- Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PNP 2015-061 

August 28, 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 

Requirements for Mitigation Strategies for Beyond-Design-Basis External 

Events (Order Number EA-12-049) 

Palisades Nuclear Plant 

Docket No. 50-255 

License No. DPR-20 

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

to Requirements for Mitigation Strategies for Beyond-Design-Basis 

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

ML 12054A736) 

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

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

Mitigation Strategies for Beyond-Design-Basis External Events, 

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

ML12229A174) 

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

Implementation Guide, Revision 0, dated August 2012 (ADAMS 

Accession No. ML 12242A378) 

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

Status Report in Response to March 12,2012 Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation 

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

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

ML 12300A065) 

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

Integrated Plan in Response to March 12,2012 Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation 

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

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

ML 13246A399) 
PNP 2015-061 

Page 2 of 3 

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

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

March 12,2012 Commission Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis 

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

(ADAMS Accession No. ML 13241A234) 

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

Palisades Nuclear Plant Second Six-Month Status Report in Response 

to March 12,2012 Commission Order Modifying Licenses with Regard 

to Requirements for Mitigation Strategies for Beyond-Design-Basis 

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

(ADAMS Accession No. ML 14059A078) 

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

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

March 12,2012 Commission Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis 

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

(ADAMS Accession No. ML 14240A279) 

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

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

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

(ADAMS Accession No.ML 13365A264) 

10. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2015-007, 

Palisades Nuclear Plant Fourth Six-Month Status Report in Response 

to March 12,2012 Commission Order Modifying Licenses with Regard 

to Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events (Order Number EA-12-049), dated February 27, 2015 

(ADAMS Accession No. ML 15062A011) 

Dear Sir or Madam: 

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

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

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

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

beyond-design-basis external event. 

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

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

Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 

(Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 

provided the Palisades Nuclear Plant (PNP) initial status report regarding mitigation strategies. 

Reference 5 provided the PNP overall integrated plan. 

Reference 1 requires submission of a status report at six-month intervals following submittal of 

the overall integrated plan. Reference 3 provides direction regarding the content of the status 

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

second six-month status report. Reference 8 provided the third six-month status report. In 
PNP 2015-061 

Page 3 of 3 

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

Reference 10 provided the fourth six-month status report. 

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 attachment provides an update of milestone accomplishments, including 

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

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. 

Sincerely, 

/ 

AJV/jse 

Attachment: Palisades Nuclear Plant Fifth Six-Month Status Report in Response to March 12, 

2012, Commission Order Modifying Licenses with Regard to Requirements for 

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

EA-12-049) 

cc: Office Director, NRR, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
ATTACHMENT 

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

March 12, 2012 Commission Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External 

Events (Order Number EA-12-049) 

1 Introduction 

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

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

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

milestone accomplishments since submittal of the last status report (Reference 4), 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 

• Develop Strategies with NSRC - March 2015 

• Perform Staffing Analysis - April 2015 

• Purchase and Procure On-site FLEX Equipment - July 2015 

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

August 2015. 

3 Milestone Schedule Status 

The following provides an update to Attachment 2 of the overall integrated plan. It provides 

the activity status of each item, and whether the expected completion date has changed. The 

dates are planning dates subject to change as design and implementation details are 

developed. 

• Training Complete 

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

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

date. 

• Validation / Demonstration 

The Validation / Demonstration milestone completion date has been changed to 

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

implementation date. 

Page 1 of 17 
• Submit Completion Report 

The Submit Completion Report milestone completion date has been changed to 

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

implementation date. 

Target Revised Target 

Milestone Completion Activity Status Completion 

Date* Date 

Submit Overall Integrated Feb 2013 Complete Implementation Plan 

Six-Month Status Updates 

Update 1 Aug 2013 Complete 

Update 2 Feb 2014 Complete 

Update 3 Aug 2014 Complete 

Update 4 Feb 2015 Complete 

Update 5 Aug 2015 Complete 

FLEX Strategy Evaluation Jan 2014 Complete 

Perform Staffing Analysis Apr 2015 Complete 

Modifications 

Modifications Evaluation Apr 2014 Complete 

Engineering and Implementation 

N-1 Walkdown Feb 2014 Complete 

Design Engineering Sept 2014 Complete 

Implementation Outage Oct 2015 Not Started 

On-site FLEX Equipment 

Purchase and Procure Aug 2015 Completed 

Off-site FLEX Equipment 

Develop Strategies with NSRC Oct 2015 Complete 

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

Procedures 

Pressurized Water Reactor Owners 

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

Specific Guidelines 

Create PNP FLEX FSG/FIGS Oct 2015 Started 

Create Maintenance Procedures Oct 2015 Started 

Training 

Develop Training Plan Jun 2015 Complete 

Training Complete July 2015 Started Oct 2015 

Page 2 of 17 
Target Revised Target 

Milestone Completion Activity Status Completion 

Date* Date 

Validation I Demonstration Oct 2015 Started Sept 2015 

Submit Completion Report Oct 2015 Not Started Dec 2015 

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

status reports 

4 Changes to Compliance Method 

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

Plan (Reference 1). However, since the last update, three items have been identified as 

alternate approaches to NEI 12-06, Revision 0, "Diverse and Flexible Coping Strategies," 

(Reference 7) for meeting the Order. NRC Interim Staff Guidance JLD-ISG-2012-01 

(Reference 66) states that licensees may use other methods for compliance with Order 

EA-12-049 as an alternative to meeting NEI12-06. The NRC requested that alternate 

approaches be included in a future FLEX six-month status report during the June 2015 NRC 

Audit Visit. These items are discussed below. 

• FLEX Storage Strategy Alternate Approach 

Palisades' strategy for the deployment of FLEX equipment following a seismic event is an 

alternate approach to NEI 12-06 for meeting the Order. NEI 12-06, Section 5.3.2 (1) 

states: "If the equipment needs to be moved from a storage location to a different pOint 

for deployment, the route to be traveled should be reviewed for potential soil liquefaction 

that could impede movement following a severe seismic event." 

Soil test borings were performed on site and soil liquefaction susceptibility was identified. 

Analysis determined that the soil outside the Protected Area (PA) was susceptible to 

liquefaction after a seismic event. Liquefiable soil would likely cause differential 

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

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

could withstand all beyond-design-basis external events (BDBEE). The solution to this 

problem is to house FLEX equipment in two structures that will each withstand a portion 

of the required BDBEE such that at least one set of portable FLEX equipment will be 

available and accessible for any and all BDBEE consistent with NEI 12-06, Section 

11.3.3. The storage location inside the PA consists of a pre-engineered metal building 

(FLEX Storage Building - A) designed to withstand extreme temperature, probable 

maximum flood, and seismic BDBEE, while the storage location outside the PA is a 

reinforced concrete building (FLEX Storage Building - B) designed to withstand extreme 

temperature, probable maximum flood, and high wind BDBEE, including tornado 

generated missiles, as well as seismic BDBEE for protection of the Phase 3 equipment 

which will be stored in the building. 

Liquefaction only impacts deployment of equipment from the reinforced concrete building 

(FLEX Storage Building - B) located outside of the PA. During the seismic event, 

equipment will be deployed from the pre-engineered metal building inside the PA (FLEX 

Storage Building - A) where there are no liquefaction concerns. 

This alternate approach was reviewed by the NRC during the June 2015 NRC Audit Visit 

at Palisades and no new open items were identified for this approach. 

Page 3 of 17 
T-81 Missile Shielding Alternate Approach 

This discussion provides the justification of an alternate approach to NEI 12-06 to meet 

the Order regarding tornado and tornado missiles evaluations and the method for 

addressing the tornado generated automobile missile hazard as it applies to evaluation of 

the primary system makeup storage tank (T-81). 

All the equipment needed to meet the Phase 1 strategy are found to be robust with the 

exception of T-81 foundation anchor bolts for an automobile tornado missile hazard. 

T-81 was not required to meet tornado wind and missile protection criteria for the original 

design of the plant. As part of the FLEX strategy, use of the tank is desired. Modifications 

are being made to enhance T-81 as well as the condensate storage tank (T-2). These 

modifications will strengthen both tanks to meet the requirements for tornado and tornado 

missiles with the single exception of T-81 for an automobile missile hazard (both tanks 

are fully protected against the missile hazards exclusive of an automobile missile hazard 

for T -81 only). 

In lieu of specifically protecting T-81 from an automobile missile hazard, a qualitative 

evaluation has been performed which demonstrates that protection is not required to 

credit T-81 as robust. For the following reasons, an alternate approach to tank protection 

against an automobile missile hazard is justified: 

o The tank is partially protected from all sides by intervening structures. 

o The probability of occurrence of a tornado is reasonably low. 

o Site procedures will institute specific mitigating actions to remove/restrain all objects 

that are characteristic of the automobile/large object missile hazard from the zone of 

concern in advance of the occurrence of a tornado, thereby removing the potential 

hazard of concern. 

o Procedural identification and control of alternate sources of water should T-81 

become unavailable. 

![EU11This alternate approach, as documented in a white paper entitled "Tornado 

Generated Missile Hazard Evaluation for the Primary System Makeup Storage Tank 

(T-81)," was reviewed by the NRC during the June 2015 NRC Audit Visit at Palisades and 

no new open items were identified for this approach. 

Use of Installed Charging Pumps in Lieu of Portable Pumps 

Palisades' strategy to use installed charging pumps as the primary and alternate means 

of primary coolant system (PCS) makeup is an alternate approach to NEI 12-06 for 

meeting the Order. NEI12-06, Section 3.2.2 (13) states: "Regardless of installed coping 

capability, all plants will include the ability to use portable pumps to provide RPV/RCS/SG 

makeup as a means to provide a diverse capability beyond installed equipment. .. " 

Though an alternate approach to NEI 12-06, this strategy is deemed to meet the diversity 

requirements because each pump is powered from a separate safety related load center, 

each with a primary and alternate strategy for receiving power from the FLEX generator. 

Additionally, the load centers can be cross-tied and either charging pump can be powered 

by either connection pOint to provide a reliable primary and alternate connection pOint 

(separate safety-related trains) for each charging pump. 

Page 4 of 17 
Palisades has two independent flowpaths to inject water to the PCS. Each flowpath 

utilizes a different system for discharging water to the PCS. One path allows flow to be 

directed to the high pressure safety injection (HPSI) header and on to the PCS while the 

normal flow path is through the chemical volume control system (CVCS) regenerative 

heat exchanger to the PCS. The HPSI system branch connection is an independent 

piping path off the common header and separate from the CVCS connection. Each 

charging pump and diverse flowpath can be physically isolated from one another (pump 

discharge valves and header isolation valves) should either be compromised. Each 

piping flow path has been validated to be robust in accordance with NEI 12-06. Valves 

which are required to align either flow path are powered by the FLEX generator and 

procedures for valve operation are addressed in the FLEX Support Guidelines (FSGs). 

This Palisades FLEX strategy promotes success by utilizing robust plant equipment that 

is located within a structure that is protected from all Palisades design basis external 

events (Le., auxiliary building) and reduces the number of operator actions required to 

place that equipment into operation. 

This alternate approach was reviewed by the NRC during the June 2015 NRC Audit Visit 

at Palisades and no new open items were identified for this approach. 

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

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

at this time. 

6 Open Items from Overall Integrated Plan and Interim Staff 

Evaluation 

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

Overall Integrated Plan and any open items or confirmatory items documented in Interim 

Staff Evaluation (ISE) (Reference 3). A fourth table includes a listing of all audit questions 

and the status of each item. A fifth table includes the FLEX related NRC Audit Visit 

(Reference 5) open items, which includes open items on previously issued ISE Open and 

Confirmatory Items and new Safety Evaluation (SE) Open Items that were not closed during 

the June 2015 NRC Audit Visit, and their status. 

Note that during the June 2015 NRC Audit Visit the NRC utilized a spreadsheet entitled 

Palisades Nuclear Plant, SE Item Tracker to maintain a status of Open Items associated with 

development of the NRC's Safety Evaluation. The SE Tracker numbered each item with an 

Audit Item No. based on the category of the Open Item. The categories were: 

A. ISE Open and Confirmatory Items (Audit Item Ol-xxxxx or CI-xxxxx) 

B. Audit Questions (Audit Item x-B) 

C. Licensee OIP Open Items (Audit Item x-C) 

D. SFP Instrumentation RAls (Audit Item SRAI-x-D) 

E. Combined SE Template Technical Review Gaps (Audit Item x-E) 

In the Status columns of the following tables, closed items are identified by the phrase "This 

item was closed during the June 2015 NRC Audit Visit." 

Page 5 of 17 
Overall Integrated Plan Open Item Status 

011. Perform analysis on Palisades' susceptibility to This item was closed during the June 

soil liquefaction and potential consequences on the 2015 NRC Audit Visit (Reference 5). 

FLEX implementation plan. See Section 4 above. 

012. Develop Phase 3 deployment strategy with This item was closed during the June 

correspondence with the RRC. 2015 NRC Audit Visit (Reference 5). 

013. Evaluate the need to missile protect primary This item was closed during the June 

system makeup storage tank (T -S1) and other 2015 NRC Audit Visit (Reference 5). 

external tanks. See Section 4 above and resolution of 

ISE CI 3.2.4.7.A and SE Tracker Audit 

Item CI 3.2.4.7.A below. 

014. Select the location of FLEX equipment storage This item was closed during the June 

facility. 2015 NRC Audit Visit (Reference 5). 

015. Perform seismic evaluation of turbine-driven This item was closed during the June 

auxiliary feedwater pump (TDAFWP) driver K-S. 2015 NRC Audit Visit (Reference 5). 

016. Evaluate strategies to extend battery coping This item was closed during the June 

time. 2015 NRC Audit Visit (Reference 5). 

017. Evaluate sources of non-borated water in This item was closed during the June 

addition to condensate storage tank (T-2) and T-S1. 2015 NRC Audit Visit (Reference 5). 

OIS. Palisades Probabilistic Risk Assessment (PRA) This item was closed during the June 

to provide justification why battery room ventilation 2015 NRC Audit Visit (Reference 5). 

is not required until 24 hours. 

019. Evaluate the effects of FLEX on security This item was closed during the June 

procedures. 2015 NRC Audit Visit (Reference 5). 

0110. Evaluate requirements of mobile purification This item was closed during the June 

unit from RRC. 2015 NRC Audit Visit (Reference 5). 

0111. Evaluate requirements of mobile boration unit This item was closed during the June 

from RRC. 2015 NRC Audit Visit (Reference 5). 

0112. Evaluate methods of venting the fuel handling This item was closed during the June 

building. 2015 NRC Audit Visit (Reference 5). 

0113. Evaluate the use of high-efficiency LED This item was closed during the June 

lighting. 2015 NRC Audit Visit (Reference 5). 

0114. Perform evaluation to determine if additional This item was closed during the June 

parameters will need to be monitored during FLEX 2015 NRC Audit Visit (Reference 5). 

activities. 

0115. Perform analysis to ensure survivability of This item was closed during the June 

containment. 2015 NRC Audit Visit (Reference 5). 

0116. Evaluate borated water sources in addition to This item was closed during the June 

safety injection refueling water tank (SIRWT). 2015 NRC Audit Visit (Reference 5). 

0117. Entergy, for the Palisades site, will negotiate This item was closed during the June 

and execute a contract with Strategic Alliance for 2015 NRC Audit Visit (Reference 5). 

FLEX Emergency Response (SAFER) that will meet 

the requirements of NEI 12-06, Section 12. 

011S. Evaluate a location to install a tee in the This item was closed during the June 

Page 6 of 17 
Overall Integrated Plan Open Item Status 

service water system to allow the ultimate heat sink 2015 NRC Audit Visit (Reference 5). 

(UHS) FLEX pump to provide cooling. 

0119. Evaluate the use of lake water to cool the This item was closed during the June 

steam generators during an extended loss of ac 2015 NRC Audit Visit (Reference 5). 

power (ELAP). 

0120. Evaluate time until primary coolant system This item was closed during the June 

(PCS) makeup is necessary in Modes 5 & 6. 2015 NRC Audit Visit (Reference 5). 

0121. Evaluate connection to ensure cooling water This item was closed during the June 

can be provided for containment air fans. 2015 NRC Audit Visit (Reference 5). 

0122. Evaluate the robustness of the charging This item was closed during the June 

pumps. 2015 NRC Audit Visit (Reference 5). 

Interim Staff Evaluation Open Items Status 

3.1.1.2.A Evaluate the impact of potential soil This item was closed during 

liquefaction on deployment of portable FLEX the June 2015 NRC Audit 

equipment. Visit (Reference 5). See 

Section 4 above. 

3.1.1.2.8 Evaluate the potential need for a power source This item was closed during 

to move or deploy the equipment (e.g., to open the June 2015 NRC Audit 

the door from a storage location). Visit (Reference 5). 

3.1.1.3.A Evaluate impacts from large internal flooding This item was closed during 

sources that are not seismically robust and the the June 2015 NRC Audit 

potential impact on the mitigating strategies. Visit (Reference 5). 

3.1.1.3.8 Evaluate the potential for ground water to This item was closed during 

impact the mitigating strategies. the June 2015 NRC Audit 

Visit (Reference 5). 

3.1.5.1.A Evaluate the potential for high temperature This item was closed during 

hazards to impact the functionality of FLEX the June 2015 NRC Audit 

equipment in the FLEX storage facility. Visit (Reference 5). 

3.1.5.3.A Evaluate the potential for high temperature This item was statu sed as 

hazards to impact the deployment of FLEX Open during the June 2015 

equipment. NRC Audit Visit (Reference 

5). See the June 2015 

NRC Audit Visit FLEX 

Related Open Items table 

(below) Audit Item 01 

3.1.5.3.A for status. 

3.2.1.S.A Verify resolution of the generic concern This item was closed during 

associated with the modeling of the timing and the June 2015 NRC Audit 

uniformity of the mixing of a liquid boric acid Visit (Reference 5). 

solution injected into the PCS under natural 

circulation conditions potentially involving twophase flow. 

3.2.1.9.8 Provide additional justification for the alternate This item was closed during 

Page 7 of 17 
approach to NEI 12-06 involving the use of the June 2015 NRC Audit 

installed charging pumps. Visit (Reference 5). See 

Section 4 above. 

Interim Staff Evaluation Confirmatory Items Status 

3.1.3.1.A Confirm that the FLEX storage facility(s) will meet This item was closed 

the plant's design-basis tornado wind speed of 300 during the June 2015 NRC 

mph or will be designed or evaluated equivalent to Audit Visit (Reference 5). 

ASCE 7-10 using a tornado wind speed of 230 

mph with separation and diversity between the 

storage locations. If the method of protection 

chosen is the later, confirm that separation and 

diversity is adequate. 

3.2.1.A Confirm that the operator actions times in the first This item was closed 

20 minutes of the event are adequate and during the June 2015 NRC 

reasonably achievable when the associated ELAP Audit Visit (Reference 5). 

procedures are developed and validated. 

3.2.1.B Confirm the robustness of the charging pump This item was closed 

control circuit or provide FLEX procedure during the June 2015 NRC 

guidance to manually operate the charging pumps Audit Visit (Reference 5). 

by breaker operation. 

3.2.1.C Confirm the seismic robustness of the BAST This item was statused as 

piping to support use of the BAST water as a Open during the June 

supply source for the charging pumps. 2015 NRC Audit Visit 

(Reference 5). See the 

June 2015 NRC Audit Visit 

FLEX Related Open Items 

table (below) Audit Item CI 

3.2.1.C for status. 

3.2.1.0 Confirm the availability and adequacy of a borated This item was closed 

water supply to support the PCS makeup strategy. during the June 2015 NRC 

Audit Visit (Reference 5). 

3.2.1.E Confirm the continued functionality of the This item was closed 

Atmospheric Dump Valves in the context of a during the June 2015 NRC 

tornado missile hazard during an ELAP in order to Audit Visit (Reference 5). 

support a symmetric cooldown. Alternatively, 

address the effects of asymmetric natural 

circulation cooldown. 

3.2.1.F Confirm the ability of any non-safety related This item was statused as 

equipment to function as credited in the mitigation Open during the June 

strategies in accordance with the external event 2015 NRC Audit Visit 

criteria described in NEI-12-06. (Reference 5). See the 

June 2015 NRC Audit Visit 

FLEX Related Open Items 

table (below) Audit Item CI 

3.2.1. F for status. 

3.2.1.1.A Confirm that the use of Combustion Engineering This item was closed 

Page 8 of 17 
Interim Staff Evaluation Confirmatory Items Status 

Nuclear Transient Simulator (CENTS) in the ELAP during the June 2015 

analysis is limited to the flow conditions prior to NRC Audit Visit 

reflux boiling initiation. This confirmation should (Reference 5). 

include a description of the CENTS- calculated 

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

condition when two-phase natural circulation ends 

and reflux boiling initiates. 

3.2.1.2.A Confirm the Primary Coolant Pump (PCP) seal This item was statused as 

leakage rate assumed in the ELAP analysis is Open during the June 

justified. Specifically, if the PCP seal leakage rate 2015 NRC Audit Visit 

used in the plant-specific analysis is less than he (Reference 5). See the 

upper bound expectation for the seal leakage rate June 2015 NRC Audit Visit 

(15 gpm/seal) discussed in the PWROG position FLEX Related Open Items 

paper addressing the PCP seal leakage for table (below) Audit Item CI 

Combustion Engineering plants (ADAMS 3.2.1.2.A for status. 

Accession No. ML 13235A 151, non-publicly 

available), justification should be provided. 

3.2.1.2.B Confirm whether seal failure will occur or not when This item was closed 

subcooling of the coolant in the PCS cold-legs is during the June 2015 NRC 

greater than 50 degrees Fahrenheit (OF). This Audit Visit (Reference 5). 

evaluation should specify the seal leakage flow 

assumed for the ELAP from time zero to the 

timeframe when subcooling in the PCS cold-legs 

decreases to 50°F, and provide justification for the 

assumed leakage rate. 

3.2.1.2.C If the Integrated Plan is changed to credit isolation This item was closed 

of controlled bleed-off (CBO), confirm the during the June 2015 NRC 

assumption that the integrity of the PCP seals can Audit Visit (Reference 5). 

be maintained, and the seal leakage rate is less 

than 1 gpm per PCP during an ELAP before CBO 

is isolated. This evaluation should provide the 

maximum temperature and pressure and minimum 

subcooling of the coolant in the PCS cold- legs 

during the ELAP before CBO isolation. If CBO 

isolation is being assumed, justify the sequence of 

events (SO E) and time constraints so established. 

3.2.1.3.A Confirm the applicability of ANS 5.1-1979 + 2 This item was statused as 

sigma decay heat curve. Open during the June 

2015 NRC Audit Visit 

(Reference 5). See the 

June 2015 NRC Audit Visit 

FLEX Related Open Items 

table (below) Audit Item CI 

3.2.1.3.A for status. 

3.2.1.5.A Confirm the containment temperature, pressure, This item was closed 

and moisture profiles during the ELAP event, and during the June 2015 NRC 

justify the adequacy of the computer Audit Visit (Reference 5). 

codes/methodologies, and assumptions used in 

the analysis. 

Page 9 of 17 
Interim Staff Evaluation Confirmatory Items Status 

3.2.1.5.B Confirm whether further instrumentation is needed This item was closed 

based upon ongoing ELAP evaluations. during the June 2015 NRC 

Audit Visit (Reference 5). 

3.2.1.6.A Complete validation of the SOE timeline. This item was closed 

during the June 2015 NRC 

Audit Visit (Reference 5). 

3.2.1.6.B In the audit process, the licensee has indicated This item was closed 

that an assessment has been performed during the June 2015 NRC 

identifying potential changes to the SOE. Confirm Audit Visit (Reference 5). 

that a final SOE has been developed incorporating 

any identified changes. 

3.2.1.9.A Confirm that the ability to line up portable pumps is This item was closed 

consistent with the times assumed in the final during the June 2015 NRC 

version of the Integrated Plan. Audit Visit (Reference 5). 

3.2.2.A Resolve the discrepancy between the licensee- This item was closed 

determined flow rate of 100 gallons per minute during the June 2015 NRC 

(gpm) SFP spray and the 250 gpm performance Audit Visit (Reference 5). 

attribute of NEI 12-06, Table 0-3. 

3.2.3.A Confirm the plan assumptions for containment This item was closed 

cooling, after completion of the containment during the June 2015 NRC 

response analysis. Audit Visit (Reference 5). 

3.2.4.1.A Confirm whether supplemental cooling is required This item was closed 

for components or systems used in the mitigating during the June 2015 NRC 

strategies plan. Audit Visit (Reference 5). 

3.2.4.1.B Confirm the connection point for the UHS FLEX This item was closed 

Pump to the Service Water System. during the June 2015 NRC 

Audit Visit (Reference 5). 

3.2.4.2.A Confirm the adequacy of the ventilation provided This item was closed 

in the battery room to protect the batteries from during the June 2015 NRC 

the effects of extreme high and low temperatures. Audit Visit (Reference 5). 

3.2.4.2.B Confirm the adequacy of battery room ventilation This item was closed 

to prevent hydrogen accumulation while during the June 2015 NRC 

recharging the batteries in Phase 2 or Phase 3. Audit Visit (Reference 5). 

3.2.4.3.A Confirm whether heat traCing is required for This item was closed 

borated water systems. during the June 2015 NRC 

Audit Visit (Reference 5). 

3.2.4.4.A Confirm that communication enhancements This item was closed 

credited in the NRC's communication assessment during the June 2015 NRC 

{ADAMS Accession No. ML 13129A219) are Audit Visit (Reference 5). 

completed as planned. 

3.2.4.6.A Confirm that habitability limits will be maintained This item was closed 

and/or operator protective measures will be during the June 2015 NRC 

employed in all phases of an ELAP to ensure Audit Visit (Reference 5). 

operators will be capable of FLEX strategy 

execution under adverse temperature conditions. 

Page 10 of 17 
Interim Staff Evaluation Confirmatory Items Status 

3.2.4.7.A Confirm that the evaluation of the CST and T-S1 This item was statused as 

shows that the tank qualification is consistent with Open during the June 

the strategy and the provisions of NEI 12-06. 2015 NRC Audit Visit 

(Reference 5). See the 

June 2015 NRC Audit Visit 

FLEX Related Open Items 

table (below) Audit Item CI 

3.2.4.7.A for status. 

3.2.4.7.8 Confirm that the FLEX Support Guidelines provide This item was closed 

clear criteria for transferring to the next preferred during the June 2015 NRC 

source of water when refilling the CST. Audit Visit (Reference 5). 

3.2.4.10.A Confirm that the load shed calculation verifies This item was closed 

adequate battery capacity with sufficient margin during the June 2015 NRC 

throughout Phase 1 to assure the battery does not Audit Visit (Reference 5). 

get depleted prior to charging, and the results of 

the analysiS are properly integrated into the overall 

strategy. 

3.4.A Confirm that plans for the deployment of portable This item was closed 

equipment used to implement the response during the June 2015 NRC 

conform to the criteria of NEI 12-06, Section 12.2, Audit Visit (Reference 5). 

with regards to considerations 2 through 10. 

Audit Status Completion or 

Question Target Date 

PAL-002 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-003 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1.1.A) 

This item was closed during the June 2015 NRC Audit 

PAL-004 Visit (Reference 5). (Associated with ISE Confirmatory 

Items 3.2.1.2.A, 3.2.1.2.8, 3.2.1 .2.C) 

This item was closed during the June 2015 NRC Audit 

PAL-007 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.4.3.A) 

PAL-OOS This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-011 Visit (Reference 5). (AssOCiated with ISE Confirmatory 

Items 3.2.1.A, 3.2.1.8, 3.2.1.6.8) 

This item was closed during the June 2015 NRC Audit 

PAL-012 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1.3.A) 

PAL-013 This item was closed during the June 2015 NRC Audit 

Page 11 of 17 
Audit Status Completion or 

Question Target Date 

Visit (Reference 5). (Associated with ISE Confirmatory 

Items 3.2.1.5.A, 3.2.1.5.8) 

This item was closed during the June 2015 NRC Audit 

PAL-014 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1.9.A) 

This item was closed during the June 2015 NRC Audit 

PAL-015 Visit (Reference 5). (Associated with ISE Open Item 

3.2.1.8.A) 

PAL-016 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-017 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-018 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.4.1 O.A) 

PAL-019 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-020 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-021 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-022 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-023 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.4.2.A) 

PAL-024 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-025 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.4.2.8) 

PAL-026 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-027 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1.5.8) 

PAL-028 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-030 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1 .6.A) 

PAL-033 This item was closed during the June 2015 NRC Audit 

Page 12 of 17 
Audit Status Completion or 

Question Target Date 

Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.4.1 O.A) 

This item was closed during the June 2015 NRC Audit 

PAL-035 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1.5.8) 

PAL-036 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-037 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-039 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-040 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-041 Visit (Reference 5). (Associated with ISE Open Item 

3.2.1.9.8) 

This item was closed during the June 2015 NRC Audit 

PAL-043 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1.F) 

This item was closed during the June 2015 NRC Audit 

PAL-044 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.4.7.A) 

This item was closed during the June 2015 NRC Audit 

PAL-045 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.4.7.8) 

PAL-046 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-047 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1.C) 

This item was closed during the June 2015 NRC Audit 

PAL-048 Visit (Reference 5).(Associated with ISE Confirmatory 

Item 3.2.1.D) 

PAL-049 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-050 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.3.A) 

PAL-051 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-053 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). (Associated with ISE Confirmatory 

Page 13 of 17 
Audit Status Completion or 

Question Target Date 

Item 3.2.3.A) 

PAL-054 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

This item was closed during the June 2015 NRC Audit 

PAL-055 Visit (Reference 5). (Associated with ISE Confirmatory 

Item 3.2.1.E) 

PAL-056 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

PAL-057 This item was closed during the June 2015 NRC Audit 

Visit (Reference 5). 

NOTE: 

During the June 2015 Audit Visit, additional information related to each Open Item was 

provided to the NRC for review. By the end of the NRC Audit Visit, the NRC verbally had 

statused each open item and indicated what the staff needed to close the Open Items. The 

"Status" column in the table below reflects the current activity in progress to close the Open 

Items. 

June 2015 NRC Audit Visit FLEX Related Open Items 

Audit Item Status 

Reference Item Description (Post Audit) 

01 3.1.5.3.A Evaluate the potential for high Open 

temperature hazards to impact the In progress; expected completion date deployment of FLEX equipment. is October 2015. 

CI3.2.1.C Confirm the seismic robustness of Open 

the BAST piping to support use of Pending NRC review, no further the BAST water as a supply source Entergy action required. for the charging pumps. 

CI3.2.1.F Confirm the ability of any non-safety Open 

related equipment to function as Pending NRC review, no further credited in the mitigation strategies Entergy action required. in accordance with the external 

event criteria described in 

NEI-12-06. 

CI 3.2.1.2.A Confirm the Primary Coolant Pump Open 

(PCP) seal leakage rate assumed in The Palisades FLEX strategy is the ELAP analysis is justified. consistent with the current CENTS Specifically, if the PCP seal leakage Analysis (CN-SEE-II-13-5, Rev. 1) with rate used in the plant-specific respect to the timing and flow rate at analysis is less than the upper which PCS makeup is required to bound expectation for the seal maintain single phase natural leakage rate (15 gpm/seal) circulation and for achieving adequate discussed in the PWROG position 

Page 14 of 17 
June 2015 NRC Audit Visit FLEX Related Open Items 

Audit Item Status 

Reference Item Description (Post Audit) 

paper addressing the PCP seal shutdown margin through PCS 

leakage for Combustion boration. The CENTS analysis 

Engineering plants (ADAMS assumes an initial PCP seal leakage 

Accession No. ML13235A151, non- rate of 15 gpm/pump. Consistent with 

publicly available), justification this analysis, the Palisades strategy 

should be provided. assumes an initial PCP seal leakage 

rate of 15 gpm/pump for the 

determining time at which PCS makeup 

is required, but does not assume this 

leakage rate indefinitely. 

New analysis by Flowserve (PCP Seal 

Vendor) has been performed that 

determines a new PCP seal leakage 

rate of 1.5 gpm is applicable to 

Palisades. Following NRC endorsement 

of this FlowServe analysis, Palisades 

will review the analysis to ensure 

applicability to the installed seals. Once 

it is determined that the new Flowserve 

analysis is applicable to the installed 

seals, Palisades may pursue a revision 

to the CENTS analysis which uses the 

seal leakage rate of 1.5 gpm/pump as 

opposed 15 gpm/pump used in the 

current analysis. If credited, the new 

CENTS analysis will provide additional 

margin in the timeline for establishing 

PCS makeup. 

CI 3.2.1.3.A Confirm the applicability of ANS 5.1- Open 

1979 + 2 sigma decay heat curve. Pending NRC review, no further 

Entergy action required. 

CI3.2.4.7.A Confirm that the evaluation of the Open (Reference Entergy Correction 

CST and T-81 shows that the tank Action CR-PLP-2015-02482, CA-12) 

qualification is consistent with the In progress; expected completion date strategy and the provisions of NEI is October 2015. 12-06. 

Additionally, see Section 4 for 

justification of the alternate approach 

for meeting the Order for T-81 Missile 

Shielding. 

Palisades recognizes that T-81 is not 

fully protected from missile hazards, 

which means relying on the tanks could 

be an alternative to NEI 12-06. The 

following steps are being taken as 

justification for this alternate approach. 

Page 15 of 17 
June 2015 NRC Audit Visit FLEX Related Open Items 

Audit Item Status 

Reference Item Description (Post Audit) 

- EC 48187 has been revised (ECN 

56234) to prevent chemical totes 

T-989, T-990, and a resin storage 

cask from becoming air-borne during 

a BDBEE and striking T-81. A 

whitepaper that documents the 

walkdown preceding ECN 56234 

showing all items evaluated as 

potential missiles will be posted to 

the NRC ePortal for review. 

- AOP-38 (Acts of Nature) is being 

revised to ensure that all potential 

transient missile hazards are 

removed from T-81 proximity in the 

event tornado/wind conditions of 

sufficient magnitude are imminent. 

- FSG-6 (Alternate CST Makeup) is 

being revised to address the need to 

perform one of the compensatory 

actions to line up alternate water 

makeup sources within 

approximately 4 hours if T-81 were 

found to be structurally compromised 

(e.g., use EOP Supplement 31, 

"Supply AFW Pumps From Alternate 

Sources" or FIG- 6, "Filling T-2 (CST) 

From Fire Header"). 

1-E Provide a detailed discussion on the Open (Reference Entergy Correction 

capability of equipment (in Action CR-PLP-2015-02482, CA-24) 

containment, the auxiliary building In progress; expected completion date (TDAFW pump room), the main is October 2015. control room, the electrical 

switchgear rooms, and the ADV 

rooms in particular) to perform their 

expected functions under ELAP 

conditions (Le., temperature, 

pressure, radiation, humidity, etc.) 

for an indefinite period 

7 Potential Interim Staff Evaluation Impacts 

There are no additional potential impacts to the Interim Staff Evaluation since the last status 

report identified at this time. 

Page 16 of 17 
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 2013-010, Overall Integrated Plan 

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

Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events (Order 

Number EA-12-049), dated February 28,2013 (ADAMS Accession No. ML 13246A399) 

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

Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events, dated 

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

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

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

MF0768), dated February 10, 2014 (ADAMS Accession No.ML13365A264) 

4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2015-007, Palisades Nuclear Plant 

Fourth Six-Month Status Report in Response to March 12,2012 Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation Strategies for 

8eyond-Design-8asis External Events (Order Number EA-12-049), dated February 27, 

2015 (ADAMS Accession No. ML 15062A011) 

5. Palisades Nuclear Plant - Plan for the Onsite Audit Regarding Implementation of 

Mitigating Strategies and Reliable Spent Fuel Instrumentation Related To Orders 

EA-12-049 and EA-12-051 (TAC NOS. MF0768 and MF0769), dated April 22, 2015 

(ML 1511 OA051) 

6. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, 

Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 

8eyond-Design-8asis External Events, Revision 0, dated August 29,2012 (ADAMS 

Accession No. ML 12229A174) 

7. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, 

Revision 0, dated August 2012 (ADAMS Accession No. ML 12242A378) 

Page 17 of 17