,. Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PNP 2015-062 

August28,2015 

Tel 269 764 2000 

Anthony J. Vitale 

Site Vice President 

u.s. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

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

March 12, 2012 Commission Order Modifying Licenses with Regard to 

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

Palisades Nuclear Plant 

Docket No. 50-255 

License No. DPR-20 

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

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

2012 (ADAMS Accession No. ML 12054A682) 

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

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

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

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

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

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

Accession No. ML 12240A307) 

4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-092, Initial 

Status Report in Response to March 12,2012 Commission Order 

Modifying Licenses with Regard to Reliable Spent Fuel Pool 

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

(ADAMS Accession No. ML 12300A067) 

5. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-009, Overall 

Integrated Plan in Response to March 12,2012 Commission Order 

Modifying License With Regard to Reliable Spent Fuel Pool 

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

(ADAMS Accession No. ML 13060A360) 

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

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

March 12,2012 Commission Order Modifying Licenses with Regard to 

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

dated August 28,2013 (ADAMS Accession No. ML 13241A235) 
PNP 2015-062 

Page 2 of 3 

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

Request for Additional Information Regarding the Overall Integrated 

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

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

(ADAMS Accession No. ML 13312A423) 

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

Palisades Nuclear Plant Second Six-Month Status Report in Response 

to March 12,2012 Commission Order Modifying Licenses with Regard 

to Reliable Spent Fuel Pool Instrumentation (Order Number 

EA-12-0S1), dated February 28,2014 (ADAMS Accession No. 

ML 14059A078) 

9. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2014-084, 

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

March 12,2012 Commission Order Modifying Licenses with Regard to 

Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-0S1), 

dated August 28,2014 (ADAMS Accession No. ML 14240A278) 

10. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2015-005, 

Palisades Nuclear Plant Fourth Six-Month Status Report in Response 

to March 12,2012 Commission Order Modifying Licenses with Regard 

to Reliable Spent Fuel Pool Instrumentation (Order Number 

EA-12-0S1), dated February 27,2015 (ADAMS Accession No. 

ML 15062A056) 

Dear Sir or Madam: 

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

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

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

Palisades Nuclear Plant (PNP). 

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

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

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

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

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

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

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

Reference 5 provided the PNP overall integrated plan. Reference 6 provided the first 

six-month status report. Reference 7 contains a request for additional information regarding 

the overall integrated plan for implementation of Order EA-12-051. References 8,9, and 10 

provide the second, third, and fourth six-month status reports, respectively. 

The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, 

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

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

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

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

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

Reference 7. 
PNP 2015-062 

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 

August 28,2015. 

AJVljse 

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

12,2012 Commission Order Modifying Licenses with Regard to Reliable Spent 

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

cc: Office Director, NRR, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
Attachment 

Palisades Nuclear Plant Fifth Six-Month Status Report in Response 

to March 12, 2012 Commission Order Modifying Licenses with 

Regard to Reliable Spent Fuel Pool Instrumentation 

(Order Number EA-12-051) 

1 Introduction 

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

overall integrated plan (Reference 1 in Section 8), documenting the requirements to install 

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

This attachment provides an update of milestone accomplishments since the last status 

report, including any changes to the compliance method, schedule, or need for 

relief/relaxation and the basis, if any. 

2 Milestone Accomplishments 

The following milestone(s) have been completed since January 31,2015 and are current as 

of July 31,2015. 

• Fourth Six-Month Status Report - February 2015 

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

2015. 

• Response to NRC Interim Staff Evaluation (ISE) Request for Additional Information 

(received November 26, 2013) - February 2015. 

3 Milestone Schedule Status 

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

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

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

and implementation details are developed. 

Target Completion Activity Revised Target 

Milestone Datet Status Completion 

Date 

Reliable SFPI Installed Fall 2015 Refueling In Progress N/A 

Outa9_e 

Response to NRC Request Submitted for Additional Information 

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

(Reference 3) 2013 

Page 1 of 4 
Response to NRC ISE Submitted Request for Additional March 31, 2015 February 27, Information (received 2015 N/A 

November 26, 2013) 

T' Target Completion Date IS the last submitted date from either the overall mtegrated plan or 

previous six-month update. 

4 Changes to Compliance Method 

There are no additional changes to the compliance method. 

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

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

at this time. 

6 Open Items from Overall Integrated Plan and Interim Staff 

Evaluation 

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

Additional Information (RAls). There were 3 additional RAls received prior to the June 2015 

Audit Visit (Reference 0), for a total of 21 RAls. The following table provides the status of 

these RAls. 

RAI # Response Status 

1 This item was closed during the 

June 2015 NRC Audit Visit. 

2 This item was closed during the 

June 2015 NRC Audit Visit. 

3 This item was closed during the 

June 2015 NRC Audit Visit. 

4 This item was closed during the 

June 2015 NRC Audit Visit. 

5 This item was closed during the 

June 2015 NRC Audit Visit. 

6 This item was closed during the 

June 2015 NRC Audit Visit. 

7 This item was closed during the 

June 2015 NRC Audit Visit. 

8 This item was closed during the 

June 2015 NRC Audit Visit. 

9 This item was closed during the 

June 2015 NRC Audit Visit. 

10 This item was closed during the 

June 2015 NRC Audit Visit. 

11 This item was closed during the 

June 2015 NRC Audit Visit. 

12 This item was closed during the 

June 2015 NRC Audit Visit. 

Page 2 of 4 
13 This item was closed during the 

June 2015 NRC Audit Visit. 

14 This item was closed during the 

June 2015 NRC Audit Visit. 

15 This item was closed during the 

June 2015 NRC Audit Visit. 

16 This item was closed during the 

June 2015 NRC Audit Visit. 

17 This item was closed during the 

June 2015 NRC Audit Visit. 

18 This item was closed during the 

June 2015 NRC Audit Visit. 

19 (New) This item was closed during the 

June 2015 NRC Audit Visit. 

20 (New) This item was closed during the 

June 2015 NRC Audit Visit. 

21 (New) See Section 9 

7 Potential Interim Staff Evaluation Impacts 

There are no potential impacts to the ISE identified at this time. 

8 References 

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

attachment. 

1. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-009, Overall Integrated Plan 

in Response to March 12,2012 Commission Order Modifying License With Regard to 

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

28, 2013 (ADAMS Accession No. ML 13060A360) 

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

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

ML 12054A682) 

3. NRC email to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant- Requests for 

Additional Information Regarding OveraJllntegrated Plan for Reliable Spent Fuel Pool 

Instrumentation (TAC MF0769), dated July 18, 2013 (ADAMS Accession No. 

ML 13200A328) 

4. NRC letter to Entergy Nuclear Operations, Inc., Palisades -Interim Staff Evaluation and 

Request for Additional Information Regarding the OveraJllntegrated Plan for 

Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC 

NO. MF0769), dated November 26, 2013 (ADAMS Accession No. ML 13312A423) 

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

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

2013 (ADAMS Accession No. ML 133478030). 

6. NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant - Plan for the 

Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel 

Page 3 of 4 
Instrumentation Related To Orders EA-12-049 and EA-12-051 (TAG Numbers MF0768 

and MF0769), dated April 22, 2015 (ADAMS Accession No. ML 15110A051) 

9 Responses to Open Requests for Additional Information 

RAI#21 

Please describe the impact of recent MOHR's SFPI equipment failures (failure of the filter coil 

(or choke) in particular) on the Palisades' SFP level instrument. Also, any actions/measures 

Waterford [sic] plans to implement to address this equipment failure. 

Note: RAI #21 was issued prior to the NRC June 2015 Audit Visit (Reference O) and is still 

open. This is a generic issue for all plants with MOHR instrumentation. The NRC has 

requested additional information from MOHR concerning qualification of the proposed 

circuitry changes. A response was provided during the audit and has been updated below to 

reflect the current status. 

ENO Response: 

The vendor MOHR determined that the source of the failures is a miniature surface mount 

common-mode choke component used on the Video and Digicomp printed circuit boards 

within the EFP-IL Signal Processor. Per MOHR's recommendation, the two boards have 

been replaced in both EFP-IL Signal Processors at Palisades. Corrective actions were 

performed under condition report CR-HQN-2015-0345 to replace each of the two circuit 

boards within the two EFP-IL Signal Processors at the site. They are Corrective Action 10 for 

U-2141 (Spent Fuel Pool Level Indication) and Corrective Action 11 for U-2142 (Spent Fuel 

Pool Level Indication). The new boards have equivalent substitute components that are less 

susceptible to transient electrical events. The substitute components have equivalent size, 

mass, and solder attachment technique as the original component such that there is no 

impact to the system mechanical characteristics. The components demonstrate equivalent 

electrical performance such that EMC characteristics are not significantly changed. 

MOHR has provided Palisades with a copy of their Root Cause Analysis Report, Revision 1, 

dated 6/1/2015. 

In the event one or both channels become non-functioning at any pOint in the future, 

compensatory actions will be applied under the plant's Operating Requirements Manual. 

Page 4 of 4