UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

May 13, 2011

Mr. Thomas Kirwin

Vice-President, Operations (Acting)

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANT – NRC TEMPORARY INSTRUCTION 2515/183

INSPECTION REPORT 05000255/2011010

Dear Mr. Kirwin:

On April 29, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection 

at your Palisades Nuclear Plant, using Temporary Instruction 2515/183, “Followup to the

Fukushima Daiichi Nuclear Station Fuel Damage Event.” The enclosed inspection report 

documents the inspection results which were discussed on May 5, 2011, with yourself and 

members of your staff.

The objective of this inspection was to promptly assess the capabilities of Palisades Nuclear 

Plant to respond to extraordinary consequences similar to those that have recently occurred at 

the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, along with 

the results from this inspection performed at other operating commercial nuclear plants in the 

United States will be used to evaluate the U. S. nuclear industry’s readiness to safely respond to 

similar events. These results will also help the NRC to determine if additional regulatory actions 

are warranted.

All of the potential issues and observations identified by this inspection are contained in this 

report. The NRC’s Reactor Oversight Process will further evaluate any issues to determine if 

they are regulatory findings or violations. Any resulting findings or violations will be documented 

by the NRC in a separate report. You are not required to respond to this letter. 
T. Kirwin -2-

In accordance with 10 CFR 2.390 of the NRC’s “Rules of Practice,” a copy of this letter

and its enclosure will be made available electronically for public inspection in the NRC 

Public Document Room or from the Publicly Available Records (PARS) component of 

NRC’s document system (ADAMS), accessible from the NRC Web site at 

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John B. Giessner, Chief

Branch 4

Division of Reactor Projects

Docket Nos. 50-255

License Nos. DPR-20

Enclosure: Inspection Report 05000255/2011010

cc w/encl: Distribution via ListServ 
Enclosure

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-255

License No: DPR-20

Report No: 05000255/2011010

Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant

Location: Covert, MI

Dates: March 23, 2011, through April 29, 2011

Inspectors: J. Ellegood, Senior Resident Inspector

T. Taylor, Resident Inspector

Approved by: John B. Giessner, Chief

Branch 4

Division of Reactor Projects
 1 Enclosure

SUMMARY OF FINDINGS

IR 05000255/2011010, 03/23/2011 – 04/29/2011; Palisades Nuclear Plant Temporary 

Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event

This report covers an announced Temporary Instruction inspection. The inspection was 

conducted by Resident and Region III inspectors. The NRC’s program for overseeing the safe 

operation of commercial nuclear power reactors is described in NUREG-1649, “Reactor 

Oversight Process,” Revision 4, dated December 2006.”

INSPECTION SCOPE

The intent of the TI is to provide a broad overview of the industry’s preparedness for events 

that may exceed the current design basis for a plant. The focus of the TI was on (1) assessing 

the licensee’s capability to mitigate consequences from large fires or explosions on site, 

(2) assessing the licensee’s capability to mitigate station blackout (SBO) conditions, 

(3) assessing the licensee’s capability to mitigate internal and external flooding events 

accounted for by the station’s design, and (4) assessing the thoroughness of the licensee’s walk 

downs and inspections of important equipment needed to mitigate fire and flood events to 

identify the potential that the equipment’s function could be lost during seismic events possible 

for the site. If necessary, a more specific follow-up inspection will be performed at a later date.

INSPECTION RESULTS

All of the potential issues and observations identified by this inspection are contained in this 

report. The NRC’s Reactor Oversight Process will further evaluate any issues to determine if 

they are regulatory findings or violations. Any resulting findings or violations will be documented 

by the NRC in a separate report.
 2 Enclosure

03.01 Assess the licensee’s capability to mitigate conditions that result from beyond design basis events, typically bounded by 

security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident 

management guidelines (SAMGs) and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use 

Inspection Procedure (IP) 71111.05T, “Fire Protection (Triennial),” Section 02.03 and 03.03 as a guideline. If IP 71111.05T was 

recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of 

inspection. Particular emphasis should be placed on strategies related to the spent fuel pool (SFP). The inspection should include, 

but not be limited to, an assessment of any licensee actions to: 

Licensee Action Describe what the licensee did to test or inspect equipment.

a. Verify through test or inspection 

that equipment is available and 

functional. Active equipment 

shall be tested and passive 

equipment shall be walked down 

and inspected. It is not 

expected that permanently 

installed equipment that is 

tested under an existing 

regulatory testing program be 

retested. 

This review should be done for a 

reasonable sample of mitigating 

strategies/equipment.

Licensee actions included the identification of equipment (active and passive) utilized for 

implementation of B.5.b actions and any additional equipment used in Severe Accident 

Management Guidelines (SAMGs). The licensee credited ongoing programs where 

permanently installed equipment is part of the mitigating strategy. These programs include 

the “limiting condition for operation” (LCO) board, for safety-related equipment, and the 

Operations aggregate list for nonsafety-related equipment. For equipment not permanently 

installed, the licensee performed walkdowns, tested or verified recent operation of the 

equipment. Non-installed active equipment within the scope defined above that did not 

have recent test results was tested. Non-installed passive equipment within the scope was 

walked down and inspected.

Describe inspector actions taken to confirm equipment readiness (e.g., observed a 

test, reviewed test results, discussed actions, reviewed records, etc.). 

The inspectors reviewed the licensee’s consolidated response. In addition, the inspectors 

performed a walkdown/inventory of equipment stored in the licensee’s B.5.b building and an 

in-plant location. The inspectors discussed the operation of the equipment with licensee 

personnel responsible for maintaining the equipment. The inspectors observed the start of 

a generator-operated light and a portable generator. The inspectors performed a walkdown 

and checked calibration of radiation meters available outside of the protected area. 

As part of the inspection, the inspectors noted that the licensee had obtained an air 

compressor for recharging air bottles. The inspectors noted that the compressor could 

be used as an air source for small pneumatic plant loads. 

The inspectors identified a discrepancy with equipment needed for emergency cooling of 

the SFP. One required fitting was missing that was discovered while preparing for a walk 

thru of the procedure for the NRC. Other mitigating strategies exist for cooling the SFP in 

addition to the one strategy that requires the missing fitting. The licensee wrote a condition 
 3 Enclosure

report (CR) to address the issue and obtained the missing coupling. The inspectors are 

determining the significance of this issue. 

The inspectors reviewed the results of the triennial fire protection inspection documented in 

report 05000255/2010-008. No findings of significance were identified. The triennial team 

reviewed the following strategies:

NEI 06-12, 

Revision 2, Section 

Licensee Strategy (Table) Selected for 

Review 

3.2.2 On-Site and Off-Site Communications 

(Table A.3-1) 

Evaluated

3.2.3 Notifications/ERO Activation (Table A.3-1) Evaluated

3.2.4 Initial Operational Response Actions 

(Table A.3-1) 

Evaluated

3.2.5 Initial Damage Assessment (Table A.3-1) Evaluated

3.3.7 PWR Enhancement Strategy No.7 – Portable 

Sprays (Table A.4-7) 

Evaluated

Discuss general results including corrective actions by licensee.

The licensee identified several enhancements which have been added to condition reports.

The licensee identified the following discrepancies:

- Some consumables useful to plugging a hole in the SPF were not in stock. The 

licensee determined that sufficient material was available to plug a breech.

- Caterpillar gensets, an offsite resource, were not available. This equipment is 

redundant to other B.5.b equipment and the licensee will delete the item. 

- One section of hose for B.5.b response was missing. The staged B.5.b equipment 

trailer contained 29 hoses; 20 are needed with 10 additional lengths of hose as part 

of the normal inventory. The licensee initiated actions to obtain another length of 

hose. 
 4 Enclosure

- Two cell phones were missing from the Emergency Operations Facility (EOF). The 

licensee replaced the phones. 

Licensee Action Describe the licensee’s actions to verify that procedures are in place and can be 

executed (e.g. walkdowns, demonstrations, tests, etc.)

b. Verify through walkdowns or 

demonstration that procedures to 

implement the strategies associate 

with B.5.b and 10 CFR 50.54(hh) a 

in place and are executable. 

Licensees may choose not to 

connect or operate permanently 

installed equipment during this 

verification. 

This review should be done for a 

reasonable sample of mitigating 

strategies/equipment.

The licensee developed a matrix that listed applicable procedures. For most procedures, 

the licensee performed a review. In some cases, the licensee also performed a walkdown 

of the procedure. The walkdowns were performed primarily for procedures that are not 

specific to B.5.b/SAMGs. 

Describe inspector actions and the sample strategies reviewed. Assess whether 

procedures were in place and could be used as intended.

The inspectors reviewed the licensee’s results. The inspectors observed some walkdowns 

to verify adequacy of the procedures and equipment. The inspectors reviewed portions of 

three procedures specific to B.5.b/SAMGs. These procedures were:

- Emergency Management Guidelines

- Alternate resources document

- PCSO-5, Alternate Source for Charging to PCS

The inspectors discussed the emergency management guidelines and alternate resources 

document with Operations. 

The inspectors concluded that the procedures, with one exception, were in place and could 

be used as intended. The exception relates to PCSO-5, the procedure for emergency SFP 

cooling. As previously identified, an additional fitting was needed to hook the hoses to the 

water source. The licensee wrote a condition report (CR) to address the issue and obtained 

the missing coupling. 

Discuss general results including corrective actions by licensee.

The licensee identified several enhancements to procedures. In some cases, the 

enhancements address conditions that have changed since the procedures were first 

developed. For example, one procedure directed responders to the Emergency Operations 

Facility (EOF) to muster in the manner (Sic) house. The manor house is associated with the 

old EOF. The licensee initiated procedure changes. The inspector concluded that the 

discrepancies did not impact the licensee’s ability to perform the mitigating strategies.
 5 Enclosure

Licensee Action Describe the licensee’s actions and conclusions regarding training and qualifications 

of operators and support staff.

c. Verify the training and 

qualifications of operators and 

the support staff needed to 

implement the procedures and 

work instructions are current for 

activities related to Security 

Order Section B.5.b and severe 

accident management 

guidelines as required by 

10 CFR 50.54 (hh). 

The licensee verified that all emergency response organization (ERO) and fire brigade 

personnel were in the Learning Management System (LMS) and current on training.

Describe inspector actions and the sample strategies reviewed to assess training and 

qualifications of operators and support staff.

The inspectors reviewed print outs of LMS qualifications to verify that training was current 

for personnel. The inspectors also reviewed initial and requalification lesson plans for ERO 

members. ERO members are tested each year on Emergency Management Guidelines. 

Prior to the test, members have the option to complete computer based training on the 

Emergency Management Guidelines. 

For fire brigade members, the inspectors discussed training content and frequency with 

personnel responsible for fire brigade training. The trainers stated that use of the B.5.b 

pump is demonstrated on a routine basis as part of fire brigade training. The inspectors 

reviewed the training reports for the third quarters of 2009 and 2010 that identified B.5.b 

related training. The inspectors observed a fire brigade member walkthrough a procedure 

for emergency cooling to the SFP. 

The inspectors identified through discussion that the electricians had not received training 

on the use of a small portable generator. However, the procedures and job aides showed 

the installation. Based on the general skill set of the electricians, the inspectors concluded 

that the generator could be used. 

The inspectors did not identify any training issues that would prevent implementation of 

procedures

Discuss general results including corrective actions by licensee.

The licensee did not identify any training issues.

Licensee Action Describe the licensee’s actions and conclusions regarding applicable agreements 

and contracts are in place.

d. Verify that any applicable 

agreements and contracts are in 

place and are capable of 

meeting the conditions needed 

The licensee contacted local fire departments and verified current contact information.

For a sample of mitigating strategies involving contracts or agreements with offsite 

entities, describe inspector actions to confirm agreements and contracts are in place 

and current (e.g., confirm that offsite fire assistance agreement is in place and 

current).
 6 Enclosure

to mitigate the consequences of 

these events. 

This review should be done for a 

reasonable sample of mitigating 

strategies/equipment.

The inspectors reviewed memoranda of understanding with local fire departments. In 

addition the inspectors reviewed existing contracts for private organizations identified as 

sources for equipment and supplies. The inspectors noted that the contracts may need 

modification during an event to obtain desired equipment and supplies. In addition, the 

licensee included several suppliers that do not have contracts in place. The inspectors 

reviewed the memorandum of understanding between Palisades and D.C. Cook.

Discuss general results including corrective actions by licensee.

No issues were identified. The inspectors concluded that the licensee had adequate 

contracts in place.

Licensee Action

Document the corrective action report number and briefly summarize problems noted 

by the licensee that have significant potential to prevent the success of any existing 

mitigating strategy.

e. Review any open corrective 

action documents to assess 

problems with mitigating 

strategy implementation 

identified by the licensee. 

Assess the impact of the 

problem on the mitigating 

capability and the remaining 

capability that is not impacted.

The licensee did not identify any issues that could have a significant impact on the success 

on the mitigating strategy. The inspectors reviewed open CRs for potential impacts that 

were not already discussed in Sections 03.01a through d above. No additional major 

impacts were noted.

03.02 Assess the licensee’s capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, “Loss of All 

Alternating Current Power,” and station design, is functional and valid. Refer to TI 2515/120, “Inspection of Implementation of Station 

Blackout Rule Multi-Plant Action Item A-22” as a guideline. It is not intended that TI 2515/120 be completely reinspected. The 

inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe the licensee’s actions to verify the adequacy of equipment needed to 

mitigate an SBO event.

a. Verify through walkdowns and 

inspection that all required 

materials are adequate and 

properly staged, tested, and 

maintained.

The licensee verified that equipment relied upon for mitigating an SBO was available and 

appropriately staged. The licensee reviewed procedures that would be utilized in an SBO 

and did field walkdowns of equipment utilized in the procedures to validate it was available. 

Additionally, the licensee did a walkdown of spare safety-related motors in the warehouse.
 7 Enclosure

Describe inspector actions to verify equipment is available and useable. 

The inspectors walked down temporary equipment staged to provide fuel to a backup 

generator on-site to ensure the procedure could be performed and that necessary parts 

were available. The inspectors also reviewed surveillance and corrective action records to 

validate that there were no issues impacting the functionality of a backup emergency 

generator. Additionally, manual actions for control of auxiliary feedwater during SBO were 

reviewed and the parts necessary for that evolution were verified in-place and ready to use. 

The inspectors also walked down a small gasoline generator that would connect to a 

safety-related panel to provide minimum safe shutdown capability in an SBO, watched it 

operate, and validated the necessary electrical connections were available and that the 

associated procedure could be implemented. Overall, based on their review, the inspectors 

determined there were no significant issues with the licensee’s mitigating strategy for SBO.

Discuss general results including corrective actions by licensee.

The licensee’s review of this attribute revealed no significant issues and concluded the 

capability to mitigate SBO and station design were functional and valid. The licensee did 

identify potential enhancements to a procedure that installs spare safety-related motors 

from the warehouse. As a result of additional walk-downs with the NRC, the licensee 

identified a potential enhancement with regard to a tagout needed in an off-normal 

procedure during an SBO. Specifically, while the tagout referenced in the procedure is pregenerated in the electronic tagging system, during a SBO or other possible events that 

system may not be available. Additionally, there may be other procedures where this is the 

case. The licensee initiated a document revision notice to consider creating a nonelectronic backup for tagouts referenced in emergency and off-normal procedures. 

Licensee Action Describe the licensee’s actions to verify the capability to mitigate an SBO event.

b. Demonstrate through 

walkdowns that procedures for 

response to an SBO are 

executable.

The licensee reviewed procedures that would be utilized in an SBO event and verified that 

they were executable. This review included a walkdown of equipment required in the 

procedures, as described above.
 8 Enclosure

Describe inspector actions to assess whether procedures were in place and could be 

used as intended.

The inspectors reviewed commitments in SBO-related Safety Evaluation Reports and 

reviewed a sample of tests and procedures to verify the commitments were properly 

accounted for. An off-normal procedure for an electrical lineup to provide power to 

pressurizer heaters was also reviewed. The inspectors also reviewed the procedure to 

connect a small gasoline generator to a safety-related panel in the plant. Additionally, the 

inspectors reviewed the procedure for obtaining spare safety-related motors from the 

warehouse and the general emergency operating procedure for SBO events. Overall, 

based on their review, the inspectors determined there were no significant issues with the 

licensee’s mitigating strategy for SBO.

Discuss general results including corrective actions by licensee.

The licensee’s review of this attribute revealed no significant issues and concluded the 

capability to mitigate an SBO was functional and valid. The licensee identified possible 

enhancements to the gasoline generator connection procedure which would provide more 

clarity. During a walk down of the gasoline generator with the NRC, an additional 

enhancement was identified to include pictures of the connections for further clarity. The 

inspectors reviewed preventative maintenance procedures for the spare motors in storage 

as well. As a result of the inspectors’ observations, the licensee is considering an 

enhancement to a work order which would further clarify acceptable oil levels in the spare 

motors.

03.03 Assess the licensee’s capability to mitigate internal and external flooding events required by station design. Refer to 

IP 71111.01, “Adverse Weather Protection,” Section 02.04, “Evaluate Readiness to Cope with External Flooding” as a guideline. The 

inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections 

that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include 

verification that accessible doors, barriers, and penetration seals are functional. 

Licensee Action Describe the licensee’s actions to verify the capability to mitigate existing design 

basis flooding events.

a. Verify through walkdowns and 

inspection that all required 

materials are adequate and 

properly staged, tested, and 

maintained.

The licensee reviewed existing design and licensing basis documentation regarding 

protection against flooding events to include Individual Plant Examination of External Events 

(IPEEE) reviews, the Final Safety Analysis Report (FSAR), off-normal and emergency 

procedures, and design basis documents. As a result, the licensee identified both 

permanent and non-permanent plant features, materials, and equipment used to respond to 

flooding. Walk downs were performed and preventative maintenance records were 

reviewed to validate the functionality of the equipment. Additionally, the licensee reviewed
 9 Enclosure

a number of condition reports previously written against flood mitigation features or 

equipment for functionality concerns.

Describe inspector actions to verify equipment is available and useable. Assess 

whether procedures were in place and could be used as intended.

The inspectors walked-down various safety-related areas to inspect flood mitigation features 

such as level switches, sump pumps, drain paths, and watertight barriers. Additionally, the 

inspectors reviewed flooding analyses that had been performed for safety-related plant 

areas and checked to see if assumptions were still valid during plant walk-downs. The 

inspectors also reviewed condition reports and preventative maintenance activities dealing 

with flood mitigation features to ensure there were no functionality issues and that the 

maintenance was being performed at the designated intervals. Overall, based on their 

review, the inspectors determined there were no significant issues with the licensee’s 

mitigating strategy for flooding.

Discuss general results including corrective actions by licensee.

The licensee’s review of this attribute concluded that all necessary equipment and features 

per the design and licensing bases were functional and appropriately staged. The licensee 

identified that a non-credited, gasoline-powered sump pump that could be used to mitigate 

flooding was located below the design flood level. As an enhancement, the licensee 

initiated a condition report to evaluate relocating the pump. NRC review revealed that in 

2008, a condition report was written documenting an NRC-identified issue regarding the 

capacity of the floor drains in the safety-related 1-D switchgear and adjoining cable 

spreading room. Operators had been noting that they had to reduce flow to less-than

approximately 20 gpm when performing a maintenance activity to flush fire piping and test 

the floor drains. Resolution of the issue at the time included generation of a work order to 

clean the drain piping. As of this review in 2011, the work order had not been completed. 

After discussion with the licensee, the work order has been returned to planning and is 

being scheduled for completion. For some time, the licensee has maintained a door from 

the 1-D room to another room open for other concerns. With this larger effective floor area, 

the licensee determined that for the design flooding scenario, the analyses are not 

challenged. However, the licensee is evaluating if further control is needed over the door 

given the potential impact on flooding in the 1-D room.

03.04 Assess the thoroughness of the licensee’s walkdowns and inspections of important equipment needed to mitigate fire and

flood events to identify the potential that the equipment’s function could be lost during seismic events possible for the site. Assess 

the licensee’s development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action 

program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of 

important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response 
 10 Enclosure

equipment; and developed mitigating strategies to cope with the loss of that important function. Use IP 71111.21, “Component 

Design Basis Inspection,” Appendix 3, “Component Walkdown Considerations,” as a guideline to assess the thoroughness of the 

licensee’s walkdowns and inspections.

Licensee Action Describe the licensee’s actions to assess the potential impact of seismic events on 

the availability of equipment used in fire and flooding mitigation strategies.

a. Verify through walkdowns that 

all required materials are 

adequate and properly staged, 

tested, and maintained.

The licensee identified equipment utilized/required for mitigation of fire and flood events. 

The licensee also reviewed the results of the walk-downs conducted in the 1990’s to 

address Unresolved Safety Issue (USI) A-46, Seismic Qualification Utility Group (SQUG), in 

which the plant sought to validate the adequacy of mechanical and electrical equipment 

against seismic criteria not in use when the plant was originally licensed. This included nonsafety-related equipment such as fire and flood mitigation features. Additionally, walk-downs 

were performed of major equipment used to mitigate fires and flooding.

Describe inspector actions to verify equipment is available and useable. Assess 

whether procedures were in place and could be used as intended.

The inspectors conducted walk-downs of important structures, systems and components

(SSCs) needed to mitigate fire and flood events to identify the potential that the SSCs’

function could be lost during a seismic event. This included installed fire protection 

equipment, flood barriers, and major B.5.b equipment. Additionally, the inspectors reviewed 

the context of USI A-46 (SQUG) and the conclusions drawn by the licensee from the review 

of that issue. Overall, based on their review, the inspectors determined there were no 

significant issues with the licensee’s mitigating strategies.

Discuss general results including corrective actions by licensee. Briefly summarize 

any new mitigating strategies identified by the licensee as a result of their reviews. 

Seismically qualified SSCs normally consist of safety-related equipment that has been 

formally qualified to function during and after a design basis earthquake. The licensee’s 

reviews for this issue determined that nonsafety-related SSCs, in general, were not 

considered to be formally qualified to safety-related seismic standards. However, in 

resolving USI A-46 (SQUG) in the 1990’s, experts reviewed the seismic ruggedness of 

nonsafety-related piping, cable trays, and other equipment throughout the plant as part of 

that effort. This included fire and flood mitigation piping and other features. The conclusion 

of analysis was that there were no seismic vulnerabilities and that piping systems were well 

supported. Additionally, for flood mitigation barriers, flooding loads were determined to 

bound seismic loads, maintaining the functionality of those barriers during seismic events. 

Sump pumps and level switches not seismically rugged were determined to not be needed 

for flood mitigation. The licensee did identify a potential enhancement to provide more 

detailed direction in fire procedures for the use of alternate water sources given the primary 
 11 Enclosure

source for a fire zone was disabled. Additionally, equipment staged to respond to B.5.b 

events was not stowed in seismically qualified buildings and locations, as a seismic event 

and B.5.b event have never been assumed to occur concurrently. Finally, the licensee is 

considering removing some heaters in the turbine building that might fall during a seismic 

event and impact hose stations below. In sum, the licensee determined present measures 

and design are sufficient with no need for new mitigating strategies.
12 Enclosure

Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. T. Kirwin and other members of 

licensee management at the conclusion of the inspection on May 5, 2011. The 

inspectors asked the licensee whether any materials examined during the inspection 

should be considered proprietary. No proprietary information was identified.
13 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. White, Operations 

D. Campbell

K. Simpson

M Sicard

G. Sleeper

T. Horan

L. Gilbert

Nuclear Regulatory Commission

R. Langstaff
14 Enclosure

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does 

not imply that the NRC inspectors reviewed the documents in their entirety but rather that 

selected sections of portions of the documents were evaluated as part of the overall inspection 

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or 

any part of it, unless this is stated in the body of the inspection report.

03.01 Assess the licensee’s capability to mitigate conditions that result from beyond design 

basis events

Number Description or Title Date or

Revision

PCSO-5 User Curriculum Status for ERO positions printed April 26, 

2011

Agreement 

10207202

Multipurpose Maintenance Modification and General Services 

Agreement

effective 

September 1, 

2008

LM-0311 Qualification Matrix (Fire Brigade Qualifications

Emergency Management Guidelines Requalification Training printed April 20, 

2011

PL-LOR07E003LSecurity Issues Revision 0

PL-NLO-07E001LSecurity Revision 0

PL-FBT-B5B001LHale Fire Pump Operation Revision 0

PL-BEP-EPT002EMG Exam Example

PL-BEP-SEP001RSAMG Exam Example

PLLP-LOR10C-02SAMGs Revision 0

PL-BEP-EPT001LEMGs Revision 5

PL-BEP-SEP001LRevision 4

FP-PE-16 Fire Protection Check Sheet Revision 2

WO 52333244 

01

B5B Strategy and PM for Fire Equipment Inspection and 

Testing

printed April 20, 

2011

SAMG and EMG Spreadsheet compiled May 2, 

2011

Initial Fire Brigade training attendance July 2011

Fire Brigade Report 3rd Quarter 2009

Fire Brigade report 3rd Quarter 2010

Fire Brigade Initial Training Plan July 2010 Class

Nuclear Fire Brigade requalification Training Attendance September 2009

Letter of Agreement, South Haven Emergency Services and 

PNPP

October 10, 

2010

Letter of Agreement, Covert Fire Department and PNPP October 12, 

2010
15 Enclosure

CR-PLP-2011-

2196

Two-Fittings unavailable May 2, 2011

Letter of Agreement, South Haven Community Hospital and 

PNPP

October 14, 

2010

Letter of Agreement, Community Emergency Service and 

PNPP

October 18, 

2010

Letter of Agreement, GEL Labs and PNPP October 22, 

2010

Reciprocal Laboratory Use Agreement, Indiana Michigan 

Power and Entergy

October 14, 

2010

Mutual Assistance Agreement between Detroit Edison, 

Entergy Nuclear Palisades and Indiana Michigan Power

November 5, 

2010

03.02 Assess the licensee’s capability to mitigate station blackout (SBO) conditions

Number Description or Title Date or

Revision

PFM-E-1 Emergency Post-Fire Repair for Appendix R Equipment Revision 10

EOP 

Supplement 19 

Alternate Auxiliary Feedwater Methods Revision 9

WO 52265961 PM-Spare Electric Motor Check

Contract 

10235674-00

Regarding fuel oil delivery

EOP 3.0 Station Blackout Recovery Revision 14

FSAR Chapter 8 Electrical Systems Revision 25

NRC Letter to Palisades Station Blackout Analysis-Safety 

Evaluation 

June 25, 

1992

NRC Letter to Palisades Station Blackout Analysis-Safety 

Evaluation 

May 20, 

1991

ONP 2.1 Loss of AC Power Revision 14

SOP-22 Emergency Diesel Generators Revision 49

Palisades 

Alternate 

Resources 

Document

PCSO-5 

Alternate Source for Charging to PCS Revision 3

03.03 Assess the licensee’s capability to mitigate internal and external flooding events required 

by station design

Number Description or Title Date or

Revision

CR-PLP-2008-

03991 

During NRC review flowrates questioned for 1D switchgear 

room floor drains 

September 24, 

2008

WO 178560 Clear blockage of floor drain in Rm 223 and 224

WO 52204653 D/Gs and D bus floor drain flow verification

ARP-8 Safeguards Safety Injection and Isolation Scheme EK-13 

(EC-13) 

Revision 70

EC5000121910 Replacement of SFP to ESS SDC to SFP SIRW to 

SDC/ESS and SDC to CCW Header Expansion Joints [flood 

barriers]

Calculation Internal Flooding Evaluation for Plant Areas Outside Revision 4
16 Enclosure

EA-C-PAL-95-

1526-01 

Containment 

MSM-M-16 Inspection of Watertight Barriers Revision 17

CR-PLP-2008-

00750 

Review of NRC Information Notice 2007-01 Recent 

Operating Experience Concerning Hydrostatic Barriers 

February 14, 

2008

DBD 7.08 Plant Protection from Flooding Revision 6

ONP-12 Acts of Nature Revision 26

WO 52233622 Inspection of Watertight Barriers

PFM-E-1 Emergency Post-Fire Repair for Appendix R Equipment Revision 10

EOP 

Supplement 19 

Alternate Auxiliary Feedwater Methods Revision 9

WO 52265961 PM-Spare Electric Motor Check

03.04 Assess the thoroughness of the licensee’s walkdowns and inspections of important 

equipment needed to mitigate fire and flood events to identify the potential that the 

equipment’s function could be lost during seismic events

Number Description or Title Date or

Revision

CR-PLP-2011-

01280 

Fukushima Daiichi Nuclear Station Fuel Damage Caused by 

Earthquake and Tsunami 

March 16, 

2011

Palisades A-46 Final Report May 15, 

1995

Generic Letter 

87-02 

Verification of Seismic Adequacy of Mechanical and Electrical 

Equipment in Operating Reactors Unresolved Safety Issue A46
17 Enclosure

LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System

AF Auxiliary Feedwater

ARM Area Radiation Monitors

CAM Continuous Air Monitors

CC Component Cooling Water

CFR Code of Federal Regulations

EOF Emergency Operations Facility

ERO Emergency Response Organization

FSAR Final Safety Analysis Report

IPEEE Individual Plant Examination of External Events

LCO limiting condition for operation

LMS Learning Management System

NRC United States Nuclear Regulatory Commission

PCS Primary Coolant System

PWR Pressurized Water Reactor

SAMGs Severe Accident Management Guidelines

SFP Spent Fuel Pool

SQUG Seismic Qualification Utility Group

SSCs Structures, Systems, and Components
T. Kirwin -2-

In accordance with 10 CFR 2.390 of the NRC’s “Rules of Practice,” a copy of this letter

and its enclosure will be made available electronically for public inspection in the NRC 

Public Document Room or from the Publicly Available Records (PARS) component of 

NRC’s document system (ADAMS), accessible from the NRC Web site at 

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John B. Giessner, Chief 

Branch 4

Division of Reactor Projects

Docket Nos. 50-255

License Nos. DPR-20

Enclosure: Inspection Report 05000255/2011010

cc w/encl: Distribution via ListServ 

DOCUMENT NAME: G:\DRPIII\1-Secy\1-Work In Progress\TI Reports\Palisades 2011 

010.docx

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII

NAME JGiessner:dtp

DATE 05/11/11

OFFICIAL RECORD COPY
Letter to T. Kirwin from J. Giessner dated May 13, 2011.

SUBJECT: PALISADES NUCLEAR PLANT – NRC TEMPORARY INSTRUCTION 2515/183 

INSPECTION REPORT 05000255/2011010

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