ML15055A377

and Salem Nuclear Generating Station, Unit Nos. 1 and 2, Request for Additional Information Request to Update Appendix B to Renewed Facility Operating License DPR-70, DPR-75 and NPF-57

ML15055A377
Person / Time
Site:	Salem, Hope Creek
Issue date:	03/10/2015
From:	Carleen Parker Plant Licensing Branch 1
To:	Joyce T Public Service Enterprise Group
Parker C, NRR/DORL/LPL1-2, 415-2956
References
TAC MF5389, TAC MF5390, TAC MF5391
Download: ML15055A377 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 1O, 2015 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear P.O. Box 236, N09 Hancocks Bridge, NJ 08038

SUBJECT:

HOPE CREEK GENERATING STATION AND SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO UPDATE APPENDIX B TO RENEWED FACILITY OPERATING LICENSE DPR-70, DPR-75 AND NPF-57 (TAC NOS. MF5389, MF5390, AND MF5391)

Dear Mr. Joyce:

By letter dated December 9, 2014 (Agencywide Documents Access and Management System Accession No. ML14343A926), PSEG Nuclear LLC (PSEG or the licensee) submitted a license amendment request to revise Appendix B of the Renewed Facility Operating Licenses for Salem Nuclear Generating Station, Units 1 and 2, and Hope Creek Generating Station, Unit 1 for Nuclear Regulatory Commission (NRC) staff review and approval. The proposed amendments would revise the PSEG Environmental Protection Plans (EPPs) to clarify that PSEG must adhere to the currently applicable biological opinion issued by the National Marine Fisheries Service. The proposed changes would also simplify the Aquatic Monitoring section of the EPPs, modify reporting requirements related to the New Jersey Pollutant Discharge Elimination System permits, modify the criteria for reporting Unusual or Important Environmental Events, and remove the requirement for PSEG to submit an Annual Environmental Operating Report.

The NRC staff has determined that additional information is needed to complete its review of the submittal. The specific questions are found in the enclosed request for additional information.

The draft questions were sent via electronic transmission on February 24, 2015, to Mr. Paul Duke of your staff. The draft questions were sent to ensure the questions were understandable, the regulatory basis was clear, and to determine if the information was previously docketed. On March 9, 2015, Mr. Duke indicated that the licensee will submit a response within 30 days of this letter.

T. Joyce If you have any questions, please contact me at 301-415-1603 or via e-mail at Carleen.SandersParker@nrc.gov.

Si~ce;ely~I ~

~ ) .

7 Carleen J. arker, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-354, 50-272 and 50-311

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION LICENSE AMENDMENT REQUEST TO UPDATE APPENDIX B TO RENEWED FACILITY OPERATING LICENSES NPF-57, DPR-70, AND DPR-75 PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION AND SALEM GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-354, 50-272, AND 50-311 By letter dated December 9, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14343A926), PSEG Nuclear LLC (PSEG or the licensee) submitted a license amendment request (LAR) to revise Appendix B of the Renewed Facility Operating Licenses for Salem Nuclear Generating Station, Units 1 and 2 (Salem, Units 1 and 2), and Hope Creek Generating Station, Unit 1 (Hope Creek) for Nuclear Regulatory Commission (NRC) staff review and approval. The proposed amendments would revise the PSEG Environmental Protection Plans (EPPs) to clarify that PSEG must adhere to the currently applicable biological opinion issued by the National Marine Fisheries Service. The proposed changes would also simplify the Aquatic Monitoring section of the EPPs, modify reporting requirements related to the New Jersey Pollutant Discharge Elimination System permits, modify the criteria for reporting Unusual or Important Environmental Events, and remove the requirement for PSEG to submit an Annual Environmental Operating Report. To complete its review, the NRC staff requests a response to the questions below.

1. Under the proposed LAR, Section 3.2 of the EPPs for Salem, Units 1 and 2, and Hope Creek would no longer contain requirements to provide copies of proposed changes to or renewals of New Jersey Pollutant Discharge Elimination System (NJPDES) permits to the NRC. PSEG's justification for this proposed change is that it " ... would reduce unnecessary duplication of reports ... " Under the proposed LAR, what regulation or other NRC requirement would continue to require PSEG to provide copies of proposed changes to or renewals of NJPDES permits to the NRC, such that the proposed LAR would reduce unnecessary duplication?

2. The LAR proposes to delete the list of examples of unusual or important events from EPP Section 4.1 for Salem, Units 1 and 2, and Hope Creek. PSEG states that the list "may conflict with other regulatory guidance." Explain how each of the following conflicts with NRC regulations or regulatory guidance:

a. Excessive bird impaction events

b. Onsite plant or animal disease outbreaks

c. Mortality or unusual occurrence of any species protected by the Endangered Species Act or 1973

d. Fish kills or impingement events on the intake screens Enclosure

e. Increase in nuisance organisms or conditions

f. Unanticipated or emergency discharge of waste water or chemical substances

3. Under the proposed LAR, Salem, Units 1 and 2 EPP Section 4.2.1 would state, "PSEG Nuclear LLC shall adhere to the specific requirements within the currently applicable Incidental Take Statement, to the Biological Opinion."

a. Describe or list the specific requirements within the Incidental Take Statement (ITS) that PSEG would adhere to under the currently applicable July 2014 Biological Opinion (BiOp) (ADAMS Accession No. ML14202A146) (i.e., specify the Reasonable and Prudent Measures (RPMs) and Terms and Conditions (T&Cs) by number provided in the BiOp).

b. Clarify whether PSEG intends to include in the EPP all RPMs and T&Cs or only those that apply to both NRC and PSEG in the current BiOp and any future BiOps.

c. Concerning the ITS in the July 2014 BiOp, describe how PSEG intends to notify NRC of the distinct population segment for each Atlantic sturgeon that is incidentally taken at the trash bars or travelling screens to ensure that the NRC can reinitiate consultation with National Marine Fisheries Service (NMFS) in a timely manner if the ITS limit is exceeded.

d. Concerning T&C #1 of the July 2014 BiOp, provide a copy of the estimated trash bar cleaning frequency by season, which this T&C required PSEG to provide to the NMFS within 30 days of issuance of the Bi Op.

e. Concerning T&C #2 of the July 2014 BiOp, describe whether and what changes to inspection of the cooling water intake structures (if any) PSEG has implemented or intends to implement under the July 2014 BiOp.

f. Concerning T&C #3 of the July 2014 BiOp, describe whether and what changes to lighting at the intake structure or trash racks (if any) PSEG has implemented or intends to implement under the July 2014 BiOp.

g. Concerning T&C #4 of the July 2014 BiOp, describe whether and what sea turtle rescue equipment changes (if any) PSEG has implemented or intends to implement under the July 2014 BiOp.

h. Concerning T&C #7 of the July 2014 BiOp, provide a copy of the formal letter from PSEG to NMFS specified in this T&C to be sent to NMFS within 60 days of receiving the July 2014 BiOp that details arrangements made with a NMFS-approved lab for shortnose and Atlantic sturgeon fin clip processing.

i. Concerning T&C #8 of the July 2014 BiOp, describe changes, if any, PSEG intends to make to its procedures concerning reporting of live or dead sea turtles or sturgeon incidentally take at the Salem, Units 1 and 2 trash bars or traveling screens as a result of this T&C.

j. Concerning T&C #9 of the July 2014 BiOp, confirm whether PSEG intends to submit to NMFS and the NRC an annual report for 2014 that includes the information specified in this T&C by March 15, 2015.

k. Concerning T&C #10 of the July 2014 BiOp, what stranding/rehabilitation facility has PSEG made arrangements with to respond to live and dead sea turtles collected from the Salem, Units 1 and 2 intakes?

I. Concerning T&C #11 of the July 2014 BiOp, what facility has PSEG made arrangements with to perform necropsies on dead sea turtles?

m. Concerning T&Cs #15-23 of the July 2014 BiOp, describe any measures PSEG has taken to educate personnel regarding the July 2014 BiOp's T&Cs regarding Radiological Environmental Monitoring Program (REMP) gillnet sampling for Salem, Units 1 and 2, and Hope Creek.

n. Concerning T&C #17 of the July 2014 BiOp, describe arrangements, if any, PSEG has made to ensure that at least one crew member performing REMP gillnet sampling is experienced in the identification of shortnose and Atlantic sturgeon.

o. Concerning T&C #18 of the July 2014 BiOp, describe any arrangements PSEG has made regarding the collection of shortnose and Atlantic sturgeon fin clip samples during REMP gillnet sampling pursuant to the T&C.

p. Concerning T&C #19 of the July 2014 BiOp, describe any arrangements PSEG has made regarding Passive Integrated Transponder tagging during REMP gillnet sampling pursuant to the T&C.

q. Concerning T&C #23 of the July 2014 BiOp, confirm whether PSEG intends to submit to NMFS and the NRC an annual report for 2014 that includes the information specified in this T&C by March 15, 2015.

r. Concerning the Conservation Recommendations in the July 2014 BiOp, describe whether PSEG has implemented or intends to implement any of NMFS's six recommendations concerning scientific study of shortnose and Atlantic sturgeon.

s. Concerning reinitiation of consultation, describe how PSEG intends to monitor and notify the NRC if it finds that any of the conditions, as provided in 50 CFR 402.16 and described under Section 13.0 of the July 2014 BiOp, are met that would require NRC to reinitiate consultation with NMFS.

4. Under the proposed LAR, Hope Creek EPP Section 4.2.1 does not contain a statement that PSEG will adhere to the specific requirements within the currently applicable ITS to the BiOp as is proposed for Salem, Units 1 and 2 EPP Section 4.2.1. However, the ITS in the July 2014 BiOp contains requirements that apply to both Salem Units, 1 and 2, and Hope Creek.

a. Explain why PSEG does not propose to include such a statement.

b. Does PSEG believe the language in Hope Creek EPP Section 4.2.1, as proposed, requires PSEG to adhere to the specific requirements concerning Hope Creek in the currently applicable ITS to the BiOp?

5. Under the proposed LAR, EPP Section 5.4.1 for Salem, Units 1 and 2, and Hope Creek would be deleted, which would remove the requirement for PSEG to provide the NRC with an Annual Environmental Operating Report (AEOR).

a. In the LAR, PSEG states that "information previously contained in the AEOR would continue to be gathered and available through other reporting and/or inspection mechanisms." Describe these reporting and inspection mechanisms.

b. The AEOR includes information on threatened and endangered species removed from the Circulating Water System each year. Confirm that the information typically included in the AEOR regarding threatened and endangered species would be provided to the NRC in the annual report of incidental takes required by T&C #9 of the July 2014 BiOp.

a. In the LAR, PSEG states that "information previously contained in the AEOR would continue to be gathered and available through other reporting and/or inspection mechanisms." Describe these reporting and inspection mechanisms.

b. The AEOR includes information on threatened and endangered species removed from the Circulating Water System each year. Confirm that the information typically included in the AEOR regarding threatened and endangered species would be provided to the NRC in the annual report of incidental takes required by T&C #9 of the July 2014 BiOp.

ML15055A377 *via e-mail OFFICE LPL 1-2/PM LPL 1-2/LA DLR/RE RB LPL 1-2/BC LPL 1-2/PM NAME CParker ABaxter

• DWrona DBroaddus CParker DATE 02/24/2015 03/03/15 03/09/15 03/10/15 03/10/15