Entergy Nuclear Operations, Inc.

“‘ #11.E, Palisades Nuclear Plant

Iii1LI7jY 27780 Blue Star Memorial Highway

Covert, MI 49043-9530

Tel 269 764 2000

Anthony J. Vitale

Site Vice President

PNP 2014-085

August 28, 2014

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

11555 Rockville Pike

Rockville, MD 20852

SUBJECT: 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)

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.

1 2054A736)

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.

ML1 2229A1 74)

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

Implementation Guide, Revision 0, dated August 2012 (ADAMS

Accession No. ML1 2242A378)

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.

ML1 2300A065)

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.

ML1 3246A399)

.-

·~Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

PNP 2014-085 

August 28, 2014 

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 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) 

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 8eyond-Design-Basis 

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

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. 

ML 12229A174) 

3. NEI12-06, 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 2014-085

Page 2 of 3

6. Entergy Nuclear Operations, 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. ML1 3241 A234)

7. Entergy Nuclear Operations, 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. ML1 4059A078)

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 pooi 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 1

(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.

The purpose of this letter is to provide the third 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,

2014.

ncerely,,

ajv/jse

PNP 2014-085 

Page 2 of 3 

6. Entergy Nuclear Operations, 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 13241 A234) 

7. Entergy Nuclear Operations, 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) 

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 1 

(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. 

The purpose of this letter is to provide the third 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, 

2014. 

Sincerely, 

ajv/jse 
PNP 2014-085

Page 3 of 3

Attachment: 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)

cc: Office Director, NRR, USNRC

Administrator, Region Ill, USNRC

Project Manager, Palisades, USNRC

Resident Inspector, Palisades, USN RC

PNP 2014-085 

Page 3 of 3 

Attachment: 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) 

cc: Office Director, NRR, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
ATTACHMENT

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-1 2-049)

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 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, 2014, and are current as

of July 31, 2014.

• Second Six-Month Status Report — February 2014

• Modifications Evaluation — April 2014

• N-i Walkdown — February 2014

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

August 2014.

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.

• Perform Staffing Analysis

The Perform Staffing Analysis milestone completion date has been changed to April

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

implementation date.

• Modifications — Design Engineering

The Design Engineering milestone completion date has been changed to September

2014. This new milestone target completion date does not impact the Order

implementation date.

• On-site FLEX Equipment - Purchase and Procure

The On-Site FLEX Equipment Purchase and Procure milestone completion date has been

changed to August 2015. This new milestone target completion date does not impact the

Order implementation date.

Page 1 of 16

ATTACHMENT 

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) 

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 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, 2014, and are current as 

of July 31,2014. 

• Second Six-Month Status Report - February 2014 

• Modifications Evaluation - April 2014 

• N-1 Walkdown - February 2014 

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

August 2014. 

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. 

• Perform Staffing Analysis 

The Perform Staffing Analysis milestone completion date has been changed to April 

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

implementation date. 

• Modifications - Design Engineering 

The Design Engineering milestone completion date has been changed to September 

2014. This new milestone target completion date does not impact the Order 

implementation date. 

• On-site FLEX Equipment - Purchase and Procure 

The On-Site FLEX Equipment Purchase and Procure milestone completion date has been 

changed to August 2015. This new milestone target completion date does not impact the 

Order implementation date. 

Page 1 of 16 
• Create PNP FLEX FSG

The Create PNP FLEX FSG milestone completion date has been changed to December

2014. 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 Feb2014 Complete

Update 3 Aug 2014 Complete

Update 4 Feb 2015 Not Started

Update 5 Aug 2015 Not Started

FLEX Strategy Evaluation Jan 2014 Complete

Perform Staffing Analysis Apr2014 Started Apr2015

Modifications

Modifications Evaluation Apr 2014 Complete

Engineering and Implementation

N-i Walkdown Feb 2014 Complete

Design Engineering May 2014 In Progress September 2014

Implementation Outage Oct 2015 Not Started

On-site FLEX Equipment

Purchase and Procure Jun 2014 Started Aug 2015

Off-site FLEX Equipment

Develop Strategies with RRC Jan 2015 Started

Install Off-Site Delivery Station (If Oct 2015 Not Started Necessary)

Procedures

Pressurized Water Reactor Owners

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

Specific Guidelines

Create PNP FLEX FSG Mar 2015 Started Dec 2014

Create Maintenance Procedures Mar 2015 Not Started

Training

Develop Training Plan Jun 2015 Not Started

Training Complete Sept 2015 Not Started

Page 2 of 16

• Create PNP FLEX FSG 

The Create PNP FLEX FSG milestone completion date has been changed to December 

2014. 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 Not Started 

Update 5 Aug 2015 Not Started 

FLEX Strategy Evaluation Jan 2014 Complete 

Perform Staffing Analysis Apr2014 Started Apr2015 

Modifications 

Modifications Evaluation Apr2014 Complete 

Engineering and Implementation 

N-1 Walkdown Feb 2014 Complete 

Design Engineering May 2014 In Progress September 2014 

Implementation Outage Oct 2015 Not Started 

On-site FLEX Equipment 

Purchase and Procure Jun 2014 Started Aug 2015 

Off-site FLEX Equipment 

Develop Strategies with RRC Jan 2015 Started 

Install Off-Site Delivery Station (If Oct 2015 Not Started Necessary) 

Procedures 

Pressurized Water Reactor Owners 

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

Specific Guidelines 

Create PNP FLEX FSG Mar 2015 Started Dec 2014 

Create Maintenance Procedures Mar 2015 Not Started 

Training 

Develop Training Plan Jun 2015 Not Started 

Training Complete Sept 2015 Not Started 

Page 2 of 16 
Target Revised Target

Milestone Completion Activity Status Completion

Date* Date

Validation! Demonstration Oct 2015 Not Started

Submit Completion Report Oct 2015 Not Started

*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 previous

correspondence.

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

Evaluation (ISE) (Reference 5). A fou

status of each item.

Overall Integrated Plan Open Item

Oil. Perform analysis on Palisades’

susceptibility to soil liquefaction and

potential consequences on the

FLEX implementation plan.

Complete/Closed

Borings were performed on site and soil liquefaction

susceptibility was identified along the FLEX equipment

deployment route outside the PA. Based on this

information a set of FLEX equipment will be stored

inside the protected area (PA) for the seismic event.

The other set of FLEX equipment will be stored

outside of the PA and be protected against the

tornado event. Both locations will be protected

against other applicable (screened-in) beyond-designbasis external events (BDBEEs). Additional planning

is under way to address other impacts to equipment

storage and deployment. This Open item is related to

1SE Open Item 3.1.1 .2.A and is addressed on updated

Audit Question (AQ) response spreadsheet on the

ePortal.

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

rth table includes a listing of audit questions and the

Status

012. Develop Phase 3 deployment Started

strategy with correspondence with Staging areas have been identified. The National the RRC. SAFER Response Center (NSRC) [formerly known as

the Regional Response Center (RRC)] kickoff meeting

was conducted on 7/22/14 to complete checklist as

Page 3 of 16

Target Revised Target 

Milestone Completion Activity Status Completion 

Date* Date 

Validation I Demonstration Oct 2015 Not Started 

Submit Completion Report Oct 2015 Not Started 

*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 previous 

correspondence. 

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 5). A fourth table includes a listing of audit questions and the 

status of each item. 

Overall Integrated Plan Open Item Status 

011. Perform analysis on Palisades' Complete/Closed 

susceptibility to soil liquefaction and Borings were performed on site and soil liquefaction potential consequences on the susceptibility was identified along the FLEX equipment FLEX implementation plan. deployment route outside the PA. Based on this 

information a set of FLEX equipment will be stored 

inside the protected area (PA) for the seismic event. 

The other set of FLEX equipment will be stored 

outside of the PA and be protected against the 

tornado event. Both locations will be protected 

against other applicable (screened-in) beyond-designbasis external events (BDBEEs). Additional planning 

is under way to address other impacts to equipment 

storage and deployment. This Open Item is related to 

ISE Open Item 3.1.1.2.A and is addressed on updated 

Audit Question (AQ) response spreadsheet on the 

ePortal. 

012. Develop Phase 3 deployment Started 

strategy with correspondence with Staging areas have been identified. The National the RRC. SAFER Response Center (NSRC) [formerly known as 

the Regional Response Center (RRC)] kickoff meeting 

was conducted on 7/22/14 to complete checklist as 

Page 3 of 16 
Overall Integrated Plan Open Item Status

approved by AREVA. The NSRC and Palisades are in

process of developing Site Response Plans. This

Open Item is related to ISE Confirmatory Item 3.4.A

and is addressed on updated AQ response

spreadsheet on the ePortal.

013. Evaluate the need to missile Complete/Closed

protect primary system makeup The condensate storage tank (CST) (T-2) and T-81 storage tank (T-81) and other

are cross-connected such that upon depletion of the external tanks. CST, at approximately 4 hours, the inventory in tank

T-81 can also be gravity fed to the TDAFW pump. To

allow credit for an 8 hour supply, tanks T-2 and T-81

will be missile protected. Following the required

modifications, tanks T-2 and T-81 will be considered

robust against all of the applicable tornado missile

hazards described on Table 2 of RG 1.76, Rev. 1, with

the single exception of tank T-81 foundation mounting

bolts. Tank T-81 would be fully protected against the

design basis tornado missile hazards of a 6-inch

Schedule 40 steel pipe and a 1-inch diameter solid

steel sphere (the exception being anchor bolting for

the automobile missile hazard impact). A white paper

describing the tornado generated missile hazard

evaluation for tank T-81 has been posted to the

ePortal.

This Open Item is also addressed by updated AQ

PAL-044 response.

014. Select the location of FLEX Complete/Closed

equipment storage facility. Refer to OIl. One set of equipment will be stored in a

new structure inside the PA designed for the Seismic

event. An additional set(s) of equipment will be stored

outside the PA in a structure(s) providing an

appropriate level of protection for the tornado event.

Both sets will be protected against other applicable

(screened-in) BDBEE external hazards.

015. Perform seismic evaluation of Complete/Closed

turbine-driven auxiliary feedwater Seismic evaluation documents the seismic

pump (TDAFWP) driver K-8. qualification of the pump and associated components.

The TDAFW pump is qualified with the exception of an

outlier related to a check for bolt tightness. Bolt

tightness on the pump is being performed under WO#

372138 and documented under EC 46465.

016. Evaluate strategies to extend Complete/Closed

battery coping time. The battery load shedding strategy has been revised

to extend the battery coping time through shedding

loads in addition to those identified in the station

blackout procedure. The results indicate a coping

time of at least 8 hours for the installed batteries

Page 4 of 16

Overall Integrated Plan Open Item Status 

approved by AREVA. The NSRC and Palisades are in 

process of developing Site Response Plans. This 

Open Item is related to ISE Confirmatory Item 3.4.A 

and is addressed on updated AQ response 

spreadsheet on the ePortal. 

013. Evaluate the need to missile Complete/Closed 

protect primary system makeup The condensate storage tank (CST) (T-2) and T-81 storage tank (T -81) and other 

are cross-connected such that upon depletion of the external tanks. CST, at approximately 4 hours, the inventory in tank 

T-81 can also be gravity fed to the TDAFW pump. To 

allow credit for an 8 hour supply, tanks T-2 and T-81 

will be missile protected. Following the required 

modifications, tanks T -2 and T -81 will be considered 

robust against all of the applicable tornado missile 

hazards described on Table 2 of RG 1.76, Rev. 1, with 

the single exception of tank T-81 foundation mounting 

bolts. Tank T-81 would be fully protected against the 

design basis tornado missile hazards of a 6-inch 

Schedule 40 steel pipe and a 1-inch diameter solid 

steel sphere (the exception being anchor bolting for 

the automobile missile hazard impact). A white paper 

describing the tornado generated missile hazard 

evaluation for tank T -81 has been posted to the 

ePortal. 

This Open Item is also addressed by updated AQ 

PAL -044 response. 

014. Select the location of FLEX Complete/Closed 

equipment storage facility. Refer to 011. One set of equipment will be stored in a 

new structure inside the PA designed for the Seismic 

event. An additional set(s) of equipment will be stored 

outside the PA in a structure(s) providing an 

appropriate level of protection for the tornado event. 

Both sets will be protected against other applicable 

(screened-in) BDBEE external hazards. 

015. Perform seismic evaluation of Complete/Closed 

turbine-driven auxiliary feedwater Seismic evaluation documents the seismic 

pump (TDAFWP) driver K-8. qualification of the pump and associated components. 

The TDAFW pump is qualified with the exception of an 

outlier related to a check for bolt tightness. Bolt 

tightness on the pump is being performed under WO# 

372138 and documented under EC 46465. 

016. Evaluate strategies to extend Complete/Closed 

battery coping time. The battery load shedding strategy has been revised 

to extend the battery coping time through shedding 

loads in addition to those identified in the station 

blackout procedure. The results indicate a coping 

time of at least 8 hours for the installed batteries 

Page 4 of 16 
Overall Integrated Plan Open Item Status

accompanying the expected deep load shed list. This

Open Item is addressed by updated AQ PAL-018

response.

017. Evaluate sources of non- Complete/Closed

borated water in addition to After depletion of T-2 and T-81, makeup to the steam condensate storage tank (T-2) and generators (SGs) will be from a portable pump with T-81. the credited suction source being Lake Michigan.

Modifications to credit sources of non-borated water

for sources other than T-2, T-81 and Lake Michigan

were determined to not be required.

018. Palisades Probabilistic Risk Complete/Closed

Assessment (PRA) to provide Palisades PRA provided multiple evaluations for justification why battery room battery room hydrogen generation. It was determined ventilation is not required until 24 that supplemental ventilation is required approximately hours. 1.5 hours after charging begins for removal of

hydrogen. Ventilation is not required for Phase 2

temperature control. This supplemental ventilation

has been included in the Palisades strategy. This

Open Item is addressed by updated AQ PAL-025

response.

019. Evaluate the effects of FLEX Started

on security procedures. The security plan/program will be updated to

correspond to FLEX procedures.

0110. Evaluate requirements of Complete/Closed

mobile purification unit from RRC. It was determined that the 250 gpm NSRC

demineralized water treatment unit is preferred over

the 100 gpm NSRC reverse osmosis unit in order to

support SG makeup and provide makeup to the NSRC

mobile boration unit. The mobile purification unit is

only required to enhance Phase 3 actions post 72

hours.

0111. Evaluate requirements of Complete/Closed

mobile boration unit from RRC. Current strategy is to have adequate borated water

inventory onsite for 72 hours to cope with any BDBEE.

Therefore, the requirements of the mobile boration

unit from NSRC is only required to enhance Phase 3

actions post 72 hours.

0112. Evaluate methods of venting Complete/Closed

the fuel handling building. The strategy for venting the fuel handling building will

be to open an existing double leaf door/hatch on the

roof of the building.

0113. Evaluate the use of Complete/Closed

high-efficiency LED lighting. The use of high-efficiency LED lighting has been

evaluated for its impact to battery coping time and

control room heat loads. LED lighting would have

Page 5 of 16

Overall Integrated Plan Open Item Status 

accompanying the expected deep load shed list. This 

Open Item is addressed by updated AQ PAL-018 

response. 

017. Evaluate sources of non- Complete/Closed 

borated water in addition to After depletion of T-2 and T-81 , makeup to the steam condensate storage tank (T -2) and generators (SGs) will be from a portable pump with T-81. the credited suction source being Lake Michigan. 

Modifications to credit sources of non-borated water 

for sources other than T-2, T-81 and Lake Michigan 

were determined to not be required. 

018. Palisades Probabilistic Risk Complete/Closed 

Assessment (PRA) to provide Palisades PRA provided multiple evaluations for justification why battery room battery room hydrogen generation. It was determined ventilation is not required until 24 that supplemental ventilation is required approximately hours. 1.5 hours after charging begins for removal of 

hydrogen. Ventilation is not required for Phase 2 

temperature control. This supplemental ventilation 

has been included in the Palisades strategy. This 

Open Item is addressed by updated AQ PAL-025 

response. 

019. Evaluate the effects of FLEX Started 

on security procedures. The security plan/program will be updated to 

correspond to FLEX procedures. 

0110. Evaluate requirements of Complete/Closed 

mobile purification unit from RRC. It was determined that the 250 gpm NSRC 

demineralized water treatment unit is preferred over 

the 100 gpm NSRC reverse osmosis unit in order to 

support SG makeup and provide makeup to the NSRC 

mobile boration unit. The mobile purification unit is 

only required to enhance Phase 3 actions post 72 

hours. 

0111. Evaluate requirements of Complete/Closed 

mobile boration unit from RRC. Current strategy is to have adequate borated water 

inventory onsite for 72 hours to cope with any BDBEE. 

Therefore, the requirements of the mobile boration 

unit from NSRC is only required to enhance Phase 3 

actions post 72 hours. 

0112. Evaluate methods of venting Complete/Closed 

the fuel handling building. The strategy for venting the fuel handling building will 

be to open an existing double leaf door/hatch on the 

roof of the building. 

0113. Evaluate the use of Complete/Closed 

high-efficiency LED lighting. The use of high-efficiency LED lighting has been 

evaluated for its impact to battery coping time and 

control room heat loads. LED lighting would have 

Page 5 of 16 
Overall Integrated Plan Open Item Status

minimal impact and is not required or recommended.

0114. Perform evaluation to Complete/Closed

determine if additional parameters In addition to NEt 12-06, PWROG FLEX guidance was will need to be monitored during reviewed for key parameter monitoring. The NEt FLEX activities. 12-06 and PWROG guidance regarding

recommended instrumentation has been incorporated

into the FLEX strategy and the power supply for these

instruments evaluated. All the credited instruments

are powered by battery/DC buses and available

throughout the event.

0115. Perform analysis to ensure Complete/Closed

survivabiIit’ of containment. Containment analysis has been completed using the

Modular Accident Analysis Program (MAAP). Results

of this analysis show containment design parameters

will not be exceeded for the at-power scenario (i.e.,

event initiating in Mode 1). For the most conservative

shutdown scenario (i.e., Mode 5 reduced inventory),

results of the analysis show that a vent path will be

required to prevent exceeding the design limits of

containment. Containment vent paths that could be

used are the personnel air lock, the emergency air

lock, or the equipment hatch. Procedural controls will

be established using the supplemental guidance

provided in the NRC-endorsed NEI position paper

titled “Shutdown / Refueling Modes.” This Open Item

is addressed by updated AQ PAL-050 response.

0116. Evaluate borated water Complete/Closed

sources in addition to safety All additional sources of borated water were evaluated injection refueling water tank for use following a BDBEE. This Open Item is (SIRWT). addressed by updated AQ PAL-048 response.

0117. Entergy, for the Palisades Complete/Closed

site, will negotiate and execute a

contract with Strategic Alliance for

FLEX Emergency Response

(SAFER) that will meet the

requirements of NEI 12-06, Section

12.

0118. Evaluate a location to install a Complete/Closed

tee in the service water system to Several locations in the service water system were allow the ultimate heat sink (UHS) evaluated. A pipe elbow downstream of service water FLEX pump to provide cooling, system (SWS) pump P-7C was identified as the best

location for connecting a pipe tee to allow flow from

the NSRC UHS pump. This Open Item is related to

ISE Confirmatory Item 3.2.4.1 .B and is addressed on

updated AQ response spreadsheet on the ePortal.

Page 6 of 16

Overall Integrated Plan Open Item Status 

minimal impact and is not required or recommended. 

0114. Perform evaluation to Complete/Closed 

determine if additional parameters In addition to NEI 12-06, PWROG FLEX guidance was will need to be monitored during reviewed for key parameter monitoring. The NEI FLEX activities. 12-06 and PWROG guidance regarding 

recommended instrumentation has been incorporated 

into the FLEX strategy and the power supply for these 

instruments evaluated. All the credited instruments 

are powered by battery/DC buses and available 

throughout the event. 

0115. Perform analysis to ensure Complete/Closed 

survivability of containment. Containment analysis has been completed using the 

Modular Accident Analysis Program (MAAP). Results 

of this analysis show containment design parameters 

will not be exceeded for the at-power scenario (Le., 

event initiating in Mode 1). For the most conservative 

shutdown scenario (Le., Mode 5 reduced inventory), 

results of the analysis show that a vent path will be 

required to prevent exceeding the design limits of 

containment. Containment vent paths that could be 

used are the personnel air lock, the emergency air 

lock, or the equipment hatch. Procedural controls will 

be established using the supplemental guidance 

provided in the NRC-endorsed NEI position paper 

titled "Shutdown / Refueling Modes." This Open Item 

is addressed by updated AQ PAL-050 response. 

0116. Evaluate borated water Complete/Closed 

sources in addition to safety All additional sources of borated water were evaluated injection refueling water tank for use following a BDBEE. This Open Item is (SIRWT). addressed by updated AQ PAL-048 response. 

0117. Entergy, for the Palisades Complete/Closed 

site, will negotiate and execute a 

contract with Strategic Alliance for 

FLEX Emergency Response 

(SAFER) that will meet the 

requirements of NEI 12-06, Section 

12. 

0118. Evaluate a location to install a Complete/Closed 

tee in the service water system to Several locations in the service water system were allow the ultimate heat sink (UHS) evaluated. A pipe elbow downstream of service water FLEX pump to provide cooling. system (SWS) pump P-7C was identified as the best 

location for connecting a pipe tee to allow flow from 

the NSRC UHS pump. This Open Item is related to 

ISE Confirmatory Item 3.2.4.1.B and is addressed on 

updated AQ response spreadsheet on the ePortal. 

Page 6 of 16 
Overall Integrated Plan Open Item Status

0119. Evaluate the use of lake water Complete/Closed

to cool the steam generators during An analysis has been completed that determined the loss of ac power impacts on the steam generators when using lake ( ). water as the makeup source. The analysis

determined that the heat transfer capability of each

steam generator was diminished by approximately

4.4% after 120 hours. This reduction in heat transfer

capability was determined to be inconsequential due

to the reduced decay heat load by 120 hours into the

event and therefore is acceptable.

0120. Evaluate time until primary Complete/Closed

coolant system (PCS) makeup is An evaluation was performed that documented the

necessary in Modes 5 & 6. time until PCS makeup is required in shutdown

modes. The time when makeup is required varies

greatly depending on the status of the PCS when the

event occurs (i.e., PCS level, pressure, and

temperature). The most limiting scenario was found to

be such that PCS makeup could be required as early

as one hour after the event if the PCS is vented and at

reduced inventory. High risk evolutions such as

vented PCS and reduced inventory will be managed

by outage risk planning and contingency actions such

as pre-staging equipment as discussed in the NEI

position paper titled “Shutdown I Refueling Modes.”

0121. Evaluate connection to ensure Complete/Closed

cooling water can be provided for Cooling water flow to the containment air fans is containment air fans. through the service water system addressed in the

status update to Cl 18. Connection of the NSRC

supplied FLEX UHS pump to the SWS will provide the

necessary means/connection for cooling water flow to

the containment air coolers.

0122. Evaluate the robustness of Complete/Closed

the charging pumps. The charging pumps have been evaluated as robust

for all applicable external events (seismic, tornado,

high temperature, low temperature and flooding). This

Open Item is addressed by updated AQ PAL-041

response.

Interim Staff Evaluation Open Items Status

3.1.1 .2.A Evaluate the impact of potential soil This item is addressed on

liquefaction on deployment of portable FLEX updated Audit Question

equipment. (AQ) response spreadsheet

on the ePortal.

3.1.1 .2.B Evaluate the potential need for a power source This item is addressed on

to move or deploy the equipment (e.g., to open updated AQ response

Page 7 of 16

Overall Integrated Plan Open Item Status 

0119. Evaluate the use of lake water Complete/Closed 

to cool the steam generators during An analysis has been completed that determined the 

an extended loss of ac power impacts on the steam generators when using lake (ELAP). water as the makeup source. The analysis 

determined that the heat transfer capability of each 

steam generator was diminished by approximately 

4.4 % after 120 hours. This reduction in heat transfer 

capability was determined to be inconsequential due 

to the reduced decay heat load by 120 hours into the 

event and therefore is acceptable. 

0120. Evaluate time until primary Complete/Closed 

coolant system (PCS) makeup is An evaluation was performed that documented the 

necessary in Modes 5 & 6. time until PCS makeup is required in shutdown 

modes. The time when makeup is required varies 

greatly depending on the status of the PCS when the 

event occurs (Le., PCS level, pressure, and 

temperature). The most limiting scenario was found to 

be such that PCS makeup could be required as early 

as one hour after the event if the PCS is vented and at 

reduced inventory. High risk evolutions such as 

vented PCS and reduced inventory will be managed 

by outage risk planning and contingency actions such 

as pre-staging equipment as discussed in the NEI 

position paper titled "Shutdown / Refueling Modes." 

0121. Evaluate connection to ensure Complete/Closed 

cooling water can be provided for Cooling water flow to the containment air fans is containment air fans. through the service water system addressed in the 

status update to 01 18. Connection of the NSRC 

supplied FLEX UHS pump to the SWS will provide the 

necessary means/connection for cooling water flow to 

the containment air coolers. 

0122. Evaluate the robustness of Complete/Closed 

the charging pumps. The charging pumps have been evaluated as robust 

for all applicable external events (seismic, tornado, 

high temperature, low temperature and flooding). This 

Open Item is addressed by updated AQ PAL-041 

response. 

Interim Staff Evaluation Open Items Status 

3.1.1.2.A Evaluate the impact of potential soil This item is addressed on 

liquefaction on deployment of portable FLEX updated Audit Question 

equipment. (AQ) response spreadsheet 

on the ePorta!. 

3.1.1.2.8 Evaluate the potential need for a power source This item is addressed on 

to move or deploy the equipment (e.g., to open updated AQ response 

Page 7 of 16 
the door from a storage location), spreadsheet on the ePortal.

3.1.1 .3.A Evaluate impacts from large internal flooding This item is addressed on

sources that are not seismically robust and the updated AQ response

potential impact on the mitigating strategies. spreadsheet on the ePortal.

3.1.1 .3.B Evaluate the potential for ground water to This item is addressed on

impact the mitigating strategies. updated AQ response

spreadsheet on the ePortal.

3.1.5.1.A Evaluate the potential for high temperature This item is addressed on

hazards to impact the functionality of FLEX updated AQ response

equipment in the FLEX storage facility, spreadsheet on the ePortal.

3.1.5.3.A Evaluate the potential for high temperature This item is addressed on

hazards to impact the deployment of FLEX updated AQ response

equipment. spreadsheet on the ePortal.

3.2.1.8.A Verify resolution of the generic concern This item is addressed by

associated with the modeling of the timing and updated AQ PAL-015

uniformity of the mixing of a liquid boric acid response.

solution injected into the PCS under natural

circulation conditions potentially involving twophase flow.

3.2.1 .9.B Provide additional justification for the alternate This item is addressed by

approach to NEI 12-06 involving the use of updated AQ PAL-041

installed charging pumps. response.

Interim Staff Evaluation Confirmatory Items Status

3.1.3.1 .A Confirm that the FLEX storage facility(s) will meet This item is addressed on

the plant’s design-basis tornado wind speed of 300 updated AQ response

mph or will be designed or evaluated equivalent to spreadsheet on the

ASCE 7-10 using a tornado wind speed of 230 ePortal.

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 is addressed by

20 minutes of the event are adequate and updated AQ PAL-Cl 1

reasonably achievable when the associated ELAP response.

procedures are developed and validated.

3.2.1 .B Confirm the robustness of the charging pump This item is addressed by

control circuit or provide FLEX procedure updated AQ PAL-Cl 1

guidance to manually operate the charging pumps response.

by breaker operation.

3.2.1 .C Confirm the seismic robustness of the BAST This item is addressed by

piping to support use of the BAST water as a updated AQ PAL-047

supply source for the charging pumps. response.

3.2.1 .D Confirm the availability and adequacy of a borated This item is addressed by

water supply to support the PCS makeup strategy. updated AQ PAL-048

response.

Page 8 of 16

the door from a storage location}. spreadsheet on the ePortal. 

3.1.1.3.A Evaluate impacts from large internal flooding This item is addressed on 

sources that are not seismically robust and the updated AQ response 

potential impact on the mitigating strategies. spreadsheet on the ePortal. 

3.1.1.3.B Evaluate the potential for ground water to This item is addressed on 

impact the mitigating strategies. updated AQ response 

spreadsheet on the ePortal. 

3.1.S.1.A Evaluate the potential for high temperature This item is addressed on 

hazards to impact the functionality of FLEX updated AQ response 

equipment in the FLEX storage facility. spreadsheet on the ePortal. 

3.1.S.3.A Evaluate the potential for high temperature This item is addressed on 

hazards to impact the deployment of FLEX updated AQ response 

equipment. spreadsheet on the ePortal. 

3.2.1.8.A Verify resolution of the generic concern This item is addressed by 

associated with the modeling of the timing and updated AQ PAL-01S 

uniformity of the mixing of a liquid boric acid response. 

solution injected into the PCS under natural 

circulation conditions potentially involving twophase flow. 

3.2.1.9.B Provide additional justification for the alternate This item is addressed by 

approach to N EI 12-06 involving the use of updated AQ PAL-041 

installed charging pumps. response. 

Interim Staff Evaluation Confirmatory Items Status 

3.1.3.1.A Confirm that the FLEX storage facility(s} will meet This item is addressed on 

the plant's design-basis tornado wind speed of 300 updated AQ response 

mph or will be designed or evaluated equivalent to spreadsheet on the 

ASCE 7-10 using a tornado wind speed of 230 ePortal. 

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 is addressed by 

20 minutes of the event are adequate and updated AQ PAL-011 

reasonably achievable when the associated ELAP response. 

procedures are developed and validated. 

3.2.1.B Confirm the robustness of the charging pump This item is addressed by 

control circuit or provide FLEX procedure updated AQ PAL-011 

guidance to manually operate the charging pumps response. 

by breaker operation. 

3.2.1.C Confirm the seismic robustness of the BAST This item is addressed by 

piping to support use of the BAST water as a updated AQ PAL-047 

supply source for the charging pumps. response. 

3.2.1.D Confirm the availability and adequacy of a borated This item is addressed by 

water supply to support the PCS makeup strategy. updated AQ PAL-048 

response. 

Page 8 of 16 
Interim Staff Evaluation Confirmatory Items Status

3.2.1 .E Confirm the continued functionality of the This item is addressed by

Atmospheric Dump Valves in the context of a updated AQ PAL-055

tornado missile hazard during an ELAP in order to response.

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 is addressed by

equipment to function as credited in the mitigation updated AQ PAL-043

strategies in accordance with the external event response.

criteria described in NEI-12-06.

3.2.1.1 .A Confirm that the use of Combustion Engineering This item is addressed

Nuclear Transient Simulator (CENTS) in the ELAP by updated AQ PAL-003

analysis is limited to the flow conditions prior to response.

reflux boiling initiation. This confirmation should

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 is addressed by

leakage rate assumed in the ELAP analysis is updated AQ PAL-004

justified. Specifically, if the PCP seal leakage rate response.

used in the plant-specific analysis is less than he

upper bound expectation for the seal leakage rate

(15 gpm/seal) discussed in the PWROG position

paper addressing the PCP seal leakage for

Combustion Engineering plants (ADAMS

Accession No. ML13235A151, non-publicly

available), justification should be provided.

3.2.1 .2.B Confirm whether seal failure will occur or not when This item is addressed by

subcooling of the coolant in the PCS cold-legs is updated AQ PAL-004

greater than 50 degrees Fahrenheit (°F). This response.

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 is addressed by

of controlled bleed-off (CBO), confirm the updated AQ PAL-004

assumption that the integrity of the PCP seals can response.

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 (SOE) and time constraints so established.

Page 9 of 16

Interim Staff Evaluation Confirmatory Items Status 

3.2.1.E Confirm the continued functionality of the This item is addressed by 

Atmospheric Dump Valves in the context of a updated AQ PAL-055 

tornado missile hazard during an ELAP in order to response. 

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 is addressed by 

equipment to function as credited in the mitigation updated AQ PAL-043 

strategies in accordance with the external event response. 

criteria described in N EI-12-06. 

3.2.1.1.A Confirm that the use of Combustion Engineering This item is addressed 

Nuclear Transient Simulator (CENTS) in the ELAP by updated AQ PAL-003 

analysis is limited to the flow conditions prior to response. 

reflux boiling initiation. This confirmation should 

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 is addressed by 

leakage rate assumed in the ELAP analysis is updated AQ PAL-004 

justified. Specifically, if the PCP seal leakage rate response. 

used in the plant-specific analysis is less than he 

upper bound expectation for the seal leakage rate 

(15 gpm/seal) discussed in the PWROG position 

paper addressing the PCP seal leakage for 

Combustion Engineering plants (ADAMS 

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 is addressed by 

subcooling of the coolant in the PCS cold-legs is updated AQ PAL-004 

greater than 50 degrees Fahrenheit (OF). This response. 

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 is addressed by 

of controlled bleed-off (CBO), confirm the updated AQ PAL-004 

assumption that the integrity of the PCP seals can response. 

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 (SOE) and time constraints so established. 

Page 9 of 16 
Interim Staff Evaluation Confirmatory Items Status

3.2.1.3.A Confirm the applicability of ANS 5.1-1979 + 2 This item is addressed by

sigma decay heat curve, updated AQ PAL-012

response.

3.2.1 .5.A Confirm the containment temperature, pressure, This item is addressed by

and moisture profiles during the ELAP event, and updated AQ PAL-013

justify the adequacy of the computer response.

codes/methodologies, and assumptions used in

the analysis.

3.2.1 .5.B Confirm whether further instrumentation is needed This item is addressed by

based upon ongoing ELAP evaluations, updated AQ PAL-013, AQ

PAL-027 and AQ PAL-035

responses.

3.2.1 .6.A Complete validation of the SQE timeline. This item is addressed by

updated AQ PAL-030

response.

3.2.1.6.B In the audit process, the licensee has indicated This item is addressed by

that an assessment has been performed updated AQ PAL-Ol 1

identifying potential changes to the SQE. Confirm response.

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 is addressed by

consistent with the times assumed in the final updated AQ PAL-014

version of the Integrated Plan. response.

3.2.2.A Resolve the discrepancy between the licensee- This item is addressed on

determined flow rate of 100 gallons per minute updated AQ response

(gpm) SFP spray and the 250 gpm performance spreadsheet on the

attribute of NEt 12-06, Table D-3. ePortal.

3.2.3.A Confirm the plan assumptions for containment This item is addressed by

cooling, after completion of the containment updated AQ PAL-050 and

response analysis. AQ PAL-053 responses.

3.2.4.1 .A Confirm whether supplemental cooling is required This item is addressed on

for components or systems used in the mitigating updated AQ response

strategies plan. spreadsheet on the

ePortal.

3.2.4.1 .B Confirm the connection point for the UHS FLEX This item is addressed on

Pump to the Service Water System. updated AQ response

spreadsheet on the

ePortal.

3.2.4.2.A Confirm the adequacy of the ventilation provided This item is addressed by

in the battery room to protect the batteries from updated AQ PAL-023

the effects of extreme high and low temperatures. response.

3.2.4.2.B Confirm the adequacy of battery room ventilation This item is addressed by

to prevent hydrogen accumulation while updated AQ PAL-025

recharging the batteries in Phase 2 or Phase 3. response.

Page 10 of 16

Interim Staff Evaluation Confirmatory Items Status 

3.2.1.3.A Confirm the applicability of ANS 5.1-1979 + 2 This item is addressed by 

sigma decay heat curve. updated AQ PAL-012 

response. 

3.2.1.5.A Confirm the containment temperature, pressure, This item is addressed by 

and moisture profiles during the ELAP event, and updated AQ PAL-013 

justify the adequacy of the computer response. 

codes/methodologies, and assumptions used in 

the analysis. 

3.2.1.5.8 Confirm whether further instrumentation is needed This item is addressed by 

based upon ongoing ELAP evaluations. updated AQ PAL-013, AQ 

PAL-027 and AQ PAL-035 

responses. 

3.2.1.6.A Complete validation of the SOE timeline. This item is addressed by 

updated AQ PAL-030 

response. 

3.2.1.6.8 I n the audit process, the licensee has indicated This item is addressed by 

that an assessment has been performed updated AQ PAL-011 

identifying potential changes to the SOE. Confirm response. 

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 is addressed by 

consistent with the times assumed in the final updated AQ PAL-014 

version of the Integrated Plan. response. 

3.2.2.A Resolve the discrepancy between the licensee- This item is addressed on 

determined flow rate of 100 gallons per minute updated AQ response 

(gpm) SFP spray and the 250 gpm performance spreadsheet on the 

attribute of NEI12-06, Table D-3. ePortal. 

3.2.3.A Confirm the plan assumptions for containment This item is addressed by 

cooling, after completion of the containment updated AQ PAL-050 and 

response analysis. AQ PAL-053 responses. 

3.2.4.1.A Confirm whether supplemental cooling is required This item is addressed on 

for components or systems used in the mitigating updated AQ response 

strategies plan. spreadsheet on the 

ePortal. 

3.2.4.1.8 Confirm the connection point for the UHS FLEX This item is addressed on 

Pump to the Service Water System. updated AQ response 

spreadsheet on the 

ePortal. 

3.2.4.2.A Confirm the adequacy of the ventilation provided This item is addressed by 

in the battery room to protect the batteries from updated AQ PAL-023 

the effects of extreme high and low temperatures. response. 

3.2.4.2.8 Confirm the adequacy of battery room ventilation This item is addressed by 

to prevent hydrogen accumulation while updated AQ PAL-025 

recharging the batteries in Phase 2 or Phase 3. response. 

Page 10 of 16 
Interim Staff Evaluation Confirmatory Items Status

3.2.4.3.A Confirm whether heat tracing is required for This item is addressed by

borated water systems. updated AQ PAL-007

response.

3.2.4.4.A Confirm that communication enhancements NRC Confirmatory Action

credited in the NRC’s communication assessment

{ADAMS Accession No. ML13129A219) are

completed as planned.

3.2.4.6.A Confirm that habitability limits will be maintained This item is addressed on

and/or operator protective measures will be updated AQ response

employed in all phases of an ELAP to ensure spreadsheet on the

operators will be capable of FLEX strategy ePortal.

execution under adverse temperature conditions.

3.2.4.7.A Confirm that the evaluation of the CST and T-81 This item is addressed by

shows that the tank qualification is consistent with updated AQ PAL-044

the strategy and the provisions of NEI 12-06. response.

3.2.4.7.B Confirm that the FLEX Support Guidelines provide This item is addressed by

clear criteria for transferring to the next preferred updated AQ PAL-045

source of water when refilling the CST. response.

3.2.4.10.A Confirm that the load shed calculation verifies This item is addressed by

adequate battery capacity with sufficient margin updated AQ PAL-018 and

throughout Phase 1 to assure the battery does not AQ PAL-033 responses.

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 is addressed on

equipment used to implement the response updated AQ response

conform to the criteria of NEI 12-06, Section 12.2, spreadsheet on the

with regards to considerations 2 through 10. ePortal.

Page 11 of 16

Interim Staff Evaluation Confirmatory Items Status 

3.2.4.3.A Confirm whether heat tracing is required for This item is addressed by 

borated water systems. updated AQ PAL -007 

response. 

3.2.4.4.A Confirm that communication enhancements NRC Confirmatory Action 

credited in the NRC's communication assessment 

{ADAMS Accession No. ML 13129A219) are 

completed as planned. 

3.2.4.6.A Confirm that habitability limits will be maintained This item is addressed on 

and/or operator protective measures will be updated AQ response 

employed in all phases of an ELAP to ensure spreadsheet on the 

operators will be capable of FLEX strategy ePortal. 

execution under adverse temperature conditions. 

3.2.4.7.A Confirm that the evaluation of the CST and T-81 This item is addressed by 

shows that the tank qualification is consistent with updated AQ PAL-044 

the strategy and the provisions of NEI 12-06. response. 

3.2.4.7.8 Confirm that the FLEX Support Guidelines provide This item is addressed by 

clear criteria for transferring to the next preferred updated AQ PAL-045 

source of water when refilling the CST. response. 

3.2.4.10.A Confirm that the load shed calculation verifies This item is addressed by 

adequate battery capacity with sufficient margin updated AQ PAL-018 and 

throughout Phase 1 to assure the battery does not AQ PAL-033 responses. 

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 is addressed on 

equipment used to implement the response updated AQ response 

conform to the criteria of NEI 12-06, Section 12.2, spreadsheet on the 

with regards to considerations 2 through 10. ePortal. 

Page 11 of 16 
Audit Status Completion or Target

Question Date

PAL-002 Closed*

Updated response available on the ePortal (ISE PAL-003 Confirmatory Item 3.2.1.i.A)

Updated response available on the ePortal (ISE

Confirmatory Item 3.2.1 .2.A)

Updated response available on the ePortal (ISE PAL-004 Confirmatory Item 3.2.1 .2.B)

Updated response available on the ePortal (ISE

Confirmatory Item 3.2.1.2.C)

Updated response available on the ePortal (ISE PAL-007 Confirmatory Item 3.2.4.3.A)

PAL-008 Updated response available on the ePortal

Updated response available on the ePortal (ISE

Confirmatory Item 3.2.1 .A)

Updated response available on the ePortal (ISE PAL-Ol 1 Confirmatory Item 3.2.1 .B)

Updated response available on the ePortal (ISE

Confirmatory Item 3.2.i.6.B)

Updated response available on the ePortal (ISE PAL-Ui 2 Confirmatory Item 3.2.i.3.A)

Updated response available on the ePortal (ISE

Confirmatory Item 3.2.1.5.A) PAL-Ol 3

Updated response available on the ePortal (ISE

Confirmatory Item 3.2.1.5.B)

Updated response available on the ePortal (ISE PAL-Ui 4 Confirmatory Item 3.2.i.9.A)

Updated response available on the ePortal (ISE PAL-Ol 5 Open Item 3.2.1.8.A)

PAL-Ui 6 Updated response available on the ePortal

In progress - This AQ response will be updated PAL-Ui 7 Oct 2015 when information is available

Updated response available on the ePortal (ISE PAL-Ui 8 Confirmatory Item 3.2.4.iO.A)

PAL-Ui9 Updated response available on the ePortal

PAL-U2U Closed*

PAL-02i Updated response available on the ePortal

PAL-U22 Closed*

PAL-U23 Updated response available on the ePortal (ISE

Page 12 of 16

Audit Status Completion or Target 

Question Date 

PAL-002 Closed* 

PAL-003 Updated response available on the ePortal (I SE 

Confirmatory Item 3.2.1.1.A) 

Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.2.A) 

PAL-004 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.2.8) 

Updated response available on the ePortal (I SE 

Confirmatory Item 3.2.1.2.C) 

PAL-OO? Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.4.3.A) 

PAL-OOB Updated response available on the ePortal 

Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.A) 

PAL-011 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.8) 

Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.6.8) 

PAL-012 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.3.A) 

Updated response available on the ePortal (I SE 

PAL-013 Confirmatory Item 3.2.1.5.A) 

Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.5.8) 

PAL-014 Updated response available on the ePortal (I SE 

Confirmatory Item 3.2.1.9.A) 

PAL-015 Updated response available on the ePortal (ISE 

Open Item 3.2.1.B.A) 

PAL-016 Updated response available on the ePortal 

PAL-01? In progress - This AQ response will be updated Oct 2015 when information is available 

PAL-01B Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.4.1 O.A) 

PAL-019 Updated response available on the ePortal 

PAL-020 Closed* 

PAL-021 Updated response available on the ePortal 

PAL-022 Closed* 

PAL-023 Updated response available on the ePortal (I SE 

Page 12 of 16 
Audit Status Completion or Target

Question Date

Confirmatory Item 3.2.4.2.A)

PAL-024 Closed*

PAL-025 Updated response available on the ePortal (ISE

Confirmatory Item 3.2.4.2.B)

PAL-026 Updated response available on the ePortal

PAL-027 Updated response available on the ePortal (ISE

Confirmatory Item 3.2.1.5.B)

PAL-028 Updated response available on the ePortal

Updated response available on the ePortal (ISE PAL-030 Confirmatory Item 3.2.1.6.A)

PAL-033 Updated response available on the ePortal (ISE

Confirmatory Item 3.2.4.1O.A)

PAL-035 Updated response available on the ePortal (ISE

Confirmatory Item 3.2.1 .5.B)

PAL-036 Updated response available on the ePortal

PAL-037 Updated response available on the ePortal

PAL-039 Closed*

PAL-040 Updated response available on the ePortal

Updated response available on the ePortal (ISE PAL-041 Open Item 3.2.1.9.B)

Updated response available on the ePortal (ISE PAL-043 Confirmatory Item 3.2.1.F)

Updated response available on the ePortal (ISE PAL-044 Confirmatory Item 3.2.4.7.A)

Updated response available on the ePortal (ISE PAL-045 Confirmatory Item 3.2.4.7.B)

PAL-046 Updated response available on the ePortal

Updated response available on the ePortal (ISE PAL-047 Confirmatory Item 3.2.1 .C)

Updated response available on the ePortal (ISE PAL-048 Confirmatory Item 3.2.1.D)

PAL-049 Updated response available on the ePortal

Updated response available on the ePortal (ISE PAL-050 Confirmatory Item 3.2.3.A)

PAL-051 In progress - This AQ response will be updated Feb 2015 when information is available

Updated response available on the ePortal (ISE PAL-053 Confirmatory Item 3.2.3.A)

Page 13 of 16

Audit Status Completion or Target 

Question Date 

Confirmatory Item 3.2.4.2.A) 

PAL-024 Closed* 

PAL-025 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.4.2.8) 

PAL-026 Updated response available on the ePortal 

PAL-027 Updated response available on the ePortal (I SE 

Confirmatory Item 3.2.1.5.8) 

PAL-028 Updated response available on the ePortal 

PAL-030 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.6.A) 

PAL-033 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.4.1 O.A) 

PAL-035 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.5.8) 

PAL-036 Updated response available on the ePortal 

PAL-037 Updated response available on the ePortal 

PAL-039 Closed* 

PAL-040 Updated response available on the ePortal 

PAL-041 Updated response available on the ePortal (ISE 

Open Item 3.2.1.9.8) 

PAL-043 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.F) 

PAL-044 Updated response available on the ePortal (I SE 

Confirmatory Item 3.2.4.7 .A) 

PAL-045 Updated response available on the ePortal (I SE 

Confirmatory Item 3.2.4.7.8) 

PAL-046 Updated response available on the ePortal 

PAL-047 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.C) 

PAL-048 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.0) 

PAL-049 Updated response available on the ePortal 

PAL-050 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.3.A) 

PAL-051 In progress - This AQ response will be updated Feb 2015 when information is available 

PAL-053 Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.3.A) 

Page 13 of 16 
Audit Completion or Target Status Question Date

PAL-054 Updated response available on the ePortal

Updated response available on the ePortal (ISE PAL-055 Confirmatory Item 3.2.1.E)

PAL-056 Closed*

PAL-057 Updated response available on the ePortal

* Closed indicates that the ENO response is complete.

7 Potential Interim Staff Evaluation Impacts

The following items have been identified which have potential impact to the Interim Staff

Evaluation (ISE) except for those identified in Section 6.

1. ISE/TER, Section 3.0, Page 5, second paragraph, the ISE states, “A portable FLEX

generator will be connected to the existing plant electrical distribution system.

Another FLEX diesel generator will power one of the installed plant charging. . .

The current strategy uses only one FLEX generator. This FLEX generator is

sufficiently sized to carry all the loads that are planned for use in the Phase 2 FLEX

strategy.

2. ISE/TER Section 3.1.1.2, Page 8, second paragraph, the TER states “On page 26 of

the Integrated Plan, the licensee identified the connection point for the strategy to refill

the condensate storage tank (CST) as being...” The Phase 2 core cooling strategy

has changed such that the CST refill will not be used. Instead, inventory for feeding

the steam generators in Phase 2 will be provided directly to the main feed water

(MFW) system piping or the auxiliary feed water (AFW) system piping via hose

connections, thereby bypassing the CST. The source of water for Phase 2 SG

makeup will be directly from Lake Michigan using a portable FLEX pump staged on

the west side of the Intake Structure.

3. ISE/TER Section 3.1.1.2, Page 8, fourth paragraph, the TER states, “...regarding SFP

cooling water, the available suction sources for all the above options are the safety

injection and refueling water storage tank (SIRWT) and Lake Michigan.” The current

strategy does not credit the SIRWT. The SFP makeup suction source will be directly

from Lake Michigan using the FLEX portable transfer pump.

4. ISE/TER Section 3.2.1, Page 28, sixth paragraph, the TER states, “...a design

change is in the preliminary stages to modify the ADV backup nitrogen supply source

from the High Pressure System to bottled nitrogen.” The design change/modification

selected, and which will allow for the remote manual operation of the ADVs, is the

installation of backup nitrogen bottles to last through Phase 1 and connection point for

an air compressor to be connected to the Phase 2 FLEX generator.

5. ISE/TER Section 3.2.1.9, Page 46, last paragraph, the TER states, “...the FLEX

pump that can be used for both SEP makeup and CST refill along...” The Phase 2

core cooling strategy has changed such that the CST refill will not be used. Instead,

Page 14 of 16

Audit Status Completion or Target 

Question Date 

PAL-OS4 Updated response available on the ePortal 

PAL-OSS Updated response available on the ePortal (ISE 

Confirmatory Item 3.2.1.E) 

PAL-OS6 Closed* 

PAL-OS7 Updated response available on the ePortal 

* Closed indicates that the END response is complete. 

7 Potential Interim Staff Evaluation Impacts 

The following items have been identified which have potential impact to the Interim Staff 

Evaluation (lSE) except for those identified in Section 6. 

1. ISElTER, Section 3.0, Page 5, second paragraph, the ISE states, "A portable FLEX 

generator will be connected to the existing plant electrical distribution system . 

..... Another FLEX diesel generator will power one of the installed plant charging .... " 

The current strategy uses only one FLEX generator. This FLEX generator is 

sufficiently sized to carry all the loads that are planned for use in the Phase 2 FLEX 

strategy. 

2. ISEITER Section 3.1.1.2, Page 8, second paragraph, the TER states "On page 26 of 

the Integrated Plan, the licensee identified the connection point for the strategy to refill 

the condensate storage tank (CST) as being ... " The Phase 2 core cooling strategy 

has changed such that the CST refill will not be used. Instead, inventory for feeding 

the steam generators in Phase 2 will be provided directly to the main feed water 

(MFW) system piping or the auxiliary feed water (AFW) system piping via hose 

connections, thereby bypassing the CST. The source of water for Phase 2 SG 

makeup will be directly from Lake Michigan using a portable FLEX pump staged on 

the west side of the Intake Structure. 

3. ISEITER Section 3.1.1.2, Page 8, fourth paragraph, the TER states, " ... regarding SFP 

cooling water, the available suction sources for all the above options are the safety 

injection and refueling water storage tank (SIRWT) and Lake Michigan." The current 

strategy does not credit the SIRWT. The SFP makeup suction source will be directly 

from Lake Michigan using the FLEX portable transfer pump. 

4. ISEITER Section 3.2.1, Page 28, sixth paragraph, the TER states, " ... a design 

change is in the preliminary stages to modify the ADV backup nitrogen supply source 

from the High Pressure System to bottled nitrogen." The design change/modification 

selected, and which will allow for the remote manual operation of the ADVs, is the 

installation of backup nitrogen bottles to last through Phase 1 and connection point for 

an air compressor to be connected to the Phase 2 FLEX generator. 

5. ISEITER Section 3.2.1.9, Page 46, last paragraph, the TER states, " ... the FLEX 

pump that can be used for both SFP makeup and CST refill along ... " The Phase 2 

core cooling strategy has changed such that the CST refill will not be used. Instead, 

Page 14 of 16 
inventory for feeding the steam generators in Phase 2 will be provided directly to the

main feed water (MEW) system piping or the auxiliary feed water (AEW) system

piping via hose connections, thereby bypassing the CST. The source of water for

Phase 2 SG makeup will be directly from Lake Michigan using a FLEX portable

transfer pump.

6. ISE/TER Section 3.2.1.9, Page 47, first paragraph, the TER states, “. . ..or CST refill

pump (FLEX transfer pump) may be utilized to . . .“ The Phase 2 core cooling strategy

has changed such that the CST refill will not be used. Instead inventory for feeding

the steam generators will be provided by the FLEX portable transfer pump directly to

the main feed water (MEW) system piping or the auxiliary feed water (AEW) system

via hose connections, thereby bypassing the CST.

7. ISE/TER Section 3.2.2, Page 49, second paragraph, the TER states, “Since the SEP

makeup and CST refill both have relatively. . .“ The Phase 2 core cooling strategy has

changes such that the CST refill will not be used. Instead inventory for feeding the

steam generators will be provided by the FLEX portable transfer pump directly to the

main feed water (MEW) system piping or the auxiliary feed water (AFW) system via

hose connections, thereby bypassing the CST.

8. ISE/TER Section 3.2.2, Page 49, first paragraph, the TER states, “The available

suction sources for all of the above options are the SIRWT and Lake Michigan.” The

current strategy does not credit the SIRWT. The SEP makeup suction source will be

Lake Michigan using the FLEX portable transfer pump.

9. ISE/TER Section 3.2.4.7, Page 57, last paragraph, the TER states, “...core cooling

uses a portable FLEX transfer pump to refill the CST to prolong...” The Phase 2 core

cooling strategy has changes such that the CST refill will not be used. Instead

inventory for feeding the steam generators will be provided by the FLEX portable

transfer pump directly to the main feed water (MEW) system piping or the auxiliary

feed water (AEW) system via hose connections, thereby bypassing the CST.

10. ISE/TER Section 3.2.4.7, Page 58, fourth paragraph, the TER states, “...to connect

portable pumps to refill the CST.” The Phase 2 core cooling strategy has changes

such that the CST refill will not be used. Instead inventory for feeding the steam

generators will be provided by the FLEX portable transfer pump directly to the main

feed water (MEW) system piping or the auxiliary feed water (AEW) system via hose

connections, thereby bypassing the CST.

11. ISE/TER Section 3.2.4.7, Page 58, first paragraph, the TER states, “. . . initiated at hour

24, the mobile water purification unit should be received from the RRC.. .“ This timing

was determined to be not required by the strategy as evaluated in EC 46465. EC

46465 determined that the use of Lake Michigan for up to 120 hours has

inconsequential impact on Steam Generator fouling based on decay heat load

present. Palisades will accept a mobile purification unit as evaluated for its use in EC

46465 at 72 hours for use in a long term Phase 3 strategy. Therefore the purification

units will not be credited until 72 hours after the event.

Page 15 of 16

inventory for feeding the steam generators in Phase 2 will be provided directly to the 

main feed water (MFW) system piping or the auxiliary feed water (AFW) system 

piping via hose connections, thereby bypassing the CST. The source of water for 

Phase 2 SG makeup will be directly from Lake Michigan using a FLEX portable 

transfer pump. 

6. ISEITER Section 3.2.1.9, Page 47, first paragraph, the TER states, " .... or CST refill 

pump (FLEX transfer pump) may be utilized to ... " The Phase 2 core cooling strategy 

has changed such that the CST refill will not be used. Instead inventory for feeding 

the steam generators will be provided by the FLEX portable transfer pump directly to 

the main feed water (MFW) system piping or the auxiliary feed water (AFW) system 

via hose connections, thereby bypassing the CST. 

7. ISEITER Section 3.2.2, Page 49, second paragraph, the TER states, "Since the SFP 

makeup and CST refill both have relatively ... " The Phase 2 core cooling strategy has 

changes such that the CST refill will not be used. Instead inventory for feeding the 

steam generators will be provided by the FLEX portable transfer pump directly to the 

main feed water (MFW) system piping or the auxiliary feed water (AFW) system via 

hose connections, thereby bypassing the CST. 

8. ISEITER Section 3.2.2, Page 49, first paragraph, the TER states, ''The available 

suction sources for all of the above options are the SIRWT and Lake Michigan." The 

current strategy does not credit the SIRWT. The SFP makeup suction source will be 

Lake Michigan using the FLEX portable transfer pump. 

9. ISEITER Section 3.2.4.7, Page 57, last paragraph, the TER states, " ... core cooling 

uses a portable FLEX transfer pump to refill the CST to prolong ... " The Phase 2 core 

cooling strategy has changes such that the CST refill will not be used. Instead 

inventory for feeding the steam generators will be provided by the FLEX portable 

transfer pump directly to the main feed water (MFW) system piping or the auxiliary 

feed water (AFW) system via hose connections, thereby bypassing the CST. 

10. ISEITER Section 3.2.4.7, Page 58, fourth paragraph, the TER states, " ... to connect 

portable pumps to refill the CST." The Phase 2 core cooling strategy has changes 

such that the CST refill will not be used. Instead inventory for feeding the steam 

generators will be provided by the FLEX portable transfer pump directly to the main 

feed water (MFW) system piping or the auxiliary feed water (AFW) system via hose 

connections, thereby bypassing the CST. 

11. ISEITER Section 3.2.4.7, Page 58, first paragraph, the TER states, " .. .initiated at hour 

24, the mobile water purification unit should be received from the RRC ... " This timing 

was determined to be not required by the strategy as evaluated in EC 46465. EC 

46465 determined that the use of Lake Michigan for up to 120 hours has 

inconsequential impact on Steam Generator fouling based on decay heat load 

present. Palisades will accept a mobile purification unit as evaluated for its use in EC 

46465 at 72 hours for use in a long term Phase 3 strategy. Therefore the purification 

units will not be credited until 72 hours after the event. 

Page 15 of 16 
8 References

The following references support the updates to the Overall Integrated Plan described in this

attachment.

1. ENO 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. ML13246A399).

2. 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. ML12054A736).

3. ENO 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.

ML1 3241 A234).

4. ENO 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.

ML1 4059A078).

5. NRC letter, Pailsades Nuclear Plant — Interim Staff Evaluation Regarding Overall

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

MFO768), dated February 10, 2014 (ADAMS Accession No. ML13365A264).

Page 16 of 16

8 References 

The following references support the updates to the Overall I ntegrated Plan described in this 

attachment. 

1. ENO 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). 

2. 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). 

3. ENO 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). 

4. ENO 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). 

5. 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). 

Page 16 of 16