Entergy Nuclear Operations, Inc.

E’nteigjr Highway

Covert, Ml 49043-9530

Tel 269 764 2000

Anthony J. Vitale

Site Vice President

PNP 2014-011

February 28, 2014

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

11555 Rockville Pike

Rockville, MD 20852

SUBJECT: Palisades Nuclear Plant Second 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-1 2-049, Order Modifying Licenses with Regard

to Requirements for Mitigation Strategies for Beyond-Design-Basis

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

1 2054A736)

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.

ML12229A174)

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

implementation Guide, Revision 0, dated August 2012 (ADAMS

Accession No. ML1 2242A378)

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.

ML1 2300A065

5. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-01 0,

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

• Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PNP 2014-011 

Tel 269 7642000 

Anthony J. Vitale 

Site Vice President 

February 28, 2014 

u.s. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

SUBJECT: Palisades Nuclear Plant Second 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 8eyond-Design-8asis 

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 8eyond-Design-8asis 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 8eyond-Design-8asis 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 8eyond-Design-8asis External Events (Order Number 

EA-12-049), dated February 28,2013 
PNP 2014-011

Page 2 of 2

6. Entergy Nuclear Operation, Inc. (ENO) letter to NRC, PNP 201 3-064,

Pailsades 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), dated August 28, 2013

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. Reference 6 provided the first six-month status report. The purpose of this

letter is to provide the second 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

February 28, 2013.

Attachment: Palisades Nuclear Plant Second 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 Ill, USNRC

Project Manager, Palisades, USNRC

Resident Inspector, Palisades, USNRC

Sincerely,

ajv/jse

PNP 2014-011 

Page 2 of 2 

6. Entergy Nuclear Operation, Inc. (ENO) letter to NRC, PNP 2013-064, 

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), dated August 28,2013 

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 NEI12-06, 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. Reference 6 provided the first six-month status report. The purpose of this 

letter is to provide the second 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 

February 28, 2013. 

Sincerely, 

ajv/jse 

Attachment: Palisades Nuclear Plant Second 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 Second 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-1 2-049)

1 Introduction

Entergy Nuclear Operations, Inc. (END) 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 last status report (Reference 3), 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 July 31, 2013, and are current as of

January 31, 2014.

• First Six-Month Status Report — August 2013

• Second Six-Month Status Report — Complete with submission of this document in

February 2014

• FLEX Strategy Evaluation — January 2014

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.

• Perlorm Staffing Analysis

The Perform Staffing Analysis milestone completion date has been changed to April 2014.

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

• Modifications Evaluation

The Modifications Evaluation milestone target completion date has been changed to April

2014. This new milestone target completion date does not impact the Order implementation

date.

Page 1 of 10

ATTACHMENT 

Palisades Nuclear Plant Second 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 last status report (Reference 3), 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 July 31, 2013, and are current as of 

January 31,2014. 

• First Six-Month Status Report - August 2013 

• Second Six-Month Status Report - Complete with submission of this document in 

February 2014 

• FLEX Strategy Evaluation - January 2014 

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. 

• Perform Staffing Analysis 

The Perform Staffing Analysis milestone completion date has been changed to April 2014. 

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

• Modifications Evaluation 

The Modifications Evaluation milestone target completion date has been changed to April 

2014. This new milestone target completion date does not impact the Order implementation 

date. 

Page 1 of 10 
Target Revised Target

Milestone Completion Activity Status Completion

Date* Date

Submit Overall Integrated Feb 2013 Complete Implementation Plan

Six-Month Status Updates

Update 1 Aug 2013 Complete

Update 2 Feb 2014 Complete

Update 3 Aug 2014 Not Started

Update 4 Feb 2015 Not Started

Update 5 Aug 2015 Not Started

FLEX Strategy Evaluation Jan 2014 Complete

Perform Staffing Analysis Dec 2013 Started Apr 2014

Modifications

Modifications Evaluation Jan 2014 Started Apr 2014

Engineering and Implementation

N-i Walkdown Feb 2014 Started

Design Engineering May 2014 Started

Implementation Outage Oct 2015 Not Started

On-site FLEX Equipment

Purchase and Procure Jun 2014 Started

Off-site FLEX Equipment

Develop Strategies with RRC Jan 2015 Started

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

Procedures

Pressurized Water Reactor Owners

Group (PWROG) issues Nuclear Jun 2013 Complete Steam Supply System (NSSS)

Specific_Guidelines

Create PNP FLEX FSG Mar 2015 Not Started

Create Maintenance Procedures Mar 2015 Not Started

Training

Develop Training Plan Jun 2015 Not Started

Training Complete Sept 2015 Not Started

Validation I Demonstration Oct 2015 Not Started

Submit Completion Report Oct 2015 Not Started

*Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month

status reports

Page 2 of 10

Target Revised Target 

Milestone Completion Activity Status Completion 

Date* Date 

Submit Overall Integrated Feb 2013 Complete Implementation Plan 

Six-Month Status Updates 

Update 1 Aug 2013 Complete 

Update 2 Feb 2014 Complete 

Update 3 Aug 2014 Not Started 

Update 4 Feb 2015 Not Started 

Update 5 Aug 2015 Not Started 

FLEX Strategy Evaluation Jan 2014 Complete 

Perform Staffing Analysis Dec 2013 Started Apr 2014 

Modifications 

Modifications Evaluation Jan 2014 Started Apr 2014 

Engineering and Implementation 

N-1 Walkdown Feb 2014 Started 

Design Engineering May 2014 Started 

I mplementation Outage Oct 2015 Not Started 

On-site FLEX Equipment 

Purchase and Procure Jun 2014 Started 

Off-site FLEX Equipment 

Develop Strategies with RRC Jan 2015 Started 

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

Procedures 

Pressurized Water Reactor Owners 

Group (PWROG) issues Nuclear Jun 2013 Complete Steam Supply System (NSSS)-

Specific Guidelines 

Create PNP FLEX FSG Mar 2015 Not Started 

Create Maintenance Procedures Mar 2015 Not Started 

Training 

Develop Training Plan Jun 2015 Not Started 

Training Complete Sept 2015 Not Started 

Validation I Demonstration Oct 2015 Not Started 

Submit Completion Report Oct 2015 Not Started 

"Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month 

status reports 

Page 2 of 10 
4 Changes to Compliance Method

The following changes are being incorporated to the FLEX strategy for PNP.

1. Overall Integrated Plan (OIP) page 9, item 3 (and other locations of DIP) states the

battery life will be four hours. The four hour battery capacity was determined to

provide insufficient margin for transition to Phase 2. Based on analysis and planning

for a deeper load shed, the installed battery capacity will be extended to eight hours

(see Open Item 016). Therefore, the time at which a portable FLEX generator is

required to be deployed and operational has been extended from hour 4 to hour 8

based on battery capacity.

2. OIP page 10, item 9 (and other locations of DIP) stated that LC-19 will be repowered

from the portable FLEX generator. This remains the primary strategy to provide

power to battery chargers. However, Load Center 20 will also be modified similar to

Load Center 19 to provide diverse connection locations to the battery chargers.

3. QIP page 11, item 10 (and other locations of OIP) stated that a FLEX portable

transfer pump will be used to refill the CST. The Phase 2 core cooling strategy has

changed such that the CST refill will not be used. Instead inventory for feeding the

steam generators will be provided by the FLEX portable transfer pump directly to the

main feed water (MFW) system piping or the auxiliary feed water (AFW) system

piping via hose connections, thereby bypassing the CST.

4. DIP page 11, item 10 (and other locations of DIP) requires commencement of

deployment of a portable FLEX pump two hours after the event such that it can be

operational four hours after the event. This was based on the limited protected

inventory of the condensate storage tank (CST) and the primary system makeup

storage tank (T-81). Additional inventory in the CST and T-81 will now be protected

(see Open Item 013) which increases the volume available for Phase 1 of the

beyond-design-basis external event (BDBEE). Therefore, the time at which the FLEX

pump is required to be deployed and operational has been delayed from hour 4 to

hour 8 based on CST and T-81 protected inventory. Additionally, the strategy of

refilling the CST has changed such that the CST refill will not be used. Instead

inventory for feeding the steam generators will be provided directly to the main feed

water (MFW) system piping or the auxiliary feed water (AFW) system piping via hose

connections, thereby bypassing the CST (see Open Item 017).

5. DIP page 11, item 14 (and other locations of DIP) credits the battery room exhaust

fans for removal of hydrogen from the battery rooms. It has been determined that the

battery room exhaust fans are not robust and cannot be credited. Therefore a new

strategy developed for control of hydrogen will employ the use of portable fans for

ventilation in battery rooms. Also see Open Item 018.

6. OIP page 11, item 15 (and other locations of DIP) credits the volume control tank

(VCT) and safety injection refueling water tank (SIRWT) as borated sources of water

for primary coolant system (PCS) inventory and reactivity control. However, it has

been determined that the VCT and SIRWT are not robust for all applicable external

hazards. Therefore the VCT and SIRWT are no longer the credited sources of

borated water. Concentrated boric acid storage tanks (T-53A and T-53B) will now be

credited as the borated water sources for these functions early in Phase 2. Later in

Page 3 of 10

4 Changes to Compliance Method 

The following changes are being incorporated to the FLEX strategy for PNP. 

1. Overall Integrated Plan (OIP) page 9, item 3 (and other locations of OIP) states the 

battery life will be four hours. The four hour battery capacity was determined to 

provide insufficient margin for transition to Phase 2. Based on analysis and planning 

for a deeper load shed, the installed battery capacity will be extended to eight hours 

(see Open Item 016). Therefore, the time at which a portable FLEX generator is 

required to be deployed and operational has been extended from hour 4 to hour 8 

based on battery capacity. 

2. OIP page 10, item 9 (and other locations of DIP) stated that LC-19 will be repowered 

from the portable FLEX generator. This remains the primary strategy to provide 

power to battery chargers. However, Load Center 20 will also be modified similar to 

Load Center 19 to provide diverse connection locations to the battery chargers. 

3. OIP page 11, item 10 (and other locations of OIP) stated that a FLEX portable 

transfer pump will be used to refill the CST. The Phase 2 core cooling strategy has 

changed such that the CST refill will not be used. Instead inventory for feeding the 

steam generators will be provided by the FLEX portable transfer pump directly to the 

main feed water (MFW) system piping or the auxiliary feed water (AFW) system 

piping via hose connections, thereby bypassing the CST. 

4. OIP page 11, item 10 (and other locations of OIP) requires commencement of 

deployment of a portable FLEX pump two hours after the event such that it can be 

operational four hours after the event. This was based on the limited protected 

inventory of the condensate storage tank (CST) and the primary system makeup 

storage tank (T-81). Additional inventory in the CST and T-81 will now be protected 

(see Open Item 013) which increases the volume available for Phase 1 of the 

beyond-design-basis external event (BDBEE). Therefore, the time at which the FLEX 

pump is required to be deployed and operational has been delayed from hour 4 to 

hour 8 based on CST and T-81 protected inventory. Additionally, the strategy of 

refilling the CST has changed such that the CST refill will not be used. Instead 

inventory for feeding the steam generators will be provided directly to the main feed 

water (MFW) system piping or the auxiliary feed water (AFW) system piping via hose 

connections, thereby bypassing the CST (see Open Item 017). 

5. OIP page 11, item 14 (and other locations of OIP) credits the battery room exhaust 

fans for removal of hydrogen from the battery rooms. It has been determined that the 

battery room exhaust fans are not robust and cannot be credited. Therefore a new 

strategy developed for control of hydrogen will employ the use of portable fans for 

ventilation in battery rooms. Also see Open Item 018. 

6. OIP page 11, item 15 (and other locations of DIP) credits the volume control tank 

(VCT) and safety injection refueling water tank (SIRWT) as borated sources of water 

for primary coolant system (PCS) inventory and reactivity control. However, it has 

been determined that the VCT and SIRWT are not robust for all applicable external 

hazards. Therefore the VCT and SIRWT are no longer the credited sources of 

borated water. Concentrated boric acid storage tanks (T-53A and T-53B) will now be 

credited as the borated water sources for these functions early in Phase 2. Later in 

Page 3 of 10 
Phase 2 (>24 hours), the boric acid batching tank (T-77) will be used to batch

required borated water inventory. Also see Open Item 0116.

7. DIP page 12, item 16 states that spent fuel pool (SFP) equipment (hoses and monitor

nozzles) will be deployed at hour 18 to prevent SEP level from dropping below the

level of 15 feet above the fuel at hour 20.93. Under worst case conditions it is

estimated that boiling could occur beginning at approximately 5.6 hours. Therefore

operators would be required to enter the SFP area under potentially onerous

conditions. It was determined that in order to protect personnel from the need to enter

the SFP area after it is already boiling that actions should be taken for deployment of

SEP cooling equipment (hoses and monitor nozzles) prior to the start of boiling. The

action will now be taken at approximately five hours after event initiation and prior to

SEP boiling in order to mitigate potential habitability concerns after boiling.

8. OIP page 12, item 21 (and other locations of OIP) credit a mobile water purification

unit (and/or other large regional response center (RRC) equipment) 24 hours after the

event. This timing was determined to be unlikely and unsupported by the RRC for

large equipment such as purification units, 4160 V diesel generators, and boration

units. Therefore the purification units will not be credited until 72 hours after the

event.

9. OIP page 18, in the section for PWR Installed Equipment Phase 1, it is stated that the

turbine driven auxiliary feedwater (TDAFW) pump is not credited for seismic events

because the turbine driver is not seismically qualified. The TDAEW system (including

the turbine driver) has now been qualified as seismically robust and is credited for all

external events. See Open Item 015 in this report for additional information.

10. DIP page 19, under Steam Generators Available for Cooling (Modes 1-4), states that

a modification will be required to provide for remote manual operation of the ADVs to

begin cooling down the plant at hour 2. The modification selected, and which will

allow for the remote manual operation of the ADVs, is the installation of backup

nitrogen bottles to last through Phase 1 and connection point for an air compressor to

be connected for Phase 2.

11. OIP page 19, under Key Reactor parameters (and other locations of DIP) the level

indications for tank T-81 and SIRWT are credited. Because the CST and T-81 are

cross-tied, it has been determined that the level indication for the CST is sufficient to

indicate the available inventory in both tanks. Therefore level indication for T-81 is

redundant and is not required. SIRWT level indication is not required because the

tank is no longer credited.

12. DIP page 62 (and other locations of DIP) states use of multiple ELEX generators.

PNP has determined that it is preferable to use only one FLEX generator in the PNP

strategy. This FLEX generator will be sufficiently sized to carry all the loads that are

planned for use in the FLEX strategy.

13. During analysis of site seismic capabilities it was determined that PNP is susceptible

to soil liquefaction. Therefore new storage locations are being developed and

Attachment 3 of DIP will be updated for storage, staging and routing. Also see Open

Item OIl.

Page 4 of 10

Phase 2 (> 24 hours), the boric acid batching tank (T-77) will be used to batch 

required borated water inventory. Also see Open Item 0116. 

7. 01 P page 12, item 16 states that spent fuel pool (SFP) equipment (hoses and monitor 

nozzles) will be deployed at hour 18 to prevent SFP level from dropping below the 

level of 15 feet above the fuel at hour 20.93. Under worst case conditions it is 

estimated that boiling could occur beginning at approximately 5.6 hours. Therefore 

operators would be required to enter the SFP area under potentially onerous 

conditions. It was determined that in order to protect personnel from the need to enter 

the SFP area after it is already boiling that actions should be taken for deployment of 

SFP cooling equipment (hoses and monitor nozzles) prior to the start of boiling. The 

action will now be taken at approximately five hours after event initiation and prior to 

SFP boiling in order to mitigate potential habitability concerns after boiling. 

8. OIP page 12, item 21 (and other locations of OIP) credit a mobile water purification 

unit (and/or other large regional response center (RRC) equipment) 24 hours after the 

event. This timing was determined to be unlikely and unsupported by the RRC for 

large equipment such as purification units, 4160 V diesel generators, and boration 

units. Therefore the purification units will not be credited until 72 hours after the 

event. 

9. OIP page 18, in the section for PWR Installed Equipment Phase 1, it is stated that the 

turbine driven auxiliary feedwater (TDAFW) pump is not credited for seismic events 

because the turbine driver is not seismically qualified. The TDAFW system (including 

the turbine driver) has now been qualified as seismically robust and is credited for all 

external events. See Open Item 015 in this report for additional information. 

10. OIP page 19, under Steam Generators Available for Cooling (Modes 1-4), states that 

a modification will be required to provide for remote manual operation of the ADVs to 

begin cooling down the plant at hour 2. The modification selected, and which will 

allow for the remote manual operation of the ADVs, is the installation of backup 

nitrogen bottles to last through Phase 1 and connection point for an air compressor to 

be connected for Phase 2. 

11. OIP page 19, under Key Reactor parameters (and other locations of OIP) the level 

indications for tank T-81 and SIRWT are credited. Because the CST and T-81 are 

cross-tied, it has been determined that the level indication for the CST is sufficient to 

indicate the available inventory in both tanks. Therefore level indication for T-81 is 

redundant and is not required. SIRWT level indication is not required because the 

tank is no longer credited. 

12. OIP page 62 (and other locations of OIP) states use of multiple FLEX generators. 

PNP has determined that it is preferable to use only one FLEX generator in the PNP 

strategy. This FLEX generator will be sufficiently sized to carry all the loads that are 

planned for use in the FLEX strategy. 

13. During analysis of site seismic capabilities it was determined that PNP is susceptible 

to soil liquefaction. Therefore new storage locations are being developed and 

Attachment 3 of OIP will be updated for storage, staging and routing. Also see Open 

Item 011. 

Page 4 of 10 
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation

Overall Integrated Plan Open Item

Dli. Perform analysis on Palisades’

susceptibility to soil liquefaction and potential

consequences on the FLEX implementation

plan.

012. Develop Phase 3 deployment strategy

with correspondence with the RRC.

013. Evaluate the need to missile protect

primary system makeup storage tank (T-81)

and other external tanks.

Started

Preliminary borings were performed on site

and soil liquefaction susceptibility was

identified. Based on this information a set of

FLEX equipment will be stored inside the

protected area (PA) for the seismic event.

The other set of FLEX equipment will be

stored outside of the PA and be protected

against the tornado event. Both locations will

be protected from all other BDBEEs.

Additional planning is under way to address

other impacts to equipment storage and

deployment. See also Change to

Compliance Method Item 13.

Started

Started

The CST volume alone is insufficient to

provide the required inventory, when

considering available on site resources for

SG makeup during Phase 1. Additional

inventory is required and can be provided by

tank T-81. T-81 will be verified/credited as

robust for all applicable external events. As

required, modifications will be implemented

to protect both the CST and primary system

makeup tank for all applicable external

events. See also Change to Compliance

Method Item 4.

Started

Refer to Cli. One set of equipment will be

stored in Sea-Land containers inside the PA

for the Seismic event. An additional set(s) of

equipment will be stored outside the PA in a

structure(s) providing an appropriate level of

protection for the tornado event. Both sets

will be protected against the other applicable

(screened-in) BDBEE external hazards.

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

at this time.

6 Open Items from Overall Integrated Plan and Interim Staff

Evaluation

The following tables provide a summary and status of any open items documented in the

overall integrated plan and any open items or confirmatory items documented in Interim Staff

Evaluation (ISE). A fourth table includes a listing of audit questions and the status of each

item.

Status

014. Select the location of FLEX equipment

storage facility.

Page 5 of 10

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. 

6 Open Items from Overall Integrated Plan and Interim Staff 

Evaluation 

The following tables provide a summary and status of any open items documented in the 

overall integrated plan and any open items or confirmatory items documented in Interim Staff 

Evaluation (ISE). A fourth table includes a listing of audit questions and the status of each 

item. 

Overall Integrated Plan Open Item 

011. Perform analysis on Palisades' 

susceptibility to soil liquefaction and potential 

consequences on the FLEX implementation 

plan. 

012. Develop Phase 3 deployment strategy 

with correspondence with the RRC. 

013. Evaluate the need to missile protect 

primary system makeup storage tank (T-81) 

and other external tanks. 

014. Select the location of FLEX equipment 

storage facility. 

Status 

Started 

Preliminary borings were performed on site 

and soi/liquefaction susceptibility was 

identified. Based on this information a set of 

FLEX equipment will be stored inside the 

protected area (PA) for the seismic event. 

The other set of FLEX equipment will be 

stored outside of the PA and be protected 

against the tornado event. Both locations will 

be protected from all other BDBEEs. 

Additional planning is under way to address 

other impacts to equipment storage and 

deployment. See also Change to 

Compliance Method Item 13. 

Started 

Started 

The CST volume alone is insufficient to 

provide the required inventory, when 

considering available on site resources for 

SG makeup during Phase 1. Additional 

inventory is required and can be provided by 

tank T-81. T-81 will be verified/credited as 

robust for all applicable external events. As 

required, modifications will be implemented 

to protect both the CST and primary system 

makeup tank for all applicable external 

events. See also Change to Compliance 

Method Item 4. 

Started 

Refer to 011. One set of equipment will be 

stored in Sea-Land containers inside the PA 

for the Seismic event. An additional set(s) of 

equipment will be stored outside the PA in a 

structure(s) providing an appropriate level of 

protection for the tornado event. Both sets 

will be protected against the other applicable 

(screened-in) BDBEE external hazards. 

Page 5 of 10 
Overall Integrated Plan Open Item Status

015. Perform seismic evaluation of turbine- Started

driven auxiliary feedwater pump (TDAFWP) Seismic evaluation documents the seismic driver K-8. qualification of the pump and associated

components. The TDAFW pump is qualified

with the exception of an outlier related to a

check for bolt tightness. Bolt tightness on

the pump is being performed under W0#

372138 and documented under EC 46465.

See also Change to Compliance Method

Item 9.

016. Evaluate strategies to extend battery Started

coping time. The battery load shedding strategy is

currently being revised to extend the battery

coping time through shedding loads in

addition to those identified in the station

blackout procedure. Preliminary results

indicate a coping time of at least 8 hours for

the installed batteries accompanying the

expected deep load shed list. See also

Change to Compliance Method Item 1.

017. Evaluate sources of non-borated water Complete/Closed

in addition to condensate storage tank (T-2) After depletion of T-2 and T-81, makeup to and T81. the SGs will be from a portable pump with

the credited suction source being Lake

Michigan. Modifications to credit sources of

non-borated water for sources other than T-2

and T-81 were determined to not be

required.

018. Palisades Probabilistic Risk Assessment Complete/Closed

(PRA) to provide justification why battery Palisades PRA provided multiple evaluations

room ventilation is not required until 24 hours. for battery room hydrogen generation. It was

determined that supplemental ventilation is

required approximately 1.5 hours after

charging begins for removal of hydrogen.

Ventilation is not required for Phase 2

temperature control. This supplemental

ventilation has been included in the

Palisades strategy. See also Change to

Compliance Method Item 5.

019. Evaluate the effects of FLEX on security Started

procedures. The security plan/program will be updated to

correspond to FLEX procedures.

0110. Evaluate requirements of mobile Complete/Closed

purification unit from RRC. It was determined that the 250 gpm RRC

demineralized water treatment unit is

preferred over the 100 gpm RRC reverse

osmosis unit in order to support SG makeup

and provide makeup to the RRC mobile

Page 6 of 10

Overall Integrated Plan Open Item Status 

015. Perform seismic evaluation of turbine- Started 

driven auxiliary feedwater pump (TDAFWP) Seismic evaluation documents the seismic 

driver K-8. qualification of the pump and associated 

components. The TDAFW pump is qualified 

with the exception of an outlier related to a 

check for bolt tightness. Bolt tightness on 

the pump is being performed under WO# 

372138 and documented under EC 46465. 

See also Change to Compliance Method 

Item 9. 

016. Evaluate strategies to extend battery Started 

coping time. The battery load shedding strategy is 

currently being revised to extend the battery 

coping time through shedding loads in 

addition to those identified in the station 

blackout procedure. Preliminary results 

indicate a coping time of at least 8 hours for 

the installed batteries accompanying the 

expected deep load shed list. See also 

Change to Compliance Method Item 1. 

017. Evaluate sources of non-borated water Complete/Closed 

in addition to condensate storage tank (T-2) After depletion of T-2 and T-81 , makeup to 

and T-81. the SGs will be from a portable pump with 

the credited suction source being Lake 

Michigan. Modifications to credit sources of 

non-borated water for sources other than T-2 

and T-81 were determined to not be 

required. 

018. Palisades Probabilistic Risk Assessment Complete/Closed 

(PRA) to provide justification why battery Palisades PRA provided multiple evaluations 

room ventilation is not required until 24 hours. for battery room hydrogen generation. It was 

determined that supplemental ventilation is 

required approximately 1.5 hours after 

charging begins for removal of hydrogen. 

Ventilation is not required for Phase 2 

temperature control. This supplemental 

ventilation has been included in the 

Palisades strategy. See also Change to 

Compliance Method Item 5. 

019. Evaluate the effects of FLEX on security Started 

procedures. The security plan/program will be updated to 

correspond to FLEX procedures. 

0110. Evaluate requirements of mobile Complete/Closed 

purification unit from RRC. It was determined that the 250 gpm RRC 

demineralized water treatment unit is 

preferred over the 100 gpm RRC reverse 

osmosis unit in order to support SG makeup 

and provide makeup to the RRC mobile 

Page 6 of 10 
Overall Integrated Plan Open Item Status

boration unit.

011 1. Evaluate requirements of mobile Complete/Closed

boration unit from RRC. The required flow rate of borated water for

PNP is a maximum of 58.3 gpm.

0112. Evaluate methods of venting the fuel Complete/Closed

handling building. The strategy for venting the fuel handling

building will be to open an existing double

leaf door/hatch on the roof of the building.

0113. Evaluate the use of high-efficiency LED Complete/Closed

lighting. The use of high-efficiency LED lighting has

been evaluated for its impact to battery

coping time and control room heat loads.

LED lighting would have minimal impact and

is not required or recommended.

0114. Perform evaluation to determine if Complete/Closed

additional parameters will need to be In addition to NEI 12-06, PWROG FLEX monitored during FLEX activities, guidance was reviewed for key parameter

monitoring. The NEI 12-06 and PWROG

guidance regarding recommended

instrumentation has been incorporated into

the FLEX strategy and the power supply for

these instruments evaluated. All the credited

instruments are powered by battery/DC

buses and available throughout the event.

0115. Perform analysis to ensure survivability Started

of containment. Containment analysis has been completed

using the Modular Accident Analysis

Program (MAAP) and is being reviewed for

owner’s acceptance. Preliminary results of

this analysis show containment design

parameters will not be exceeded for the

at-power scenario (i.e., event initiating in

Mode 1). For the most conservative

shutdown scenario (i.e., Mode 5 reduced

inventory), preliminary results of the analysis

show that actions will be required to prevent

exceeding the design limits of containment.

0116. Evaluate borated water sources in Complete/Closed

addition to safety injection refueling water All additional sources of borated water were tank (SIRWT). evaluated for use following a BDBEE. The

concentrated boric acid storage tanks (T-53A

and T-53B) are the credited source of

borated water. These tanks are analyzed to

provide sufficient borated water for greater

than 24 hours. After 24 hours, borated water

will be batched as necessary for inventory

control using the boric acid batching tank

T-77. See also Change to Compliance

Page 7 of 10

Overall Integrated Plan Open Item Status 

boration unit. 

0111. Evaluate requirements of mobile Complete/Closed 

boration unit from RRC. The required flow rate of borated water for 

PNP is a maximum of 58.3 gpm. 

0112. Evaluate methods of venting the fuel Complete/Closed 

handling building. The strategy for venting the fuel handling 

building will be to open an existing double 

leaf door/hatch on the roof of the building. 

0113. Evaluate the use of high-efficiency LED Complete/Closed 

lighting. The use of high-efficiency LED lighting has 

been evaluated for its impact to battery 

coping time and control room heat loads. 

LED lighting would have minimal impact and 

is not required or recommended. 

0114. Perform evaluation to determine if Complete/Closed 

additional parameters will need to be In addition to NE112-06, PWROG FLEX 

monitored during FLEX activities. guidance was reviewed for key parameter 

monitoring. The NE112-06 and PWROG 

guidance regarding recommended 

instrumentation has been incorporated into 

. the FLEX strategy and the power supply for 

these instruments evaluated. All the credited 

instruments are powered by battery/DC 

buses and available throughout the event. 

0115. Perform analysis to ensure survivability Started 

of containment. Containment analysis has been completed 

using the Modular Accident Analysis 

Program (MAAP) and is being reviewed for 

owner's acceptance. Preliminary results of 

this analysis show containment design 

parameters will not be exceeded for the 

at-power scenario (Le., event initiating in 

Mode 1). For the most conservative 

shutdown scenario (Le., Mode 5 reduced 

inventory), preliminary results of the analysis 

show that actions will be required to prevent 

exceeding the design limits of containment. 

0116. Evaluate borated water sources in Complete/Closed 

addition to safety injection refueling water All additional sources of borated water were 

tank (SIRWT). evaluated for use following a BDBEE. The 

concentrated boric acid storage tanks (T-53A 

and T -53 B) are the credited source of 

borated water. These tanks are analyzed to 

provide sufficient borated water for greater 

than 24 hours. After 24 hours, borated water 

will be batched as necessary for inventory 

control using the boric acid batching tank 

T-77. See also Change to Compliance 

Page 7 of 10 
Overall Integrated Plan Open Item Status

Method Item 6.

0117. Entergy, for the Palisades site, will Complete

negotiate and 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 Complete/Closed

the service water system to allow the ultimate Several locations in the service water system heat sink (UHS) FLEX pump to provide were evaluated. A pipe elbow downstream of cooling, service water system (SWS) pump P-7C was

identified as the best location for connecting

a pipe tee to allow flow from the RRC UHS

pump.

0119. Evaluate the use of lake water to cool Started

the steam generators during an extended An analysis has been completed and is being loss of ac power (ELAP). reviewed for owner’s acceptance that

determines the impacts on the steam

generators when using lake water as the

makeup source.

0120. Evaluate time until primary coolant Complete/Closed

system (PCS) makeup is necessary in Modes An evaluation was performed that 5 & 6. documented the time until PCS makeup is

required in shutdown modes. The time when

makeup is required varies greatly depending

on the status of the PCS when the event

occurs (i.e., PCS level, pressure, and

temperature). The most limiting scenario

was found to be such that PCS makeup

could be required as early as one hour after

the event if the PCS is vented and at reduced

inventory. High risk evolutions such as

vented PCS and reduced inventory will be

managed by outage risk planning and

contingency actions such as pre-staging

equipment as discussed in the NRC

endorsed white paper on Shutdown /

Refueling Modes.

0121. Evaluate connection to ensure cooling Complete/Closed

water can be provided for containment air Cooling water flow to the containment air fans. tans is through the service water system

addressed in the status update to Cl 18.

Connection of the RRC supplied FLEX UHS

pump to the SWS will provide the necessary

means/connection for cooling water flow to

the containment air coolers.

0122. Evaluate the robustness of the Complete/Closed

charging pumps. The charging pumps have been evaluated as

robust for seismic events. The pumps are

Page 8 of 10

Overall Integrated Plan Open Item Status 

Method Item 6. 

0117. Entergy, for the Palisades site, will Complete 

negotiate and 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 Complete/Closed 

the service water system to allow the ultimate Several locations in the service water system heat sink (UHS) FLEX pump to provide were evaluated. A pipe elbow downstream of 

cooling. service water system (SWS) pump P-7C was 

identified as the best location for connecting 

a pipe tee to allow flow from the RRC UHS 

pump. 

0119. Evaluate the use of lake water to cool Started 

the steam generators during an extended An analysis has been completed and is being loss of ac power (ELAP). reviewed for owner's acceptance that 

determines the impacts on the steam 

generators when using lake water as the 

makeup source. 

0120. Evaluate time until primary coolant Complete/Closed 

system (PCS) makeup is necessary in Modes An evaluation was performed that 

5&6. documented the time until PCS makeup is 

required in shutdown modes. The time when 

makeup is required varies greatly depending 

on the status of the PCS when the event 

occurs (Le., PCS level, pressure, and 

temperature). The most limiting scenario 

was found to be such that PCS makeup 

could be required as early as one hour after 

the event if the PCS is vented and at reduced 

inventory. High risk evolutions such as 

vented PCS and reduced inventory will be 

managed by outage risk planning and 

contingency actions such as pre-staging 

equipment as discussed in the NRC 

endorsed white paper on Shutdown / 

Refueling Modes. 

0121. Evaluate connection to ensure cooling Complete/Closed 

water can be provided for containment air Cooling water flow to the containment air 

fans. fans is through the service water system 

addressed in the status update to 01 18. 

Connection of the RRC supplied FLEX UHS 

pump to the SWS will provide the necessary 

means/connection for cooling water flow to 

the containment air coolers. 

0122. Evaluate the robustness of the Complete/Closed 

charging pumps. The charging pumps have been evaluated as 

robust for seismic events. The pumps are 

Page 8 of 10 
Page 9 of 10

Overall Integrated Plan Open Item Status

located inside the auxiliary building and

protected against all other external hazards.

Interim Staff Evaluation Open Items

The U.S. Nuclear Regulatory Commission (NRC) has

not issued an Interim Staff Evaluation for Palisades;

therefore, there are no open items for the Interim Staff

Evaluation identified at this time

Status

N/A

Interim Staff Evaluation Confirmatory Items

The NRC has not issued an Interim Staff Evaluation for

Palisades; therefore, there are no confirmatory items

from the Interim Staff Evaluation identified at this time

Status

N//A

Audit Question Open Items Status Completion or Target Date

PAL-002 Closed

PAL-003 Closed

PAL-004 Closed

PAL-007 In progress Aug 2014

PAL-008 In progress Aug 2014

PAL-Oil In progress Aug 2014

PAL-012 In progress Aug 2014

PAL-013 In progress Aug 2014

PAL-0l4 In progress Aug 2014

PAL-015 Closed

PAL-O16 In progress Aug 2014

PAL-0l7 In progress Oct2015

PAL-0i8 In progress Aug 2014

PAL-019 In progress Aug 2014

PAL-020 Closed

PAL-021 In progress Aug 2014

PAL-022 Complete e-Portal updated

PAL-O23 In progress Aug 2014

PAL-024 Closed

PAL-025 In progress Aug 2014

PAL-026 In progress Aug 2014

PAL-027 In progress Aug 2014

PAL-028 In progress Aug 2014

PAL-030 In progress Aug 2014

PAL-033 In progress Aug 2014

PAL-035 In progress Aug 2014

PAL-O36 In progress Oct 2015

PAL-037 In progress Aug 2014

PAL-039 Closed

PAL-04O In progress Oct 2015

PAL-041 Closed

PAL-043 In progress Aug 2014

Overall Integrated Plan Open Item Status 

located inside the auxiliary building and 

protected against all other external hazards. 

Interim Staff Evaluation Open Items Status 

The U.S. Nuclear Regulatory Commission (NRC) has N/A 

not issued an Interim Staff Evaluation for Palisades; 

therefore, there are no open items for the Interim Staff 

Evaluation identified at this time 

Interim Staff Evaluation Confirmatory Items Status 

The NRC has not issued an Interim Staff Evaluation for NIIA 

Palisades; therefore, there are no confirmatory items 

from the Interim Staff Evaluation identified at this time 

Audit Question Open Items Status Completion or Target Date 

PAL-002 Closed 

PAL-003 Closed 

PAL-004 Closed 

PAL-007 In progress Aug 2014 

PAL-008 In progress Aug 2014 

PAL-011 In progress Aug 2014 

PAL-012 In progress Aug 2014 

PAL-013 In progress Aug 2014 .. PAL-014 In progress Aug 2014 

PAL-015 Closed 

PAL-016 In progress Aug 2014 

PAL-017 In progress Oct 2015 

PAL-018 In progress Aug 2014 

PAL-019 In progress Aug 2014 

PAL-020 Closed 

PAL-021 In progress Aug 2014 

PAL-022 Complete e-Portal updated 

PAL-023 In progress Aug 2014 

PAL-024 Closed 

PAL-025 In progress Aug 2014 

PAL-026 In progress Aug 2014 

PAL-027 In progress Aug 2014 

PAL-028 In progress Aug 2014 

PAL-030 In progress Aug 2014 

PAL-033 In progress Aug 2014 

PAL-035 In progress Aug 2014 

PAL-036 In progress Oct 2015 

PAL-037 In progress Aug 2014 

PAL-039 Closed 

PAL-040 In progress Oct 2015 

PAL-041 Closed 

PAL-043 In progress Aug 2014 

Page 9 of 10 
Audit Question Open Items Status Completion or Target Date

PAL-044 In progress Aug 2014

PAL-045 In progress Aug 2014

PAL-046 In progress Aug 2014

PAL-047 In progress Aug 2014

PAL-048 In progress Aug 2014

PAL-049 In progress Aug 2014

PAL-050 In progress Aug 2014

PAL-051 In progress Aug 2014

PAL-053 In progress Aug 2014

PAL-054 In progress Aug 2014

PAL-055 Closed

PAL-057 In progress Aug 2014

PAL-057 In progress Aug 2014

7 Potential Interim Staff Evaluation Impacts

The NRC has not yet issued an interim staff evaluation for PNP; therefore, there are no

potential impacts to the interim staff evaluation identified 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 2013-01 0, 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-1 2-049, Order Modifying Licenses with Regard to

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

March 12, 2012 (ADAMS Accession No. ML12054A736).

3. Entergy Nuclear Operation, Inc. (ENO) letter to NRC, PNP 2013-064, 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), dated August 28,

2013.

Page 10 of 10

Audit Question Open Items Status Completion or Target Date 

PAL-044 In progress Aug 2014 

PAL-04S In progress Aug 2014 

PAL-046 In progress Aug 2014 

PAL-04? In progress Aug 2014 

PAL-048 In progress Aug 2014 

PAL-049 In progress Aug 2014 

PAL-OSO In progress Aug 2014 

PAL-OS 1 In progress Aug 2014 

PAL-OS3 In progress Aug 2014 

PAL-OS4 In progress Aug 2014 

PAL-OSS Closed 

PAL-OS? In progress Aug 2014 

PAL-OS? In progress Aug 2014 

7 Potential Interim Staff Evaluation Impacts 

The NRC has not yet issued an interim staff evaluation for PNP; therefore, there are no 

potential impacts to the interim staff evaluation identified at this time. 

S 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 120S4A?36). 

3. Entergy Nuclear Operation, Inc. (ENO) letter to NRC, PNP 2013-064, 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), dated August 28, 

2013. 

Page 10 of 10