• Entergy 

Entergy Nuclear'Operatlons, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PNP 2013-064 

August 28, 2013 

Tel 269 7642000 

Anthony J. Vitale 

Site Vice President 

U.S. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

SUBJECT: Palisades Nuclear Plant First Six-Month 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 No. 50-255 

License No. DPR-20 

REFERENCES: 1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard 

to Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events, dated March 12, 2012 (ADAMS Accession No. 

12054A736) 

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 No. 

ML 12229A174) 

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

Implementation Guide, Revision 0, dated August 2012 (ADAMS 

Accession No. ML 12242A378) 

4. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2012-091, 

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), dated October 25, 2012 (ADAMS Accession No. 

ML 12300A065 

5. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-010, 

Overall Integrated Plan 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), dated February 28,2013 
PNP 2013-064 

Page 2 of 2 

Dear Sir or Madam: 

On March 12,2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 

1) to Entergy Nuclear Operations, Inc. (ENO). Reference 1 was immediately effective and 

directs ENO to develop, implement, and maintain guidance and strategies to maintain or 

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

beyond-design-basis external event. 

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

final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section 

IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 1 

(Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 

provided the Palisades Nuclear Plant (PNP) initial status report regarding mitigation 

strategies. Reference 5 provided the PNP overall integrated plan. 

Reference 1 requires submission of a status report at six-month intervals following submittal 

of the overall integrated plan. Reference 3 provides direction regarding the content of the 

status reports. The purpose of this letter is to provide the first six-month status report 

pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in 

implementing the requirements of Reference 1. The attachment provides an update of 

milestone accomplishments, including any changes to the compliance method, schedule, or 

need for relief and the basis, if any. 

This letter contains no new commitments and no revised commitments. 

I declare under penalty of perjury that the foregoing is true and correct; executed on 

August 28,2013. 

Sincerely, 

ajv/jse 

Attachment: Palisades Nuclear Plant First Six-Month 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) 

cc: Office Director, NRR, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
ATTACHMENT 

Palisades Nuclear Plant First Six-Month 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) 

1 Introduction 

Entergy Nuclear Operations, Inc. (ENO) developed for Palisades Nuclear Plant (PNP) an 

overall integrated plan (Reference 1), which documented the diverse and flexible strategies 

(FLEX), in response to Reference 2. This attachment provides an update of milestone 

accomplishments since submittal of the overall integrated plan, including any changes to the 

compliance method, schedule, or need for relief/relaxation and the basis, if any. 

2 Milestone Accomplishments 

The following milestone(s) have been completed since the development of the Overall 

Integrated Plan (Reference 1), and are current as of July 31, 2013. 

None. 

3 Milestone Schedule Status 

The following provides an update to Attachment 2 of the overall integrated plan. It provides 

the activity status of each item, and whether the expected completion date has changed. The 

dates are planning dates subject to change as design and implementation details are 

developed. 

• FLEX Strategy Evaluation 

The FLEX Strategy Evaluation is underway. The milestone target completion date has been 

changed to December 2013. This new milestone target completion date does not impact the 

Order implementation date. 

• Modifications Evaluation 

The Modifications Evaluation is underway. The milestone target completion date has been 

changed to January 2014. This new milestone target date does not impact the Order 

implementation date. 

• N-1 Walkdown 

The N-1 Walkdown milestone date was changed to February 2014. This engineering design 

walkdown was to coincide with the refueling outage prior to the implementation outage. The 

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date of this refueling outage. has"changect/sna is' now' scheduled to end in F.ebruary:201'4:· 

This new milestone target completion date does not impact the Order implementation date. 

• Implementation Outage 

The Implementation Outage milestone target completion date changed to October 2015. 

This is the outage that wi" implement FLEX modificatior:ls, which require the plant to be in a 

shutdown mode. The date of this refueling outage has changed and is now scheduled to end 

in October 2015. This new milestone target date does not impact the Order implementation 

date. 

• Purchase and Procure 

The Purchase and Procure milestone date changed to June 2014 to better align with the 

Design Engineering milestone, which wi" determine the specific equipment required. This 

new milestone target completion date does not impact the Order implementation date. 

• Develop Strategies with Regional Response Center 

The Develop Strategies with Regional Response Center (RRC) milestone date was changed 

to January 2015. This new milestone target completion date does not impact the Order 

implementation date. 

• Insta" Off-Site Delivery Station (If Necessary) 

The Insta" Off-Site Delivery Station milestone date was changed to October 2015. This 

milestone date was revised due to a change in the 2015 refueling outage schedule, which 

changed from the Spring of 2015 to the Fa" of 2015. This new milestone target completion 

date does not impact the Order implementation date. 

• Create Palisades FLEX Support Guideline 

The Create Palisades FLEX Support Guideline (FSG) milestone date was changed to March 

2015. This milestone date was revised due to a change in the 2015 refueling outage 

schedule, which changed from the Spring of 2015 to the Fa" of 2015. This new milestone 

target completion date does not impact the Order implementation date. 

• Create Maintenance Procedures 

The Create Maintenance Procedures milestone date was changed to March 2015. This 

milestone date was revised due to a change in the 2015 refueling outage schedule, which 

changed from the Spring of 2015 to the Fa" of 2015. This new milestone target completion 

date does not impact the Order implementation date. 

• Develop Training Plan 

The Develop Training Plan milestone date was changed to June 2015. This milestone date 

was revised due to a change in the 2015 refueling outage schedule, which changed from the 

Spring of 2015 to the Fa" of 2015. This new milestone target completion date does not 

impact the Order implementation date. 

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• Training Complete 

The Training Complete milestone date was changed to September 2015. This milestone 

date was revised due to a change in the 2015 refueling outage schedule, which changed 

from the Spring of 2015 to the Fall of 2015. This new milestone target completion date does 

not impact the Order implementation date. .' 

• ValidationlDemonstration , 

A FLEX strategy Validation/Demonstration target completion date has been added to the 

milestone listing. The validation/demonstration will be completed October 2015 following 

FLEX modification implementation. 

• Submit Completion Report 

The Submit Completion Report target completion date was changed to coincide with the 

implementation Outage milestone date of October 2015. This new milestone target date 

does not impact the Order implementation date. 

Target Revised 

Target Milestone Completion Activity Status 

Date Completion 

Date 

Submit Overall Integrated Feb 2013 Complete Implementation Plan 

6 Month Status Updates 

Update 1 Aug 2013 Complete 

Update 2 Feb 2014 Not Started 

Update 3 Aug 2014 Not Started 

Update 4 Feb 2015 Not Started 

Update 5 Aug 2015 Not Started 

FLEX Strategy Evaluation Apr 2013 Started Dec 2013 

Perform Staffing Analysis Dec 2013 Started 

Modifications 

Modifications Evaluation Jun 2013 Started Jan 2014 

Engineering and Implementation 

N-1 Walkdown Nov 2013 Not Started Feb 2014 

Design Engineering May 2014 Started 

Page 3 of 7 
Target Revised 

Target Milestone Completion Activity Status 

Date Completion 

Date 

Implementation Outage Mar 2015 Not Started Oct 2015 

On-site FLEX Equipment 

Purchase and Procure Dec 2013 Not Started Jun 2014 

Off-site FLEX Equipment 

Develop Strategies with RRC Nov 2013 Started Jan 2015 

Install Off-Site Delivery Station May 2015 Not Started Oct 2015 (If Necessary) 

Procedures 

Pressurized Water Reactor 

Owners Group (PWROG) 

issues Nuclear Steam Supply Jun 2013 Complete 

System (NSSS)-Specific 

Guidelines 

Create Palisades FLEX FSG Oct 2014 Not Started Mar 2015 

Create Maintenance Procedures Oct 2014 Not Started Mar 2015 

Training 

Develop Training Plan Jan 2015 Not Started Jun 2015 

Training Complete Apr2015 Not Started Sept 2015 

Validation I Demonstration Oct 2015 Not Started 

Submit Completion Report May 2015 Not Started 

Oct 2015 

4 Changes to Compliance Method 

There are no changes to the compliance method as documented in the overall integrated 

plan (Reference 1). 

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation 

ENO expects to comply with the order implementation date and no relief/relaxation is required 

at this time. 

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6 Open Items from Overall Integrated Plan and Draft Safety 

Evaluation 

The following tables provide a summary of the open items documented in the overall 

integrated plan or the Draft Safety Evaluation, and the status of each item. 

Overall Integrated Plan Open Item Status 

011 . Perform analysis on Palisades' susceptibility to soil Started 

liquefaction and potential consequences on the FLEX 

implementation plan. 

012. Develop Phase 3 deployment strategy with Started 

correspondence with the RRC. 

013. Evaluate the need to missile protect primary system Started 

makeup storage tank (T-81) and other external tanks. 

014. Select the location of FLEX equipment storage Started 

facility. 

015. Perform seismic evaluation of turbine-driven Started 

auxiliary feedwater pump (TDAFWP) driver K-8. 

016. Evaluate strategies to extend battery coping time. Started 

017. Evaluate sources of non-borated water in addition Started 

to condensate storage tank (T-2) and T-81. 

018. Palisades Probabilistic Risk Assessment (PRA) to Not Started 

provide justification why battery room ventilation is not 

required until 24 hours. 

019. Evaluate the effects of FLEX on security Started 

procedures. 

0110. Evaluate requirements of mobile purification unit Started 

from RRC. 

0111. Evaluate requirements of mobile boration unit Started 

from RRC. 

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Overall Integrated Plan~ Open Item' Status0112. Evaluate methods of venting the fuel handling l Started 

building. 

0113. Evaluate the use of high-efficiency LED lighting. Started 

0114. Perform evaluation to determine if additional Started 

parameters will need to be monitored during FLEX 

activities. 

0115. Perform analysis to ensure survivability of Not Started 

containment. 

0116. Evaluate borated water sources in addition to Started 

safety injection refueling water tank (SIRWT). 

0117. Entergy, for the Palisades site, will negotiate and Complete 

execute a contract with Strategic Alliance for FLEX 

Emergency Response (SAFER) that will meet the 

requirements of NEI 12-06, Section 12. 

0118. Evaluate a location to install a tee in the service Not Started 

wa'ter system to allow the ultimate heat sink (UHS) 

FLEX pump to provide cooling. 

0119. Evaluate the use of lake water to cool the steam Not Started 

generators during an extended loss of ac power (ELAP). 

0120. Evaluate time until primary coolant system (PCS) Started 

makeup is necessary in Modes 5 & 6. 

0121. Evaluate connection to ensure cooling water can Started 

be provided for containment air fans. 

0122. Evaluate the robustness of the charging pumps. Started 

Draft Safety Evaluation Open Item Status 

None. 

Page 6 of 7 
7 Potential Draft Safety Evaluation Impacts 

The Draft Safety Evaluation has not been issued at this time. 

8 References 

The following references support the updates to the Overall Integrated Plan described in this 

attachment. 

1. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-010, Overall 

Integrated Plan 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), dated February 28,2013 

2. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated 

March 12, 2012 (ADAMS Accession No. ML 12054A736). 

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