Entergy Nuclear Operations, Inc.

J?w-i #,ipcr, Palisades Nuclear Plant

Lii 27780 Blue Star Memorial Highway

Covert, Ml 49043-9530

Tel 269 764 2000

Anthony J. Vitale

PNP 2015-005 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

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. ML12054A682)

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

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

dated August 29, 2012 (ADAMS Accession No. ML12221A339)

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

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

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

Accession No. ML1 2240A307)

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. ML1 2300A067)

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. ML1 3060A360)

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

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

March 12, 2012 Commission Order Modifying Licenses with Regard to

Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-05 1),

dated August 28, 2013 (ADAMS Accession No. ML13241A235)

• Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PNP 2015-005 

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 

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

Palisades Nuclear Plant 

Docket No. 50-255 

License No. DPR-20 

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

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

2012 (ADAMS Accession No. ML 12054A682) 

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

EA-12-0S1, Reliable Spent Fuel Pool Instrumentation, Revision 0, 

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

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

EA-12-0S1, '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-12-0S1), dated October 25, 2012 

(ADAMS Accession No. ML 12300A067) 

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

Integrated Plan in Response to March 12,2012 Commission Order 

Modifying License With Regard to Reliable Spent Fuel Pool 

Instrumentation (Order Number EA-12-0S1), dated February 28, 2013 

(ADAMS Accession No. ML 13060A360) 

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

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

March 12, 2012 Commission Order Modifying Licenses with Regard to 

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

dated August 28, 2013 (ADAMS Accession No. ML 13241 A235) 
PNP 2015-005

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. ML13312A423)

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

Palisades Nuclear Plant Second Six-Month Status Report in Response

to March 12, 2012 Commission Order Modifying Licenses with Regard

to Reliable Spent Fuel Pool Instrumentation (Order Number

EA-12-051), dated February 28, 2014 (ADAMS Accession No.

ML1 4059A078)

9. Entergy Nuclear Operations, Inc. letter to NRC, PNP 201 4-084,

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- 12-05 1),

dated August 28, 2014 (ADAMS Accession No. ML14240A278)

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. Reference 8 provided the

second six-month status report and Reference 9 provided the third six-month status report.

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 attached report provides an update of milestone

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

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

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

Reference 7.

This letter contains no new commitments and no revised commitments.

PNP 201S-00S 

Page 2 of 3 

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

Request for Additional Information Regarding the Overall Integrated 

Plan for I mplementation of Order EA-12-0S1, Reliable Spent Fuel Pool 

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

(ADAMS Accession No. ML 13312A423) 

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

Palisades Nuclear Plant Second Six-Month Status Report in Response 

to March 12, 2012 Commission Order Modifying Licenses with Regard 

to Reliable Spent Fuel Pool Instrumentation (Order Number 

EA-12-051), dated February 28,2014 (ADAMS Accession No. 

ML 140S9A078) 

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-12-051), 

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

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 

N EI 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 S 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-12-0S1. Reference 8 provided the 

second six-month status report and Reference 9 provided the third six-month status report. 

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 attached report provides an update of milestone 

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

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

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

Reference 7. 

This letter contains no new commitments and no revised commitments. 
PNP 2015-005

Page 3 of 3

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

February 27, 2015.

Sincerely,

.t

ajv/jse /

Attachment: 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-12-051)

cc: Office Director, NRR, USNRC

Administrator, Region Ill, USNRC

Project Manager, Palisades, USNRC

Resident Inspector, Palisades, USN RC

PNP 2015-005 

Page 3 of 3 

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 

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 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-12-051)

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 July 31, 2014 and are current as of

January 31, 2015.

• Third Six-Month Status Report — August 2014

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

February 2015.

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

(received November 26, 2013) — Complete with submission of this document in

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.

Revised Target Target Completion Activity Milestone Completion Datet Status Date

Reliable SFPI Installed Fall 2015 Refueling In Progress N/A

Outage

Response to NRC Request Submitted for Additional Information August 19, 2013 August 19, (received July 18, 2013) N/A 2013 (Reference 3)

1 of 24

Attachment 

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-12-051) 

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 July 31,2014 and are current as of 

January 31,2015. 

• Third Six-Month Status Report - August 2014 

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

February 2015. 

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

(received November 26, 2013) - Complete with submission of this document in 

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 SFPllnstalled Fall 2015 Refueling In Progress N/A 

Outage 

Response to NRC Request 

Submitted for Additional Information 

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

(Reference 3) 2013 

1 of 24 
TTarget Completion Date is the last submitted date from either

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 (RAIs). Responses to the RAls are due by March 31, 2015 and are

discussed in Section 9 of this six-month status report. The following table provides a status

of any RAIs documented in the Interim Staff Evaluation.

RAI # Response Status

1 See Section 9

2 See Section 9

3 See Section 9

4 See Section 9

5 See Section 9

6 See Section 9

7 See Section 9

8 See Section 9

9 See Section 9

10 See Section 9

1 1 See Section 9

12 See Section 9

13 See Section 9

14 See Section 9

15 See Section 9

16 See Section 9

17 See Section 9

18 See Section 9

Response to NRC ISE

Request for Additional Submitted

Information (received March 31, 2015 February 27,

November26,2013) 2015 N/A

the overall integrated plan or

2 of 24

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 Integrated 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). Responses to the RAls are due by March 31,2015 and are 

discussed in Section 9 of this six-month status report. The following table provides a status 

of any RAls documented in the Interim Staff Evaluation. 

RAJ # Response Status 

1 See Section 9 

2 See Section 9 

3 See Section 9 

4 See Section 9 

5 See Section 9 

6 See Section 9 

7 See Section 9 

8 See Section 9 

9 See Section 9 

10 See Section 9 

11 See Section 9 

12 See Section 9 

13 See Section 9 

14 See Section 9 

15 See Section 9 

16 See Section 9 

17 See Section 9 

18 See Section 9 

2 of 24 
7 Potential Interim Staff Evaluation Impacts

There are no potential impacts to the ISE identified at this time except for those identified in

Section 6.

8 References

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

attachment.

1. ENO letter to NRC, PNP 2013-009, Overall Integrated Plan in Response to March 12,

2012 Commission Order Modifying License With Regard to Reliable Spent Fuel Pool

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

Accession No. ML1 3060A360)

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

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

ML1 2054A682)

3. NRC email to ENO, Palisades Nuclear Plant — Requests for Additional Information

Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (TAC

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

4. NRC letter to ENO, Palisades — Interim Staff Evaluation and Request for Additional

Information Regarding the Overall Integrated Plan for Implementation of Order

EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NO. MFO769), dated

November 26, 2013 (ADAMS Accession No. ML1 331 2A423)

5. Summary of the November26, 2013, Public Meeting to Discuss Industry Responses to

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

2013 (ML13347B030)

3 of 24

7 Potential Interim Staff Evaluation Impacts 

There are no potential impacts to the ISE identified at this time except for those identified in 

Section 6. 

8 References 

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

attachment. 

1. ENO letter to NRC, PNP 2013-009, Overall Integrated Plan in Response to March 12, 

2012 Commission Order Modifying License With Regard to Reliable Spent Fuel Pool 

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

Accession No. ML 13060A360) 

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

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

ML 12054A682) 

3. NRC email to ENO, Palisades Nuclear Plant - Requests for Additional Information 

Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (T AC 

MF0769), dated July 18, 2013 (ADAMS Accession No. ML 13200A328) 

4. NRC letter to ENO, Palisades -Interim Staff Evaluation and Request for Additional 

Information Regarding the Overall Integrated Plan for Implementation of Order 

EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NO. MF0769), dated 

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

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

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

2013 (ML 133478030) 

3 of 24 
9 Responses to the Interim Staff Evaluation Requests for

Additional Information

RAI#1

Given the potential for varied dose rates from other materials stored in the SFP, please

describe how level 2 will be adjusted to other than the elevation provided in section 2 above.

ENO Response:

The response to this RAI was provided in the 3rd Six-Month Status Report (Reference 1).

RAI #2

Please provide the analyses verifying the seismic capability of the level probes, the mounting

brackets, and the electronics units, and provide the results of the analysis of the combined

maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly

exposed to the potential sloshing effects. Show that the SFP instrument design configuration

will be maintained during and following the maximum seismic ground motion considered in

the design of the SFP structure.

ENO Response:

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

See bridging document Topics #8, 9, & 12 (Section 10 of this status report).

RAI #3

For each of the mounting attachments required to attach SFP Level equipment to plant

structures, please describe the design inputs, and the methodology that will be used to

qualify the structural integrity of the affected structures/equipment.

ENO Response:

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

See bridging document Topics #8, 9, 12, & 13 (Section 10 of this status report).

RAI #4

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

the fixed instrument location(s).

4 of 24

9 Responses to the Interim Staff Evaluation Requests for 

Additional Information 

RAI#1 

Given the potential for varied dose rates from other materials stored in the SFP, please 

describe how level 2 will be adjusted to other than the elevation provided in section 2 above. 

ENO Response: 

The response to this RAI was provided in the 3rd Six-Month Status Report (Reference 1). 

RAI#2 

Please provide the analyses verifying the seismic capability of the level probes, the mounting 

brackets, and the electronics units, and provide the results of the analysis of the combined 

maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly 

exposed to the potential sloshing effects. Show that the SFP instrument design configuration 

will be maintained during and following the maximum seismic ground motion considered in 

the design of the SFP structure. 

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

See bridging document Topics #8,9, & 12 (Section 10 of this status report). 

RAI#3 

For each of the mounting attachments required to attach SFP Level equipment to plant 

structures, please describe the design inputs, and the methodology that will be used to 

qualify the structural integrity of the affected structures/equipment. 

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

See bridging document Topics #8, 9, 12, & 13 (Section 10 of this status report). 

RAI#4 

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

the fixed instrument location(s). 

4 of 24 
ENO Response:

The response to this RAI was provided in the 3rd Six-Month Status Report (Reference 1).

RAI#5

Please provide analysis of the maximum expected radiological conditions (dose rate and total

integrated dose) to which the sensor electronics will be exposed. Also, please provide

documentation indicating the radiological dosage the electronics for this equipment are

capable of withstanding. Please discuss the time period over which the analyzed total

integrated dose is evaluated to be applied.

ENO Response:

The immediately following replaces what was provided in the 3rd Six-Month Status Report

(Reference 1).

See bridging document Topic #3 (Section 10 of this status report).

RAI#6

Please provide information indicating the maximum expected ambient temperature in the

room in which the sensor electronics will be located under BDB conditions with no ac power

available to run Heating Ventilation and Air Conditioning (HVAC) systems, and whether the

sensor electronics are capable of continuously performing required functions under this

expected temperature condition.

ENO Response:

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

See bridging document Topic #3 (Section 10 of this status report).

RAI#7

Please provide information indicating the maximum expected relative humidity in the room in

which the sensor electronics will be located under 8DB conditions, with no ac power available

to run HVAC systems, and whether the sensor electronics are capable of continuously

performing required functions under this expected humidity condition.

5 of 24

ENO Response: 

The response to this RAI was provided in the 3rd Six-Month Status Report (Reference 1). 

RAI#5 

Please provide analysis of the maximum expected radiological conditions (dose rate and total 

integrated dose) to which the sensor electronics will be exposed. Also, please provide 

documentation indicating the radiological dosage the electronics for this equipment are 

capable of withstanding. Please discuss the time period over which the analyzed total 

integrated dose is evaluated to be applied. 

ENO Response: 

The immediately following replaces what was provided in the 3rd Six-Month Status Report 

(Reference 1). 

See bridging document Topic #3 (Section 10 of this status report). 

RAI#6 

Please provide information indicating the maximum expected ambient temperature in the 

room in which the sensor electronics will be located under BOB conditions with no ac power 

available to run Heating Ventilation and Air Conditioning (HVAC) systems, and whether the 

sensor electronics are capable of continuously performing required functions under this 

expected temperature condition. 

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

See bridging document Topic #3 (Section 10 of this status report). 

RAI#7 

Please provide information indicating the maximum expected relative humidity in the room in 

which the sensor electronics will be located under BOB conditions, with no ac power available 

to run HVAC systems, and whether the sensor electronics are capable of continuously 

performing required functions under this expected humidity condition. 

5 of 24 
ENO Response:

The immediately following was updated since the 3 Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

See bridging document Topic #3 (Section 10 of this status report).

RAI #8

Please provide a description of the specific method or combination of methods that will be

used to demonstrate the reliability of the permanently installed equipment under BDB shock

and vibration conditions. Identify the specific commercial and/or military standards that will be

used to establish the testing requirements, and the specific acceleration levels and

frequencies that will be simulated.

ENO Response:

The immediately following was updated since the 3 Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MQHR)

Reference 2).

See bridging document Topic #14 (Section 10 of this status report).

RAI #9

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

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

with the Order requirements.

ENO Response:

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

See bridging document Topic #14 (Section 10 of this status report).

RAI#1O

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

the instrument performance reliability, following exposure to simulated seismic conditions

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

adequately demonstrated.

6 of 24

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

See bridging document Topic #3 (Section 10 of this status report). 

RAI#S 

Please provide a description of the specific method or combination of methods that will be 

used to demonstrate the reliability of the permanently installed equipment under BOB shock 

and vibration conditions. Identify the specific commercial and/or military standards that will be 

used to establish the testing requirements, and the specific acceleration levels and 

frequencies that will be simulated. 

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

Reference 2). 

See bridging document Topic #14 (Section 10 of this status report). 

RAI#9 

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

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

with the Order requirements. 

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

See bridging document Topic #14 (Section 10 of this status report). 

RAI#10 

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

the instrument performance reliability, following exposure to simulated seismic conditions 

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

adequately demonstrated. 

6 of 24 
ENO Response:

The immediately following was updated since the 3 Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

See bridging document Topic #8 (Section 10 of this status report).

RAI#11

Please provide the NRC staff with the final configuration of the power supply source for each

channel so the staff may conclude the two channels are independent from a power supply

assignment perspective.

ENO Response:

The response to this RAI was provided in the 3rd Six-Month Status Report (Reference 1).

RAI#12

Please provide the results of the calculation depicting the battery backup duty cycle

requirements demonstrating battery capacity is sufficient to maintain the level indication

function until offsite resource availability is reasonably assured.

ENO Response:

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

See bridging document Topic #18 (Section 10 of this status report).

RAI#13

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

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

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

restoration of power.

ENO Response:

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

See bridging document Topics #16, 17 & 18 (Section 10 of this status report).

7 of 24

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

See bridging document Topic #8 (Section 10 of this status report). 

RAI#11 

Please provide the NRC staff with the final configuration of the power supply source for each 

channel so the staff may conclude the two channels are independent from a power supply 

assignment perspective. 

ENO Response: 

The response to this RAI was provided in the 3rd Six-Month Status Report (Reference 1). 

RAI#12 

Please provide the results of the calculation depicting the battery backup duty cycle 

requirements demonstrating battery capacity is sufficient to maintain the level indication 

function until off site resource availability is reasonably assured. 

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

See bridging document Topic #18 (Section 10 of this status report). 

RAI#13 

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

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

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

restoration of power. 

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

See bridging document Topics #16, 17 & 18 (Section 10 of this status report). 

7 of 24 
RAI#14

Please provide a description of the methodology that will be used for determining the

maximum allowed deviation from the instrument channel design accuracy to be employed

under normal operating conditions as an acceptance criterion for a callbration procedure to

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

ENO Response:

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

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

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

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

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

bridging document Topics #20 (Section 10).

RAI#15

Please provide a description of the in-situ calibration process at the SFP location that will

result in the channel callbration being maintained at its design accuracy.

ENO Response:

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1)

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

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

recommendations and ENO process and procedures. The instrument automatically monitors

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

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

threshold prompts operator intervention. See bridging document Topic #20 (Section 10).

8 of 24

RAI#14 

Please provide a description of the methodology that will be used for determining the 

maximum allowed deviation from the instrument channel design accuracy to be employed 

under normal operating conditions as an acceptance criterion for a calibration procedure to 

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

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

I n general relative to normal operating conditions, any applicable calibration procedure 

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

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

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

bridging document Topics #20 (Section 10). 

RAI #15 

Please provide a description of the in-situ calibration process at the SFP location that will 

result in the channel calibration being maintained at its design accuracy. 

ENO Response: 

The immediately following was updated since the 3rd Six-Month Status Report (Reference 1) 

to include changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

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

recommendations and ENO process and procedures. The instrument automatically monitors 

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

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

threshold prompts operator intervention. See bridging document Topic #20 (Section 10). 

8 of 24 
RAI#16

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

please describe the evaluation used to validate the display location can be accessed without

unreasonable delay following a BDB event. Include the time available for personnel to access

the display as credited in the evaluation, as well as the actual time (e.g., based on walk

throughs) that it will take for personnel to access the backup display. Additionally, please

include a description of the radiological and environmental conditions on the paths personnel

might take. Describe whether the display location remains habitable for radiological, heat and

humidity, and other environmental conditions following a BDB event. Describe whether

personnel are continuously stationed at the backup display or monitor the display periodically.

ENO Response:

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

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

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

Stairwell 16 and Corridor 1 06A can be approached from the north, east, and west via Corridor

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

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

(Section 3.1 of NEI 12-02).

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

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

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

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

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

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

technologies for response personnel.

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

be included in a future six month status report.

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

9 of 24

RAI#16 

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

please describe the evaluation used to validate the display location can be accessed without 

unreasonable delay following a BOB event. Include the time available for personnel to access 

the display as credited in the evaluation, as well as the actual time (e.g., based on walkthroughs) that it will take for personnel to access the backup display. Additionally, please 

include a description of the radiological and environmental conditions on the paths personnel 

might take. Describe whether the display location remains habitable for radiological, heat and 

humidity, and other environmental conditions following a BOB event. Describe whether 

personnel are continuously stationed at the backup display or monitor the display periodically. 

ENO Response: 

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

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

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

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

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

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

(Section 3.1 of NEI 12-02). 

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

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

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

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

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

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

technologies for response personnel. 

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

be included in a future six month status report. 

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

9 of 24 
RAI#17

Please provide a list of the procedures addressing operation (both normal and abnormal

response), calibration, test, maintenance, and inspection that will be developed for use of the

SFP instrumentation. The licensee is requested to include a brief description of the specific

technical objectives to be achieved within each procedure.

ENO Response:

The following was updated since the 3 Six-Month Status Report (Reference 1) to include

changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

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

manuals developed by MOHR. See bridging document Topics #10, 19, & 20 (Section 10 of

this status report). The objectives are to measure system performance, determine if there is

a deviation from normal tolerances, and return the system to normal tolerances.

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

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

parameters such as battery voltage, 4-20 mA loop continuity, and Time Domain

Reflectometry (TDR) waveform of the transmission cable. The technical objective of the

diagnostic procedures is to identify system conditions that require operator attention to

ensure continued reliable liquid level measurement. Manual diagnostic procedures are also

provided in the event that further workup is determined to be necessary.

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

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

is maintained.

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

system.

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

MOHR and ENO procedures and processes.

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

beyond design basis external event.

10 of 24

RAI#17 

Please provide a list of the procedures addressing operation (both normal and abnormal 

response), calibration, test, maintenance, and inspection that will be developed for use of the 

SFP instrumentation. The licensee is requested to include a brief description of the specific 

technical objectives to be achieved within each procedure. 

ENO Response: 

The following was updated since the 3rd Six-Month Status Report (Reference 1) to include 

changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

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

manuals developed by MOHR. See bridging document Topics #10,19, & 20 (Section 10 of 

this status report). The objectives are to measure system performance, determine if there is 

a deviation from normal tolerances, and return the system to normal tolerances. 

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

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

parameters such as battery voltage, 4-20 mA loop continuity, and Time Domain 

Reflectometry (TOR) waveform of the transmission cable. The technical objective of the 

diagnostic procedures is to identify system conditions that require operator attention to 

ensure continued reliable liquid level measurement. Manual diagnostic procedures are also 

provided in the event that further workup is determined to be necessary. 

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

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

is maintained. 

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

system. 

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

MOHR and ENO procedures and processes. 

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

beyond design basis external event. 

10 of 24 
RAI#18

Please provide further information describing the maintenance and testing program the

licensee will establish and implement to ensure that regular testing and calibration is

performed and verified by inspection and audit to demonstrate conformance with design and

system readiness requirements. Include a description of your plans for ensuring that

necessary channel checks, functional tests, periodic calibration, and maintenance will be

conducted for the level measurement system and its supporting equipment.

ENO Response:

The following was updated since the 3td Six-Month Status Report (Reference 1) to include

changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR)

(Reference 2).

SFPI channel/equipment maintenance/preventative maintenance and testing program

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

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

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

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

Topics #10 and 20 (Section 10).

RAI Response References

1. 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-12-051), dated August 28, 2014 (ADAMS Accession No.

ML1 4240A278)

2. NRC letter, Donald C. Cook Nuclear Plant, Units 1 and 2— Report for the Onsite Audit

of MOHR Regarding Implementation of Reliable Spent Fuel Pool Instrumentation

Related to Order EA-12-051 (TAC Nos. MFO761 AND MFO762), dated August 27,

2014 (ADAMS Accession No. ML14216A362)

11 of 24

RAI#18 

Please provide further information describing the maintenance and testing program the 

licensee will establish and implement to ensure that regular testing and calibration is 

performed and verified by inspection and audit to demonstrate conformance with design and 

system readiness requirements. Include a description of your plans for ensuring that 

necessary channel checks, functional tests, periodic calibration, and maintenance will be 

conducted for the level measurement system and its supporting equipment. 

ENO Response: 

The following was updated since the 3rd Six-Month Status Report (Reference 1) to include 

changes based on issuance of the NRC Audit Report for the SFPI vendor (MOHR) 

(Reference 2). 

SFPI channel/equipment maintenance/preventative maintenance and testing program 

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

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

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

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

Topics #10 and 20 (Section 10). 

RAI Response References 

1. 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-12-051), dated August 28,2014 (ADAMS Accession No. 

ML 14240A278) 

2. NRC letter, Donald C. Cook Nuclear Plant, Units 1 and 2 - Report for the Onsite Audit 

of MOHR Regarding Implementation of Reliable Spent Fuel Pool Instrumentation 

Related to Order EA-12-051 (TAC Nos. MF0761 AND MF0762), dated August 27, 

2014 (ADAMS Accession No. ML 14216A362) 

11 of 24 
10 PNP Bridging Document Between Vendor Technical Information and Licensee

Implementation Based on NRC Staff Requests for Additional Information (RAI) and NR

# Topic Parameter Vendor Additional Test or Licensee Evaluation

Summary Reference Comment Analysis

Document Results

#

Design SFPI References Evaluation of the vendor in

Specification Requirements 4-13, 17- scope of EC 46466.

derived from 19, 28, 34,

References 1, & 38

2, & 3

2 Test Strategy Per References The equipment testing per

Requirements 4, 6-13, 17- been found to be acceptab

in References 19, 28, 34, design requirements.

1,2,&3 &38

3 Environmental 50-121°F Reference 14-131°F The display/processors wil

Qualification for (References 1, 4 Control Room and C-40 Pa

Electronics 2, 14, & 16) EA-EC46465-03 (Referenc

Enclosure with the maximum temperature 

Display be 121°F. The operating t

Panel Room is 50-110°F (R

vendor, MOHR, has succes

electronics to a nominal tem

to 131°F. The sensor eleccontinuously performing its 

the expected temperature 

the vendor testing are avai

MOHR Report 1-0410-1 R

“MOHR EFP-IL SFPI Syste

Humidity Report.”

5-95% RH Reference 5-95% RH The SFPI vendor, MOHR, 

4 its system electronics to op

range of 5% to 95% relativ

12 of 24

10 PNP Bridging Document Between Vendor Technical Information and Licensee 

Implementation Based on NRC Staff Requests for Additional Information (RAI) and NR

# Topic Parameter Vendor Additional Test or Licensee Evaluation 

Summary Reference Comment Analysis 

Document Results 

# 

1 Design SFPI References Evaluation of the vendor in

Specification Requirements 4-13,17- scope of EC 46466. 

derived from 19,28,34, 

References 1, &38 

2, &3 

2 Test Strategy Per References The equipment testing per

Requirements 4,6-13, 17- been found to be acceptab

in References 19,28,34, design requirements. 

1,2, &3 &38 

3 Environmental 50-121°F Reference 14-131°F The display/processors wil

Qualification for (References 1, 4 Control Room and C-40 Pa

Electronics 2,14, & 16) EA-EC46465-03 (Referenc

Enclosure with the maximum temperature 

Display be 121 of. The operating t

Panel Room is 50-110°F (

vendor, MOHR, has succe

electronics to a nominal te

to 131 of. The sensor elec

continuously performing its 

the expected temperature 

the vendor testing are ava

MOHR Report 1-0410-1 R

"MOHR EFP-IL SFPI Syste

Humidity ReQort." 

5-950/0 RH Reference 5-950/0 RH The SFPI vendor, MOHR, 

4 its system electronics to op

--

range of 5% to 95% relativ

12 of 24 
the vendor testing are avai

MOHR Report 1-0410-1 R

SFPI System Temperature 

(Reference 4).”

Humidity in the Control Ro

Room are normally regulat

at 50% (Reference 43). Du

AC power, the HVAC syste

Assuming the Control Roo

remain isolated from outsid

expected to increase and t

to decrease because the h

by the sensible heat of elec

Therefore, the maximum te

the Control Room (Referen

C-40 Panel Room (Referen

below 50% is bounded by percent RH test case prese

1-0410-1 (Reference 4).

In the event outside air is i

Room or C-40 Panel Room

HVAC system connections 

ASH RAE (Reference 41, C

Design Conditions for Sele

the 0.4% dehumidification 

db, 73.0 °F dew point, and 

Kalamazoo, Michigan. Sim

wb, and —66% RH is define

evaporation condition. The

bounded by the 32°C (89.6

test case presented in MO

(Reference 4).

Hence, the operational hum

1313 of of 2424 

the vendor testing are avai

MOHR Report 1-0410-1 Re

SFPI System Temperature 

(Reference 4)." 

Humidity in the Control Ro

Room are normally regulat

at 500/0 (Reference 43). Du

AC power, the HVAC systeAssuming the Control Roo

remain isolated from outsid

expected to increase and t

to decrease because the h

by the sensible heat of ele

Therefore, the maximum te

the Control Room (Referen

C-40 Panel Room (Referen

below 50% is bounded by 

percent RH test case prese

1-0410-1 (Reference 4). 

I n the event outside air is i

Room or C-40 Panel Room

HVAC system connections 

ASH RAE (Reference 41, C

Design Conditions for Sele

the 0.40/0 dehumidification 

db, 73.0 of dew point, and 

Kalamazoo, Michigan. Sim

wb, and -660/0 RH is define

evaporation condition. The

bounded by the 32°C (89.6

test case presented in MO

(Reference 4). 

Hence, the operational hum
encompasses all expected 

Control Room and C-40 Pa

sensor electronics are cap

performing their required fexpected humidity conditio

No radiation N/A The location of Channel A 

effects Palisades Control Room is 

environment and no additio

per NRC Audit Report for M

Similar to the Control Room

(Channel B location) is con

environment as it is not inc

Equipment Qualification (E

42). This is acceptable for 

that contains semiconducto

is acceptable to use for SF

related equipment.

Radiation levels in the Con

Panel Room are not impac

_________

Spent Fuel Pool water leve

4 Environmental 50-212°F Reference RAD TID is 480°F long- The NRC Audit Report for 

Testing for Level (References 1, 5 the total 40 term for PEEK concludes that the SEP-i p

Sensor 2, & 14)

yr dose plus Insulators operation in the SFP envir

Components in Submerged Reference the 7 day PEEK

SEP Area- Component 5 worst case Insulators The SFP is expected to rem

Submerged (References 1 accident capable of minimum ambient tempera

Portion of Probe & 2) dose at the long term in the UFSAR (Reference 

Body lowest submergence Maximum accident conditio

spacer is taken to be 212°F boiling 

location on atmospheric pressure. Bas

the Probe analysis results, the sensiti

body body will not be challenged 

conditions of References 1

acceptable.

14 of 24

encompasses all expected 

Control Room and C-40 Pa

sensor electronics are cap

performing their required f

expected humidity conditio

No radiation N/A The location of Channel A 

effects Palisades Control Room is 

environment and no additio

per NRC Audit Report for M

Similar to the Control Room

(Channel B location) is con

environment as it is not inc

Equipment Qualification (E

42). This is acceptable for 

that contains semiconduct

is acceptable to use for SF

related equipment. 

Radiation levels in the ConPanel Room are not impac

Spent Fuel Pool water leve

4 Environmental 50-212°F Reference RADTID is 480°F long- The NRC Audit Report for 

Testing for Level (References 1, 5 the total 40 term for PEEK concludes that the SFP-1 p

Sensor 2, & 14) yr dose plus Insulators operation in the SFP enviro

Components in Submerged Reference the 7 day PEEK 

SFP Area- Component 5 worst case Insulators The SFP is expected to re

Submerged (References 1 accident capable of minimum ambient tempera

Portion of Probe & 2) dose at the long term in the UFSAR (Reference 

Body lowest submergence Maximum accident conditio

spacer is taken to be 212°F boiling 

location on atmospheric pressure. Bas

the Probe analysis results, the sensit

body body will not be challenged 

conditions of References 1 

acceptable. 

14 of 24 
The NRC Audit Report for 

concludes that the SEP-i poperation in the SFP envir

The SFP area is expected 

minimum ambient tempera

in the UFSAR (Reference 

Maximum accident conditio

humidity directly above the 

to be a condensing steam 

conservatively will be no gr

temperature of boiling wate

pressure. Based on the ve

sensitive materials in the p

challenged under the requi

References 1, 2, & 14, and For coaxial transmission caHead, MOHR uses Class 1 

Related RSCC Wire & Cab

meets the requirements of 

Electronic Engineers (IEEE

Standard for Type Test of 

Cables, Field Splices, and 

Power Generating Stations

(Reference 40).

5

7.33E+07 rad Reference 10 Grad for The NRC Audit Report for TID 5 PEEK concludes that the SFP-1 p

(References 1, Insulators operation in the SEP envir

2, & 31)

Calculation EA-EC46466-0

a worst case dose rate of a

rad to the probe via the ap

References 1 & 2. As such

suitable for the application

Environmental

Testing for Level

Sensor Electronics

Housing-Probe

Head Located

Above the SFP

50-212°F

(References 1,

2, & 14)

Reference

5

Rad TID is

the total 40

yr dose plus

the 7 dayworst case

accident

dose at the

location

PEEK: 480°F

EPDM: 194°F

long-term, 500

days @232°F, 12

days @311°F

Sylgard 170:

392°F long

term

15 of 24

7.33E+07 rad Reference 10 Grad for The NRC Audit Report for 

TID 5 PEEK concludes that the SFP-1 p

(References 1, Insulators operation in the SFP enviro

2, & 31) 

Calculation EA-EC46466-0

a worst case dose rate of a

rad to the probe via the ap

References 1 & 2. As suc

suitable for the application

5 Environmental 50-212°F Reference Rad TID is PEEK: 480°F The NRC Audit Report for 

Testing for Level (References 1, 5 the total 40 EPDM: 194°F concludes that the SFP-1 p

Sensor Electronics 2, & 14) yr dose plus long-term, 500 operation in the SFP enviro

Housing-Probe the 7 day days @ 

Head Located worst case 232°F, 12 The SFP area is expected 

Above the SFP accident days @ 311°F minimum ambient tempera

dose at the Sylgard 170: in the UFSAR (Reference 

location 392°F long- Maximum accident conditio

term humidity directly above the 

to be a condensing steam 

conservatively will be no g

temperature of boiling wate

pressure. Based on the ve

sensitive materials in the p

challenged under the requ

References 1, 2, & 14, and 

For coaxial transmission ca

Head, MOHR uses Class 1 

Related RSCC Wire & Cab

meets the requirements of 

Electronic Engineers (IEEE

Standard for Type Test of 

Cables, Field Splices, and 

Power Generating Stations

(Reference 40). 

15 of 24 
0-100% RH Reference 0-100% RH The NRC Audit Report for 

Condensing 5 for PEEK, concludes that the SEP-i p

(References 1 EPDM and operation in the SEP envir

& 2) Sylgard 170

100% non-condensing RH 

humidity range for normal 

Based on the vendor analy

materials in the probe head 

under the required conditio

and are acceptable.

2.78E+05 rad Reference PEEK: 10 The NRC Audit Report for 

TID 5 Grad concludes that the SEP-i p

(Reference 31) EPDM: 2 operation in the SEP envir

Grad

Sylgard Calculation EA-EC46466-0

170:200 Mrad a worst case dose rate of a

rad. Based on the vendor 

sensitive materials in the p

challenged under the requ

References 1, 2, & 31 and 

6 Thermal & See Topics #4 Reference See above Acceptable, vendor test/an

Radiation Aging- & 5 above 5 Topics #4 and parameters, see discussion 

Organic 5 5.

Components inSEP area

7 Basis for Dose References 1 N/A ENO Calculation Procedur

Requirement & 2 to develop calculations EA

30) and EA-EC46466-04 (the requirements of NEI 12

EA-12-051 (Reference 1). 

determine conservative sou

rates at key instrument loc

accident scenario and 40-y

8 Seismic Seismic Class References Seismic Class Acceptable, MOHR has pr

Qualification I (References 8, 1 1, & 12 1 seismic analysis which bou

1, 2, 3 & 14) criteria. The qualification r

16 of 24

0-1000/0 RH Reference 0-1000/0 RH The NRC Audit Report for 

Condensing 5 for PEEK, concludes that the SFP-1 p

(References 1 EPDM and operation in the SFP enviro

& 2) Sylgard 170 

1000/0 non-condensing RH 

humidity range for normal 

Based on the vendor analy

materials in the probe head 

under the required conditio

and are acceQtable. 

2.78E+05 rad Reference PEEK: 10 The NRC Audit Report for 

TID 5 Grad concludes that the SFP-1 p

(Reference 31) EPDM: 2 operation in the SFP envi ro

Grad 

Sylgard Calculation EA-EC46466-0

170:200 Mrad a worst case dose rate of a

rad. Based on the vendor 

sensitive materials in the p

challenged under the requ

References 1,2, & 31 and 

6 Thermal & See Topics #4 Reference See above Acceptable, vendor test/an

Radiation Aging- & 5 above 5 Topics #4 and parameters, see discussio

Organic 5 5. Components in 

SFP area 

7 Basis for Dose References 1 N/A ENO Calculation Procedur

Requirement &2 to develop calculations EA

30) and EA-EC46466-04 (

the requirements of NEI 12

EA-12-051 (Reference 1). 

determine conservative so

rates at key instrument loc

accident scenario and 40-y

8 Seismic Seismic Class References Seismic Class Acceptable, MOHR has pr

Qualification I (References 8,11, & 12 1 seismic analysis which bou

1,2,3& 14) criteria. The qualification r

16 of 24 
Water induced

motion from

seismic eventdoes not

cause

equipment

structural

failure

components of the new SF

required to be operational 

post-event. This documen

0410-9.19 (Reference 12). 

Reports 1-0410-6 (Referen

(Reference 11) are also pr

Calculations EA-EC46466-

EA-EC46466-02 (Referenc

components, supports, and 

are structurally adequate aas all Interaction Ratios ar

Reference Topic #9 for dis

induced sloshing effect.

Acceptable, the MOHR sei

(References 8, 11,

& 12) in 

1725-003 (Reference 17), 

(Reference 19) and PNP s

1791 -006 (Reference 18) a

hydrodynamic loads assoc

PNP.

Calculation EA-EC46466-0

accounts for sloshing effec

determines that all componanchorages required are s

seismically qualified as all are less than one (1.0). Th

(References 18

& 19) are u

bracket design. Reference 

portal for review.

9 Sloshing References

11, 12,17,18,

& 19

See Topic

#8

10 Spent Fuel Pool System must References The system features on bo

Instrumentation allow for 25, 26,& 27 diagnostics. SFPI channel/

System routine, in situ maintenance/preventative 

Functionality functionality program requirements to e

17 of 24

components of the new SF

required to be operational 

post-event. This documen

0410-9.19 (Reference 12). 

Reports 1-0410-6 (Referen

(Reference 11) are also pr

Calculations EA-EC46466-

EA-EC46466-02 (Referenc

components, supports, and 

are structurally adequate a

as all Interaction Ratios are 

Reference Topic #9 for dis

induced sloshing effect . 

9 Sloshing Water induced References See Topic Acceptable, the MOHR se

motion from 11,12,17, #8 (References 8, 11, & 12) in 

seismic event 18, & 19 1725-003 (Reference 17), 

does not (Reference 19) and PNP s

cause 1791-006 (Reference 18) a

equipment hydrodynamic loads assoc

structural PNP. 

failure 

Calculation EA-EC46466-0

accounts for sloshing effecdetermines that all compon

anchorages required are s

seismically qualified as all 

are less than one (1.0). Th

(References 18 & 19) are 

bracket design. Reference portal for review. 

10 Spent Fuel Pool System must References The system features on bo

Instrumentation allow for 25,26,& 27 diagnostics. SFPI channel/

System routine, in situ maintenance/preventative 

Functionality functional ity program requirements to e

17 of 24 
readiness will be establish

ENO processes and proce

consideration of vendor re

ensure that appropriate re

checks, functional tests, pe

maintenance are performeinspection and audit). The 

monitors the integrity of its 

system using in-situ capabi

manuals has been provide

(References 26

& 27) for u

possible these could be ambased on installation exper

11 Boron Build-Up Buildup cannot Reference Boron buildup MOHR Report 1-0410-8 (R

produce error 10 can produce

a that the presence of borate

greater than 1’ maximum deposits will not significant

including all error of 2.5 MOHR EFP-lL SFPI system 

other error inches water level in the SFP env

source terms

(References 1 Previous Topic #10 already 

& 2) / preventative maintenance 

established in consideratio

recommendations (which i

those associated with boro

Topic #20 below discusses 

channel functional testing 

be based on vendor stated 

comparison of SFPI chann

(which would also bound b

specified in Reference 40)and/or wash down of the p

initiated by accuracy requi

inspection. The probe hea

connection mechanism for 

boron build-up as may be n

the SEP water level can be 

18 of 24

readiness will be establish

ENO processes and proce

consideration of vendor re

ensure that appropriate reg

checks, functional tests, pe

maintenance are performeinspection and audit). The 

monitors the integrity of its 

system using in-situ capab

manuals has been provide

(References 26 & 27) for u

possible these could be am

based on installation expe

11 Boron Build-Up Buildup cannot Reference Boron buildup MOHR Report 1-0410-8 (R

produce error 10 can produce a that the presence of borate

greater than l' maximum deposits will not significant

including all error of 2.5 MOHR EFP-IL SFPI system 

other error inches water level in the SFP env

source terms 

(References 1 Previous Topic #10 alread

& 2) / preventative maintenance 

established in consideratio

recommendations (which i

those associated with boro

Topic #20 below discusses 

channel functional testing 

be based on vendor stated 

comparison of SFPI chann

(which would also bound b

specified in Reference 40)

and/or wash down of the p

initiated by accuracy requi

inspection. The probe hea

connection mechanism for 

boron build-up as may be 

the SFP water level can be 

18 of 24 
The NRC Audit Report for 

concludes that the shock a

were satisfactory. The repo

that the testing performed 

16 (Reference 38) is suffic

item identified during the M

Acceptable, the vendor tes

addresses the requiremen

of the enclosures. The pro

are essentially a coax cabl

considered inherently resis

vibration. The probes and 

evaluated to be adequately 

against shock and vibration 

The new probe mounting c

fasteners are seismically q

rigid components inherentl

effects. The probes will be 

using a machine screw con

proper thread engagement 

The indicator and battery e

mounted in the control room 

14

and dissolves the boric aci27).

12 Pool-side Bracket Seismic Class References See Topic Seismic Class Calculation EA-EC46466-0

Seismic Analysis I (References 11 & 12 #8 I determines that all compon

(References 1 & 1, 2, & 15) anchorages required are s

2) Reference 32 is available o

13 Additional Seismic Class Reference See Topic Seismic Class Calculation EA-EC46466-0

Brackets (Sensor I (Reference 1, 8 #8 I determines that all compon

Electronics and 2, 3 & 14) anchorages required are s

Electronics Reference 33 is available o

Enclosure)

Shock & Vibration References

7,11,12, &

38

(Reference 1,

2,3)

MIL-STD-1 67-

1 (Reference

23) for

vibration and

MIL-STD-901 D

(Reference 24)

for shock

IEC 60068-2-

27 (2008-02)

(Reference

20)

IEC 60068-2-

6 (2007-12)

(Reference

21)

19 of 24

and dissolves the boric aci

27}. 

12 Pool-side Bracket Seismic Class References See Topic Seismic Class Calculation EA-EC46466-0

Seismic Analysis I (References 11 & 12 #8 I determines that all compon

(References 1 & 1,2,&15) anchorages required are s

2) Reference 32 is available o

13 Additional Seismic Class Reference See Topic Seismic Class Calculation EA-EC46466-0

Brackets (Sensor I (Reference 1, 8 #8 I determines that all compon

Electronics and 2,3& 14) anchorages required are s

Electronics Reference 33 is available o

Enclosure) 

14 Shock & Vibration (Reference 1, References IEC 60068-2- The NRC Audit Report for 

2,3) 7,11,12,& 27 (2008-02) concludes that the shock a

MIL-STD-167- 38 (Reference were satisfactory. The repo

1 (Reference 20) that the testing performed 

23) for IEC 60068-2- 16 (Reference 38) is suffic

vibration and 6 (2007-12) item identified during the M

MIL-STD-901 D (Reference 

(Reference 24) 21) Acceptable, the vendor tes

for shock addresses the requiremen

of the enclosures. The proare essentially a coax cabl

considered inherently resis

vibration. The probes and 

evaluated to be adequately 

against shock and vibratio

The new probe mounting c

fasteners are seismically q

rigid components inherent

effects. The probes will be 

using a machine screw co

proper thread engagemen

The indicator and battery e

mounted in the control roo

19 of 24 
The equipment is not affix

rotating machinery that wo

effects in the area of instal

instrument mounting comp

seismically qualified and d

components inherently res

Similarly, the effects of sho

fixtures is not a credible th

control room and C-40 Pan

seismically such that there 

from adjacent objects durin

basis earthquake requirem

02. Even though shock an

for Control Room and C-40 

equipment, it is adequately 

test reports.

15 Requirements Software Reference The instrument software V

Traceability Matrix Traceability 29 was performed by MOHR 

Matrix Report 1-0410-11 (Referen

Required for

Software

Evaluation of

equipment

16 Factory Must MOHR Acceptable channel factory 

Acceptance Test demonstrate FAT been completed successful

functionality of Procedure

full EFP-lL and

SFP-1

17 Channel Accuracy +- 1 foot References 3.0 in max, Appendix A of Reference 2

(Reference 2) 25 & 28 not including absolute accuracy is 76.2 

boric acid including boric acid deposit

deposition or complies with the limit of ±

boiling effects (Reference 2). See Topic #

deposition effects.

Additionally, the probe is d

20 of 24

The equipment is not affixe

rotating machinery that wo

effects in the area of instal

instrument mounting comp

seismically qualified and d

components inherently res

Similarly, the effects of sho

fixtures is not a credible th

control room and C-40 Pan

seismically such that there 

from adjacent objects durin

basis earthquake requirem

02. Even though shock an

for Control Room and C-40 

equipment, it is adequately 

test reports. 

15 Requirements Software Reference The instrument software V

Traceability Matrix Traceability 29 was performed by MOHR 

Matrix Report 1-0410-11 (Referen

Required for 

Software 

Evaluation of 

equipment 

16 Factory Must MOHR Acceptable channel factory 

Acceptance Test demonstrate FAT been completed successfu

functionality of Procedure 

full EFP-I Land 

SFP-1 

17 Channel Accuracy +- 1 foot References 3.0 in max, Appendix A of Reference 2

(Reference 2) 25 &28 not including absolute accuracy is 76.2 

boric acid including boric acid deposi

deposition or complies with the limit of ±

boiling effects (Reference 2). See Topic #

deposition effects. 

Additionally, the probe is d

20 of 24 
accurate level indication in 

(multiphase) environments Report 1-0410-15 (Referen

18 Power 120 VAC, 60 References 85-264 VAC The NRC Audit Report for 

consumption Hz 9, 13, & 37 47-63 HZ concludes that no deficits w

(References 11.48 W respect to function reliabilit

14 & 37) (average) calibration as a result of po

18.83W

(Maximum) Acceptable, the power req

instrument are met by the provide normal AC power t

MOHR Report 1-0410-10 (

that the accuracy is not aff

in power.

7 day battery Reference 7 day battery The NRC Audit Report for 

life required 9 life @ 15 concludes that battery life 

samples per

hour rate Acceptable, the instrument 

the battery capacity is suff

duration required by Refer

19 Technical Manual N/A References Revision 0 of the manuals 

26 & 27 the vendor for use, althoug

could be amended in the fu

installation experience.

20 Calibration Must allow for References System is Revision 0 of the manuals 

in-situ 25, 26, & calibrated the vendor for use, althoug

calibration 27 using CT- could be amended in the fu

100 device installation experience. Pre

and discusses maintenance / p

processing requirements being establi

of scan files vendor recommendations.

by vendor.

Dry scan Overall calibration or chann

from original methodology is expected t

installation stated accuracy and to inc

21 of 24

accurate level indication in 

(multiphase) environments 

Report 1-0410-15 (Referen

18 Power 120 VAC, 60 References 85-264 VAC The NRC Audit Report for 

consumption Hz 9,13,&37 47-63 HZ concludes that no deficits w

(References 11.48 W respect to function reliabilit

14 & 37) (average) calibration as a result of po

18.83 W 

(Maximum) Acceptable, the power req

instrument are met by the 

provide normal AC power t

MOHR Report 1-0410-10 (

that the accuracy is not aff

in power. 

7 day battery Reference 7 day battery The NRC Audit Report for 

life required 9 life @ 15 concludes that battery life 

samples per 

hour rate Acceptable, the instrumen

the battery capacity is suff

duration required by Refer

19 Technical Manual N/A References Revision 0 of the manuals 

26&27 the vendor for use, althoug

could be amended in the fu

installation experience. 

20 Calibration Must allow for References System is Revision 0 of the manuals 

in-situ 25,26,& calibrated the vendor for use, althoug

calibration 27 using CT- could be amended in the fu

100 device installation experience. Pre

and discusses maintenance I p

processing requirements being establi

of scan files vendor recommendations. 

by vendor. 

Dry scan Overall calibration or chan

from original methodology is expected t

installation stated accuracy and to inc

21 of 24 
must be SFPI channels to actual po

maintained SFPI cross channel compa

21 Failure Modes and System Reference SFPI system Acceptable, the FMEA pro

Effects Analysis provides 39 will meet addresses failure modes a

(FMEA) reliable requirements instrument channel with cr

indication of of References two redundant channels pr

fuel pool level, 1 & 2 when meets all requirements stip

consistent with installed as 2.

the required

requirements

of References

i&2

22 Emissions Testing EPRI TR- Reference EPRI TR- Acceptable, MOHR reports 

102323, Rev. 3 6 102323, Rev, and 1-0410-4-Si (Referen

(Reference 22) 3 (Reference new SFPI satisfies the EM

22) guidelines of Revision 3 of 

(Reference 22) in accordan

Engineering Standard EN-

(Reference 35). As demon

System EMC Test Report 

Information (References 6 

passed the High Frequenc

Conducted Emissions testi

FLEX Support Guidelines 

of the SFPI are expected tstatement to preclude radi

proximity to the displays.

22 of 24

must be SFPI channels to actual po

maintained SFPI cross channel compa

21 Failure Modes and System Reference SFPI system Acceptable, the FMEA pro

Effects Analysis provides 39 will meet addresses failure modes a

(FMEA) reliable requirements instrument channel with cr

indication of of References two redundant channels pr

fuel pool level, 1 & 2 when meets all requirements stip

consistent with installed as 2. 

the required 

requirements 

of References 

1&2 

22 Emissions Testing EPRI TR- Reference EPRI TR- Acceptable, MOHR reports 

102323, Rev. 3 6 102323, Rev. and 1-0410-4-S1 (Referen

(Reference 22) 3 (Reference new SFPI satisfies the EM

22) guidelines of Revision 3 of 

(Reference 22) in accorda

Engineering Standard EN-

(Reference 35). As demon

System EMC Test Report 

Information (References 6 

passed the High Frequenc

Conducted Emissions test

FLEX Support Guidelines 

of the SFPI are expected t

statement to preclude radi

- proximjty 

22 of 24 
Spent Fuel Pool Instrumentation Order (EA-12-051)

Bridging Document Between Vendor Technical Information and Licensee Implementation Based on NRC Staff Requests for Additional Information (RAIs) and NRC Vendor Audit

References:

1. ML1 2054A682, NRC Order EA-1 2-051, “Order Modifying Licenses with Regard to Reliable Spent Fuel Pool In

Regulatory Commission, March 12, 2012

2. ML12240A307, NEI 12-02, Revision 1, “Industry Guidance for compliance with NRC Order EA-12-051, “To Mo

to Reliable Spent Fuel Pool Instrumentation” August, 2012.

3. ML12221A339, Revision 0, JLD-ISG-2012-03, “Compliance with Order EA-12-051, Reliable Spent Fuel Pool I

2012, Nuclear Regulatory Commission Japan Lessons-Learned Project Directorate

4. 1-0410-1, “MOHR EFP-IL SFPI System Temperature and Humidity Test Report”

5. 1-0410-2, “MOHR SFP-1 Level Probe Assembly Materials Qualification Report”

6. 1-0410-4, “MOHR EFP-IL SFPI System EMC Test Report”7. 1-0410-5, “MOHR EFP-lL SFPI System Shock and Vibration Test Report”

8. 1-0410-6, “MOHR EFP-IL SFPI System Seismic Test Report”

9. 1-0410-7, “MOHR EFP-IL SFPI System Battery Life Report”

10. 1-0410-8, “MOHR EFP-IL SFPI System Boric Acid Deposition Report”

11. 1-0410-9, “MOHR SFP-1 Level Probe Assembly Seismic Analysis Report”

12. 1-0410-9.19, “MOHR SFP-1 Site-Specific Seismic Analysis Report: Palisades Nuclear Power Station (PLP)”13. 1-0410-10, “MOHR EFP-lL SFPI System Power Interruption Report

14. FSAR, Rev. 31, “Palisades Final Safety Analysis Report”15. EN-DC-126, Rev. 5, “Engineering Calculation Process”

16. EA-EC46465-03, Rev. 0, “Control Room Heatup for Extended Loss of AC Power”

17. NAI-1725-003, Rev. 0, “GOTHIC Verification and Sensitivity Studies for Predicting Hydrodynamic Response t

Rectangular Shaped Pools”

18. NAI-1 791-006, Rev. 0, “PLP GOTHIC Hydrodynamic Analysis”

19. NAI-1725-004, Rev. 3, “Seismic Induced Hydraulic Response in the CGS Spent Fuel Pool”

20. IEC 60068-2-27 (2008-02), “Environmental Testing-Part 2-27: Tests-Test Ea and Guidance: Shock”21. IEC 60068-2-6 (2007-12), “Environmental Testing-Part 2-6: Tests-Test Fc: Vibration (sinusoidal)”

22. EPRI TR-102323, Rev. 3, “Guidelines for Electromagnetic Interference of Power Plant Equipment”

23. MIL-STD-167-1, “Mechanical Vibrations of Shipboard Equipment (Type 1-Environmentally and Type Il-Internal

24. MIL-S-901 D, “Shock Tests H.l.(High Impact) Shipboard Machinery, Equipment, and Systems, Requirements f

23 of 24

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

Bridging Document Between Vendor Technical Information and Licensee Implementation 

Based on NRC Staff Requests for Additional Information (RAls) and NRC Vendor Audit 

References: 

1. ML 12054A682, NRC Order EA-12-051 , "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool In

Regulatory Commission, March 12,2012 

2. ML12240A307, NEI12-02, Revision 1, "Industry Guidance for compliance with NRC Order EA-12-051, ''To Mo

to Reliable Spent Fuel Pool Instrumentation"" August, 2012. 

3. ML 12221A339, Revision 0, JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool In

2012, Nuclear Regulatory Commission Japan Lessons-Learned Project Directorate 

4. 1-0410-1, "MOHR EFP-IL SFPI System Temperature and Humidity Test Report" 

5. 1-0410-2, "MOHR SFP-1 Level Probe Assembly Materials Qualification Report" 

6. 1-0410-4, "MOHR EFP-IL SFPI System EMC Test Report" 

7. 1-0410-5, "MOHR EFP-IL SFPI System Shock and Vibration Test Report" 

8. 1-0410-6, "MOHR EFP-IL SFPI System Seismic Test Report" 

9. 1-0410-7, "MOHR EFP-IL SFPI System Battery Life Report" 

10. 1-0410-8, "MOHR EFP-IL SFPI System Boric Acid Deposition Report" 11.1-0410-9, "MOHR SFP-1 Level Probe Assembly Seismic Analysis Report" 

12. 1-0410-9.19, "MOHR SFP-1 Site-Specific Seismic Analysis Report: Palisades Nuclear Power Station (PLP)" 

13.1-0410-10, "MOHR EFP-IL SFPI System Power Interruption Report 

14. FSAR, Rev. 31, "Palisades Final Safety Analysis Report" 

15. EN-DC-126, Rev. 5, "Engineering Calculation Process" 

16. EA-EC46465-03, Rev. 0, "Control Room Heatup for Extended Loss of AC Power" 

17. NAI-1725-003, Rev. 0, "GOTHIC Verification and Sensitivity Studies for Predicting Hydrodynamic Response t

Rectangular Shaped Pools" 

18. NAI-1791-006, Rev. 0, "PLP GOTHIC Hydrodynamic Analysis" 

19. NAI-1725-004, Rev. 3, "Seismic Induced Hydraulic Response in the CGS Spent Fuel Pool" 

20. IEC 60068-2-27 (2008-02), "Environmental Testing-Part 2-27: Tests-Test Ea and Guidance: Shock" 

21. IEC 60068-2-6 (2007-12), "Environmental Testing-Part 2-6: Tests-Test Fc: Vibration (sinusoidal)" 

22. EPRI TR-102323, Rev. 3, "Guidelines for Electromagnetic Interference of Power Plant Equipmenf' 

23. MIL-STD-167-1, "Mechanical Vibrations of Shipboard Equipment (Type 1-Environmentally and Type II-Interna24. MIL-S-901 0, "Shock Tests H.I.(High Impact) Shipboard Machinery, Equipment, and Systems, Requirements f

23 of 24 
25. 1-0410-12, “EFP-IL Signal Processor Operator’s Manual”

26. 1-0410-13, “EFP-IL Signal Processor Technical Manual”27. 1-0410-14, “SEP-i Level Probe Assembly Technical Manual”

28. 1-041 0-1 5, “MOHR EFP-IL SFPI System Uncertainty Analysis”

29. 1-0410-11, “MOHR EFP-IL SFPI System Software Verification and Validation”

30. EA-EC46466-03, Rev.0, “Beyond Design Basis Spent Fuel Pool Instrumentation Source Term Calculation”31. EA-EC46466-04, Rev. 0, “Beyond Design Basis Spent Fuel Pool Instrumentation Dose Calculation”

32. EA-EC46466-01, Rev. 0, “Design of SFPI Probe Mounting Bracket”

33. EA-EC46466-02, Rev. 0, “Qualification of SEP Instrumentation Mounting Details”

34. 1-0410-4-51, “MOHR EFP-IL SFPI Supplemental EMC Information”35. EN-EC-S-004-MULTI, Rev. 1, “EMI/REI Design Considerations”

36. DBD-1 .07, Rev. 5, “Entergy Nuclear Northeast Palisades Design Basis Document for Auxiliary Building HVAC 

37. MOHR drawing 1-0430-20, “EEP-IL System Electrical Diagram”

38. 1-0410-16, “MOHR SEP-i Level Probe Assembly Shock and Vibration Test Report”

39. EVAL-194-4812-0i, “MOHR EFP-IL Liquid Level Measurement System Failure Modes and Effects Analysis (E

40. “Donald C. Cook Nuclear Plant, Units 1 and 2 -Report for the Onsite Audit of MOHR Regarding Implementatio

Pool Instrumentation Related to Order EA-12-05i (TAC Nos. MF0761 and MF0762),” dated August 27, 2014 

ML1 421 6A362)

41. 2009 ASH RAE Handbook Fundamentals, I-P Edition

42. DBD-7.01, Rev. 10, “Entergy Nuclear Northeast Palisades Design Basis Document for Electrical Equipment Q

43. DBD-1 .06, Rev. 8, “Entergy Nuclear Northeast Palisades Design Basis Document for Control Room HVAC Sy

24 of 24

25. 1-0410-12, "EFP-IL Signal Processor Operator's Manual" 26. 1-0410-13, "EFP-I L Signal Processor Technical Manual" 

27.1-0410-14, "SFP-1 Level Probe Assembly Technical Manual" 

28. 1-0410-15, "MOHR EFP-IL SFPI System Uncertainty Analysis" 

29.1-0410-11, "MOHR EFP-IL SFPI System Software Verification and Validation" 

30. EA-EC46466-03, Rev.O, "Beyond Design Basis Spent Fuel Pool Instrumentation Source Term Calculation" 

31. EA-EC46466-04, Rev. 0, "Beyond Design Basis Spent Fuel Pool Instrumentation Dose Calculation" 

32. EA-EC46466-01, Rev. 0, "Design of SFPI Probe Mounting Bracket" 

33. EA-EC46466-02, Rev. 0, "Qualification of SFP Instrumentation Mounting Details" 34. 1-0410-4-S1, "MOHR EFP-IL SFPI Supplemental EMC Information" 

35. EN-EC-S-004-MUL TI, Rev. 1, "EMIIRFI Design Considerations" 

36. DBD-1.07, Rev. 5, "Entergy Nuclear Northeast Palisades Design Basis Document for Auxiliary Building HVAC 

37. MOHR drawing 1-0430-20, "EFP-IL System Electrical Diagram" 38.1-0410-16, "MOHR SFP-1 Level Probe Assembly Shock and Vibration Test Report" 

39. EVAL-194-4812-01, "MOHR EFP-IL Liquid Level Measurement System Failure Modes and Effects Analysis (F

40. "Donald C. Cook Nuclear Plant, Units 1 and 2 - Report for the Onsite Audit of MOHR Regarding Implementatio

Pool Instrumentation Related to Order EA-12-051 (TAC Nos. MF0761 and MF0762)," dated August 27,2014 (

ML 14216A362) 

41. 2009 ASH RAE Handbook Fundamentals, I-P Edition 

42. DBD-7.01, Rev. 10, "Entergy Nuclear Northeast Palisades Design Basis Document for Electrical Equipment Q

43. DBD-1.06, Rev. 8, "Entergy Nuclear Northeast Palisades Design Basis Document for Control Room HVAC Sy

24 of 24