Entergy Nuclear Operations, Inc.

w, #ai’cra, Palisades Nuclear Plant

I

1tt7 27780 Blue Star Memorial Highway

Covert, Ml 49043-9530

Tel 269 764 2000

Anthony J. Vitale

Site Vice President

PNP 201 4-010

February 28, 2014

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

11555 Rockville Pike

Rockville, MD 20852

SUBJECT: Palisades Nuclear Plant Second Six-Month Status Report in Response to

March 12, 2012 Commission Order Modifying Licenses with Regard to

Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Palisades Nuclear Plant

Docket No. 50-255

License No. DPR-20

REFERENCES: 1. NRC Order Number EA-12-051, Order To Modify Licenses With

Regard To Reliable Spent Fuel Pool Instrumentation, dated March 12,

2012 (ADAMS Accession No. ML12054A682)

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order

EA- 12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0,

dated August 29, 2012 (ADAMS Accession No. ML12221A339)

3. NEI 12-02, Industry Guidance for Compliance with NRC Order

EA-12-051, “To Modify Licenses with Regard to Reliable Spent Fuel

Pool Instrumentation,” Revision 1, dated August 2012 (ADAMS

Accession No. ML1 2240A307)

4. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2012-092,

Initial Status Report in Response to March 12, 2012 Commission Order

Modifying Licenses with Regard to Reliable Spent Fuel Pool

Instrumentation (Order Number EA- 12-05 1), dated October 25, 2012

(ADAMS Accession No. ML1 2300A067)

5. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-009,

Overall Integrated Plan in Response to March 12, 2012 Commission

Order Modifying License With Regard to Reliable Spent Fuel Pool

Instrumentation (Order Number EA- 12-05 1), dated February 28, 2013

(ADAMS Accession No. ML13060A360)

6. NRC Interim Staff Evaluation, Palisades — Interim Staff Evaluation and

Request for Additional Information Regarding the Overall Integrated

Plan for Implementation of Order EA- 12-05 1, Reliable Spent Fuel Pool

Instrumentation (TAC No. MFO769), dated November 26, 2013

(ADAMS Accession No. ML13312A423)

• Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PNP 2014-010 

Tel 269 764 2000 

Anthony J. Vitale 

Site Vice President 

February 28, 2014 

u.s. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

SUBJECT: Palisades Nuclear Plant Second Six-Month Status Report in Response to 

March 12, 2012 Commission Order Modifying Licenses with Regard to 

Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) 

Palisades Nuclear Plant 

Docket No. 50-255 

License No. DPR-20 

REFERENCES: 1. NRC Order Number EA-12-051, Order To Modify Licenses With 

Regard To Reliable Spent Fuel Pool Instrumentation, dated March 12, 

2012 (ADAMS Accession No. ML 12054A682) 

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order 

EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, 

dated August 29, 2012 (ADAMS Accession No. ML 12221 A339) 

3. NEI 12-02, Industry Guidance for Compliance with NRC Order 

EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel 

Pool Instrumentation," Revision 1, dated August 2012 (ADAMS 

Accession No. ML 12240A307) 

4. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2012-092, 

Initial Status Report in Response to March 12,2012 Commission Order 

Modifying Licenses with Regard to Reliable Spent Fuel Pool 

Instrumentation (Order Number EA-12-051), dated October 25,2012 

(ADAMS Accession No. ML 12300A067) 

5. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-009, 

Overall Integrated Plan in Response to March 12,2012 Commission 

Order Modifying License With Regard to Reliable Spent Fuel Pool 

Instrumentation (Order Number EA-12-051), dated February 28,2013 

(ADAMS Accession No. ML 13060A360) 

6. NRC Interim Staff Evaluation, Palisades -Interim Staff Evaluation and 

Request for Additional Information Regarding the Overall Integrated 

Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool 

Instrumentation (TAC No. MF0769), dated November 26,2013 

(ADAMS Accession No. ML 13312A423) 
PNP 201 4-010

Page 2 of 2

Dear Sir or Madam:

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

(Reference 1) to Entergy Nuclear Operations, Inc. (ENO). This order was immediately

effective and directed ENO to install reliable spent fuel pool level instrumentation at the

Palisades Nuclear Plant (PNP).

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

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

Section IV, Condition C. Reference 1 requires submission of a status report at six-month

intervals following submittal of the overall integrated plan. Reference 3 provides direction

regarding the content of the status reports. Reference 2 endorses industry guidance

document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in

Reference 2. Reference 4 provided the PNP initial status report regarding mitigation

strategies. Reference 5 provided the PNP overall integrated plan. Reference 6 contains a

request for additional information regarding the overall integrated plan for implementation of

Order EA-12-051.

The purpose of this letter is to provide the second six-month status report pursuant to

Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the

requirements of Reference 1. The attached report provides an update of milestone

accomplishments since the last status report, including any changes to the compliance

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

This letter also provides information in response to the request for additional information in

Reference 6.

This letter contains no new commitments and no revised commitments.

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

February 28, 2014.

Sincerely,

ajv/jse

4/)/{

Attachment: Palisades Nuclear Plant Second Six-Month Status Report in Response to

March 12, 2012 Commission Order Modifying Licenses with Regard to

Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

cc: Office Director, NRR, USNRC

Administrator, Region Ill, USNRC

Project Manager, Palisades, USNRC

Resident Inspector, Palisades, USNRC

PNP 2014-010 

Page 2 of 2 

Dear Sir or Madam: 

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

(Reference 1) to Entergy Nuclear Operations, Inc. (END). This order was immediately 

effective and directed ENO to install reliable spent fuel pool level instrumentation at the 

Palisades Nuclear Plant (PNP). 

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

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

Section IV, Condition C. Reference 1 requires submission of a status report at six-month 

intervals following submittal of the overall integrated plan. Reference 3 provides direction 

regarding the content of the status reports. Reference 2 endorses industry guidance 

document NEI12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in 

Reference 2. Reference 4 provided the PNP initial status report regarding mitigation 

strategies. Reference 5 provided the PNP overall integrated plan. Reference 6 contains a 

request for additional information regarding the overall integrated plan for implementation of 

Order EA-12-051 . 

The purpose of this letter is to provide the second six-month status report pursuant to 

Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the 

requirements of Reference 1. The attached report provides an update of milestone 

accomplishments since the last status report, including any changes to the compliance 

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

This letter also provides information in response to the request for additional information in 

Reference 6. 

This letter contains no new commitments and no revised commitments. 

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

February 28, 2014. 

Sincerely, 

Attachment: Palisades Nuclear Plant Second Six-Month Status Report in Response to 

March 12, 2012 Commission Order Modifying Licenses with Regard to 

Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) 

cc: Office Director, NRR, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
Attachment

Palisades Nuclear Plant Second Six-Month Status Report in

Response to March 12, 2012 Commission Order Modifying Licenses

with Regard to Reliable Spent Fuel Pool Instrumentation

(Order Number EA-12-051)

1 Introduction

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

overall integrated plan (Reference 1), documenting the requirements to install reliable spent

fuel pool level instrumentation (SFPI), in response to Reference 2. This attachment provides

an update of milestone accomplishments since the last status report, including any changes

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

2 Milestone Accomplishments

The following milestone(s) have been completed since July 31, 2013, and are current as of

January 31, 2014:

• Response to NRC request for additional information dated July 18, 2013 (Reference

3).

• Although not part of the original milestone schedule, ENO received an Interim Staff

Evaluation (ISE) for PNP from the NRC on November 26, 2013 (Reference 4). The

ISE also includes requests for additional information (RAIs) for NRC staff to complete

its review. NRC staff clarified during the November 26, 2013, public meeting that the

Interim Staff Evaluation questions supersede any previous requests for information

issued by the staff concerning the spent fuel pool instrumentation (Reference 5).

Therefore, the RAIs dated July 18, 2013 (Reference 3), are considered superseded

by the RAIs contained in the ISE. The addition of this milestone and target

completion date does not impact the Order implementation date.

1 of 10

Attachment 

Palisades Nuclear Plant Second Six-Month Status Report in 

Response to March 12, 2012 Commission Order Modifying Licenses 

with Regard to Reliable Spent Fuel Pool Instrumentation 

(Order Number EA-12-0S1) 

1 Introduction 

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

overall integrated plan (Reference 1), documenting the requirements to install reliable spent 

fuel pool level instrumentation (SFPI), in response to Reference 2. This attachment provides 

an update of milestone accomplishments since the last status report, including any changes 

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

2 Milestone Accomplishments 

The following milestone(s) have been completed since July 31,2013, and are current as of 

January 31 , 2014: 

• Response to NRC request for additional information dated July 18, 2013 (Reference 

3). 

• Although not part of the original milestone schedule, ENO received an Interim Staff 

Evaluation (ISE) for PNP from the NRC on November 26,2013 (Reference 4). The 

ISE also includes requests for additional information (RAls) for NRC staff to complete 

its review. NRC staff clarified during the November 26, 2013, public meeting that the 

Interim Staff Evaluation questions supersede any previous requests for information 

issued by the staff concerning the spent fuel pool instrumentation (Reference 5). 

Therefore, the RAls dated July 18, 2013 (Reference 3), are considered superseded 

by the RAls contained in the ISE. The addition of this milestone and target 

completion date does not impact the Order implementation date. 

1 of 10 
3 Milestone Schedule Status

The following provides a line item update to milestone schedule to support the Overall

Integrated Plan. It provides the activity status of each item, and whether the expected

completion date has changed. The dates are planning dates subject to change as design

and implementation details are developed.

Milestone Target Completion Activity Revised Target

Datet Status Completion

Date

Reliable SFPI Installed Fall 2015 Refueling In Progress N/A

Outage

Response to NRC Request

for Additional Information

(received July 18, 2013) August 19, 2013 Submitted N/A

(Reference 3) August 19,

2013

Response to NRC ISE

Request for Additional

Information (received March 31, 2015 See Section 6 N/A

November 26, 2013)

tTarget Completion Date is the last submitted date from either the overall integrated plan or

previous six-month update.

4 Changes to Compliance Method

Attachment 1 of the Overall Integrated Plan (Reference 1) shows Channel A mounted against

the north wall near the northwest corner of the Spent Fuel Pool (SFP). The location of

Channel A has been moved to the west wall near the northwest corner of the SFP. See

Section 7 for additional discussion. Section 7 also contains a figure with the new cable

routing for the SFP area.

Section 6 of the Overall Integrated Plan states that SFPI cables in the SFP area shall be

routed in seismically mounted rigid metal conduit. This is true for the coaxial cable, but does

not apply to the Si0 2stainless steel armored cable. See Section 7 for additional discussion.

Attachment 2 of the Overall Integrated Plan shows SFPI Channel A being powered by MCC-7

via Lighting Panel EL-25. SFPI Channel A will now be powered by MCC-1 via Lighting Panel

EL-25B.

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

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

at this time.

2 of 10

3 Milestone Schedule Status 

The following provides a line item update to milestone schedule to support the Overall 

Integrated Plan. It provides the activity status of each item, and whether the expected 

completion date has changed. The dates are planning dates subject to change as design 

and implementation details are developed. 

Target Completion Activity Revised Target 

Milestone Datet Status Completion 

Date 

Reliable SFPI Installed Fall 2015 Refueling In Progress N/A 

Outage 

Response to NRC Request 

for Additional Information Submitted N/A (received July 18, 2013) August 19,2013 

August 19, (Reference 3) 2013 

Response to NRC ISE 

Request for Additional March 31,2015 See Section 6 N/A Information (received 

November 26, 2013) 

tTarget Completion Date is the last submitted date from either the overall integrated plan or 

previous six-month update. 

4 Changes to Compliance Method 

Attachment 1 of the Overall Integrated Plan (Reference 1) shows Channel A mounted against 

the north wall near the northwest corner of the Spent Fuel Pool (SFP). The location of 

Channel A has been moved to the west wall near the northwest corner of the SFP. See 

Section 7 for additional discussion. Section 7 also contains a figure with the new cable 

routing for the SFP area. 

Section 6 of the Overall Integrated Plan states that SFPI cables in the SFP area shall be 

routed in seismically mounted rigid metal conduit. This is true for the coaxial cable, but does 

not apply to the Si02 stainless steel armored cable. See Section 7 for additional discussion. 

Attachment 2 of the Overall Integrated Plan shows SFPI Channel A being powered by MCC-7 

via Lighting Panel EL-25. SFPI Channel A will now be powered by MCC-1 via Lighting Panel 

EL-25B. 

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

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

at this time. 

2 of 10 
6 Open Items from Overall Integrated Plan and Interim Staff

Evaluation

As discussed in Section 2, ENO has received an Interim Staff Evaluation for PNP that

includes 18 RAIs. Responses to the RAIs are due by March 31, 2015, and are discussed in

Section 9 of this six-month status report. The following table provides a status of the RAIs

documented in the Interim Staff Evaluation.

RAI # Response Status

1 In Progress

2 In Progress

3 In Progress

4 In Progress

5 In Progress

6 In Progress

7 In Progress

8 In Progress

9 In Progress

10 In Progress

11 In Progress

12 In Progress

13 In Progress

14 In Progress

15 In Progress

16 In Progress

17 In Progress

18 In Progress

3 of 10

6 Open Items from Overall Integrated Plan and Interim Staff 

Evaluation 

As discussed in Section 2, ENO has received an Interim Staff Evaluation for PNP that 

includes 18 RAls. Responses to the RAls are due by March 31,2015, and are discussed in 

Section 9 of this six-month status report. The following table provides a status of the RAls 

documented in the Interim Staff Evaluation. 

RAI# Response Status 

1 In Progress 

2 In Progress 

3 In Progress 

4 In Progress 

5 In Progress 

6 In Progress 

7 In Progress 

8 In Progress 

9 In Progress 

10 In Progress 

11 In Progress 

12 In Progress 

13 In Progress 

14 In Progress 

15 In Progress 

16 In Progress 

17 In Progress 

18 In Progress 

3 of 10 
7 Potential Interim Staff Evaluation Impacts

Section 3.4 of the Interim Staff Evaluation discusses the arrangement of the SFPI channels

and references the sketch in Attachment 1 of the Overall Integrated Plan. As discussed in

Section 4, the location of the Channel A level instrument has been moved to the west SEP

waIl, within 12” of the northwest SEP corner. The updated sketch of the SFPI arrangement

showing the new cable routing is provided below in Figure 1.

Section 3.4 of the Interim Staff Evaluation also refers to a statement that declares cables in

the SEP area will be routed in seismically mounted rigid metal conduit. It should be noted that

this statement does not apply to the first 20 ft. of cable run, which is comprised of SiC 2

stainless steel armored cable. The SiC 2stainless steel armored cable then transitions to

coaxial cable, at which point the coaxial cable will be installed in seismically mounted rigid

metal conduit for the remainder of the run in the SEP area. This cable installation is

applicable to both Channel A and Channel B.

There are no additional potential impacts to the Interim Staff Evaluation identified at this time

except for those identified in Section 6.

Figure 1: SEP Area Plan View

4 of 10

7 Potential Interim Staff Evaluation Impacts 

Section 3.4 of the Interim Staff Evaluation discusses the arrangement of the SFPI channels 

and references the sketch in Attachment 1 of the Overall Integrated Plan. As discussed in 

Section 4, the location of the Channel A level instrument has been moved to the west SFP 

wall, within 12" of the northwest SFP corner. The updated sketch of the SFPI arrangement 

showing the new cable routing is provided below in Figure 1. 

--,:' ~ - __ _ _ j .... ,_· , ' 1 '~ -- ' -' '-'- =1 _ -.=- = :--"?_=.J o;. ~' •• :;~ '. '.~ :,. • ",: ". 

~ "'-

Figure 1: SFP Area Plan View 

Section 3.4 of the Interim Staff Evaluation also refers to a statement that declares cables in 

the SFP area will be routed in seismically mounted rigid metal conduit. It should be noted that 

this statement does not apply to the first 20 ft. of cable run, which is comprised of Si02 

stainless steel armored cable. The Si02 stainless steel armored cable then transitions to 

coaxial cable, at which point the coaxial cable will be installed in seismically mounted rigid 

metal conduit for the remainder of the run in the SFP area. This cable installation is 

applicable to both Channel A and Channel B. 

There are no additional potential impacts to the Interim Staff Evaluation identified at this time 

except for those identified in Section 6. 

4 of 10 
8 References

The following references support the updates to the overall integrated plan described in this

attachment.

1. ENO letter to NRC, PNP 2013-009, Overall Integrated Plan in Response to March 12,

2012 Commission Order Modifying License With Regard to Reliable Spent Fuel Pool

Instrumentation (Order Number EA- 12-051), dated February 28, 2013 (ADAMS

Accession No. ML1 3060A360)

2. NRC Order Number EA-12-051, Order To Modify Licenses With Regard To Reliable

Spent Fuel Pool Instrumentation, dated March 12, 2012 (ADAMS Accession No.

ML1 2054A682)

3. NRC email to ENO, Palisades Nuclear Plant — Requests for Additional Information

Regarding Overall Integrated Plan for Rellable Spent Fuel Pool Instrumentation (TAC

MFO769), dated July 18, 2013 (ADAMS Accession No. ML13200A328)

4. NRC letter to ENO, Pailsades — Interim Staff Evaluation and Request for Additional

Information Regarding the Overall Integrated Plan for Implementation of Order EA- 12-

051, Reliable Spent Fuel Pool Instrumentation (TAC NO. MF0769), dated November 26,

2013 (ADAMS Accession No. ML1 331 2A423)

5. Summaiy of the November26, 2013, Publlc Meeting to Discuss Industry Responses to

Staff Interim Evaluations for Spent Fuel Pool Instrumentation, dated December 26,

2013 (ML1 3347B030).

5 of 10

8 References 

The following references support the updates to the overall integrated plan described in this 

attachment. 

1. ENO letter to NRC, PNP 2013-009, Overall Integrated Plan in Response to March 12, 

2012 Commission Order Modifying License With Regard to Reliable Spent Fuel Pool 

Instrumentation (Order Number EA-12-051), dated February 28,2013 (ADAMS 

Accession No. ML 13060A360) 

2. NRC Order Number EA-12-051, Order To Modify Licenses With Regard To Reliable 

Spent Fuel Pool Instrumentation, dated March 12,2012 (ADAMS Accession No. 

ML 12054A682) 

3. NRC email to ENO, Palisades Nuclear Plant - Requests for Additional Information 

Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (TAC 

MF0769), dated July 18, 2013 (ADAMS Accession No. ML 13200A328) 

4. NRC letter to ENO, Palisades -Interim Staff Evaluation and Request for Additional 

Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-

051, Reliable Spent Fuel Pool Instrumentation (TAC NO. MF0769), dated November 26, 

2013 (ADAMS Accession No. ML 13312A423) 

5. Summary of the November 26, 2013, Public Meeting to Discuss Industry Responses to 

Staff Interim Evaluations for Spent Fuel Pool Instrumentation, dated December 26, 

2013 (ML 133478030). 

5 of 10 
9 Responses to the Interim Staff Evaluation Requests for

Additional Information

RAI #1

Given the potential for varied dose rates from other materials stored in the SFP, please

describe how level 2 will be adjusted to other than the elevation provided in section 2 above.

ENO Response:

This response will be provided in a future update.

RAI #2

Please provide the analyses verifying the seismic capability of the level probes, the mounting

brackets, and the electronics units, and provide the results of the analysis of the combined

maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly

exposed to the potential sloshing effects. Show that the SFP instrument design configuration

will be maintained during and following the maximum seismic ground motion considered in

the design of the SFP structure.

ENO Response:

This response will be provided in a future update.

RAI#3

For each of the mounting attachments required to attach SFP Level equipment to plant

structures, please describe the design inputs, and the methodology that will be used to

qualify the structural integrity of the affected structures/equipment.

ENO Response:

This response will be provided in a future update.

RAI #4

Please address how other hardware stored in the SFP will not create adverse interaction with

the fixed instrument location(s).

ENO Response:

This response will be provided in a future update.

6 of 10

9 Responses to the Interim Staff Evaluation Requests for 

Additional Information 

RAI#1 

Given the potential for varied dose rates from other materials stored in the SFP, please 

describe how level 2 will be adjusted to other than the elevation provided in section 2 above. 

ENO Response: 

This response will be provided in a future update. 

RAI#2 

Please provide the analyses verifying the seismic capability of the level probes, the mounting 

brackets, and the electronics units, and provide the results of the analysis of the combined 

maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly 

exposed to the potential sloshing effects. Show that the SFP instrument design configuration 

will be maintained during and following the maximum seismic ground motion considered in 

the design of the SFP structure. 

ENO Response: 

This response will be provided in a future update. 

RAI#3 

For each of the mounting attachments required to attach SFP Level equipment to plant 

structures, please describe the design inputs, and the methodology that will be used to 

qualify the structural integrity of the affected structures/equipment. 

ENO Response: 

This response will be provided in a future update. 

RAI#4 

Please address how other hardware stored in the SFP will not create adverse interaction with 

the fixed instrument location(s). 

ENO Response: 

This response will be provided in a future update. 

6 of 10 
RAI #5

Please provide analysis of the maximum expected radiological conditions (dose rate and total

integrated dose) to which the sensor electronics will be exposed. Also, please provide

documentation indicating the radiological dosage the electronics for this equipment are

capable of withstanding. Please discuss the time period over which the analyzed total

integrated dose is evaluated to be applied.

ENO Response:

This response will be provided in a future update.

RAI #6

Please provide information indicating the maximum expected ambient temperature in the

room in which the sensor electronics will be located under BDB conditions with no ac power

available to run Heating Ventilation and Air Conditioning (HVAC) systems, and whether the

sensor electronics are capable of continuously performing required functions under this

expected temperature condition.

ENO Response:

This response will be provided in a future update.

RAI #7

Please provide information indicating the maximum expected relative humidity in the room in

which the sensor electronics will be located under BDB conditions, with no ac power available

to run HVAC systems, and whether the sensor electronics are capable of continuously

performing required functions under this expected humidity condition.

ENO Response:

The response will be provided in a future update.

RAI #8

Please provide a description of the specific method or combination of methods that will be

used to demonstrate the reliability of the permanently installed equipment under BDB shock

and vibration conditions. Identify the specific commercial and/or military standards that will

be used to establish the testing requirements, and the specific acceleration levels and

frequencies that will be simulated.

ENO Response:

This response will be provided in a future update.

7 of 10

RAI#5 

Please provide analysis of the maximum expected radiological conditions (dose rate and total 

integrated dose) to which the sensor electronics will be exposed. Also, please provide 

documentation indicating the radiological dosage the electronics for this equipment are 

capable of withstanding. Please discuss the time period over which the analyzed total 

integrated dose is evaluated to be applied. 

ENO Response: 

This response will be provided in a future update. 

RAI#6 

Please provide information indicating the maximum expected ambient temperature in the 

room in which the sensor electronics will be located under BOB conditions with no ac power 

available to run Heating Ventilation and Air Conditioning (HVAC) systems, and whether the 

sensor electronics are capable of continuously performing required functions under this 

expected temperature condition. 

ENO Response: 

This response will be provided in a future update. 

RAI#7 

Please provide information indicating the maximum expected relative humidity in the room in 

which the sensor electronics will be located under BOB conditions, with no ac power available 

to run HVAC systems, and whether the sensor electronics are capable of continuously 

performing required functions under this expected humidity condition. 

ENO Response: 

The response will be provided in a future update. 

RAI#8 

Please provide a description of the specific method or combination of methods that will be 

used to demonstrate the reliability of the permanently installed equipment under BDB shock 

and vibration conditions. Identify the specific commercial andlor military standards that will 

be used to establish the testing requirements, and the specific acceleration levels and 

frequencies that will be simulated. 

ENO Response: 

This response will be provided in a future update. 

7 of 10 
#9

For RAI #8 above, please provide the results for the selected methods, tests and analyses

used to demonstrate the qualification and reliability of the installed equipment in accordance

with the Order requirements.

ENO Response:

This response will be provided in a future update.

RAI#1O

Please provide an evaluation of the vendor analysis and seismic testing results and show that

the instrument performance reliability, following exposure to simulated seismic conditions

representative of the environment anticipated for the SFP structures at Palisades, has been

adequately demonstrated.

ENO Response:

This response will be provided in a future update.

RAI #11

Please provide the NRC staff with the final configuration of the power supply source for each

channel so the staff may conclude the two channels are independent from a power supply

assignment perspective.

ENO Response:

This response will be provided in a future update.

RAI #12

Please provide the results of the calculation depicting the battery backup duty cycle

requirements demonstrating battery capacity is sufficient to maintain the level indication

function until offsite resource availability is reasonably assured.

ENO Response:

This response will be provided in a future update.

RAI#13

Please, provide an analysis verifying the proposed instrument performance is consistent with

these estimated accuracy normal and BDB values. Please demonstrate the channels will

retain these accuracy performance values following a loss of power and subsequent

restoration of power.

ENO Response:

This response will be provided in a future update.

8 of 10

#9 

For RAI #8 above, please provide the results for the selected methods, tests and analyses 

used to demonstrate the qualification and reliability of the installed equipment in accordance 

with the Order requirements. 

ENO Response: 

This response will be provided in a future update. 

RAI#10 

Please provide an evaluation of the vendor analysis and seismic testing results and show that 

the instrument performance reliability, following exposure to simulated seismic conditions 

representative of the environment anticipated for the SFP structures at Palisades, has been 

adequately demonstrated. 

ENO Response: 

This response will be provided in a future update. 

RAI#11 

Please provide the NRC staff with the final configuration of the power supply source for each 

channel so the staff may conclude the two channels are independent from a power supply 

assignment perspective. 

ENO Response: 

This response will be provided in a future update. 

RAI#12 

Please provide the results of the calculation depicting the battery backup duty cycle 

requirements demonstrating battery capacity is sufficient to maintain the level indication 

function until offsite resource availability is reasonably assured. 

ENO Response: 

This response will be provided in a future update. 

RAJ #13 

Please, provide an analysis verifying the proposed instrument performance is consistent with 

these estimated accuracy normal and BOB values. Please demonstrate the channels will 

retain these accuracy performance values following a loss of power and subsequent 

restoration of power. 

ENO Response: 

This response will be provided in a future update. 

8 of 10 
RAI #14

Please provide a description of the methodology that will be used for determhhg the

maximum allowed deviation from the instrument channel design accuracy to be employed

under normal operating conditions as an acceptance criterion for a calibration procedure to

alert operators and technicians of the need for adjustment to within normal design accuracy.

ENO Response:

This response will be provided in a future update.

RAI #15

Please provide a description of the h-situ calibration process at the SFP location that will

result in the channel calibration being maintained at its design accuracy.

ENO Response:

This response will be provided in a future update.

RAI#16

For the SFP level instrumentation backup display located in the radwaste control panel room,

please describe the evaluation used to validate the display location can be accessed without

unreasonable delay following a BDB event. Include the time available for personnel to

access the display as credited in the evaluation, as well as the actual time (e.g., based on

walk-throughs) that it will take for personnel to access the backup display. Additionally,

please include a description of the radiological and environmental conditions on the paths

personnel might take. Describe whether the display location remains habitable for

radiological, heat and humidity, and other environmental conditions following a BDB event.

Describe whether personnel are continuously stationed at the backup display or monitor the

display periodically.

ENO Response:

This response will be provided in a future update.

RAI#17

Please provide a list of the procedures addressing operation (both normal and abnormal

response), calibration, test, maintenance, and inspection that will be developed for use of the

SFP instrumentation. The licensee is requested to hclude a brief description of the specific

technical objectives to be achieved within each procedure.

ENO Response:

This response will be provided in a future update.

9 of 10

RAI #14 

Please provide a description of the methodology that will be used for determining the 

maximum allowed deviation from the instrument channel design accuracy to be employed 

under normal operating conditions as an acceptance criterion for a calibration procedure to 

alert operators and technicians of the need for adjustment to within normal design accuracy. 

ENO Response: 

This response will be provided in a future update. 

RAI #15 

Please provide a description of the in-situ calibration process at the SFP location that will 

result in the channel calibration being maintained at its design accuracy. 

ENO Response: 

This response will be provided in a future update. 

RAI#16 

For the SFP level instrumentation backup display located in the radwaste control panel room, 

please describe the evaluation used to validate the display location can be accessed without 

unreasonable delay following a BOB event. Include the time available for personnel to 

access the display as credited in the evaluation, as well as the actual time (e.g., based on 

walk-throughs) that it will take for personnel to access the backup display. Additionally, 

please include a description of the radiological and environmental conditions on the paths 

personnel might take. Describe whether the display location remains habitable for 

radiological, heat and humidity, and other environmental conditions following a BOB event. 

Describe whether personnel are continuously stationed at the backup display or monitor the 

display periodically. 

ENO Response: 

This response will be provided in a future update. 

RAI#17 

Please provide a list of the procedures addressing operation (both normal and abnormal 

response), calibration, test, maintenance, and inspection that will be developed for use of the 

SFP instrumentation. The licensee is requested to include a brief description of the specific 

technical objectives to be achieved within each procedure. 

ENO Response: 

This response will be provided in a future update. 

9 of 10 
RAI#18

Please provide further information describing the maintenance and testing program the

licensee will establish and implement to ensure that regular testing and calibration is

performed and verified by inspection and audit to demonstrate conformance with design and

system readiness requirements. Include a description of your plans for ensuring that

necessary channel checks, functional tests, periodic calibration, and maintenance will be

conducted for the level measurement system and its supporting equipment.

ENO Response:

This response will be provided in a future update.

10 of 10

RAI#18 

Please provide further information describing the maintenance and testing program the 

licensee will establish and implement to ensure that regular testing and calibration is 

performed and verified by inspection and audit to demonstrate conformance with design and 

system readiness requirements. Include a description of your plans for ensuring that 

necessary channel checks, functional tests, periodic calibration, and maintenance will be 

conducted for the level measurement system and its supporting equipment. 

ENO Response: 

This response will be provided in a future update. 

10 of 10