LR-N14-0027, PSEG Nuclear Llc'S Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)

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PSEG Nuclear Llc'S Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)
ML14058A230
Person / Time
Site: Salem  PSEG icon.png
Issue date: 02/25/2014
From: Schwarz C
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, LR-N14-0027
Download: ML14058A230 (21)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 Order EA-12-049 LR-N 14-0027 FEB 252014 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

Subject:

PSEG Nuclear LLC's Second Six-Month Status Report for the Salem 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-N13-0034, "PSEG Nuclear LLC's Overall Integrated Plan for the Salem 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 28, 2013
3. PSEG Letter LR-N13-0175, "PSEG Nuclear LLC's First Six-Month Status Report for the Salem 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 25, 2013
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 Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012

FEB- 2 5 2014 Order EA-12-049 Page 2 LR-N 14-0027

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, "Salem Nuclear Generating Station, Unit Nos. 1 and 2 -

Interim Staff Evaluation and Audit Report Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0868 and MF0869)," dated January 24, 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 Salem Generating Station (SGS) Units 1 and 2, on February 28, 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 at SGS Units 1 and 2, on August 25, 2013 (Reference 3). The purpose of this letter is to provide the second six-month status report for SGS Units 1 and 2, 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, industry guidance document NEI 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 SGS Units 1 and 2, 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 SGS Units 1 and 2 (Reference 6). There are no changes in compliance method or requests for regulatory relief identified in Enclosure 1.

FEB 2 5 2014 Order EA-12-049 Page 3 LR-N 14-0027 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.

Executed on 0 V 72 2- 3 7

0/ ' /

(Date)

Sincerely, Christopher J. Schwarz Vice President - Operations Support Enclosure 1: Salem Generating Station Units 1 and 2 Second Six-Month Status Report for the Implementation of Ord~r 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, Salem Mr. P. Mulligan, Manager IV, NJBNE Salem Commitment Tracking Coordinator PSEG Corporate Commitment Coordinator

FEB 252014 ENCLOSURE 1 LR-N 14-0027 Salem Generating Station Units 1 and 2 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 Salem Generating Station Units 1 and 2 PSEG Nuclear LLC

ENCLOSURE 1 LR-N 14-0027 1 Introduction PSEG Nuclear LLC (PSEG) developed an Overall Integrated Plan (alP) (Reference 1) for the Salem Generating Station (SGS) Units 1 and 2, documenting the diverse and flexible coping strategies (FLEX) in response to NRC Order EA-12-049 (Reference 2). In Reference 3, PSEG provided the first six-month status report associated with SGS FLEX OIP. Provided herein is the second six-month status report, for the 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 (Section 4) and no issues requiring regulatory relief (Section 5) identified in this report. Section 6 includes a status of the open items and confirmatory items identified in the NRC's interim staff evaluation and audit report for SGS Units 1 and 2 (Reference 5).

2 Milestone Accomplishments The following milestones have been completed since the development of the SGS FLEX OIP, and are current as of January 31, 2014.

  • Submit Integrated Plan: PSEG submitted the SGS FLEX OIP to the NRC.
  • Develop FLEX Strategies: PSEG has developed SGS Units 1 and 2 FLEX strategies as described in the SGS FLEX OIP and has identified design, analysis, procurement, and programmatic actions necessary to achieve compliance with Order EA-12-049.

Changes to the FLEX strategies are being evaluated and are the subject of Confirmatory Item (CI) 3.2.1.6.A in Section 6, below.

3 Milestone Schedule Status The following table provides an update of SGS FLEX OIP milestones. The table provides the milestone activity status and indicates 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 dates.

Page 1 of 17

ENCLOSURE 1 LR-N14-0027 Original Revised Milestone Target Activity Status Target Completion 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 - Unit 1 Dec 2013 Started Mar 2014 Implement Modifications - Unit 1 Oct 2014 Not Started Nov 2014 Develop Modifications - Unit 2 Dec 2013 Started May 2014 Implement Modifications - Unit 2 Oct 2015 Not Started Nov 2015 Flex Support Guidelines (FSGs)

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

Develop FSGs - Unit 2 Dec 2013 Started Oct 2014 Validation Walk-throughs or Demonstrations of FLEX Strategies Nov 2015 Not Started and Procedures - Unit 2 (Note 1)

Perform Staffing Analysis Dec 2013 Started Jun 2014 (Note 2)

Develop Training Plan Jun 2014 Started Implement Training Unit 1 Training Dec 2014 Started Nov 2014 Unit 2 Training Dec 2014 Started Nov 2015 Develop Strategies/Contract with Oct 2013 Started Oct 2014 Regional Response Center (RRC)

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ENCLOSURE 1 LR-N14-0027 Original Revised Milestone Target Activity Status Target Completion Completion Date Date Procure Equipment Unit 1 Procurement Dec 2013 Started Oct 2014 Unit 2 Procurement Dec 2013 Started Oct 2014 Create Maintenance Procedures May 2014 Started Nov 2014 Emergency Preparedness (EP)

Communications Improvements Jun 2014 Started Nov 2015 (Note 3)

Unit 1 Implementation Outage Oct 2014 Not Started Nov 2014 Unit 1 Report to NRC When Full Feb 2015 Not Started Compliance is Achieved Unit 2 Implementation Outage Oct 2015 Not Started Nov 2015 Unit 2 Report to NRC When Full Feb 2016 Not Started Compliance is Achieved Section 3 Table Notes

1) The validation walk-through milestone is not specifically identified in the SGS FLEX alP 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 6). PSEG's staffing analyses will address simultaneous ELAP scenarios at HCGS and SGS 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). This milestone is based on PSEG's regulatory commitment in Reference 8, to complete communications improvements prior to restart from the Salem Unit 1 23 rd Refueling Outage (S1 R23) in Fall 2014.

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.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation PSEG expects to comply with the Order EA-12-049 (Reference 2) implementation date for SGS Units 1 and 2, and no relief or relaxation is requested at this time.

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ENCLOSURE 1 LR-N 14-0027 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a status of SGS Units 1 and 2 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 and audit report for SGS Units 1 and 2 (Reference 5):

ID Item Ref. Description Status I

1. Generic Concern - Battery SGS is currently working on extending the battery duty cycle, and is In progress. PSEG Life following the industry position on battery life as outlined in the Nuclear expects to provide Energy Institute (NEI) white paper dated August 27, 2013 (Reference 9) the results of battery and endorsed by NRC via letter to NEI dated September 16, 2013 load shedding and (Reference 10). duty cycle evaluations by the August 2014 update.
2. Generic Concern - MAAP SGS is using the Modular Accident Analysis Program (MAAP) to In progress. PSEG complete the development of FLEX timelines and strategies, consistent expects to provide a with the NRC endorsement letter to NEI dated October 3, 2013 summary of the (Reference 11). results of the SGS MAAP analyses by the August 2014 update.
3. Generic Concern - SGS will enhance shutdown risk processes and procedures using the Not started. PSEG Shutdown / Refueling supplemental guidance provided in the NEI position paper entitled expects completion Modes "Shutdown / Refueling Modes," dated September 18, 2013 to be coincident with (Reference 12) and endorsed by the NRC via letter to NEI dated Order EA-12-049 September 30, 2013 (Reference 13).. compliance.

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ENCLOSURE 1 LR-N 14-0027 ID Item Ref. Description Status

4. Generic Concern - As part of the development of FLEX maintenance and testing programs, In progress. PSEG Preventive Maintenance SGS will use the EPRI Technical Report entitled "Nuclear Maintenance expects completion Applications Center: Preventative Maintenance Basis for FLEX to be coincident with Equipment," transmitted to NRC via NEI letter dated October 3, 2013 Order EA-12-049 (Reference 14) and endorsed by NRC letter dated October 7, 2013 compliance.

(Reference 15).

5. Generic Concern - Core Core Sub-Criticality - The Pressurized Water Reactor Owners Group In progress. See Sub-criticality (PWROG) submitted to NRC a position paper, dated August 15, 2013, Section 7.

via Reference 16, which provides test data regarding boric acid mixing 01 3.2.1.8.A under single-phase natural circulation conditions and outlined applicability conditions intended to ensure that boric acid addition and mixing would occur under conditions similar to those for which boric acid mixing data is available. The licensee should address the clarifications in the NRC endorsement letter dated January 8,2014 (Reference 17).

6. 013.2.4.7.A Water Sources - The licensee appears to use a probability approach to In progress. See reach a conclusion that at least one of the three tanks depended on for Section 7.

SG makeup will survive an ELAP event. NEI 12-06 guidance does not give probability as an option. The licensee should determine if a water supply would be available after a tornado event by analyzing the tornado characteristics for the site compared to the separation characteristics of the tanks. This is an alternate approach from the strategies identified in NEI 12-06.

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ENCLOSURE 1 LR-N 14-0027 10 Item Ref. Description Status

7. CI3.1.1.1.A Protection of FLEX Equipment including FLEX diesel In progress. PSEG generators (DGs) - The licensee needs to finalize its evaluation of the is evaluating use of the SGS auxiliary building and the use of the Hope Creek changes to FLEX Generating Station, Unit 2 reactor building for permanent FLEX equipment storage equipment storage. and deployment strategies and expects to provide additional information by the August 2014 update.
8. CI 3.1.1.2.A Deployment of FLEX Equipment - The licensee should complete a The req uested review of deployment routes between the proposed equipment storage information is locations and the areas the equipment will be moved to and evaluate provided in the potential for soil liquefaction. Section 7.
9. CI3.1.1.2.B Deployment of FLEX Equipment - The licensee does not state that the In progress. Seismic Nuclear Service Water Connections will be protected from seismic capability of the events. Confirm that this is ensured. connections will be ensured as part of the design change process.
10. CI 3.1.1.3.B Procedural Interfaces - Seismic Hazard - The licensee's integrated plan In progress. PSEG did not provide any information on: 1) non-robust internal flooding expects to provide sources that do not require ac power; 2) the use of ac power to mitigate additional ground water in critical locations. information by the August 2014 update.

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ENCLOSURE 1 LR-N14-0027 ID Item Ref. Description Status

11. CI3.1.1.4.A Considerations in Using Offsite Resources - Seismic Hazard - Flooding In progress. PSEG I Hazard - High Winds Hazard - Snow, Ice and Extreme Cold Hazard - expects to provide Equipment staging areas for deployment of offsite equipment from additional SAFER will be finalized in a future 6 month update. information by the I

I August 2014 update.

12. CI 3.1.2.2.A Deployment of FLEX Equipment - Flooding Hazard - Finalization of In progress. PSEG proposed changes to the deployment of FLEX equipment during a expects to provide hurricane induced flooding condition will be provided in a future 6 month additional update. information by the August 2014 update.
13. CI 3.1.4.2.A Deployment of FLEX Equipment- Flooding Hazard - The licensee In progress. PSEG should address the formation of frazil ice and means to cope with it. expects to provide additional information by the August 2014 update.
14. CI 3.1.4.2.B The licensee should address manual operations required by plant In progress. PSEG personnel during periods of snow, ice, and extreme cold hazards. expects to provide additional information by the August 2014 update.
15. CI 3.1.5.2.A The licensee should confirm that there is no need for backup ventilation In progress. PSEG with respect to protection of FLEX equipment during high temperature expects to provide hazards and what the impacts of high temperature hazards would be on additional the deployment of the FLEX equipment in such conditions. information by the August 2014 update.

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ENCLOSURE 1 LR-N 14-0027 10 Item Ref. Description Status

16. CI 3.1.5.3.A The licensee should specify the peak temperature for which FLEX In progress. PSEG eq uipment would be expected to operate. expects to provide additional information by the August 2014 update.
17. CI3.2.1.A The licensee should specify which analysis performed in The requested WCAP-17601-P (Reference 18) is applicable to SGS and justify the use information is of that analysis by identifying and evaluating the important parameters provided in and assumptions demonstrating that they are representative of SGS Section 7.

and appropriate for simulating the ELAP transient.

18. CI3.2.1.1.A Computer Code Used for ELAP Analysis - Reliance on the NOTRUMP The req uested code for the ELAP analysis of Westinghouse plants is limited to the flow information is conditions prior to reflux condensation initiation. Verify that the code is provided in not used beyond these flow conditions. This includes specifying an Section 7.

acceptable definition for the onset of reflux condensation cooling.

19. CI3.2.1.1.B The licensee utilized the existing analyses in WCAP-17601-P to Not started. PSEG develop its sequence of events and time constraints. The licensee will expects completion validate the response times at a future time. to be coincident with Order EA-12-049 compliance.
20. CI 3.2.1.2.A Reactor Coolant Pump Seal Leakage Rates - Confirm that the RCP seal The req uested initial maximum leakage rate used in the analysis is greater than or information is equal to the upper bound expectation for the ELAP event (21 gpm/seal) provided in discussed in the PWROG white paper addressing the RCP seal leakage Section 7.

for Westinghouse plants.

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ENCLOSURE 1 LR-N 14-0027 ID Item Ref. Description Status

21. CI3.2.1.2.B Reactor Coolant Pump Seal Leakage Rates - In some plant designs, The req uested such as those with 1200 to 1300 psia SG design pressures and no information is accumulator backing of the main steam system power-operated relief provided in valve actuators, the cold legs could experience temperatures as high as Section 7.

580°F before cooldown commences. This is beyond the 550°F qualification temperature of the O-rings used in the RCP seals. For those Westinghouse designs, a discussion of the information (including the applicable analysis and relevant seal leakage testing data) should be provided to justify that (1) the integrity of the associated O-rings will be maintained at the temperature conditions experienced during the ELAP event, and (2) the seal leakage rate of 21 gpm/seal used in the ELAP is adequate and acceptable.

22. CI 3.2.1.5.A Monitoring Instrumentation and Controls - The review identified a In progress. PSEG concern with the level of accuracy of the FLEX instrumentation to expects to provide ensure that electrical equipment remains protected (from an electrical additional standpoint- e.g., power fluctuations) and with the ability of this information by the instrumentation to provide operators with accurate information ensure August 2014 update.

the maintenance of core cooling, containment, and spent fuel cooling.

The licensee should confirm the accuracy of portable equipment instrumentation as it relates to equipment protection and operator information for maintenance of FLEX strategies.

23. CI 3.2.1.6.A Sequence of Events - During the NRC audit process the licensee In progress. PSEG summarizes the changes in its mitigation strategies for Phase 1 and expects to provide Phase 2. The evaluation for implementing these changes will be additional communicated in a future 6 month update. information by the August 2014 update.

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ENCLOSURE 1 LR-N 14-0027 ID Item Ref. Description Status

24. CI 3.2.1.9.A Use of Portable Pumps - The Integrated Plan provides a table depicting In progress. PSEG the FLEX equipment to be deployed and states that the quantity does expects to provide not reflect the NEI 12-06 spare capability (N+1) guidance. The licensee additional should specify how many pieces of equipment will be available for an information by the ELAP/Loss of Ultimate Heat Sink (UHS), and this should meet N+1 August 2014 update.

requirements unless an alternative approach is proposed.

25. CI3.2.2.A Spent Fuel Pool Cooling Strategies - In the audit and review, the In progress. PSEG i licensee provided additional information regarding the SFP makeup expects to provide during an ELAP event. It stated that a new 411 FLEX hose is being additional evaluated as replacement for SFP makeup. This connection would be information by the upstream of 1(2)SF9 and would allow water from SW, AFW, and the August 2014 update.

FLEX boron mixing tank pump discharges to be aligned for SFP I makeup. The proposed connection point is in the Auxiliary Building in the SFP pump area. Additionally, a spray pipe system is being re-evaluated. The licensee should provide details of the final  !

configuration, including flow rates, and this information should be included in a six-month update.

I

26. CI3.2.3.A The licensee committed to perform further containment analysis to In progress. PSEG I demonstrate that containment integrity can be maintained up until a expects to provide  !

point in time when containment cooling can be restored during Phase 3. additional  !

information by the I August 2014 update.

I

27. CI3.2.3.B Containment Functions Strategies - In the audit and review, the licensee In progress. PSEG stated that SGS plans to use the Modular Accident Analysis Program expects to provide analYSis to complete the FLEX strategies and timelines. Review these additional analyses when available. information by the August 2014 update.

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ENCLOSURE 1 LR-N 14-0027 10 Item Ref. Description Status

28. CI 3.2.4.2.A Ventilation - Equipment Cooling - The licensee has provided insufficient In progress.

details of the ventilation provided in the battery room to support a Evaluation of high conclusion that there is reasonable assurance that the effects of temperatures elevated or lowered temperatures in the battery room, especially if the depends on the ELAP is due to a high or low temperature hazard, have been results of GOTHIC considered. Confirm the adequacy of the ventilation provided in the modeling and battery room to protect the batteries from the effects of elevated or analyses. PSEG lowered temperatures. expects to provide a :

response by the August 2014 update.

29. CI3.2.4.2.8 Ventilation - Equipment Cooling - The licensee provided a discussion on In progress. PSEG how hydrogen concentration in the battery rooms will be mitigated when plans to mitigate the batteries are being recharged during Phases 2 and 3. The licensee hydrogen build-up by will provide strategies to repower installed battery room exhaust fans or repowering the portable fans for ventilation. installed battery room exhaust fans when the batteries are being recharged, and expects to provide additional information by the August 2014 update.
30. CI 3.2.4.2.C Ventilation - Equipment Cooling - The licensee stated that GOTHIC In progress. PSEG modeling and room heat-up calculations are being developed for plant expects to provide strategic areas including the TDAFW rooms. The results of the the results of modeling and analyses will be communicated in a future 6 month GOTHIC modeling update. and analyses by the August 2014 update.

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ENCLOSURE 1 LR-N 14-0027 10 Item Ref. Description Status

31. CI 3.2.4.4.A Communications - Confirm that upgrades to the site's communications In progress. A systems have been completed. current status of the upgrades is provided in Note 1.
32. CI 3.2.4.6.A Personnel Habitability - Elevated Temperature - Confirm the maximum In progress. PSEG environmental room temperatures at ELAP coping periods greater than expects to provide the 4-hours assumed in NUMARC 87-00, and confirm that measures the results of are in place to ensure personnel habitability, as needed. GOTHIC modeling and analyses by the August 2014 update.
33. CI 3.2.4.6.B Personnel Habitability - The licensee stated that formal analyses would In progress. PSEG be performed to support the initial actions taken to provide cooling for expects to provide the MCR until Phase 2 actions can be implemented. The results of the the results of modeling and analyses will be communicated in a future 6 month GOTHIC modeling update. and analyses by the August 2014 update.
34. CI 3.2.4.8.A Electrical Power Sources/Isolations and Interactions - licensee stated In progress. PSEG that diesel generator sizing calculations are in progress. The results will expects to provide be communicated in a future six-month update. additional information by the August 2014 update.
35. CI 3.2.4.8.B Electrical Power Sources/Isolations and Interactions - The licensee In progress. PSEG discussed use of electrical equipment such as 480 VAC DG Power expects to provide Distribution, 480 VAC nAn Vital Bus, 230 VAC DG Power Distribution, additional associated cablings and connectors. Confirm that electrical isolation will information by the be maintained such that (a) Class 1E equipment is protected from faults August 2014 update.

in portable/FLEX electrical equipment and (b) multiple sources do not attempt to power electrical buses.

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ENCLOSURE 1 LR-N 14-0027 ID Item Ref. Description Status

36. CI 3.2.4.8.C Electrical Power Sources/Isolations and Interactions - Confirm the In progress. PSEG analyses address the minimum voltage that must be maintained on the expects to provide dc buses and its basis. additional information by the August 2014 update.
37. CI 3.2.4.9.A Portable Equipment Fuel - Confirm that sufficient fuel is available In progress. PSEG considering the fuel consumption rate for each FLEX piece of expects to provide equipment. additional information by the August 2014 update.
38. CI 3.2.4.10.A Load Reduction to Conserve DC Power - The licensee should describe In progress. PSEG the results of the final battery load shed analyses, including which expects to provide functions are lost, plant components that will change state, and the additional effects of components changing state. information by the August 2014 update.
39. CI3.3.2.A Configuration Control - The licensee should provide the single line In progress. PSEG diagrams of the proposed electrical systems. expects to provide additional information by the August 2014 update.
40. CI3.4.A Offsite Resources - The licensee's Integrated Plan addressed the use of In progress. This is off-site resources to obtain equipment and commodities to sustain and part of RRC strategy backup the site's coping strategies (NEI 12-06, Section 12.2, Guideline development, with a 1). The licensee should provide information on how the plan addresses milestone target implementation guidelines 2 through 10. completion date of October 2014.

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ENCLOSURE 1 LR-N 14-0027 Section 6 Table Note 1:

CI 3.2.4.4.A, Communications Improvements PSEG's regulatory commitments in Reference 8 are to complete communications improvements prior to restart from the Salem Unit 1 23 rd Refueling Outage (S1 R23) in Fall 2014 and the Salem Unit 2 21 st Refueling Outage (S2R21) in Fall 2015. Reference 7 identified planned communications enhancements for satellite phones, radio communications, and communications vendor interfaces. 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 S1 R23. 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 S1 R23.

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.

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ENCLOSURE 1 LR-N14-0027 7 Potential Draft Safety Evaluation Impacts Generic Concern and 01 3.2.1.8.A, Core Sub-Criticality SGS Units 1 and 2 abide by the position expressed by the NRC staff in the letter dated January 8, 2014 regarding the boron mixing issue for PWRs (Reference 17). The NRC letter states that the NRC staff has reviewed the information submitted to date and concluded that use of the industry approach (Reference 16) is acceptable with clarifications listed in the letter.

01 3.2.4.7.A, Water Sources During a high wind event, it could be postulated that three sources of water (auxiliary feedwater, demineralized water, and fresh water storage tanks) are lost due to the effects of a tornado. In such a scenario, SGS can align the fire water header to the Hope Creek fire water system to provide water from the Hope Creek fire water tank. The Hope Creek fire water tank is located a sufficient distance from the SGS tanks to not be affected by the same tornado. A new FLEX connection on the fire header will be provided in the auxiliary building to supply this source of water to the suction of the TDAFW pump. PSEG will provide additional details regarding this approach in a future update.

CI 3.2.1.1.A, Computer Code Used for ELAP Analysis SGS Units 1 and 2 used generic ELAP analyses performed with the NOTRUMP computer code to support the mitigating strategy in the SGS FLEX OIP (Reference 1). The use of NOTRUMP was limited to the thermal-hydraulic conditions before reflux condensation initiates. The initiation of reflux condensation cooling is defined when the one hour centered moving average (CMA) of the flow quality at the top of the SG U-tube bend exceeds 0.1 in anyone loop.

CI 3.1.1.2.A, Deployment Routes and Soil Liquefaction Liquefaction of the uppermost and recent geologic age site layered sediments, beyond the areas of safety related structures, could possibly occur during the seismic event; but it is expected that the material's behavior as a liquid would cease following the earthquake and would revert to a stiffness and strength needed to accommodate equipment movement onsite.

In the event pathways or roadways are damaged, alternate travel routes around the potentially undermined surfaces would be implemented. In addition, Phase 3 equipment can be transported to the site via helicopter.

CI 3.2.1.A, WCAP-17601-P Applicability The analysis performed in section 5.2 of WCAP-17601-P (Reference 18) is being applied to SGS Units 1 and 2. The use of this analysis is justified as the SGS Units 1 and 2 are Westinghouse designed NSSS with replacement steam generators. Section 5.3 of WCAP-17601-P discusses ELAP coping times relative to RCS inventory control and is an Page 15 of 17

ENCLOSURE 1 LR-N 14-0027 extension of the analysis performed in Section 5.2. WCAP-17601-P Section 5.3 describes Westinghouse NSSS analysis performed in Section 5.2 as being applicable to the SGS design.

The parameters and assumptions utilized in WCAP-17601-P are representative of the values and actions taken in the current Salem Station Blackout (SBO) procedures. The WCAP Steam Generator (S/G) depressurization target of 300 psia correlates to the 250 psia S/G target contained in the Salem Emergency Operating Procedures (EOPs) with the same basis of balancing RCS cooldown, RCS pressure, ECCS Accumulator liquid injection, and re-criticality.

The Reactor Coolant Pump (RCP) design (Model 93-A) evaluated in the WCAP reference case is similar to the Salem RCPs. The Westinghouse AFW consumption calculation performed in WCAP-17601-P, Section 5.2.2 is utilized, substituting the Salem rated core power of 3459 MWt, CI 3.2.1.2.A and CI 3.2.1.2.B, RCP Seal Leakage Rates The RCPs at SGS Units 1 and 2 are Westinghouse Model 93-A with high temperature seals.

SGS Units 1 and 2 ELAP analyses assume that RCP seal leakage increases to 21 gpm per seal package consistent with the Westinghouse-specific analyses in WCAP-17601-P (Reference 18).

8 References

1. PSEG letter LR-N13-0034, "PSEG Nuclear LLC's Overall Integrated Plan for the Salem 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 28, 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-N13-0175, "PSEG Nuclear LLC's First Six-Month Status Report for the Salem 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 25, 2014
4. Nuclear Energy Institute (NEI) Report NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012
5. NRC letter, "Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Interim Staff Evaluation and Audit Report Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0868 and MF0869), dated January 24,2014
6. 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 Page 16 of 17

ENCLOSURE 1 LR-N14-0027

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. PSEG Letter LR-N12-0351, "PSEG Nuclear LLC's Assessment Report for Communications During and Extended Loss of AC Power," dated October 31, 2012
9. NElletter to NRC, "EA-12-049 Mitigating Strategies Resolution of Extended Battery Duty Cycles Generic Concern," dated August 27,2013 (ADAMS Accession No ML13241A186)
10. NRC letter to NEI, "Battery Life White Paper Endorsement," dated September 16, 2013 (ADAMS Accession No. ML13241A188)
11. NRC letter to NEI, "Mitigation Strategies Order EA-12-049, NEI Position Paper: MAAP Endorsement Letter," dated October 3, 2013 (ADAMS Accession No. ML13275A318)
12. NEI Position Paper, "Shutdown / Refueling Modes," dated September 18, 2013 (ADAMS Accession No. ML13273A514)
13. 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)
14. NElletter to NRC, "EA-12-049 Mitigating Strategies Resolution of FLEX Equipment Maintenance and Testing Templates," dated October 3, 2013 (ADAMS Accession No. ML13276A573)
15. 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)
16. Westinghouse proprietary position paper, "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG)," transmitted to NRC via letter dated August 16, 2013 (ADAMS Accession No. ML13235A135)
17. NRC letter to PWROG, "Boron Mixing Endorsement Letter in Regards to Mitigation Strategies Order EA-12-049," dated January 8, 2014 (ADAMS Accession No. ML13276A183)
18. Westinghouse Report WCAP-17601-P Revision 0, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox N$SS Designs," dated August 2012 Page 17 of 17
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