Text

License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 Hours to 14 Days
	ML22180A268
Person / Time
Site:	Salem
Issue date:	06/29/2022
From:	Sharbaugh D; Public Service Enterprise Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LAR S22-02, LR-N22-0006
	Download: ML22180A268 (58)
	v • d • e

{{#Wiki_filter:10 CFR 50.90 LR-N22-0006 LAR S22-02 June 29, 2022 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:

License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 hours to 14 Days In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Salem Generating Station (Salem). The proposed change will revise the Salem Unit 1 and Unit 2 TS Action 3.8.1.1.b.4 to extend the allowed out of service time (AOT) for an inoperable emergency diesel generator (EDG) from 72 hours to 14 days. The proposed amendment is deterministic and has been developed using the guidelines established in Branch Technical Position 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions. Additional risk insights reflecting the change in the AOT are also provided. PSEG concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified. The Enclosure provides a description and assessment of the proposed change. Attachment 1 provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides the existing TS Bases pages marked up for information only to reflect the proposed change. Attachment 3 contains a summary of regulatory commitments associated with the proposed change. Attachment 4 provides supporting drawings and figures regarding the plant electrical system and connection and backfeed from the Branch Technical Position (BTP) 8-8 supplemental power source. Attachment 5 provides the timeline of actions and durations required to place the BTP 8-8 supplemental power source in service.

LR-N22-0006 10 CFR 50.90 Page 2 PSEG requests approval of this LAR in accordance with standard NRG approval process and schedule. Once approved, the amendment will be implemented within 120 days from the date of issuance. In accordance with 10 CFR 50. 91, a copy of this application, with attachments, is being provided to the designated State of New Jersey Official. If there are any questions or if additional information is needed, please contact Mr. Michael Wiwel at 856-339-7907. I declare under penalty of perjury that the foregoing is true and correct. Executed on opfu itAl'J'l (Date) Respectfully, w David Sharbaugh Site Vice President Salem Generating Station

Enclosure:

Evaluation of the Proposed Changes : Technical Specification Page Markups : Technical Specification Bases Page Markups for Information Only : Summary of Regulatory Commitments : Supporting Drawings and Figures : Actions and Durations to place AOT Diesel Generators in Service cc: Administrator, Region I, NRG Project Manager, NRG NRG Senior Resident Inspector, Salem Ms. A. Pfaff, Manager, NJBNE PSEG Corporate Commitment Tracking Coordinator Site Commitment Tracking Coordinator

LR-N22-0006 LAR S22-02 Enclosure Enclosure Evaluation of the Proposed Change

Subject:

License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 hours to 14 Days Table of Contents 1.0

SUMMARY

DESCRIPTION .............................................................................................. 2 2.0 DETAILED DESCRIPTION ............................................................................................... 2 2.1 System Design and Operation .................................................................................. 2 2.2 Current Technical Specification Requirements ......................................................... 5 2.3 Reason for the Proposed Change ............................................................................. 5 2.4 Description of the Proposed Change ........................................................................ 7

3.0 TECHNICAL EVALUATION

.............................................................................................. 7 3.1 Bases for the Proposed Change ................................................................................ 7 3.2 Grid Reliability .......................................................................................................... 11 3.3 Station Blackout Capability ...................................................................................... 11 3.4 EDG Reliability Program .......................................................................................... 14 3.5 Maintenance Rule Program ..................................................................................... 14 3.6 Supplemental AC Power Source for Extended AOT ................................................ 15 3.7 Risk Assessment of Scheduled Work ...................................................................... 17 3.8 Risk Assessment of Increasing the EDG AOT to 14-Days....................................... 18 3.9 Assessment of NUREG-0800, Branch Technical Position 8-8 Requirements ......... 20 3.10 Operator Actions ..................................................................................................... 25

4.0 REGULATORY EVALUATION

........................................................................................ 26 4.1  Applicable Regulatory Requirements/Criteria ......................................................... 26 4.2  Precedent ................................................................................................................ 27 4.3  No Significant Hazards Consideration Analysis ...................................................... 28 4.4  Conclusion .............................................................................................................. 29

5.0 ENVIRONMENTAL CONSIDERATION

.......................................................................... 30

6.0 REFERENCES

................................................................................................................ 30 ATTACHMENTS:

1. Technical Specification Page Markups

2. Technical Specification Bases Page Markups for Information Only

3. Summary of Regulatory Commitments

4. Supporting Drawings, Pictures and Figures

5. Actions and Durations to place Supplemental Power Source in Service 1

LR-N22-0006 LAR S22-02 Enclosure 1.0

SUMMARY

DESCRIPTION The proposed change revises Salem Generating Station Units 1 and 2 (Salem) Technical Specification (TS) 3.8.1 Electrical Power Systems - A.C. Sources to extend the required Action in TS 3.8.1.1.b.4 for an inoperable emergency diesel generator (EDG) from 72 hours to 14 days. The extension of the Allowed Outage Time (AOT) for an inoperable EDG beyond 72 hours is contingent on availability of a supplemental alternating current (AC) power source to provide power to the 4kV electrical bus associated with the inoperable EDG in the event of a loss of offsite power (LOOP) and subsequent failure of one of the remaining operable EDGs. The proposed change will provide operational and maintenance flexibility to perform adequate preventative maintenance to ensure long term EDG reliability and availability. The proposed change would reduce EDG unavailability by allowing on-line performance of EDG maintenance activities in a single outage versus multiple outages, or during refueling outages that challenge plant resources and schedule. The proposed change also provides flexibility to resolve unanticipated EDG deficiencies and avoid a potential unplanned plant shutdown should an emergent condition occur online requiring EDG corrective maintenance beyond the current 72 hour TS Action time. The proposed extended AOT is based on a PSEG deterministic justification and a summary of probabilistic risk insights provided in this Enclosure. The additional considerations and compensatory measures are consistent with the 14 day Action completion time permitted in NUREG 0800 Branch Technical Position (BTP) 8-8 (Reference 6.1). 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.1.1 Offsite Power System The Salem offsite Alternating Current (AC) power supply for station startup, normal operation, and safe shutdown is supplied from the PJM Regional Transmission Organization (RTO) transmission network. Offsite power is supplied to Salem from three physically independent, 500-kV circuits designed and located to minimize the likelihood of simultaneous failure. Two 500-kV transmission lines extend north from the plant via separate rights-of-way to two major switching stations: Public Service Electric and Gas (PSE&G) New Freedom Switching Station and Atlantic City Electrics Orchard Switching Station. The New Freedom Switching Station is solidly connected to the PSE&G 230-kV bulk power system via four 500/230-kV autotransformers. The Orchard Switching Station is also connected to the PJM 500-kV system as well as to Atlantic City Electrics 230-kV bulk power system via a 500-230-V autotransformer. The third transmission line serves as a tie line to the adjacent Hope Creek Generating Station (Hope Creek) 500-kV switchyard which is interconnected to the PJM 500-kV system via two independent transmission lines, one of which terminates at the PSE&G New Freedom Switching Station and the other to Delmarva Powers Red Lion switching station in Delaware. Figure 1 in provides a simplified single line diagram of Salem and Hope Creeks 500-kV connections to the PJM system The Salem switchyard is a breaker-and-a-half scheme fed by the three independent offsite transmission lines. All of the Salem offsite AC power sources are provided by a split 13-kV ring bus (north and south) that are connected to the 500-kV switchyard. The 13-kV north ring bus arrangement is shown on in Figure 2 of Attachment 4. Each 500-13-kV station power 2

LR-N22-0006 LAR S22-02 Enclosure transformer (1SPT and 2SPT) feeds two (one for each unit) 13-4-kV station power transformers 11SPT, 21SPT, and 12SPT, and 22SPT associated with non-safety related group buses. The 13-kV south section bus arrangement is also shown in Figure 2 of Attachment 4. Each isolated section (A and D) of the bus is powered from 500-13-kV station power transformers 3SPT and 4SPT respectively and feeds two (one for each unit) 13-4-kV station power transformers 13SPT, 24SPT and 14SPT, 23SPT associated with the safety related vital buses and circulating water switchgear. The 13-4-kV station power transformers 13SPT and 14SPT (Unit 1) share the loads of three vital buses and two circulating water bus sections while 23SPT and 24SPT (Unit 2) share the loads of three vital buses and two circulating water bus sections. The 13-kV bus arrangements assure a continuous preferred power supply to each unit in the event one 500-13kV transformer should become inoperable. 2.1.2 Onsite Power System The Onsite Power System for each unit consists of the main generator, the auxiliary power and station power transformers (SPTs), the EDGs, the group, vital and circulating water bus sections and their related distribution systems. The 4160-V (4-kV) buses, which feed safeguard equipment, are energized by SPTs served by the 13-kV south bus sections. Preferred power is supplied to the 13-kV bus south sections by two sources from the 500-kV switchyard as described in Section 2.1.1 (Reference Figure 2 in Attachment 4). For each Salem unit, the 4160-V system is divided into four group bus sections, three vital bus sections and two circulating water bus sections. The group buses feed plant auxiliaries other than engineered safeguards equipment. The group buses are energized by the 13-4-kV SPTs during startup. After the generator is synchronized to the 500-kV system, the group buses are manually transferred to the 25-4-4 kV auxiliary power transformer. Should a unit trip, each 4-kV group bus automatically transfers from the auxiliary power transformer source to the SPT source. The vital buses are fed directly from the 13-4-kV 13SPT, 14SPT (Unit 1) and 23SPT, 24SPT (Unit 2). During normal operation, two of the three vital buses are supplied from one SPT and the third vital bus from the other SPT. 13SPT, 14SPT (Unit 1) and 23SPT, 24SPT (Unit 2) also serve as the power source for two sections of Circulating Water switchgear (See Figures 2 and 3 in Attachment 4). The tie breaker between these sections is normally open. The in-feed breakers on each vital bus from the two SPTs are electrically interlocked to prevent paralleling both sources through a vital bus. These in-feed breakers provide means for transferring between sources in the event of an interruption of power from one source. Safeguards loads are divided among vital buses in three independent load groups. Each of these load groups is provided with a dedicated EDG which serves as a standby power supply in the event the preferred source is unavailable. The three 4-kV vital ac buses are normally energized from either No. 13 (23) or No. 14 (24) SPT through in-feed breakers 13(23)ASD, 13(23)BSD, 13(23)CSD or 14(24)ASD, 14(24)BSD, 14(24)CSD (see Figure 3 in Attachment 4). In the event the normal source to a 4-kV bus becomes unavailable, that bus can be automatically transferred to its alternate source under normal breaker alignments and protective relaying conditions. In the event all offsite power is lost, the standby EDGs are automatically started and the normal in-feed breakers to each 4-kV vital bus are opened. Once the EDG is up to rated speed and voltage, its generator output breaker is closed to energize its respective vital 4-kV bus. An interlock from the diesel generator breaker prevents closure of either in-feed breaker to that bus, 3

LR-N22-0006 LAR S22-02 Enclosure thereby preventing any interconnection between redundant 4-kV buses. Loading of each 4-kV vital bus is automatically controlled by a load sequencer to ensure post-accident loads are energized within the times analyzed in Chapter 15 of the Updated Final Safety Analysis Report (UFSAR). The standby AC power source consists of three ALCO Model 251G, 18-cylinder emergency diesel generators that are automatically started by accident initiation logic or on detection of a loss of offsite power. Each EDG set supplies power to one 4160-V vital bus in the event of a LOOP. The nameplate continuous rating of the diesel generator units is 2600 kW, 3250 kVA, 900 rpm, 4160-V, three phase, 60 cycles. Each EDG is sized to handle the loads necessary for a design basis Loss of Coolant Accident (LOCA) coincident with a LOOP. Each EDG has the following electrical ratings associated with specific run durations: Time KW PF KVAR KVA 1/2 HR <3100 0.8 2325 3875 2 HRS <2860 0.8 2145 3575 2000 HRS <2750 0.8 2063 3438 CONT <2600 0.8 1950 3250 The EDGs are designed to be ready to accept load within 13 seconds after receipt of a signal to start. The EDGs are started automatically by the safety injection signal or detection of a loss of offsite power which is determined via 2-out-of-3 undervoltage (UV) protective relaying logic which initiates the loading sequence for each vital bus. UV protection of the 4kV vital buses is provided in two levels. The first level uses UV relays that drop out when voltage drops below 70 percent of its rated voltage. Drop out of these UV relays isolates the vital buses from the offsite sources and initiates the Safeguards Equipment Controller (SEC) to load the buses in a predetermined sequence. The second level under voltage protection system (SLUPS) is comprised of three UV and time delay relays per vital bus which react after vital bus voltage drops below a 94.6% TS voltage setpoint. The SLUPS relay provides an input to the SEC. The loading sequence trips the vital bus in-feed breakers and all motor feeder breakers, closes the EDG output breaker after the unit comes up to its speed and voltage permissive setpoints and connects the required safeguard loads in a predetermined sequence by the SEC. The SEC ensures required loads are energized within 35 seconds after EDG breaker closure. The loading sequence logic for each vital bus is separate and independent of the other buses. The EDGs are located in the Auxiliary Building at the 100 foot elevation and are isolated from each other and from other equipment in the area by fire walls and fire doors. Each EDG has its own fuel oil day tank with a 550 gallon capacity. The tank is mounted above the unit for gravity feed of fuel at startup. Two 30,000 gallon fuel-oil storage tanks are located below the diesels at Elevation 84 feet. Any two of the three EDGs and their associated vital buses can supply sufficient power for operation of the required safeguards equipment for a design basis LOCA coincident with a LOOP. Sufficient redundancy is provided in the safety features and their assignment to the vital buses so that failure to energize any one vital bus does not prevent operation of the required minimum safety equipment to achieve safe shutdown. The station DC systems provide a continuous source of power for operation of circuit breakers, valve controls, inverters, etc. No initiation or control is required to connect the batteries to the DC buses. The station DC power system includes one non-vital 250-V, three vital 125-V and two vital 28-V batteries, static battery chargers for each battery and a ground detection system 4

LR-N22-0006 LAR S22-02 Enclosure and undervoltage alarm relay for each bus. The 250-V, 125-V and 28-V batteries are rated 1326, 2320 and 800 amp-hours respectively at the eight hour rate of discharge. The safety-related 125-Vdc power system provides power to safeguard loads via three separate and independent vital DC buses. Each bus provides an independent source of control power for each of the three 4-kV and 460-Vac vital buses and the 125-Vdc distribution cabinets. The 125-Vdc system also supplies power through inverters to the 115-Vac instrument buses that power critical Class 1E instrument loads. The 28-Vdc system provides power to the safety related interposing relay system that interfaces plant controls from the control room to loads in the plant. During normal operation, the DC load is fed from the battery chargers with the batteries floating on the system. Two chargers, each capable of 100-percent normal load, are provided for each 28-V and 125-V battery. Each normal charging source supplies the continuous DC loads and maintains a float charge on the battery to ensure the capability of each battery to deliver its emergency DC requirements. The 28-V and 125-V chargers are fed from the vital AC buses. Each 28-V and 125-V battery is fed from two separate vital buses. Each battery charger maintains a floating charge on its associated battery, and is capable of supplying the required equalizing charge when necessary. Each 125-V and 28-V Battery system (one battery, two chargers, and one switchgear unit) has a ground detection system, undervoltage alarm, and DC voltmeters and ammeters. Each of the station batteries is continuously monitored in the main control room for voltage and discharge current. Loss of AC input and/or DC output is annunciated in the main control room. Each unit is provided with a non-safety related 125-Vdc battery to serve the 4-kV CW switchgear, 13-kV south bus section breakers, switchyard Supervisory Control and Data Acquisition (SCADA) system and portions of switchgear relaying systems. Two separate 125-Vdc batteries and associated equipment are provided in the circulating water switchgear building to provide power to the switchgear and 13.8-kV south bus section breakers. As described in Section 3.3 below, the capacity of the station 125-Vdc Class 1E batteries is sufficient to provide power to all analyzed loads in response to a station blackout (SBO) condition for the required four hour coping period. 2.2 Current Technical Specification Requirements Salem TS Section 3.8.1.1 Action b.4 requires an inoperable diesel generator to be restored to OPERABLE status within 72 hours, or the plant be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. 2.3 Reason for the Proposed Change This proposed Technical Specification change is being requested to extend the TS allowed outage time from 72 hours to 14 days to allow sufficient time and flexibility to perform planned EDG preventative maintenance and subsequent surveillances online to ensure long term diesel generator reliability and availability. The extended AOT also gives additional time for repairing and reestablishing operability in the event of an emergent inoperability of an EDG while online, thus reducing the risk associated with a unit shutdown. Given the conclusions reached by the evaluations that follow, extending the AOT associated with an inoperable EDG would also provide the following: 5

LR-N22-0006 LAR S22-02 Enclosure

1. Efficient Use of Resources Extending the AOT to 14 days to perform recommended maintenance or to restore an inoperable EDG to OPERABLE status can avert an unplanned unit shutdown and minimize the potential need for expedited licensing actions seeking approval of additional completion time.

This proposed change will allow some maintenance activities that improve EDG reliability to be performed online that would otherwise require performance during a refueling outage. Online preventative maintenance and scheduled overhauls provide the flexibility to focus more maintenance, operations and management resources directly on preventative or corrective EDG maintenance. During refueling outages, resources are required to support many testing and maintenance evolutions on station systems, structures and components (SSCs) that can present a challenge to station maintenance and management resources. In comparison, during online maintenance, plant resources can be more focused on the EDG overhaul. The extended AOT associated with an inoperable EDG will improve the effectiveness of the allowed maintenance period. A significant portion of online maintenance activities are associated with preparation and return to service activities, such as tagging, fluid system drain down, fluid system fill and vent and cylinder block heat-up. The durations for these activities are relatively constant. A longer TS Action duration allows more maintenance to be accomplished during a given online maintenance period and therefore would improve maintenance efficiency. Performance of more EDG maintenance online will improve availability during plant refueling outages. Performing more EDG overhaul activities online should reduce the risk and synergistic effects on risk due to EDG unavailability occurring concurrently with other activities and equipment outages during a refueling outage.

2. Reduction of Unnecessary Burden The proposed change provides a reduction in unnecessary burden based on the following:

Allows additional time to perform routine maintenance activities on the EDG without the need and potential transient risk of a unit shutdown. This enhances the ability to focus quality resources on the activity and improve maintenance efficiency. Increases the time to troubleshoot, repair, and reestablish operability of an emergently inoperable EDG without the need for a unit shutdown. Averts the potential need for requests for expedited licensing actions. 6

LR-N22-0006 LAR S22-02 Enclosure 2.4 Description of the Proposed Change The Salem Unit 1 and Unit 2 TS 3.8.1.1 Action b.4 will be revised as follows to extend the AOT for the EDGs to 14 days:

4) In any case:

a) Restore the inoperable diesel generator to OPERABLE status:

1. Within 72 hours, or

2. Within 14 days if the Supplemental Power Source (SPS) is available within 72 hours and verified once per 12 hours thereafter. If at any time availability of the SPS cannot be met either:

a. Restore the SPS to available status or restore the diesel generator to OPERABLE status within 72 hours from entry into 3.8.1.1 Action b, or

b. If 3.8.1.1 Action b has been entered for > 48 hours, restore the SPS to available status or restore the diesel generator to OPERABLE status within 24 hours, Otherwise,

3. Be in at least HOT STANDBY within the next 6 hours and COLD SHUTDOWN within the next 30 hours.

Markups of the proposed TS pages are provided in Attachment 1. Markups of the proposed TS Bases changes associated with this proposed change are provided in Attachment 2 for information only.

3.0 TECHNICAL EVALUATION

The following sections evaluate the bases for the proposed change as well as the design and programmatic defense-in-depth features planned and in place at Salem station to accommodate an extended AOT for the emergency diesel generators. In addition to the deterministic assessment of plant features and processes, a risk assessment is also provided to demonstrate with reasonable assurance that the proposed AOT extension is within the current risk acceptance guidelines in Regulatory Guide (RG) 1.174, An Approach for Using Probabilisitic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, and RG 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications. 3.1 Bases for the Proposed Change The proposed change to extend the TS AOT for an inoperable EDG from 72 hours to 14 days is necessary to provide the time to support preventative maintenance activities planned for work during normal operation and to reduce the likelihood and unnecessary burden and transient risk of a plant shutdown should an unplanned EDG outage occur with the plant at power. The 7

LR-N22-0006 LAR S22-02 Enclosure additional time allows for the repair and restoration of operability of the affected EDG. To justify the 11 day extension to the existing TS AOT, a supplemental AC power source (SPS) is provided in the form of dual, trailer-mounted diesels that can be synchronized and connected to the 4-kV vital bus affected by the inoperable EDG. The current Salem practice is to perform one online maintenance outage per 18 months per EDG, entering the 72 hour AOT directed by TS Action 3.8.1.1.b.4. The outage durations are typically scheduled for a maximum of 36 hours or 50 percent of the AOT in accordance with procedure WC-AA-101, On-Line Work Management Process. The online maintenance outages encompass both planned preventative maintenance activities and maintenance to address equipment conditions identified during the operating cycle that do not affect operability. The typical scope of online work includes the following: Rack Booster Replacement Fuel Rack and Linkage Lubrication Governor Oil Sampling Jacket Water Pressure Switch Calibration Banjo Bolt Torque Check Jacket Water Gasket Repairs Pre-lube Pump Replacement Cylinder Indicator Valve Replacement Larger maintenance windows that would exceed the 72 hour AOT are scheduled during refueling outages. During a refueling outage, three EDG maintenance windows are completed, one for each EDG. Each window completes maintenance on a once per cycle frequency in accordance with plant procedure SC.MD-PM.DG-0032, Standby Diesel Generator Inspection. In addition to the once-per-cycle maintenance, one EDG per refueling outage is scheduled for a larger maintenance window to support maintenance activities on three, six and nine refueling cycle frequencies. The preventative maintenance (PM) schedule among all three EDGs is staggered so that one large maintenance window for one designated EDG and one typical maintenance window for each of the three EDGs is completed during a typical refueling outage. The maintenance performed during a large window is dependent on the scope of required work that is due for that scheduled outage - either every third outage, every sixth outage or every ninth outage. The following is a breakdown of work that is performed for reach scheduled major maintenance window: 1R Maintenance Window Lube Oil Pump Drive Gear Inspection Fuel Injection Nozzle Testing Cylinder Borescope Inspection Fuel Injection Pump Timing Check/Valve Clearance Verification Fuel Rack Uniformity Verification and Adjustment Fuel Injection Pump Rack Assembly Cleaning/Inspection Overspeed Trip Device Inspection and Cleaning Governor Inspection Governor Oil Sampling, Oil Change and Venting Aftercooler (Air Side) Inspection Fuel Oil Booster Pump Coupling Inspection Flexible Connections Inspections 8

LR-N22-0006 LAR S22-02 Enclosure Cylinder Compression Test Engine Mounting Bolts Inspection Valve Cover and Crankcase Closure Inspection 3R Maintenance Window Camshaft Drive and Thrust Inspection Fuel Injection Pump Support Inspection Crankcase Exhauster Inspection Jacket Water Pump Drive Gear Inspection Governor Replacement and Drive Gear Inspection Crankshaft Thrust and Deflection Inspection Fuel Rack Booster and Diverter Valve Inspection Air Intake Inspection Lube Oil Filter Continuous Vent Line Inspection Electrical Generator Inspection External Wiring and Conduit Inspection 6R Maintenance Window Air Start Motor Replacement Fuel Pump Control Shaft and Crossover Linkage Inspection Jacket Water (Cylinder Head to Cylinder Block) Hose Replacement Overspeed Trip Assembly Capscrews and Flywheel Inspection Camshaft Free End Capscrew Inspection 9R Maintenance Window Main Bearing Cap Removal Main Bearing and Journal Inspection Connecting Rod Bearing Removal Connecting Rod Bearing and Crankpin Inspection Connecting Rod Bearing Reassembly Exhaust Manifold Inspection Camshaft and Fuel Pump Support Inspection Water Pump Replacement Replace Lube Oil Header and Turbocharger Supply Check Valves Turbocharger Inspection and Replacement Connection Inspection/Replacement Salem plans to move the performance of those maintenance activities performed during refueling outages to online during the proposed 14 day (336 hours) extended AOT. The outage maintenance activities in conjunction with the activities currently performed online during the 72 hour AOT would result in an expected outage duration of between 90 and 280 hours depending on the scope of work scheduled to be performed for that maintenance interval. This duration is based on the following nominal outage durations experienced for established maintenance windows at their required intervals: 9

LR-N22-0006 LAR S22-02 Enclosure 1R Maintenance Window - 90 hours 3R & 6R Maintenance Windows - 120 hours 9R Maintenance Window - 280 hours The above time frames are nominal and include the time associated with application and removal of clearances, draining and filling of systems and post-maintenance testing required to declare TS operability. Unanticipated findings that can only be identified during the maintenance activities or failures/complications that can arise during post-maintenance testing as well as the need for troubleshooting and subsequent repairs present the potential to exceed the expected nominal outage durations identified above. Based on this potential for additional unforeseen maintenance, a contingency of 56 hours is proposed to be added to the maximum expected outage window duration (280 hours) to arrive at the proposed 14-day (336 hour) AOT. In addition to the above established PMs, corrective maintenance activities and/or end-of-life component replacements can also be performed during an EDG maintenance outage window. Depending on the scope of these additional corrective maintenance and replacement activities, the duration of the outage window could be prolonged beyond the duration of an established interval outage. Due to the limited time afforded by the current 72 hour AOT, the above described activities are required to be performed during a refueling outage. Performance of this work during a refueling outage requires an extended availability of qualified technicians and support personnel thus challenging the availability of these same resources to perform other safety-critical work during the refueling outage. PSEG believes performing planned EDG maintenance on-line during a 14-day AOT under the requirements and controls established under BTP 8-8, provides improved focus and removes substantial distractions from station operations during refueling, especially during potential windows of heightened risk that occur within a refueling outage. Online performance of EDG maintenance evolutions affords increased focus and immediate attention on the part of operations, maintenance and management personnel that can be more challenging during refueling outages. In order to accommodate the proposed AOT extension, the requirements outlined in BTP 8-8 will be implemented that include crediting the availability of a supplemental power source which consists of two synchronized diesel generators that are described in detail in Section 3.6 below. The BTP 8-8 requirement to verify availability of the supplemental power source prior to entry into the extended AOT and every 12 hours thereafter is included in the proposed TS change described above in Section 2.4. In the event the SPS cannot be verified available while in the extended 14 day AOT, the proposed TS action allows for 72 hours to restore either the SPS to available status or the EDG to OPERABLE status. In the event the AOT is entered for a period of greater than or equal to 48 hours, the time frame to restore availability to the SPS or to restore operability to the EDG is limited to 24 hours. Entry into the 24 hour action for restoration of the SPS or EDG is not limited such that unforeseen unavailability of the SPS can be addressed. This TS Action essentially enforces a nominal time frame commensurate with the original 72-hour AOT. This AOT time frame is warranted given the lack of defense-in-depth protection afforded by the SPS and allowing a reasonable amount of time to restore either the inoperable diesel or the SPS to avoid the transient risk associated with a unit shutdown. Precedent for this proposed TS action is established in the license amendments in Precedents 4.2.5 and 4.2.6 shown below. A markup of the proposed TS change for both Salem units can be found in Attachment 1. 10

LR-N22-0006 LAR S22-02 Enclosure 3.2 Grid Reliability The Salem 500-kV switchyard is sourced by three independent offsite transmission lines; two of which emanate from two independent offsite switching stations in New Jersey (Orchard and New Freedom) and the third 500-kV line coming in as a cross tie from the Hope Creek switchyard. Any one transmission line provides sufficient power for post-accident and safe-shutdown loads for both Salem stations. The electrical and geographical independence of these three offsite transmission lines provide increased reliability relative to the connection of the Salem offsite sources to the PJM 500-kV system. There are established procedures and communications protocols in place between PSEG Nuclear, the regional grid operator, PJM and PSE&Gs Electrical Systems Operations Center (ESOC). The PSEG response to Generic Letter (GL) 2006-02, Grid Reliability and the Impact on Risk and the Operability of Offsite Power, was provided on March 31, 2006 (Reference 6.2) and supplemented via response to an NRC Request for Additional information on January 26, 2007 (Reference 6.3). These responses detail the agreements, monitoring tools and communications in place between PSEG Nuclear and the grid operator (PJM and ESOC) to ensure the regional transmission system is monitored and operated in a way to ensure overall grid reliability. In the event of actual or projected grid contingencies or voltage violations that could possibly impact the adequacy or reliability of Salems offsite sources, protocols are established to notify control room operators of the contingency condition and expected duration within 15 minutes. All station communications and interactions with ESOC are governed by Station procedure OP-AA-108-107-1001, Response to Grid Emergencies and ESOC / ER&T Interface. This procedure ensures the communication protocols established for abnormal conditions are maintained between PSEG Nuclear, ESOC and PSEG Energy Resources & Trade consistent with FERC Order 2004, Standards of Conduct for Transmission Providers, (Reference 6.4). This procedure will be utilized prior to AOT entry and daily while in the extended AOT relative to verifying that there are no grid disturbances that could challenge offsite source reliability as described below in Section 3.9.l regarding compliance with BTP 8-8 guidelines. 3.3 Station Blackout Capability Station blackout refers to a complete loss of all offsite and onsite AC power. 10 CR 50.63, Loss of all Alternating Current Power, requires licensees to assess the impact of a loss of preferred power (offsite power) concurrent with a loss of the unit's emergency diesel generators. The Salem Generating Station SBO analysis was performed in accordance with the guidelines provided in Regulatory Guide 1.155, "Station Blackout," and NUMARC 87-00, "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors" (Reference 6.5), for assessment of Salems compliance with the requirements of 10CFR 50.63. Salem does not utilized an alternate AC source operation approach; instead the assessment uses the "AC-Independent" approach outlined in NUMARC 87-00 for its coping capability. In this approach, plants rely on available process steam, DC power, and compressed air to operate equipment necessary to achieve and maintain Hot Shutdown. 11

LR-N22-0006 LAR S22-02 Enclosure The Salem plant site parameters and plant design equipment characteristics for compliance with 10 CFR 50.63 are: Power Design Characteristic Group (P): P1 Extreme Severe Weather (ESW Group): 2 Severe Weather (SW Group): 2 Emergency AC Power Configuration (EAC): D Independence of Offsite Power (I Group) I1 / I/2 EDG Reliability Target: 0.975 The required SBO coping duration for Salem is calculated as four hours in accordance with the guidance provided in NUMARC 87-00, Section 3.0. EDG reliability is calculated based on NSAC-108 criteria (Reference 6.6) and is considered to be 0.975 for Salem. The reliability is defined in terms of the number of failures in 20, 50 or 100 demands. Salem monitors the EDG reliability under the Maintenance Rule Program (see Section 3.5) as well as the EDG Reliability Program (see Section 3.4). Increasing the EDG AOT to 14 days will not have any impact on the Salem target reliability used in the SBO coping time calculation at Salem. The SBO analysis establishes that adequate condensate inventory will be available for decay heat removal via the turbine-driven auxiliary feedwater (AFW) pump, and the plants Class 1E 125-Vdc and 28-Vdc batteries have adequate capacity to supply all SBO DC and inverter loads for four hours. The capacity analysis of the DC system assumes no credit for manual stripping of loads in the first 30 minutes of the SBO event. After 30 minutes, operator action is assumed to energize or de-energize some components as necessary (e.g. de-energization of the alternate shutdown distribution panel and main generator excitation voltage regulator; energization of reactor head vent valves and main steam drain valves). The A and B vital instrument inverter loads are continuous for the entire SBO event. The C and D vital instrument inverter loads (the D inverter is fed from the B battery) are continuous for the first 30 minutes after which load is reduced by manual actions. There is sufficient battery capacity for operation of the steam driven AFW pump controls. A Modular Accident Analysis Program (MAAP) analysis for Salem assessed the primary, secondary and containment response to an SBO event. The analysis determined that adequate water volume is available in the AFW Storage Tank to remove decay heat via the Turbine Driven AFW Pump. In addition, containment isolation capability is maintained to ensure containment integrity. The results of the analysis provide adequate assurance that Salem will be able to withstand and recover from an SBO event for a coping duration of four hours. SBO equipment operability is maintained in rooms with elevated temperatures resulting from loss of ventilation. Areas containing equipment necessary to cope with a SBO event were conservatively evaluated for the effect of loss-of-ventilation due to the SBO. The evaluation showed that equipment operability remained bounded due to conservatism in the existing design and qualification bases. The only required operator action credited for maintaining room temperatures within required range during an SBO is opening the door between the Motor Driven AFW Pump compartment and the Steam Turbine Driven AFW Pump compartment. The 12

LR-N22-0006 LAR S22-02 Enclosure operator action to open the door between AFW Pump compartments is assumed to occur within 30 minutes of onset of the SBO. This manual action is controlled by Salem procedure S1(2).OP-AB.LOOP-0001, Loss of Offsite Power. A summary of the above coping evaluation was provided to the NRC in the PSEG letter identified in Reference 6.7. The referenced letter also identified as part of the coping analysis the need for a means to provide a backup to the station air system in order to supply compressed air to safety related instrumentation, controls and equipment. As part of installed SBO coping equipment, in the event the station air header pressure cannot be maintained during the four hour coping period, a backup to the Emergency Control Air System is provided. The backup is a permanently installed, diesel-driven air compressor rated for 500 standard cubic feet per minute at 125 psig provided in a separate protective enclosure. The diesel driven air compressor is sized to maintain station air header pressure throughout the four hour coping period. Directions for use of the diesel driven air compressor are also controlled by Salem procedure S1(2).OP-AB.LOOP-0001. PJM Manual M-39, Nuclear Plant Interface Coordination (Reference 6.8) requires the system dispatcher to notify the station of grid conditions that could potentially result in a LOOP. In addition, PSEG procedures require the station to inform the dispatcher (ESOC) of station activities or observable conditions that could affect grid conditions. If there is a loss of power to the PSEG site (i.e. Artificial Island), ESOC procedure, Operating Instruction Emergency Operations 1 PSE&G Restoration Procedure and Philosophy, provides the actions to be taken to restore one source of offsite power within four hours (SBO coping time), to comply with the requirements of PJM Manual M-39. PJM manual M-39 provides guidelines on how PJM and PJM members are expected to coordinate operations to ensure the Nuclear Plant Interface Requirements are addressed and implemented while maintaining Bulk Electric System Reliability. While Salem is a four hour SBO coping plant, additional, non-credited SBO diesels are provided for additional defense-in-depth protection as well as to reduce the risk significance of EDG performance issues by improving the ability to recover offsite power during a prolonged station blackout. These 460/230-Vac SBO diesels are not formally credited in the Salem licensing basis for the four hour SBO coping period. One SBO diesel provides an available source of power to backup battery chargers for the 125-Vdc and 28-Vdc system. A second portable SBO diesel is available to provide power to the 500-kV switchyard breaker controls. Since the battery charger SBO diesel is modeled in the Salem PRA and is procedurally controlled under station SBO procedures, the risk assessment described in Section 3.8 reflects the availability of the SBO battery charger diesel to address a loss of all AC power as well as its probability of failure to provide power to the battery chargers. Use of the SBO diesel during the course of a loss of all AC power is directed by Salem procedure S1(2).OP-AB.LOOP-0001 with directions on their alignment detailed in procedure S1(2).OP-SO.500-0125, SBO Diesel - Vital Battery Chargers and SC.OP-SO.500-0125, SBO Diesel - Miscellaneous Switchyard. S1(2).OP-AB. -0001 also provides additional operator actions to ensure the coping margin associated with an SBO event. An additional defense-in-depth SBO coping enhancement available to both Salem units is a common Diesel Driven AFW Pump that can be aligned to either of the two units. The pump is independent of AC or DC power and provides an additional diverse means of makeup to the steam generators to provide core cooling during an SBO event. Like the SBO diesels described above, the Diesel Driven AFW Pump is not credited in the Salem licensing basis for the four hour SBO coping period but was added as a risk mitigation feature. 13

LR-N22-0006 LAR S22-02 Enclosure Based on the established four hour SBO coping period for Salem station and the additional risk mitigating defense-in-depth features available to prolong the amount of time to restore AC power (either offsite or onsite), sufficient time margin exists to accommodate establishing the supplemental power source in the event of a LOOP with one EDG inoperable and a failure of a remaining EDG. 3.4 EDG Reliability Program The EDG condition monitoring criteria that ensure the EDGs are performing within the limits of the DG Reliability Program are described in PSEG common procedure ER-AA-201, Emergency Diesel Generator Reliability Program. The procedure establishes the EDG Reliability Program for Hope Creek and Salem stations and provides guidance for monitoring start and load demands in relation to preset trigger values. The program provides direction on remedial actions if those trigger values are exceeded. The EDG Reliability Program is based primarily on the guidance contained in Revision 1 to NUMARC 87-00 (Reference 6.5). The program provides measures to ensure detailed failure analyses and cause investigations of EDG failures are performed and effective corrective actions taken in response to failures. The program requires monitoring EDG availability and performance parameters to ensure target reliability is met or exceeded, including determining and evaluating the EDG reliability indicators for the last 20, 50 or 100 demands. The EDG target reliability for Salem is 0.975. The Unavailability and Reliability of the Salem EDGs are tracked and reported on a monthly basis through the Mitigating System Performance Index (MSPI) performance indicator. The three Salem EDGs on each unit are currently in Green status and meet availability and reliability margins. MSPI reliability and unavailability are tracked over a 36-month period. There are zero accrued unplanned unavailability hours on all six EDGs with the lowest number of unplanned unavailability hours allowed being 1445 for Unit 1 and 1566 for Unit 2. For planned unavailability, the lowest margin is on the 1B EDG with 1594 hours remaining in Green status. There are no recorded Start, Load, or Run Time failures affecting the reliability margin for any Salem EDG. 3.5 Maintenance Rule Program 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, (i.e. the Maintenance Rule) requires an evaluation be performed when equipment covered by the Maintenance Rule does not meet its performance criteria. If the pre-established performance criteria are not achieved for the EDGs, they are considered for 10 CFR 50.65(a)(1) actions. These (a)(1) corrective actions require increased management attention and goal setting to restore their performance to acceptable level. The actual out-of-service time for the EDGs is minimized to ensure that the performance criteria are met. All Salem EDGs are currently in Maintenance Rule (a)(2) status, and have remained in (a)(2) status for over ten years. The Salem Maintenance Rule program has established three performance criteria to monitor the EDGs; unavailability, reliability, and condition monitoring. The Maintenance Rule performance criteria for unavailability provides a control mechanism on the usage of the proposed extended AOT. The EDG unavailability goal is 197 hours per train per 18 months. Current data as of May 2022, indicate the 2B train EDG unavailability has the most unavailability accrued with approximately 33% of the established criteria. Reliability criteria are provided for the loss of more than one EDG, with an established goal of zero functional failures over the span of 36 months. Current performance of the Salem EDGs meets this established goal. Condition monitoring criteria are provided for the loss of a single EDG, with a goal of two condition 14

LR-N22-0006 LAR S22-02 Enclosure monitoring events (CME) over the span of 36 months. Each EDG is tested monthly, so this trend covers the most recent 36 demands on each diesel engine (monitored on a per engine basis). There is currently one CME, which is related to governor oscillations during post maintenance testing; therefore Salem is meeting this established goal. 3.6 Supplemental AC Power Source for Extended AOT Per Branch Technical Position 8-8, a supplemental AC power source is required to be available throughout the extended TS AOT such that it can provide AC power to the vital bus impacted by the EDG outage in the event of a loss of offsite power concurrent with a single failure of a remaining EDG during plant operation in the extended AOT. The supplemental AC power source will consist of two portable, trailer mounted diesel generators (from here on referred to as AOT diesels) that will be synchronized and connected to one of two receptacle panels, one for each Salem unit, located on the exterior of the common circulating water (CW) switchgear building east of the Salem turbine building (See Attachment 4, Figure 5). Each of the two receptacle panels provides a backfeed path to any one of the three 4-kV vital buses on their respective units via a new, non-safety related CW switchgear circuit breaker (one for each unit) permanently connected to their associated exterior CW receptacle panel. The backfeed path uses existing breakers that, when required in response to a LOOP and a single failure of a remaining EDG, are manually aligned to the vital bus associated with the EDG outage. The new connections are designed such that the Unit 1 CW switchgear can only be aligned to one of the Unit 1 vital 4-kV buses and the Unit 2 CW switchgear can only be aligned only to one of the Unit 2 vital buses. Only one vital bus will be backfed at any time. Figures 4-1 through 4-4 in Attachment 4 provide example single line backfeed schemes for the 1A and 2A vital buses. The same type of breaker alignment is used for backfeeding the B and C vital buses. The portable AOT diesels will be shared with Hope Creek as dedicated supplemental power sources for EDG outages beyond 72 hours, although the AOT diesels will not be credited by both stations for extended AOTs at the same time. The AOT diesels have a combined (synchronized) rating of 5487-kVA and the following time-based capacity ratings as well as the net ratings taking into account parasitic losses (e.g. forced ventilation within the AOT diesel trailer): RATING KW PF KVAR KVA 2 Hour 4912 0.8 3685 6140 Continuous 4550 0.8 3412.5 5687.5 2 Hour less losses 4712 0.8 3485 5940 Continuous less losses 4350 0.8 3212.5 5487.5 The above AOT diesel ratings exceed the Salem time-based EDG ratings identified in Section 2.1.2 above. When synchronized, the AOT diesels exceed the load demand for both a LOOP event and a LOCA concurrent with a LOOP. The AOT diesels are equipped with voltage regulators and speed governors to maintain voltage and frequency within the same limits as those applicable to the EDGs. The AOT diesels have been tested by the manufacturer to successfully start and accept a load representative of the largest Hope Creek load (1250 HP Residual Heat Removal (RHR) pump) while feeding an established base load of 2750 KW. The Hope Creek RHR pump is larger than any load on the Salem EDGs, the largest being the 1000 HP Service Water pump. The combination of the Hope Creek base load plus the Hope Creek RHR pump load exceeds the maximum requirements for starting any of the Salem EDG loads. The AOT diesels are 15

LR-N22-0006 LAR S22-02 Enclosure sufficiently sized and have the capability to enable a safe and orderly shutdown of either Salem unit, maintain the plant in a safe shutdown condition and mitigate the consequences of a LOOP. The AOT diesel components are physically and electrically separated from the Class 1E Engineered Safeguards Function (ESF) components. There are no direct connections to the Class 1E vital buses during normal operations nor are the transfer schemes between offsite sources and the EDG affected by the AOT diesel connection points. There is a single receptacle panel that is connected to each non-class 1E CW Bus via a dedicated, normally open, CW switchgear breaker. The receptacle panels will be de-energized unless required during the proposed 14 day AOT. There is no condition or failure mode where two electrical feeds to the Class 1E 4-KV buses can be cross connected or paralleled. The connections between the AOT diesels and the exterior receptacle panels will be made by pre-fabricated cables and matching connectors that are the same currently used by Hope Creek. Synchronization of the two AOT diesels is automated allowing the combined diesels to operate as a single power source prior to output breaker closure to provide backfeed power to the associated 4-kV vital bus. The AOT diesels will be able to backfeed any one of the three vital buses on either Salem unit via the normally open backfeed breaker in the CW switchgear. At the time the AOT diesels are required to be placed in service (i.e. a LOOP coincident with a failure of a remaining EDG), the AOT diesel trailers will be towed to their pre-established staging area in front of the CW switchgear building via a dedicated tugger and established heavy haul path. A dedicated trailer mounted cable reel is also towed into the staging area and the cables laid out between the diesel trailers and the associated connection panel. Alignment of the AOT diesels to the required vital bus is performed by manual breaker operations prior to starting the AOT diesels and closing the CW backfeed breaker. A synchronizing cable is connected between the two AOT diesels allowing them to auto-synchronize when started. The sequence of steps and a conservative estimate of durations for connecting and aligning the AOT diesels to the 1A or 2A 4-kV bus is described in Attachment 5. The only differences between the steps required for the A vital bus and the B and C buses are the breaker designations that need to be manually aligned. These estimates are based on the same staging and backfeed evolution established for Hope Creek. Each AOT diesel provides its own dedicated output breaker and associated protective relaying. The breaker protection provided by the AOT diesels will maintain the same level of bus protection as is currently provided by the Salem EDG output breakers. Section 3.9.f below provides a protective relaying assessment for the 4-kV buses and compatibly with the output loading characteristics of the AOT diesels. Each of the two AOT diesels is stored onsite within the protected area on a trailer within weatherproof enclosures. The AOT diesels are provided with a 480-V power source to maintain required heating and basic operation per the vendor. Each AOT diesel is equipped with a fuel tank with the capacity to run for a minimum of ten hours at rated load. The diesels are configured to be refueled while running via FLEX fuel transfer pumps and transportable, 1000 gallon fuel cubes. Diesel fuel oil from onsite fuel supplies (e.g. EDG and FLEX diesel fuel oil storage tanks) are available as sources for refueling. In addition, a tanker truck from the local offsite supplier of diesel fuel for the station can be brought on site in short notice as a refueling source. The procedures and materials necessary for refueling the AOT diesels have already been established for their use at Hope Creek. These same procedures and fuel transfer equipment will be adapted for use of the AOT diesels at Salem. 16

LR-N22-0006 LAR S22-02 Enclosure The operations and maintenance training for staging, connecting and operating the AOT diesels developed for use at Hope Creek will also be applied for training Salem personnel. Operator rounds will ensure the availability of the AOT diesels and provide an additional level of overall monitoring. A dedicated, 1.0 MW load bank is stationed near the AOT diesel storage location to accommodate routine load testing of each AOT diesel to ensure availability for use during an extended EDG outage. Routine testing of the AOT diesels is accomplished by Hope Creek procedure HC.OP-PT.NB-4160, AOT Diesel Generators Periodic Test. In the event the shared AOT diesels are ever replaced in the future, or if Salem decides to procure their own dedicated AOT diesels, the replacement diesels will have output ratings greater than the half-hour maximum rating identified in Section 2.1.2. The replacement diesels will be tested to ensure they can accommodate the worst-case loading transient and continuous LOCA load or be shown by calculation to be capable of performing within these limits. 3.7 Risk Assessment of Scheduled Work The effectiveness of maintenance on the EDGs and support systems is monitored pursuant to the Maintenance Rule, which requires licensees to assess and manage the increase in risk that may result from proposed maintenance activities before performing such activities. Therefore, before performing maintenance activities on an EDG during the extended AOT, pursuant to 10 CFR 50.65(a)(4), PSEG assesses and manages any increase in risk that may result from such activities. Assessments for online and outage activities are performed in accordance with PSEG procedure OP-AA-107, Integrated Risk Management. This procedure directs a graded assessment of the overall impact of maintenance activities on plant risk and allows station management to review and challenge the risk management plans, and provide increased oversight for elevated risk activities. The assessment includes the following: The schedule is evaluated and classified against the risk bases derived from the Salem PRA. The scheduled activities are assessed before starting work to maximize safety (reduce risk) when performing on-line work. Activities that require entering the same TS Action are combined to limit the number of times a TS entry is made, thus maximizing the equipments availability and avoiding recurring entries into TS Actions. The work activity risk assessment process assesses the online risk of work activities planned for a given window using the following key phases of OP-AA-107: Phase 1, Activity Owner Initial Risk Classification Phase 2, Activity Owner Development of Risk Management Plans Phase 3, Operations Risk Validation and Classification Phase 4, Station Aggregate Risk Assessment Phase 5, Station Risk Challenge Board A key risk management strategy applied during online and offline work windows is governed by Station procedure OP-AA-108-116, Protected Equipment Program. The primary purpose of the program directed under OP-AA-108-116 is to maintain plant risk within acceptable levels by maintaining defense-in-depth of key safety functions and to prevent inadvertent plant trips, 17

LR-N22-0006 LAR S22-02 Enclosure transients, or TS Limiting Conditions for Operations entries. In accordance with BTP 8-8, this program will be directly employed during the extended 14 day AOT to provide assurance that work activities will not have a significant impact on the reliability/function of the following systems and equipment being protected: Salem switchyard and offsite source equipment Remaining operable EDGs and supporting equipment 4-kV vital buses Turbine Driven Auxiliary Feedwater System In scheduling maintenance tasks on TS systems, OP-AA-107 provides guidance and recommendations relative to scheduling system outage windows such that the outage window provides substantial margin to the total TS AOT. Any work involving a TS shutdown action statement with an AOT between 72 hours and 30 days is targeted to be completed within 50% of the AOT. Exceeding this threshold requires additional risk mitigating measures to ensure the AOT is not exceeded and to minimize TS unavailability for the system. 3.8 Risk Assessment of Increasing the EDG AOT to 14-Days A quantitative and qualitative analysis of risk was performed to support the conclusion that the change in risk associated with the proposed 14 day AOT extension for the EDGs is acceptable. The risk analysis is intended to augment this deterministic assessment of extending the AOT from 72 hours to 14 days. This risk analysis was performed to demonstrate with reasonable assurance that the proposed TS change is within the current risk acceptance guidelines in Regulatory Guide (RG) 1.174 and RG 1.177. The risk analysis addressed Key Principles 4 and 5 of RG 1.174 and RG 1.177, and the risk was calculated consistent with NRC guidance provided in these RGs. The guidelines given in RG 1.174 for determining an acceptable permanent change are that the CDF and LERF associated with the change should be less than the specified criteria, which are dependent on the baseline CDF and LERF. Key Principle 4: Change in Risk is Consistent with the Safety Goal Policy Statement The risk assessment performed for this change addresses the philosophy of risk-informed decision-making. RG 1.177 specifies the acceptable incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) for permanent changes, typically associated with changing an allowed outage time. The guidelines given in RG 1.177 for determining an acceptable TS change are that the ICCDP and ICLERP associated with the change should be less than 1E-06 and less than 1E-07, respectively. The risk assessment performed for this change addresses the philosophy of risk-informed decision-making. The risk analysis was based on the CDF and ICCDP, and LERF and ICLERP for the unavailability of each EDG. This analysis demonstrates the acceptability, from a risk perspective, of increasing the Salem TS AOT for one inoperable EDG from the currently specified 72 hours to 14 days, based on the availability of an alternate AC power source (i.e., AOT diesel generators). As such, the change in risk is small and consistent with the intent of the Commissions Safety Goal Policy Statement. 18

LR-N22-0006 LAR S22-02 Enclosure Key Principle 5: Monitor the Impact of the Proposed Change The impact of the proposed change will be monitored for effectiveness in accordance with the existing plant maintenance rule program pursuant to 10 CFR50.65(a)(4) and the associated implementation guidance, Regulatory Guide 1.160. The program requires, in part, that performing maintenance activities shall not reduce the overall availability of SCCs which are important to safety. Table 3.8-1 below provides the Full Power Internal Events (FPIE) calculations for CDF and LERF for a single EDG and compares the results to the acceptance guidelines in RG 1.174, while Table 3.8-2 calculates ICCDP and ICLERP for each EDG and compares the results to the acceptance guidelines in RG 1.177. In order to calculate the effect on average CDF and LERF for the RG 1.174 calculations, a long-term average unavailability time for each EDG is needed. Per the review of planned preventative maintenance and component replacements described in Section 3.1 above, on average, each EDG is conservatively estimated to be in the AOT configuration seven days per operating cycle. Therefore, the CDFnew and LERFnew calculations below use seven days as the total time per operating cycle that each EDG is out of service for the extended AOT. Table 3.8 FPIE Quantification Results - RG 1.174(1, 2, 3, 4, 5) RG 1.174 CDFnew / CDF / Base LARA-OOS LARB-OOS LARC-OOS Acceptance Metric LERFnew LERF (/yr.) (/yr.) (/yr.) (/yr.) Guidelines for (/yr.) (/yr.) Region III (/yr.) CDF 5.05E-06 1.28E-05 1.31E-05 5.40E-06 5.26E-06 2.06E-07 <1E-06 LERF 2.86E-07 1.44E-06 1.45E-06 3.28E-07 3.16E-07 3.02E-08 <1E-07 Notes to Table 3.8-1:

1. The results shown include contribution from internal events and internal flood.

The risk contributions from Fire, Seismic, and Other External Hazards were evaluated qualitatively in the risk assessment.

2. Total CDF meets the RG 1.174 acceptance criteria of less than 1E-04 per year.

3. Total LERF meets the RG 1.174 acceptance criteria of less than 1E-05 per year.

4. CDF meets the RG 1.174 acceptance criteria of less than 1E-06 per year.

5. LERF meets the RG 1.174 acceptance criteria of less than 1E-07 per year.

Table 3.8-2 below shows the calculations for ICCDP and ICLERP for a 14-day AOT for each EDG and compares the results to the acceptance guidelines in RG 1.177. 19

LR-N22-0006 LAR S22-02 Enclosure Table 3.8 FPIE Quantification Results - RG 1.177(1, 2, 3, 4) RG 1.177 ICCDP/ICLERP Base LAR Delta ICCDP/ICLERP EDG Metric (assumed 14 (/yr.) (/yr.) (/yr.) Acceptance days) Guidelines CDF 5.05E-06 1.28E-05 7.70E-06 2.96E-07 < 1E-06 A LERF 2.86E-07 1.44E-06 1.15E-06 4.42E-08 < 1E-07 CDF 5.05E-06 1.31E-05 8.04E-06 3.08E-07 < 1E-06 B LERF 2.86E-07 1.45E-06 1.17E-06 4.48E-08 < 1E-07 CDF 5.05E-06 5.40E-06 3.50E-07 1.34E-08 < 1E-06 C LERF 2.86E-07 3.28E-07 4.26E-08 1.63E-09 < 1E-07 Notes to Table 3.8-2:

1. The ICCDP/ICLERP values were calculated using the following equation:

ICCDP/ICLERP = (OOS case - Base case) x (14/365).

2. The results shown include contribution from internal events and internal flood.

The risk contributions from Fire, Seismic, and Other External Hazards was evaluated qualitatively in the risk assessment.

3. ICCDP meets the RG 1.177 acceptance criteria of less than 1E-06 per year.

4. ICLERP meets the RG 1.177 acceptance criteria of less than 1E-07 per year.

The results in the tables above demonstrate the acceptability, from a risk perspective, of increasing the Salem TS AOT for one inoperable EDG from the currently specified 72 hours to 14 days, based on the availability of an alternate AC power source (i.e., AOT diesel generators). 3.9 Assessment of NUREG-0800, Branch Technical Position 8-8 Requirements NUREG-0800, Branch Technical Position 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions," specifically discusses the defense-in-depth aspects for onsite power sources from a deterministic perspective for proposed AOT extensions. The following is a list of critical BTP 8-8 requirements and how Salem meets the intent of these requirements. a) The supplemental source must have the capacity to bring a unit to safe shutdown (cold shutdown) in case of a loss of offsite power (LOOP) concurrent with a single failure during plant operation (Mode 1). Per Salem calculation ES-9.002(Q), Standby Class 1E Diesel Generator Sizing, the ratings for the Salem EDGs are as follows: RATING KW PF KVAR KVA 1/2 Hour <3100 0.8 2325 3875 2 Hour <2860 0.8 2145 3575 2000 Hour <2750 0.8 2063 3438 Continuous <2600 0.8 1950 3250 20

LR-N22-0006 LAR S22-02 Enclosure Per Regulatory Guide 1.9, Rev. 2, loading on the diesel generators is not to exceed the short time (2 hour) rating. Based on comparison with the diesel generator load totals in PSEG calculation ES-9.002, the 2-Hour rating of 2860kW is not exceeded in all Unit 1 and Unit 2 LOCA and LOOP cases. The AOT diesel generators, when synchronized, have a rated capacity from the manufacturer as follows including the effects of parasitic loads for diesel support systems such as forced ventilation within the AOT diesel enclosure: RATING KW PF KVAR KVA 2 Hour 4912 0.8 3685 6140 Continuous 4550 0.8 3412.5 5687.5 2 Hour less losses 4712 0.8 3485 5940 Continuous less losses 4350 0.8 3212.5 5487.5 As can be seen from the above tables, the synchronized capacity of the AOT diesels exceeds the requirements of a single Salem EDG. Therefore, the AOT diesel generators will meet the electrical load requirements for each of the three Salem EDGs during a LOOP concurrent with a single failure to safely shutdown the plant. b) The permanent or temporary power source can be either a diesel generator, gas or combustion turbine, or power from nearby hydro units. This source can be credited as a supplemental source, that can be substituted for an inoperable EDG during the period of extended AOT in the event of a LOOP, provided the risk-informed and deterministic evaluation supports the proposed AOT and the power source has enough capacity to carry all LOOP loads to bring the unit to a cold shutdown. The supplemental power source will be supplied from two portable, synchronized diesel generators in weather tight containers that are trailer mounted and stored onsite. See Item a and Section 3.6 above regarding the adequacy of the capacity of the synchronized AOT diesels to supply all LOOP loads to achieve cold shutdown. c) For plants using Alternate Alternating Current (AAC) or supplemental power sources discussed above, the time to make the AAC or supplemental power source available, including accomplishing the cross-connection, should be approximately one hour to enable restoration of battery chargers and control reactor coolant system inventory. The total time required to stage the AOT diesels, electrically connect them to the respective backfeed panel and align associated bus breakers to the impacted 4kV bus is estimated to be less than three hours. Attachment 5 provides a sequence of conservatively estimated time steps for completing all the required staging, connection and backfeed actions within three hours. As discussed in Section 3.3 above and Item e below, the three hour time frame for making the AAC available is bounded by the four hour required coping time for loss of all AC power for Salem. Hope Creek uses the same AOT diesel package and connections as will be used by Salem. Hope Creek has a three hour time frame for establishing the AAC as part of its 14-day extended AOT within its TS and has validated the time frame as part of implementation of the TS amendment approved in Reference 6.9. The transit distance for the AOT diesels to the Salem connection points is shorter and there is more direct access to the electrical backfeed panels at Salem compared to the backfeed access at Hope Creek. Based on these factors and other conservative assumptions, use of the Hope Creek time line shown in 21

LR-N22-0006 LAR S22-02 Enclosure Attachment 5 is considered to be conservative for application to Salem. The procedures for establishing the AOT diesels for Salem will be based on those procedures developed for Hope Creek and the actions for establishing the AOT diesels will be included in Salem procedure OP-SA-102-106, Salem Operations Master List of Timed Actions and will be time validated as part of implementation of the amendment. d) The availability of AAC or supplemental power source should be verified within the last 30 days before entering extended AOT by operating or bringing the power source to its rated voltage and frequency for 5 minutes and ensuring all its auxiliary support systems are available or operational. The AOT diesel generators have been placed into a periodic testing program to ensure they are always available to support both planned and unplanned EDG outages. Hope Creek procedure HC.OP-PT.NB-4160, AOT Diesel Generators Periodic Test, was developed to perform this testing as part of implementation of the Hope Creek TS amendment described in Reference 6.9. Testing of each AOT diesel consists of starting, synching and electrically loading both diesels via use of a dedicated 1.0 MW load bank to verify the AOT diesels reach proper voltage and frequency. This test procedure will continue to be used as a common procedure to support the extended AOT for Salem as well. Based on this established test program, this BTP 8-8 requirement is met. e) To support the one-hour time for making this power source available, plants must assess their ability to cope with loss of all AC power for one hour independent of an AAC power source. Existing Salem calculation ES-4.009 for Unit 1 and ES-4.010 for Unit 2 provide the 125-Vdc safety related battery sizing, load profile and voltage drop calculations for the Class 1E 125-Vdc system. Salem calculation ES-3.002 provides the 28-Vdc battery and battery charger sizing calculation for both Salem units. These calculations demonstrate that Salem can cope for up to four hours during a loss of all AC power (SBO). Salem is therefore requesting a three hour allowance for establishing the AAC based on this four hour coping period and based on the three hour timeframe conservatively established for staging and connecting the AOT diesels to backfeed the applicable Salem vital 4-kV bus. Attachment 5 provides the actions and timelines necessary to establish the AAC within three hours. These actions will be controlled under Salem procedure OP-SA-102-106. f) The plant should have formal engineering calculations for equipment sizing and protection and have approved procedures for connecting the AAC or supplemental power sources to the safety buses. Salems Safety Related Diesel Generator Loading calculation ES-9.002 will be revised to document the AOT diesel generator capability showing how the AOT diesel generators fully support the load from any one EDG. The AOT diesel generator test data show that, when synchronized, they can successfully start a load representative of the Hope Creek 1250 HP RHR pump motor (0.3 pf) with a pre-established base load of 2750 KW (0.9 pf). Under this transient loading condition, the synchronized AOT diesels exhibited a measured 20.5% voltage dip. Salem motor starting requirements are defined in calculation ES-15.004, Load Flow and Motor Starting Calculation. Per this calculation, the primary safety related motors on the vital buses have a rated motor voltage of 4.16-kV and have a minimum allowable starting voltage of 70%. Therefore, the Hope Creek AOT diesel generator test results show that the Salem 4.16-kV Class 1E motors can be successfully started. 22

LR-N22-0006 LAR S22-02 Enclosure The following analysis compares this data to the Salem EDGs. The largest Salem EDG load is a 1000 HP Service Water Pump. Salem Calculation ES-9.003, System Dynamic Performance of the Salem NGS Emergency Diesel Generators, shows that the 1A EDG has the worst case accident load profile. Based on the 1A EDG auto load sequence, there is a total established base load of 1677 kW (659 kW static load + 333 kW Safety Injection Pump

  + 356 kW RHR Pump + 329 kW Containment Spray Pump). With this base load being supplied, the Salem EDG exhibits a 19% measured voltage dip when starting the 856 kW Service Water Pump. Since the Salem EDG loads are all less than the loads used for testing the AOT diesels, the test reports provided by the supplier for the AOT diesels show that they can start (with less than 20% voltage dip) and supply all required Salem EDG loads.

Salems Emergency Diesel Generator Protective Relaying Setpoint calculation ES-7.009, Protective Relaying Setpoint Calculation - Salem 1 and 2 Emergency Diesel Generators, will be revised to document the AOT diesel generator protective relaying setpoints. The AOT diesel generators were specified to provide the same level of protection as the Class 1E Hope Creek Emergency Diesel Generators. The Salem CW Bus undervoltage (UV) relays and the CW Infeed breaker UV relays are connected across a 4200/120-V (35/1) potential transformer (PT) with a dropout setting of 84-V. The 84-V UV dropout converts to 2940 Volts which is 70% of 4160 Volts. Since the AOT diesel generator test data show that the voltage never dips below 20% during application of the largest load, the CW Bus UV relays and the CW Infeed breaker UV relays will not actuate when the AOT diesel generators are being used as a supplemental power source for an EDG. There are two sets of undervoltage relays on the 4-kV vital buses. One relay is set at 70% and the other is set at 95.1% with a time delay of 13 seconds and a reset time voltage of 96%. There are also 70% UV relays associated with the 13/14 and 23/24 Station Power Transformers. As was discussed above in the CW bus 70% UV relay evaluation, the AOT diesel generator voltage never dips to 70% when the maximum load was applied during factory testing. Therefore, neither the 70% vital bus UV relays nor the SPT 70% UV relays are ever initiated. The 120V settings for the 95.1% UV relays are 113-Vac with a 114.1-Vac (reset) based on a 4200/120 PT. The actual drop out voltage for the 95.1% UV relays is (113

35) 3955-Vac and the actual reset voltage is (114.1*35) 3993.5-Vac. Based on detailed test data provided in the vendor test report for the AOT diesels, the AOT diesel voltage recovered above 96%

in less than 13.0 seconds for all simulated Hope Creek motor starts. Since the Salem motor loads are smaller than the Hope Creek motor loads, it is reasonable to conclude that the AOT diesel generator voltages will recover before the drop out time delay of the 95.1% UV relays on the vital 4-kV buses. At the time of implementation, procedures will be developed for Salem station to stage and connect the supplemental power source. These procedures will be based on the procedures established for use of the AOT diesels at Hope Creek adapted to reflect the breaker alignments required to backfeed the Salem vital buses. g) The EDG or offsite power AOT should be limited to 14 days to perform maintenance activities. The licensee must provide justification for the duration of the requested AOT (actual hours plus margin based on plant-specific past operating experience). 23

LR-N22-0006 LAR S22-02 Enclosure The proposed AOT for the Salem EDGs is for a period of 14 days based on the established scope and duration of the extensive 280 hour EDG maintenance window that currently takes place every ninth refueling outage. The established scope and duration of Salem EDG maintenance windows are described in Section 3.1. The duration of these maintenance outages include application and restoration of clearances, draining and filling of applicable fluids and performance of post maintenance surveillance testing which all contribute to the overall duration of the outage window for that maintenance interval. A contingency of 56 hours (2.3 days) is proposed to be added to the longest established maintenance window of 280 hours. This additional time is provided to accommodate unanticipated discovery and/or complications and associated troubleshooting that can arise during a major EDG overhaul or during emergent troubleshooting and associated repairs that can potentially arise during plant operation. h) The Tech Specs (TS) must contain Required Actions and Completion Times to verify that the supplemental AC source is available before entering extended AOT. For an inoperable EDG, the proposed change to TS 3.8.1.1 Action b.4 will require verification that the supplemental power source (the AOT diesel generators) is available within 72 hours. This is also reflected in the markup of the proposed TS change for both Salem units as shown in Attachment 1. i) The availability of the AAC or supplemental power source shall be checked every 8-12 hours (once per shift). The proposed change to TS 3.8.1.1 Action b.4 will include a requirement to verify the supplemental power source is available within 72 hours and once per 12 hours thereafter. j) The extended AOT will be used no more than once in a 24-month period (or refueling interval) on a per diesel basis to perform EDG maintenance activities, or any major maintenance on offsite power transformer or bus. The extended AOT will be applied for planned maintenance outages no more than once in an 18-month period per EDG which corresponds to Salems refueling interval. The Salem EDG out-of-service hours are tracked in accordance with Maintenance Rule Unavailability requirements. No limit is placed on the use of the extended AOT for unplanned (emergent) maintenance. k) The preplanned maintenance will not be scheduled if severe weather conditions are anticipated. Salem procedure OP-SA-108-116, Operability Assessment and Equipment Control Program which will control entry into the extended TS AOT will be revised to ensure that voluntary entry into the extended AOT should not be scheduled if adverse weather conditions are expected. This requirement is also reflected in the TS Bases markup provided in Attachment 2 for information only. l) The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended AOT. At the time of implementation, Salem procedure OP-SA-108-116, Salem Operability Assessment and Equipment Control Program, will be revised to include the requirement to 24

LR-N22-0006 LAR S22-02 Enclosure contact the grid operator (Load Dispatcher) once per day during the extended AOT to ensure no significant grid disturbances are expected during the extended AOT. This requirement is also reflected in the TS Bases markup provided in Attachment 2 for information only. m) Component testing or maintenance of safety systems and important non safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided. In addition, no discretionary switchyard maintenance will be performed. Salem procedures OP-SA-108-116 which will be used to control entry into the extended TS AOT and OP-AA-108-116, Protected Equipment Program, will ensure component testing or maintenance of safety systems and important non safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided during the extended 14 day AOT. The requirement will also encompass work activities categorized by station procedures as Production Risk. This requirement is also reflected in the TS Bases markup provided in Attachment 2 for information only. n) TS required systems, subsystems, trains, components, and devices that depend on the remaining power sources will be verified to be operable and positive measures will be provided to preclude subsequent testing or maintenance activities on these systems, subsystems, trains, components, and devices. Technical Specification required equipment will be verified to be operable in accordance with TS and appropriate LCO Action Statements will be entered as applicable. Maintenance and testing activities will also be controlled in accordance with the operability requirements for the affected equipment contained within the TS. Use of the AOT diesels as a supplemental power source does not alter Salems approach to ensuring operability of TS required systems, subsystems, trains, components, and devices. Operator rounds will ensure the functionality of the AOT diesels and provide an additional level of overall monitoring. o) Steam-driven emergency feed water pump(s) in case of PWR units, and Reactor Core Isolating Cooling and High Pressure Coolant Injection systems in case of BWR units, will be controlled as protected equipment. Salem procedures OP-SA-108-116 which will be used to control entry into the extended TS AOT and OP-AA-108-116, Protected Equipment Program, will be revised to ensure that the Turbine-Driven Auxiliary Feedwater Pump and all supporting systems and components shall be operable and controlled as protected equipment. This requirement is also reflected in the TS Bases markup provided in Attachment 2 for information only 3.10 Operator Actions The actions required to connect, start and align the AOT diesels as a backfeed to a vital 4kV bus at Salem station will be predominantly based on the established procedures in place for use of the same AOT diesel generators at Hope Creek. In the event of a LOOP and a contingent failure of a remaining EDG, both AOT diesels will be transported and staged in the area near the external connection panels on the exterior of the CW switchgear building (see Attachment 4, Figure 5). These steps are generally described in Section 3.6 above and a sequence of conservatively timed steps to perform the staging, alignment and backfeed of the AOT diesels is 25

LR-N22-0006 LAR S22-02 Enclosure described in Attachment 5. Based on experience from Hope Creek, the sequence of steps to establish the backfeed using the same trailers and interconnecting cables is less than three hours based on the minimum onsite staffing from Operations, Maintenance and Station Yard Services.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50, Appendix A, General Design Criteria (GDC) Salem was designed in accordance with Atomic Energy Commission (AEC) proposed General Design Criteria published in July 1967. The applicable AEC proposed criteria, as documented in Salem UFSAR Section 3.1, were compared to 10 CFR 50 Appendix A General Design Criteria (GDC) as discussed below. The applicable GDC criteria are GDC 17 and 18. Criterion 17 - Electric power systems. An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents. The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure. Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained. Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies. GDC Criterion 17 is similar to AEC Criteria 24 and 39 Criterion 18Inspection and testing of electric power systems. Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall 26

LR-N22-0006 LAR S22-02 Enclosure be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system. GDC Criterion 18 is similar to AEC Criteria 39 and 48 Following implementation of the proposed change, Salem Units 1 and 2 will remain in compliance with AEC Criteria 24, 39 and 48. In 10 CFR 50.36, Technical Specifications, the Commission established its regulatory requirements related to the content of the TS. Pursuant to 10 CFR 50.36, TS are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. Based on the assessments presented herein, the proposed change to the Salem TS continues to comply with the requirements of 10 CFR 50.36. 10 CFR 50.90, "Application for amendment of license or construction permit," addresses the requirements for a licensee desiring to amend its license and the TS incorporated therein. This license amendment request to extend the allowed outage time for an inoperable EDG from 72 hours to 14 days contingent on the availability of an alternate AC source, has been prepared to meet the requirements of 10 CFR 50.90. Following implementation of the proposed changes, Salem will remain in compliance with the above regulations and guidance. 4.2 Precedents

1. Letter from Wolf Creek Generating Station to USNRC, Docket No. 50-482: License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating, dated September 29, 2021 (ML21272A369)

2. Letter to Joseph Shea from NRC, Watts Bar Nuclear Plant, Units 1 and 2 - Issuance of Amendments Regarding Extension of Completion Time for Inoperable Diesel Generator (CAC Nos. MF7147 and MF7148), dated January 13, 2017 (ML17006A271)

3. Letter to Thomas Joyce from NRC, Hope Creek Generating Station - Issuance of Amendment RE: Emergency Diesel Generators A and B Allowed Outage Time Extension (TAC No. ME3597), dated March 25, 2011 (ML110610501)

4. Letter to Peter Sena from NRC, Hope Creek Generating Station - Issuance of Amendment No. 216 RE: Revise Technical Specification 3/4.8.1, AC Sources -

Operating, Action for Inoperable Diesel Generator (EPID L-2018-LLA-0079), dated April 30, 2019 (ML19073A073)

5. Letter to Tom Simril from NRC, Catawba Nuclear Station, Units 1 and 2 - Issuance of Amendment Nos. 304 and 300 to Technical Specification 3.8.1, AC Sources -

27

LR-N22-0006 LAR S22-02 Enclosure Operating (CAC Nos. MF9667, MF9668, MF9671, MF9672 and EPID Nos. L-2017-LLA-0256 and L-2017-LLA-0257), dated August 27, 2019 (ML19212A655)

6. Letter to Thomas Ray from NRC, McGuire Nuclear Station, Units 1 and 2 -

Issuance of Amendment Nos. 314 and 293 to Technical Specification 3.8.1, AC Sources - Operating (CAC Nos. MF9669, MF9670, MF9672, MF9673 and EPID Nos. L-2017-LLA-0256 and L-2017-0257), dated June 28, 2019 ( (ML19126A030) 4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) requests an amendment to the renewed Facility Operating License Nos. DPR-70 and DPR-75 for Salem Unit 1 and Unit 2 respectively. The proposed change revises Technical Specifications (TS) Action Statement 3.8.1.1.b.4 to allow an extension of the Allowed Outage Time (AOT) for an inoperable Emergency Diesel Generator from 72 hours to 14 days. The AOT extension is premised on implementing the requirements of NUREG 0800 Branch Technical Position 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions. These requirements include the availability of a supplemental power source capable of supplying power to the affected vital safeguard bus and established procedural requirements for equipment protection and validation of weather and grid conditions whenever the extended AOT is entered. PSEG has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

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

Response: No The proposed change does not adversely affect accident initiators or precursors or alter the design assumptions, conditions, or configuration of the facility or the manner in which the plant is operated and maintained. The proposed change does not alter or prevent the ability of the Emergency Diesel Generators (EDGs) or their associated 4-kV vital buses, or their supporting structures, systems, and components (SSCs) to perform their intended function to provide AC electrical power to accident mitigating systems. All plant mitigating systems will remain capable to address all analyzed accidents and transients and maintain their consequences within the acceptance limits coincident with a loss of offsite power. The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. The proposed change is consistent with and continues to support the assumptions and resultant consequences of the Safety Analyses contained in Chapter 15 of the Updated Final Safety Analysis Report (UFSAR). Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. 28

LR-N22-0006 LAR S22-02 Enclosure

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

Response: No The proposed change does not alter or involve any design basis accident initiators. The proposed change to the EDG allowed outage time will not result in a change to the design or operation of the plant. All plant systems and components will be operated in the same configuration and manner for which the systems were analyzed and designed. Since no change is being made to the configuration or operation of the plant, the proposed change does not cause any plant systems or processes to become initiators of a new or different type of accident. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change does not alter the permanent plant design, including instrument set points, nor does it change the assumptions contained in the UFSAR Safety Analyses. There is no reduction in capability or change in operation, design or configuration of the Salem EDGs or their associated 4-kV vital buses as a result of the proposed change. Therefore the EDGs ability to respond to a design basis accident is unaffected. The proposed change does not alter any design basis or safety limit. Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety. Based upon the above, PSEG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified. 4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. 29

LR-N22-0006 LAR S22-02 Enclosure

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 NUREG-0800 Branch Technical Position 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions, February 2012 6.2 Letter from Thomas P. Joyce to USNRC, Response to NRC Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power Salem Generating Station - Unit Nos. 1 and 2 Facility Operating License nos. DPR-70 and DPR-75 Docket Nos. 50-272 and 50-311, dated March 31, 2006 (ML061010718) 6.3 Letter from Thomas P. Joyce to USNRC, Response to the Request for Additional Information Regarding Resolution of NRC Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power, dated January 26, 2007 (ML070380313) 6.4 Federal Energy Regulatory Commission (FERC) Order 2004, Standard of Conduct for Transmission Providers, April 16, 2002, 18 CFR Part 358 6.5 NUMARC 87-00, Guidelines and Technical Basis for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, Revision 1, August 1991 (ML12137A732). 6.6 Electric Power Research Institute, Reliability of Emergency Diesel Generators and U.S. Nuclear Power Plants, NSAC-108, September 1, 1986 6.7 Letter NLR-N92031 from PSEG to USNRC, Response to Safety Evaluation on Station Blackout (SBO) Salem Generating Station, Units 1 and 2, dated March 19, 1992 (ML18096A579) 6.8 PJM Manual 39, Nuclear Plant Interface Coordination, Revision 21, June 22, 2020 6.9 Letter from USNRC to Peter Sena, Hope Creek Generating Station - Issuance of Amendment No. 216 RE: Revise Technical Specification 3/4.8.1, A.C. Sources - Operating, Action for Inoperable Diesel Generator (EPID L-2018-LLA-0079), dated April 30, 2019 (ML190773A073) 30

LR-N22-0006 LAR S22-02 Salem Technical Specification Markups The following Technical Specifications pages for Renewed Facility Operating License DPR-70 are affected by this change request: Technical Specification Page 3.8.1.1 Action b.4 3/4 8-2 The following Technical Specifications pages for Renewed Facility Operating License DPR-75 are affected by this change request: Technical Specification Page 3.8.1.1 Action b.4 3/4 8-2 1

ELECTRICAL POWSR SYSTEMS ACTION (Continued)

3. Determine the two remaining OPERABLE diesel generators are not inoperable due to common cause failure or perform Surveillance Requirement 4.8.1.1.2.a.2 within 24 hours. If the diesel generator is inoperable for preventive maintenance, the two remaining OPERABLE diesel generators need not be tested nor the OPERABILITY evaluated; and

4. In any easer : restore the inoperable diesel generator to OPERABLE status *.vithin 72 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

c. With one independent A.C. circuit and one diesel generator of the above required A.C. electrical power sources inoperable, SEE INSERT demonstrate the OPERABILITY of the remaining independent A.C.

circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours thereafter; demonstrate the OPERABILITY of the remaining OPERABLE diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.2 within 8 hours; restore at least one of the inoperable sources to OPERABLE status within 12 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore at least two independent A.C. circuits and three diesel generators to OPERABLE status within 72 hours from the time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

d. With two of the above required independent A.C. circuits inoperable:

1. Demonstrate the OPERABILITY of three diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.2 within 8 hours, unless the diesel generators are already operating; and

2. Within 12 hours, declare required systems or components supported by the inoperable offsite ci:cuits inoperable when a required redundant system or component is inoperable, or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within che following 30 hours; and

3. Restore at least one of the inoperable independent A.C.

circuits to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours; and

4. With only one of the independent A.C. circuits OPERABLE, restore the other independent A.C. circuit to OPERABLE status within 72 hours from time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

SALEM - UNIT 1 3/4 8-2 Amendment No. 253

ELECTRICAL POWER SYSTEMS ACTION (Continued)

3. Determine the two remaining OPERABLE diesel generators are not inoperable due to common cause failure or perform Surveillance Requirement 4.8.1.1.2.a.2 within 24 hours. If the diesel generator is inoperable for preventive maintenance, the two remaining OPERABLE diesel generators need not be tested nor the OPERABILITY evaluated; and

4. In any case, : restore the inoperable diesel generator to OPERABLE status within 72 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

SEE INSERT c. With one independent A.C. circuit and one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining independent A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours thereafter; demonstrate the OPERABILITY of the remaining OPERABLE diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.2 within 8 hours; restore at least one of the inoperable sources to OPERABLE status within 12 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore at least two independent A.C. circuits and three diesel generators to OPERABLE status within 72 hours from the time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

d. With two of the above required independent A.C. circuits inoperable:

1. Demonstrate the OPERABILITY of three diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.2 within 8 hours, unless the diesel generators are already operating; and

2. Within 12 hours, declare required systems or components supported by the inoperable offsite circuits inoperable when a required redundant system or component is inoperable, or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours; and

3. Restore at least one of the inoperable independent A.C. circuits to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours; and

4. With only one of the independent A.C. circuits OPERABLE, restore the other independent A.C. circuit to OPERABLE status within 72 hours from time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

SALEM - UNIT 2 3/4 8-2 Amendment No. 234

LR-N22-0006 LAR S22-02 INSERT a) Restore the inoperable diesel generator to OPERABLE status:

1. Within 72 hours, or

2. Within 14 days if the Supplemental Power Source (SPS) is available within 72 hours and verified once per 12 hours thereafter. If at any time the availability of the SPS cannot be met, either:

a. Restore the SPS to available status or restore the diesel generator to OPERABLE status within 72 hours from entry into 3.8.1.1 Action b, or

b. If 3.8.1.1 Action b has been entered for > 48 hours, restore the SPS to available status or restore the diesel generator to OPERABLE status within 24 hours, Otherwise,

3. Be in at least HOT STANDBY within the next 6 hours and COLD SHUTDOWN within the next 30 hours.

4

LR-N22-0006 LAR S22-02 Markup of Technical Specification Bases Pages for Information Only The following Technical Specifications Bases pages for Renewed Facility Operating License DPR-70 are affected by this change request: Technical Specification Bases Page 3/4.8 B 3/4 8-2 The following Technical Specifications Bases pages for Renewed Facility Operating License DPR-75 are affected by this change request: Technical Specification Bases Page 3/4.8 B 3/4 8-2 1

3/4.B ELECTRICAL POWER SYSTEMS BASES (Continued) If at any time during these conditions a redundant required system or component subsequently becomes inoperable, this completion time begins to be tracked. Discovering no offsite power to one train of the onsite Class lE Electrical Power Distribution System, or one required DG inoperable, coincident with one or more inoperable required support or supported systems or components that are associated with the other train that has power, results in starting the completion times for the Action. The specified time is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. The remaining OPERABLE AC supplies (one offsite circuit and three DGs for Condition (al, two offsite circuits and two DGs for Condition (bl, or three DGs for Condition (di) are adequate to supply electrical power to the onsite Class lE Distribution System. Thus, on a component basis, single failure protection for the required system or component's function may have been lost; however, function has not been lost. The completion time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required system or component. Additionally, the completion time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. The completion time for Condition d (loss of both offsite circuits) is reduced to 12 hours from that allowed for one train without offsite power (Action 3.8.1.1.a.2). The rationale is that Regulatory Guide 1.93 allows a completion time of 24 hours for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required system or component failure exists, this assumption is not the case, and a shorter completion time of 12 hours is appropriate. Insert A The OPERABILITY of the minimum spcified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that 1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status. The Applicability of specifications 3.8.2.2, 3.8.2.4, and 3.8.2. 6 includes the movement of irradiated fuel assemblies. This will insure adequate electrical power is available for proper operation of the fuel handling building ventilation system during movement of irradiated fuel in the spent fuel pool. An offsite circuit would be considered inoperable if it were not available to one required train. Although two trains are required by LCOs 3.8.2.2 and 3.8.2.4, the one train with offsite power available may be capable of supporting sufficient required fetures to allow continuation of CORE ALTERATIONS and irradiated fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LC01s actions. With the offsite circuit or diesel generator not available to all required trains, the option exists to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is generators inoperable, made. With both required diesel the minimum required diversity of AC power sources is

SALEM - UNIT 1 B 3/4 8-2 Amendment No. 264

3/4.8 ELECTRICAL POWER SYSTEMS BASES (Continued)

        =============================================================================

or components that are associated with the other train that has power, results in starting the completion times for the Action. The specified time is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. The remaining OPERABLE AC supplies (one offsite circuit and three DGs for Condition (a), two offsite circuits and two DGs for Condition (b), or three DGs for Condition (d)) are adequate to supply electrical power to the onsite Class lE Distribution System. Thus, on a component basis, single failure protection for the required system or component's function may have been lost; however, function has not been lost. The completion time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required system or component. Additionally, the completion time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this p,eriod. The completion time for Condition d (loss of both offsite circuits) is reduced to 12 hours from that allowed for one train without offsite power (Action 3.8.1.1.a.2). The rationale is that Regulatory Guide 1.93 allows a completion time of 24 hours for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required system or component failure exists, this assumption is not the case, and a shorter completion time of 12 hours is appropriate. Insert A The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that

1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

The Applicability of specifications 3.8.2.2, 3.8.2.4, and 3.8.2.6 includes the movement of irradiated fuel assemblies. This will insure adequate electrical power is available for proper operation of the fuel handling building ventilation system during movement of irradiated fuel in the spent fuel pool. An offsite circuit would be considered inoperable if it were not available to one required train. Although two trains are required by LCOs 3.8.2.2 and 3.8.2.4, the one train with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and irradiated fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected r'equired features LCO' s actions. With the offsite circuit or diesel generator not available to all required trains, the option exists to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With both required diesel generators inoperable, the minimum required diversity of AC power sources is not available. Therefore, it is required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required shutdown margin or boron concentration. Suspending positive reactivity additions that could result in failure to meet the minimum shutdown margin or boron concentration limit is required to assure continued safe operation. SALEM - UNIT 2 B 3/4 8-2 Amendment No.246

LR-N22-0006 LAR S22-02 Insert-A: LCO 3.8.1.1, Action b.4.a.2 allows the Allowed Outage Time (AOT) for an inoperable emergency diesel generator (EDG) to extend from 72 hours to 14 days provided the availability of the supplemental power source is verified within the initial 72-hour period and once per 12 hours thereafter. The supplemental power source provides additional defense-in depth during the extended AOT. In the event the supplemental power source cannot be verified available during the AOT, 72 hours is allowed to restore the SPS to available status or the EDG to OPERABLE status. In the event TS Action statement 3.8.1.1.b is entered for an inoperable EDG for greater than or equal to 48 hours, then only 24 hours is allowed to return the SPS to available status or the EDG to OPERABLE status. The 24 hour allowance for an unavailable SPS can be entered more than once to address unanticipated conditions associated with the SPS. When utilizing the extended EDG AOT (greater than 72 hours and less than or equal to 14 days), the following regulatory commitments shall be implemented:

1. When an EDG is removed from service for an extended 14-day AOT, the Turbine Driven Auxiliary Feedwater Pump and supporting systems and components shall be operable.

2. Component testing or maintenance of safety systems and important non safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided. In addition, no discretionary switchyard maintenance will be performed.

3. Voluntary entry into this extended 14 day AOT should not be scheduled if adverse weather conditions are expected.

4. The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended diesel generator AOT

5. Licensed Operators and Auxiliary Operators will be appropriately trained on the purpose and use of the Supplemental Power Source (AOT diesels)

6. Operating crews will be briefed on the EDG work plan and procedural actions regarding LOOP and SBO, prior to entering the extended 14 day EDG AOT.

If one or more of the above commitments is not met while in the extended completion time, the corrective action program shall be entered, the risk managed in accordance with the Maintenance Rule, and the commitment(s) restored without delay. 4

LR-N22-0006 LAR S22-02 Summary of Regulatory Commitments 1

LR-N22-0006 LAR S22-02 The following table identifies those actions committed to by PSEG in this document. Any other statements in this submittal are provided for information only purposes and are not considered to be regulatory commitments. Commitment Type Regulatory Commitment Committed One-Time Programmatic Date Action (Yes/No) (Yes/No) The following compensatory actions, which will be Concurrent with No Yes included in the TS Bases, will be applicable during approval and the extended AOT for the EDGs: subsequent implementation of

1. When a Salem EDG is removed from this proposed service for an extended 14 day AOT, the license amendment Turbine Driven Auxiliary Feedwater Pump and supporting systems and components shall be operable.

2. Component testing or maintenance of safety systems and important non safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided. In addition, no discretionary switchyard maintenance will be performed.

3. Voluntary entry into this LCO action should not be scheduled if adverse weather conditions are expected.

4. The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended diesel generator AOT

5. Licensed Operators and Auxiliary Operators will be appropriately trained on the purpose and use of the Supplemental Power Source (AOT diesels).

6. Operating crews will be briefed on the EDG work plan and procedural actions regarding LOOP and SBO prior to entering the 14 day extended AOT for the EDG.

2

LR-N22-0006 LAR S22-02 Supporting Drawings and Figures 1

LR-N22-0006 LAR S22-02 Figure-1 Simplified Diagram of 500-kV Connection to PJM System 2

TRANSMISSION OUTAGES PJM OASIS OASIS LINK: (http://oasis.pjm.com/doc/linesout_new.txt) UPDATED: 11011900 12:00 AM Artificial Island 500kV Network To BRANCHBURG NEW SMITHBURG CTHIS LINE IS NOT FREEDOM 4 5019 3-ASSOCIATED WITH OUR AIOG.) 5020 (FE) Bus 12 2- 4 L 30kV EAST WINDSOR (FE) Bus28 5038 Bl2(C) ORCHARD (AE) 230kV 4 5039 3- Bus 63 5007 BlO(A) 5024 5021 5023 RED LION (DPW Bus27 501 505 5025 r-..-r--'"1-lr--1 50 36 505 502 500kV KEENEY (DPW ROCK SPRINGS Bus 51 Bus 10 230kV S00/2SOKV 500-1 BRK AUTO TRANS SILVER RUN HOPE CREEK A1P UNDERCONTRlJCTION Bus29

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LR-N22-0006 LAR S22-02 Figure 4-1 AOT Diesel Backfeed Path - 1A Vital Bus Example 8

Engineering Record #: DEC220044 80131437-0100 Attachment 1 Page 1 of 4 AOT DG

              #1 And #2 Red-indicates breaker CLOSED Green-indicates breaker OPEN Blue-indicates energized buss work

Engineering Record #: DEC220044 80131437-0100 Attachment 1 Page 2 of 4 Red-indicates breaker CLOSED Green-indicates breaker OPEN Blue-indicates energized buss work AOT DG

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LR-N22-0006 LAR S22-02 Figure 4-2 AOT Diesel Backfeed Path - 2A Vital Bus Example 11

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Engineering Record #: DEC220044 80131437-0100 Attachment 1 Page 4 of 4 AOT DG

                                                            #1 and #2 Red-indicates breaker CLOSED Green-indicates breaker OPEN Blue-indicates energized buss work

LR-N22-0006 LAR S22-02 Figure 5 AOT Diesel Staging Area Unit-1 Connection Panel Unit-2 Connection Panel 14

LR-N22-0006 LAR S22-02 Actions and Durations to place AOT Diesels in Service 1

LR-N22-0006 Attachment 5 LAR S22-02 Performance Time Minutes Time 0-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90 90-100 100-110 110-120 120-130 130-140 140-150 150-160 160-170 170-180 Notes Item # Task (mins) Resource 1 Start of LOOP 20 CR X Note 2 Assemble, Brief & Dispatch Team to Outdoor Flex Storage 2 Area 2 (OFSA2) to Move Cable and Diesel Trailers 10 Note 1 X Notes 1 & 3 Open breaker for 240V power source to Portable Diesel 1- Tech 3 Generators 5 1-NEO X Note 3 1-Tech 4 Disconnect 240V Cables from Portable Diesel Generators 10 1-NEO X Note 3 5 Hook Truck to Cable Trailer 5 3- Note 1 X Notes 1 & 3 6 Drive Cable Trailer to Deployment Location 5 3- Note 1 X Notes 1 & 3 7 Hook Tow Vehicle to DG #1 15 3- Note 1 X Note 3 8 Drive DG #1 to Deployment Location 10 3- Note 1 X Notes 1 & 3 9 Disconnect Tow Vehicle From DG #1 15 3- Note 1 X Note 3 10 Drive Tow Vehicle back to OFSA 2 10 3- Note 1 X Note 3 11 Hook Tow Vehicle to DG #2 15 3- Note 1 X Note 3 12 Drive DG #2 to Deployment location 10 3- Note 1 X Notes 1 & 3 13 Disconnect Tow Vehicle from DG #2 15 3- Note 1 X Notes 1 & 4 Remove Cables from Cable Trailer and Connect to DG#1, 1-Tech 14 DG #2, and CW Switchgear Receptacle 95 1-NEO X Note 5 Example - Assume AOT Diesels Will Power 1A 4KV Vital Bus 15 CR ensures 1A SEC breaker opened 1AVIB24 10 1- NEO X Note 6 CR crew aligns 4KV &13KV Bus by Opening the following breakers 13KV BS A-F 13ASD 1A3D 13CW1AD 13BSD 1A5D 1CW8AD 13CSD 1ADD 10 CR X 1CW2AD 14ASD 1A7D 1CW3AD 1A1D 1A8D 1CW4AD 1A2D 1A10D 16 1CW8AD Auto Swap Off Note 7 Defeat CW Bus UV Relays 20 1-Qualifed x Note 8 17 Individual Rack -in and CLOSE 1CW3BD 5 1-Tech X Note 8 18 1-NEO 19 CR CLOSE 13CW1AD 5 CR X Note 7 Start AOT DGs 10 1-Tech X Note 3 20 1-NEO CR CLOSES 13ASD, A Vital Bus is energized and ready for 5 CR 21 further loading X Note 7 Notes: Note 1 It is expected that the AOT EDG Team will consist of a Towing Team with 1 Qualified Towing Operator and 2 support personnel, a qualified individual to defeat the CW Bus undervoltage relays and 2 other personnel, either 2 NEOs or 1 NEO and 1 Shift Technician. Note 2 Assume longest timeline, Ops enters EOP TRIP-1, Transitions to EOP-TRIP-2, Initiates AB.LOOP-0001 when directed by EOP-TRIP-2 Note 3 Times are consistent with Hope Creek Timeline Note 4 Tow vehicle may remain connected. Time accounts for proper positioning, securing and leveling of the Diesel. Note 5 Times for staging and connecting of cabling are consistent with Hope Creek with some conservatism added. Note 6 Opening 1A SEC breaker gives CR control of 1A 4KV bus breakers. Field action performed by NEO that is not assigned to AOT Team. Action addressed in EOP-TRIP-2 Note 7 All breaker operations performed from the control room. Not required to open 1A4D (AOT DG can support start with 460/230 loads ready). 13CW1AD Closed after UV relay protection defeated. Note 8 Activities performed at Circulating Water breaker enclosure. 3 Total UV relays on CW bus. The one qualified individual performing the relay work is not part of team connecting cables. Unsure at this time who will be qualified to perform this action. Acronyms NEO - Nuclear Equipment Operator (non-Licensed) CR - Control Room 1}}

v t e Letter Sequence Request
EPID:L-2022-LLA-0095, License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 Hours to 14 Days (Approved, Closed)
Initiation Request, Request, Request Acceptance Administration Questions 17 October 2022 29 November 2022 Answers Results Approval Other:
MONTHYEAR2022-12-09 [Table View]

LR-N22-0006, License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 Hours to 14 Days

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Subject:

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Subject:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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LR-N22-0006, License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 Hours to 14 Days

Text

Subject:

Enclosure:

Subject:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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