Text

Third 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)
	ML14240A279
Person / Time
Site:	Palisades
Issue date:	08/28/2014
From:	Vitale A; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, PNP 2014-085
	Download: ML14240A279 (19)
	v • d • e

Entergy Nuclear Operations, Inc.

11.E, Palisades Nuclear Plant Iii 1LI7jY 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2014-085 August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Palisades Nuclear Plant Third 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, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ADAMS Accession No.

1 2054A736) 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 External Events, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174) 3.

NFl 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378) 4.

Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-091, Initial 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), dated October 25, 2012 (ADAMS Accession No. ML12300A065) 5.

Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-010, Overall Integrated Plan 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), dated February 28, 2013 (ADAMS Accession No. ML13246A399)

~Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 PNP 2014-085 August 28, 2014 Tel 269 764 2000 Anthony J. Vitale Site Vice President u.s. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Palisades Nuclear Plant Third 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, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-Basis External Events, dated March 12,2012 (ADAMS Accession No.

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 External Events, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174)

3. NEI12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378)

4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-091, Initial 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), dated October 25,2012 (ADAMS Accession No. ML12300A065)

5. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-010, Overall Integrated Plan 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), dated February 28,2013 (ADAMS Accession No. ML13246A399)

PNP 2014-085 Page 2 of 3 6.

Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-064, Palisades Nuclear Plant First 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), dated August 28, 2013 (ADAMS Accession No. ML13241A234) 7.

Entergy Nuclear Operations, Inc. letter to NRC, PNP 2014-011, 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), dated February 28, 2014 (ADAMS Accession No. ML14059A078)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Entergy Nuclear Operations, Inc. (ENO). Reference 1 was immediately effective and directs ENO to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pooi cooling capabilities in the event of a beyond-design-basis external event.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 1 (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 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. Reference 7 provided the second six-month status report.

The purpose of this letter is to provide the third 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.

This letter contains no new commitments and no revised commitments.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2014.

ncerely,,

ajv/jse PNP 2014-085 Page 2 of 3

6. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-064, Palisades Nuclear Plant First 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), dated August 28,2013 (ADAMS Accession No. ML13241A234)

7. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2014-011, 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), dated February 28,2014 (ADAMS Accession No. ML14059A078)

Dear Sir or Madam:

On March 12,2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Entergy Nuclear Operations, Inc. (ENO). Reference 1 was 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 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 1 (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 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. Reference 7 provided the second six-month status report.

The purpose of this letter is to provide the third 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.

This letter contains no new commitments and no revised commitments.

I declare under penalty of perjury that the foregOing is true and correct; executed on August 28, 2014.

Sincerely, ajv/jse

PNP 2014-085 Page 3 of 3

Attachment:

Palisades Nuclear Plant Third 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) cc:

Office Director, NRR, USNRC Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USN RC PNP 2014-085 Page 3 of 3

Attachment:

Palisades Nuclear Plant Third 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) cc:

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

ATTACHMENT Palisades Nuclear Plant Third 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-1 2-049) 1 Introduction Entergy Nuclear Operations, Inc. (ENO) developed for Palisades Nuclear Plant (PNP) an overall integrated plan (Reference 1), which documented the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference 4), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since January 31, 2014, and are current as of July 31, 2014.

Second Six-Month Status Report February 2014 Modifications Evaluation April 2014 N-i Walkdown February 2014 Third Six-Month Status Report Complete with submission of this document in August 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.

Perform Staffing Analysis The Perform Staffing Analysis milestone completion date has been changed to April 2015. This new milestone target completion date does not impact the Order implementation date.

Modifications Design Engineering The Design Engineering milestone completion date has been changed to September 2014. This new milestone target completion date does not impact the Order implementation date.

On-site FLEX Equipment - Purchase and Procure The On-Site FLEX Equipment Purchase and Procure milestone completion date has been changed to August 2015. This new milestone target completion date does not impact the Order implementation date.

Page 1 of 16 ATTACHMENT Palisades Nuclear Plant Third 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) 1 Introduction Entergy Nuclear Operations, Inc. (ENO) developed for Palisades Nuclear Plant (PNP) an overall integrated plan (Reference 1), which documented the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference 4), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since January 31, 2014, and are current as of July 31,2014.

Second Six-Month Status Report -

February 2014 Modifications Evaluation - April 2014 N-1 Walkdown - February 2014 Third Six-Month Status Report -

Complete with submission of this document in August 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.

Perform Staffing Analysis The Perform Staffing Analysis milestone completion date has been changed to April 2015. This new milestone target completion date does not impact the Order implementation date.

Modifications - Design Engineering The Design Engineering milestone completion date has been changed to September 2014. This new milestone target completion date does not impact the Order implementation date.

On-site FLEX Equipment - Purchase and Procure The On-Site FLEX Equipment Purchase and Procure milestone completion date has been changed to August 2015. This new milestone target completion date does not impact the Order implementation date.

Page 1 of 16

Create PNP FLEX FSG The Create PNP FLEX FSG milestone completion date has been changed to December 2014. This new milestone target completion date does not impact the Order implementation date.

Target Revised Target Milestone Completion Activity Status Completion Date*

Date Submit Overall Integrated Feb 2013 Complete Implementation Plan Six-Month Status Updates Update 1 Aug 2013 Complete Update 2 Feb2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Jan 2014 Complete Perform Staffing Analysis Apr2014 Started Apr2015 Modifications Modifications Evaluation Apr 2014 Complete Engineering and Implementation N-i Walkdown Feb 2014 Complete Design Engineering May 2014 In Progress September 2014 Implementation Outage Oct 2015 Not Started On-site FLEX Equipment Purchase and Procure Jun 2014 Started Aug 2015 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 Jun 2013 Complete Steam Supply System (NSSS)

Specific Guidelines Create PNP FLEX FSG Mar 2015 Started Dec 2014 Create Maintenance Procedures Mar 2015 Not Started Training Develop Training Plan Jun 2015 Not Started Training Complete Sept 2015 Not Started Page 2 of 16 Create PNP FLEX FSG The Create PNP FLEX FSG milestone completion date has been changed to December 2014. This new milestone target completion date does not impact the Order implementation date.

Target Revised Target Milestone Completion Activity Status Completion Date*

Date Submit Overall Integrated Feb 2013 Complete Implementation Plan Six-Month Status Updates Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Jan 2014 Complete Perform Staffing Analysis Apr2014 Started Apr2015 Modifications Modifications Evaluation Apr2014 Complete Engineering and Implementation N-1 Walkdown Feb 2014 Complete Design Engineering May 2014 In Progress September 2014 Implementation Outage Oct 2015 Not Started On-site FLEX Equipment Purchase and Procure Jun 2014 Started Aug 2015 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 Jun 2013 Complete Steam Supply System (NSSS)-

Specific Guidelines Create PNP FLEX FSG Mar 2015 Started Dec 2014 Create Maintenance Procedures Mar 2015 Not Started Training Develop Training Plan Jun 2015 Not Started Training Complete Sept 2015 Not Started Page 2 of 16

Target Revised Target Milestone Completion Activity Status Completion Date*

Date Validation! Demonstration Oct 2015 Not Started Submit Completion Report Oct 2015 Not Started

Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports.

4 Changes to Compliance Method There are no changes to the compliance method as documented in previous correspondence.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation ENO expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation Evaluation (ISE) (Reference 5). A fou status of each item.

Overall Integrated Plan Open Item Oil. Perform analysis on Palisades susceptibility to soil liquefaction and potential consequences on the FLEX implementation plan.

Complete/Closed Borings were performed on site and soil liquefaction susceptibility was identified along the FLEX equipment deployment route outside the PA. 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 against other applicable (screened-in) beyond-design-basis external events (BDBEEs). Additional planning is under way to address other impacts to equipment storage and deployment. This Open item is related to 1SE Open Item 3.1.1.2.A and is addressed on updated Audit Question (AQ) response spreadsheet on the ePortal.

The following tables provide a summary and status of any open items documented in the overall integrated plan and any open items or confirmatory items documented in interim Staff rth table includes a listing of audit questions and the Status 012. Develop Phase 3 deployment Started strategy with correspondence with Staging areas have been identified. The National the RRC.

SAFER Response Center (NSRC) [formerly known as the Regional Response Center (RRC)] kickoff meeting was conducted on 7/22/14 to complete checklist as Page 3 of 16 Target Revised Target Milestone Completion Activity Status Completion Date*

Date Validation I Demonstration Oct 2015 Not Started Submit Completion Report Oct 2015 Not Started

Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports.

4 Changes to Compliance Method There are no changes to the compliance method as documented in previous correspondence.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation ENO expects to comply with the order implementation date and no relief/relaxation is 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 overall integrated plan and any open items or confirmatory items documented in Interim Staff Evaluation (ISE) (Reference 5). A fourth table includes a listing of audit questions and the status of each item.

Overall Integrated Plan Open Item Status 011. Perform analysis on Palisades' Complete/Closed susceptibility to soil liquefaction and Borings were performed on site and soil liquefaction potential consequences on the susceptibility was identified along the FLEX equipment FLEX implementation plan.

deployment route outside the PA. 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 against other applicable (screened-in) beyond-design-basis external events (BDBEEs). Additional planning is under way to address other impacts to equipment storage and deployment. This Open Item is related to ISE Open Item 3.1.1.2.A and is addressed on updated Audit Question (AQ) response spreadsheet on the ePortal.

012. Develop Phase 3 deployment Started strategy with correspondence with Staging areas have been identified. The National the RRC.

SAFER Response Center (NSRC) [formerly known as the Regional Response Center (RRC)] kickoff meeting was conducted on 7/22/14 to complete checklist as Page 3 of 16

Overall Integrated Plan Open Item Status approved by AREVA. The NSRC and Palisades are in process of developing Site Response Plans. This Open Item is related to ISE Confirmatory Item 3.4.A and is addressed on updated AQ response spreadsheet on the ePortal.

013. Evaluate the need to missile Complete/Closed protect primary system makeup The condensate storage tank (CST) (T-2) and T-81 storage tank (T-81) and other are cross-connected such that upon depletion of the external tanks.

CST, at approximately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the inventory in tank T-81 can also be gravity fed to the TDAFW pump. To allow credit for an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months supply, tanks T-2 and T-81 will be missile protected. Following the required modifications, tanks T-2 and T-81 will be considered robust against all of the applicable tornado missile hazards described on Table 2 of RG 1.76, Rev. 1, with the single exception of tank T-81 foundation mounting bolts. Tank T-81 would be fully protected against the design basis tornado missile hazards of a 6-inch Schedule 40 steel pipe and a 1-inch diameter solid steel sphere (the exception being anchor bolting for the automobile missile hazard impact). A white paper describing the tornado generated missile hazard evaluation for tank T-81 has been posted to the ePortal.

This Open Item is also addressed by updated AQ PAL-044 response.

014. Select the location of FLEX Complete/Closed equipment storage facility.

Refer to OIl. One set of equipment will be stored in a new structure inside the PA designed for the Seismic event. An additional set(s) of equipment will be stored outside the PA in a structure(s) providing an appropriate level of protection for the tornado event.

Both sets will be protected against other applicable (screened-in) BDBEE external hazards.

015. Perform seismic evaluation of Complete/Closed turbine-driven auxiliary feedwater Seismic evaluation documents the seismic pump (TDAFWP) driver K-8.

qualification of the pump and associated components.

The TDAFW pump is qualified with the exception of an outlier related to a check for bolt tightness. Bolt tightness on the pump is being performed under WO# 372138 and documented under EC 46465.

016. Evaluate strategies to extend Complete/Closed battery coping time.

The battery load shedding strategy has been revised to extend the battery coping time through shedding loads in addition to those identified in the station blackout procedure. The results indicate a coping time of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the installed batteries Page 4 of 16 Overall Integrated Plan Open Item Status approved by AREVA. The NSRC and Palisades are in process of developing Site Response Plans. This Open Item is related to ISE Confirmatory Item 3.4.A and is addressed on updated AQ response spreadsheet on the ePortal.

013. Evaluate the need to missile Complete/Closed protect primary system makeup The condensate storage tank (CST) (T-2) and T-81 storage tank (T -81) and other are cross-connected such that upon depletion of the external tanks.

CST, at approximately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the inventory in tank T-81 can also be gravity fed to the TDAFW pump. To allow credit for an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months supply, tanks T-2 and T-81 will be missile protected. Following the required modifications, tanks T -2 and T -81 will be considered robust against all of the applicable tornado missile hazards described on Table 2 of RG 1.76, Rev. 1, with the single exception of tank T-81 foundation mounting bolts. Tank T-81 would be fully protected against the design basis tornado missile hazards of a 6-inch Schedule 40 steel pipe and a 1-inch diameter solid steel sphere (the exception being anchor bolting for the automobile missile hazard impact). A white paper describing the tornado generated missile hazard evaluation for tank T -81 has been posted to the ePortal.

This Open Item is also addressed by updated AQ PAL -044 response.

014. Select the location of FLEX Complete/Closed equipment storage facility.

Refer to 011. One set of equipment will be stored in a new structure inside the PA designed for the Seismic event. An additional set(s) of equipment will be stored outside the PA in a structure(s) providing an appropriate level of protection for the tornado event.

Both sets will be protected against other applicable (screened-in) BDBEE external hazards.

015. Perform seismic evaluation of Complete/Closed turbine-driven auxiliary feedwater Seismic evaluation documents the seismic pump (TDAFWP) driver K-8.

qualification of the pump and associated components.

The TDAFW pump is qualified with the exception of an outlier related to a check for bolt tightness. Bolt tightness on the pump is being performed under WO# 372138 and documented under EC 46465.

016. Evaluate strategies to extend Complete/Closed battery coping time.

The battery load shedding strategy has been revised to extend the battery coping time through shedding loads in addition to those identified in the station blackout procedure. The results indicate a coping time of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the installed batteries Page 4 of 16

Overall Integrated Plan Open Item Status accompanying the expected deep load shed list. This Open Item is addressed by updated AQ PAL-018 response.

017. Evaluate sources of non-Complete/Closed borated water in addition to After depletion of T-2 and T-81, makeup to the steam condensate storage tank (T-2) and generators (SGs) will be from a portable pump with T-81.

the credited suction source being Lake Michigan.

Modifications to credit sources of non-borated water for sources other than T-2, T-81 and Lake Michigan were determined to not be required.

018. Palisades Probabilistic Risk Complete/Closed Assessment (PRA) to provide Palisades PRA provided multiple evaluations for justification why battery room battery room hydrogen generation.

It was determined ventilation is not required until 24 that supplemental ventilation is required approximately hours.

1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months after charging begins for removal of hydrogen. Ventilation is not required for Phase 2 temperature control. This supplemental ventilation has been included in the Palisades strategy. This Open Item is addressed by updated AQ PAL-025 response.

019. Evaluate the effects of FLEX Started on security procedures.

The security plan/program will be updated to correspond to FLEX procedures.

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

It was determined that the 250 gpm NSRC demineralized water treatment unit is preferred over the 100 gpm NSRC reverse osmosis unit in order to support SG makeup and provide makeup to the NSRC mobile boration unit. The mobile purification unit is only required to enhance Phase 3 actions post 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

0111. Evaluate requirements of Complete/Closed mobile boration unit from RRC.

Current strategy is to have adequate borated water inventory onsite for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to cope with any BDBEE.

Therefore, the requirements of the mobile boration unit from NSRC is only required to enhance Phase 3 actions post 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

0112. Evaluate methods of venting Complete/Closed the fuel 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 Complete/Closed high-efficiency LED 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 Page 5 of 16 Overall Integrated Plan Open Item Status accompanying the expected deep load shed list. This Open Item is addressed by updated AQ PAL-018 response.

017. Evaluate sources of non-Complete/Closed borated water in addition to After depletion of T-2 and T-81, makeup to the steam condensate storage tank (T -2) and generators (SGs) will be from a portable pump with T-81.

the credited suction source being Lake Michigan.

Modifications to credit sources of non-borated water for sources other than T-2, T-81 and Lake Michigan were determined to not be required.

018. Palisades Probabilistic Risk Complete/Closed Assessment (PRA) to provide Palisades PRA provided multiple evaluations for justification why battery room battery room hydrogen generation. It was determined ventilation is not required until 24 that supplemental ventilation is required approximately hours.