View source for LR-N09-0314, Request for Scheduler Exemption from Certain Aspects of the New Physical Security Requirements

{{Adams
| number = ML093640062
| issue date = 12/22/2009
| title = Request for Scheduler Exemption from Certain Aspects of the New Physical Security Requirements
| author name = Keenan J
| author affiliation = PSEG Nuclear, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000272, 05000311, 05000354
| license number = DPR-070, DPR-075, NPF-057
| contact person = 
| case reference number = LR-N09-0314
| document type = Letter type:LR
| page count = 10
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter: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 ..................
3

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.
4

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.
5

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.
6

Enclosure LR-N09-0314   PSEG Salem and Hope Creek Stations Non-proprietary version E. Arial View 7}}