• E’n teigjr ~

• E’n
~ Entergy
teigjr
Entergy
Entergy Nuclear
Nuclear Operations,
Operations, Inc.
Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Highway
Covert,
Covert, MI
Ml 49043-9530
49043-9530
Tel
269 7642000
764 2000
Tel 269
Anthony
Anthony J. Vitale
Vitale
Site
Vice President
Site Vice
President
PNP 2014-011
PNP
February 28, 2014
February
Nuclear Regulatory
U.S. Nuclear
Regulatory Commission
u.s.
ATTN: Document Control Desk
11555 Rockville Pike
Rockville, MD 20852
SUBJECT:
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)
Palisades Nuclear Plant
Docket No. 50-255
License No. DPR-20
REFERENCES:
1. NRC Order Number EA-12-049,
EA-1 2-049, Order Modifying Licenses with Regard
1.
to Requirements for Mitigation Strategies for 8eyond-Design-8asis
Beyond-Design-Basis
External Events, dated March 12, 2012 (ADAMS Accession No.
1 2054A736)
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
8eyond-Design-8asis External Events,
Revision 0, dated August 29, 2012 (ADAMS Accession No.
ML12229A174)
ML
12229A174)
3. NEI
NEI 12-06,
12-06, Diverse and Flexible Coping Strategies (FLEX)
implementation
Implementation Guide, Revision 0, dated August 2012 (ADAMS
Accession
2242A378)
Accession No.
No. ML1
ML 12242A378)
4. Entergy Nuclear Operations, Inc.
Inc. (ENO) letter
letter to NRC,
NRC, PNP 2012-091,
2012-091,
Initial Status Report in Response to March 12,
2012 Commission Order
12,2012
Modifying Licenses with Regard to Requirements for Mitigation
Strategies
Strategies for Beyond-Design-Basis
8eyond-Design-8asis External Events (Order Number
EA-12-049), dated
2012 (ADAMS
25,2012
(ADAMS Accession No.
No.
dated October
October 25,
ML1
2300A065
ML 12300A065
5.
5. Entergy
Entergy Nuclear
Nuclear Operations,
Operations, Inc.
Inc. (ENO)
(ENO) letter
letter to
to NRC,
NRC, PNP
PNP 2013-01
2013-010,
0,
Overall
Overall Integrated
Integrated Plan in
in Response
Response to March
March 12,
12,2012
Commission
2012 Commission
Order
Order Modifying
Modifying Licenses
Licenses with Regard
Regard to
to Requirements
Requirements for Mitigation
Strategies
Strategies for Beyond-Design-Basis
8eyond-Design-8asis External
External Events
Events (Order
(Order Number
Number
EA-12-049),
2013
28,2013
EA-12-049), dated
dated February
February 28,
PNP 2014-011
2014-011
PNP
Page 22 of
of 22
Page
6. Entergy
Entergy Nuclear
Nuclear Operation,
Operation, Inc.
Inc. (ENO)
(ENO) letter
6.
letter to
to NRC,
NRC, PNP
PNP 2013-064,
201 3-064,
Pailsades Nuclear
Nuclear Plant
Plant First
First Six-Month
Six-Month Status
Status Report
Palisades
Report in
in Response
Response to
to
March 12,2012
Commission Order
12, 2012 Commission
Order Modifying
Modifying Licenses
March
Licenses with
with Regard
Regard to
to
Requirements
for
Mitigation
Strategies for
for Beyond-Design-Basis
Beyond-Design-Basis
Requirements for Mitigation Strategies
External Events
Events (Order
(Order Number
Number EA-12-049),
EA- 12-049), dated
External
dated August 28,2013
28, 2013
Madam:
or Madam:
Dear Sir or
On March 12,
12, 2012, the Nuclear Regulatory Commission
Commission (NRC) issued an order (Reference
On
Nuclear Operations, Inc.
Entergy Nuclear
Inc. (ENO). Reference 11 was immediately
immediately effective and
1) to Entergy
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 11 required submission of an initial status report 60 days following issuance of the
the
final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section
IV, Condition C. Reference 2 endorses industry guidance document NEI12-06,
NEI 12-06, Revision 11
(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.
1 requires submission of a status report at six-month intervals following submittal
Reference 1
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. The purpose of this
letter is to provide the second 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.
any.
This letter contains no new commitments and no revised commitments.
II declare under penalty of perjury that the foregoing is true and correct; executed on
February 28,
28, 2013.
Sincerely,
Sincerely,
ajv/jse
ajv/jse
Attachment:
Attachment:
cc:
cc:
Palisades Nuclear
Nuclear Plant Second
Second Six-Month
Six-Month Status Report in Response to
March
March 12,
12, 2012,
2012, Commission
Commission Order Modifying
Modifying Licenses
Licenses with
with Regard
Regard to
Requirements for
for Mitigation
Mitigation Strategies
Strategies for
for Beyond-Design-Basis
Beyond-Design-Basis External
External
Events
Events (Order
(Order Number
Number EA-12-049)
EA-12-049)
Office
Office Director,
Director, NRR,
NRR, USNRC
USNRC
Administrator,
Administrator, Region
Region Ill,
III, USNRC
USNRC
Project
Project Manager,
Manager, Palisades,
Palisades, USNRC
USNRC
Inspector,
Resident
Palisades,
Resident Inspector, Palisades, USNRC
USNRC
ATTACHMENT
ATTACHMENT
Palisades Nuclear
Nuclear Plant
Plant Second
Second Six-Month
Six-Month Status
Report in
Status Report
Palisades
Response to
in Response
to
March 12,2012
12, 2012 Commission
Commission Order
Order Modifying
Modifying Licenses
Licenses with
March
Regard to
with Regard
to
Requirements for Mitigation
Mitigation Strategies
Strategies for Beyond-Design-Basis
Beyond-Design-Basis External
Requirements
External
(Order Number
Events (Order
Number EA-12-049)
EA-1 2-049)
Events
11 Introduction
(END) developed for Palisades Nuclear
Entergy Nuclear Operations, Inc. (ENO)
Nuclear Plant
Plant (PNP) an
overall integrated plan
plan (Reference 1),
1), which documented the diverse and flexible strategies
in response
response to Reference
Reference 2. This attachment provides an update of milestone
(FLEX), in
milestone
accomplishments since submittal of the last status report (Reference 3), including any
the compliance method, schedule, or need for relief/relaxation and the basis, if
changes to the
any.
Accomplishments
2 Milestone Accomplishments
The following milestone(s) have been completed since July 31, 2013, and are current as of
31, 2014.
January 31,2014.
•
First Six-Month Status Report -
•
Second Six-Month Status Report February 2014
•
FLEX Strategy Evaluation - January 2014
—
August 2013
—
Complete with submission of this document in
—
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.
•
Perlorm
Perform Staffing
Staffing Analysis
The Perform
Perform Staffing Analysis milestone
milestone completion
completion date has been changed to April 2014.
This
This new
new milestone target completion
completion date
date does
does not impact the
the Order
Order implementation date.
date.
•
Modifications Evaluation
Evaluation
The
The Modifications Evaluation milestone
milestone target completion date
date has
has been
been changed
changed to
to April
April
2014.
2014. This
This new
new milestone target completion date
date does
does not
not impact
impact the Order implementation
implementation
date.
date.
Page
Page 11 of
of 10
10
Target
Target
Completion
Completion
Date*
Date*
Activity
Activity Status
Status
2013
Feb 2013
Feb
Complete
Complete
Update 11
Update
Aug 2013
Aug
Complete
Update 2
Feb 2014
Complete
Update 3
Aug 2014
Not Started
Started
Update 4
Update
Feb 2015
Feb
Not Started
Not
Update 5
Aug 2015
Not Started
Not
FLEX Strategy Evaluation
Jan 2014
Complete
Perform Staffing Analysis
Dec 2013
Started
Apr 2014
Jan 2014
Started
Apr 2014
N-i Walkdown
N-1
Feb 2014
Started
Design Engineering
May 2014
Started
IImplementation
mplementation Outage
Oct 2015
Not Started
Jun 2014
Started
Jan 2015
Started
Oct 2015
Not Started
Milestone
Milestone
Submit Overall
Overall Integrated
Integrated
Submit
Implementation Plan
Plan
Implementation
Revised
Target
Revised Target
Completion
Completion
Date
Date
Updates
Six-Month Status Updates
Modifications
Modifications Evaluation
Engineering and Implementation
On-site FLEX Equipment
Purchase and Procure
Off-site FLEX Equipment
Develop Strategies with RRC
Install Off-Site Delivery Station (If
Necessary)
Procedures
Pressurized Water Reactor Owners
Group (PWROG) issues Nuclear
Nuclear
Steam Supply
Supply System (NSSS)
(NSSS)Specific_Guidelines
Specific Guidelines
Create PNP FLEX FSG
Jun
Jun 2013
2013
Complete
Complete
Mar
Mar 2015
Not Started
Not
Create
Create Maintenance
Maintenance Procedures
Procedures
Mar
Mar 2015
2015
Not
Not Started
Develop
Develop Training
Training Plan
Plan
Training
Training Complete
Complete
Jun 2015
2015
Jun
Sept
Sept 2015
2015
Not Started
Started
Not
Not
Not Started
Started
Validation
Validation I Demonstration
Demonstration
Oct
Oct 2015
2015
Not Started
Started
Not
Submit
Submit Completion
Completion Report
Report
Oct
Oct 2015
2015
Not
Not Started
Started
Training
Training
*Target
"Target Completion
Completion Date
Date is
is the
the last
last submitted
submitted date
date from
from either
either the
the overall
overall integrated
integrated plan
plan or
or previous
previous six-month
six-month
status
status reports
reports
Page
Page 22 of
of 10
10
Changes to Compliance
Compliance Method
Method
4 Changes
The following changes
changes are
are being
being incorporated
incorporated to
FLEX strategy
The
to the FLEX
strategy for
for PNP.
PNP.
1. Overall
Overall Integrated
Integrated Plan
Plan (OIP)
(OIP) page
page 9,
9, item
item 33 (and
(and other
1.
other locations
locations of
DIP) states
of OIP)
states the
the
battery
life
four
will be
hours. The four hour
be four hours.
hour battery
battery capacity
battery life will
capacity was determined
determined to
to
provide insufficient
insufficient margin
margin for transition to Phase
Phase 2.
2. Based
provide
Based on
on analysis and
and planning
planning
load shed, the installed
installed battery
battery capacity will be
for a deeper load
be extended to eight hours
hours
Open Item
Item 016).
016). Therefore, the time
time at
at which a portable FLEX
(see Open
FLEX generator is
required to be deployed and operational has
has been extended from hour 4 to hour 8
required
based on battery capacity.
10, item
item 9 (and other locations of DIP) stated that LC-19 will be
2. OIP page 10,
be repowered
FLEX generator. This remains the primary
from the portable FLEX
primary strategy to provide
power to battery chargers. However, Load Center 20 will also be modified similar to
Load Center 19 to provide diverse connection locations to the battery chargers.
QIP page 11, item 10 (and other locations of OIP) stated that a FLEX portable
3. OIP
transfer pump will be used to refill the CST. 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
piping via hose connections, thereby bypassing the CST.
DIP page 11, item 10 (and other locations of OIP)
DIP) requires commencement of
4. OIP
deployment of a portable FLEX pump two hours after the event such that it can be
operational four hours after the event. This was based on the limited protected
inventory of the condensate storage tank (CST) and the primary system makeup
storage tank (T-81). Additional inventory in the CST and T-81 will now be protected
(see Open Item 013) which increases the volume available for Phase 1
1 of the
beyond-design-basis external event (BDBEE). Therefore, the time at which the FLEX
pump is required to be deployed and operational has been delayed from hour 4 to
hour 8 based on CST and T-81 protected inventory. Additionally, the strategy of
refilling the CST has changed such that the CST refill will not be used.
used. Instead
inventory for feeding the steam generators will be provided directly to the main feed
water (MFW)
(MFW) system piping or the auxiliary feed water (AFW) system piping via hose
connections, thereby bypassing the CST
CST (see Open Item 017).
5. DIP
locations of
OIP page
page 11,
11, item 14
14 (and other
other locations
of DIP)
OIP) credits the battery room exhaust
exhaust
fans for removal
removal of hydrogen
hydrogen from the battery rooms. ItIt has
has been
been determined that the
the
battery
battery room exhaust
exhaust fans
fans are
are not
not robust
robust and
and cannot be
be credited.
credited. Therefore
Therefore aa new
strategy developed
developed for control of hydrogen
hydrogen will
will employ
employ the use
use of portable
portable fans for
ventilation in
in battery rooms. Also see Open
Open Item
Item 018.
018.
6.
6. OIP
OIP page
page 11,
11, item
item 15
15 (and
(and other
other locations
locations of
of DIP)
DIP) credits the
the volume
volume control
control tank
tank
(VCT)
and
injection
safety
refueling
water
tank
(VCT) and safety injection refueling water tank (SIRWT)
(SIRWT) as
as borated
borated sources
sources of
of water
water
for
for primary
primary coolant
coolant system
system (PCS)
(PCS) inventory
inventory and
and reactivity
reactivity control.
control. However,
However, itit has
has
been
been determined
determined that
that the
the VCT
VCT and
and SIRWT
SIRWT are
are not
not robust
robust for
for all
all applicable
applicable external
external
hazards.
hazards. Therefore
Therefore the
the VCT
VCT and
and SIRWT
SIRWT are
are no
no longer
longer the
the credited
credited sources
sources of
of
borated
borated water.
water. Concentrated
Concentrated boric
boric acid
acid storage
storage tanks
tanks (T-53A
(T-53A and
and T-53B)
T-53B) will
will now
now be
be
credited
in Phase
Phase 2.
2. Later
Later in
in
credited as
as the
the borated
borated water
water sources
sources for
for these
these functions
functions early
early in
Page
10
Page 33 of
of 10
Phase 22 (>
the boric
(>24
hours), the
boric acid
acid batching
batching tank
tank (T-77)
(T-77) will
Phase
24 hours),
will be
be used
batch
used to
to batch
required borated
inventory. Also
borated water
water inventory.
Also see
see Open
Open Item
Item 0116.
required
0116.
7. 01
page 12,
12, item
item 16
DIP
states that
16 states
fuel pool
that spent
spent fuel
pool (SFP)
(SFP) equipment
equipment (hoses
7.
P page
(hoses and
and monitor
monitor
nozzles) will
will be
deployed at
be deployed
at hour
hour 18
prevent SFP
18 to
to prevent
from dropping
SEP level
level from
nozzles)
dropping below
below the
the
of 15
15 feet
feet above
level of
the fuel
fuel at
above the
20.93. Under
at hour
hour 20.93.
Under worst case
level
conditions
it
is
case conditions it is
estimated that
that boiling
could occur
boiling could
beginning at
occur beginning
at approximately
approximately 5.6
estimated
5.6 hours.
hours. Therefore
Therefore
operators would
would be
required to
be required
SFP area
to enter
enter the
the SFP
area under
under potentially
operators
potentially onerous
onerous
order to protect
in order
protect personnel
personnel from the need
conditions. ItIt was determined that in
need to enter
enter
boiling that actions should be
the SFP area after itit is already boiling
be taken
taken for deployment
deployment of
cooling equipment
SEP cooling
equipment (hoses and
and monitor nozzles)
nozzles) prior
prior to the start of boiling. The
SFP
approximately five hours after event initiation and prior to
action will now be taken at approximately
SEP boiling in order to mitigate potential habitability concerns after
SFP
after boiling.
mobile water purification
8. OIP page 12, item 21 (and other locations of OIP) credit a mobile
unit (and/or other large regional response center (RRC) equipment) 24 hours after the
event. This timing was determined to be unlikely and unsupported by
by the RRC for
large equipment such as purification units,
units, 4160 V diesel generators, and boration
large
units. Therefore the purification units will not be credited until 72 hours after the
event.
9. OIP page 18, in the section for PWR Installed Equipment Phase 1, it is stated that the
turbine driven auxiliary feedwater (TDAFW) pump is not credited for seismic events
because the turbine driver is not seismically qualified. The TDAFW
TDAEW system (including
the turbine driver) has now been qualified as seismically robust and is credited for all
external events. See Open Item 015 in this report for additional information.
DIP page 19, under Steam Generators Available for Cooling (Modes 1-4), states that
10. OIP
a modification will be required to provide for remote manual operation of the ADVs to
begin cooling down the plant at hour 2. The modification selected, and which will
allow for the remote manual operation of the ADVs, is the installation of backup
1 and connection point for an air compressor to
nitrogen bottles to last through Phase 1
be connected for Phase 2.
11. OIP page 19, under Key Reactor parameters (and other locations of DIP)
11.
OIP) the level
indications for tank T-81 and SIRWT are credited. Because the CST and T-81 are
cross-tied, it has been
been determined that the level indication for the CST is sufficient to
indicate the available inventory in
in both
both tanks. Therefore level indication for T-81 is
redundant and
and is not required. SIRWT level indication is not
not required because the
tank is no longer credited.
12.
12. DIP
OIP page 62 (and other locations of DIP)
OIP) states use of multiple ELEX
FLEX generators.
PNP
PNP has
has determined that
that itit is
is preferable
preferable to
to use
use only one
one FLEX generator
generator in
in the PNP
PNP
strategy.
strategy. This
This FLEX
FLEX generator
generator will
will be sufficiently
sufficiently sized
sized to carry all
all the
the loads
loads that are
are
planned
planned for use in the FLEX strategy.
13.
13. During
During analysis
analysis of site
site seismic capabilities
capabilities itit was
was determined
determined that
that PNP is
is susceptible
susceptible
to
to soil
soil liquefaction.
liquefaction. Therefore
Therefore new
new storage
storage locations
locations are
are being
being developed
developed and
and
Attachment
will
be
3
of
DIP
updated
for
storage,
Attachment 3 of OIP will be updated for storage, staging
staging and
and routing.
routing. Also
Also see
see Open
Open
Item
Item OIl.
011.
Page
Page 44 of
of 10
10
5
Need for Relief/Relaxation and Basis for the Relief/Relaxation
implementation date and no
ENO expects to comply with the order implementation
no relief/relaxation is required
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
integrated plan and any open items or confirmatory items documented in Interim
overall integrated
Interim Staff
Evaluation (ISE). A fourth table includes a listing of audit questions and the status of each
item.
Overall Integrated Plan Open Item
Dli. Perform analysis on Palisades'
Palisades’
011.
susceptibility to soil liquefaction and potential
consequences on the FLEX implementation
plan.
Status
Started
Preliminary borings were performed on site
soil liquefaction susceptibility was
and soi/liquefaction
identified. 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 from all other BDBEEs.
Additional planning is under way to address
other impacts to equipment storage and
deployment. See also Change to
Compliance Method Item 13.
012. Develop Phase 3 deployment strategy
with correspondence with the RRC.
Started
013. Evaluate the need to missile protect
primary system makeup storage tank (T-81)
and other external tanks.
Started
014. Select the location of FLEX equipment
storage facility.
The CST volume alone is insufficient to
provide the required inventory, when
considering available on site resources for
SG makeup during Phase 1. Additional
inventory is required and can be provided by
tank T-81. T-81 will be verified/credited as
robust for all applicable external events. As
required, modifications will be implemented
to protect both the CST and primary system
makeup tank for all applicable external
events. See also Change to Compliance
Method Item 4.
Started
Refer to Cli.
011. One set of equipment will be
stored in Sea-Land containers inside the PA
for the Seismic event. An additional set(s) of
equipment will be stored outside the PA in a
structure(s) providing an
an appropriate level
level of
protection for the tornado
tornado event.
event. Both
Both sets
will be
be protected against the other applicable
(screened-in) BDBEE external hazards.
Page 5 of 10
10
Overall Integrated
Integrated Plan
Plan Open
Item
Open Item
Overall
015. Perform
Perform seismic
seismic evaluation
evaluation of
of turbineturbine015.
driven auxiliary
auxiliary feedwater
feedwater pump
pump (TDAFWP)
(TDAFWP)
driven
driver K-8.
K-8.
driver
016. Evaluate strategies to extend battery
coping time.
017. Evaluate sources of non-borated water
in addition to condensate storage tank (T-2)
T81.
and T-81.
018. Palisades Probabilistic Risk Assessment
(PRA) to provide justification why battery
room ventilation is not required until 24 hours.
019.
019. Evaluate
Evaluate the effects
effects of FLEX on
on security
security
procedures.
0110.
0110. Evaluate
Evaluate requirements
requirements of
of mobile
mobile
purification
purification unit
unit from
from RRC.
RRC.
Status
Status
Started
Started
Seismic evaluation
Seismic
evaluation documents
documents the
the seismic
seismic
qualification of
qualification
the
pump
and
associated
of the pump and associated
components. The
components.
The TDAFW
TDAFW pump
pump is
is qualified
qualified
the exception
exception of an
with the
an outlier
outlier related
related to aa
check for bolt
bolt tightness. Bolt
Bolt tightness on
the pump is being performed
performed under WO#
W0#
372138 and documented
46465.
documented under
under EC
EC
See also Change to Compliance Method
Method
Item 9.
Item
Started
The battery load shedding strategy is
currently being revised to extend the battery
coping time through shedding loads in
addition to those identified in the station
blackout procedure. Preliminary results
indicate a coping time of at least 8 hours for
the installed batteries accompanying the
expected deep load shed list. See also
Change to Compliance Method Item 1.
Complete/Closed
After depletion of T-2 and T-81
T-81,, makeup to
the SGs will be from a portable pump with
the credited suction source being Lake
Michigan. Modifications to credit sources of
non-borated water for sources other than T-2
and T-81 were determined to not be
required.
Complete/Closed
Palisades PRA provided multiple evaluations
for battery room hydrogen generation. It was
determined that supplemental ventilation is
required approximately 1.5
1.5 hours after
charging begins for removal of hydrogen.
Ventilation is not required for Phase 22
temperature control. This supplemental
ventilation has been included
in the
included in
Palisades
Palisades strategy. See
See also
also Change to
Compliance Method Item
Item 5.
Started
The
The security plan/program will be
be updated
updated to
correspond
correspond to
to FLEX
FLEX procedures.
procedures.
Complete/Closed
Complete/Closed
ItIt was
was determined
determined that
that the
the 250
250 gpm
gpm RRC
RRC
demineralized
demineralized water
water treatment
treatment unit
unit is
is
preferred
preferred over
over the
the 100
100 gpm
gpm RRC
RRC reverse
reverse
osmosis
in order
order to
to support
support SG
SG makeup
makeup
osmosis unit
unit in
and
and provide
provide makeup
makeup to
to the
the RRC
RRC mobile
mobile
Page
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Overall Integrated Plan
Plan Open Item
Status
Status
boration unit.
011 1. Evaluate requirements of mobile
mobile
0111.
boration unit from RRC.
Complete/Closed
The required flow rate of borated water for
PNP is aa maximum of 58.3 gpm.
methods of
of venting the fuel
0112. Evaluate methods
handling building.
0113. Evaluate the use of high-efficiency LED
lighting.
0114. Perform evaluation to determine if
additional parameters will need to be
activities,
monitored during FLEX activities.
0115. Perform analysis to ensure survivability
of containment.
0116. Evaluate borated water sources in
addition to safety injection refueling water
tank (SIRWT).
Complete/Closed
The strategy for venting the fuel handling
building will be to open an existing double
leaf door/hatch on the roof of the building.
Complete/Closed
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 minimal impact and
is not required or recommended.
Complete/Closed
In addition to NE112-06,
NEI 12-06, PWROG FLEX
guidance was reviewed for key parameter
monitoring. The NE112-06
NEI 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.
Started
Containment analysis has been completed
using the Modular Accident Analysis
Program (MAAP) and is being reviewed for
owner’s acceptance. Preliminary results of
owner's
this analysis show containment design
parameters will not be exceeded for the
at-power scenario (Le.,
(i.e., event initiating in
Mode 1). For the most conservative
(i.e., Mode 5 reduced
shutdown scenario (Le.,
inventory), preliminary results of the analysis
show that actions will be required to prevent
exceeding the design limits of containment.
Complete/Closed
All additional sources of borated water were
evaluated for use following a BDBEE. The
concentrated boric acid storage tanks (T-53A
and T-53B)
T -53 B) are the credited source of
borated water. These tanks are analyzed to
provide sufficient borated water for greater
than 24 hours. After 24
24 hours, borated water
will be batched as necessary for inventory
inventory
control using
using the boric acid batching tank
T-77. See also Change to Compliance
Compliance
Page 7 of 10
10
Plan Open Item
Item
Overall Integrated Plan
0117. Entergy, for the Palisades 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 tee in
the service water system to allow the ultimate
heat sink (UHS) FLEX pump to provide
cooling,
cooling.
0119. Evaluate the use of lake water to cool
the steam generators during an extended
loss of ac power (ELAP).
0120. Evaluate time until primary coolant
system (PCS) makeup is necessary in Modes
5 & 6.
5&6.
0121. Evaluate connection to ensure cooling
water can be provided for containment air
fans.
0122. Evaluate the robustness of the
charging pumps.
Status
Method Item 6.
Complete
Complete/Closed
Several locations in the service water system
were evaluated. A pipe elbow downstream of
service water system (SWS) pump P-7C was
identified as the best location for connecting
a pipe tee to allow flow from the RRC UHS
pump.
Started
An analysis has been completed and is being
reviewed for owner's
owner’s acceptance that
determines the impacts on the steam
generators when using lake water as the
makeup source.
Complete/Closed
An evaluation was performed that
documented the 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
(i.e., PCS level, pressure, and
occurs (Le.,
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 NRC
endorsed white paper on Shutdown /
Refueling Modes.
Complete/Closed
Cooling water flow to the containment air
tans
fans is through the service water system
addressed in the status update to Cl
01 18.
18.
Connection of the RRC supplied FLEX UHS
pump to the SWS will provide the necessary
means/connection for cooling water flow to
the containment air coolers.
Complete/Closed
The charging pumps have
have been evaluated as
robust for seismic events. The
The pumps
pumps are
Page 88 of 10
10
Overall Integrated Plan Open Item
Status
located inside the auxiliary building and
protected against all other external hazards.
hazards.
Interim Staff Evaluation Open Items
The U.S. Nuclear Regulatory Commission (NRC) has
not issued an Interim Staff Evaluation for Palisades;
therefore, there are no open items for the Interim Staff
Evaluation identified at this time
Interim Staff Evaluation Confirmatory Items
The NRC has not issued an Interim Staff Evaluation for
Palisades; therefore, there are no confirmatory items
from the Interim Staff Evaluation identified at this time
Audit Question Open Items
PAL-002
PAL-003
PAL-004
PAL-007
PAL-008
PAL-Oil
PAL-011
PAL-012
PAL-013
PAL-0l4
PAL-014
PAL-015
PAL-O16
PAL-016
PAL-0l7
PAL-017
PAL-0i8
PAL-018
PAL-019
PAL-020
PAL-021
PAL-022
PAL-O23
PAL-023
PAL-024
PAL-025
PAL-026
PAL-027
PAL-028
PAL-030
PAL-033
PAL-035
PAL-O36
PAL-036
PAL-037
PAL-039
PAL-039
PAL-04O
PAL-040
PAL-041
PAL-043
Status
Closed
Closed
Closed
In progress
In progress
In progress
In progress
In progress
In progress
Closed
In progress
In progress
In progress
In progress
Closed
In progress
Complete
In progress
Closed
In progress
progress
In
In progress
In
In progress
In progress
In progress
In progress
In
In progress
In
In progress
In progress
In
Closed
Closed
In
In progress
Closed
In
In progress
Page 99 of
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10
Status
N/A
Status
NIIA
N//A
Completion or Target Date
Aug
Aug
Aug
Aug
Aug
Aug
2014
2014
2014
2014
2014
2014
Aug 2014
Oct
2015
Oct2015
Aug 2014
Aug 2014
Aug 2014
e-Portal updated
Aug 2014
Aug 2014
2014
Aug 2014
Aug 2014
Aug 2014
Aug 2014
Aug 2014
Aug 2014
Oct 2015
2014
Aug 2014
Oct
Oct 2015
Aug 2014
.
Audit Question
Open Items
Question Open
Items
Audit
PAL-044
PAL-044
PAL-045
PAL-04S
PAL-046
PAL-046
PAL-047
PAL-04?
PAL-048
PAL-048
PAL-049
PAL-049
PAL-050
PAL-OSO
PAL-051
PAL-OS 1
PAL-053
PAL-OS3
PAL-054
PAL-OS4
PAL-055
PAL-OSS
PAL-057
PAL-OS?
PAL-057
PAL-OS?
7
Status
Status
progress
In progress
In
progress
In progress
In
progress
In progress
In
progress
In progress
In
progress
In progress
In
progress
In progress
In
progress
In progress
In
progress
In progress
In
In progress
In
progress
In progress
In
Closed
In progress
In
In progress
Completion or
Completion
or Target
Target Date
Date
Aug
Aug 2014
2014
Aug
Aug 2014
2014
Aug
Aug 2014
2014
Aug 2014
2014
Aug
Aug 2014
2014
Aug
Aug 2014
2014
Aug
Aug 2014
2014
Aug 2014
Aug 2014
Aug 2014
Aug 2014
Aug 2014
Potential Interim Staff Evaluation Impacts
The NRC has not yet issued an interim staff evaluation for PNP; therefore, there are no
potential impacts to the interim staff evaluation identified at this time.
S8 References
The following references support the updates to the Overall Integrated Plan described in this
attachment.
1. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-010,
2013-01 0, Overall
12, 2012 Commission Order Modifying Licenses
Integrated Plan in Response to March 12,2012
with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis
External Events (Order Number EA-12-049), dated February 28,2013
28, 2013
2. NRC Order Number EA-12-049,
EA-1 2-049, Order Modifying Licenses with Regard to
Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated
ML12054A736).
March 12, 2012 (ADAMS Accession No. ML
120S4A?36).
3. Entergy Nuclear Operation, Inc. (ENO) letter to NRC, PNP 2013-064, Palisades Nuclear
Plant First Six-Month Status Report in Response to March 12,
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.
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