UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

Vice President, Operations 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, Ml 49043-9530 

October 13, 2015 

SUBJECT: PALISADES NUCLEAR PLANT - REPORT FOR THE AUDIT REGARDING 

IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT 

FUEL POOL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND 

EA-12-051 (TAC NOS. MF0768 AND MF0769) 

Dear Sir or Madam: 

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, 

"Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for 

Beyond Design-Basis External Events" and Order EA-12-051, "Issuance of Order to Modify 

Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents 

Access and Management System (ADAMS) Accession Nos. ML 12054A736 and ML 12054A679, 

respectively). The orders require holders of operating reactor licenses and construction permits 

issued under Title 1 O of the Code of Federal Regulations Part 50 to submit for review, Overall 

Integrated Plans (OIPs) including descriptions of how compliance with the requirements of 

Attachment 2 of each order will be achieved. 

By letter dated February 28, 2013 (ADAMS Accession No. ML 13060A361 ), Entergy Nuclear 

Operations, Inc. (Entergy, the licensee) submitted its OIP for Palisades Nuclear Plant 

(Palisades) in response to Order EA-12-049. By letters dated August 28, 2013, February 28, 

2014, August 28, 2014, February 27, 2015 and August 28, 2015 (ADAMS Accession Nos. 

ML13241A234, ML14059A078, ML14240A279, ML15062A011 and ML15240A074, 

respectively), the licensee submitted its first five six-month updates to the OIP. By letter dated 

August 28, 2013 (ADAMS Accession No. ML 13234A503), the NRC notified all licensees and 

construction permit holders that the staff is conducting audits of their responses to Order 

EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office 

Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit 

process led to the issuance of the Palisades interim staff evaluation (ISE) (ADAMS Accession 

No. ML 13365A261) on February 10, 2014, and continues with in-office and onsite portions of 

this audit. 

By letter dated February 28, 2013 (ADAMS Accession No. ML 13060A360), the licensee 

submitted its OIP for Palisades in response to Order EA-12-051. By e-mail dated July 18, 2013 

(ADAMS Accession No. ML 13200A328), the NRC staff sent a request for additional information 

(RAI) to the licensee. By letters dated August 19, 2013, August 28, 2013, February 28, 2014, 

August 28, 2014, February 27, 2015 and August 28, 2015 (ADAMS Accession Nos. 

ML 13231A126, ML 13241A235, ML 14059A078, ML 14240A278, ML 15062A056 and 

ML 15240A07 4, respectively), the licensee submitted its RAI responses and first five six-month 

updates to the OIP. The NRC staff's review to date led to the issuance of the Palisades ISE 
- 2 -

March 26, 2014 (ADAMS Accession No. ML 14083A620), the NRC notified all licensees and 

construction permit holders that the staff is conducting in-office and onsite audits of their 

responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as 

discussed above. 

The ongoing audits allow the staff to review open and confirmatory items from the mitigation 

strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the 

licensee's integrated plans, and other audit questions. Additionally, the staff gains a better 

understanding of submitted and updated information, audit information provided on ePortals, 

and preliminary Overall Program Documents/Final Integrated Plans while identifying additional 

information necessary for the licensee to supplement its plan and staff potential concerns. 

In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff 

conducted an onsite audit at Palisades from June 15 - 18, 2015, per the audit plan dated April 

22, 2015 {ADAMS Accession No. ML 1511 OA051 ). The purpose of the onsite portion of the 

audit was to provide the NRC staff the opportunity to continue the audit review and gain key 

insights most easily obtained at the plant as to whether the licensee is on the correct path for 

compliance with the Mitigation Strategies and SFPI orders. The onsite activities included 

detailed analysis and calculation discussions, walk-throughs of strategies and equipment 

laydown, visualization of portable equipment storage and deployment, review of staging and 

deployment of offsite equipment, and review of installation details for SFPI equipment. 

The enclosed audit report provides a summary of the activities for the onsite audit portion. 

Additionally, this report contains an attachment listing all open audit items currently under NRC 

staff review. 
- 3 -

If you have any questions, please contact me at 301-415-3204 or by e-mail at 

John.Hughey@nrc.gov. 

Docket No.: 50-255 

Enclosure: 

Audit plan 

cc w/encl: Distribution via Listserv 

Sincerely, 

John D. Hughey, Project Manager 

Orders Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION 

RELATED TO ORDERS EA-12-049 AND EA-12-051 MODIFYING LICENSES 

WITH REGARD TO REQUIREMENTS FOR 

MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 

AND RELIABLE SPENT FUEL POOL INSTRUMENTATION 

ENTERGY NUCLEAR OPERATIONS, INC 

PALISADES NUCLEAR PLANT 

DOCKET NO. 50-255 

BACKGROUND AND AUDIT BASIS 

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, 

"Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for 

Beyond Design-Basis External Events" and Order EA-12-051, "Issuance of Order to Modify 

Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents 

Access and Management System (ADAMS) Accession Nos. ML 12054A736 and ML 12054A679, 

respectively). Order EA-12-049 directs licensees to develop, implement, and maintain guidance 

and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) 

cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Order 

EA-12-051 requires, in part, that all operating reactor sites have a reliable means of remotely 

monitoring wide-range SFP levels to support effective prioritization of event mitigation and 

recovery actions in the event of a BDBEE. The orders require holders of operating reactor 

licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 

50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how 

compliance with the requirements of Attachment 2 of each order will be achieved. 

By letter dated February 28, 2013 (ADAMS Accession No. ML 13060A361 ), Entergy Nuclear 

Operations, Inc. (Entergy, the licensee) submitted its OIP for Palisades Nuclear Plant 

(Palisades) in response to Order EA-12-049. By letters dated August 28, 2013, February 28, 

2014, August 28, 2014, February 27, 2015 and August 28, 2015 (ADAMS Accession Nos. 

ML 13241A234, ML 14059A078, ML 14240A279, ML 15062A011 and ML 1520A053, respectively), 

the licensee submitted its first five six-month updates to the OIP. By letter dated August 28, 

2013 (ADAMS Accession No. ML 13234A503), the NRC notified all licensees and construction 

Enclosure 
- 2 -

permit holders that the staff is conducting audits of their responses to Order EA-12-049 in 

accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, 

"Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the 

issuance of the Palisades interim staff evaluation (ISE) (ADAMS Accession No. ML 13365A261) 

on February 10, 2014, and continues with in-office and onsite portions of this audit. 

By letter dated February 28, 2013 (ADAMS Accession No. ML 13060A360), the licensee 

submitted its OIP for Palisades in response to Order EA-12-051. By e-mail dated July 18, 2013 

(ADAMS Accession No. ML 13200A328), the NRC staff sent a request for additional information 

(RAI) to the licensee. By letters dated August 19, 2013, August 28, 2013, February 28, 2014, 

August 28, 2014, February 27, 2015 and August 28, 2015 (ADAMS Accession Nos. 

ML 13231A126, ML 13241A235, ML 14059A078, ML 14240A278, ML 15062A056 and 

ML 15240A074, respectively), the licensee submitted its RAI responses and first five six-month 

updates to the OIP. The NRC staff's review to date led to the issuance of the Palisades ISE 

and RAI dated November 26, 2013 (ADAMS Accession No. ML 13312A423). By letter dated 

March 26, 2014 (ADAMS Accession No. ML 14083A620), the NRC notified all licensees and 

construction permit holders that the staff is conducting in-office and onsite audits of their 

responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as 

discussed above. 

The ongoing audits allow the staff to review open and confirmatory items from the mitigation 

strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the 

licensee's integrated plans, and other audit questions. Additionally, the staff gains a better 

understanding of submitted and updated information, audit information provided on ePortals, 

and preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs) while 

identifying additional information necessary for the licensee to supplement its plan and address 

staff potential concerns. 

In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff 

conducted an onsite audit at Palisades from June 15 - 18, 2015, per the audit plan dated April 

22, 2015 (ADAMS Accession No. ML15110A051). The purpose of the onsite portion of the 

audit was to provide the NRC staff the opportunity to continue the audit review and gain key 

insights most easily obtained at the plant as to whether the licensee is on the correct path for 

compliance with the Mitigation Strategies and SFPI orders. The onsite activities included 

detailed analysis and calculation discussion, walk-throughs of strategies and equipment 

laydown, visualization of portable equipment storage and deployment, review of staging and 

deployment of offsite equipment, and review of installation details for SFPI equipment. 

Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs, 

as supplemented; the resulting site-specific OPDs/FIPs; and, as appropriate, other licensee 

submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a 

safety determination using the Nuclear Energy Institute (NEI) developed guidance document 

NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," issued in 

August 2012 (ADAMS Accession No. ML 12242A378), as endorsed, by NRC Japan 

Lessons-Learned Directorate (JLD) interim staff guidance (ISG) 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"' (ADAMS Accession No. ML 12229A174). 

For Order EA-12-051, the staff will make a safety determination using the NEI developed 
- 3 -

guidance document NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order 

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

(ADAMS Accession No. ML 12240A307), as endorsed, with exceptions and clarifications, by 

NRC ISG JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool 

Instrumentation"' (ADAMS Accession No. ML 12221A339), as providing one acceptable means 

of meeting the order requirements. Should the licensee propose an alternative strategy for 

compliance, additional staff review will be required to evaluate the alternative strategy in 

reference to the applicable order. 

AUDIT ACTIVITIES 

The onsite audit was conducted at the Palisades facility from June 15, 2015, through June 18, 

2015. The NRC audit team staff was as follows: 

Title Team Member Organization 

T earn Lead/Project Manager John Hughey NRR/JLD 

Technical Support- Electrical Matthew NRR/JLD 

McConnell 

Technical Support- Reactor Joshua Miller NRR/JLD 

Systems 

Technical Support - Balance of Plant Kevin Roche NRR/JLD 

Technical Support - SFPI Khoi Nguyen NRR/JLD 

Observer Bruce Bartlett Region 111/DRP 

Management Observer Mandy Halter NRR/JLD 

The NRC staff executed the onsite portion of the audit per the three part approach discussed in 

the April 22, 2015, plan, to include conducting a tabletop discussion of the site's integrated 

mitigating strategies compliance program, a review of specific technical review items, and 

discussion of specific program topics. Activities that were planned to support the above 

included detailed analysis and calculation discussions, walk-throughs of strategies and 

equipment laydown, visualization of portable equipment storage and deployment, staging and 

deployment of offsite equipment, and physical sizing and placement of SFPI equipment. 

AUDIT SUMMARY 

1.0 Entrance Meeting (June 15. 2015) 

At the onsite audit entrance meeting, the NRC staff audit team introduced itself followed 

by introductions from the licensee's staff. The NRC audit team provided a brief overview 

of the audit's objectives and anticipated schedule. 

2.0 Integrated Mitigating Strategies Compliance Program Overview 

Per the audit plan and as an introduction to the site's program, the licensee provided a 

presentation to the NRC audit team describing the site's strategies to meet the NRC 

orders. The licensee presented a review of its strategy to maintain core cooling, 

containment, and SFP cooling in the event of a BDBEE, and the plant modifications 
- 4 -

being done in order to implement the strategies. Also reviewed were the design and 

location of the storage facilities for the FLEX equipment, the interface with the National 

SAFER [Strategic Alliance for FLEX Emergency Response] Response Centers 

(NSRCs), and the SFPI modification. 

3.0 Onsite Audit Technical Discussion Topics 

Based on the audit plan, and with a particular emphasis on the Part 2 "Specific Technical 

Review Items," the NRC staff technical reviewers conducted interviews with licensee 

technical staff, site walk-downs, and detailed document review for the items listed in the 

plan. Results of these technical reviews and any additional review items needed from 

the licensee are documented in the audit item status table in Attachment 3, as discussed 

in the Conclusion Section below. 

3.1 Reactor Systems Technical Discussions and Walk-Downs 

The NRC staff met with licensee staff to discuss the amount of leakage from the reactor 

coolant pump (RCP) seals, the timing of the injection of borated water into the reactor 

coolant system (RCS), and the availability of water sources. The NRC staff reviewed the 

analyses and flow calculations along with applicable procedures including the plant 

parameters that will be monitored to determine whether adequate core cooling is being 

provided. The NRC staff also walked down the licensee's strategies and reviewed plant 

procedures for implementing the core cooling and makeup strategies. The NRC staff 

also reviewed Palisades' modeling of an extended loss of alternating current power 

(ELAP) event and its ability to mitigate the event, including the computer code used and 

input parameters for the ELAP analysis. 

3.2 Electrical Technical Discussions and Walk-Downs 

The NRC staff reviewed the calculations regarding battery life and FLEX generating 

sizing. The NRC staff walked down the procedures for electrical load shedding to 

evaluate feasibility. The NRC staff also walked down the diesel-driven auxiliary 

feedwater pump room, battery rooms and control room envelope to evaluate strategies 

for hydrogen control and temperature control due to the presence of heat generating 

electrical equipment. The NRC staff reviewed the isolation and interactions of electrical 

power sources regarding the protection of class 1 E equipment from faults in portable 

FLEX equipment and the design elements that ensure multiple electrical sources do not 

attempt to simultaneously power electrical buses. The NRC staff also walked down 

panels used for load shedding to evaluate feasibility and timing. Lastly, the NRC staff 

conducted a walk-through of portable FLEX diesel generator procedures, to include 

power pathways, areas where manual actions are required, and electrical isolation. 
- 5 -

3.3 SFPI Technical Discussions and Walk-Downs 

The NRC staff walked down instrument, transmitter, electronics, and display locations for 

the SFP level instrumentation, along with the associated cable runs. In addition, the 

NRC staff noted that the licensee had completed design calculations and drawings 

detailing the installation of the SFPI components as well as the associated calibration, 

maintenance and test procedures. 

The NRC staff also identified that recently identified failures of the SFPI equipment 

required reevaluation of the SFPI equipment qualification. Given the generic nature of 

this issue, it was addressed by the SFPI vendor (MOHR Test and Measurement, LLC). 

3.4 FLEX Equipment Storage Configuration Discussion Areas and Walk-Downs 

The Palisades FLEX storage configuration utilizes two storage locations; one located 

inside the protected area (PA) and one located outside the PA. FLEX storage building A 

is located inside the PA and protects FLEX equipment from extreme temperature, 

probable maximum flooding and seismic BDBEE. FLEX storage building B is located 

outside the PA and protects the FLEX equipment from extreme temperatures, probable 

maximum flooding and high wind BDBEE, including tornado missiles. FLEX building B 

itself protects against seismic BDBEE. However, liquefaction concerns due to a seismic 

BDBEE were identified for the equipment haul path areas between FLEX building B and 

the PA. Therefore, FLEX equipment stored in FLEX building B cannot be credited for 

successful deployment into the PA staging areas in a seismic BDBEE. 

In NEI 12-06, Rev. 0, Section 11.3.3 states the following: 

FLEX mitigation equipment should be stored in a location or 

locations informed by evaluations performed per Sections 5 

through 9 such that no one external event can reasonably fail the 

site FLEX capability (N). 

In NEI 12-06, Rev. 0, Section 10.1, "Aggregation of FLEX Strategies," includes the 

following: 

Provision of at least N+ 1 sets of portable on-site equipment stored 

in diverse locations or in structures designed to reasonably protect 

from applicable BDBEEs is essential to provide reasonable 

assurance that N sets of FLEX equipment will remain deployable 

to assure success of the FLEX strategies. 

Per the guidance above, it is essential to reasonably protect N+ 1 sets of FLEX 

equipment from all applicable BDBEEs to reasonably assure that N sets (FLEX 

capability, per section 11.3.3) will remain deployable after the BDBEE. 

The Palisades FLEX storage configuration utilizes both storage locations to protect a 

total of N sets of FLEX equipment from all hazards. Section 4 of the Palisades fifth 
- 6 -

6-Month Update (ADAMS Accession No. ML 15240A053) identifies the FLEX storage 

configuration as an Alternative to NEI 12-06, Rev. 0. The alternative approach does not 

protect N+ 1 FLEX equipment from all applicable BDBEE hazards as stipulated in 

Section 10.1 of the guidance. Thus, when a piece of FLEX equipment is out of service, 

the site capability is less than N. 

The FLEX unavailability time allowance of 90 days (NEI 12-06, Rev. 0, Section 11.5.3.b) 

is predicated on protection of N+ 1 sets of equipment such that site capability is still N 

when one piece of FLEX equipment is unavailable. Therefore, the 90 day unavailability 

allowance is not applicable to the Palisades FLEX storage configuration. Entergy is 

requested to propose and justify a reduced unavailability allowance time commensurate 

with the Palisades FLEX storage configuration alternative. See additional information 

with associated audit item 12-E in Attachment 3. 

3.5 Other Technical Discussion Areas and Walk-Downs 

a. The NRC staff reviewed the licensee's plans to ensure adequate communications, 

lighting, personnel access, and equipment access, to successfully implement the 

strategies. The staff interviewed plant personnel responsible for these areas, and 

observed lighting and communication needs during plant walkdowns. 

b. The NRC staff reviewed the Palisades SAFER Response Plan, which describes the 

coordination with the NSRC and State authorities to provide and facilitate delivery of 

phase 3 portable equipment and commodities. During the NRC Audit, the NRC staff 

requested that Palisades submit evidence of the ability to obtain offsite support 

during an ELAP (e.g., fuel, equipment and personnel transport, food, etc.). 

Palisades added a corrective action to the corrective action program to develop a 

BDBEE response plan to address this request. (Reference corrective actions CRPLP-2015-02482 CA-32 and CA-33.) 

c. The NRC staff walked down the licensee's strategy for ventilating the control room 

envelope, battery room and turbine-driven auxiliary feedwater pump room to ensure 

equipment reliability and personnel habitability. 

d. The NRC staff reviewed the strategy that will be implemented by the licensee to 

refuel the portable diesel-powered FLEX equipment. The NRC staff reviewed the 

instructions for refueling the equipment, as well as the equipment needed to perform 

the refueling. The staff noted that the licensee's controls for ensuring adequate fuel 

quality will be addressed in the Palisades FLEX maintenance and testing program. 

e. The NRC staff confirmed that implementation of the Palisades FLEX maintenance 

and testing program is in progress. During the onsite audit, the licensee generated a 

corrective action (CR-PLP-2015-02482 CA-7) in the Palisades corrective action 

program to ensure consideration of the Electric Power Research Institute Templates, 

Manufacturer Recommendations and to utilize standard plant preventive 

maintenance (PM) processes when developing the maintenance and testing PMs for 
- 7 -

FLEX equipment. The corrective action also included language to ensure that 

acceptance criteria and shelf life of FLEX equipment components (e.g., a-rings, 

gaskets, batteries, etc.) are included in the PMs. 

f. The NRG staff confirmed that the deployment path and debris removal evaluations 

adequately justified the site capability to deploy FLEX equipment to mitigate the 

applicable BDBEEs inside the PA. The alternative FLEX storage configuration 

described in Section 3.4 of this report addresses liquefaction concerns regarding the 

deployment path outside of the PA. 

g. The NRG staff noted that the licensee completed FLEX training for Non-Licensed 

Operators, Licensed Operators, and Emergency Response Organization decision 

makers. Simulator training was utilized to validate timelines for FLEX strategy 

implementation. Gap training will be performed to address any differences between 

draft and approved FLEX procedures before they are issued and periodic, on-going 

FLEX training has been established. 

h. The potential for extreme temperature hazards to impact the storage and deployment 

of FLEX equipment was reviewed. During the ongoing audit process, the NRG staff 

requested that Palisades identify the maximum and minimum ambient operating and 

storage temperatures for the FLEX equipment that will be deployed and confirm that 

these temperatures are bounded by the maximum/minimum ambient temperature for 

the Palisades site/storage locations. See additional information with associated audit 

item 01 3.1.5.3.A in Attachment 3. 

i. The NRG staff reviewed the licensee's planned routes for SFP and reactor core 

cooling hoses through a portion of the turbine building. The Palisades FLEX 

evaluation report PLP-RPT-13-00050, "Turbine Driven Auxiliary Feedwater (TDAFW) 

Upgrade and Evaluation for FLEX," Rev. 0, refers to section 5.7.3.1.2 of the 

Palisades Final Safety Analysis Report to support its position that the turbine building 

will not collapse following a seismic event. During the on-going audit process, the 

NRG staff requested that Palisades determine if additional hose is available to 

bypass the turbine building, if necessary. See additional information with associated 

audit item Cl 3.2.1.F in Attachment 3. 

j. Palisades identified procedural actions to remove missile hazards from the zone of 

influence as an alternate approach to the guidance in NEI 12-06 regarding alternate 

water sources. Palisades initiated corrective action CR-PLP-2015-02482 CA-12 to 

track the completion of the actions required to implement this alternative. During the 

on-going audit process, the NRG staff requested that Palisades provide the text of 

this initiated corrective action item. See additional information with associated audit 

item Cl 3.2.7.A in Attachment 3. 
- 8 -

4.0 Exit Meeting (June 18, 2015) 

The NRC staff audit team conducted an exit meeting with licensee staff following the 

closure of onsite audit activities. The NRC staff highlighted items reviewed and noted 

that the results of the onsite audit trip will be documented in this report. The NRC staff 

also discussed the remaining open items with the licensee and information needed for 

closure. The outstanding open items are listed in Attachment 3 of this report. 

CONCLUSION 

The NRC staff completed all three parts of the April 22, 2015, onsite audit plan. The audit items 

referenced in Part 2 of the plan were reviewed by NRC staff members while on site. In addition 

to the list of NRC and licensee onsite audit staff participants in Attachment 1, Attachment 2 

provides a list of documents reviewed during the onsite audit portion. 

In support of the continuing audit process as the licensee proceeds towards orders compliance 

for this site, Attachment 3 provides the status of all open audit review items that the NRC staff is 

evaluating in anticipation of issuance of a combined safety evaluation (SE) for both the 

Mitigation Strategies (MS) and SFPI orders. The five sources for the audit items referenced 

below are as follows: 

a. ISE Open Items (Ols) and Confirmatory Items (Cls) 

b. Audit Questions (AQs) 

c. Licensee-identified OIP Ols 

d. SFPI RAls 

e. Additional SE needed information 

The attachments provide audit information as follows: 

a. Attachment 1: List of NRC staff and licensee staff audit participants 

b. Attachment 2: List of documents reviewed during the onsite audit 

c. Attachment 3: MS/SFPI SE Audit Items currently under NRC staff review 

(licensee input needed, as noted) 

While this report notes the completion of the onsite portion of the audit per the audit plan dated 

April 22, 2015, the ongoing audit process continues, as per the letters dated August 28, 2013, 

and March 26, 2014, to all licensees and construction permit holders for both orders. 
- 9 -

Additionally, while Attachment 3 provides a list of currently open items, the status and progress 

of the NRC staff's review may change based on licensee plan changes, resolution of generic 

issues, and other NRC staff concerns not previously documented. Changes in the NRC staff 

review will be communicated in the ongoing audit process. 

Attachments: 

1. NRC and Licensee Staff Onsite Audit Participants 

2. Onsite Audit Documents Reviewed 

3. MS/SFPI Audit Items currently under NRC staff review 
Onsite Audit Participants 

NRC Staff: 

John Hughey NRR/JLD/JOMB Joshua Miller NRR/JLD/JERB 

KhoiNguyen NRR/JLD/JERB Bruce Bartlett Region 111/DRP 

Matthew McConnell NRR/JLD/JERB Mandy Halter NRR/JLD 

Kevin Roche NRR/JLD/JCBB 

Palisades Staff: 

Kevin O'Connor DesiQn EnQineerinQ 

Brian Sova Design Engineering 

Adam Bono Design Engineering 

Kirk Cramer DesiQn EnQineerinQ 

Greg Hubers Design Engineering 

Al Lyon DesiQn EnQineerinQ 

Dan G. Malone EmerQencv Planning 

Tim Horan Emergency Planning 

Thom HiQinbotham Emerqencv Planning 

Jeff Hardy Licensing 

Jeff Erickson Licensing 

Jim Miksa LicensinQ 

Bob Tucker Operations 

Bill Townes Operations 

Paul Rhodes Operations 

Vern Jorgensen Projects 

Diana Fried Projects 

Bob Hamm Projects 

Robert Kaup Projects 

Darrel Turner Projects 

Tom McCarthy Project Support 

Kevin Bessel! Project Support 

Brian GereQ Project Support 

Kevin Homan Project Support 

Margot Wilson Project Support 

Brian Norman Project Support 

Mike Cymbor Project Support 

Matt Rohrer Enterav Corporate Support 

Dave Stallings Entergy Corporate Support 

David Viener EnterQY Corporate Support 

Alvin Robertson Pressurized Water Reactors Owners Group 

Attachment 1 
Documents Reviewed 

• Calculation CN-SEE-11-12-42, "Determination of the Time to Boil in the Palisades 

Nuclear Plants Spent Fuel Pools after Earthquake," Rev. 0. 

• Calculation EA-EC46465-02, "PLP MAAP4 Containment Analysis for BDBEE," Rev. 0. 

• Calculation EA-ELEC-LDTAB-021, "Station Batteries ED-01 & ED-02 FLEX Coping 

Capability," Rev. 0. 

• Calculation EA-ELEC-LDTAB-022, "PLP FLEX Diesel Sizing Calculation," Rev. 0. 

• Calculation EA-GOTHIC-AFW-01, "Auxiliary Feedwater Pump Room Heat Up 

Analysis," Rev. 0. 

• Calculation EA-EC46465-03, "Control Room Heatup for Extended Loss of AC Power," 

Rev. 0. 

• Calculation EC 46465-06, "Hydraulic Analysis of FLEX Coping Strategies,'' Rev 0. 

• Calculation EC 46465-09, "Evaluation of the ADV Air Requirements for FLEX Event,'' 

Rev. 0. 

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

• Calculation EA-EC46466-02, "Qualification of SFP Instrumentation Mounting Details," 

Rev. 0. 

• Calculation NAl-1791-006, "Seismic Induced Hydraulic Response in the Palisades 

Spent Fuel Pool," Rev. 0. 

• DBD[Design Basis Document ]-7.01, "Entergy Nuclear Northeast Palisades Design 

Basis Document for Electrical Equipment Qualification Program," Rev. 10. 

• DBD-1.07, "Entergy Nuclear Northeast Palisades Design Basis Document for Auxiliary 

Building HVAC Systems," Rev. 5. 

• Drawing WD 950, "Single Line Meter and Relay Diagram," Sheet A, Rev. 6. 

• Engineering Analysis EA-JEF-97-01, "Operation of Charging Pumps P-55B & C 

without CCW flow to the oil coolers," Rev 0. 

• Engineering Change EC 46465, "FLEX Basis," Rev 0. 

• Engineering Change EC46465 Topic Notes Attachment 9.3.3 (pages 12 -14), "Phase 

2 Electrical Evaluations." 

• Engineering Change EA-EC46465-03, "Control Room Heatup for Extended Loss of AC 

Power,'' Rev. 0. 

• Engineering Change EC 46465-08, "Freezing of Coolant Sources for FLEX Event." 

Rev. 4. 

• Engineering Change EC 46466, "Design Input Record," Rev. 0. 

• Evaluation No. EA-SC-94-004-02, "Evaluation of Tubing and Supports," Rev. 1. 

• FLEX Implementation Guide (FIG)-1, "FLEX Generator Staging and Operation," Rev. 

D. 

• FIG-6, "Filling the T-2 (CST [condensate storage tank]) from the Fire Header," Rev. B. 

• FIG-8, "FLEX Alternate Ventilation," Rev. C. 

• FIG-10, "Fuel Oil Transfer,'' Rev. C. 

• FIG-12, "4160 VAC Generator - Phase 3," .Rev. A 

• FSG-4, "ELAP DC Load Shed and Management," Rev. D. 

• FSG-5, "Initial Assessment and FLEX Equipment Staging," Rev. D. 

• FSG-6, "Alternate CST (T-2) Makeup," Rev. D. 

Attachment 2 
- 2 -

• FSG-7, "Loss of Vital Instrument or Control Power," Rev. F. 

• FSG-11, "Alternate SFP Makeup and Cooling," Rev. B. 

• Palisades FLEX evaluation report PLP-RPT-13-00050, "Turbine Driven Auxiliary 

Feedwater (TDAFW) Upgrade and Evaluation for FLEX," Rev. 0. 

• Palisades FLEX evaluation report PLP-RPT-13-00051, "Boric Acid Storage Tank 

(BAST) Suction Piping and Component Evaluation for FLEX," Rev. 0. 

• Palisades procedure EOP-3.0, "Station Blackout Recovery," Rev. 16. 

• Palisades site specific report NAl-1791-006, "Seismic Induced Hydraulic Response in 

the Palisades Spent Fuel Pool," Rev. 0. 

• Work Order-Task#/Package Type: 00374145-04- Level-2 Package. 

• Work Order-Task#/Package Type: 00374145-04- Level-2 Package-EB19. 

• Work Order-Task#/Package Type: 00374147-04 - Level-2 Package. 

• Work Order-Task#/Package Type: 00374147-04- Level-2 Package - EB-20. 
Palisades 

Mitigation Strategies/Spent Fuel Pool Instrumentation Safety Evaluation Audit Items: 

Audit Items Currently Under NRC Staff Review, Requiring Licensee Input As Noted 

Audit Item Item Description Licensee Input Needed Reference 

Identify the maximum and minim

operating and storage tempera

ISE 01 3.1.5.3.A Evaluate the potential for high temperature hazards to equipment that will be deployed 

impact the deployment of FLEX equipment. these temperatures are bounde

maximum/minimum ambient te

Palisades site/storage locations

Confirm the ability of any non-safety related equipment 

ISE Cl 3.2.1.F to function as credited in the mitigation strategies in Palisades is requested to deter

accordance with the external event criteria described in hose is available to bypass the 

NEl-12-06. 

Confirm that the evaluation of the CST and T-81 shows Palisades is requested to provi

ISE Cl 3.2.4. 7.A that the tank qualification is consistent with the strategy 

and the provisions of NEI 12-06. corrective action CR-PLP-2015

Entergy is requested to propos

Justify a FLEX equipment allowed unavailability time reduced unavailability allowanc

SE #12 associated with the proposed FLEX equipment storage commensurate with the Palisad

configuration alternative to NEI 12-06. configuration alternative. 
- 3 -

If you have any questions, please contact me at 301-415-3204 or by e-mail at 

John. H ughey@nrc.gov. 

Docket No.: 50-255 

Enclosure: 

Audit plan 

cc w/encl: Distribution via Listserv 

DISTRIBUTION: 

PUBLIC 

JOMB R/F 

RidsNrrDorlLpl 3-1 Resource 

RidsNrrPMPalisades Resource 

RidsNrrLASLent Resource 

BTitus, NRR/JLD 

Sincerely, 

IRA! 

John D. Hughey, Project Manager 

Orders Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 

RidsRgn3MailCenter Resource 

JHughey, NRR/JLD 

MHalter, NRR/JLD 

RidsAcrsAcnw_MailCTR Resource 

SBailey, NRR/JLD 

ADAMS Accession No. ML 15272A324 

OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NRR/JLD/JCBB/BC(A) NRR/JLD/JERB/BC 

NAME JHughey Slent BTitus SBailey 

DATE 10/6/2015 09/30/2015 10/6/2015 10/6/2015 

OFFICE NRR/JLD/JOMB/BC(A) NRR/JLD/JOMB/PM 

NAME MHalter JHughey 

DATE 10/7/2015 10/13/2015 

OFFICIAL RECORD COPY