Text

Sixth 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)
	ML16063A241
Person / Time
Site:	Hope Creek
Issue date:	02/29/2016
From:	Davison P; Public Service Enterprise Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, LR-N16-0042
	Download: ML16063A241 (27)
	v • d • e

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSEG Nuclear !LC FEB 2 92016 Order EA-12-049 LR-N16-0042 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 Sixth 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-N15-0169, "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)," dated August 27, 2015

FEB 29 2016 Order EA-12-049 Page 2 LR-N16-0042

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

6. PSEG Letter LR-N15-0190, "Intermediate Implementation Milestone Change for 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 December 14, 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 sixth 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, and PSEG's planned installation of the alternate FLEX mechanical connection during the fall 2016 refueling outage, as described in Reference 6.

FEB 2 9 2016 Order EA-12-049 Page 3 LR-N16-0042 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 -----"--'-1-i-q_\+-1_

0

. _\ b__

( 6ate)

Sincerely,

.\)

Paul J. Davison Site Vice President Hope Creek Generating Station Attachment 1: Hope Creek Generating Station Sixth 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. Daniel Dorman, Administrator, Region I, NRC Ms. Carleen Parker, Project Manager, NRC/NRR/DORL Mr. Justin Hawkins, NRC Senior Resident Inspector, Hope Creek Mr. John Boska, Senior Project Manager, NRC/NRR/JLD Mr. Patrick Mulligan, Chief, NJBNE Mr. Thomas MacEwen, Hope Creek Commitment Tracking Coordinator Mr. Lee Marabella, PSEG Commitment Coordinator - Corporate

LR-N16-0042 Attachment 1 Hope Creek Generating Station Sixth 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-Bas is External Events

LR-N16-0042 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 7, PSEG provided six-month status reports associated with implementation of the requirements of NRC Order EA-12-049. This report is the sixth six-month status report, which provides implementation status and progress since the previous report (Reference 7). This update follows the guidance in Section 13.2 of Nuclear Energy Institute (NEI) Report 12-06, Revision 0 (Reference 8), 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 9 and 1 O; PSEG has completed activities to support implementation of the FLEX strategies at HCGS as of December 18, 2015, and will achieve full compliance with NRC Order EA-12-049 prior to startup from the fall 2016 refueling outage (H1R20). The actions necessary to achieve full compliance prior to startup from the H1R20 outage include completion of design changes and evaluations for the hardened torus vent in accordance with NRC Order EA-13-109 (Reference 11), and installation of the alternate FLEX mechanical connection to the Residual Heat Removal system as described in Reference 12.

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.

Develop FLEX Support Guidelines (FSGs)

Approve FSGs - PSEG issued FSGs to implement the HCGS FLEX strategies.

Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures

Perform Staffing Analysis - PSEG completed the HCGS Phase 2 staffing analysis (Reference 15) as required by the 10 CFR 50.54(f) information request dated March 12, 2012 (Reference 16). 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.

Page 1 of 19

LR-N16-0042

Develop Training Plan

Implement Training - Initial training has been completed.

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).

Create Maintenance Procedures - periodic inventory and maintenance of FLEX equipment are addressed by procedures and preventive maintenance tasks.

Emergency Preparedness (EP) Communications Improvements 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 2015 refueling outage. The current milestones reflect the schedule relaxations in References 9 and 10.

Original Revised Target Target Milestone Activity Status Completion Completion Date Date Submit Overall Integrated Plan Feb 2013 Complete Aug 2013 Complete Feb 2014 Complete Aug 2014 Complete Feb 2015 Complete Six-Month Status Update Aug 2015 Complete Complete With Feb 2016 This Report Aug 2016 Not Started Develop Strategies May 2013 Complete Modifications Develop Modifications Apr 2014 Started Apr 2016 Implement Modifications Apr 2015 Started Nov 2016 Page 2 of 19

LR-N16-0042 FLEX Support Guidelines (FSGs)

Develop FSGs Dec 2013 Complete Apr 2015 Approve FSGs Oct 2015 Complete Dec 2015 Validation Walk-throughs or Demonstrations of FLEX May 2015 Complete Dec 2015 Strategies and Procedures Perform Staffing Analysis Dec 2013 Complete Dec 2014 Develop Training Plan Jun 2014 Complete Jan 2015 Implement Training Dec 2014 Complete Dec 2015 Develop Strategies I Contract with National SAFER Response Oct 2013 Complete Feb 2015 Center (formerly called "Regional Response Center")

Procure Equipment Dec 2013 Started Nov 2016 Create Maintenance Procedures Jun 2014 Complete Dec 2015 Emergency Preparednes s (EP)

Jun 2014 Complete May 2015 Communications Improvements HC Implementation Outage Apr 2015 Not Started Nov 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 Revision 0 (Reference 8) in the August 2015 status report (Reference 7). The NRC staff subsequently issued a Revision 1 to Interim Staff Guidance (ISG) JLD-ISG-2012-01 (Reference 13) which endorses the use of NEI 12-06 Revision 2 (Reference 14) as an acceptable means of meeting the requirements of NRC Order EA-12-049, with exceptions, additions, and clarifications. Differences between NEI 12-06 Revision 0 and Revision 2 that are relevant to the discussion of changes to compliance method at HCGS are mentioned below. Revision bars indicate changes to the information provided in Section 4 of the August 2015 status report.

Page 3 of 19

LR-N16-0042 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 is stored at a separate on-site location.

FLEX equipment stored outdoors is designed for extreme high and low temperatures for the site and is 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 cited as a minimum separation distance in FLEX FAQ 2013-01 (NRG ADAMS Accession Number ML13070A475), and supported by a site-specific evaluation of tornado characteristics.

Separation is generally in a north-south direction and provides reasonable protection from a tornado event.

Pre-Staged Equipment 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 Revision 0 (Reference 8). Revision 2 to NEI 12-06 (Reference 14) supports the use of pre-staged FLEX equipment; e.g., the definition of "FLEX Equipment" in Appendix A includes the following:

"The on-site equipment may be installed, pre-staged, or portable equipment based on the site-specific sequence of events ..."

At HCGS, 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.

Page 4 of 19

LR-N16-0042 Attachment 1 Pre-Staged FLEX Diesel Generators Two FLEX Diesel Generators (DGs) are 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 and enclosures 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 DGs on the HCGS Unit 2 Reactor Building roof, an additional diesel generator will be deployed from a location greater than 1200 feet from the affected DGs. Outdoor FLEX Storage Area 2 (OFSA2) includes a FLEX DG located greater than 1200 ft. from the HCGS Unit 2 Reactor Building.

OFSA2 is south of HCGS Unit 2, with the Unit 1 building structures located in between Unit 2 and OFSA2. The orientation and separation distances of these storage areas are favorable for tornado missile protection, considering that the majority of tornados in the region have a component of motion from the southwest, and the storage locations are separated by greater than the 1200 ft. minimum separation distance.

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 HC FLEX DG storage and deployment strategy considers the external hazards applicable to the site and provides reasonable assurance that no single event will defeat the FLEX strategy.

Pre-Staged Electric Motor-Driven FLEX Pumps Section 3 and Table 3-1 of NEI 12-06 Revision 0 describe the use of portable pumps for core cooling and SFP cooling capabilities. As an alternative to using portable, electric motor-driven pumps, the HCGS FLEX strategy includes pre-staging the N and N+1 electric motor-driven FLEX pumps in Core Spray Room 4104 in the Unit 1 Reactor Building. The pre-staged pumps are protected from all external hazards within the Seismic Category I Reactor Building. Analyses of the 72-hour transient temperatures during an Extended Loss of AC Power (ELAP) demonstrate acceptable temperatures for equipment reliability and personnel access to establish the flow paths in accordance with the FLEX timelines. Based on the pumps' design characteristics and low likelihood of catastrophic failure, consequential failure of the N+1 pump due to failure of the N pump is not considered credible. Therefore, the pre-staged electric motor-driven Page 5 of 19

LR-N16-0042 pumps provide reasonable assurance of maintaining core cooling and SFP cooling during an ELAP.

Installed Motor Control Center HCGS uses a single 480 V Motor Control Center (MCC) that has been installed specifically to support the FLEX strategy. The MCC is installed in HCGS Unit 2 Auxiliary Building Corridor 5424 and is protected from all external hazards. The MCC is not safety-related but is seismically qualified and subject to augmented quality requirements to assure that it remains functional following a seismic event. The use of a single MCC is an alternative to NEI 12-06 provisions regarding the use of primary and alternate connections as diverse means of re-powering FLEX equipment, e.g., in NEI 12-06, Section 3.2.2. The use of the permanently installed MCC to distribute power from the FLEX DGs is consistent with NEI 12-06 Section 3.2.1.3, Item (8), which states the following:

"Installed electrical distribution system, including inverters and battery chargers, remain available provided they are protected consistent with current station design."

Event Timelines The Phase 2 staffing assessment (Reference 15) includes a sequence of events consistent with event timelines supported by plant-specific MAAP4 analyses. The final timelines are incorporated into a HCGS FLEX program document and will be submitted with a final integrated plan after full compliance with NRC Order EA-12-049 is achieved.

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

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.

Page 6 of 19

LR-N16-0042 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 7 of 19

LR-N16-0042 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 VAC Diesel Driven Generators Core, Containment, (H1 FLX-1O-G-2025, H1FLX-1 O-G-2026) SFP, Instrumentation 2 (1) Diesel Driven Pump Core, Containment, (H1FLX-1O-P-500) SFP 2 (2) Motor Driven Pumps Core, Containment, (H1FLX-1 O-P-001, H1FLX-1 O-P-002) SFP 2 (2) Compressors Core, Containment (H1FLX-1 O-K-001, H1FLX-1 O-K-002) 2 (2) FLEX Fuel Oil Pumps Core, Containment, (H1 FLX-1 O-P-003, H1FLX-1 O-P-004) SFP 2 (1) Caterpillar 930K Wheel Loader Accessibility (C1FLX-1FLXE41) 2 (1 ) Komatsu 250 Wheel Loader Accessibility (C1FLX-1FLXE43) 2 (2) Kalmar Ottawa 4 x 2 Terminal Tractors Deployment (C1 FLX-1FLXE44, C1FLX-1FLXE45) 2 (2) Forklifts Accessibility (C1FLX-1FLXE65, C1FLX-1FLXE66) 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 8 of 19

LR-N16-0042 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 Section 7.3.1.1.c of NEI 12-06, Revision 0 and Revision 2.

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 uses NEl's recommended alternative to NEI 12-06 Revision 0 regarding N+1 hoses and cables (Reference 31) as endorsed by the NRC in Reference 32. This approach is incorporated into NEI 12-06 Revision 2, and has been endorsed by the NRC staff via Revision 1 to Interim Staff Guidance (ISG) JLD-ISG-2012-01.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation By letter dated April 16, 2014 (Reference 18), 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 9 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 11).

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 19), and supplemented by letter dated April 13, 2015 (Reference 20). The NRC granted the requested schedule relaxation on April 29, 2015 (Reference 10),

which required 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. By letter dated December 14, 2015 (Reference 12), PSEG notified the NRC of the need to defer installation of the alternate FLEX mechanical connection to the Residual Heat Removal (RHR) system due to seat leakage of a locked closed valve that was intended to serve as the blocking point during on-line installation. PSEG is finalizing a design change to complete installation of the RHR tie-in for the alternate FLEX connection during the fall 2016 refueling outage.

Page 9 of 19

LR-N16-0042 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 22 ) 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 voe and 250 voe batteries Energy Institute (NEI) white paper dated August 27, 2013 have been completed using the (Reference 23) and endorsed by NRC via letter to NEI dated NRG-endorsed white paper.

September 16, 2013 (Reference 24).

2. Generic Concern HCGS is using the Modular Accident Analysis Program (MAAP) to Complete - Plant-specific MAAP4

- MAAP complete the development of FLEX timelines and strategies, analyses have been performed consistent with the NRC endorsement letter to NEI dated consistent with the NRC October 3, 2013 (Reference 25). endorsement letter.

3. Generic Concern HCGS will enhance shutdown risk processes and procedures using Complete -this requirement is

- Shutdown I the supplemental guidance provided in the NEI position paper entitled addressed via a new FSG for Refueling Modes "Shutdown I Refueling Modes, " dated September 18, 2013 shutdown cooling modes and (Reference 26) and endorsed by the NRC via letter to NEI dated changes to existing outage September 30, 2013 (Reference 27). management and equipment control procedures.

4. Generic Concern As part of the development of FLEX maintenance and testing Complete - PSEG developed

- Preventive programs, HCGS will use the EPRI Technical Report entitled "Nuclear FLEX equipment PM tasks using Maintenance Maintenance Applications Center: Preventative Maintenance Basis for the guidance in the NRG-endorsed (PM) FLEX Equipment, transmitted to NRC via NEI letter dated October 3, EPRI guidance, EPRI or PSEG 2013 (Reference 28) and endorsed by NRC letter dated October 7, templates appropriate for the 2013 (Reference 29). equipment, and vendor recommendations..

Page 10 of 19

LR-N16-0042 ID Item Ref. Description Status

5. Generic Concern With regard to maintaining containment, the implementation of Boiling Complete - PSEG is currently

- 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 013.2.3.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. SAG revisions to January 9, 2014 (Reference 30). support severe accident containment venting will be implemented prior to startup from the fall 2016 outage.

6. 013.2.4.8.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 strateQv.

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

Page 11 of 19

LR-N16-0042 ID Item Ref. Description Status

8. Cl 3.1.2.3.A Confirm that the procedures and programs for deployment of portable Complete - with procedure equipment in a flooding event conforms to NEI 12-06, Section 6.2.3 issuance 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 hiQh temperatures.

9. Cl 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. Cl 3.2.1.1.A From the June 2013 position paper (endorsed by the NRC via Complete - Same as Item #2, Reference 25), benchmarks must be identified and discussed which Generic Concern - MAAP.

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

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

within technical specificaUon limits.

12. Cl 3.2.1.1.C Confirm that MAAP4 is used in accordance with Sections 4.1, 4.2, 4.3, Complete - Same as Item #2, 4.4, and 4.5 of the June 2013 position paper (endorsed by the NRC Generic Concern - MAAP.

via Reference 25).

13. Cl 3.2.1.1.D Confirm that in using MAAP4, the licensee identifies and justifies the Complete - Same as Item #2, subset of key modeling parameters cited from Tables 4-1 through 4-6 Generic 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 12 of 19

LR-N16-0042 ID Item Ref. Description Status

14. Cl 3.2.1.1.E Confirm that the specific MAAP4 analysis case that was used to Complete - Same as Item #2, validate the timing of miti1ating strategies in the Integrated Plan is Generic Concern- MAAP.

identified and available torr NRG 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 TAF 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 Complete - Same as Item #2, seal or other sources of leakage used in the ELAP analysis. Generic Concern- MAAP.

Additional information is naquired 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 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 ntegrated Plan is tentative. The licensee Complete - final documentation of addressed this issue during the audit process by describing that the the event timelines supported the SOE timeline presented in the Integrated Plan will be finalized based FLEX implementation milestone of on plant-specific analysis, procedure development and timeline 12/18/15.

validation. Confirm that the final SOE timeline is acceptable.

17. CI 3.2.1.3.B The licensee stated that they are performing a HCGS specific MAAP4 Complete - part of resolution of the analysis consistent with the NRG endorsement letter to NEI dated generic concern regarding use of October 3, 2013 (ADAMS Accession No. ML13275A318) MAAP for containment analyses (Reference 25), 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).

Page 13 of19

LR-N16-0042 ID Item Ref. Description Status

18. Cl 3.2.1.4.A Additional technical basis or a supporting analysis is needed for both Reported as complete in the FLEX pumping system (one engine/pump located at the SWIS and August 2015, six-month update one motor/pump located in the reactor building) capabilities (Reference 7), this item is re-considering the pressure within the RPV and the loss of pressure opened pending revision to the along with details regarding the FLEX pump supply line routes, length hydraulic analyses.

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 Complete - based on plant-specific accumulators, the final temperature profile of the drywell, DC coping SRV accumulator sizing, MAAP results and the results of the GOTHIC temperature modeling for the analyses, and GOTHI C results.

reactor buildinQ are acceptable.

20. Cl 3.2.2.A Confirm that the licensee's final SFP cooling timeline is valid for the Complete - The FLEX strategy is required response actions capable of providing SFP cooling with consideration of timelines and environmental conditions during an ELAP.

21. Cl 3.2.3.A A site-specific analysis (MAAP) will be performed to determine the Complete - plant-specific MAAP correct time to open the HCVS vent and the expected drywell and analysis temperature results wetwell temperatures during the BDBEE. This information will be provide margin for critical included in a future six-month update. The site-specific analysis equipment that is qualified to needs to include a listing of critical drywell components that may be design basis accident conditions.

affected by the elevated temperatures (e.g., drywell seals and penetrations). Confirm that the analysis results are acceptable.

22. Cl 3.2.3.B The NRG 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 14 of 19

LR-N16-0042 ID Item Ref. Description Status

23. Cl 3.2.4.2.A Confirm that the GOTHIC analysis and/or technical evaluation Complete- based on GOTHI C 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.

to support essential equipment operation throughout all phases of an ELAP is acceptable.

24. Cl 3.2.4.2.B Confirm that the effects of elevated or lowered temperatures in the Complete - based on GOTHIC battery room, especially if the ELAP is due to a high or low results and a separate evaluation temperature hazard, have been considered. Confirm the adequacy of of low temperatures.

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 implemented improvements to (References 17 and 21) in response to the March 12, 2012, 50.54(f) radio and satellite phone request for information letter for HCGS and documented in the staff communications capability.

analysis (ADAMS Accession No. ML13130A387) (Reference 16) have been completed.

27. Cl 3.2.4.6.A Confirm that the GOTHIC modeling and room temperaturei Complete- based on GOTHIC calculations of plant strategic areas (e.g. MGR, RCI C room, HPCI modeling and room temperature room (if needed), torus room, and battery rooms including pathways calculations.

for access to equipment) show acceptable results for personnel habitability and equipment capability.

28. Cl 3.2.4.6.B Confirm that potential high temperature and high humidity in the SFP Complete- based on evaluation fo and fuel handling floor area has been addressed with regard to timeline constraints and GOTHI C accessibility. calculations.

Page 15 of 19

LR-N16-0042 ID Item Ref. Description Status

29. Cl 3.2.4.8.A Confirm that the design of the FLEX electrical hookups include the Complete - FLEX electrical details on how to connect to, and interface with existing plant connections and interfaces with equipment. plant equipment are designed for ease of installation using prefabricated connectors or terminal lugs. FSGs include guidance for connections.

30. Cl 3.2.4.8.B Confirm that the sizing of the FLEX diesel generators (OGs) is Complete - Sizing calculations for adequate to supply the planned loads. the Phase 2 and Phase 3 FLEX OGs support steady state operation of the FLEX loads and starting of the largest single load.

31. Cl 3.2.4.1O.A Confirm that the analysis of battery load profiles for the safety related Complete - Coping analyses for 125 and 250 Vdc batteries for a BOBEE demonstrate satisfactory load 125 voe and 250 voe batteries profiles and battery life. have been completed using the NRG-endorsed white paper.

Page 16 of 19

LR-N16-0042 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. PSEG Letter LR-N15-0169, "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),"

dated August 27, 2015

8. Nuclear Energy Institute (NEI) Report NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 Page 17 of 19

LR-N16-0042

9. 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

10. 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

11. NRC Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Effective Immediately)," dated June 6, 2013

12. PSEG Letter LR-N15-0190, "Intermediate Implementation Milestone Change for 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 December 14, 2015

13. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA 049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, " Revision 1, dated January 22, 2016

14. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 2, dated December 2015

15. 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

16. 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

17. 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

18. 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 Page 18 of 19

LR-N16-0042

19. 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

20. 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

21. PSEG Letter LR-N12-0351, "PSEG Nuclear LLC's Assessment Report for Communications During an Extended Loss of AC Power," dated October 31, 2012

22. 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

23. 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)

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

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

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

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

27. 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)

28. 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)

29. 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)

30. 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)

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

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

Page 19 of 19

LR-N16-0042 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 Black Equipment is ELECTRONICS ROOM Existing 460 9 REACTOR

- Red Equipment is VESSEL SPENT FUEL POOL

-- DCP 80110321 Blue Equipment is DCP 80112012 EL.162' EQUIPMENT AIRLOCK ROOM4323 Staircase No, FLWX SW Pump (P500) 43-02 Diesel Driven Pump Rated @ 1300 gpm RUN DISCHAROE

@400 ft of head HOSE THROUGH Deployed near SWIS PROPPED OPEN DOOR FLXV010 511 B ,!

i!

i' Exlstlng36" SW Header toReactor .

Buildlng 1 8" EL.86'*6"-1

'if. I Fuel Pool 4 SACS/RAGS HV-223 Makeup Existing A.V658 2" Cross-Tie Service Waler 1

I Waler HV- exlsUng Fue l Pool Makeup BC-V637 Propped

= m .ZJ.\. a" exlsUng c r o RHR System 1

{: ,_____,.___

0 i

HV-F075

-;;:2 0PSIG en Door

[Z]

RACSPUMP stralne' AREA ROOM Del. River 2 Bypa§11 A SW BSW t FLXrV001 4209 Loop 1 Loop 1

- - J"" - - I RHR HX I= - - - - - - - _;

RHR "A"HX TO HV-F017B ROOM4214 (Alternate Injection) w BE-205 ll.HV.f"015B

'--'-, - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - c - -

(' f'T1 FLX*V006 I EL. 77' PRIMARY DEMINWATER CONDENSATE PUMP AREA PUMP AREA ROOM 1110 ROOM 1104*

H 1

I

--:- **------ -- ,:: : Q.fOOPSl L ag.p1.101- l

--- E-Vl44 B

E CORE SPRAY ROOM4104 car11sf!rfrram f-----1

' E Electric Driven F'ump Powered From

--*----- -----: ---- -- R---- -- --- FLEXMCC "D" Demin.

Water :

Storage : ::J 1" FLX*V014 Condensate FLX*V01:l

- - - - - - - - - - - - - - - - - - - - - - - - - - - - .: -[J f:

Header Tank L!J

,I I

' FLX*V003 I

-II 6"SSHOSEi AN-V016 TWCU PUMP All New Valves, Fittings, Piping & Hose are ROOM4101A FCX*VOOO 4" unless otherwise noted FLEX ALT Hoodor Pump (P200) 460 GPM @ 400 foot of hood eleotrlc Driven Pump (76 HP)

EL. 6 '

80112012RO Version 9/28/15 SUP01R3 Hope Creek FLEX Mechanical Connection Modifications - Master Diagram

6 EfN t 1ctt-ro E

1. HOWN IS FLEX 'PHflSE-2' EOUIPMENT UNLESS 1£Tk'tJrl l1!1 \ \ij

2. ALL RECEPTACLES SHOWN ON THIS DIAGRAM ARE PERMANENTLY C C E

BE USED ONLY DURING 3.L INDICATED LDAOS,RATINGS,ANO CABLE LENGTHS NEED VERIFICATION.

SllALLBE USED TO SUPPLYNEW FLEXliENERATOflS LOAOSU.E.HEATERS,BATTERYCllAAGERSIOUJl)Nll OPERATION ONLY .

PANEL SHALL NOT BEUSEO DURING 5, SEISMICALLY OUALIFIEO OUICI< DISCONNECT PANEL EOUI PPEO WITH HOLOE!lLOCKINGCl>>B4ECTORS/RECEPTACLES.MAm!FACTURED BY TPC WIRE &CABLE lflR EOUIVALENTI,

6. BDNOEO TO GRllUNO BUSWHICH CONOUITS SHALL BE USEDFOR 1Wllr 140HFORHOPE CREEK m

MOUNTED NEflA NORTH/EAST 7,PORTABLE CORDS SHALL HAVE MALE PLUGS THAT Will PLUG INTO THE CORNER Of 'SOURCPRECEPTACLE Et<<l ANO FEMALE PLUGS THAT WD.L PLUG INTO THE UZ R/B ROOF 10*5*020 !NJ 10*5*4022IN) 'LOAO'RECEPTACLE END.

8. DESIGNATES NEW CIRCUIT BREAKER THAT WILL BE USED TO 'BACK-FEED' THEPOWER FOR TIEFLEX LOAOS, MOl.elTEONEAR PRIMARYOG NORTH ENO Of RJ!dW FLEXC:ABLE STORAGE 'I. FIELD SHALL REPLACE 1/0 LUGS INSIOE OF NEW CROUSE HINDS REC£PTfOSW UZ R/B ROOF ENCLOSURES!N) WJ1H NEW 2/0 LUGS.TYPIC:AL4PLAC:ES.

ll:l-5*4012 !NI 10*S*4013 (N) 10.UNSCHEO CONDUITS AIIDFIELD ADDEO BOX ARE FOR VENDOR COMMLMCATION C:ABLES TO FLEXliENERATOflS.

MOUNTED NEAR LEGEND:

SOUTH ENO OF RJ!dW UZR/B ROOF ---EXISTJNG CA!!LE!S) 10*S*4010!Nl Jll*S*40\ltNl

---NEii CABLE/CORO PENETRATION*AS NOTED NLJBl'l422A* 13!1/C 5110 MCM!Nl 4BllV NDN*FU51BLE lJNRLR01* 3'C!Nf ,...\. POWER RECEPTACLE WfTH DISCONNEc:T SWITCH NLJ80422B* 13!1/C 5110 MCM !NI

\JNRLR02* 3'CINJ 0 480'1 POWER RECEPTACLE

!El- EXISTIM; EOUIPMENT IN!* N E ii EOUIPMENT

!VJ- BYVEl'llOR tl-r\g . 1'*61JWG

!Nl r}gc 11.GCNWG

IN!

CONDUIT EXPANSION FITTINGStNHPLACES NE W PEN SEAL IN DRYWALL NL\80423F*H/C16AVG lNI 14tlf!UM3* 2'C: !Nl i

i PANEL 01H*364!EJ i

480/277V,4BIMMP,3-PHASE

!SEENOTE 4l i

'I Ls1l!t1t _____________________________ rL.!111: ________ _

FLOOR OPENING NEAR COL.V/34.6

!NO SEAU 80110322R0 SUP01R6 REV,6*REVISE PERFC:R 601162111*0001*0480 FLEX - PHASE 2 REV.5*RELOC:ATE CABLE REEL BOXES PER FCR 6 0l211116*00lil*01108 REV.HEVISE CABLESPEC: FOR NL\80423FPERFCR 601l620l-0001*0230 REV.3*ADDSPARE A!R CCW.& FLEX FUEL DIL TRANSFER PUMPPER FCR 60116201*0001*0130 & ADD REFEED TO 10X23LPERFCR 601\6201-000Hl50 REV.Z*OELETE CABLES & RECE PT'S TO RE*FEED AVH408PER FCR 60116201*0001*0140 REV.!*REVISEREC:EPT'S &MC:C,AOONOTES'l&l0,& CABLE REEL BOXPER FCR 601162D!*000Hll!J0 REV.0*HDPE CJIEEt:'FLEXPHASE2'* MASTERDIA!illA H

10 NOTES:

l.ALL NE\IEOOIPHENT SHOWN ISFLEX'PHASE*J' EOUIPMENTIUNLESSillllCATEOOTHERWISEJ.

2. SEISMICALLY OOALIFIEO 2 HlX.E MA LUGS MOIJ'olTEO IN AN ENCLOSURE PROVIDEDBY TPC \llRE

&. CABLE !OR EOUIVALENTl, J.NOT USEO 4.0ESIGNATES NEWCIRCU[TBREAKER THAT WILLBEUSEO TOFEEOTIEPLIWTLOADS.

5,SAFEA TEAM SHALL PROVIDE THESE PHASE J GENERATORSBASED ON THE PIM PROGRAM REOUJREMENTS.THESEPHASEJGENERATORS SHALLBESTORED AT TIERRC.

r

-------------------------------------- --------------- 1 T

6.

fJ, W'i'oNSill{:¥i WiL ', WEST I RM 5150 I I RM 5417 I N*54!Hl04

\/ALL OPENING i:

I RM5416 I i I COl!AIOOR 5WI I 7.THE ENDSOF EACHPORTABLECB A LE AREPROVIDED WJTH2*HOLE LUGSFOR TERMJNATJON.

NE\ICORE ORILL TO CORR!OOR540'1 LEGEND;

! NEW CORE DRILL TOCOAR!OOR540q ---BYOHERS !NOT IN THESCOPEOFTHIS OCPI.

IEI* EXISTIWGEOUIPMENT i

1 0A40l!EI INI* NE\IEOUIPt-ENT i

ARC* REGIONAL RESPll'ISE CENTER SAFER* STRATIGIC ALLIA NCE FORFLEX EMERGENCYRESPONSE i PIH* POOLED INVENTORY MANAGEMENT i !

i i 6

1 4.

A f BUS r

i i 05tE [

N( a CORE DRILL Q5Ei JD CORE DRILL i REFERENCE DWGS:

i

-0:! ---------------------------------

I

_________________________________ : ______________________________________ J _______________

SUPOI *SHEET I FLEX 'PHASE 2'MASrER DIAGRAM

\ I RM 533q I I RH 5301 1 l cORRroOR53t5 I l

i i l

i

-5KV !Nl NC!A03148-!3Jl/C500 MCM - !NJ f MCM 1) 5KV 51l0 i

HNRCR02- 4'C mi i i i

i REARBLOG TRUCK OOOR!EI ER i

_Y11J EXISTJNGSECURITY CARO REAOER&CONOUIT L

SEEOOTE6 L,c.,c - - - _ _ _ __ - -- _ _ _ _ _ _ _ _ _ _ _ _____ _ _ _ - '- - ----- " ' N°1, 2_,_

______________ /

UNIT 1 AUX DIESEL I CONTROL BLDG /

!LOOKINGWESTFROMlNSIOEl

(

\

SEE NOTE5

,/---------------------------------------- ------------------------------------------

\

r 1--

l I

I I I rr ""!""'"' : --- :-- ---------------------------- \ I I I l J I I SAFER SWITCHGEAR I I I I I l__ ::::::::::::::::::::::::::::::::::::::::::::::::t:::::::: =::: '-\

(1L

! Jh!

_:-::"'l A 'Q -_:-:l A sYOCHI R MZING SYNCHRONIZING SYNCHRONIZINO

'Q _ __ 'Q _ _:-::l 'Q RAC FLEX TUB R INE GENERATOR12rn1 4 K

!LOCATED L O/GBLOG) [LOCATED DtftiE W : trt f 6 u s5 L DIG BL(]Gl O/G8LOG: !LOCATED O /G BLDG!

\

, __________________________________________________________________________________ /

FLEX - PHASE 3

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSEG Nuclear !LC FEB 2 92016 Order EA-12-049 LR-N16-0042 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 Sixth 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-N15-0169, "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)," dated August 27, 2015

FEB 29 2016 Order EA-12-049 Page 2 LR-N16-0042

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

6. PSEG Letter LR-N15-0190, "Intermediate Implementation Milestone Change for 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 December 14, 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 sixth 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, and PSEG's planned installation of the alternate FLEX mechanical connection during the fall 2016 refueling outage, as described in Reference 6.

FEB 2 9 2016 Order EA-12-049 Page 3 LR-N16-0042 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 -----"--'-1-i-q_\+-1_

0

. _\ b__

( 6ate)

Sincerely,

.\)

Paul J. Davison Site Vice President Hope Creek Generating Station Attachment 1: Hope Creek Generating Station Sixth 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. Daniel Dorman, Administrator, Region I, NRC Ms. Carleen Parker, Project Manager, NRC/NRR/DORL Mr. Justin Hawkins, NRC Senior Resident Inspector, Hope Creek Mr. John Boska, Senior Project Manager, NRC/NRR/JLD Mr. Patrick Mulligan, Chief, NJBNE Mr. Thomas MacEwen, Hope Creek Commitment Tracking Coordinator Mr. Lee Marabella, PSEG Commitment Coordinator - Corporate

LR-N16-0042 Attachment 1 Hope Creek Generating Station Sixth 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-Bas is External Events

LR-N16-0042 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 7, PSEG provided six-month status reports associated with implementation of the requirements of NRC Order EA-12-049. This report is the sixth six-month status report, which provides implementation status and progress since the previous report (Reference 7). This update follows the guidance in Section 13.2 of Nuclear Energy Institute (NEI) Report 12-06, Revision 0 (Reference 8), 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 9 and 1 O; PSEG has completed activities to support implementation of the FLEX strategies at HCGS as of December 18, 2015, and will achieve full compliance with NRC Order EA-12-049 prior to startup from the fall 2016 refueling outage (H1R20). The actions necessary to achieve full compliance prior to startup from the H1R20 outage include completion of design changes and evaluations for the hardened torus vent in accordance with NRC Order EA-13-109 (Reference 11), and installation of the alternate FLEX mechanical connection to the Residual Heat Removal system as described in Reference 12.

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.

Develop FLEX Support Guidelines (FSGs)

Approve FSGs - PSEG issued FSGs to implement the HCGS FLEX strategies.

Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures

Perform Staffing Analysis - PSEG completed the HCGS Phase 2 staffing analysis (Reference 15) as required by the 10 CFR 50.54(f) information request dated March 12, 2012 (Reference 16). 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.

Page 1 of 19

LR-N16-0042

Develop Training Plan

Implement Training - Initial training has been completed.

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).

Create Maintenance Procedures - periodic inventory and maintenance of FLEX equipment are addressed by procedures and preventive maintenance tasks.

Emergency Preparedness (EP) Communications Improvements 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 2015 refueling outage. The current milestones reflect the schedule relaxations in References 9 and 10.

Original Revised Target Target Milestone Activity Status Completion Completion Date Date Submit Overall Integrated Plan Feb 2013 Complete Aug 2013 Complete Feb 2014 Complete Aug 2014 Complete Feb 2015 Complete Six-Month Status Update Aug 2015 Complete Complete With Feb 2016 This Report Aug 2016 Not Started Develop Strategies May 2013 Complete Modifications Develop Modifications Apr 2014 Started Apr 2016 Implement Modifications Apr 2015 Started Nov 2016 Page 2 of 19

LR-N16-0042 FLEX Support Guidelines (FSGs)

Develop FSGs Dec 2013 Complete Apr 2015 Approve FSGs Oct 2015 Complete Dec 2015 Validation Walk-throughs or Demonstrations of FLEX May 2015 Complete Dec 2015 Strategies and Procedures Perform Staffing Analysis Dec 2013 Complete Dec 2014 Develop Training Plan Jun 2014 Complete Jan 2015 Implement Training Dec 2014 Complete Dec 2015 Develop Strategies I Contract with National SAFER Response Oct 2013 Complete Feb 2015 Center (formerly called "Regional Response Center")

Procure Equipment Dec 2013 Started Nov 2016 Create Maintenance Procedures Jun 2014 Complete Dec 2015 Emergency Preparednes s (EP)

Jun 2014 Complete May 2015 Communications Improvements HC Implementation Outage Apr 2015 Not Started Nov 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 Revision 0 (Reference 8) in the August 2015 status report (Reference 7). The NRC staff subsequently issued a Revision 1 to Interim Staff Guidance (ISG) JLD-ISG-2012-01 (Reference 13) which endorses the use of NEI 12-06 Revision 2 (Reference 14) as an acceptable means of meeting the requirements of NRC Order EA-12-049, with exceptions, additions, and clarifications. Differences between NEI 12-06 Revision 0 and Revision 2 that are relevant to the discussion of changes to compliance method at HCGS are mentioned below. Revision bars indicate changes to the information provided in Section 4 of the August 2015 status report.

Page 3 of 19

LR-N16-0042 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 is stored at a separate on-site location.