ML080920983

Summary of Telephone Conference Call Between NRC and Entergy Nuclear Operations, Inc., Pertaining to the Indian Point Units 2 & 3, License Renewal Application - Environmental Request for Additional Information

ML080920983
Person / Time
Site:	Indian Point
Issue date:	04/09/2008
From:	Bo Pham NRC/NRR/ADRO/DLR
To:	Office of Nuclear Reactor Regulation
Pham B, NRR/DLR/REBB, 415-8450
References
FOIA/PA-2009-0193
Download: ML080920983 (7)

Text

April 9, 2008 LICENSEE: Entergy Nuclear Operations, Inc.

FACILITY: Indian Point Nuclear Generating Unit Nos. 2 and 3

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MARCH 18, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., PERTAINING TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - ENVIRONMENTAL RAI The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., (Entergy) held a telephone conference call on March 18, 2008, concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), license renewal application (LRA). The staff initiated the call to seek clarification about Entergys January 4, 2008, response to the staffs request for additional information (RAI) dated December 5, 2007, regarding the possible reactor vessel head replacements at IP2 and IP3 and their potential treatment as refurbishment according to guidance established in the GEIS.

The staff received scoping comments during its review of the IP2 and IP3 LRA (ADAMS Accession Nos. ML071990093 and ML073100985) indicating that Entergy had taken steps toward procuring replacement reactor vessel heads for IP2 and IP3. The scoping comments contained excerpts from a presentation by Doosan Heavy Industries indicating that Doosan plans to deliver replacement reactor vessel heads for IP2 and IP3 in October of 2011 and 2012, respectively. Based on this information, the staff requested, by letter to Entergy dated December 5, 2007, additional information regarding refurbishment.

Entergys response, dated January 4, 2008, indicated that no reactor vessel head replacements are required for purposes of aging management during the period of extended operation. Accordingly, no evaluation of the environmental impacts of reactor vessel head replacement as a refurbishment activity is required or presented in the Environmental Report.

Further, Entergy also noted that the decision to proceed with procurement of long lead items

[replacement vessel heads] is strictly economic, and therefore need not be addressed in Entergys Environmental Report.

During the conference call, the staff acknowledged that while there may be no requirement to replace the reactor vessel heads at IP2 and IP3 during license renewal, Section 2.6.1 of the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) discusses environmental impact-initiating actions associated with license renewal. These actions include both, (1) refurbishment, repair, or replacement activities that may be performed to ensure that this objective [aging management and maintaining functionality of certain SSCs]

is achieved, as well as (2) activities that the licensee may choose to undertake, including various refurbishment and upgrade activities at their nuclear facilities to better maintain or improve reliability, performance, and economics of power plant operation during the extended period of operation.

In the course of the conference call, Entergy staff indicated that reactor vessel head replacement is currently not a certainty. Entergy staff indicated that the fleet-wide decision to order a number of vessel head forgings was a corporate decision that allowed the company to reserve a spot in line for these long-lead-time components, as well as to secure economies of scale by taking steps toward ordering heads for all of Entergys pressurized-water reactors (PWRs). Entergy staff indicated that they may yet sell their spot(s) in line, or sell the forgings before they are complete. Even if Doosan completes their work on the replacement heads, Entergy staff indicated that Entergy would refrain from drilling penetrations and hold the unfinished heads in storage until Entergy is certain that replacement is appropriate. Entergy staff also noted that the vendor responsible for the IP2 and IP3 original heads has a better vessel head longevity track record than most other vendors, and thus head replacement may be unnecessary. Entergy staff noted, however, that vessel head replacement, should it occur, would likely occur during the renewal term. In addition, Entergy staff indicated that Entergy would not have taken steps to order replacement reactor vessel head forgings for IP2 and IP3 had Entergy not planned to seek license renewal for the units. As such, NRC staff indicated that the vessel head replacement may constitute a refurbishment activity associated with license renewal.

At the conclusion of the conference call, the staff indicated that it intends to assess the impacts related to vessel head replacement activities, and that additional information may be requested from Entergy to facilitate the staffs review and understanding of those impacts. The NRC staff also suggested that Entergy staff use the NRCs analysis in Chapter 3 of the GEIS as a starting point for Entergys response to the RAI, which includes discussions about Category 1 and Category 2 impacts related to potential license renewal refurbishment activities (all issues are listed in 10 CFR 51 Subpart A, Appendix B, Table B-1).

The Enclosure provides a list of the participants.

/RA/

Bo M. Pham, Senior Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286

Enclosure:

As stated

ML080920983 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME SFigueroa BPham RFranovich (BPham for)

DATE 04/7/08 04/1/08 04/9/08 TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION - ENVIRONMENTAL RAI LIST OF PARTICIPANTS March 18, 2008 PARTICIPANTS AFFILIATIONS Artic Bortz Entergy Charlie Caputo Entergy John Curry Entergy Dara Gray Entergy Mike Stroud Entergy Rani Franovich NRC Bo Pham NRC Drew Stuyvenberg NRC ENCLOSURE

Letter to Entergy from B. Pham, dated April 9, 2008 DISTRIBUTION:

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MARCH 18, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., PERTAINING TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - ENVIRONMENTAL RAI HARD COPY:

DLR RF E-MAIL:

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Indian Point Nuclear Generating Units 2 and 3 cc:

Senior Vice President Entergy Nuclear Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Vice President Oversight Entergy Nuclear Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety &

Licensing Entergy Nuclear Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President and COO Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Manager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Paul D. Tonko President and CEO New York State Energy Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. John P. Spath New York State Energy, Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspectors Office Indian Point 2 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Senior Resident Inspectors Office Indian Point 3 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. William DiProfio PWR SRC Consultant 48 Bear Hill Road Newton, NH 03858

Indian Point Nuclear Generating Units 2 and 3 cc:

Mr. Garry Randolph 1750 Ben Franklin Drive, 7E PWR SRC Consultant Sarasota, FL 34236 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001 Mr. Phillip Musegaas Riverkeeper, Inc.

828 South Broadway Tarrytown, NY 10591 Mr. Mark Jacobs IPSEC 46 Highland Drive Garrison, NY 10524 Mr. R. M. Waters Technical Specialist Licensing 450 Broadway P.O. Box 0249 Buchanan, NY 10511-0249 Mr. Sherwood Martinelli 351 Dyckman Peekskill, NY 10566 Ms. Susan Shapiro, Esq.

21 Perlman Drive Spring Valley, NY 10977 John Sipos Assistant Attorney General New York State Department of Law Environmental Protection Bureau The Capitol Albany, NY 12224 Robert Snook Assistant Attorney General Office of the Attorney General State of Connecticut 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Ms. Kathryn M. Sutton, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. Paul M. Bessette, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. Martin J. ONeill, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 The Honorable Nita Lowey 222 Mamaroneck Avenue, Suite 310 White Plains, NY 10605 Joan Leary Matthews Senior Counsel for Special Projects Office of General Counsel NYS Department of Environmental Conservation 625 Broadway Albany, NY 12233-5500