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 

September 9, 2015 

SUBJECT: PALISADES NUCLEAR PLANT - RESPONSE REGARDING PHASE 2 

STAFFING SUBMITTALS ASSOCIATED WITH NEAR-TERM TASK FORCE 

RECOMMENDATION 9.3 RELATED TO THE FUKUSHIMA DAl-ICHI 

NUCLEAR POWER PLANT ACCIDENT (TAC NO. MF6273) 

Dear Sir or Madam: 

By letter dated March 12, 2012 (Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML 12053A340), the U.S. Nuclear Regulatory Commission (NRC) 

issued a request for information pursuant to Title 1 O of the Code of Federal Regulations (1 O 

CFR) Part 50, Section 50.54(f) (hereafter referred to as the 50.54(f) letter), regarding 

Recommendations 2.1 (seismic and flooding evaluations), 2.3 (seismic and flooding 

walkdowns), and 9.3 (emergency preparedness communication and staffing) of the Near-Term 

Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident. With respect to 

Recommendation 9.3, Enclosure 5 to the NRC's letter requested licensees and holders of 

construction permits to assess their means to power communications equipment onsite and 

offsite during a prolonged station blackout (SBO) event and to perform a staffing assessment to 

determine the staff required to fill all necessary positions in response to a multi-unit event. 

The 50.54(f) letter in part, requested licensee responses pursuant to the provisions of 1 O CFR 

50.54(f) pertaining to onsite and augmented staff availability to implement the strategies 

discussed in the emergency plan and plant operating procedures including new staff or 

functions resulting from the assessment, identified collateral duties, an implementation 

schedule to perform the assessments, identified modifications, and any changes that have 

been made or will be made to the emergency plan regarding on-shift or augmented staffing. In 

addition, NTTF Recommendation 9.3 has a dependency on the implementation of NTTF 

Recommendation 4.2 (mitigating strategies). As a result of this dependency, licensees 

responded to the 50.54(f) letter in phases. The Phase 1 staffing assessment requested 

licensees to evaluate their ability to respond to a multi-unit extended loss of alternating current 

(ac) power (ELAP) event utilizing existing processes and procedures. The licensee responses 

to the 50.54(f) letter for Phase 1 staffing assessments for multi-unit sites were received and 

evaluated by the NRC staff. The NRC staff issued acknowledgement letters to all licensees 

with multi-unit sites, with the exception of San Onofre Nuclear Generating Station, by April 28, 

2014. 
- 2 -

Licensees were also requested to submit for NRC staff review a Phase 2 staffing assessment, 

which provides an assessment of the staffing necessary to perform the functions related to the 

strategies developed in response to NTTF Recommendation 4.2 and the resulting NRC Order 

EA-12-049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for 

Beyond-Design-Basis External Events [BDBEE]" (ADAMS Accession No. ML 12054A736). 

Licensees were requested to provide their Phase 2 Staffing Assessments to the NRC no later 

than four months prior to the beginning of their second refueling outage (as used in the context 

of NRC Order EA-12-049). By letter dated May 19, 2015 (ADAMS Accession No. 

ML 15142A546), Entergy Nuclear Operations, Inc. (the licensee) submitted its Phase 2 staffing 

assessment for Palisades Nuclear Plant to the NRC in response to the 50.54(f) letter. 

The NRC staff reviewed your Phase 2 staffing assessment in accordance with the assumptions 

and guidelines of Sections 2.2, 2.3, and 3 of the Nuclear Energy Institute (NEI) guidance 

document NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response 

Staffing and Communications Capabilities," (ADAMS Accession No. ML 12125A412), which was 

endorsed by the NRC staff by letter dated May 15, 2012 (ADAMS Accession No. 

ML 12131A043). The NRC staff noted that you assessed your current onsite minimum staffing 

levels to identify any enhancements needed to respond following a beyond-design-basis largescale natural event, and to ensure that the strategies contained in the existing emergency plan 

and plant operating procedures, such as those used in response to a SBO, can be performed by 

the site staff. Your assessment assumed that a large-scale natural event causes: ( 1) an ELAP, 

(2) all units on the site to be affected, and (3) access to the site to be impeded for a minimum of 

six hours. You also assessed your capability to perform the site specific functions related to the 

strategies developed in response to Order EA-12-049. You conducted independent reviews 

and concluded, based on your staffing assessment, that the existing on-shift minimum staff is 

sufficient to implement the loss of all ac power event response strategies, including those 

strategies developed to support the requirements of Order EA-12-049, while supporting 

performance of the required emergency planning duties without unacceptable collateral duties. 

The NRC staff reviewed your Phase 2 staffing submittal and confirmed that your existing 

emergency response resources, as described in your emergency plan, are sufficient to perform 

the required plant actions and emergency plan functions, and implement the response 

strategies that were developed in response to Order EA-12-049 without the assignment of 

collateral duties that would impact the performance of assigned emergency plan functions. 

As a result, the NRC staff concludes that your Phase 2 staffing submittal adequately addresses 

the response strategies needed to respond to a BDBEE using your procedures and guidelines. 

The NRC staff will verify the implementation of your staffing capabilities through the inspection 

program. 
- 3 -

If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-

2365 or via email at Stephen.Philpott@nrc.gov. 

Docket No. 50-255 

cc: Distribution via Listserv 

Sincerely, 

Mandy K. Halter, Acting Branch Chief 

Orders Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 
- 3 -

If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-

2365 or via email at Stephen.Philpott@nrc.gov. 

Docket No. 50-255 

cc: Distribution via Listserv 

DISTRIBUTION: 

PUBLIC 

JOMB R/F 

RidsNrrDorllpl3-1 

JHughey, NRR 

RidsOgcMailCenter 

RidsNrrLASLent 

VWilliams, NSIR 

DPelton, NRR 

ADAMS Accession No.: ML 15231A344 

OFFICE NRR/JLO/JOMB/PM NRR/JLD/LA 

NAME SPhilpott Slent 

DATE 08/25/15 08/24/15 

Sincerely, 

/RAJ 

Mandy K. Halter, Acting Branch Chief 

Orders Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 

RidsNrrPMPalisades 

RidsRgn3MailCenter 

MHalter, NRR 

NSIR/DPR/DDEP/NRLB/BC* 

A Rivera 

08/31/15 

CMurray, NSIR 

ARivera, NSIR 

SPhilpott, NRR 

*via email 

NRR/JLD/JOMB/BC(A) 

MHalter 

09/09/15 

OFFICIAL RECORD COPY