Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, Ml 49043

ILL Tel 2697642000

Anthony J. Vitale

Site Vice President

PNP 2012-050

June 8,2012

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

11555 Rockville Pike

Rockville, MD 20852

SUBJECT: 90-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

References: 1. 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-ichi Accident,” dated

March 12, 2012 (ADAMS Accession Number ML12053A340)

2. Entergy Nuclear Operations, Inc. letter to NRC, “Entergy Nuclear

Operations, Inc. 60-Day Response to the March 12, 2012,

Information Request, Action Plan for Completing Emergency

Communication and Staffing Assessments, dated May 11, 2012

Dear Sir or Madam:

On March 12, 2012, the NRC issued Reference 1. Enclosure 5 of Reference 1 contains

specific requested actions and requested information associated with Recommendation

9.3 for Emergency Preparedness 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. The letter also provided requested due dates for

written responses.

1Wab?dance with the Re1ë?ñè2 (60-day response) on May 11, 20T2, Entergy

Nuclear Operations, Inc. submitted an alternative course of action for providing the

requested information. The alternative course of action included revised information

due dates and the basis for those dates. As described in the alternative course of

action, Attachment 1 to this letter transmits the responses to the following information
PNP 2012-050

Page 2

requests: Enclosure 5 communications request #2 and staffing requests #3, #4, and

#5.

The new commitments contained in this submittal are summarized in Attachment 2.

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

June 8, 2012.

Sincerely,

Attachments: 1. Request for Information 90-Day Emergency Preparedness

Response

2. List of Regulatory Commitments

cc: Director of Office of Nuclear Regulation

Administrator, Region Ill, USNRC

Project Manager, Palisades, USN RC

Resident Inspector, Palisades, USN RC
Attachment 1 to

PNP 201 2-050

Request for Information 90-Day Emergency Preparedness Response
Attachment 1 to

PNP 2012-050

Page 1 of 3

Request for Information (RFI) 90-Day Emergency Preparedness Response

Communications:

Nuclear Regulatory Commission (NRC) Request

2. 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.

Entergy Nuclear Operations, Inc. (ENO) Response

2. Purchase orders have been submitted for two uninterruptible power supplies

(UPSs) to be used at Palisades Nuclear Plant (PNP) to provide backup

power upon loss of all alternating current power for radio communications

systems for onsite response teams and offsite field monitoring teams. The

schedule for installation of the UPSs will be provided with the

communications assessment by October 31, 2012, as previously committed

to in the 60-day response (Reference 2).

In addition to existing emergency response radios and B.5.b dedicated

radios currently on site at PNP, ten additional portable digital radios, with

extra batteries and chargers, to be used for communications with onsite

response teams or offsite field monitoring teams, have been purchased,

received, and deployed.

In addition to existing satellite phones currently on site at PNP, 11 additional

battery-operated satellite phones, to be used for emergency onsite and

offsite communications, have been purchased and received for deployment.

Staffing:

NRC Request

3. Identify how the augmented staff would be notified given degraded

communications capabilities.

ENO Response

3. Initial expectations have been communicated to the Emergency Response

Organization-(ERO)-to-respon&tolheir assigne&eme ryerluy response

facilities when made aware of an area-wide loss-of-grid that results in

degraded communications capability. This will be included in the ERO

annual requalification training program by December 12, 2012.
Attachment 1 to

PNP 2012-050

Page2of3

NRC Request

4. 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 natural event.

ENO Response

4. Various types of transport to PNP are applicable including: walking, personal

vehicle, helicopter, and watercraft.

Pursuant to Michigan Public Act 390 of 1976, known as the Michigan

Emergency Management Act, the Michigan State Police Emergency

Management Homeland Security Division (MSP/EMHSD) is required by state

law to provide support, consistent with competing priorities, to PNP in the

event of a large-scale natural disaster that inhibits site access. MSP/EMHSD

is the central coordinating agency for mutual aid in Michigan for all state, local

and federal resources. This support may include enabling plant emergency

responders to gain access to the nuclear plant site by clearing roads, or

coordinating air or water transportation, as needed.

The following Letters of Agreement for assistance and/or other services are

also in place in accordance with the PNP Site Emergency Plan:

Covert Fire Department

South Haven Area Emergency Services Authority

Mutual Assistance Agreement

In support of these agreements, Entergy Nuclear Operations, Inc. (ENO) is

evaluating additional potential staging areas to be used by the emergency

responders, if they are available, as common locations for transport to the

PNP site. This evaluation is scheduled for completion by October 30, 2012.

NRC Request

5. Identify any interim actions that have been taken or are planned prior to the

completion of the staffing assessment.
Attachment 1 to

PNP 2012-050

Page 3 of 3

ENO Response

5. ENO is assessing initial on-shift ERO staffing at PNP for design-basis event

conditions in response to the requirements of changes to 10 CFR Part 50,

Appendix E, Section lV(A)(9). This assessment is scheduled for completion

by December 24, 2012. Although limited to the time following a design-basis

event initiation until the on-shift ERO is augmented, this assessment is

expected to provide an initial indication of the adequacy of staffing to respond

to beyond design-basis events.

In addition, supplies including food and water to support extended presence

of emergency workers at PNP have been purchased and are available on

site.

References:

1. NRC letter to ENO, “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 (ML12053A340)

2. ENO letter to NRC, “Entergy Nuclear Operations, Inc. 60-Day Response

to the March 12, 2012, Information Request, Action Plan for Completing

Emergency Communication and Staffing Assessments,” dated May 11,

2012
Attachment 2 to

PNP 201 2-050

List of Regulatory Commitments

nePagEaHow&
List of Regulatory Commitments

The following table identifies those actions committed to by Entergy Nuclear Operations, Inc.

(ENO) in this document. Any other statements in this submittal are provided for information

purposes and are not considered to be regulatory commitments.

SCHEDULED

TYPE COMPLETION

(Check One) DATE COMMITMENT (If Required)

ONE-TIME CONTINUING

ACTION COMPLIANCE

Include instructions for the December 12,

Emergency Response X 2012

Organization (ERO) to respond to

their assigned emergency

response facilities when made

aware of an area-wide loss-ofgrid in the ERO annual

requalification training program.

ENO will evaluate additional October 30,

potential staging areas to be X 2012

used by the emergency

responders, if they are available,

as common locations for

transport to the affected site.