Text

Compliance with March 12, 2012, NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
	ML16116A053
Person / Time
Site:	Salem
Issue date:	04/23/2016
From:	Jamila Perry; Public Service Enterprise Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, LR-N16-0070
	Download: ML16116A053 (35)
	v • d • e

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 Order EA-12-049 L R-N16-0070 APR* 2 S* 2016 U . S. Nuclear Regulatory Com mission ATTN : Document Control Desk Washingto n , DC 20555-0001 Salem Generating Station U n it 2 Renewed Faci l ity Operating License No. DPR-75 N RC Docket No. 50-311

Subject:

Salem Generating Station U n it 2 Compliance with March 12 , 2012, NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. N RC Order Number EA-12-049, "Order Mod ifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 2 .

N RC Letter, "Salem Nuclear Generating Station, U n it Nos. 1 and 2 -

Report for the Audit Regard i ng I mp lementation of Mitigating Strategies and Rel iable S pent Fuel Pool I nstrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0868 , MF0869, MF0913, and MF0914)," dated October 10, 2014 On March 12 , 2012 , i n response to events at the Fukushima Dai-ichi nuclear plant, the Nuclear Regulatory Com mission (N RC) issued Order EA-12-049 (Reference 1) to all power reactor l icensees, includi ng PSEG Nuclear LLC (PS EG). N RC Order EA-12-049 was i m mediately effective and d i rected PS EG to develop, implement, and maintain guid ance and strategies to maintai n o r restore core cooling, containment, and spent fuel pool cooling capabilities i n the event of a beyond-design-basis external event. I n accord ance with the reporting require meht of Cond ition IV.C.3 of the Order, this letter affirms that Salem G enerating Station (S GS ) U n it 2 has achieved full com pliance with N RC Order EA-12-049, Attachment 2 , "Requirements for Mitigation Strategies for

APR

2 32016 Order EA-1 2-049 Page 2 L R-N 1 6-0070 Beyond-Design-Basis Events at Operating Reactor Sites and Construction Permit Holders."

Attachment 1 to this letter provides a summary of SGS Unit 2 com pliance with the Order req u i rements. Attachment 2 provides the response to items i n the SGS m itigation strategies and spent fuel pool level instrumentation NRC aud it report (Reference 2).

There are no regulatory com m itments contained i n this letter. If you have any questions or requ i re additional i nformation , please do not hesitate to contact M r. Brian Thomas at 856-339-2022 .

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

Execute d on Ap,..; / 3) "J.-0/(;

(Date)

S i n cerely, d

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F. Perry S ite Vice President

Salem Generating Station Attachment 1 : Salem Generating Station Unit 2 Com pliance with N RC Order EA-1 2-049, Order Mod ifying Licenses with Regard to Requirements for M itigation Strategies for Beyond-Design-Basis External Events Attachment 2: SGS Unit 2 Response to N RC FLEX Aud it Items cc: M r. Daniel Dorman , Adm i nistrator, Region I , N RC M r. Thomas Wengert, Project Manager, NRC/N RRIDORL M r. John Boska , Senior Project Manager, N RC/N RRIJ LD M r. Patrick Finney, N RC Senior Resident I nspector, Salem M r. Patrick Mulligan, Chief, NJBN E M r. Thomas Cachaza, Salem Commitment Tracking Coord inator M r. Lee Marabella , PS EG Com m itment Coord inator - Corporate

L R-N 1 6-0070 Attach ment 1 Salem Generating Station Unit 2 C ompliance with NRC Order EA 049 , Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

LR- N 1 6-0070 Salem Generating Station Unit 2 C ompliance with NRC Order EA 0 49 ,

Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events References for this attachment are identified in Section 5.

1 INTRODUCTION PS EG Nuclear LLC (PS EG) developed an Overall I nteg rated Plan (O I P) (Reference 1 )

fo r the Salem Generating Station (SGS) Units 1 and 2 , documenting the d iverse and flexible coping strategies (FLEX) in response to N RC Order EA-1 2-049 (Reference 2).

In References 3 thro ugh 8 , PSEG provided six-month status reports associated with i mplementation of the requirements of N RC Order EA-1 2-049. The current SGS Unit 2 strategies are descri bed i n E M-SA-1 00-1 000, "Response to Beyond Design Basis External Events Prog ram Document Salem Generating Statio n ," Revision 0, which is the overall program docu ment consistent with the configuration control guidance in Section 1 1 . 8 of N uclear Energy I nstitute (N E I ) Report 1 2-06 (Reference 9).

The o riginal com pliance milestone for SGS U n it 2 i mplementation of NRC Order EA-1 2-049 was prior to startu p from the 2 1 st refueling o utage (S2R2 1 ) in fall 201 5 . In response to PS EG's req uest (Reference 1 0), the N RC staff approved schedu le relaxation (Reference 1 1 ) to allow SGS U n it 2 to fully implement the FLEX strategies within 90 days of startup from S2R2 1 . SGS Unit 2 entered Mode 2 (Startup) from S2 R2 1 on November 27, 20 1 5 and ach ieved ful l compl iance with N RC Order EA-1 2-049 on February 25, 201 6 , consistent with the N RC schedu le relaxation i n Reference 1 1 .

2 NRC FLEX AUDIT ITEM RESOLUTION SGS U n it 2 responses to items identified in the N RC's i nteri m staff evaluation (IS E)

(Reference 1 3) and N RC aud it report (Reference 14) are provided in Attachment 2.

3 MILESTONE SC HEDULE STATUS The February 20 1 6, six-month u pdate (Reference 8 ) reported all of the SGS Unit 2 and common m ilestones as complete, with the exception of the com pl iance report being provided via this letter.

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L R-N 1 6-0070 4 NRC ORDER EA 049 COMPLIANC E ELEMENTS

SUMMARY

SGS U n it 2 com p l iance with N RC Order EA-1 2-049 (Reference 2) was achieved using the g uidance in N E I 1 2-06 , Revision 0 (Reference 9 ) wh ich has been endorsed by the N RC (Reference 1 2) , with clarifications on determining baseline coping capability and equipment quality. The significant com plia nce elements have been add ressed for SGS U n it 2, as descri bed below.

Strategies - Complete SGS U n it 2 m itigation strategies are i n com pliance with NRC Order EA-1 2-049 and are documented i n the SGS FLEX overall progra m document.

Mod ifications - Complete The plant mod ifications required to su pport the FLEX strategies for SGS Unit 2 were i m plemented in accordance with the station design control process such that the associated systems and com ponents are fully capable of supporting the FLEX strategies.

Equipment - Procurement. Maintenance, and Testing - Complete The equipment req u i red to implement the FLEX strateg ies for SGS U n it 2 was procured ,

received , i n itially tested and/or performance verified . The availability of FLEX equipment and connection poi nts is adm i n istratively controlled by O P-SA-1 08-1 15-100 1 , "Operability Assessment and Equi pment Control Progra m . "

Periodic maintenance and testing is being add ressed via the P S E G Preventive Mai ntenance process.

Protected Storage - Complete The storage facilities required for implementation of the SGS Unit 2 m itigation strategies have been placed within the Owner Contro lled Area using the PSEG design change process. The storage config uration add resses all of the hazards identified in N E I 1 2-06 such that the m i n i m u m set of equ ipment ("N" set) wi ll survive a ny of the external events associated with the applicable N E I 1 2-06 hazards.

Procedu res - Complete FLEX S upport G u idelines (FSGs) for SGS U n it 2 have been developed and integ rated with existing procedures. The FSGs and affected existing proced ures have been verified and are available for use in accordance with the PS EG procedure control process.

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L R-N 1 6-0070 Training - Complete Training for S GS Unit 2 has been com pleted in accordance with an accepted training process, as recommended in N E I 1 2-06 , Section 1 1 .6 .

Staffing - Complete PS EG completed the SGS staffing assessment (Reference 1 5) in response to the NRC staff 1 0 CFR 50 . 54(f) i nformation request dated March 1 2 , 201 2 ( Reference 1 6).

Administratively controlled minimum shift staffing levels are sufficient to implement multi-unit m itigation strategies . The N RC staff concluded that the staffing assessment adequately addresses the SGS response strategies (Reference 1 7) .

Natio nal SAFER Response Center - Complete PS EG established a contract with Pooled Equipment I nventory Com pany (PEl Co) and has joined the Strategic Alliance for FLEX Emergency Response (SAFE R) Team Equipment Com mittee for off-site faci lity coordination . It has been confirmed that PEl Co is ready to support PSEG with Phase 3 equipment stored in the National SAFER Response Centers in accordance with PSEG Vendor Technical Document (VTD) 903060, Volume 1 , "Salem Generati ng Station SAFER Response Plan . "

Validation - Complete PSEG performed validation in accordance with industry-developed guidance (Reference 1 8) to assure required tasks, manual actions, and decisions for the SGS U n it 2 FLEX strategies are feasi ble and may be executed withi n the time constraints identified i n the SGS FLEX overall program document.

FLEX P rogram Document - Establ ished The SGS FLEX overall program document has been developed in accordance with the requirements of N E I 1 2-06 , and has been approved in accordance with PS EG's document contro l process.

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L R-N 1 6-0070 5 REFERENC ES

1. PSEG letter LR-N 1 3-0034, "PS EG N uclear LLC's Overall I nteg rated Plan for the Salem Generating Station in Response to March 1 2 , 2012 Com m ission Order Modifying L icenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order N umber EA-12-049)," dated February 28, 2013 2 . N RC Order N u m ber EA-1 2-049, "Order Mod ifyi ng Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Desig n-Basis External Events,"

d ated March 12 , 2012

3. PSEG Letter LR-N 1 3-0 1 75 , "PS EG N uclear LLC's First S ix-Month Status Report for the Salem Generating Station in Response to March 1 2 , 20 1 2 Commission Order Mod ifying Licenses with Regard to Req uirements for M itigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049)," dated August 25, 20 1 3 4 . P S E G Letter LR-N 14-0027, "PS E G N uclear LLC's Second S ix-Month Status Report for the Salem Generating Station in Response to March 12, 201 2 Commission Order Mod ifying Licenses with Regard to Requ i rements for Mitigation Strateg ies for Beyond-Design-Basis External Events (Order N um ber EA-1 2-049),"

dated February 25, 201 4

5. PSEG Letter LR-N 1 4-0 1 87, "PS E G N uclear LLC's Third S ix-Month Status Report for the Salem Generating Station i n Response to March 1 2 , 2012 Commission Order Mod ifying Licenses with Regard to Requirements for M itigatio n Strategies for Beyo nd-Design-Basis External Events (Order N u m ber EA-1 2-049)," dated Aug ust 26, 20 1 4 6 . PSEG Letter LR-N 1 5-0023, "PS EG N uclear LLC's Fou rth S ix-Month Status Report for the Salem Generating Station i n Response to March 1 2 , 2012 Commission Order Mod ifyi ng Licenses with Regard to Req uirements for M itigation Strategies for Beyond-Desig n-Basis External Events (Order N umbe r EA-1 2-049)," dated February 18, 20 1 5 7 . PS EG Letter L R-N 1 5-0 1 68 , "PS EG Nuclear LLC's Fifth S ix-Month Status Report for the Salem Generating Station in Response to March 1 2 , 2012 Commission Order Mod ifying Licenses with Regard to Requirements for M itigation Strategies for Beyond-Design-Basis Externa l Events (Order Number EA-12-049)," dated August 26, 20 1 5 8 . PSEG Letter LR-N 1 6-0043, " PS EG N uclear LLC's S ixth S ix-Month Status Report for the Salem Generating Station in Response to March 1 2 , 2012 Commission Order Mod ifying Licenses with Regard to Req uirements for M itigation Strategies fo r Beyond-Design-Basis External Events (Order N umber EA-1 2-049), " dated February 29, 201 6

9. N uclear Energy I nstitute (N E I ) Report NEI 1 2-06 , "Diverse and Flexi ble Coping Strategies (FLEX) I mplementation G uide," Revision 0 , d ated Aug ust 20 1 2 Page 4 of 5

L R-N 1 6-0070 1 0 . PSEG Letter LR-N1 5-0223, "PSEG N uclear LLC's Request for Relaxation from Sched u le Requirements of N RC Order EA-1 2-049, 'Order Mod ifying Licenses with Regard to Requirements for M itigation Strategies for Beyond-Design-Basis External Events' - Salem Generati ng Station Unit 2," dated October 23, 20 1 5 1 1 . N RC Letter, "Salem N uclear Generating Station, U n it No. 2 - Relaxation of the Sched ule Req uirements for Order EA-1 2-049 'Order Mod ifying Licenses with Regard to Req uirements for M itigation Strategies for Beyond-Design-Basis External Events,"' dated November 9, 2 0 1 5 1 2 . N RC I nteri m Staff G u idance J LD-ISG-20 1 2-0 1 , "Compliance with Order EA-1 2-049, Order Modifying Licenses with Regard to Req uirements for M itigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 20 1 2 1 3 . N RC letter, "Salem N uclear Generating Station, Unit Nos. 1 and 2 - I nterim Staff Evaluation and Audit Report Relating to Overall I ntegrated Plan i n Response to Order EA-1 2-049 (Mitigation Strategies) (TAC Nos. M F0868 and MF0869)," dated January 24, 20 1 4 1 4. N RC Letter, "Salem N uclear Generating Station, Unit Nos. 1 and 2 - Report for the Aud it Regarding I m plementation of M itigating Strategies and Reliable S pent Fuel Pool I nstrumentation Related to Orders EA-1 2-049 and EA-1 2-051 (TAC Nos. M F0868, M F0869, M F091 3, and M F091 4)," dated Octo ber 1 0, 20 1 4 1 5. PS EG letter LR-N 1 4-0 1 4 1 , "Salem Generating Station's Response to March 1 2, 201 2, Request for I nformation Pursuant to Title 1 0 of the Code of Federal Regulations 50 .54(f) Regard ing Recommendations of the Near-Term Task Force Review of I nsights from the Fukush i ma Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Req uested I nformation Items 1 , 2, and 6 - Phase 2 Staffing Assessment," dated June 1 6, 20 1 4 1 6 . US N uclear Regulatory Com mission (N RC) letter, "Request for I nformation Pursuant to Title 1 0 of the Code of Federal Regu lations 50.54(f) Regardi ng Recommendations 2 . 1 , 2 . 3, and 9.3, of the Near-Term Task Force Review of I nsights from the Fukushima Dai-l ch i Accident," dated March 1 2, 201 2 1 7. N RC letter, "Response Regarding Licensee Phase 2 Staffing Submittals Associated with Near-Term Task Force Recommendation 9.3 Related to the Fukushima Dai-ich i N uclear Power Plant Accident (TAC Nos. M F431 0, M F43 1 1 ,

M F43 1 2, MF43 1 3, MF432 1 , M F4322, M F4323, MF4324, M F4325, M F4326, and M F4327)," dated September 29, 20 1 4 1 8. N E I letter APC-1 4-1 7, "Validation Document for FLEX Strategies," dated J u ly 1 8, 201 4 Page 5 of 5

L R-N1 6-0070 Attach ment 2 SGS Unit 2 Response to NRC FLEX Audit Items

L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items References for this attachment are identified i n Section 3.

1 INTRODUCTION The N RC staff's i n itial review and audit of the SGS m itigation strategies is documented in the I nteri m Staff Eval uation ( I S E) dated January 24, 20 1 4 (Reference 1 ) The ISE identified N RC Generic Concerns, Open Items (Ois), and Confirmatory Items (Cis) for PSEG to add ress as part of i m plementation of the req uirements of N RC Order EA-1 2-049 (Reference 2). The N RC staff conducted an on-site audit of the SGS m itigation strategies i n August 20 1 4. The audit included a review of the Generic Concerns, O l s, and Cis, and also resulted i n add itional Aud it Questions (AQs) and S afety Eval uation (SE) items. The N RC audit report dated October 1 0, 20 1 4

( Reference 3) incl udes a listi ng of open audit items. Section 2 , below, provides responses to the N RC G eneric Concerns, open Cis and O l s, and i ncludes responses to the closed items from the I S E for completeness.

2 SGS UNIT 2 RESPONSETO NRC FLEX AUDIT ITEMS 2.1. Generic C oncern- Battery Life Item Description SGS is currently working on extending the battery d uty cycle, and is following the industry position on battery l ife as outlined in the N uclear Energy I nstitute ( N E I ) white paper dated Aug ust 27, 201 3 (Reference 4) and endorsed by NRC via letter to NEI dated September 1 6 , 20 1 3 (Reference 5).

SGS U nit 2 Response Battery coping calculations ES-3 . 005, "28 VDC Beyond Design Base Event Battery S izing Calcu lation," and ES-4.008 , " 1 25 VDC Salem BDBEE Battery S izing Calculation," have been satisfactori ly com pleted using the N RC-endorsed white paper.

The calcu lations show that the deep load shedding strategy wi ll provide at least six hours of battery life without charging. PSEG provided these calculations to the NRC staff as part of the aud it process.

2.2. Generic C oncern - MAAP Item Description SGS is using the Mod ular Accident Analysis Prog ra m (MAAP) to complete the development of FLEX timeli nes and strategies, consistent with the N RC endorsement letter to N E I dated October 3, 20 1 3 (Reference 7).

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items SGS Unit 2 Response PSEG performed MAAP analyses of the containment response to an Extended Loss of AC Power (ELAP) event for SGS, consistent with the NRC endorsement letter to N E I ( Reference 7). The results of the MAAP analyses were provided to the N RC staff as part of the audit process, i n response to C l 3.2 .3.A and Cl 3.2 .3.8

( Items 2.26 and 2 .27, below).

2.3. Generic C oncern and SE#10 - Sh utdownI Refueling Modes Item Description SGS will enhance shutdown risk processes and procedures using the supplemental g u idance provided i n the N E I position paper entitled "Shutdown I Refueling Modes, "

d ated September 1 8 , 20 1 3 (Reference 8) and endorsed b y the N RC v i a letter to N E I d ated September 30, 20 1 3 (Reference 9). N RC audit item S E #1 0 is for P S E G to provide the revised shutdown risk processes and proced ures.

SGS Unit 2 Response PSEG revised SGS Unit 2 and common proced ures to enhance shutdown risk processes and procedu res co nsistent with the N RC-endorsed guidance

( References 8 and 9). The following procedures and guidance documents have been revised and provided to the N RC staff as part of the audit process:

OP-SA-1 08-1 1 5-1 001 , "Operability Assessment and Equipment Control Program"

OU-AA-1 03, "Sh utdown Safety Management Program"

OU-SA-1 0 5 , "Sh utdown Safety Management Program - Salem Annex"

S2 .0P-AB . RH R-0001 , "Loss of RH R"

S2.0P-AB.RH R-0002, "Loss of RH R at Red uced I nventory"

S2 .0P-AB . LOOP-000 1 , "Loss of Off-S ite Power"

S2.0P-AB . FU E L-0002 , "Loss of Refuel ing Cavity or Spent Fuel Poo l Level"

S2.0P-AB . S F-000 1 , "Loss of Spent Fuel Cooling" 2.4. Generic C oncern and SE#11 - Preventive Maintenance ( PM)

Item Description As part of the development of FLEX mai ntenance and testing programs, SGS will use the EPRI Technical Report entitled "N uclear Maintenance Applications Center:

Preventative Mai ntenance Basis for FLEX Equipment," transmitted to N RC via NEI letter dated October 3, 20 1 3 (Reference 1 0 ) and endorsed by N RC letter dated Page 2 of 26

L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items October 7 , 201 3 (Reference 1 1 ) . N RC audit report item SE #1 1 is for PS EG to provide the FLEX maintenance and testing progra m .

SGS U n it 2 Response PS E G identified the FLEX equipment PM activities using the NRC-endorsed EPRI guida nce, E PRI or PSEG templates appropriate for the equi pment, and vendor recommendations. These activities are tracked and implemented using PSEG's PM process and are retrievable via the SAP work management system.

2.5. Generic C oncern and 01 3.2.1.8.A- C ore Sub- criticality Item Description Co re S ub-Criticality - The Pressurized Water Reactor Owners G roup ( PWROG) submitted to N RC a positio n paper, dated August 1 5, 201 3, via Reference 1 2 , which provides test data regarding boric acid m ixing under sing le-phase natural circulation cond itions and outlined applicability cond itions intended to ensu re that boric acid add ition and m ixing wou ld occu r u nder conditions similar to those for wh ich boric acid m ixing data is available. The licensee should add ress the clarifications in the NRC endorsement letter dated January 8 , 20 1 4 (Reference 1 3). The N RC a u d it report

( Reference 3) req uests co mpletion of the Emergency Operating Proced u re (EOP) setpoint calculations and a determ i nation of how much RCP seal leakage must be considered in the ELAP analyses.

SGS Unit 2 Response PS E G responded to this item via SAP Order Operation 801 0871 1 -0080 as part of the audit process. Transmittal of Design I nformation (TOOl ) N FS 1 4-1 06 provided the EOP setpoint V.08 value of 1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , which is the latest time after reactor trip I start of E LAP for i nitiation of borated makeup to ensure core subcriticality. This setpoint was determ ined using the N RC-endorsed PWROG position paper on boron m ixing

( References 1 2 and 1 3). The setpoint calculation assu med conservative End of Life

( EOL) core con d itions, an i n itial cooldown to 420 deg rees F, and the conservative ass u m ption of no RCP seal leakage. The V.08 setpoi nt also accou nts for a one-hour boron mixing time. The setpoi nt of 1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months occurs prior to the onset of reflux cooling .

I n o rder to add ress core subcritical ity d u ring an ELAP with RCP seal leakage, PS EG performed Technical Evaluation 801 1 1 83 1 -02 1 0 , and provided it to the N RC staff as part of the audit process, in response to AQ-34 ( Item 2 . 46, below). The evaluation uses SGS-specific RCP seal leakage rates calculated by Westinghouse, accounting fo r the installation of flow restricting o rifices in the RCP seal leakoff lines d u ring the fall 2 0 1 5 refueling o utage. Techn ical Evaluation 801 1 1 83 1 -02 1 0 concludes that the boric acid storage tan ks and the FLEX boron mixing tan k are capable of providing sufficient boro n to establish the requ i red boron concentration at 1 0 .3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months followi ng the ELAP.

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items The FLEX boron m ixing tank can prod uce sufficient boron to make up for leakage indefi n itely.

2.6. 01 3.2.4.7 .A- Water Sources Ite m Description The l icensee appears to use a p robabi lity approach to reach a conclusion that at least one of the th ree tanks depended on for S G makeup will survive an ELAP event.

N E I 1 2-06 ( Reference 6) g uidance does not g ive probability as an option . The licensee shou l d determine if a water supply wou ld be available after a tornado event by analyzing the tornado characteristics for the site com pared to the separation characteristics of the tanks. Th is is an alternate approach from the strategies identified i n N E I 1 2-06 . The N RC aud it report (Reference 3 ) states that if the separation approach is used, the Hope Creek fire water cross connect valve needs to be protected to survive a tornado, and req uests that the actions to switch to an alternate water supply be shown to be completed prior to Reactor Coolant System

( RCS ) heatup due to steam generator dryout.

SGS U n it 2 Response PS E G Vendor Techn ical Document VTD 903078 Revision 2, "FLEX Water Storage Tornado Wind Hazard Evaluation , " provides a basis for adequate separation of the SGS Auxiliary Feedwater (AFW) Storage Tanks and the Hope Creek Generating Station ( HCGS) Fire Water tanks , based on a conservative plant-specific tornado evaluation .

Because S G S is using the separation option to demonstrate adequacy o f water so u rces, resol ution of this item also required the replacement of the HCGS fire protection cross tie valve post i ndicator (valve operator) with a curb box design to i m p rove m issi le protectio n . The cross-tie pipe has an underground isolation valve at the i nterface to each station's system . The SGS valve (1 FP-30) is located under a curb box and operated with a valve key. The HCGS valve (0-KC-V-1 1 5) had an above g ro u nd post indicator as the valve o perator. I n order to decrease tornado vulnerability of the HCGS valve, the post indicator was replaced with a curb box design similar to the SGS valve, as part of Design Change Package (DCP) 8 0 1 1 1 494, "Salem FLEX Generator Deployment (Canyon)."

Tim e validation of the ability to establish the fire protection water supply to the Salem turbine-d riven AFW pumps prior to RCS heatup due to SG d ryout is included in VTD 90302 1 , "Response to Beyond Design Basis External Events FLEX Validation Docu ment Based on N E I 1 2-06 Methodology Salem Generating Station."

VTD 903078 and VTD 90302 1 have been provided to the N RC staff as part of the a u d it process.

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.7 . C l 3.1.1.1.A - Protection of FLEX Equipment Including FLEX Diesel Generators (DGs)

Item Description The licensee needs to finalize its evaluation of the use of the SGS auxiliary build ing and the use of the Hope Creek Generating Station, U n it 2 reactor building for permanent FLEX equi pment storage.

SGS U nit 2 Response This item has been closed as part of the audit process. PSEG finalized the FLEX storage locations, incl ud ing the use of alternatives to N E I 1 2-06 (Reference 6), as summarized in the most recent six-month status report ( Reference 1 4 ) .

2.8. C l 3.1.1.2.A - Deployment of FLEX Equipment Item Description The licensee should complete a review of deployment ro utes between the proposed equ i pment storage locations and the areas the eq uipment wi ll be moved to and evaluate the potential for soil l iquefaction.

SGS Unit 2 Response This item was add ressed in the February 20 1 4, six-month status report (Reference 1 5) and closed d uring the on-site N RC audit. The response is repeated below for convenience.

Liquefaction of the uppermost and recent geolog ic age site layered sed iments, beyond the a reas of safety related structures, could possibly occur d u ring the seismic event; b ut it is expected that the m aterial's behavior as a liquid wou ld cease following the earthq uake and would revert to a stiffness and strength needed to accommodate equipment movement onsite. I n the event pathways or roadways are damaged ,

alternate travel routes around the potentially underm i ned surfaces wou ld be i m plemented . In addition , Phase 3 equipment can be transported to the site via helico pter.

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LR-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.9. C I3.1.1.2.B- Deployment of FLEX Equipment Item Descriptio n The licensee does not state that the Nuclear Service Water Connections will be protected from seismic events. Confirm that this is ensured .

SGS U n it 2 Response Discharge hoses will be routed from the d iesel engine-d riven FLEX Service Water (SW) pump discharge to a pri mary connection on the SW test header or to an alternate connection within the missile-protected Service Water I ntake Structu re (SW I S ) in SW Bays 2 and 3, that can supply the SW nuclear headers . The SW con nections are seismically robust.

2.1 0. C l 3.1.1.3.8 - Procedural Interfaces - Seismic Hazard Item Description The licensee's integrated plan d id not provide any i nformation on: 1 ) non-robust i nternal flooding sources that do not require AC power; 2 ) the use of AC power to m itigate ground water i n critical locations.

SGS Unit 2 Response To address the potential for seismically ind uced i nternal flood i ng hazards, PS EG reviewed large internal flood i ng sou rces that are not seism ically robust and do not req u i re AC power, e.g . , gravity d rainage from lakes or cooling basins for non-safety related cooling water systems (N E I 1 2-06 , Section 5.3.3). There are no internal flooding sou rces of th is type that are within the SGS flood p rotected boundary. FLEX equ i p ment storage locations outside of flood-protected structures were evaluated for the potential im pact of fai l u re of large, non-seismic tan ks . The largest non-seismic tan ks are the two dem ineralized water storage tanks (DWSTs), each with a 500 ,000 gallon capacity. The DWSTs are greater than 400 feet away from the closest outdoor FLEX equ i pment storage area. S ig n ificant open areas exist between the storage sites and non-seismic tanks . Due to the d istances and intervening structures, it is unlikely that sig nificant flooding and equi pment damage wi ll occur to equipment at the storage locations.

The SGS FLEX strategy does not rely on AC power for g round water mitigation within the plant flood protected areas. For a hurricane event, dewatering pumps to remove accumulated rainwater from the Canyon Area (outdoor area between the SGS Unit 2 Fuel Hand l i ng B uilding and Auxi liary Building ) wil l be powered by the FLEX DG or station power (if available).

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.11. C l 3.1.1.4.A - C onsiderations in Using Offsite Resources- Seismic Hazard- Flooding Hazard- High Winds Hazard- Snow, Ice and Extreme C old Hazard Item Description Equipment staging areas for deployment of offsite equ ipment from SAFER will be finalized in a future 6 month u pdate.

SGS U n it 2 Response PS EG finalized the equipment stagi ng areas as descri bed in Vendor Techn ical Document (VTD ) 903060 Volume 1 , "SAFER Response Plan for Salem Generating Station ," and E M-SA- 1 00-1 000 , "Response to Beyond Design Basis External Events Program Document Salem Generating Station." These documents have been provided to the N RC staff as part of the audit process.

Onsite Staging Area "B" at the northeast corner of the site is a minimum of 350' x 250',

which is large enough to accommodate the on-site staging area required by SAFE R for SGS a n d H CG S . T h e area wou ld b e utilized a t approxi mately 20 to 2 4 hou rs after the i nitiating event and notification to the offsite organ ization ( SAFER) . By this time, additional personnel util izi ng the debris removal equ i p ment would be capable of restoring the on-site staging and deployment areas and routes to a usable status.

This wou ld include, if required, grad ing the soil after a seismic event, removal of snow and ice, and removal of debris after a flooding or high wind event. For extreme cold ,

the eq uipment is designed to be able to operate under extreme cold cond itions or equ ipped with keep warm systems to ensure their availabil ity.

2.12. C l 3.1.2.2.A- Deployment of FLEX Equipment- Flooding Hazard Item Description Finalization of proposed changes to the deployment of FLEX eq uipment d u ring a hurricane ind uced flood ing condition will be provided in a future 6 month u pdate.

SGS Unit 2 Response This item was closed to SE #6 ( Item 2 .42 , below) as part of the audit process.

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.13. C l 3.1.4.2.A- Deployment of FLEX Equipment - Flooding Hazard Item Description The licensee sho u ld add ress the formation of frazil ice and means to cope with it.

SGS Unit 2 Response This item was closed as part of the audit process. Suction hoses wil l be placed in the river and water will be d rawn thro ug h strainers to limit pump damage and blockage from debris and frazi l ice.

2.14. C l 3.1.4.2.8- Deployment of FLEX Equipment- Snow, Ice and Extreme C old Hazards Item Description The l icensee sho u ld address manual operations required by plant personnel d uring periods of snow, ice , and extreme cold hazards.

SGS Unit 2 Response This item was closed as part of the audit process. PS EG integrated the FLEX capabilities into existing site cold weather proced ures and established periodic FLEX equ i pment status checks that i nclude d iesel keep warm systems and verification that access to equipment is not impaired by snow or ice . The following proced u res were revised to support o utdoor FLEX equi pment operational fu nctionality and deployment d u ring periods of cold weather including snow and ice:

OP-AA- 1 08- 1 1 1 -1 00 1 , "Severe Weather and Natural Disaster G u idelines"

S C . OP-PT.ZZ-0002 , "Station Preparations for Seasonal Conditions"

S C . O P-PM . FLX-000 1 , "FLEX Standby Equi pment Status Checks"

MA-AA-7 1 6-002-1 002 , " Facilities Maintenance G uidel ines" Page 8 of 26

LR-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.15. C l 3.1.5.2.A- Deployment of FLEX Equipment- High Temperature Hazard Item Description The l icensee should confirm that there is no need for backup ventilation with respect to protection of FLEX equipment during high temperature hazard s and what the i m pacts of high tem perature hazards would be on the deployment of the FLEX equ i p ment i n such cond itions.

SGS Unit 2 Response Th is item was closed during the audit process based on walkdowns and the use of air-coo led FLEX eq uipment. Cl 3.2.4.2.C ( Item 2 . 30, below) provides add itional i nformation regard i ng GOTH I C analyses of tem peratures i n plant areas d u ring an ELAP.

2.16. C l 3.1.5.3.A- Procedural Interfaces- High temperature Hazard Item Description The l icensee sho u ld specify the peak tem perature for wh ich FLEX eq uipment would be expected to operate.

SGS U n it 2 Response This item was closed d u ring the audit process based on equipment being procured to operate in expected temperatures. C l 3.2.4.2 . C ( Item 2 .30, below) provides additional info rmation regard ing GOTH IC analyses of tem peratures in plant areas d u ring an ELAP.

2.17 . C I3.2.1.A - RC S C ooling and Heat Removal, and RC S Inventory C ontrol Strategies Item Description The licensee shou ld specify which analysis performed in WCAP- 1 760 1 -P (Reference 1 6) is applicable to SGS and justify the use of that analysis by identifying and evaluating the impo rtant parameters and assumptions demonstrating that they are representative of SGS and appropriate for simulating the ELAP transient.

The N RC aud it report (Reference 3) identifies the licensee input needed regarding applicability of WCAP-1 760 1 -P to SGS:

"Demonstrate how the Salem RCP seal leakage rate will meet the rate assumed i n Section 5.2 (of WCAP-1 760 1 -P). Also, u pdate the ELAP Page 9 of 26

L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items parameters comparison to show the Salem SG PORVs steam flow rate in percent of ful l power steam flow."

SGS U n it 2 Response PS EG provided a revised ELAP parameters comparison table as part of the audit process. Revision 2 of the table reflects the plant-specific calculation of RCP seal leakage wh ich is cu rrently used as the basis for the SGS FLEX strategy in l ieu of the WCAP-1 760 1 -P values. The plant-specific RCP seal leakage flow rates at 2250 psia

( 1 4. 5 gpm per pump ) and 1 500 psia ( 1 5.2 gpm per pump ) are lower than the WCAP- 1 760 1 -P peak flow rate of 21 gpm per pump that was used in the initial development of the SGS FLEX strategy.

Revision 2 of the ELAP parameters com parison table also provides SGS Steam Generator Power-operated Relief Valve ( S G PORV) ( MS 1 0 valve ) steam flow rate in percent of fu ll power steam flow, i . e . , fo ur S G PORVs with a combined capacity of 1 Oo/o of full power steam flow.

2.18. C l 3.2.1.1.A and SE#5 - C omputer C ode Used for ELAP Analysis Item Description Rel iance on the NOTRU M P code for the ELAP analysis of Westinghouse plants is l i mited to the flow conditions prior to reflux condensation initiation. Verify that the code is not used beyond these flow conditions. This i ncl udes specifying a n acceptable defi n ition for the onset of reflux condensation cooling . NRC audit item SE #5 pertains to resolution of d ifferences between N OTRU M P and N RC simulations of an ELAP using the TRACE code.

SGS Unit 2 Response PS E G provided a response to the N RC's position on the use of N OTRU M P

( Reference 1 7 ) a s part o f the audit process. T h e use of NOTRU M P as i t applies to the SGS FLEX strategy is limited to the flow cond itions prior to in itiation of reflux cooling.

The onset of reflux cooling is considered to occu r when the one-hou r centered moving average of the steam generator U-bend flow q uality has increased to a value of 0 . 1 in any o ne loop. This definition of reflux cool i ng is consistent with the N RC staff's letter to the PWROG ( Reference 1 7 ) regard i ng the use of NOTRU M P and the PWROG- 1 4027-P ( Reference 1 8 ) scaling methodology to evaluate ELAP events.

Reflux cooling precedes core u ncovery d u ring an ELAP scenario and prevention of reflux cool ing is a conservative means of demonstrati ng adeq uate core cool ing via the FLEX strategies, e.g . , as shown in WCAP-1 760 1 -P ( Reference 1 6 ) .

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.19. C l 3.2.1.1.8 and SE#9 - C omputer C ode Used for ELAP Analysis Item Description The licensee util ized the existing analyses i n WCAP-1 760 1 -P (Reference 1 6) to develop its sequence of events and time co nstraints. The l icensee will val idate the response ti mes at a future time. N RC audit item SE #9 is for PS EG to provide validation and verification proced u res which also add ress h u man factors concerns.

SGS U nit 2 Response PS EG revised the timeli nes using plant-specific evaluations that i nclude resol ution of RCP seal leakage issues, and performed timeline validation docu mented in Vendor Techn ical Document VTD 90302 1 , "Response to Beyond Design Basis External Events FLEX Val idation Document Based on N E I 1 2-06 Methodology Salem Generati ng Statio n . " VTD 90302 1 uses NEI g uidance (Reference 1 9) with consideration of h uman factors and has been provided to the N RC staff as part of the audit process.

2.2 0. C l 3.2.1.2.A and SE#2 - Reactor C oolant Pump Seal L eakage Rates Item Description Confi rm that the RCP seal initial maxi m u m leakage rate used i n the analysis is greater than or equal to the upper bound expectation for the ELAP event (2 1 g pm/seal) discussed in the PWROG white paper add ressing the RCP seal leakage for Westinghouse plants. N RC audit item S E #2 pertains to higher than expected leakage rates identified by Westinghouse.

SGS Unit 2 Response PS EG installed X-inch d iameter flow restricting orifices in the SGS U n it 2 RCP seal leakoff lines, via Desig n Change Package (DCP) 801 1 29 1 9 , "DCP Fukushima - I nstall RCP Seal Orifices." The generic leakage rate of 2 1 gpm per pump originally used to develop the SGS FLEX strategy has been superseded by a Westinghouse calculation of plant-specific leakage based on the installation of the orifices. PSEG provided a response to this item as part of the audit process. A margin assessment to address leakage rate uncertainty based on plant specific attributes of the SGS FLEX strategies is summarized below.

RCS Cooldown - The SGS FLEX timeline assumes the i n itial RCS cooldown is i nitiated withi n two hours of an E LAP, consistent with generic Westinghouse assumptions. Vendor Tech nical Docu ment VTD 90302 1 , "Response to Beyond Design Basis External Events FLEX Val idation Document Based on NEI 1 2-06 Page 1 1 of 26

L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items Methodo logy Salem Generating Station," shows a margin of 30 minutes based on time validation.

RCS Makeup Time - PS EG Techn ical Evaluation 801 1 1 83 1 -0220 uses the methodology of PWROG-1 4027-P (Reference 1 8) to determ ine a plant-specific time to reflux cooling of approxim ately 1 7 .4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The time to reach reflux cooling cond itions provides significant marg i n with respect to the SGS FLEX ti meli ne value of eight hours to begin RCS injection . I n addition, actual times for RCS makeup would depend on the scenario that results i n the ELAP, with eig ht hours considered to be a maximum val u e . SGS can al locate resources in response to low level as indicated by Reactor Vessel Level I nstrumentation (RVLIS) or Pressu rizer level. FLEX Support G u ideline FSG-1 has a caution statement: "IF RVL IS < 74o/o then real locate resou rces to i m plement the FSG-1 RCS makeup strategy immediately."

Boration Sources and Makeup Capacity- The boric acid storage tanks (BASTs) and FLEX boric acid m ixing tan k are capable of prod ucing sufficient boron to establish the req u i red shutdown marg i n before the EOP setpoi nt V.08 time of 1 2 hou rs to initiate boration followi ng reactor tri p , and maintai n subcritical ity indefinitely. FLEX charging p u m p capacity of 56 gpm at h ig h pressures is greater than the 40 gpm capacity reco mmended for a fou r-loop Westinghouse plant by WCAP-1 760 1 -P.

PSEG reduced SGS U n it 2 RCP seal leakage d u ring an ELAP via installation of flow restricting orifices. The resulting plant-specific calculated flow rates at 2250 psia

( 1 4. 5 gpm per pump) and the peak value at 1 500 psi a ( 1 5.2 gpm per pump) are lower than the generic WCAP-1 760 1 -P peak flow rate of 2 1 gpm per pump. The plant-specific leakage rates and FLEX capabilities provide margin to accommodate u n certainty i n calcu lated leakage rates.

2.21. C l 3.2.1.2.8 - Reactor C oolant Pump Seal L eakage Rates Item Description In some plant designs, such as those with 1 200 to 1 300 psia S G design pressures and no accumu lator backi ng of the main steam system power-operated relief valve actuators , the cold legs cou ld experience temperatures as h igh as 580°F before cool down com mences. This is beyond the 550°F qualification tem perature of the 0-ri ngs used in the RCP seals. For those Westinghouse designs, a discussion of the i nformation (including the applicable analysis and relevant seal leakage testing data) should be provided to j ustify that ( 1 ) the integrity of the associated 0-rings will be maintained at the temperature cond itions experienced during the ELAP event, and (2) the seal leakage rate of 21 gpm/seal used in the ELAP is adequate and acceptable.

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L R- N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items SGS Unit 2 Response PS EG provided a response to the N RC staff as part of the audit process, based on design changes to install four h igh pressure nitrogen bottles per SG PORV (MS 1 0 valve), via Design Change Package (DCP) 80 1 1 041 9 , perm itting automatic o r manual operation of each valve from the main control room . This will support the FLEX strategy of performing a symmetrical RCS cooldown beginn ing at 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months following the E LAP (T+2 hours) and completing the initial cool down at T +4 hours . With the enhanced capability to control SG pressure (and therefore RCS temperature) using the n itrogen-backed SG PORVs, the RCP seal package components wou ld be expected to perform as designed d u ring the ELAP event.

2.22. C l 3.2.1.5.A- Monitoring Instrumentation and C ontrols Item Description The review identified a concern with the level of accu racy of the FLEX instrumentation to ensure that electrical equipment remains protected (from an electrical standpoint, e.g . , power fluctuations) and with the ability of this instrumentation to provide operators with accu rate i nformation ensure the maintenance of core cooling ,

containment, a n d spent fuel cooling. The licensee should confirm the accuracy of portable equipment instru mentation as it relates to eq uipment protection and operator info rmatio n fo r maintenance of FLEX strategies.

SGS U nit 2 Response This item was closed d u ring the audit process based on use of instrumentation as described in S1 (2).0P-FS . FLX-0007(Q), "Loss of Vital I nstrumentation or Control Power (FSG-7).

2.23. C l3.2.1.6.A- Sequence of Events Item Description During the N RC audit process the licensee summarizes the changes i n its m itigation strategies fo r Phase 1 and Phase 2. The eval uation for implementing these changes wi ll be com m unicated in a future 6 month u pdate. The N RC audit report (Reference 3) subsequently stated that the NRC staff reviewed the changes and have no concerns, and requested that the changes be issued on the docket in an update to the Overall I ntegrated Plan.

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items SGS Unit 2 Response The SGS FLEX timeline wi ll be included with the Final I nteg rated Plan subm ittal following SGS U n it 1 com pliance with N RC Order EA-1 2-049.

2.24. C l 3.2.1.9. A - Use of Portable Pumps Item Description The I nteg rated Plan provides a table depicting the FLEX equipment to be deployed and states that the q uantity does not reflect the N E I 1 2-06 spare capabil ity ( N+1 )

guidance. The licensee should specify how many pieces of eq uipment will be available for an ELAP/Loss of U ltimate Heat Sink (U HS), and this should meet N+1 requ i rements u nless an alternative approach is proposed .

SGS Unit 2 Response Th is item was closed during the N RC audit process. E M-SA-1 00-1 000 , "Response to Beyond Design Basis External Events Prog ram Document Salem Generati ng Station,"

contains tables identifyi ng FLEX eq uipment, including eq uipment shared with Hope Creek Generati ng Statio n (HCGS) .

2.25. C l3.2.2.A - Spent Fuel Pool C ooling Strategies Item Description In the audit and review, the licensee provided add itional information regard ing the SFP m akeu p d u ring an ELAP event. It stated that a new 4" FLEX hose is bei ng evaluated as replacement for SFP makeup. This connection would be upstream of 1 (2)S F9 and wou ld allow water from SW, AFW, and the FLEX boron m ixing tank pump d ischarges to be alig ned for S F P makeu p. The proposed connection poi nt is in the Auxi liary B uild i ng i n the S FP pump area. Add itional ly, a spray pipe system is being re-evaluated. The licensee should provide details of the final configu ration , i nclud ing flow rates, and th is i nformation should be included in a six-month u pdate.

SGS Unit 2 Response This item was closed d u ring the NRC aud it process. EM-SA-1 00-1 000 , " Response to Beyond Design Basis External Events Program Document Salem Generating Station ,"

descri bes the SFP make-up configuration.

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.26. C l 3.2.3. A- C ontainment C ooling Item Description The licensee committed to perform fu rther contai nment analysis to demonstrate that containment integrity can be maintai ned u p unti l a point in time when contai nment cooling can be restored d u ring Phase 3.

SGS U n it 2 Response PS EG provided Tech nical Evaluations of the SGS MAAP containment analyses to the N RC staff as part of the audit process, as follows:

Tech n ical Eval uation 80 1 1 1 831 -0030 evaluated containment response to an ELAP d u ring Modes 5 and 6 (Cold S hutdown and Refueling). The Mode 5 and 6 MAAP analysis indicates that containment pressu re can be mai ntained below the design pressu re of 47 psig and well below the test pressure of 54 psig using the instal led contain ment vent paths through the person nel airlocks .

Techn ica l Evaluation 801 1 1 831 -0040 evaluated containment response to an ELAP in Modes 1 through 4 ( Power Operation to Hot S hutdown) and concl uded that containment pressure can be maintained substantially below the design pressure using only FLEX RCS cooldown via the steam generators. Techn ical Evaluation 801 1 1 83 1 -004 1 confi rmed that the conclusion of 80 1 1 1 83 1 -0040 remains valid with consideration of plant-specific RCP seal leakage.

2.27. C l 3.2.3.8- C ontainment Functions Strategies Item Description I n the aud it and review, the l icensee stated that SGS plans to use the MAAP analysis to com plete the FLEX strateg ies and timelines. Review these analyses when avai lable.

SGS U n it 2 Response PS EG provided the Techn ical Eval uations of the MAAP analyses results as part of the audit process, as summarized above in response to Cl 3.2.3.A - Containment Cooling

( Item 2 . 26).

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.28. C l 3.2.4.2.A - Ventilation - Equipment C oo ling Item Description The licensee has provided insufficient details of the venti lation provided in the battery roo m to support a conclusion that there is reasonable assurance that the effects of elevated or lowered tem peratu res in the battery room, especially if the ELAP is d ue to a h i g h or low temperature hazard, have been considered. Confirm the adequacy of the venti lation provided i n the battery room to protect the batteries from the effects of elevated or lowered temperatures.

SGS U n it 2 Response This item was closed as part of the N RC audit process based on Technical Evaluation 801 1 1 83 1 -0020 (high temperature) and 80 1 1 1 831 -0080 (low temperature).

2.29. C l 3.2.4.2.8 - Ventilation - Equipment C ooling Item Description The licensee provided a d iscussion on how hyd rogen concentration i n the battery roo ms will be m itigated when the batteries are being recharged d u ring Phases 2 and 3. The licensee will provide strategies to repower installed battery room exhaust fans or portable fans for ventilation .

SGS U n it 2 Response This item was closed as part of the N RC audit process, based on the Phase 2 FLEX strategy to re-energize the battery room exhaust fans prior to placing the batteries on charge.

2.3 0. C l 3.2.4.2. C - Ventilation - Equipment C ooling Item Description The licensee stated that GOTH I C modeling and room heat-up calcu lations are being developed for plant strategic areas including the TDAFW rooms. The results of the modeling and analyses wil l be com municated in a future 6 month update.

SGS Unit 2 Response PS EG com pleted Technical Evaluation 801 1 1 83 1 -0020, "UPDATE D - U n it 1 and 2 Evaluation of Salem GOTH I C Results," to document the results of G OTH I C analyses of tem peratu res during an ELAP, and provided the evaluation to the N RC staff as part of the audit process. The results of the GOTH I C analyses summarized in Technical Page 1 6 of 26

L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items Eval uation 801 1 1 83 1 -0020 show that with the actions listed below, the SGS FLEX strategy can be implemented without i mpact to equipment o r personnel.

1 . Opening the TDAFP room door within 30 minutes of an ELAP, and installing a portable fan in the doorway at approximately 1 0 hou rs.

2 . Restoration of the #1 1 /2 1 Switchgear and Penetration Area Ventilation , at approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following an ELAP.

3 . Restoration o f the #1 2 Contro l Area Venti lation fan , at approximately 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months fol lowing an ELAP. NOTE - #22 Control Area Fan is not required since the Control Room Envelope is a common area.

2.31. C l 3.2.4.4.A- C ommunications Item Description Confirm that upgrades to the site's com m u nications system s have been completed .

SGS U n it 2 Response This item was closed as part of the N RC audit process, based on review of Desig n Change Package ( DCP ) 80 1 1 0936, "Salem Comm unications Upgrade," and related equipment enhancements.

2.32. C l 3.2.4.6.A- Personnel Habitability- ElevatedTemperature Item Description Confirm the m axim u m enviro n mental room tem peratu res at ELAP coping periods g reater than the 4-hours assumed in N U MARC 87-00, and confi rm that measures are i n place to ensure personnel habitabil ity, as needed.

SGS U n it 2 Response This item is addressed by Technical Evaluation 80 1 1 1 831 -0020, " U P DATED -

U n it 1 and 2 Evaluation of Salem G OTH I C Results," which was provided to the N RC staff as part of the audit process. The results of Techn ical Evaluation 801 1 1 831 -0020 are descri bed in response to Cl 3.2.4 . 2 . C - Ventilation - Equipment Cooling ( Item 2.30, a bove ) .

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 2.33. C l 3.2.4.6.8- PersonnelHabitability Item Description The licensee stated that formal analyses wou ld be performed to support the initial actions taken to provide cool ing for the MCR until Phase 2 actions can be i m plemented . The results of the modeling and analyses wi ll be communicated in a futu re 6 month u pdate.

SGS U n it 2 Response This item is addressed by Techn ical Evaluation 80 1 1 1 83 1 -0020 , "UPDATED -

U n it 1 and 2 Evaluation of Salem G OTH I C Resu lts," which was provided to the NRC staff as part of the audit p rocess. The results of Techn ical Evaluation 801 1 1 831 -0020 are descri bed in response to Cl 3.2 .4.2 . C - Ventilation - Eq u ipment Cooling (Item 2 . 30 ,

above).

2.34. C l 3.2.4.8.A- Electrical Power Sources/Isolations and Interactions Item Description The licensee stated that d iesel generator sizing calculations are in progress. The results wil l be commu nicated in a futu re six-month u pdate.

SGS Unit 2 Response PS EG Calcu lation ES-1 5 . 0 1 9 , "FLEX Electrical System Analysis - Salem 1 and 2 , "

has been provided to t h e N RC staff as part of the aud it process (text on ly) and demonstrates that the FLEX Diesel Generators (DGs) are appropriately sized to support the FLEX strategies.

2.35. C l 3.2.4.8.8- Electrical Power Sources/Isolations and Interactions Item Description The licensee d iscussed use of electrical eq uipment such as 480 VAC DG Power Distri b utio n , 480 VAC "A" Vital Bus, 230 VAC DG Power Distri bution , associated cablings and connectors. Confirm that electrical isolation will be maintained such that (a) Class 1 E equipment is protected from faults in portable/FLEX electrical eq uipment and (b) m u ltiple sources do not attempt to power electrical buses.

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items SGS Unit 2 Response PS EG Calculation ES-1 5 . 0 1 9 , "FLEX Electrical System Analysis - Salem 1 and 2,"

has been provided to the N RC staff as part of the audit process (text only) and addresses protective device selection and coord i nation .

2.36. C l 3.2.4.8. C - Minimum DC BusVoltage Item Description Confi rm the analyses add ress the minimum voltage that must be maintained on the de buses and its basis .

SGS U nit 2 Response Battery coping calculations ES-3.005, "28 VDC Beyond Design Base Event Battery S izing Calculation" and ES-4.008, "1 25 VDC Salem BDBEE Battery Sizing Calculation" address the battery voltages to support the FLEX strategies and have been provided to the N RC staff as part of the audit process.

2.37 . C I3.2.4.9.A - Portable Equipment Fuel Item Description Confirm that sufficient fuel is available considering the fuel consum ption rate for each FLEX piece of equipment.

SGS Unit 2 Response This item was closed as part of the aud it process. Tech nical Evaluation 801 1 1 831 -0060 , " Evaluation of FLEX Portable Equipment Fuel Usage Against N E I 1 2-06 Req uirements," has been provided to the N RC staff and concl udes that i nstalled sources of fuel can supply FLEX equipment for 5.45 d ays after an ELAP, after which offsite resources are assumed available to resupply the diesel fuel oil .

2.38. C l 3.2.4.1O.A - Load Reduction to C onserve DC Power Item Description The licensee should descri be the resu lts of the final battery load shed analyses, i ncludi ng which functions are lost, plant components that wi ll change state, and the effects of components changing state.

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L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items SGS U nit 2 Response This item is addressed by Technical Evaluation 80 1 1 1 83 1 -005 1 , "Salem Unit 2 ELAP DC Coping Analysis , " which has been provided to the N RC staff as part of the aud it process. Technical Evaluation 801 1 1 831 -005 1 reviewed loads de-energized during the deep load shed to preserve 28 V and 1 25 V battery life. The evaluation concluded that the load shed would not cause conditions that wou ld prevent implementation of the FLEX Phase 1 or Phase 2 strategies, and that equipment required to implement the Phase 1 or Phase 2 strategies wou ld be available when req uired .

2.39. C l3.3.2.A - C onfiguration C ontrol Item Descriptio n The l icensee should p rovide the single l i n e d iagrams of the proposed electrical systems. As part of this item the N RC aud it report (Reference 3) requested PSEG to address potential personnel hazards regarding the orientation of d isconnecting blades in the FLEX power receptacles.

SGS Unit 2 Response PS EG provided the single line d iagrams as part of the audit process, and they are i ncluded i n EM-SA-1 00-1 000 , "Response to Beyond Design Basis External Events Program Document Salem Generati ng Station." PS EG provided the following i nformation in response to the personnel safety aspect of this ite m :

"The d isconnects eq uipped with receptacles for attaching portable cables are a l l orientated s u c h that the potential power feed s i d e is wi red to the non-blade side of the receptacle. Below is a description of the orientation used.

If the F L EX bus is the power source, the power cable to the d isconnect is wired to the stationary side (non-blade side).

If the plant bus is energized (normal configuration , no ELAP), the plant eq u i p ment is wired to the stationary side (non-blade side) of the disconnect.

The portable cable connections between d isconnects are normally wi red to the blade side of the disco n nect. Portable cables will be installed prior to closing any d isconnects (proced u rally controlled)."

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LR-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items

2. 4 0. C l 3.4.A - Off site Resources Item Description The licensee's I nteg rated Plan add ressed the use of off-site resou rces to obtain equipment and com mod ities to sustain and backup the site's coping strateg ies

( N E I 1 2-06 , Section 1 2 .2 , Guideline 1 ) . The licensee should provide i nformation on how the plan add resses implementation g u idelines 2 through 1 0 .

S G S Unit 2 Response PS EG provided Vendor Tech nical Docu ment (VTD) 903060 Volume 1 , "SAFER Response Plan for Salem Generating Station," to the NRC staff as part of the audit process. The N RC issued their staff assessment of the National SAFE R Response Centers in a letter to N E I dated September 26, 20 1 4 (Reference 20), which concluded that SAFE R has taken the appropriate actions to suppo rt site responses to a beyond design-basis external event, and "licensees can reference the SAFE R program and i mplement their SAFE R Response Plans to meet the Phase 3 requirements of Order EA-1 2-049."

2.41. SE#1 - RC S Venting Item Description N RC staff needs to com plete its review of FSG-8 .

SGS U n it 2 Response PS EG provided d raft FLEX S upport G uidelines (FSGs) during the on-site audit and has since provided approved FSG's on the e-portal . PSEG assumes that this item is pending N RC approval u nless add itional PSEG action is requested .

2.42. SE#6 - Permanent Staging of th e FLEX Generators in th e SGS Unit 2 C anyon ( an Alternate to NEI 12- 06)

Item Description Provide a n eval uation of the susceptibil ity to damage for the FLEX generators.

Demonstrate that the construction of the canyon wall is viable.

SGS U n it 2 Response The SGS FLEX strategy uses three 480 V FLEX Diesel Generators (DGs) to provide Phase 2 power for both SGS units, and incl udes pre-stag ing of two DGs in the o utdoor storage area between the SGS U n it 2 Fuel Handling Build i ng and Auxiliary Page 2 1 of 26

LR-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items B u i ld i ng (Canyon Area). The pre-staged DG 's are protected from N E I 1 2-06 external hazards.

As described i n the most recent six-month u pdate (Reference 1 4 ) , SGS is using an alternative to the criteria of NEI 1 2-06 Section 7 . 3 . 1 , "Protection of FLEX Eq uipment,"

which reco m mends protection of FLEX equipment from high wind hazards via storage in a structu re or in d iverse locations. The two pre-staged DGs in the Canyon Area are i n the eastern most a rea of the canyo n , surrou nded on all four sides by the Fuel Hand l i ng B uilding and Auxiliary Building. FLEX equi pment i n the Canyon Area, i ncluding the DGs, are designed for a site specific wind speed of 200 m p h that has an exceedance probability of 1 o-7 for this location .

Design Change Package (DCP) 80 1 1 1 494, Supplement 7, "Salem Generating Station Canyon Area H ig h Wind Hazard FLEX Eq u ipment Storage and Deployment, " includes a tornado m issile evaluation specifically for the Canyon Area configu ration. Based on this evaluatio n , a 1 " solid steel rod traveling at 26 feet/sec is used to design the hardened protection of FLEX equ ipment and connections located in the sheltered Canyon Area . The FLEX DGs pre-staged in the Canyon Area are hardened to provide protection from this m issile i mpact and are secu red to protect against tornado wind speeds. The two FLEX DGs stored outside of the Canyon Area are not m issile protected b ut are separated by 1 200 feet o r g reater to ensure a single tornado does not impact more than one stored FLEX DG . Therefore, at least one of the unprotected FLEX DGs wil l be available for deployment to the canyon area followi ng a tornado event.

DCP 801 1 1 494, "Salem FLEX Generator Deployment (Canyon)," i ncluded the restrai nt and evaluation of gas bottles stored on the Auxiliary Building roof, to ensure that they wou ld not become tornado m issiles.

N E I 1 2-06 Section 5 . 3. 1 ( 1 )(c) states that FLEX equipment may be stored outside a structure provided it is evaluated for seismic i nteractions to ensure equ i p ment is not damaged by non-seismically robust com ponents or structures. Storing or pre-staging FLEX DGs i n the canyon area satisfies the requirements of Section 5.3 . 1 ( 1 )(c). The structures surround ing the canyon area are Seismic I buildings desig ned to withstand a Safe S hutdown Earthquake . There are no non-seismically robust com ponents or structures positioned to interact with stored FLEX DGs in the Canyon Area.

DCP 801 1 1 494 provided bracing systems for the DGs in the Canyon Area to resist seismic and wi nd loads.

In the event a flood is predicted from a h u rricane, two add itional DGs (one N and one N+1 ) wi ll be moved to the Canyon Area and flood protected via a tem porary flood barrier ( H ESCO wall) and de-wateri ng p u m ps. The feasibility of flood protecting the p re-staged and portable DGs as an anticipatory measure is addressed in Vendor Tech nical Document VTD 90302 1 , "Response to Beyond Design Basis External Events FLEX Validation Document Based on N E I 1 2-06 Methodology Salem Page 22 of 26

L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items Generating Station . " DCP 80 1 1 1 494 evaluated the effects of constructing the H ESCO wall on SGS structures, systems, and com ponents (i.e. , build i ng walls and u nderground commod ities), and determined there is no adverse i mpact.

2. 43. SE#7 - Feeding Steam Generators from th eTurbine Building Basement Item Description P rovide the eval uation and timeline of the ability to pump water from the tu rbine b u i l d i ng basement to the steam generators.

S G S U n it 2 Response PS E G provided Techn ical Evaluations 801 1 1 83 1 -0 1 20, "Time Req uired to Flood ing the Turbine B u i ld ing for FLEX S ubmersible Pump Operation" and 80 1 1 1 831 -0 1 30, "Tim e Required To Fill the Demineralized Water I Auxiliary Feedwater Alternate P i ping" to the N RC staff as part of the audit process. These eval uations conclude that, at a flood level of greater than two feet above grade, sufficient water will flood the h otwell area through one set of double door vents to support the use of the s u bmersible pumps. Based on a 1 5 m i n ute time to flood the hotwell to a usable depth and a 1 5 minute time to fill the Dem ineralized Water I Auxiliary Feedwater alternate feed line, sufficient time exists to establ ish an alternate Auxiliary Feedwater supply prior to steam generator d ryout (loss of feedwater for > 55 m i n utes) . Validation of the ability to meet the 55 m i n ute time constraint with margin is documented in Vendor Techn ical Document VTD 90302 1 , "Response to Beyond Design Basis External Events FLEX Validation Document Based on N E I 1 2-06 Methodology Salem Generating Statio n . "

2.44. SE#8 - Equipment Habitability for Steam Generator Power- operated Relief ValveOperation Item Description P rovide the evaluation of the fu nctionality of the SG PORVs.

S G S Unit 2 Response PSEG provided the evaluation of Steam Generator Power-operated Relief Valve (SG PORV) ( MS 1 0 valve) functionality via Technical Evaluation 801 1 1 83 1 -0020,

" U P DATE D - U n it 1 and 2 Evaluation of Salem G OTH I C Results," as part of the response to Cl 3.2 .4.2 .C, Ventilation - Equipment Cooling ( Item 2 . 30 , a bove). Based on a com parison of GOTH I C tem perature results and component data , Technical Evaluation 801 1 1 831 -0020 concludes that operation of the SG PORVs is not challenged d uring an ELAP.

Page 23 of 26

LR-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items

2. 45. AQ Decay Heat C urve Item Description The N RC staff needs to review the plant-specific auxi liary feedwater storage tank technical evaluation, for water supplies for decay heat remova l , which was not com pleted . Provide the techn ical evaluation for the AFST usage. Add ress how AFST vol u me and other analyses were calculated where decay heat is an input. Was the same ANS model used for these purposes, or were d ifferent models used for other applications, and how are they justified?

SGS Unit 2 Response PS E G provided Techn ical Eval uation 801 1 1 831 -0 1 00, "Evaluation of Auxiliary Feedwater Storage Tan k (AFST) Capability to S upply Aux Feedwater During ELAP Cooldown ," to the N RC staff as part of the audit process. The decay heat cu rve used in 8 0 1 1 1 83 1 -0 1 00 util izes ANS 5 . 1 -1 979 plus two sigma, consistent with assumption 4 .2 . 1 (4) in WCAP-1 760 1 -P ( Reference 1 6), and the curve incorporates plant-specific parameters and assu mes three year full power operation as part of the decay heat calculation . The com putation of AFST water co nsum ption i n Technical Evaluation 80 1 1 1 83 1 -0 1 00 provides conservative results relative to the generic evaluation p resented in WCAP-1 760 1 -P.

2.46. AQ Portable Boron MixingTank Item Description The N RC staff is looking for an evaluation showing that one 1 000 gallon tan k will provide sufficient vol ume to feed both units. Also , if the batch stream is d i l uted , there is a concern as to how the licensee can measure the flowrate of the pure water stream if there is no power.

SGS Unit 2 Response PSEG provided Tech nical Evaluation 801 1 1 83 1 -02 1 0 , "Salem Response to N RC M itigating Strategies Audit Question AQ-34, Portable Boron M ixing Tank," to the NRC staff as part of the audit process. A single 1 000 gallon portable boron m ixi ng tank is requ i red to produce concentrated boric acid for both Salem u n its to restore RCS i nventory, make-u p for RCS inventory loss due to RCP seal leakage, and maintain shutdown marg i n . The capability of the portable boron m ixing tan k com bined with the available Boric Acid Storage Tan k (BAST) level exceeds the req uired boric acid inventory to establish and maintai n adequate sh utdown margin and maintain RCS i nventory, ensuring natu ral circulation flow i n the RCS is mai ntained throughout the event.

Page 24 of 26

L R-N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items The FLEX charging p u m p is a 56 gpm positive d isplacement pump with a 2-valve suctio n manifold . Each leg of the manifold contains a flow meter capable of allowing measurement and contro l of borated and non-borated water sources. The flow meters receive power from the pump skid FLEX power and will provide ind ication when requ i red.

3 REFERENC ES 1 . N RC letter, "Salem N uclear Generating Station , U n it Nos. 1 and 2 - I nterim Staff Evaluation and Aud it Report Relating to Overall I ntegrated Plan in Response to Order EA-1 2-049 (Mitigation Strategies) (TAC Nos. MF0868 and M F0869)," dated January 24, 201 4 2 . N RC Order N u m ber EA-1 2-049 , "Order Mod ifyi ng Licenses with Regard to Requirements for M itigation Strateg ies for Beyond-Design-Basis External Events, "

dated March 1 2 , 20 1 2

3. N RC Letter to PSEG , "Salem N uclear Generati ng Station, Unit Nos. 1 and 2 -

Report for the Aud it Regard i ng I mplementation of Mitigating Strategies and Reliable Spent Fuel Pool I nstru mentation Related to Orders EA-1 2-049 and EA-1 2-05 1 (TAC Nos. M F0868 , MF0869, M F09 1 3 , and M F09 1 4)," dated October 1 0, 201 4 4 . N E I letter to N RC , " EA- 1 2-049 Mitigating Strateg ies Resolution of Extended Battery Duty Cycles G eneric Concern , " dated August 27, 20 1 3 (ADAMS Accession No ML13241A186)

5. N RC letter to N E I , "Battery Life White Paper Endorsement," dated September 1 6 , 20 1 3 (ADAMS Accession No. M L 1 324 1 A 1 88)

6. N uclear Energy I nstitute (N E I ) Report N E I 1 2-06 , " Diverse and Flexi ble Coping Strategies (FLEX) I mplementation G uide, " Revision 0 , dated August 20 1 2

7. N RC letter to NEI, " Mitigation Strategies Order EA-1 2-049 , N E I Position Paper:

MAAP Endorsement Letter," dated October 3, 201 3 (ADAMS Accession No. ML13275A318)

8. NEI Position Paper, "Sh utdown I Refueling Modes," dated September 1 8 , 201 3 (ADAMS Accession No . M L 1 3273A5 1 4)

9. N RC letter to N E I , "Endorsement Letter: Mitigation Strategies Order EA-1 2-049, N E I Position Paper: S h utdown I Refueling Modes," dated Septem ber 30, 201 3 (ADAMS Accession No . M L 1 3267A382) 1 0 . N E I letter to N RC, "EA- 1 2-049 Mitigating Strategies Resolution of FLEX Equipment Maintenance and Testing Tem plates, " dated October 3 , 20 1 3 (ADAMS Accession No. ML13276A573)

Page 25 of 26

LR- N 1 6-0070 SGS Unit 2 Response to NRC FLEX Audit Items 1 1 . N RC letter to N E I , "Maintenance and Testing Endorsement Letter i n Regards to M itigation Strategies Order EA- 1 2-049, " dated October 7, 201 3 (ADAMS Accession No. ML13276A224) 1 2 . Westi nghouse proprietary position paper, "Westinghouse Response to N RC Generic Req uest for Add itional I nformation (RAI ) on Boron Mixing i n S uppo rt of the Pressurized Water Reactor Owners Group (PWROG) , " transmitted to N RC via letter dated August 1 6, 20 1 3 (ADAMS Accession No. ML13235A135) 1 3. N RC letter to PWROG, "Boron M ixing Endorsement Letter in Regards to M itigation Strategies Order EA-1 2-049, " dated January 8 , 201 4 (ADAMS Accession No. ML13276A183) 1 4. PS EG Letter L R-N 1 6-0043, "PS EG N uclear LLC's S ixth S ix-Month Status Report for the Salem Generating Station in Response to March 1 2 , 20 1 2 Commission Order Mod ifying Licenses with Regard to Requ i rements for M itigation Strategies fo r Beyond-Desig n-Basis External Events (Order N u m ber EA-1 2-049)," dated February 29, 20 1 6 1 5. PS EG Letter L R-N 1 4-0027, "PS EG N uclear LLC's Second S ix-Month Status Report for the Salem Generati ng Station in Response to March 1 2 , 201 2 Com m ission Order Mod ifying Licenses with Regard to Requirements for M itigation Strateg ies fo r Beyond-Design-Basis External Events (Order Number EA- 1 2-049),"

dated February 25, 201 4 1 6 . Westingho use Report WCAP-1 7601 -P Revisio n 0 , "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Com bustion Engineering and Babcock & Wilcox N SSS Designs," dated August 201 2 1 7. N RC letter to PWROG Regard i ng NOTRU M P dated J une 1 6, 201 5 ( N RC ADAMS Accession No. ML15061A442) 1 8 . PWROG- 1 4027-P, "No. 1 Seal Flow Rate for Westingho use Reactor Coolant Pumps Fol lowing Loss of All AC Power Task 3 : Evaluation of Revised Seal Flow Rate on Time to Enter Reflux Cooling and Time at which the Core Uncovers,"

Revision 3 , Apri l 20 1 5 1 9 . N E I Ietter APC-1 4-1 7, "Validation Document for FLEX Strategies," dated J uly 1 8 , 201 4

20. N RC letter, "Staff Assessment of National SAFE R Response Centers Established in Response to Order EA- 1 2-049 ," dated Septem ber 26, 20 1 4 (ADAMS Accession No. ML14265A107)

Page 26 of 26

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 Order EA-12-049 L R-N16-0070 APR* 2 S* 2016 U . S. Nuclear Regulatory Com mission ATTN : Document Control Desk Washingto n , DC 20555-0001 Salem Generating Station U n it 2 Renewed Faci l ity Operating License No. DPR-75 N RC Docket No. 50-311

Subject:

Salem Generating Station U n it 2 Compliance with March 12 , 2012, NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. N RC Order Number EA-12-049, "Order Mod ifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 2 .

N RC Letter, "Salem Nuclear Generating Station, U n it Nos. 1 and 2 -

Report for the Audit Regard i ng I mp lementation of Mitigating Strategies and Rel iable S pent Fuel Pool I nstrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0868 , MF0869, MF0913, and MF0914)," dated October 10, 2014 On March 12 , 2012 , i n response to events at the Fukushima Dai-ichi nuclear plant, the Nuclear Regulatory Com mission (N RC) issued Order EA-12-049 (Reference 1) to all power reactor l icensees, includi ng PSEG Nuclear LLC (PS EG). N RC Order EA-12-049 was i m mediately effective and d i rected PS EG to develop, implement, and maintain guid ance and strategies to maintai n o r restore core cooling, containment, and spent fuel pool cooling capabilities i n the event of a beyond-design-basis external event. I n accord ance with the reporting require meht of Cond ition IV.C.3 of the Order, this letter affirms that Salem G enerating Station (S GS ) U n it 2 has achieved full com pliance with N RC Order EA-12-049, Attachment 2 , "Requirements for Mitigation Strategies for

APR

2 32016 Order EA-1 2-049 Page 2 L R-N 1 6-0070 Beyond-Design-Basis Events at Operating Reactor Sites and Construction Permit Holders."

Attachment 1 to this letter provides a summary of SGS Unit 2 com pliance with the Order req u i rements. Attachment 2 provides the response to items i n the SGS m itigation strategies and spent fuel pool level instrumentation NRC aud it report (Reference 2).

There are no regulatory com m itments contained i n this letter. If you have any questions or requ i re additional i nformation , please do not hesitate to contact M r. Brian Thomas at 856-339-2022 .

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

Execute d on Ap,..; / 3) "J.-0/(;

(Date)

S i n cerely, d

?a;,

C: &.

F. Perry S ite Vice President

Salem Generating Station Attachment 1 : Salem Generating Station Unit 2 Com pliance with N RC Order EA-1 2-049, Order Mod ifying Licenses with Regard to Requirements for M itigation Strategies for Beyond-Design-Basis External Events Attachment 2: SGS Unit 2 Response to N RC FLEX Aud it Items cc: M r. Daniel Dorman , Adm i nistrator, Region I , N RC M r. Thomas Wengert, Project Manager, NRC/N RRIDORL M r. John Boska , Senior Project Manager, N RC/N RRIJ LD M r. Patrick Finney, N RC Senior Resident I nspector, Salem M r. Patrick Mulligan, Chief, NJBN E M r. Thomas Cachaza, Salem Commitment Tracking Coord inator M r. Lee Marabella , PS EG Com m itment Coord inator - Corporate