• Entergy 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

Tel 269 764 2000 

Charles F. Arnone 

Site Vice President 

PNP 2016-058 

November 29, 2016 

U. S. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

SUBJECT: Spent Fuel Pool Evaluation Supplemental Report, Response to NRC 

Request for Information Pursuant to 10 CFR 50.54(f) Regarding 

Recommendation 2.1 of the Near-Term Task Force Review of Insights from 

the Fukushima Dai-ichi Accident 

References: 

Palisades Nuclear Plant 

Docket 50-255 

Renewed Facility Operating License No. DPR-20 

1. NRC letter, Request for Information Pursuant to Title 10 of the 

Code of Federal Regulations 50.54(f) Regarding 

Recommendations 2.1,2.3, and 9.3 of the Near-Term Task Force 

Review of Insights from the Fukushima Dai-ichi Accident, dated 

March 12, 2012 (ADAMS Package Accession Number 

ML 12056A046) 

2. NRC letter, Final Determination of Licensee Seismic Probabilistic 

Risk Assessments Under the Request for Information Pursuant to 

Title 10 of the Code of Federal Regulations 50.54(f) Regarding 

Recommendation 2.1 "Seismic" of the Near-Term Task Force 

Review of Insights from the Fukushima Dai-ichi Accident, dated 

October 27,2015 (ADAMS Accession Number ML15194A015) 

3. Nuclear Energy Institute letter, Request for Endorsement of 

"Seismic Evaluation Guidance: Spent Fuel Pool Integrity 

Evaluation (EPRI 3002007148)," dated February 23, 2016 

(ADAMS Accession Number ML 16055A017) 

4. Electric Power Research Institute Report Number 3002007148, 

Seismic Evaluation Guidance: Spent Fuel Pool Integrity 

Evaluation, February 2016 (ADAMS Accession Number 

ML 16055A021) 
PNP 2016-058 

Page 2 of 3 

5. NRC letter, Endorsement of Electric Power Research Institute 

Report 3002007148, "Seismic Evaluation Guidance: Spent Fuel 

Pool Integrity Evaluation," dated March 17, 2016 (ADAMS 

Accession Number ML 15350A 158) 

6. Entergy Nuclear Operations, Inc. letter, PNP 2014-033, 

Palisades Nuclear Plant Seismic Hazard and Screening Report 

(CEUS Sites), Response to NRC Request for Information 

Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of 

Recommendation 2. 1 of the Near-Term Task Force Review of 

Insights from the Fukushima Dai-ichi Accident, dated March 31, 

2014 (ADAMS Accession Number ML 14090A069) 

7. NRC letter, Palisades Nuclear Plant - Staff Assessment of 

Information provided Pursuant to Title 10 of the Code of Federal 

Regulations Part 50, Section 50.54(f), Seismic Hazard 

Reevaluations for Recommendation 2.1 of the Near-Term Task 

Force Review of Insights from the Fukushima Dai-ichi Accident 

(TAC No. MF3786), dated April 30, 2015 (ADAMS Accession 

Number ML 15098A032) 

8. Electric Power Research Institute Report Number 1025287, 

Seismic Evaluation Guidance: Screening, Prioritization and 

Implementation Details (SPID) for the Resolution of Fukushima 

Near-Term Task Force Recommendation 2. 1: Seismic, dated 

November 2012 (ADAMS Accession Number ML 12333A 170) 

Dear Sir or Madam: 

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

50.54(f) letter to all power reactor licensees and holders of construction permits in 

active or deferred status. Enclosure 1, titled "Recommendation 2.1: Seismic," Item (9) 

in the 50.54(f) letter requested addressees to provide spent fuel pool (SFP) integrity 

evaluations with any actions identified to address any discovered vulnerabilities. 

By letter dated October 27,2015 (Reference 2), the NRC transmitted final seismic 

information request tables which identified that Entergy Nuclear Operations, Inc. (ENO) 

is to conduct a limited scope SFP evaluation for Palisades Nuclear Plant (PNP). By 

Reference 3, Nuclear Energy Institute (NEI) submitted an Electric Power Research 

Institute (EPRI) Report Number 3002007148, entitled "Seismic Evaluation Guidance: 

Spent Fuel Pool Integrity Evaluation," (Reference 4) for NRC review and endorsement. 

NRC endorsement of EPRI Report Number 3002007148 was provided in Reference 5. 

EPRI Report Number 3002007148 provides criteria for evaluating the seismic adequacy 

of a SFP to the reevaluated ground motion response spectrum (GMRS) hazard levels. 

This report supplements the guidance in the Seismic Evaluation Guidance, Screening, 

Prioritization and Implementation Details (SPID) (Reference 8) for plants where the 

GMRS peak spectral acceleration is less than or equal to 0.8g. Section 3.3, 
PNP 2016-058 

Page 3 of 3 

"Site-Specific Spent Fuel Pool Criteria for Low GMRS Sites," of EPRI Report Number 

3002007148 lists the parameters to be verified to confirm that the results of the report 

are applicable to PNP and that the PNP SFP is seismically adequate in accordance 

with the Near-Term Task Force (NTIF) Recommendation 2.1 seismic evaluation 

criteria. 

The attachment to this letter provides the data for the PNP that confirms applicability of 

the EPRI Report Number 3002007148 criteria, confirms that the SFP is seismically 

adequate, and provides the requested information in response to Item (9) of the 

50.54(f) letter associated with NTIF Recommendation 2.1: Seismic. 

This letter contains no new regulatory commitments and no revisions to existing 

regulatory commitments. 

I declare under penalty of perjury that the foregoing is true and correct. Executed on 

November 29, 2016. 

Sincerely, 

CFA/jse 

Attachment: Site-Specific Spent Fuel Pool Criteria for Palisades Nuclear Plant 

cc: Director of Office of Nuclear Regulation, USNRC 

Administrator, Region III, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
PNP 2016-058 

ATTACHMENT 

SITE-SPECIFIC SPENT FUEL POOL CRITERIA 

FOR PALISADES NUCLEAR PLANT 
ATTACHMENT 

SITE-SPECIFIC SPENT FUEL POOL CRITERIA 

FOR PALISADES NUCLEAR PLANT 

The Near-Term Task Force (NTTF) 50.54(f) letter requested that, in conjunction with the 

response to NTTF Recommendation 2.1, a seismic evaluation be made of the spent fuel 

pool (SFP). More specifically, licensees were asked to consider "all seismically induced 

failures that can lead to draining of the SFP." Such an evaluation would be needed for 

any plant in which the ground motion response spectrum (GMRS) exceeds the safe 

shutdown earthquake (SSE) in the 1 to 10Hz frequency range. The staff confirmed 

through References 2 and 7 that the GMRS exceeds the SSE and concluded that a SFP 

evaluation is merited for the Palisades Nuclear Plant (PNP). By letter dated March 17, 

2016 (Reference 5), the staff determined that Electric Power Research Institute (EPRI) 

Report Number 3002007148 was an acceptable approach for performing SFP 

evaluations for plants in which the peak spectral acceleration is less than or equal to 

0.8g. 

The table below lists the criteria from Section 3.3, "Site-Specific Spent Fuel Pool Criteria 

for Low GMRS Sites," of EPRI Report Number 3002007148 along with data for PNP that 

confirms applicability of the EPRI Report Number 3002007148 criteria, and confirms that 

the SFP is seismically adequate and can retain adequate water inventory for 72 hours in 

accordance with NTTF 2.1 seismic evaluation criteria. 

SFP Criteria from EPRI PNP SFP Site-Specific Data 

Report Number 3002007148 

Site Parameters 

1. The site-specific GMRS peak spectral The PNP site GMRS peak spectral acceleration as 

acceleration at any frequency should reported in Reference 6 as accepted by the NRC in 

be less than or equal to 0.8g. Reference 7 is 0.56g, which is less than or equal 

to 0.8g; therefore, this criterion is met for PNP. 

Structural Parameters 

1. The structure housing the SFP should The SFP is housed in the Auxiliary Building, which is 

be designed using an SSE with a seismically designed to the site SSE with a PGA of 

peak ground acceleration (PGA) of 0.2g. The PNP PGA is greater than 0.1 g; therefore, 

at least 0.1 g. this criterion is met for PNP. 

2. The structural load path to the SFP The structural load path from the Auxiliary Building 

should consist of some combination foundation to the SFP consists of reinforced 

of reinforced concrete shear wall concrete floors and shear walls from the 590 foot 

elements, reinforced concrete frame elevation to the base of the SFP. The SFP is wholly 

elements, post-tensioned concrete contained within the reinforced concrete structure of 

elements and/or structural steel frame the Auxiliary Building as shown in Updated Final 

elements. Safety Analysis Report (UFSAR) Figures 1-5 thru 

1-8; therefore, this criterion is met for PNP. 

1of4 
ATTACHMENT 

SITE-SPECIFIC SPENT FUEL POOL CRITERIA 

FOR PALISADES NUCLEAR PLANT 

SFP Criteria from EPRI PNP SFP Site-Specific Data 

Report Number 3002007148 

3. The SFP structure should be included The SFP structure is included in the PNP Structural 

in the Civil Inspection Program Monitoring Inspection Program in accordance with 

performed in accordance with 10 CFR 50.65, Requirements for monitoring the 

Maintenance Rule. effectiveness of maintenance at nuclear power 

plants, which monitors the performance or condition 

of structures, systems, or components (SSCs) in a 

manner sufficient to provide reasonable assurance 

that these SSCs are capable of fulfilling their 

intended functions. Therefore, this criterion is met 

for PNP. 

Non-Structural Parameters 

1. To confirm applicability of the piping Piping attached to the SFP is evaluated to the SSE 

evaluation in Section 3.2 of EPRI in accordance with PNP Specification M-195(Q), 

3002007148, piping attached to the Technical Requirements for the Design and Analysis 

SFP up to the first valve should have of Safety Related Piping and Instrument Tubing; 

been evaluated for the SSE. therefore, this criterion is met for PNP. 

2. Anti-siphoning devices should be An anti-siphon device is installed on the SFP cooling 

installed on any piping that could lead system supply piping, which consists of a short 

to siphoning water from the SFP. In section of 1-112 inch pipe connected to the 12-inch 

addition, for any cases where active supply piping. The elevation of the open end of the 

anti-siphoning devices are attached to 1-112 inch pipe is slightly below the normal SFP 

2-inch or smaller piping and have water level which prevents any significant backflow 

extremely large extended operators, through the supply line piping should that pipe fail in 

the valves should be walked down to an area below the discharge elevation in the pool. 

confirm adequate lateral support. The SFP cooling suction piping, as well as all other 

piping entering the pool, is located near the top of 

the pool, which obviates the need for an anti-siphon 

device since a pipe break cannot contribute to 

draining of the pool. 

As described, the anti-siphoning device is installed 

on the one SFP pipe that could lead to siphoning; 

therefore, this criterion is met for PNP. 

There are no valves or operators on this 

anti-siphoning device. The pipe is inactive and 

benign. 

As described, no anti-siphoning devices are 

attached to 2-inch or smaller piping with extremely 

large extended operators; therefore, this criterion is 

met for PNP. 

20f4 
ATTACHMENT 

SITE-SPECIFIC SPENT FUEL POOL CRITERIA 

FOR PALISADES NUCLEAR PLANT 

SFP Criteria from EPRI PNP SFP Site-Specific Data 

Report Number 3002007148 

3. To confirm applicability of the sloshing The PNP main SFP has a length of 38.75 ft, a width 

evaluation in Section 3.2 of EPRI of 14.67 ft and a depth of 38 ft, and the connected 

3002007148, the maximum SFP North Tilt Pit portion of the pool is 21 ft long, 5 ft 

horizontal dimension (length or width) wide, and 39 ft deep based on PNP UFSAR Figures 

should be less than 125 ft, the SFP 1-5 thru 1-8; therefore, this criterion is met. 

depth should be greater than 36 ft, The PNP GMRS maximum spectral acceleration in and the GMRS peak Sa should be the frequency range less than 0.3 Hz is 0.04g from <0.1 g at frequencies equal to or less Reference 6, which is less than 0.1 g; therefore, this than 0.3 Hz. criterion is met. 

4. To confirm applicability of the The surface area of the PNP main SFP is 568.5 If, 

evaporation loss evaluation in which is greater than 500 If. Including the North tilt 

Section 3.2 of EPRI 3002007148, the pit and its connecting channel to the main pool, the 

SFP surface area should be greater total surface area is 685 If. Licensed reactor 

than 500 If and the licensed reactor thermal power for PNP is 2565.4 MWt which is less 

core thermal power should be less than 4,000 MWt; therefore, this criterion is met. 

than 4,000 MWt per unit. 

References 

1. NRC letter, Request for Information Pursuant to Title 10 of the Code of Federal 

Regulations 50.54(f) Regarding Recommendations 2. 1, 2.3, and 9.3 of the 

Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, 

dated March 12, 2012 (ADAMS Package Accession Number ML 12056A046). 

2. NRC letter, Final Determination of Licensee Seismic Probabilistic Risk Assessments 

Under the Request for Information Pursuant to Title 10 of the Code of Federal 

Regulations 50.54(f) Regarding Recommendation 2. 1 "Seismic" of the Near-Term 

Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated October 

27,2015 (ADAMS Accession Number ML 15194A015) 

3. Nuclear Energy Institute letter, Request for Endorsement of "Seismic Evaluation 

Guidance: Spent Fuel Pool Integrity Evaluation (EPRI3002007148)," dated 

February 23, 2016 (ADAMS Accession Number ML 16055A017) 

4. EPRI Report Number 3002007148, Seismic Evaluation Guidance: Spent Fuel Pool 

Integrity Evaluation, February 2016 (ADAMS Accession Number ML 16055A021) 

5. NRC letter, Endorsement of Electric Power Research Institute Report 3002007148, 

"Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation," dated March 

17, 2016 (ADAMS Accession Number ML 15350A 158). 

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