ML18284A375

Issuance of Amendment No. 248, Revise Site Emergency Plan for On-Shift and Emergency Response Organization Staffing to Address Permanently Defueled Condition

ML18284A375
Person / Time
Site:	Pilgrim
Issue date:	11/30/2018
From:	John Lamb Special Projects and Process Branch
To:	Brian Sullivan Entergy Nuclear Operations
Lamb J, NRR/DORL/LSPB, 301-415-3100
References
EPID L-2018-LLA-0046
Download: ML18284A375 (32)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 30, 2018 Mr. Brian R. Sullivan Site Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508

SUBJECT:

PILGRIM NUCLEAR POWER STATION- ISSUANCE OF AMENDMENT NO. 248 RE: LICENSE AMENDMENT REQUEST TO REVISE THE PILGRIM NUCLEAR POWER STATION EMERGENCY PLAN TO ADDRESS THE PERMANENTLY DEFUELED CONDITION (EPID L-2018-LLA-0046)

Dear Mr. Sullivan:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 248 to the Renewed Facility Operating License No. DPR-35, to authorize the revision to the Site Emergency Plan for the Pilgrim Nuclear Power Station (Pilgrim).

You requested NRC approval of proposed changes to the Pilgrim Site Emergency Plan, as required under Section 50.54(q)(4) of Title 10 of the Code of Federal Regulations (10 CFR),

prior to implementation by the licensee, to support the planned permanent cessation of operations and permanent removal of fuel from the reactor vessel.

This amendment request consists of changes to the Emergency Response Organization's on-shift and augmented staffing in response to your application dated January 12, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18023A795), and as supplemented by letter dated May 23, 2018 (ADAMS Accession No. ML18152A843).

This amendment would revise the Pilgrim Emergency Response Organization on-shift and augmented staffing commensurate with the reduced spectrum of credible accidents for a permanently shut down and defueled power reactor facility.

B. Sullivan A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.

Sincerely, mb, Senior Project Manager rejects and Process Branch f Operating Reactor Licensing Nuclear Reactor Regulation Docket No. 50-293

Enclosures:

1. Amendment No. 248 to Renewed License No. DPR-35

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.

PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 248 Renewed License No. DPR-35

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by Entergy Nuclear Operations, Inc. (the licensee), dated January 12, 2018, as supplemented by letter dated May 23, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the

• public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, by Amendment No. 248, Renewed Facility Operating License No. DPR-35 is hereby amended to authorize the revision to the Pilgrim Nuclear Power Station Site Emergency Plan as set forth in the licensee's application dated January 12, 2018, as supplemented by letter dated May 23, 2018, evaluated in the NRC staff's safety evaluation issued with this amendment.

3. This license amendment is effective upon submittal of the certification of permanent removal of fuel from the reactor vessel in accordance with 10 CFR 50.82(a)(1 )(ii), and shall be implemented within 90 days of the effective date.

FOR THE NUCLEAR REGULATORY COMMISSION

• ~f-l~6C'L Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: November 3 o , 2 o1 8

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 248 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-35 ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.

PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

1.0 INTRODUCTION

By application dated January 12, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18023A795), as supplemented by letter dated May 23, 2018 (ADAMS Accession No. ML18152A843), Entergy Nuclear Operations, Inc. (Entergy, the licensee), requested approval by the U.S. Nuclear Regulatory Commission (NRC) for proposed changes to the Pilgrim Nuclear Power Station (Pilgrim, PNPS) Site Emergency Plan (SEP) as required under Section 50.54(q)(4) of Title 10 of the Code of Federal Regulation (10 CFR), prior to implementation by the licensee, to support the planned permanent cessation of operations and permanent removal of fuel from the reactor vessel.

The proposed changes would revise the Pilgrim SEP Emergency Response Organization (ERO) on-shift and augmented staffing commensurate with the reduced spectrum of credible accidents for a permanently shut down and defueled power reactor facility. As a result of the transition from an operating facility to a permanently defueled facility, the proposed changes will properly reflect the conditions of the facility, while continuing to maintain effectiveness of the Pilgrim SEP.

The supplemental letter dated May 23, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 27, 2018 (83 FR 13149).

2.0 BACKGROUND

By letter dated November 10, 2015 (ADAMS Accession No. ML15328A053), in accordance with 10 CFR 50.82{a}(1 ), Entergy certified that Pilgrim will permanently cease operations no later than June 1, 2019. Upon docketing of Entergy's certification that all fuel has been permanently removed from the reactor vessel and placed into the spent fuel pool (SFP), pursuant to 10 CFR 50.82(a)(2), the license for Pilgrim will no longer authorize operation of the reactor, or Enclosure 2

emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be initially stored in the SFP, and then subsequently transferred to the onsite independent spent fuel storage installation (ISFSI) until it is shipped offsite.

3.0 REGULATORY EVALUATION

An operating power reactor licensee's emergency plan is developed for a level of effectiveness commensurate with the potential consequences to public health and safety for a wide spectrum of accident scenarios. Upon the permanent cessation of operations and the permanent removal of the fuel from the reactor vessel at Pilgrim, most of the accident scenarios postulated for an operating power reactor will no longer be possible. The irradiated fuel will be stored in the SFP and in canisters on the onsite ISFSI until it can be moved offsite for long-term storage or disposal. The reactor, reactor coolant system (RCS), and reactor support systems are no longer in operation, and have no function related to the storage of the irradiated fuel. Therefore, postulated accidents involving a failure or malfunction of the reactor, RCS, or reactor support systems are no longer applicable.

Section 14, "Station Safety Analysis," of the Pilgrim Final Safety Analysis Report (FSAR) describes the abnormal operational transients and design-basis accident (DBA) scenarios that are applicable during plant operations. During reactor decommissioning, the principal public safety concerns involve the radiological risks associated with the storage of spent fuel onsite.

The postulated DBA that will remain applicable to Pilgrim in a permanently shut down and defueled condition is a fuel handling accident (FHA) in the containment, where the SFP is located (FSAR Section 14.5.5). The licensee stated that Section 14 of the FSAR will be revised to eliminate the DBAs that will not be applicable in the permanently defueled condition.

The regulatory requirements and guidance on which the NRC staff based its review of the license amendment request are addressed below.

3.1 Regulatory Requirements The regulation 10 CFR 50.47(b)(1) states, in part, that "each principal response organization has staff to respond and to augment its initial response on a continuous basis."

The regulation 10 CFR 50.47(b)(2) states, in part, that "adequate staffing to provide initial facility accident response in key functional areas is maintained at all times," and that "timely augmentation of response capabilities is available .... "

The regulation 10 CFR 50. 72(a)(3) states, in part, that "[t]he licensee shall notify the NRC immediately after notification of the appropriate State or local agencies and not later than one hour after the time the licensee declares one of the Emergency Classes."

Section IV.A, "Organization," of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states, in part, that "[t]he organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization .... "

Section IV.D, "Notification Procedures," of Appendix E to 10 CFR Part 50, states, in part, that

"[a] licensee shall have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency."

3.2 Guidance Regulatory Guide 1.101 (Revision 2), "Emergency Planning and Preparedness for Nuclear Power Reactors," October 1981 (ADAMS Accession No. ML090440294), provides guidance on acceptable methods for implementing the planning standards of 10 CFR 50.47(b)(1) and (2),

and the requirements of Sections IV.A and IV.D of Appendix E to 10 CFR Part 50. Regulatory Guide 1.101 (Revision 2) endorses NUREG-0654/FEMA-REP-1 [Federal Emergency Management Agency - Radiological Emergency Preparedness] (Revision 1}, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980 (referred to hereafter as NUREG-0654)

(ADAMS Accession No. ML040420012), which provides specific criteria that the NRC and FEMA find acceptable for complying with the planning standards set forth in 10 CFR 50.47. As such, these criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans.

In NUREG-0654,Section II, "Planning Standards and Evaluation Criterion," Evaluation Criteria 11.B.1 and 11.B.5 address planning standards 10 CFR 50.47(b)(1) and (b)(2). Evaluation Criterion 11.B.1 specifies the onsite emergency organization of plant staff personnel for all shifts, and its relation to the responsibilities and duties of the normal shift complement. In addition, Evaluation Criterion 11.B.5, states, in part, that:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.

The NRC's Office of Nuclear Security and Incident Response (NSIR)/Division of Preparedness and Response (DPR) Interim Staff Guidance (ISG) document - NSIR/DPR-ISG-01, "Emergency Planning for Nuclear Power Plants," November 2011 (ADAMS Accession No. ML113010523),

provides updated guidance addressing emergency planning requirements for nuclear power plants. Specifically, NSIR/DPR-ISG-01 was developed to address the assignment of tasks or responsibilities to on-shift ERO personnel that would potentially overburden them and thus possibly prevent the timely performance of their emergency plan functions. The ISG also endorsed the Nuclear Energy Institute (NEI) document NEI 10-05 (Revision 0), "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," June 2011 (ADAMS Accession No. ML111751698), which was developed to establish a standard methodology for licensees to analyze the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency for an operating power reactor. Licensees are able to use this methodology as an acceptable method to meet the requirements of Section IV.A.9 to Appendix E of 10 CFR Part 50 for all accident scenarios that are applicable in a permanently defueled condition.

4.0 TECHNICAL EVALUATION

The NRC staff reviewed the licensee's regulatory and technical analyses in support of its proposed emergency plan changes, as described in the licensee's letter dated

January 12, 2018, and as supplemented by letter dated May 23, 2018. The NRC staff reviewed the request using the evaluation criteria in Table B-1 of NUREG-0654, as well as the licensee's ability to promptly implement the SFP mitigation strategies, if required. The NRC staff's technical evaluation for the major functional areas of Table B-1 to NUREG-0654 is detailed in Sections 3.1 through 3.7 of this safety evaluation.

In Section 3.2.1, "On-Shift Staffing," of Attachment 1, "Description and Evaluation of the Proposed Changes," to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

To support reduced staffing following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents that could occur in the permanently shut down and defueled condition.

Specifically, the licensee stated that the following accident scenarios were evaluated in the analysis of proposed post-shutdown on-shift staff:

• Design basis threat,

• FHA,

• Aircraft probable threat (50.54(hh)),

• Control Room fire requiring evacuation and maintain SFP cooling, and

• General Emergency with radioactive release and protective action recommendation.

The spectrum of credible accidents and operational events for a permanently shut down and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced, as compared to an operating plant. Operating nuclear power reactor licensees' emergency plans are developed for a level of effectiveness commensurate with the potential consequences to public health and safety for a wide spectrum of accident scenarios. Once Entergy certifies the permanent cessation of operations and the permanent removal of the fuel from the reactor vessel at Pilgrim, most of the accident scenarios postulated for an operating power reactor will no longer be possible. The irradiated fuel will be stored in the SFP and ISFSI, and will remain onsite until it can be moved offsite for long-term storage or disposal. The reactor, RCS, and reactor support systems will no longer be in operation, and will have no functions related to the storage of the irradiated fuel. Therefore, postulated accidents involving failure or malfunction of the reactor, RCS, or reactor support systems will be no longer applicable. During reactor decommissioning, the principal public safety concerns involve the radiological risks associated with the storage of spent fuel onsite.

The licensee identified that the primary events of concern in the immediate post-shutdown and defueled condition will be an FHA and a loss of SFP cooling and/or water inventory.

In Section 3.2.2.2, "Operational Support Center," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

The primary events of concern in the immediate post-shutdown and defueled condition will be a FHA, and a loss of SFP cooling and/or water inventory.

Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of SFP inventory makeup strategies required under

10 CFR 50.54(hh)(2). These capabilities will continue to be maintained as a license condition [License Condition 3.K.(b)].

4.1 Major Functional Area: Plant Operations and Assessment of Operational Aspects The guidance for licensee minimum staffing for nuclear power reactor plants licensed by the NRC is documented in Table B-1 of NUREG-0654. Plant operations on-shift staffing, as implemented in the current Pilgrim SEP, was based on a philosophy that provided defense-in-depth for an operating nuclear power reactor plant.

The Pilgrim SEP currently identifies the following Operations on-shift staffing:

• one Shift Manager,

• one Shift Control Room Engineer,

• three Licensed Nuclear Plant Operators, and

• two Non-Licensed Nuclear Plant Operators.

The licensee's post-shutdown On-Shift Staffing Analysis concluded that in a permanently shut down and defueled condition, with the postulated accidents that would be applicable to that condition, the following on-shift complement would be able to perform all required Pilgrim SEP actions in a timely manner and that there are no identified collateral duties that would prevent the timely performance of emergency plan functions:

• one Control Room Supervisor (CRS) (qualified as a Certified Fuel Handler (CFH)), and

• two Non-Certified Operators (NCOs).

In Section 2.0, "Detailed Description," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

An individual qualified as a CFH will supervise fuel handling operations in the permanently shut down and defueled condition. CRSs will be qualified as CFHs.

The CRS position requires additional qualification beyond the CFH training.

Command and Control will remain with the CRS, regardless of location of the individual designated as the CRS. NCOs will perform duties typically associated with those performed by current Non-Licensed Nuclear Plant Operators, such as manipulation and monitoring of plant equipment. NCOs will also be assigned to monitor indications and communications in the Control Room.

In Section 3.2.1.6, "Major Functional Area: Repair and Corrective Actions," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee further stated, in part, that:

The analysis of proposed post-shutdown on-shift staffing concluded that the on-shift CRS and two (2) NCOs can perform any required technical analysis, until augmented by the [technical support center] TSC, in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

The licensee concluded that the proposed on-shift staffing changes do not impact the capabilities of the on-shift staff to respond to an emergency and continue to comply with the Pilgrim SEP, site commitments, and applicable regulations.

In Section 3.2.2.5, "Control Room Augmenting Positions," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee further stated, in part, that:

PNPS SEP Figure 8-1 b, "Operations Emergency Organization" illustrates the Operations Emergency Organization, including augmenting positions that respond to the Control Room following an emergency declaration. PNPS SEP Part 2, Section 8.1.b.5 [PNPS Emergency Response Organization] describes the Emergency Plant Operations Supervisor as the senior management position in the Control Room responsible for coordination of the Control Room activities with all outside emergency facilities. The Emergency Plant Operations Supervisor does not relieve the Shift Manager of responsibilities for operation of the plant.

This position advises the Emergency Plant Manager on plant status and trends and their potential impact. The Emergency Plant Operations Supervisor interfaces with the TSC Manager, OSC [operations support center] Manager, Radiological Coordinator, and the TSC Security Coordinator.

The licensee concluded that it was no longer necessary to require the augmentation of the Emergency Plant Operations Supervisor to the Control Room in the permanently shut down and defueled condition.

The NRC staff reviewed the licensee's analysis of proposed post-shutdown on-shift staffing. As discussed previously in Section 4.0, the spectrum of credible accidents and operational events for a permanently shut down and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel, is reduced as compared to those at an operating nuclear power reactor plant. Based on this, the NRC staff determined the proposed level of onsite operations staffing will continue to provide for the direction and performance of actions to mitigate the remaining identified applicable events, and the prompt implementation of mitigating actions in response to an SFP accident. Additionally, the augmentation of the Emergency Plant Operations Supervisor to the Control Room is no longer required due to the same basis.

Based on the NRC staff's review of the information provided in Entergy's application dated January 12, 2018, as supplemented by letter dated May 23, 2018, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47{b)(1) and (b )(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. As such, the proposed changes in on-shift staffing for the positions listed above for this functional area are acceptable and do not impact the ability of the on-shift staffing to perform the required plant operations and assessment of operational aspects functions.

4.2 Major Functional Area: Notification/Communication The Pilgrim SEP currently identifies an on-shift staffing position as the Shift Communicator, who is responsible for performing the function of notification/communication. On-shift notification will typically be performed by an NCO or Operations Supervisor at Pilgrim. The licensee proposes to maintain the present communication protocol of a Shift Communicator as an on-shift position (i.e., the function would remain within the Control Room until the augmented staff relieves the on-shift communicator). This Pilgrim SEP currently has a 60-minute augmenting Emergency

Notification System (ENS) Communicator responding to the Control Room to relieve the Shift Communicator. The licensee proposes to eliminate the augmenting ENS Communicator to the Control Room by maintaining the communication functions with on-shift NCO.

The regulations in Section IV.D.3 of Appendix E to 10 CFR Part 50 require that "[a] licensee shall have the capability to notify responsible State and local government agencies within 15 minutes after declaration of an emergency classification." In addition, the regulations in 10 CFR 50. 72(a)(3) state, in part that "[t]he licensee shall notify the NRC immediately after notification of the appropriate State or local agencies and not later than one hour after the time the licensee declares one of the Emergency Classes."

Section D, "Emergency Classification System," of the Pilgrim SEP states that it will notify the Commonwealth of Massachusetts and local communities within 15 minutes after declaration of an emergency, and will notify the NRC immediately after notification of the appropriate State and local agencies, and no later than an hour after the time Pilgrim declares one of the emergency classes.

In Section 3.2.1.2, "Major Functional Area: Notification and Communications," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

Initial notification to offsite authorities are required to occur within 15 minutes of declaration of an emergency and initial NRC notification is required to occur immediately after notification of the appropriate Commonwealth of Massachusetts or local agencies and not later than 60 minutes after the time of the emergency declaration. Subsequent notifications are made should the event escalate and for informational updates. The resource commitment to support the communication function is not full time so there is time to support performance of collateral duties during the first 60 minutes until staff augmentation can occur.

The on-shift and offsite communicators have advanced communications capabilities available such as the Dedicated Notification Network (DNN).

Communications with the NRC take place over dedicated telephone lines provided for and maintained by the NRC ENS. For purposes of the analysis of proposed post-shutdown on-shift staffing, NRC notifications were treated as a continuous action in accordance with 10 CFR 50.72(c)(3), meaning that once the initial NRC communications are established, it was assumed that the NRC will request an open line to be continuously maintained with the NRC Operations Center. The use of dedicated phone circuits and headsets enables these notifications to be performed by the same on-shift NCO who performs the Commonwealth of Massachusetts and local notifications.

In the post-shutdown condition, the task of notifying and communicating with offsite authorities will typically be performed by an NCO at Pilgrim. The NRC staff reviewed the licensee's analysis of proposed post-shutdown on-shift staffing and determined that in a permanently defueled condition, the designated on-shift staffing could perform this required Pilgrim SEP action in a timely manner. No collateral duties were identified that would prevent the timely performance of this emergency plan function and the licensee continues to maintain the same level of communications equipment capabilities from its emergency facilities to perform timely communications with the required offsite agencies. Based on this, the NRC staff determined that in a permanently defueled condition, the designated on-shift staffing could perform this required Pilgrim SEP action in a timely manner.

Based on the NRC staff's review of the information provided in Entergy's application dated January 12, 2018, as supplemented by letter dated May 23, 2018, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47(b)(1) and (b)(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. In addition, the proposed change continues to provide adequate staffing to meet the requirements of 10 CFR 50. 72(a)(3) and Section IV.D of Appendix E to 10 CFR Part 50 for the timely notification of the NRC and responsible State and local governmental agencies. As such, the proposed changes in staffing for the communications positions listed above for this functional area are acceptable and do not impact the ability of the on-shift staffing to perform the required notification/ communication functions.

4.3 Major Functional Area: Radiological Accident Assessment and Support of Operational Accident Assessment The purpose of conducting accident assessment is to review radiological conditions using data from available instrumentation; assessing the impact of changing radiological conditions on emergency classification; assisting in accident assessments based upon those changing radiological conditions, and recommending appropriate offsite protective measures.

The Pilgrim SEP currently identifies the following on-shift staffing:

• one Radiation Protection Technician, and

• one Chemistry Technician (also referred to as "Radio Chemistry Technician" in the submittal).

The current Pilgrim SEP on-staffing has the on-shift Radiation Protection Technician and Chemistry Technician performing the initial dose assessment. The licensee proposes to eliminate the on-shift Chemistry Technician position, while requiring that, during activities that could cause mechanical damage to spent fuel, either a Chemistry Technician will be onsite or the radiation monitor listed in gaseous effluent Emergency Action Levels (EALS) will be in service.

In Section 3.2.1.4.1, "Major Task: Offsite Dose Assessment," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

The elimination of the on-shift Chemistry Technician position does not impact the ability of the on-shift staff to perform the initial dose assessment. The analysis of proposed post-shutdown on-shift staffing concluded that in a permanently defueled condition, the on-shift CRS and two NCOs can perform all required PNPS SEP actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions. Control Room personnel can perform initial dose assessment using existing EPIPs

[emergency plan implementing procedures].

As such, the change is acceptable, because it is an administrative reassignment of the on-shift personnel designated to perform initial dose assessment.

In Section 3.2.1.4.4, "Major Task: Chemistry/Radiochemistry," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

For gaseous releases, the only credible scenario for releasing gas would be to mechanically damage spent fuel during handling or by impact of a heavy object.

Activities that could cause mechanical damage will require that a Radio Chemistry Technician be onsite or the radiation monitor listed in gaseous effluent EALs is in service, thereby alleviating any reliance on a potentially delayed sample analysis to determine EAL applicability.

In Section 3.2.1.4.4 of Attachment 1 to Entergy's application dated January 12, 2018, the licensee further stated, in part, that:

When the on-shift Radio Chemistry Technician position is eliminated, the on-shift Radiation Protection Technician will be able to perform sampling and analysis, so as to not delay information potentially needed by the Shift Manager to determine if an emergency declaration is required.

The NRC staff reviewed the licensee's analysis of proposed post-shutdown on-shift staffing, which provided that there were not any chemistry job tasks required for any of the analyzed events. As the licensee stated previously, one of the purposes of the Radio Chemistry Technician is to collect and analyze gaseous and liquid samples if the applicable radiation monitor is not available during a release, or as directed by the Shift Manager. With the elimination of the Radio Chemistry Technician, this function will now be performed by the on-shift Radiation Protection Technician, if required. The Radiation Protection Technician is capable of performing the reassigned duties that were previously performed by the eliminated Radio Chemistry Technician position, because the on-shift Radiation Protection Technicians will be trained to perform liquid sampling and analysis to support an emergency declaration. The reassignment will not affect the capability of the Radiation Protection Technician to perform the assigned functions associated with remaining applicable accidents. As such, the removal of the Radio Chemistry Technician position does not impact the ability of the on-shift or ERO staff to perform the major functional area of radiological accident assessment and support of operational accident assessment. Therefore, the staff concludes that the change in staffing is acceptable.

Based on the NRC staff's review of the information provided in Entergy's application dated January 12, 2018, as supplemented by letter dated May 23, 2018, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47(b)(1) and (b)(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. As such, the proposed changes in on-shift staffing for the positions listed above for this functional area are acceptable and do not impact the ability of the on-shift staffing to perform the required radiological accident assessment and support of operational accident assessment functions.

4.4 Major Functional Area: Plant System Engineering, Repair, and Corrective Actions The licensee proposes to eliminate the Shift Control Room Engineer (SCRE) position from the on-shift staffing. The licensee concluded that because of the permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the SCRE position would no

longer be necessary for technical and analytical assistance for plant operational concerns during abnormal and emergency situations, analysis of events and their effects, or the on-shift core/thermal hydraulics function of the emergency plan.

In Section 3.2.1.6, "Major Functional Area: Repair and Corrective Actions," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

The SCRE performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations.

The SCRE also contributes to operations during normal plant conditions. By routine monitoring of equipment and plant operations, the SCRE can focus on preventative actions to mitigate the consequences of an accident.

In Section 3.2.1.6 of Attachment 1 to Entergy's application dated January 12, 2018, the licensee further stated, in part, that:

The analysis of proposed post-shutdown on-shift staffing concluded that the on-shift CRS and two (2) NCOs can perform any required technical analysis, until augmented by the TSC, in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

The NRC staff reviewed the analysis of proposed post-shutdown on-shift staffing and the supplemental information from the licensee, and concludes that because of the permanent cessation of power operations and removal of fuel from the reactor vessel, the SCRE position is no longer necessary for technical and analytical assistance. The NRC determined that qualified personnel are available to respond to an emergency. As discussed previously in Section 3.0, the spectrum of credible accidents and operational events for a permanently shut down and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating nuclear power reactor. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities in the Control Room. The NRC staff agrees with the licensee's analysis of proposed post-shutdown on-shift staffing, which concluded that the on-shift CRS and two NCOs can perform any required technical analysis, until augmented by the TSC, in a timely manner and that there are no collateral duties that would prevent the timely performance of this task.

Based on the NRC staff's review of the information provided in Entergy's application, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47(b)(1) and (b)(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. As such, the proposed changes in the on-shift staffing for the positions discussed above for this functional area are acceptable and do not impact the ability of the on-shift staffing to perform the required plant system engineering, repair, and corrective actions functions.

4.5 Major Functional Area: Protective Actions (In-Plant)

This functional area exists to provide radiation protection oversight of the on-shift complement of personnel and augmented personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue, first aid, firefighting, and personnel monitoring. These personnel can also be expected to provide for access control and the issuance of dosimetry.

The Pilgrim SEP currently identifies two on-shift Radiation Protection Technicians as performing the in-plant protective actions. However, per Table B-1 to NUREG-0654, these tasks can be performed by personnel assigned other functions. The Pilgrim SEP further identifies that augmentation of the on-shift Radiation Protection Technicians is by two Radiation Protection Technicians within approximately 30 minutes and two additional Radiation Protection Technicians within approximately 60 minutes. The licensee proposes to eliminate one on-shift Radiation Protection Technician, as well as one 30-minute and one 60-minute augmenting Radiation Protection Technicians.

In Section 3.2.1.7.1, "Major Tasks: Radiation Protection, Access Control, RP Coverage, Personnel Monitoring, and Dosimetry," of Attachment 1 to Entergy's application, dated January 12, 2018, the licensee stated, in part, that:

During a declared emergency, Radiation Work Permits (RWPs) and dose set points will change depending on the emergency and plant conditions. Both systems have been used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used. If a worker's dose margin is inadequate or training is expired, the worker's access would be precluded and the access control system would not allow issuance of an electronic dosimeter. In an emergency, approval to exceed dose margins is required. During the log-in process, workers acknowledge their electronic dosimeter alarm set points and that they have read and understand their RWP. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and will alarm at preset dose and dose rates. Worker use of electronic dosimeters facilitates more efficient use of Radiation Protection Technicians to provide Radiation Protection coverage while preserving the As Low As Reasonably Achievable (ALARA) concept. Access control is maintained because the worker must obtain an electronic dosimeter and enter a radiation work permit number into the access control computer system prior to being allowed access into the Radiologically Controlled Area (RCA). No setup is required for the RWP access control computers, which allows Radiation Protection Technicians to be used for more critical tasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit the RCA No Radiation Protection involvement is necessary for this contamination monitoring activity because workers are trained to perform this task without supervision or oversight. However, contaminated personnel exiting the RCA will require Radiation Protection oversight.

During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, Radiation Protection

coverage would not be required for all areas. Because entry is expected to be limited to those areas where maintenance necessary to maintain SFP cooling is required and the areas potentially affected by an accident involving the SFP are limited, there is a significant decrease in areas potentially requiring Radiation Protection coverage in a permanently shut down and defueled condition. If Radiation Protection coverage is deemed necessary, multiple emergency teams can be covered by the on-shift Radiation Protection Technician. If Radiation Protection coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate set points) and because of the installed ARMs [area radiation monitors] (which alarm locally and remotely at preset dose rates) located throughout the plant.

Activities related to the conduct of surveys or radiological assessment of the area surrounding PNPS are performed by the OMT [offsite monitoring team] Members identified in the Offsite Surveys Major Task of Table B-1 of the PNPS SEP, independent of the augmenting Radiation Protection Technician positions.

The NRC staff reviewed the licensee's analysis of proposed post-shutdown on-shift staffing, which provided that in a permanently defueled condition the designated on-shift Radiation Protection Technician staffing could perform this required Pilgrim SEP action in a timely manner. As discussed previously in Section 3.0, the spectrum of credible accidents and operational events for a permanently shut down and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced, as compared to an operating plant. Based on this, the NRC staff concludes that the level of on-shift staffing of one Radiation Protection Technician and augmentation of one 30-minute and one 60-minute Radiation Protection Technicians will continue to provide for support of radiation protection oversight of the on-shift complement of personnel for damage repair, corrective actions, search and rescue, first aid, firefighting, and personnel monitoring required for the remaining DBAs and for mitigative actions in response to an SFP accident.

Based on the NRC staff's review of the information provided in Entergy's application, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47(b)(1) and (b)(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. As such, the proposed changes in the on-shift and augmentation staffing for the positions discussed above for this functional area are acceptable and do not impact the ability of the on-shift staffing to perform the required plant system engineering functions.

4.6 Major Functional Areas: Fire Fighting/Rescue Operations and First Aid The Pilgrim Fire Brigade complement currently consists of five responders, one of which acts as the Plant Fire Brigade Leader.

In Section 3.2.1.7.2, "Major Task: Fire Fighting," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

The Fire Brigade will continue to be staffed in accordance with Technical Specifications. All Fire Brigade training and qualification requirements will be maintained using the Fire Hazards Analysis requirements. The Fire Brigade will continue to perform the task of firefighting in the permanently shut down and defueled condition. The Fire Brigade will be available to promptly implement SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2) without impacting the performance of designated emergency plan functions.

Entergy proposes no staffing changes to the Rescue Operations and First Aid Major Functional Area. Currently, on-shift Emergency Medical Personnel initially perform the task augmented by on-call ambulance service.

As there are no staffing changes proposed for this functional area, the NRC staff concludes that the licensee's proposal will not impact the timing or performance of existing emergency response duties and that the proposal will not impact the licensee's ability to provide initial facility accident response in this functional area, in accordance with 10 CFR 50.47(b ).

4.7 Licensee Augmented ERO Changes The proposed changes to the Pilgrim SEP will eliminate certain ERO positions currently identified in Section B, "Emergency Response Organization," of the Pilgrim SEP and EPIPs for the augmentation of the Control Room staff, and the activation and operation of the TSC, Emergency Operations Facility (EOF), OSC, and Joint Information Center (JIC). Several of these positions are described in Table B-1, "Minimum Staffing Requirements for the Pilgrim ERO," of the Pilgrim SEP and EPIPs as positions required to meet the minimum positions needed to declare the emergency response facility (ERF) operational.

In Section 2.3, "PNPS Specific Background," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

The PNPS SEP defines four classes of emergency events: Notification of Unusual Event (UE), Alert, Site Area Emergency (SAE) and General Emergency (GE). Because on-shift personnel can normally address an emergency response to UEs without additional support, staff augmentation may not be activated for an UE declaration. The Operations Shift Manager maintains responsibility during UEs, unless the EOF has been activated. An Alert or higher emergency declaration results in the activation of the EOF, TSC, OSC, and JIC. Overall responsibility for the event is assumed by the Emergency Director in the EOF when the EOF is declared operational.

In Section 3.2.2, "Augmented ERO Staffing," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

Prior to an emergency declaration, the normal plant operating organization is in place. The initial classification of an off-normal event and declaration are performed by the Shift Manager. Upon the classification and declaration of an emergency, the Shift Manager assumes the role of Emergency Director and retains that role until another designated Emergency Director can assume

control. Following implementation of the changes described in this amendment, the command and control function will reside with the CRS. The onsite emergency organization is activated by personnel notification or when the station alarm is sounded and the emergency is announced over the public address system. Initially, the ERO consists of the normal operating shift personnel who function as the emergency team members. The normal operating staff is augmented by qualified plant personnel. Those personnel onsite respond when the station alarm is sounded and the announcement is made or when individuals are notified by another means. Personnel not onsite during off-hours operations will be notified via an ERO notification system. A designated on-shift plant employee shall perform notifications.

In the permanently shut down and defueled condition, PNPS will continue to maintain ERO teams to respond to an emergency declaration. When the CRS directs the activation of the ERO call out system, ERO members are notified to ensure adequate coverage of ERO positions at each ERF. ERO members not on-call are expected to respond unless they are unavailable.

PNPS requires ERO personnel to act promptly in reporting to their assigned ERF even when not on duty. During duty periods, procedures further require that team members respond within the required response time for their ERF (unless a longer time frame is specified for their specific ERO position) and that they remain fit for duty throughout the duty assignment. Individuals are trained to respond to their ERF even if they are not on duty. Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift. This conservative policy ensures timely activation because some off-duty personnel may respond sooner than the on-duty personnel.

The proposed revisions to the PNPS SEP will not change the requirements described above. Management's continued expectation is that all duty and support ERO members report to their respective ERF as quickly as possible. All ERO personnel are expected to respond when notified by the ERO notification system. Each of the positions proposed for elimination was analyzed to identify the key duties associated with the position and the duties were then evaluated against the planning standards in NUREG-0654.

In Section 3.2.2 of Attachment 1 to Entergy's application dated January 12, 2018, the licensee further stated, in part, that:

To validate the results of the proposed changes to the augmented ERO, one or more drills will be developed and conducted prior to implementation of the changes described within this LAR [license amendment request]. The drills will be conducted to confirm the ability of the post-shutdown augmented ERO to perform the necessary functions of each ERF and will utilize the post-shutdown procedures that will be developed depicting the revised assignment of duties.

The drills will be used to train and qualify post-shutdown augmented ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time-sensitive activities or in the ability to communicate with OROs [offsite response organizations]. The drills will also validate that the post-shutdown augmented ERO continues to address the risks to public health

and safety and comply with the PNPS SEP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of the post-shutdown augmented ERO staff and during the conduct of drills described above.

The elimination of the following minimum staffing positions is evaluated below, in addition to other requested changes to the Pilgrim ERO:

• TSC Manager,

• two OSC Instrumentation and Control (l&C) Technicians,

• one OSC Chemistry Technician, and

• EOF Manager.

4. 7 .1 Operations Support Center The OSC is an onsite assembly area separate from the Control Room and the TSC, where the licensee's operations support personnel shall report in an emergency. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the OSC will continue to be located on the ground floor of the Operations and Maintenance Building, next to the TSC. The proposed changes to the Pilgrim SEP do not involve any physical modifications to or layout configuration changes in the OSC.

In the permanently shut down and defueled condition, the primary functions of the OSC will remain dispatching of, and accounting for, repair and corrective action teams and the dispatching of onsite and offsite field monitoring teams. The OSC craft functions will continue to be performed by augmenting qualified resources. The OSC Manager will continuously evaluate the need for resources and coordinate with the EOF Technical Advisor to call in additional assistance, if needed. The OSC resources will continue to be augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the post-shutdown condition.

The following table illustrates the NRC staff's summary of the proposed changes to the OSC staffing in the post-shutdown emergency plan:

PNPS OSC Augmented Staff Positions Current Staff Positions Proposed Staff Positions OSC Manager OSC Manager Technicians (Electrical, Mechanical Technicians {Electrical, Mechanical Maintenance, l&C, Radiation Protection) Maintenance, Radiation Protection)

OSC Operations Support Position Eliminated Work Control Support Position Eliminated Mechanical and l&C/Electrical Coordinators Position Eliminated Rad/Chem Coordinator Position Eliminated Dosimetry Clerk Position Eliminated OSC Log Keeper Position Eliminated

The proposed staffing changes eliminate the following three ERO positions in the OSC, described in the Pilgrim SEP as typical minimum staffing that could be necessary to declare the OSC operational:

• two l&C Technicians, and

• one Chemistry Technician.

The proposed staffing changes will also eliminate two augmenting Electrical Technicians, one Mechanical/Maintenance Technician, and five Radiation Protection Technicians. These positions are included in Pilgrim SEP Table B-1 as augmenting responders.

In Section 3.2.2.2, "Operations Support Center," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee provided, in part, that:

In the permanently shut down and defueled condition, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The primary events of concern in the immediate post-shutdown and defueled condition will be a[n] FHA and a loss of SFP cooling and/or water inventory. Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2). These capabilities will continue to be maintained as a license condition. OSC staff is not relied upon to implement SFP inventory makeup.

Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC and OSC in a permanently shut down and defueled condition. Although ERO activation/response time requirements will be unchanged, the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. The proposed changes do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency or provide information to offsite authorities in a timely manner. Therefore, the OSC Operations Support, Work Control Coordinator, Mechanical and l&C /Electrical Coordinators, Rad/Chem

[Radiological/Chemical] Coordinator, Dosimetry Clerk, and OSC Log Keeper positions can be eliminated without placing an undue burden on the remaining ERO positions in the OSC and without increasing the risk to public health and safety.

The NRC staff reviewed the licensee's analysis of proposed post-shutdown ERO staffing, which stated that these proposed changes are the reassignment of functional and administrative responsibilities to the remaining staff in the OSC. As discussed previously in Section 3.0, the spectrum of credible accidents and operational events for a permanently shut down and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced, as compared to an operating plant. The NRC staff concludes that the proposed level of OSC staffing remaining after elimination of the OSC Operations Support, Work Control Coordinator, Mechanical and l&C/Electrical Coordinators, Radiological/Chemical Coordinator, Dosimetry Clerk, and OSC Log Keeper positions will continue to provide the level of support required for the remaining OBA and for mitigative actions in response to an SFP accident.

Based on the NRC staff's review of the information provided in the Entergy letter dated January 12, 2018, as supplemented by letter dated May 23, 2018, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47(b)(1) and (b )(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. As such, the proposed changes in the on-shift staffing for the positions discussed above for this functional area are acceptable and do not impact the licensee's ability to perform the required plant repair and corrective action, and radiological field monitoring functions.

4.7.2 Technical Support Center The TSC is an onsite facility located close to the Control Room that provides plant management and technical support to the reactor operating personnel located in the Control Room during emergency conditions. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the TSC will continue to be located on the ground floor of the Operations and Maintenance Building. The proposed changes to the Pilgrim SEP do not involve any physical modifications to or layout/configuration changes in the TSC.

The following table illustrates the NRC staff's summary of the proposed changes to the TSC staffing in the post-shutdown emergency plan:

PNPS TSC Augmented Staff Positions Current Staff Positions Proposed Staff Positions Emergency Plant Manager Emergency Plant Manager Operations Coordinator Operations Coordinator Engineering Coordinator Engineering Coordinator Radiological Coordinator Radiological Coordinator Security Coordinator Security Coordinator TSC Manager Position Eliminated TSC Reactor Engineer Position Eliminated TSC Engineers (Electrical, l&C, Mechanical) Positions Eliminated IT flnformation Technologyl Specialist Position Eliminated TSC Communicator Position Eliminated Operations Engineer Position Eliminated The licensee stated that the current Pilgrim SEP and ERO staffing is intended to address the risks to public health and safety inherent in an operating nuclear power reactor. The risk in the permanently defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel, is also reduced as compared to an operating nuclear power reactor. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform. As a result, the licensee concluded that the positions, as listed in the table above, can be eliminated without placing an undue burden on the remaining positions in the TSC and without increasing the risk to public health and safety.

The proposed staffing changes eliminate the TSC Manager who, as described in EPIPs as minimum staffing, could be necessary to declare the TSC operational. The licensee's basis for eliminating this position is provided in Section 3.2.2.1, Technical Support Center," of to Entergy's application dated January 12, 2018, in which the licensee stated, in part, that:

The TSC Manager is currently responsible for supervising engineering activities associated with mitigation of the emergency, for ensuring the TSC is being activated in accordance with applicable procedures, and for ensuring notification of the ERO has been made. This position also advises the Emergency Plant Manager on proposed corrective actions and emergency classification from a technical standpoint (i.e., plant system damage, core damage, etc.). Functional responsibilities of the TSC Manager position that remain applicable in a permanently shut down and defueled condition will be reassigned to remaining positions in the TSC. The proposed ERO staffing reductions continue to address the risks to public health and safety/comply with the PNPS SEP, site commitments, and applicable regulations.

The following TSC positions are also proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel:

• TSC Reactor Engineer,

• TSC Engineers (Electrical, l&C and Mechanical),

• Operations Engineer,

• IT Specialist, and

• TSC Communicator.

In Section 3.2.2.1 of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently shut down and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform.

Therefore, the TSC Manager, TSC Reactor Engineer, TSC Engineers, IT Specialist, TSC Communicator, and Operations Engineer positions can be eliminated without placing an undue burden on the remaining ERO positions in the TSC and without increasing the risk to public health and safety.

Additionally, Attachment 6, "Emergency Response Organization Task Analysis," to Entergy's application dated January 12, 2018, contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations.

In Section 3.2.1.6 of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated:

The Engineering Coordinator is tasked with performing an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant. With respect to responding to engineering requests from the Engineering

Coordinator, this function will continue to be performed by augmenting qualified engineering resources. The Engineering Coordinator will continuously evaluate the need for engineering resources and coordinate with the EOF Technical Advisor to call in additional qualified engineering personnel. These individuals may be tasked with activities to be completed at engineering offices external to the TSC, called to report to the TSC, or directed to other facilities.

In its supplemental letter dated May 23, 2018, the licensee provided clarification:

In the permanently shut down and defueled condition, the TSC Engineering Coordinator would have the necessary qualifications, expertise, and capabilities to perform an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant in response to a fuel handling accident or an event resulting in damage to the spent fuel pool (SFP) integrity or the loss of a SFP cooling or inventory.

TSC Reactor Engineer The primary duties of the TSC Reactor Engineer include: monitoring plant conditions for any indication of core damage, assisting in clarifying core parameter information to the Engineering Team, and assisting in the implementation of Severe Accident Management Guidelines. In a permanently shut down and defueled condition, responsibilities associated with a reactor core no longer need to be maintained. Therefore, elimination of the TSC Reactor Engineer position will have no effect on emergency response in a permanently shut down and defueled condition.

The TSC Reactor Engineer position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary or possible in a permanently shut down and defueled condition.

TSC Engineers (Electrical, l&C and Mechanical) and Operations Engineer The primary duties of the TSC Engineer positions include responding to engineering requests from the Engineering Coordinator, evaluating the implementation of Severe Accident Management Guidelines, and assisting the OSC in preparing to send repair teams into the plant. These duties are either no longer necessary in a permanently shut down and defueled condition or will be performed by the Engineering Coordinator. The Engineering Coordinator is tasked with performing an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant.

With respect to responding to engineering requests from the Engineering Coordinator, this function will continue to be performed by augmenting qualified engineering resources. The Engineering Coordinator will continuously evaluate the need for engineering resources and coordinate with the EOF Technical Advisor to call in qualified engineering personnel, as necessary. These individuals may be tasked with activities to be completed at engineering offices external to the TSC, called to report to the TSC, or directed to other facilities.

Engineering resources will continue to be available as augmenting positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the permanently shut down and defueled condition. However, these positions will no longer be identified as on-call positions. The elimination of the TSC Engineer positions is justified because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as

compared to an operating nuclear power reactor. The set of plant equipment required in the permanently shut down and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform. Attachment 6 to Entergy's application dated January 12, 2018, contains an analysis of the TSC Engineer positions and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel.

In addition, the functional responsibilities of the IT Specialist and TSC Communicator positions have been reassigned to the remaining TSC positions, supporting the elimination of these positions.

The NRC staff reviewed the licensee's analysis of proposed post-shutdown ERO staffing, which evaluated that these proposed changes are the reassignment of functional and administrative responsibilities to the remaining staff in the TSC. As discussed previously in Section 4.0, the spectrum of credible accidents and operational events for a permanently shut down and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced, as compared to an operating nuclear power reactor. The NRC staff concludes that the proposed level of TSC staffing, remaining after the proposed changes will continue to support plant management and Control Room operating personnel providing an adequate level of support for the remaining DBAs and for mitigative actions in response to an SFP accident.

Based on the NRC staff's review of the information provided in Entergy's application dated January 12, 2018, as supplemented by letter dated May 23, 2018, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47(b)(1) and (b)(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. As such, the proposed changes in the on-shift staffing for the positions discussed above for this functional area are acceptable and do not impact the licensee's ability to perform the required TSC functions.

4.7.3 Emergency Operations Facility The EOF is a near-site support facility for the management of overall licensee emergency response (including coordination with Federal, State, and local officials), coordination of offsite radiological and environmental assessments, and determination of recommended public protective actions. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the EOF will continue to be located at 44 Obery Street, across from Plymouth North High School in Plymouth, Massachusetts, approximately 4 miles west of PNPS. The proposed changes to the Pilgrim SEP do not involve any physical modifications to or layout/configuration changes in the EOF.

The following table illustrates the NRC staff's summary of the proposed changes to the EOF staffing in the post-shutdown emergency plan:

PNPS EOF Augmented Staff Positions Current Staff Positions Proposed Staff Positions Emergency Director Emergency Director EOF Technical Advisor EOF Technical Advisor Radiological Assessment Coordinator Radiological Assessment Coordinator Offsite Communicator Offsite Communicator Lead Offsite Liaison Lead Offsite Liaison Offsite Team Coordinator Offsite Team Coordinator Dose Assessor Dose Assessor Offsite Liaisons Offsite Liaisons Monitoring Teams (2) Monitoring Teams (2)

EOF Manager Position Eliminated EOF Log Keeper Position Eliminated Administration and Logistics Coordinator Position Eliminated IT Specialist Position Eliminated EOF Communicator Position Eliminated Public Information Liaison Position Eliminated The proposed staffing changes eliminate the EOF Manager position, described in Pilgrim EPIPs as a minimum staff position, necessary to declare the EOF operational.

In Section 3.2.2.3, "Emergency Operations Facility," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

The EOF maintains extensive communications capability with all ERFs and direct links are established between the EOF, the Commonwealth of Massachusetts and town EOCs [emergency operation centers], and the JIC to provide up-to-date emergency status reports. The proposed changes to the PNPS SEP do not involve changes to the ability of offsite authorities to report to the EOF or the JIC, and as a result, do not impact the ability of the offsite authorities to mobilize to, or operate from, the EOF and JIC. When activated, the Emergency Director reports to the EOF and directs the activities of the ERO throughout the emergency and until the recovery activities have been terminated. The Emergency Director, or a designated alternate, issues periodic status reports of the event to the responding offsite representatives located in the EOF. The Lead Offsite Liaison will continue to provide and interpret plant information to the offsite representatives in the EOF and will communicate this information to the towns of Carver, Kingston, Duxbury, and Marshfield EOCs through a bridge line.

Additionally, technical support staff will be dispatched to the Commonwealth of Massachusetts and Plymouth EOCs when requested and appropriate, or generally, during a SAE or GE to act as a liaison with the plant technical staff so the magnitude of the emergency can be more clearly conveyed to the EOCs' staff. The proposed changes to the PNPS SEP do not reduce the ability of PNPS to provide the necessary information regarding the status and progression of an event or in the frequency at which event information updates are provided.

Nor do the changes impact the ability to dispatch additional technical support to

the EOCs. As a result, the proposed changes do not impact the ability of PNPS to communicate with the offsite response organizations.

Centralized coordination of the offsite radiological assessment effort with all organizations interested in, and/or performing, assessments is necessary to ensure that the data and its interpretation are reviewed by organizations with monitoring and assessment responsibilities. The number and types of organizations performing this effort vary with time. Initially, plant emergency response personnel are the only organization performing this function and they are directed from, and their results evaluated, at the EOF. Commonwealth of Massachusetts authorities join the EOF monitoring and assessment activities.

Federal response agencies would augment plant and Commonwealth radiological assessment efforts upon their arrival. Plant and Commonwealth monitoring efforts are coordinated at the EOF. The proposed changes to the PNPS SEP do not involve changes to offsite radiological assessment capabilities or coordination of these efforts with OROs, and as a result, do not impact the ability of offsite agencies to effectively implement their emergency plans. PNPS will continue to maintain the capability to display plant and meteorological data in the EOF, maintain offsite monitoring equipment at the EOF and maintain the current dose assessment capabilities at the EOF. Additionally, PNPS will maintain a goal of approximately sixty (60) minutes after declaration of an emergency to activate the EOF.

In Section 3.2.2 of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

To validate the results of the proposed changes to the augmented ERO, one or more drills will be developed and conducted prior to implementation of the changes described within this LAR. The drills will be conducted to confirm the ability of the post-shutdown augmented ERO to perform the necessary functions of each ERF and will utilize the post-shutdown procedures that will be developed depicting the revised assignment of duties. The drills will be used to train and qualify post-shutdown augmented ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time-sensitive activities or in the ability to communicate with OROs. The drills will also validate that the post-shutdown augmented ERO continues to address the risks to public health and safety and comply with the PNPS SEP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of the post-shutdown augmented ERO staff and during the conduct of drills described above.

The NRC staff reviewed the licensee's analysis of proposed post-shutdown ERO staffing, which stated that these proposed changes are the reassignment of functional and administrative responsibilities to the remaining staff in the EOF. As discussed previously in Section 4.0, the spectrum of credible accidents and operational events for a permanently shut down and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced, as compared to an operating nuclear power reactor. The NRC staff concludes that the proposed level of EOF staffing will continue to provide management of overall licensee emergency response (including coordination with Federal, State, and local

officials), coordination of radiological and environmental assessments, and determination of recommended public protective actions required for the remaining DBAs and for mitigative actions in response to an SFP accident.

Based on the NRC staff's review of the information provided in Entergy's application dated January 12, 2018, as supplemented by letter dated May 23, 2018, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47(b){1) and (b )(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. As such, the proposed changes in the on-shift staffing for the positions discussed above for this functional area are acceptable and do not impact the ability of the on-shift staffing to perform the required EOF functions.

4. 7.4 Joint Information Center The JIC provides a location for the news media to receive information from all involved agencies and companies during an emergency and provide it to the public. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the JIC will continue to be located at the Entergy Industrial Park Training Center in Plymouth, Massachusetts, approximately 6.5 miles northwest of Pilgrim. The proposed changes to the Pilgrim SEP do not involve any physical modifications to or layout/configuration changes in the JIC.

The following table illustrates the NRC staff's summary of the proposed changes to the JIC staffing in the post-shutdown emergency plan:

PNPS JIC Augmented Staff Positions Current Staff Positions Proposed Staff Positions Company Spokesperson Company Spokesperson JIC Manaoer JIC Manager JIC Media Liaison JIG Media Liaison Media Monitor Medial Monitor Public Inquiry Responders Public Inquiry Responder Technical Advisor Position Eliminated JIG Looistics Coordinator Position Eliminated Information Coordinator Position Eliminated JIC Loo Keeper Position Eliminated JIG Technical Assistant Position Eliminated Press Release Writer Position Eliminated Inquiry Response Coordinator Position Eliminated Agency Coordinator Position Eliminated Credentialino Position Eliminated Media Assistants Position Eliminated A/V [audio/visual] Assistants Position Eliminated Admin Team Position Eliminated

In Section 3.2.2.4, "Joint Information Center," of Attachment 1 to Entergy's application dated January 12, 2018, the licensee stated, in part, that:

The PNPS JIC provides a location for the news media to receive information from all involved agencies and companies during an emergency and provide it to the public. The JIC is equipped to accommodate the news media for large briefings and conferences and contains extensive communications systems. Media monitoring and rumor control are also accomplished at the JIC, allowing PNPS, Entergy, and Commonwealth of Massachusetts representatives to address incorrect information or rumors. Responses to media telephone inquiries are also addressed at the JIC.

In Section 3.2.2.4 of Attachment 1 to Entergy's application dated January 12, 2018, the licensee further stated, in part, that:

In the permanently shut down and defueled condition, media briefings and rumor control will continue to be conducted regularly during an emergency to provide accurate and timely information to the public. The proposed JIC staffing changes described above do not impact the capabilities of the on-shift staffing or augmented response. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the JIC and without increasing the risk to public health and safety. Functional responsibilities of the positions proposed for elimination will be reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the PNPS SEP, site commitments, and applicable regulations.

The NRC staff reviewed the licensee's analysis of proposed post-shutdown ERO staffing, which evaluated that these proposed changes are the reassignment of functional and administrative responsibilities to the remaining staff in the JIC. As discussed previously in Section 3.0, the spectrum of credible accidents and operational events for a permanently shut down and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced, as compared to an operating nuclear power reactor. The NRC staff concludes that the proposed level of staffing at the JIC will continue to disseminate information to the public, providing the level of support required for the remaining DBAs and for mitigative actions in response to an SFP accident.

Based on the NRC staff's review of the information provided in the licensee's letter dated January 12, 2018, as supplemented by letter dated May 23, 2018, the NRC staff finds that the proposed level of staffing continues to meet the planning standards of 10 CFR 50.47(b)(1) and (b )(2) to have adequate staffing to provide initial facility response, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents once Pilgrim is in a permanently shut down and defueled condition. As such, the proposed changes in the on-shift staffing for the positions discussed above for this functional area are acceptable and do not impact the ability of the on-shift staffing to perform the required JIC functions.

4.8 Potential Impact of Staff Changes on Offsite Emergency Response Organizational Interfaces In Section 3.2.2.6 of Attachment 1 of the letter dated January 12, 2018, the licensee stated, in part, that:

Formal offsite REP [Radiological Emergency Preparedness] plans, approved by the FEMA in accordance with 44 CFR 350, are required to be maintained in effect until the NRC approves an exemption to formal offsite emergency preparedness requirements. Because the changes proposed by [Entergy Nuclear Operations] ENO, specifically in regards to ERO staffing of the EOF and JIC, and the Offsite Liaisons at the Carver, Kingston, Duxbury, and Marshfield EOCs, have the potential to adversely impact the effective implementation of the Commonwealth of Massachusetts and local REP plans, the proposed changes to the PNPS SEP were evaluated for impacts on the ability of the Commonwealth of Massachusetts and local response organizations to effectively implement their FE MA-approved REP Plans. This evaluation included a review of the Commonwealth of Massachusetts Radiological Emergency Response Plan, Commonwealth of Massachusetts Radiological Emergency Response Plan Area II, the Town of Plymouth Radiological Emergency Response Plan, the Town of Carver Radiological Emergency Response Plan, the Town of Duxbury Radiological Emergency Response Plan, the Town of Kingston Radiological Emergency Response Plan, the Town of Marshfield Radiological Emergency Response Plan, the Town of Bridgewater Radiological Emergency Response Plan, the City of Taunton Radiological Emergency Response Plan, and the Town of Braintree Reception Community Radiological Emergency Response Plan.

The review of the Commonwealth of Massachusetts and local REPs identified specific references to PNPS Offsite Liaison positions proposed for elimination.

The town emergency plans refer to these Offsite Liaisons as "Pilgrim Station Community Liaisons." Additionally, the proposed changes to the PNPS SEP involve the elimination of two (2) PNPS ERO positions that have tasks that involve interfacing with Commonwealth and local representatives. These two positions are the EOF Manager and the JIC Logistics Coordinator. The discussion provided previously in this section addresses the potential impacts the proposed changes to the PNPS SEP have on the EOF and the JIC, and the potential impacts on the ability of the offsite response organizations to implement their FEMA-approved REP Plans.

The proposed changes do not reduce the ability of PNPS to provide the necessary information regarding the status and progression of an event or the frequency at which event information updates are provided. Nor do the changes impact the ability to provide technical information or dispatch technical support to the EOCs, if necessary. The proposed changes to the ERO staffing do not impact the ability of the Commonwealth of Massachusetts or the local response organizations to effectively implement their FEMA-approved REP Plans.

During the last week of September 2017, PNPS Emergency Planning management and staff discussed the proposed changes to the PNPS SEP, including the proposed elimination of Offsite Liaison positions in the Carver, Kingston, Duxbury, and Marshfield EOCs, with the Emergency Management

Directors from each of these towns. Each of the individuals agreed that the dedicated bridge line would be a satisfactory replacement for the liaison at their town EOC. In addition, the proposed changes to the ERO staffing and the PNPS SEP were also discussed with the representatives from the Commonwealth of Massachusetts and the towns of Plymouth, Duxbury, and Marshfield, and the FEMA regional office during a meeting on November 9, 2017. , "Emergency Response Organization Task Analysis," to Entergy's application dated January 12, 2018, contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The discussion also addresses the potential impacts the proposed changes to the Pilgrim ERO have on the EOF and the JIC, and the potential impacts on the ability of the offsite response organizations to implement their FEMA-approved REP plans.

By letter dated March 8, 2018 (ADAMS Accession No. ML18067A118), the NRC staff requested FEMA's review of the proposed licensee staffing changes against the current FEMA-approved State and local REP plans to verify that no potential adverse impacts exist that would preclude the effective implementation of State and local REP plans. In a letter dated April 25, 2018 (ADAMS Accession No. ML18115A252), FEMA responded that the FEMA Region I and Headquarters REP staff reviewed the proposed licensee staffing changes to the Pilgrim EOF and JIC against the current FEMA-approved REP Plans for the Commonwealth of Massachusetts, and local municipalities. FEMA confirmed that no adverse impacts exist precluding the effective implementation of State and local REP Plans or impacting FEMA's finding of continued reasonable assurance for the PNPS site.

Based on the NRC staff's review of the information addressed above, and the evaluation by FEMA of potential, unintended impacts on offsite REP plans, the NRC staff finds that the proposed changes to the Pilgrim SEP staffing are acceptable and continue to meet the planning standards of 10 CFR 50.47(b)(1) and (b)(2) to have the staff to respond and augment its initial response and the requirement of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with a reduced spectrum of credible accidents in a permanently shut down and defueled condition at the Pilgrim.

4.9 Summary Based on the evaluation above, the NRC staff finds that the proposed emergency plan changes meet the planning standards in 10 CFR 50.47(b)(1) and (b)(2) and the requirements in 10 CFR 50.72(a)(3) and Sections IV.A and IV.D of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds that the proposed Pilgrim SEP will continue to provide reasonable assurance that adequate protective measures can and will continue to be taken in the event of a radiological emergency, commensurate with a reduced spectrum of credible accidents in a permanently shut down and defueled condition at Pilgrim.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Massachusetts State official was notified of the proposed issuance of the amendment on October 10, 2018. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (83 FR 13149; March 27, 2018). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Jeannette Arce, NSIR/DPR/RLB Date: November 30, 2018

ML18284A375 *via memo -via email OFFICE NRR/DORL/LSPB/PM NRR/DORL/LSPB/LA NSIR/DPR/BC*

NAME Jlamb JBurkhardt (!Betts for) JAnderson DATE 10/4/18 10/19/18 9/14/18 OFFICE OGC-NLO** NRR/DORL/LSPB/BC NRR/DORL/LSPB/D NAME KGamin DBroaddus CErlanger DATE 11/6/18 11/15/18 11/20/18 OFFICE NRR/D NRR/DORL/LSPB/PM NAME HNieh (MEvans for) Jlamb DATE 11/29/18 11/30/18