LR-N19-0064, License Amendment Request - Deletion of Facility Operating License Conditions Related to Decommissioning Trust Provisions and License Transfer

License Amendment Request - Deletion of Facility Operating License Conditions Related to Decommissioning Trust Provisions and License Transfer

ML19210C880
Person / Time
Site:	Salem, Hope Creek
Issue date:	07/29/2019
From:	Duke P Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H19-04, LAR S19-04, LR-N19-0064
Download: ML19210C880 (34)

Text

LR-N 19-0064 LAR S19-04 LAR H19-04 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 JUL 2 9 2019 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 0PSEG NuclearLLC 10 CFR 50.90

Subject:

License Amendment Request - Deletion of Facility Operating License Conditions Related to Decommissioning Trust Provisions and License Transfer

Reference:

1.

NRC Final Rule for Decommissioning Trust Provisions (67 FR 78332),

published December 24, 2002 In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby requests amendments to Renewed Facility Operating License (FOL) Nos. DPR-70 and DPR-75 for Salem Generating Station Units 1 & 2 respectively and FOL No. NPF-57 for Hope Creek Generating Station. In accordance with 10 CFR 50.91 (b)(1 ), a copy of this request for amendment has been sent to the State of New Jersey.

The proposed amendment revises the operating licenses for the above plants to delete certain license conditions which impose specific requirements on the decommissioning trust agreement, on the basis that upon approval of this amendment, the provisions of 10 CFR

50. 75(h) that specify the regulatory requirements for decommissioning trust funds will apply to PSEG Nuclear. The option to delete license conditions relating to the terms and conditions of decommissioning trust fund agreements and, instead, conform to the 10 CFR 50. 75(h) regulations adopted in 2002 (Reference 1) is specifically contemplated by the provisions of 10 CFR 50. 75(h)(5) and the generic finding of no significant hazards consideration in 10 CFR

50. 75(h)(4).

LR-N19-0064 Page 2 10 CFR 50.90 The proposed amendment also removes legacy financial requirements associated with the license transfer from PSE&G to PSEG Nuclear relative to maintaining available funding for an extended shutdown. This FOL requirement is a legacy requirement from the license transfer and is not required to ensure PSEG Nuclear's financial qualifications to cover estimated operating costs for the period of the licenses.

Exelon Generation Company (EGC) is a co-owner of SGS and, as such, certain license conditions being deleted as part this license amendment request specifically apply to EGC.

PSEG has obtained formal concurrence from EGC for deletion of these license conditions.

The enclosure to this letter provides a detailed description and evaluation of the proposed changes.

Attachments 1 and 2 provide markups of the proposed changes to the affected pages of the FOLs for Salem Unit -1 and Salem Unit -2 respectively. provides a markup of the proposed changes to the affected pages of the FOL for Hope Creek Generating Station PSEG requests approval of this LAR in accordance with standard NRC approval process and schedule. Once approved, the amendment will be implemented within 60 days from the date of issuance.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on _1_. _!_2_

____ /

__ *2_o_t_9

 (date)

Respectfully, Q

. r()

0 Paul Duke



Manager - Licensing PSEG Nuclear

Enclosure:

Description and Evaluation of the Proposed Change : Mark-up of the Current Salem Generating Station Unit -1 Facility Operating License Pages : Mark-up of the Current Salem Generating Station Unit -2 Facility Operating License Pages : Mark-up of the Current Hope Creek Generating Station Facility Operating License Pages cc:

Administrator, Region I, NRC Mr. J. Kim, NRC Project Manager, Salem & Hope Creek NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Chief-Financial Projects Branch, NRC

LR-N1 9-0064 Enclosure Description and Evaluation of the Proposed Change LAR 51 9-04 LAR H 1 9-04 License Amendment Request (LAR) S1 9 Salem Generating Station License Amendment Request (LAR) H1 9 Hope Creek Generating Station Deletion of Facility Operating License Conditions Related to Decommissioning Trust Provisions Table of Contents 1.0

SUMMARY

DESCRIPTION.............................................................................. 2 2.0 DETAILED DESCRIPTION............................................................................................. 2 2.1 Current SGS-1 License Requirements...................................................................... 2 2.2 Current SGS-2 License Requirements...................................................................... 4 2.3 Current HCGS License Requirements...................................................................... 6 2.4 Reason for the Proposed Change............................................................................ 7

3.0 TECHNICAL EVALUATION

............................................................................................ 7 3.1 License Conditions Common to SGS and HCGS - Decommissioning Funding......... 7 3.2 License Conditions Common to SGS and HCGS - Extended Shutdown Funding... 11 3.3 License Conditions Unique to SGS.......................................................................... 12

4.0 REGULATORY EVALUATION

...................................................................................... 19 4.1 No Significant Hazards........................................................................................... 19 4.2 Precedent............................................................................................................... 20 4.3 Conclusion............................................................................................................. 21

5.0 ENVIRONMENTAL CONSIDERATION

......................................................................... 21

6.0 REFERENCES

.............................................................................................................. 21 ATTACHMENTS:

1.

Mark-up of the Current Salem Generating Station Unit -1 Facility Operating License Pages

2.

Mark-up of the Current Salem Generating Station Unit -2 Facility Operating License Pages

3.

Mark-up of the Current Hope Creek Generating Station Facility Operating License Pages 1 of 21

LR-N1 9-0064 1.0

SUMMARY

DESCRIPTION LAR 51 9-04 LAR H 1 9-04 This license amendment request proposes to delete conditions which impose specific requirements related to the decommissioning trust agreement from the Salem Generating Station (SGS) Units 1 & 2 and Hope Creek Generating Station (HCGS) Renewed Facility Operating Licenses (FOLs) and license conditions which impose financial requirements associated with the prior transfer of licenses from Public Service Electric and Gas Company (PSE&G) to PSEG Nuclear LLC.

Deletion of the license conditions associated with the decommissioning trust agreements is proposed on the basis that PSEG Nuclear LLC (PSEG) has elected to subject its decommissioning trust agreements to the regulatory requirements for decommissioning trust funds that are specified in 10 CFR 50. 75(h). The option to delete license conditions relating to the terms and conditions of decommissioning trust fund agreements and, instead, conform to the 10 CFR 50. 75(h) regulations adopted in 2002 (Reference 1 ), is consistent with the Nuclear Regulatory Commission's (NRC) stated intent in the Final Rule for Decommissioning Trust Provisions published in the Federal Register (67 FR 78332, 68 FR 65388) and is specifically contemplated by the provisions of 10 CFR 50. 75(h)(5), and the generic finding of no significant hazards consideration in 10 CFR 50;75(h)(4).

Based on the existing license conditions and pursuant to the terms of 10 CFR 50.75(h)(5), the requirements in 10 CFR 50. 75(h)(1) through h(3) are currently not applicable to SGS Units 1 & 2 and HCGS. Therefore, by deleting the specific license conditions as contemplated by the generic finding of no significant hazards consideration in 10 CFR 50.75(h)(4), the new terms and conditions of the decommissioning trust agreement will conform with and be subject to the NRC's regulations in 10 CFR 50. 75(h)(1) through (h)(3).

The proposed deletion of the license conditions associated with commitments of PSEG Power or its parent companies to fund an extended plant shutdown are based on the legacy nature of the requirement stemming from the transition of PSEG Nuclear from a traditional utility to a merchant generator during deregulation in the late 1990's. The license conditions are not required to ensure PSEG Nuclear's financial qualifications to cover estimated operating costs for the period of the licenses.

2.0 DETAILED DESCRIPTION The current License Conditions pertaining to Provisions for the Decommissioning Trust Fund and commitments to fund an extended plant shutdown contained in the SGS-1, SGS-2 and HCGS FOLs are identified below. Note that License Condition 2.C.12 for SGS-1 and License Condition 2.C.28 for SGS-2 pertain to restrictions associated with Exelon Generation Company who is a co-owner of SGS. These License Conditions are not affected by this LAR.

2.1 Current SGS-1 License Requirements License Conditions 2.C.11.a, 2.C.11.b, 2.C.13, 2.C.14 and 2.C.15 of the SGS-1 Amended FOL currently include the following requirements for the decommissioning trust funds. License Condition 2.C.11.c of the SGS-1 Amended FOL is associated with funding requirements for an extended plant shutdown:

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LR-N1 9-0064 (11) PSE&G to PSEG Nuclear LLC License Transfer Conditions LAR 5 1 9-04 LAR H 1 9-04

a. PSEG Nuclear LLC shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application, the requirements of the Order Approving Transfer of License and Conforming Amendment, dated February 16, 2000, and related Safety Evaluation dated February 16, 2000.

b. The decommissioning trust agreement shall provide that:

1. The use of assets in both the qualified and non-qualified funds shall be limited to expenses related to decommissioning of the unit as defined by the NRC in its regulations and issuances, and as provided in the unit's renewed license and any amendments thereto. However, upon completion of decommissioning, as defined above, the assets may be used for any purpose authorized by law.

2. Investments in the securities or other obligations of PSE&G or affiliates thereof, or their successors or assigns, shall be prohibited. In addition, except for investments tied to market indexes or other non-nuclear sector mutual funds, investments in any entity owning one or more nuclear power plants shall be prohibited.

3. No disbursements or payments from the trust shall be made by the trustee until the trustee has first given the NRC 30 days notice of the payment. In addition, no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the Director, Office of Nuclear Reactor Regulation.

4. The trust agreement shall not be modified in any material respect without prior written notification to the Director, Office of Nuclear Reactor Regulation.

5. The trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32(3) of the Federal Energy Regulatory Commission's regulations.

c. PSEG Nuclear LLC shall not take any action that would cause PSEG Power LLC or its parent companies to void, cancel, or diminish the commitment to fund an extended plant shutdown as represented in the application for approval of the transfer of this license from PSE&G to PSEG Nuclear LLC.

(13) Exelon Generation Company shall have decommissioning trust funds for Salem, Unit 1, in the following minimum amount on the closing date of the license transfer:

Salem, Unit 1

$53,780,652 (14) The decommissioning trust agreement for Salem, Unit 1, shall be subject to the following:

a. The decommissioning trust agreement must be in a form acceptable to the NRC.

b. With respect to the decommissioning trust fund, investments in the securities or other obligations of Exelon Corporation or affiliates thereof, or their successors or 3 of 21

LR-N 1 9-0064 LAR 5 1 9-04 LAR H 1 9-04 assigns are prohibited. Except for investments tied to market indexes or other non nuclear sector mutual funds, investments in any entity owning one or more nuclear power plants are prohibited.

c. The decommissioning trust agreement for Salem, Unit 1, must provide that no disbursements or payments from the trust shall be made by the trustee unless the trustee has first given the Director of the Office of Nuclear Reactor Regulation 30 days prior written notice of payment. The decommissioning trust agreement shall further contain a provision that no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the NRC.

d. The decommissioning trust agreement must provide that the agreement cannot be amended in any material respect without 30 days prior written notification to the Director of the Office of Nuclear Reactor Regulation.

e. The appropriate section of the decommissioning trust agreement shall state that the trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32(a)(3) of the Federal Energy Regulatory Commission's regulations.

( 15) Exelon Generation Company shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application for approval of the transfer of the Salem, Unit 1, license to it and the requirements of the Order approving the transfer, and consistent with the safety evaluation supporting the Order.

2.2 Current SGS-2 License Requirements License Conditions 2.C.27.a, 2.C.27.b, 2.C.29, 2.C.30 and 2.C.31 of the SGS-2 Amended FOL currently include the following requirements for the decommissioning trust funds. License Condition 2.C.27.c of the SGS-2 Amended FOL is associated with funding requirements for an extended plant shutdown:

(27) PSE&G TO PSEG Nuclear LLC License Transfer Conditions

a. PSEG Nuclear LLC shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application, the requirements of the Order Approving Transfer of License and Conforming Amendment, dated February 16, 2000, and the related Safety Evaluation dated February 16, 2000.

b. The decommissioning trust agreement shall provide that:

1. The use of assets in both the qualified and non-qualified funds shall be limited to expenses related to decommissioning of the unit as defined by the NRC in its regulations and issuances, and as provided in the unit's renewed license and any amendments thereto. However, upon completion of decommissioning, as defined above, the assets may be used for any purpose authorized by law.

2. Investments in the securities or other obligations of PSE&G or affiliates thereof, or their successors or assigns, shall be prohibited. In addition, except for investments tied to market indexes or other non-nuclear sector mutual funds, 4 of 21

LR-N19-0064 LAR 519-04 LAR H19-04 investments in any entity owning one or more nuclear power plants shall be prohibited.

3. No disbursements or payments from the trust shall be made by the trustee until the trustee has first given the NRC 30 days notice of the payment. In addition, no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the Director, Office of Nuclear Reactor Regulation.

4. The trust agreement shall not be modified in any material respect without prior written notification to the Director, Office of Nuclear Reactor Regulation.

5. The trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32(3) of the Federal Energy Regulatory Commission's regulations.

c.

PSEG Nuclear LLC shall not take any action that would cause PSEG Power LLC or its parent companies to void, cancel, or diminish the commitment to fund an extended plant shutdown as represented in the application for approval of the transfer of this license from PSE&G to PSEG Nuclear LLC.

(29) Exelon Generation Company shall have decommissioning trust funds for Salem, Unit 2, in the following minimum amount on the closing date of the license transfer to it:

Salem, Unit 2

$45,059,302 (30) The decommissioning trust agreement for Salem, Unit 2, shall be subject to the following:

a. The decommissioning trust agreement must be in a form acceptable to the NRC.

b. With respect to the decommissioning trust fund, investments in the securities or other obligations of Exelon Corporation or affiliates thereof, or their successors or assigns are prohibited. Except for investments tied to market indexes or other non nuclear sector mutual funds, investments in any entity owning one or more nuclear power plants are prohibited.

c. The decommissioning trust agreement for Salem, Unit 2, must provide that no disbursements or payments from the trust shall be made by the trustee unless the trustee has first given the Director of the Office of Nuclear Reactor Regulation, 30 days prior written notice of payment. The decommissioning trust agreement shall further contain a provision that no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the NRC.

d. The decommissioning trust agreement must provide that the agreement cannot be amended in any material respect without prior written consent of the Director, Office of Nuclear Reactor Regulation.

e. The appropriate section of the decommissioning trust agreement shall state that the trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32(a)(3) of the Federal Energy Regulatory Commission's regulations.

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LR-N1 9-0064 LAR 51 9-04 LAR H 1 9-04 (31) Exelon Generation Company shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application for approval of the transfer of its ownership interest in Salem, Unit 2, license and the requirements of the Order approving the transfer, and consistent with the safety evaluation supporting the Order.

2.3 Current HCGS License Requirements License Conditions 2.C.15.a and 2.C.15.b, of the HCGS Amended FOL currently include the following requirements for the decommissioning trust funds. License Condition 2.C.15.c of the HCGS Amended FOL is associated with funding requirements for an extended plant shutdown:

(15) PSE&G to PSEG Nuclear LLC License Transfer Conditions

a. PSEG Nuclear LLC shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application, the requirements of the Order Approving Transfer of License and Conforming Amendment, dated February 16, 2000, and the related Safety Evaluation dated February 16, 2000.

b. The decommissioning trust agreement shall provide that:

1. The use of assets in both the qualified and non-qualified funds shall be limited to expenses related to decommissioning of the unit as defined by the NRC in its regulations and issuances, and as provided in the unit's renewed license and any amendments thereto. However, upon completion of decommissioning, as defined above, the assets may be used for any purpose authorized by law.

2. Investments in the securities or other obligations of PSE&G or affiliates thereof, or their successors or assigns, shall be prohibited. In addition, except for investments tied to market indexes or other non-nuclear sector mutual funds, investments in any entity owning one or more nuclear power plants shall be prohibited.

3. No disbursements or payments from the trust shall be made by the trustee until the trustee has first given the NRC 30 days notice of the payment. In addition, no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the Director, Office of Nuclear Reactor Regulation.

4. The trust agreement shall not be modified in any material respect without prior written notification to the Director, Office of Nuclear Reactor Regulation.

5. The trustee, investment advisor, or anyone etse directing the investments made in the trust shall adhere to a "prudent investor standard, as specified in 18 CFR 35.32(3) of the Federal Energy Regulatory Commission's regulations.

c. PSEG Nuclear LLC shall not take any action that would cause PSEG Power LLC or its parent companies to void, cancel, or diminish the commitment to fund an extended plant shutdown as represented in the application for approval of the transfer of this license from PSE&G to PSEG Nuclear LLC.

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LR-N 1 9-0064 2.4 Reason for the Proposed Change LAR 5 1 9-04 LAR H 1 9-04 The requested amendment would delete the SGS-1 License Conditions 2.C.11.a, 2.C.11.b, 2.C.13, 2.C.14 and 2.C.15; delete SGS-2 License Conditions 2.C.27.a, 2.C.27.b, 2.C.29, 2.C.30 and 2.C.31; and delete HCGS License Conditions 2.C.15.a and 2.C.15.b from their respective FOLs since they are addressed in the regulations. These license conditions were established during the time of license transfer from PSE&G to PSEG Nuclear LLC during deregulation of the electric power industry in the late 1990's.

Rulemaking to codify the decommissioning funding requirements covered by the subject license conditions was in its early stages during this timeframe.

The requested amendment would delete SGS-1-License Condition 2.C.11.c, SGS-2 License Condition 2.C.27.c and HCGS License Condition 2.C.15.c. from their respective FOLs because they are no longer required to ensure PSEG Nuclear's financial qualifications to cover estimated operating costs for the period of the licenses.

3.0 TECHNICAL EVALUATION

3.1 License Conditions Common to Salem Generating Station and Hope Creek Generating Station Associated With the Decommissioning Trust Fund The Table below summarizes the manner in which the specific requirements in License Conditions common to SGS and HCGS (described in Sections 2.1, 2.2 and 2.3 above) requested for deletion are addressed in the regulations.

License Condition (2.C.1 1 ) (SGS-1 )

Regulatory Requirement License Condition (2.C.27) (SGS-2)

License Condition (2.C.1 5) (HCGS)

PSE&G to PSEG Nuclear LLC License Transfer Conditions

.a: PSeG Nt1eleaF bbG sRall take all This license condition is no longer needed, based Aeeessai:y ste¥s te 9ASt1Fe Uat tRe on the provisions of 10 CFR 50. 75(h) and PSEG's EleeemmissieAiA§ tF\\;jst is maiAtaiReEI iA decision to comply with that section's aeeeFElaAee witA tAe a¥¥lieatieR, tRe decommissioning trust agreementrequirements.

FeEf l::JiFemeRts ef tAe GFEleF A¥¥Fe1JiR§ In addition, as noted in the NRC's 2002

+FaRsfeF ef bieeAse aREI GeAfeFmiR§ rulemaking, "the NRC has always believed that it AmeAElmeAt, Elate9 F'.eeFl:JaPf  e, 2000, aAEI is preferable and more efficient to adopt standard relatee Safety evaltiatieA Elatee Feernary rules, as opposed to applying specific license 19, 2000. (Deleted) conditions on a case-by-case basis" (67 FR 78334). This license condition is effectively addressed by the standard requirements codified in the regulations.

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LR-N1 9-0064 License Condition (2.C.1 1 ) (SGS-1 )

License Condition (2.C.27) (SGS-2)

License Condition (2.C.1 5) (HCGS)

PSE&G to PSEG Nuclear LLC License Transfer Conditions

.b: The decommissioning trust agreement shall provide that:

. b.1 : The use of assets in both the qualified and non qualified funds shall be the NRG in its regulations and issuances, and as provided in the unit's renewed license and any amendments thereto.

Hm'.'ever, upon completion of decommissioning, as defined above, the

. b.2: Investments in the securities or other obligations of PSE&G or affiliates thereof, or their successors or assigns, shall be prohibited. In addition, except for investments tied to market indexes or other non nuclear sector mutuat funds, investments in any entity owning one or more nuclear pot.Nor plants shall be prohibited. (Deleted)

Regulatory Requirement 10 CFR 50. 75(h)(1 )(iv)

LAR 5 1 9-04 LAR H 1 9-04 Disbursements or payments from the trust, escrow account, Government fund, or other account used to segregate and manage the funds, other than for payment of ordinary administrative costs (including taxes) and other incidental expenses of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, are restricted to decommissioning expenses or transfer to another financial assurance method acceptable under paragraph (e) of this section until final decommissioning has been completed.

10 CFR 50. 75(h)(1 )(i)

The trustee, manager, investment advisor, or other person directing investment of the funds:

(A) Is prohibited from investing the funds in securities or other obligations of the licensee or any other owner or operator of any nuclear power reactor or their affiliates, subsidiaries, successors or assigns, or in a mutual fund in which at least 50 percent of the fund is invested in the securities of a licensee or parent company whose subsidiary is an owner or operator of a foreign or domestic nuclear power plant. However, the funds may be invested in securities tied to market indices or other non-nuclear sector collective, commingled, or mutual funds, provided that this subsection shall not operate in such a way as to require the sale or transfer either in whole or in part, or other disposition of any such prohibited investment that was made before the publication date of this rule, and provided further that no more than 10 percent of trust assets may be indirectly invested in securities of any entity owning or operating one or more nuclear power plants.

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LR-N1 9-0064 License Condition (2.C.1 1 ) (SGS-1 )

License Condition (2.C.27) (SGS-2)

License Condition (2.C.1 5) (HCGS)

PSE&G to PSEG Nuclear LLC License Transfer Conditions

.b.3: Ne EliseuFsemeAts eF f:)aymeAts ffem tl=le tFUSt SRall ee A=!aEle ey tl=le tFUStee until tl=le tFustee has fiFSt given the NRG 30 days netise ef the f:)ayment. In aEIElitien, ne diseuFsemeAts eF f3ayments fFeFR the tFust shall be A=lade if the tFustee Feceives f3Fier wFitten netise ef ebjectien frem tl=le Qii:ecteF, Gffice ef Nt1cleaF Reacter Regulatien. (Deleted)

Regulatory Requirement 10 CFR 50.75(h)(1)(iv)

LAR 5 1 9-04 LAR H 1 9-04 Except for withdrawals being made under 10 CFR 50.82(a)(8) or for payments of ordinary administrative costs (including taxes) and other incidental expenses of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, no disbursement or payment may be made from the trust, escrow account, Government fund, or other account used to segregate and manage the funds until written notice of the intention to make a disbursement or payment has been given to the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days before the date of the intended disbursement or payment.

The disbursement or payment from the trust, escrow account, Government fund or other account may be made following the 30-working day notice period if the person responsible for managing the trust, escrow account, Government fund, or other account does not receive written notice of objection from the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, within the notice period.

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LR-N1 9-0064 License Condition (2.C.1 1 ) (SGS-1 )

License Condition (2.C.27) (SGS-2)

License Condition (2.C.1 5) (HCGS)

PSE&G to PSEG Nuclear LLC License Transfer Conditions

.b.4: +Ae tFl::ISt agFeemeAt SRall Aet ee meeifiee iR aRy mateFial Fesf>eGt witAetJt f>FieF )NFitteA AetifieatieA te tAe QiFesteF, Offise ef N1::1clear ReaGter Reg1::1latieR.

(Deleted)

. b.5: +Re tF1::1stee, iAiJestmeAt aeviseF, er aAyeAe else ElireGtiAg tAe iAvestmeAts maEle iA tAe tr1::1st SAall aeReFe te a 11J3Fl::IGeAt iR1Jester:' staRElaFEI, as Sf>eeifieEI iR 8 GF'.R Ja.Jº(J1/4 ef tl:te F'.eeeral eRergy Regl:llatept GemmissieR's reg1::1latieAs. (Deleted)

Regulatory Requirement 10 CFR 50.75(h)(1)(iii)

LAR 51 9-04 LAR H 1 9-04 The trust, escrow account, Government fund, or other account used to segregate and manage the funds may not be amended in any material respect without written notification to the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days before the proposed effective date of the amendment. The licensee shall provide the text of the proposed amendment and a statement of the reason for the proposed amendment. The trust, escrow account, Government fund, or other account may not be amended if the person responsible for managing the trust, escrow account, Government fund, or other account receives written notice of objection from the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, within the notice period.

10 CFR 50.75(h)(1 )(i)

The trustee, manager, investment advisor, or other person directing investment of the funds:

(8) Is obligated at all times to adhere to a standard of care set forth in the trust, which either shall be the standard of care, whether in investing or otherwise, required by State or Federal law or one or more State or Federal regulatory agencies with jurisdiction over the trust funds, or, in the absence of any such standard of care, whether in investing or otherwise, that a prudent investor would use in the same circumstances. The term "prudent investor," shall have the same meaning as set forth in the Federal Energy Regulatory Commission's "Regulations Governing Nuclear Plant Decommissioning Trust Funds" at 18 CFR 35.32(a}(3), or any successor regulation.

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LR-N 1 9-0064 LAR 51 9-04 LAR H 1 9-04 3.2 License Conditions Common to Salem Generating Station and Hope Creek Generating Station Associated With Financial Commitments of PSEG Power or Parent Companies The requested amendment would delete SGS-1 License Condition 2.C.11.c, SGS-2 License Condition 2.C.27.c and HCGS License Condition 2.C.15.c. from their respective FOLs. The wording is common in all three License Conditions:

PSEG Nuclear LLC shall not take any action that would cause PSEG Power LLC or its parent companies to void, cancel, or diminish the commitment to fund an extended plant shutdown as represented in the application for approval of the transfer of this license from PSE&G to PSEG Nuclear LLC. (Deleted)

These license conditions were included in the NRC orders approving the license transfers from PSE&G to PSEG Nuclear to ensure sufficient funding was committed to the new licensee. In an October 22, 1999 letter to the NRC, PSE&G stated that, while PSEG Power would not maintain a specific cash reserve or other segregated account to fund an extended (i.e., 6 month) shutdown, PSEG Power would have the ability to fund such a shutdown given: 1) PSEG Power's proposed capitalization and assets; and 2) the expected revenue streams that will exist independent of a unit shutdown, from PSEG Power's diverse and extensive generating assets (fossil and nuclear). Although the NRC staff concluded that PSEG Power's projected operating revenue would provide a sufficient source of funds for PSEG Nuclear to meet its ongoing operating expenses, the orders approving the license transfers were conditioned to require that "PSEG Nuclear shall not take any action that would cause PSEG Power or its parent companies to void, cancel, or diminish the commitment to fund an extended plant shutdown as represented in the application for approval of the transfer of the respective license for each of the five units."

These license conditions were established based on the uncertainty surrounding the projected finances of PSEG Power, the parent of PSEG Nuclear, as it entered into the merchant generation business model as a part of deregulation of New Jersey's electric power market in the late 1990's. As such, the license conditions are a legacy issue from the time of the license transfers. The license conditions are no longer necessary based on the following considerations:

PSEG Power was established with capitalization to support a credit rating of at least BBB from widely-accepted rating organizations, and has retained an "investment-grade" rating since its establishment.

PSEG Nuclear and PSEG Power are now "established entities" within the working definition provided in NUREG-1577, Rev. 1, "Standard Review Plan on Power Reactor Licensee Financial Qualifications and Decommissioning Funding Assurance." PSEG Nuclear has an established and proven record of more than five years of managing and owning nuclear power plants. PSEG Power has an established record of more than five years of raising and managing capital required to fund nuclear power plants' capital additions, and operating expenses.

Financial reporting relative to PSEG Nuclear occurs through PSEG Power. Statements of cash flows for PSEG Power are supplied under existing reporting requirements to the Securities and Exchange Commission.

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LR-N1 9-0064 LAR 5 1 9-04 LAR H 1 9-04 The financial decision to fund an extended plant shutdown, versus permanent cessation of operations, for any of the operating units would be determined based on the nature of the extended shutdown and on other factors that exist at the time.

Deletion of this license condition does not affect the regulatory requirements to provide financial assurance for decommissioning.

3.3 License Conditions Unique to Salem Generating Station The Table below summarizes the manner in which the specific requirements in License Conditions unique to SGS (described in Sections 2.1 and 2.2 above) requested for deletion are addressed in the regulations.

License Condition (2.C.1 3) (SGS-1 )

Regulatory Requirement e*eleR GeReFatieR Gem¥aRy SAall Aa11e This license condition is no longer needed since EleeemmissieAiA§ tFl:jst fl:jAEls feF Salem, the minimum decommissioning trust fund (DTF) ldAit 1, iA tl=le felle1NiAJ miAimlJm amelJAt eR amount specified in this license condition was a tl=le clesiRJ Elate ef tl=le liceAse traAsfeF:

one-time requirement that was satisfied upon license transfer from PSE&G to PSEG Nuclear Salem, ldAit

$5a,:;zsG,e52 LLC. The DTF continues to be maintained by both (Deleted)

PSEG Power and Exelon per the minimum decommissioning funding requirements in 10 CFR

50. 75(a) - (f) as reported by PSEG Nuclear and Exelon.

License Condition (2.C.29) (SGS-2)

Regulatory Requirement e*eleA GeAeFatieR Gem¥aRy SAall Rave This license condition is no longer needed since ElecemmissieRiR§ tF1:;1st f1:;1AEls feF Salem, the minimum DTF amount specified in this license ldRit 2, iR tAe follev.tiA§ miAimlJFA amelJAt 9R condition was a one-time requirement that was tt=le clesiR§ Elate ef tl=le liceRse traRsfeF te it satisfied upon license transfer. The DTF continues to be maintained by both PSEG Power Salem, ldRit 2

$45,Q59,JQ2 and Exelon per the minimum decommissioning (Deleted) funding requirements in 10 CFR 50.75(a) - (f) as reported by PSEG Nuclear and Exelon.

License Condition (2.C.1 4) (SGS-1 )

Regulatory Requirement

+t=le ElecemmissieAiA§ tFlJst a§FeemeAt feF Salem, ldAit 1, st=lall be slJbject te tt:le felle>NiA§: (Deleted) 12 of 21

LR-N1 9-0064

.a: The decommissioning trust agreement must be in a form acceptable to the NRG.

(Deleted)

. b: '.JVith respect to the decommissioning trust fund, investments in the securities or other obligations of Exelon Corporation or affiliates thereof; or their successors or assigns are prohibited. Except for investments tied to market indexes or other non nuclear sector mutual funds, investments in any entity owning one or more nuclear pm,1er plants are prohibited.

(Deleted)

LAR 5 1 9-04 LAR H 1 9-04 While this wording is not explicitly stated in the revised regulations of 10 CFR 50.75, the intent of this license condition is the basic focus of the NRC's 2002 rulemaking (67 FR 78332). In that rulemaking, the NRC stated that "[t]he amendments to NRC's requirements for decommissioning trust provisions of nuclear power plants require that decommissioning trust agreements be in a form acceptable to the NRC in order to increase assurance that an adequate amount of decommissioning funds will be available for their intended purpose" (67 FR 78349 (emphasis added)).

10 CFR 50.75(h)(1)(i)

The trustee, manager, investment advisor, or other person directing investment of the funds:

(A) Is prohibited from investing the funds in securities or other obligations of the licensee or any other owner or operator of any nuclear power reactor or their affiliates, subsidiaries, successors or assigns, or in a mutual fund in which at least 50 percent of the fund is invested in the securities of a licensee or parent company whose subsidiary is an owner or operator of a foreign or domestic nuclear power plant. However, the funds may be invested in securities tied to market indices or other non-nuclear sector collective, commingled, or mutual funds, provided that this subsection shall not operate in such a way as to require the sale or transfer either in whole or in part, or other disposition of any such prohibited investment that was made before the publication date of this rule, and provided further that no more than 10 percent of trust assets may be indirectly invested in securities of any entity owning or operating one or more nuclear power plants.

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LR-N 1 9-0064

.c: +l=le Elecemmissienin§ tFt1st a§FeeFRent feF Salem, ldnit , m1::1st f)Fe1JiEle tt:lat ne EliseYFsemeAts eF f)ayments frem U=le tr1::1st SRall ee maEle ey tt:le tr1::1stee 1::1nless tt:le trnstee t:las fiFst §iveR tt:le QirecteF, Gffice ef N1::1clear ReaGteF Re§1::1latien, JQ Elays f)FioF 1NFitten netice ef f)aymeAt. +.f::le Eleeemmissienin§ tF1::1st a§reement sl=lall f1::1Ftl=leF eentain a f)Fm.<ision tt:lat ne Elise1::1rsements eF f)aymeRts fFem tl=le trt1st sf::lall ee FF1aee if tf::le tr1:1stee reeeives f3FieF

'NritteR netice ef oejeGtien frem tt:le NRG.

(Deleted)

.d: +!:le EieeeFRmissieAiA§ tnJst a§reeFReRt m1::1st f3F91-<iee tt:lat tRe a§FeeFF1eAt caRAet ee ameAElee iR aRy material resf3ect witt=let1t JQ Efays f3Fier \\.<ritteA RetificatieA te Ue Qirecter of tt=le Gffice of N1::1clear ReaGter Re§ulatien. (Deleted) 10 CFR 50.75(h)(1)(iv)

LAR 5 1 9-04 LAR H 1 9-04 Except for withdrawals being made under 10 CFR 50.82(a)(8) or for payments of ordinary administrative costs (including taxes) and other incidental expenses of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, no disbursement or payment may be made from the trust, escrow account, Government fund, or other account used to segregate and manage the funds until written notice of the intention to make a disbursement or payment has been given to the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days before the date of the intended disbursement or payment.

The disbursement or payment from the trust, escrow account, Government fund or other account may be made following the 30-working day notice period if the person responsible for managing the trust, escrow account, Government fund, or other account does not receive written notice of objection from the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, within the notice period.

10 CFR 50. 75(h)(1 )(iii)

The trust, escrow account, Government fund, or other account used to segregate and manage the funds may not be amended in any material respect without written notification to the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days before the proposed effective date of the amendment. The licensee shall provide the text of the proposed amendment and a statement of the reason for the proposed amendment. The trust, escrow account, Government fund, or other account may not be amended if the person responsible for managing the trust, escrow account, Government fund, or other account receives written notice of objection from the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, within the notice Period.

14 of 21

LR-N1 9-0064 Regulatory Commission's regulations.

(Deleted)

License Condition (2.C.30) (SGS-2)

The decommissioning trust agreement for Salem, Unit 2, shall be subject to the following: (Deleted)

.a: The decommissioning trust agreement must be in a form acceptable to the NRG.

(Deleted) 10 CFR 50.75(h)(1)(i)

LAR 51 9-04 LAR H 1 9-04 The trustee, manager, investment advisor, or other person directing investment of the funds:

(8) Is obligated at all times to adhere to a standard of care set forth in the trust, which either shall be the standard of care, whether in investing or otherwise, required by State or Federal law or one or more State or Federal regulatory agencies with jurisdiction over the trust funds, or, in the absence of any such standard of care, whether in investing or otherwise, that a prudent investor would use in the same circumstances. The term "prudent investor," shall have the same meaning as set forth in the Federal Energy Regulatory Commission's "Regulations Governing Nuclear Plant Decommissioning Trust Funds" at 18 CFR 35.32(a)(3), or my successor regulation.

Regulatory Requirement of 1 0 CFR 50. 75(h)

While this wording is not explicitly stated in the revised regulations of 10 CFR 50.75, the intent of this license condition is the basic focus of the NRC's 2002 rulemaking (67 FR 78332). In that rulemaking, the NRC stated that "[t]he amendments to NRC's requirements for decommissioning trust provisions of nuclear power plants require that decommissioning trust agreements.be in a form acceptable to the NRC in order to increase assurance that an adequate amount of decommissioning funds will be available for their intended purpose" (67 FR 78349 (emphasis added)).

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.b: VVith respect to the decommissioning trust fund, investments in the securities or other obligations of Exelon Corporation or affiliates thereof; or their successors or assigns are prohibited. Except for investments tied to market indexes or other non nuclear sector mutual funds, investments in any entity owning one or more nuclear power plants are prohibited.

(Deleted) 10 CFR 50.75(h)(1 )(i)

LAR 5 1 9-04 LAR H 1 9-04 The trustee, manager, investment advisor, or other person directing investment of the funds:

(A) Is prohibited from investing the funds in securities or other obligations of the licensee or any other owner or operator of any nuclear power reactor or their affiliates, subsidiaries, successors or assigns, or in a mutual fund in which at least 50 percent of the fund is invested in the securities of a licensee or parent company whose subsidiary is an owner or operator of a foreign or domestic nuclear power plant. However, the funds may be invested in securities tied to market indices or other non-nuclear sector collective, commingled, or mutual funds, provided that this subsection shall not operate in such a way as to require the sale or transfer either in whole or in part, or other disposition of any such prohibited investment that was made before the publication date of this rule, and provided further that no more than 10 percent of trust assets may be indirectly invested in securities of any entity owning or operating one or more nuclear power plants.

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LR-N1 9-0064

.c: :+l=le EleeemmissieRiR§ tF1::1st a§FeemeRt feF Salem, blRit 2, m1::1st 13rnviee tt:lat Re eisel::lFSSFfleRtS 9F 13aymeRtS fF9Ffl tRe tFl::lSt SRall ee maEle ey U=le tF1::1stee l::lRless ue tF1::1stee Ras fiFst §i>,{eR U=1e QiFeeteF, Gffiee ef N1::1eleaF ReaeteF Re§1::1latieR, JQ Elays J3FieF >NFitteR Retiee ef 13aymeRt. +Re EleeemmissieRiR§ tF1::1st a§FeemeRt sRall fl:lFtReF S9RtaiR a J3F9¥isieR tRat A9 Elisel:lFserneRts eF 13aymeRts frnrn tRe tr:1;1st sRall ee rnaEle if tRe tFl:lstee Feeeives 13rieF

>NFitteR Retise ef eejeGtieR fFem tRe NRG.

{Deleted)

.d: +Re EleeemrnissieRiR§ tF1::1st a§FeemeRt Ffll:lSt J3F9¥iEle tRat tRe a§F88ffi8Rt GaRAet ee arneREleEI iR aRy mateFial Fes13eGt witRe1::1t J3FieF tA{FitteA eeAseAt ef tt::le QiFesteF, Gffise ef N1::1GleaF Reaeter Re§l:llatieR. {Deleted) 10 CFR 50. 75(h)(1 )(iv)

LAR 51 9-04 LAR H 1 9-04 Except for withdrawals being made under 10 CFR 50.82(a)(8) or for payments of ordinary administrative costs (including taxes) and other incidental expenses of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, no disbursement or payment may be made from the trust, escrow account, Government fund, or other account used to segregate and manage the funds until written notice of the intention to make a disbursement or payment has been given to the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days before the date of the intended disbursement or payment.

The disbursement or payment from the trust, escrow account, Government fund or other account may be made following the 30-working day notice period if the person responsible for managing the trust, escrow account, Government fund, or other account does not receive written notice of objection from the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, within the notice period.

10 CFR 50.75(h)(1 )(iii)

The trust, escrow account, Government fund, or other account used to segregate and manage the funds may not be amended in any material respect without written notification to the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days before the proposed effective date of the amendment. The licensee shall provide the text of the proposed amendment and a statement of the reason for the proposed amendment. The trust, escrow account, Government fund, or other account may not be amended if the person responsible for managing the trust, escrow account, Government fund, or other account receives written notice of objection from the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, within the notice Period.

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LR-N1 9-0064

.e: +he af3f3F9f3Fiate sestieA ef the EleseFflFflissieRiA§ tFust a§FeemeAt shall state tl=lat tl=le tFustee, iA11estFfleAt aE111iseF, eF aAyeAe else EliFestiA§ U:te iRvestmeAts Fflaee iA U=le tF1::1st shall aeheFe te a 11f3F1::JElent iA\\<esteF" staReaFEt, as sraeeifieEI iR

 g GFR 38.Jº>>aHJ) ef tl=le FeSeFal eReF§y Re§ulatery GeFflFflissieA's Fe§ulatieAs.

(Deleted)

License Condition (2.C.1 5) (SGS-1) e*eleR GeAeFatieR G9FflJ3aAy sl=lall take all AeeessaPi steras te eAs1::1Fe tl=lat tl=le eeseFflFflissieRin§ tFust is FflaintaineEI iR aseeFElaAee witl=l the araralisatieA feF a1313Feti1<al ef tl=le tFansfeF ef the SaleFfl, bJRit

, liGeRse te it aREI tl=le FeEf UiFeFfleRts ef tl=le GFEleF af3f3FeviR§ tl=le tFaRsfeF, aREI sensisteRt 1.Nitl=l tl=le safety evaluatieR s1::1rapertiR§ the GFEleF. (Deleted)

License Condition (31 ) (SGS-2) e*eleA GeReratien G9Fflf3any sl=lall take all nesessapt ste13s te ensuFe tl:lat tl:le eeGeFflFflissieRiR§ tFust is FflaintaiReEI iR asserElaRse 11.<<iU:t tt:le ara13lisatieR feF aprare1,<al ef tl:le tFaRsfer ef its ewReFsl:li13 iRteFest iR SaleFfl, bJnit º' lisense aRe tl=le FeEf l::liFeFflents ef tl:le GFEleF aJ313Fe11iR§ tt:le tFaRsfeF, ans sensistent v1itl=l tl=le safety evaluatieR surapertiR§ the GFEler. (Deleted) 10 CFR 50. 7 5(h )( 1 )(i)

LAR 51 9-04 LAR H 1 9-04 The trustee, manager, investment advisor, or other person directing investment of the funds:

(8) Is obligated at all times to adhere to a standard of care set forth in the trust, which either shall be the standard of care, whether in investing or otherwise, required by State or Federal law or one or more State or Federal regulatory agencies with jurisdiction over the trust funds, or, in the absence of any such standard of care, whether in investing or otherwise, that a prudent investor would use in the same circumstances. The term "prudent investor," shall have the same meaning as set forth in the Federal Energy Regulatory Commission's "Regulations Governing Nuclear Plant Decommissioning Trust Funds" at 18 CFR 35.32(a)(3), or any successor regulation Regulatory Requirement of 1 0 CFR 50. 75(h)

This license condition is no longer needed based on the provisions of 10 CFR 50. 75(h) and the licensee's decision to comply with that section's decommissioning trust agreement requirements.

In addition, as noted in the NRC's 2002 rulemaking, "the NRC has always believed that it is preferable and more efficient to adopt standard rules, as opposed to applying specific license conditions on a case-by-case basis" (67 FR 78334). This license condition is effectively addressed by the standard requirements codified in the regulations.

Regulatory Requirement of 1 0 CFR 50. 75(h)

This license condition is no longer needed based on the provisions of 10 CFR 50.75(h) and the licensee's decision to comply with that section's decommissioning trust agreement requirements.

In addition, as noted in the NRC's 2002 rulemaking, "the NRC has always believed that it is preferable and more efficient to adopt standard rules, as opposed to applying specific license conditions on a case-by-case basis" (67 FR 78334). This license condition is effectively addressed by the standard requirements codified in the regulations.

18 of 21

LR-N1 9-0064

4.0 REGULATORY EVALUATION

4.1 No Significant Hazards Consideration Analysis LAR 5 1 9-04 LAR H 1 9-04 The proposed changes do no more than delete specific license conditions relating to the terms and conditions of decommissioning trust agreements and license transfer commitments associated with funding extended plant shutdowns. In 10 CFR 50. 75(h)(4), the NRC (Commission) determined that such an amendment does not normally involve any significant hazards consideration:

(4) Unless otherwise determined by the Commission with regard to a specific application, the Commission has determined that any amendment to the license of a utilization facility that does no more than delete specific license conditions relating to the terms and conditions of decommissioning trust agreements involves "no significant hazards consideration."

The requested changes are consistent with the type of license amendment permitted in 10 CFR 50.75(h)(4).

The proposed deletion of the license conditions relative to commitment to funding an extended plant shutdown does not alter any plant system, structure or component nor does it alter any requirement relative to plant operations. The propose change eliminates a legacy concern from the time of license transfer between PSE&G and PSEG Nuclear LLC that is no longer warranted and hence does not involve any significant hazard.

Pursuant to 10 CFR 50.92, PSEG has reviewed the proposed changes and concludes that the changes satisfy the criteria in 10 CFR 50.92(c) and 10 CFR 50.75(h)(4), and as such, the proposed changes do not involve a significant hazards consideration. The criteria in 10 CFR 50.92(c) require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The discussion below addresses each criterion and demonstrates that the proposed amendment does not constitute a significant hazard.

1. Do the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The requested changes delete License Conditions which pertain to the decommissioning trust funds for Salem Generating Station (SGS) and Hope Creek Generating Station (HCGS) and to funding an extended plant shutdown.

These requests involve changes that are administrative in nature. No actual plant equipment or accident analyses will be affected by the proposed changes.

Therefore, the proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.

1 9 of 21

LR-N1 9-0064 LAR 5 1 9-04 LAR H 1 9-04

2. Do the proposed amendments create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

This request involves administrative changes to the Renewed Facility Operating Licenses (FOLs) of SGS Units 1 and 2 and HCGS relating to the terms and conditions of the decommissioning trust agreements and to funding an extended plant shutdown.

The proposed changes will be consistent with the NRC's regulations at 10 CFR 50.75(h).

No actual plant equipment or accident analyses will be affected by the proposed changes and no failure modes not bounded by previously evaluated accidents will be created.

Therefore, the proposed amendments do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Do the proposed amendments involve a significant reduction in a margin of safety?

Response: No.

This request involves administrative changes to the SGS Units 1 and 2 and HCGS FOLs that will be consistent with the NRC's regulations set forth in 10 CFR 50. 75(h).

The request also involves removal of extended shutdown funding requirements for both stations that are historical in nature and are no longer warranted.

The changes being proposed are administrative in nature. Margins of safety are associated with confidence in the ability of the fission product barriers to limit the level of potential dose to the public. No actual plant equipment or accident analyses will be affected by the proposed change. Additionally, the proposed changes will not relax any criteria used to establish safety limits, will not relax any safety systems settings, nor will they relax the bases for any limiting conditions of operation.

Therefore, the proposed amendments do not involve a significant reduction in the margin of safety.

Based on the above, PSEG concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.2 Precedent The proposed changes are consistent with those previously approved for Indian Point Nuclear Generating Unit Nos. 1 and 2 (Reference 2), Oyster Creek Nuclear Generating Station (Reference 3), and Comanche Peak Steam Electric Station, Units 1 and 2 (Reference 4) 20 of 21

LR-N1 9-0064 4.3 Conclusion LAR 51 9-04 LAR H 1 9-04 Based on the considerations discussed above: ( 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendments are confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii} changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

6.0 REFERENCES

1.

NRC Final Rule for Decommissioning Trust Provisions (Volume 67 Federal Register 78332 - 78352), published December 24, 2002

2.

Letter, NRC to Entergy Nuclear Operations, Inc., "Indian Point Nuclear Generating Unit Nos 1 and 2 - Issuance of Amendment No. 61 and No. 289 RE:

Deletion of Facility Operating License Conditions Related to Decommissioning Trust Provisions (EPID L-2018-LLA-0180)" dated March 21, 2019 (ML19065A101)

3.

Letter, NRC to Exelon Generation Company, LLC, "Oyster Creek Nuclear Generating Station - Issuance of Amendment RE: Deletion of Facility Operating License Conditions Related to Decommissioning Trust Provisions (CAC No.

MF9293)," dated June 23, 2017 (ML17067A042)

4.

Letter, NRC to TXU Energy, "Comanche Peak Steam Electric Station (CPSES),

Units 1 and 2 - Issuance of Amendments RE: Deletion of Unnecessary License Conditions and Reporting Requirements (TAC Nos. MB5770 and MB5771),"

dated May 15, 2003 (ML031350770) 21 of 21 LR-N1 9-0064 LAR 5 1 9-04 LAR H1 9-04 Mark-up of the Current Salem Generating Station U nit-1 Facility Operating License Pages 1

LR-N19-0064 (B}

Iodine Monitoring The licensee shall implement a program whJch will ensure the capability to accurately detemiine the airborne iodine concentration ln Vital areas under accident coodruons. This program shall iflclude the following:

t.

Training of personnel;

2.

Procedures for monltoong. and

3.

Provisions for maintenance of sampling and analysis equipment (9}

Backup Metllod far Determrning Subcooling Margin LAR 519-04 LAR H19-04 The licensee shall implement a program whidl will ensure the capability to accurately mooitor 1he Reactor Coolant System subcoofing margin. Thrs program shall include the following:

1.

Training Of personnel. and

2.

Procedures for monitoring.

{10} Additional Coooltions ITEM '1 1 The Additional Conditions contained in Appendix C, as revised through DELETED.

Amendment No. 246,. are hereby mcorparated into this renewed Ucense. PSEG

...,"' Nuclear LLC shall operate the tacilily in accordance with the Addmonal Conditiomt

{11) 12Sti&G lQ PE NYdedr llC YGQIQSQ Ti:xi8fer CGA.QR8 FSG tilui;lear bbC gf:taH tai<& all R&GessaPJ &t9P8 tg &RS\\Jre that tl:Je Eleea mmmemAQ trust is maifltalne iR a££emoe with ttm af>Plieatio, the requimmeRts ef the OFEler.i\\f>pnw1ng Tfansfer et Li£f!Se aAd CeAfe1miAg i\\meAEimem. eatea FeBft.JaFy 16., 2009. ane related Safe!\\* EvakdaliaR eietee Fehruary 16. 200<1.

1. Tils YSQ* Qf a&&ets iR bGtt:l the quaifi9d agg QA \\;lYalmed rtJRgg shall be limimd to &;.:p&Rs&& latsd to dsc;emmis;iQAilRQ Qf the YRil Q&r#l:led by tRe: WRC JR Its P&QYlatiQR& and i&it!aRG86. aRd as

• 1R Ynieg RSJ;i!"8d UG9RS& :n1d iJ'IY 3m9RdR:l9r:Jtg th8fQtQ. HQ.wewr:. Ypoo comJ:tl Qf deeomisfQniA91 as defit:1t9d abQ!l:Q, th& as&sts may bQ 1:Jsee fer any 13urpese ooliertzea ey law.

2. lR'i'estmeflts iR the seel:lAties er ether abUgatieAS af PSE&G er affiliates tf:leroef, or their sueressBfs ar assigns, shall 9e,:JFehibitet fA additieA.

Renewed license No. DPR-70 2

LR-N19-0064 ffEMS 13 THROUGH 15 ARE DELETED LAR 51 9-04 LAR H19-04 exeet fer iFr1estrfH3flts tiea te mafket :iA08*es er attl!er aoo mrelear seeter mHtHal fHAes. iRwstmems 1R ilH'f e* 0YIFHRf1 eRe er m9f8 ma£4eer power pants shalt oo J:}fOOmited.

J_ Ng disbur'steme.U Gr p:aymeRts fmm the tmst shall be made by 1he tmstee YRtil tl:te wstee ha:s *m:st Qi'..-ren #le NRC 3Q days ootk:a Qf th@

paymeRt. IA addi1tQR, RQ gjgbg[tgQR'!&R{g Qf pajim&Rt& fmm *tf:lg trust Rall QQ miQQ jf tR@. tl:Ystae 1=9Geii¥8& RQf VNitt&R Rb'tk& gt @bj&diOR ftgm tA&

Di00:cter. Oftiee af Nuclear Reader Re§utatleR.

4. Tue trust S§Feemet shall Ret ae JHeeffo iR aAY matefial Feeet wffheut Jl!ABF wrmeA RefifieatieR te the rnr-e:eter Qm:e:e ef N1:1eJear Reaeter Re§lilatien.

5. TI-le tmstse. *iR'IJ9stR:'leRt adk>i&Gr, gr aR}toRe elsQ dimctiRQ #le iA¥eWJ:tenm made iA the trust shall aih8ra to a Aldem liw&&tGr' staooam, as gcm8d iR 12 CR l5.'J(l) Qf tl:JiQ QQ8f31 9ry R;gU]alQlY CQRURissiQfl's r99YlatiGRs.

.G-:-

PSEG Nuclear tlC sRall Am tdl<e any d(:tfcm that *NOU/d QYSS f!SEG f!gwer LLG BF its 19aFeflt eempa1-1ies te 'leis, EiJAeel, er aiFftiAisA "IRe eemmilmeRt ta Ra aFt. B*t:eRaes plaRt st:lt1teeWfl as i:epreseRtea iR the :fliiealioA for ap.J3m'al sf tRe traRSfer ef Utls lieense fmm flSE&G te PSEG HJ:Jelear l+/-C.

(12) Exelon Generattoo Company shall provide to the Director of Ile Office of Nuclear Reactor Reguf.afion a copy of any application, at the time it is filed, to transfer (exctuding grants of security interests or liens) from Exefon Generation Company to its direct or indirect parent, or to any other affiliated company, faciHties for the produdioo. transmissioo, or dis1rbution of elecmc energy having a depreciated book value exceeding ten percent (10%) of Exelon Generatfon Company's consolidated net utilil'J plant. as recorded oo Exelon Generation Company's books of account

&eleR Generalioo CempaAy shall RiJve. eeeamisieAifl trust fuAas mr Salem Unit 1, 1A too follm*Jift§ minir;u:1m ameHAt eR Uie E1esiR§ aate of the lieense tfoosfer:

(14) Tue dQtQR:ilm3iQRiAQ tru&t aQemeRt fgr Salem, 1 Jnit 1. silall b@ &Yb]ad m ttw fgl1Qwi19:

{a)

TIIQ decgmmiSsioning trust agpB&meRt mGst ba iR a f9m:1 acceptable to tf:I&

00 With resped ta ttle deeommissiomg ttu5t fund. investmeRts iR the seoofities er att=ier ebHgattos of EmfoA GoFf)OfaOOR or affiliat-es tffer=et. or their stJeeesaFS er assi§1s are prahilJlteEI. &eeJt fer investmeRts tiOO ta mafket Renewed License No. DPR-70 3

LR-N1 9-0064

• 7..

LAR 51 9-04 LAR H1 9-04 f!Aee*es er ether Aon :ntaelear seeter ffmh:1QI h:mes:i rw1es.tments in aAy emtity ifl§ 'iJRe err m'*e nustear power ?lams we pFGmbi1ed.

00 n+e EH!OOFRFF!iSsieAiA§ 1A:JSt a§reemeFlt fer Salemr UAW 1 i mYSt fl!FEJ"AEfe that Ae ais9ur&emeeBy-tiess tt-le tftlstee t.ae fiF&t §LveR tFiie Direetsr et the OOiee et t1;1eiear Reaeter Reüatio 30 Sa :pi!ier Wr4bA AGtiGe af payment The daiaemmisioiA{J tr-c.st agr-eemeAt al:\\aU *l'\\ilfther QGAlaifl a pretiAsiaA that AQ £.tls&Ho1FaemeR¢s ar payments fmm t.e trt-Jst el!lail t1e malile if tt1e rl;t6tee FeEiE!hfe; pfiar v.witteA notiee of ElbjeeltoA frem l:he NRG.

{a}

The deoomisiGF1ing trust agr:eem-eAt must provfde thalt the agFeemeAt OOA net.be.a.miem1oo in any materiatuR:lspee:fwi 30 days priGF mlten f.latifteatioA le the Dlrooror ef the OOk#e of Nuvfear Reaater Relatioo.

ta}

The appropriate sec;;tiaA of the-deoomisk:lr:dR§ tnast agteemant shI tlhe*-4fU$ffJ&rit"a.fr*My$fll&MFnJifaeliflg.*tls mad irrth&trust"ahalJ,,a$l&l!een"irwestGf!tamdarora&'$fJOOff#*in 18 CFR !l6.32(a)(3) at the F&deFal EAa1tgy RegY!awry Cemmia.iOJ'l's wNittiSRIS, (15J &elefl GeAe:ratioA Company.shal take au AGOessel)l Sleps lt'Hmsuro that lhe eeaemmtasioo tmsH51MintaiAed-if'Hlt>>-Wilh the eppUeatlef'Hor appmval ef !he tmnsfer el the Satem1 Yf!lit 1, Usemse te it aAa 'he Feir-ements ef tt;e-.QrdeF appn.wing 1he tmnefer.uanet* Genl'lHvith the safety evakEtim euf*efthi the Off.liar.

(16) Mitigalio.n Slrateav The* ificensee :shaU develop and matntain strategies for addresstng large fires and explosions and that lnctude the fofk>wilng key areas:

(a)

Fire iightmg response strategy 'With th& fomowlng elements:

1. Pre-defined coordinated fire r&$pOOSe strategy and guidance

2. Assessment Of mutual aid fire fighting a

3. Designated staglng areas for equipment and materials

4. Command and control

5. TrainPrig of respcnse pef$0nnel (b)

Operations to mfiigate fuel damage considering the foMowlng:

1. Protection and use of per$00nei assets

2. Communications

3. Minlmb:ing lire spread

4. Procedures for implementing Integrated fire response strategy

5. Identification ot readlly...avallabte presta.ged equipment

6. Training on integrated fire response strategy

7. Spent tu.el pool miliga1kln measures 4

Renewed license No. DPR..;70 Amendment No,, 316 LR-N1 9-0064 LAR 51 9-04 LAR H1 9-04 Mark-up of the Current Salem Generating Station U nit-2 Facility Operating License Pages 1

LR-N 19-0064 ITEM 27 DELETED (26) Additional Conditions LAR 5 1 9-04 LAR H19-04 The Additional Condruoos contained in Appendix c as revised 'through Amendment No_ 227 are hereby incorporated into this renewed license. PSEG Nudear LLC shall operate the facility in accordance with Ure Additional conditions.

PSE&G TO PSeG Jlluclear LLC Ucense TFaRSfer GondltiORS a:

PSEG l:ldear LLC sf'laD take all necessary ste13s tu eRSHre tt:lat #le decommisioning trust is maintained ifl acromance *:14th the apf)Hcatio, the FeflYiremeRts of the Order Appro"ARft TfaRsfer of Liam*se am1 Goofer:miRg l'.mensmeAt, sate9 fel3ruary 1. 2QQQ, aRe tRe relates Safety E\\iai1:tatieA datee feeruaiy te. 2QOQ_

G:-

TRe eecommis:roaing trnst agreement shaH f)fQYide that

+.

The use of assets iR boll the qualified ans noo qtaaJmed fllnds shall be limited to expenses related to tJesemmlssk>AiR!J of the ttnit as aefinB\\1 by the NRG in its reg1Jlations aRa issuances and as prrn.'ided iR the llRirs Fene\\"Jed iiceAse and any amendments Ylerero. 1=1mr1e*.-er. upon completioR of decommissiaRiR§, as def.inee abeve" tne assets may ee usi*I fer aR){ fH:IFflGSe a0tfi9fize bl)' law lnvestfneRts iR tRe se£Hlities or etl:ler ebligatieRS et P8E:&G er aff.mates tf:lemaf, Gf U1eir Sl:IG60SS9FB Of asSi§RST shalt tie 13mt:llelteG_ JR amUtieR.

f*cept for iRvestmeAts tiee te maF]{;et indexes or ether mm A1:1sear sestor m1:1wa1 fl:nids, iR*1esimeRis iR aRy entity OWRiB§ ooe er mere nYEJear pt:>'Ner plaAts sf:Jall l:Je fJmRieifee_

3:-

Na diSIJursemeRts or payments from the trust shall be made by the trustee 1:1atu theJrnstee has iiFBt giveR the NRG gg Elays natiGe ef the paymeRf_ IA aEieitien. ne disbursenmnts or payments from U:le trust shaU ee maee if ihe trustee reGeiYes JlROr 'NFitteR netit::e sf osjestieR ffeFR 1he Director, OOite of Nudear Reactor RegYlaUen_

4:-

The trust agreement shal Hot ee modified in aRY material resped i."'iitheut pfier 'tlfitieR RetmGaiieA ts the Qlredar, Office ef NYGlear R.eader Reg1:1laYon_

a:.

The trnsiee, irn.*estmeRt amAisor, or tmyone else diFediRg the iFnestments made in the trust st:laH adhere m a "pfuseRt ifwestor"' stanearn as speefied iA 18 Cf'.R a.32 et tRe Fe9efal f2Refgy Re§YlatSEY Commjsiofl's Fe§latiens PSEG Nudear LLC sJ:laU HGt take ;my action that WOl:lld tause PSEG Pew:er LLG er its parent oomptmies te veia caRGel, er dimiAish tl'le oommitment lo Renewed License No. DPR-75 2

LR-N1 9-0064 ITEMS 29 THROUGH 31 ARE DELETED

 LAR 5 1 9-04 LAR H 1 9-04 fooG an e*1eAGed plaAt sootdatA'fl as represeAted iR the applicaeon for af)f)fG\\'al et tl:ie tr-aHSfer ef" this liteAse ffem PSE&G te P-SeG til1:1tlear LLC.

{28} Exelon Generation Company shall provide to the Director of the Office of Nuclear Reactor Regulation a copy of any appncation. at the time it is filed. to transfer (excluding grants of security interests or liens) from Exelon Generation Company to tts direct or 1ndirect parent. or to any other amuated company, facilities for the production, transmission, or distribution of eledric energy having a depreciated book vatue exceeding ten percent {1 rr'k) of Exelon Generation Company's consolidated net utility plant, as recorded on Exelon Generation Company's oooks of account.

(29) BmleA GeneratkJH Cempaay shall ha\\'e aec::smisioniA§ 1RJst fllnes fer Salem, Unit 2 fn the folowiAg miiimYm ame4.1At GA the tlesing f1ate ef the: lleAse transfer ts-it-Salem. Unit 2

$4aJlfi9;ao2 (gQ) The aeeemtsienIR§ 1fyst aoi:eemeAt fer Salem, Um 2. sl=lall ee sejed ts the follo"Ang:

a::

The eerommissioning wst agFeemeRt mast be in a foEm acr;eptable lo the NRG:-

G:-

With r:espect to the deeemissieRiR§ tfl:Jst flilfld, iRvestmeAts iR tJ:m securities er e#ler et=>!igatisAs ef E:xeleR Gerpefatio er amliates lReFeef; sr their sYstessers er assi§RS ar:e pret=tie1teE1. ExGefi'f far iRves1meRfi tiee te maFI indexes or ether non Ruclear sedor mutual runes, irn.testments in any entlty 0¥1'.Rifl§ OAe er moFe 1n1cJear power plaflts are pffiAil:Jfted.

Tlle deGemmisioHing trust agraemem for Salem UAit 2. must provide that ne eismnsements ar payffleRts fmm the trust st:lall be maee 9)f the trustee YAless the trustee has fiFSt giveR t:Re Directer. Offfe of Nuclear Reader RegY0tion, gg flays pFier *Nfitten netice ef paymeRt The eeeemissieRiR§ wsi agreement shall rur:ther oontaiR a pw:isioR tt:iat RG mseuFSements or payments ffem the trnst st:iau be made if the trustee fecei'iles poor *Nfitten ootiee of ebjedjen frem the NRG.

4 The decommisioniHg 'fnlst agmemeRt mast provide that the ag1eement can oot se ameneeEi iR aRy mateFial r-esee vmh01:1t pfier wrltteA ooRseRt ef the OiFedOf, OffiGe of NuGlear Reader R9JYt:ltioR.

The appmpriate sediGo ef the fieoomissiotng wst agreeRleflt st.all state that the trnstee, investr:nent advisor, Gr ar::tyeAe else eiredmg #te investments made in #le trust sflall adhere to a "prueest iR'lestar" staReam. as speemed in 18 GFH 3a.a2(ana) ef1Re Feeeral eRef§Y RegYlaIDPJ' CemmisioA's reg1:1latiens.

Renewed License No. DPR'."75 3

LR-N1 9-0064 LAR 51 9-04 LAR H 1 9-04

(!t) E* Gelletab c* shal take all AF)1 *5tep& te efl&ure that the iseio,.. ftd i$. maimainoo m eeee wilppffeatiefrfeF aw d the hfmfef *of* u OW"1ership iAlerest in Smem* Urtttai lieene a tem.-ef tne Ofder appf't'.WiAU 1he tra.Asfer: aAd SCR&istent with the aaf11y e*slA GftiAg *tf:ie Order.

(32) ilgglk;mnStr*QY The It* $hlil* develop and maintain strategies for address.tog large fires and e:xplosiom and that include the fotlowlng key areas:

a.

Fllre fighting r.esponse strategy with the following atements:

t Pre-defined coordinated fire response strategy and gufdartee

2. Anessment of mutuaJ aid tire 'fighting a$$S1$

3. DesJgoated staging area$ tor equipment and matenaf$

4. Cemmand and eontra

s. Training or respoose personnel b;

Operations to mitigate fuel damage considering l'le following:

1. Protection.and use of personnel assets

i. COmmunicatiQm

a. Minimir.g lite d

4. Procedures for menting integrated fire response strategy s;f tafmlibton ¢f reat11y+avmllble pr equipment

e. Training on fire response strategy 7.. Spent *fUet* pod mitigdcm measures c,

Adion1 to minima rdease to Inetude oonsldera1ion of:

1 Water spray saubbing t

Dose to onsi* rs (33) Upon impknentatkm cl Amendment No *. 269 adopting TSTF-448, Revision 3t the determimdcn of com.rd room envelope (CRE) unflitered air irieakage as required by SR 4.. 1.&at in with TS ft 11 c.(i). ttte assessment of CRE habitability as required by Sptciflcalan 6.17.c. (it-and* lhe measurement of CRE pressure as reqUired by Spedfication 6.17.dt shall be considered met Foilowing impfementaifon:

a.

The ftrst petfort'N:lnce of SR 4.7.6.2, in aooordanc& with Speclication 6. t7.c.(i), shall be Within the specified frequency of 6 years. pfu$.

the 18 month allowance of SR 4.0.2 as measured from June 4. 2003, ihe date of the 1T.10tt recent suat.::euful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01. Of within *the next 18 months if the Ume per1od :54nce the most recent successfut trace< gas

- Is greater than 6 years.

4

Renewed llc

ense No DPff.75 Amendment No,. 297 LR-N1 9-0064 LAR 51 9-04 LAR H 1 9-04 Mark-up of the Current Hope Creek Generating Station Facility Operati ng License Pages 1

LR-N1 9-0064 ffEM 1 f DELETED DELETED LAR 5 1 9-04 LAR H 1 9-04

{t3)

Safety Parameter Display System (Section 182 SSER No. 5)

DELETED

{14)

Additional Condltions The Additional Conditions contained 1n Appendix ex as revised through Amendment No. 135 are hereby incorporated into this renewed license.

PSEG Nuclear LlC shall operate the facility in accordance with the Additional Conditions.

PSf.&G to PSEG Nelear LLG LieeAse TFaAsfer CeAE:fitiens PSB; dear LLG skaN take all Reeesary steps te eRSE:IFe that the deoomisim;ing tr:ust is maimaiined iR aeOOFcfamse 'tVifh the applieatiem. the requiFeme1-1ts ef 1fm Omer l\\pr&liRg TmRsfer of UeeRse aad CeAferfHiRg l\\mem:lment, dated Fearuary 16, 2QQO.

and llG 1=8latad Safab1 Evartmioo dated FebmaJY 1 G. 2000.

4f The t:JSe ef assets iR helR the EJWatifieEI a.Ad RaR El'*llifled R:mds shall be l\\imitee te eAses Felated te seeemmisieniR§ ef the uRit as defiAea by tRe inc iR ils regulatiefls and isst:JaAes. clRd as Pffi\\'ided m the 1:1nit's reAewea lieeRSe aAel aAy aFReRdmeRls ti=lefele_ Mewe*.er, HpeR OOFRfpJetieR ef dee-OimisieAi:A§. as deiAee al3evc, the assets fflaJ be used fur aRy tiFJlese thfieel by law.

IR¥eSffleRts ifl the seanities er ether eeligatiaAs af PSE&G er affiliates tf:ieFeef. er their sueeeseFS eF assigAs.

2 Renewed License No. NPF-57 Amendment No. 193 LR-N1 9-0064 LAR 51 9-04 LAR H 1 9-04 shall SC f'r-OhihiteEJ lR aaeEfiefl. EBEe:ef* fer iRa!esiffleAl:s tieel to maFket iooe er ether AeA Auclear seeter ml:lturu ft.tREis, inveslmeRls iR af1¥ entity 0\\'ffing er:m er more Rttelear ewer planls sl=lalil he f1Fel=li9itea.

3}

No di:sbYrsemeHts or pa;qnRts from the trYst ahaH be mad9 by tha 1rns.t98 YRlil ths tr:ustaa ha8 fis:st 9i¥eA 1Re NRC 30 ddys ootics of the pa:yment IR additiGR

.* no disbYi:SQRUUls gr pasrms fmm #'tQ iR,;J;gf shall b& m41ld& if the wstec reeeiwes prier written neiie ef ebjeetim from tAe Direetor, Offie ef N1:1elear Reael!er Re§l=llatiefl.

4J The *trast UfJFeement :shalt Rel he meelified if! il.Jf'if material resped wit.ow. prier wriften mmfieatieA to the Uire&ter.

Offie &f N-=iclear Reader Regulation.

§}

The trustee invesimeRt ad*iser. or aRyer:te else direeliA§ the iR¥Cs&rleflts made iR the ift:lst sf:lalf aelheFe te a "pmd8Rt iR\\'r"' id::;u1d ag 8peGifisd iR

• rn CFR J5.3J(3) ofthe Fsderal Emugy Ragulatory ComR:ii:sgigR*g i:r991:1fafigf:)g_

e:

PSEG 41:1elear LLC shall Bet take BRJf aetiefl that v101:dd eawse PSEG Po*.. ver LlC er its par:eRt eemp.aAies te veid, eaneel, er aimiAish tRe eemFRitR:ieft te fuAd aR E>>de:AEled FJlam shuieewR as Fepresemea in ttte applieatieA for aproval ef the k:aHSfer ef this license from PSE&G to PSfG Nuclear LLC.

(1 6)

Mitigation Strategy The licensee shall develop and maintain strategies f.or addressing large fires and explosions and that indude the following key areas:

(a}

Fire fighting response strategy with the following elements:

• t.

Pre-defined coordinated fire response s1rategy and guidance 2..

Assessment of mutual aid flfe fighting assets

3.

Designated staging areas for equipment and materials

4.

Command and conlrol

5.

Training of response personnel (b}

Operations to mitigate fuel damage,considering the following:

1.

Protection and use of personnel assets

2.

Communications

3.

Minimizing fire spread 3

Renewed License No. NPF-57