Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

fl Covert, Ml 49043-9530

Tel 269 764 2000

Anthony J. Vitale

Site Vice President

PNP 2015-007

February 27, 2015

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

11555 Rockville Pike

Rockville, MD 20852

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

March 12, 2012 Commission Order Modifying Licenses with Regard to

Requirements for Mitigation Strategies for Beyond-Design-Basis External

Events (Order Number EA-12-049)

Palisades Nuclear Plant

Docket No. 50-255

License No. DPR-20

REFERENCES: 1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard

to Requirements for Mitigation Strategies for Beyond-Design-Basis

External Events, dated March 12, 2012 (ADAMS Accession No.

1 2054A736)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order

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

Mitigation Strategies for Beyond-Design-Basis External Events,

Revision 0, dated August 29, 2012 (ADAMS Accession No.

ML1 2229A1 74)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012 (ADAMS

Accession No. ML12242A378)

4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-091, Initial

Status Report in Response to March 12, 2012 Commission Order

Modifying Licenses with Regard to Requirements for Mitigation

Strategies for Beyond-Design-Basis External Events (Order Number

EA-12-049), dated October 25, 2012 (ADAMS Accession No.

ML1 2300A065

5. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-010, Overall

Integrated Plan in Response to March 12, 2012 Commission Order

Modifying Licenses with Regard to Requirements for Mitigation

Strategies for Beyond-Design-Basis External Events (Order Number

EA-12-049), dated February 28, 2013 (ADAMS Accession No.

ML1 3246A399)

PNP 2015-007 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

Tel 269 764 2000 

Anthony J. Vitale 

Site Vice President 

February 27,2015 

U.S. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

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

March 12, 2012 Commission Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External 

Events (Order Number EA-12-049) 

Palisades Nuclear Plant 

Docket No. 50-255 

License No. DPR-20 

REFERENCES: 1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard 

to Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events, dated March 12,2012 (ADAMS Accession No. 

12054A736) 

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order 

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

Mitigation Strategies for Beyond-Design-Basis External Events, 

Revision 0, dated August 29,2012 (ADAMS Accession No. 

ML 12229A174) 

3. NEI12-06, Diverse and Flexible Coping Strategie$ (FLEX) 

Implementation Guide, Revision 0, dated August 2012 (ADAMS 

Accession No. ML 12242A378) 

4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-091, Initial 

Status Report in Response to March 12,2012 Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation 

Strategies for Beyond-Design-Basis External Events (Order Number 

EA-12-049), dated October 25,2012 (ADAMS Accession No. 

ML 12300A065 

5. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-010, Overall 

Integrated Plan in Response to March 12,2012 Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation 

Strategies for Beyond-Design-Basis External Events (Order Number 

EA-12-049), dated February 28,2013 (ADAMS Accession No. 

ML 13246A399) 
PNP 2015-007

Page 2 of 3

6. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2013-064,

Palisades Nuclear Plant First Six-Month Status Report in Response to

March 12, 2012 Commission Order Modifying Licenses with Regard to

Requirements for Mitigation Strategies for Beyond-Design-Basis

External Events (Order Number EA- 12-049), dated August 28, 2013

(ADAMS Accession No. ML1 3241 A234)

7. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2014-011,

Palisades Nuclear Plant Second Six-Month Status Report in Response

to March 12, 2012 Commission Order Modifying Licenses with Regard

to Requirements for Mitigation Strategies for Beyond-Design-Basis

External Events (Order Number EA- 12-049), dated February 28, 2014

(ADAMS Accession No. ML1 4059A078)

8. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2014-085,

Palisades Nuclear Plant Third Six-Month Status Report in Response to

March 12, 2012 Commission Order Modifying Licenses with Regard to

Requirements for Mitigation Strategies for Beyond-Design-Basis

External Events (Order Number EA-12-049), dated August 28, 2014

(ADAMS Accession No. ML1 4240A279)

9. NRC letter, Palisades Nuclear Plant — Interim Staff Evaluation

Regarding Overall Integrated Plan in Response to Order EA- 12-049

(Mitigation Strategies) (TAC No. MF0768), dated February 10, 2014

(ADAMS Accession No. ML1 3365A264)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1)

to Entergy Nuclear Operations, Inc. (ENO). Reference 1 was immediately effective and directs

ENO to develop, implement, and maintain guidance and strategies to maintain or restore core

cooling, containment, and spent fuel pool cooling capabilities in the event of a

beyond-design-basis external event.

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 2 endorses industry guidance document Nuclear Energy Institute (NEI)

12-06, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the Palisades Nuclear Plant (PNP) initial status report regarding

mitigation strategies. Reference 5 provided the PNP overall integrated plan.

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 6 provided the first six-month status report. Reference 7 provided the

second six-month status report. Reference 8 provided the third six-month status report. In

Reference 9, the NRC issued an interim staff evaluation for the PNP overall integrated plan.

The purpose of this letter is to provide the fourth 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 attachment provides an update of milestone accomplishments, including

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

PNP 2015-007 

Page 2 of 3 

6. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2013-064, 

Palisades Nuclear Plant First Six-Month Status Report in Response to 

March 12, 2012 Commission Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events (Order Number EA-12-049), dated August 28,2013 

(ADAMS Accession No. ML 13241 A234) 

7. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2014-011, 

Palisades Nuclear Plant Second Six-Month Status Report in Response 

to March 12, 2012 Commission Order Modifying Licenses with Regard 

to Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events (Order Number EA-12-049), dated February 28,2014 

(ADAMS Accession No. ML 14059A078) 

8. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2014-085, 

Palisades Nuclear Plant Third Six-Month Status Report in Response to 

March 12,2012 Commission Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events (Order Number EA-12-049), dated August 28,2014 

(ADAMS Accession No. ML 14240A279) 

9. NRC letter, Palisades Nuclear Plant -Interim Staff Evaluation 

Regarding Overall Integrated Plan in Response to Order EA-12-049 

(Mitigation Strategies) (TAC No. MF0768), dated February 10, 2014 

(ADAMS Accession No. ML 13365A264) 

Dear Sir or Madam: 

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) 

to Entergy Nuclear Operations, Inc. (ENO). Reference 1 was immediately effective and directs 

ENO to develop, implement, and maintain guidance and strategies to maintain or restore core 

cooling, containment, and spent fuel pool cooling capabilities in the event of a 

beyond-design-basis external event. 

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 2 endorses industry guidance document Nuclear Energy Institute (NEI) 

12-06, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. 

Reference 4 provided the Palisades Nuclear Plant (PNP) initial status report regarding 

mitigation strategies. Reference 5 provided the PNP overall integrated plan. 

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 6 provided the first six-month status report. Reference 7 provided the 

second six-month status report. Reference 8 provided the third six-month status report. In 

Reference 9, the NRC issued an interim staff evaluation for the PNP overall integrated plan. 

The purpose of this letter is to provide the fourth 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 attachment provides an update of milestone accomplishments, including 

any changes to the compliance method, schedule, or need for relief and the basis, if any. 
PNP 2015-007

Page 3 of 3

This letter contains no new commitments and no revised commitments.

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

27, 2015.

Sincerely,

/

Palisades Nuclear Plant Fourth Six-Month Status Report in Response to March

12, 2012, Commission Order Modifying Licenses with Regard to Requirements

for Mitigation Strategies for Beyond-Design-Basis External Events (Order

Number EA-12-049)

cc: Office Director, NRR, USNRC

Administrator, Region Ill, USNRC

Project Manager, Palisades, USN RC

Resident Inspector, Palisades, USN RC

ajv/jse

Attachment:

PNP 2015·007 

Page 3 of 3 

This letter contains no new commitments and no revised commitments. 

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

27,2015. 

Sincerely, 

ajv/jse 

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

12, 2012, Commission Order Modifying Licenses with Regard to Requirements 

for Mitigation Strategies for Beyond·Design-Basis External Events (Order 

Number EA-12-049) 

cc: Office Director, NRR, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
ATTACHMENT

Palisades Nuclear Plant Fourth Six-Month Status Report in Response to

March 12, 2012 Commission Order Modifying Licenses with Regard to

Requirements for Mitigation Strategies for Beyond-Design-Basis External

Events (Order Number EA-12-049)

1 Introduction

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

overall integrated plan (Reference 1), which documented the diverse and flexible coping

strategies (FLEX), in response to Reference 2. This attachment provides an update of

milestone accomplishments since submittal of the last status report (Reference 6), including

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

if any.

2 Milestone Accomplishments

The following milestone(s) have been completed since July 31, 2014, and are current as of

January 31, 2015.

• Third Six-Month Status Report —August 2014

• Design Engineering — September 2014

• Install Off-Site Delivery Station — October 2014

• Develop Training Plan — December 2014

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

February 2015.

3 Milestone Schedule Status

The following provides an update to Attachment 2 of 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.

• Develop Strategies with NSRC

The Develop Strategies with NSRC milestone completion date has been changed to

October 2015. This new milestone target completion date does not impact the Order

implementation date.

• Create PNP FLEX FSG

The Create PNP FLEX FSG milestone completion date has been changed to October

2015. This new milestone target completion date does not impact the Order

implementation date.

Page 1 of 15

ATTACHMENT 

Palisades Nuclear Plant Fourth Six-Month Status Report in Response to 

March 12, 2012 Commission Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External 

Events (Order Number EA-12-049) 

1 Introduction 

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

overall integrated plan (Reference 1), which documented the diverse and flexible coping 

strategies (FLEX), in response to Reference 2. This attachment provides an update of 

milestone accomplishments since submittal of the last status report (Reference 6), including 

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

if any. 

2 Milestone Accomplishments 

The following milestone(s) have been completed since July 31, 2014, and are current as of 

January 31, 2015. 

• Third Six-Month Status Report -August 2014 

• Design Engineering - September 2014 

• Install Off-Site Delivery Station - October 2014 

• Develop Training Plan - December 2014 

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

February 2015. 

3 Milestone Schedule Status 

The following provides an update to Attachment 2 of 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. 

• Develop Strategies with NSRC 

The Develop Strategies with NSRC milestone completion date has been changed to 

October 2015. This new milestone target completion date does not impact the Order 

implementation date. 

• Create PNP FLEX FSG 

The Create PNP FLEX FSG milestone completion date has been changed to October 

2015. This new milestone target completion date does not impact the Order 

implementation date. 

Page 1 of 15 
• Create Maintenance Procedures

The Create Maintenance Procedures milestone completion date has been changed to

October 2015. This new milestone target completion date does not impact the Order

implementation date.

• Training Complete

The Training Complete milestone completion date has been changed to July 2015. This

new milestone target completion date does not impact the Order implementation date.

Target Revised Target

Milestone Completion Activity Status Completion

Date* Date

Submit Overall Integrated Feb 2013 Complete Implementation Plan

Six-Month Status Updates

Update 1 Aug 2013 Complete

Update 2 Feb 2014 Complete

Update 3 Aug 2014 Complete

Update 4 Feb 2015 Complete

Update 5 Aug 2015 Not Started

FLEX Strategy Evaluation Jan 2014 Complete

Perform Staffing Analysis Apr2015 Started

Modifications

Modifications Evaluation Apr 2014 Complete

Engineering and Implementation

N-i Walkdown Feb 2014 Complete

Design Engineering Sept 2014 Complete

Implementation Outage Oct 2015 Not Started

On-site FLEX Equipment

Purchase and Procure Aug 2015 Started

Off-site FLEX Equipment

Develop Strategies with NSRC Jan 2015 Started October 2015

Install Off-Site Delivery Station (If Oct 2015 Complete Necessary)

Procedures

Pressurized Water Reactor Owners

Group (PWROG) issues Nuclear Jun 2013 Com lete Steam Supply System (NSSS)- p

Specific_Guidelines

Create PNP FLEX FSG Dec 2014 Started October 2015

Create Maintenance Procedures Mar 2015 Started October 2015

Page 2 of 15

• Create Maintenance Procedures 

The Create Maintenance Procedures milestone completion date has been changed to 

October 2015. This new milestone target completion date does not impact the Order 

implementation date. 

• Training Complete 

The Training Complete milestone completion date has been changed to July 2015. This 

new milestone target completion date does not impact the Order implementation date. 

Target Revised Target 

Milestone Completion Activity Status Completion 

Date* Date 

Submit Overall Integrated Feb 2013 Complete Implementation Plan 

Six-Month Status Updates 

Update 1 Aug 2013 Complete 

Update 2 Feb 2014 Complete 

Update 3 Aug 2014 Complete 

Update 4 Feb 2015 Complete 

Update 5 Aug 2015 Not Started 

FLEX Strategy Evaluation Jan 2014 Complete 

Perform Staffing Analysis Apr 2015 Started 

Modifications 

Modifications Evaluation Apr 2014 Complete 

Engineering and Implementation 

N-1 Walkdown Feb 2014 Complete 

Design Engineering Sept 2014 Complete 

I mplementation Outage Oct 2015 Not Started 

On-site FLEX Equipment 

Purchase and Procure Aug 2015 Started 

Off-site FLEX Equipment 

Develop Strategies with NSRC Jan 2015 Started October 2015 

Install Off-Site Delivery Station (If Oct 2015 Complete Necessary) 

Procedures 

Pressurized Water Reactor Owners 

Group (PWROG) issues Nuclear Jun 2013 Complete Steam Supply System (NSSS)-

Specific Guidelines 

Create PNP FLEX FSG Dec 2014 Started October 2015 

Create Maintenance Procedures Mar 2015 Started October 2015 

Page 2 of 15 
Target Revised Target

Milestone Completion Activity Status Completion

Date* Date

Training

Develop Training Plan Jun 2015 Complete

Training Complete Sept 2015 Not Started July2015

Validation! Demonstration Oct 2015 Not Started

Submit Completion Report Oct2015 Not Started

*Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month

status reports

4 Changes to Compliance Method

There are no changes to the compliance method as documented in the Overall Integrated

Plan (Reference 1).

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

The following tables provide a summary and status of any open items documented in the

overall integrated plan and any open items or confirmatory items documented in Interim Staff

Evaluation (ISE) (Reference 5). A fourth table includes a listing of audit questions and the

status of each item.

Overall Integrated Plan Open Item

OIl. Perform analysis on Palisades’

susceptibility to soil liquefaction and

potential consequences on the

FLEX implementation plan.

Complete/Closed

Status

Borings were performed on site and soil liquefaction

susceptibility was identified along the FLEX equipment

deployment route outside the PA. Based on this

information a set of FLEX equipment will be stored

inside the protected area (PA) for the seismic event.

The other set of FLEX equipment will be stored

outside of the PA and be protected against the

tornado event. Both locations will be protected

against other applicable (screened-in) beyond-designbasis external events (BDBEEs). Additional planning

is under way to address other impacts to equipment

storage and deployment. This Open Item is related to

ISE Open Item 3.1.1 .2.A and is addressed on Audit

Question (AQ) response spreadsheet on the ePortal.

Page 3 of 15

Target Revised Target 

Milestone Completion Activity Status Completion 

Date* Date 

Training 

Develop Training Plan Jun 2015 Complete 

Training Complete Sept 2015 Not Started July 2015 

Validation I Demonstration Oct 2015 Not Started 

Submit Completion Report Oct 2015 Not Started 

*Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month 

status reports 

4 Changes to Compliance Method 

There are no changes to the compliance method as documented in the Overall Integrated 

Plan (Reference 1). 

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 

The following tables provide a summary and status of any open items documented in the 

overall integrated plan and any open items or confirmatory items documented in Interim Staff 

Evaluation (ISE) (Reference 5). A fourth table includes a listing of audit questions and the 

status of each item. 

Overall Integrated Plan Open Item Status 

011. Perform analysis on Palisades' Complete/Closed 

susceptibility to soil liquefaction and Borings were performed on site and soil liquefaction potential consequences on the susceptibility was identified along the FLEX equipment FLEX implementation plan. deployment route outside 'the PA. Based on this 

information a set of FLEX equipment will be stored 

inside the protected area (PA) for the seismic event. 

The other set of FLEX equipment will be stored 

outside of the PA and be protected against the 

tornado event. Both locations will be protected 

against other applicable (screened-in) beyond-designbasis external events (BDBEEs). Additional planning 

is under way to address other impacts to equipment 

storage and deployment. This Open Item is related to 

ISE Open Item 3.1.1.2.A and is addressed on Audit 

Question (AQ) response spreadsheet on the ePortal. 

Page 3 of 15 
Overall Integrated Plan Open Item Status

012. Develop Phase 3 deployment Started

strategy with correspondence with Staging areas have been identified. The National

e SAFER Response Center (NSRC) [formerly known as

the Regional Response Center (RRC)] kickoff meeting

was conducted on 7/22/14 to complete checklist as

approved by AREVA. The NSRC and Palisades are in

process of developing Site Response Plans. This

Open Item is related to ISE Confirmatory Item 3.4.A

and is addressed on the AQ response spreadsheet on

the ePortal.

013. Evaluate the need to missile Complete/Closed

protect primary system makeup The condensate storage tank (CST) (T-2) and T-81 storage tank (T-81) and other

are cross-connected such that upon depletion of the external tanks. .

CST, at approximately 4 hours, the inventory in tank

T-81 can also be gravity fed to the TDAFW pump. To

allow credit for an 8 hour supply, tanks T-2 and T-81

will be missile protected. Following the required

modifications, tanks T-2 and T-81 will be considered

robust against all of the applicable tornado missile

hazards described on Table 2 of RG 1.76, Rev. 1, with

the single exception of tank T-81 foundation mounting

bolts. Tank T-81 would be fully protected against the

design basis tornado missile hazards of a 6-inch

Schedule 40 steel pipe and a 1-inch diameter solid

steel sphere (the exception being anchor bolting for

the automobile missile hazard impact). A white paper

describing the tornado generated missile hazard

evaluation for tank T-81 has been posted to the

ePortal.

This Open Item is also addressed by AQ PAL-044

response.

014. Select the location of FLEX Complete/Closed

equipment storage facility. Refer to OIl. One set of equipment will be stored in a

new structure inside the PA designed for the Seismic

event. An additional set(s) of equipment will be stored

outside the PA in a structure(s) providing an

appropriate level of protection for the tornado event.

Both sets will be protected against other applicable

(screened-in) BDBEE external hazards.

015. Perform seismic evaluation of Complete/Closed

turbine-driven auxiliary feedwater Seismic evaluation documents the seismic

pump (TDAFWP) driver K-8. qualification of the pump and associated components.

The TDAFW pump is qualified with the exception of an

outlier related to a check for bolt tightness. Bolt

tightness on the pump is being performed under WO#

372138 and documented under EC 46465.

Page 4 of 15

Overall Integrated Plan Open Item Status 

012. Develop Phase 3 deployment Started 

strategy with correspondence with Staging areas have been identified. The National the RRC. SAFER Response Center (NSRC) [formerly known as 

the Regional Response Center (RRC)] kickoff meeting 

was conducted on 7/22114 to complete checklist as 

approved by AREVA. The NSRC and Palisades are in 

process of developing Site Response Plans. This 

Open Item is related to I SE Confirmatory Item 3.4.A 

and is addressed on the AQ response spreadsheet on 

the ePortal. 

013. Evaluate the need to missile Complete/Closed 

protect primary system makeup The condensate storage tank (CST) (T-2) and T-81 storage tank (T-81) and other 

external tanks. are cross-connected such that upon depletion of the 

CST, at approximately 4 hours, the inventory in tank 

T-81 can also be gravity fed to the TDAFW pump. To 

allow credit for an 8 hour supply, tanks T-2 and T-81 

will be missile protected. Following the required 

modifications, tanks T -2 and T -81 will be considered 

robust against all of the applicable tornado missile 

hazards described on Table 2 of RG 1.76, Rev. 1, with 

the single exception of tank T-81 foundation mounting 

bolts. Tank T-81 would be fully protected against the 

design basis tornado missile hazards of a 6-inch 

Schedule 40 steel pipe and a 1-inch diameter solid 

steel sphere (the exception being anchor bolting for 

the automobile missile hazard impact). A white paper 

describing the tornado generated missile hazard 

evaluation for tank T-81 has been posted to the 

ePortal. 

This Open Item is also addressed by AQ PAL-044 

response. 

014. Select the location of FLEX Complete/Closed 

equipment storage facility. Refer to 011. One set of equipment will be stored in a 

new structure inside the PA designed for the Seismic 

event. An additional set(s) of equipment will be stored 

outside the PA in a structure(s) providing an 

appropriate level of protection for the tornado event. 

Both sets will be protected against other applicable 

(screened-in) BDBEE external hazards. 

015. Perform seismic evaluation of Complete/Closed 

turbine-driven auxiliary feedwater Seismic evaluation documents the seismic 

pump (TDAFWP) driver K-8. qualification of the pump and associated components. 

The TDAFW pump is qualified with the exception of an 

outlier related to a check for bolt tightness. Bolt 

tightness on the pump is being performed under WO# 

372138 and documented under EC 46465. 

Page 4 of 15 
Overall Integrated Plan Open Item Status

016. Evaluate strategies to extend Complete/Closed

battery coping time. The battery load shedding strategy has been revised

to extend the battery coping time through shedding

loads in addition to those identified in the station

blackout procedure. The results indicate a coping

time of at least 8 hours for the installed batteries

accompanying the expected deep load shed list. This

Open Item is addressed by AQ PAL-01 8 response.

017. Evaluate sources of non- Complete/Closed

borated water in addition to After depletion of T-2 and T-81, makeup to the steam condensate storage tank (T-2) and generators (SG5) will be from a portable pump with T-81. the credited suction source being Lake Michigan.

Modifications to credit sources of non-borated water

for sources other than T-2, T-81 and Lake Michigan

were determined to not be required.

018. Palisades Probabilistic Risk Complete/Closed

Assessment (PRA) to provide Palisades PRA provided multiple evaluations for justification why battery room battery room hydrogen generation. It was determined ventilation is not required until 24 that supplemental ventilation is required approximately hours. 1.5 hours after charging begins for removal of

hydrogen. Ventilation is not required for Phase 2

temperature control. This supplemental ventilation

has been included in the Palisades strategy. This

Open Item is addressed by AQ PAL-025 response.

019. Evaluate the effects of FLEX Started

on security procedures. The security plan/program will be updated to

correspond to FLEX procedures.

0110. Evaluate requirements of Complete/Closed

mobile purification unit from RRC. It was determined that the 500 gpm NSRC water

treatment unit is preferred over the 250 gpm NSRC

reverse osmosis unit in order to support SG makeup

and provide makeup to the NSRC mobile boration

unit. The mobile water treatment unit is only required

to enhance Phase 3 actions post 72 hours.

0111. Evaluate requirements of Complete/Closed

mobile boration unit from RRC. Current strategy is to have adequate borated water

inventory onsite for 72 hours to cope with any BDBEE.

Therefore, the requirements of the mobile boration

unit from NSRC is only required to enhance Phase 3

actions post 72 hours.

0112. Evaluate methods of venting Complete/Closed

the fuel handling building. The strategy for venting the fuel handling building will

be to open an existing double leaf door/hatch on the

roof of the building.

Page 5 of 15

Overall Integrated Plan Open Item Status 

016. Evaluate strategies to extend Complete/Closed 

battery coping time. The battery load shedding strategy has been revised 

to extend the battery coping time through shedding 

loads in addition to those identified in the station 

blackout procedure. The results indicate a coping 

time of at least 8 hours for the installed batteries 

accompanying the expected deep load shed list. This 

Open Item is addressed by AQ PAL-018 response. 

017. Evaluate sources of non- Complete/Closed 

borated water in addition to After depletion of T -2 and T -81, makeup to the steam condensate storage tank (T -2) and generators (SGs) will be from a portable pump with T-81. the credited suction source being Lake Michigan. 

Modifications to credit sources of non-borated water 

for sources other than T-2, T-81 and Lake Michigan 

were determined to not be required. 

018. Palisades Probabilistic Risk Complete/Closed 

Assessment (PRA) to provide Palisades PRA provided multiple evaluations for justification why battery room battery room hydrogen generation. It was determined ventilation is not required until 24 that supplemental ventilation is required approximately hours. 1.5 hours after charging begins for removal of 

hydrogen. Ventilation is not required for Phase 2 

temperature control. This supplemental ventilation 

has been included in the Palisades strategy. This 

Open Item is addressed by AQ PAL-025 response. 

019. Evaluate the effects of FLEX Started 

on security procedures. The security plan/program will be updated to 

correspond to FLEX procedures. 

0110. Evaluate requirements of Complete/Closed 

mobile purification unit from RRC. It was determined that the 500 gpm NSRC water 

treatment unit is preferred over the 250 gpm NSRC 

reverse osmosis unit in order to support SG makeup 

and provide makeup to the NSRC mobile boration 

unit. The mobile water treatment unit is only required 

to enhance Phase 3 actions post 72 hours. 

0111. Evaluate requirements of Complete/Closed 

mobile boration unit from RRC. Current strategy is to have adequate borated water 

inventory onsite for 72 hours to cope with any BDBEE. 

Therefore, the requirements of the mobile boration 

unit from NSRC is only required to enhance Phase 3 

actions post 72 hours. 

0112. Evaluate methods of venting Complete/Closed 

the fuel handling building. The strategy for venting the fuel handling building will 

be to open an existing double leaf door/hatch on the 

roof of the building. 

Page 5 of 15 
Overall Integrated Plan Open Item Status

0113. Evaluate the use of high- Complete/Closed

efficiency LED lighting. The use of high-efficiency LED lighting has been

evaluated for its impact to battery coping time and

control room heat loads. LED lighting would have

minimal impact and is not required or recommended.

0114. Perform evaluation to Complete/Closed

determine if additional parameters In addition to NEI 12-06, PWROG FLEX guidance was will need to be monitored during reviewed for key parameter monitoring. The NEI FLEX activities. 12-06 and PWROG guidance regarding

recommended instrumentation has been incorporated

into the FLEX strategy and the power supply for these

instruments evaluated. All the credited instruments

are powered by battery/DC buses and available

throughout the event.

0115. Perform analysis to ensure Complete/Closed

survivability of containment. Containment analysis has been completed using the

Modular Accident Analysis Program (MAAP). Results

of this analysis show containment design parameters

will not be exceeded for the at-power scenario (i.e.,

event initiating in Mode 1). For the most conservative

shutdown scenario (i.e., Mode 5 reduced inventory),

results of the analysis show that a vent path will be

required to prevent exceeding the design limits of

containment. Containment vent paths that could be

used are the personnel air lock, the emergency air

lock, or the equipment hatch. Procedural controls will

be established using the supplemental guidance

provided in the NRC-endorsed NEI position paper

titled “Shutdown / Refueling Modes.” This Open Item

is addressed by AQ PAL-050 response.

0116. Evaluate borated water Complete/Closed

sources in addition to safety All additional sources of borated water were evaluated injection refueling water tank for use following a BDBEE. This Open Item is ( ). addressed by AQ PAL-048 response.

0117. Entergy, for the Palisades Complete/Closed

site, will negotiate and execute a

contract with Strategic Alliance for

FLEX Emergency Response

(SAFER) that will meet the

requirements of NEI 12-06, Section

12.

Page 6 of 15

Overall Integrated Plan Open Item Status 

0113. Evaluate the use of high- Complete/Closed 

efficiency LED lighting. The use of high-efficiency LED lighting has been 

evaluated for its impact to battery coping time and 

control room heat loads. LED lighting would have 

minimal impact and is not required or recommended. 

0114. Perform evaluation to Complete/Closed 

determine if additional parameters In addition to NEI12-06, PWROG FLEX guidance was will need to be monitored during reviewed for key parameter monitoring. The NEI FLEX activities. 12-06 and PWROG guidance regarding 

recommended instrumentation has been incorporated 

into the FLEX strategy and the power supply for these 

instruments evaluated. All the credited instruments 

are powered by battery/DC buses and available 

throughout the event. 

0115. Perform analysis to ensure Complete/Closed 

survivability of containment. Containment analysis has been completed using the 

Modular Accident Analysis Program (MAAP). Results 

of this analysis show containment design parameters 

will not be exceeded for the at-power scenario (Le., 

event initiating in Mode 1). For the most conservative 

shutdown scenario (Le., Mode 5 reduced inventory), 

results of the analysis show that a vent path will be 

required to prevent exceeding the design limits of 

containment. Containment vent paths that could be 

used are the personnel air lock, the emergency air 

lock, or the equipment hatch. Procedural controls will 

be established using the supplemental guidance 

provided in the NRC-endorsed NEI position paper 

titled "Shutdown / Refueling Modes." This Open Item 

is addressed by AQ PAL-050 response. 

0116. Evaluate borated water Complete/Closed 

sources in addition to safety All additional sources of borated water were evaluated injection refueling water tank for use following a BDBEE. This Open Item is (SIRWT). addressed by AQ PAL-048 response. 

0117. Entergy, for the Palisades Complete/Closed 

site, will negotiate and execute a 

contract with Strategic Alliance for 

FLEX Emergency Response 

(SAFER) that will meet the 

requirements of NEI 12-06, Section 

12. 

Page 6 of 15 
Overall Integrated Plan Open Item Status

0118. Evaluate a location to install a Complete/Closed

tee in the service water system to Several locations in the service water system were allow the ultimate heat sink (UHS) evaluated. A pipe elbow downstream of service water FLEX pump to provide cooling, system (SWS) pump P-7C was identified as the best

location for connecting a pipe tee to allow flow from

the NSRC UHS pump. This Open Item is related to

ISE Confirmatory Item 3.2.4.1 .B and is addressed on

the AQ response spreadsheet on the ePortal.

0119. Evaluate the use of lake water Complete/Closed

to cool the steam generators during An analysis has been completed that determined the

an extended loss of ac power

(ELAP) impacts on the steam generators when using lake

‘ water as the makeup source. The analysis

determined that the heat transfer capability of each

steam generator was diminished by approximately

4.4% after 120 hours. This reduction in heat transfer

capability was determined to be inconsequential due

to the reduced decay heat load by 120 hours into the

event and therefore is acceptable.

0120. Evaluate time until primary Complete/Closed

coolant system (PCS) makeup is An evaluation was performed that documented the

necessary in Modes 5 & 6. time until PCS makeup is required in shutdown

modes. The time when makeup is required varies

greatly depending on the status of the PCS when the

event occurs (i.e., PCS level, pressure, and

temperature). The most limiting scenario was found to

be such that PCS makeup could be required as early

as one hour after the event if the PCS is vented and at

reduced inventory. High risk evolutions such as

vented PCS and reduced inventory will be managed

by outage risk planning and contingency actions such

as pre-staging equipment as discussed in the NEI

position paper titled “Shutdown / Refueling Modes.”

0121. Evaluate connection to ensure Complete/Closed

cooling water can be provided for Cooling water flow to the containment air fans is containment air fans. through the service water system addressed in Cl 18.

Connection of the NSRC supplied FLEX UHS pump to

the SWS will provide the necessary means/connection

for cooling water flow to the containment air coolers.

0122. Evaluate the robustness of Complete/Closed

the charging pumps. The charging pumps have been evaluated as robust

for all applicable external events (seismic, tornado,

high temperature, low temperature and flooding). This

Open Item is addressed by AQ PAL-041 response.

Page 7 of 15

Overall Integrated Plan Open Item Status 

0118. Evaluate a location to install a Complete/Closed 

tee in the service water system to Several locations in the service water system were allow the ultimate heat sink (UHS) evaluated. A pipe elbow downstream of service water FLEX pump to provide cooling. system (SWS) pump P-7C was identified as the best 

location for connecting a pipe tee to allow flow from 

the NSRC UHS pump. This Open Item is related to 

ISE Confirmatory Item 3.2.4.1.8 and is addressed on 

the AQ response spreadsheet on the ePortal. 

0119. Evaluate the use of lake water Complete/Closed 

to cool the steam generators during An analysis has been completed that determined the 

an extended loss of ac power impacts on the steam generators when using lake (ELAP). water as the makeup source. The analysis 

determined that the heat transfer capability of each 

steam generator was diminished by approximately 

4.40/0 after 120 hours. This reduction in heat transfer 

capability was determined to be inconsequential due 

to the reduced decay heat load by 120 hours into the 

event and therefore is acceptable. 

0120. Evaluate time until primary Complete/Closed 

coolant system (PCS) makeup is An evaluation was performed that documented the 

necessary in Modes 5 & 6. time until PCS makeup is required in shutdown 

modes. The time when makeup is required varies 

greatly depending on the status of the PCS when the 

event occurs (i.e., PCS level, pressur~, and 

temperature). The most limiting scenario was found to 

be such that PCS makeup could be required as early 

as one hour after the event if the PCS is vented and at 

reduced inventory. High risk evolutions such as 

vented PCS and reduced inventory will be managed 

by outage risk planning and contingency actions such 

as pre-staging equipment as discussed in the NEI 

position paper titled "Shutdown / Refueling Modes." 

0121. Evaluate connection to ensure Complete/Closed 

cooling water can be provided for Cooling water flow to the containment air fans is containment air fans. through the service water system addressed in 01 18. 

Connection of the NSRC supplied FLEX UHS pump to 

the SWS will provide the necessary means/connection 

for cooling water flow to the containment air coolers. 

0122. Evaluate the robustness of Complete/Closed 

the charging pumps. The charging pumps have been evaluated as robust 

for all applicable external events (seismic, tornado, 

high temperature, low temperature and flooding). This 

Open Item is addressed by AQ PAL-041 response. 

Page 7 of 15 
Interim Staff Evaluation Open Items Status

3.1.1 .2.A Evaluate the impact of potential soil This item is addressed on

liquefaction on deployment of portable FLEX the Audit Question (AQ)

equipment. response spreadsheet on

the ePortal.

3.1.1 .2.B Evaluate the potential need for a power source This item is addressed on

to move or deploy the equipment (e.g., to open the AQ response

the door from a storage location), spreadsheet on the ePortal.

3.1.1 .3.A Evaluate impacts from large internal flooding This item is addressed on

sources that are not seismically robust and the the AQ response

potential impact on the mitigating strategies. spreadsheet on the ePortal.

3.1.1 .3.B Evaluate the potential for ground water to This item is addressed on

impact the mitigating strategies. the AQ response

spreadsheet on the ePortal.

3.1.5.1 .A Evaluate the potential for high temperature This item is addressed on

hazards to impact the functionality of FLEX the AQ response

equipment in the FLEX storage facility, spreadsheet on the ePortal.

3.1 .5.3.A Evaluate the potential for high temperature This item is addressed on

hazards to impact the deployment of FLEX the AQ response

equipment. spreadsheet on the ePortal.

3.2.1 .8.A Verify resolution of the generic concern This item is addressed by

associated with the modeling of the timing and updated AQ PAL-015

uniformity of the mixing of a liquid boric acid response.

solution injected into the PCS under natural

circulation conditions potentially involving twophase flow.

3.2.1 .9.B Provide additional justification for the alternate This item is addressed by

approach to NEI 12-06 involving the use of AQ PAL-041 response.

installed charging pumps.

Interim Staff Evaluation Confirmatory Items Status

3.1.3.1.A Confirm that the FLEX storage facility(s) will meet This item is addressed on

the plant’s design-basis tornado wind speed of 300 the AQ response

mph or will be designed or evaluated equivalent to spreadsheet on the

ASCE 7-10 using a tornado wind speed of 230 ePortal.

mph with separation and diversity between the

storage locations. If the method of protection

chosen is the later, confirm that separation and

diversity is adequate.

3.2.1 .A Confirm that the operator actions times in the first This item is addressed by

20 minutes of the event are adequate and updated AQ PAL-Ol 1

reasonably achievable when the associated ELAP response.

procedures are developed and validated.

Page 8 of 15

Interim Staff Evaluation Open Items Status 

3.1.1.2.A Evaluate the impact of potential soil This item is addressed on 

liquefaction on deployment of portable FLEX the Audit Question (AQ) 

equipment. response spreadsheet on 

the ePortal. 

3.1.1.2.8 Evaluate the potential need for a power source This item is addressed on 

to move or deploy the equipment (e.g., to open the AQ response 

the door from a storage location). spreadsheet on the ePortal. 

3.1.1.3.A Evaluate impacts from large internal flooding This item is addressed on 

sources that are not seismically robust and the the AQ response 

potential impact on the mitigating strategies. spreadsheet on the ePortal. 

3.1.1.3.8 Evaluate the potential for ground water to This item is addressed on 

impact the mitigating strategies. the AQ response 

spreadsheet on the ePortal. 

3.1.5.1.A Evaluate the potential for high temperature This item is addressed on 

hazards to impact the functionality of FLEX the AQ response 

equipment in the FLEX storage faCility. spreadsheet on the ePortal. 

3.1.5.3.A Evaluate the potential for high temperature This item is addressed on 

hazards to impact the deployment of FLEX the AQ response 

equipment. spreadsheet on the ePortal. 

3.2.1.B.A Verify resolution of the generic concern This item is addressed by 

associated with the modeling of the timing and updated AQ PAL-015 

uniformity of the mixing of a liquid boric acid response. 

solution injected into the PCS under natural 

circulation conditions potentially involving twophase flow. 

3.2.1.9.8 Provide additional justification for the alternate This item is addressed by 

approach to NEI 12-06 involving the use of AQ PAL-041 response. 

installed charging pumps. 

Interim Staff Evaluation Confirmatory Items Status 

3.1.3.1.A Confirm that the FLEX storage facility(s) will meet This item is addressed on 

the plant's design-basis tornado wind speed of 300 the AQ response 

mph or will be designed or evaluated equivalent to spreadsheet on the 

ASCE 7-10 using a tornado wind speed of 230 ePortal. 

mph with separation and diversity between the 

storage locations. If the method of protection 

chosen is the later, confirm that separation and 

diversity is adequate. 

3.2.1.A Confirm that the operator actions times in the first This item is addressed by 

20 minutes of the event are adequate and updated AQ PAL-011 

reasonably achievable when the associated ELAP response. 

procedures are developed and validated. 

Page B of 15 
Interim Staff Evaluation Confirmatory Items Status

3.2.1 .B Confirm the robustness of the charging pump This item is addressed by

control circuit or provide FLEX procedure updated AQ PAL-Ol 1

guidance to manually operate the charging pumps response.

by breaker operation.

3.2.1 .C Confirm the seismic robustness of the BAST This item is addressed by

piping to support use of the BAST water as a AQ PAL-047 response.

supply source for the charging pumps.

3.2.1 .D Confirm the availability and adequacy of a borated This item is addressed by

water supply to support the PCS makeup strategy. updated AQ PAL-048

response.

3.2.1 .E Confirm the continued functionality of the This item is addressed by

Atmospheric Dump Valves in the context of a AQ PAL-055 response.

tornado missile hazard during an ELAP in order to

support a sym metric cooldown. Alternatively,

address the effects of asymmetric natural

circulation cooldown.

3.2.1 .F Confirm the ability of any non-safety related This item is addressed by

equipment to function as credited in the mitigation AQ PAL-043 response.

strategies in accordance with the external event

criteria described in NEI-12-06.

3.2.1.1 .A Confirm that the use of Combustion Engineering This item is addressed by

Nuclear Transient Simulator (CENTS) in the ELAP updated AQ PAL-003

analysis is limited to the flow conditions prior to response.

reflux boiling initiation. This confirmation should

include a description of the CENTS- calculated

flow quality at the top of the SG U-tube for the

condition when two-phase natural circulation ends

and reflux boiling initiates.

3.2.1 .2.A Confirm the Primary Coolant Pump (POP) seal This item is addressed by

leakage rate assumed in the ELAP analysis is AQ PAL-004 response.

justified. Specifically, if the POP seal leakage rate

used in the plant-specific analysis is less than he

upper bound expectation for the seal leakage rate

(15 gpm/seal) discussed in the PWROG position

paper addressing the POP seal leakage for

Combustion Engineering plants (ADAMS

Accession No. ML13235A151, non-publicly

available), justification should be provided.

3.2.1 .2.B Confirm whether seal failure will occur or not when This item is addressed by

subcooling of the coolant in the PCS cold-legs is AQ PAL-004 response.

greater than 50 degrees Fahrenheit (°F). This

evaluation should specify the seal leakage flow

assumed for the ELAP from time zero to the

timeframe when subcooling in the POS cold-legs

decreases to 50°F, and provide justification for the

assumed leakage rate.

Page 9 of 15

Interim Staff Evaluation Confirmatory Items Status 

3.2.1.B Confirm the robustness of the charging pump This item is addressed by 

control circuit or provide FLEX procedure updated AQ PAL-011 

guidance to manually operate the charging pumps response. 

by breaker operation. 

3.2.1.C Confirm the seismic robustness of the BAST This item is addressed by 

piping to support use of the BAST water as a AQ PAL-047 response. 

supply source for the charging pumps. 

3.2.1.0 Confirm the availability and adequacy of a borated This item is addressed by 

water supply to support the PCS makeup strategy. updated AQ PAL-048 

response. 

3.2.1.E Confirm the continued functionality of the This item is addressed by 

Atmospheric Dump Valves in the context of a AQ PAL-055 response. 

tornado missile hazard during an ELAP in order to 

support a symmetric cooldown. Alternatively, 

address the effects of asymmetric natural 

circulation cooldown. 

3.2.1.F Confirm the ability of any non-safety related This item is addressed by 

equipment to function as credited in the mitigation AQ PAL-043 response. 

strategies in accordance with the external event 

criteria described in NEI-12-0S. 

3.2.1.1.A Confirm that the use of Combustion Engineering This item is addressed by 

Nuclear Transient Simulator (CENTS) in the ELAP updated AQ PAL-003 

analysis is limited to the flow conditions prior to response. 

reflux boiling initiation. This confirmation should 

include a description of the CENTS- calculated 

flow quality at the top of the SG U-tube for the 

condition when two-phase natural circulation ends 

and reflux boiling initiates. 

3.2.1.2.A Confirm the Primary Coolant Pump (PCP) seal This item is addressed by 

leakage rate assumed in the ELAP analysis is AQ PAL-004 response. 

justified. Specifically, if the PCP seal leakage rate 

used in the plant-specific analysis is less than he 

upper bound expectation for the seal leakage rate 

(15 gpm/seal) discussed in the PWROG position 

paper addressing the PCP seal leakage for 

Combustion Engineering plants (ADAMS 

Accession No. ML 13235A 151, non-publicly 

available), justification should be provided. 

3.2.1.2.B Confirm whether seal failure will occur or not when This item is addressed by 

subcooling of the coolant in the PCS cold-legs is AQ PAL-004 response. 

greater than 50 degrees Fahrenheit (OF). This 

evaluation should specify the seal leakage flow 

assumed for the ELAP from time zero to the 

timeframe when subcooling in the PCS cold-legs 

decreases to 50°F, and provide justification for the 

assumed leakage rate. 

Page 9 of 15 
Interim Staff Evaluation Confirmatory Items Status

3.2.1 .2.C If the Integrated Plan is changed to credit isolation This item is addressed by

of controlled bleed-off (CBO), confirm the AQ PAL-004 response.

assumption that the integrity of the PCP seals can

be maintained, and the seal leakage rate is less

than 1 gpm per PCP during an ELAP before CBO

is isolated. This evaluation should provide the

maximum temperature and pressure and minimum

subcooling of the coolant in the PCS cold- legs

during the ELAP before CBO isolation. If CBO

isolation is being assumed, justify the sequence of

events (SOE) and time constraints so established.

3.2.1 .3.A Confirm the applicability of ANS 5.1-1979 + 2 This item is addressed by

sigma decay heat curve. AQ PAL-012 response.

3.2.1 .5.A Confirm the containment temperature, pressure, This item is addressed by

and moisture profiles during the ELAP event, and AQ PAL-013 response.

justify the adequacy of the computer

codes/methodologies, and assumptions used in

the analysis.

3.2.1 .5.B Confirm whether further instrumentation is needed This item is addressed by

based upon ongoing ELAP evaluations. AQ PAL-013, AQ PAL-027

and AQ PAL-035

responses.

3.2.1.6.A Complete validation of the SQE timeline. This item is addressed by

AQ PAL-030 response.

3.2.1 .6.B In the audit process, the licensee has indicated This item is addressed by

that an assessment has been performed AQ PAL-al 1 response.

identifying potential changes to the SQE. Confirm

that a final SQE has been developed incorporating

any identified changes.

3.2.1 .9.A Confirm that the ability to line up portable pumps is This item is addressed by

consistent with the times assumed in the final updated AQ PAL-014

version of the Integrated Plan. response.

3.2.2.A Resolve the discrepancy between the licensee- This item is addressed on

determined flow rate of 100 gallons per minute the AQ response

(gpm) SFP spray and the 250 gpm performance spreadsheet on the

attribute of NEI 12-06, Table D-3. ePortal.

3.2.3.A Confirm the plan assumptions for containment This item is addressed by

cooling, after completion of the containment AQ PAL-050 and AQ

response analysis. PAL-053 responses.

3.2.4.1 .A Confirm whether supplemental cooling is required This item is addressed on

for components or systems used in the mitigating the AQ response

strategies plan. spreadsheet on the

ePortal.

Page 10 of 15

Interim Staff Evaluation Confirmatory Items Status 

3.2.1.2.C If the Integrated Plan is changed to credit isolation This item is addressed by 

of controlled bleed-off (CBO), confirm the AQ PAL-004 response. 

assumption that the integrity of the PCP seals can 

be maintained, and the seal leakage rate is less 

than 1 gpm per PCP during an ELAP before CBO 

is isolated. This evaluation should provide the 

maximum temperature and pressure and minimum 

subcooling of the coolant in the PCS cold- legs 

during the ELAP before CBO isolation. If CBO 

isolation is being assumed, justify the sequence of 

events (SOE) and time constraints so established. 

3.2.1.3.A Confirm the applicability of ANS 5.1-1979 + 2 This item is addressed by 

sigma decay heat curve. AQ PAL-012 response. 

3.2.1.5.A Confirm the containment temperature, pressure, This item is addressed by 

and moisture profiles during the ELAP event, and AQ PAL-013 response. 

justify the adequacy of the computer 

codes/methodologies, and assumptions used in 

the analysis. 

3.2.1.5.B Confirm whether further instrumentation is needed This item is addressed by 

based upon ongoing ELAP evaluations. AQ PAL-013, AQ PAL-027 

and AQ PAL-035 

responses. 

3.2.1.6.A Complete validation of the SOE timeline. This item is addressed by 

AQ PAL-030 response. 

3.2.1.6.B In the audit process, the licensee has indicated This item is addressed by 

that an assessment has been performed AQ PAL -011 response. 

identifying potential changes to the SOE. Confirm 

that a final SOE has been developed incorporating 

any identified changes. 

3.2.1.9.A Confirm that the ability to line up portable pumps is This item is addressed by 

consistent with the times assumed in the final updated AQ PAL-014 

version of the Integrated Plan. response. 

3.2.2.A Resolve the discrepancy between the licensee- This item is addressed on 

determined flow rate of 100 gallons per minute the AQ response 

(gpm) SFP spray and the 250 gpm performance spreadsheet on the 

attribute of NEI 12-06, Table D-3. ePortal. 

3.2.3.A Confirm the plan assumptions for containment This item is addressed by 

cooling, after completion of the containment AQ PAL-050 and AQ 

response analysis. PAL-053 responses. 

3.2.4.1.A Confirm whether supplemental cooling is required This item is addressed on 

for components or systems used in the mitigating the AQ response 

strategies plan. spreadsheet on the 

ePortal. 

Page 10 of 15 
Interim Staff Evaluation Confirmatory Items Status

3.2.4.1 .B Confirm the connection point for the UHS FLEX This item is addressed on

Pump to the Service Water System. the AQ response

spreadsheet on the

ePortal.

3.2.4.2.A Confirm the adequacy of the ventilation provided This item is addressed by

in the battery room to protect the batteries from AQ PAL-023 response.

the effects of extreme high and low temperatures.

3.2.4.2.B Confirm the adequacy of battery room ventilation This item is addressed by

to prevent hydrogen accumulation while AQ PAL-025 response.

recharging the batteries in Phase 2 or Phase 3.

3.2.4.3.A Confirm whether heat tracing is required for This item is addressed by

borated water systems. AQ PAL-007 response.

3.2.4.4.A Confirm that communication enhancements NRC Confirmatory Action

credited in the NRC’s communication assessment

{ADAMS Accession No. ML13129A219) are

completed as planned.

3.2.4.6.A Confirm that habitability limits will be maintained This item is addressed by

and/or operator protective measures will be updated response on the

employed in all phases of an ELAP to ensure AQ response spreadsheet

operators will be capable of FLEX strategy on the ePortal.

execution under adverse temperature conditions.

3.2.4.7.A Confirm that the evaluation of the CST and T-81 This item is addressed by

shows that the tank qualification is consistent with updated AQ PAL-044

the strategy and the provisions of NEI 12-06. response.

3.2.4.7.B Confirm that the FLEX Support Guidelines provide This item is addressed by

clear criteria for transferring to the next preferred updated AQ PAL-045

source of water when refilling the CST. response.

3.2.4.10.A Confirm that the load shed calculation verifies This item is addressed by

adequate battery capacity with sufficient margin AQ PAL-al 8 and AQ PALthroughout Phase 1 to assure the battery does not 033 responses.

get depleted prior to charging, and the results of

the analysis are properly integrated into the overall

strategy.

3.4.A Confirm that plans for the deployment of portable This item is addressed on

equipment used to implement the response the AQ response

conform to the criteria of NEt 12-06, Section 12.2, spreadsheet on the

with regards to considerations 2 through 10. ePortal.

Audit Completion or Target . Status Question Date

PAL-002 Closed.* Response available on the ePortal.

PAL-003 Updated response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1.1 .A).

Page 11 of 15

Interim Staff Evaluation Confirmatory Items Status 

3.2.4.1.B Confirm the connection point for the UHS FLEX This item is addressed on 

Pump to the Service Water System. the AQ response 

spreadsheet on the 

ePortal. 

3.2.4.2.A Confirm the adequacy of the ventilation provided This item is addressed by 

in the battery room to protect the batteries from AQ PAL-023 response. 

the effects of extreme high and low temperatures. 

3.2.4.2.B Confirm the adequacy of battery room ventilation This item is addressed by 

to prevent hydrogen accumulation while AQ PAL-025 response. 

recharging the batteries in Phase 2 or Phase 3. 

3.2.4.3.A Confirm whether heat tracing is required for This item is addressed by 

borated water systems. AQ PAL-007 response. 

3.2.4.4.A Confirm that communication enhancements NRC Confirmatory Action 

credited in the NRC's communication assessment 

{ADAMS Accession No. ML 13129A219) are 

completed as planned. 

3.2.4.6.A Confirm that habitability limits will be maintained This item is addressed by 

and/or operator protective measures will be updated response on the 

employed in all phases of an ELAP to ensure AQ response spreadsheet 

operators will be capable of FLEX strategy on the ePortal. 

execution under adverse temperature conditions. 

3.2.4.7.A Confirm that the evaluation of the CST and T-81 This item is addressed by 

shows that the tank qualification is consistent with updated AQ PAL -044 

the strategy and the provisions of NEI 12-06. response. 

3.2.4.7.B Confirm that the FLEX Support Guidelines provide This item is addressed by 

clear criteria for transferring to the next preferred updated AQ PAL-045 

source of water when refilling the CST. response. 

3.2.4.10.A Confirm that the load shed calculation verifies This item is addressed by 

adequate battery capacity with sufficient margin AQ PAL-018 and AQ PALthroughout Phase 1 to assure the battery does not 033 responses. 

get depleted prior to charging, and the results of 

the analysis are properly integrated into the overall 

strategy. 

3.4.A Confirm that plans for the deployment of portable This item is addressed on 

equipment used to implement the response the AQ response 

conform to the criteria of NEI 12-06, Section 12.2, spreadsheet on the 

with regards to considerations 2 through 10. ePortal. 

Audit Status Completion or Target 

Question Date 

PAL-002 Closed. * Response available on the ePortal. 

PAL-003 Updated response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.1.A). 

Page 11 of 15 
Audit Completion or Target . Status Question Date

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1 .2.A).

PAL-004

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1 .2.B).

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1 .2.C).

PAL-007

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.4.3.A).

PAL-008 Closed.* Response available on the ePortal.

Updated response available on the ePortal (ISE

Confirmatory Item 3.2.1 .A).

PAL-ol 1 Updated response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1 .B).

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1 .6.B).

PAL-012

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1 .3.A).

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1 .5.A). PAL-Ol 3 Closed.* Response available on the ePortal (ISE

Confirmatory Item 3.2.1.5.B).

PAL-014 Updated Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.1 .9.A).

PAL-015 Updated response available on the ePortal

(associated with ISE Open Item 3.2.1 .8.A).

PAL-016 Updated response available on the ePortal.

PAL-017 In progress -ThisAQ response will be updated Oct 2015 when information is available.

PAL-018

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.4.10.A).

PAL-019 Closed.* Response available on the ePortal.

PAL-020 Closed.* Response available on the ePortal.

PAL-021 Closed.* Response available on the ePortal.

PAL-022 Closed.* Response available on the ePortal.

PAL-023

Closed.* Response available on the ePortal.

(associated with ISE Confirmatory Item 3.2.4.2.A).

PAL-024 Closed.* Response available on the ePortal.

PAL-025

Closed.* Response available on the ePortal

(associated with ISE Confirmatory Item 3.2.4.2.B).

Page 12 of 15

Audit Status Completion or Target 

Question Date 

Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.2.A). 

PAL-004 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.2.8). 

Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.2.C). 

PAL-007 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.4.3.A). 

PAL-008 Closed. * Response available on the ePortal. 

Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.A). 

PAL-011 Updated response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.8). 

Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.6.8). 

PAL-012 Closed.* Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.3.A). 

Closed. * Response available on the ePortal 

PAL-013 (associated with ISE Confirmatory Item 3.2.1.5.A). 

Closed. * Response available on the ePortal (ISE 

Confirmatory Item 3.2.1.5.8). 

PAL-014 Updated Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.9.A). 

PAL-015 Updated response available on the ePortal 

(associated with ISE Open Item 3.2.1.8.A). 

PAL-016 Updated response available on the ePortal. 

PAL-017 In progress - This AQ response will be updated Oct 2015 when information is available. 

PAL-018 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.4.1 O.A). 

PAL-019 Closed. * Response available on the ePortal. 

PAL-020 Closed. * Response available on the ePortal. 

PAL-021 Closed. * Response available on the ePortal. 

PAL-022 Closed. * Response available on the ePortal. 

PAL-023 Closed. * Response available on the ePortal. 

(associated with ISE Confirmatory Item 3.2.4.2.A). 

PAL-024 Closed. * Response available on the ePortal. 

PAL-025 Closed: Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.4.2.8). 

Page 12 of 15 
Audit Completion or Target Status Question Date

PAL-026 Closed.* Response available on the ePortal.

Closed.* Response available on the ePortal PAL-027 (associated with ISE Confirmatory Item 3.2.1 .5.B).

PAL-028 Closed.* Response available on the ePortal.

Closed.* Response available on the ePortal PAL-030 (associated with ISE Confirmatory Item 3.2.1 .6.A).

Closed.* Response available on the ePortal PAL-033 (associated with ISE Confirmatory Item 3.2.4.10.A).

Closed.* Response available on the ePortal PAL-035 (associated with ISE Confirmatory Item 3.2.1 .5.B).

PAL-036 Closed.* Response available on the ePortal.

PAL-037 Closed.* Response available on the ePortal.

PAL-039 Closed.* Response available on the ePortal.

PAL-040 Closed.* Response available on the ePortal.

Closed.* Response available on the ePortal PAL-041 (associated with ISE Open Item 3.2.1.9.B).

Closed.* Response available on the ePortal PAL-043 (associated with ISE Confirmatory Item 3.2.1 .F).

PAL-044 Updated response available on the ePortal

(associated with ISE Confirmatory Item 3.2.4.7.A).

Updated Response available on the ePortal PAL-045 (associated with ISE Confirmatory Item 3.2.4.7.B).

PAL-046 Closed.* Response available on the ePortal.

Closed.* Response available on the ePortal PAL-047 (associated with ISE Confirmatory Item 3.2.1 .C).

Updated response available on the ePortal (ISE PAL-048 Confirmatory Item 3.2.1.D).

PAL-049 Closed.* Response available on the ePortal.

Closed.* Response available on the ePortal PAL-050 (associated with ISE Confirmatory Item 3.2.3.A).

PAL-051 In progress -This AQ response will be updated Oct 2015 when information is available.

Closed.* Response available on the ePortal PAL-053 (associated with ISE Confirmatory Item 3.2.3.A).

PAL-054 Closed.* Response available on the ePortal.

Closed.* Response available on the ePortal PAL-055 (associated with ISE Confirmatory Item 3.2.1 .E).

PAL-056 Closed.* Response available on the ePortal.

Page 13 of 15

Audit Status Completion or Target 

Question Date 

PAL-026 Closed. * Response available on the ePortal. 

PAL-027 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.5.8). 

PAL-028 Closed. * Response available on the ePortal. 

PAL-030 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.6.A). 

PAL-033 Closed.* Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.4.1 O.A). 

PAL-035 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.5.8). 

PAL-036 Closed. * Response available on the ePortal. 

PAL-037 Closed. * Response available on the ePortal. 

PAL-039 Closed. * Response available on the ePortal. 

PAL-040 Closed. * Response available on the ePortal. 

PAL-041 Closed. * Response available on the ePortal 

(associated with ISE Open Item 3.2.1.9.8). 

PAL-043 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.F). 

PAL-044 Updated response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.4.7.A). 

PAL-045 Updated Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.4.7.8). 

PAL-046 Closed. * Response available on the ePortal. 

PAL-047 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.C). 

PAL-048 Updated response available on the ePortal (lSE 

Confirmatory Item 3.2.1.D). 

PAL-049 Closed. * Response available on the ePortal. 

PAL-050 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.3.A). 

PAL-051 In progress - This AQ response will be updated Oct 2015 when information is available. 

PAL-053 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.3.A). 

PAL-054 Closed. * Response available on the ePortal. 

PAL-055 Closed. * Response available on the ePortal 

(associated with ISE Confirmatory Item 3.2.1.E). 

PAL-056 Closed. * Response available on the ePortal. 

Page 13 of 15 
Audit Completion or Target Status I Question Date

PAL-057 Closed. Response available on the ePortal.

* Closed indicates that Entergy’s response is complete.

7 Potential Interim Staff Evaluation Impacts

In addition to the items identified in Section 6, the following item has been identified which

has potential impact to the Interim Staff Evaluation (ISE).

1. ISE TER Section 3.1.1.1, page 6, first paragraph after the numbered list, states, “Two

potential storage areas for FLEX portable equipment have been identified. The

licensee will determine where the storage facility will be located at Palisades and

communicate this information in a future six-month update.”

Structures to provide protection of FLEX equipment are constructed to meet the

requirements of NEI 12-06 Rev. 0 for seismic, flooding, high winds, snow, ice,

extreme cold, and high temperatures. Two structures, one inside the Protected Area

(PA) and one outside the PA are utilized to house all portable FLEX equipment. The

necessity for two locations as stated arose after the soil outside the PA was found to

be liquefiable in a seismic event. Liquefiable soil would likely cause differential

settlements of soil along the deployment path, resulting in roads that could not be

traversed. At the same time, there is minimal area inside the PA to house a building

that could withstand all BDBEE. The solution to this problem is to house FLEX

equipment in two structures that will each withstand a portion of the required BDBEE

such that at least one set of portable FLEX equipment will be available and accessible

for any and all BDBEE. The storage location inside the PA will be a storage container

designed to withstand seismic and seismic-induced seiche BDBEE, while the storage

location outside the PA will be a FLEX Storage Building designed to withstand

external temperature and high wind BDBEE, including tornado generated missiles, as

well as seismic BDBEE for protection of the Phase 3 equipment (step-down

transformer and the temporary cable to connect to Bus 1 D) which will be stored in the

building. The storage strategy for the FLEX equipment is to utilize Sea-Land

containers (FLEX storage container) inside the Protected Area and one hardened

structure (FLEX Storage Building) located near the abandoned security gate, east of

the employee parking lot.

Page 14 of 15

Audit Status Completion or Target 

Question Date 

PAL-057 Closed. * Response available on the ePortal. 

* Closed indicates that Entergy's response is complete. 

7 Potential Interim Staff Evaluation Impacts 

In addition to the items identified in Section 6, the following item has been identified which 

has potential impact to the Interim Staff Evaluation (ISE). 

1. ISE TER Section 3.1.1.1, page 6, first paragraph after the numbered list, states, ''Two 

potential storage areas for FLEX portable equipment have been identified. The 

licensee will determine where the storage facility will be located at Palisades and 

communicate this information in a future six-month update." 

Structures to provide protection of FLEX equipment are constructed to meet the 

requirements of NEI 12-06 Rev. 0 for seismic, flooding, high winds, snow, ice, 

extreme cold, and high temperatures. Two structures, one inside the Protected Area 

(PA) and one outside the PA are utilized to house all portable FLEX equipment. The 

necessity for two locations as stated arose after the soil outside the PA was found to 

be liquefiable in a seismic event. Liquefiable soil would likely cause differential 

settlements of soil along the deployment path, resulting in roads that could not be 

traversed. At the same time, there is minimal area inside the PA to house a building 

that could withstand all BDBEE. The solution to this problem is to house FLEX 

equipment in two structures that will each withstand a portion of the required BDBEE 

such that at least one set of portable FLEX equipment will be available and accessible 

for any and all BDBEE. The storage location inside the PA will be a storage container 

designed to withstand seismic and seismic-induced seiche BDBEE, while the storage 

location outside the PA will be a FLEX Storage Building designed to withstand 

external temperature and high wind BDBEE, including tornado generated missiles, as 

well as seismic BDBEE for protection of the Phase 3 equipment (step-down 

transformer and the temporary cable to connect to Bus 1 D) which will be stored in the 

building. The storage strategy for the FLEX equipment is to utilize Sea-Land 

containers (FLEX storage container) inside the Protected Area and one hardened 

structure (FLEX Storage Building) located near the abandoned security gate, east of 

the employee parking lot. 

Page 14 of 15 
8 References

The following references support the updates to the Overall Integrated Plan described in this

attachment.

1. ENO letter to NRC, PNP 2013-010, Overall Integrated Plan in Response to March 12,

2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation

Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), dated

February 28, 2013 (ADAMS Accession No. ML13246A399)

2. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to

Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated

March 12, 2012 (ADAMS Accession No. ML12054A736).

3. ENO letter to NRC, PNP 2013-064, Palisades Nuclear Plant First Six-Month Status

Report in Response to March 12, 2012 Commission Order Modifying Licenses with

Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External

Events (Order Number EA-12-049), dated August 28, 2013 (ADAMS Accession No.

ML1 3241 A234).

4. ENO letter to NRC, PNP 2014-011, Palisades Nuclear Plant Second Six-Month Status

Report in Response to March 12, 2012 Commission Order Modifying Licenses with

Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External

Events (Order Number EA- 12-049), dated February 28, 2014 (ADAMS Accession No.

ML1 4059A078).

5. NRC letter, Palisades Nuclear Plant — Interim Staff Evaluation Regarding Overall

Integrated Plan in Response to Order EA- 12-049 (Mitigation Strategies) (TAC No.

MFO768), dated February 10, 2014 (ADAMS Accession No.ML1 3365A264)

6. ENO letter to NRC, PNP 2014-085, Palisades Nuclear Plant Third Six-Month Status

Report in Response to March 12, 2012 Commission Order Modifying Licenses with

Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External

Events (Order Number EA- 12-049), dated August 28, 2014 (ADAMS Accession No.

ML1 4240A279)

Page 15 of 15

8 References 

The following references support the updates to the Overall Integrated Plan described in this 

attachment. 

1. ENO letter to NRC, PNP 2013-010, Overall Integrated Plan in Response to March 12, 

2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation 

Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated 

February 28, 2013 (ADAMS Accession No. ML 13246A399) 

2. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated 

March 12,2012 (ADAMS Accession No. ML 12054A736). 

3. ENO letter to NRC, PNP 2013-064, Palisades Nuclear Plant First Six-Month Status 

Report in Response to March 12, 2012 Commission Order Modifying Licenses with 

Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External 

Events (Order Number EA-12-049), dated August 28,2013 (ADAMS Accession No. 

ML 13241 A234). 

4. ENO letter to NRC, PNP 2014-011, Palisades Nuclear Plant Second Six-Month Status 

Report in Response to March 12,2012 Commission Order Modifying Licenses with 

Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External 

Events (Order Number EA-12-049), dated February 28,2014 (ADAMS Accession No. 

ML 14059A078). 

5. NRC letter, Palisades Nuclear Plant -Interim Staff Evaluation Regarding Overall 

Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. 

MF0768), dated February 10, 2014 (ADAMS Accession No.ML 13365A264) 

6. ENO letter to NRC, PNP 2014-085, Palisades Nuclear Plant Third Six-Month Status 

Report in Response to March 12, 2012 Commission Order Modifying Licenses with 

Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External 

Events (Order Number EA-12-049), dated August 28,2014 (ADAMS Accession No. 

ML 14240A279) 

Page 15 of 15