PilgrimWhaleMonitoringSubmittal.12-2013

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S n t r y Entergy Nuclear Operations, Inc600 Rocky ill RoadPlymouth, MA 02360Pilgrim Nuclear Power Station

December 31, 2013

U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D.C. 20555SUBJECT:

REFERENCES:

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power StationDocket No.: 50-293License No.: DPR-351. Letter, D. S. Morris, United States Department of Commerce, NationalOceanic and Atmospheric Administration, National Marine FisheriesService, to A. S. Imboden, Chief, Environmental Review and GuidanceUpdate Branch, U.S. Nuclear Regulatory Commission, PilgrimNuclearPowerStation May 17, 2012.2. Letter, J. K. Bullard, United States Department of Commerce, NationalOceanic and Atmospheric Administration, National Marine FisheriesService, to A. Hull, Acting Chief, Environmental Review and GuidanceUpdate Branch, U.S. Nuclear Regulatory Commission, Pilgrim NuclearPower Station, April 24, 2013.

LETTER NUMBER: 2.13.102Dear Sir or Madam:On May 17, 2012, the National Marine Fisheries Service (NMFS) issued Reference 1, aconsultation letter, which concluded that the continued operation of the Pilgrim Nuclear PowerStation (Pilgrim) under the terms of a renewed license is not likely to adversely affect any listedspecies under NMFS jurisdiction. The letter further concluded that the continued operation ofPilgrim will have no effect on the right whale critical habitat.Reference 1 further stated, erroneously, that: As a condition of their existing license, Entergy must report to NRC any observations of listedspecies.There are no current conditions of the Pilgrim Operating License that require reporting of suchobservations. Pilgrim continues to conduct environmental monitoring under its NationalPollutant Discharge Elimination System (NPDES) permit, which includes impingement andentrainment monitoring. Although the current scope of monitoring does not specifically addresslisted species, Pilgrim recognizes the appropriateness of promptly reporting to NMFS anyobserved incidental taking of an endangered marine species. Any such report would then be


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PNPS Letter 2.13.102Page 12

reported to NRC in accordance with 10 CFR 50.72(b)(2)(xi), News Release or NotificationofOther Government Agency.In Reference 2, NMFS recognized the erroneous statement in its consultation letter andrequested that the NRC require the reporting of observations of listed species. Pilgrim is notaware of any basis for imposing such a requirement. There is no indication of any incidentaltaking of an endangered species having resulted from Pilgrim's operation over the last fortyyears. Further, both NMFS and NRC have determined that any impact on an endangeredspecies is unlikely.Nevertheless, Pilgrim will be supplementing the plant's environmental monitoring to includereporting of any confirmed sightings of listed whales in the vicinity of Pilgrim Station. This wouldcombine an opportunistic whale sighting by qualified individuals at the site with assistance froman outside organization with expertise in the identification of whale species. A representativedescription of this protocol, which is currently being proceduralized, is provided as Attachment1.This letter contains one new regulatory commitment, which is identified in Attachment 2 to thisletter.Please do not hesitate to contact Mr. Joseph R. Lynch, (508) 830-8403, if there are anyquestions regarding this submittal.

Sincerely,

DavidDirector, Regulatory and Performance Improvement

Attachment 1: Representative Description of Whale Sighting ProtocolAttachment 2: Pilgrim Nuclear Power Station List of Regulatory Commitments.


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PNPS Letter 2.13.102Page I3

cc: Mr. William M. DeanRegional Administrator, Region 1U.S. Nuclear Regulatory Commission2100 Renaissance Blvd., Suite 100King of Prussia, PA 19406-2713

Ms. Nadiyah S. Morgan, Project ManagerDivision of Operating Reactor LicensingOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionMail Stop O-8-F211555 Rockville PikeRockville, MD. 20852

USNRC Senior Resident InspectorPilgrim Nuclear Power Station


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ATTACHMENT 1PNPS Letter 2.13.102

Pilgrim Nuclear Power Station (PNPS)REPRESENTATIVE DESCRIPTION OF WHALE SIGHTING PROTOCOL


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Pilgrim Station WhaleSighting Protocol 12/31/2013

Initial Whale Sighting-Notify Control Room. I

Control Room contactscognizant Entergyindividual.

Whale Expert contactedto prompt site visit.

Whale Expert escortedinto OCA to confirmwhale sighting.

If possible, Whale Expertthen identifies the

whale(s) and determinesifspecies is Listed .

Security Officer or other qualified employeedetermines that there is a whale sighting in thevicinity of Pilgrim Station. Control Room iscontacted immediately.

Control Room then calls cognizant Entergyindividual to permit Whale Expert's access tothe site.

Entergy initiates immediate verbal contact withWhale Expert and arranges for priority site visit.

Whale Expert visitor escorted to the shorefrontfor whale observation.This independent confirmation of the whaleobservation is critical.

If possible, Whale Expert identifies the speciesof whale(s). Determination then made whetheror not species is Listed (if on list ofEndangered or Threatened species).

Control Room is promptly informed of whether ornot whale(s) could be identified and, ifso,whether species is Listed . Ifwhale is found tobe a Listed species then this observation mustbe reported to NRC and NMFS (National MarineFisheries Service).If this whale sighting is determined to bereportable then Operations completes a 4-hournotification to NRC per 10CFR50.72(b)(2)(xi).

Whale Expert reports sighting of Listed Whaleto NMFS.

Pertinent information and actions aredocumented in a condition report. Anyappropriate internal notifications and actions areperformed. Site maintains surveillance.

Whale Expert informsControl Room whethersighting was of Listed

Whale or not.

If eportable, ControlRoom notifies NRC.

If reportable, WhaleExpert notifies NMFS of Listed Whale sighting.

Follow up actions anddocumentationperformed.


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ATTACHMENT 2PNPS Letter 2.13.102

Pilgrim Nuclear Power Station (PNPS)LIST OF REGULATORY COMMITMENTS


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List of Regulatory CommitmentsThe following table identifies those actions committed to by Entergy in this document. Any other statements in this submittaare provided for information purposes and are not considered to be regulatory commitments.

/i .. .. ~ TYP .. , ,:... .T ek OSCHEDULEDS(Check One) COMPLETION DATE

COMMITMENT ONE CONTINUINGTIMEA TION COMPLIANCE IfRequired)ACTION

Entergy commits to supplement its existing March 1, 2014environmental monitoring program to includeany potential whale sightings in the vicinity ofPilgrim Station.

Documents

PilgrimWhaleMonitoringSubmittal.12-2013