UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

Vice President, Operations 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, Ml 49043-9530 

June 1, 2015 

SUBJECT: NUCLEAR REGULATORY COMMISSION PLAN FOR THE AUDIT OF 

ENTERGY NUCLEAR OPERATIONS, INC.'S FLOOD HAZARD 

REEVALUATION REPORT SUBMITTAL RELATING TO THE NEAR-TERM 

TASK FORCE RECOMMENDATION 2.1-FLOODING FOR PALISADES 

NUCLEAR PLANT (TAC NO. MF6128) 

Dear Sir or Madam: 

This letter documents the U.S. Nuclear Regulatory Commission (NRC) staff's plan to perform a 

regulatory audit of Entergy Nuclear Operations, lnc.'s (the licensee) supporting calculations for 

the Flood Hazard Reevaluation Report (FHRR) submittal related to the Near-Term Task Force 

Recommendation 2.1, Flooding for Palisades Nuclear Plant (Palisades). This technical audit 

will be performed consistent with NRC Office of Nuclear Reactor Regulation, Office Instruction 

LIC-111, "Regulatory Audits," dated December 29, 2008 (Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML082900195). The audit will be conducted 

over multiple sessions, as needed, and the NRC staff will develop an audit summary report to 

document its observations and conclusions within 90 days of the final audit session. 

The audit will provide the NRC staff with a better understanding of the Palisades FHRR which 

was submitted March 11, 2015 (ADAMS Accession No. ML 15106A681 ). Specifically, the audit 

will provide the NRC with a better understanding of the analyses of the flooding hazards 

presented in the Palisades FHRR. The audit is intended to support completion of the staff's 

review of the FHRR and the subsequent issuance of a Staff Assessment. 

The enclosed audit plan outlines the process that will allow the NRC staff to identify additional 

information potentially necessary for licensees to supplement their FHRRs, and resolve 

potential technical concerns. The details of this audit have been discussed with Mr. Donald 

Bentley of your staff. 
- 2 -

If you have any questions, please contact me at (301) 415-6197 or by e-mail at 

tekia.govan@nrc.gov. 

Docket No. 50-255 

Enclosure: 

Audit Plan 

cc w/encl: Distribution via Listserv 

Sincerely, 

Tekia V. Govan, Project Manager 

Hazards Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 
NRC PLAN FOR THE AUDIT OF ENTERGY NUCLEAR OPERATIONS. INC.'S FLOOD 

HAZARD REEVALUATION REPORT SUBMITTAL RELATING TO THE NEAR-TERM TASK 

FORCE RECOMMENDATION 2.1-FLOODING FOR PALISADES NUCLEAR PLANT 

BACKGROUND AND AUDIT BASIS: 

By letter dated March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued a 

request for information to all power reactor licensees and holders of construction permits in 

active or deferred status, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), 

Section 50.54(f) "Conditions of license" (hereafter referred to as the "50.54(f) letter"). The 

request was issued in connection with implementing lessons-learned from the 2011 accident at 

the Fukushima Dai-ichi nuclear power plant, as documented in The Near-Term Task Force 

Review of Insights from the Fukushima Dai-ichi Accident. Recommendation 2.1 of that 

document recommended that the staff issue orders to all licensees to reevaluate seismic and 

flooding for their sites against current NRC requirements and guidance. Subsequent Staff 

Requirements Memoranda associated with Commission Papers SECY 11-0124 and 

SECY-11-0137, instructed the NRC staff to issue requests for information to licensees pursuant 

to 10 CFR 50.54(f). 

By letter dated March 11, 2015, Entergy Nuclear Operations, lnc.'s (Entergy, the licensee) 

submitted its Flood Hazard Reevaluation Report (FHRR) for Palisades Nuclear Plant 

(Palisades) (Agencywide Documents Access and Management System Accession No. 

ML 15106A681 ). The NRC staff has begun its review of the aforementioned submittals and 

plans to conduct a regulatory audit of Entergy to aid in its review of the licensee's FHRR. 

REGULATORY AUDIT SCOPE AND METHODOLGY: 

The areas of focus for the regulatory audit is the information contained in the Palisades FHRR 

submittal, and all associated and relevant supporting documentation used in the development of 

the aforementioned document including, but not limited to, methodology, process information, 

calculations, computer models, etc. The audit will be conducted and completed over several 

meetings that are to be determined, as necessary. 

Enclosure 
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INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT: 

The information required for the audit is the licensee's models and supporting calculations, 

aswell as documentation related to the storm surge and site specific probable maximum 

precipitation analyses. Other information needs will be discussed as audit meetings are 

scheduled. 

NRC AUDIT TEAM: 

Title Team Member Affiliation 

Team Leader, NRR/JLD Tekia Govan NRC 

Branch Chief, NRO/DSEA Chris Cook NRC 

Technical Lead Lyle Hibler NRC 

Technical Manaqer Laura Quinn-Willinqham NRC 

Technical Support Various Contractors Department of Energy National 

Laboratory 

LOGISTICS: 

The audit meetings will be coordinated with Entergy staff. 

DELIVERABLES: 

The NRC team will develop an audit summary report to convey the audit results. The report will 

be placed in ADAMS within 90 days of the completion of the final audit session, and will be 

publicly available. 

The information discussed in the audit may be included, fully or in part, in the development of 

the NRC technical staff's assessments as a result of the FHRR review. 
- 2 -

If you have any questions, please contact me at (301) 415-6197 or by e-mail at 

tekia.govan@nrc.gov. 

Docket No. 50-255 

Enclosure: 

Audit Plan 

cc w/encl: Distribution via Listserv 

DISTRIBUTION: 

PUBLIC 

JLD R/F 

RidsNRRJLD Resource 

LHibler, NRO 

CCook, NRO 

JBowen, NRR 

MShams, NRR 

ARivera, NRO 

BHarvey,NRO 

ADAMS Accession No.: ML 15146A293 

Sincerely, 

IRA/ 

Tekia V. Govan, Project Manager 

Hazards Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 

LWillingham, NRO TGovan, NRR 

KErwin, NRO MFranovich, NRR 

RidsNrrPMPalisades Resource 

RidsNrrDorllpl3-1 

OFFICE NRR/JLD/JHMB/PM NRR/JLD/JHMB/LA NRR/JLD/JHMB/BC NRR/JLD/JHMB/PM 

NAME TGovan Slent MShams TGovan 

DATE 05/27/15 05/27/15 05/31/15 06/01/15 

OFFICAL RECORD COPY