PNP 2014-011, 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)

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)

ML14059A078
Person / Time
Site:	Palisades
Issue date:	02/28/2014
From:	Vitale A Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, PNP 2014-011
Download: ML14059A078 (12)

Text

• En

~ Entergy teigjr Entergy Entergy Nuclear Nuclear Operations, Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI Covert, Tel Tel 269 Ml 49043-9530 49043-9530 269 7642000 764 2000 Inc.

Highway Anthony J. Vitale Anthony Vitale Site Site Vice Vice President President PNP 2014-011 PNP February 28, 2014 February u.s. Nuclear Regulatory U.S. Nuclear Regulatory Commission 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,

1. EA-1 2-049, Order Modifying Licenses with Regard 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 12-06, Diverse and Flexible Coping Strategies (FLEX)

NEI 12-06, implementation Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession Accession No.No. ML1 2242A378)

ML12242A378)

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 dated October October 25, 2012 (ADAMS 25,2012 (ADAMS Accession No. No.

ML1 2300A065 ML12300A065

5. Entergy

5. Entergy Nuclear Nuclear Operations, Operations, Inc.

Inc. (ENO)

(ENO) letter letter to to NRC, NRC, PNPPNP 2013-01 2013-010,0, Overall Overall Integrated Integrated Plan in in Response Response to March March 12, 2012 Commission 12,2012 Commission Order Order Modifying Modifying Licenses Licenses with Regard Regard toto Requirements Requirements for Mitigation Strategies Strategies for Beyond-Design-Basis 8eyond-Design-8asis External External Events Events (Order (Order Number Number EA-12-049),

EA-12-049), dated dated February February 28, 2013 28,2013

PNP 2014-011 PNP 2014-011 Page 22 of Page of 22

6. Entergy

6. Entergy Nuclear Nuclear Operation, Operation, Inc.

Inc. (ENO)

(ENO) letter letter to to NRC, NRC, PNP PNP 2013-064, 201 3-064, Pailsades Nuclear Palisades Nuclear Plant Plant First First Six-Month Six-Month Status Status Report Report in in Response Response to to March 12,2012 March 12, 2012 Commission Commission Order Order Modifying Modifying Licenses Licenses with with Regard Regard to to Requirements for Mitigation Strategies for Requirements for Mitigation Strategies for Beyond-Design-Basis Beyond-Design-Basis External Events External Events (Order (Order Number Number EA-12-049),

EA- 12-049), dated dated August 28,2013 28, 2013

Dear Sir or Madam:

or Madam:

On March 12, On 12, 2012, the Nuclear Regulatory Commission Commission (NRC) issued an order (Reference

1) to Entergy Nuclear Operations, Inc.

Entergy Nuclear Inc. (ENO). Reference 11 was immediately 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 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.

Reference 1 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. 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:

Palisades Nuclear Nuclear Plant Second Second Six-Month Six-Month Status Report in Response to March March 12, 2012, Commission 12, 2012, 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) cc:

cc: Office Director, Office Director, NRR, NRR, USNRC USNRC Administrator, Administrator, Region Region Ill, III, USNRC USNRC Project Manager, Project Manager, Palisades, Palisades, USNRC USNRC Resident Inspector, Palisades, Resident Inspector, Palisades, USNRC USNRC

ATTACHMENT ATTACHMENT Palisades Nuclear Palisades Nuclear Plant Plant Second Second Six-Month Six-Month Status Report in Status Report in Response Response to to March 12,2012 March 12, 2012 Commission Commission OrderOrder Modifying Modifying Licenses Licenses with with Regard Regard to to Requirements for Mitigation Requirements Mitigation Strategies Strategies for Beyond-Design-Basis Beyond-Design-Basis External External Events (Order Number Events (Order Number EA-12-049)

EA-1 2-049) 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 (FLEX), inin response response to Reference Reference 2. This attachment provides an update of milestone milestone accomplishments since submittal of the last status report (Reference 3), including any changes to thethe compliance method, schedule, or need for relief/relaxation and the basis, if 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 - August 2013

• Second Six-Month Status Report - Complete with submission of this document in February 2014

• FLEX Strategy Evaluation - January 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.

• Perlorm Staffing Analysis Perform Staffing The Perform Perform Staffing Analysis milestone milestone completion completion date has been changed to April 2014.

This new milestone target completion This new 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 been changed has been changed toto April April 2014. This new 2014. This new milestone target completion datedate does not impact does not impact the Order implementation implementation date.

date.

Page of 10 Page 11 of 10

Target Target Revised Revised Target Target Milestone Milestone Completion Completion Activity Status Activity Status Completion Completion Date*

Date* Date Date Submit Overall Submit Overall Integrated Integrated Feb 2013 Feb 2013 Complete Complete Implementation Plan Implementation Plan Six-Month Status Updates Updates 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 Modifications Modifications Evaluation Jan 2014 Started Apr 2014 Engineering and Implementation N-i Walkdown N-1 Feb 2014 Started Design Engineering May 2014 Started IImplementation mplementation Outage Oct 2015 Not Started On-site FLEX Equipment Purchase and Procure Jun 2014 Started 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 Nuclear Steam Supply Jun Jun 2013 2013 Complete Complete Supply System (NSSS)

(NSSS)-

Specific_Guidelines Specific Guidelines Create PNP FLEX FSG Mar Mar 2015 Not Not Started Create Create Maintenance Maintenance Procedures Procedures Mar 2015 Mar 2015 Not Not Started Training Training Develop Training Develop Training Plan Plan Jun 2015 Jun 2015 Not Not Started Started Training Training Complete Complete Sept 2015 Sept 2015 Not Not Started Started Validation Validation I Demonstration Demonstration Oct Oct 2015 2015 Not Not Started Started Submit Submit Completion Completion Report Report Oct 2015 Oct 2015 Not Not Started Started

• Target "Target Completion Completion Date is the Date is 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 4 Changes Compliance Method Method The following changes The changes are are being being incorporated incorporated to to the FLEX FLEX strategy strategy for for PNP.

PNP.

1. Overall

1. Overall Integrated Integrated PlanPlan (OIP)

(OIP) page page 9, 9, item item 33 (and (and other other locations locations of of OIP)

DIP) states states the the battery life will be battery life will four hours. The four hour be four hours. hour battery battery capacity capacity was determined determined to to provide insufficient provide insufficient margin margin for transition to Phase Phase 2. 2. Based Based on on analysis and and planning planning for a deeper load load shed, the installed installed battery battery capacity will be be extended to eight hours hours Open Item (see Open Item 016).

016). Therefore, the time time at at which a portable FLEX FLEX generator is required to be deployed and operational has required has been extended from hour 4 to hour 8 based on battery capacity.

2. OIP page 10, 10, item item 9 (and other locations of DIP) stated that LC-19 will be be repowered from the portable FLEX FLEX generator. This remains the primary 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)

4. OIP DIP) requires commencement of 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 OIP page page 11,11, item 14 14 (and other locations of 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 room exhaust battery exhaust fans are not fans are not robust robust andand 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 ItemItem 018.

018.

6.

6. OIP OIP page page 11, item 15 11, item (and other 15 (and other locations locations of of DIP)

DIP) credits thethe volume volume control control tank tank (VCT) and safety injection refueling water (VCT) and safety injection refueling water tank (SIRWT) tank (SIRWT) as as borated borated sources sources ofof water water for primary for 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 VCT and the VCT and SIRWT SIRWT are are not robust for not robust all applicable for all 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 andand T-53B)

T-53B) will will now now be be credited credited as the borated as the water sources borated water sources forfor these these functions functions early early in in Phase Phase 2.2. Later Later in in Page Page 33 of of 10 10

Phase 22 (>

Phase (>2424 hours), the boric hours), the boric acid acid batching batching tank tank (T-77)

(T-77) will will be be used used to to batch batch required borated required borated water inventory. Also water inventory. Also see see Open Open Item Item 0116.

0116.

7. 01

7. DIP page 12, P page 12, item item 16 states that 16 states that spent fuel pool spent fuel pool (SFP)

(SFP) equipment equipment (hoses (hoses and and monitor monitor nozzles) will nozzles) will be deployed at be deployed at hour hour 1818 to prevent SFP to prevent SEP level from dropping level from dropping belowbelow the the level of 15 level of 15 feet feet above the fuel above the fuel atat hour 20.93. Under hour 20.93. Under worst casecase conditions it is conditions it is estimated that estimated that boiling could occur boiling could beginning at occur beginning at approximately approximately 5.6 5.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

hours. Therefore Therefore operators would operators would be required to be required to enter enter the SFP area the SFP area under under potentially potentially onerous onerous conditions. ItIt was determined that in order to protect in order protect personnel personnel from the need need to enter enter the SFP area after itit is already boiling boiling that actions should be be taken taken for deployment deployment of SFP cooling equipment SEP cooling equipment (hoses and and monitor nozzles) nozzles) prior prior to the start of boiling. The 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.

8. OIP page 12, item 21 (and other locations of OIP) credit a mobile mobile water purification unit (and/or other large regional response center (RRC) equipment) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event. This timing was determined to be unlikely and unsupported by by the RRC for large equipment such as purification units, large units, 4160 V diesel generators, and boration units. Therefore the purification units will not be credited until 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 nitrogen bottles to last through Phase 1 1 and connection point for an air compressor to 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 both tanks. Therefore level indication for T-81 is in both 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 oneone FLEX generator generator in in the PNP PNP strategy. This strategy. This FLEXFLEX generator generator will will be sufficiently sized to carry all sufficiently sized 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 soil liquefaction.

to soil liquefaction. Therefore Therefore new new storage storage locations are being locations are being developed developed and and Attachment 3 of DIP will be updated for Attachment 3 of OIP will be updated for storage, staging storage, 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 Status Dli. Perform analysis on Palisades' 011. Palisades Started susceptibility to soil liquefaction and potential Preliminary borings were performed on site consequences on the FLEX implementation soil liquefaction susceptibility was and soi/liquefaction plan. 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 Started with correspondence with the RRC.

013. Evaluate the need to missile protect Started primary system makeup storage tank (T-81) The CST volume alone is insufficient to and other external tanks. 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.

014. Select the location of FLEX equipment Started storage facility. 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 anan 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 Overall Integrated Plan Plan Open Item Open Item Status Status 015. Perform 015. Perform seismic seismic evaluation evaluation of of turbine-turbine- Started Started driven auxiliary driven auxiliary feedwater feedwater pump pump (TDAFWP)

(TDAFWP) Seismic evaluation Seismic evaluation documents documents the the seismic seismic driver K-8.

driver K-8. qualification of qualification of the pump and associated the pump and associated components. The components. The TDAFW TDAFW pump pump is is qualified qualified with thethe exception exception of an an outlier outlier related related to aa check for boltbolt tightness. Bolt Bolt tightness on the pump is being performedperformed under WO# W0#

documented under 372138 and documented under ECEC 46465.

See also Change to Compliance Method Method Item 9.

Item 016. Evaluate strategies to extend battery Started coping time. 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the installed batteries accompanying the expected deep load shed list. See also Change to Compliance Method Item 1.

017. Evaluate sources of non-borated water Complete/Closed in addition to condensate storage tank (T-2) After depletion of T-2 and T-81 T-81,, makeup to T81.

and T-81. 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.

018. Palisades Probabilistic Risk Assessment Complete/Closed (PRA) to provide justification why battery Palisades PRA provided multiple evaluations room ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. for battery room hydrogen generation. It was determined that supplemental ventilation is required approximately 1.5 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after charging begins for removal of hydrogen.

Ventilation is not required for Phase 22 temperature control. This supplemental ventilation has been includedincluded in in the Palisades Palisades strategy. See See also also Change to Compliance Method Item Item 5.

019.

019. Evaluate Evaluate the effects effects of FLEX on on security security Started procedures. The The security plan/program will be be updated updated to correspond correspond to to FLEX FLEX procedures.

procedures.

0110.

0110. Evaluate Evaluate requirements requirements ofof mobile mobile Complete/Closed Complete/Closed purification unit purification unit from from RRC.

RRC. ItIt was was determined determined that that the the 250 250 gpm gpm RRCRRC demineralized demineralized water water treatment treatment unit unit is is preferred preferred overover the the 100 gpm RRC 100 gpm RRC reverse reverse osmosis osmosis unit unit in in order order to to support support SG SG makeup makeup and and provide provide makeup makeup to to the the RRC RRC mobile mobile Page of 10 Page 66 of 10

Overall Integrated Plan Plan Open Item Status Status boration unit.

011 1. Evaluate requirements of mobile 0111. mobile Complete/Closed boration unit from RRC. The required flow rate of borated water for PNP is aa maximum of 58.3 gpm.

methods of 0112. Evaluate methods of venting the fuel Complete/Closed 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 high-efficiency LED Complete/Closed 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 minimal impact and is not required or recommended.

0114. Perform evaluation to determine if Complete/Closed additional parameters will need to be NEI 12-06, PWROG FLEX In addition to NE112-06, activities, monitored during FLEX activities. guidance was reviewed for key parameter NEI 12-06 and PWROG monitoring. The NE112-06 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 survivability Started of containment. Containment analysis has been completed using the Modular Accident Analysis Program (MAAP) and is being reviewed for owners acceptance. Preliminary results of owner's this analysis show containment design parameters will not be exceeded for the (i.e., event initiating in at-power scenario (Le.,

Mode 1). For the most conservative shutdown scenario (Le.,(i.e., Mode 5 reduced inventory), preliminary results of the analysis show that actions will be required to prevent exceeding the design limits of containment.

0116. Evaluate borated water sources in Complete/Closed addition to safety injection refueling water All additional sources of borated water were tank (SIRWT). 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. After 24 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 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 Overall Integrated Plan Item Status Method Item 6.

0117. Entergy, for the Palisades site, will Complete 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 Complete/Closed the service water system to allow the ultimate Several locations in the service water system heat sink (UHS) FLEX pump to provide were evaluated. A pipe elbow downstream of cooling, cooling. 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.

0119. Evaluate the use of lake water to cool Started the steam generators during an extended An analysis has been completed and is being loss of ac power (ELAP). owners acceptance that reviewed for owner's determines the impacts on the steam generators when using lake water as the makeup source.

0120. Evaluate time until primary coolant Complete/Closed system (PCS) makeup is necessary in Modes An evaluation was performed that 5 & 6.

5&6. 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.

0121. Evaluate connection to ensure cooling Complete/Closed water can be provided for containment air Cooling water flow to the containment air fans. 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.

0122. Evaluate the robustness of the Complete/Closed charging pumps. 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 hazards.

protected against all other external hazards.

Interim Staff Evaluation Open Items Status The U.S. Nuclear Regulatory Commission (NRC) has N/A 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 Status The NRC has not issued an Interim Staff Evaluation for N//A NIIA Palisades; therefore, there are no confirmatory items from the Interim Staff Evaluation identified at this time Audit Question Open Items Status Completion or Target Date PAL-002 Closed PAL-003 Closed PAL-004 Closed PAL-007 In progress Aug 2014 PAL-008 In progress Aug 2014 PAL-Oil PAL-011 In progress Aug 2014 PAL-012 In progress Aug 2014 PAL-013 In progress Aug 2014 .

PAL-0l4 PAL-014 In progress Aug 2014 PAL-015 Closed PAL-O16 PAL-016 In progress Aug 2014 PAL-0l7 PAL-017 In progress Oct2015 Oct 2015 PAL-0i8 PAL-018 In progress Aug 2014 PAL-019 In progress Aug 2014 PAL-020 Closed PAL-021 In progress Aug 2014 PAL-022 Complete e-Portal updated PAL-O23 PAL-023 In progress Aug 2014 PAL-024 Closed PAL-025 In progress In progress Aug 2014 2014 PAL-026 In progress Aug 2014 PAL-027 In progress In Aug 2014 PAL-028 In progress Aug 2014 PAL-030 In progress Aug 2014 PAL-033 In progress Aug 2014 PAL-035 In progress In Aug 2014 PAL-O36 PAL-036 In progress In Oct 2015 PAL-037 In progress In Aug 2014 2014 PAL-039 PAL-039 Closed Closed PAL-04O PAL-040 In progress In Oct Oct 2015 PAL-041 Closed PAL-043 In In progress Aug 2014 Page 99 of of 10 10

Audit Question Audit Open Items Question Open Items Status Status Completion or Completion or Target Target Date Date PAL-044 PAL-044 In progress In progress Aug Aug 2014 2014 PAL-045 PAL-04S In progress In progress Aug Aug 2014 2014 PAL-046 PAL-046 In progress In progress Aug Aug 2014 2014 PAL-047 PAL-04? In progress In progress Aug 2014 2014 PAL-048 PAL-048 In progress In progress Aug Aug 2014 2014 PAL-049 PAL-049 In progress In progress Aug Aug 2014 2014 PAL-050 PAL-OSO progress In progress In Aug Aug 2014 2014 PAL-051 PAL-OS 1 In progress In progress Aug 2014 PAL-053 PAL-OS3 In progress In Aug 2014 PAL-054 PAL-OS4 In progress In progress Aug 2014 PAL-055 PAL-OSS Closed PAL-057 PAL-OS? In progress In Aug 2014 PAL-057 PAL-OS? In progress Aug 2014 7 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 March 12, 2012 (ADAMS Accession No. ML ML12054A736).

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.

Page Page 10 10 of of 10 10