UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

May 29,2013 

Vice President, Operations 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

SUBJECT: PALISADES NUCLEAR PLANT - STAFF ASSESSMENT IN RESPONSE TO 

RECOMMENDATION 9.3 OF THE NEAR-TERM TASK FORCE RELATED TO 

THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT 

(TAC NO. ME9973) 

Dear Sir: 

By letter dated March 12,2012, the U.S. Nuclear Regulatory Commission (NRC) issued a 

request for information pursuant to Section 50.54(f) to Title 10 of the Code of Federal 

Regulations (henceforth referred to as the 50.54(f) letter). The request was issued as a part of 

implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. 

Enclosure 5 to the 50.54(f) letter contained specific requested information associated with the 

NRC's Near-Term Task Force Recommendation 9.3 for emergency preparedness 

communications. Specifically, the letter requested that licensees provide an assessment of the 

current communications systems and equipment used during an emergency event. 

By letter dated October 31, 2012, Entergy Operations, Inc. (the licensee), responded to this 

request for Palisades Nuclear Plant (Palisades). In response to NRC staff questions, the 

licensee provided additional information by letter dated February 21, 2013. 

The NRC staff has reviewed the communications assessment for Palisades and, as 

documented in the enclosed safety assessment, determined that the assessment for 

communications is reasonable, and the interim measures, analyzed existing systems, and 

proposed enhancements will help to ensure that communications are maintained. Further, in 

coordination with the Near-Term Task Force Recommendation 4.2 (mitigating strategies), the 

NRC staff plans to follow up with the licensee to confirm that upgrades to the site's 

communications systems have been completed. 
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If you have any questions, please contact me at (301) 415-8371. 

Sincerely, 

Mahesh Chawla, Project Manager 

Plant Licensing Branch 3-1 

Division of Operating Reactor Licensing 

Office of Nuclear Reactor Regulation 

Docket No. 50-255 


Enclosure: 


Safety Assessment 


cc w/encl: Distribution via Listserv 

UNITED STATES 


NUCLEAR REGULATORY COMMISSION 


WASHINGTON, D.C. 20555-0001 

SAFETY ASSESSMENT BY THE OFFICE OF NUCLEAR REACTOR REGULATION 

ASSESSMENT OF COMMUNICATIONS IN RESPONSE TO 

REQUEST FOR INFORMATION DATED MARCH 12, 2012 

ENTERGY NUCLEAR OPERATIONS, INC. 

PALISADES NUCLEAR PLANT 

DOCKET NO. 50-255 

1.0 INTRODUCTION 

By letters dated May 11, 2012 (Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML 12135A289), June 8, 2012 (ADAMS Accession No. 

ML 12163A546), October 31,2012 (ADAMS Accession No. ML 12305A540), and February 21, 

2013 (ADAMS Accession No. ML 13053A080), Entergy Nuclear Operations, Inc., (the licensee), 

for Palisades Nuclear Plant provided an assessment of its communications capabilities in 

response to the U.S. Nuclear Regulatory Commission's (NRC's) March 12,2012 (ADAMS 

Accession No. ML 12053A340), request for information, regarding the Near-Term Task Force 

(NTTF), Recommendation 9.3, on emergency preparedness communications, under Section 

50.54(f) to Title 10 to the Code of Federal Regulations (10 CFR). 

Within the licensee response letter, an assessment of the current communications systems and 

equipment to be used during an emergency event was performed to identify any enhancements 

needed to ensure communications are maintained during and following a beyond design basis 

large-scale natural event. In this assessment it was assumed that a large-scale natural event 

causes: (1) a loss of all alternating current (ac) power; and (2) extensive damage to normal and 

emergency communications systems both onsite and in the area surrounding the site 

(i.e., within 25 miles of the site, consistent with the guidance endorsed by NRC's May 15, 2012, 

letter (ADAMS Accession No. ML 12131A043)). Additionally, in its letter dated June 8,2012, the 

licensee identified interim actions during the period of implementation of the planned 

improvements to the communications systems or procedures. 

1.1 Background 

On March 12, 2012, NRC issued a letter entitled "Request for Information Pursuant to Title 10 of 

the Code of Federal Regulations 50. 54(f) regarding Recommendations 2.1, 2.3, and 9.3, of the 

Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident." In 

accordance with 10 CFR 50.54(f), addressees were requested to submit a written response to 

the information requests within 90 days. 

Enclosure 
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The March 12, 2012, letter, states that if an addressee cannot meet the requested response 

date, then the addressee must respond within 60 days of the date of the letter, and describe the 

alternative course of action that it proposes to take, including any estimated completion date. 

On May 11,2012, the licensee committed to submitting their completed communications 

assessment and implementation schedule by October 31,2012. On June 8,2012, the licensee 

also provided their description of any interim actions (discussed in further detail in Section 3.0) 

that have been taken, or are planned to be taken, to enhance existing communications systems 

power supplies until the communications assessment and the resulting actions are complete. 

The NRC staff found the proposed schedule acceptable by letter dated July 26, 2012 (ADAMS 

Accession No. ML 12200A106). 

Enclosure 5 of NRC's March 12, 2012, letter contained specific requested information 

associated with NRC's NTTF, Recommendation 9.3, for emergency preparedness 

communications. Specifically, the letter requested that licensees provide an assessment of the 

current communications systems and equipment used during an emergency event to identify 

any enhancements that may be needed to ensure communications are maintained during a 

large-scale natural event and subsequent loss of ac power. The licensee's assessment should: 

• 	 identify any planned or potential improvements to existing onsite communications 

systems and their required normal and/or backup power supplies; 

• 	 identify any planned or potential improvements to existing offsite communications 

systems and their required normal and/or backup power supplies; 

• 	 provide a description of any new communications system(s) or technologies that will be 

deployed based upon a large-scale natural event and damage to communications 

systems onsite and offsite; and 

• 	 provide a description of how the new and/or improved systems and power supplies will 

be able to provide for communications during a loss of all ac power. 

The letter also asked for licensees to: 

• 	 describe any interim actions that have been taken or are planned to be taken to enhance 

existing communications systems power supplies until the communications assessment 

and the resulting actions are complete; and 

• 	 provide a schedule of the time needed to implement the results of the communications 

assessment. 

2.0 REGULATORY EVALUATION 

The NRC staff reviewed the licensee's responses to the March 12, 2012,10 CFR 50.54(f), 

request for information against the regulations and guidance described below. 

2.1 Regulations 

Section 50.47, "Emergency plans," to 10 CFR Part 50, sets forth emergency plan requirements 

for nuclear power plant facilities. 
- 3 ­

Section 50.47(b) establishes the standards that the onsite and offsite emergency response 

plans must meet for NRC staff to make a positive finding that there is reasonable assurance that 

the licensee can and will take adequate protective measures in the event of a radiological 

emergency. Planning Standard (6) of this section requires that a licensee's emergency 

response plan contain provisions for communications among response organizations to 

emergency personnel and the public. Planning Standard (8) requires that the design should 

include adequate emergency facilities and equipment to support emergency response. 

Section IV.D of Appendix E, "Emergency Planning and Preparedness for Production and 

Utilization Facilities," to 10 CFR Part 50, requires that a licensee have the capability to notify 

responsible State and local governmental agencies within 15 minutes after declaring an 

emergency. The design objective of the alert and notification system shall be to have the 

capability to complete the alerting and initiate notification of the public within the plume 

exposure pathway within approximately 15 minutes. This alerting and notification capability will 

include a backup method of public alerting and notification. 

Section IV.E of Appendix E, "Emergency Planning and Preparedness for Production and 

Utilization Facilities," to 10 CFR Part 50, states that adequate provisions will be made and 

described for emergency facilities including at least one onsite and one offsite communications 

system; and each system shall have a backup power source. These arrangements will include: 

a. Provision for communications with contiguous Statellocal governments within the plume 

exposure pathway emergency planning zone. 

b. Provision for communications with Federal emergency response organizations. 

c. Provision for communications among the nuclear power reactor control room, the onsite 

technical support center, and the emergency operations facility; and among the nuclear 

facility, the principal State and local emergency operations centers, and the field 

assessment teams. 

d. Provisions for communications by the licensee with NRC Headquarters and the 

appropriate NRC Regional Office Operations Center from the nuclear power reactor 

control room, the onsite technical support center, and the emergency operations facility. 

2.2 Guidance 

The Nuclear Energy Institute (NEI) 12-01, "Guideline for Assessing Beyond Design Basis 

Accident Response Staffing and Communication Capabilities," presents a methodology for 

licensees to analyze their ability to perform critical communications during and after a largescale natural event. NRC staff has previously reviewed (ADAMS Accession No. ML 12131A043) 

NEI 12-01 and determined that it was an acceptable method for licensees to use in responding 

to NRC's March 12, 2012, information request. 

The staff reviewed the licensee's analyses against the assumptions and guidance within 

NEI 12-01, Sections 2.2, 2.4, and 4. These sections provide a discussion on the assumptions 

and criteria to be used for a communications assessment. 
-4­

3.0 TECHNICAL EVALUATION 

In its October 31,2012, letter, the licensee submitted its assessment of communications 

assuming a large-scale natural event, which would lead to an extended loss of all ac power. 

This letter included a discussion of required communications links, primary and backup methods 

of communications, and any identified improvements. 

On February 21,2013 (ADAMS Accession No. ML 13053A080), the licensee submitted 

supplemental information to their October 31,2012, communications response, which the NRC 

staff reviewed as part of this evaluation. 

3.1 Communication Areas Reviewed 

Palisades Nuclear Plant currently has communications capabilities with offsite response 

organizations, NRC, between licensee emergency response facilities, with field and offsite 

monitoring teams, and with in-plant and offsite licensee emergency response organization staff. 

As part of its communications assessment, the licensee has determined that many of the 

communications equipment described in their emergency plan can be assumed to not be 

available. However, certain existing onsite communications system equipment such as the 

existing satellite telephones and site radios would be available after implementation of planned 

enhancements, for the communication link listed above given a seismic, high wind, or flooding 

event. 

As an interim measure prior to the implementation of all planned enhancements, the licensee 

has distributed satellite telephones to the Emergency Response Facilities (ERFs). Additionally, 

the licensee has purchased additional radios and spare batteries for the site. This purchased 

equipment will be used in conjunction with existing satellite telephones and site radios until the 

final implementation of all planned enhancements. This additional communication equipment 

has been staged in the ERFs and deployed; further, licensee personnel will be familiarized with 

communication equipment use and capabilities in the interim prior to finalization of all 

enhancements. 

As the planned enhancement, the licensee plans on ensuring that portable satellite telephones 

or radio communications are available for each communication link outlined in Section 4 of 

NEI 12-01. Communications with offsite response organizations, as well as between licensee 

emergency response facilities, will utilize radios in addition to portable satellite telephones. 

Further enhancements for equipment protection will be made to ensure the availability of the 

radio communications system. The licensee is also implementing planned improvements for 

communications with offsite response organizations by ensuring each organization has a 

portable satellite telephone. The licensee will put these enhancements in place with licenseeapproved procedures by May 19, 2015. 

The NRC staff has reviewed the licensee's expected communications links within their 

communications assessment. In reviewing their submittal, the NRC staff considered whether it 

is reasonable that each communication link can be maintained after the implementation of all 

planned enhancements, in accordance with the NRC-endorsed guidance of NEI 12-01. The 

portable satellite telephones, as well as the site radios, are expected to help maintain 

communications offsite and onsite due to planned enhancements to equipment protection and 

the expected functionality of satellite communications without infrastructure postulated to be 
- 5 ­

damaged by a large-scale natural event. The NRC staff concludes that since the licensee's 

assessment for the availability of communications systems is reasonable, and planned 

enhancements are to be made for communications areas to help ensure reliability, the 

licensee's interim measures and proposed enhancements will help to ensure that 

communications are maintained consistent with the assumptions in NRC-endorsed guidance of 

NEI 12-01. 

3.1.2 Equipment Location 

The licensee has determined the survivability of their existing equipment for large-scale natural 

events by performing area walkdowns of equipment located onsite. The structural capacity of 

equipment in its current configuration was evaluated in its ability to withstand the external 

hazards as identified in the NEI 12-01 guidance. These hazards include seismic, flooding, and 

high winds. The licensee's evaluation was based on engineering judgment developed by a 

consensus of experienced engineers in structural design and construction using the guidance 

provided in NEI 12-01. 

NRC staff reviewed the licensee's submittal and verified that the licensee has considered the 

equipment location and protection contained within the NRC-endorsed guidance of NEI 12-01. 

The NRC staff also verified that all equipment discussed in Section 3.1.1 of this document has 

been analyzed to be available after a large-scale natural event; actions will be taken for its 

protection, or would be stored in a reasonably protected area from seismic, flooding, and high 

wind events as discussed in NEI 12-01. The NRC staff also ensured that ancillary equipment, 

such as battery chargers, would be protected from seismic, flooding, and high wind events. 

Based on this review, the staff considers the licensee's analysis of communications assessment 

equipment survivability and proposed enhancements for equipment location to be consistent 

with NRC-endorsed guidance NEI 12-01. This determination of equipment protection, support 

the conclusion that these measures will help to ensure communications equipment availability 

for a large-scale natural event. 

3.1.3 Equipment Power and Fuel 

Palisades Nuclear Plant has analyzed the availability of their communications system power 

supplies following the loss of all ac power. The licensee has proposed a combination of 

batteries and uninterrupted power supplies (UPSs) to power site communications equipment, 

including the satellite telephones, radios, and radio systems. The site strategies will result in: 

(1) each satellite telephone will be provided for a 24-hour power supply capability through 

batteries; (2) radios will be provided for a 24-hour power supply capability through batteries, and 

(3) UPS units will provide 24 hours of back-up power for radio repeater systems. 

The NRC staff has reviewed the licensee's communications assessment power supplies. In 

reviewing their submittal, the NRC staff finds it reasonable that power for the existing equipment 

and proposed enhancement equipment, as listed in Section 3.1.1 of this document, would 

remain available for a 24-hour duration, based on the availability of extra batteries. Additionally, 

the licensee's interim measures and proposed enhancements are in accordance with NRCendorsed guidance of NEI 12-01. 
- 6 ­

Based on this review, the staff considers the licensee's analysis of equipment power and 

proposed enhancements for equipment power to be consistent with NRC endorsed guidance 

NEI 12-01. This determination of available equipment power support the conclusion that these 

measures will help to ensure communications equipment functionality for a large-scale natural 

event. 

3.1.4 Proceduralization and Training 

Palisades Nuclear Plant has confirmed that there are sufficient reserves of equipment to 

minimize the need of multi-use equipment for different communication functions. The licensee 

plans on revising existing site procedures for inventory checks and testing of the new portable 

satellite phones and radios in the future. Licensee staff will be trained on equipment location 

and use of this communications equipment by May 19, 2015. 

General employee training procedures will be updated to include direction regarding actions to 

be taken by plant employees following the observation of a large-scale natural event should the 

public address system be unavailable. The licensee has procedures in place for emergency 

response organization self-activation due to major disturbances in the power grid. These site 

capabilities will activate the offsite emergency response organization and notify plant staff. 

The NRC staff reviewed the licensee's commitments on the planned quality assurance and 

maintenance of the equipment and licensee staff training on the use of this equipment. The 

NRC staff determined that the licensee's submittal is in accordance with the NRC-endorsed 

guidance of NEI 12-01. 

Based on this review, the staff considers the licensee's planned proceduralization of equipment 

use and licensee staff training be consistent with NRC-endorsed guidance, NEI 12-01. This 

determination of equipment availability and functionality, support the conclusion that these 

measures will help to ensure communications equipment functionality for a large-scale natural 

event. 

3.2 Regulatory Commitments 

In response to the 50.54(f) letter, the licensee made the following regulatory commitment in its 

letter dated October 31, 2012, which is applicable to this assessment and will be implemented 

prior to startup from Refueling Outage 24 (1 R24) Spring 2015): 

Enhancements identified within the assessment (Attachment 1) will be further 

developed as implementation progresses. Alternate approaches will be utilized if 

prudent (e.g., alternate/new technology, improved capability, cost savings, etc.). 

These enhancement commitments are subject to change as a result of Diverse 

and Flexible Coping Strategies (FLEX) developments, advances in technology, 

and progress in the manner of addressing the need for these enhancements. 

The NRC staff concludes that reasonable controls for the implementation and for the 

subsequent evaluation of the proposed changes pertaining to the above regulatory commitment 

is best provided by the licensee's administrative processes, including its commitment 
- 7 ­

management program. The regulatory commitment above does not warrant the creation of 

regulatory requirements (items requiring prior NRC approval of subsequent changes). 

4.0 CONCLUSION 

The NRC staff has reviewed the licensee's communications assessment for communications 

with or among: offsite response organizations, NRC, licensee emergency response facilities, 

field and offsite monitoring teams, and on-site and in-plant response teams. In reviewing their 

submittal, the NRC staff considered the factors outlined above, and determined that their 

assessment of existing equipment, proposed enhancements and interim actions was in 

accordance with the NRC-endorsed guidance of NEI 12-01. The staff concludes that the 

licensee's assessment for communications is reasonable, and the licensee's interim measures, 

analyzed existing systems, and proposed enhancements will help to ensure that 

Ocommunications are maintained. Further, in coordination with the NTTF Recommendation 4.2 

(mitigating strategies), NRC staff is planning on following up with the licensee to confirm that 

upgrades to the site's communications systems have been completed. 

Principal Contributors: R. Chang 

E. Robinson 

Date of issuance: May 29,2013 
- 2 ­

If you have any questions, please contact me at (301) 415-8371. 

Sincerely, 

IRA! 

Mahesh Chawla, Project Manager 

Plant Licensing Branch 3-1 

Division of Operating Reactor Licensing 

Office of Nuclear Reactor Regulation 

Docket No. 50-255 

Enclosure: 

Safety Assessment 

cc w/encl: Distribution via Listserv 

Distribution: 

PUBLIC LPL3-1 rlt RidsNrrPMPalisades Resource RidsNsirOd Resource 

RidsNrrDorlLpl3-1 Resource RidsNrrLASRohrer Resource RTaylor, NRR DSkeen, NRR 

RidsNroOd Resource RidsNrrDorl Resource EBrown, NRR BHarris, NRR 

RidsNrrOd Resource RidsOeMailCenter Resource MMitchell, NRR ERobinson, NSIR 

RChang, NSIR 

ADAMS Accession No' .. ML13129A219

OFFICE M LPL3-1/LA NSIRlDPRlNRLB/BC 

NAME MChawia SRohrer KWilliams* 

"via memo NRR-106 

OGC NRRlLPL3-1/BC LPL3-1/PM 

BHarris RCarlson ISWall for MChawla 

DATE 05/28/13 05/14/13 ~ 05/17113 05/29/13 05129113 

OFFICIAL RECORD COpy