SEn tergy Entergy Nuclear Operations, Inc.

600 Rocky Hill Road

Plymouth, MA 02360

Pilgrim Nuclear Power Station

December 31, 2013

U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Washington, D.C. 20555

SUBJECT:

REFERENCES:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station

Docket No.: 50-293

License No.: DPR-35

1. Letter, D. S. Morris, United States Department of Commerce, National

Oceanic and Atmospheric Administration, National Marine Fisheries

Service, to A. S. Imboden, Chief, Environmental Review and Guidance

Update Branch, U.S. Nuclear Regulatory Commission, Pilgrim Nuclear

Power Station, May 17, 2012.

2. Letter, J. K. Bullard, United States Department of Commerce, National

Oceanic and Atmospheric Administration, National Marine Fisheries

Service, to A. Hull, Acting Chief, Environmental Review and Guidance

Update Branch, U.S. Nuclear Regulatory Commission, Pilgrim Nuclear

Power Station, April 24, 2013.

LETTER NUMBER: 2.13.102

Dear Sir or Madam:

On May 17, 2012, the National Marine Fisheries Service (NMFS) issued Reference 1, a

consultation letter, which concluded that the continued operation of the Pilgrim Nuclear Power

Station (Pilgrim) under the terms of a renewed license is not likely to adversely affect any listed

species under NMFS jurisdiction. The letter further concluded that the continued operation of

Pilgrim 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 listed

species."

There are no current conditions of the Pilgrim Operating License that require reporting of such

observations. Pilgrim continues to conduct environmental monitoring under its National

Pollutant Discharge Elimination System (NPDES) permit, which includes impingement and

entrainment monitoring. Although the current scope of monitoring does not specifically address

listed species, Pilgrim recognizes the appropriateness of promptly reporting to NMFS any

observed incidental taking of an endangered marine species. Any such report would then be
PNPS Letter 2.13.102

Page 12

reported to NRC in accordance with 10 CFR 50.72(b)(2)(xi), News Release or Notification of

Other Government Agency.

In Reference 2, NMFS recognized the erroneous statement in its consultation letter and

requested that the NRC require the reporting of observations of listed species. Pilgrim is not

aware of any basis for imposing such a requirement. There is no indication of any incidental

taking of an endangered species having resulted from Pilgrim's operation over the last forty

years. Further, both NMFS and NRC have determined that any impact on an endangered

species is unlikely.

Nevertheless, Pilgrim will be supplementing the plant's environmental monitoring to include

reporting of any confirmed sightings of listed whales in the vicinity of Pilgrim Station. This would

combine an opportunistic whale sighting by qualified individuals at the site with assistance from

an outside organization with expertise in the identification of whale species. A representative

description of this protocol, which is currently being proceduralized, is provided as Attachment

1.

This letter contains one new regulatory commitment, which is identified in Attachment 2 to this

letter.

Please do not hesitate to contact Mr. Joseph R. Lynch, (508) 830-8403, if there are any

questions regarding this submittal.

Sincerely,

David N es

Director, Regulatory and Performance Improvement

Attachment 1: Representative Description of Whale Sighting Protocol

Attachment 2: Pilgrim Nuclear Power Station List of Regulatory Commitments.
PNPS Letter 2.13.102

Page I 3

cc: Mr. William M. Dean

Regional Administrator, Region 1

U.S. Nuclear Regulatory Commission

2100 Renaissance Blvd., Suite 100

King of Prussia, PA 19406-2713

Ms. Nadiyah S. Morgan, Project Manager

Division of Operating Reactor Licensing

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Mail Stop O-8-F2

11555 Rockville Pike

Rockville, MD. 20852

USNRC Senior Resident Inspector

Pilgrim Nuclear Power Station
ATTACHMENT 1

PNPS Letter 2.13.102

Pilgrim Nuclear Power Station (PNPS)

REPRESENTATIVE DESCRIPTION OF WHALE SIGHTING PROTOCOL
Pilgrim Station "Whale Sighting Protocol" 12/31/2013

Initial Whale SightingNotify Control Room. I

Control Room contacts

cognizant Entergy

individual.

Whale Expert contacted

to prompt site visit.

Whale Expert escorted

into OCA to confirm

whale sighting.

If possible, Whale Expert

then identifies the

whale(s) and determines

if species is "Listed".

Security Officer or other qualified employee

determines that there is a whale sighting in the

vicinity of Pilgrim Station. Control Room is

contacted immediately.

Control Room then calls cognizant Entergy

individual to permit Whale Expert's access to

the site.

Entergy initiates immediate verbal contact with

Whale Expert and arranges for priority site visit.

Whale Expert visitor escorted to the shorefront

for whale observation.

This independent confirmation of the whale

observation is critical.

If possible, Whale Expert identifies the species

of whale(s). Determination then made whether

or not species is "Listed" (if on list of

Endangered or Threatened species).

Control Room is promptly informed of whether or

not whale(s) could be identified and, if so,

whether species is "Listed". If whale is found to

be a "Listed" species then this observation must

be reported to NRC and NMFS (National Marine

Fisheries Service).

If this whale sighting is determined to be

reportable then Operations completes a 4-hour

notification to NRC per 10CFR50.72(b)(2)(xi).

Whale Expert reports sighting of "Listed Whale"

to NMFS.

Pertinent information and actions are

documented in a condition report. Any

appropriate internal notifications and actions are

performed. Site maintains surveillance.

Whale Expert informs

Control Room whether

sighting was of "Listed

Whale" or not.

If reportable, Control

Room notifies NRC.

If reportable, Whale

Expert notifies NMFS of

"Listed Whale" sighting.

Follow up actions and

documentation

performed.
ATTACHMENT 2

PNPS Letter 2.13.102

Pilgrim Nuclear Power Station (PNPS)

LIST OF REGULATORY COMMITMENTS
List of Regulatory Commitments

The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal

are provided for information purposes and are not considered to be regulatory commitments.

/i .. .. ~ TYP•E TPek OSCHEDULED .. , ,•:... .

S(Check One) COMPLETION DATE

COMMITMENT ONE- CONTINUING

TIME A.TION COMPLIANCE (If Required) ACTION

Entergy commits to supplement its existing March 1, 2014

environmental monitoring program to include

any potential whale sightings in the vicinity of

Pilgrim Station.