Entergy Nuclear Operations, Inc.

‘“ s-i Palisades Nuclear Plant

Lt1çJ’ 27780 Blue Star Memorial Highway

Covert, MI 49043-9530

Tel 269 764 2000

Anthony J. Vitale

PNP 2014-084 Site Vice President

August 28, 2014

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

11555 Rockville Pike

Rockville, MD 20852

SUBJECT: Palisades Nuclear Plant Third 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-1 2-051, 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- 12-05 1, “To Modify Licenses with Regard to Reliable Spent Fuel

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

Accession No. ML12240A307)

4. Entergy Nuclear Operations, Inc. 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. ML12300A067)

5. Entergy Nuclear Operations, Inc. 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. ML1 3060A360)

6. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-065,

Palisades Nuclear Plant First 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),

dated August 28, 2013 (ADAMS Accession No. ML1 3241 A235)

.-Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PN P 2014-084 

August28,2014 

Tel 269 764 2000 

Anthony J. Vitale 

Site Vice President 

u.s. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

SUBJECT: Palisades Nuclear Plant Third 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-12-0S1, Reliable Spent Fuel Pool Instrumentation, Revision 0, 

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

3. NEI12-02, Industry Guidance for Compliance with NRC Order 

EA-12-0S1, ITo 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. 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-12-0S1), dated October 25,2012 

(ADAMS Accession No. ML 12300A067) 

5. Entergy Nuclear Operations, Inc. 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-12-0S1), dated February 28,2013 

(ADAMS Accession No. ML 13060A360) 

6. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-065, 

Palisades Nuclear Plant First 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), 

dated August 28,2013 (ADAMS Accession No. ML 13241A235) 
PNP 2014-084

Page 2 of 3

7. 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. ML1 331 2A423)

8. Entergy Nuclear Operations, Inc. letter to NRC, PNP 201 4-010,

Pailsades 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), dated February 28, 2014 (ADAMS Accession No. ML14059A078)

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 provided the first sixmonth status report. Reference 7 contains a request for additional information regarding the

overall integrated plan for implementation of Order EA-12-051. Reference 8 provided the

second six-month status report.

The purpose of this letter is to provide the third 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 7.

This letter contains no new commitments and no revised commitments.

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

August 28, 2014.

Sincerely,

ajv/jse

PN P 2014-084 

Page 2 of 3 

7. 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) 

8. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2014-010, 

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), dated February 28,2014 (ADAMS Accession No. ML 14059A078) 

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 provided the first sixmonth status report. Reference 7 contains a request for additional information regarding the 

overall integrated plan for implementation of Order EA-12-051. Reference 8 provided the 

second six-month status report. 

The purpose of this letter is to provide the third 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 7. 

This letter contains no new commitments and no revised commitments. 

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

August 28, 2014. 

Sincerely, 

ajv/jse 
PNP 2014-084

Page 3 of 3

Attachment: Palisades Nuclear Plant Third 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

PN P 2014-084 

Page 3 of 3 

Attachment: Palisades Nuclear Plant Third 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) 

cc: Office Director, NRR, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
Attachment

Palisades Nuclear Plant Third 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 in Section 8), documenting the requirements to install

reliable spent fuel pool level instrumentation (SFPI), in response to Reference 2 in Section 8.

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 January 31, 2014 and are current as

of July31, 2014.

• Second Six-Month Status Report — February 2014

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

August 2014.

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 FaIl 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 in Section 8) August 19,

2013

Response to NRC ISE

Request for Additional

Information (received March 31, 2015 In Progress N/A

November 26, 2013)

1 of 13

Attachment 

Palisades Nuclear Plant Third 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 in Section 8), documenting the requirements to install 

reliable spent fuel pool level instrumentation (SFPI), in response to Reference 2 in Section 8. 

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 January 31,2014 and are current as 

of July 31,2014. 

• Second Six-Month Status Report - February 2014 

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

August 2014. 

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 SFPllnstalied 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 in Section 8) 2013 

Response to NRC ISE 

Request for Additional March 31,2015 In Progress N/A Information (received 

November 26, 2013) 

1 of 13 
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 in Section 8) 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 SEP.

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

routing for the SEP area.

The Overall Integrated Plan states in Section 6 that SFPI cables in the SEP 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. SEPI 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

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

at this time.

6 Open Items from Overall Integrated Plan and Interim Staff

Evaluation

END has received an Interim Staff Evaluation for PNP that includes 18 Requests for

Additional Information (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 any RAIs documented in the Interim Staff Evaluation.

RAI # Response Status

1 See Section 9

2 See Section 9

3 See Section 9

4 See Section 9

5 See Section 9

6 See Section 9

7 See Section 9

8 See Section 9

9 See Section 9

10 See Section 9

1 1 See Section 9

12 See Section 9

13 See Section 9

2 of 13

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 in Section 8) 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. 

The Overall Integrated Plan states in Section 6 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. 

6 Open Items from Overall Integrated Plan and Interim Staff 

Evaluation 

ENO has received an Interim Staff Evaluation for PNP that includes 18 Requests for 

Additional Information (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 any RAls documented in the Interim Staff Evaluation. 

RAI # Response Status 

1 See Section 9 

2 See Section 9 

3 See Section 9 

4 See Section 9 

5 See Section 9 

6 See Section 9 

7 See Section 9 

8 See Section 9 

9 See Section 9 

10 See Section 9 

11 See Section 9 

12 See Section 9 

13 See Section 9 

2 of 13 
14 See Section 9

15 See Section 9

16 See Section 9

17 See Section 9

18 See Section 9

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 SEP corner.

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 feet of cable run, which is comprised of Si0 2

stainless steel armored cable, routed in seismically mounted 12 gauge unistrut channel with a

closure strip. The S1O 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.

An updated sketch of the SFPI arrangement showing the current Channel A and Channel B

cable routings is provided below in Figure 1.

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

except for those identified in Section 6 of this report.

3 of 13

14 See Section 9 

15 See Section 9 

16 See Section 9 

17 See Section 9 

18 See Section 9 

7 Potential Interim Staff Evaluation Impacts 

Section 3.4 of the I nterim 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. 

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 feet of cable run, which is comprised of Si02 

stainless steel armored cable, routed in seismically mounted 12 gauge unistrut channel with a 

closure strip. 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. 

An updated sketch of the SFPI arrangement showing the current Channel A and Channel B 

cable routings is provided below in Figure 1. 

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

except for those identified in Section 6 of this report. 

3 of 13 
p I 7 I

Figure 1: SEP Area Plan View

4 of 13

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4 of 13 
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-1 2-051, 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 Reliable Spent Fuel Pool Instrumentation (TAC

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

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 (TAG NO. MFO769), dated

November 26, 2013 (ADAMS Accession No. ML13312A423)

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 (ML1 3347B030)

5 of 13

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 13 
9 Responses to the Interim Staff Evaluation Requests for

Additional Information (RAIs)

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:

Interim Staff Guidance JLD-ISG-2012-03, “Compliance with Order EA-12-051, Reliable Spent

Fuel Pool Instrumentation,” states “The NRC staff considers that the methodologies and

guidance in conformance with the guidelines provided in NEI 12-02, Revision 1, subject to the

clarifications and exceptions in Attachment 1 to this ISG, are an acceptable means of

meeting the requirements of Order EA-12-051.”

NEI 12-02, Revision 1, Section 2.3.2, states “Level 2 - level that is adequate to provide

substantial radiation shielding for a person standing on the spent fuel pool operating deck.”

Level 2 represents the range of water level where any necessary operations in the vicinity of

the spent fuel pool can be completed without significant dose consequences from direct

gamma radiation from the stored spent fuel. Level 2 is based on either of the following:

• 10 feet (+1- 1 foot) above the highest point of any fuel rack seated in the spent

fuel pools, or

• a designated level that provides adequate radiation shielding to maintain

personnel radiological dose levels within acceptable limits while performing

local operations in the vicinity of the pool. This level shall be based on either

plant-specific or appropriate generic shielding calculations, considering the

emergency conditions that may apply at the time and the scope of necessary

local operations, including installation of portable SFP instrument channel

components. Additional guidance can be found in EPA-400 (Reference 4),

USNRC Regulatory Guide 1.13 (Reference 5), and ANSI/ANS-57.2-1983

(Reference 6).

ENO has selected the 10-foot option, which has been determined by the NRC to meet the

requirements of the order with no further evaluation or review required.

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.

6 of 13

9 Responses to the Interim Staff Evaluation Requests for 

Additional Information (RAls) 

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: 

Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent 

Fuel Pool Instrumentation," states ''The NRC staff considers that the methodologies and 

guidance in conformance with the guidelines provided in NEI 12-02, Revision 1, subject to the 

clarifications and exceptions in Attachment 1 to this ISG, are an acceptable means of 

meeting the requirements of Order EA-12-051." 

NEI 12-02, Revision 1, Section 2.3.2, states "Level 2 - level that is adequate to provide 

substantial radiation shielding for a person standing on the spent fuel pool operating deck." 

Level 2 represents the range of water level where any necessary operations in the vicinity of 

the spent fuel pool can be completed without significant dose consequences from direct 

gamma radiation from the stored spent fuel. Level 2 is based on either of the following: 

• 10 feet (+/- 1 foot) above the highest point of any fuel rack seated in the spent 

fuel pools, or 

• a designated level that provides adequate radiation shielding to maintain 

personnel radiological dose levels within acceptable limits while performing 

local operations in the vicinity of the pool. This level shall be based on either 

plant-specific or appropriate generic shielding calculations, considering the 

emergency conditions that may apply at the time and the scope of necessary 

local operations, including installation of portable SFP instrument channel 

components. Additional guidance can be found in EPA-400 (Reference 4), 

USNRC Regulatory Guide 1.13 (Reference 5), and ANSI/ANS-57.2-1983 

(Reference 6). 

ENO has selected the 10-foot option, which has been determined by the NRC to meet the 

requirements of the order with no further evaluation or review required. 

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. 

6 of 13 
ENO Response:

See draft bridging document Topics #8, 9, & 12 located on ePortal. [Note: Preliminary

responses are available in the draft bridging document, which will be finalized upon issuance

of the NRC audit report for the SFPI vendor (MOHR).]

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:

See draft bridging document Topics #8, 9, 12, & 13 located on ePortal. [Note: Preliminary

responses are available in the draft bridging document, which will be finalized upon issuance

of the NRC audit report for the SFPI vendor (MOHR).J

RAI #4

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

the fixed instrument location(s).

ENO Response:

The SFP and Auxiliary Building are Seismic Category 1 Structures. As a part of the

Engineering Change (EC) process for PNP, SFPI probe locations were verified to be free of

stored SEP hardware. Future hardware additions to the SEP are controlled by procedure.

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:

The Channel A display containing the system electronics will be mounted in the Main Control

Room, a mild radiation environment. The Channel B display is located in the C-40 Panel

Room, which is a mild radiation area. Both the Main Control Room and C-40 Panel Room

are not affected by increased radiation levels due to receding SEP water level. No analysis is

necessary to evaluate the system electronics for exposure to radiation.

7 of 13

ENO Response: 

See draft bridging document Topics #8,9, & 12 located on ePortal. [Note: Preliminary 

responses are available in the draft bridging document, which will be finalized upon issuance 

of the NRC audit report for the SFPI vendor (MOHR).] 

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: 

See draft bridging document Topics #8, 9, 12, & 13 located on ePortal. [Note: Preliminary 

responses are available in the draft bridging document, which will be finalized upon issuance 

of the NRC audit report for the SFPI vendor (MOHR).] 

RAI#4 

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

the fixed instrument location(s). 

ENO Response: 

The SFP and Auxiliary Building are Seismic Category 1 Structures. As a part of the 

Engineering Change (EC) process for PNP, SFPI probe locations were verified to be free of 

stored SFP hardware. Future hardware additions to the SFP are controlled by procedure. 

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: 

The Channel A display containing the system electronics will be mounted in the Main Control 

Room, a mild radiation environment. The Channel B display is located in the C-40 Panel 

Room, which is a mild radiation area. Both the Main Control Room and C-40 Panel Room 

are not affected by increased radiation levels due to receding SFP water level. No analysis is 

necessary to evaluate the system electronics for exposure to radiation. 

7 of 13 
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:

See draft bridging document Topic #3 located on ePortal. [Note: Preliminary responses are

available in the draft bridging document, which will be finalized upon issuance of the NRC

audit report for the SFPI vendor (MOHR).]

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:

See draft bridging document Topic #3 in located on ePortal. [Note: Preliminary responses

are available in the draft bridging document, which will be finalized upon issuance of the NRC

audit report for the SFPI vendor (MOHR).J

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:

See draft bridging document Topic #14 located on ePortal. [Note: Preliminary responses are

available in the draft bridging document, which will be finalized upon issuance of the NRC

audit report for the SFPI vendor (MOHR).]

8 of 13

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: 

See draft bridging document Topic #3 located on ePortal. [Note: Preliminary responses are 

available in the draft bridging document, which will be finalized upon issuance of the NRC 

audit report for the SFPI vendor (MOHR).] 

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: 

See draft bridging document Topic #3 in located on ePortal. [Note: Preliminary responses 

are available in the draft bridging document, which will be finalized upon issuance of the NRC 

audit report for the SFPI vendor (MOHR).] 

RAI#S 

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 BOB 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: 

See draft bridging document Topic #14 located on ePortal. [Note: Preliminary responses are 

available in the draft bridging document, which will be finalized upon issuance of the NRC 

audit report for the SFPI vendor (MOHR).] 

8 of 13 
RAI#9

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

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

with the Order requirements.

ENO Response:

See draft bridging document Topic #14 located on ePortal. [Note: Preliminary responses are

available in the draft bridging document, which will be finalized upon issuance of the NRC

audit report for the SFPI vendor (MOHR).J

RAI#1O

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

the instrument performance rellabillty, following exposure to simulated seismic conditions

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

adequately demonstrated.

ENO Response:

See draft bridging document Topic #8 located on ePortal. [Note: Preliminary responses are

available in the draft bridging document, which will be finalized upon issuance of the NRC

audit report for the SFPI vendor (MOHR).]

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:

Instrument Channel A is being powered from Lighting Panel (L-25B) through existing 20A

breaker #5, which is supplied from MCC #1. Instrument Channel B is being powered from

Lighting Panel (L-76) through existing 20A breaker #12, which is supplied from MCC #82.

These two buses represent independent 480 V power sources.

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.

9 of 13

RAI#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: 

See draft bridging document Topic #14 located on ePortal. [Note: Preliminary responses are 

available in the draft bridging document, which will be finalized upon issuance of the NRC 

audit report for the SFPI vendor (MOHR).] 

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: 

See draft bridging document Topic #8 located on ePortal. [Note: Preliminary responses are 

available in the draft bridging document, which will be finalized upon issuance of the NRC 

audit report for the SFPI vendor (MOHR).] 

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: 

Instrument Channel A is being powered from Lighting Panel (L-25B) through existing 20A 

breaker #5, which is supplied from MCC #1. Instrument Channel B is being powered from 

Lighting Panel (L-76) through existing 20A breaker #12, which is supplied from MCC #82. 

These two buses represent independent 480 V power sources. 

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 off site resource availability is reasonably assured. 

9 of 13 
ENO Response:

See draft bridging document Topic #18 located on ePortal. [Note: Preliminary responses are

available in the draft bridging document, which will be finalized upon issuance of the NRC

audit report for the SFPI vendor (MOHR).}

RAI#13

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

these estimated accuracy normal and 8DB values. Please demonstrate the channels will

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

restoration of power.

ENO Response:

See draft bridging document Topics #16, 17 & 18 located on ePortal. [Note: Preliminary

responses are available in the draft bridging document, which will be finalized upon issuance

of the NRC audit report for the SFPI vendor (MOHR).]

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 callbration procedure to

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

ENO Response:

In general relative to normal operating conditions, any applicable calibration procedure

tolerances (or acceptance criterion) will be established based on the vendor manuals

stated/recommended reference accuracy (or design accuracy). The methodology used will

be based on the vendor manuals and captured in plant procedures and/or programs. See

draft bridging document Topics #20 located on ePortal. [Note: Preliminary responses are

available in the draft bridging document, which will be finalized upon issuance of the NRC

audit report for the SFPI vendor (MOHR).]

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:

The process will be captured in ENO procedures established based on manufacturer’s

recommendations and ENO process and procedures. The instrument automatically monitors

the integrity of its level measurement system using in-situ capability. Deviation of measured

test parameters from manufactured or as-installed configuration beyond a configurable

threshold prompts operator intervention.

10 of 13

ENO Response: 

See draft bridging document Topic #18 located on ePortal. [Note: Preliminary responses are 

available in the draft bridging document, which will be finalized upon issuance of the NRC 

audit report for the SFPI vendor (MOHR).] 

RAI#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: 

See draft bridging document Topics #16, 17 & 18 located on ePortal. [Note: Preliminary 

responses are available in the draft bridging document, which will be finalized upon issuance 

of the NRC audit report for the SFPI vendor (MOHR).] 

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: 

In general relative to normal operating conditions, any applicable calibration procedure 

tolerances (or acceptance criterion) will be established based on the vendor manuals 

stated/recommended reference accuracy (or design accuracy). The methodology used will 

be based on the vendor manuals and captured in plant procedures and/or programs. See 

draft bridging document Topics #20 located on ePortal. [Note: Preliminary responses are 

available in the draft bridging document, which will be finalized upon issuance of the NRC 

audit report for the SFPI vendor (MOHR).] 

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: 

The process will be captured in ENO procedures established based on manufacturer's 

recommendations and ENO process and procedures. The instrument automatically monitors 

the integrity of its level measurement system using in-situ capability. Deviation of measured 

test parameters from manufactured or as-installed configuration beyond a configurable 

threshold prompts operator intervention. 

10 of 13 
See draft bridging document Topic #20 located on ePortal. [Note: Preliminary responses are

available in the draft bridging document, which will be finalized upon issuance of the NRC

audit report for the SFPI vendor (MOHR).]

RAI#16

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

please describe the evaluation used to vaildate 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:

The backup display will be mounted in the Radwaste Control Panel Room Cabinet Cl 04 at

the 590’ elevation of the Aux. Building. This cabinet is located in Room 121, and can be

accessed via Stairwell No. 16 and Door 75, or via Corridor 1 06A through Door 190. Both

Stairwell 16 and Corridor 106A can be approached from the north, east, and west via Corridor

106. The back-up channel display can be considered promptly accessible, because it can be

reached within the 30 minute deployment requirement that exists for portable instrumentation

(Section 3.1 of NEI 12-02).

The impact to habitability would be primarily from elevated temperatures, as the C-40 panel

room is considered a mild radiation environment. Habitability will be assured by heat stress

countermeasures and rotation of personnel to the extent feasible. Personnel will not be

continuously stationed at the backup display, it will be monitored periodically. The site FLEX

Support Guidelines will provide guidance for personnel to evaluate the room temperature and

take actions as necessary. In addition, site procedures already use passive cooling

technologies for response personnel.

The FLEX staffing plan has not been finalized at this time. The results of the staffing plan will

be included in a future six month status report.

If necessary, portable radios will be used to communicate with decision makers.

11 of 13

See draft bridging document Topic #20 located on ePortal. [Note: Preliminary responses are 

available in the draft bridging document, which will be finalized upon issuance of the NRC 

audit report for the SFPI vendor (MOHR).] 

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: 

The backup display will be mounted in the Radwaste Control Panel Room Cabinet C104 at 

the 590' elevation of the Aux. Building. This cabinet is located in Room 121, and can be 

accessed via Stairwell No. 16 and Door 75, or via Corridor 106A through Door 190. Both 

Stairwell 16 and Corridor 106A can be approached from the north, east, and west via Corridor 

106. The back-up channel display can be considered promptly accessible, because it can be 

reached within the 30 minute deployment requirement that exists for portable instrumentation 

(Section 3.1 of NEI 12-02). 

The impact to habitability would be primarily from elevated temperatures, as the C-40 panel 

room is considered a mild radiation environment. Habitability will be assured by heat stress 

countermeasures and rotation of personnel to the extent feasible. Personnel will not be 

continuously stationed at the backup display, it will be monitored periodically. The site FLEX 

Support Guidelines will provide guidance for personnel to evaluate the room temperature and 

take actions as necessary. In addition, site procedures already use passive cooling 

technologies for response personnel. 

The FLEX staffing plan has not been finalized at this time. The results of the staffing plan will 

be included in a future six month status report. 

If necessary, portable radios will be used to communicate with decision makers. 

11 of 13 
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:

The calibration and test procedures developed by MOHR are provided in the technical

manuals developed by MOHR. See bridging document Topics #10, 19, & 20 located on

ePortal. [Note: Preliminary responses are available in the draft bridging document, which will

be finalized upon issuance of the NRC audit report for the SFPI vendor (MOHR).] The

objectives are to measure system performance, determine if there is a deviation from normal

tolerances, and return the system to normal tolerances.

Diagnostic procedures developed by MOHR are provided as automated and semi-automated

routines in system software alerting the operator to abnormal deviation in selected system

parameters such as battery voltage, 4-20 mA loop continuity, and TDR waveform of the

transmission cable. The technical objective of the diagnostic procedures is to identify system

conditions that require operator attention to ensure continued reliable liquid level

measurement. Manual diagnostic procedures are also provided in the event that further

workup is determined to be necessary.

Maintenance procedures developed by MOHR are provided in the technical manual. These

allow a technician trained in EFP-lL system maintenance to ensure that system functionality

is maintained.

An operation procedure will provide sufficient instructions for operation and use of the

system.

ENO procedures will be developed in accordance with the vendor manuals provided by

MQHR and ENO procedures and processes.

FLEX Support Guidelines will provide sufficient instructions for use of the SFPI during a

beyond design basis external event.

12 of 13

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: 

The calibration and test procedures developed by MOHR are provided in the technical 

manuals developed by MOHR. See bridging document Topics #10,19, & 20 located on 

ePortal. [Note: Preliminary responses are available in the draft bridging document, which will 

be finalized upon issuance of the NRC audit report for the SFPI vendor (MOHR).] The 

objectives are to measure system performance, determine if there is a deviation from normal 

tolerances, and return the system to normal tolerances. 

Diagnostic procedures developed by MOHR are provided as automated and semi-automated 

routines in system software alerting the operator to abnormal deviation in selected system 

parameters such as battery voltage, 4-20 mA loop continuity, and TDR waveform of the 

transmission cable. The technical objective of the diagnostic procedures is to identify system 

conditions that require operator attention to ensure continued reliable liquid level 

measurement. Manual diagnostic procedures are also provided in the event that further 

workup is determined to be necessary. 

Maintenance procedures developed by MOHR are provided in the technical manual. These 

allow a technician trained in EFP-IL system maintenance to ensure that system functionality 

is maintained. 

An operation procedure will provide sufficient instructions for operation and use of the 

system. 

ENO procedures will be developed in accordance with the vendor manuals provided by 

MOHR and ENO procedures and processes. 

FLEX Support Guidelines will provide sufficient instructions for use of the SFPI during a 

beyond design basis external event. 

12 of 13 
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:

SFPI channel/equipment maintenance/preventative maintenance and testing program

requirements to ensure design and system readiness will be established in accordance with

ENO processes and procedures and in consideration of vendor recommendations to ensure

that appropriate regular testing, channel checks, functional tests, periodic calibration, and

maintenance are performed (and available for inspection and audit). See draft bridging

document Topics #10 and #20 located on ePortal. [Note: Preliminary responses are available

in the draft bridging document, which will be finalized upon issuance of the NRC audit report

for the SFPI vendor (MOHR).J

13 of 13

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: 

SFPI channel/equipment maintenance/preventative maintenance and testing program 

requirements to ensure design and system readiness will be established in accordance with 

ENO processes and procedures and in consideration of vendor recommendations to ensure 

that appropriate regular testing, channel checks, functional tests, periodic calibration, and 

maintenance are performed (and available for inspection and audit). See draft bridging 

document Topics #10 and #20 located on ePortal. [Note: Preliminary responses are available 

in the draft bridging document, which will be finalized upon issuance of the NRC audit report 

for the SFPI vendor (MOHR).] 

13 of 13