Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant '" .=::-Entergy 27780 Blue Star Memorial Highway 

Covert, MI 49043 

Tel 269 764 2000 

PNP 2012-091 

Anthony J. Vitale 

Site Vice President 

October 25, 2012 

U. S. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

Washington, DC 20555-0001 

SUBJECT: 

References: 

Initial 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) 

Palisades Nuclear Plant 

Docket 50-255 

License No. DPR-20 

1. NRC Order Number EA-12-049, "Issuance of Order to Modify 

Licenses with Regard to Requirements for Mitigation Strategies 

for Beyond-Design-Basis External Events," dated March 12, 

2012 [ADAMS Accession Number ML 12054A 736] 

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance 

with Order EA-12-049, Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events," Revision 0, dated August 29,2012 [ADAMS 

Accession Number ML 12229A 174] 

3. Nuclear Energy Institute (NEI) Letter to NRC, "Industry Initiative 

on Procurement of Equipment for the Diverse and Flexible 

Coping Strategy (FLEX)," dated February 24,2012 

4. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) 

Implementation Guide," Revision 0, dated August 2012 [ADAMS 

Accession Number ML 12242A378] 

Dear Sir or Madam: 

On March 12, 2012, the NRC issued an order (Reference 1) to Entergy Nuclear 

Operations, Inc. (ENO). This order was immediately effective and directed ENO to 

develop, implement, and maintain guidance and strategies to maintain or restore core 
PNP 2012-091 

Page 2 

cooling, containment, and spent fuel pool cooling capabilities in the event of a 

beyond-design-basis external event. Specific requirements are outlined in Attachment 2 

of Reference 1 . 

Reference 1 requires submission of an initial status report 60 days following issuance of 

the final interim staff guidance. The final interim staff guidance (Reference 2) was 

issued August 30,2012. 

The purpose of this letter is to provide the initial status report pursuant to Section IV, 

Condition C.2, of Reference 1 within 60 days following issuance of Reference 2. This 

report confirms ENO has received Reference 2 and is in the process of evaluating the 

guidance for the purpose of establishing mitigation strategies to maintain or restore core 

cooling, containment, and spent fuel pool cooling capabilities in the event of a beyonddesign-basis external event as described in Attachment 2 of Reference 1 . 

Major activities completed during this reporting period: 

• Additional portable equipment was ordered prior to the issuance of Reference 2, 

as described in an NEI letter to the NRC (Reference 3). 

• A site-specific evaluation is in progress to establish the coping capabilities as 

defined in NE112-06 (Reference 4). 

• Resources are being identified and project plans initiated, including development 

of milestones, to assure compliance with Reference 1. 

Planned activities for the next six months: 

• Development and submittal of the overall integrated plan. 

Technical difficulties encountered that could affect the ability to provide the licensee's 

February 28, 2013, submittal: 

• None at this time. 

Project milestone schedule through completion of installation and testing: 

• A project milestone schedule will be provided with the overall integrated plan. 

Implementation of the order will be completed for Palisades Nuclear Plant prior to 

startup from refueling outage 1 R24 (scheduled Spring 2015). 

This letter contains no new regulatory commitments. 
PNP 2012-091 

Page 3 

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

October 25,2012. 

cc: U. S. Nuclear Regulatory Commission 

Attn: Director, Office of Nuclear Reactor Regulation 

One White Flint North 

11555 Rockville Pike 

Rockville, MD 20852 

U. S. Nuclear Regulatory Commission 

Attn: Mac Chawla, Project Manager, Palisades 

1155 Rockville Pike 

Rockville, MD 20852 

U. S. Nuclear Regulatory Commission 

Attn: Region III Administrator 

2443 Warrenville Rd Suite 210 

Lisle, IL 60532-4352 

U. S. Nuclear Regulatory Commission 

Attn: Resident Inspector, Palisades 

27880 Blue Star Highway 

Covert, MI 49043 

U. S. Nuclear Regulatory Commission 

Attn: Robert J. Fretz Jr. 

OWFN, Mailstop # 4A15A 

11555 Rockville Pike 

Rockville, MD 20852-2378 

U. S. Nuclear Regulatory Commission 

Attn: Robert L. Dennig 

OWFN, Mailstop # 10E1 

11555 Rockville Pike 

Rockville, MD 20852-2378 
PNP 2012-091 

Page 4 

U. S. Nuclear Regulatory Commission 

Attn: Ms. Jessica A. Kratchman 

OWFN, Mailstop # 902 

11555 Rockville Pike 

Rockville, MO 20852-2378 

U. S. Nuclear Regulatory Commission 

Attn: Mr. Eric E. Bowman 

OWFN, Mailstop # 12020 

11555 Rockville Pike 

Rockville, MO 20852-2378 

U. S. Nuclear Regulatory Commission 

Attn: Ms. Eileen M. McKenna 

TWFN, Mailstop # 1005 

11555 Rockville Pike 

Rockville, MO 20852-2378