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 

December 13, 2016 

SUBJECT: PALISADES NUCLEAR PLANT- STAFF REVIEW OF SPENT FUEL POOL 

EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD 

IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1 (CAC 

NO. MF3786) 

Dear Sir or Madam: 

The purpose of this letter is to inform Entergy Nuclear Operations, Inc. (Entergy, the licensee) of 

the results of the U.S. Nuclear Regulatory Commission (NRC) staff's review of the spent fuel 

pool (SFP) evaluation for Palisades Nuclear Plant (Palisades), which was submitted in response 

to Item 9 of Enclosure 1 of the NRC's March 12, 2012, request for information (Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML 12053A340), issued 

under Title 10 of the Code of Federal Regulations Part 50, Section 50.54(f) (hereafter referred to 

as the 50.54(f) letter). The NRC staff concludes that the licensee's assessment was performed 

consistent with the NRC-endorsed SFP Evaluation Guidance Report and that the licensee has 

provided sufficient information to complete the response to Item 9 of the 50.54(f) letter. 

BACKGROUND 

On March 12, 2012, the NRC issued a 50.54(f) letter as part of implementing lessons learned 

from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 1 to the 50.54(f) 

letter requested that licensees reevaluate seismic hazards at their sites using present-day 

methodologies and guidance. Enclosure 1, Item 4, of the 50.54(f) letter requested that 

licensees perform a comparison of the ground motion response spectrum (GMRS) and the safe 

shutdown earthquake (SSE). The staff's assessment of the information provided in response to 

Items 1-3 and 5-7 of the 50.54(f) letter is provided by letter dated April 30, 2015 (ADAMS 

Accession No. ML 15098A032). Enclosure 1, Item 9, of the 50.54(f) letter requested that, when 

the GMRS exceeds the SSE in the 1 to 10 Hertz frequency range, a seismic evaluation be 

made of the SFP. More specifically, plants were asked to consider " ... all seismically induced 

failures that can lead to draining of the SFP." 
- 2 :-

By letter dated February 23, 2016 (ADAMS Accession No. ML 16055A021 ), the Nuclear Energy 

Institute (NEI) staff submitted Electric Power Research Institute (EPRI) Report No. 3002007148 

entitled, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation" (SFP Evaluation 

Guidance Report). The SFP Evaluation Guidance Report provides criteria for evaluating the 

seismic adequacy of an SFP to the reevaluated GMRS hazard levels. This report supplements 

the guidance in EPRI Report 1025287, "Seismic Evaluation Guidance: Screening, Prioritization 

and Implementation Details (SPID)" (ADAMS Accession No. ML 12333A 170), for plants where 

the GMRS peak spectral acceleration is less than or equal to 0.8g (low GMRS sites). The NRG 

endorsed the SFP Evaluation Guidance Report by letter dated March 17, 2016 (ADAMS 

Accession No. ML 15350A 158), as an acceptable method for licensees to use when responding 

to Item 9 in Enclosure 1 of the 50.54(f) letter. 

By letter dated October 27, 2015 (ADAMS Accession No. ML15194A015), the NRG staff stated 

that SFP evaluation submittals for low GMRS sites are expected by December 31, 2016. 

REVIEW OF LICENSEE SPENT FUEL POOL EVALUATION 

By letter dated November 29, 2016 (ADAMS Accession No. ML 16334A405), the licensee 

submitted its SFP evaluation for Palisades for NRG review. The NRG staff assessed the 

licensee's implementation of the SFP Evaluation Guidance Report through the completion of a 

reviewer checklist, which is included as an enclosure to this letter. 

TECHNICAL EVALUATION 

Section 3.0 of the SFP Evaluation Guidance Report develops SFP evaluation criteria for plants 

with GMRS peak spectral acceleration less than or equal to 0.8g. These criteria address SFP 

structural elements (e.g., floors, walls, and supports); non-structural elements (e.g., 

penetrations); seismically-induced SFP sloshing; and water losses due to heat-up and boil-off. 

Section 3.0 also provides applicability criteria, which will enable licensees to determine if their 

site-specific conditions are within the bounds considered in developing the evaluation criteria for 

this report. The staff's review consists of confirming that these SFP site-specific conditions are 

within the bounds considered for the evaluation criteria specified in the SFP Evaluation 

Guidance Report. 

1.1 Spent Fuel Pool Structural Evaluation 

Section 3.1 of the SFP Evaluation Guidance Report provides a SFP structural evaluation 

approach used to demonstrate that the SFP structure is sufficiently robust against the 

reevaluated seismic hazard. This approach supplements the guidance in Section 7 of the SPID 

and followed acceptable methods used to assess the seismic capacity of structures, systems, 

and components (SSCs) for nuclear power plants as documented in EPRI NP-6041, 

"A Methodology for Assessment of Nuclear Plant Seismic Margin, Revision 1." Table 3-2 of the 

SFP Evaluation Guidance Report (reproduced from Table 2.3 of EPRI NP-6041) provides the 

structural screening criteria to assess the SFPs and their supporting structures. 

The licensee stated that it followed the SFP structural evaluation approach presented in the 

SFP Evaluation Guidance Report and provided site-specific data to confirm its applicability. 

The NRG staff reviewed the structural information provided, which included the requested sitespecific data in Section 3.3 of the SFP Evaluation Guidance Report, and confirmed that the 
- 3 -

evaluation criteria are applicable to the Palisades site. The staff concludes that SFP SSCs were 

appropriately evaluated and screened based on the seismic capacity criteria in EPRI NP-6041, 

and that the licensee has demonstrated that the SFP structure is sufficiently robust and can 

withstand ground motions with peak spectral acceleration less than or equal to 0.8g. 

1.2 Spent Fuel Pool Non-Structural Evaluation 

Section 3.2 of the SFP Evaluation Guidance Report provides criteria for evaluating the nonstructural aspects of the SFP, such as piping connections, fuel gates, and anti-siphoning 

devices, as well as SFP sloshing and heat up and boil-off of SFP water inventory. Specifically, 

Table 3-4 of the SFP Evaluation Guidance Report provides a summary of the SFP nonstructural evaluation criteria derived in Section 3.2, along with applicability criteria to 

demonstrate that site-specific conditions are suitable for applying the evaluation criteria. 

The licensee stated that it followed the SFP non-structural evaluation approach presented in the 

guidance report and provided site-specific data to confirm its applicability. The staff reviewed 

the non-structural information provided, which included the requested site-specific data in Table 

3-4 of the SFP Evaluation Guidance Report, and confirmed that the evaluation criteria are 

applicable to the Palisades site. Therefore, the staff concludes that the licensee adequately 

evaluated the non-structural considerations for SSCs whose failure could lead to potential draindown of the SFP due to a seismic event. 

CONCLUSION 

The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC 

staff concludes that the licensee's implementation of the SFP integrity evaluation met the criteria 

of the SFP Evaluation Guidance Report for Palisades and therefore, the licensee responded 

appropriately to Item 9 in Enclosure 1 of the NRC's 50.54(f) letter. 
- 4 -

If you have any questions, please contact me at (301) 415-1617 or via e-mail at 

Frankie.Vega@nrc.gov. 

Docket No. 50-255 

Enclosure: 

Technical Review Checklist 

cc w/encl: Distribution via Listserv 

Sincerely, 

~td Frankie Vega, Z Manager 

Hazards Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 
TECHNICAL REVIEW CHECKLIST 

BY THE OFFICE OF NUCLEAR REACTOR REGULATION 

RELATED TO SPENT FUEL POOL EVALUATIONS FOR LOW GROUND MOTION 

RESPONSE SPECTRUM SITES 

IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1 SEISMIC 

PALISADES NUCLEAR PLANT 

DOCKET NO. 50-255 

BACKGROUND 

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

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

issued a request for information to all power reactor licensees and holders of construction 

permits in active or deferred status, pursuant to Title 1 O of the Code of Federal Regulations 

(10 CFR), Section 50.54(f), "Conditions of Licenses" (hereafter referred to as the "50.54(f) 

letter''). Enclosure 1 of the 50.54(f) letter requests addressees to reevaluate the seismic hazard 

at their site using present-day methods and guidance for licensing new nuclear power plants, 

and identify actions to address or modify, as necessary, plant components affected by the 

reevaluated seismic hazards. Enclosure 1, Item 4, of the 50.54(f) letter requested that licensees 

perform a comparison of the ground motion response spectrum (GMRS) with the safe shutdown 

earthquake (SSE). Enclosure 1, Item 9, requests that, when the GMRS exceeds the SSE in the 

1 to 1 O Hertz (Hz) frequency range, a seismic evaluation be made of the spent fuel pool (SFP). 

More specifically, plants were asked to consider " ... all seismically induced failures that can lead 

to draining of the SFP." 

Additionally, by letter dated February 23, 2016 (ADAMS Accession No. ML 16055A021 ), the 

Nuclear Energy Institute (NEI) submitted Electric Power Research Institute (EPRI) Report No. 

3002007148 entitled, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation" 

(SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report supports the 

completion of SFP evaluations for sites with reevaluated seismic hazard exceedance in the 1 to 

1 O Hz frequency range. Specifically, the SFP Evaluation Guidance Report addressed those 

sites where the GMRS peak spectral acceleration (Sa) is less than or equal to 0.89 (low GMRS 

sites). The NRC endorsed the SFP Evaluation Guidance Report by letter dated March 17, 2016 

(ADAMS Accession No. ML 15350A 158), as an acceptable method for licensees to use when 

responding to Item 9 in Enclosure 1 of the 50.54(f) letter. Licensee deviations from the SFP 

Evaluation Guidance should be discussed in their SFP evaluation submittal. 

By letter dated November 29, 2016 (ADAMS Accession No. ML 16334A405), Entergy Nuclear 

Operations, Inc. (Entergy, the licensee) provided an SFP report in a response to Enclosure 1, 

Item 9, of the 50.54(f) letter, for the Palisades Nuclear Plant (Palisades). The NRC staff 

performed its review of the licensee's submittal to assess whether the licensee responded 

appropriately to Item 9 in Enclosure 1 of the 50.54(f) letter. The NRC staff checked whether the 

site-specific parameters are within the bounds of the criteria considered in the SFP Evaluation 

Guidance Report, verified the SFP's seismic adequacy to withstand the reevaluated GMRS 

hazard levels, and confirmed that the requested information in response to Item 9 of the 50.54(f) 

letter was provided. 

Enclosure 
- 2 -

A review checklist was used for consistency and scope. The application of this staff review is 

limited to the SFP evaluation as part of the seismic review of low GMRS sites as part of the 

Near-Term Task Force (NTTF) Recommendation 2.1. 
NTTF Recommendation 2.1 Spent Fuel Pool Evaluations 

Technical Review Checklist for Palisades Nuclear Plant 

Site Parameters: 

I. Site-Specific GMRS 

The licensee: 

• Provided the site-specific GMRS consistent with the information 

provided in the Seismic Hazard and Screening Report (SHSR), or 

its update, and evaluated by the staff in its staff assessment. 

• Stated that the GMRS peak Sa is less than or equal to 0.8g for any 

frequency. 

Notes from the reviewer: 

Yes 

Yes 

1. The NRC staff confirmed that the site-specific peak Sa= 0.56g (SHSR - ADAMS 

Accession No. ML 14090A069). 

Deviation(s) or Deficiency(ies), and Resolution: 

No deviations or deficiencies were identified. 

The NRC staff concludes: 

• The site-specific GMRS peak Sa at any frequency is less than 0.8g . 

• The licensee's GMRS used in this evaluation is consistent with the 

information provided in the SHSR. 

Structural Parameters: 

II. Seismic Design of the SFP Structure 

The licensee: 

• Specified the building housing the SFP. 

• Specified the plant's peak ground acceleration (PGA). 

• Stated that the building housing the SFP was designed using an 

SSE with a PGA of at least 0.1 g. 

- 3 -

Yes 

Yes 

Yes 

Yes 

Yes 
Notes from the reviewer: 

1. The NRC staff confirmed that the SFP is housed in the auxiliary building which is 

designed to the site SSE with a PGA of 0.20g (SHSR Section 3.1 and Updated Final 

Safety Analysis Report (UFSAR, Section 5.9.3.1 ). 

Deviation(s) or Deficiency(ies), and Resolution: 

No deviations or deficiencies were identified. 

The NRC staff concludes that: 

• The structure housing the SFP was designed using an SSE with a Yes 

PGA of at least 0.1 g. 

Ill. Structural Load Path to the SFP 

The licensee: 

• Provided a description of the structural load path from the Yes 

foundation to the SFP. 

• Performed screening based on EPRI NP-6041 Table 2-3 screening Yes 

criteria. 

Notes from the reviewer: 

1. The staff verified the structural load path to the SFP. 

2. The staff confirmed that the structural load path from the auxiliary building foundation 

to the SFP consists of reinforced concrete floors and shear walls (UFSAR Section 

Section 5.9.3.3 and UFSAR Figures 1-5 thru 1-8). 

Deviation(s) or Deficiency(ies), and Resolution: 

No deviations or deficiencies were identified. 

The NRC staff concludes that: 

• Licensee appropriately described the structural load path to the Yes 

SFP. 

• Structures were appropriately screened based on the screening Yes 

criteria in EPRI NP-6041. 

- 4 -
IV. SFP Structure Included in the Civil Inspection Program Performed in 

Accordance with Maintenance Rule 

The licensee: 

• Stated that the SFP structure is included in the Civil Inspection Yes 

Program performed in accordance with Maintenance Rule (1 O CFR 

50.65). 

Notes from the reviewer: 

None 

Deviation(s) or Deficiency(ies), and Resolution: 

No deviations or deficiencies were identified. 

The NRC staff concludes that: 

• The SFP structure is included in the Civil Inspection Program Yes 

performed in accordance with Maintenance Rule (1 O CFR 50.65). 

Non-Structural Parameters: 

V. Applicability of Piping Evaluation 

The licensee: 

• Stated that piping attached to the SFP is evaluated to the SSE . Yes 

Notes from the reviewer: 

1. The staff confirmed that the SFP cooling system is a design Class 1 system evaluated 

to the SSE (UFSAR Section 9.4.1 and Section 5.7). 

Deviation(s) or Deficiency(ies), and Resolution: 

No deviations or deficiencies were identified. 

The NRC staff concludes that: 

• The piping attached to the SFP is evaluated to the SSE . Yes 

• Failure of piping attached to the SFP is not likely to result in rapid Yes 

drain-down as defined in the SFP evaluation guidance. 

- 5 -
• Applicability criteria specified in Table 3-4 of SFP evaluation 

guidance have been met. 

VI. Siphoning Evaluation 

The licensee: 

• Stated that anti-siphoning devices are installed on piping systems 

that could lead to siphoning inventory from the SFP. 

• In cases where anti-siphoning devices were not included on the 

applicable piping, a description documenting the evaluation 

performed to determine the seismic adequacy of the piping is 

provided. 

• Stated that the piping of the SFP cooling system cannot lead to rapid 

drain down due to siphoning. 

• Provided a seismic adequacy evaluation, in accordance with NP6041, for cases where active siphoning devices are attached to 2" or 

smaller piping with extremely large extended operators. 

• Stated that no anti-siphoning devices are attached to 2" or smaller 

piping with extremely large extended operators. 

Notes from the reviewer: 

Yes 

Yes 

N/A 

No 

N/A 

Yes 

1. The licensee stated that anti-siphoning devices are installed on all SFP piping that 

could lead to siphoning. (UFSAR Figure 9.8) 

2. Licensee stated that no active anti-siphoning devices are attached to 2" or smaller 

piping with extremely large extended operator. 

3. Piping of the SFP cooling system is not likely to lead to rapid draindown due to 

siphoning. 

Deviation(s) or Deficiency(ies), and Resolution: 

No deviations or deficiencies were identified. 

The NRC staff concludes : 

• Anti-siphoning devices exist in applicable piping systems that could Yes 

lead to siphoning water from the SFP. 

• No active anti-siphoning devices are attached to 2" or smaller piping Yes 

with extremely large extended operators. 

• Applicability criteria specified in Table 3-4 of SFP evaluation Yes 

guidance have been met. 

- 6 -
VII. Sloshing Evaluation 

The licensee: 

• Specified the SFP dimensions (length, width, and depth). Yes 

• Specified that the SFP dimensions are bounded by the dimensions Yes 

specified in the report (i.e. SFP length and width <125ft.; SFP 

depth >36ft.). 

• Stated that the peak Sa in the frequency range less than 0.3 Hz is Yes 

less than 0.1 g. 

Notes from the reviewer: 

1. Verified the SFP dimensions (UFSAR Figure 1-5 thru 1-8): 

- SFP Length - 38.75 ft. 

- SFP Width - 14.67 ft. 

- SFP Depth - 39 ft. 

2. The staff confirmed in the SHSR that the peak Sa in the frequency range less than 0.3 

Hz is less than 0.1 g (SHSR). 

Deviation(s) or Deficiency(ies), and Resolution: 

No deviations or deficiencies were identified. 

The NRC staff concludes: 

• SFP dimensions are bounded by the dimensions specified in the 

report (i.e. SFP length and width <125ft.; SFP depth >36ft.). 

• The peak Sa in the frequency range less than 0.3 Hz is less than 

0.1g. 

• Applicability criteria specified in Table 3-4 of SFP evaluation 

guidance have been met. 

VIII. Evaporation Evaluation 

The licensee: 

• Provided the surface area of the plant's SFP. 

• Stated that the surface area of the plant's SFP is greater than 

500 ft2 

• Provided the licensed reactor core thermal power. 

• Stated that the reactor core thermal power is less than 4,000 

MW, per unit. 

- 7 -

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 
Notes from the reviewer: 

1. Surface area of pool = 568.5 ft2 

2. Reactor thermal power= 2,565.4 MW, (UFSAR Section 1.1 ); 

Deviation(s) or Deficiency(ies), and Resolution: 

No deviations or deficiencies were identified. 

The NRC staff concludes: 

• The surface area of the plant's SFP is greater than 500 ft2. Yes 

• The reactor core thermal power is less than 4,000 MW, per unit. Yes 

• Applicability criteria specified in Table 3-4 of SFP evaluation Yes 

guidance have been met. 

Conclusions: 

The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC 

staff concludes that the licensee's implementation of the SFP integrity evaluation met the criteria 

of the SFP Evaluation Guidance Report for Palisades and therefore the licensee responded 

appropriately to Item 9 in Enclosure 1 of the 50.54(f) letter. 

- 8 -
- 4 -

If you have any questions, please contact me at (301) 415-1617 or via e-mail at 

Frankie.Vega@nrc.gov. 

Docket No. 50-255 

Enclosure: 

Technical Review Checklist 

cc w/encl: Distribution via Listserv 

DISTRIBUTION: 

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JHMB R/F 

RidsNrrDorlLpl3-1 Resource 

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Sincerely, 

IRA! 

Frankie Vega, Project Manager 

Hazards Management Branch 

Japan Lessons-Learned Division 

Office of Nuclear Reactor Regulation 

FVega, NRR 

BTitus, NRR 

RidsNrrPMPalisades Resource 

RidsNrrLASLent Resource 

RidsRgn3MailCenter Resource 

ADAMS Accession No.: ML 16342C530 *via e-mail 

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