Nuclear Development244 Chestnut Street, Salem, NJ 08079

o PSEGPower LLC

ND-2011-0057September 8, 2011

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Subject: PSEG Early Site PermitNRC Docket No. 52-043Response to Request for AdditionalClimatology

Information, RAI No. 33, Regional

References: 1) PSEG Power, LLC letter to USNRC, Application for Early SitePermit for the PSEG Site, dated May 25, 2010

2) RAI No. 33, SRP Section: 02.03.01 - Regional Climatology, datedAugust 12, 2011 (eRAI 5843)

The purpose of this letter is to respond to the request for additional information (RAI)identified in Reference 2 above. This RAI addresses Regional Climatology, asdescribed in Section 2.3.1. of the Site Safety Analysis Report (SSAR), as submitted inPart 2 of the PSEG Site Early Site Permit Application, Revision 0.

Enclosure 1 provides our response for RAI No. 33, Question No. 02.03.01-6. Ourresponse to RAI No. 33 will require revisions to the SSAR. Enclosure 2 providesproposed revisions to the SSAR. Enclosure 3 includes the new regulatory commitmentestablished in this submittal.

If any additional information is needed, please contact David Robillard, PSEG NuclearDevelopment Licensing Engineer, at (856) 339-7914.

U. S. Nuclear RegulatoryCommission

2 9/8/11

I declare under penalty of perjury that thethe 8th day of September, 2011.

foregoing is true and correct. Executed on

Sincerely,

James MallonNuclear DevelopmentEarly Site Permit ManagerPSEG Power, LLC

Enclosure 1:

Enclosure 2:

Enclosure 3:

Response to NRC Request for Additional Information, RAI No. 33,Question No. 02.03.01-6, SRP Section: 02.03.01 - Regional ClimatologyProposed Revisions Part 2 - Site Safety Analysis Report (SSAR)Subsection 2.3.1Summary of Regulatory Commitments

cc: USNRC Project Manager, Division of New Reactor Licensing, PSEG Site(w/enclosures)USNRC, Environmental Project Manager, Division of Site and EnvironmentalReviews (w/enclosures)USNRC Region I, Regional Administrator (w/enclosures)

PSEG Letter ND-2011-0057, dated September 8, 2011

ENCLOSURE 1

RESPONSE to RAI No. 33, QUESTION 02.03.01-6

Response to RAI No. 33, Question 02.03.01-6:

In Reference 2, the NRC staff asked PSEG for information regarding RegionalClimatology, as described in Section 2.3.1 of the Site Safety Analysis Report (SSAR).The specific request for Question 02.03.01-6 was:

10 CFR 52.17(a)(1)(vi) states, in part, that ESP applicants must identify themeteorological characteristics of the proposed site with appropriate considerationof the most severe of the natural phenomena that have been historically reportedfor the site and surrounding area and with sufficient margin for the limitedaccuracy, quantity, and period of time in which the historical data have beenaccumulated. Temperatures based on a 1 00-year return period are considered toprovide sufficient margin for the limited accuracy, quantity, and period of time inwhich the historical data have been accumulated as required by the regulation.The PSEG Site ESP ambient air temperature and humidity site characteristicvalues should include both historic extreme and 100-year return period values forcomparison with the DCD 0% exceedance air temperature and humidity siteparameter values at the COL stage.

In RAI 14, Question 02.03.01-4 (ML 111040109), the staff requested that SSARTable 2.0-1 be expanded to include site characteristic values that correspond tothe ambient air temperature and humidity site parameter values contained in thedesign control documents (DCDs) for the reactor designs that are referenced inSSAR Section 1.2.2 (i.e., the U.S. EPR, ABWR, US-APWR, and APlO00 reactordesigns). In a May 13, 2011, response to this RAI (ML 11136A236), SSAR Table2.0-1 was updated to include additional site characteristic temperatures.However, the updated SSAR Table 2.0-1 did not include a 100-year return periodmean coincident wet-bulb temperature.

Please update the SSAR to include a 100-year return period mean coincidentwet-bulb temperature that corresponds with the 100-year return period dry bulbtemperature, or provide justification as to why this is not necessary.

PSEG Response to NRC RAI:

The mean coincident wet bulb temperature that corresponds to the 100-year returnperiod dry-bulb temperature (105.91F) was found using the graphical techniquedescribed in SSAR Subsection 2.3.1.7. Application of this method produced a meancoincident wet bulb temperature of 82.41F.

Associated PSEG Site ESP Application Revisions:

SSAR Table 2.0-1 and SSAR Subsection 2.3.1.7 will be updated as specified inEnclosure 2 of this document.

Enclosure 1 Page 1

PSEG Letter ND-2011-0057, dated September 8, 2011

ENCLOSURE 2

Proposed RevisionsPart 2 - Site Safety Analysis Report (SSAR)

Subsections 2.0, Site Characteristicsand 2.3.1, Meteorology

Marked Up Pages2.0-2

2.3-17

PSEG SiteESP Application 14,

Part 2, Site Safety Analysis Report Queston 02.03.0

Table 2.0-1 (Sheet I of 8)PSEG Site Characteristics

Site Characteristic PSEG Site Value SSARe I DefinitionI Section Demonrti

Geography and Demnography

1-4

Exclusion Area BoundarySThe EAB is a circle at least 600

meters (1968 feet) from the edge ofthe power block area in all

The area surrounding the reactor(s), in whi(2.1.1.2 has the authority to determine all activities,

removal of personnel and property from the

ch the reactor licensee I

including exclusion orarea.

108F (DBT) I The hiahest recorded ambient dry-bulb temperature and me7923 17WB coincident wet-bulb temperature.

- _r. 81l. . - Illll• t.ll *•I ....... I nonilated renter nontaininn mor. than ahmit 215 (M ren.sident-

1% ~nnualExte E exceedanceS

9OWF (DBT)

756F (MCWB)T The ambient dry-bulb temoerature (and mean coincident wet-bulbTable 2.3-14 temperature) that will be exceeded 1% of the time annually.

Meteorology

Ambient Air Temperature and Humidity

MaximDry-BulbTTemperatur

2% annualexceedance

88"F (DBT)

73-F (MCWB)Table 2.3-14 The ambient dry-bulb temperature (and mean coincident wet-bulb

temperature) that will be exceeded 2% of the time annually.

0.4% annual 93-F (DBT) 1 The ambient dry-bulb temperature (and mean coincident wet-bulbexceedance 76-F (MCWB) Table 2.3-14 temperature) that will be exceeded 0.4% of the time annually.

100-yearretum period 105-9-F (DBT) Table 2.3-13

The ambient dry-bulb temperaturehat has a 1% annual probabilityof being exceeded (100-year m recurrence interval).

(and mean coincident-wet-bulb temperature) Rev. 0

Enclosure 2 Page 1

PSEG SiteESP Application

Part 2, Site Safety Analysis Report

An additional review of regional extreme DBT data is done using NCDC TD 3200 SOD(surmary of the day) digital datasets for the same 10 regional COOP monitoring stations forwhich daily precipitation data are reviewed above in Subsection 2.3.1.3.4. Those stations are:Dover, Millington 1 SE, Wilmington, Marcus Hook, Philadelphia lAP, Hammonton I NE,Glassboro 2 NE, Woodstown Pittsgrove 4 E, Seabrook Farms, and Millville MAP.

Those ten stations do not measure WBT, and do not record hourly DBT. They only recordmaximum and minimum daily DBTs and daily precipitation totals. Therefore, it is not possible toidentify WBTs that are coincident with extreme DOTs identified in the TD 3200 datasets. Table2.3-15 presents results of review of TD 3200 datasets for the 10 regional stations. That tablealso includes results of review of 32 years of SAI-iC hourly on-site data. As shown in Table 2.3-15, overall maximumn and minimum recorded DBTs at the site and in its surrounding climatearea are 108 and -15 'F.

As discussed above, WBTs coincident with extreme DBTs identified in the TD 3200 datasetsare not directly available in existing publications for two masons. First, the COOP monitoringstations that record the extreme DOTs do not record WBTs. Second, a frequency distribution ofDBT versus WBT depression available for Wilmington on the International StationMeteorological Climate Summary CD (ISMCS, Reference 2.3.1-20) has a DOT upper limit of102 deg F. Therefore, the coincident WBT is estimated.

A graphical extrapolation is used to estimated the WBT that would occur during the peak overallDBT of 108 *F. A simple graphical approach is most appropriate for several reasons.

* A simple graphical approach is appropriate because at the extreme high end of the DBTrange there are only a small number of observations. Use of an objective numencaltechnique to project larger DBT values using such a small population as input is unjustifiedbecause it is effectively no less subjective than the graphical approach.

* The requirement is for only a mean coincident WBT value. A mean WBT value is simplyidentified for any DBT value on the graph, therefore a set of such means is easily plotted,and form the basis for an extrapolation line.

" A DBTiWBT JFD table from Reference 2.3.1-20 for Wilmington is already published and issuitable for use in sketching the graphical relationship between regional DBT and WBTduring conditions of the peak DBT.

Graphical extrapolation of the DBTWVBT depression relationship to a DBT of 108 'F results inestimation of a WBT depression of 29 "F, and a MCWB of 79 *F.

2.3.1.8 Restrictive Dispersion Conditions

Major air pollution episodes are typically a result of persistent s high pressure weathersystems that cause light and variable surface winds and stagnant teorolegical conditions forfour or more consecutive days. Estimates of stagnation frequency are provided in Air StagnationClmatology for the United States (Reference 2.3.1-47, Figures 1 2). Those estimatesindicate that, on the average, the PSEG Site experiences 11 days year with stagnationconditions, or 2 cases per year with the mean duration of each ca lasting 5 days.

vRev. 0RAI N.332.3-17

Apokffg of a similar tahueQ tot W thi e 10veer DBT (105.9 OF) results in a MCW of 82.4 OT

[:; 9 == === ............ .............. ==

Enclosure 2 Page 2

PSEG Letter ND-2011-0057, dated September 8, 2011

ENCLOSURE 3

Summary of Regulatory Commitments

ENCLOSURE3

SUMMARY OF REGULATORY COMMITMENTS

The following table identifies commitments made in this document. (Any other actionsdiscussed in the submittal represent intended or planned actions. They are describedto the NRC for the NRC's information and are not regulatory commitments.)

COMMITMENT COMMITTED DATE COMMITMENT TYPEONE-TIME ProgrammaticACTION (Yes/No)(Yes/No)

PSEG will revise This revision will be Yes NoSSAR Subsections included in the next2.0 and 2.3.1 to update of the PSEGincorporate the Site ESP applicationchanges in Enclosure SSAR.2 in response to NRCRAI No. 33.

Enclosure 3 Page 1