LR-N23-0018, Technical Specification 6.9.1.5.b - 2022 Annual Report of SRV Challenges2023-02-27027 February 2023 Technical Specification 6.9.1.5.b - 2022 Annual Report of SRV Challenges LR-N23-0012, Annual Property Insurance Status Report2023-02-24024 February 2023 Annual Property Insurance Status Report LR-N23-0014, Stations Submittal of 2022 Annual Report of Fitness for Duty Performance Data Per 10 CFR 26.203(e) and 10 CFR 26.7172023-02-23023 February 2023 Stations Submittal of 2022 Annual Report of Fitness for Duty Performance Data Per 10 CFR 26.203(e) and 10 CFR 26.717 LR-N23-0003, Response to Requests for Additional Information Salem Unit 2 Relief Request S2-I4R-2112023-02-0101 February 2023 Response to Requests for Additional Information Salem Unit 2 Relief Request S2-I4R-211 LR-N23-0011, In-Service Inspection Activities - 90 Day Report: Twenty-Fourth Refueling Outage2023-01-19019 January 2023 In-Service Inspection Activities - 90 Day Report: Twenty-Fourth Refueling Outage LR-N22-0096, and Salem Generating Station, Units 1 and 2 - Request for Threshold Determination2023-01-0505 January 2023 and Salem Generating Station, Units 1 and 2 - Request for Threshold Determination LR-N22-0095, Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - Annual Report 20222022-12-20020 December 2022 Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - Annual Report 2022 LR-N22-0094, Emergency Plan Document Revisions Implemented November 21, 20222022-12-14014 December 2022 Emergency Plan Document Revisions Implemented November 21, 2022 LR-N22-0092, Response to Final Iolb Request for Additional Information for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG2022-12-0909 December 2022 Response to Final Iolb Request for Additional Information for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG LR-N22-0091, Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments2022-12-0202 December 2022 Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments LR-N22-0084, Response to Final Request for Additional Information for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG (EPID L- 2022-LLA-0095)2022-11-17017 November 2022 Response to Final Request for Additional Information for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG (EPID L- 2022-LLA-0095) LR-N22-0090, Supplement to Submittal of Salem Generating Station Updated FSAR, Revision 33, 10 CFR 71.106 Review Results and 10 CFR 54.37(b) Review Results for Salem2022-11-10010 November 2022 Supplement to Submittal of Salem Generating Station Updated FSAR, Revision 33, 10 CFR 71.106 Review Results and 10 CFR 54.37(b) Review Results for Salem LR-N22-0075, 2022 Annual 10 CFR 50.46 Report2022-09-30030 September 2022 2022 Annual 10 CFR 50.46 Report LR-N22-0065, Submittal of Relief Request Associated with the Fourth Inservice Inspection (ISI) Interval Limited Examinations2022-09-27027 September 2022 Submittal of Relief Request Associated with the Fourth Inservice Inspection (ISI) Interval Limited Examinations LR-N22-0074, Emergency Plan Evacuation Time Estimate2022-09-15015 September 2022 Emergency Plan Evacuation Time Estimate LR-N22-0066, License Amendment Request (LAR) to Relocate Technical Specifications (TS) Requirements for Reactor Head Vents to the Technical Requirements Manual (TRM)2022-08-31031 August 2022 License Amendment Request (LAR) to Relocate Technical Specifications (TS) Requirements for Reactor Head Vents to the Technical Requirements Manual (TRM) LR-N22-0063, Spent Fuel Cask Registration2022-08-10010 August 2022 Spent Fuel Cask Registration LR-N22-0068, In-Service Inspection Activities - 90-Day Report2022-08-10010 August 2022 In-Service Inspection Activities - 90-Day Report LR-N22-0012, License Amendment Request to Amend the Technical Specifications to Revise and Relocate the Reactor Coolant System Pressure and Temperature Limits and Pressurizer Overpressure Protection System Limits to a Pressure and Temperature2022-08-0707 August 2022 License Amendment Request to Amend the Technical Specifications to Revise and Relocate the Reactor Coolant System Pressure and Temperature Limits and Pressurizer Overpressure Protection System Limits to a Pressure and Temperature LR-N22-0062, Spent Fuel Cask Registration2022-07-21021 July 2022 Spent Fuel Cask Registration LR-N22-0006, License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 Hours to 14 Days2022-06-29029 June 2022 License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 Hours to 14 Days LR-N22-0051, License Amendment Request to Relocate Technical Specification Facility/Unit Staff Qualification Requirements to Quality Assurance Topical Report2022-06-22022 June 2022 License Amendment Request to Relocate Technical Specification Facility/Unit Staff Qualification Requirements to Quality Assurance Topical Report LR-N22-0044, Emergency Plan Document Revisions Implemented November, 20212022-05-19019 May 2022 Emergency Plan Document Revisions Implemented November, 2021 LR-N22-0043, Core Operating Limits Report - Cycle 292022-05-0909 May 2022 Core Operating Limits Report - Cycle 29 LR-N22-0041, 2021 Annual Radioactive Effluent Release Report (Rerr)2022-04-28028 April 2022 2021 Annual Radioactive Effluent Release Report (Rerr) LR-N22-0040, 2021 Annual Radiological Environmental Operating Report2022-04-28028 April 2022 2021 Annual Radiological Environmental Operating Report LR-N22-0039, Emergency Plan Document Revisions Implemented March 24, 20222022-04-21021 April 2022 Emergency Plan Document Revisions Implemented March 24, 2022 LR-N21-0052, Request for Relief from ASME Code Defect Removal for Service Water Buried Piping2022-04-0707 April 2022 Request for Relief from ASME Code Defect Removal for Service Water Buried Piping LR-N22-0023, Guarantees of Payment of Deferred Premiums2022-03-21021 March 2022 Guarantees of Payment of Deferred Premiums LR-N22-0022, Response to Request for Additional Information Relief Request S1-14R-210, Alternative Examination of Welds2022-03-21021 March 2022 Response to Request for Additional Information Relief Request S1-14R-210, Alternative Examination of Welds 2023-09-08
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Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 0 PSEG Nuclear L.L. C.
10 CFR 73.5 LR-N09-0314 December 22, 2009 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SALEM GENERATING STATION - UNIT 1 and UNIT 2 FACILITY OPERATING LICENSE NOS. DPR 70 and DPR-75 NRC DOCKET NOS. 50-272 and 50-311 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 NRC DOCKET NO. 50-354
Subject:
REQUEST FOR SCHEDULER EXEMPTION FROM CERTAIN ASPECTS OF THE NEW PHYSICAL SECURITY REQUIREMENTS.
(NON-SAFEGUARDS VERSION).
In accordance with the requirements of 10CFR 73.5, PSEG Nuclear LLC requests the Nuclear Regulatory Commission (NRC) approve an exemption of the compliance date for specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials" for the combined Salem - Hope Creek Generating Station site by extending the deadline for the implementation of certain measures required by the new rule.
The NRC issued a Final Rule for new security requirements in the Federal Register dated March 27, 2009. Pursuant to the Final Rule, the new security requirements must be implemented by March 31, 2010. PSEG Nuclear has evaluated these new requirements and determined that many of the new requirements can be implemented within this implementation period. PSEG Nuclear has determined; however, that implementation of specific parts of the new requirements will require more time to implement since they involve significant physical modifications that have a large impact on the PSEG Nuclear defense security strategy and Protected Area boundary.
Therefore, additional time beyond the March 31, 2010 date is requested to complete these security modifications.
Document Control Desk 2 LR-N09-0314 PSEG Nuclear is requesting the implementation date be extended from March 31, 2010 to December 17, 2010 for certain new security requirements contained in 10 CFR 73.55 as described in the Enclosure to this letter. PSEG Nuclear has determined that its current security program along with the new security requirements that will be implemented by March 31, 2010 will provide continued assurance of public health and safety and common defense and security. Accordingly, the requested exemption is authorized by law and will not endanger life or property or the common defense and security in accordance with 10 CFR 73.5.
PSEG Nuclear requests approval of this exemption request by March 5, 2010 so that appropriate and timely actions can be taken to revise and implement the PSEG Nuclear security program. The proposed exemptions are requested to be effective upon issuance.
This letter supersedes the previous exemption request letters LR-N09-0248 and LR-N09-0249 with the exception of the environmental impact statement.
The information provided in the Enclosure to this letter is free from proprietary and safeguards information and available for public disclosure. The Enclosure to this letter includes a redacted version of the accompanying letter's (LR-N09-0313) Enclosure which is designated Safeguards material.
There are no regulatory commitments made in this letter. If you have any questions or require additional information, please do not hesitate to contact Lee Marabella at (856) 339-1208 or Michelle Patti at (856) 339-3691.
Sincerely,
Enclosure:
PSEG Salem and Hope Creek Stations Non-proprietary version
Document Control Desk 3 LR-N09-0314 C Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Project Manager - Salem Unit 1 and Unit 2 U. S. Nuclear Regulatory Commission Mail Stop 08B1 Washington, DC 20555-0001 USNRC Senior Resident Inspector - Salem Generating Station (X24)
USNRC Senior Resident Inspector - Hope Creek Generating Station (X24)
LR-N09-0314 PSEG Salem and Hope Creek Stations Non-proprietary Version Enclosure 1
Enclosure LR-N09-0314 PSEG Salem and Hope Creek Stations Non-proprietary version A. Background Prior to the new rule making PSEG Nuclear (PSEG) had identified a need to upgrade ........
.................................................. ................................................. A co m p re he nsive upgrade project was approved through the Plant Health Committee in September 2007, and a design basis document (DBD) was developed and taken to the Corporate Senior Management Team for approval of funding. The upgrade schedule was extended to ensure PSEG would be in compliance with the new standards. The new security rule-making was in the Federal Register Notice dated March 27, 2009 and associated supporting regulatory guides were completed in July 2009. While the new security rule and associated guidelines were being developed, based on the evolution of the final rule, PSEG Nuclear has determined that implementation of specific parts of the new requirements will require additional time beyond March 31, 2010 date to complete these modifications.
Salem and Hope Creek is a three unit nuclear facility with a large Protected Area (PA) that encompasses all three units. The PA includes: the containment, turbine, auxiliary, fuel handling, service water and circulating water buildings, an administrative building, the Independent Spent Fuel Storage Installation and a portion of the Material Center. The PA of the facility is the second largest in the United States. The Salem and Hope Creek Physical Security System Upgrade Project encompasses new rule requirements, corrects deficiencies, and improvement opportunities.
The extent of the Salem and Hope Creek Physical Security System Upgrade project is significant such that a dedicated project team is focused on the modification and changes.
Due to the significant number of engineering design packages, procurement needs, and installation activities, some of the requirements contained in 10CFR73.55 will require additional time beyond March 31, 2010.
With approval of this exemption request, the Part 73 provisions required to be implemented by March 31, 2010 will be completed except for the proposed exemptions described in Section B below. These items, subject to the request for an exemption, will be implemented by December 17, 2010. PSEG will then be in full compliance with the new rule.
B. Proposed Exemptions PSEG requests an exemption, from the implementing deadline only, for the three items listed below in this section. The request for an extension of the March 31, 2010 date to December 17, 2010 is based on completion of the upgrade to address many of the new rule requirements, resource and logistical impacts of the units upcoming two refueling outages
.......................................................... PSEG Nuclear is continuing efforts to im plement the remaining new requirements identified in the March 27, 2009 Federal Register Notice and associated Regulatory Guides completed in July 2009 by March 31, 2010. Accordingly, the 2
Enclosure LR-N09-0314 PSEG Salem and Hope Creek Stations Non-proprietary version requested exemption is authorized by law and will not endanger life or property or the common defense and security in accordance with 10 CFR 73.5.
Listed below are the three specific regulations that an exemption from the implementation deadline is requested.
10 CFR 73.55 ........... states:
10 CFR 73.55 ............ states:
10 CFR73.55 ............. states:
The specific changes that are required to be made to meet the regulations identified above require extensive engineering, and are related to our ...............................................
which requires a systematic approach for implementation.
C u rre n tly . ....... ............................... ................... ......................... ..................
.......................... See photo in section E of this enclosure.
T h e .................................................... ........................................ . . ............ .
These modifications when completed will fully implement regulatory requirement ..................
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Enclosure LR-N09-0314 PSEG Salem and Hope Creek Stations Non-proprietary version T h e ..................................................................................... .................................
Additional changes that are being implemented to strengthen the security position but are not Additional changes that are being implemented to strengthen the security position but are not new rule related include:
T he ............ ......................................
As the modifications required by the new regulation are linked to the ...........................
these changes are expected to be complete when the ............................ upgrade is complete. This is scheduled for December 17, 2010.
The total estimated cost for all the new security-related modifications scheduled for Salem and Hope Creek Stations (SHC) is in ................... The additional work scope required by the:
new Part 73 requirements and not associated with modifications listed in this enclosure are expected to be completed by March 31, 2010.
PSEG request exemption to these specific items from Part 73 physical security requirements.
Each of these exemptions are linked to the Security System Upgrade Project. The project milestones are listed in Section D.
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Enclosure LR-N09-0314 PSEG Salem and Hope Creek Stations Non-proprietary version C. Challenges to Compliance by March 31, 2010 The PA perimeter upgrade project extends beyond just Part 73 related modifications; however, all these security-related modifications are linked together. The size and scope of the project adds considerable challenges when coupled with planned refueling outages, Part 26 implementation, personnel and material resources.
The Salem and Hope Creek Physical Security System Upgrade project will .........................
The physical challenges related to modifications in specific locations, technology available, engineering evaluation and processes required to meet station and regulatory requirements for physical changes, scheduling, weather and safety considerations for implementation were all considerations for requiring this request for an exemption to the implementation date for these specific regulations. The security physical protection program is not affected by this request.
The protective strategy.................................................
.............................. remains compliant with the regulations.
Engineering for all the major modifications are in progress; however, the engineering packages have not been completed to identify all the specifics needed to implement the packages. The proposed schedule permits the engineering process to ensure the engineering regulatory requirements are met.
Pre-outage in-processing requires the use of the security computer. The in-processing dates are shown below on the project schedule.
Vendor resources are also restricted due to the limited available of suppliers. The PSEG schedule as proposed provides expected time for vendor support.
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Enclosure LR-N09-0314 PSEG Salem and Hope Creek Stations Non-proprietary version D. Milestone Table The milestone schedule is for the ...............................................
however, PSEG believes this schedule bounds the time needed to complete the security project. This milestone schedule has been developed based on current information and anticipated challenges.
Item DaeI Description
+ +/- +
4 i -
.4 I.
.4 4.
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Enclosure LR-N09-0314 PSEG Salem and Hope Creek Stations Non-proprietary version E. Arial View 7