LR-N14-0025, PSEG Nuclear Llc'S Second Six-Month Status Report for Hope Creek in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

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PSEG Nuclear Llc'S Second Six-Month Status Report for Hope Creek in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.
ML14058A229
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 02/25/2014
From: Davison P
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N14-0025
Download: ML14058A229 (18)


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 Order EA-12-049 LR-N14-0025 FEB 252014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

PSEG Nuclear LLC's Second Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
2. PSEG Letter LR-N13-0031, "PSEG Nuclear LLC's Overall Integrated Plan for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27,2013
3. PSEG Letter LR-N13-0173, "PSEG Nuclear LLC's First Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 22, 2013

FEB 252014 Order EA-12-049 Page 2 LR-N 14-0025

4. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-Basis External Events," Revision 0, dated August 29, 2012
5. Nuclear Energy Institute (NEI) Report NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012
6. NRC Letter to PSEG, "Hope Creek Generating Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NO. MF0867)," dated February 11, 2014 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to PSEG Nuclear LLC (PSEG). NRC Order EA-12-049 was immediately effective and directed PSEG to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. In accordance with Section IV.C of NRC Order EA-12-049, PSEG submitted an Overall Integrated Plan (OIP) for the Hope Creek Generating Station (HCGS), on February 27, 2013 (Reference 2). In accordance with Condition IV.C.2 of NRC Order EA-12-049, PSEG provided the first six-month status report to summarize the progress made in implementing the requirements of the Order, on August 22, 2013 (Reference 3). The purpose of this letter is to provide the second six-month status report for HCGS, pursuant to Condition IV.C.2 of NRC Order EA-12-049.

NRC Interim Staff Guidance JLD-ISG-2012-01 (Reference 4) endorsed, with clarifications, Nuclear Energy Institute (NEI) Report 12-06, Revision 0 (Reference 5) as an acceptable means of meeting the requirements of NRC Order EA-12-049.

NEI 12-06 provides direction regarding the content of the status reports; i.e., the reports should include an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, and the need for relief and the basis for relief, if applicable. Enclosure 1 provides the second six-month status report for HCGS, in accordance with the NRC-endorsed guidance of NEI 12-06.

Enclosure 1 reflects the status of FLEX implementation as of January 31, 2014 and includes a status of open items and confirmatory items identified in the NRC's interim staff evaluation report for HCGS (Reference 6). There are no changes in compliance method or requests for regulatory relief identified in Enclosure 1.

FEB 252014 Order EA-12-049 Page 3 LR-N 14-0025 There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please do not hesitate to contact Mrs. Emily Bauer at 856-339-1023.

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

I') - "\ !;'" - \ '1 Executed on ~ cJ..

(Date)

Sincerely,

~~~-\)~

Paul J. Davison Site Vice President Hope Creek Generating Station Enclosure 1: Hope Creek Generating Station Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc: Mr. E. Leeds, Director of Office of Nuclear Reactor Regulation Mr. W. Dean, Administrator, Region I, NRC Mr. J. Hughey, Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Manager IV, NJBNE Hope Creek Commitment Tracking Coordinator PSEG Corporate Commitment Coordinator

FEB 2 5 2014 ENCLOSURE 1 LR-N 14-0025 Hope Creek Generating Station Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Hope Creek Generating Station PSEG Nuclear LLC

ENCLOSURE 1 LR-N 14-0025 1 Introduction PSEG Nuclear LLC (PSEG) developed an Overall Integrated Plan (DIP) (Reference 1) for the Hope Creek Generating Station (HCGS), documenting the diverse and flexible coping strategies (FLEX) in response to NRC Order EA-12-049 (Reference 2). By letter dated August 22,2013 (Reference 3), PSEG transmitted the first six-month status report associated with the HCGS FLEX DIP. Provided herein is the second six-month status report, for the reporting period ending January 31,2014. This update follows the guidance in Section 13.2 of Nuclear Energy Institute (NEI) Report 12-06 (Reference 4), which states that the six-month status reports should include an update of milestone accomplishments since the previous report, changes to the' compliance method, schedule, and the need for relief and the basis for relief, if applicable.

Sections 2 and 3 of this status report include milestone accomplishments and milestone schedule status, respectively. There are no changes to compliance method identified in Section 4 of this report. Section 5 addresses the potential need for relief associated with the severe accident-capable hardened containment venting capabilities required by NRC Order EA-13-109 (Reference 8). Section 6 includes a status of the open items and confirmatory items identified in the NRC's interim staff evaluation for HCGS (Reference 20).

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the HCGS FLEX DIP, and are current as of January 31, 2014.

  • Submit Integrated Plan: PSEG submitted the HCGS FLEX DIP to the NRC.
  • Develop FLEX Strategies: PSEG has developed HCGS FLEX strategies as described in the HCGS FLEX DIP and has identified design, analysis, procurement, and programmatic actions necessary to achieve compliance with Order EA-12-049. PSEG is evaluating changes to the HCGS FLEX strategies, as identified in Section 6, below.

3 Milestone Schedule Status The following table provides an update to HCGS FLEX DIP milestones. The table provides the activity status of each item, and whether the original expected completion date has changed.

The dates are planning dates subject to change as design and implementation details are developed. The revised milestone target completion dates do not impact the Order EA-12-049 compliance date.

Page 1 of 14

ENCLOSURE 1 LR-N 14-0025 Original Revised Target Activity Target Milestone Completion Status Completion Date Date Submit Overall Integrated Plan Feb 2013 Complete Aug 2013 Complete Feb 2014 Complete Six-Month Status Update Aug 2014 Not Started Feb 2015 Not Started Aug 2015 Not Started Develop Strategies May 2013 Complete Modifications Develop Modifications Apr 2014 Started Aug 2014 Implement Modifications Apr 2015 Not Started May 2015 FLEX Support Guidelines (FSGs)

Develop FSGs Dec 2013 Started Apr 2014 Validation Walk-throughs or Demonstrations of FLEX Strategies May 2015 Not Started and Procedures (Note 1)

Perform Staffing Analysis Dec 2013 Not Started Dec 2014 (Note 2)

Develop Training Plan Jun 2014 Started Implement Training Dec 2014 Not Started Develop Strategies/Contract with Oct 2013 Started Oct 2014 Regional Response Center (RRC)

Procure Equipment Dec 2013 Started Nov 2014 Create Maintenance Procedures Jun 2014 Started May 2015 Page 2 of 14

ENCLOSURE 1 LR-N14-0025 Original Revised Target Activity Target Milestone Completion Status Completion Date Date Emergency Preparedness (EP)

Communications Improvements Jun 2014 Started May 2015 (Note 3)

HC Implementation Outage Apr 2015 Not Started May 2015 Report to NRC When Full Compliance Aug 2015 Not Started is Achieved Section 3 Table Notes

1) The validation walk-through milestone is not specifically identified in the HCGS FLEX OIP milestone schedule, but is added here as a follow-up to the milestone for development of FSGs.
2) The staffing analysis milestone's revised target completion date is aligned with the FLEX staffing study required by the 10 CFR 50.54(f) information request dated March 12, 2012 (Reference 5). PSEG's staffing analyses will address simultaneous ELAP scenarios at HCGS and Salem Generating Station, Units 1 and 2.
3) The original EP communications improvement milestone is the target completion date associated with the milestone to complete installation, procedure revision, and training for satellite phone base units and antennae (Reference 7). PSEG's regulatory commitment in Reference 6 is to complete communications improvements prior to restart from HCGS Refueling Outage 19 (H1 R19) in Spring 2015.

4 Changes to Compliance Method PSEG is evaluating changes to FLEX equipment storage and deployment strategies and will include the results of the evaluation in a future six-month update.

Page 3 of 14

ENCLOSURE 1 LR-N 14-0025 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation PSEG is evaluating the impact of NRC Order EA-13-1 09 (Reference 8) on the implementation of FLEX strategies as described in the HCGS FLEX OIP (Reference 1). The HCGS FLEX strategies depend, in part, on the ability to vent primary containment using a hardened containment vent system as prescribed by NRC Order EA-12-050 (Reference 9). NRC Order EA-13-1 09 rescinded NRC Order EA-12-050 and imposes additional requirements on containment venting capability in order to ensure reliable venting capability during severe accident conditions. NRC Order EA-13-1 09 also extends the implementation milestone for hardened containment venting via the wetwell by one refueling outage, commensurate with the increase in venting system requirements. HCGS is required to comply with the wetwell venting requirements of NRC Order EA-13-1 09 prior to restart from HCGS Refueling Outage 20 (H1 R20) in Fall 2016, whereas FLEX implementation pursuant to NRC Order EA-12-049 (Reference 2) is required prior to restart from H1 R19 in Spring 2015.

PSEG is evaluating the need for relief from the requirements of NRC Order EA-12-049, in light of the revised containment venting requirements in NRC Order EA-13-1 09. If PSEG determines that relief from the requirements of NRC Order EA-12-049 is necessitated by the change in containment venting requirements, then PSEG will request such relief via separate correspondence.

Page 4 of 14

ENCLOSURE 1 LR-N 14-0025 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a status of HCGS resolution of NRC Generic Concerns associated with mitigation strategies, as well as Open Items (Ols) and Confirmatory Items (Cis) that are identified in the NRC's interim staff evaluation for HCGS (Reference 20):

ID Item Ref. Description Status

1. Generic Concern HCGS is currently working on extending the battery duty cycle and is following In progress. PSEG

- Battery Life the industry position on battery life as outlined in the Nuclear Energy Institute expects to provide the (NEI) white paper dated August 27, 2013 (Reference 10) and endorsed by results of battery load NRC via letter to NEI dated September 16, 2013 (Reference 11). shedding and duty cycle evaluations by the August 2014 update.

2. Generic Concern HCGS is using the Modular Accident Analysis Program (MAAP) to complete In progress. PSEG

- MAAP the development of FLEX timelines and strategies, consistent with the NRC expects to provide a endorsement letter to NEI dated October 3, 2013 (Reference 12). summary of the results of the HCGS MAAP analyses by the August 2014 update.

3. Generic Concern HCGS will enhance shutdown risk processes and procedures using the Not started, with completion

- Shutdown I supplemental guidance provided in the NEI position paper entitled "Shutdown expected to be coincident Refueling Modes I Refueling Modes," dated September 18, 2013 (Reference 13) and endorsed with Order EA-12-049 by the NRC via letter to NEI dated September 30,2013 (Reference 14). compliance.

4. Generic Concern As part of the development of FLEX maintenance and testing programs, In progress with

- Preventive HCGS will use the EPRI Technical Report entitled "Nuclear Maintenance completion expected to be Maintenance Applications Center: Preventative Maintenance Basis for FLEX Equipment," coincident with Order EA-transmitted to NRC via NEI letter dated October 3, 2013 (Reference 15) and 12-049 compliance.

endorsed by NRC letter dated October 7, 2013 (Reference 16).

Page 5 of 14

ENCLOSURE 1 LR-N 14-0025 ID Item Ref. Description Status

5. Generic Concern With regard to maintaining containment, the implementation of Boiling Water In progress. PSEG is

- Anticipatory Reactor Owners Group (BWROG) Emergency Procedure Guidelines I Severe developing plant specific Venting Accident Guidelines (EPG/SAG), Revision 3, including any associated plant- containment venting 01 3.2.3.C specific evaluations, must be completed in accordance with the provisions of guidance based on NRC letter dated January 9,2014 (Reference 18). Revision 3 to the BWROG EPG/SAG, as described in Reference 17 and endorsed by NRC in Reference 18.

6. 01 3.2.4.8.E The use of pre-staged FLEX generators appears to be an alternative to NEI In progress. PSEG is 12-06. The licensee has not provided sufficient information to demonstrate evaluating changes to that the approach meets the NEI 12-06 provisions for pre-staged portable FLEX equipment storage equipment. Additional information is needed from the licensee to determine and deployment strategies.

whether the proposed approach provides an equivalent level of flexibility for responding to an undefined event as would be provided through conformance with NEI 12-06. I

7. CI 3.1.1.1.A Confirm licensee's evaluation of the HCGS Unit 2 structures verifies that the In progress. PSEG is I structures will meet the considerations described in NEI 12-06, Section 5.3.1 evaluating changes to (protection against seismic hazards). FLEX equipment storage I and deployment strategies. I
8. CI 3.1.2.3.A Confirm that the procedures and programs for deployment of portable In progress. PSEG is  !

equipment in a flooding event conforms to NEI 12-06, Section 6.2.3 evaluating changes to considerations 1 (incorporation of actions necessary to support flooding FLEX equipment storage deployment considerations into procedures) and 2 (additional guidance may and deployment strategies.

be required to address the deployment of FLEX for flooded conditions).

Additionally, procedures and programs need to address hazard concerns related to high winds, snow, ice and extreme cold and high temperatures.

Page 6 of 14

ENCLOSURE 1 LR-N 14-0025 ID Item Ref. Description Status

9. CI3.1.3.1.A Confirm that the licensee's separation of equipment stored outside is sufficient In progress. PSEG is to preclude all sets of equipment from being damaged by a single tornado. evaluating changes to FLEX equipment storage and deployment strategies.
10. CI3.2.1.1.A From the June 2013 position paper (endorsed by the NRC via Reference 12), In progress as part of benchmarks must be identified and discussed which demonstrate that MAAP4 resolution of the generic is an appropriate code for the simulation of an ELAP event at your facility. concern regarding use of MAAP for containment analyses (Item 2, above).
11. CI 3.2.1.1.8 Confirm that the collapsed vessel level in the MAAP4 analysis remains above In progress as part of Top of Active Fuel (TAF) and the cool down rate is within technical resolution of the generic specification limits. concern regarding use of MAAP for containment analyses (Item 2, above).
12. CI3.2.1.1.C Confirm that MAAP4 is used in accordance with Sections 4.1, 4.2, 4.3, 4.4, In progress as part of and 4.5 of the June 2013 position paper (endorsed by the NRC via resolution of the generic Reference 12). concern regarding use of MAAP for containment analyses (Item 2, above).

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ENCLOSURE 1 LR-N 14-0025 ID Item Ref. Description Status

13. CI3.2.1.1.D Confirm that in using MAAP4, the licensee identifies and justifies the subset of In progress as part of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP4 resolution of the generic Application Guidance, Desktop Reference for Using MAAP4 Software, concern regarding use of Revision 2" (Electric Power Research Institute Report 1020236). This should MAAP for containment include response at a plant-specific level regarding specific modeling options analyses (Item 2, above).

and parameter choices for key models that would be expected to substantially affect the ELAP analysis performed for that licensee's plant. Although some suggested key phenomena are identified below, other parameters considered important in the simulation of the ELAP event by the vendor / licensee should also be included as follows: Nodalization, General two-phase flow modeling, Modeling of heat transfer and losses, Choked flow, Vent line pressure losses, and Decay heat.

14. CI3.2.1.1.E Confirm that the specific MAAP4 analysis case that was used to validate the In progress as part of timing of mitigating strategies in the Integrated Plan is identified and available resolution of the generic for NRC staff to view. Alternately, a comparable level of information may be concern regarding use of included in the supplemental response. In either case, the analysis should MAAP for containment include a plot of the collapsed vessel level to confirm that TAF is not reached analyses (Item 2, above).

(the elevation of the TAF should be provided) and a plot of the temperature cool down to confirm that the cool down is within technical specification limits.

15. CI 3.2.1.2.A Insufficient information was provided relative to recirculation pump seal or In progress as part of other sources of leakage used in the ELAP analysis. Additional information is resolution of the generic required to evaluate the amount of seal leakage that was used in the HCGS concern regarding use of transient analyses and how the seal leakage was determined. This MAAP for containment information will need to include the technical basis for the assumptions made analyses (Item 2, above).

regarding the leakage rate through the recirculation pump seals and also other sources. Also include the assumed pressure-dependence of the leakage rate, and whether the leakage was determined or assumed to be single-phase liquid, two-phase mixture, or steam at the donor cell, and discuss how mixing the leakage flow with the drywell atmosphere is modeled.

Page 8 of 14

ENCLOSURE 1 LR-N 14-0025 ID Item Ref. Description Status

16. CI 3.2.1.3.A The SOE Timeline in the Integrated Plan is tentative. The licensee addressed In progress. PSEG expects this issue during the audit process by describing that the SOE timeline to provide finalized presented in the Integrated Plan will be finalized based on plant-specific timelines by the analysis, procedure development and timeline validation. Confirm that the February 2015 update.

final SOE timeline is acceptable.

17. CI 3.2.1.3.B The licensee stated that they are performing a HCGS specific MAAP4 In progress as part of analysis consistent with the NRC endorsement letter to NEI dated resolution of the generic I

October 3, 2013 (ADAMS Accession No. ML13275A318) (Reference 12), to concern regarding use of I validate the timeline and NEDC-33771-P applicability. Confirm that the MAAP for containment results of the evaluation and validation of the SOE timeline are acceptable. analyses (Item 2, above).

I

18. CI 3.2.1.4.A Additional technical basis or a supporting analysis is needed for both FLEX In progress. PSEG i

pumping system (one engine/pump located at the SWIS and one motor/pump expects to provide the located in the reactor building) capabilities considering the pressure within the results of HC FLEX design I

RPV and the loss of pressure along with details regarding the FLEX pump activities by the August supply line routes, length of runs, connecting fittings, to show that the pumps 2014 update. I are capable of injecting water into the RPV with a sufficient rate to maintain and recover core inventory for both the primary and alternate flow paths as well as supplying water [to] the SFP. The licensee addressed these issues I

during the audit process and stated that this analysis will be performed as part of the design change process. Confirm that the analysis results are acceptable.

I

19. CI 3.2.1.6.A Confirm that the results of the final sizing calculations for the SRVs In progress. PSEG I

accumulators, the final temperature profile of the drywell, DC coping results expects to provide the and the results of the GOTHIC temperature modeling for the reactor building results of GOTHIC are acceptable. modeling and analyses by the August 2014 update.

Page 9 of 14

ENCLOSURE 1 LR-N 14-0025 ID Item Ref. Description Status

21. CI3.2.3.A A site-specific analysis (MAAP) will be performed to determine the correct In progress. PSEG time to open the HCVS vent and the expected drywell and wetwell expects to provide the temperatures during the BDBEE. This information will be included in a future requested information by six-month update. The site-specific analysis needs to include a listing of the February 2015 update.

critical drywell components that may be affected by the elevated temperatures (e.g., drywell seals and penetrations). Confirm that the analysis results are acceptable.

22. CI3.2.3.B The NRC staff questioned the ability of RCIC to operate with suction In progress. PSEG temperatures up to 230 degrees Fahrenheit. During the audit process, the expects to provide the licensee addressed this issue by stating that a RCIC durability study is in requested information by progress. Confirm that the results are acceptable. the February 2015 update.
23. CI 3.2.4.2.A Confirm that the GOTHIC analysis and/or technical evaluation performed to In progress. PSEG demonstrate the adequacy of the ventilation provided in all plant strategic expects to provide the areas (includins pathways for access to equipment) to support essential results of GOTHIC
f equipment operation thr~ughout all pha5e~ an ELAp
is' ~cceptable. modeling and afialys~§ by the August 2014 update.
24. CI 3.2.4.2.B Confirm that the effects of elevated or lowered temperatures in the battery In progress. Evaluation of room, especially if the ELAP is due to a high or low temperature hazard, have high temperatures been considered. Confirm the adequacy of the ventilation provided in the depends on the results of battery room to protect the batteries from the effects of extreme high and low GOTHIC modeling and temperatures. analyses. PSEG expects to provide a response by the August 2014 update.
25. CI 3.2.4.2.C Confirm that the GOTHIC calculations for the battery rooms include the In progress. PSEG effects of hydrogen accumulation and confirm the actions necessary to expects to provide the prevent unacceptable hydrogen accumulation. results of GOTH IC modeling and analyses by the August 2014 update.

Page 10 of 14

ENCLOSURE 1 LR-N 14-0025 ID Item Ref. Description Status

26. CI 3.2.4.4.A Confirm that the upgrades to the plant communication systems discussed in In progress. A current the licensee communications assessment (Reference 6) in response to the status of the upgrades is March 12, 2012, 50.54(f) request for information letter for HCGS and provided in Note 1.

documented in the staff analysis (ADAMS Accession No. ML13130A387)

(Reference 19) have been completed.

27. CI 3.2.4.6.A Confirm that the GOTHIC modeling and room temperature calculations of In progress. PSEG plant strategic areas (e.g. MCR, RCIC room, HPCI room (if needed), torus expects to provide the room, and battery rooms including pathways for access to equipment) show results of GOTHIC acceptable results for personnel habitability and equipment capability. modeling and analyses by the August 2014 update.
28. CI 3.2.4.6.8 Confirm that potential high temperature and high humidity in the SFP and fuel In progress. PSEG handling floor area has been addressed with regard to accessibility. expects to provide the results of GOTHIC modeling and analyses by the August 2014 update.
29. CI 3.2.4.8.A Confirm that the design of the FLEX electrical hookups include the details on In progress. PSEG how to connect to, and interface with existing plant equipment. expects to provide the results of HC FLEX design activities by the February 2015 update.
30. CI3.2.4.8.8 Confirm that the sizing of the FLEX DGs is adequate to supply the planned In progress. PSEG loads. expects to provide the results of HC FLEX design activities by the February 2015 update.

- - - I Page 11 of 14

ENCLOSURE 1 LR-N 14-0025 10 Item Ref. Description Status

31. CI 3.2.4.10.A Confirm that the analysis of battery load profiles for the safety related 125 and In progress. PSEG 250 Vdc batteries for a BDBEE demonstrate satisfactory load profiles and expects to provide the battery life. results of battery load shedding and duty cycle evaluations by the August 2014 update.

Section 6 Table Note 1:

CI 3.2.4.4.A, Communications Improvements PSEG's regulatory commitment in Reference 6 is to complete communications improvements prior to restart from the H1 R19 outage in Spring 2015. Reference 7 identified planned communications enhancements for satellite phones, radio communications and communications vendor interfaces. A summary of the current status and schedule of these improvements is provided below:

Satellite phones - PSEG purchased ten new Iridium satellite phones, batteries and chargers, and has distributed them to PSEG Emergency Response Facilities (ERFs). A Design Change Package (DCP) is being developed to install satellite base stations and antennae. DCP issuance is targeted for May 2014, with installation prior to H1R19. The new satellite phones and associated equipment will be included in EP procedures as part of the design change process.

Radio Communications - PSEG initiated the procurement of additional batteries and chargers for existing EP radios. These batteries and chargers will be deployed to the appropriate ERFs following receipt. A DCP is being developed to ensure power is available to critical radio repeaters. DCP issuance is targeted for May 2014, with installation prior to H1 R19.

Periodic Verification of EP Communication Vendor Contracts - PSEG verified EP communication vendor contracts are in place, and will ensure that vendor contracts relied upon for EP communications, including those associated with ongoing communications enhancements, are periodically verified.

Page 12 of 14

ENCLOSURE 1 LR-N14-0025 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References

1. PSEG letter LR-N13-0031, "PSEG Nuclear LLC's Overall Integrated Plan for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013
2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
3. PSEG Letter LR-N13-0173, "PSEG Nuclear LLC's First Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 22, 2013
4. Nuclear Energy Institute (NEI) Report NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012
5. US Nuclear Regulatory Commission (NRC letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident," dated March 12, 2012
6. PSEG Letter LR-N12-0351, "PSEG Nuclear LLC's Assessment Report for Communications During and Extended Loss of AC Power," dated October 31,2012 (ADAMS Accession No. ML12306A249)
7. PSEG letter LR-N13-0026, "PSEG Nuclear LLC' s Response to NRC Follow-up Letter on Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Fukushima Near-Term Task Force Recommendation 9.3," dated February 21, 2013
8. NRC Order EA-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Effective Immediately)," dated June 6, 2013
9. NRC Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," dated March 12, 2012
10. NEI letter to NRC, "EA-12-049 Mitigating Strategies Resolution of Extended Battery Duty Cycles Generic Concern," dated August 27,2013 (ADAMS Accession No ML13241A186)
11. NRC letter to NEI, "Battery Life White Paper Endorsement," dated September 16,2013 (ADAMS Accession No. ML13241A188)
12. NRC letter to NEI, "Mitigation Strategies Order EA-12-049, NEI Position Paper: MAAP Endorsement Letter," dated October 3, 2013 (ADAMS Accession No. ML13275A318)

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ENCLOSURE 1 LR-N 14-0025

13. NEI Position Paper, "Shutdown / Refueling Modes," dated September 18, 2013 (ADAMS Accession No. ML13273A514)
14. NRC letter to NEI, "Endorsement Letter: Mitigation Strategies Order EA-12-049, NEI Position Paper: Shutdown / Refueling Modes," dated September 30, 2013 (ADAMS Accession No. ML13267A382)
15. NElletter to NRC, "EA-12-049 Mitigating Strategies Resolution of FLEX Equipment Maintenance and Testing Templates," dated October 3, 2013 (ADAMS Accession No. ML13276A573)
16. NRC letter to NEI, "Maintenance and Testing Endorsement Letter in Regards to Mitigation Strategies Order EA-12-049," dated October 7, 2013 (ADAMS Accession No. ML13276A224)
17. NElletter to NRC, "EA-12-049 Mitigating Strategies Resolution with Respect to BWR Mark I and II Anticipatory Containment Venting," dated November 21, 2013 (ADAMS Accession Nos. ML13352A061 and ML13352A057)
18. NRC letter to NEI, "Nuclear Energy Institute, BWR Anticipatory Venting Letter in Regards to Order EA-12-049," dated January 9, 2014 (ADAMS Accession No. ML13358A206)
19. NRC letter to PSEG, "Hope Creek Generating Station and Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Staff Assessment in Response to Request for Information Pursuant to 10 CFR 50.54(f) - Recommendation 9.3 Communications Assessment (TAC Nos. ME9959, ME9984, and ME9985)," dated June 3, 2013 (ADAMS Accession No. ML13130A387)
20. NRC Letter to PSEG, "Hope Creek Generating Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NO. MF0867)," dated February 11,2014 Page 14 of 14