• Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043 

Tel 269 764 2000 

PNP 2012-034 

May 11,2012 

Anthony J. Vitale 

Site Vice President 

U. S. Nuclear Regulatory Commission 

AnN: Document Control Desk 

Washington, DC 20555-0001 

SUBJECT: 

Reference: 

Entergy Nuclear Operations, Inc. 60-Day Response to the March 12, 

2012, Information Request, Action Plan for Completing Emergency 

Communication and Staffing Assessments 

Palisades Nuclear Plant 

Docket 50-255 

License No. DPR-20 

NRC letter to Entergy, 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-ichi Accident, dated March 

12, 2012 (ADAMS Accession Number ML 12056A046) 

Dear Sir or Madam: 

On March 12, 2012, the NRC issued a letter (Reference 1) entitled, 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-ichi Accident. Enclosure 5 of the letter contains specific 

requested actions and requested information associated with Recommendation 9.3 for 

Emergency Preparedness (EP) programs. In accordance with 10 CFR 50.54, 

"Conditions of licenses," paragraph (f), addressees were requested to submit a written 

response to the information requests within 90 days. 

The letter states that if an addressee cannot meet the requested response date, then 

the addressee must provide a response within 60 days of the date of the letter and 

describe the alternative course of action that it proposes to take, including the basis of 

the acceptability of the proposed alternative course of action and estimated completion 

date. After a careful review of the requested actions and information, Entergy Nuclear 

Operations, Inc. proposes to take the alternative course of action described in 

Attachment 1 of this letter. The basis for the alternate proposal is provided in 

Attachment 2. 
PNP 2012-034 

Page 2 

The new commitments contained in this submittal are summarized in Attachment 3. 

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

May 11,2012. 

Sincerely, 

Attachments: 1. Proposed Alternative Course of Action for Responding to 

Recommendation 9.3 Information Request 

2. Basis for Proposed Alternative Course of Action for Responding to 

Emergency Preparedness Requested Information 

3. List of Regulatory Commitments 

cc: Director of Office of Nuclear Regulation 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
Attachment 1 to 

PNP 2012-034 

Proposed Alternative Course of Action for 

Responding to Recommendation 9.3 Information Request 
Attachment 1 to 

PNP 2012-034 

Page 1 of 3 

Proposed Alternative Course of Action for 

Responding to Recommendation 9.3 Information Request 

Communications 

Request Estimated 

Completion Requested Information # Date 

1 10/31/12 Provide an assessment of the current communications 

systems and equipment used during an emergency event to 

identify any enhancements that may be needed to ensure 

communications are maintained during a large scale natural 

event meeting the conditions described in the Discussion 

section of Enclosure 5 to the 10 CFR 50.54(f) letter. The 

assessment should: 

• Identify any planned or potential improvements to existing 

onsite communications systems and their required normal 

and/or backup power supplies, 

• Identify any planned or potential improvements to existing 

offsite communications systems and their required normal 

and/or backup power supplies, 

• Provide a description of any new communications 

system(s) or technologies that will be deployed based 

upon the assumed conditions described above, and 

• Provide a description of how the new and/or improved 

systems and power supplies will be able to provide for 

communications during a loss of all alternating current 

(AC) power. 

2 6/11/12 Describe any interim actions that have been taken or are 

planned to be taken to enhance existing communications 

systems power supplies until the communications 

assessment and the resulting actions are complete. 

3 See dates Provide an implementation schedule of the time needed to 

below conduct and implement the results of the communications 

assessment. 

9/28/12 Conduct the communications assessment. 

10/31/12 Provide an implementation schedule of the time needed to 

implement the results of the communications assessment. 
Attachment 1 to 

PNP 2012-034 

Page 2 of 3 

Staffing 

A two-phase approach is proposed to respond to the information requests 

associated with Staffing. The table below summarizes this approach. 

Request Estimated 

Completion Requested Information # Date 

1 See date Provide an assessment of the onsite and augmented staff 

below needed to respond to a large scale natural event meeting the 

conditions described in the Discussion section of Enclosure 5 

to the 10 CFR 50.54(f} letter. This assessment should 

include a discussion of the onsite and augmented staff 

available to implement the strategies as discussed in the 

emergency plan and/or described in plant operating 

procedures. The following functions are requested to be 

assessed: 

• How onsite staff will move back-up equipment (e.g., 

pumps, generators) from alternate onsite storage facilities 

to repair locations at each reactor as described in the 

order regarding the Near-Term Task Force (NTTF) 

Recommendation 4.2. It is requested that consideration 

be given to the major functional areas of NUREG-0654, 

Table 8-1 such as plant operations and assessment of 

operational aspects, emergency direction and control, 

notification/communication, radiological accident 

assessment, and support of operational accident 

assessment, as appropriate. 

• New staff or functions identified as a result of the 

assessment. 

• Collateral duties (personnel not being prevented from 

timely performance of their assigned functions). 

12/19/14 Provide onsite and augmented staffing assessment 

considering functions related to NTTF Recommendation 4.2 

(Phase 2 staffing assessment). 

2 See dates Provide an implementation schedule of the time needed to 

below conduct the onsite and augmented staffing assessment. If 

any modifications are determined to be appropriate, please 

include in the schedule the time to implement the changes. 

1. Conduct the onsite and augmented staffing assessment: 
Attachment 1 to 

PNP 2012-034 

Page 3 of 3 

Request Estimated 

Completion # Date 

2 (con't) 11/19/14 

12/19/14 

3 6/11/12 

4 6/11/12 

S 6/11/12 

6 See date 

below 

12/19/14 

Requested Information 

The onsite and augmented staffing assessment considering 

functions related to NTTF Recommendation 4.2 (Phase 2 

staffing assessment) 

2. A schedule of the time needed to implement changes will 

be provided as follows: 

Those associated with the Phase 2 staffing assessment 

Identify how the augmented staff would be notified given 

degraded communications capabilities. 

Identify the methods of access (e.g., roadways, navigable 

bodies of water and dockage, airlift, etc.) to the site that are 

expected to be available after a widespread large scale 

natu ral event. 

Identify any interim actions that have been taken or are 

planned prior to the completion of the staffing assessment. 

Identify changes that have been made or will be made to 

your emergency plan regarding the on-shift or augmented 

staffing changes necessary to respond to a loss of all AC 

power, multi-unit event, including any new or revised 

agreements with offsite resource providers (e.g., staffing, 

equipment, transportation, etc.). 

Changes will be identified as follows: 

Those associated with the Phase 2 staffing assessment 
Attachment 2 to 

PNP 2012-034 

Basis for Proposed Alternative Course of Action for 

Responding to Emergency Preparedness Requested Information 
Attachment 2 to 

PNP 2012-034 

Page 1 of 3 

Basis for Proposed Alternative Course of Action for 

Responding to Emergency Preparedness Requested Information 

Communications 

There are two separate responses to the information requests related to 

communications. The alternative timing of responses to requests #1 and #3 

proposed in this letter reflects the higher priority placed by the Staff, and 

approved by the Commission in Staff Requirements Memorandum 

(SRM)-SECY-12-002S, upon the completion of licensee actions necessary to 

comply with the Final Emergency Preparedness (EP) Rule issued on November 

23, 2011 (76 Federal Register 72560). The proposed alternative timing is 

warranted because many of the licensee staff resources necessary for 

performing the communications assessment are the same resources involved in 

implementing new EP Rule requirements, responding to Institute of Nuclear 

Power Operations (INPO) initiatives related to enhancing communications 

capabilities (e.g., INPO Event Report 11-4), and maintaining existing EP 

communications equipment. 

In addition, the estimated completion date assigned to information request #3 

promotes alignment between the out-year budgeting/funding of future 

enhancements and the development of an accurate and complete enhancement 

implementation schedule. 

Staffing 

As presented in Attachment 1 of this letter, a two-phase approach is proposed to 

respond to the information requests associated with Staffing. The table below 

summarizes this approach. 

Phase 1 Staffing 

Assessment Phase 2 Staffing 

Plant Type (for functions except those Assessment 

related to Near-Term Task (for functions related to 

Force (NTTF) NTTF Recommendation 4.2) 

Recommendation 4.2) 

Single-unit plants Perform staffing assessment Perform staffing assessment 

and implement actions as as requested by the 

required by recent EP Rule 10 CFR SO.S4(f) letter using 

using Interim Staff Guidance NEI 12-01; provide results 

(ISG) and Nuclear Energy per Attachment 1 of this 

Institute (NEI) 10-05 letter 

The basis for this approach is discussed below. 
Attachment 2 to 

PNP 2012-034 

Page 2 of 3 

• Single-unit plants do not need to provide a Phase 1 staffing assessment 

in response to the 10 CFR 50.54(f) letter as performance of this activity is 

governed by the recent EP Rule and existing license requirements. 

• The Phase 2 staffing assessment will be performed by November 19, 

2014, and provided by December 19, 2014. This assessment will 

consider the requested functions related to Fukushima NTTF 

Recommendation 4.2. 

The industry will be responding to multiple regulatory actions resulting 

from the recommendations contained in the Fukushima NTTF Report, as 

modified in related Commission Papers (SECYs) and SRMs. One of 

these actions, in particular, has the potential to impact emergency 

response staffing levels. This action is associated with Fukushima NTTF 

Recommendation 4.2 and subsequently issued as NRC Order to 

Modifying Licenses with Regard to Requirements for Mitigation Strategies 

for Beyond-Design-Basis External Events EA-12-049 (the Order). A 

summary of the Order is provided below. 

This Order requires a three-phase approach for mitigating 

beyond-design-basis external events. The initial phase requires the 

use of installed equipment and resources to maintain or restore core 

cooling, containment and spent fuel pool cooling. The transition phase 

requires providing sufficient, portable, onsite equipment and 

consumables to maintain or restore these functions until they can be 

accomplished with resources brought from off site. The final phase 

requires obtaining sufficient offsite resources to sustain those 

functions indefinitely. 

Additional details on an acceptable approach for complying with this 

Order are expected to be contained in the final ISG scheduled to be 

issued by the NRC in August 2012. 

In response to the Order, each licensee must develop new strategies for 

mitigating beyond-design-basis external events. To ensure accurate 

results, the staffing assessment for response functions related to NTTF 

Recommendation 4.2 must be based on the actions delineated in 

procedures and guidelines developed in response to the Order. Once the 

site-specific actions associated with the new response strategies are 

defined (e.g., down to the procedure or guideline step level), the staffing 

needed to perform these actions can be assessed with the necessary level 

of accuracy. 
Attachment 2 to 

PNP 2012-034 

Page 3 of 3 

Based on a review of the planned actions necessary to comply with the 

Order, an assessment of the staffing for functions related to NTTF 

Recommendation 4.2 will be provided by December 19, 2014. 

As requested, an implementation schedule for any modifications that are 

determined to be appropriate will be included with the Phase 2 staffing 

assessment. 

The Phase 2 staffing assessment is one component of the overall work plan 

necessary to implement the requirements of the Order. Entergy, as stated 

in the Order, " ... shall complete full implementation no later than two 

refueling cycles after submittal of the overall integrated plan, as required in 

Condition C.1.a, or December 31 , 2016, whichever comes first." "Full 

compliance shall include procedures, guidance, training, and acquisition, 

staging, or installing of equipment needed for the strategies." 
Attachment 3 to 

PNP 2012-034 

List of Regulatory Commitments 
Attachment 3 to 

PNP 2012-034 

Page 1 of 2 

List of Regulatory Commitments 

The following table identifies those actions committed to by Entergy Nuclear 

Operations, Inc. in this document. Any other statements in this submittal are provided 

for information purposes and are not considered to be regulatory commitments. 

TYPE 

(Check One) 

COMMITMENT SCHEDULED 

ONE- COMPLETION 

TIME CONTINUING DATE 

ACTION COMPLIANCE (If Required) 

Provide an assessment of the current X* October 31, 

communications systems and 2012 

equipment used during an emergency 

event to identify any enhancements 

that may be needed to ensure 

communications are maintained 

during a large scale natural event. 

Describe any interim actions that have 

been taken 6r are planned to be taken 

X* June 11, 2012 

to enhance existing communications 

systems power supplies until the 

communications assessment and the 

resulting actions are complete. 

Conduct the communications X September 28, 

assessment. 2012 

Provide an implementation schedule X* October 31, 

of the time needed to implement the 2012 

results of the communications 

assessment. 

Provide onsite and augmented staffing X* December 19, 

assessment considering functions 2014 

related to NTIF Recommendation 4.2. 

Conduct the onsite and augmented X November 19, 

staffing assessment considering 2014 

functions related to NTIF 

Recommendation 4.2. 

Provide a schedule of the time needed X* December 19, 

to implement changes associated with 2014 

the Phase 2 staffing assessment. 
Attachment 3 to 

PNP 2012-034 

Page 2 of 2 

Identify how the augmented staff 

would be notified given degraded 

communications capabilities. 

Identify the methods of access (e.g., 

roadways, navigable bodies of water 

and dockage, air/ift, etc.) to the site 

that are expected to be available after 

a widespread large scale natural 

event. 

Identify any interim actions that have 

been taken or are planned prior to the 

completion of the staffing assessment. 

Identify changes that have been made 

or will be made to the emergency plan 

regarding the on-shift or augmented 

staffing changes associated with the 

Phase 2 staffing assessment. 

* NRC submittal 

X* June 11,2012 

X* June 11,2012 

X* June 11, 2012 

X* December 19, 

2014