UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

Vice President, Operations 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, Ml 49043-9530 

April 22, 2015 

SUBJECT: PALISADES NUCLEAR PLANT - PLAN FOR THE ONSITE AUDIT REGARDING 

IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT 

FUEL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND EA-12-

051 (TAC NOS. MF0768 AND MF0769) 

Dear Sir or Madam: 

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

"Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for 

Beyond Design-Basis External Events" and Order EA-12-051, "Issuance of Order to Modify 

Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents 

Access and Management System (ADAMS) Accession Nos. ML 12054A736 and ML 12054A679, 

respectively). The orders require holders of operating reactor iicenses and construction permits 

issued under Title 1 O of the Code of Federal Regulations Part 50 to submit for review, Overall 

Integrated Plans (OIPs) including descriptions of how compliance with the requirements of 

Attachment 2 of each order will be achieved. 

By letter dated February 28, 2013 (ADAMS Accession No. ML ~3060A361), Entergy Nuclear 

Operations. Inc. (Entergy, the licensee) submitted its OIP for Palisades Nuclear Plant 

(Palisades) in response to Order EA-12-049. By letters dated August 28, 2013, February 28, 

2014, August 28, 2014, and February 27, 2015 (ADAMS Accession Nos. ML 13241A234, 

ML ~4059A078, ML 14240A279 and ML 15062A011, respectively), the licensee submitted its first 

four six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. 

ML 13234A503), the NRC notified all licensees and construction permit holders that the staff is 

conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of 

Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS 

Accession No. ML082900195). This audit process led to the issuance of the Palisades interim 

staff evaluation (ISE) (ADAMS Accession No. ML 13365A261) on February 10, 2014, and 

continues with in-office and onsite portions of this audit. 

By letter dated February 28, 2013 (ADAMS Accession No. ML 13060A360), the licensee 

submitted its OIP for Palisades in response to Order EA-12-051. By e-mail dated July 18, 2013 

(ADAMS Accession No. ML 13200A328), the NRC staff sent a request for additional information 

(RAI) to the licensee. By letters dated August 19, 2013, August 28, 2013, February 28, 2014, 

August 28, 2014, and February 27, 2015 (ADAMS Accession Nos. ML 13231A126, 

ML 13241A235, ML 14059A078, ML 14240A278 and ML 15062A056, respectively), the licensee 

submitted its RAI responses and first four six-month updates to the OIP. The NRC staff's 

review to date led to the issuance of the Palisades ISE and RAI dated November 26, 2013 

(ADAMS Accession No. ML 13312A423). By letter dated March 26, 2014 
- 2 -

(ADAMS Accession No. ML 14083A620), the NRC notified all licensees and construction permit 

holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-

051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above. 

The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess 

whether it has enough information to make a safety evaluation of the Integrated Plans. The 

audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, 

RAI responses from the spent fuel pool instrumentation ISE, the licensee's integrated plans, and 

other audit questions. Additionally, the staff gains a better understanding of submitted 

information, identifies additional information necessary for the licensee to supplement its plan, 

and identifies any staff potential concerns. The audit's onsite portion will occur prior to 

declarations of compliance for the first unit at each site. 

This document outlines the onsite audit process that occurs after ISE issuance as licensees 

provide new or updated information via periodic updates, update audit information on e-portals, 

provide preliminary Overall Program Documents/Final Integrated Plans, and continue in-office 

audit communications with staff while proceeding towards compliance with the orders. 

The staff plans to conduct an onsite audit at Palisades in accordance with the enclosed audit 

plan from June 15 - 18, 2015. 

If you have any questions, please contact me at 301-415-3204 or by e-mail at 

john.hughey@nrc.gov. 

Docket No.: 50-255 

Enclosure: 

Audit plan 

cc w/encl: Distribution via Listserv 

jil2 

John Hughey, Project Manager 

Orders Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 
Audit Plan 

Palisades Nuclear Plant 

BACKGROUND AND AUDIT BASIS 

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

"Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for 

Beyond Design-Basis External Events" and Order EA-12-051, "Issuance of Order to Modify 

Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents 

Access and Management System (ADAMS) Accession Nos. ML 12054A736 and ML 12054A679, 

respectively). Order EA-12-049 directs licensees to develop, implement, and maintain guidance 

and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) 

cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Order EA12-051 requires, in part, that all operating reactor sites have a reliable means of remotely 

monitoring wide-range SFP levels to support effective prioritization of event mitigation and 

recovery actions in the event of a BDBEE. The orders require holders of operating reactor 

licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 

50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how 

compliance with the requirements of Attachment 2 of each order will be achieved. 

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

Operations, Inc. (Entergy, the licensee) submitted its OIP for Palisades Nuclear Plant 

(Palisades) in response to Order EA-12-049. By letters dated August 28, 2013, February 28, 

2014, August 28, 2014, and February 27, 2015 (ADAMS Accession Nos. ML 13241A234, 

ML 14059A078, ML 14240A279 and ML 15062A011, respectively), the licensee submitted its first 

four six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. 

ML 13234A503), the NRC notified all licensees and construction permit holders that the staff is 

conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of 

Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS 

Accession No. ML082900195). This audit process led to the issuance of the Palisades interim 

staff evaluation (ISE) (ADAMS Accession No. ML 13365A261) on February 10, 2014, and 

continues with in-office and onsite portions of this audit. 

By letter dated February 28, 2013 (ADAMS Accession No. ML 1 3060A360), the licensee 

submitted its OIP for Palisades in response to Order EA-12-051. By e-mail dated July 18, 2013 

(ADAMS Accession No. ML 13200A328), the NRC staff sent a request for additional information 

(RAI) to the licensee. By letters dated August 19, 2013, August 28, 2013, February 28, 2014, 

August 28, 2014 and February 27, 2015 (ADAMS Accession Nos. ML 13231A126, 

ML 13241A235, ML 14059A078, ML 14240A278 and ML 15062A056, respectively), the licensee 

submitted its RAI responses and first four six-month updates to the OIP. The NRC staff's 

review to date led to the issuance of the Palisades ISE and RAI dated November 26, 2013 

(ADAMS Accession No. ML 13312A423). By letter dated March 26, 2014 (ADAMS Accession 

No. ML 14083A620), the NRC notified all licensees and construction permit holders that the staff 

is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance 

with NRC NRR Office Instruction LIC-111, as discussed above. 

Enclosure 
- 2 -

The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess 

whether it has enough information to make a safety evaluation of the Integrated Plans. The 

audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, 

RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated 

plans, and other audit questions. Additionally, the staff gains a better understanding of 

submitted information, identifies additional information necessary for the licensee to supplement 

its plan, and identifies any staff potential concerns. The audit's onsite portion will occur prior to 

declarations of compliance for the first unit at each site. 

This document outlines the onsite audit process that occurs after ISE issuance as licensees 

provide new or updated information via periodic updates, update audit information on e-portals, 

provide preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs), and 

continue in-office audit communications with staff while proceeding towards compliance with the 

orders. 

Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs, 

as supplemented, the resulting site-specific OPDs/FIPs, and, as appropriate, other licensee 

submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a 

safety determination regarding order compliance using the Nuclear Energy Institute (NEI) 

guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation 

Guide" issued in August 2012 (ADAMS Accession No. ML 12242A378), as endorsed, by NRC 

Japan Lessons-Learned Project Directorate (JLD) interim staff guidance (ISG) JLD-ISG-2012-

01 "Compliance with Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements 

for Mitigation Strategies for Beyond-Design-Basis External Events"' (ADAMS Accession No. 

ML 12229A174) as providing one acceptable means of meeting the order requirements. For 

Order EA-12-051, the staff will make a safety determination regarding order compliance using 

the NEI guidance document NEI 12-02, "Industry Guidance for Compliance with NRC Order EA12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"' (ADAMS 

Accession No. ML 12240A307), as endorsed, with exceptions and clarifications, by NRC ISG 

JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool 

Instrumentation"' (ADAMS Accession No. ML 12221A339) as providing one acceptable means of 

meeting the order requirements. Should the licensee propose an alternative strategy or other 

method deviating from the guidance, additional staff review will be required to evaluate if the 

alternative strategy complies with the applicable order. 

AUDIT SCOPE 

As discussed, onsite audits will be performed per NRR Office Instruction LIC-111, "Regulatory 

Audits," to support the development of safety evaluations. Site-specific OIPs and OPDs/FIPs 

rely on equipment and procedures that apply to all units at a site, therefore, audits will be 

planned to support the "first unit at each site." Onsite audits for subsequent units at a site will 

be on an as-needed basis. 

The purpose of the audit is to obtain and review information responsive to the Palisades OIPs, 

as supplemented, open and confirmatory items from the mitigation strategies ISE, RAI 

responses from the SFPI ISE, and to observe and gain a better understanding of the basis for 

the site's overall programs to ensure the licensee is on the correct path for compliance with the 

Mitigation Strategies and SFPI orders. These may include, but are not limited to: 
- 3 -

• Onsite review and discussion for the basis and approach for detailed analysis and 

calculations (Orders EA-12-049, EA-12-051); 

• Walk-throughs of strategies and laydown of equipment to assess feasibility, timing, and 

effectiveness of a given mitigating strategy or integration of several strategies (Order 

EA-12-049); 

• Storage, protection, access, and deployment feasibility and practicality for onsite 

portable equipment (Order EA-12-049); 

• Evaluation of staging, access, and deployment of offsite resources to include equipment 

provided by the Strategic Alliance for FLEX Emergency Response (SAFER) from the 

National SAFER Response Centers (NSRCs) (Order EA-12-049); and 

• Review dimensions and sizing of the SFP area, placement of the SFP level 

instrumentation, and applicable mounting methods and design criteria (Order EA-12-

051 ). 

NRC AUDIT TEAM 

Title Team Member 

T earn Lead I Project ManaQer John HuQhev 

Technical Suooort Matthew McConnell 

Technical Support KhoiNguyen 

Technical Suooort Kevin Roche 

Technical Support Summer Sun 

LOGISTICS 

The audit will be conducted onsite at Palisades on June 15 - 18, 2015. Entrance and exit 

briefings will be held with the licensee at the beginning and end of the audit, respectively, as 

well as daily briefings of team activities. Additional details will be addressed over the phone. A 

more detailed schedule is provided below. 

A private conference room is requested for NRC audit team use with access to audit 

documentation upon arrival and as needed. 

DELIVERABLES 

An audit report/summary will be issued to the licensee within 90 days from the end of the audit. 
- 4 -

INFORMATION NEEDS 

• Materials/documentation provided in responses to open or confirmatory items and RAls 

in the ISEs; 

• OPD/FIP (current version), operator procedures, FLEX Support Guidelines (FSGs), 

operator training plans, SAFER Response Plan for Palisades; and 

• Materials/documentation for staff audit questions and/or licensee OIP identified open 

items as described in Part 2 below 

To provide supplemental input to the ongoing audit of documents submitted to the NRC and 

made available via e-portal, the onsite audit will have three components: 1) a review of the 

overall mitigating strategies for the site, including, if needed, walk-throughs of strategies and 

equipment laydown of select portions; 2) a review of material relating to open or confirmatory 

items and RAls from the ISEs, staff audit questions, and licensee open items; and 3) additional 

specific issues requested by NRC technical reviewers related to preparation of a safety 

evaluation. Each part is described in more detail below: 

Part 1 - Overall Mitigating Strategies and Program Review: 

During the onsite audit, please be prepared to conduct a tabletop discussion of the site's 

integrated mitigating strategies and SFPI compliance program. This discussion should address 

the individual components of the plans, as well as the integrated implementation of the 

strategies including a timeline. The licensee team presenting this should include necessary 

representatives from site management, engineering, training, and operations that were 

responsible for program development, and will be responsible for training and execution. 

Following the tabletop discussion please be prepared to conduct walk-throughs of procedures 

and demonstrations of equipment as deemed necessary by NRC audit team members. Include 

representatives from engineering and operations that will be responsible for training and 

execution. At this time we expect, at a minimum, to walk-through the items below. Based on 

the tabletop presentations and audit activities, this list may change. 

WALK-THROUGH LIST: 

1. Walk-through a sample of strategies that will be delineated by specific NRC technical 

staff audit team members 

2. Walk-through of portable (FLEX) diesel generator procedures, to include power supply 

pathways, areas where manual actions are required, and electrical isolation 

3. Walk-through of building access procedures, to include any unique access control 

devices 

4. Strategy walk-through of transfer routes from staging and storage areas to deployment 

locations for both onsite and offsite equipment 
- 5 -

5. Strategy walk-through for core cooling and reactor coolant system inventory, to include 

portable pumping equipment, flow paths, and water storage locations and the related 

reactor systems analysis and calculations 

6. Walk-through of communications enhancements 

7. Walk-through of SFP area, SFPI locations, and related equipment mounting areas 

Part 2 - Specific Technical Review Items: 

During the visit, audit items will be addressed from the licensee's ISEs open items, confirmatory 

items, and SFPI RAls; audit question list; licensee OIP, as supplemented, open items; and draft 

safety evaluation additional questions. Please provide documents or demonstrations as needed 

to respond to each item. 

Part 3 - Specific Topics for Discussion: 

1. Draft of Palisades OPD/FIP 

2. Reactor systems analyses to include a discussion of Primary Coolant Pump seal 

leakage. 

3. Training 

4. Portable (FLEX) equipment maintenance and testing 

5. NSRC Response Plan for Palisades 
- 6 -

Proposed Schedule 

Onsite Day 1, Monday, June 15, 2015 

0800 Check in at site; Badging; Dosimetry 

1000 Entrance meeting 

1015 Licensee presentation of strategies 

1230 Lunch 

1330 NRC Audit Team Activities: 

• Technical area break-out discussions between NRC and licensee staff in the areas of 

reactor systems, electrical, balance-of-plant/structures, SFPI, and others 

• Review documents relating to open or confirmatory items, RAls, codes, analyses, etc. 

• NRC Mitigating Strategies/SFPI walk-throughs with licensee 

1630 Team lead daily debrief/next day planning with licensee 

Onsite Day 2, Tuesday, June 16, 2015 

0800 Continue NRC Audit Team Activities 

1200 Lunch 

1300 Continue NRC Audit Team Activities 

1630 Team lead daily debrief/next day planning with licensee 

Onsite Day 3, Wednesday, June 17, 2015 

0800 Continue NRC Audit Team Activities 

1200 Lunch 

1300 Continue NRC Audit Team Activities 

1630 Team lead daily debrief/next day planning with licensee 
Onsite Day 4, Thursday, June 18, 2015 

0800 Continue NRC Audit Team Activities 

1200 Lunch 

1300 NRC Audit Team meeting 

1430 NRG/Licensee pre-exit meeting 

1630 NRG/Licensee exit meeting 

1700 Audit closeout/departure 

- 7 -
- 2 -

(ADAMS Accession No. ML 13312A423). By letter dated March 26, 2014 (ADAMS Accession 

No. ML 14083A620), the NRC notified all licensees and construction permit holders that the staff 

is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance 

with NRC NRR Office Instruction LIC-111, as discussed above. 

The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess 

whether it has enough information to make a safety evaluation of the Integrated Plans. The 

audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, 

RAI responses from the spent fuel pool instrumentation ISE, the licensee's integrated plans, and 

other audit questions. Additionally, the staff gains a better understanding of submitted 

information, identifies additional information necessary for the licensee to supplement its plan, 

and identifies any staff potential concerns. The audit's onsite portion will occur prior to 

declarations of compliance for the first unit at each site. 

This document outlines the onsite audit process that occurs after ISE issuance as licensees 

provide new or updated information via periodic updates, update audit information on e-portals, 

provide preliminary Overall Program Documents/Final Integrated Plans, and continue in-office 

audit communications with staff while proceeding towards compliance with the orders. 

The staff plans to conduct an onsite audit at Palisades in accordance with the enclosed audit 

plan from June 15 - 18, 2015. 

If you have any questions, please contact me at 301-415-3204 or by e-mail at 

john.hughey@nrc.gov. 

Docket No.: 50-255 

Enclosure: 

Audit plan 

Sincerely, 

IRA/ 

John Hughey, Project Manager 

Orders Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 

cc w/encl: Distribution via Listserv 

DISTRIBUTION: 

PUBLIC 

JOMB R/F 

RidsNrrDorlLpl 3-1 Resource 

RidsNrrPMPalisades Resource 

RidsNrrLASLent Resource 

ADAMS Accession No. ML 15110A051 

OFFICE NRR/JLD/JOMB/PM 

NAME JHughey 

DATE 04/21/15 

OFFICE NRR/JLD/JOMB/BC(A) 

NAME MHalter 

DATE 04/22/15 

NRR/JLD/LA 

SLent 

04/20/15 

RidsRgn3MailCenter Resource 

JHughey, NRR/JLD 

MHalter, NRR/JLD 

RidsAcrsAcnw_MailCTR Resource 

SBailey 

SWhaley 

NRR/JLD/JCBB/BC NRR/JLD/JERB/BC 

SBailey (BTitus for) SWhaley 

04/22/15 04/21/15 

NRR/DORL/LPL3-1 /PM NRR/JLD/JOMB/PM 

JRankin JHughey 

04/21/15 04/22/15 

OFFICIAL AGENCY RECORD