UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

Vice President, Operations 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, Ml 49043-9530 

February 10, 2014 

SUBJECT: PALISADES NUCLEAR PLANT-INTERIM STAFF EVALUATION 

REGARDING OVERALL INTEGRATED PLAN IN RESPONSE TO 

ORDER EA-12-049 (MITIGATION STRATEGIES) (TAC NO. MF0768) 

Dear Sir or Madam: 

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, 

"Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BeyondDesign-Basis External Events" (Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML 12054A736). By letter dated February 28, 2013 (ADAMS 

Accession No. ML 13060A361), Entergy Nuclear Operations, Inc. (Entergy, the licensee) 

submitted its Overall Integrated Plan for Palisades Nuclear Plant in response to Order EA-12-

049. By letter dated August 28, 2013 (ADAMS Accession No. ML 13241A234), Entergy 

submitted a six-month update to the Overall Integrated Plan. 

Based on a review of Entergy's plan, including the six-month update dated August 28, 2013, 

and information obtained through the mitigation strategies audit process, 1 the NRC concludes 

that the licensee has provided sufficient information to determine that there is reasonable 

assurance that the plan, when properly implemented, will meet the requirements of Order 

EA-12-049, at Palisades Nuclear Plant. This conclusion is based on the assumption that the 

licensee will implement the plan as described, including the satisfactory resolution of the open 

and confirmatory items detailed in the enclosed Interim Staff Evaluation (ISE) and Audit Report. 

As discussed in Section 4.0 of the ISE, the open item warranting the greatest attention to 

ensure successful implementation relates to the use of installed charging pumps, instead of 

portable pumps, for primary coolant system makeup. 

1 A description of the mitigation strategies audit process may be found at ADAMS Accession No. ML 13234A503. 
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If you have any questions, please contact Peter Bamford, Mitigating Strategies Project 

Manager, at 301-415-2833, or at peter.bamford@nrc.gov. 

Docket No. 50-255 

Enclosures: 

1. Interim Staff Evaluation 

2. Technical Evaluation Report 

cc w/encl: Distribution via Listserv 

Jeremy S. Bowen, Chief 

Mitigating Strategies Projects Branch 

Mitigating Strategies Directorate 

Office of Nuclear Reactor Regulation 
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

INTERIM STAFF EVALUATION AND AUDIT REPORT BY THE OFFICE OF 

NUCLEAR REACTOR REGULATION 

RELATED TO ORDER EA-12-049 MODIFYING LICENSES 

WITH REGARD TO REQUIREMENTS FOR 

MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 

1.0 INTRODUCTION 

ENTERGY NUCLEAR OPERATIONS, INC 

PALISADES NUCLEAR PLANT 

DOCKET NO. 50-255 

The earthquake and tsunami at the Fukushima Dai-ichi nuclear power plant in March 2011, 

highlighted the possibility that extreme natural phenomena could challenge the prevention, 

mitigation and emergency preparedness defense-in-depth layers. At Fukushima, limitations in 

time and unpredictable conditions associated with the accident significantly challenged attempts 

by the responders to preclude core damage and containment failure. During the events in 

Fukushima, the challenges faced by the operators were beyond any faced previously at a 

commercial nuclear reactor. The U.S. Nuclear Regulatory Commission (NRC) determined that 

additional requirements needed to be imposed to mitigate beyond-design-basis external events 

(BDBEE). Accordingly, by letter dated March 12, 2012, the NRC issued Order EA-12-049, 

"Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BeyondDesign-Basis External Events" [Reference 1]. The order directed licensees to develop, 

implement, and maintain guidance and strategies to maintain or restore core cooling, 

containment, and spent fuel pool (SFP) cooling capabilities in the event of a BDBEE. 

By letter dated February 28, 2013 [Reference 2], Entergy Nuclear Operations, Inc. (Entergy, the 

licensee), provided the Overall Integrated Plan (hereafter referred to as the Integrated Plan) for 

compliance with Order EA-12-049 for Palisades Nuclear Plant (Palisades). The Integrated Plan 

describes the guidance and strategies under development for implementation by Entergy for the 

maintenance or restoration of core cooling, containment, and SFP cooling capabilities following 

a BDBEE, including modifications necessary to support this implementation, pursuant to Order 

EA-12-049. As further required by the order, by letter dated August 28, 2013 [Reference 3], the 

licensee submitted the first six-month status report since the submittal of the Integrated Plan, 

describing the progress made in implementing the requirements of the order. 

Enclosure 1 
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2.0 REGULATORY EVALUATION 

Following the events at the Fukushima Dai-ichi nuclear power plant on March 11, 2011, the 

NRC established a senior-level agency task force referred to as the Near-Term Task Force 

(NTTF). The NTTF was tasked with conducting a systematic and methodical review of the 

NRC's regulations and processes, and with determining if the agency should make 

improvements to these programs in light of the events at Fukushima Dai-ichi. As a result of this 

review, the NTTF developed a comprehensive set of recommendations, documented in 

SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the 

Events in Japan," dated July 12, 2011 [Reference 4]. These recommendations were enhanced 

by the NRC staff following interactions with stakeholders. Documentation of the NRC staff's 

efforts is contained in SECY-11-0124, "Recommended Actions to be Taken without Delay from 

the Near-Term Task Force Report," dated September 9, 2011 [Reference 5] and SECY-11-

0137, "Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons 

Learned," dated October 3, 2011 [Reference 6]. 

As directed by the Commission's Staff Requirement Memorandum (SRM) for SECY-11-0093 

[Reference 7], the NRC staff reviewed the NTTF recommendations within the context of the 

NRC's existing regulatory framework and considered the various regulatory vehicles available to 

the NRC to implement the recommendations. SECY-11-0124 and SECY-11-0137 established 

the NRC staff's prioritization of the recommendations based upon the potential safety 

enhancements. 

After receiving the Commission's direction in SRM-SECY -11-0124 [Reference 8] and 

SRM-SECY-11-0137 [Reference 9], the NRC staff conducted public meetings to discuss 

enhanced mitigation strategies intended to maintain or restore core cooling, containment, and 

SFP cooling capabilities following a BDBEE. At these meetings, the industry described its 

proposal for a Diverse and Flexible Mitigation Capability (FLEX), as documented in the Nuclear 

Energy Institute's (NEI's) letter, dated December 16, 2011 [Reference 10]. FLEX was proposed 

as a strategy to fulfill the key safety functions of core cooling, containment integrity, and spent 

fuel cooling. Stakeholder input influenced the NRC staff to pursue a more performance-based 

approach to improve the safety of operating power reactors than envisioned in NTTF 

Recommendation 4.2, SECY-11-0124, and SECY-11-0137. 

On February 17, 2012, the NRC staff provided SECY-12-0025, "Proposed Orders and Requests 

for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku 

Earthquake and Tsunami," [Reference 11] to the Commission, including the proposed order to 

implement the enhanced mitigation strategies. As directed by SRM-SECY-12-0025 

[Reference 12], the NRC staff issued Order EA-12-049, "Order Modifying Licenses with Regard 

to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" 

[Reference 1]. 

Order EA-12-049, Attachment 2, 1 requires that operating power reactor licensees and 

construction permit holders use a three-phase approach for mitigating BDBEEs. The initial 

phase requires the use of installed equipment and resources to maintain or restore core cooling, 

containment and SFP cooling capabilities. The transition phase requires providing sufficient, 

1. Attachment 3 to Order EA-12-049 provides requirements for Combined License holders. 
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portable, onsite equipment and consumables to maintain or restore these functions until they 

can be accomplished with resources brought from off site. The final phase requires obtaining 

sufficient offsite resources to sustain those functions indefinitely. Specific operational 

requirements of the order are listed below: 

1) Licensees or construction permit (CP) holders shall develop, implement, and 

maintain guidance and strategies to maintain or restore core cooling, 

containment, and SFP cooling capabilities following a beyond-design-basis 

external event. 

2) These strategies must be capable of mitigating a simultaneous loss of all 

alternating current (ac) power and loss of normal access to the ultimate heat sink 

and have adequate capacity to address challenges to core cooling, containment, 

and SFP cooling capabilities at all units on a site subject to the Order. 

3) Licensees or CP holders must provide reasonable protection for the associated 

equipment from external events. Such protection must demonstrate that there is 

adequate capacity to address challenges to core cooling, containment, and SFP 

cooling capabilities at all units on a site subject to the Order. 

4) Licensees or CP holders must be capable of implementing the strategies in all 

modes. 

5) Full compliance shall include procedures, guidance, training, and acquisition, 

staging, or installing of equipment needed for the strategies. 

On May 4, 2012, NEI submitted document 12-06, "Diverse and Flexible Coping Strategies 

(FLEX) Implementation Guide," Revision B [Reference 13] to provide specifications for an 

industry developed methodology for the development, implementation, and maintenance of 

guidance and strategies in response to the Mitigating Strategies order. On May 13, 2012, NEI 

submitted NEI 12-06, Revision B1 [Reference 14]. The guidance and strategies described in 

NEI 12-06 expand on those that industry developed and implemented to address the limited set 

of BDBEEs that involve the loss of a large area of the plant due to explosions and fire required 

pursuant to paragraph (hh)(2) in Section 50.54, "Conditions of licenses" of Title 10 of the Code 

of Federal Regulations. 

On May 31, 2012, the NRC staff issued a draft version of the interim staff guidance (ISG) 

document, 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," [Reference 15] and published a notice of its availability for public comment in the 

Federal Register (77 FR 33779), with the comment period running through July 7, 2012. JLDISG-2012-01 proposed endorsing NEI 12-06, Revision B1, as providing an acceptable method 

of meeting the requirements of Order EA-12-049. The NRC staff received seven comments 

during this time. The NRC staff documented its analysis of these comments in "NRC Response 

to Public Comments, JLD-ISG-2012-01 (Docket ID NRC-2012-0068)" [Reference 16]. 

On July 3, 2012, NEI submitted comments on JLD-ISG-2012-01, including Revision C to NEI 

12-06 [Reference 17], incorporating many of the exceptions and clarifications included in the 

draft version of the ISG. Following a public meeting held July 26, 2012, to discuss the 
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remaining exceptions and clarifications, on August 21, 2012, NEI submitted Revision 0 to NEI 

12-06 [Reference 18]. 

On August 29, 2012, the NRC staff issued the final version of JLD-ISG-2012-01, [Reference 19], 

endorsing NEI 12-06, Revision 0, as an acceptable means of meeting the requirements of Order 

EA-12-049, and published a notice of its availability in the Federal Register?? FR 55230. 

The NRC staff determined that the overall integrated plans submitted by licensees in response 

to Order EA-12-049, Section IV.C.1.a should follow the guidance in NEI 12-06, Section 13, 

which states that: 

The Overall Integrated Plan should include a complete description of the FLEX 

strategies, including important operational characteristics. The level of detail 

generally considered adequate is consistent to the level of detail contained in the 

Licensee's Final Safety Analysis Report (FSAR). The plan should provide the 

following information: 

1. Extent to which this guidance, NEI 12-06, is being followed including a 

description of any alternatives to the guidance, and provide a milestone 

schedule of planned actions. 

2. Description of the strategies and guidance to be developed to meet the 

requirements contained in Attachment 2 or Attachment 3 of the order. 

3. Description of major installed and portable FLEX components used in the 

strategies, the applicable reasonable protection for the FLEX portable 

equipment, and the applicable maintenance requirements for the portable 

equipment. 

4. Description of the steps for the development of the necessary 

procedures, guidance, and training for the strategies; FLEX equipment 

acquisition, staging or installation, including necessary modifications. 

5. Conceptual sketches, as necessary to indicate equipment which is 

installed or equipment hookups necessary for the strategies. (As-built 

piping and instrumentation diagrams (P&ID) will be available upon 

completion of plant modifications.) 

6. Description of how the portable FLEX equipment will be available to be 

deployed in all modes. 

By letter dated August 28, 2013 [Reference 20]. the NRC notified all licensees and 

construction permit holders that the staff is conducting audits of their responses to Order 

EA-12-049. That letter described the process used by the staff in its review, leading to 

the issuance of this interim staff evaluation (ISE) and audit report. The purpose of the 

staff's audit is to determine the extent to which the licensees are proceeding on a path 

towards successful implementation of the actions needed to achieve full compliance with 

the order. Additional NRC staff review and inspection may be necessary following full 

implementation of those actions to verify licensees' compliance with the order. 
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3.0 TECHNICAL EVALUATION 

The NRC staff contracted with Mega Tech Services, LLC (MTS) for technical support in the 

evaluation of the Integrated Plan for Palisades, submitted by Entergy's letter dated 

February 28, 2013, as supplemented. NRC and MTS staff have reviewed the submitted 

information and held clarifying discussions with Entergy in evaluating the licensee's plans for 

addressing BDBEEs and its progress towards implementing those plans. By letter dated 

February 6, 2014 [Reference 21 ], MTS documented the interim results of that ongoing review in 

the attached technical evaluation report (TER). The NRC staff has reviewed this TER for 

consistency with NRC policy and technical accuracy and finds, in general, that it accurately 

reflects the state of completeness of the Integrated Plan. The NRC staff therefore adopts the 

findings of the TER with respect to individual aspects of the requirements of Order EA-12-049. 

A simplified description of the Palisades Integrated Plan is that the licensee will remove the core 

decay heat by adding water to the steam generators (SGs) and releasing steam from the SGs to 

the atmosphere. The water will initially be added by the turbine-driven auxiliary feedwater 

(TDAFW) pump, taking suction from the condensate storage tank (CST), with subsequent 

makeup provided from other potentially available site tanks or the ultimate heat sink (UHS) 

(UHS, or Lake Michigan for Palisades). A portable FLEX generator will be connected to the 

existing plant electrical distribution system. This will allow the energizing of selected loads to 

implement the licensee's strategy, such as critical instrumentation and the battery chargers. 

Recharging the batteries will support continued operation of the direct current (de) distribution 

system. Another FLEX diesel generator will power one of the installed plant charging pumps to 

be used for primary coolant system (PCS) makeup. If the existing volume control tank or safety 

injection and refueling water storage tank (SIRWT) are not available, the licensee plans to use a 

combination of the boric acid storage tank (BAST) water and a non-borated water source such 

as the UHS to provide a blended borated water supply for the charging pump. When the 

TDAFW pump can no longer be operated reliably due to the lowering SG pressure, a portable 

FLEX pump will be used to add water to the SGs. In the long-term, additional equipment, such 

as 4160 volt ac generators, will be delivered from one of the Regional Response Centers 

(RRCs) established by the nuclear power industry to provide supplemental accident mitigation 

equipment. 

Palisades has a large dry containment building, which contains the PCS. There is limited mass 

and energy addition into containment under the postulated extended loss of ac power (ELAP) 

scenario, and thus no immediate containment cooling need is anticipated. In the long-term, 

restoration of containment cooling is planned with support from the RRC-supplied 4160 volt ac 

generators powering the existing containment air fans. 

In the postulated ELAP event, the SFP may reach the boiling point. The licensee plans to 

initiate SFP makeup in time to ensure that sufficient water is maintained for cooling and 

shielding considerations. This is true for a normal (at power) decay heat level or a core offload 

scenario. A diesel-driven FLEX pump will be used to provide this makeup capability to the SFP, 

supplied from either the SIRWT, or the UHS. 
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4.0 OPEN AND CONFIRMATORY ITEMS 

This section contains a summary of the open and confirmatory items identified as part of the 

technical evaluation. The NRC and MTS have assigned each review item to one of the 

following categories: 

Confirmatory item -an item that the NRC considers conceptually acceptable, but for 

which resolution may be incomplete. These items are expected to be acceptable, 

but will require some minimal follow up review, audit, or inspection to verify 

completion. 

Open item- an item for which the licensee has not presented a sufficient basis for 

the NRC to determine that the issue is on a path to resolution. The intent behind 

designating an issue as an open item is to document significant items that need 

resolution during the review process, rather than being verified after the compliance 

date through the inspection process. 

As discussed in Section 3.0, above, the NRC staff has reviewed MTS' TER for consistency with 

NRC policy and technical accuracy and finds that, in general, it accurately reflects the state of 

completeness of the licensee's Integrated Plan. The open and confirmatory items identified in 

the TER are listed in the tables below, with some NRC edits made for clarity from the TER 

version. In addition to the editorial clarifications, Confirmatory Item 3.2.1.2. D from the TER was 

eliminated by combining it with Confirmatory Item 3.2.1.2.C. Confirmatory Item 3.2.4.5.A was 

deleted because it would be addressed by the site's existing configuration management 

program, in accordance with the guidance contained in Section 2.0 of the TER. Confirmatory 

Items 3.2.4.8 A, 3.2.4.8.8, and 3.2.4.8.C from in the TER, regarding electrical strategies, were 

closed because they were either addressed during the review, or will be reviewed further in 

conjunction with Open Item 3.2.1.9.8. Finally, Confirmatory Items 3.2.4.10.8 and 3.2.4.10.C 

from the TER were closed because they were encompassed by Confirmatory Item 3.2.4.1 O.A. 

Further details for each open and confirmatory item listed below are provided in the 

corresponding sections of the TER, identified by the item number. 

The NRC staff notes that for Open Item 3.2.1.8.A on boric acid mixing, the staff has now 

endorsed the August 2013, Pressurized Water Reactor Owners Group (PWROG) position 

paper, with several clarifications, which the licensee will need to address, including the assumed 

mixing delay time. The NRC endorsement letter is dated January 8, 2014, and is publicly 

available (ADAMS Accession No. ML 13276A 183). 

Regarding Open Item 3.2.1.9.8, the NRC staff notes that the strategy of utilizing installed 

charging pumps is an alternate method to the provisions of NEI 12-06. The licensee proposes 

to use the installed power distribution system to provide power to the charging pump(s) supplied 

by a FLEX diesel generator. This places greater reliance on the current state of knowledge of 

external hazards, which are being re-examined for flooding and seismic hazards pursuant to 

NTTF Recommendation 2.1. Additionally, further re-evaluations will be conducted pursuant to 

Section 402 of Public Law 112-07 4, "Consolidated Appropriations Act," which requires that the 

NRC require licensees to reevaluate the seismic, tsunami, flooding, and other external hazards. 

New information from those efforts may necessitate changes in the degree of protection 

afforded this equipment in order to maintain the guidance and strategies required by Order EA12-049. Also, additional information will be needed from the licensee to determine whether the 
- 7-

proposed approach provides an equivalent level of flexibility for responding to an undefined 

event as would be provided through conformance with NEI 12-06. This could necessitate the 

provision of connection points for the use of portable pumping sources should the installed 

charging pumps be rendered unavailable by the initiating event, and/or alternate electrical 

connections for supplying power to the charging pumps that would not be dependent on the 

existing electrical distribution system for success of the PCS makeup strategy. 

4.0 OPEN AND CONFIRMATORY ITEMS 

4.1 OPEN ITEMS 

Item Number Description Notes 

3.1.1.2.A Evaluate the impact of potential soil liquefaction on deployment of 

!portable FLEX equipment. 

3.1.1.2.8 Evaluate the potential need for a power source to move or deploy 

he equipment (e.g., to open the door from a storage location). 

3.1.1.3.A Evaluate impacts from large internal flooding sources that are not 

seismically robust and the potential impact on the mitigating 

strategies. 

3.1.1.3.8 Evaluate the potential for ground water to impact the mitigating 

strategies. 

3.1.5.1.A Evaluate the potential for high temperature hazards to impact the 

!functionality of FLEX equipment in the FLEX storage facility. 

3.1.5.3.A Evaluate the potential for high temperature hazards to impact the 

deployment of FLEX equipment. 

3.2.1.8.A ~erify resolution of the generic concern associated with the 

modeling of the timing and uniformity of the mixing of a liquid 

boric acid solution injected into the PCS under natural circulation 

conditions potentially involving two-phase flow. 

3.2.1.9.8 Provide additional justification for the alternate approach to NEI Significant 

12-06 involving the use of installed charging pumps. 

4.2 CONFIRMATORY ITEMS 

Item Number Description Notes 

3.1.3.1.A Confirm that the FLEX storage facility(s) will meet the plant's 

design-basis tornado wind speed of 300 mph or will be designed 

or evaluated equivalent to ASCE 7-10 using a tornado wind speed 

of 230 mph with separation and diversity between the storage 

locations. If the method of protection chosen is the later, confirm 

hat separation and diversity is adequate. 

3.2.1.A Confirm that the operator actions times in the first 20 minutes of 

he event are adequate and reasonably achievable when the 

associated ELAP procedures are developed and validated. 

3.2.1.8 Confirm the robustness of the charging pump control circuit or 

provide FLEX procedure guidance to manually operate the 

charging pumps by breaker operation. 
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3.2.1.C Confirm the seismic robustness of the BAST piping to support use 

of the BAST water as a supply source for the charging pumps. 

3.2.1.D Confirm the availability and adequacy of a borated water supply to 

support the PCS makeup strategy. 

3.2.1.E Confirm the continued functionality of the Atmospheric Dump 

!Valves in the context of a tornado missile hazard during an ELAP 

in order to support a symmetric cooldown. Alternatively, address 

he effects of asymmetric natural circulation cooldown. 

3.2.1.F Confirm the ability of any non-safety related equipment to function 

as credited in the mitigation strategies in accordance with the 

external event criteria described in NEI-12-06. 

3.2.1.1.A Confirm that the use of Combustion Engineering Nuclear 

Transient Simulator (CENTS) in the ELAP analysis is limited to 

he flow conditions prior to reflux boiling initiation. This 

confirmation should include a description of the CENTScalculated flow quality at the top of the SG U-tube for the 

condition when two-phase natural circulation ends and reflux 

boiling initiates. 

3.2.1.2.A Confirm the Primary Coolant Pump (PCP) seal leakage rate 

assumed in the ELAP analysis is justified. Specifically, if the PCP 

seal leakage rate used in the plant-specific analysis is less than 

he upper bound expectation for the seal leakage rate (15 

gpm/seal) discussed in the PWROG position paper addressing 

he PCP seal leakage for Combustion Engineering plants 

(ADAMS Accession No. ML 13235A 151, non-publicly available), 

·ustification should be provided. 

3.2.1.2.B Confirm whether seal failure will occur or not when subcooling of 

he coolant in the PCS cold-legs is greater than 50 degrees 

Fahrenheit (°F). This evaluation should specify the seal leakage 

flow assumed for the ELAP from time zero to the timeframe when 

subcooling in the PCS cold-legs decreases to 50°F, and provide 

·ustification for the assumed leakage rate. 

3.2.1.2.C If the Integrated Plan is changed to credit isolation of controlled 

bleed-off (CBO), confirm the assumption that the integrity of the 

PCP seals can be maintained, and the seal leakage rate is less 

han 1 gpm per PCP during an ELAP before CBO is isolated. 

This evaluation should provide the maximum temperature and 

pressure, and minimum subcooling of the coolant in the PCS coldlegs during the ELAP before CBO isolation. If CBO isolation is 

being assumed, justify the sequence of events (SOE) and time 

constraints so established. 

3.2.1.3.A Confirm the applicability of ANS 5.1-1979 + 2 sigma decay heat 

curve. 
- 9-

3.2.1.5.A Confirm the containment temperature, pressure, and moisture 

profiles during the ELAP event, and justify the adequacy of the 

computer codes/methodologies, and assumptions used in the 

analysis. 

3.2.1.5.8 Confirm whether further instrumentation is needed based upon 

ongoing ELAP evaluations. 

3.2.1.6.A Complete validation of the SOE timeline. 

3.2.1.6.8 In the audit process, the licensee has indicated that an 

assessment has been performed identifying potential changes to 

he SOE. Confirm that a final SOE has been developed 

incorporating any_ identified changes. 

3.2.1.9.A Confirm that the ability to line up portable pumps is consistent with 

he times assumed in the final version of the Integrated Plan. 

3.2.2.A Resolve the discrepancy between the licensee-determined flow 

rate of 100 gallons per minute (gpm) SFP spray and the 250 gpm 

!performance attribute of NEI 12-06, Table D-3. 

3.2.3.A Confirm the plan assumptions for containment cooling, after 

completion of the containment response analysis. 

3.2.4.1.A Confirm whether supplemental cooling is required for components 

or systems used in the mitigating strategies plan. 

3.2.4.1.8 Confirm the connection point for the UHS FLEX Pump to the 

Service Water System. 

3.2.4.2.A Confirm the adequacy of the ventilation provided in the battery 

room to protect the batteries from the effects of extreme high and 

low temperatures. 

3.2.4.2.8 Confirm the adequacy of battery room ventilation to prevent 

hydrogen accumulation while recharging the batteries in Phase 2 

or Phase 3. 

3.2.4.3.A Confirm whether heat tracing is required for borated water 

systems. 

3.2.4.4.A Confirm that communication enhancements credited in the NRC's 

communication assessment (ADAMS Accession No. 

ML 13129A219) are completed as planned. 

3.2.4.6.A Confirm that habitability limits will be maintained and/or operator 

protective measures will be employed in all phases of an ELAP to 

ensure operators will be capable of FLEX strategy execution 

under adverse temperature conditions. 

3.2.4.7.A Confirm that the evaluation of the CST and T-81 shows that the 

ank qualification is consistent with the strategy and the provisions 

of NEI 12-06. 

3.2.4.7.8 Confirm that the FLEX Support Guidelines provide clear criteria 

or transferring to the next preferred source of water when refilling 

he CST. 

3.2.4.10.A Confirm that the load shed calculation verifies adequate battery 

capacity with sufficient margin throughout Phase 1 to assure the 

battery does not get depleted prior to charging, and the results of 

he analysis are properly integrated into the overall strategy. 
- 10-

3.4.A Confirm that plans for the deployment of portable equipment used 

o implement the response conform to the criteria of NEI 12-06, 

Section 12.2, with regards to considerations 2 through 10. 

5.0 SUMMARY 

As required by Order EA-12-049, the licensee is developing, and will implement and maintain, 

guidance and strategies to maintain or restore core cooling, containment, and SFP cooling 

capabilities in the event of a BDBEE. These new requirements provide a greater mitigation 

capability consistent with the overall defense-in-depth philosophy, and, therefore, greater 

assurance that the challenges posed by BDBEEs to power reactors do not pose an undue risk 

to public health and safety. 

The NRC's objective in preparing this ISE and audit report is to provide a finding to the licensee 

on whether or not their integrated plan, if implemented as described, provides a reasonable path 

for compliance with the order. For areas where the NRC staff has insufficient information to 

make this finding (identified above in Section 4.0), the staff will review these areas as they 

become available or address them as part of the inspection process. The staff notes that the 

licensee has the ability to modify their plans as stated in NEI 12-06, Section 11.8. However, 

additional NRC review and/or inspection may be necessary to verify compliance. 

The NRC staff has reviewed the licensee's plans for additional defense-in-depth measures. 

Assuming a successful resolution to the items identified in Section 4.0 above, the NRC staff 

finds that the proposed measures, properly implemented, will meet the intent of Order 

EA-12-049, thereby enhancing the licensee's capability to mitigate the consequences of a 

BDBEE that impacts the availability of alternating current power and the ultimate heat sink. Full 

compliance with the order will enable the NRC to continue to have reasonable assurance of 

adequate protection of public health and safety. The staff will issue a safety evaluation 

confirming compliance with the order and may conduct inspections to verify proper 

implementation of the licensee's proposed measures. 

6.0 REFERENCES 

1. Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation 

Strategies for Beyond-Design-Basis External Events," March 12, 2012 (Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML 12054A736) 

2. Letter from Entergy to NRC, "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)," 

regarding Palisades Nuclear Plant, dated February 28, 2013 (ADAMS Accession No. 

ML 13060A361) 

3. Letter from Entergy to NRC, "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 (ADAMS Accession No. ML 13241A234) 
- 11 -

4. SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions 

Following the Events in Japan," July 12, 2011 (ADAMS Accession No. ML 11186A950) 

5. SECY-11-0124, "Recommended Actions to be Taken without Delay from the Near-Term 

Task Force Report," September 9, 2011 (ADAMS Accession No. ML 11245A 158) 

6. SECY-11-0137, "Prioritization of Recommended Actions to be Taken in Response to 

Fukushima Lessons Learned," October 3, 2011 (ADAMS Accession No. ML 11272A 111) 

7. SRM-SECY-11-0093, "Staff Requirements- SECY-11-0093- Near-Term Report and 

Recommendations for Agency Actions following the Events in Japan," August 19, 2011 

(ADAMS Accession No. ML 112310021) 

8. SRM-SECY-11-0124, "Staff Requirements- SECY-11-0124- Recommended Actions to 

be Take without Delay from the Near-Term Task Force Report," October 18, 2011 

(ADAMS Accession No. ML 112911571) 

9. SRM-SECY-11-0137, "Staff Requirements- SECY-11-0137- Prioritization of 

Recommended Actions to be Taken in Response to Fukushima Lessons Learned," 

December 15, 2011 (ADAMS Accession No. ML 113490055) 

10. Letter from Adrian Heymer (NEI) to David L. Skeen (NRC), "An Integrated, 

Safety-Focused Approach to Expediting Implementation of Fukushima Dai-ichi Lessons 

Learned," December 16, 2011 (ADAMS Accession No. ML 11353A008) 

11. SECY-12-0025, "Proposed Orders and Requests for Information in Response to 

Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and 

Tsunami," February 17, 2012 (ADAMS Accession No. ML 12039A103) 

12. SRM-SECY-12-0025, "Staff Requirements- SECY-12-0025- Proposed Orders and 

Requests for Information in Response to Lessons Learned from Japan's 

March 11, 2011, Great Tohoku Earthquake and Tsunami," March 9, 2012 (ADAMS 

Accession No. ML 120690347) 

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

Implementation Guide," Revision B, May 4, 2012 (ADAMS Accession No. 

ML 12144A419) 

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

Implementation Guide," Revision B1, May 13, 2012 (ADAMS Accession No. 

ML 12143A232) 

15. Draft 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," May 31, 2012 (ADAMS Accession No. ML 12146A014) 

16. NRC Response to Public Comments, JLD-ISG-2012-01 (Docket ID NRC-2012-0068), 

August 29, 2012 (ADAMS Accession No. ML 12229A253) 
- 12-

17. Nuclear Energy Institute, Comments from Adrian P. Heymer on Draft 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," 

July 3, 2012 (ADAMS Accession No. ML 121910390) 

18. Nuclear Energy Institute document 12-06, "Diverse and Flexible Coping Strategies 

(FLEX) Implementation Guide," Revision 0, August 21, 2012 (ADAMS Accession No. 

ML 12242A378) 

19. Final 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," August 29, 2012 (ADAMS Accession No. 

ML 12229A174) 

20. Letter from Jack R. Davis (NRC) to All Operating Reactor Licensees and Holders of 

Construction Permits, "Nuclear Regulatory Commission Audits of Licensee Responses 

to Mitigation Strategies Order EA-12-049," August 28, 2013 (ADAMS Accession No. 

ML 13234A503) 

21. Letter from John Bowen, Mega Tech Services, LLC, to Eric Bowman, NRC, submitting 

"Technical Evaluation Report Related to Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, EA12-049," for Palisades Nuclear Plant, Revision 1, dated February 6, 2014 (ADAMS 

Accession No. ML 14037 A 160) 

Principal Contributors: 

Date: February 10, 2014 

G. Armstrong 

B. Lee 

G. Singh 

S.Sun 

E. Bowman 

P. Bamford 
Enclosure 2 

Technical Evaluation Report 
Mega-Tech Services, LLC 

Technical Evaluation Report Related to Order Modifying Licenses with Regard to Requirements 

for Mitigation Strategies for Beyond-Design-Basis External Events, EA-12-049 

Revision 1 

February 6, 2014 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

Docket No. 50-255 

Prepared for: 

U.S. Nuclear Regulatory Commission 

Washington, D.C. 20555 

Contract NRC-HQ-13-C-03-0039 

Task Order No. NRC-HQ-13-T-03-0001 

Job Code: J4672 

TAC No. MF0768 

Prepared by: 

Mega-Tech Services, LLC 

11118 Manor View Drive 

Mechanicsville, Virginia 23116 

11118 Manor View Drive • Mechanicsville, Virginia 23116 

804.789.1577 • Fax: 804.789.1578 

www. mega-techservices. biz 
1.0 BACKGROUND 

Technical Evaluation Report 

Palisades Nuclear Plant 

Order EA-12-049 Evaluation 

Following the events at the Fukushima Dai-ichi nuclear power plant on March 11, 2011, the 

U.S. Nuclear Regulatory Commission (NRC) established a senior-level agency task force 

referred to as the Near-Term Task Force (NTTF}. The NTTF was tasked with conducting a 

systematic, methodical review of NRC regulations and processes to determine if the agency 

should make additional improvements to these programs in light of the events at Fukushima 

Dai-ichi. As a result of this review, the NTTF developed a comprehensive set of 

recommendations, documented in SECY-11-0093, "Near-Term Report and Recommendations 

for Agency Actions Following the Events in Japan," dated July 12, 2011. These 

recommendations were enhanced by the NRC staff following interactions with stakeholders. 

Documentation of the staff's efforts is contained in SECY-11-0124, "Recommended Actions to 

be Taken without Delay from the Near-Term Task Force Report," dated September 9, 2011, and 

SECY-11-0137, "Prioritization of Recommended Actions to be Taken in Response to Fukushima 

Lessons Learned," dated October 3, 2011. 

As directed by the Commission's staff requirement memorandum (SRM) for SECY-11-0093, the 

NRC staff reviewed the NTTF recommendations within the context of the NRC's existing 

regulatory framework and considered the various regulatory vehicles available to the NRC to 

implement the recommendations. SECY-11-0124 and SECY-11-0137 established the staff's 

prioritization of the recommendations. 

After receiving the Commission's direction in SRM-SECY-11-0124 and SRM-SECY-11-0137, 

the NRC staff conducted public meetings to discuss enhanced mitigation strategies intended to 

maintain or restore core cooling, containment, and Spent Fuel Pool (SFP) cooling capabilities 

following beyond-design-basis external events (BDBEEs). At these meetings, the industry 

described its proposal for a Diverse and Flexible Mitigation Capability (FLEX), as documented in 

Nuclear Energy Institute's (NEI) letter, dated December 16, 2011 (Agencywide Documents 

Access and Management System (ADAMS) Accession No. ML 11353A008). FLEX was 

proposed as a strategy to fulfill the key safety functions of core cooling, containment integrity, 

and spent fuel cooling. Stakeholder input influenced the NRC staff to pursue a more 

performance-based approach to improve the safety of operating power reactors relative to the 

approach that was envisioned in NTTF Recommendation 4.2, SECY-11-0124, and SECY-11-

0137. 

On February 17, 2012, the NRC staff provided SECY-12-0025, "Proposed Orders and Requests 

for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku 

Earthquake and Tsunami," to the Commission, including the proposed order to implement the 

enhanced mitigation strategies. As directed by SRM-SECY-12-0025, the NRC staff issued 

Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation 

Strategies for Beyond-Design-Basis External Events." 

Guidance and strategies required by the Order would be available if a loss of power, motive 

force and normal access to the ultimate heat sink needed to prevent fuel damage in the reactor 

and SFP affected all units at a site simultaneously. The Order requires a three-phase approach 

for mitigating BDBEEs. The initial phase requires the use of installed equipment and resources 

Revision 1 Page 2 of 74 2014-02-06 
to maintain or restore key safety functions including core cooling, containment, and SFP 

cooling. The transition phase requires providing sufficient portable onsite equipment and 

consumables to maintain or restore these functions until they can be accomplished with 

resources brought from offsite. The final phase requires obtaining sufficient offsite resources to 

sustain those functions indefinitely. 

NEI submitted its document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) 

Implementation Guide" in August 2012 (ADAMS Accession No. ML 12242A378) to provide 

specifications for an industry-developed methodology for the development, implementation, and 

maintenance of guidance and strategies in response to Order EA-12-049. The guidance and 

strategies described in NEI 12-06 expand on those that industry developed and implemented to 

address the limited set of BDBEEs that involve the loss of a large area of the plant due to 

explosions and fire required pursuant to paragraph (hh)(2) of 10 CFR 50.54, "Conditions of 

licenses." 

As described in Interim Staff Guidance (ISG), 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," the NRC staff considers that the development, 

implementation, and maintenance of guidance and strategies in conformance with the 

Guidelines provided in NEI 12-06, Revision 0, subject to the clarifications in Attachment 1 of the 

ISG are an acceptable means of meeting the requirements of Order EA-12-049. 

In response to Order EA-12-049, licensees submitted Overall Integrated Plans (hereafter, the 

Integrated Plan) describing their course of action for mitigation strategies that are to conform 

with the guidance of NEI 12-06, or provide an acceptable alternative to demonstrate compliance 

with the requirements of Order EA-12-049. 

2.0 EVALUATION PROCESS 

In accordance with the provisions of Contract NRC-HQ-13-C-03-0039, Task Order No. 

NRC-HQ-13-T-03-0001, Mega-Tech Services, LLC (MTS) performed an evaluation of each 

licensee's Integrated Plan. As part of the evaluation, MTS, in parallel with the NRC staff, 

reviewed the original Integrated Plan and the first 6-month status update, and conducted an 

audit of the licensee documents. The staff and MTS also reviewed the licensee's answers to 

the NRC staff's and MTS's questions as part of the audit process. The objective of the 

evaluation was to assess whether the proposed mitigation strategies conformed to the guidance 

in NEI 12-06, as endorsed by the positions stated in JLD-ISG-2012-01, or an acceptable 

alternative had been proposed that would satisfy the requirements of Order EA-12-049. The 

audit plan that describes the audit process was provided to all licensees in a letter dated August 

29, 2013 from Jack R. Davis, Director, Mitigating Strategies Directorate (ADAMS Accession No. 

ML 13234A503). 

The review and evaluation of the licensee's Integrated Plan was performed in the following 

areas consistent with NEI 12-06 and the regulatory guidance of JLD-ISG-2012-01: 

• Evaluation of External Hazards 

• Phased Approach 

~ Initial Response Phase 

~ Transition Phase 

~ Final Phase 

• Core Cooling Strategies 

Revision 1 Page 3 of 74 2014-02-06 
• SFP Cooling Strategies 

• Containment Function Strategies 

• Programmatic Controls 

);> Equipment Protection, Storage, and Deployment 

);> Equipment Quality 

The technical evaluation in Section 3.0 documents the results of the MTS evaluation and audit 

results. Section 4.0 summarizes Confirmatory Items and Open Items that require further 

evaluation before a conclusion can be reached that the Integrated Plan is consistent with the 

guidance in NEI 12-06 or an acceptable alternative has been proposed that would satisfy the 

requirements of Order EA-12-049. For the purpose of this evaluation, the following definitions 

are used for Confirmatory Item and Open Item. 

Confirmatory Item - an item that is considered conceptually acceptable, but for which 

resolution may be incomplete. These items are expected to be acceptable, but are 

expected to require some minimal follow up review or audit prior to the licensee's 

compliance with Order EA-12-049. 

Open Item - an item for which the licensee has not presented a sufficient basis to 

determine that the issue is on a path to resolution. The intent behind designating an 

issue as an Open Item is to document items that need resolution during the audit 

process, rather than being verified after the compliance date through the inspection 

process. 

Additionally, for the purpose of this evaluation and the NRC staff's interim staff evaluation (ISE), 

licensee statements, commitments, and references to existing programs that are subject to 

routine NRC oversight (Updated Final Safety Analysis Report (UFSAR) program, procedure 

program, quality assurance program, modification configuration control program, etc.) will 

generally be accepted. For example, references to existing UFSAR information that supports 

the licensee's overall mitigating strategies plan, will be assumed to be correct, unless there is a 

specific reason to question its accuracy. Likewise, if a licensee states that they will generate a 

procedure to implement a specific mitigating strategy, assuming that the procedure would 

otherwise support the licensee's plan, this evaluation accepts that a proper procedure will be 

prepared. This philosophy for this evaluation and the ISE does not imply that there are any 

limits in this area to future NRC inspection activities. 

3.0 TECHNICAL EVALUATION 

By letter dated February 28, 2013 (ADAMS) Accession No. ML 13060A361), and as 

supplemented by the first six-month status report in a letter dated August 28, 2013 (ADAMS 

Accession No. ML 13241A234) Entergy Nuclear Operations, Inc. (the licensee or Entergy) 

provided Palisades Nuclear Plant's (PNP) Integrated Plan for Compliance with Order EA-12-

049. The Integrated Plan describes the strategies and guidance under development for 

implementation by the licensee for the maintenance of restoration of core cooling, containment, 

and SFP cooling capabilities following a BDBEE, including modifications necessary to support 

this implementation, pursuant to Order EA-12-049. By letter dated August 28, 2013 (ADAMS 

Accession No. ML 13234A503), the NRC staff notified all licensee and construction permit 

holders that the staff is conducting audits of their responses to Order EA-12-049. That letter 

described the process used by the NRC staff in its review, leading to the issuance of an interim 

staff evaluation and audit report. The purpose of the staffs audit is to determine the extent to 

which the licensees are proceeding on a path towards successful implementation of the actions 

Revision 1 Page 4 of 74 2014-02-06 
needed to achieve full compliance with the Order. 

3.1 EVALUATION OF EXTERNAL HAZARDS 

Sections 4 through 9 of NEI 12-06 provide the NRC-endorsed methodology for the 

determination of applicable extreme external hazards in order to identify potential complicating 

factors for the protection and deployment of equipment needed for mitigation of BDBEEs 

leading to an extended loss of all alternating current (ac) power (ELAP) and loss of normal 

access to the ultimate heat sink (UHS). These hazards are broadly grouped into the categories 

discussed below in Sections 3.1.1 through 3.1.5 of this evaluation. Characterization of the 

applicable hazards for a specific site includes the identification of realistic timelines for the 

hazard; characterization of the functional threats due to the hazard; development of a strategy 

for responding to events with warning; and development of a strategy for responding to events 

without warning. 

3.1.1 Seismic Events. 

NEI 12-06, Section 5.2 states: 

All sites will address BDB [beyond-design-basis] seismic considerations in the 

implementation of FLEX strategies, as described below. The basis for this is 

that, while some sites are in areas with lower seismic activity, their design basis 

generally reflects that lower activity. There are large, and unavoidable, 

uncertainties in the seismic hazard for all U.S. plants. In order to provide an 

increased level of safety, the FLEX deployment strategy will address seismic 

hazards at all sites. 

These considerations will be treated in four primary areas: protection of FLEX 

equipment, deployment of FLEX equipment, procedural interfaces, and 

considerations in utilizing off-site resources. 

On page 1 of the Integrated Plan, the licensee confirms that it has screened in for this external 

hazard. The licensee further states that per the UFSAR Section 2.4.4, the seismic criteria for 

Palisades includes two (2) design basis earthquake spectra: the operating basis earthquake 

(OBE) and the safe shutdown earthquake (SSE) and that the peak horizontal ground 

acceleration for the SSE is 0.2 g. 

The licensee also stated that the seismic re-evaluation pursuant to the 10 CFR 50.54(f) letter of 

March 12, 2012 had not been completed and therefore was not assumed in the Integrated Plan. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to screening for 

seismic hazards, if these requirements are implemented as described. 

3.1.1.1 Protection of FLEX Equipment- Seismic Hazard 

NEI 12-06, Section 5.3.1 states: 

1. FLEX equipment should be stored in one or more of following three 

configurations: 

Revision 1 Page 5 of 74 2014-02-06 
a. In a structure that meets the plant's design basis for the Safe Shutdown 

Earthquake (SSE)(e.g., existing safety-related structure). 

b. In a structure designed to or evaluated equivalent to [American Society of 

Civil Engineers] ASCE 7-10, Minimum Design Loads for Buildings and 

Other Structures. 

c. Outside a structure and evaluated for seismic interactions to ensure 

equipment is not damaged by non-seismically robust components or 

structures. 

2. Large portable FLEX equipment such as pumps and power supplies should 

be secured as appropriate to protect them during a seismic event (i.e., Safe 

Shutdown Earthquake (SSE) level). 

3. Stored equipment and structures should be evaluated and protected from 

seismic interactions to ensure that unsecured and/or non-seismic 

components do not damage the equipment. 

On page 25 of the Integrated Plan, the licensee stated that protection of associated portable 

equipment from seismic hazards would be provided and that the FLEX storage facility will be 

designed to withstand the SSE. Two potential storage areas for FLEX portable equipment 

have been identified. The licensee will determine where the storage facility will be located at 

Palisades and communicate this information in a future six-month update. 

On pages 25, 54 and 64 of the Integrated Plan, the licensee described the protection plan to 

determine storage requirements of portable FLEX equipment from seismic hazards, which 

includes that structures to provide protection of FLEX equipment, will be constructed to meet the 

requirements of NEI 12-06, Section 11. The schedule to construct the permanent building is 

contained in Attachment 2, and will satisfy the site compliance date. Procedures and programs 

will be developed to address storage structure requirements, haul path requirements, and FLEX 

equipment requirements relative to the external hazards applicable to Palisades. The reviewer 

considers the development of these procedures and programs as including the securing of 

portable equipment and the evaluation of stored equipment and structures as described in 

paragraphs 2 and 3 above. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to storage of 

FLEX equipment during seismic events, if these requirements are implemented as described. 

3.1.1.2 Deployment of FLEX Equipment- Seismic Hazard 

NEI 12-06, Section 5.3.2 states: 

The baseline capability requirements already address loss of non-seismically 

robust equipment and tanks as well as loss of all AC. So, these seismic 

considerations are implicitly addressed. 

There are five considerations for the deployment of FLEX equipment following a 

Revision 1 Page 6 of 74 2014-02-06 
seismic event: 

1. If the equipment needs to be moved from a storage location to a different 

point for deployment, the route to be traveled should be reviewed for potential 

soil liquefaction that could impede movement following a severe seismic 

event. 

2. At least one connection point for the FLEX equipment will only require access 

through seismically robust structures. This includes both the connection point 

and any areas that plant operators will have to access to deploy or control the 

capability. 

3. If the plant FLEX strategy relies on a water source that is not seismically 

robust, e.g., a downstream dam, the deployment of FLEX coping capabilities 

should address how water will be accessed. Most sites with this configuration 

have an underwater berm that retains a needed volume of water. However, 

accessing this water may require new or different equipment. 

4. If power is required to move or deploy the equipment (e.g., to open the door 

from a storage location), then power supplies should be provided as part of 

the FLEX deployment. 

5. A means to move FLEX equipment should be provided that is also 

reasonably protected from the event. 

With respect to the movement of FLEX equipment during a seismic event, the licensee indicates 

on page 13 of the Integrated Plan that deployment paths from the FLEX storage building to 

each staging area are identified, as well as the debris removal concerns, security barriers, and 

lighting needs as they apply to each deployment path. 

The licensee also stated that the deployment paths refer to the route from a storage location to 

the staging location for the pumps and generators, and routing paths refer to the route from a 

staging location to the point of connection to existing plant equipment for hoses and cables. 

To ensure the strategies can be implemented in all modes, areas adjacent to the equipment 

storage facilities and staging areas, as well as the deployment and hose routing paths will be 

kept normally accessible. These requirements will be included in an administrative program. 

The licensee stated that debris removal equipment will be procured to ensure that onsite 

roadways are passable following a BDBEE. Offsite travel paths from the offsite response center 

will be assessed as part of the Regional Response Center (RRC) response dependent on postevent conditions. 

The licensee also stated that for the FLEX generators and cables, the staging areas for Modes 

1-4 will be either at the north side of the Turbine Building near Auxiliary Building (AB) (Staging 

Area 1 on Figure 3-3 in the Integrated Plan) or the on the north east side of the Containment 

Building. The maximum deployment path will be 2,200 feet from Storage Area 1 and 900 feet 

from Storage Area 2. Debris from various overheard hazards may need to be cleared; however, 

the expected debris can be cleared with moderately sized equipment. There are no security 

barriers in the deployment paths for the pumps, and the entirety of the deployment path is within 

the protected area. 

Revision 1 Page 7 of 74 2014-02-06 
On page 26 of the Integrated Plan, the licensee stated that the connection from both tanks T-90 

and T-91 is not guaranteed to survive every event simultaneously but is the preferred source if 

available. Suction from Lake Michigan will survive all the events and will use a rigid suction 

hose to draft out of the lake to ensure its availability. The new connection to the CST will be 

protected by the CST missile barrier. The discharge connection for the AFW system is location 

inside the AB and will survive all events. The CST connection is the manway on the tank and is 

expected to survive the same events as the tank; all but a wind missile event. A modification to 

missile-protect the CST will allow this connection to survive all events. 

On page 26 of the Integrated Plan, the licensee identified the connection point for the strategy to 

refill the condensate storage tank (CST) as being to either the manway or through a 

modification to the overflow line, which would not require access to a structure. The licensee 

also identified a connection point within the turbine building (TB) for the strategy for providing 

steam generator (SG) makeup using a portable pump. The licensee stated that if the TB is 

inaccessible, and this connection point is unavailable, a second connection point utilizes a 

modified Auxiliary Feedwater (AFW) system drain downstream of the motor driven AFW pump 

P-8C. 

On pages 32 and 33 of the Integrated Plan, the licensee stated that the UHS FLEX pump will be 

staged along Lake Michigan. The suction hose will simply be draped into the open lake with a 

strainer to filter debris. The reviewer noted that the use of Lake Michigan as a water source 

addresses the considerations for failure of downstream dams because the nearest downstream 

dams are within the St. Lawrence Seaway and are sufficiently removed from the site such that a 

seismic initiating event would be unlikely to impact both the site and the dams. The discharge 

hose will be run along grade level to the Service Water Pump House, the Service Water piping 

adjacent to the pump house, or near the Component Cooling Water (CCW) heat exchanger in 

the AB where the discharge of the hose will be connected to the Service Water System. The 

precise location of the Service Water connection has not yet been determined, but is identified 

as being within the AB, which is seismically robust. 

On page 53 of the Integrated Plan the licensee stated that regarding SFP cooling water 

sources, he available suction sources for all of the above options are the safety injection and 

refueling water storage tank (SIRWT) and Lake Michigan. 

On pages 56 and 57 of the Integrated Plan, the licensee stated in part that for SFP cooling: 

The suction pipe for the SIRWT will be constructed to withstand all the hazards. 

Lake Michigan will survive all the events and will use a hardened suction hose to 

draft out of the lake to ensure its availability. Both discharge connections are 

inside the Auxiliary Building, which will survive all events. Hose will be used to 

get from the pumps to the connection points; this hose will be stored in the FLEX 

building that will be designed to withstand all events. 

On page 1 of the Integrated Plan, the licensee states that soil liquefaction is not explicitly 

addressed in its UFSAR and identified that an evaluation is being conducted for its impact on 

deployment of portable FLEX equipment. This has been identified as Confirmatory Item 

3.1.1.2.A in Section 4.2. 

The licensee did not address potential need for a power source to move or deploy the 

equipment (e.g., to open the door from a storage location). This has been identified as 

Confirmatory Item 3.1.1.2.B in Section 4.2. 

Revision 1 Page 8 of 74 2014-02-06 
On page 65 of the Integrated Plan the licensee stated that the generators, cables, and transport 

vehicles will all be stored in the FLEX storage facility. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Items, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to deployment of FLEX equipment for 

seismic hazards, if these requirements are implemented as described. 

3.1.1.3 Procedural Interfaces- Seismic Hazard 

NEI 12-06, Section 5.3.3 states: 

There are four procedural interface considerations that should be addressed. 

1. Seismic studies have shown that even seismically qualified electrical 

equipment can be affected by BOB seismic events. In order to address 

these considerations, each plant should compile a reference source for 

the plant operators that provides approaches to obtaining necessary 

instrument readings to support the implementation of the coping strategy 

(see Section 3.2.1.1 0). This reference source should include control room 

and non-control room readouts and should also provide guidance on how 

and where to measure key instrument readings at containment 

penetrations, where applicable, using a portable instrument (e.g., a Fluke 

meter). Such a resource could be provided as an attachment to the plant 

procedures/guidance. Guidance should include critical actions to perform 

until alternate indications can be connected and on how to control critical 

equipment without associated control power. 

2. Consideration should be given to the impacts from large internal flooding 

sources that are not seismically robust and do not require ac power (e.g., 

gravity drainage from lake or cooling basins for non-safety-related cooling 

water systems). 

3. For sites that use ac power to mitigate ground water in critical locations, a 

strategy to remove this water will be required. 

4. Additional guidance may be required to address the deployment of FLEX 

for those plants that could be impacted by failure of a not seismically 

robust downstream dam. 

On page 62 of the integrated Plan the licensee stated in part that: 

Support for the safety functions is provided by continued observation of plant 

conditions by operators using specific instruments and coordinating activities 

from the Control Room. In addition, the Key Reactor Parameters can be 

determined from a local reading using standard I&C instruments and local 

indications. 

The licensee did not provide information concerning impacts from large internal flooding sources 

Revision 1 Page 9 of 74 2014-02-06 
that are not seismically robust and the potential impact on the mitigating strategies. This is 

Open Item 3.1.1.3.A in Section 4.1. 

The licensee did not provide information concerning ground water mitigation requirements. This 

is Open Item 3.1.1.3.8 in Section 4.1. 

Guidance regarding downstream dams is not required as discussed in TER section 3.1.1.2 

above. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Open Items, and provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to procedural interfaces for seismic 

hazards, if these requirements are implemented as described. 

3.1.1.4 Considerations in Using Offsite Resources - Seismic Hazard 

NEI 12-06, Section 5.3.4 states: 

Severe seismic events can have far-reaching effects on the infrastructure in and 

around a plant. While nuclear power plants are designed for large seismic 

events, many parts of the Owner Controlled Area and surrounding infrastructure 

(e.g., roads, bridges, dams, etc.) may be designed to lesser standards. 

Obtaining off-site resources may require use of alternative transportation (such as 

air-lift capability) that can overcome or circumvent damage to the existing local 

infrastructure. 

1. The FLEX strategies will need to assess the best means to obtain 

resources from off-site following a seismic event. 

On pages 16 and 17 of the Integrated Plan, the licensee stated that the industry will establish 

two (2) RRCs to support utilities during beyond-design events. Each RRC will hold five (5) sets 

of equipment, four (4) of which will be able to be fully deployed when required, the fifth set will 

have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local 

assembly area, established by the Strategic Alliance for FLEX Emergency Response (SAFER) 

team and the utility. Communications will be established between the affected nuclear site and 

the SAFER team and required equipment moved to the site as needed. First arriving 

equipment, as established during development of the nuclear site's playbook, will be delivered 

to the site within 24 hours from the initial request. Entergy, for the Palisades site, will negotiate 

and execute a contract with SAFER that will meet the requirements of NEI 12-06, Section 12. 

For Palisades this will include provisions to connect the sites 2400V distribution system. 

Licensee plans for use of off-site resources is not complete. The licensee has not identified the 

local assembly area, or provided a discussion regarding the means to be used to deliver 

equipment to the site. This has been identified as Confirmatory Item 3.1.1.4.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to use of off-site resources during 

seismic events, if these requirements are implemented as described. 

Revision 1 Page 10 of 74 2014-02-06 
3.1.2 Flooding. 

NEI 12-06, Section 6.2 states: 

The evaluation of external flood-induced challenges has three parts. The first part 

is determining whether the site is susceptible to external flooding. The second 

part is the characterization of the applicable external flooding threat. The third 

part is the application of the flooding characterization to the protection and 

deployment of FLEX strategies. 

NEI 12-06, Section 6.2.1 states in part: 

Susceptibility to external flooding is based on whether the site is a "dry'' site, i.e., 

the plant is built above the design basis flood level (DBFL). For sites that are not 

"dry", water intrusion is prevented by barriers and there could be a potential for 

those barriers to be exceeded or compromised. Such sites would include those 

that are kept "dry" by permanently installed barriers, e.g., seawall, levees, etc., 

and those that install temporary barriers or rely on watertight doors to keep the 

design basis flood from impacting safe shutdown equipment. 

On page 2 of the Integrated Plan, the licensee stated that the flood assessment for the 

Palisades site provided in the UFSAR considered flooding due to high levels in Lake Michigan, 

high rainfall, seismically-induced floods, wind-generated waves concurrent with flooding, and 

significant flooding in rushes called seiches. High tides, hurricane surges, and tsunamis were 

determined to not affect the site due to the inland location. Ground level elevation for Palisades 

is 590ft. MSL. The PMF for Palisades including a seiche event is 594.1 ft. All plant equipment 

that will be used for FLEX is protected against a flood to a level of 594.4 ft. per UFSAR Section 

2.2. 

Thus, the Palisades site screens in for the external flooding hazard. 

On page 2 of the Integrated Plan, the licensee further stated that, a seiche event is short in 

duration and is predicted to last less than 30 minutes. While the safety-related equipment is 

protected from the PMF, all safety-related structures are not located above this elevation and all 

structures are susceptible to the seiche levels. Therefore, the Palisades site is not considered a 

"dry" site and is susceptible to external flood. Accordingly, FLEX strategies will be developed 

for consideration of external flooding hazards. In addition, Palisades is also developing 

procedures and strategies for delivery of offsite FLEX equipment during Phase 3, which 

considers regional impacts from flooding. The licensee also stated that the flooding reevaluation pursuant to the 10 CFR 50.54(f) letter of March 12, 2012, had not been completed 

and therefore not assumed in the Integrated Plan. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to screening for 

flooding hazards, if these requirements are implemented as described. 

3.1.2.1 Protection of FLEX Equipment- Flooding Hazard 

Revision 1 Page 11 of 74 2014-02-06 
NEI 12-06, Section 6.2.3.1 states: 

These considerations apply to the protection of FLEX equipment from external 

flood hazards: 

1. The equipment should be stored in one or more of the following 

configurations: 

a. Stored above the flood elevation from the most recent site flood analysis. 

The evaluation to determine the elevation for storage should be informed 

by flood analysis applicable to the site from early site permits, combined 

license applications, and/or contiguous licensed sites. 

b. Stored in a structure designed to protect the equipment from the flood. 

c. FLEX equipment can be stored below flood level if time is available and 

plant procedures/guidance address the needed actions to relocate the 

equipment. Based on the timing of the limiting flood scenario(s), the 

FLEX equipment can be relocated [footnote 2 omitted] to a position that is 

protected from the flood, either by barriers or by elevation, prior to the 

arrival of the potentially damaging flood levels. This should also consider 

the conditions on-site during the increasing flood levels and whether 

movement of the FLEX equipment will be possible before potential 

inundation occurs, not just the ultimate flood height. 

2. Storage areas that are potentially impacted by a rapid rise of water should be 

avoided. 

On pages 25, 55 and 64 of the Integrated Plan, the licensee stated that the FLEX storage facility 

will be designed to withstand flooding events to a PMF of 594.1 ft .. The equipment will be 

protected during a short duration seiche event and available for any standing flood event. 

Similar statements were made throughout the Integrated Plan when referring to storage and 

protection of FLEX portable equipment with respect to flooding. 

On page 24 of the Integrated Plan, the licensee stated that structures to provide protection of 

FLEX equipment will be constructed to meet the requirements of NEI 12-06, Section 11. 

Schedule to construct the permanent building is contained in Attachment 2, and will satisfy the 

site compliance date. Procedures and programs will be developed to address storage structure 

requirements, haul path requirements, and FLEX equipment requirements relative to the 

external hazards applicable to Palisades. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to protection of 

FLEX equipment during flood events, if these requirements are implemented as described. 

3.1.2.2 Deployment of FLEX Equipment- Flooding Hazard 

NEI 12-06, Section 6.2.3.2 states: 

Revision 1 Page 12 of 74 2014-02-06 
There are a number of considerations which apply to the deployment of FLEX 

equipment for external flood hazards: 

1. For external floods with warning time, the plant may not be at power. In fact, 

the plant may have been shut down for a considerable time and the plant 

configuration could be established to optimize FLEX deployment. For 

example, the portable pump could be connected, tested, and readied for use 

prior to the arrival of the critical flood level. Further, protective actions can be 

taken to reduce the potential for flooding impacts, including cooldown, 

berating the RCS, isolating accumulators, isolating RCP seal leak off, 

obtaining dewatering pumps, creating temporary flood barriers, etc. These 

factors can be credited in considering how the baseline capability is 

deployed. 

2. The ability to move equipment and restock supplies may be hampered during 

a flood, especially a flood with long persistence. Accommodations along 

these lines may be necessary to support successful long-term FLEX 

deployment. 

3. Depending on plant layout, the ultimate heat sink may be one of the first 

functions affected by a flooding condition. Consequently, the deployment of 

the FLEX equipment should address the effects of LUHS, as well as ELAP. 

4. Portable pumps and power supplies will require fuel that would normally be 

obtained from fuel oil storage tanks that could be inundated by the flood or 

above ground tanks that could be damaged by the flood. Steps should be 

considered to protect or provide alternate sources of fuel oil for flood 

conditions. Potential flooding impacts on access and egress should also be 

considered. 

5. Connection points for portable equipment should be reviewed to ensure that 

they remain viable for the flooded condition. 

6. For plants that are limited by storm-driven flooding, such as Probable 

Maximum Surge or Probable Maximum Hurricane (PMH), expected storm 

conditions should be considered in evaluating the adequacy of the baseline 

deployment strategies. 

7. Since installed sump pumps will not be available for dewatering due to the 

ELAP, plants should consider the need to provide water extraction pumps 

capable of operating in an ELAP and hoses for rejecting accumulated water 

for structures required for deployment of FLEX strategies. 

8. Plants relying on temporary flood barriers should assure that the storage 

location for barriers and related material provides reasonable assurance that 

the barriers could be deployed to provide the required protection. 

9. A means to move FLEX equipment should be provided that is also 

reasonably protected from the event. 

The licensee stated that debris removal equipment will be procured to ensure that onsite 

Revision 1 Page 13 of 74 2014-02-06 
roadways are passable following a BDBEE. Offsite travel paths from the offsite response center 

will be assessed as part of the Regional Response Center (RRC) response dependent on postevent conditions. 

The licensee stated that for the FLEX pumps and hoses, the staging area for Modes 1-4 will be 

either at the Lake Michigan suction area or near Tanks T-90 and T-91 (Staging Areas 2 and 3 

on Figure 3-3 in the Integrated Plan); dependent on which suction source will be used. The 

staging area for Modes 5 and 6 will be either at the Lake Michigan suction area or near the 

Tendon Tunnel (Staging Areas 3 and 4 on Figure 3-3 in the Integrated Plan); dependent on 

which suction source will be used. 

The licensee also explained that for the FLEX generators and cables, the staging areas for 

Modes 1-4 will be either at the north side of the Turbine Building near AB (Staging Area 1 on 

Figure 3-3 in the Integrated Plan) or the on the north east side of the Containment Building 

(Staging Area 5 on Figure 3-3 in the Integrated Plan). 

On page 27 of the Integrated Plan, the licensee described the connection points for its 

strategies as described in section 3.1.1.2 above. In addition, the licensee stated that for one of 

its strategies, the Tendon Tunnel is below the flood elevation, therefore the hose cannot be 

used unless the access to the Tendon Tunnel is sealed against flooding. A pipe would have to 

be installed so that a FLEX portable pump would be able to connect to the Auxiliary Feed Water 

(AFW) system piping as an alternate strategy. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to deployment of 

FLEX equipment for flooding hazards, if these requirements are implemented as described. 

3.1.2.3 Procedural Interfaces - Flooding Hazard 

NEI 12-06, Section 6.2.3.3 states: 

The following procedural interface considerations should be addressed. 

1. Many sites have external flooding procedures. The actions necessary to 

support the deployment considerations identified above should be 

incorporated into those procedures. 

2. Additional guidance may be required to address the deployment of FLEX for 

flooded conditions (i.e., connection points may be different for flooded vs. 

non-flooded conditions). 

3. FLEX guidance should describe the deployment of temporary flood barriers 

and extraction pumps necessary to support FLEX deployment. 

On page 15 of the Integrated Plan, the licensee states that it is a participant in the PWROG 

project and will develop Functional Support Guidelines (FSGs) that supports implementation of 

FLEX by the Spring of 2015. The FSGs will be used to develop site-specific procedures used to 

cope with ELAP in a manner that is compliant with NEI 12-06. Additionally, the licensee stated 

that the FSGs will be implemented as necessary to maintain the key safety functions of core 

cooling, containment, and spent fuel pool cooling in parallel with the controlling procedure 

Revision 1 Page 14 of 74 2014-02-06 
actions. The licensee stated that the FSGs would interface with controlling procedures such as 

Emergency Operating Procedures (EOPs), Abnormal Operating Procedures (AOPs), and 

Standard Operating Procedures (SOPs). 

The licensee also stated that the proposed procedural interfaces used to implement the 

response for flooding hazards would be prepared under their internal change process. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to procedural 

interfaces for flooding hazards, if these requirements are implemented as described. 

3.1.2.4 Considerations in Using Offsite Resources - Flooding Hazard 

NEI 12-06, Section 6.2.3.4 states: 

Extreme external floods can have regional impacts that could have a significant 

impact on the transportation of offsite resources. 

1. Sites should review site access routes to determine the best means to obtain 

resources from off-site following a flood. 

2. Sites impacted by persistent floods should consider where equipment 

delivered from offsite could be staged for use on-site. 

The licensee has not identified the local assembly area, or provided a discussion regarding the 

means to be used to deliver equipment to the site. This has been combined with Confirmatory 

Item 3.1.1.4.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to use of off-site resources during 

flooding events, if these requirements are implemented as described. 

3.1.3 High Winds 

NEI 12-06, Section 7, provides the NRC-endorsed screening process for evaluation of high wind 

hazards. This screening process considers the hazard due to hurricanes and tornadoes. The 

first part of the evaluation of high wind challenges is determining whether the site is potentially 

susceptible to different high wind conditions to allow characterization of the applicable high wind 

hazard. 

The screening for high wind hazards associated with hurricanes should be accomplished by 

comparing the site location to NEI 12-06, Figure 7-1 (Figure 3-1 of U.S. NRC, "Technical Basis 

for Regulatory Guidance on Design Basis Hurricane Wind Speeds for Nuclear Power Plants," 

NUREG/CR-7005, December, 2009); if the resulting frequency of recurrence of hurricanes with 

wind speeds in excess of 130 mph exceeds 1 o-6 per year, the site should address hazards due 

to extreme high winds associated with hurricanes. 

The screening for high wind hazard associated with tornadoes should be accomplished by 

Revision 1 Page 15 of 74 2014-02-06 
comparing the site location to NEI 12-06, Figure 7-2, from U.S. NRC, "Tornado Climatology of 

the Contiguous United States," NUREG/CR-4461, Rev. 2, February 2007; if the recommended 

tornado design wind speed for a 1 o-6

/year probability exceeds 130 mph, the site should address 

hazards due to extreme high winds associated with tornadoes. 

The screening for high wind hazard associated with tornadoes should be accomplished by 

comparing the site location to NEI 12-06, Figure 7-2, from U.S. NRC, "Tornado Climatology of 

the Contiguous United States," NUREG/CR-4461, Rev. 2, February 2007; if the recommended 

tornado design wind speed for a 1 o-6

/year probability exceeds 130 mph, the site should address 

hazards due to extreme high winds associated with tornadoes. 

On page 2 of the Integrated Plan regarding the determination of applicable extreme external 

hazards, the licensee stated that per the UFSAR Figure 1-1, Sheet 1, the Palisades site is 

contained within a box with corner coordinates 42 degrees 18 minutes N, 086 degrees 18 

minutes Wand 42 degrees 20 minutes' N, 086 degrees 19 minutes W. Based on these 

coordinates, Palisades will consider a maximum wind speed of 200 mph for FLEX per NEI 12-

06, Figures 7-1 and 7-2. Thus, the Palisades site screens in for the high winds hazard. The 

design basis tornado for Palisades uses a tangential wind speed of 300 mph per UFSAR 

Section 2.5.1.4. In summary, based on the available locale data and Figures 7-1 and 7-2 of NEI 

12-06, Palisades is susceptible to severe storms with high winds. 

The reviewer noted that a comparison of the site location to NEI 12-06, Figure 7-1 shows the 

site to be North and West of the contour line for a peak-gust hurricane wind speed of 130 mph 

with an annual exceedance probability of 1 o-6

/year; this is in the direction of diminishing peakgust hurricane wind speeds. As a result, the site is not susceptible to hurricane conditions. The 

licensee's identification of a maximum wind speed of 200 mph is derived from the site location 

being within Region 1 of NEI12-06, Figure 7-2, which has a recommended tornado design wind 

speed of 200 mph for the 1 o-6

/year probability. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to screening for 

high wind hazards, if these requirements are implemented as described. 

3.1.3.1 Protection of FLEX Equipment- High Wind Hazard 

NEI 12-06, Section 7.3.1 states: 

These considerations apply to the protection of FLEX equipment from high wind 

hazards: 

1. For plants exposed to high wind hazards, FLEX equipment should be stored 

in one of the following configurations: 

Revision 1 

a. In a structure that meets the plant's design basis for high wind hazards 

(e.g., existing safety-related structure). 

b. In storage locations designed to or evaluated equivalent to ASCE 7-10, 

Minimum Design Loads for Buildings and Other Structures given the 

limiting tornado wind speeds from Regulatory Guide 1. 76 or design basis 

hurricane wind speeds for the site. 

Page 16 of 74 2014-02-06 
• Given the FLEX basis limiting tornado or hurricane wind speeds, 

building loads would be computed in accordance with requirements of 

ASCE 7-10. Acceptance criteria would be based on building 

serviceability requirements not strict compliance with stress or 

capacity limits. This would allow for some minor plastic deformation, 

yet assure that the building would remain functional. 

• Tornado missiles and hurricane missiles will be accounted for in that 

the FLEX equipment will be stored in diverse locations to provide 

reasonable assurance that N sets of FLEX equipment will remain 

deployable following the high wind event. This will consider locations 

adjacent to existing robust structures or in lower sections of buildings 

that minimizes the probability that missiles will damage all mitigation 

equipment required from a single event by protection from adjacent 

buildings and limiting pathways for missiles to damage equipment. 

• The axis of separation should consider the predominant path of 

tornados in the geographical location. In general, tornadoes travel 

from the West or West Southwesterly direction, diverse locations 

should be aligned in the North-South arrangement, where possible. 

Additionally, in selecting diverse FLEX storage locations, 

consideration should be given to the location of the diesel generators 

and switchyard such that the path of a single tornado would not impact 

all locations. 

• Stored mitigation equipment exposed to the wind should be 

adequately tied down. Loose equipment should be in protective boxes 

that are adequately tied down to foundations or slabs to prevent 

protected equipment from being damaged or becoming airborne. 

(During a tornado, high winds may blow away metal siding and metal 

deck roof, subjecting the equipment to high wind forces.) 

c. In evaluated storage locations separated by a sufficient distance that 

minimizes the probability that a single event would damage all FLEX 

mitigation equipment such that at least N sets of FLEX equipment would 

remain deployable following the high wind event. (This option is not 

applicable for hurricane conditions). 

• Consistent with configuration b., the axis of separation should consider 

the predominant path of tornados in the geographical location. 

• Consistent with configuration b., stored mitigation equipment should 

be adequately tied down. 

On pages 25, 39 and 55 of the Integrated Plan, the licensee stated that the FLEX storage facility 

will be designed to withstand severe storms with high wind events to the magnitude discussed 

in the "General Integrated Plan Elements" section of the Integrated Plan. The reviewer noted 

that the cited portion of the Integrated Plan includes both the site design-basis tangential wind 

speed of 300 mph, which would be useable to conform to NEI 12-06, Section 7.3.1, 

Consideration 1.a., and the 200 mph wind speed derived from NEI 12-06, Figure 7-2. The use 

Revision 1 Page 17 of 74 2014-02-06 
of 200 mph, which is a wind speed also discussed in the cited portion of the Integrated Plan, 

would fall short of the design criteria for NEI 12-06, Section 7.3.1, Consideration 1.b. This is 

because the Consideration 1.b. criteria for the protective structures relies on the tornado wind 

speeds from Regulatory Guide (RG) 1.76, "Design-Basis Tornado and Tornado Missiles for 

Nuclear Power Plants." RG 1.76, Revision 1, which is based in part on the source document for 

NEI12-06, Figure 7-2, NUREG/CR-4461, Revision 2, provides the NRC Regulatory Position 

that design-basis tornado parameters from RG 1.76, Table 1 should be used for defining the 

design-basis tornado for a nuclear power plant. Using this Regulatory Position would result in a 

design-basis tornado wind speed of 230 mph for PNP's site. (Use of the prior revision of RG 

1.76 would result in a design-basis tornado wind speed of 360 mph.) The licensee should 

confirm that the structures will meet the plant's design-basis tornado wind speed of 300 mph or 

will be designed or evaluated equivalent to ASCE 7-10 using a tornado wind speed of 230 mph 

with separation and diversity between the storage locations. If the method of protection chosen 

is the later, the licensee should justify that the separation and diversity is adequate. This is 

identified as Confirmatory Item 3.1.3.1.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to storage to FLEX equipment during 

high wind events, if these requirements are implemented as described. 

3.1.3.2 Deployment of FLEX Equipment- High Wind Hazard 

NEI 12-06, Section 7.3.2 states: 

There are a number of considerations which apply to the deployment of FLEX 

equipment for high wind hazards: 

1. For hurricane plants, the plant may not be at power prior to the simultaneous 

ELAP and LUHS condition. In fact, the plant may have been shut down and 

the plant configuration could be established to optimize FLEX deployment. 

For example, the portable pumps could be connected, tested, and readied for 

use prior to the arrival of the hurricane. Further, protective actions can be 

taken to reduce the potential for wind impacts. These factors can be credited 

in considering how the baseline capability is deployed. 

2. The ultimate heat sink may be one of the first functions affected by a 

hurricane due to debris and storm surge considerations. Consequently, the 

evaluation should address the effects of ELAP/LUHS, along with any other 

equipment that would be damaged by the postulated storm. 

3. Deployment of FLEX following a hurricane or tornado may involve the need to 

remove debris. Consequently, the capability to remove debris caused by 

these extreme wind storms should be included. 

4. A means to move FLEX equipment should be provided that is also 

reasonably protected from the event. 

5. The ability to move equipment and restock supplies may be hampered during 

a hurricane and should be considered in plans for deployment of FLEX 

Revision 1 Page 18 of 74 2014-02-06 
equipment. 

Because PNPP is not susceptible to hurricanes, considerations 1, 2, and 5 are not applicable. 

On page 15 of the Integrated Plan, the licensee states that it will develop FSGs. The FSGs will 

be used to develop site-specific procedures used to cope with ELAP in a manner that is 

compliant with NEI 12-06. The licensee stated that the FSGs would interface with controlling 

procedures such as EOPs, AOPs, and SOPs. The licensee states that the procedures will 

direct the movement of the FLEX transfer pump to the Lake Michigan access, as required so 

that it will be able to function by the hour 4 after the declaration of the ELAP event. 

The licensee stated that debris removal equipment will be procured to ensure that onsite 

roadways are passable following a BDBEE. Offsite travel paths from the offsite response center 

will be assessed as part of the Regional Response Center (RRC) response dependent on postevent conditions. The licensee did not address a means to move FLEX equipment that is also 

reasonably protected from the event. This has been identified as Confirmatory Item 3.1.3.2.A in 

Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to deployment of FLEX equipment 

during high wind events, if these requirements are implemented as described. 

3.1.3.3 Procedural Interfaces - High Wind Hazard 

As discussed in NEI 12-06, Section 7.3.3, the following procedural interface considerations 

should be addressed: 

The overall plant response strategy should be enveloped by the baseline 

capabilities, but procedural interfaces may need to be considered. For example, 

many sites have hurricane procedures. The actions necessary to support the 

deployment considerations identified above should be incorporated into those 

procedures. 

On page 15 of the Integrated Plan, the licensee states that it is a participant in the PWROG 

project and will develop FSGs that supports implementation of FLEX by the Spring of 2015. 

The FSGs will be used to develop site-specific procedures used to cope with ELAP in a manner 

that is compliant with NEI 12-06. Further, the licensee stated that the FSGs will be implemented 

as necessary to maintain the key safety functions of core cooling, containment, and spent fuel 

pool cooling in parallel with the controlling procedure actions. The licensee stated that the 

FSGs would interface with controlling procedures such as EOPs, AOPs, and SOPs. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides 

reasonable assurance that the requirements of Order EA-12-049 will be met with respect 

to procedural interfaces for high wind hazards, if these requirements are implemented as 

described. 

3.1.3.4 Considerations in Using Offsite Resources - High Wind Hazard 

Revision 1 Page 19 of 74 2014-02-06 
NEI 12-06, Section 7.3.4 states: 

Extreme storms with high winds can have regional impacts that could have a 

significant impact on the transportation of off-site resources. 

1. Sites should review site access routes to determine the best means to obtain 

resources from off-site following a hurricane. 

2. Sites impacted by storms with high winds should consider where equipment 

delivered from off-site could be staged for use on-site. 

The licensee has not identified the local assembly area, or provided a discussion regarding the 

means to be used to deliver equipment to the site. This has been combined with Confirmatory 

Item 3.1.1.4.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to use of off-site resources during 

high wind events, if these requirements are implemented as described. 

3.1.4 Snow, Ice and Extreme Cold 

As discussed in NEI 12-06, Section 8.2.1: 

All sites should consider the temperature ranges and weather conditions for their site in storing 

and deploying their FLEX equipment consistent with normal design practices. All sites outside 

of Southern California, Arizona, the Gulf Coast and Florida are expected to address deployment 

for conditions of snow, ice, and extreme cold. All sites located North of the 35th Parallel should 

provide the capability to address extreme snowfall with snow removal equipment. Finally, all 

sites except for those within Level 1 and 2 of the maximum ice storm severity map contained in 

Figure 8-2 should address the impact of ice storms. 

On page 2 of the Integrated Plan, regarding the determination of applicable extreme external 

hazards, the licensee stated that per the FLEX guidance all sites should consider the 

temperature ranges and weather conditions for their site in storing and deploying their FLEX 

equipment. That is, the equipment procured should be suitable for use in the anticipated range 

of conditions with normal design practices. The guidance provided in NEI 12-06, Section 8.2.1 

states that plants above the 35th parallel must consider extreme cold and snowfall. Per the 

UFSAR Figure 1-1, Sheet 1, Palisades' is located between 42 degrees 18 minutes Nand 42 

degrees 20 minutes N, which is above the 35th parallel and located in the Level 5 region for ice 

storms in NEI 12-06, Figure 8-2. Thus, the Palisades site screens in for the extreme cold 

hazard and the extreme ice storm hazard. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to screening for 

snow, ice and extreme cold hazards, if these requirements are implemented as described. 

3.1.4.1 Protection of FLEX Equipment - Snow, Ice, and Extreme Cold Hazard 

Revision 1 Page 20 of 74 2014-02-06 
NEI 12-06, Section 8.3.1 states: 

These considerations apply to the protection of FLEX equipment from snow, ice, 

and extreme cold hazards: 

1. For sites subject to significant snowfall and ice storms, portable FLEX 

equipment should be stored in one of the two configurations. 

a. In a structure that meets the plant's design basis for the snow, ice and 

cold conditions (e.g., existing safety-related structure). 

b. In a structure designed to or evaluated equivalent to ASCE 7-10, 

Minimum Design Loads for Buildings and Other Structures for the snow, 

ice, and cold conditions from the site's design basis. 

c. Provided the N sets of equipment are located as described in a. or b. 

above, the spare (N+1) set of equipment may be stored in an evaluated 

storage location capable of withstanding historical extreme weather 

conditions such that the equipment is deployable. 

2. Storage of FLEX equipment should account for the fact that the equipment will need 

to function in a timely manner. The equipment should be maintained at a 

temperature within a range to ensure its likely function when called upon. For 

example, by storage in a heated enclosure or by direct heating (e.g., jacket water, 

battery, engine block heater, etc.). 

On pages 25, 39 and 55 of the Integrated Plan, the licensee stated that the FLEX storage facility 

will be designed to withstand snow, ice, and extreme cold events to the magnitude discussed in 

the "General Integrated Plan Elements" section of the Integrated Plan. 

The licensee stated that the design of the FLEX storage facility is not complete. Although the 

licensee stated that cold temperatures, snow, and ice are conditions commonly experienced, 

the Integrated Plan did not specify what features would be used to ensure the functionality of 

FLEX equipment. During the NRC audit and review process, the licensee states that the 

preliminary design of the FLEX storage buildings will include considerations for harsh 

environment conditions by providing climate controls. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to protection of 

equipment for snow, ice and extreme cold hazards, if these requirements are implemented as 

described. 

3.1.4.2 Deployment of Portable Equipment- Snow, Ice and Extreme Cold Hazard 

NEI 12-06, Section 8.3.2 states: 

There are a number of considerations that apply to the deployment of FLEX 

equipment for snow, ice, and extreme cold hazards: 

Revision 1 Page 21 of 74 2014-02-06 
1. The FLEX equipment should be procured to function in the extreme 

conditions applicable to the site. Normal safety-related design limits for 

outside conditions may be used, but consideration should also be made for 

any manual operations required by plant personnel in such conditions. 

2. For sites exposed to extreme snowfall and ice storms, provisions should be 

made for snow/ice removal, as needed to obtain and transport equipment 

from storage to its location for deployment. 

3. For some sites, the ultimate heat sink and flow path may be affected by 

extreme low temperatures due to ice blockage or formation of frazil ice. 

Consequently, the evaluation should address the effects of such a loss of the 

UHS on the deployment of FLEX equipment. For example, if UHS water is to 

be used as a makeup source, some additional measures may need to be 

taken to assure that the FLEX equipment can utilize the water. 

On page 13 of the Integrated Plan regarding the deployment strategies of FLEX equipment in all 

modes, the licensee stated that deployment of FLEX equipment is described in the subsequent 

sections for each strategy and all modes. The broad-spectrum deployment strategies are 

unchanged for the different operating modes. The deployment strategies from the FLEX 

storage building to each staging area are identified, as well as the debris removal concerns, 

security barriers, and lighting needs as they apply to each deployment path. 

The licensee did not address snow and ice removal from the FLEX equipment deployment 

paths, nor was this topic addressed in a licensee identified open item. During the NRC audit 

and review process, the licensee stated that the preliminary design of the FLEX storage 

buildings will include considerations for harsh environment conditions by providing climate 

controls, protecting the equipment from wind, snow and ice and having paved access to existing 

employee parking areas. Winter weather driven events are predictable, and Palisades routinely 

has snow plows mounted and road sanders prestaged prior to snow/ice events. Plowing and 

sanding are routine to ensure safe passage of Palisades employees with onsite salt/sand 

capabilities to address icing. In addition, Palisades contracts a local provider for snow removal. 

As part of the FLEX storage building design process, haul paths will be identified. Subsequent 

actions will be identified and tracked to include into Palisades procedures adverse weather 

preparations providing assurance FLEX equipment deployment paths will be capable of being 

readily cleared of snow and ice to meet FLEX strategy timelines. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to deployment of 

FLEX equipment for snow, ice and extreme cold hazards, if these requirements are 

implemented as described. 

3.1.4.3 Procedural Interfaces- Snow, Ice and Extreme Cold Hazard 

NEI 12-06, Section 8.3.3 states: 

The only procedural enhancements that would be expected to apply involve 

addressing the effects of snow and ice on transport the FLEX equipment. This 

includes both access to the transport path, e.g., snow removal, and appropriately 

equipped vehicles for moving the equipment. 

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As described in Section 3.1.4.2 of this TER, during the NRC audit and review process, the 

licensee stated that the preliminary design of the FLEX storage buildings will include 

considerations for harsh environment conditions by providing climate controls, protecting the 

equipment from wind, snow and ice and having paved access to existing employee parking 

areas. Winter weather driven events are predictable, and Palisades routinely has snow plows 

mounted and road sanders prestaged prior to snow/ice events. Plowing and sanding are 

routine to ensure safe passage of Palisades employees with onsite salt/sand capabilities to 

address icing. In addition, Palisades contracts a local provider for snow removal. As part of the 

FLEX storage building design process, haul paths will be identified. Subsequent actions will be 

identified and tracked to include into Palisades procedures adverse weather preparations 

providing assurance FLEX equipment deployment paths will be capable of being readily cleared 

of snow and ice to meet FLEX strategy timelines. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to procedural 

interfaces for snow, ice and extreme cold hazards, if these requirements are implemented as 

planned. 

3.1.4.4 Considerations in Using Offsite Resources - Snow, Ice and Extreme Cold Hazard 

NEI 12-06, Section 8.3.4, states that: 

Severe snow and ice storms can affect site access and can impact staging areas 

for receipt of off-site material and equipment. 

The licensee has not identified the local assembly area, or provided a discussion regarding the 

means to be used to deliver equipment to the site. This has been combined with Confirmatory 

Item 3.1.1.4.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to use of off-site resources during 

snow, ice and extreme cold events, if these requirements are implemented as described. 

3.1.5 High Temperatures 

NEI 12-06, Section 9.2 states: 

All sites will address high temperatures. Virtually every state in the lower 48 

contiguous United States has experienced temperatures in excess of 110°F. 

Many states have experienced temperatures in excess of 120°F. 

In this case, sites should consider the impacts of these conditions on deployment 

of the FLEX equipment. 

On page 3 of the Integrated Plan, regarding the determination of applicable extreme external 

hazards, the licensee stated that due to Palisades' proximity to Lake Michigan, the site 

experiences cooler temperatures than most locations in their region, the 10 year maximum 

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temperature is 95 degrees F per UFSAR Section 2.5. However, the guidance in NEI 12-06 

Section 9.2 states that all sites within the continental United States will address the high 

temperature scenarios. Thus the Palisades site screens in for the extreme heat hazard. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to screening for 

high temperature hazards, if these requirements are implemented as described. 

3.1.5.1 Protection of FLEX Equipment- High Temperature Hazard 

NEI 12-06, Section 9.3.1, states: 

The equipment should be maintained at a temperature within a range to ensure 

its likely function when called upon. 

On page 25 of the Integrated Plan, regarding maintaining core cooling and heat removal, the 

licensee stated that the FLEX storage facility will be designed to withstand high temperature 

events to the magnitude discussed in the "General Integrated Plan Elements" section of the 

Integrated Plan. The licensee stated that the design of the FLEX storage facility is not 

complete. The licensee did not specify what features would be used to ensure the functionality 

of FLEX equipment in the presence of high temperature hazards. This is Open Item 3.1.5.1.A in 

Section 4.1. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Open Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to protection of FLEX equipment 

during high temperature events, if these requirements are implemented as described. 

3.1.5.2 Deployment of FLEX Equipment- High Temperature Hazard 

NEI 12-06, Section 9.3.2 states: 

The FLEX equipment should be procured to function, including the need to move 

the equipment, in the extreme conditions applicable to the site. The potential 

impact of high temperatures on the storage of equipment should also be 

considered, e.g., expansion of sheet metal, swollen door seals, etc. Normal 

safety-related design limits for outside conditions may be used, but consideration 

should also be made for any manual operations required by plant personnel in 

such conditions. 

On page 13 of the Integrated Plan regarding the deployment strategies of FLEX equipment in all 

modes, the licensee stated that deployment of FLEX equipment is described in the subsequent 

sections below for each strategy and all modes. The deployment strategies from the FLEX 

storage building to each staging area are identified, as well as the debris removal concerns, 

security barriers, and lighting needs as they apply to each deployment path. 

The licensee provided examples of the manual operations that are anticipated in response to an 

ELAP in the Integrated Plan. Such examples include manual isolation of the PCS letdown 

valves, breaker and switching operations, and manual control of the automatic depressurization 

Revision 1 Page 24 of 74 2014-02-06 
valves (ADVs). 

The licensee did not address the potential impact of high temperatures on the storage of 

equipment, e.g., expansion of sheet metal, or swollen door seals. This has been identified as 

Confirmatory Item 3.1.5.2.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to deployment of FLEX equipment 

during high temperature events, if these requirements are implemented as described. 

3.1.5.3 Procedural Interfaces- High Temperature Hazard 

NEI 12-06, Section 9.3.3 states: 

The only procedural enhancements that would be expected to apply involve 

addressing the effects of high temperatures on the portable equipment. 

The licensee stated that the design of the FLEX storage facility is not complete. The 

licensee did not specify what features would be used to ensure the functionality of FLEX 

equipment when deployed in the presence of High Temperatures. This is Open Item 

3.1.5.3.A in Section 4.1. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides 

reasonable assurance that the requirements of Order EA-12-049 will be met with respect 

to procedural interfaces for high temperature hazards, if these requirements are 

implemented as described. 

3.2 PHASED APPROACH 

Attachment (2) to Order EA-12-049 describes the three-phase approach required for mitigating 

BDBEEs in order to maintain or restore core cooling, containment and SFP cooling capabilities. 

The phases consist of an initial phase using installed equipment and resources, followed by a 

transition phase using portable onsite equipment and consumables and a final phase using 

offsite resources. 

To meet these EA-12-049 requirements, Licensees will establish a baseline coping capability to 

prevent fuel damage in the reactor core or SFP and to maintain containment capabilities in the 

context of a BDBEE that results in the loss of all ac power, with the exception of buses supplied 

by safety-related batteries through inverters, and loss of normal access to the UHS. 

As described in NEI 12-06, Section 1.3, plant-specific analyses will determine the duration of 

each phase. 

3.2.1 PCS Cooling and Heat Removal, and PCS Inventory Control Strategies 

Note: Palisades sometimes refers to the RCS as the primary coolant system (PCS) 

NEI 12-06, Table 3-2 and Appendix D summarize one acceptable approach for the reactor core 

Revision 1 Page 25 of 74 2014-02-06 
cooling strategies. This approach uses the installed emergency feedwater (EFW) system to 

provide steam generator (SG) makeup sufficient to maintain or restore SG level in order to 

continue to provide core cooling for the initial phase. This approach relies on depressurization 

of the SGs for makeup with a portable injection source in order to provide core cooling for the 

transition and final phases. This approach accomplishes primary coolant system (PCS) 

inventory control and maintenance of long term subcriticality through the use of low leak reactor 

coolant pump seals and/or borated high pressure PCS makeup with a letdown path. In mode 5 

(cold shutdown) and mode 6 (refueling) with SGs not available, this approach relies on an onsite pump for PCS makeup and diverse makeup connections to the PCS for long-term PCS 

makeup with borated water and residual heat removal from the vented RCS. 

As described in NEI12-06, Section 3.2.1.7 and JLD-ISG-2012-01, Section 2.1, strategies that 

have a time constraint to be successful should be identified and a basis provided that the time 

can be reasonably met. NEI 12-06, Section 3 provides the performance attributes, general 

criteria, and baseline assumptions to be used in developing the technical basis for the time 

constraints. Since the event is a beyond-design-basis event, the analysis used to provide the 

technical basis for time constraints for the mitigation strategies may use nominal initial values 

(without uncertainties) for plant parameters, and best-estimate physics data. All equipment 

used for consequence mitigation may be assumed to operate at nominal setpoints and 

capacities. NEI 12-06, Section 3.2.1.2 describes the initial plant conditions for the at-power 

mode of operation; Section 3.2.1.3 describes the initial conditions; and Section 3.2.1.4 

describes boundary conditions for the reactor transient. 

Acceptance criteria for the analyses serving as the technical basis for establishing the time 

constraints for the baseline coping capabilities described in NEI 12-06, which provide an 

acceptable approach, as endorsed by JLD-ISG-2012-01, to meeting the requirements of EA-12-

049 for maintaining core cooling are 1) the preclusion of core damage as discussed in NEI 12-

06, Section 1.3 as the purpose of FLEX; and 2) prevention of recriticality as discussed in 

Appendix D, Table D-1. 

As described in NEI 12-06, Section 1.3, plant-specific analyses determine the duration of the 

phases for the mitigation strategies. In support of its mitigation strategies, the licensee 

performed a thermal-hydraulic analysis for an event with a simultaneous loss of all alternating 

current (ac) power and loss of normal access to the ultimate heat sink for an extended period 

(the ELAP event). 

The licensee was requested to provide a discussion regarding Section 3.2 of WCAP-17601 

which discusses the PWROG recommendations that cover the following subjects for 

consideration in developing FLEX mitigation strategies: (1) minimizing reactor coolant pump 

(RCP) seal leakage rates; (2) adequate shutdown margin; (3) time initiating cooldown and 

depressurization; (4) prevention of the RCS overfill; (5) blind feeding an SG with a portable 

pump; (6) nitrogen injection from SITs [safety injection tanks], and (7) asymmetric natural 

circulation cooldown (NCC). 

During the audit process the licensee provided the following information regarding Section 3.2 of 

WCAP-17601: 

• Item 1: The early initiation of cooldown and depressurization discussed in Item 2 

reduces the seal differential pressure, further reducing seal leakage. 

• Item 2: The ELAP analysis assumes at 2 hours a plant cooldown commences at 

approximately 75 deg F/hr using the atmospheric dump valves to approximately 350 deg 

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F cold leg temperatures and the plant is stabilized. During the plant cooldown the safety 

injection tanks (SIT) will inject borated water. Additional inventory and borated water will 

be required. The ELAP analysis (CN-SEE-11-13-5 (REDACTED) Rev1) concluded that 

a FLEX pump (which can provide at least 30 gpm at pressures up to 300 psia) started 

within 8 hours will maintain the primary coolant in a single phase flow condition 

assuming the seal leakage listed in WCAP-17601-P, Revision 1 for combustion 

engineering design. Furthermore, when started at 13 hours and operated for 7 hours, 

will provide sufficient shutdown margin at 24 hours to overcome Xe decay and maintain 

at least 1% shutdown margin indefinitely for hot leg temperatures of approximately 355 

deg F. The Palisades FLEX pump will be an installed charging pump which exceeds the 

assumed capacity and discharge pressure. 

• Item 3: The ELAP analysis assumes a cooldown to approximately 350 deg F cold leg 

temperatures. The analysis also includes considerations to prevent SIT N2 injection into 

the primary coolant system. Because of SIT N2 injection concerns, when developed, 

FLEX procedures will ensure the cooldown is secured at a primary coolant system 

pressure adequate to prevent SIT N2 injection. See (6) for additional details. 

• Item 4: The ELAP analysis describes opening the reactor vessel upper head vent to 

allow refilling the upper head and provides a letdown path during the boration period. 

The analysis recommends that makeup flow be halted by procedure if indicated level in 

the pressurizer reaches its upper bound or primary coolant pressure exceeds a 

maximum determined by procedure. It is also recommended that the vent be shut when 

the makeup pump is secured, unless letdown flow is required to make room for more 

borated water. When developed, FLEX procedures will include guidance to mitigate 

primary coolant system overfill. 

• Item 5: Blind feeding of a steam generator (SG) with a portable pump will not occur. 

Qualified SG level instrumentation remains available during the event and 

communications will be established between the control room and flow control locations 

for controlling steam generator levels. 

• Item 6: The Palisades ELAP analysis determined the minimum primary coolant system 

pressure to ensure that SIT N2 is not injected into the primary coolant system is 136.4 

psig. However, for conservatism the analysis stated the plant should not operate with an 

RCS pressure below143.6 psia. Therefore, when developed, FLEX procedures will 

ensure the cooldown is secured at a primary coolant system pressure adequate to 

prevent SIT N2 injection. 

• Item 7: NEI 12-06 states that the ADVs operate as designed. FLEX procedures will 

maintain level in both SG's in the post-trip range eliminating the concern for asymmetric 

natural circulation cooldown. 

During the audit and review process, the licensee was asked to provide information regarding 

action at hour 0.95 documented on page 80 of the Integrated Plan, and to discuss operator 

actions required within 0.95 hour prior to declaration of the ELAP and show that all the required 

actions can be reasonably be met. 

In its response to the audit, the licensee stated that operator actions performed in the first 20 

minutes of the event are associated with standard post-trip actions (EOP-1.0) and station 

blackout recovery (EOP-3.0). Along with main control board instrumentation and reports for the 

field, preliminary evaluations concluded that equipment assessments can be reasonably 

estimated to a degree to declare the ELAP within 0.95 hours. This information will be updated 

when procedures are developed and validated. The updated information regarding the required 

operator actions and the associated operator actions times in 20 minutes is needed from the 

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licensee to determine whether the operator actions are adequate and reasonably achievable. 

This is identified as Confirmatory Item 3.2.1.A in Section 4.2. 

During the NRC audit and review process, the licensee was asked to provide justification for 

meeting the time constraint that states that at hour 5 of the event, that deployment of the PCS 

makeup pump will be completed at hour 8. 

In its response to the NRC audit and review process question, the licensee stated that 

preliminary evaluations have extended the time to deploying the FLEX generator to hour 6 that 

will be used to re-power an installed charging pump. This information will be updated when 

procedures and design for equipment storage locations are developed and validated via 

walkthroughs. The evaluation will also include either validating the robustness of the charging 

pump control circuit or provide FLEX procedure guidance to manually operate the charging 

pumps by breaker operation. The updated information regarding the FLEX generator 

deployment and operation of the charging pump is needed from the licensee to determine 

adequacy of use of the charging pump for PCS inventory makeup during an ELAP. This is 

identified as Confirmatory Item 3.2.1.B in Section 4.2. 

During the NRC audit and review process, the licensee was asked to discuss the robustness of 

the charging pumps and the boric acid system, since they are currently part of the mitigation 

strategy for providing makeup to the PCS during Phase 2. 

In response to the NRC audit and review process question, the licensee states that additional 

review of plant documentation, determined that each of these pumps is seismically robust. 

Evaluation of the piping from the BASTs to the pump suction identified a section of piping which 

requires additional evaluation. This will be resolved during the detailed design process and will 

be provided in a future six- month update report. The information regarding the evaluation 

results of seismic robustness for the BAST piping is needed from the licensee to determine the 

adequacy of the use of the BAST water as a supply source for the charging pumps. This is 

identified as Confirmatory Item 3.2.1.C in Section 4.2 below. 

During the NRC audit and review process, the licensee was asked to provide information 

concerning the ADV modifications described in the Integrated Plan. 

In response, the licensee stated that a design change is in the preliminary stages to modify the 

ADV backup nitrogen supply source from the High Pressure System to bottled nitrogen. The 

size of the source will be determined during the design process to support the SOE. 

Calculations will be performed to determine the volume of nitrogen required for each valve 

actuation, the number of actuations required, the estimated nitrogen leakage for each valve, and 

the overall time that nitrogen supply will be required without makeup. The ADVs and control 

circuit are powered from the Class 1 E batteries and will not be impacted by the extended load 

shed that will extend battery capability for approximately 8 hours. Procedures will be written to 

align the nitrogen supply source to the ADVs in response to enable control room operation for 

stabilizing the plant following the reactor trip. No further actions will be required to enable 

commencing the cooldown at 2 hours. 

During the NRC audit and review process, the licensee was asked, concerning the use of the 

Volume Control Tank (VCT) and SIRWT to provide makeup to the PCS, to provide more 

information about the tanks' seismic and wind missile hazard robustness. Further, the licensee 

was asked to provide more information about the alternate protected borated water sources as 

described for their usage along with the Lake Michigan water source, including other time critical 

Revision 1 Page 28 of 74 2014-02-06 
actions in the event that the SIRWT and/or VCT are unavailable. 

In response to the NRC audit and review process question, the licensee states that the VCT is 

missile protected however, the SIRWT is not. Crediting the VCT or SIRWT for a seismic event 

will require additional evaluations. There are no plans to credit the SIRWT or the VCT as a 

source of borated water. Additionally, because the SIRWT is not missile protected, the 

Integrated Plan includes Open Item 16 to evaluate an alternative borated water tank to 

supplement the water volume that may be added when Lake Michigan is the source. 

Evaluations are planned to provide an engineering solution that allows mixing of the BAST 

concentrated borated water with non-borated water. While the source of the non-borated water 

has not yet been determined, Lake Michigan is an available source. An installed connection to 

the charging pump suction already exists. Since the SIRWT and/or VCT is currently not 

planned to be credited, there are no time critical actions associated with unavailability. In 

addition, NEI 12-06 section 3.2.1.2 states that no additional failures are assumed to occur 

immediately prior to or during the event. This is identified as Confirmatory Item 3.2.1.D in 

Section 4.2 below. 

During the audit, the licensee was asked to confirm that the primary ELAP strategy is to perform 

a symmetric cooldown using all RCS loops. 

In response, the licensee states that as described above, NEI 12-06 section 3.2.1.4 states that 

ADVs are assumed to operate as designed. FLEX procedures will maintain level in both steam 

generators in the post-trip range which will eliminate the concern for asymmetric natural 

circulation cooldown. The licensee relies on the ADVs to release steam from the SGs to cool 

down the plant during an ELAP, which may be initiated from external hazards including hazards 

of tornado missiles. The ADVs at Palisades have two design functions, the first being that of a 

pressure boundary and the second being that of a control system for a vent path. The licensee 

should justify the continued functionality of the ADVs in the context of a tornado missile hazard 

resulting in an ELAP in order to support a symmetric cooldown given that the design basis 

operability of the ADVs appears to allow for incapacitation of individual ADVs. Alternatively, the 

licensee may address the effects of asymmetric natural circulation cooldown. This is identified 

as Confirmatory Item 3.2.1.E in Section 4.2. 

During the NRC audit and review process, the licensee was asked to provide a summary of 

nonsafety-related equipment that is used in the mitigation strategies including a discussion of 

whether the equipment is qualified to survive all ELAP events. In response to the NRC audit 

and review process question, the licensee states that all installed equipment credited in 

mitigating strategies will be evaluated to verify conformance to the external event criteria 

described in NEI-12-06. This is identified as Confirmatory Item 3.2.1. F in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Items, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to RCS cooldown and PCS inventory 

strategies, if these requirements are implemented as described. 

3.2.1.1 Computer Code Used for the ELAP Analysis 

NEI 12-06, Section 1.3 states: 

To the extent practical, generic thermal hydraulic analyses will be developed to 

Revision 1 Page 29 of 74 2014-02-06 
support plant- specific decision-making. Justification for the duration of each 

phase will address the on-site availability of equipment, the resources necessary 

to deploy the equipment consistent with the required timeline, anticipated site 

conditions following the beyond-design-basis external event, and the ability of the 

local infrastructure to enable delivery of equipment and resources from off- site. 

The licensee has provided a Sequence of Events (SOE) in their Integrated Plan, which included 

the time constraints and the technical basis for the site. That SOE is based on an analysis 

using the industry-developed Combustion Engineering Nuclear Transient Simulation (CENTS) 

computer code. CENTS was written to simulate the response of pressurized water reactors to 

non-loss of coolant accident (LOCA) transients for licensing basis safety analysis. 

The licensee has decided to use the CENTS computer code for simulating the ELAP event. 

Although the NRC staff does acknowledge that CENTS has been reviewed and approved for 

performing non-LOCA transient analysis, the NRC staff has not examined its technical 

adequacy for simulating the ELAP transient. A generic concern associated with the use of 

CENTS for ELAP analysis arose because NRC staff reviews for previous applications of the 

CENTS code had imposed a condition limiting the code's heat transfer modeling in natural 

circulation to the single-phase liquid flow regime. This condition was imposed due to the lack of 

benchmarking for the two-phase flow models that would be LOCA scenarios. Because the 

postulated ELAP scenario generally includes leakage from reactor coolant pump seals and 

other sources, two-phase natural circulation flows may be reached prior to reestablishing 

primary makeup. Therefore, the NRC staff requested that the industry provide adequate basis 

for reliance on simulations with the CENTS code as justification for licensees' mitigation 

strategies. 

To address the NRC staff's concern associated with the use of CENTS to simulate two-phase 

natural circulation flows that may occur during an ELAP for the licensee and other Combustion 

Engineering (CE)-designed PWRs, the PWROG submitted a position paper dated September 

24, 2013, entitled "Westinghouse Response to NRC Generic Request for Additional Information 

(RAI) on CENTS Code in Support of the Pressurized Water Reactor Owners Group (PWROG)" 

(ADAMS Accession No. ML 13297A174 (Non-Publicly Available)). This position paper provided 

a comparison of several small-break LOCA simulations using the CENTS code to the 

CEFLASH-4AS code that was previously approved for analysis of design-basis small-break 

LOCAs. The analyses in the position paper show that the predictions of CENTS were similar or 

conservative relative to CEFLASH-4AS for key figures of merit for natural circulation conditions, 

including the predictions of loop flow rates and the timing of the transition to reflux boiling. The 

NRC staff further observed the fraction of the initial PCS mass remaining at the transition to 

reflux boiling predicted by the CENTS code for the ELAP simulations in WCAP-17601-P to be 

(1) in reasonable agreement with confirmatory analysis performed by the staff with the TRACE 

code and (2) within the range of results observed in scaled thermal-hydraulic tests that involved 

natural circulation (e.g., Semiscale Mod-2A, ROSA-IV large-scale test facility). After review of 

this position paper, the NRC staff endorsed a resolution through letter dated October 7, 2013 

(ADAMS Accession No. ML 13276A555 (Non-Publicly Available)). This endorsement contained 

one limitation on the CENTS computer code's use for simulating the ELAP event. That 

limitation is provided as follows: 

• The use of CENTS in the ELAP analysis for CE plants is limited to the flow conditions 

prior to reflux boiling initiation. This is identified as Confirmatory Item 3.2.1.1.A in Section 

4.2 below. 

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The requested information includes providing a justification for how the initiation of reflux boiling 

is defined. Specifically, the CENTS-calculated flow quality at the top of the SG U-tube should 

be provided for condition when two-phase natural circulation ends and reflux boiling initiates. 

Also, the licensee should discuss how the applicable ELAP analyses meet the above limitation 

on the use of CENTS. 

On page 84 of the Integrated Plan, regarding the assumptions used in the analyses to establish 

the sequence of events and time constraints, the licensee stated supported by Reference G8 

Table C-4, Entergy has evaluated WCAP-17601-P considering PNP site-specific parameters 

and determined that the conclusions of that document are applicable to PNP. Entergy has 

performed analysis consistent with the recommendations of the core cooling position paper. 

There are no deviations in the Palisades FLEX conceptual design with respect to the PWROG 

guidance. 

In Table C-4, "Palisades Plant Specific Evaluation of Significant PWROG Generic NSSS 

Parameters Supporting FLEX Implementation," of Nexus Document 12-4105-03-08, Rev. 0, 

"Palisades FLEX Implementation Plan," February 2013, the licensee stated that the CENTS 

computer code was used in its plant specific analysis in order to meet WCAP-17061-P. The 

analysis was used in determining PCS makeup requirements and timing accounting for 

expected sources of PCS inventory loss and changes in PCS volume due to primary system 

cooldown and depressurization. 

Further, in Table C-4 mentioned above, the licensee stated that a Palisades specific CENTS 

basedeck was not available for the analysis in PNP document CN-SEE-11-213-5, Rev. 

1 ,"Palisades Reactor Coolant System (RCS) Inventory and Shutdown Margin Analysis to 

Support the Diverse and Flexible Coping Strategies (FLEX)". The St. Lucie Unit 1 CENTS 

basedeck was used instead. St. Lucie Unit 1 is very similar in RCS volume configuration to 

Palisades and therefore, the timing of key events such as flow transitions and boration rates are 

considered to be adequately similar. This approach is consistent with WCAP -17601-P and 

therefore does not constitute a deviation. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to successful 

closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to the computer codes used to 

perform ELAP analysis if these requirements are implemented as described. 

3.2.1.2 Primary Coolant Pump (PCP) Seal Leakage Rates 

NEI 12-06, Section 1.3 states: 

To the extent practical, generic thermal hydraulic analyses will be developed to 

support plant specific decision-making. Justification for the duration of each 

phase will address the on-site availability of equipment, the resources necessary 

to deploy the equipment consistent with the required timeline, anticipated site 

conditions following the beyond-design-basis external event, and the ability of the 

local infrastructure to enable delivery of equipment and resources from offsite. 

Note: Palisades refers to reactor coolant pumps as primary coolant pumps PCPs) 

During ELAP, cooling to the Reactor Coolant Pumps (RCPs) seal packages will be lost and 

Revision 1 Page 31 of 74 2014-02-06 
water at high temperatures may degrade seal materials leading to excess seal leakage from the 

Reactor Coolant System (RCS). Without ac power available to the emergency core cooling 

system, inadequate core cooling may result from the leakage out of the seals. The ELAP 

analysis credits operator actions to align the high pressure RCS makeup sources and replenish 

the RCS inventory in order to ensure the core is covered with water, thus precluding inadequate 

core cooling. The amount of high pressure RCS makeup needed is mainly determined by the 

seal leakage rate, therefore the seal leakage rate is of primary importance in an ELAP analysis 

as greater values of the leakage rates will result in a shorter time period for the operator action 

to align the high pressure RCS makeup water sources. 

The licensee provided a Sequence of Events (SOE) in their Integrated Plan, which included the 

time constraints and the technical basis for their site. The SOE is based on an analysis using 

specific RCP seal leakage rates. The issue of RCP seal leakage rates was identified as a 

Generic Concern and was addressed by the NEI in the following submittals: 

• WCAP-1760 1-P, Revision 1 , "Reactor Coolant System Response to the Extended 

Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & 

Wilcox NSSS Designs" dated January 2013 (ADAMS Accession Nos. ML 13042A011 

and ML 13042A013 (Non-Publicly Available)). 

• A position paper dated August 16, 2013, entitled "Westinghouse Response to NRC 

Generic Request for Additional Information (RAI) on Reactor Coolant Pump (RCP) 

Seal Leakage in Support of the Pressurized Water Reactor Owners Group 

(PWROG)" (ADAMS Accession No. ML 13235A151 (Non-Publicly Available)). 

After review of these submittals, the NRC staff has placed certain limitations for Combustion 

Engineering (CE) designed plants (with the exception of Palo Verde Nuclear Generating 

Station). Those limitations and the corresponding Confirmatory Item number for this TER are 

provided as follows: 

1. The RCP seal initial maximum leakage rate should be greater than or equal to the 

upper bound expectation for the seal leakage rate for the ELAP event (15 gpm/seal) 

discussed in the PWROG position paper addressing the RCP seal leakage for CE 

plants (Reference 2). If the RCP seal leakage rate used in the plant-specific ELAP 

analysis is less than upper bound expectation for the seal leakage rate discussed in 

the position paper, justification should be provided. This is identified as Confirmatory 

Item 3.2.1.2.A in Section 4.2. 

On page 35 of its Integrated Plan the licensee states that Palisades' strategy for coping with an 

ELAP includes an early cooldown to low pressure to further minimize leakage from the Primary 

Coolant Pump (PCP) seals. As the plant cools down and the PCS volume begins to shrink, 

some makeup will be required; however this will be accomplished by lowering PCS pressure 

below 300 psig. This action will allow the Safety Injection Tanks (SITs) to discharge to the PCS 

for makeup. Given the expected start time for cooldown and limiting cooldown rate, this will 

happen at approximately 5 hours. Additionally, boron addition will not be required to maintain 

adequate shutdown margin to criticality until 13 hours into the event. 

On page 35 of the Integrated Plan regarding maintaining PCS inventory control during the initial 

phase, the licensee stated that PCS inventory control during Phase 1 is controlled by isolation of 

the letdown and the performance of installed PCP seals. With the successful use of these two 

items, the leakage from the PCS will be minimized. In the event of an ELAP, valves in the PCS 

Revision 1 Page 32 of 74 2014-02-06 
letdown path automatically fail closed as a part of the containment isolation actions. In the 

event valves do not automatically close, operators can manually isolate the system. 

The licensee did not provide a site-specific analysis to validate assumed RCP Seal Leakage 

Rate. The applicable cases listed in Table 4.1.2.1-1 of WCAP-17601 assumed that the RCP 

seal leakage commences at the pressure in the PCS at the time subcooling in the PCS coldlegs is less than 50°F. The condition to assumes initiation of the RCP seal leakage is based on 

the information in Section 4.4.2 of WCAP 17601, which states that "the probability of seal failure 

greatly increases when there is less than 50°F subcooling in the Cold Legs." However, the 

licensee did not discuss whether the seal failure will occur or not when subcooling of the coolant 

in the RCS cold-legs is greater than 50°F. The licensee should specify the seal leakage flow 

assumed for the ELAP from the time zero to the timeframe when subcooling in the RCS coldlegs decreases to 50°F, and provide justification for the assumed leakage rate. This has been 

identified as Confirmatory Item 3.2.1.2.B in Section 4.2. 

The licensee further states that it is planning on changing the Integrated Plan to utilize a lower 

maximum RCP seal leak rate based on the plant's design capability to isolate the CBO line 

through both the CBO header isolation and CBO header relief valve isolation. The practice of 

isolating the CBO line is institutionalized through the present SBO response procedure, EOP3.0, and will occur within the 20 minute isolation time analyzed in WCAP-16175-P. Both the 

CBO header and header relief isolation valves are direct current (de) powered air operated 

valves capable of being remotely isolated from the main control room. The Palisades PCPs are 

Byron Jackson model DFSS with FlowServe N-9000 4-stage seals. WCAP 16175-P provides a 

failure model analysis associated with loss of seal cooling (LOSC) for CE NSSS Plants. This 

document provides RCP seal analysis associated with various LOSC event initiators including 

the SBO Event initiator. This model was used as input for the CE RCP seal leakage analysis of 

WCAP 17601 for the "CBO Not Isolated" case. 

WCAP-17601 does not include seal leakage analysis forCE plants designed with CBO isolation 

capability. Therefore, while WCAP-17601 provides a bounding analysis assuming a 15 

gpm/pump seal leak rate for CE plants, the basis for expected design seal leakage with CBO 

isolation capability (CBO Isolated Case) forCE plants is provided in WCAP-16175. 

The licensee states that the NRC endorsed the model of WCAP-16175 via issuance of a Safety 

Evaluation Report associated with WCAP-16175-P-A (ADAMS Accession No. ML070240429). 

Since the Palisades operational practice for an SBO event is to isolate the CBO line completely 

(relief valve and common header), the RCP seal leakage analysis of WCAP-17601 is not 

directly applicable to model the PNP seal leakage characteristics and behavior for the ELAP 

event. The PNP operating practice to isolate the CBO line is predicated on an operating 

strategy designed to prevent the three RCP seal failure mechanisms (elastomer binding, 

elastomer extrusion, and seal face hydraulic instability - "pop open") described in WCAP-16175 

from occurring thereby providing maximum protection against seal failure and hence seal 

leakage. The SBO analysis of WCAP 16175 was based on normal plant operating practice to 

cope with the SBO event through extended maintenance of subcooling through slow cooldown 

and slow depressurization. This type of coping results in extended elevated PCS temperature 

of approximately 350 degrees F five hours into the event. Because of this, PCS temperature 

will be reduced sooner in the loss of power event than that analyzed in the SBO scenario of 

WCAP-16175. Seal cartridge temperatures will not be maintained at elevated RCS temperature 

conditions as long as those analyzed in the SBO event of WCAP-16175. It is recognized that 

the SBO event is not equivalent to the ELAP event (SBO event is a short duration event of 

approximately 8 hours whereas the ELAP event is expected to last indefinitely). However, the 

SBO analysis of WCAP 16175 with CBO Isolated is considered applicable and binding based on 

Revision 1 Page 33 of 74 2014-02-06 
the following: 

1. The analysis is specific to the CE NSSS Fleet (WCAP-16175, 1.2)- Palisades is a 

CE plant. 

2. The analysis addresses Palisades unique RCP/Seal Combination (WCAP-16175, 

Table 3.1.2) 

3. RCPs trip at the initiation of the SBO and ELAP event- same response 

characteristic 

4. The loss of seal cooling is caused by loss of motive power to the cooling water 

pumps -same response characteristic 

5. Isolation of the CBO line will occur within occur 20 minutes which is enveloped by 

the analysis of WCAP-16175. For the purposes of WCAP-16175 and pertinent 

data this time is considered "late" or "delayed" isolation and the technical data 

associated with the response is for the delayed or late isolation condition (e.g., 

Table 5.3-2a of WCAP-16175). 

6. The temperature rate of rise within the seal cartridge of the SBO event with CBO 

isolated is bounding for the reason noted above (i.e., Palisades will conducted an 

early cooldown therefore temperatures within the RCS will decrease sooner in the 

loss of power condition than assumed in the base analysis). This preserves the 

analysis with respect to the elastomeric failure mechanisms which are temperature 

related failure modes. Temperatures are assured to not exceed those presented in 

the SBO event applicable to the Palisades CBO isolated condition is depicted in 

WCAP-16175, Table 5.3-2a, "CBO Isolated Late column." This table shows the 

highest temperature to be below the expected long term service conditions for the 

elastomers of the Palisades seal cartridge assembly (WCAP-16175, Table 3.1-1 ). 

A representative graph for the estimated Palisades seal cartridge elastomer 

performance at elevated temperature is shown in WCAP 16175, Figure 3.4-1 and 

is further discussed in Sections 3.4 and 7.3 of the report. Long term serviceability 

of the ethylene-propylene elastomers is expected at temperature in excess of 550 

degrees F even when exposed for extended durations of greater than 8 hours. 

Finally, the Safety Evaluation Report 9 notes the superior performance of the 

tungsten carbide facing material used in the Palisades seal cartridge design to 

ward against "heat checking" concerns for the seal faces. 

7. While the early cooldown may impact lower stage seal subcooling, maintenance of 

hydraulic seal face stability ("pop open" failure mode) is mitigated by two means, 

control of subcooling or maintenance of backpressure at greater than half the 

saturation pressure at the inlet temperature to prevent flashing (WCAP-16175, 

Section 4.2.3). When CBO is isolated, pressure across the seal faces and the "pop 

open" failure mode is effectively averted (WCAP-16175, Station Blackout Scenario 

discussion, page B-9). Additionally, the FlowServe N-9000 seals are designed 

such that when the seal is static, the seal faces are divergent further minimizing the 

potential for seal leakage (WCAP-16175, page B-42). Lastly, the rapid cooldown 

will assist in maintaining the RCS cold legs in a subcooled state. Maintenance of 

subcooling during the first 20 minutes prior to CBO isolation is bounded by the 

existing SBO analysis (WCAP-16175, Station Blackout Scenario discussion, pages 

B-9 and B-29), since there is no difference between the SBO scenario and the 

ELAP timeline during this period - Operator response is governed by the SBO 

event response procedural controls. 

8. The RCPs will not be restarted for the ELAP event consistent with the assumptions 

within the analysis for the SBO event. 

9. There are no plans for Palisades to restore seal cooling for the ELAP event at this 

Revision 1 Page 34 of 74 2014-02-06 
time. The focus of the Palisades plan is maintenance of the key safety functions 

for an indefinite period. It is noted that WCAP-16175 acknowledges that the 

FlowServe N-9000 seals are thermal shock resistant and restoration of seal cooling 

following an LOSC is unlikely to cause further damage. 

10. The materials of the RCP seals are consistent with the analysis. The elastomers 

are ethylene-propylene and the seal faces are tungsten carbide (WCAP-16175, 

Table 3.1-1 ). 

11. Validation of the CBO isolation capability will be via Plant Simulator as a function of 

finalizing the designs of the FLEX strategy to assure isolation using the existing 

EOP-3.0 procedural guidance can be effected by 20 minutes and that human 

factors requirements are appropriate to minimize the risk of human error. 

12. Palisades will perform a symmetric cooldown using all loops for both steam 

generators. 

13. Palisades will perform equipment qualification analysis as a function of finalizing 

the designs of the FLEX strategy for the CBO header and CBO relief valve isolation 

valves to ensure that they are robust for the ELAP event. 

14. Consistent with the SBO event analysis; heat removal for the PCS is assured by 

maintenance of the key safety functions of Reactor Core Cooling and will be 

performed by the SGs with the TDAFW pump providing the cooling water from the 

CST and it's makeup source the Primary System Makeup Tank {T-81 ). ADVs will 

respond as designed. As noted earlier, a key difference from the SBO event 

analysis will be that a rapid cooldown of the PCS will be conducted providing 

additional benefit to maintaining seal cartridge temperatures lower than that 

analyzed for the SBO event. 

15. The PWROG acknowledges that the capability to credit lower leakage values when 

CBO is isolated may be appropriate (L TR-FSE-13-45, Rev. 0). 

The licensee further identifies that the PNP maximum PCS leak rate applied will be 1 gpm/RCP 

Seal + Unidentified leakage. The basis for this leakage rate is: 

• Any combination of vapor stage intact or one of the three lower stages intact results in 

leakage values that are small or negligible. The normal vapor stage leakage is 

insignificant and is essentially masked by evaporation. This value is therefore 

conservative and bounding (WCAP-16175, 6.2.1 ), and, 

• This value exceeds the various combinations of expected seal stage leak rates for the 

CE plants as depicted in the "CBO Increase" column of Table 5.2-1 of WCAP-16175 

(Palisades has a nominal design CBO flow of 1.0 gpm, Reference WCAP-16175, Table 

3.2-1, page 3-3), and, 

• The leakage rate past individual stages during normal operation is restricted by internal 

pressure breakdown devices (PBD) to the nominal flow of 1 gpm (reference WCAP16175, A.5, page A-15), and, provided at least one of three lower stage PBDs remains 

functional, any flow from degraded lower stages out of the seal cartridge assembly 

through the vapor stage would be restricted to this value, and, 

• Of the industry event and testing data available, the analysis supports this value as a 

bounding value (WCAP-16175, page B-29), and, 

• This value is consistent with input used in the RCP seal leakage generic industry 

modeled analysis of WCAP-17601 at the onset of the ELAP event and bounds the input 

used in the plant specific Palisades seal leakage analysis for when for when CBO is 

isolated at 20 minutes into the event (CN-SEE-11-13.5, Revision 1, page 29). 

• The value utilized for Unidentified leakage is consistent with Assumption 18 of WCAPRevision 1 Page 35 of 74 2014-02-06 
17601 (Section 4.2.1) and consistent with the limits of Palisades Technical 

Specifications 

The licensee concludes that the SBO analysis provided in WCAP-16175 forms the basis for the 

maximum leakage rate condition for the Palisades station with CBO isolated. The SBO analysis 

ofWCAP-16175 bounds the PNP plant equipment, operator response and plant response to the 

ELAP event. The combination of isolation of the CBO line coupled with the existing ELAP cooldown strategy results in optimum seal preservation strategy for the ELAP event. The practice of 

isolating the CBO common header and CBO common header relief valve is institutionalized 

through existing operational guidance and training at PNP. Isolation of the CBO line effectively 

mitigates the three RCP failure mechanisms from the model of WCAP-16175. Isolation of the 

CBO coupled with a rapid cooldown provides an effective mitigation strategy for minimizing RCP 

seal leakage consistent with the recommendation of WCAP-17601, Section 3.2. However, the 

licensee did not discuss whether the failure of the PCP seals will occur or not during an ELAP 

before the CBO isolation. The licensee should provide the maximum temperature and pressure, 

and minimum subcooling of the coolant in the RCS cold-legs during the ELAP before the CBO 

isolation, and justify the assumption that the integrity of the RCP seals can be maintained, and 

the seal leakage rate is less than 1 gpm per RCP during an ELAP before the CBO is isolated. 

This is identified as Confirmatory Item 3.2.1.2.C in Section 4.2. 

From the licensee's Integrated Plan and the response to the audit questions discussed above, it 

is not clear to the reviewer whether the SOE and the associated time constraints in the 

licensee's finalized mitigation strategies will be based on: (1) the case discussed in WCAP17601-P without CBO isolation, which assumes the seal leakage rate of 15 gpm per RCP, or (2) 

the SBO case discussed in WCAP-16175 with CBO isolation, which assumes the seal leakage 

rate of 1 gpm per RCP. The licensee should (1) confirm whether above Case 1 without the 

CBO isolation, or Case 2 with the CBO isolation is used to establish its mitigation strategies, 

and (2) provide and justify the updated SOE and time constraints so established. This has been 

identified as Confirmatory Item 3.2.1.2.0 in Section 4.2. 

During the audit and review process, the licensee was asked to provide additional information 

regarding assumption 2 on page 4-35 ofWCAP-17601 which states that "Once RCP seal failure 

occurs, the leakage flow path characteristics remain constant for the rest of the event." The 

licensee was asked to address the applicability of the information in Section 4.4.2 of WCAP17601, which states that "it has been shown that the probability of seal failure greatly increases 

when there is less than 50°F of subcooling in the Cold Legs." 

In response to the audit, the licensee states that the analysis of WCAP-17601 applies to the 

case when CBO is not isolated as noted above. Assumption 2 applies directly to the analysis 

supporting WCAP-17601. The pressure dependent model used in support of WCAP-17601 is 

the CENTS model. The CENTS model applies flow modeling for any flow out of the Primary 

Coolant System through leaks or relief valves and is based on standard critical flow correlations. 

The specifics of the model are proprietary. As noted above, Palisades is planning on changing 

its Integrated Plan to credit a reduced PCP Seal Leak rate due to the existing practice of 

isolation of the CBO line that is institutionalized at the station. The applicable PCP Seal failure 

and leak rate analysis for the Palisades station is that associated with the SBO event of WCAP16175 (not WCAP-17601) and specifically for the SBO scenario with CBO isolated. In the case 

of the CBO isolated condition, any leakage would have to be through the vapor seal and would 

be expected to be negligible as discussed above. While assumption 2 is not addressed by the 

model of WCAP-16175, the physical characteristics of the leak path for the non-modeled CBO 

Isolated case could be reasonably concluded to be valid because the flow path characteristics 

Revision 1 Page 36 of 74 2014-02-06 
would remain constant and be influenced by the driving head of the RCS. This enables the 

application of fundamental engineering principles of pressure drop across a seal cartridge that is 

not degraded because of CBO isolation. As the plant cools down the flow would be pressure 

dependent and decrease with lowering primary coolant system pressure. Since the CENTS 

modeled case does not exist for the condition with CBO flow isolated, there is no direct flow 

model analysis available. Maintenance of subcooling (>50 degrees F) is one important means 

to mitigate the potential for the "pop-open" failure mode to prevent flashing at the seal faces 

when CBO line is in service. As indicated in WCAP-16175, Table 4.2-3, if the CBO line is 

isolated, pressures will be equalized across the seal faces removing the potential for flashing 

and thus removing the mechanism for the failure, as previously described above. 

During the NRC audit and review process, the licensee was asked to discuss how the pressuredependent RCP seal leakage rates are calculated with respect to the use of the equivalent size 

of the break area based on the initial total RCP leakage rate. Further, the licensee was asked 

to discuss and justify the flow rate model used and to discuss whether the size of the break area 

is changed or not in the analysis for the ELAP event. Additionally, the licensee was asked to 

provide information regarding the friction losses in the leakage flow path that are credited in the 

pressure-dependent leak rate calculation, including whether friction loss model is adequate for 

the use in the RCP Seal Leak rate calculation. 

In its response to the NRC audit process, the licensee states that for PNP, no specific pressure 

dependent CENTS flow model is available for the case where CBO is isolated. 

During the NRC audit and review process, the licensee was asked to provide a discussion 

regarding the applicability of WCAP-17601-P to the ELAP analysis with respect to minimizing 

any seal temperature excursions above 500 degrees F and the effects on the upper seal stages 

and the vapor seal. Additionally, the licensee was asked to discuss the Westinghouse 

recommendation to conduct further testing with current FlowServe N-9000 seals seal 

configurations in order to get a quantifiable assessment of seal function at extreme temperature 

conditions for periods greater than 24 hours. 

In its response to the NRC audit process, the licensee states that as described above, the PNP 

PCP seals are FlowServe N-9000 4 stage seal assemblies. These seal assemblies contain 

ethylene-propylene elastomers. These types of elastomeric materials are capable of 

withstanding high temperatures in excess of 550 degrees F for extended duration without 

change in service properties. Section 6. 7 of WCAP 17601 is highlighting the concern with 

respect to high service temperature conditions on seal properties and the potential for 

elastomeric failure modes associated with "thermal binding" and "extrusion" (and, concerns for 

"heat checking" of the seal faces). Palisades is planning a change to the submitted Integrated 

Plan to credit CBO full isolation capability. The net effect of the CBO isolation strategy when 

combined with a plant cool-down commencing at 2 hours into the event will be to reduce 

primary coolant system pressure and temperature, such that within approximately 5 hours 

following the event, the RCS will reach a temperature of approximately 350 degrees F. By so 

doing, the heating effects to the seal and its elastomers are significantly reduced and long term 

seal sustainability is optimized. Any temperature rate of rise will be gradual, will be progressive 

throughout the stages (lower stage heats up first) and will occur over an extended period of 

time. Since Palisades is expected to affect isolation of the CBO within 20 minutes, all stage 

temperatures are expected to be maintained below the elastomeric materials service properties 

of 550 degrees F. Because of the CBO isolation, the method of heat-up will be via conduction. 

This strategy is consistent with the protocol noted. 

Revision 1 Page 37 of 74 2014-02-06 
The licensee further states that Section 6.8 is based on the information provided in 6.6 of WCAP 

17601 indicating that there is limited long term survivability testing associated with the elastomer 

formulations used in the RCP seals when exposed to high temperatures (in excess of 

approximately 550 degrees F). Since the Palisades strategy is to isolate the flow of hot RCS 

water through the seal cartridge and initiate RCS cool down at hour 2, the temperatures remain 

below 550 degrees F and therefore the recommendation is not pertinent. 

During the NRC audit and review process, the licensee was asked to provide the manufacturer's 

name and model number for the RCPs and the RCP seals. 

In response to the audit, the licensee states that as described above, the PNP PCP seals are 

FlowServe N-9000 seals. Further, the licensee states that the seal cartridge is described and 

covered by the discussion in WCAP 17601 (but, more applicably WCAP 16175 to the Palisades 

case where CBO is isolated). The PNP pump model number is not included in WCAP 17601, 

nor WCAP 16175. It is implicit in WCAP 16175 that the pump models for the CE fleet are 

addressed though the analysis. 

The reviewer further noted that the adequacy of protection against tornado missile hazards 

afforded the ADVs will be subject to further separate re-evaluation pursuant to Section 402 of 

Public Law 112-074, "Consolidated Appropriations Act," which requires that the NRC to require 

licensees to reevaluate the seismic, tsunami, flooding, and other external hazards at their sites 

against current applicable Commission requirements and guidance for such licenses as 

expeditiously as possible, and thereafter when appropriate. 

During the NRC audit and review process, the licensee was asked to confirm that load shed 

activities will not interfere with required valve positioning or operator action capability that may 

be credited in establishing ELAP response strategies, including specifically those actions related 

to isolating RCS leakage paths, including the CBO. 

In response to the NRC audit and review process question, the licensee states that the 

preliminary battery load shed strategy evaluation includes consideration of valve positioning that 

validates the capability for performing CBO isolation. This is combined with Confirmatory Item 

3.2.1.2.D in Section 4.2. 

During the NRC audit and review process, the licensee was asked if it is intended to credit 

significant improvement for ELAP related to the isolation of the CBO lines, and to confirm that 

CBO isolation procedures, human factors requirements, and equipment qualifications are 

applicable to the ELAP event and are able to be achieved within the time frames described in 

section 5.3.1 ofWCAP 16175. 

In response to the NRC audit and review process question, the licensee states that it will 

validate CBO isolation procedures for human performance and revise them as required, to 

ensure conformance within the bounds for the determined isolation time frame. Further, the 

licensee states that the CBO isolation valves and associated components will be evaluated for 

robustness for the ELAP event. This is combined with Confirmatory Item 3.2.1.2.D in Section 

4.2. 

The current understanding of the licensee's approach, as described above, is consistent with 

the guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the 

successful closure of issues related to the Confirmatory Items, provides reasonable assurance 

that the requirements of Order EA-12-049 will be met with respect to the reactor coolant pump 

Revision 1 Page 38 of 74 2014-02-06 
seal leakages rates, if these requirements are implemented as planned. 

3.2.1.3 Decay Heat 

NEI Section 3.2.1.2 states in part: 

The initial plant conditions are assumed to be the following: 

Prior to the event the reactor has been operating at 1 00 percent rated thermal 

power for at least 100 days or has just been shut down from such a power history 

as required by plant procedures in advance of the impending event. 

On page 80, in Attachment 1A for sequence of events, the licensee indicated that the initial 

power evaluated for an ELAP event was 100%. 

During the NRC audit and review process, the licensee was asked to address the applicability of 

assumption 4 on page 4-13 ofWCAP 17601, to Palisades. Assumption 4 states that decay heat 

is per ANS 5.1-1979 + 2 sigma, or equivalent. The licensee was asked to consider initial power 

level, fuel enrichment, fuel burn up, effective full power operating days per fuel cycle, number of 

fuel cycles, if hybrid fuels are used in the core, and fuel characteristics addressing whether they 

are based on the beginning of the cycle, middle of the cycle, or end of the cycle. 

In its response to the NRC audit and review question, the licensee states that Assumption 4 of 

WCAP 1760 1-P applies to the analyses performed for the WCAP 1760 1-P, of which the results 

of Section 5.2.3 were used in the development of the Integrated Plan. The applicability of ANS 

5.1-1979 + 2 sigma decay heat curve for Palisades will be addressed in a future six-month 

update report. This is identified as Confirmatory Item 3.2.1.3.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to decay heat rate determination, if 

these requirements are implemented as described. 

3.2.1.4 Initial Values for Key Plant Parameters and Assumptions 

NEI 12-06, Section 3.2 provides a series of assumptions to which initial key plant parameters 

(core power, RCS temperature and pressure, etc.) are required to conform. When considering 

the code used by the licensee and its use in supporting the required event times for the SOE, it 

is important to ensure that the initial key plant parameters not only conform to the assumptions 

provided in NEI 12-06, Section 3.2, but that they also represent the starting conditions of the 

code used in the analyses and that they are included within the code's range of applicability. 

On page 3 in the Integrated Plan, in regards to key site assumptions to implement NEI 12-06 

strategies, the licensee referred to section 2.3 of Nexus Document 12-4105-03-08, Rev. 0, 

"Palisades FLEX Implementation Plan," February 2013. 

A review was conducted of the licensee's baseline assumptions included in the Integrated Plan 

and the licensee's Nexus document and finds that it included all the relevant baseline 

assumptions assumed in NEI 12-06, Section 3.2.1.2, Section 3.2.1.3, 3.2.1.4, and 3.2.1.5, used 

with the baseline analyses for the determination of required times for the SOE. 

Revision 1 Page 39 of 74 2014-02-06 
The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to Initial Values for 

Key Plant Parameters and Assumptions, if these requirements are implemented as described. 

3.2.1.5 Monitoring Instrumentation and Controls 

NEI 12-06, Section 3.2.1.1 0 states, in part: 

The parameters selected must be able to demonstrate the success of the 

strategies at maintaining the key safety functions as well as indicate imminent or 

actual core damage to facilitate a decision to manage the response to the event 

within the Emergency Operating Procedures and FLEX Support Guidelines or 

within the SAMGs. Typically, these parameters would include the following: 

• SG Level 

• SG Pressure 

• RCS Pressure 

• RCS Temperature 

• Containment Pressure 

• SFP Level 

The plant-specific evaluation may identify additional parameters that are needed 

in order to support key actions identified in the plant procedures/guidance or to 

indicate imminent or actual core damage. 

On page 19 of the Integrated Plan regarding maintaining core cooling & heat removal, the 

licensee listed the installed instrumentation credited for maintaining core cooling and heat 

removal during Phase 1 of an ELAP. They included the following parameters: 

To support this function, the following instrumentation will be needed: 

SG Level, SG Pressure, CST Level, T-81 Level, PCS Pressure, PCS Temperature, Pressurizer 

Level, Reactor Vessel Level Indication, SIRW Tank Level. 

During the NRC audit and review process, the licensee was asked to discuss the analysis used 

to determine the containment temperature, pressure, and moisture profiles during the ELAP 

event and to address the adequacy of the computer codes/methodologies, and assumptions 

used in the analysis. 

In response to the NRC audit and review question, the licensee states that a preliminary 

evaluation has identified the instrumentation to be used for the ELAP mitigation based on the 

Palisades Integrated Plan. The evaluation includes identification of instrumentation meeting 

Regulatory Guide 1.97 Revision 3 and instrumentation listed in the Integrated Plan requiring 

additional evaluation to determine robustness to support FLEX strategies. No automatic actions 

will be credited other than those already credited as part of the current plant design and 

licensing basis at the beginning of the event which are not impacted (e.g., autostart of turbinedriven auxiliary feedwater pump, auxiliary feedwater flow initiation and reactor trip) at the onset 

of the external event. 

The licensee also states that a MAAP calculation will be performed to validate that containment 

profiles remain well within the containment temperature and pressure design parameters. 

Revision 1 Page 40 of 74 2014-02-06 
Results of the MAAP calculation will be utilized as an input to evaluate the robustness of key 

parameter instrumentation to support FLEX strategies. This is identified as Confirmatory Item 

3.2.1.5.A in Section 4.2. 

During the NRC audit and review process, the licensee was asked in regard to its on-going 

FLEX strategy evaluation, to provide the need for further instrumentation if identified by the 

evaluation. 

In response to the NRC audit and review process question, the licensee states that a 

preliminary evaluation has identified the instrumentation to be used for the ELAP mitigation 

based on the Integrated Plan and preliminary strategy changes identified during a strategy 

assessment. The evaluation includes identification of instrumentation meeting Regulatory 

Guide 1.97, Revision 3 and instrumentation requiring additional evaluation to determine 

robustness to support FLEX strategies. The evaluation also identified instrumentation not 

previously identified in the Integrated Plan (e.g., boric acid storage tank level instrumentation) 

and instrumentation identified in the Integrated Plan that provides redundancy for electrical 

system status but are not required (e.g., battery amp-hour meters). This is identified as 

Confirmatory Item 3.2.1.5.8 in Section 4.2. 

During the audit, the licensee was requested to provide additional description of the 

instrumentation that will be used to monitor portable FLEX electrical power equipment including 

their associated measurement tolerances/accuracy to ensure that the electrical equipment 

remains protected from power fluctuations, and that the operator is provided with accurate 

information to maintain core cooling, containment, and SFP cooling. In addition, provide a 

discussion on the issue of portable electrical instrumentation. 

During the audit the licensee stated that instrumentation to monitor portable FLEX electrical 

power equipment will be addressed later in the design and procedure development phase and 

will consider the equipment to which it will be connected. This has been combined with 

Confirmatory Item 3.2.1.5.8 in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Items, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to instrumentation and controls for the 

ELAP, if these requirements are implemented as described. 

3.2.1.6 Sequence of Events 

NEI 12-06 discusses an event timeline and time constraints in several sections of the document, 

for example Section 1.3, Section 3.2.1. 7 principle ( 4) and (6), Section 3.2.2 Guideline ( 1) and 

Section 12.1. 

NEI 12-06, Section 3.2.2, in part, addresses the minimum baseline capabilities: 

Each site should establish the minimum coping capabilities consistent with unit-specific 

evaluation of the potential impacts and responses to an ELAP and LUHS. In general, 

this coping can be thought of as occurring in three phases: 

• Phase 1: Cope relying on installed plant equipment. 

Revision 1 Page 41 of 74 2014-02-06 
• Phase 2: Transition from installed plant equipment to on-site FLEX equipment. 

• Phase 3: Obtain additional capability and redundancy from off-site equipment 

until power, water, and coolant injection systems are restored or commissioned. 

The SOE is discussed in the integrated plan on pages 9 and 10 and in Attachment 1 A on pages 

81, 82, and 83. 

On page 9 of the Integrated Plan, providing a sequence of events (SOE) and time constraint 

required for success, including the technical basis for the time constraint, the licensee stated 

that the sequence of events and any associated time constraints are identified for Palisades' 

Modes 1-4 strategies for FLEX Phase 1 through Phase 3. These actions are more bounding 

when compared to the Modes 5 and 6 and full core offload scenarios as they require the most 

personnel, actions, and time constraints. The times identified to initiate each action in this 

section and in Attachment 1A are based on resource loading to allow completion of all actions 

prior to their individual time constraints. Time critical completion times are included. Palisades' 

timeline is outlined in Attachment 1A. A timeline walkthrough will be completed when detailed 

design and site strategy is finalized. 

The licensee has not completed final analysis regarding validation of the action times reported 

in the Sequence of Events. 

During the NRC audit and review process, the licensee was asked to describe the methodology 

for the SOE timeline validation and to provide the results thereof, when available. 

In response to the NRC audit and review process question, the licensee states that although the 

Integrated Plan contains the preliminary SOE timeline, an assessment has been performed 

identifying potential changes. The methodology and results of the SOE timeline validation will 

include a walk through validation. This is identified as Confirmatory Item 3.2.1.6.A in Section 

4.2. 

During the NRC audit and review process, the licensee was asked to provide a discussion 

showing the impact of injection on reactivity because WCAP-17601-P does not include PCS 

makeup. Additionally, the licensee was asked to describe the impact of injection on actions that 

take place later in the Sequence of Events, including the time to switch water sources and 

provide mobile boration. 

In its response to the NRC audit and review process question, the licensee stated that its 

Integrated Plan contains a preliminary Sequence of Events timeline. A preliminary assessment 

has been performed identifying potential changes to the Sequence of Events. Validation 

methodology and results of the timeline will be provided when completed which is expected in a 

future six-month update report. The updated information regarding the Sequence of Events is 

needed from the licensee to confirm that the mitigation strategies listed in the Sequence of 

Events are updated and acceptable. This is identified as Confirmatory Item 3.2.1.6.8 in Section 

4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory ltem(s), provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to the sequence of events, if these 

requirements are implemented as described. 

Revision 1 Page 42 of 74 2014-02-06 
3.2.1. 7 Cold Shutdown and Refueling 

NEI 12-06, Table 1-1, lists the coping strategy requirements as presented in Order EA-12-049. 

Item ( 4) of that list states: 

Licensee or CP holders must be capable of implementing the strategies in all 

modes. 

The NRC staff reviewed the licensee's Integrated Plan and determined that the Generic 

Concern related to shutdown and refueling requirements is applicable to the plant. This Generic 

Concern has been resolved generically through the NRC endorsement of NEI position paper 

entitled "Shutdown/Refueling Modes" (ADAMS Accession No. ML 13273A514); and has been 

endorsed by the NRC in a letter dated September 30, 2013 (ADAMS Accession No. 

ML 13267 A382). 

The position paper describes how licensees will, by procedure, maintain equipment available for 

deployment in shutdown and refueling modes. The NRC staff concluded that the position paper 

provides an acceptable approach for demonstrating that the licensees are capable of 

implementing mitigating strategies in all modes of operation. Entergy Nuclear Operations 

informed the NRC of their plan to abide by this generic The NRC staff will evaluate the 

licensee's resulting program through the audit and inspection process. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides 

reasonable assurance that the requirements of Order EA-12-049 will be met with respect 

to the analysis of an ELAP during Cold Shutdown or Refueling if these requirements are 

implemented as described. 

3.2.1.8 Core Sub-Criticality 

NEI 12-06 Table 3-2 states in part that: 

All plants provide means to provide borated RCS makeup. 

On page 33 of the Integrated Plan regarding maintaining core cooling and heat removal mobile 

boration unit in the final phase, the licensee stated that the Mobile Boration Unit will be staged 

along Lake Michigan with the Water Purification Unit. The Mobile Boration Unit will have a tank 

where the purified water can be routed, mixed with boron, and then delivered to the desired 

tank. The requirements for this equipment must still be developed. 

During the NRC audit and review process regarding core subcriticality, the licensee was asked 

to discuss the results of the Palisades ELAP analysis and show that the core will remain subcritical during an ELAP. Further, the licensee was asked to discuss whether the uniform boron 

mixing model was used in its ELAP analysis and whether compliance with the recommendations 

discussed in a PWROG white paper the related to the boron mixing model exists. 

In its response to the NRC audit and review process question, the licensee states that the 

results of the PNP ELAP analysis conclude that the core will remain indefinitely sub-critical 

during an ELAP (for RCS temperatures of 350 degrees F after xenon has decayed away.) 

Minimum credit is conservatively taken for SIT injection as a result of the plant cooldown. The 

Revision 1 Page 43 of 74 2014-02-06 
remaining boron injection requirement is determined using the RCS FLEX pump parameters, 

minimum boron concentration of the injection source, and shutdown margin requirement. 

CENTS was used for all cases, with a St. Lucie Unit 1 base deck, modified for Palisades core 

parameters (St. Lucie Unit 1 is very similar in RCS volume configuration to Palisades). The 

analysis indicates sufficient shutdown margin from accumulator injection alone for the first 13 

hours, followed by RCS boration using the FLEX pump for 7 hours to reach the required 

concentration to indefinitely maintain the core sub-critical at 350 degrees F. The site-specific 

analysis differed from the analysis described in WCAP-17601 in that it included credit for RCS 

makeup via the FLEX pump whereas the WCAP analysis only credited SIT injection. The 

analysis in WCAP 17601 additionally assumed a constant, conservative moderator temperature 

coefficient (MTC) though the MTC will become considerably less negative as temperature 

drops, as discussed on page 5-218 ofWCAP-17601. 

The licensee further states that a uniform boron mixing model is used in the PNP ELAP 

analysis. The recommendation from the August 15, 2013 PWROG position paper (OG-13-284) 

referenced in the question, is to allow 60 minutes for assuming complete mixing. The position 

paper also indicates this is actually conservative since the boron concentration may actually be 

higher in the core than the rest of the RCS over that time period due to the flow from the cold 

leg injection into the core. The PNP strategy has sufficient margin between the time boration 

needs to begin (task begins at hour 8, time critical at hour 1 0) and finish (for subcriticality, start 

at hour 13, inject for 7 hours, must complete before 24 hours) to ensure adequate shutdown 

margin, additionally makeup will occur beyond this time period to account for RCS leakage and 

to ensure single phase natural circulation is maintained. 

The NRC staff reviewed the licensee's Integrated Plan and determined that the Generic 

Concern associated with the modeling of the timing and uniformity of the mixing of a liquid boric 

acid solution injected into the reactor coolant system (PCS) under natural circulation conditions 

potentially involving two-phase flow was applicable to Palisades. 

The Pressurized Water Reactor Owners Group submitted a position paper, dated August 15, 

2013 (withheld from public disclosure due to proprietary content), which provides test data 

regarding boric acid mixing under single-phase natural circulation conditions and outlined 

applicability conditions intended to ensure that boric acid addition and mixing would occur under 

conditions similar to those for which boric acid mixing data is available. During the audit 

process, the licensee informed the NRC staff of its intent to abide by the generic approach 

discussed above. In an endorsement letter dated January 8, 2014, ADAMS Accession No. 

ML 13276A 183, the NRC staff concluded that the August 15, 2013, position paper constitutes an 

acceptable approach for addressing boric acid mixing under natural circulation during an ELAP 

event, provided that the following additional conditions are satisfied: 

(1) The required timing for providing borated makeup to the primary system should consider 

conditions with no reactor coolant system leakage and with the highest applicable 

leakage rate for the reactor coolant pump seals and unidentified reactor coolant system 

leakage. 

(2) For the condition associated with the highest applicable reactor coolant system leakage 

rate, two approaches have been identified, either of which is acceptable to the staff: 

Revision 1 

a. Adequate borated makeup should be provided such that the loop flow rate in twophase natural circulation does not decrease below the loop flow rate 

corresponding to single-phase natural circulation. 

Page 44 of 74 2014-02-06 
b. If loop flow during two-phase natural circulation has decreased below the singlephase natural circulation flow rate, then the mixing of any borated primary 

makeup added to the reactor coolant system is not to be credited until one hour 

after the flow in all loops has been restored to a flow rate that is greater than or 

equal to the single-phase natural circulation flow rate. 

(3) In all cases, credit for increases in the reactor coolant system boron concentration 

should be delayed to account for the mixing of the borated primary makeup with the 

reactor coolant system inventory. Provided that the flow in all loops is greater than or 

equal to the corresponding single-phase natural circulation flow rate, the staff considers 

a mixing delay period of one hour following the addition of the targeted quantity of boric 

acid to the reactor coolant system to be appropriate. 

At the time the audit was conducted, the licensee had neither (1) committed to abide by the 

generic approach discussed above, including the additional conditions specified in the NRC's 

endorsement letter, nor (2) identified an acceptable alternate approach for justifying the boric 

acid mixing assumptions in the analyses supporting its mitigating strategy. To satisfactorily 

resolve this issue, the licensee should confirm its compliance with the conditions specified in the 

NRC endorsement letter discussed above. Alternatively, the licensee may identify an 

acceptable alternate approach for justifying the boric acid mixing assumptions in the 

subcriticality analyses. This is identified as Open Item 3.2.1.8.A in Section 4.1. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01 and subject to the successful 

closure of issues related to the Open Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to boron mixing, if these requirements 

are implemented as described. 

3.2.1.9 Use of Portable Pumps 

NEI 12-06, Section 3.2.2, Guideline (13), states in part: 

Regardless of installed coping capability, all plants will include the ability to use 

portable pumps to provide RPV/RCS/SG makeup as a means to provide diverse 

capability beyond installed equipment. The use of portable pumps to provide 

RCS/SG makeup requires a transition and interaction with installed systems. For 

example, transitioning ... to a portable pump for SG makeup may require 

cooldown and depressurization of the SGs in advance of using the portable 

pump connections. Guidance should address both the proactive transition from 

installed equipment to portable and reactive transitions in the event installed 

equipment degrades or fails. Preparations for reactive use of portable equipment 

should not distract site resources from establishing the primary coping strategy. 

In some cases, in order to meet the time-sensitive required actions of the sitespecific strategies, the FLEX equipment may need to be stored in its deployed 

position. 

The fuel necessary to operate the FLEX equipment needs to be assessed in the 

plant specific analysis to ensure sufficient quantities are available as well as to 

address delivery capabilities. 

Revision 1 Page 45 of 74 2014-02-06 
NEI 12-06 Section 11.2 states in part: 

Design requirements and supporting analysis should be developed for portable 

equipment that directly performs a FLEX mitigation strategy for core, 

containment, and SFP that provides the inputs, assumptions, and documented 

analysis that the mitigation strategy and support equipment will perform as 

intended. 

On page 71 of the Integrated Plan, discussing the safety function support regarding portable 

equipment for use during the transition phase, the licensee provides the following information: 

Portable SG Makeup Pump- 300 gpm, 780ft. 

Portable SFP Makeup Pump- 300 gpm, 164ft. 

On page 73 of the Integrated Plan, discussing the safety function support regarding portable 

equipment for use during the final phase, the licensee provides the following information: 

Ultimate Heat Sink Pump - 6,000 gpm 

Containment Cooling Pump 

On page 73 of the Integrated Plan, discussing the safety function support regarding portable 

equipment for use during the final phase, the licensee states that there is a Large Fuel Truck 

(also outfitted for debris removal). 

During the audit, the licensee was asked provide information on the portable pumps required for 

ELAP mitigation, (the Phase 2 SG makeup pumps, Phase 3 ultimate heat sink pump, and 

containment cooling pump). The licensee is requested to discuss any time constraints for the 

operator to deploy and start each of the portable pumps noted above. Additionally, the licensee 

was asked to discuss how the required capacity of the each of the listed pumps is determined 

with respect to maintaining core cooling and sub-criticality during Phases 2 and 3 of the ELAP. 

In its response to the NRC audit and review question, the licensee states that the timing 

requirements for connecting the pumps for Modes 1-4 are discussed in the sequence of events 

timeline and the relevant sections of the Integrated Plan. Due to a revision in the strategy, the 

limiting time constraint for deployment of portable pumps is 8 hours for CST makeup. 

Procedures have not been developed at this time, but validation of the procedures will confirm 

the timing. Per the white paper on shutdown modes (ADAMS Accession No. ML 13267 A382) 

specific time lines are not required to be addressed for Modes 5 and 6. Times for phase 3 

actions are contained in the Integrated Plan. With respect to the flow and heads identified in the 

Phase 2 and Phase 3 portable equipment tables, the flow rates and required heads are 

generally valid however, the design process is not yet complete. Calculations are currently 

being prepared and the values may change slightly when the calculations are finalized. The flow 

rates for pumps supporting core cooling and sub-criticality are consistent with or bound WCAP17601 and the plant specific CN-SEE-11-13-5 analyses. Required total developed head (TDH) is 

determined by hand calculations using standard methods (e.g., Crane 410). The licensee 

should provide verification that the procedures will line up with the estimated time for 

deployment of the portable pumps. This has been identified as Confirmatory Item 3.2.1.9.A in 

Section 4.2. 

During the NRC audit and review process, the licensee was asked for a description of the FLEX 

pump that can be used for both SFP makeup and CST refill along with detailed information on 

Revision 1 Page 46 of 74 2014-02-06 
how the flow requirements for both functions will be met during the ELAP event. 

In response to the NRC audit and review process question, the licensee states that as shown in 

figure 3-2 in the Integrated Plan, either the SFP makeup FLEX pump or CST Refill pump (FLEX 

transfer pump) may be utilized to provide flow for the SFP makeup and CST refill functions from 

a common source. Multiple pumps are available in order to allow the flexibility for multiple water 

sources to be utilized simultaneously. The SFP makeup FLEX pump and CST Refill pump 

(FLEX transfer pump) will be sized adequately to meet the requirements of providing flow to 

both SFP makeup and CST refill from a common water source. 

The licensee stated that in order to provide makeup to the PCS, Palisades will utilize two of its 

three installed positive displacement charging pumps. Additionally the licensee stated that In 

order to utilize the installed charging pumps an evaluation of the charging system robustness 

must be performed. The proposed use of portable generators to repower installed charging 

pumps is an alternative approach to NEI 12-06. This places greater reliance on the current 

state of knowledge of external hazards, which are being re-examined pursuant to NTTF 

Recommendation 2.1. New information from that effort may necessitate changes in the degree 

of protection afforded the pre-staged generators and associated equipment in order to maintain 

the guidance and strategies required by EA-12-049. Additional information is needed from the 

licensee to determine whether the proposed approach provides an equivalent level of flexibility 

for responding to an undefined event as would be provided through conformance with NEI 12-

06, including provision of connection points for the use of portable pumping sources from off-site 

should the installed equipment be rendered unavailable by the initiating event. The Staff 

approval of this approach has been identified as Open Item 3.2.1.9.8 in Section 4.1. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01 and subject to the successful 

closure of issues related to the Confirmatory and Open Items, provides reasonable assurance 

that the requirements of Order EA-12-049 will be met with respect to use of portable pumps, if 

these requirements are implemented as described. 

3.2.2 Spent Fuel Pool Cooling Strategies 

NEI 12-06, Table 3-2 and Appendix D summarize one acceptable approach for the SFP cooling 

strategies. This approach uses a portable injection source to provide: 1) makeup via hoses on 

the refuel deck/floor capable of exceeding the boil-off rate for the design basis heat load; 2) 

makeup via connection to spent fuel pool cooling piping or other alternate location capable of 

exceeding the boil-off rate for the design basis heat load; and alternatively 3) spray via portable 

monitor nozzles from the refueling deck/floor capable of providing a minimum of 200 gallons per 

minute (gpm) per unit (250 gpm to account for overspray). This approach will also provide a 

vent pathway for steam and condensate from the SFP. 

As described in NEI 12-06, Section 3.2.1. 7 and JLD-ISG-2012-01, Section 2.1, strategies that 

have a time constraint to be successful should be identified and a basis provided that the time 

can be reasonably met. NEI 12-06, Section 3, provides the performance attributes, general 

criteria, and baseline assumptions to be used in developing the technical basis for the time 

constraints. Since the event is a beyond-design-basis event, the analysis used to provide the 

technical basis for time constraints for the mitigation strategies may use nominal initial values 

(without uncertainties) for plant parameters, and best-estimate physics data. All equipment 

used for consequence mitigation may assume to operate at nominal setpoints and capacities. 

NEI 12-06, Section 3.2.1.2 describes the initial plant conditions for the at-power mode of 

Revision 1 Page 47 of 74 2014-02-06 
operation; Section 3.2.1.3 describes the initial conditions; and Section 3.2.1.6 describes SFP 

initial conditions. 

NEI 12-06, Section 3.2.1.1 provides the acceptance criterion for the analyses serving as the 

technical basis for establishing the time constraints for the baseline coping capabilities 

described in NEI 12-06, which provide an acceptable approach to meeting the requirements of 

EA-12-049 for maintaining SFP cooling. This criterion is keeping the fuel in the SFP covered. 

On pages 51 of the Integrated Plan, in regards to maintaining SFP cooling during the initial 

phase, the licensee stated that under non-outage conditions, the maximum SFP heat load is 

4.405 MW. Loss of SFP cooling with this heat load and an initial SFP temperature of 140 

degrees F results in a time to boil of 5.63 hours. This does not include the amount of time it 

takes to reach the top of active fuel once the boiling initiates. Palisades will use a safety margin 

of 15 feet above the top of the spent fuel, which will be reached after 20.93 hours; therefore, 

completing the equipment line-up for initiating SFP make-up at 18 hours is conservative. 

The licensee stated that the worst case SFP heat load during an outage is 9.02 MW. Loss of 

SFP cooling with this heat load and an initial SFP temperature of 140 degrees F results in a 

time to boil of 3.28 hours. With the entire core being located in the SFP, manpower resources 

normally allocated to core cooling along with the operations outage shift manpower can be 

allocated to aligning SFP make-up which ensures the system alignment can be established prior 

to the point at which SFP conditions become challenged. Palisades will use a safety margin of 

15 feet above the top of the spent fuel, which will occur after 11.28 hours; therefore, completing 

the equipment line-up for initiating SFP make-up at 9 hours is conservative. 

The licensee stated that given the time available before makeup is necessary, there are no 

activities required to support SFP cooling during Phase 1; however, SFP area vent is 

established during inspection of SFP conditions by actions such as opening doors or wall 

louvers. Palisades will determine the optimal method of established ventilation. 

On pages 53 of the Integrated Plan, the licensee stated that the transition to Phase 2 strategies 

will be as the inventory in the SFP slowly declines due to boiling. It has been determined that 

the SFP makeup with an intact pool is not required until 20.93 hours for a normal decay heat 

load, and 11.28 hours for a maximum decay heat load. SFP cooling through makeup and spray 

will be provided by using the SFP makeup FLEX pump. For makeup, the primary method for 

maintaining Spent Fuel Pool makeup is to modify a flanged connection in the Spent Fuel Pool 

Cooling System so that it can be fed by a portable pump. 

The licensee stated that the secondary method is a hose connection in the SFP Cooling System 

fed by a portable pump. A method of providing SFP spray must also be established in the event 

the SFP area becomes uninhabitable. The method for this function will be to use an existing 

monitor nozzle in the SFP Room fed from a hose and pump. The portable pump is required to 

deliver 1 00 gpm at 28 psi to perform the SFP Cooling function. 

The licensee stated that these connections are both located in the SFP Heat Exchanger Room 

on the 590' Level. The primary connection is an existing flange that must be fitted with a hose 

connection. The secondary connection is an existing hose connection. 

The licensee stated that if SFP spray is necessary, a monitor nozzle will be attached to the 

discharge hose of the SFP makeup FLEX pump. The hose will then be routed to the top of the 

SFP level on the 649' Level. The monitor nozzle will be staged in the SFP Room early in the 

Revision 1 Page 48 of 74 2014-02-06 
event, before the area becomes uninhabitable. Palisades will use existing pumps to fulfill this 

requirement. The monitor nozzle discharges 100 gpm at a pressure of 30- 50 psi. The 

available suction sources for all of the above options are the SIRWT and Lake Michigan. NEI 

12-6 Table D-3, SFP cooling section, specifies that a flow rate minimum of 200 gpm per unit to 

the pool or 250 gpm per unit if overs pray occurs consistent with 10 CFR 50.54(hh)(2). 

Resolution of the discrepancy between the licensee flow rate of 100 gpm spray and the NEI 12-

06 specified 250 gpm for spray is required This has been identified as Confirmatory Item 

3.2.2.A in Section 4.2. 

The licensee stated that two diesel engine driven pumps will be stored to support this 

requirement. The pump will be sized to provide the bounding hydraulic requirements for 

all spent fuel pool cooling alignments. Since the SFP makeup and CST refill both have 

relatively low pressure and flow requirements the same pump may be used to provide 

flow to both when they are using the same suction source. 

On pages 58 of the Integrated Plan, in regards to maintaining SFP cooling during the final 

phase, the licensee stated that the strategies to maintain SFP cooling from Phase 2 can 

continue as long as there is sufficient inventory available to feed the strategies. 

The licensee stated that for long term cooling of the SFP, Palisades will repower one train of 

normal SFP cooling equipment. The Phase 3 medium voltage 2 MW FLEX Generator from the 

RRC will be used to repower the equipment for SFP cooling. To remove heat, the RRC will 

have supplied a UHS FLEX pump connected as described in the Phase 3 portion of the Core 

Cooling and Heat Removal section of the Integrated Plan. 

During the NRC audit and review process, the licensee was asked to describe how SFP 

instrumentation would be maintained operational until off-site power is restored and during all 3 

Phases of the event. 

In response to the NRC audit and review process question, the licensee states that in 

accordance to its response to RAI for Order EA-12-051 (ADAMS Accession No. 

ML 13231 A 126), the instrument configuration is planned to be established for a sample rate 

when under battery power consistent with seven days continuous operation. External 

connections will be provided to permit powering the system from any portable 9-36VDC source, 

24VDC nominal. Procedures will be developed to include guidance to either replace the 

onboard batteries or provide an external power supply to the instrumentation prior to exhaustion 

of the onboard battery. 

On page 51 of the Integrated Plan, regarding determination of baseline coping capability during 

the transitional phase for the SFP, the licensee stated that given the time available before 

makeup is necessary, there are no activities required to support SFP cooling during Phase 1; 

however, SFP area vent is established during inspection of SFP conditions by actions such as 

opening doors or wall louvers. Palisades will determine the optimal method of establishing 

ventilation. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of the issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to SFP cooling strategies, if these 

requirements are implemented as described. 

Revision 1 Page 49 of 74 2014-02-06 
3.2.3 Containment Functions Strategies 

NEI 12-06, Table 3-2 and Appendix D provide some examples of acceptable approaches for 

demonstrating the baseline capability of the containment strategies to effectively maintain 

containment functions during all phases of an ELAP. For example: Containment pressure 

control/heat removal utilizing containment spray or repowering hydrogen igniters for ice 

condenser containments. 

On page 45 of the Integrated Plan, regarding maintaining containment in the initial phase, the 

licensee stated: 

Containment pressure and temperature are expected to increase during an ELAP 

due to loss of containment cooling and mass and energy transfer from the PCS 

to containment. The Palisades Containment design pressure is 55 psig and the 

design temperature is 283 degrees F. The Containment Liner has been 

analyzed for temperatures up to 410 degrees F for a design basis accident. 

A containment evaluation has been performed consistent with the boundary 

conditions described in Section 2 of NEI 12-06. Based on the performance of 

installed PCP seals, pressure and temperature of containment are not expected 

to rise significantly. Analysis done in support of the IER 11-4 response 

demonstrated that as long as cooling water was restored to the SGs prior to fuel 

damage there would not be any structural concerns with containment for this 

event. Therefore there are no specific Phase 1 actions required at this time. 

However, the FSGs will include steps to monitor containment conditions. 

Additional strategies to maintain containment during conditions outside those 

described in Section 2 of NEI 12-06 have not been determined. 

On pages 47 and 49 of the Integrated Plan, regarding maintaining containment in the transition 

and final phases, the licensee stated a containment evaluation will be performed based on the 

boundary conditions described in Section 2 of NEI 12-06. Based on the results of this 

evaluation, required actions to ensure maintenance of containment integrity and required 

instrument function will be developed, if needed. In the NRC audit process, the licensee stated 

that the analysis will be provided in a future six-month update. This is identified as Confirmatory 

Item 3.2.3.A in Section 4.2. 

To provide long term support of containment, Palisades will use the medium voltage 2 MW 

FLEX generator from the RRC to repower the installed containment air fans. Palisades has a 

2400V system and the RRC generator will be 4160V, a transformer will be required to make the 

two compatible. 

During the NRC audit and review process, the licensee was asked whether water hammer is 

considered when establishing flow through the containment air cooling fans after they are repowered. 

In response to the NRC audit and review process question, the licensee states that the detailed 

design work is in progress. The Engineering Change process requires engineers to evaluate 

any adverse effects to systems, structures, and components including the potential for water 

hammer. 

Revision 1 Page 50 of 74 2014-02-06 
The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to containment functions strategies, if 

these requirements are implemented as described. 

3.2.4 Support Functions 

3.2.4.1 Equipment Cooling -Support Functions 

NEI 12-06, Section 3.2.2, Guideline (3) states: 

Plant procedures/guidance should specify actions necessary to assure that 

equipment functionality can be maintained (including support systems or 

alternate method) in an ELAPILUHS or can perform without ac power or normal 

access to the UHS. 

Cooling functions provided by such systems as auxiliary building cooling water, 

service water, or component cooling water may normally be used in order for 

equipment to perform their function. It may be necessary to provide an alternate 

means for support systems that require ac power or normal access to the UHS, 

or provide a technical justification for continued functionality without the support 

system. 

The licensee did not provide any information regarding the need for systems such as closed 

cooling water systems of service water that me be necessary to cool plant components that are 

credited in the ELAP mitigating strategies. The licensee will use the TDAFW pump and the 

positive displacement charging pumps, Additionally information is required to determined is 

supplemental cooling is required for these components or components or any others not noted 

here. This is identified as Open Item 3.2.4.1.A in Section 4.1. 

On page 30 of the Integrated Plan regarding maintaining core cooling and heat removal in the 

final phase, the licensee stated that as Phase 3 continues, the RRC will provide a large 2 MW 

medium voltage generator, which will supply power to installed equipment used to bring the 

plant to cold shutdown. The RRC will additionally provide a large, diesel-driven UHS FLEX 

pump. This pump will provide Service Water flow, as it is assumed the Service Water Pumps or 

intake structure are unrecoverable. PNP still needs to determine the connection point for the 

UHS FLEX Pump to the Service Water System. This has been identified as Confirmatory Item 

3.2.4.1.8 in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to equipment 

cooling support functions if these requirements are implemented as described. 

3.2.4.2 Ventilation - Equipment Cooling 

NEI 12-06, Section 3.2.2, Guideline (1 0) states, in part: 

Plant procedures/guidance should consider loss of ventilation effects on specific 

energized equipment necessary for shutdown (e.g., those containing internal 

Revision 1 Page 51 of 74 2014-02-06 
electrical power supplies or other local heat sources that may be energized or 

present in an ELAP. 

ELAP procedures/guidance should identify specific actions to be taken to ensure 

that equipment failure does not occur as a result of a loss of forced 

ventilation/cooling. Actions should be tied to either the ELAP/LUHS or upon 

reaching certain temperatures in the plant. Plant areas requiring additional air 

flow are likely to be locations containing shutdown instrumentation and power 

supplies, turbine-driven decay heat removal equipment, and in the vicinity of the 

inverters. These areas include: steam driven AFW pump room, ... the control 

room, and logic cabinets. Air flow may be accomplished by opening doors to 

rooms and electronic and relay cabinets, and/or providing supplemental air flow. 

Air temperatures may be monitored during an ELAP/LUHS event through 

operator observation, portable instrumentation, or the use of locally mounted 

thermometers inside cabinets and in plant areas where cooling may be needed. 

Alternatively, procedures/guidance may direct the operator to take action to 

provide for alternate air flow in the event normal cooling is lost. Upon loss of 

these systems, or indication of temperatures outside the maximum normal range 

of values, the procedures/guidance should direct supplemental air flow be 

provided to the affected cabinet or area, and/or designate alternate means for 

monitoring system functions. 

For the limited cooling requirements of a cabinet containing power supplies for 

instrumentation, simply opening the back doors is effective. For larger cooling 

loads, such as ... AFW pump rooms, portable engine-driven blowers may be 

considered during the transient to augment the natural circulation provided by 

opening doors. The necessary rate of air supply to these rooms may be 

estimated on the basis of rapidly turning over the room's air volume. 

Actuation setpoints for fire protection systems are typically at 165-180°F. It is 

expected that temperature rises due to loss of ventilation/cooling during an 

ELAP/LUHS will not be sufficiently high to initiate actuation of fire protection 

systems. If lower fire protection system setpoints are used or temperatures are 

expected to exceed these temperatures during an ELAP/LUHS, 

procedures/guidance should identify actions to avoid such inadvertent actuations 

or the plant should ensure that actuation does not impact long term operation of 

the equipment. 

On page 21 of the Integrated Plan, regarding maintaining core cooling and heat removal during 

the transitional phase, the licensee stated that ventilation for the TDAFWP spaces will not be 

required during Phase 2; however, if time is available, temporary fans can be staged ahead of 

time to prepare for high temperatures. 

During the audit, the licensee was asked to provide a detailed summary of the analysis and/or 

technical evaluation performed to demonstrate the adequacy of the ventilation provided in the 

TDAFW pump room to support equipment operation throughout all phases of an ELAP. 

In response to the audit, the licensee states that a GOTHIC analysis was performed to 

determine a conservative temperature profile over time in the auxiliary feedwater pump room. 

This analysis accounted for the maximum design basis ambient conditions and assumed 

Revision 1 Page 52 of 74 2014-02-06 
leakage from a steam trap in the room. The only credited cooling was that via natural circulation 

through the ceiling vent pipe. Analysis assumptions include: loss of offsite power, no active 

room ventilation, the turbine building temperature is 110 degrees F, initial AFW room 

temperature is 104 degrees F, and no credit for heat sinks from the insulated AFW piping in the 

room. The analysis determined that the maximum temperature of the room was 159 degrees F 

after 5 days. The TDAFW pump is supported through all phases of an ELAP. 

On page 60 of the Integrated Plan, regarding determination of baseline coping capability, the 

licensee stated that the instrumentation functionality and Control Room accessibility are 

supported by establishing Control Room ventilation per existing coping for a licensed SBO 

event. Per EOP-3.0, the SBO procedure, the operators are directed to open the Control Room 

doors to provide some natural ventilation. Portable fans are added to increase the air circulation 

if opening the door proves to be insufficient. 

On page 62 of the Integrated Plan, regarding safety function support in the transition phase, the 

licensee stated that during Phase 2, two portable 480 V, 100 kW FLEX diesel generators will be 

used to maintain power to critical instrumentation, as well as recharging the vital batteries and 

SBO battery loads. The generators will also be used to power existing battery room ventilation 

and emergency lighting or, where necessary, portable lighting and portable ventilation can be 

powered by smaller ac generators. 

During the NRC audit and review process, the licensee was asked to provide information on the 

adequacy of the ventilation provided in the battery room to protect the batteries from the effects 

of extreme high and low temperatures and to prevent hydrogen accumulation while recharging 

the batteries in Phase 2 or 3. 

In response to the NRC audit and review process question, the licensee states that during 

battery charging operations in Phases 2 and 3 in support of maintaining power to 

instrumentation and controls for core cooling, containment, and SFP cooling functions, 

ventilation may be required in the battery rooms and associated de equipment rooms for cooling 

the rooms. If necessary due to extreme heat conditions, the doors will be manually propped 

open and forced ventilation can then be established using portable fans. 

The licensee also stated that, for extreme cold temperatures, the battery rooms would be at 

their normal operating temperature at the onset of the event and the temperature of the 

electrolyte in the cells would build up due to the heat generated by the batteries discharging and 

during re-charging. Higher temperatures have a positive impact on battery life. The battery 

rooms are located internal to the plant leading to a long time frame required for outside 

temperatures to cause the electrolyte in the cells to drop to a limiting temperature. Therefore, it 

is reasonable to assume that the room will remain near its pre-event temperature during the 

relatively short period of time until the FLEX generators are deployed and have energized the 

battery chargers. Once the battery charger is re-energized and is charging the battery, the 

charger is carrying the de loads during Phase 2 and 3. A calculation is being prepared to 

evaluate the temperature profile of the battery and de equipment rooms and determine whether 

additional forced air flow for cooling is required. Additional details on adequacy of battery room 

ventilation for extreme temperature protection will be available later in the design I procedure 

development process. This is identified as Confirmatory Item 3.2.4.2.A in Section 4.2. 

The licensee further stated that preliminary analysis indicates battery room ventilation will need 

to be established less than 1.5 hours after charging has been started to prevent hydrogen 

accumulation to less than 2% concentration. The AB heating ventilation air conditioning (HVAC) 

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system exhaust path is neither seismically designed nor tornado missile protected. As such, the 

ventilation will likely be provided by a portable ventilation fan, exhausting through the open door 

into the cable spreading room. The exact strategy will be finalized during the design phase. 

The capability to minimize hydrogen buildup in the cable spreading room and battery room will 

be addressed in the final strategy. This information will be provided in a future update. This is 

identified as Confirmatory Item 3.2.4.2.8 in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Items, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to providing ventilation and 

equipment cooling, if these requirements are implemented as described. 

3.2.4.3 Heat Tracing 

NEI 12-06, Section 3.2.2, Guideline ( 12) states: 

Plant procedures/guidance should consider loss of heat tracing effects for 

equipment required to cope with an ELAP. Alternate steps, if needed, should be 

identified to supplement planned action. 

Heat tracing is used at some plants to ensure cold weather conditions do not 

result in freezing important piping and instrumentation systems with small 

diameter piping. Procedures/guidance should be reviewed to identify if any heat 

traced systems are relied upon to cope with an ELAP. For example, additional 

condensate makeup may be supplied from a system exposed to cold weather 

where heat tracing is needed to ensure control systems are available. If any 

such systems are identified, additional backup sources of water not dependent 

on heat tracing should be identified. 

During the NRC audit and review process, the licensee was asked to provide a discussion 

concerning the use of heat tracing for freeze protection and prevention of boric acid precipitation 

on equipment used for ELAP response and to address instrument and sensing lines as well as 

piping. 

In its response to the NRC audit and review process question the licensee states that a 

preliminary evaluation has determined that freeze protection heat tracing for installed piping that 

has continuing or frequent flow (e.g. CST and turbine driven auxiliary feedwater pump suction 

piping) is not required. The evaluation also identified that further analysis to determine heat 

tracing requirements for borated water systems (e.g., boric acid storage tank and associated 

discharge lines) because of the potential for precipitation of boric acid. The current Palisades 

level indication design does not have installed heat tracing; however, the lines are frequently 

blown-down to prevent precipitation. This common practice will continue and the current 

frequency will be evaluated for adequacy. The sensing line has been considered and is blown 

down every shift. Walkdowns will be conducted to identify additional areas heat tracing for 

freeze protection and boric acid precipitation may be required. Results of the walkdowns and 

precipitation evaluation will be included in FLEX procedures. This is identified as Confirmatory 

Item 3.2.4.3.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

Revision 1 Page 54 of 74 2014-02-06 
closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to heat tracing and component cold 

weather protection, if these requirements are implemented as described. 

3.2.4.4 Accessibility- Lighting and Communications 

NEI 12-06, Section 3.2.2, Guideline (8) states: 

Plant procedures/guidance should identify the portable lighting (e.g., flashlights 

or head/amps) and communications systems necessary for ingress and egress to 

plant areas required for deployment of FLEX strategies. 

Areas requiring access for instrumentation monitoring or equipment operation 

may require portable lighting as necessary to perform essential functions. 

Normal communications may be lost or hampered during an ELAP. 

Consequently, in some cases, portable communication devices may be required 

to support interaction between personnel in the plant and those providing overall 

command and control. 

On page 13 of the Integrated Plan, the licensee stated that prior to hour 2 in the Sequence of 

Events, emergency lighting is being provided by Appendix R lighting, emergency de lighting, 

and emergency lighting from the 100 kW FLEX generators. Once time critical steps are 

completed additional temporary lighting can be strategically placed in several vital areas (e.g. 

Control Room, AB, Cable Spreading room, etc.). This lighting will be powered by smaller cart 

FLEX generators noted in the table on Page 71 of the Integrated Plan. The licensee provided 

two 8kW generators in the Phase 2 equipment table on Page 71. 

On page 63 of the Integrated Plan, the licensee stated smaller diesel generators loaded on 

carts, will be used as necessary to power communications equipment, portable fans, and 

portable lighting. 

On page 71 of the Integrated Plan in the Table of portable equipment during the transition 

phase, the licensee identified that a portable cell tower would be deployed. 

The NRC staff has reviewed the licensee communications assessment (ML 12305A540 and 

ML 13053A080) in response to the March 12, 2012 50.54(f) request for information letter for 

Palisades and, as documented in the staff analysis (ML 13129A219) has determined that the 

assessment for communications is reasonable, and the analyzed existing systems, proposed 

enhancements, and interim measures will help to ensure that communications are 

maintained. Therefore, there is reasonable assurance that the guidance and strategies 

developed by the licensee will conform to the guidance of NEI 12-06 Section 3.2.2 (8) regarding 

communications capabilities during an ELAP. Verification that these communication 

enhancements are made is identified as Confirmatory Item 3.2.4.4.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, and provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to Accessibility- Lighting and 

Communications, if these requirements are implemented as described. 

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3.2.4.5 Protected and Internal Locked Area Access 

NEI 12-06, Section 3.2.2, Guideline (9) states: 

Plant procedures/guidance should consider the effects of ac power Joss on area 

access, as well as the need to gain entry to the Protected Area and internal 

locked areas where remote equipment operation is necessary. 

At some plants, the security system may be adversely affected by the loss of the 

preferred or Class 1 E power supplies in an ELAP. In such cases, manual actions 

specified in ELAP response procedures/guidance may require additional actions 

to obtain access. 

On page 7 of the Integrated Plan, in the section regarding sequence of events, the licensee 

stated that exceptions to the site security plan or other (license/site specific) requirements of a 

nature requiring NRC approval will be communicated in a future six-month update following 

identification. This is identified as Confirmatory Item 3.2.4.5.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to protected and internal locked area 

access, if these requirements are implemented as described. 

3.2.4.6 Personnel Habitability- Elevated Temperature 

NEI 12-06, Section 3.2.2, Guideline ( 11 ), states: 

Plant procedures/guidance should consider accessibility requirements at locations 

where operators will be required to perform local manual operations. 

Due to elevated temperatures and humidity in some locations where local 

operator actions are required (e.g., manual valve manipulations, equipment 

connections, etc.), procedures/guidance should identify the protective clothing or 

other equipment or actions necessary to protect the operator, as appropriate. 

FLEX strategies must be capable of execution under the adverse conditions 

(unavailability of installed plant lighting, ventilation, etc.) expected following a 

BDBE resulting in an ELAP/LUHS. Accessibility of equipment, tooling, connection 

points, and plant components shall be accounted for in the development of the 

FLEX strategies. The use of appropriate human performance aids (e.g., 

component marking, connection schematics, installation sketches, photographs, 

etc.) shall be included in the FLEX guidance implementing the FLEX strategies. 

NEI 12-06 Section 9.2 states: 

Virtually every state in the lower 48 contiguous United States has experienced 

temperatures in excess of 11 ooF. Many states have experienced temperatures 

in excess of 120°F. 

The licensee's plan on personnel habitability/accessibility in an elevated temperature 

Revision 1 Page 56 of 74 2014-02-06 
environment lacked information to determine that the habitability limits will be maintained and/or 

operator protective measures will be employed in all phases of an ELAP to ensure operators will 

be capable of FLEX strategy execution under adverse temperature conditions. Examples of 

areas of concern are the control room, TDAFW pump room, SFP area, and charging pump 

room. This is identified as Confirmatory Item 3.2.4.6.A in Section 4.2 below. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to access and personnel habitability, 

if these requirements are implemented as described. 

3.2.4. 7 Water Sources 

NEI 12-06, Section 3.2.2, Guideline (5) states: 

Plant procedures/guidance should ensure that a flow path is promptly established 

for makeup flow to the steam generator/nuclear boiler and identify backup water 

sources in order of intended use. Additionally, plant procedures/guidance should 

specify clear criteria for transferring to the next preferred source of water. 

Under certain beyond-design-basis conditions, the integrity of some water 

sources may be challenged. Coping with an ELAP/LUHS may require water 

supplies for multiple days. Guidance should address alternate water sources 

and water delivery systems to support the extended coping duration. Cooling 

and makeup water inventories contained in systems or structures with designs 

that are robust with respect to seismic events, floods, and high winds, and 

associated missiles are assumed to be available in an ELAP/LUHS at their 

nominal capacities. Water in robust UHS piping may also be available for use but 

would need to be evaluated to ensure adequate NPSH can be demonstrated 

and, for example, that the water does not gravity drain back to the UHS. 

Alternate water delivery systems can be considered available on a case-by-case 

basis. In general, all CSTs should be used first if available. If the normal source 

of makeup water (e.g., CST) fails or becomes exhausted as a result of the 

hazard, then robust demineralized, raw, or borated water tanks may be used as 

appropriate. 

Finally, when all other preferred water sources have been depleted, lower water 

quality sources may be pumped as makeup flow using available equipment (e.g., 

a diesel driven fire pump or a portable pump drawing from a raw water source). 

Procedures/guidance should clearly specify the conditions when the operator is 

expected to resort to increasingly impure water sources. 

On page 21 of the Integrated Plan, in the section regarding maintaining core cooling and heat 

removal during the transition phase, the licensee stated that the primary strategy for core 

cooling uses a portable FLEX transfer pump to refill the CST to prolong the use of the TDAFWP. 

Potentially available suction sources for refilling the CST are T-90, T-91, and Lake Michigan. 

The pump will be placed near the suction source and hose will be routed to the CST. This 

action must be completed before the inventory in the CST and T-81 deplete, which occurs in 

approximately 4 hours. 

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On page 12 of the Integrated Plan, initiated at hour 24.0, the mobile water purification unit 

should be received from the RRC, and deployment into the site. This equipment will support the 

effective heat removal from the PCS by providing pure, demineralized water to makeup to the 

CST. Although the quality of the water in Lake Michigan may be acceptable to feed the SGs, 

higher quality water is preferred. 

During the NRC audit and review process, the licensee was asked to provide an estimated 

completion date for the T-81 and CST seismic and wind missile hazard evaluation and a 

description of any modifications necessary. 

In response to the NRC audit and review process question, the licensee stated that a 

preliminary strategy assessment has been conducted to identify options for seismic upgrade 

and missile protection of T-81. Minor modifications of the anchorage may be required however, 

the evaluation is not yet complete. The evaluation for the CST is not yet complete however, the 

results will be provided at a future date. This is identified as Confirmatory Item 3.2.4.7.A in 

Section 4.2 below. 

During the NRC audit and review process, the licensee was asked to provide information 

concerning the capacity of tanks T-80, CST, T-90, and T-91 for use as water sources and the 

means to connect portable pumps to refill the CST. In addition, the licensee was asked whether 

there was a priority in the source of water from T-90, T-91, and Lake Michigan. 

In response to the NRC audit and review process question, the licensee states that an 

assessment has been conducted and because tanks T-90 and T-91 are non-seismic, nonmissile protected and have not been evaluated to withstand the effects of a design basis flood. 

They are not planned on being credited. 

In addition the licensee states that for Phase 2, CST makeup will be from Lake Michigan using a 

portable FLEX pump. Currently, the portable FLEX pump will be staged on the west side of the 

Intake Structure. Removable grating adjacent to the Intake Structure provides access to Lake 

Michigan via the intake canal using a suction hose. Flexible discharge hoses will be routed to a 

tee connection prior to depletion of combined CST and T-81 inventory. A design is being 

developed to install the tee connection on the CST overflow line. 

The licensee did not identify whether the FSGs would provide clear criteria for transferring to the 

next preferred source of water. This is identified as Confirmatory Item 3.2.4. 7.8 in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Items, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to makeup water sources, if these 

requirements are implemented as described. 

3.2.4.8 Electrical Power Sources/Isolations and Interactions 

NEI12-06, Section 3.2.2, Guideline (13) states in part: 

The use of portable equipment to charge batteries or locally energize equipment 

may be needed under ELAP/LUHS conditions. Appropriate electrical isolations 

and interactions should be addressed in procedures/guidance. 

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The licensee provided no information on the procedures used to describe electrical isolations 

and interactions, however, on page 65 of the Integrated Plan, in the section that describes 

safety function support for portable equipment during the transition phase, the licensee stated 

that it would modify spare breakers on necessary buses. The breakers will need to be replaced 

with breakers large enough to support the load from the generator. Additionally, the face of the 

breaker will need to be modified to have external female connectors, capable of receiving power 

from the FLEX generators. Four (4) female connectors will be required for 480 V distribution 

centers, one for each phase (A, B, C) and one to ground the generator to the bus. The 

connectors will be quick-electrical connections that require little to no electrical training to marry 

the connection. Two (2) breakers on LC-19 will require this modification. A spare breaker on 

both Bus 11 and Bus 12 will also need this modification. 

During the NRC audit and review process, the licensee was asked to provide information 

concerning the proposed breaker modifications described above. 

In response to the NRC audit and review process question, the licensee states that 480 Volt 

Load Control Centers (LCC) EB-11, EB-12, EB-19, and EB-20 are being modified to receive 

power from the 480 VAC Phase 2 portable FLEX generators. A new breaker will be installed for 

each load control center. A permanent cable will be installed to connect to newly installed 

breaker with a newly mounted quick disconnect box near the LCC. This is identified as 

Confirmatory Item 3.2.4.8.A in Section 4.2 below. 

During the NRC audit and process review, the licensee was asked to provide a summary of the 

sizing calculation for the FLEX generators to show that they can supply the loads assumed in 

Phases 2 and 3. 

In response to the NRC audit and review process question, the licensee states that the loading 

calculation for the 480V Generators for Phase 2 and 4160V Generator( s) to power the 2400V 

loads (via 4160VI2400V stepdown transformer) for Phase 3 has not been completed at this 

time. However, the calculation will develop conservative estimates for the electrical loading 

requirements for both the 480V and 4160V portable generators for electrical loads that supply 

key safety functions and other support loads in support of the Phase 2 and Phase 3 FLEX 

strategies. Nexus Document 12-4105-03-08 "Palisades FLEX Implementation Plan", Section 

8.6.2.2, Description of Procedures I Strategies I Guidelines, lists the expected loads on the 

Phase 2 FLEX DG and Section 8.6.3.2, Description of Procedures I Strategies I Guidelines, 

describes the 2400V equipment that will be repowered by the RRC FLEX 4160 generators. 

The licensee also stated that the calculation will generate the critical performance 

characteristics (kW, KVAR, and kVA demands for starting, stopping, and maintaining loads with 

margin) that must be met by the portable generators. For RRC provided Phase 3 portable 

generators, the calculation will verify the equipment to be furnished will be capable of 

repowering the Station's required electrical loads to support the strategies. These calculations 

are being developed in accordance with approved design processes that utilize appropriate 

design inputs for calculating electrical loads and the necessary considerations for use in sizing 

generators and their drivers (e.g., load starting requirement, voltage and frequency recovery 

requirements between applied loads, etc.). Loading and unloading of the generators will be 

controlled by procedure, based on vendor recommendations, to prevent overloading or tripping 

of generators. 

The licensee needs to finalize the loading and sizing calculations for the 480V flex generators 

Revision 1 Page 59 of 74 2014-02-06 
and the 4160V flex generators. This is identified as Confirmatory Item 3.2.4.8.B in Section 4.2 

below. 

During the NRC audit and review process, the licensee was asked to provide Single Line 

Diagrams showing the proposed connections of Phase 2 and 3 electrical equipment. 

Additionally, show protection information (breaker, relay etc.) and rating of the equipment on the 

Single Line Diagrams and the connection points for the 2 MW Generator with the 2400V 

switchgear. 

In response to the NRC audit and review process question, the licensee states that preliminary 

Single Line Diagrams showing the proposed connections of Phase 2 ( 480V Bus 11, 480V Bus 

12, and 480V bus 19) and a preliminary Single Line Diagram (2400V Bus 1C/1D) for Phase 3 

electrical equipment are provided. The finalized Single Line Diagrams will be available in a 

future six-month update report. 

During the NRC audit and review process, the licensee was asked to discuss how the charging 

pumps are going to be repowered with regard to their use as described in the Integrated Plan. 

In response to the NRC audit and review process question, the licensee states that either P-55B 

or P-55C will be used as the motive force to provide makeup to the PCS. The selected pump 

will be powered from FLEX Generator 2 through either Bus 11 or Bus 12. A portable generator 

will be used to power Bus 11 or Bus 12 through the use of cables and a modified breaker with 

quick disconnects. 

During the NRC audit and review process, the licensee was asked to describe how electrical 

isolation will be maintained such that Class 1 E equipment is protected from faults in 

portable/FLEX equipment and how multiple sources do not attempt to power electrical buses. 

In response to the NRC audit and review process question, the licensee states that appropriate 

controls for the equipment will be implemented in procedures to ensure compliance with NEI 12-

06 section 3.2.2.13. However, the primary goal of FLEX generators is to power components 

credited in the FLEX strategy and not to protect Class 1 E equipment. Further, the licensee 

explained that at the onset of the ELAP, Class 1 E emergency diesel generators are assumed to 

be unavailable to supply the Class 1 E buses. Portable generators are used in response to an 

ELAP in FLEX strategies for Phases 2 and 3. At the point when ELAP mitigation activities 

require tie-in of FLEX generators, in addition to existing electrical interlocks, procedural controls, 

such as inhibiting EDG start circuits and breaker rack-outs (e.g., EDG breakers, offsite feeder 

breakers, etc.), will be employed to prevent simultaneous connection of both the FLEX 

generators and Class 1 E EDGs to the same ac distribution system or component. Additionally, 

repowering the Class 1 E electrical buses from either FLEX generators or subsequently the 

Class 1 E EDGs (should they become available) will be accomplished manually and controlled 

by procedure; no automatic sequencing or automatic repowering of the buses will be utilized. 

FLEX strategies, including the transition from installed sources to (and vice versa), will be 

addressed in the FLEX procedures and guidance which are in the development stage. This is 

identified as Confirmatory Item 3.2.4.8.C in Section 4.2 below. 

During the NRC audit and review process, the licensee was asked to discuss which 

components change state when loads are shed and actions required to mitigate resultant 

hazards such as allowing hydrogen release from the main generator and disabling credited 

equipment via interlocks. 

Revision 1 Page 60 of 74 2014-02-06 
In response to the NRC audit and review process question, the licensee states that existing 

procedures address the issue of venting the main generator . For the interaction of components 

that may change state during load shed operations, PNP is evaluating a deeper load shed 

strategy of non-essential loads beyond that required by the EOP to obtain longer battery life for 

the ELAP event. The results of this evaluation will yield a procedure for extended load shed. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Items, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to electrical power sources/Isolations 

and interactions, if these requirements are implemented as described. 

3.2.4.9 Portable Equipment Fuel 

NEI 12-06, Section 3.2.2, consideration (13) states in part: 

The fuel necessary to operate the FLEX equipment needs to be assessed in the 

plant specific analysis to ensure sufficient quantities are available as well as to 

address delivery capabilities. 

NEI 12-06, Section 3.2.1.3, initial condition (5) states: 

Fuel for FLEX equipment stored in structures with designs which are robust with 

respect to seismic events, floods and high winds and associated missiles, 

remains available. 

On page 67 of the Integrated Plan, regarding portable equipment during the transition phase, 

the licensee stated that refueling operations in Phase 3 will be similar to that of Phase 2, using a 

diesel fuel tank loaded on a truck. Additional fuel supplies can be brought by the RRC when onsite supplies are diminished. 

During the NRC audit and review process, the licensee was asked to describe plans for 

supplying fuel oil to FLEX equipment (i.e., fuel oil storage tank volume, supply pathway, etc.). 

Additionally, the licensee was asked to describe how fuel quality will be assured if stored for 

extended periods of time. 

In response to the NRC audit and review process question, the licensee states that 

underground diesel fuel oil storage tank T-10A is the source to refuel FLEX equipment. This 

tank contains approximately 30,000 gallons of fuel. Fuel from T-10A will be transferred to a 

portable tank mounted on a trailer or truck and then transported to the diesel driven components 

for refueling as necessary. Existing plant procedures provide guidance for manually transferring 

fuel oil from T-10A with a manual pump and hoses. Provisions will be made to ensure the 

equipment required to manually transfer fuel oil from T-10A will be available. The portable tank 

will use the same path that for deployment of the FLEX equipment. The diesel fuel can be 

gravity drained from the portable tank or transferred using a FLEX fuel transfer pump. The 

quality of the diesel fuel in T-1 OA is maintained under the Diesel Fuel Monitoring and Storage 

Program in accordance with the guidelines of the ASTM Standards D 1796, D 2276, D 2709, 

and D 4057. The quality of the diesel fuel in stored FLEX equipment will be maintained under 

the site's Preventative Maintenance program according to the manufacturer's guidance and 

existing site maintenance practices. 

Revision 1 Page 61 of 74 2014-02-06 
The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to portable 

equipment fuel, if these requirements are implemented as described. 

3.2.4.1 0 Load Reduction to Conserve DC Power 

NEI 12-06, Section 3.2.2, consideration (6) provides that: 

Plant procedures/guidance should identify loads that need to be stripped from the 

plant de buses (both Class 1 E and non-Class 1 E) for the purpose of conserving 

de power. 

DC power is needed in an ELAP for such loads as shutdown system 

instrumentation, control systems, and de backed AOVs and MOVs. Emergency 

lighting may also be powered by safety-related batteries. However, for many 

plants, this lighting may have been supplemented by Appendix R and security 

lights, thereby allowing the emergency lighting load to be eliminated. ELAP 

procedures/guidance should direct operators to conserve de power during the 

event by stripping nonessential loads as soon as practical. Early load stripping 

can significantly extend the availability of the unit's Class 1 E batteries. In certain 

circumstances, AFW/HPCI /RCIC operation may be extended by throttling flow to 

a constant rate, rather than by stroking valves in open-shut cycles. 

Given the beyond-design-basis nature of these conditions, it is acceptable to strip 

loads down to the minimum equipment necessary and one set of instrument 

channels for required indications. Credit for load-shedding actions should 

consider the other concurrent actions that may be required in such a condition. 

During the NRC audit and review process, the licensee was asked to provide the direct current 

load profile with the required loads for the mitigating strategies to maintain core cooling, 

containment, and SFP cooling. 

In response to the audit, the licensee states that the load profile for Station Blackout load 

shedding activities is developed in calculation EA-ELEC-LDTAB-009. Preliminary evaluation 

identified additional load shedding activities to extend battery coping time will be required. A 

calculation will be completed to determine the de load profile for the extended load shedding 

activities. 

During the audit, the licensee was asked to provide a detailed discussion on the loads that will 

be shed from the de bus, the equipment location (or location where the required action needs to 

be taken), and the required operator actions needed to be performed and the time to complete 

each action. The licensee was further asked to explain which functions are lost as a result of 

shedding each load and discuss any impact on defense in depth and redundancy. 

In response to the audit, the licensee states that a preliminary strategy has been drafted 

identifying a success path for extending the battery coping time to approximately eight hours to 

support FLEX strategies. The preliminary evaluation identified a deeper load shed than 

identified in the current Palisades station blackout response while providing the acceptable 

minimum equipment necessary per NEI 12-06 Section 3.2.2. The extended load shed does not 

include any fuse or lead manipulations and breakers are located in the AB and the diesel 

Revision 1 Page 62 of 74 2014-02-06 
generator 1-2 room. The potential impacts are being evaluated. 

The licensee needs to complete the load shed calculation to confirm adequate battery capacity 

with sufficient margin throughout Phase 1 to assure the battery does not get depleted prior to 

charging. This is noted as Confirmatory Item 3.2.4.1 O.A in Section 4.2. 

Additionally, the licensee states that any non-essential loads that are included in the extended 

load shed will not be credited for ELAP and will be available to be repowered once the battery 

chargers are energized. The preliminary strategy evaluation includes actions to determine the 

time frame to complete the proposed load shed including walkthroughs. Walkthrough results 

will be utilized in the battery coping methodology. 

During the NRC audit and review process, the licensee was asked to provide the basis for the 

minimum de bus voltage that is required to ensure proper operation of all required electrical 

equipment. 

In response to the NRC audit and review process question, the licensee states that the basis for 

the existing minimum de bus voltage is the Technical Specifications minimum battery voltage of 

105 Vat the terminals. Calculation EA-ELEC-VOLT-052 determines the minimum required 

voltages at each breaker which will be utilized to determine the minimum de bus voltage 

required during extended load shedding. 

In response to the NRC audit and review process question, the licensee states that the initial 

coping strategy during Phase 1 relies on installed instrumentation to monitor critical parameters. 

All essential instrumentation required to monitor core, containment, and spent fuel safety 

parameters are provided with power from the batteries. The present battery coping time is 

approximately 4 hours per the current Palisades SBO procedure, EOP-3.0. A preliminary 

strategy evaluation has been drafted to extend the battery coping time to approximately eight 

hours at which point portable power will be required to power the battery chargers during Phase 

2. This is identified as Confirmatory Item 3.2.4.1 0. B in Section 4.2. 

During the NRC audit, the licensee was asked to clarify if margin. was provided in establishing a 

4 hour battery duty cycle. 

In response to the NRC audit, the licensee states that at present, battery coping time is 

approximately 4 hours per the current SBO procedures. A preliminary strategy evaluation has 

been drafted to extend the battery coping time to approximately 8 hours. The preliminary 

evaluation includes actions to determine the time frame to complete the proposed load shed 

including walkthroughs and battery run-time calculations. The licensee confirms that the station 

battery run-time will be calculated in accordance with the IEEE-485 methodology using 

manufacturer discharge test data applicable to the FLEX strategy as outlined in the NEI white 

paper on Extended Battery Duty Cycles. The detailed PNP calculations, supporting vendor 

discharge data, FLEX strategy battery load profile, and other inputs/initial conditions required by 

IEEE-485 will be available in a future 6-month update report. This is identified as Confirmatory 

Item 3.2.4.1 O.C in Section 4.2 below. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01 and subject to the successful 

closure of issues related to the Confirmatory Items, provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to load reduction to conserve power, 

if these requirements are implemented as described. 

Revision 1 Page 63 of 74 2014-02-06 
3.3 PROGRAMMATIC CONTROLS 

3.3.1 Equipment Maintenance and Testing 

NEI12-06, Section 3.2.2, the paragraph following Guideline (15) states in part: 

In order to assure reliability and availability of the FLEX equipment required to 

meet these capabilities, the site should have sufficient equipment to address all 

functions at all units on-site, plus one additional spare, i.e., an N+1 capability, 

where "N" is the number of units on-site. Thus, a two-unit site would nominally 

have at least three portable pumps, three sets of portable ac/dc power supplies, 

three sets of hoses & cables, etc. It is also acceptable to have a single resource 

that is sized to support the required functions for multiple units at a site (e.g., a 

single pump capable of all water supply functions for a dual unit site). In this 

case, the N+1 could simply involve a second pump of equivalent capability. In 

addition, it is also acceptable to have multiple strategies to accomplish a function 

(e.g., two separate means to repower instrumentation). In this case the 

equipment associated with each strategy does not require N+1. The existing 

50.54(hh)(2) pump and supplies can be counted toward the N+1, provided it 

meets the functional and storage requirements outlined in this guide. The N+1 

capability applies to the portable FLEX equipment described in Tables 3-1 and 

3-2 (i.e., that equipment that directly supports maintenance of the key safety 

functions). Other FLEX support equipment only requires an N capability. 

NEI 12-06, Section 11.5 states: 

1. FLEX mitigation equipment should be initially tested or other reasonable 

means used to verify performance conforms to the limiting FLEX 

requirements. Validation of source manufacturer quality is not required. 

2. Portable equipment that directly performs a FLEX mitigation strategy for the 

core, containment, or SFP should be subject to maintenance and testing 

guidance provided in INPO AP 913, Equipment Reliability Process, to verify 

proper function. The maintenance program should ensure that the FLEX 

equipment reliability is being achieved. Standard industry templates (e.g., 

EPRI) and associated bases will be developed to define specific 

maintenance and testing including the following: 

Revision 1 

a. Periodic testing and frequency should be determined based on equipment 

type and expected use. Testing should be done to verify design 

requirements and/or basis. The basis should be documented and 

deviations from vendor recommendations and applicable standards 

should be justified. 

b. Preventive maintenance should be determined based on equipment type 

and expected use. The basis should be documented and deviations from 

vendor recommendations and applicable standards should be justified. 

Page 64 of 74 2014-02-06 
c. Existing work control processes may be used to control maintenance and 

testing. (e.g., PM Program, Surveillance Program, Vendor Contracts, and 

work orders). 

3. The unavailability of equipment and applicable connections that directly 

performs a FLEX mitigation strategy for core, containment, and SFP should 

be managed such that risk to mitigating strategy capability is minimized. 

a. The unavailability of installed plant equipment is controlled by existing 

plant processes such as the Technical Specifications. When installed 

plant equipment which supports FLEX strategies becomes unavailable, 

then the FLEX strategy affected by this unavailability does not need to be 

maintained during the unavailability. 

b. Portable equipment may be unavailable for 90 days provided that the site 

FLEX capability (N) is available. 

c. Connections to permanent equipment required for FLEX strategies can 

be unavailable for 90 days provided alternate capabilities remain 

functional. 

d. Portable equipment that is expected to be unavailable for more than 90 

days or expected to be unavailable during forecast site specific external 

events (e.g., hurricane) should be supplemented with alternate suitable 

equipment. 

e. The short duration of equipment unavailability, discussed above, does not 

constitute a loss of reasonable protection from a diverse storage location 

protection strategy perspective. 

f. If portable equipment becomes unavailable such that the site FLEX 

capability (N) is not maintained, initiate actions within 24 hours to restore 

the site FLEX capability (N) and implement compensatory measures 

(e.g., use of alternate suitable equipment or supplemental personnel) 

within 72 hours. 

Information regarding the specific storage areas for FLEX equipment is described in section 3.1, 

above. 

The NRC staff reviewed the licensee's Integrated Plan and determined that the Generic 

Concern related to maintenance and testing of FLEX equipment is applicable to the plant. This 

Generic Concern has been resolved generically through the NRC endorsement of the Electric 

Power Research Institute (EPRI) technical report on preventative maintenance of FLEX 

equipment, submitted by NEI by letter dated October 3, 2013 (ADAMS Accession No. 

ML 13276A573). The NRC staff's endorsement letter is dated October 7, 2013 (ADAMS 

Accession No. ML 13276A224) 

This Generic Concern involves clarification of how licenses would maintain FLEX equipment 

such that it would be readily available for use. The technical report provided sufficient basis to 

resolve this concern by describing a database that licensee could use to develop preventive 

maintenance programs for FLEX equipment. The database describes maintenance tasks and 

Revision 1 Page 65 of 74 2014-02-06 
maintenance intervals that have been evaluated as sufficient to provide for the readiness of the 

FLEX equipment. The NRC staff has determined that the technical report provides an 

acceptable approach for developing a program for maintaining FLEX equipment in a ready-touse status. During the NRC audit and review process, the licensee informed the NRC of their 

plans to abide by this generic resolution. The NRC staff will review the resulting program during 

the audit and inspection process. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to maintenance 

and testing, if these requirements are implemented as described. 

3.3.2 Configuration Control 

NEI 12-06, Section 11.8 states: 

1. The FLEX strategies and basis will be maintained in an overall program document. 

This program document will also contain a historical record of previous strategies 

and the basis for changes. The document will also contain the basis for the ongoing 

maintenance and testing programs chosen for the FLEX equipment. 

2. Existing plant configuration control procedures will be modified to ensure that 

changes to the plant design, physical plant layout, roads, buildings, and 

miscellaneous structures will not adversely impact the approved FLEX strategies. 

3. Changes to FLEX strategies may be made without prior NRC approval provided: 

a) The revised FLEX strategy meets the requirements of this guideline. 

b) An engineering basis is documented that ensures that the change in FLEX 

strategy continues to ensure the key safety functions (core and SFP cooling, 

containment integrity) are met. 

In the Integrated Plan, the licensee stated, that the unavailability of equipment and applicable 

connections that directly perform a FLEX mitigation strategy will be managed using plant 

equipment control guidelines developed in accordance with NEI 12-06 Section 11.5. 

Programs and controls will be established to assure personnel proficiency in the mitigation of 

beyond-design- basis events is developed and maintained in accordance with NEI 12-06 

Section 11.6. The FLEX strategies and basis will be maintained in an overall program 

document. Existing plant configuration control procedures will be modified to ensure that 

changes to the plant design, physical plant layout, road, buildings, and miscellaneous structures 

will not adversely impact the approved FLEX strategies in accordance with NEI 12-06, Section 

11.8. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to configuration 

control, if these requirements are implemented as described. 

3.3.3 Training 

Revision 1 Page 66 of 74 2014-02-06 
NEI 12-06, Section 11.6 states: 

1. Programs and controls should be established to assure personnel proficiency 

in the mitigation of beyond-design-basis events is developed and maintained. 

These programs and controls should be implemented in accordance with an 

accepted training process. 

2. Periodic training should be provided to site emergency response leaders? on 

beyond design-basis emergency response strategies and implementing 

guidelines. Operator training for beyond-design-basis event accident 

mitigation should not be given undue weight in comparison with other training 

requirements. The testing/evaluation of Operator knowledge and skills in this 

area should be similarly weighted. 

3. Personnel assigned to direct the execution of mitigation strategies for 

beyond-design basis events will receive necessary training to ensure 

familiarity with the associated tasks, considering available job aids, 

instructions, and mitigating strategy time constraints. 

4. "ANSI/ANS 3.5, Nuclear Power Plant Simulators for use in Operator Training" 

certification of simulator fidelity (if used) is considered to be sufficient for the 

initial stages of the beyond-design-basis external event scenario until the 

current capability of the simulator model is exceeded. Full scope simulator 

models will not be upgraded to accommodate FLEX training or drills. 

5. Where appropriate, the integrated FLEX drills should be organized on a team 

or crew basis and conducted periodically; with all time-sensitive actions to be 

evaluated over a period of not more than eight years. It is not the intent to 

connect to or operate permanently installed equipment during these drills and 

demonstrations. 

On page 16 of the Integrated Plan, in regards to training, the licensee stated that the training 

materials for FLEX will be developed for all station staff involved in implementing FLEX 

strategies. For accredited training programs, the Systematic Approach to Training will be used 

to determine training needs. For other station staff, a training overview will be developed and 

communicated. Training for FLEX implementation will be done in accordance with NEI 12-06, 

Section 11.6 and will be conducted prior to design implementation. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and provides reasonable 

assurance that the requirements of Order EA-12-049 will be met with respect to training, if these 

requirements are implemented as described. 

3.4 OFFSITE RESOURCES 

NEI12-06, Section 12.2 lists the following minimum capabilities for offsite resources for which 

each licensee should establish the availability of: 

1) A capability to obtain equipment and commodities to sustain and backup the 

site's coping strategies. 

Revision 1 Page 67 of 74 2014-02-06 
2) Off-site equipment procurement, maintenance, testing, calibration, storage, 

and control. 

3) A provision to inspect and audit the contractual agreements to reasonably 

assure the capabilities to deploy the FLEX strategies including unannounced 

random inspections by the Nuclear Regulatory Commission. 

4) Provisions to ensure that no single external event will preclude the capability 

to supply the needed resources to the plant site. 

5) Provisions to ensure that the off-site capability can be maintained for the life 

of the plant. 

6) Provisions to revise the required supplied equipment due to changes in the 

FLEX strategies or plant equipment or equipment obsolescence. 

7) The appropriate standard mechanical and electrical connections need to be 

specified. 

8) Provisions to ensure that the periodic maintenance, periodic maintenance 

schedule, testing, and calibration of off-site equipment are 

comparable/consistent with that of similar on-site FLEX equipment. 

9) Provisions to ensure that equipment determined to be unavailable/nonoperational during maintenance or testing is either restored to operational 

status or replaced with appropriate alternative equipment within 90 days. 

1 0) Provision to ensure that reasonable supplies of spare parts for the off-site 

equipment are readily available if needed. The intent of this provision is to 

reduce the likelihood of extended equipment maintenance (requiring in 

excess of 90 days for returning the equipment to operational status). 

The licensee identified that Entergy, for the Palisades site, will negotiate and execute a contract 

with SAFER that will meet the requirements of NEI12-06, Section 12. 

A review was conducted of the licensee's plans for the deployment of portable equipment used 

to implement the response for all hazards and finds that more information was needed in order 

to conclude that the plan would conform to the criteria of NEI 12-06 with regards to 

considerations 2 through 10. This is Confirmatory Item 3.4.A in Section 4.2. 

The licensee's approach described above, as currently understood, is consistent with the 

guidance found in NEI 12-06, as endorsed by JLD-ISG-2012-01, and subject to the successful 

closure of issues related to the Confirmatory Item, and provides reasonable assurance that the 

requirements of Order EA-12-049 will be met with respect to off-site resources, if these 

requirements are implemented as described. 

Revision 1 Page 68 of 74 2014-02-06 
4.0 OPEN AND CONFIRMATORY ITEMS 

4.1 OPEN ITEMS 

Item Number Description Notes 

3.1.1.2.A In the Integrated Plan, the licensee stated that soil liquefaction is 

not explicitly addressed in its UFSAR and identified that an 

evaluation is being conducted for its impact on deployment of 

!portable FLEX equipment. 

3.1.1.2.8 !The licensee should address potential need for a power source to 

move or deploy the equipment (e.g., to open the door from a 

storage location). 

3.1.1.3.A lfhe licensee did not provide information concerning impacts from 

large internal flooding sources that are not seismically robust and 

he potential impact on the mitigating strategies. 

3.1.1.3.8 lfhe licensee did not provide information concerning ground water 

mitigation. 

3.1.5.1.A !The licensee did not specify what features would be used to 

ensure the functionality of FLEX equipment in the presence of 

high temperature hazards. 

3.1.5.3.A The licensee stated did not specify what features would be used 

o ensure the functionality of FLEX equipment when deployed in 

he presence of high temperatures. 

3.2.1.8.A At the time the audit was conducted, the licensee had neither (1) 

committed to abide by the generic approach discussed above, 

including the additional conditions specified in the NRC's 

endorsement letter, nor (2) identified an acceptable alternate 

approach for justifying the boric acid mixing assumptions in the 

analyses supporting its mitigating strategy. To satisfactorily 

resolve this issue, the licensee should confirm its compliance with 

he conditions specified in the NRC endorsement letter discussed 

above. Alternatively, the licensee may identify an acceptable 

alternate approach for justifying the boric acid mixing 

assumptions in the subcriticality analyses. 

3.2.1.9.8 lfhe proposed use of portable generators to repower installed 

charging pumps is an alternative approach to NEI 12-06. The 

NRC staff notes that this places greater reliance on the current 

state of knowledge of external hazards, which are being reexamined pursuant to NTTF Recommendation 2.1. New 

information from that effort may necessitate changes in the 

degree of protection afforded the pre-staged generators and 

associated equipment in order to maintain the guidance and 

strategies required by EA-12-049. Additional information is 

needed from the licensee to determine whether the proposed 

approach provides an equivalent level of flexibility for responding 

o an undefined event as would be provided through conformance 

with NEI 12-06, including provision of connection points for the 

use of portable pumping sources from off-site should the installed 

equipment be rendered unavailable by the initiating event. 

Revision 1 Page 69 of 74 2014-02-06 
4.2 CONFIRMATORY ITEMS 

Item Number Description Notes 

3.1.3.1.A !The licensee should confirm that the structures will meet the 

plant's design-basis tornado wind speed of 300 mph or will be 

designed or evaluated equivalent to ASCE 7-10 using a tornado 

!wind speed of 230 mph with separation and diversity between the 

storage locations. If the method of protection chosen is the later, 

1

lhe licensee should justify that the separation and diversity is 

adequate. 

3.2.1.A !The licensee stated that operator actions performed in the first 20 

minutes of the event are associated with standard post-trip 

actions (EOP-1.0) and station blackout recovery (EOP-3.0). 

Along with main control board instrumentation and reports for the 

ield, preliminary evaluations concluded that equipment 

assessments can be reasonably estimated to a degree to declare 

he ELAP within 0.95 hours. This information will be updated 

twhen procedures are developed and validated. The updated 

information regarding the required operator actions and the 

associated operator actions times in 20 minutes is needed from 

he licensee to determine whether the operator actions are 

adequate and reasonably achievable. 

3.2.1.B !The evaluation will also include either validating the robustness of 

he charging pump control circuit or provide FLEX procedure 

guidance to manually operate the charging pumps by breaker 

operation. The updated information regarding the FLEX generator 

deployment and operation of the charging pump is needed from 

he licensee to determine the adequacy of use of the charging 

pump for RCS inventory makeup during an ELAP. 

3.2.1.C Evaluation of the piping from the BASTs to the pump suction 

identified a section of piping which requires additional evaluation. 

This will be resolved during the detailed design process and will 

be provided in a future six- month update report. The information 

regarding the evaluation results of seismic robustness for the 

BAST piping is needed from the licensee to determine the 

adequacy of the use of the BAST water as a supply source for the 

charging pumps. 

3.2.1.0 The Integrated Plan includes Open Item 16 to evaluate an 

alternative borated water tank to supplement the water volume 

hat may be added when Lake Michigan is the source. 

Evaluations are planned to provide an engineering solution that 

allows mixing of the BAST concentrated borated water with nonborated water. While the source of the non-borated water has not 

yet been determined, Lake Michigan is an available source. An 

installed connection to the charging pump suction already exists. 

Since the SIRWT and/or VCT is currently not planned to be 

credited, there are no time critical actions associated with 

unavailability. In addition, NEI 12-06 section 3.2.1.2 states that no 

additional failures are assumed to occur immediately prior to or 

during the event. 

Revision 1 Page 70 of 74 2014-02-06 
3.2.1.E 

3.2.1.F 

3.2.1.1.A 

3.2.1.2.A 

3.2.1.2.8 

3.2.1.2.C 

3.2.1.2.0 

3.2.1.3.A 

3.2.1.5.A 

Revision 1 

!The licensee should justify the continued functionality of the ADVs 

in the context of a tornado missile hazard resulting in an ELAP in 

order to support a symmetric cooldown given that the design 

basis operability of the ADVs appears to allow for incapacitation of 

individual ADVs. Alternatively, the licensee may address the 

effects of asymmetric natural circulation cooldown. 

!The licensee was asked to provide a summary of nonsafetyrelated equipment that is used in the mitigation strategies 

including a discussion of whether the equipment is qualified to 

survive all ELAP events. In response to the NRC audit and 

review process question, the licensee states that all installed 

equipment credited in mitigating strategies will be evaluated to 

verify conformance to the external event criteria described in NEI12-06. Review of this evaluation is needed. 

!The use of CENTS in the ELAP analysis for CE plants is limited to 

he flow conditions prior to reflux boiling initiation. Specifically, the 

CENTS-calculated flow quality at the top of the SG U-tube should 

be provided for condition when two-phase natural circulation ends 

and reflux boiling initiates. Also, the licensee should discuss how 

he applicable ELAP analyses meet the above limitation on the 

use of CENTS. 

The RCP seal initial maximum leakage rate should be greater 

han or equal to the upper bound expectation for the seal leakage 

rate for the ELAP event (15 gpm/seal) discussed in the PWROG 

position paper addressing the RCP seal leakage for CE plants 

(Reference 2). If the RCP seal leakage rate used in the plantspecific ELAP analysis is less than upper bound expectation for 

he seal leakage rate discussed in the position paper, justification 

should be provided. 

The licensee did not discuss whether the seal failure will occur or 

not when subcooling of the coolant in the RCS cold-legs is greater 

han 50°F. The licensee should specify the seal leakage flow 

assumed for the ELAP from the time zero to the timeframe when 

subcooling in the RCS cold-legs decreases to 50°F, and provide 

·ustification for the assumed leakage rate. 

[The licensee should provide the maximum temperature and 

pressure, and minimum subcooling of the coolant in the RCS 

cold-legs during the ELAP before the CBO isolation, and justify 

he assumption that the integrity of the RCP seals can be 

maintained, and the seal leakage rate is less than 1 gpm per RCP 

during an ELAP before the CBO is isolated. 

[The licensee should ( 1 ) confirm whether above Case 1 without 

he CBO isolation, or Case 2 with the CBO isolation is used to 

establish its mitigation strategies, and (2) provide and justify the 

updated SOE and time constraints so established. 

[The applicability of ANS 5.1-1979 + 2 sigma decay heat curve for 

PNP will be addressed in a future six-month update report. 

!The licensee was asked to discuss the analysis used to determine 

he containment temperature, pressure, and moisture profiles 

during the ELAP event and to address the adequacy of the 

Page 71 of 74 2014-02-06 
computer codes/methodologies, and assumptions used in the 

~nalysis. 

3.2.1.5.8 lfhe licensee was asked in regard to its on-going FLEX strategy 

~valuation, to provide the need for further instrumentation if 

identified by the evaluation. 

3.2.1.6.A lfhe licensee was asked to describe the methodology for the SOE 

imeline validation and to provide the results thereof, when 

available. 

3.2.1.6.8 rrhe licensee stated that its Integrated Plan contains a preliminary 

Sequence of Events timeline. A preliminary assessment has 

been performed identifying potential changes to the Sequence of 

Events. Validation methodology and results of the timeline will be 

provided when completed which is expected in a future six-month 

update report. The updated information regarding the Sequence 

of Events is needed from the licensee to confirm that the 

mitigation strategies listed in the Sequence of Events are updated 

~nd acceptable. 

3.2.1.9.A lfhe flow rates for pumps supporting core cooling and sub-

~riticality are consistent with or bound the WACP 17601 and the 

plant specific CN-SEE-11-13-5 analyses. Required total developed 

head (TDH) is determined by hand calculations using standard 

methods (e.g., Crane 410). The licensee should provide 

verification that the procedures will line up with the estimated time 

or deployment of the portable pumps. 

3.2.2.A The monitor nozzle discharges 100 gpm at a pressure of 30 to 50 

psi. The available suction sources for all of the above options are 

he SIRWT and Lake Michigan. NEI 12-6 Table D-3, SFP cooling 

section, specifies that a flow rate minimum of 200 gpm per unit to 

he pool or 250 gpm per unit if overspray occurs consistent with 

10 CFR 50.54(hh)(2). Resolution of the discrepancy between the 

licensee flow rate of 100 gpm spray and the NEI 12-06 specified 

250 gpm for spray is required. 

3.2.3.A The licensee should provide the results of containment response 

analysis. 

3.2.4.1.A The licensee did not provide any information regarding the need 

for systems such as closed cooling water systems of service 

water that me be necessary to cool plant components that are 

credited in the ELAP mitigating strategies. The licensee will use 

he TDAFW pump and the positive displacement charging pumps, 

Information is required to determined is supplemental cooling is 

required for these components or systems or any other not noted 

here. 

3.2.4.1.8 lfhe RRC will additionally provide a large, diesel-driven UHS 

FLEX pump. This pump will provide Service Water flow, as it is 

assumed the Service Water Pumps or intake structure are 

unrecoverable. PNP still needs to determine the connection point 

or the UHS FLEX Pump to the Service Water System. 

3.2.4.2.A lfhe licensee was asked to provide information on the adequacy 

pf the ventilation provided in the battery room to protect the 

batteries from the effects of extreme high and low temperatures. 

Revision 1 Page 72 of 74 2014-02-06 
3.2.4.2.8 The licensee was asked to provide a discussion of battery room 

ventilation to prevent hydrogen accumulation while recharging the 

batteries in Phase 2 or Phase 3 

3.2.4.3.A Complete heat tracing analysis for borated water systems. 

3.2.4.4.A Verification that completed communication enhancements is 

needed to confirm acceptability. 

3.2.4.5.A Exceptions to the site security plan or other (license/site specific) 

requirements of a nature requiring NRC approval will be 

communicated in a future six-month update following identification 

3.2.4.6.A The licensee's plan on personnel habitability/accessibility in an 

felevated temperature environment lacked information to 

determine that the habitability limits will be maintained and/or 

operator protective measures will be employed in all phases of an 

ELAP to ensure operators will be capable of FLEX strategy 

execution under adverse temperature conditions. Examples of 

areas of concern are the control room, TDAFW pump room, SFP 

area, and charging pump room. 

3.2.4.7.A lfhe licensee stated that a preliminary strategy assessment has 

been conducted to identify options for seismic upgrade and 

missile protection of T-81. Minor modifications of the anchorage 

may be required however, the evaluation is not yet complete. The 

fevaluation for the CST is not yet complete however, the results 

~ill be provided at a future date 

3.2.4.7.8 CST makeup will be from Lake Michigan using a portable FLEX 

pump. Currently, the portable FLEX pump will be staged on the 

~est side of the Intake Structure. Flexible discharge hoses will be 

routed to a tee connection prior to depletion of combined CST and 

IT-81 inventory. A design is being developed to install the tee 

connection on the CST overflow line. The licensee did not identify 

~hether the FSGs would provide clear criteria for transferring to 

he next preferred source of water. 

3.2.4.8.A The 480 Volt Load Control Centers (LCC) E8-11, E8-12, E8-19, 

pnd E8-20 are being modified to receive power from the 480 VAC 

Phase 2 portable FLEX generators. A new breaker will be 

installed for each load control center. A permanent cable will be 

installed to connect to newly installed breaker with a newly 

mounted quick disconnect box near the LCC. The licensee should 

provide information concerning the proposed breaker 

modifications. 

3.2.4.8.8 The licensee was asked to describe how electrical isolation will be 

maintained such that Class 1 E equipment is protected from faults 

in portable/FLEX equipment and how multiple sources do not 

attempt to power electrical buses. 

3.2.4.8.C Repowering the Class 1 E electrical buses from either FLEX 

generators or subsequently the Class 1 E EDGs (should they 

become available) will be accomplished manually and controlled 

by procedure; no automatic sequencing or automatic repowering 

of the buses will be utilized. FLEX strategies, including the 

ransition from installed sources to (and vice versa), will be 

addressed in the FLEX procedures and guidance which are in the 

Revision 1 Page 73 of 74 2014-02-06 
development stage. 

3.2.4.10.A The licensee confirms that the FLEX strategy station battery runime will be calculated in accordance with the IEEE-485 

methodology using manufacturer discharge test data applicable to 

he FLEX strategy as outlined in the NEI white paper on Extended 

Battery Duty Cycles. The detailed Palisades calculations, 

supporting vendor discharge data, FLEX strategy battery load 

profile, and other inputs/initial conditions required by IEEE-485 will 

be available in a future 6-month update report. 

3.2.4.10.B rrhe present battery coping time is approximately 4 hours per the 

current Palisades SBO procedure, EOP-3.0. A preliminary 

strategy evaluation has been drafted to extend the battery coping 

ime to approximately eight hours at which point portable power 

~ill be required to power the battery chargers during Phase 2. 

3.2.4.10.C rrhe licensee confirms that the FLEX strategy station battery runime will be calculated in accordance with the IEEE-485 

methodology using manufacturer discharge test data applicable to 

he FLEX strategy as outlined in the NEI white paper on Extended 

Battery Duty Cycles. The detailed Palisades calculations, 

supporting vendor discharge data, FLEX strategy battery load 

profile, and other inputs/initial conditions required by IEEE-485 will 

be available in a future 6-month update report. 

3.4.A The licensee's plans for the deployment of portable equipment 

used to implement the response for all hazards is not complete. 

More information was needed in order to conclude that the plan 

would conform to the criteria of NEI 12-06 with regards to 

considerations 2 through 10. 

Revision 1 Page 74 of 74 2014-02-06 
- 2 -

If you have any questions, please contact Peter Bamford, Mitigating Strategies Project 

Manager, at 301-415-2833, or at peter.bamford@nrc.gov. 

Docket No. 50-255 

Enclosures: 

1. Interim Staff Evaluation 

2. Technical Evaluation Report 

cc w/encl: Distribution via Listserv 

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PUBLIC 

LPL3-1 R/F 

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RidsNrrPMPalisades Resource 

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RidsAcrsAcnw_MaiiCTR Resource 

Sincerely, 

IRA/ 

Jeremy S. Bowen, Chief 

Mitigating Strategies Projects Branch 

Mitigating Strategies Directorate 

Office of Nuclear Reactor Regulation 

RidsRgn3MaiiCenter Resource 

PBamford, NRR/MSD 

JBowen, NRR/MSD 

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