LR-N15-0169, Fifth Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

From kanterella
(Redirected from ML15239B333)
Jump to navigation Jump to search

Fifth Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.
ML15239B333
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 08/27/2015
From: Davison P
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, LR-N15-0169
Download: ML15239B333 (26)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSEG Order EA-12-049 LR-N15-0169 AUG 27 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

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

References:

1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
2. PSEG Letter LR-N13-0031, "PSEG Nuclear LLC's Overall Integrated Plan for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013
3. PSEG Letter LR-N15-0022, "PSEG Nuclear LLC's Fourth Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 18, 2015

AUG 27 2015 Order EA-12-049 Page 2 LR-N15-0169

4. NRC Letter to PSEG, "Hope Creek Generating Station- Relaxation of the Schedule Requirements For Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"' dated May 20, 2014
5. NRC Letter to PSEG, "Hope Creek Generating Station- Relaxation of the Schedule Requirements For Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"' dated April 29, 2015 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to PSEG Nuclear LLC (PSEG). NRC Order EA-12-049 was immediately effective and directed PSEG to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. In accordance with Condition IV. C.1.a of NRC Order EA-12-049, PSEG submitted an Overall Integrated Plan (OIP) for the Hope Creek Generating Station (HCGS) on February 27, 2013 (Reference 2). Condition IV.C.2 of NRC Order EA-12-049 requires six-month status reports to delineate the progress made in implementing the requirements of the Order. Attachment 1 to this letter provides the fifth six-month status report, which summarizes progress made in implementing the requirements of NRC Order EA-12-049 at HCGS since the previous update provided in Reference 3.

Attachment 1 reflects the schedule relaxations granted by the NRC in References 4 and 5. The potential need for additional schedule relaxation is described in Section 5 of Attachment 1.

There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please do not hesitate to contact Mr. Brian Thomas at 856-339-2022.

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

Executed on t\:v.... ,t 'J.l) ()..., o \)

(Date)

Sincerely,

\*\)

Paul J. Davison Site Vice President Hope Creek Generating Station

AUG 27 2015 Order EA-12-049 Page 3 LR-N15-0169 Attachment 1: Hope Creek Generating Station Fifth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc: Mr. William Dean, Director of Office of Nuclear Reactor Regulation Mr. Daniel Dorman, Administrator, Region I, NRC Ms. Carleen Parker, Project Manager, NRC Mr. Justin Hawkins, NRC Senior Resident Inspector, Hope Creek Mr. Patrick Mulligan, Chief, NJBNE Mr. Thomas MacEwen, Hope Creek Commitment Tracking Coordinator Mr. Lee Marabella, PSEG Commitment Coordinator- Corporate

LR-N15-0169 Attachment 1 Hope Creek Generating Station Fifth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

LR-N15-0169 1 Introduction PSEG Nuclear LLC (PSEG) developed an Overall Integrated Plan (OIP) (Reference 1) for the Hope Creek Generating Station (HCGS), documenting the diverse and flexible coping strategies (FLEX) in response to NRC Order EA-12-049 (Reference 2). In References 3 through 6, PSEG provided six-month status reports associated with implementation of the requirements of NRC Order EA-12-049. This report is the fifth six-month status report, which provides implementation status and progress since the previous report (Reference 6). This update follows the guidance in Section 13.2 of N uclear Energy Institute (NEI) Report 12-06 (Reference 7), which states that the six month status reports should include an update of milestone accomplishments since the previous report, changes to the compliance method, schedule, and the need for relief and the basis for relief, if applicable. This status report reflects the schedule relaxation requests that were approved by the NRC in References 8 and 9.

2 Milestone Accomplishments The following HCGS FLEX milestones have been completed:

  • Submit Overall Integrated Plan - PSEG submitted the HCGS FLEX OIP to the NRC via Reference 1.
  • Develop FLEX Strategies - PSEG has developed HCGS FLEX strategies as described in the OIP and has identified design, analysis, procurement, and programmatic actions necessary to achieve compliance with NRC Order EA-12-049. Changes to the FLEX strategies involving changes to methods of compliance with NEI 12-06 are addressed in Section 4.
  • Perform Staffing Analysis- PSEG completed the HCGS Phase 2 staffing analysis (Reference 10) as required by the 10 CFR 50.54(f) information request dated March 12, 2012 (Reference 11). The HCGS Phase 2 staffing analysis addresses resources needed to implement FLEX strategies during simultaneous extended loss of AC power scenarios at HCGS and Salem Generating Station, Units 1 and 2.
  • Develop Training Plan- PSEG developed training materials and schedules, and has begun training personnel on the HCGS FLEX strategies.
  • Develop Strategies/Contract with Regional Response Center (RRC) - PSEG Nuclear is a member of the Strategic Alliance for FLEX Emergency Response (SAFER) and has a SAFER response plan to coordinate delivery of additional equipment from the National SAFER Response Centers (formerly known as Regional Response Centers).

Page 1 of 18

LR-N15-0 169 3 Milestone Schedule Status The following table provides an update to HCGS FLEX OIP milestones. The table provides the activity status of each item, and whether the original expected completion date has changed. Original target completion dates are based on the original NRC Order EA-12-049 schedule requirement of compliance prior to startup from the spring 20 15 refueling outage. The current milestones reflect the schedule relaxations in References 8 and 9.

Original Revised Target Target Milestone Activity Status Completion Completion Date Date Submit Overall Integrated Plan Feb 20 13 Complete Aug 2013 Complete Feb 20 14 Complete Aug 20 14 Complete Feb 20 15 Complete Six-Month Status Update Complete With Aug 2015 This Report Feb 20 16 Not Started Aug 20 16 Not Started Develop Strategies May 20 13 Complete Modifications Develop Modifications Apr 20 14 Started Oct 20 15 Implement Modifications Apr 20 15 Started Oct 2016 FLEX Support Guidelines (FSGs)

Develop FSGs Dec 20 13 Complete Apr 20 15 N/A Approve FSGs ( milestone Started Oct 20 15 added)

Validation Walk-throughs or Demonstrations of FLEX May 20 15 Started Oct 20 15 Strategies and Procedures Perform Staffing Analysis Dec 20 13 Complete Dec 20 14 Develop Training Plan Jun 2014 Complete Jan 20 15 Implement Training Dec 20 14 Started Dec 20 15 Page 2 of 18

LR-N15-0169 Original Revised Target Target Milestone Activity Status Completion Completion Date Date Develop Strategies I Contract with National SAFER Response Oct 2013 Complete Feb 2015 Center (formerly called "Regional Response Center")

Procure Equipment Dec 2013 Started Sep 2015 Create Maintenance Procedures Jun 2014 Started Oct 2015 Emergency Preparedness (EP)

Jun 2014 Complete May 2015 Communications Improvements HC Implementation Outage Apr 2015 Not Started Oct 2016 Report to NRC When Full Aug 2015 Not Started Jan 2017 Compliance is Achieved 4 Changes to Compliance Method PSEG identified changes to the method of compliance with NEI 12-06 in the February 2015 status report (Reference 6). Additional details of changes to the original FLEX strategies are being provided as part of the mitigation strategies audit process.

The information provided in the February 2015 status report is revised as indicated by revision bars, as follows:

Outdoor FLEX Storage Areas and Deployment Strategies HCGS is using an alternative to the criteria of NEI 12-06 Section 8.3.1, "Protection of FLEX Equipment," which recommends storage of the N FLEX equipment within a structure to provide protection against snow, ice and extreme cold hazards. A comparable level of protection is being provided by outdoor storage locations which consist of the following:

  • the HCGS Unit 2 reactor building roof
  • west of Salem Generating Station (SGS) - inside the protected area
  • east of the SGS oil water separator area - outside the protected area and within the vehicle barrier system
  • the northwest corner of the HCGS Unit 2 reactor building- inside the protected area An additional set of debris removal and towing equipment will be stored at a separate on-site location.

Page 3 of 18

LR-N15-0169 FLEX equipment stored outdoors is designed for extreme high and low temperatures for the site and will be protected as required by the manufacturer, e.g., equipped with direct heating features to ensure it will function when called upon.

The outdoor storage locations provide greater than 1200 feet of separation, generally in a north-south direction, to provide reasonable protection from a tornado event.

Two diesel generators will be pre-staged at their point of deployment on the HCGS Unit 2 reactor building roof. Either of the two DGs is capable of providing the necessary power for the FLEX strategies. The elevation of the HCGS Unit 2 reactor building roof is 132', which is above the flood elevation and provides protection against hurricane missiles (e.g., automobile) originating from ground level. The FLEX DG supports are designed to withstand the design basis hurricane wind load of 108 mph. The DGs are mounted seismically to the HCGS Unit 2 reactor building roof, which is a Seismic Category I structure. Seismic II/I criteria apply to the structural design of the DG supports and anchorage to the concrete roof. The mounting has been analyzed to ensure the DGs will remain available after a seismic event equal to a safe shutdown earthquake (SSE) . In the event of a tornado that disables both diesel generators, an additional diesel generator will be deployed from a location greater than 1200 feet from the affected diesel generators.

Prior to the arrival of a hurricane on site, FLEX equipment to mitigate a flooding event will be moved inside flood-protected areas of HCGS Units 1 and 2.

The HCGS FLEX strategy includes equipment pre-staged at its point of deployment as an alternative to portable Phase 2 equipment as suggested by NEI 12-06. Protection of pre-staged equipment from external hazards combined with diversely located portable equipment provides flexibility to prevent a single event from defeating the FLEX strategy.

Event Timelines The Phase 2 staffing assessment (Reference 10) includes a sequence of events consistent with event timelines supported by plant-specific MAAP analyses. The final timelines are being incorporated into a HCGS FLEX program document to support the FLEX implementation milestones and will be submitted with a final integrated plan.

GOTHIC Analyses Plant-specific GOTHIC analyses are being used to establish temperature conditions for personnel habitability and equipment availability, including determination of the need for compensatory measures.

Page 4 of 18

LR-N15-0169 Reactor Core Isolation Cooling (RCIC) Suction Line Connection The FLEX connection to RCIC suction piping has been determined to be unnecessary and eliminated from the strategy.

RCIC Suction Temperatures The HCGS FLEX OIP (Reference 1) stated that HCGS will implement Boiling Water Reactor Owners Group (BWROG) recommendations to support RCIC operation with suction fluid temperatures of approximately 230° F. The HCGS FLEX strategy and associated MAAP analyses only credit RCIC operation at suction temperatures up to 215° F consistent with reliable long term RCIC operation.

Torus Water Flow Path A flow path from the torus to the FLEX header is being established via connection to the core spray system in lieu of the torus water cleanup system.

FLEX Equipment Fuel Oil Storage On-board diesel fuel storage tank capacities for Phase 2 FLEX equipment are revised and will not support 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of continuous operation without refueling. The tanks will provide sufficient capacity to minimize actions to keep equipment running until refueling is performed using on-site, protected fuel oil sources.

Page 5 of 18

LR-N15-0169 Equipment List The following table provides an updated list of major FLEX equipment for HCGS:

Table 1 FLEX Equipment List Phase Description of Equipment Strategy 2 (2) 480 VAG Diesel Driven Generators Core, Containment, (H1 FLX-10-G-2025, H1 FLX-10-G-2026) SFP, Instrumentation 2 (1) Diesel Driven Pump Core, Containment, (H1 FLX-10-P-500) SFP 2 (2) Motor Driven Pumps Core, Containment, (H1 FLX-10-P-001, H1 FLX-10-P-002) SFP 2 (2) Compressors Core, Containment (H1 FLX-10-K-001, H1 FLX-10-K-002) 2 (2) FLEX Fuel Oil Pumps Core, Containment, (H1 FLX-10-P-003, H1 FLX-10-P-004) SFP 2 (1) Caterpillar 930K Wheel Loader Accessibility (C1 FLX-1 FLXE41) 2 (1) Komatsu 250 Wheel Loader Accessibility (C1 FLX-1 FLXE43) 2 (2) Kalmar Ottawa 4 x 2 Terminal Tractors Deployment (C1 FLX-1FLXE44, C1 FLX-1 FLXE45) 2 (2) Forklifts Accessibility (C1 FLX-1FLXE65, C1 FLX-1 FLXE66) 3 (4) 4.16 kV Generators Core, Containment, SFP 3 (2) Diesel Driven Pumps Core, Containment, SFP 3 (1) Water Treatment Plant Core, SFP 3 (1) Suction Lift Pump Core, Containment, SFP Per NEI 12-06, Phase 2 FLEX coping equipment must be stored on site in a configuration that is protected from the applicable hazards and deployable by onsite resources. A combined total of four diesel generators and two diesel pumps are required in Phase 2 for all the reactors on site (SGS Units 1 and 2 and HCGS). SGS requires three diesel generators and one diesel pump. HCGS requires one diesel generator and one diesel pump. These are the minimum required ("N" quantity).

Page 6 of 18

LR-N15-0169 Additionally, a spare diesel generator and diesel pump are required for the N+1 requirement during any BDBEE, which results in a total of five diesel generators and three diesel pumps. Because SGS and HCGS cannot share a generator during the hurricane event due to potential flooding that could restrict equipment movements around the site, six diesel generators are required to meet the N+1 requirement for the hurricane event. Dispersing this equipment such that the six diesel generators and three separate pumps are spread across the site area allows for two diesel generators and a diesel pump to be destroyed by a tornado and still have N equipment survive a tornado. This is explicitly permitted in NEI 12-06 Section 7.3.1.1.c.

Towing and debris removal equipment are stored so that N sets of equipment (one towing vehicle, one debris removal vehicle, and one forklift) will survive all hazards.

Sketches Updated sketches are provided in Appendix A.

N+1 FLEX Hoses and Cables PSEG plans to use NEI's recommended alternative to NEI 12-06 regarding N+1 hoses and cables (Reference 27) as endorsed by the NRC in Reference 28.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation By letter dated April 16, 2014 (Reference 12), PSEG requested schedule relaxation to defer HCGS full compliance with NRC Order EA-12-049, from the HCGS Refueling Outage 19 (H1R19) in spring 2015, to H1R20 in fall 2016. This relaxation request was approved via Reference 8 in order to allow time for implementation of torus venting requirements as needed to support compliance with NRC Order EA-12-049, and is consistent with the schedule for implementation of severe accident capable torus venting requirements in NRC Order EA-13-109 (Reference 17).

In order to allow sufficient time to implement changes to the HCGS FLEX strategies, PSEG requested additional schedule relaxation by letter dated March 11, 2015 (Reference 13), and supplemented by letter dated April 13, 2015 (Reference 14). The NRC granted the requested schedule relaxation on April 29, 2015 (Reference 9), which requires completion of the activities to implement NRC Order EA-12-049, other than those associated with the severe accident capable torus vent, by December 18, 2015.

During implementation of mechanical system modifications to establish the FLEX connections to the Residual Heat Removal (RHR) system, PSEG identified the potential need for additional schedule relaxation from the December 18, 2015 milestone. The modifications include installation of a tie-in with a quick disconnect hose for an alternate FLEX connection to RHR piping in the "A" RHR Heat Exchanger Room, upstream of locked closed valve PV-F051A. PSEG planned to perform this work during reactor operation because the affected section of piping is normally isolated and installation would have had no impact on RHR system availability. However, during the work Page 7 of 18

LR-N15-0169 clearance process to support installation, PSEG discovered the PV-F051A valve to have seat leakage. The valve seat leakage and accumulation of water within RHR system piping affects installation of the modification such that it would affect RHR system availability and would require entry into a 72-hour Technical Specification action statement if performed during power operation. PSEG is currently evaluating various alternatives including a schedule relaxation request specifically to allow installation of the RHR tie-in for the alternate FLEX connection during the fall 2016 refueling outage.

Page 8 of 18

LR-N 15-0169 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation Resolution of items identified in the NRC's interim staff evaluation ( ISE) for HCGS (Reference 18) is being addressed as part of the mitigation strategies audit process. A summary and status of the ISE items are provided below.

ID Item Ref. Description Status

1. Generic Concern HCGS is currently working on extending the battery duty cycle and is Complete - Coping analyses for

- Battery Life following the industry position on battery life as outlined in the Nuclear 125 VDC and 250 VDC batteries Energy Institute (NEI) white paper dated August 27, 2013 have been completed using the (Reference 19) and endorsed by NRC via letter to NEI dated NRC-endorsed white paper.

September 16, 2013 (Reference 201

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

- MAAP complete the development of FLEX timelines and strategies, documentation of MAAP analyses consistent with the NRC endorsement letter to NEI dated October 3, that have been performed 2013 (Reference 21). consistent with the NRC endorsement letter - supports the 1211812015 FLEX implementation milestone.

3. Generic Concern HCGS will enhance shutdown risk processes and procedures using In progress with completion

- Shutdown I the supplemental guidance provided in the NEI position paper entitled scheduled to support the Refueling Modes "Shutdown I Refueling Modes," dated September 18, 2013 1211812015 FLEX implementation (Reference 22) and endorsed by the NRC via letter to NEI dated milestone.

September 30, 2013 (Reference 231-

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

- Preventive programs, HCGS will use the EPRI Technical Report entitled "Nuclear scheduled to support the Maintenance Maintenance Applications Center: Preventative Maintenance Basis for 1211812015 FLEX implementation FLEX Equipment," transmitted to NRC via NEI letter dated October 3, milestone.

2013 (Reference 24) and endorsed by NRC letter dated October 7, 2013 (Reference 25). -

Page 9 of 18

LR-N15-0169 ID Item Ref. Description Status

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

- Anticipatory Water Reactor Owners Group (BWROG) Emergency Procedure implementing the containment Venting Guidelines I Severe Accident Guidelines (EPG/SAG), Revision 3, venting guidance of Revision 3 to 01 3.2.3.C including any associated plant-specific evaluations, must be the BWROG EPG to support the completed in accordance with the provisions of NRC letter dated FLEX strategies by the 12/18/2015 January 9, 2014 (Reference 26). FLEX implementation milestone, and SAG revisions to support severe accident containment venting prior to startup from the fall 2016 outage.

6. 01 3.2.4.8.E The use of pre-staged FLEX generators appears to be an alternative Complete. PSEG has evaluated to NEI 12-06. The licensee has not provided sufficient information to the staging location of the FLEX demonstrate that the approach meets the NEI 12-06 provisions for generators as part of the overall pre-staged portable equipment. Additional information is needed from storage and deployment strategy the licensee to determine whether the proposed approach provides an with consideration of the equivalent level of flexibility for responding to an undefined event as applicable site external hazards.

would be provided through conformance with NEI 12-06. The evaluation concludes that FLEX generator storage and deployment provide reasonable assurance that no single external event would defeat the FLEX strategy.

7. CI 3.1.1.1.A Confirm licensee's evaluation of the HCGS Unit 2 structures verifies Complete. PSEG has determined I that the structures will meet the considerations described in I

the HCGS Unit 2 reactor building, NEI 12-06, Section 5. 3.1 (protection against seismic hazards). including the floor at grade elevation 102 ft. and the roof areas being used for pre-staged FLEX generators and cable reel enclosures, is structurally adequate for FLEX equipment storage.

Page 10 of 18

LR-N15-0169 ID Item Ref. Description Status

8. Cl 3.1.2.3.A Confirm that the procedures and programs for deployment of portable In progress with procedure equipment in a flooding event conforms to NEI 12-06, Section 6.2.3 issuance scheduled to support the considerations 1 (incorporation of actions necessary to support 12/18/2015 FLEX implementation flooding deployment considerations into procedures) and 2 (additional milestone.

guidance may be required to address the deployment of FLEX for flooded conditions). Additionally, procedures and programs need to address hazard concerns related to high winds, snow, ice and extreme cold and high temperatures.

9. CI 3.1.3.1.A Confirm that the licensee's separation of equipment stored outside is Complete. PSEG evaluated sufficient to preclude all sets of equipment from being damaged by a outdoor storage of FLEX single tornado. equipment as summarized in Section 4 of this update.
10. CI 3.2.1.1.A From the June 2013 position paper (endorsed by the NRC via Same as Item #2, Generic Reference 21), benchmarks must be identified and discussed which Concern- MAAP.

demonstrate that MAAP4 is an appropriate code for the simulation of an ELAP event at your facility.

11. CI 3.2.1.1.B Confirm that the collapsed vessel level in the MAAP4 analysis Same as Item #2, Generic remains above Top of Active Fuel (TAF) and the cool down rate is Concern- MAAP.

within technical specification limits.

12. C1 3.2.1.1.C Confirm that MAAP4 is used in accordance with Sections 4.1, 4. 2, 4.3, Same as Item #2, Generic 4.4, and 4.5 of the June 2013 position paper (endorsed by the NRC Concern - MAAP.

via Reference 21).

13. CI 3.2.1.1.D Confirm that in using MAAP4, the licensee identifies and justifies the Same as Item #2, Generic subset of key modeling parameters cited from Tables 4-1 through 4-6 Concern - MAAP.

of the "MAAP4 Application Guidance, Desktop Reference for Using MAAP4 Software, Revision 2" (Electric Power Research Institute Report 1020236). This should include response at a plant-specific level regarding specific modeling options and parameter choices for key models that would be expected to substantially affect the ELAP analysis performed for that licensee's plant. Although some suggested key phenomena are identified below, other parameters considered important in the simulation of the ELAP event by the vendor I licensee should also be included as follows: Nodalization, General two-phase flow modeling, Modeling of heat transfer and losses, Choked flow, Vent line pressure losses, and Decay heat. ------

Page 11 of 18

LR-N15-0169 ID Item Ref. Description Status

14. CI 3.2.1.1.E Confirm that the specific MAAP4 analysis case that was used to Same as Item #2, Generic validate the timing of mitigating strategies in the Integrated Plan is Concern - MAAP.

identified and available for NRC staff to view. Alternately, a comparable level of information may be included in the supplemental response. In either case, the analysis should include a plot of the collapsed vessel level to confirm that T AF is not reached (the elevation of the TAF should be provided) and a plot of the temperature cool down to confirm that the cool down is within technical specification limits.

15. Cl 3.2.1.2.A Insufficient information was provided relative to recirculation pump Same as Item #2, Generic seal or other sources of leakage used in the ELAP analysis. Concern - MAAP.

Additional information is required to evaluate the amount of seal leakage that was used in the HCGS transient analyses and how the seal leakage was determined. This information will need to include the technical basis for the assumptions made regarding the leakage I rate through the recirculation pump seals and also other sources.

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

16. Cl 3.2.1.3.A The SOE Timeline in the Integrated Plan is tentative. The licensee In progress with final addressed this issue during the audit process by describing that the documentation of the event SOE timeline presented in the Integrated Plan will be finalized based timelines to be completed prior to on plant-specific analysis, procedure development and timeline the FLEX implementation validation. Confirm that the final SOE timeline is acceptable. milestone of 12/18/15.
17. Cl 3.2.1.3.8 The licensee stated that they are performing a HCGS specific MAAP4 In progress, as part of resolution of analysis consistent with the NRC endorsement letter to NEI dated the generic concern regarding use October 3, 2013 (ADAMS Accession No. ML13275A318) of MAAP for containment analyses (Reference 21), to validate the timeline and NEDC-33771-P (Item 2, above), and completion of applicability. Confirm that the results of the evaluation and validation timeline validation (Item #16, of the SOE timeline are acceptable. Cl 3.2.1.3.A) - supports the 12/18/2015 FLEX implementation milestone.

Page 12 of 18

LR-N15-0169 ID Item Ref. Description Status

18. Cl 3.2.1.4.A Additional technical basis or a supporting analysis is needed for both Complete. Hydraulic analyses of FLEX pumping system (one engine/pump located at the SWIS and the diesel-driven and electric one motor/pump located in the reactor building) capabilities motor-driven FLEX pumps show considering the pressure within the RPV and the loss of pressure adequate flow capability to support along with details regarding the FLEX pump supply line routes, length the FLEX strategies.

of runs, connecting fittings, to show that the pumps are capable of injecting water into the RPV with a sufficient rate to maintain and recover core inventory for both the primary and alternate flow paths as well as supplying water [to] the SFP. The licensee addressed these issues during the audit process and stated that this analysis will be performed as part of the design change process. Confirm that the analysis results are acceptable.

19. Cl 3. 2.1.6.A Confirm that the results of the final sizing calculations for the SRVs In progress, pending final accumulators, the final temperature profile of the drywell, DC coping documentation of GOTHIC and results and the results of the GOTHIC temperature modeling for the MAAP resutts - supports reactor building are acceptable. 12/18/2015 implementation milestone.
20. CI 3.2.2.A Confirm that the licensee's final SFP cooling timeline is valid for the In progress- supports 12/18/2015 required response actions implementation milestone.
21. CI 3.2.3.A A site-specific analysis (MAAP) will be performed to determine the Same as Item #2, Generic correct time to open the HCVS vent and the expected drywell and Concern - MAAP.

wetwell temperatures during the BDBEE. This information will be included in a future six-month update. The site-specific analysis MAAP results show primary needs to include a listing of critical drywell components that may be containment temperatures during affected by the elevated temperatures (e.g., drywell seals and an ELAP would be less than those penetrations). Confirm that the analysis results are acceptable. assumed in the OIP.

22. CI 3.2.3.B The NRC staff questioned the ability of RCIC to operate with suction Complete. The FLEX strategies temperatures up to 230 degrees Fahrenheit. During the audit and supporting MAAP analyses process, the licensee addressed this issue by stating that a RCIC only credit RCIC operation at fluid durability study is in progress. Confirm that the results are temperatures up to 215 degrees F, acceptable. consistent with long term RCIC reliability.

Page 13 of 18

LR-N 15-0169 ID Item Ref. Description Status

23. Cl 3.2.4.2.A Confirm that the GOTHIC analysis and/or technical evaluation In progress. Initial GOTHIC performed to demonstrate the adequacy of the ventilation provided in modeling and room temperature all plant strategic areas (including pathways for access to equipment) calculations are complete and may to support essential equipment operation throughout all phases of an be refined to reflect additional ELAP is acceptable. compensatory measures -

supports the 12/18/2015 FLEX implementation milestone.

24. Cl 3.2.4.2.8 Confirm that the effects of elevated or lowered temperatures in the In progress - supports the battery room, especially if the ELAP is due to a high or low 12/18/2015 FLEX implementation temperature hazard, have been considered. Confirm the adequacy of milestone.

the ventilation provided in the battery room to protect the batteries from the effects of extreme high and low temperatures.

25. Cl 3.2.4.2.C Confirm that the GOTHIC calculations for the battery rooms include Complete. GOTHIC analyses the effects of hydrogen accumulation and confirm the actions assume the battery room doors necessary to prevent unacceptable hydrogen accumulation. 5541A and 5545A are opened at four hours and show that the hydrogen concentration remains below 1 percent.
26. Cl 3.2.4.4.A Confirm that the upgrades to the plant communication systems Complete. PSEG has discussed in the licensee communications assessment (References implemented improvements to 15 and16) in response to the March 12, 2012, 50.54(f) request for radio and satellite phone information letter for HCGS and documented in the staff analysis communications capability.

(ADAMS Accession No. ML13130A387) (Reference 11) have been completed.

27. Cl 3.2.4.6.A Confirm that the GOTHIC modeling and room temperature In progress. Initial GOTHIC calculations of plant strategic areas (e.g. MCR, RCIC room, HPCI modeling and room temperature room (if needed), torus room, and battery rooms including pathways calculations are complete and may for access to equipment) show acceptable results for personnel be refined to reflect additional habitability and equipment capability. compensatory measures -

supports the 12/18/2015 FLEX implementation milestone.

28. Cl 3.2.4.6.8 Confirm that potential high temperature and high humidity in the S FP In progress- supports the and fuel handling floor area has been addressed with regard to 12/18/2015 FLEX implementation accessibility. milestone.

Page 14 of 18

LR-N 15-0 169 ID Item Ref. Description Status

29. Cl 3.2.4.8.A Confirm that the design of the FLEX electrical hookups include the In progress pending approval of details on how to connect to, and interface with existing plant procedures. FLEX electrical equipment. connections and interfaces with plant equipment are designed for ease of installation using prefabricated connectors or terminal lugs. Supports 12/18/2015 FLEX implementation milestone.
30. Cl 3.2.4.8.8 Confirm that the sizing of the FLEX diesel generators (DGs) is Complete. Sizing calculations for adequate to supply the planned loads. the Phase 2 and Phase 3 FLEX DGs support steady state operation of the FLEX loads and starting of the largest single load.
31. Cl 3.2.4.1 O.A Confirm that the analysis of battery load profiles for the safety related Complete - Coping analyses for 125 and 250 Vdc batteries for a BDBEE demonstrate satisfactory load 125 VDC and 250 VDC batteries profiles and battery life. have been completed using the

NRC-endorsed white paper.

Page 15 of 18

LR-N15-0169 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References

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

dated March 12, 2012

3. PSEG Letter LR-N13-0173, "PSEG Nuclear LLC's First Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), "

dated August 22, 2013

4. PSEG Letter LR-N14-0025, "PSEG Nuclear LLC's Second Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated February 25, 2014

5. PSEG Letter LR-N14-0184, "PSEG Nuclear LLC's Third Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated August 26, 2014

6. PSEG Letter LR-N15-0022, "PSEG Nuclear LLC's Fourth Six-Month Status Report for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), "

dated February 18, 2015

7. Nuclear Energy Institute (NEI) Report NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, " Revision 0, dated August 2012
8. NRC Letter to PSEG, "Hope Creek Generating Station- Relaxation of the Schedule Requirements For Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events,"' dated May 20, 2014
9. NRC Letter to PSEG, "Hope Creek Generating Station- Relaxation of the Schedule Requirements For Order EA-12-049 'Issuance of Order to Modify Page 16 of 18

LR-N15-0169 Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events,"' dated April 29, 2015

10. PSEG Letter LR-N14-0248, "Hope Creek Generating Station's Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment, dated December 9, 2014
11. US Nuclear Regulatory Commission (NRC letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," dated March 12, 2012
12. PSEG Letter LR-N14-0093, "PSEG Nuclear LLC's Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events' - Hope Creek Generating Station," dated April 16, 2014
13. PSEG Letter LR-N15-0055, "PSEG Nuclear LLC's Request for Relaxation from Schedule Requirements of NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events'- Hope Creek Generating Station," dated March 11, 2015
14. PSEG Letter LR-N15-0087, "Supplement to the Request for Relaxation from Schedule Requirements of NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" - Hope Creek Generating Station," dated April 13, 2015
15. PSEG letter LR-N13-0026, "PSEG Nuclear LLC' s Response to NRC Follow-up Letter on Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Fukushima Near-Term Task Force Recommendation 9.3," dated February 21, 2013
16. PSEG Letter LR-N12-0351, "PSEG Nuclear LLC's Assessment Report for Communications During an Extended Loss of AC Power," dated October 31, 2012
17. NRC Order EA-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Effective Immediately)," dated June 6, 2013
18. NRC Letter to PSEG, "Hope Creek Generating Station- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NO. MF0867)," dated February 11, 2014 Page 17 of 18

LR-N15-0169

19. NEI letter to NRC, "EA-12-049 Mitigating Strategies Resolution of Extended Battery Duty Cycles Generic Concern, " dated August 27, 2013 (ADAMS Accession No ML13241A186)
20. NRC letter to NEI, "Battery Life White Paper Endorsement, " dated September 16, 2013 (ADAMS Accession No. ML13241A188)
21. NRC letter to NEI, "Mitigation Strategies Order EA-12-049, NEI Position Paper:

MAAP Endorsement Letter, " dated October 3, 2013 (ADAMS Accession No. ML13275A318)

22. NEI Position Paper, "Shutdown I Refueling Modes," dated September 18, 2013 (ADAMS Accession No. ML13273A514)
23. NRC letter to NEI, Endorsement Letter: Mitigation Strategies Order EA-12-049, NEI Position Paper: Shutdown I Refueling Modes, " dated September 30, 2013 (ADAMS Accession No. ML13267A382)
24. NEI letter to NRC, "EA-12-049 Mitigating Strategies Resolution of FLEX Equipment Maintenance and Testing Templates, " dated October 3, 2013 (ADAMS Accession No. ML13276A573)
25. NRC letter to NEI, "Maintenance and Testing Endorsement Letter in Regards to Mitigation Strategies Order EA-12-049," dated October 7, 2013 (ADAMS Accession No. ML13276A224)
26. NRC letter to NEI, "Nuclear Energy Institute, BWR Anticipatory Venting Letter in Regards to Order EA-12-049," dated January 9, 2014 (ADAMS Accession No. ML13358A206)
27. NEI letter to NRC, "Alternative Approach to NEI 12-06 Guidance for Hoses and Cables, " dated May 1, 2015 (ADAMS Accession No. ML15126A135)
28. NRC letter to NEI "Endorsement of NEI Alternate Approach for Spare Hoses and Cables, " dated May 18, 2015 (ADAMS Accession No. ML15125A442)

Page 18 of 18

Appendix A- Hope Creek Generating Station FLEX Sketches

1. Hope Creek FLEX Mechanical Connection Modifications - Master Diagram
2. Hope Creek FLEX Phase 2 Master Diagram (Electrical)
3. Hope Creek FLEX Phase 3 Master Diagram (Electrical)

EL. 201' Existing B.5.b SFP Sprayer GAMA SCAN 20 FLX-V012 Black Equipment is ELECTRONICS ROOM Existing 4609 REACTOR VESSEL Red Equipment is SPENT FUEL POOL DCP 80110321 19 Blue Equipment is FLX-V011 DCP 80112012 EL. 162' Reactor EQUIPMENT Building ROOF ROOM AIRLOCK Propped 5424 ROOM 4323 Fuel Nozzle Open Door Staircase No. 2" FLEX Fuel Oil Line FLWX SW Pump (P500) 43-02 Diesel Driven Pump EL. 130' Rated @ 1300 gpm RUN DISCHARGE

@400 ft of head HOSE THROUGH PROPPED OPEN Deployed near SWIS DOOR ROOM ROOM SEE ATTACHMENT HV-F017A HV-F017B KL-V216 5313 5315 Outside M-2 Instrument Gas Truck Bay 16 Existing Vent FLX-V008 B Day Tank FLX-V010 New Valve Drain FLX-V018 6

Propped KL-V253 SWIS 18 Open Door 120 Gallon Compressor Provided by Others Area 4328 FLEX Fuel Oil Pump EL. 102' 43 gpm, 50 psi EA-V615 Existing 36" Existing SW Header Valve Fuel Nozzle Alternate or to Reactor RHR B Inside Phase III SWIS Building HX ROOM Connection EL. 86'-6" 4208 Primary EA-V623 Phase II Fuel Pool Existing Existing Connection HV-2234 SACS/RACS Valve Makeup Existing EA-V658 Service 2" Cross-Tie Service Water Inside SWIS Water HV- existing Fuel Pool VENT HV-2238 5 F073 Makeup BC-V637 EA-V554 Portable FLEX HV-F075 3 4 Manifold EA-V340 Emergency ROOM ROOM 15 6" Crossover to BC-V636 107 110 existing RHR System Propped Open Door 0-250 PSIG RACS PUMP Strainer Del. River Abandoned AREA ROOM A SW B SW 4209 Piping Loop Loop RHR HX TO HV-FO17B RHR A HX RHR HX FLX-V006 BE-205 & HV-F015B ROOM 4214 AE-205 (Alternate Injection)

EL. 77' 14 AN-PI-101 PRIMARY DEMIN WATER CONDENSATE PUMP AREA ROOM 1110 3" Pipe to DI-Water AN-V416 AN-V415 FLX-V002 PUMP AREA 9 10 ROOM 1104 0-35 PSIG H

TORUS BE-PI-101 E 6" 0-35 PSIG A CORE SPRAY 4" Pipe to BE-V145 BE-V144 7 D ROOM 4104 Core Spray Header from CST/Torus E Electric Driven Pump Powered From R FLEX MCC D Demin. 21 1"

Water Storage 1" FLX-V014 Condensate FLX-V013 TORUS ROOM 4102 Header Tank 1"

AD-V371 AN-V014 FLX-V003 6" SS HOSE AN-V015 AN-V016 TWCU PUMP All New Valves, Fittings, Piping & Hose are ROOM 4101A FLX-V005 AN-V414 4" unless otherwise noted Globe FLEX ALT Header Pump (P200)

Valve FLEX Booster Pump OAP-135 1 6" Pump Inlet Piping 450 GPM @ 400 feet of head Propped Electric Driven Pump (75 HP) 450 GPM Open Door Check Valve Revised Per FCR 80110321-0001-0010 EL. 54' 80110321R0 Version 1/27/15 SUP01R1 Hope Creek FLEX Mechanical Connection Modifications - Master Diagram

NOTES,

1. ril NEW EllJJPM':NT SIM S I FLEX 'PHASE-2'EOOIPMENIL.N_ESS 11CATED OII£RWISE.

cr 125VOCBAITERfCit'lRCERS FLDCAillE SIIllAGEOOX ADO 2. iU RECEPTACLES SHNM CJI HiS 1-lW,[,.L%Wr:.:.smOI£f-l DIA RAM ARE PERIW£NTLf G 8E USED CN..YWlllfJ WIUMT0-1e-S-4Bl700 ltCR!llOOIS53JI 3.1UJt(I!C ATEO LOADS,RA!Ifi>S,A'<<l CA BLE LEIIJTHS ED

\'ERJFJCATICJI.

  • z AWG oo--,r--t I 4.PAI£L BIJ-l-3&4 SIW.LBEUSEO TOSLJ'f'I.Yt£1r'FLEX GEt£RATc.!S
i'fll *2 \IG !NI--H----f<j> Rylr:Jr BOOEE EVENT.

ncr&ulfJ BllCIIJ542A 1211/C5BB KCHlLIEl 5.SES I H!Co1lLY0JftJFE I OOJJC KDISCCtH:CT PAI£LE(lJIPP£0\IITH IOJIO LOCKl ClltKC!OOS I RECEP!ACLES.twl.fACilfiEOBT TPC II!R£&CA8LEICilE(lJIVALEIITI.

Bllr>>542Z I 1211/CsellKCHlLIEI I r---- H 6.Te'tiJLfm:['o/(ltC:::J '8w_"r':

___l_ J 0 I mf I B 411 (£

-==-125\'0C 10 CELL H£cro.I()FAI.I..T Cl.llRENT PATH.!li E-14111-lFOOIO'E CIUK

-BATTERY6 I GIO.IfOlMJTES.SYH30.. S.&lt:Tl A Sl.

I 1 7.f'Cft!MLE C000S SIW._L f¥1VE MALE f'll(.S Hl WI LL f'll(. INTO II£ I I 'Sm!CE'RECEPTACLE [1(1 ANJ FEwtE P\.I.S IJ THAT WILL f'll(. INTO Tl£ t_OAD'RECEPIACLEEtll.

I I I I 8.lt:SIGNATESif:II CIRClJJTBRE!f:ER TIIAT WR.LBEUSEO T0'8Atl(*FEEO' I I TI£ POIIER Fillll£fL£X LOAOS.

I I FIELDSIW._L REPLACE l/8 LI.IJS INSIDE IF 1£11 Cfn.ISE HllllS RECEPTIDSII I I IIIIH I£11218LlJJS.ITPICAL 4f'LACES.

REVISE I; I I l8. k-0 T tro::D 00 FOO I'EI((R C I:H'UIIC A TKll c l-Kl =+/-J K :t T

I

__ - - - - - - - - - - -----::+/-- - ;s---L E

__C -

1 I FLEXLNllSill !B I! 421l I

L___ ___) E'1P£CPI (H) L __________l

-4

--it----== Sill O*S*<

- O_M__"_' (N) lI i BYVE BEYOI(IOESICIIBASIS EXTERNAL EVENT DtVERS£lFLEXI BLEaJ>It(;SJAATEGIES REFERENCE QWGS*

E*llil2H *488VfU llt!.,U.ASS1Et<C.1212.188222,11'6232,ll1'6242 10042BIEI 10042il!El

!  : jE_Ll-'_i' f{c; _ _ --------------,-r- _ _ _ _ l ICLASSJELNIT SUISIAIICJI

-t- CWHEL'8' CLASS IE 12' 5 \'0C SIIITO<<AR I

I I

L_____________

DELETE IFCR 611621-1-131 ADO IFCR 611621-0001-01301 l.t0Xtf!EO SI'r££S

-\- _ _ _ _ _ _

--**ltl- _ _ _ _ _

!c_--rel!

J?.4:.: -* -* . . ---- --- - - - - ..

- -* -- -- -- - ---------J 80110322R0 SUP01R4 FLEX - PHASE 2 REV. 4-REVISE CABLE SPEC Fffi tiJBil423F PER FCR 5ill162ill*0001*231l REV.3-A005Pt'ff:A!ACOMP.&flEXFUELOll TIWISHRI'tt!PPERFCR 61lll620HI00J-8139 &AIXJAEFEEO TO 10X231PER FCA 61lll621JH\l J-815il REV.2-0ELETE CABLESlRECEPT'STORE-FEEOA\'H41lBPER FCR 61JII6201*li00I-el*e AEY.l-REYlSEAECEPI'SlC.AIXJIESq& !0,lCIIBI.E REELB X O PER FCR61lll6201-800Hl010 REV . -0 to'£ CREEK 'FL EX PHA S£2"

NOTES, LALLI£W EWII'I£NT SH.l'iN lS FLfX'f'HAS£-3'EOO IPP£NIOJHSSINDICATEDOH£R'ilSEJ.

2. SEI!Cft.LY O.W.IFIEO21(U LlS IO.NTEO IN AN OCLOSl.FIE F'ROVICEO BY II'C WIRE

& CABLE!00 EOOIVI'UNI.I

5. SAFER lEAH L PROVI[{ H£SE SE 3 OOIERIITIRS BASED M (HI* NEIIEOOIPHENT IK* I£GIIl¥t.RESPOS O £ C£NTER cl b 4lllfEJ REFERENCE DWGS, Q.ASS !E 4.16 KVVI I AlfJl S Sl..flll *SI££11 FLEX'PHASE2'MASTER DIAGFWI I>-  !£1A93!-1311/C 500 fO
  • SKV INI 14HI'CR01-4'Ctlll rFf- AABLCK; RI..CK OOl'IIEI i--- IFCR REVISE l I FLEXRECEPT TOSAFER 61lll6281-8lllll-8818 4.16KVSWl!CH3EAR PIIR RECEPT PIW:L lll*S*4000!Nl

.---::t--c

"'""'-----::r n

1/ ---,,ooo:___

.<OZ*O' I

/-------

,,/

UNIT I AUJ*s7 '"T£;ROL F

BLDG (

\

\

\

I I

I I

I

\

\

<l>

\

-- P!RTABLE aHlS 8* 1/C 4/ IVI* Ili<V I

I V,IE RRC I I

I

\

\

I1 , SEEt<<lTE5

. - -------1 ----------------------------

,--: I "

r I i I T BREAI(ERS i \

! l __________________________________

SWER SW!ToaAR i i I

II

+I -------

1

...._' I I

' I

\ I I

I I rh_

I socm,, _;h_____':':::']_m I

soom<<n

'Q

____':'::= u RA:FLEXTIJ'lSJ flJICFLEXTIJ'lSJNE flJIC FLE TIJRBJ FlEXTl.llBitt:

GERtllt>>>'31Nl GEI\EI!tllt>>>'21Nl GEII£RATM01tHI GEI\ERA!ffi!Nl 4 K - 4 6K a..oomo o.lt'r /}G t:s\t o;G BLOOI I..OCATEO oJt't 4J:6K :Lo;GBLOOl (L((AIEO o.lfs J: t:s'ft. 0/G BlOOl a.ocmo o.lfrr4it::L o;G BLOOJ 80110322R0 SUP02Rl FLEX - PHASE 3 VISE BLDG CM-10 vl :oFi !r16lJ&810 A D REY.8-4.16KV BREAKER CONNECTIONS, HOPE CREEK

'FLEX PHASE 3' MASTER DIAGRAM

Retrieved from "https://kanterella.com/w/index.php?title=LR-N15-0169,_Fifth_Six-Month_Status_Report_for_the_Hope_Creek_Generating_Station_in_Response_to_March_12,_2012_Commission_Order_Modifying_Licenses_with_Regard_to_Requirements_for_Mitigation_Strategies_for_Beyond-Design-Basis_External_Events.&oldid=2510968"