• Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PNP 2015-084 

Tel 269 764 2000 

Anthony J. Vitale 

Site Vice President 

December 16, 2015 

u.s. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

SUBJECT: Notification of Full Compliance with NRC Order EA-12-051, "Order to 

Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" 

Palisades Nuclear Plant 

Docket No. 50-255 

Renewed Facility Operating 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. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-092, Initial 

Status Report in Response to March 12,2012 Commission Order 

Modifying Licenses with Regard to Reliable Spent Fuel Pool 

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

(ADAMS Accession No. ML 12300A067) 

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

Integrated Plan in Response to March 12,2012 Commission Order 

Modifying License With Regard to Reliable Spent Fuel Pool 

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

(ADAMS Accession No. ML 13060A360) 

4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-061, 

Palisades Nuclear Plant Response to Request for Additional 

Information for the Overall Integrated Plan in Response to the 

Commission Modifying Licenses with Regard to Requirements for 

Reliable Spent Fuel Pool Instrumentation, August 19, 2013 (ADAMS 

Accession No. ML 13231A126) 

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

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

March 12,2012 Commission Order Modifying Licenses with Regard to 

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

dated August 28, 2013 (ADAMS Accession No. ML 13241 A235) 

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

Request for Additional Information Regarding the Overall Integrated 

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

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

(ADAMS Accession No. ML 13312A423) 
PNP 2015-084 

Page 2 of 3 

7. 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 14059A078) 

8. 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) 

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

Palisades Nuclear Plant Fourth Six-Month Status Report in Response 

to March 12,2012 Commission Order Modifying Licenses with Regard 

to Reliable Spent Fuel Pool Instrumentation (Order Number 

EA-12-051), dated February 27,2015 (ADAMS Accession No. 

ML 15062A056) 

10. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2015-062, 

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

March 12,2012 Commission Order Modifying Licenses with Regard to 

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

dated August 28,2015 (ADAMS Accession No. ML 15240A074) 

11. NRC letter, 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), dated October 13, 2015 (ADAMS 

Accession No. ML 15272A324). 

Dear Sir or Madam: 

The purpose of this letter is to notify the NRC that Entergy Nuclear Operations, Inc. (ENO) 

Palisades Nuclear Plant (PNP) is in full compliance with Order EA-12-051, "Order to Modify 

Licenses with Regard to Reliable Spent Fuel Pool Instrumentation." On March 12,2012, the 

Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (Reference 1) to ENO. 

Order EA-12-051 was immediately effective and directed ENO to install reliable spent fuel 

pool level instrumentation at the PNP. 

Order EA-12-051, Section IV.A.2, requires completion of full implementation to be no later 

than two refueling cycles after submittal of the Overall Integrated Plan (OIP) or December 31, 

2016, whichever comes first. In addition, Section IV.C.3 of Order EA-12-051 requires that 

licensees report to the NRC when full compliance is achieved. The OIP for EA-12-051 was 

submitted (Reference 3) on February 28, 2013. On October 19, 2015, PNP entered Mode 2 

(startup), completing two refueling cycles after submittal of the OIP. PNP was in full 

compliance with Order EA-12-051 at that time. 

In References 2, 5, 7, 8, 9, and 10, status reports were provided to the NRC with regard to 

implementation of Order EA-12-051 at PNP. 
PNP 2015-084 

Page 3 of 3 

ENO responded to NRC requests for additional information (RAls) associated with the OIP in 

Reference 4. 

In Reference 6, the NRC documented an interim staff evaluation (ISE) for the PNP OIP, 

which included additional RAls. ENO responses to the ISE RAls were provided in the third 

and fourth six-month status reports (References 8 and 9). 

In Reference 11, the NRC issued a report for an audit conducted at PNP regarding 

implementation of mitigating strategies and reliable spent fuel pool instrumentation related to 

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

Strategies for Beyond-Design-Basis External Events," and EA-12-051. The audit included a 

review of ENO responses to the ISE RAI questions. There were no open or pending SFPI 

items listed in the audit report. 

The design bridging document that compared ENO implementation of the spent fuel pool 

instrumentation at PNP to the vendor supplied technical information and assumptions was 

provided in the fourth six-month status report (Reference 9). 

The attachment summarizes PNP compliance with Order EA-12-051. 

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 

December 16, 2015. 

Sincerely, 

AJVljse 

Attachment: Palisades Nuclear Plant Compliance Bases for Order EA-12-051 

cc: Office Director, NRR, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
Attachment 

Palisades Nuclear Plant Compliance Bases for Order EA-12-0S1 

BACKGROUND 

On March 12,2012, the NRC issued Order EA-12-051, Order Modifying Licenses with 

Regard to Reliable Spent Fuel Pool (SFP) Instrumentation (Reference 1), to Entergy Nuclear 

Operations, Inc. (ENO). Order EA-12-051 was effective immediately and directed ENO to 

install reliable SFP instrumentation as outlined in Attachment 2 of the Order at Palisades 

Nuclear Plant (PNP). The information provided herein documents full compliance for PNP 

with the Order. 

COMPLIANCE 

ENO has installed two independent full range level monitors for the PNP SFP in response to 

Reference 1. 

The Overall Integrated Plan (OIP) for EA-12-051 was submitted (Reference 3) on February 

28, 2013. ENO responded to NRC requests for additional information (RAls) associated with 

the OIP in Reference 4. In Reference 6, the NRC documented an interim staff evaluation 

(ISE) for the PNP OIP, which included additional RAls. ENO responses to the ISE RAls were 

provided in the third and fourth six-month status reports (References 8 and 9). 

In References 2,5, 7, 8, 9, and 10, status reports were provided to the NRC with regard to 

implementation of Order EA-12-051 at PNP. 

In Reference 11, the NRC issued a report for an audit conducted at PNP regarding 

implementation of mitigating strategies and reliable spent fuel pool instrumentation related to 

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

Strategies for 8eyond-Design-8asis External Events," and EA-12-051. The audit included a 

review of ENO responses to the ISE RAI questions. There were no open or pending SFPI 

items listed in the audit report. 

The design bridging document that compared ENO implementation of the spent fuel pool 

instrumentation at PNP to the vendor supplied technical information and assumptions was 

provided in the fourth six-month status report (Reference 9). 

ENO plans to provide the vendor qualification report for modified SFP instrumentation in a 

supplemental submittal. 

On October 19, 2015, PNP entered Mode 2 (startup), completing two refueling cycles after 

submittal of the OIP. PNP was in full compliance with Order EA-12-051 at that time. 

ACTIONS COMPLETED 

Engineering Change (EC) 46466, "Spent Fuel Pool Instrumentation," has been implemented 

providing SFP level monitoring capability in two locations: the main control room and the 

auxiliary building. 

Page 1 of 8 
IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE 

PNP Level 1 : Elevation 645 feet 7 inches 

The level at which reliable suction loss occurs due to uncovering the coolant inlet pipe or 

any weirs or vacuum breakers associated with suction loss. 

PNP Level 2: Elevation 634 feet 5 inches 

Ten feet (+/- one foot) above highest point of any fuel rack seated in the SFP. 

PNP Level 3: Elevation 625 feet 5 inches 

Highest pOint of any fuel rack seated in SFP associated with level where fuel remains 

covered, plus one foot. 

INSTRUMENT DESIGNED FEATURES - COMPLETE 

PNP SFP level instrument channels incorporate two permanently installed, physically 

independent, and physically separated channels (channel separation is in accordance with 

existing plant design basis requirements). Sensors at the SFP are spatially separated near 

opposite corners of the SFP with the cables being protected by a metallic raceway and 

maintaining the same relative spatial separation until exiting the SFP floor. The primary 

display (channel A) is installed in the back of the main control room. The backup display 

(channel B) is installed in the auxiliary building. Power sources include 1) independent plant 

alternating current (AC) power sources, 2) channel-specific stand-alone battery power with 

analyzed and tested seven-day capacity, as well as 3) connections and cables for external 

direct current (DC) alternate power source capability. Equipment and raceways are 

mounted/installed to PNP Seismic Category I requirements. 

Program Features - COMPLETE 

Training has been conducted. The SFP instrumentation has been added to the PNP 

Operating Requirements Manual (ORM). The ORM contains functionality, applicability, and 

testing requirements, and actions to restore functionality if lost. Preventive maintenance 

(PM) activities have been established to calibrate the SFP level instrumentation and to 

replace the batteries in accordance with the ENO PM program. Routine monitoring is 

provided per operator log entries. 

Milestone Schedule - ITEMS COMPLETE 

PNP Milestones Completion Date 

Response to NRC Request for Additional August 19, 2013 (Reference 4) Information (received July 18, 2013) 

PNP Reliable SFPI Design Modification Package August 1, 2014 Developed/Issued (EC 46466) 

Response to NRC ISE Request for Additional February 27,2015 (Reference 9) Information (received November 26,2013) 

PNP Reliable SFPI Installed August 31,2015 

Based on the above, the requirements of Order EA-12-051 have been implemented for PNP. 

A summary of PNP compliance with Reference 1 is provided as follows: 

Page 2 of 8 
COMPLIANCE ELEMENTS SUMMARY 

In accordance with NRC Order EA-12-0S1, ENO shall have a reliable indication of the 

water level in associated spent fuel storage pools capable of supporting identification 

of the following pool water level conditions by trained personnel: 

(1) level at which reliable suction loss occurs due to uncovering the coolant inlet 

pipe or any weirs or vacuum breakers associated with suction loss, 

(2) level that is adequate to provide substantial radiation shielding for a person 

standing on the SFP operating deck, and 

(3) level where fuel remains covered and actions to implement make-up water 

addition should no longer be deferred. 

Per References 3, 4, and 8, key SFP water levels, including the three critical levels defined in 

Nuclear Energy Institute (NEI) 12-02, Revision 1 (Reference 12), were identified. Both the 

primary and backup instrument level channels are permanent, mounted directly within the 

SFP, and measure level over a single continuous range from above Level 1 down to below 

the upper limit of Level 3. Access to the SFP area is not required to operate the instrument 

channels or to obtain level data. Displays and signal processors are located in the main 

control room (channel A) and in the auxiliary building (channel B). The three critical levels for 

PNP are as follows: 

LEVEL 1: Level 1 is the level at which reliable pump suction loss occurs due to uncovering 

the coolant inlet pipe or any weirs or vacuum breakers since it is more limiting than level 

associated with pump net positive suction head requirements. For PNP, the elevation 

associated with this level is 645 feet 7 inches due to uncovering of the skimmer opening. 

LEVEL 2: Level 2 is the level adequate to provide substantial radiation shielding for a person 

standing on the SFP operating deck. ENO has selected the ten-foot option, as described in 

Section 2.3.2 of NEI 12-02 (Reference 12), which has been determined by the NRC to meet 

the requirements of the order with no further evaluation or review required. Because Level 2 

has been chosen as ten feet (+/- one foot) above the highest point of any fuel rack seated in 

the SFP, no additional analysis is required. The elevation associated with this level is 634 

feet 5 inches for PN P. 

LEVEL 3: Level 3 is the level where fuel remains covered plus one foot. The level where fuel 

remains covered is defined as the highest point of any fuel rack seated in the SFP (within +/-

one foot). The highest point of any fuel rack seated in the SFP is 624 feet 5 inches for PNP. 

Therefore, Level 3 is elevation 625 feet 5 inches for PNP. 

1. In accordance with NRC Order EA-12-0S1, the SFP level instrumentation shall 

include the following design features: 

a. Instruments: The instrumentation shall consist of a permanent, fixed primary 

instrument channel and a backup instrument channel. The backup instrument 

channel may be fixed or portable. 

Per References 3, 4, 8 and 9, both primary and backup SFP level instrument channels 

are fixed or permanently installed. Both instrument probes are permanently installed 

near opposite (northwest and southeast) corners of the SFP. The channel A display 

Page 3 of 8 
and signal processor is located within the main control room. The channel 8 display 

and signal processor is located in the auxiliary building. 

b. Arrangement: The SFP level instrument channels shall be arranged in a manner 

that provides reasonable protection of the level indication function against 

missiles that may result from damage to the structure over the SFP. This 

protection may be provided by locating the primary instrument channel and 

fixed portions of the backup instrument channel, if applicable, to maintain 

instrument channel separation within the SFP area, and to utilize inherent 

shielding from missiles provided by existing recesses and corners in the SFP 

structure. 

Per References 3 and 4, and in accordance with the guidance of Section 3.2 of 

NEI 12-02, Revision 1, PNP primary and backup SFP level instrument probes are 

spatially separated and installed near opposite SFP corners. Corner locations provide 

inherent protection of the probes. Channel separation for cable routing away from the 

probes maintains the same relative spatial separation distance as the SFP corner 

mounting locations. Cable routing on the SFP floor is limited until exiting via a SFP 

area floor penetration (channel A) or wall penetration (channel 8). Probe top section 

and channel cabling are protected by a metallic raceway and the probe mounting 

bracket structure itself, all of which incorporate a low profile design. Concrete curbs in 

the vicinity of the probes rise six inches above the floor elevation and provide 

additional protection. As described, reasonable protection of the SFP level 

instrumentation is provided from potential SFP area overhead structure missiles. 

c. Mounting: Installed instrument channel equipment within the SFP shall be 

mounted to retain its design configuration during and following the maximum 

seismic ground motion considered in the design of the SFP structure. 

Per References 3,4, and 9, the PNP SFP instrument channels (equipment from the 

SFP to the main control room or the auxiliary building location) are mounted and 

designed to meet or exceed the requirements of PNP seismic design bases, seismic 

Category I requirements. As such, the SFP instrument channels are designed and 

installed to retain their design configuration during and following maximum 

requirements of the PNP seismic design bases. 

d. Qualification: The primary and backup instrument channels shall be reliable at 

temperature, humidity, and radiation levels consistent with the SFP water at 

saturation conditions for an extended period. This reliability shall be 

established through use of an augmented quality assurance process (e.g., a 

process similar to that applied to the site tire protection program). 

Per References 3,4, and 9, the PNP SFP instrument channels (equipment from the 

SFP to the level processors and displays) are designed and qualified to PNP 

environmental extremes applicable for the area of interest (e.g., SFP, main control 

room, and C-40 panel room). The SFP area environmental extremes are in 

accordance with NEI 12-02, Revision 1, SFP example conditions (as summarized 

below). The SFP instrumentation channels have been designated as Augmented 

Quality per ENO processes covering procurement, design, and installation. Per ENO 

procedures, Augmented Quality refers to systems, structures, and components 

(SSCs) that have been designated as requiring additional quality level oversight or 

requirements beyond what would be required for non-safety related SSCs. As such, 

Page 4 of 8 
the SFP instrument channels have demonstrated reliability through establishment of 

Augmented Quality processes at applicable environmental extremes. 

SFP Area 

Parameter 

Radiation 

SFP Area 

NE112-02 Rev 1 Example Condition 

SFP @ Water Level·3 (low) 

for 7-day min. event/post-event 

(or until FLEX strategy mitigation) 

Fuel freshly discharged (100 Hours) 

+ normal dose 

Temperature 212°F 

Humidity 100% 

(boiling borated water &Jor steam) 

SFP Area 

Qualification 

SFP @ Water Level 3 (low) 

for 7 -day event/post-event 

(no credit for earlier FLEX 

mitigation) 

Full core off-load @ 100 hours 

remainder SFP @ 18 mo. 

(conservative) 

SFP @ normal water level for 40 yr 

212°F 

100% 

(boiling bor. water &Jor steam) 

e. Independence: The primary instrument channel shall be independent of the 

backup instrument channel. 

Per References 3, 4, and 8, PNP SFP instrument channels have highly reliable 

independent power sources (as detailed in the next section) and channel 

independence achieved by incorporation of two permanently installed, physically 

independent, and physically separated channels (with channel separation in 

accordance with existing plant design basis requirements). The channel A display 

and signal processor is located within the main control room and the channel 8 

display and signal processor is located in the auxiliary building. As such, the SFP 

instrument channels are independent. 

f. Power supplies: Permanently installed instrumentation channels shall each be 

powered by a separate power supply. Permanently installed and portable 

instrumentation channels shall provide for power connections from sources 

independent of the plant ac and dc power distribution systems, such as 

portable generators or replaceable batteries. Onsite generators used as an 

alternate power source and replaceable batteries used for instrument channel 

power shall have sufficient capacity to maintain the level indication function 

until offsite resource availability is reasonably assured. 

Per References 3, 4, and 8, the two PNP SFP instrument channels are powered from 

separate 480VAC sources. Channel A is powered from 120VAC lighting panel L-258, 

through existing 20A breaker #5, which is fed from motor control center (MCC) #1. 

Channel 8 is powered from 120VAC Lighting Panel L-76, through existing 20A 

breaker #12, which is fed from MCC #82. These two buses represent independent 

480V power sources. 

The two PNP SFP instrumentation channels incorporate channel-specific stand-alone 

backup battery power. The permanently installed replaceable and rechargeable 

backup batteries are configured for full event duration (e.g., seven days) or maximum 

offsite resource availability time frames, which is well beyond FLEX strategy 

restoration time frames. 

Page 5 of 8 
A third power alternative is available via external connections and cables included for 

each battery panel supplying each SFP processor/display panel to permit powering 

the system from an external DC source independent of plant sources. 

g. Accuracy: The instrument channels shall maintain their designed accuracy 

following a power interruption or change in power source without recalibration. 

Per References 3, 4, and 9, the PNP SFP instrument channels have a reasonably 

high certified design accuracy of equal to or better than +/- three inches (excluding 

boric acid deposition effects which can produce a maximum error of 2.5 inches) which 

is not affected by power interruption as supported by vendor test documentation. As 

such, the SFP instrument channels have been documented to maintain their designed 

accuracy following power interruption or change in power source without recalibration 

being required. 

h. Testing: The instrument channel design shall provide for routine testing and 

calibration. 

Per References 3, 4, 8, and 9, the PNP SFP instrument channels automatically 

monitor the integrity of the measurement system using in-situ capability or on board 

diagnostics. The display unit generates system alerts and warnings in response to 

hardware and/or software problems that are encountered. Channel functional tests 

are periodically performed on the SFP instrument channels. The probe itself is a 

perforated tubular coaxial waveguide with defined geometry and is not calibrated. 

Channel design provides capability for calibration or validation against known/actual 

SFP level. As such, the SFP instrument channel's design provides for routine testing 

and calibration. 

i. Display: Trained personnel shall be able to monitor the SFP water level from 

the control room, alternate shutdown panel, or other appropriate and accessible 

location. The display shall provide on-demand or continuous indication of SFP 

water level. 

Per References 3,4,8, and 9, the channel A display and signal processor is located 

within the control room and the channel B display and signal processor is located in 

the auxiliary building, and will be readily accessible. Level is displayed continuously 

when on primary AC power and on-demand when on backup DC power. As such, the 

SFP water level indication can be monitored by trained personnel in the main control 

room or the auxiliary building either continuously or on-demand. 

2. In accordance with NRC Order EA-12-051, the SFP instrumentation shall be 

maintained available and reliable through appropriate development and 

implementation of the following programs: 

a. Training: Personnel shall be trained in the use and the provision of alternate 

power to the primary and backup instrument channels. 

Two PNP instrument and control maintenance technicians received training on the 

MOHR EFP-IL SFP Level Monitoring System at the vendor (MOHR) facilities to 

become subject matter experts (SMEs). The SMEs then provided training on the 

MOHR system at PNP for site instrument and control maintenance technicians. In 

Page 6 of 8 
addition, ENO plans to provide refresher training to the technicians on the MOHR 

system every two years. 

Training was provided to plant personnel, including Operations personnel, using 

training material number PLLP-OPS-FLEXOVER, titled "FLEX Process & Equipment." 

The training included discussions of Order EA-12-051, the new SFP level instruments 

installed, how the level instruments support the FLEX strategies, the locations of the 

two instrument display panels, and the external DC power source that can be used for 

the instruments. 

On-site training was implemented in accordance with ENO training processes, which 

include the Systematic Approach to Training for both initial and continuing elements 

and the target audience. 

b. Procedures: Procedures shall be established and maintained for the testing, 

calibration, and use of the primary and backup SFP instrument channels. 

References 3, 4, 8, and 9 discussed procedure plans. The display/processor 

performs automatic in-situ diagnostics and automatically monitors for cable, 

connector, and probe faults using time domain reflectometry (TDR) technology. The 

PNP ORM was revised to include actions to be taken for the primary and back-up 

SFP level instruments should functionality be lost. PM activities have been 

established to calibrate the SFP level instrumentation on demand (based on internal 

instrument diagnostics), and to replace the batteries, in accordance with the ENO PM 

program. A new operating procedure was not required based on the simple indication 

function and use. 

c. Testing and Calibration: Processes shall be established and maintained for 

scheduling and implementing necessary testing and calibration of the primary 

and backup SFP level instrument channels to maintain the instrument channels 

at the design accuracy. 

A PM task has been established for scheduling and implementing necessary 

functional testing in accordance with ORM requirements. The testing provides for 

calibration or validation of the primary and backup SFP level instrument channels 

against known/actual SFP level to maintain the design accuracy within limits 

established. The testing also provides for SFP level instrument cross channel 

comparison. A functional check of the SFP level indicators is performed by 

Operations every seven days. 

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. 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) 

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

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

Page 7 of 8 
Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), 

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

4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-061, Palisades Nuclear 

Plant Response to Request for Additional Information for the Overall Integrated Plan 

in Response to the Commission Modifying Licenses with Regard to Requirements for 

Reliable Spent Fuel Pool Instrumentation, August 19, 2013 (ADAMS Accession No. 

ML 13231A126) 

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

Plant First Six-Month Status Report in Response to March 12,2012 Commission 

Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 

(Order Number EA-12-051), dated August 28,2013 (ADAMS Accession No. 

ML 13241 A235) 

6. NRC Interim Staff Evaluation, Palisades-Interim Staff Evaluation and Request for 

Additional Information Regarding the Overall Integrated Plan for Implementation of 

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

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

7. 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 14059A078) 

8. 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) 

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

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

Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 

(Order Number EA-12- 051), dated February 27,2015 (ADAMS Accession No. 

ML 15062A056) 

10. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2015-062, Palisades Nuclear 

Plant Fifth Six-Month Status Report in Response to March 12,2012 Commission 

Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 

(Order Number EA-12- 051), dated August 28,2015 (ADAMS Accession No. ML 

15240A074) 

11. NRC letter, 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), dated October 

13,2015 (ADAMS Accession No. ML 15272A324). 

12. NEI12-02, Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify 

Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, "Revision 1, 

August 2012. 

Page 8 of 8