NL-15-1620, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML15238B795
Person / Time
Site:	Salem
Issue date:	08/26/2015
From:	Jamila Perry Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
EA-12-049, NL-15-1620
Download: ML15238B795 (20)

Text

LR-N15-0168 AUG 2'!6.2015 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSEG Order EA-12-049 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

References:

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

1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

2. PSEG Letter LR-N13-0034, "PSEG Nuclear LLC's Overall Integrated Plan for the Salem Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013

3. PSEG Letter LR-N15-0023, "PSEG Nuclear LLC's Fourth Six-Month Status Report for the Salem Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 18, 2015

4. NRC letter, "Salem Nuclear Generating Station, Unit No. 1 - Relaxation of the Schedule Requirements for Order EA-12-049 'Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"' dated September 15, 2014

AUG !G-2015 Page 2 LR-N15-0168 Order EA-12-049 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 Salem Generating Station (SGS) Units 1 and 2, on February 28, 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 SGS since the previous update provided in Reference 3. reflects the schedule relaxation granted by the NRC in Reference 4 to allow SGS Unit 1 sufficient time for implementation of plant changes to reduce reactor coolant pump seal leakage.

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 At{t, Lff; t ;) G t 'F)_c> I r (Date)

Sincerely, ct::;:::

Vice President-Salem : Salem Generating Station Units 1 and 2 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. Patrick Finney, NRC Senior Resident Inspector, Salem Mr. Patrick Mulligan, Chief, NJBNE Mr. Thomas Cachaza, Salem Commitment Tracking Coordinator Mr. Lee Marabella, PSEG Commitment Coordinator-Corporate

LR-N15-0168 Salem Generating Station Units 1 and 2 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-N15-0168 1

Introduction PSEG Nuclear LLC (PSEG) developed an Overall Integrated Plan (OIP) (Reference 1) for the Salem Generating Station (SGS) Units 1 and 2 documenting the diverse and flexible coping strategies (FLEX) in response to NRC Order EA-12-049 (Reference 2).

In 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 Nuclear 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 request that was approved by the NRC as described in Section 5.

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

Submit Integrated Plan - PSEG submitted the SGS FLEX OIP to the NRC via Reference 1.

Develop Strategies - PSEG has developed FLEX strategies as described in the SGS FLEX 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.

Develop Modifications -PSEG has developed the plant modifications needed to support implementation of the SGS FLEX strategies.

Develop FLEX Support Guidelines (FSGs)- PSEG developed the draft FSGs to implement the strategies.

Perform Staffing Analysis - PSEG completed an analysis of the staffing needed to implement the SGS FLEX strategies during a beyond-design-basis external event, and transmitted the staffing assessment report to the NRC via Reference 8.

Develop Training Plan - PSEG developed training materials and schedules, and has begun training personnel on the SGS 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).

Emergency Preparedness (EP) Communications Improvements - PSEG has established communications capability to support the SGS FLEX strategies in response to the NRC's 10 CFR 50.54(f) information request (Reference 9).

Page 1 of 17

LR-N15-0168 3

Milestone Schedule Status The following table provides an update of SGS FLEX OIP milestones. The table provides the milestone activity status and indicates whether the original expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. The revised milestone target completion dates reflect the compliance schedule relaxation for SGS Unit 1 described in Section 5.

Original Activity Status Milestone Target Revised Target Completion Completion Date Date Submit Overall Feb 2013 Complete Integrated Plan Aug 2013 Complete Feb 2014 Complete Six-Month Status Aug 2014 Complete Update Feb 2015 Complete Complete With Aug 2015 This Report Feb 2016 Not Started Develop Strategies May 2013 Complete Modifications Develop Modifications Dec 2013 Complete Ju1 2015

- Unit 1 Implement Oct 2014 Started May 2016 Modifications-Unit 1 Develop Modifications Dec 2013 Complete Jun 2015

- Unit 2 Implement Oct 2015 Started Nov 2015 Modifications-Unit 2 Flex Support Guidelines (FSGs)

Develop FSGs -

Dec 2013 Complete Mar 2015 Unit 1 Approve FSGs -

N/A (milestone Started May 2016 Unit 1 added)

Validation Walk-throughs or Demonstrations of Nov 2014 Started Nov 2015 FLEX Strategies and Procedures - Unit 1 Page 2 of 17

LR-N15-0168 Milestone Develop FSGs-Unit 2 Approve FSGs -

Unit 2 Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures - Unit 2 Perform Staffing Analysis Develop Training Plan Implement Training Unit 1 Training Unit 2 Training Develop Strategies/Contract with National SAFER Response Centers (formerly known as Regional Response Centers)

Procure Equipment Unit 1 Procurement Unit 2 Procurement Create Maintenance Procedures Emergency Preparedness (EP)

Communications Improvements Unit 1 Implementation Outage Original Activity Status Target Revised Target Completion Completion Date Date Dec 2013 Complete Mar 2015 N/A (milestone Started Nov 2015 added)

Nov 2015 Started Nov 2015 Dec 2013 Complete Jun 2014 Jun 2014 Complete Dec 2014 Started May 2016 Dec 2014 Started Nov 2015 Oct 2013 Complete Oct 2014 Dec 2013 Complete Jun 2015 Dec 2013 Started Sep 2015 May 2014 Started Nov 2015 Jun 2014 Complete Nov 2014 Oct 2014 Not Started May 2016 Page 3 of 17

LR-N15-0168 Milestone Unit 1 Report to NRC When Full Compliance is Achieved Unit 2 Implementation Outage Unit 2 Report to NRC When Full Compliance is Achieved Original Target Completion Date Feb 2015 Oct 2015 Feb 2016 4

Changes to Compliance Method Activity Status Revised Target Completion Date Not Started Jul 2016 Not Started Nov 2015 Not Started Jan 2016 PSEG identified changes to the method of compliance with NEI 12-06 in the August 2014 status report (Reference 5). Additional details of changes to the original FLEX strategies have been communicated as part of the mitigation strategies audit process. The changes described in the August 2014 status report are repeated below with revision bars to indicate changes to outdoor FLEX equipment storage and an additional alternative to NEI 12-06 regarding N+1 FLEX hoses and cables.

The SGS Phase 1 strategy is based on an alternative to initial conditions 1 and 3 of NEI 12-06 Section 3.2.1.3. Initial condition 1 states that no specific initiating event is used, and initial condition 3 states "Cooling and makeup water inventories contained in systems or structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles are available." The SGS FLEX strategy includes event-dependent consideration of cooling water availability, e.g., the Seismic Class I auxiliary feedwater storage tank (AFST) is assumed to remain available following a seismic event, but may become unavailable due to tornado missile damage.

Based on the capability to align diverse water supplies depending on the specific hazard, the SGS FLEX strategy is consistent with the overarching goal of reasonable protection of equipment such that no single event results in failure of the strategy.

SGS is using an alternative to the criteria of N El 12-06 Section 7.3.1, "Protection of FLEX Equipment," which recommends protection of FLEX equipment from high wind hazards via storage in a structure or in diverse locations. Two FLEX DGs, electrical connections and distribution equipment will be stored in the canyon area (i.e., the area between the Salem Unit 2 fuel handling building and auxiliary building). This equipment and their associated connections will be stored outdoors and provided with protection Page 4 of 17

LR-N 15-0168 from external hazards to minimize the probability that a single event would damage all of the FLEX equipment needed to mitigate the event.

SGS 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. 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.

Outdoor storage locations consist of the following:

canyon area west of SGS -inside the protected area east of the SGS oil water separator area -outside the protected area and within the vehicle barrier system northwest corner of the Hope Creek Unit 2 reactor building, north of SGS-inside the protected area An additional set of debris removal and towing equipment will be stored at a separate on-site location.

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 24) as endorsed by the NRC in Reference 25.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation The original schedule requirement for SGS Unit 1 implementation of NRC Order EA-12-049 was prior to startup from the 23rd refueling outage (S1 R23) in fall 2014. PSEG requested schedule relaxation via Reference 10 to defer full compliance with NRC Order EA-12-049 by one refueling outage, i.e., prior to startup from S1 R24 in spring 2016. The NRC granted the schedule relaxation via Reference 11 to enable PSEG to address recalculated reactor coolant pump seal leakage rates that exceed the Westinghouse generic values assumed in the original SGS FLEX OIP.

PSEG will implement plant changes to reduce RCP seal leakage rates to values that are compatible with the assumptions of the SGS mitigation strategies. Implementation of these changes is scheduled for the fall 2015 outage for SGS Unit 2 and the spring 2016 outage for SGS Unit 1. PSEG is proceeding with completion of other design, equipment procurement and programmatic changes to support the ability to implement the SGS mitigation strategies.

Page 5 of 17

LR-N 15-0168 6

Open Items from Overall Integrated Plan and Draft Safety Evaluation Resolution of items identified in the NRC's interim staff evaluation (ISE) for SGS (Reference 12) and NRC audit report (Reference 13) is being addressed as part of the mitigation strategies audit process. A summary and status of the ISE items and Safety Evaluation (SE) items from the NRC audit report are provided below.

ID Item Ref.

Description Status

1.

Generic Concern - Battery SGS is currently working on extending the battery duty cycle, Complete. Coping analyses Life and is following the industry position on battery life as outlined for 28 VDC and 125 VDC in the Nuclear Energy Institute (NEI) white paper dated batteries have been August 27, 2013 (Reference 14) and endorsed by NRC via satisfactorily completed using letter to NEI dated September 16, 2013 (Reference 15).

the NRC-endorsed white paper.

2.

Generic Concern - MAAP SGS is using the Modular Accident Analysis Program (MAAP)

Complete. MAAP analyses to complete the development of FLEX timelines and are used for containment strategies, consistent with the NRC endorsement letter to NEI response for SGS, consistent dated October 3, 2013 (Reference 16).

with the NRC endorsement letter to NEI, and show acceptable results.

3.

Generic Concern -

SGS will enhance shutdown risk processes and procedures In progress-to be completed Shutdown I Refueling using the supplemental guidance provided in the NEI position prior to Order EA-12-049 Modes paper entitled "Shutdown I Refueling Modes," dated compliance.

September 18, 2013 (Reference 17) and endorsed by the NRC via letter to NEI dated September 30, 2013 (Reference 18). NRC audit item SE #9 is for PSEG to provide the revised shutdown risk processes and procedures.

Page 6 of 17

LR-N 15-0168 ID Item Ref.

4.

Generic Concern -

Preventive Maintenance (PM)

SE #11

5.

Generic Concern - Core Sub-criticality 01 3.2.1.8.A

6.

01 3.2.4.7.A Description As part of the development of FLEX maintenance and testing programs, SGS will use the EPRI Technical Report entitled "Nuclear Maintenance Applications Center: Preventative Maintenance Basis for FLEX Equipment," transmitted to NRC via NEI Ietter dated October 3, 2013 (Reference 19) and endorsed by NRC letter dated October 7, 2013 (Reference 20). NRC audit report item SE #11 is for PSEG to provide the FLEX maintenance and testing program.

Core Sub-Criticality -The Pressurized Water Reactor Owners Group (PWROG) submitted to NRC a position paper, dated August 15, 2013, via Reference 21, which provides test data regarding boric acid mixing under single-phase natural circulation conditions and outlined applicability conditions intended to ensure that boric acid addition and mixing would occur under conditions similar to those for which boric acid mixing data is available. The licensee should address the clarifications in the NRC endorsement letter dated January 8, 2014 (Reference 22). The NRC audit report requests completion of the Emergency Operating Procedure setpoint calculations and a determination of how much RCP seal leakage must be considered in the ELAP analyses.

Water Sources -The licensee appears to use a probability approach to reach a conclusion that at least one of the three tanks depended on for SG makeup will survive an ELAP event. NEt 12-06 guidance does not give probability as an option. The licensee should determine if a water supply would be available after a tornado event by analyzing the tornado characteristics for the site compared to the separation characteristics of the tanks. This is an alternate approach from the strategies identified in NEI 12-06. The NRC audit report includes request to show that actions to switch to an alternate water supply can be completed prior to RCS heatup due to steam generator dryout.

Page 7 of 17 Status In progress - PSEG has created PM tasks for FLEX equipment using the SGS PM process and NRC-endorsed EPRI guidance.

In progress as part of resolution of RCP seal leakage, to be completed prior to compliance with Order EA-12-049.

In progress with completion pending time validation of transfer to alternate water supply, prior to compliance with Order EA-12-049.

LR-N 15-0168 ID Item Ref.

7.

CI 3.1.1.1.A

8.

CI 3.1.1. 2.A

9.

CI 3.1.1.2.B

10.

CI3.1.1.3.B

11.

Cl 3.1.1.4.A

12.

Cl 3.1.2.2.A

13.

Cl 3.1.4.2.A

14.

Cl 3.1.4.2.8 Description Protection of FLEX Equipment including FLEX diesel generators (DGs) -The licensee needs to finalize its evaluation of the use of the SGS auxiliary building and the use of the Hope Creek Generating Station, Unit 2 reactor building for permanent FLEX equipment storage.

Deployment of FLEX Equipment -The licensee should complete a review of deployment routes between the proposed equipment storage locations and the areas the equipment will be moved to and evaluate the potential for soil liquefaction.

Deployment of FLEX Equipment -The licensee does not state that the Nuclear Service Water Connections will be protected from seismic events. Confirm that this is ensured.

Procedural Interfaces - Seismic Hazard -The licensee's integrated plan did not provide any information on: 1) non-robust internal flooding sources that do not require ac power;

2) the use of ac power to mitigate ground water in critical locations.

Considerations in Using Offsite Resources - Seismic Hazard -

Flooding Hazard - High Winds Hazard - Snow, Ice and Extreme Cold Hazard - Equipment staging areas for deployment of offsite equipment from SAFER will be finalized in a future 6 month update.

Deployment of FLEX Equipment - Flooding Hazard -

Finalization of proposed changes to the deployment of FLEX equipment during a hurricane induced flooding condition will be provided in a future 6 month update.

Deployment of FLEX Equipment-Flooding Hazard -The licensee should address the formation of frazil ice and means to cope with it.

The licensee should address manual operations required by plant personnel during periods of snow, ice, and extreme cold hazards.

Page 8 of 17

• Status Complete. Response provided as part of the audit process.

Complete-response provided in the February 2014 six-month update (Reference 4 ).

Complete. Response provided as part of audit process.

Complete. Response provided as part of audit process.

i Complete. Response provided 1 as part of audit process.

Complete. Response provided as part of audit process.

Complete. Response provided as part of audit process.

Complete. Response provided as part of audit process.

LR-N15-0168 ID Item Ref.

15.

Cl 3.1.5.2.A

16.

Cl 3.1.5.3.A

17.

CI 3.2.1.A

18.

CI 3.2.1.1.A SE #5

19.

Cl 3.2.1.1.8 SE #9

20.

Cl 3.2.1.2.A SE #2 Description The licensee should confirm that there is no need for backup ventilation with respect to protection of FLEX equipment during high temperature hazards and what the impacts of high temperature hazards would be on the deployment of the FLEX equipment in such conditions.

The licensee should specify the peak temperature for which FLEX equipment would be expected to operate.

The licensee should specify which analysis performed in WCAP-17601-P (Reference 23) is applicable to SGS and justify the use of that analysis by identifying and evaluating the important parameters and assumptions demonstrating that they are representative of SGS and appropriate for simulating the ELAP transient.

Computer Code Used for ELAP Analysis - Reliance on the NOTRUMP code for the ELAP analysis of Westinghouse plants is limited to the flow conditions prior to reflux condensation initiation. Verify that the code is not used beyond these flow conditions. This includes specifying an acceptable definition for the onset of reflux condensation cooling. NRC audit item SE #5 pertains to resolution of differences between NOTRUMP and NRC simulations of an ELAP using the TRACE code.

The licensee utilized the existing analyses in WCAP-17601-P to develop its sequence of events and time constraints. The licensee will validate the response times at a future time.

NRC audit item SE #9 is for PSEG to provide validation and verification procedures which also address human factors concerns.

Reactor Coolant Pump Seal Leakage Rates - Confirm that the RCP seal initial maximum leakage rate used in the analysis is greater than or equal to the upper bound expectation for the ELAP event (21 gpm/seal) discussed in the PWROG white paper addressing the RCP seal leakage for Westinghouse plants. NRC audit item SE #2 pertains to higher than expected leakage rates identified by Westinghouse.

Page 9 of 17 Status Complete. Response provided as part of audit process.

Complete. Response provided as part of audit process.

In progress as part of resolution of RCP seal leakage, to be completed prior to compliance with Order EA-12-049.

In progress as part of resolution of RCP seal leakage, to be completed prior to compliance with Order EA-12-049.

In progress - to be completed prior to Order EA-12-049 compliance.

In progress as part of resolution of RCP seal leakage, to be completed prior to compliance with Order EA-12-049.

LR-N 15-0168 ID Item Ref.

21.

Cl 3.2.1.2.8

22.

Cl 3.2.1.5.A

23.

Cl 3.2.1.6.A Descr>ption Reactor Coolant Pump Seal Leakage Rates - In some plant designs, such as those with 1200 to 1300 psia SG design pressures and no accumulator backing of the main steam system power-operated relief valve actuators, the cold legs could experience temperatures as high as 580°F before cooldown commences. This is beyond the 550°F qualification temperature of the 0-rings used in the RCP seals. For those Westinghouse designs, a discussion of the information (including the applicable analysis and relevant seal leakage testing data) should be provided to justify that (1) the integrity of the associated 0-rings will be maintained at the temperature conditions experienced during the ELAP event, and (2) the seal leakage rate of 21 gpm/seal used in the ELAP is adequate and acceptable.

Monitoring Instrumentation and Controls -The review identified a concern with the level of accuracy of the FLEX instrumentation to ensure that electrical equipment remains protected (from an electrical standpoint-e.g., power fluctuations) and with the ability of this instrumentation to provide operators with accurate information ensure the maintenance of core cooling, containment, and spent fuel cooling. The licensee should confirm the accuracy of portable equipment instrumentation as it relates to equipment protection and operator information for maintenance of FLEX strategies.

Sequence of Events - During the NRC audit process the licensee summarizes the changes in its mitigation strategies for Phase 1 and Phase 2. The evaluation for implementing these changes will be communicated in a future 6 month update. The NRC audit report subsequently requested this be addressed by docketed submittal of a revision to the integrated plan.

Page 10 of 17 Status Complete. Response provided as part of the audit process, based on design changes in progress to provide accumulators for the main steam power-operated relief valves.

Complete. Response provided as part of the audit process.

In progress. Docketing of the Final Integrated Plan is planned after full compliance with Order EA-12-049.

LR-N 15-0168 ID Item Ref.

24.

Cl 3.2.1.9.A

25.

CI 3.2.2.A

26.

CI 3.2.3.A

27.

Cl 3.2. 3.8 Description Status Use of Portable Pumps -The Integrated Plan provides a table Complete. Response provided depicting the FLEX equipment to be deployed and states that as part of the audit process.

the quantity does not reflect the NEI 12-06 spare capability (N+1) guidance. The licensee should specify how many pieces of equipment will be available for an ELAP/Loss of Ultimate Heat Sink (UHS), and this should meet N+1 requirements unless an alternative approach is proposed.

Spent Fuel Pool Cooling Strategies - In the audit and review, Complete. Response provided the licensee provided additional information regarding the as part of the audit process.

SFP makeup during an ELAP event. It stated that a new 4" FLEX hose is being evaluated as replacement for SFP makeup. This connection would be upstream of 1 (2)SF9 and would allow water from SW, AFW, and the FLEX boron mixing tank pump discharges to be aligned for SFP makeup. The proposed connection point is in the Auxiliary Building in the SFP pump area. Additionally, a spray pipe system is being re-evaluated. The licensee should provide details of the final configuration, including flow rates, and this information should be included in a six-month update.

The licensee committed to perform further containment Complete. Response provided analysis to demonstrate that containment integrity can be as part of the audit process.

maintained up until a point in time when containment cooling can be restored during Phase 3.

Containment Functions Strategies - In the audit and review, Complete. Response provided the licensee stated that SGS plans to use the Modular as part of the audit process.

Accident Analysis Program analysis to complete the FLEX strategies and timelines. Review these analyses when available.

Page 11 of 17

LR-N 15-0168 ID Item Ref.

28.

Cl 3.2.4.2.A

29.

Cl 3.2.4.2.8

30.

Cl 3.2.4.2.C

31.

Cl 3.2.4.4.A

32.

Cl 3.2.4.6.A

33.

Cl 3.2.4.6.8 Description Status Ventilation - Equipment Cooling -The licensee has provided Complete. Response provided insufficient details of the ventilation provided in the battery as part of the audit process.

room to support a conclusion that there is reasonable assurance that the effects of elevated or lowered temperatures in the battery room, especially if the ELAP is due to a high or low temperature hazard, have been considered. Confirm the adequacy of the ventilation provided in the battery room to protect the batteries from the effects of elevated or lowered temperatures.

Ventilation - Equipment Cooling -The licensee provided a Complete. Response provided discussion on how hydrogen concentration in the battery as part of the audit process.

rooms will be mitigated when the batteries are being recharged during Phases 2 and 3. The licensee will provide strategies to repower installed battery room exhaust fans or portable fans for ventilation.

Ventilation - Equipment Cooling -The licensee stated that Complete. Response provided GOTHIC modeling and room heat-up calculations are being as part of the audit process.

developed for plant strategic areas including the TDAFW rooms. The results of the modeling and analyses will be communicated in a future 6 month update.

Communications - Confirm that upgrades to the site's Complete. Response provided communications systems have been completed.

as part of the audit process.

Personnel Habitability - Elevated Temperature-Confirm the Complete. Response provided maximum environmental room temperatures at ELAP coping as part of the audit process, in periods greater than the 4-hours assumed in NUMARC 87-00, response to Cl 3.2.4.2 items.

and confirm that measures are in place to ensure personnel habitability, as needed.

Personnel Habitability -The licensee stated that formal Complete. Response provided analyses would be performed to support the initial actions as part of the audit process, in taken to provide cooling for the MCR until Phase 2 actions response to Cl 3.2.4.2 items.

can be implemented. The results of the modeling and analyses will be communicated in a future 6 month update.

Page 12 of 17

LR-N15-0168 ID Item Ref.

34.

Cl 3.2.4.8.A

35.

Cl 3.2.4.8.8

36.

Cl 3.2.4.8.C

37.

Cl 3.2.4.9.A

38.

Cl 3.2.4.1 O.A

39.

CI 3.3.2.A

40.

CI3.4.A Description Electrical Power Sources/Isolations and Interactions -

licensee stated that diesel generator sizing calculations are in progress. The results will be communicated in a future six-month update.

Electrical Power Sources/Isolations and Interactions -The licensee discussed use of electrical equipment such as 480 VAC DG Power Distribution, 480 VAC "A" Vital Bus, 230 VAC DG Power Distribution, associated cablings and connectors.

Confirm that electrical isolation will be maintained such that (a) Class 1 E equipment is protected from faults in portable/FLEX electrical equipment and (b) multiple sources do not attempt to power electrical buses.

Electrical Power Sources/Isolations and Interactions - Confirm the analyses address the minimum voltage that must be maintained on the de buses and its basis.

Portable Equipment Fuel - Confirm that sufficient fuel is available considering the fuel consumption rate for each FLEX piece of equipment.

Load Reduction to Conserve DC Power -The licensee should describe the results of the final battery load shed analyses, including which functions are lost, plant components that will change state, and the effects of components changing state.

Configuration Control -The licensee should provide the single line diagrams of the proposed electrical systems.

As part of this item the NRC audit report requested PSEG to address potential personnel hazards regarding the orientation of disconnecting blades in the FLEX power receptacles.

Offsite Resources -The licensee's Integrated Plan addressed the use of off-site resources to obtain equipment and commodities to sustain and backup the site's coping strategies (NEI 12-06, Section 12.2, Guideline 1 ). The licensee should provide information on how the plan addresses implementation guidelines 2 through 10.

Page 13 of 17 Status In progress pending revision to the diesel generator sizing calculations.

In progress pending revision to the diesel generator sizing calculations.

Complete. Response provided as part of the audit process.

Complete. Response provided as part of the audit process.

In progress. Evaluation is completed for Unit 1 and will be documented for Unit 2 prior to Order EA-12-049 compliance.

Complete. Response provided as part of the audit process.

i Complete. Response provided '

as part of the audit process.

LR-N 15-0168 ID

41.

SE #1

42.

SE #6

43.

SE #?

44.

SE #8 Item Ref.

Description Status RCS Venting: NRC staff needs to complete its review of Complete (i.e., no PSEG FSG-8.

action at this time).

Permanent staging of the FLEX generators in the SGS Unit 2 Complete. Section 4 canyon (an alternate to NEI 12-06):

discusses the alternative to Provide an evaluation of the susceptibility to damage for the NEI 12-06. Additional details FLEX generators. Demonstrate that the construction of the have been provided as part of canyon wall is viable.

the audit p_!ocess.

Feeding steam generators from the turbine building Complete. Response provided basement:

as part of the audit process.

Provide the evaluation and timeline of the ability to pump water from the turbine building basement to the steam generators.

Equipment habitability for steam generator power-operated Complete. Response provided relief valve operation:

as part of the audit process j=J_9Vide the evaluation of the functionality of the SG PORVs.

under Cl 3.2.4.2.

Page 14 of 17

LR-N15-0168 7

Potential Draft Safety Evaluation Impacts Impacts to the NRC Safety Evaluation (SE) of SGS compliance with Order EA-12-049 are being addressed as part of the mitigation strategies audit process. Section 6 above includes a description and status of SE items identified as open in the NRC audit report (Reference 13).

8 References

1. PSEG letter LR-N13-0034, "PSEG Nuclear LLC's Overall Integrated Plan for the Salem Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

dated March 12, 2012

3. PSEG Letter LR-N13-0175, "PSEG Nuclear LLC's First Six-Month Status Report for the Salem Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 25, 2013

4. PSEG Letter LR-N14-0027, "PSEG Nuclear LLC's Second Six-Month Status Report for the Salem Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated February 25, 2014

5. PSEG Letter LR-N14-0187, "PSEG Nuclear LLC's Third Six-Month Status Report for the Salem Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2014

6. PSEG Letter LR-N15-0023, "PSEG Nuclear LLC's Fourth Six-Month Status Report for the Salem Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated 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. PSEG letter LR-N14-0141, "Salem 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, Page 15 of 17

LR-N15-0168 Recommendation 9.3, Emergency Preparedness-Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment," dated June 16, 2014

9. 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

10. PSEG letter LR-N14-0173, "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' - Salem Generating Station Unit 1," dated July 31, 2014

11. NRC letter, "Salem Nuclear Generating Station, Unit No. 1 - Relaxation of the Schedule Requirements for Order EA-12-049 'Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"' dated September 15, 2014

12. NRC letter, "Salem Nuclear Generating Station, Unit Nos. 1 and 2-Interim Staff Evaluation and Audit Report Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0868 and MF0869), dated January 24, 2014

13. NRC Letter to PSEG, "Salem Nuclear Generating Station, Unit Nos. 1 and 2-Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0868, MF0869, MF0913, and MF0914)," dated October 10, 2014

14. NEI letter to NRC, "EA-12-049 Mitigating Strategies Resolution of Extended Battery Duty Cycles Generic Concern," dated August 27, 2013 (ADAMS Accession No M L 13241 A 186)

15. NRC letter to NEI, "Battery Life White Paper Endorsement," dated September 16, 2013 (ADAMS Accession No. ML13241A188)

16. NRC letter to NEI, "Mitigation Strategies Order EA-12-049, NEI Position Paper:

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

17. NEI Position Paper, "Shutdown I Refueling Modes," dated September 18, 2013 (ADAMS Accession No. ML13273A514)

18. 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)

19. 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)

Page 16 of 17

LR-N15-0168

20. 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)

21. Westinghouse proprietary position paper, "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG)," transmitted to NRC via letter dated August 16, 2013 (ADAMS Accession No. ML13235A135)

22. NRC letter to PWROG, "Boron Mixing Endorsement Letter in Regards to Mitigation Strategies Order EA-12-049," dated January 8, 2014 (ADAMS Accession No. ML13276A183)

23. Westinghouse Report WCAP-17601-P Revision 0, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs," dated August 2012

24. NEI letter to NRC, "Alternative Approach to NEI 12-06 Guidance for Hoses and Cables," dated May 1, 2015 (ADAMS Accession No. ML15126A135)

25. NRC letter to NEI "Endorsement of NEI Alternate Approach for Spare Hoses and Cables," dated May 18, 2015 (ADAMS Accession No. ML15125A442)

Page 17 of 17