ML17053A468

Technical Specifications Proposed Change - Administrative Controls for Permanently Defueled Condition

ML17053A468
Person / Time
Site:	Pilgrim
Issue date:	02/14/2017
From:	Dent J A Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.17.004
Download: ML17053A468 (52)

Text

• =====Entergy February 14, 2017 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 . Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 John A. Dent, Jr. Site Vice President

SUBJECT:

Technical Specifications Proposed Change -Administrative Controls for Permanently Defueled Condition Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc., to NRC, "Notification of

• Permanent Cessation of Power Operations," dated November 10, 2015 (Letter Number: 2. 15.080) (ML 15328A053)

2. Letter, Entergy Nuclear Operations, Inc., to NRC,."Request for Approval of Certified Fuel Handler Training and Retraining Program," dated February 2, 2017 (Letter Number: 2.17.001)

' ' LETTER NUMBER: 2.17.004

Dear Sir or Madam:

In accordance with 10 Code of Federal Regulations (CFR) 50.90, Entergy Nuclear Operations; Inc. (ENO) is proposing an amendment to Renewed Facility Operating License DPR-35 for Pilgrim Nuclear Power Station (PNPS). In Reference 1, ENO notified the U.S. Nuclear Regulatory Commission (NRC) that it has decided to permanently cease operations of PNPS no later than June 1, 2019. Once certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel are submitted to the NRC in accordance with 10 CFR 50.82(a)(1

)(i) and (ii) and they are docketed, the 10 CFR Part 50 license no longer will permit operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The basis for the proposed amendment is that certain administrative controls may be revised or removed to reflect the permanently defueled, condition.

This request proposes changes to the staffing and training requirements for the PNPS staff contained in Section 5.0, Administrative Controls, of the PNPS Technical Specifications (TS). Reference 2 was submitted proposing a Certified Fuel Handler Training and Retraining Program for NRC approval.

Additional changes are proposed to certain required reports and programs contained in Sections 1.0, 4.0 and 5.0 of the PNPS TS that will no longer be applicable once PNPS is permanently defueled.

D D I /r (J f.-' '

Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 2 of 3 ENO has reviewed the proposed amendment in accordance with 10 CFR 50.92 and concludes it does not involve a significant hazards consideration.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the Commonwealth of Massachusetts, Department of Public Health and Emergency Management Agency.

• Attachment 1 to this letter provides a detailed description and evaluation of the proposed changes. Attachment 2 contains a markup of the current TS pages. Attachment 3 contains the retyped TS pages. ENO requests review and approval of this proposed license amendment by February 15, 2018 and a 60-day implementqtion period from the effective date of the amendment.

ENO requests that the approved amendment become effective following NRC approval of the Certified Fuel Handler Training and Retraining Program (Reference

2) and docketing of the certifications required by 10 CFR 50.82(a)(1).

If you have any questions on this transmittal, please contact Mr. Everett P. Perkins, Jr. at 508-830-8323. There are no new regulatory commitments made in this letter. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 14, 2017. Sincerely, John A. Dent, Jr.

• Site Vice President JAD/sd Attachments:

_ ...

• .*;.* .. 1. Description and Evaluation of the Proposed Changes 2. Markup of the Current Technical Specifications Pages 3. Retyped Technical Specifications Pages Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Ms. Booma Venkataraman, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop Washington, DC 20555-001 Mr. John Priest, Director Massachusetts Department of Public Health Radiation Control Program Commonwealth of Massachusetts 529 Main Street, Suite 1 M2A Charlestown, MA 02129-1121 Mr. John Giarrusso, Jr. Planning and Preparedness Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 NRC Resident Inspector Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 3 of 3

1 Letter Number 2.17.004 Pilgrim Nuclear Power Station Description and Evaluation of Proposed Changes r Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 1.

SUMMARY

DESCRIPTION Letter No. 2.17.004 Page 1 of 18 On November 10, 2015, Entergy Nuclear Operations, Inc. (ENO) notified the U.S. Nuclear Regulatory Commission (NRC) that it would permanently cease power operations at Pilgrim Nuclear Power Station (PNPS) no later than June 1, 2019 (Reference 1 ). This evaluation supports a request to amend Renewed Facility Operating License DPR-35 for PNPS. The proposed changes would revise and remove certain requirements contained within Sections 1.0, 4.0 and 5.0 of the PNPS Technical Specifications (TS). The TS requirements being changed will not be applicable once certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel are submitted to the NRC in accordance with 10 Code of Federal Regulations (CFR) 50.82(a)(1

)(i) and (ii). Once these certifications have been docketed, the 10 CFR Part 50 license for PNPS will, no longer authorize operation of the reactor or placement of fuel in the reactor vessel or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The changes proposed by this amendment would not be effective until the certification of permanent removal of fuel from the reactor vessel has been submitted to the NRC (anticipated June 2019) and the NRC approval of the PNPS Certified Fuel Handler Training and Retraining Program submitted in Reference 2 has been received.

2. DETAILED DESCRIPTION AND BASIS FOR THE CHANGES, Attachment 2 contains a markup of the current TS pages. Attachment 3 contains the TS pages, including administrative changes to spacing to address the revised content.

• PNPS proposes to modify the TSs listed in the tables. In addition, PNPS is providing a description and basis for each of the proposed changes. Proposed Change to PNPS TS Section 1.0, Definitions Current Definition Proposed Definition There is no current definition for CERTIFIED CERTIFIED FUEL HANDLER is an individual FUEL HANDLER. who complies with the provisions of the CERTIFIED FUEL HANDLER Training and Retraining Program. Current Definition Proposed Definition There is no current definition for NON-NON-CERTIFIED OPERATOR is a non-licensed CERTIFIED OPERATOR.

operator who complies with the qualification requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER. Basis PNPS proposes to add definitions for Certified Fuel Handler and Non-Certified Operator.

This ensures that these positions are consistently utilized throughout the TS.

Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 2 of 18 Proposed Change to PNPS TS Section 4.0, Design Features Current TS 4.2. Reactor Core Proposed TS 4.2 The reactor vessel core design shall be as Deleted described in the CORE OPERATING LIMITS REPORT and shall be limited to those fuel assemblies which have been analyzed with NRC approved codes and methods and approved by the NRC in its acceptance of Amendment 22 of GESTAR 11. / Basis PNPS proposes to delete TS 4.2, Reactor Core, because it will no longer apply in the permanently defueled condition.

Once the certifications required by 10 CFR 50.82(a)(1) have been docketed, fuel assemblies will no longer be authorized to be retained or emplaced in the PNPS reactor vessel, pursuant to 10 CFR 50.82(a)(2).

Proposed Changes to PNPS TS Section 5.0, Administrative Controls' 5.1 Responsibility Current TS 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence. The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety. Current TS 5.1.2 The control room supervisor (CRS) shall be responsible for the control room command function.

During any absence of the CRS from the control room while the unit is in an operational mode other than Cold Shutdown or Refueling, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function.

DurinQ any absence of Proposed TS 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence. The plant manager or his designee shall approve, prior to implemeritation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety. Proposed TS 5.1.2 The control room supervisor (CRS) shall be responsible for the shift command function.

Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station the CRS from the control room while the unit is in Cold Shutdown or Refueling, an individual with an active SRO license or Reactor Operator (RO) license shall be designated to assume the control room ( command function.

Basis Letter No. 2.17.004 Page 3of18 This section identifies the responsibilities for the control room command function associated with Modes of plant operation, and is based on personnel positions and qualifications for an operating plant. It identifies the need for a delegation of authority for command in an operating plant when the principal assignee leaves the control room. TS 5.1.1 -The term "unit" is changed to "facility." This is an administrative change thatreflects PNPS will be permanently shutdown and defueled.

The term "facility

is a more appropriate description of a site that is undergoing decommissioning.

This change is proposed throughout this license amendment request. In all cases that this change is made, overall management and staff responsibilities and the description of the facility are unchanged.

TS 5.1.2 -PNPS proposes to change this TS to eliminate the Mode dependency for this function and personnel qualifications associated with an operating plant. The proposed change establishes the control room supervisor as having command of the shift. Delegation of command is unnecessary once PNPS is in the permanently defueled condition with fuel in the spent fuel pool. Any event involving loss of spent fuel pool cooling would evolve slowly enough that no immediate response would be required to protect the health and safety of the public or facility personnel.

5.2 Organization Current TS 5.2.1, Onsite and Offsite Pro12osed TS 5.2.1, Onsite and Offsite Organizations Organizations Organizations shall be established for unit Organizations shall be established for facility staff operation and corporate management, and corporate management, respectively.

These respectively.

These organizations shall organizations shall include the positions for include the positions for activities affecting activities affecting safety of the nuclear fuel. safety of the nuclear power plant. b. The plant manager shall be b. The plant manager shall be responsible for responsible for overall safe operation overall safe operation of the facility and shall of the plant and shall have control over have control over those onsite activities those onsite activities necessary for necessary for safe storage and maintenance safe operation and maintenance of the of the nuclear fuel; plant; c. A specified corporate officer for Pilgrim c. A specified corporate officer for Pilgrim shall shall have corporate responsibility for have corporate responsibility the safe storage overall plant nuclear safety and shall and handling of nuclear fuel and shall take any Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety; and d. The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

Basis Letter No. 2.17.004 Page 4of18 measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure safe management of . nuclear fuel; and d. The individuals who train the CERTIFIED FUEL HANDLERS, carry out health physics, or perform quality assurance functions may report to the appropriate on-site manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

The introduction to this section identifies that organizational positions are established that are responsible for the safety of the nuc;;lear plant. This is changed to require that positions be established that are responsible for the safe handling and storage of nuclear fuel. This change removes the implication that PNPS can return to operation once the certifications required by 10 CFR 50.82(a)(1) are docketed.

The term operation" is changed to "facility staff." In addition, the term "plant" is changed to "facility" in several locations.

These are administrative changes that reflect that PNPS will be permanently shutdown and defueled.

The term "facility" is a more appropriate description of a site that is undergoing decommissioning.

This change is proposed throughout this license amendment request. In all cases that this change is made, overall management and staff responsibilities and the description of the facility are unchanged.

The terms "safe storage and maintenance of nuclear fuel," "safe management of nuclear fuel," and "the safe storage and handling of nuclear fuel" are considered analogous to "nuclear safety" for a facility that will be in the permanently defueled condition.

Proposed changes to replace "nuclear safety" with one of these analogues serves to narrow the focus of nuclear safety concerns to the nuclear fuel. TS 5.2.1.a -No changes are proposed to this TS. TS 5.2.1.b -This section identifies the organizational position responsible for the safe operation of the plant, and for control of activities necessary for the safe operation and maintenance of the plant. To reflect the change in safety concerns from an operating plant to a permanently defueled facility, the responsibility for control of activities necessary for the safe operation and maintenance of the facility is changed to the responsibility for safe storage and maintenance of the nuclear fuel. The change from "plant" to "facility

is administrative.

TS 5.2.1.c -This section identifies the organizational position responsible for overall nuclear plant safety. To reflect the change in safety concerns from an operatinq plant to a permanently defueled Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 5 of 18 facility, PNPS proposes to change the responsibility from "for overall plant nuclear safety to "the safe storage and handling of nuclear fuel," and the responsibility for providing technical support to "the plant to ensure nuclear safety is changed to "the facility to ensure safe management of nuclear fuel." TS 5.2.1.d -This TS addresses the requirement for organizational independence of the personnel who train the operations staff, health physics personnel and quality assurance personnel from operating pressures.

This is changed to replace "operating staff' with "CERTIFIED FUEL HANDLERS" and to replace "their independence from operating pressures" to "their ability to perform their assigned functions." These changes reflect the changed function of the previous operating staff to a focus on safe handling and storage of nuclear fuel, and to remove the implication that PNPS can return to operation once the certifications required by 10 CFR 50.82(a)(1) are docketed.

Current TS 5.2.2, Unit Staff Proposed TS 5.2.2, Facility Staff The unit staff organization shall include the The facility staff organization shall include the following:

following:

a. A non-licensed operator shall be on a. Each duty shift shall be composed of at site when fuel is in the reactor and an least one control room supervisor and one additional non-licensed operator shall NON-CERTIFIED OPERATOR.

The NON-be assigned when the reactor is in an CERTIFIED OPERATOR position may be operational mode other than Cold filled by a CERTIFIED FUEL HANDLER. Shutdown or Refueling.

b. At least one licensed Reactor. b. At least one person qualified to stand Operator (RO) shall be present in the watch in the control room (NON-control room when fuel is in the CERTIFIED OPERATOR or CERTIFIED reactor. In addition, while the unit is FUEL HANDLER) shall be present in the in an operational mode other than control room when nuclear fuel is stored in Cold Shutdown or Refueling, at least the spent fuel pool. one licensed Senior Reactor '. Operator (SRO) shall be present in the control room. c. At least two licensed ROs shall be c. Oversight of fuel handling operations shall present in the control room during be provided by a CERTIFIED FUEL reactor startup, scheduled reactor HANDLER. shutdown and during recovery from reactor trips. d. Shift crew composition may be less d. Shift crew composition may be less than than the minimum requirement of the minimum requirement of 5.2.2.a for a 10 CFR 50.54(m)(2)(i) and 5.2.2.a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in and 5.2.2.i for a period of time not to order to accommodate unexpected exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to absence of on-duty shift crew members accommodate unexpected absence provided immediate action is taken to of on-duty shift crew members restore the shift crew composition to within provided immediate action is taken to the minimum requirements and all of the Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station restore the shift crew composition to within the minimum requirements.

e. Higher grade licensed operators may take the place of lower grade licensed or unlicensed personnel.

f. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

h. The operations manager or assistant operations manager shall hold a Senior Reactor Operator License. i. When the unit is in an operational mode other than Cold Shutdown or Refueling, an individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operations of the unit. This individual shall meet the qualifications specified by ANSI/ANS 3.1-1993 as endorsed by R.G. 1.8, Rev 3, 2000. Basis Letter No. 2.17.004 Page 6 of 18 following conditions are met: 1) No fuel movements are in progress;

2) No movement of loads over fuel are in progress; and 3) No unmanned shift positions during shift turnover shall be permitted while the shift crew is less than the minimum. e. Deleted f. An individual qualified in radiation protection procedures shall be on site during fuel handling operations and during movement of heavy loads over the fuel storage racks. The position may be vacant for not more than 2 'hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

h. The control room supervisor shall be a CERTIFIED FUEL HANDLER. i. Deleted As discussed above, the change from "unit" to "facility

in the title of this section is administrative.

TS 5.2.2.a -This TS stipulates when non-licensed operators must be onsite or assigned to the operating shift, based on status of fuel in the reactor or operational mode. Since this will never occur again at PNPS once the certifications required by 1 O CFR 50.82(a)(1) are docketed, the minimum requirement is changed to a minimum crew compliment of one control room supervisor and one Non-Certified Operator.

This reflects the reduced number of systems, compared to an ooeratinq reactor, required to provide and suooort scent fuel pool cooling and Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 7of18 monitor spent fuel pool parameters, such as spent fuel pool level and temperature, while still maintaining the ability to ensure spent fuel handling operations are carried out in a safe manner. Moreover, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for safety will be greatly reduced from that at an operating plant. The control room supervisor will be qualified as a Certified Fuel Handler in accordance with revised TS 5.2.2.h. In this position, this individual will retain command and control responsibility for operational decisions and will be responsible for the functions required for event reporting and emergency response.

TS 5.2.2.b -This TS stipulates the conditions and modes in which licensed operators must be present in the control room.

will not be required to have operators licensed pursuant to 10 CFR Part 55 once the certifications of 10 CFR 50.82(a)(1) have been docketed.

As a result, TS 5.2.2.b will not apply. This TS is changed to reflect the requirement for having one qualified watch stander (either a Non-Certified Operator or Certified Fuel Handler) in the control room when fuel is stored in the spent fuel pool. This reflects the reduced requirement for control room personnel training and qualification for a plant authorized for nuclear fuel storage only. PNPS submitted a Certified Fuel Handler Training and Retraining Program for NRC approval in Reference 2.(The training and qualification for the Non-Certified Operator will be determined in accordance with the systems approach to training (SAT) as defined in 10 CFR 55.4. This process ensures that the Non-Certified Operator will be qualified to perform the functions necessary to monitor and ensure safe storage of fuel. The SAT process requires: ( 1) systematic analysis of the jobs to be performed; (2) learning objectives derived from the analysis which describe desired performance after training; (3) training design and implementation based on the learning objectives; (4) evaluation of trainee mastery of the objectives during training; and (5) evaluation and revision of the training based on the performance of trained personnel in the job setting. There will be a sufficient number of individuals qualified as Certified Fuel Handlers to staff the plant twenty-four hours a day, seven days a week. Additional on-shift staffing will be provided to satisfy applicable security, protection, and emergency preparedness requirements.

The control room will remain the physical center of the cor:nmand function.

However, since control of activities may be performed either remotely from the control room or locally in the facility, the location of the command center is functionally where the control room supervisor is located in accordance with proposed TS 5.1.2. Activities that could be performed from the control room that have the potential to affect forced cooling of spent nuclear fuel include starting and stopping cooling water pumps, as well as changing the electrical power distribution system alignment.

All spent fuel handling activities are performed locally at the spent fuel pool. Indications and/or alarms are also received in the control room that would be indicative of spent fuel pool abnormalities.

The control room supervisor is responsible for directing response to those abnormalities, from either the control room or local to the spent fuel pool in accordance with applicable response procedures.

For any conditions, incidents, or events that occur when the Non-Certified Operator is in the control room alone and are not within the scope of qualifications that are possessed by the Non-Certified Operator, the control room supervisor will be immediately contacted for direction by phone, radio, and/or plant page system. This philosophy is deemed acceptable because the necessity to render immediate actions to protect the health and safety of the public is not challenged.

Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 8 of 18 TS 5.2.2.c -This TS stipulates additional conditions and modes in which licensed operators must be present in the control room. As stated above, PNPS will not be required to have operators licensed pursuant to 1 O CFR Part 55 once the certifications of 10 CFR 50.82(a)(1) have been docketed.

As a result, TS 5.2.2.c will not apply. This TS is changed to establish the requirement for having oversight of fuel handling operations performed by a Certified Fuel Handler. This new requirement ensures that movement of irradiated fuel is only performed under the oversight of an individual who has been trained and qualified on the procedures, processes, requirements and standards for safe movement of irradiated fuel. Oversight of fuel handling operations refers to the authorization from the control room supervisor/Certified Fuel Handler to move fuel, because proposed TS 5.2.2.h requires the control room supervisor to be a Certified Fuel Handler. TS 5.2.2.d -This TS addresses the conditions under which the minimum shift compliment may be reduced. It allows for shift crew composition to be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and TS 5.2.2.a and TS 5.2.2.i for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members, provided immediate action is taken to restore the shift crew composition to within the minimum requirements The reference to 10 CFR 50.54(m)(2)(i) is removed, because PNPS will not return to operation once the certifications required by 10 CFR 50.82(a)(1) are docketed, and the requirement for licensed operating personnel will no longer be required to protect public health and safety. No exemption from 10 CFR 50.54(m)(2)(i) is needed or requested to support this change, based on the NRC's response to a similar request from Vermont Yankee Nuclear Power Station (VYNPS) in June 2014 (Reference 3). PNPS proposes to remove the reference to TS 5.2.2.i to be consistent with the proposed change to delete that TS. TS 5.2.2.e -This TS allows for higher grade licensed operators to take the place of lower grade personnel.

As discussed above, licensed operators will not be required in the permanently defueled condition; therefore, this TS is proposed to be deleted. TS 5.2.2.f -This TS establishes the requirement for a person qualified in radiation protection procedures to be onsite when fuel is in the reactor. This TS also allows for the position to be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

PNPS proposes to revise the condition of this TS so that an individual qualified in radiation protection procedures is present onsite during the movement of fuel and during the movement of loads over fuel, because fuel will not be able to be placed or stored in the reactor vessel once the certifications required by 10 CFR 50.82(a)(1) are docketed.

TS 5.2.2.h -This TS establishes the requirement for the operations manager, or an assistant operations manager, to hold a Senior Reactor Operator (SRO) license. PNPS proposes to revise this TS to replace the requirement with a requirement that the control room supervisor be a Certified Fuel Handler. Once the certifications required by 10 CFR 50.82(a)(1) have been docketed, the requirements of 10 CFR 50.54(m) will no longer be a licable because the PNPS 1 O CFR Part 50 license will no Ion er authorize o eration of the Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 9of18 reactor or emplacement or retention of fuel in the reactor vessel. These certifications also obviate the need for the operators' licenses specified in 10 CFR Part 55. Therefore, there is no longer a need for operations management staff to hold a SRO license. Replacing this with a requirement that the control room supervisor be a Certified Fuel Handler ensures that the senior individual on shift is appropriately trained and qualified in accordance with the NRG-approved Certified Fuel Handler Training and Retraining Program, to supervise shift activities.

As discussed above, no exemption from 1 O CFR 50.54(m) is needed or requested to support this change. The PNPS management structure will not require positions above the control room supervisor to be a Certified Fuel Handler or attend equivalent training.

PNPS has determined that once the plant is permanently shutdown and defueled, the time available to mitigate credible events is expected to be greater than that for current design basis events. As such, management oversight of the facility can be performed by individuals meeting the applicable requirements of American National Standards Institute (ANSI) I American Nuclear Society (ANS) 3.1-1978 (as required by TS 5.3.1) and need not be qualified as Certified Fuel Handlers.

TS 5.2.2.i -This TS establishes the requirements for a technical advisor position.

PNPS proposes to delete this TS, because this position is only required for a plant authorized for power operations.

Once the certifications required by 10 CFR 50.82(a)(1) have been docketed, the requirements of this TS will no longer be applicable because the PNPS 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. 5.3 Unit Staff Qualifications Current TS 5.3. Unit Staff Qualifications Proposed TS 5.3, Facility Staff Qualifications

1. Each member of the unit staff shall meet 1. Each member of the facility staff shall or exceed the minimum qualifications of meet or exceed the minimum ANSI/ANS 3.1-1978 for comparable of ANSI/ANS 3.1-1978 for positions with exceptions specified in comparable positions with exceptions the Entergy Quality Assurance Program specified in the Quality Assurance Manual (QAPM). Program Manual (QAPM). 2. For the purpose of 10 CFR 55.4, a 2. An:NRC approved training and licensed Senior Reactor Operator, retraining program for CERTIFIED (SRO) and a Licensed Reactor Operator FUEL HANDLERs shall be maintained. (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

Basis As discussed above, the change from "unit" to "facility" in the title of this section is administrative.

Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 10 of 18 TS 5.3.1 -This TS specifies the minimum qualifications for the PNPS staff. The change from "unit" to "facility" in this TS is an administrative change. In addition, PNPS proposes to revise the title of the QAPM by removing specific reference to the Entergy corporate QAPM. This change will allow PNPS to transition from the Entergy corporate QAPM to a site-specific QAPM during the decommissioning process. No change to the qualification standards or exceptions to the standards are proposed.

Accordingly, this change is administrative only. TS 5.3.2 -This TS defines SROs and ROs as the individuals who perform the functions defined in 10 CFR 50.54(m).

PNPS proposes to delete this TS, because neither 10 CFR 50.54(m) nor the requirement for licensed operators per 10 CFR 55 apply following submittal of the certifications required by 10 CFR 50.82(a)(1

). As discussed above, no exemption from 10 CFR 50.54(m) is needed or requested to support this change. PNPS proposes to add a New TS 5.3.2 to require that an NRC approved training and retraining program for the Certified Fuel Handlers shall be maintained.

The Certified Fuel Handler Training and Retraining Program ensures that the qualifications of Certified Fuel Handlers are commensurate with the tasks to be performed and the conditions requiring response.

1 O CFR 50.120, "Training and qualification of nuclear power plant personnel," requires training programs to be derived using a SAT as defined in 10 CFR 55.4. Although the requirements of 1 O CFR 50.120 apply to holders of an operating license issued under 10 CFR Part 50, and the PNPS license will no longer authorize operation following docketing of the certifications required by 10 CFR 50.82(a)(1

), the Certified Fuel Handler Training and Retraining Program nonetheless aligns with those requirements.

The Certified Fuel Handler Training and Retraining Program provides adequate confidence that appropriate SAT based training of personnel who will perform the duties of a Certified Fuel Handler is conducted to ensure the facility is maintained in a safe and stable condition.

• 5.4 Procedures Current TS 5.4.1 Proposed TS 5.4.1 Written procedures shall be established, Written procedures shall be established, implemented, and maintained .covering the implemented, and maintained covering the following activities:

following activities:

a. The applicable procedures

a. The procedures applicable to the safe recommended in Regulatory Guide storage of nuclear fuel recommended in 1.33, Revision 2, Appendix A, February Regulatory Guide 1.33, Revision 2, 1978; Appendix A, February 1978; b. The emergency operating procedures

b. Deleted required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33; Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Basis Letter No. 2.17. 004 Page 11 of 18 This TS provides a description and requirements regarding administration of written procedures.

TS 5.4 will remain applicable with the reactor permanently defueled.

As such, it is retained and revised to reflect a permanently defueled condition.

Relevant procedures drawings and instructions will continue to be controlled per 10 CFR 50, Appendix B, Criterion VI, "Document Control." Activities involving security and emergency planning and preparedness will continue to be controlled by procedure

.. TS 5.4.1.a -PNPS proposes to revise the applicability for this TS to procedures applicable to the safe storage of nuclear fuel in Regulatory Guide 1.33, Revision 2, Appendix A. Since operating and refueling the reactor will both be prohibited by the 10 CFR Part 50 license once the certifications required by 10 CFR 50.82(a)(1) have been docketed, procedures associated with these activities will no longer need to be maintained.

Procedures governing fuel handling operations will provide the guidance necessary to ensure safe handling of spent fuel in the spent fuel pool and transfer from the spent fuel pool to dry fuel storage casks. Procedures governing responses to fuel handling accidents, personnel injuries, spent fuel pool events and external events provide the necessary guidance to mitigate the consequences of such events. No change to PNPS' actions in response to a fuel handling accident is proposed.

TS 5.4.1.b -This TS requires emergency operating procedures that implement the requirements ofNUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33. This TS is proposed to be deleted as Generic Letter 82-33 was only addressed to licensees of operating reactors, applicants for operating licenses, and holders of construction permits, none of which will apply to PNPS in the permanently defueled condition.

As discussed above, procedures governing the,site response to accidents, events and injuries will provide the necessary guidance to mitigate the consequences of such events. There are no changes proposed to TS 5.4.1.c through e. 5.5 Programs and Manuals The following programs shall be established, The following programs shall be established, implemented and maintained.

implemented and maintained.

Current TS 5.5.2 -Prima!Y Coolant Sources Proposed TS 5.5.2 Outside Containment Deleted This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable.

The systems include the Core Spray (CS), High Pressure Coolant Injection (HPCI), Residual Heat Removal (RHR), Reactor Core Isolation Cooling (RCIC), Reactor Water Cleanup (RWCU)[Let Down portion], Radwaste Collection Svstem from Reactor Buildino, Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station sampling system (From Recirc and RWCU), and Standby Gas Treatment (SGTS). The program shall include the following:

a. b. Basis Preventive maintenance; and Periodic visual inspection to identify and estimate leakage. Letter No. 2.17.004 Page 12of18 TS 5.5, Program and Manuals, provides a description and requirements regarding programs and manuals that are to be established, implemented, and maintained.

TS 5.5 will remain applicable with the reactor permanently defueled.

As such, it is retained and revised to reflect a permanently defueled condition.

TS 5.5.2 -Primary Coolant Sources Outside Containment

-This program was established to minimize leakage from portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident.

PNPS proposes to delete this program, because these conditions can no longer exist for a permanently defueled facility.

5.6 Reporting Requirements The following reports shall be submitted in The following reports shall be submitted in accordance with 10 CFR 50.4. accordance with 10 CFR 50.4. Current TS 5.6.2 -Annual Radiological Current TS 5.6.2 -Annual Radiological Environmental Operating Report Environmental Operating Report The Annual Radiological Environmental The Annual Radiological Environmental Operating Report covering the Operating Report covering the operation of the unit during the previous operation of the facility during the previous calendar year shall be submitted by calendar year shall be submitted by May 15 of each year ... May 15 of each year ... Current TS 5.6.3 -Radioactive Effluent Proposed TS 5.6.3 -Radioactive Effluent Release Report Release Report The Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit shall be covering the operation of the facility shall be submitted in accordance with 10 CFR 50.36a submitted in accordance with 10 CFR 50.36a by May 15th of each year. The report shall by May 15th of each year. The report shall include a summary of the quantities of include a summary of the quantities of radioactive liquid and gaseous effluents and radioactive liquid and gaseous effluents and solid waste released from the unit. The material solid waste released from the facility.

The provided shall be consistent with the objectives material provided shall be consistent with the outlined in the ODCM and process control objectives outlined in the ODCM and process procedures and in conformance with control procedures and in conformance with Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.I. Basis Letter No. 2.17.004 Page 13of18 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.I. TS 5.6.2 -Annual Radiological Environmental Operating Report -PNPS proposes to change the term "unit" to "facility" in this TS. This is an administrative change. TS 5.6.3 -Radioactive Effluent Release Report -PNPS proposes to change the term "unit" to "facility" in this TS. This is an administrative change. . 5. 7 High Radiation Area Current TS 5. 7.1 ... Individuals qualified in radiation protection procedures (e.g., radiation protection personnel) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates s 1000 mrem/hr, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas. Current TS 5.7.2 In addition to the requirements of Specification

5. 7 .1, areas with radiation levels 2: 1000 mrem/hr shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the SRO on duty or radiation protection supervision

... Basis Proposed TS 5. 7.1 ... Individuals qualified in radiation protection procedures (e.g., radiation protection personnel) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the

• performance of their assigned duties in high radiation areas with exposure rates s 1000 mrem/hr, provided they are otherwise following facility radiation protection procedures for entry into such high radiation areas. Proposed TS 5.7.2 In addition to the requirements of Specification

5. 7.1, areas with radiation levels 2: 1000 mrem/hr shall be provided with locked or continuously guarded doors .. to prevent unauthorized entry and the keys shall be maintained under the administrative control of the control room supervisor on duty or radiation protection supervision

... TS 5. 7 .1 -PNPS proposes to replace the term "plant" with the term "facility." As previously discussed, the term "facility" better represents a site undergoing decommissioning.

This is an administrative change. TS 5. 7.2 -PNPS proposes to replace the reference to the "SRO" with a reference to "control room supervisor." Once the certifications required by 10 CFR 50.82(a)(1) have been docketed, the PNPS 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. These certifications also obviate the need for the operators' licenses specified in 10 CFR Part 55. Therefore, there is no lonqer a need for * ..

Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 14of18 SROs. Replacing the SRO with a control room supervisor will continue to ensure that the senior individual on shift remains in control. The control room supervisor will be trained and qualified in accordance with the NRG-approved Certified Fuel Handler Training and Retraining Program. 3. REGULATORY EVALUATION 3.1 APPLICABLE REGULATORY REQUIREMENT/CRITERIA 10 CFR 50.82(a)(1) requires that when a licensee has determined to permanently cease operations the licensee shall, within 30 days, submit a written certification to the NRC, consistent with the requirements of 10 CFR 50.4(b)(8), and once fuel has been permanently removed from the reactor vessel, the licensee shall submit a written certification to the NRC that meets the requirements of 10 CFR 50.4(b )(9). On November 10, 2015, ENO notified the NRC that PNPS would permanently cease operations no later than June 1, 2019 (Reference 1 ). ENO recognizes that approval of these proposed changes is contingent upon the submittal of the certifications required by 10 CFR 50.82(a)(1

). 1 O CFR 50.82(a)(2) states: "Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuet from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel." '-1 10 CFR 50.36'establishes the requirements for TS. 10 CFR 50.36( c)(5), Administrative Controls, identifies that an Administrative Controls section shall t>e ineluded in the TS and shall include provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. This license amendment request .is proposing changes to the Administrative Controls section, with conforming changes proposed to additional sections; consistent with the pending decommissioning status of the plant. This request appli_es the principles identified in 10 CFR 50.36(c)(6), Decommissioning, for a facility which has submitted certifications required by 50.82(a)(1) and* proposes changes to the Administrative Controls appropriate for the PNPS permanently defueled condition.

As 10 CFR 50.36(c)(6) states, this type of change should be considered on a case-by-case basis. 10 CFR 50.54(m) establishes the requirements for having Reactor Operators and SROs licensed in accordance with 10 CFR Part 55 based on plant conditions.

Given the impending permanent cessation of operation for PNPS, the requirements of this section will no longer apply once the certifications required by 10 CFR 50.82(a)(1) have been docketed and it will be permissible to remove those positions from the TS. 3.2 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Pursuant to 1 O CFR 50.92, ENO has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration since the proposed changes satisfy the criteria in 1 OCFR50.92(c).

These criteria require that operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or conse_quences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously eva!uated; or (3) involve a significant reduction in a margin of safety.

• Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 15 of 18 The proposed changes would revise and remove certain requirements contained within Sections 1.0 (Definitions), 4.0 (Design Features) and 5.0 (Administrative Controls) of the PNPS TS. The TS requirements being changed would not be applicable until the certifications required by 10 CFR 50.82(a)(1) have been docketed and the Certified Fuel Handler Training and Retraining Program is approved by the NRC. Once the certifications for permanent cessation of operations and permanent fuel removal are made, the 10 CFR Part 50 license for PNPS will no longer authorize operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

• The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard. 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No. The proposed amendment would not take effect until PNPS has permanently ceased operation and entered a permanently defueled condition and the Certified Fuel Handler Training and Retraining Program is approved by the NRC. The proposed amendment would modify the PNPS TS by deleting the portions of the TS that are no longer applicable to a permanently defueled facility, while modifying the other sections to correspond to the permanently defueled condition.

The deletion and modification of provisions of the administrative controls do not directly affect the design of structures, systems, and components (SSCs) necessary for safe storage of irradiated fuel or the methods used for handling and storage of such fuel in the spent fuel pool. The changes to the administrative controls are administrative in nature and do not affect any accidents applicable to the safe management of irradiated fuel or the permanently shutdown and defueled condition of the reactor. Thus, the consequences of an accident previously evaluated are not increased.

In a permanently defueled condition, the only credible accidents are the fuel . handling accident (FHA) and those involving radioactive waste systems remaining in service. The probability of occurrence of previously evaluated accidents is not increased, because extended operation in a defueled condition will be the only operation allowed. This mode of operation is bounded by the existing analyses.

Additionally, the occurrence of postulated accidents associated with reactor operation is no longer credible in a permanently defueled reactor. This significantly reduces the scope of applicable accidents.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

' Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 16of18 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No. The proposed changes have no impact on facility SSCs affecting the safe storage of irradiated fuel, or on the methods of operation of such SSCs, or on the handling and storage of irradiated fuel itself. The administrative removal or modifications of the TS that are related only to administration of the facility cannot result in different or more adverse failure modes or accidents than previously evaluated because the reactor will be permanently shutdown and defueled and PNPS will no longer be authorized to operate the reactor or retain or place fuel in the reactor vessel. The proposed changes to the PNPS TS do not affect systems credited in the accident analysis for the FHA or radioactive waste system upsets at PNPS. The proposed TS will continue to require proper control and monitoring of safety significant parameters and activities.

The proposed amendment does not result in any new mechanisms that could initiate damage to the remaining relevant safety barriers for defueled plants (fuel cladding and spent fuel cooling).

Extended operation in a defueled condition will be the only operation allowed, and it is bounded by the existing analyses, such a condition does not create the possibility of a new or different kind of accident.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

• Response:

No. Since the 1 O CFR Part 50 license for PNPS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel once the certifications required by 10 CFR 50.82(a)(1) are docketed, as specified in 10 CFR 50.82(a)(2), the occurrence of postulated accidents associated with reactor operation is no longer credible.

The only remaining credible accidents are a FHA and those involving radioactive waste systems remaining in service. The proposed amendment does not adversely affect the inputs or assumptions of any of the design basis analyses that impact these analyzed conditions.

The proposed changes are limited to those portions of the TS that are not related to the safe storage of irradiated fuel. The requirements that are proposed to be revised or deleted from the PNPS TS are not credited in the existing accident analysis for the remaining applicable postulated accident; and as such, do not contribute to the margin of safety associated with the accident analysis.

Postulated design basis accidents involving the reactor are no longer possible because the reactor will be permanently shutdown Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.17.004 Page 17of18 and defueled and PNPS will no longer be authorized to operate the reactor or retain or place fuel in the reactor vessel. Therefore, the proposed change does not involve a significant reduction in the margin of safety. Based on the above, ENO concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.3 PRECEDENT The proposed changes are based on the TS Administrative Controls for VYNPS, which were issued on December 22, 2014 (Reference 4). The VYNPS TS were subsequently revised to reflect the permanently defueled condition on October 7, 2015 (Reference 5). In addition, the proposed changes include additional changes that resolve NRC Requests for Additional Information as identified in the license amendment request submitted for the James A Fitzpatrick Nuclear Power Plant, including supplements (References 6 through 8).

3.4 CONCLUSION

Based on the considerations discussed above, ( 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.

• 4. ENVIRONMENTAL CONSIDERATIONS This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as'follows: (i) The amendment involves no significant hazards consideration.

As described in Section 3.2 of this evaluation, the proposed change involves no significant hazards consideration. (ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed amendment does not involve any physical alterations to the facility configuration that could lead to a change in the type or amount of effluent release offsite. (iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, ENO concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

---. -; _,,_. -'.-**

Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 5. REFERENCES Letter No. 2.17.004 Page 18of18 1. Letter, Entergy Nuclear Operations, Inc., to NRC, "Notification of Permanent Cessation of Power Operations," dated November 10, 2015 (Letter Number: 2.15.080) (ML 15328A053)

2. Letter, Entergy Nuclear Operations, Inc., to NRC, "Request for Approval of Certified Fuel Handler Training and Retraining Program," dated February 2, 2017 (Letter Number: 2.17.001)

3. Letter, NRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station -Request for Exemption from the Requirements of 10 CFR 50.54(m) (TAC No. MF2990)," dated June 18, 2014(ML14147A216)

4. Letter, NRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station -Issuance of Amendment to Renewed Facility Operating License RE: Changes to the Administrative Controls Section of the Technical Specifications (TAC No. MF2991)," dated December 22, 2014(ML14217A072)

5. Letter, NRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station -Issuance of Amendment for Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition (CAC No. MF3714)," dated October 7, 2015 (ML 15117 A551) 6. Letter, NRC to Entergy Nuclear Operations, Inc, "License Amendment Request -Revision to Technical Specification Administrative Controls for Permanently Defueled Condition," James A. FitzPatrick Nuclear Power Plant, dated January 15, 2016 (ML 16015A456) . 7. Letter, NRC to Entergy Nuclear Operations, Inc, "Response to Request for Additional Information (RAI) Regarding Revision to Technical Specification (TS) Administrative Controls for Staffing and Training Upon Permanent Cessation of Operation (CAC No. MF7280) -Supplement 1," James A. FitzPatrick Nuclear Power Plant, dated June 3, 2016(ML16155A326)

8. Letter, NRC to Entergy Nuclear Operations, Inc, "Revision to Technical Specification (TS) Administrative Controls for Staffing and Training Upon Permanent Cessation of Operation (CAC No. MF7280)-Supplement 2 James A. FitzPatrick Nuclear Power Plant," dated September 19, 2016(ML16263A237)

• Attachment 2 Letter Number 2.17.004 I Pilgrim Nuclear Power Station Markup of the Current Technical Specifications Pages \

TABLE OF CONTENTS LIMITING CONDITIONS FOR OPERATION 3.12 Fl RE PROTECTION Alternate Shutdown Panels BASES 3.13 INSERVICE CODE TESTING A. lnservice Code Testing of Pumps and Valves BASES 3.14 SPECIAL OPERATIONS A. lnservice Hydrostatic and Leak Testing Operation B. (Not Used) C. Single Control Rod Withdrawal

-Hot Shutdown D. Single Control Rod Withdrawal

-Cold Shutdown E. Multiple Control Rod Removal F. (Not Used) G. Control Rod Testing -Operating BASES 4.0 4.1 4.2 4.3 4.3.1 4.3.2 4.3.3 4.3.4 DESIGN FEATURES Site Location I Aeaetof-Gef:e Deleted Fuel Storage Criticality Drainage Capacity Heavy Loads 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.2 Organization 5.3

• Staff Qualifications 5.4 Procedures 5.5 Programs and Manuals 5.6 Reporting Requirements

5. 7 High Radiation Area Facility Amendment No. 179, 187, 211, 221, 228;-23-1-iii SURVEILLANCE REQUIREMENTS 4.12 4.13 4.14 A. B. c. D. E. F. G. 3/4.12-1 3/4.12-1 83/4.12-1 3/4.13-1 3/4.13-1 83/4.13-1 3/4.14-1 3/4.14-1 3/4.14-3 3/4.14-4 3/4.14-6 3/4.14-8 3/4.14-9 3/4.14-10 83/4.14-1 4.0-1 4.0-1 4.0-1 4.0-1 4.0-1 4.0-2 4.0-2 4.0-2 5.0-1 5.0-1 5.0-2 5.0-4 5.0-5 5.0-6 5.0-12 5.0-15

""' -.. A CERTIFIED FUEL HANDLER is an individual who DEFINITIONS

-complies with the provisions of the CERTIFIED FUEL ... 1=*0========4===1 HANDLER Training and Retraining Program. The succeeding frequently l sed terms are explicitly defined so that a uniform interpretation of the spec ific ations may be achieved.

ACTION AUTOMATIC PRIMARY CONTAINMENT ISOLATION VALVES LO CONDITION ORE ALTERATION CERTIFIED FUEL HANDLER CORE OPERATING LIMITS REPORT (COLA) DE S IGN POWER FIRE SUPPRESSION WATER SYSTEM HOT STANDBY CONDITION IMMEDIATE PNPS ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

Are primary containment isolation valves which receive an automatic primary containment group isolation signal. 'V Reactor coolant t emperature equal to or less than 212°F. CORE ALTERATION shall be th e movement of any fuel , sources , or reactiv i ty control components , within the reactor vessel with the vesse l head removed and fuel in the vess el. T he following exceptions are not considered to be CORE ALTERATIONS:

a. Movement of source range monitors, loca l power range mon it o r s , in termediate range monitors, traversing inco re probes , or special movable detectors (including undervessel replacement);

and b. Cont ro l rod movement , provided th e re are no fuel assemblies l n the associated core cell. Suspension of CORE ALTERATIONS shall not preclude completion of ', 1ovement of a component to a sa fe position.

The COLR is a r eload-cycle spec ifi c document th at provides core oper at i ng limits f or t he current operating reload cycle. These cycle specific core operating limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these operating limits is addressed in individual specif ic ations. DESIGN POWER means a s teady state power level of 2028 thermal megawatts.

A FIRE SUPPRESSION WATER SYSTEM shall consist of: a water source(s); gravity tank(s) or pump(s); and distribution piping with associated sectionalizing control o r isolation valves. Such valves shall include hydrant post indicator valves and the first valve ahead of the water flow alarm device on each sprinkler, hose standp ipe or spray system riser. HOT STANDBY CONDITION means operation with coolant temperature greater than 212°F, system p r essure less than 600 psig , the main steam i solation valves closed and the mode switch in startup. IMMEDlATE means that the required action will be init i ated as soon as practicable considering the sate operation of t he unit and t he importance of the required action . 1-1 Amendment No. +7+, -2G4-A NON-CERTIFIED OPERATOR is a non-licensed operator who 1.0 DEFINITIONS (Cont) complies with the qualification requirements of Specification 5.3.1 , --------'------'

.__---t but is not a CERTIFIED FUEL HANDLER. OPERABILITY NON-CERT I Fl ED OPERATOR OPERAT I NG OPERATING CYCLE PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) PRIMARY CONTAINMENT INTEGRITY A system, su sys em, 1v1s1on, component, or evrce s a e OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

OPERATING means that a system or component is performing its intended functions in its required manner. Interval between the end of one refueling outage and the end of the next subsequent refueling outage. The PTLR is the Pilgrim-Specific document that provides the reactor vessel Pressure-Temperature (P-T) Curves, including heat up and cool down rates and fluence and Adjusted Reference Temperature limits for Specification 3.6.A. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.5.9. PRIMARY CONTAINMENT INTEGRITY means that the drywell and pressure suppression chamber are intact and all of the following conditions are satisfied:

1. All manual containment isolation valves on lines connected to the reactor coolant system or containment which are not required to be open during accident conditions are closed. 2. At l east one door in each airlock is closed and sealed 3. All blind flanges and manways are closed. 4. All automatic primary containment isolation valves and all instrument line check valves are operable or at least one containment isolation valve in each line having an inoperable valve shall be deactivated in the isolated condition.

5. All containment isolation check valves are operable or at least one containment valve in each line having an inoperable valve is secured in the isolated position.

PROTECTIVE ACTION An action initiated by the protection system when a limit is reached. A PROTECTIVE ACTION can be at a channel or system level. PROTECTIVE FUNCTION A system PROTECTIVE ACTION which results from the PROTECTIVE ACTION of the channels monitoring a particular plant condition.

PNPS 1-4 Amendment No. +77, 2a4

.. -4.0 4.1 DESIGN FEATURES Site Location Design Features 40 Pilgrim Nuclear Power Station is located on the western shore of Cape Cod Bay in the Town of Plymouth , Plymouth County, Massachusetts and contains approximately 517 acres owned by Entergy Nuclear as shown on FSAR Figures 2.2-1 and 2 2-2. The site boundary is posted and a perimeter security fence provides a distinct security boundary for the protected area of the station. The rea ctor (center line) is loca ted approximately 1800 feet from the nearest property boundary. 4.2 Rea*tor GeFe ::i:R.e reactof '.<cssel core design shall be as described in the GORE LIM I TS REPORT and shall be limited to t-hose fuel asseR1b li es which have been analyzed with NRG appreved cedes snd ana appre't'ed by the NRG in i ts acceptance of Amendment 22 ef G E STA R IL 4.3 Fuel Storage 4. 3.1 Criticality 4.3 1.1 PNPS The spent fuel storage racks are designed and shall be maintai'led with a. Fuel assemblies having a maximum k-infinity of 1.32 for standard core geometry, calculated at the bumup of maximum bundle reactivity, and an average U-235 enrichment of 4.6 % averaged over the axial planar zone of highest average enrichment; and b 'r<.., 11 s 0.95 if fully flooded with unborated water. which includes an al1owance for uncertainties as described in Section 10.3.5 of the FSAR. 4.0-1 (continued)

Amendment No.-477, f&1. I Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 5.1.2 Th e plant manager shall be r espons ible for overall

• operation and shall del ega te in writing th e succession to this responsibility during his absence. The plant manager or h i s designee shall approve, prior t o i mplementation , each proposed test, experiment, or modification to systems or equipment that affect nuclear safety. The control ro o m supervisor (CRS) shall be responsibl e for the oontFOI room command function.

During any absence of the GRS from the oontml room while the unit is in an opeFational mode other than Gold Shutdown or Refueling , an individual with an active Senior Reaetor Operator (SRO) lieense shall be designated to assume the oontrol room command funotion. During any absonoe of the GAS from the control room wfffie the unit is in Gold Shutdown or Refueling , an individual with an active SRO lioense or Reactor Operator (RO) liecnse shall be des i gnated to assume the oontrol TOom oommand funotion. Am en dm en t No . .:t-77., 5.0-1 Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 521 0 *t dOff. 0 . . . . ns1 e an site rganizat1ons

/ Onsite and offsite organizations shall be established for unit operation and corporate management, respectively.

The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions.

These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be facility documented in the Pilgrim Station Final Safety Analysis Report (FSAR); b. The plant manager shall be responsible for overall safe operation of the and shall have control over those onsite activities necessary for safe

• and maintenance of f safe management of nuclear fuel A specified corporate officer for Pilgrim shall have corporate facility responsibility for overall plant nuelear safety and shall take any measures needed to ensu acceptable performance of the st operating, maintaining, and roviding technical support to the to ensur At:f61ear safety; and the safe storage and handling of nuclear fuel The individuals who train the , carry out health physics, or perform quality assurance function may report to the appropriate onsite manager; however, these indiv duals shall have sufficient organizational freedom to ensure thei

• pressures CERTIFIED FUEL HANDLERS 5.2.2 YRit-Staff facility ability to perform their assigned functions taff organization shall include the following:

a. Each duty shift shall be composed of at least one control room supervisor and one ------------"==1 NON-CERTIFIED OPERATOR.

The NONAmendment No. +77, +8+; CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER. (continued) 5.0-2 Organization 5.2 and all of the following conditions are met: 1) No fuel movements are in progress; No movement of loads over fuel are in progress; and Facility 3) No unmanned shift positions during shift turnover shall __ ___, l:ffltt Staff (continued) be permitted while the shift crew is less than the minimum. At least one person qualified to stand watch in the control room CERTIFIED OPERA TOR or CERTIFIED FUEL HANDLER) shall be present in the Control Room when nuclear fuel is stored in the spent fuel pool. Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER. Deleted The control room supervisor shall be a CERTIFIED FUE L HANDLER. b. c. Shift crew compositi o n may be less than the minimum requ ement of 10 GFR 50.54(m)(2)(i) aAd 5.2.2.a aAd 5.2.2.i for a period o time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absen e of duty shift crew members provided immediate action is taken t restore the shift crew composition to within the minimum requirement

e. Higher grade licensed operators may talce the place of lower grade lieensed or unlicensed personnel.

An individual qualified in radiation protection procedures shall be on site . The position may be vacant for not more an 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence , provide immediate action is taken to fill the required position.

du ri ng fuel handling operations and during movement of heavy loads over the fuel storage racks. h. =Fhe-6per-ations maAager or assistant operations manager shall hold a License. i. A/hen the unit is in an operational mode other thaA Gold Shutdown or Refuelin g, an individual shall provide advisory toohnical support to the I Deleted ttnit operations shift crew in the areas of thermal hydrau l ics , reactor engineering , and plant aAalysis with regard to the safe operations of the unit. This individual shall meet the qualificatioAs specified by ANSlfMJS a.1 1993 as endorsed by RG. 1.8 , Rev a , 2000. Amendment No . .:t-77 , 5.0-3 *--* --

Procedures 5.4 -5.0 ADMINISTRAT I VE CON T ROLS 5.4 Procedures procedures applicable to the safe storage of nuclear fuel 5.4.1 Deleted PNPS Written procedures all be established, implemented , and maintained covering the folio ng activities:

The applicable procedures recommended in Regulatory Guide 1.33, Revision 2 , Appendix A, February 1978; The emergency operating procedures required to implement the requir:ements ef NUREG 0737 and NUREG 0737, Supplement t;-stateel in GeneFie Letter 82 33; c. Quality assurance for effluent and environmental monitoring;

d. Fire Protection Program implementation; and e. All programs specified in Specification 5.5. 5.0-5 Amendment No. U1 I Procedures 5.4 -5.0 .ADMINISTRATIVE CON T ROLS -5.4 Procedures procedures applicable to the safe storage of nuclear fuel 5.4.1 Deleted PNPS Written procedures all be established, imp l emented , and maintained covering the foflo ng activities

The applicable p r eeedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. February 1978; T he emergency operating procedures required to implement the r eei1:1irements of NU REG 0 737 and N U REG 0737, Supplefflsnt

+,-as s t a ted in Genelie L ette r 82 33; c. Quality assurance for effluent and environmental monitoring

d. Fire Protection Program implementation; and e. All programs specified in Specification 5.5. 5.0-5 Amendment No. l-22 I

-Pr ograms and Manuals 5.5 5.5 P rogram s and M anuals 5.5.2 Primary Cool a nt Sources Outs i de G o nta:iRffieAt provides controls to ffiiniffiiz e leakage from those portions of systems outside OOAtainment that OOl:Jld eontain highly radioastive fll:Jids dwing a serious transient or accident to l e vels as low as practicable.

The sy-stems iftefude tl'le Gore Spray (GS), High PressuFO Coolant lnjeotien (HPGI), Res i dua l Heat Aemo*val (Rl-IR), Reactor Gore Iso l ation Cooling (RGIG), R e actor 'Natef Cleanup (R'NGU)[Lct Down portion], Radwa s te Gelleetion System from Reactor system (FroFA Reeire and R)NGU), and Standby Gas Treatm e nt (SGTS). Tho program shall include the follmAAAg;-

a:-Pre*tentive maintenance; and Ir. . Periodic visual inspection to identify and estimate leakage. 5.5.3 N o t U se d 5.5.4 R ad i oactive EffltJen t C on t rols Pr ogram PNPS T h i s p r ogram conf o rms t o 1 O CFR 50.36a for t he con t ro l of r adioacti v e effl u en t s and for ma i n t aining th e doses t o members of the public f ro m r ad i oactive effluents as low as reasonably achievable.

The program shall be conta in ed i n the ODCM, shall be i mp l emented by procedures, and shall include remedial act i ons to be taken whenever the program limits are exceeded. The program shall include the following elements:

a. Limitations on t he functional capability of radioact i ve l iq u id and gaseo u s monitoring i nstrumentation i ncluding surveillance tes t s and setpo i nt determination in accordance with the methodology in t he ODCM; (continued) 5.0-7 A mendment No . ..+++, 294 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements Reporting Requirements 5.6 The following reports shall be submitted in accordance with 1 O CFR 50.4. 5.6.1 Not Used 5.6.2 Annual Radiolo i The Annual Ra

• logical Environmental Operating Report covering the operation of the ttRtt during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consisten t with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50 , Appendix I, Sections IV.8.2, IV.8.3, and IV.C. The Annual Radiological Environmental Operating Report shall include a summary of the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch T echnical Position, Revision 1, November 1979. In the event that some individu al results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary r eport as soon as possible. (Continued)

Amendment No. +s+, 2+2 ,-2&1 5.0-12 Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 5.6.4 5.6.5 Radioactive Effluent Release Report facility The Radioactive Effluent Release Report covering the eration of the l::fM shall be submitted in accordance with 1 O CFR 50.36a by M 15th of each year. The report shall include a summary of the quantities of ra oactive liquid and gaseous effluents and solid waste released from the * . The material provided shall be consistent with the objectives outlined in the ODCM and process control procedures and in conformance with 1 O CFR 50.36a and 1 O CFR 50, Appendix I,Section IV.B.1. Not Used Core Operating Limits Report (COLA) a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLA for the following:

1. Table 3.1.1 -APRM High Flux trip l evel setting 2. Table 3.2.C-APRM Upscale trip level setting 3. 3.11.A -Average Planar Linear Heat Generation Rate (APLHGR) 4. 3.11.B -Linear Heat Generation Rate (LHGR) 5. 3.11.C -Minimum Critical Power Ratio (MCPR) 6. 3.11.D -Power/Flow Relationship During Power Operation

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," (through the latest NRC approved amendment at the time the reload analyses are performed as specified in the COLA). (Continued)

Amendment No. 187, 181, 212, 231 5.0-13 5.0 ADMINISTRATIVE CONTROLS 5. 7 High Radiation Area High Radiation Area 5.7 5. 7.1 Pursuant to 10 CFR 20, paragraph 20.1601 (c), in lieu of the requirements of 1 O CFR 20.1601, each high radiation area, as defined in 1 O CFR 20, in which the intensity of radiation is > 100 mrem/hr but < 1000 mrem/hr, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified-in radiation protection procedures (e.g., radiation protection personnel) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates 1000 mrem/hr, provided they are otherwise following protection procedures for entry into such high radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area. b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.

Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them. c. An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the radiation protection manager in the RWP. 5.7.2 In addition to th e requirements of Specification 5.7.1, areas with radiation levels :2: 1000 mrem/hr shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the SRe on duty or radiation protection supervision.

Doors shall remain locked ex pt during periods of access by personnel under an approved RWP that shall s ecify the dose rate levels in the immediate work areas and the maximum allo ble stay times for individuals in those areas. In lieu of the stay time specificat on of the RWP, direct or remote (such as closed circuit TV cameras) continua s surveillance may be made by control room supervisor (Continued)

Amendment No. +87, 223 , 231 5.0-15 Attachment 3 Letter Number 2.17.004 Pilgrim Nuclear Power Station Retyped Technical Specifications Pages TABLE OF CONTENTS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.12 FIRE PROTECTION 4.12 3/4.12-1 Alternate Shutdown Panels 3/4.12-1 BASES B3/4.12-1 3.13 INSERVICE CODE TESTING 4.13 3/4.13-1 A. lnservice Code Iesting of Pumps and 3/4.13-1 Valves BASES B3/4:13-1 3.14 SPECIAL OPERATIONS 4.14 3/4/14-1 A. lnservice Hydrostatic and A. 3/4.14-1 Leak Testing Operation B. (Not Used) B. 3/4.14-3 C. Single Control Rod Withdrawal

-Hot C. 3/4.14-4 Shutdown D. Single Control Rod Withdrawal

-Cold D. 3/4.14-6 Shutdown E. Multiple Control Rod Removal E. 3/4.14-8 F. (Not Used) F. 3/4.14-9 G. Control Rod Testing -Operating G. 3/4.14-10 BASES B3/4.14-1 4.0 DESIGN FEATURES 4.0-1 4.1 Site Location 4.0-1 4.2 Deleted 4.0-1 4.3 Fuel Storage 4.0-1 4.3.1 Criticality 4.0-1 4.3.2 Drainage 4.0-2 4.3.3 Capacity 4.0-2 4.3.4 Heavy Loads 4.0-2 5.0 ADMINISTRATIVE CONTROLS 5.0-1 5.1 Responsibility 5.0-1 5.2 Organization 5.0-2 5.3 Facility Staff Qualifications 5.0-4 5.4 Procedures 5.0-5 5.5 Programs and Manuals 5.0-6 5.6 Reporting Requirements 5.0-12 5.7 High Radiation Area 5.0-15 Amendment No. 179, 187, 211, 221, 228, 2J1 iii 1.0 DEFINITIONS The succeeding frequently used terms are explicitly defined so that a uniform interpretation of the specifications may be achieved.

ACTION AUTOMATIC PRIMARY CONTAINMENT ISOLATION VALVES CERTIFIED FUEL HANDLER COLD CONDITION CORE AL TERA TION CORE OPERATING LIMITS REPORT (COLR) DESIGN POWER FIRE SUPPRESSION WATER SYSTEM HOT STANDBY CONDITION IMMEDIATE PNPS ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

Are primary containment isolation valves which receive an automatic primary containment group isolation signal. A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER Training and Retraining Program. Reactor coolant temperature equal to or less than 212°F. CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. The following exceptions are not considered to be CORE ALTERATIONS:

a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement);

and b. Control rod movement, provided there are no fuel assemblies in the associated core cell. Suspension of CORE AL TERA TIONS shall not preclude completion of movement of a component to a safe position.

The COLR is a reload-cycle specific document that provides core operating limits for the current operating reload cycle. These cycle specific core operating limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these operating limits is addressed in individual specifications.

DESIGN POWER means a steady state power level of 2028 thermal megawatts.

A FIRE SUPPRESSION WATER SYSTEM shall consist of: a water source(s);

gravity tank(s) or pump(s); and distribution piping with associated sectionalizing control or isolation valves. Such valves shall include hydrant post indicator valves and the first valve ahead of the water flow alarm device on each sprinkler, hose standpipe or spray system riser. HOT STANDBY CONDITION means operation with coolant temperature greater than 212°F, system pressure less than 600 psig, the main steam isolation valves closed and the mode switch in startup. IMMEDIATE means that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action. 1-1 Amendment No. 177, 201, 1.0 DEFINITIONS (Cont) NON-GERTI Fl ED OPERATOR OPERABILITY OPERATING OPERATING CYCLE PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) PRIMARY CONTAINMENT INTEGRITY PROTECTIVE ACTION PNPS A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER. A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

OPERA TING means that a system or component is performing its intended functions in its required manner. Interval between the end of one refueling outage and the end of the next subsequent refueling outage. The PTLR is the Pilgrim-Specific document that provides the reactor vessel Pressure-Temperature (P-T) Curves, including heat up and cool down rates and fluence and Adjusted Reference Temperature limits for Specification 3.6.A. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.5.9. PRIMARY CONTAINMENT INTEGRITY means that the drywell and pressure suppression chamber are intact and all of the following conditions are satisfied:

1. All manual containment isolation valves on lines connected to the reactor coolant system or containment which are not required to be open during accident conditions are closed. 2. At least one door in each airlock is closed and sealed 3. All blind flanges and manways are closed. 4. All automatic primary containment isolation valves and all instrument line check valves are operable or at least one containment isolation valve in each line having an inoperable valve shall be deactivated in the isolated condition.

5. All containment isolation check valves are operable or at least one containment valve in each line having an inoperable valve is secured in the isolated position.

An action initiated by the protection system when a limit is reached. A PROTECTIVE ACTION can be at a channel or system level. 1-4 Amendment No. 4+7, 234 1.0 DEFINITIONS (continued)

PROTECTIVE FUNCTION A system PROTECTIVE ACTION which results from the PROTECTIVE ACTION of the channels monitoring a particular plant condition.

REACTOR POWER REACTOR POWER OPERATION is any operation with the mode OPERATION switch in the "Startup" or "Run" position with the reactor critical and above 1 % design power. REACTOR VESSEL Unless otherwise indicated, REACTOR VESSEL PRESSURES PRESSURE listed in the Technical Specifications are those measured by the reactor vessel steam space detectors.

REFUELING INTERVAL REFUELING INTERVAL applies only to In-service Code Testing Program surveillance tests. For the purpose of designating frequency of these code tests, a REFUELING INTERVAL shall mean at least once every 24 months. REFUELING OUTAGE REFUELING OUTAGE is the period of time between the

• shutdown of the unit prior to a refueling and the startup of the plant after that refueling.

For the purpose of designating frequency of testing and surveillance, a REFUELING OUTAGE shall mean a regularly scheduled outage; however, where such outages occur within 11 months of completion of the previous REFUELING OUTAGE, the required surveillance testing need not be performed until the next regularly scheduled SAFETY LIMIT The SAFETY LIMITS are limits below which the reasonable maintenance of the cladding and primary systems are assured. Exceeding such a limit is cause for unit shutdown and review by the Nuclear Regulatory Commission before resumption of unit operation

.. Operation beyond such a limit may not in itself result in serious consequences, but it indicates an operational deficiency subject to regulatory review. SECONDARY SECONDARY CONTAINMENT INTEGRITY means that the CONTAINMENT reactor building is intact and the following conditions are met: INTEGRITY

1. At least one door in each access opening is closed. 2. The standby gas treatment system is operable.

3. All automatic ventilation system isolation valves are operable or secured in the isolated position.

SIMULATED AUTOMATIC SIMULATED AUTOMATIC ACTUATION means applying a ACTUATION simulated signal to the sensor to actuate the circuit in question . . SOURCE CHECK A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source. STAGGERED TEST A STAGGERED TEST BASIS shall consist of: (a) a test schedule BASIS for n systems, subsystems, trains, or other designated components obtained by dividing the specified test interval into n equal subintervals; (b) the testing of one system, subsystem, train or other designated components at the beginning of each subinterval.

Amendment No. 4-77, 1-5 Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location Pilgrim Nuclear Power Station is located on the western shore of Cape Cod Bay in the Town of Plymouth, Plymouth County, Massachusetts and contains approximately 517 acres owned by Entergy Nuclear as shown on FSAR Figures 2.2-1 and 2.2-2. The site boundary is posted and a perimeter security fence provides a distinct security boundary for the protected area of the station. The reactor (center line) is located approximately 1800 feet from the nearest property boundary.

4.2 Deleted 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 PNPS The spent fuel storage racks are designed and shall be maintained with: a. Fuel assemblies having a maximum k-infinity of 1.32 for standard core geometry, calculated at the burnup of maximum bundle reactivity, and an average U-235 enrichment of 4.6 % averaged over the axial planar zone of highest average enrichment; and b. Kett s 0.99 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 10.3.5 of the FSAR. (continued) 4.0-1 Amendment No. 177, 1,81, 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility Responsibility 5.1 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence. The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety. 5.1.2 The control room supervisor (CRS) shall be responsible for the shift command function.

• ' Amendment No. 177, 223, 5.0-1 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Organization 5.2 Onsite and offsite organizations shall be established for facility staff and corporate management, respectively.

The onsite and offsite organizations shall ,include the positions for activities affecting safety of the nuclear fuel. a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions.

These relationships shall be anq updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the J:?Ositions delineated in these Technical Specifications, shall be documented in the Pilgrim Station Final Safety Analysis Report (FSAR); b. The plant manager shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe storage and maintenance of the nuclear fuel; c. The specified corporate officer for Pilgrim shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure safe management of nuclear fuel; and d. The individuals who train the CERTIFIED FUEL HANDLERS, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

5.2.2 Facility Staff The facility staff organization shall include the following:

a. Each duty shift shall be composed of at least one control room supervisor and one NON-CERTIFIED OPERATOR.

The CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER. (continued)

Amendment No. 4-77, +3+, 5.0-2 -** *: ,.

5.2 Organization 5.2.2 Facility Staff (continued)

\ Organization 5.2 b. At least one person qualified to stand watch in the control room CERTIFl ED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the Control Room when nuclear fuel is stored in the spent fuel pool. c. Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER. d. Shift crew composition may be less than the minimum requirement of 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and all of the following conditions are met: 1) No fuel movements are in progress;

2) No movement of loads over fuel are in progress; and 3) No unmanned shift positions during shift turnover shall be permitted while the shift crew is less than the minimum. e. Deleted f. An individual qualified in radiation protection procedures shall be on site during fuel handling operations and during movement of heavy loads over the fuel storage racks. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

g. Deleted h. The control room supervisor shall be a CERTIFIED FUEL HANDLER. i. Deleted Amendment No. 4-77, 5.0-3 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications Facility Staff Qualifications . 5.3 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Quality Assurance Program Manual (QAPM). 5.3.2 An NRC approved training and retraining program for CERTIFIED FUEL HANDLERS shall be maintained.

• PNPS 5.0-4 Amendment No. ++-7, Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

PNPS a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978; b. Deleted c. Quality assurance for effluent and environmental monitoring;

d. Fire Protection Program implementation; and e. All programs specified in Specification 5.5. 5.0-5 Amendment No. 4-7+,

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.2 Deleted 5.5.3 Not Used 5.5.4 Radioactive Effluent Controls Program PNPS This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable.

The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded.

The program shall include the following elements:

a. Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; (continued) 5.0-7 Amendment No. +7+,

5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements Reporting Requirements 5.6 The following reports shall be submitted in accordance with 10 CFR 50.4. 5.6.1 Not Used 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the facility during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C. The Annual Radiological Environmental Operating Report shall include a summary of the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, Novemt>er 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible. (Continued)

Amendment No. -+B+, 212, 2J1, 5.0-12 Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the facility shall be submitted in accordance with 1 O CFR 50.36a by May 15th of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility.

The material provided shall be consistent with the objectives outlined in the ODCM and process control procedures and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1. 5.6.4 Not Used 5.6.5 Core Operating Limits Report (COLR) a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1. Table 3.1.1 -APRM High Flux trip level setting 2. Table 3.2.C -APRM Upscale trip level setting 3. 3.11.A -Average Planar Linear Heat Generation Rate (APLHGR) 4. 3.11.B -Linear Heat Generation Rate (LHGR) 5. 3.11.C -Minimum Critical Power Ratio (MCPR) 6. 3.11.D -Power/Flow Relationship During Power Operation

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," (through the latest NRC approved amendment at the time the reload analyses are performed as specified in the COLR). (Continued)

Amendment No. 437, 191, 212, 231, 5.0-13 5.0 ADMINISTRATIVE CONTROLS 5. 7 High Radiation Area High Radiation Area 5.7 5. 7.1 Pursuant to 10 CFR 20, paragraph 20.1601 ( c), in lieu of the requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is > 100 mrem/hr but < 1000 mrem/hr, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g., radiation protection personnel) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates 1000 mrem/hr, provided they are otherwise following facility radiation protection procedures for entry into such high radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area. b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.

Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them. c. An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the radiation protection manager in the RWP. 5. 7.2 In addition to the requirements of Specification

5. 7.1, areas with radiation levels 1000 mrem/hr shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the control room supervisor on duty or radiation protection supervision.

Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay times for individuals in those areas. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area. (Continued)

Amendment No. 4-8-7, 5.0-15

5. 7 High Radiation Area High Radiation Area 5.7 5.7.3 For individual high radiation areas with radiation levels of> 1000 mrem/hr, accessible to personnel, that are located within large areas such as reactor containment, where no enclosure exists for purposes of locking, or that cannot be continuously guarded, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded and conspicuously posted, and a flashing light shall be activated as a warning J device. / Amendment No. 5.0-16