ML081370507

Lr Hearing - Environmental RAI Letter

ML081370507
Person / Time
Site:	Indian Point
Issue date:	04/18/2008
From:	Office of Nuclear Reactor Regulation
To:	Division of License Renewal
References
Download: ML081370507 (9)

Text

IPRenewal NPEmails From: Bo Pham Sent: Friday, April 18, 2008 8:13 PM To: Tyner, Donna; Stroud, Mike (MSTROUD@entergy.com)

Cc: Andrew Stuyvenberg; Kimberly Green

Subject:

Environmental RAI letter Mike & Donna, We sent out the Refurb RAI letter today. Attached is an advanced electronic copy.

Thanks.

Bo Pham Sr. Project Manager Division of License Renewal U.S. Nuclear Regulatory Commission 3016134236 Refurb AI-ML0809404081.pd 1

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 51 Mail Envelope Properties (Bo.Pham@nrc.gov20080418201200)

Subject:

Environmental RAI letter Sent Date: 4/18/2008 8:12:46 PM Received Date: 4/18/2008 8:12:00 PM From: Bo Pham Created By: Bo.Pham@nrc.gov Recipients:

"Andrew Stuyvenberg" <Andrew.Stuyvenberg@nrc.gov>

Tracking Status: None "Kimberly Green" <Kimberly.Green@nrc.gov>

Tracking Status: None "Tyner, Donna" <dtyner@entergy.com>

Tracking Status: None "Stroud, Mike (MSTROUD@entergy.com)" <MSTROUD@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 225 4/18/2008 8:12:00 PM Refurb RAI-ML0809404081.pdf 89408 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

April 14, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE LICENSE RENEWAL APPLICATION FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 (TAC NOS. MD5411 AND MD5412)

Dear Sir or Madam:

By letters to Entergy Nuclear Operation, Inc. (Entergy), dated December 5 and 7, 2008, the U.S.

Nuclear Regulatory Commission (NRC or staff) requested that additional information be provided in order for the staff to complete its review of the license renewal application (LRA) for Indian Point Nuclear Generating Unit Nos. 2 and 3. By letters dated January 4, 10, 30, and February 5, 20, and March 7, 2008, Entergy provided responses to the staffs requests for additional information (RAIs). Upon review of your responses, the staff has identified areas where additional information is needed in order to complete its review.

Enclosed is the staffs RAI regarding refurbishment. As discussed with Mr. Mike Stroud of your staff, we request that you provide your responses to these questions no later than 30 days after the issuance of this letter, in order to facilitate an expeditious review. If you have any questions, please contact me at (301) 415-8450 or at BMP@nrc.gov.

Sincerely,

\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 cc w/enclosure: See next page

ML080940408 OFFICE LA:DLR PM:DLR:RPB2 OGC BC:DLR:RPB2 NAME SFigueroa BPham STurk RFranovich DATE 04/09/08 04/11/08 04/02/08 04/14/08

Letter to Entergy From B. Pham dated: April 14, 2008 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE LICENSE RENEWAL APPLICATION FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 (TAC NOS. MD5411 AND MD5412)

HARD COPY:

DLR RF E-MAIL:

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RFranovich EDacus, OCA BPham GMeyer, RI KGreen MMcLaughlin, RI JCaverly NMcNamara, RI RAuluck DScrenci, RI OPA KChang NSheehan, RI OPA MKowal PCataldo, RI JBoska CHott, RI STurk, OGC DJackson, RI LSubin, OGC BWelling, RI BMizuno, OGC RConte, RI SBurnell, OPA ECobey, RI DMcIntyre, OPA MCox, RI TMensah, OEDO

Indian Point Nuclear Generating Units 2 and 3 cc:

Senior Vice President Mr. Paul Eddy Entergy Nuclear Operations, Inc. New York State Department P.O. Box 31995 of Public Service Jackson, MS 39286-1995 3 Empire State Plaza Albany, NY 12223-1350 Vice President Oversight Entergy Nuclear Operations, Inc. Regional Administrator, Region I P.O. Box 31995 U.S. Nuclear Regulatory Commission Jackson, MS 39286-1995 475 Allendale Road King of Prussia, PA 19406 Senior Manager, Nuclear Safety &

Licensing Senior Resident Inspectors Office Entergy Nuclear Operations, Inc. Indian Point 2 P.O. Box 31995 U.S. Nuclear Regulatory Commission Jackson, MS 39286-1995 P.O. Box 59 Buchanan, NY 10511 Senior Vice President and COO Entergy Nuclear Operations, Inc. Senior Resident Inspectors Office 440 Hamilton Avenue Indian Point 3 White Plains, NY 10601 U.S. Nuclear Regulatory Commission P.O. Box 59 Assistant General Counsel Buchanan, NY 10511 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue Mr. Charles Donaldson, Esquire White Plains, NY 10601 Assistant Attorney General New York Department of Law Manager, Licensing 120 Broadway Entergy Nuclear Operations, Inc. New York, NY 10271 Indian Point Energy Center 450 Broadway, GSB Mr. Raymond L. Albanese P.O. Box 249 Four County Coordinator Buchanan, NY 10511-0249 200 Bradhurst Avenue Unit 4 Westchester County Mr. Paul D. Tonko Hawthorne, NY 10532 President and CEO New York State Energy Research and Mayor, Village of Buchanan Development Authority 236 Tate Avenue 17 Columbia Circle Buchanan, NY 10511 Albany, NY 12203-6399 Mr. William DiProfio Mr. John P. Spath PWR SRC Consultant New York State Energy, Research and 48 Bear Hill Road Development Authority Newton, NH 03858 17 Columbia Circle Albany, NY 12203-6399

Indian Point Nuclear Generating Units 2 and 3 cc:

Mr. Garry Randolph John Sipos PWR SRC Consultant Assistant Attorney General 1750 Ben Franklin Drive, 7E New York State Department of Law Sarasota, FL 34236 Environmental Protection Bureau The Capitol Mr. William T. Russell Albany, NY 12224 PWR SRC Consultant 400 Plantation Lane Robert Snook Stevensville, MD 21666-3232 Assistant Attorney General Office of the Attorney General Mr. Jim Riccio State of Connecticut Greenpeace 55 Elm Street 702 H Street, NW P.O. Box 120 Suite 300 Hartford, CT 06141-0120 Washington, DC 20001 Ms. Kathryn M. Sutton, Esq.

Mr. Phillip Musegaas Morgan, Lewis & Bockius, LLP Riverkeeper, Inc. 1111 Pennsylvania Avenue, NW 828 South Broadway Washington, DC 20004 Tarrytown, NY 10591 Mr. Paul M. Bessette, Esq.

Mr. Mark Jacobs Morgan, Lewis & Bockius, LLP IPSEC 1111 Pennsylvania Avenue, NW 46 Highland Drive Washington, DC 20004 Garrison, NY 10524 Mr. Martin J. ONeill, Esq.

Mr. R. M. Waters Morgan, Lewis & Bockius, LLP Technical Specialist Licensing 1111 Pennsylvania Avenue, NW 450 Broadway Washington, DC 20004 P.O. Box 0249 Buchanan, NY 10511-0249 The Honorable Nita Lowey 222 Mamaroneck Avenue, Suite 310 Mr. Sherwood Martinelli White Plains, NY 10605 351 Dyckman Peekskill, NY 10566 Joan Leary Matthews Senior Counsel for Special Projects Ms. Susan Shapiro, Esq. Office of General Counsel 21 Perlman Drive NYS Department of Environmental Spring Valley, NY 10977 Conservation 625 Broadway Albany, NY 12233-5500

Request for Additional Information (RAI)

Regarding Refurbishment for Indian Point Nuclear Generating Unit Nos. 2 And 3 The staff received scoping comments during its review of the License Renewal Application (LRA) for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) indicating that Entergy had taken steps toward procuring replacement reactor vessel heads for IP2 and IP3 (ADAMS accession nos. ML071990093 and ML073100985). The scoping comments contained excerpts from a presentation by Doosan Heavy Industries indicating that Doosan plans to deliver replacement reactor vessel heads and control rod drive mechanisms (CRDMs) 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 a telephone conference call on March 18, 2008 (ADAMS accession number forthcoming), the staff acknowledged that while there may be no requirement to replace the reactor vessel heads at IP2 and IP3 for license renewal, Section 2.6.1 of the Generic Environmental Impact Statement for License Renewal (GEIS) discusses environmental impact-initiating actions associated with license renewal. These actions include: (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, and (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. Since the GEIS considers refurbishment activities beyond those that are related to aging management during the period of extended operation, Entergys response to the staffs RAI related to refurbishment did not effectively address the scoping comment regarding this potential refurbishment activity.

During the conference call, Entergy indicated that, if license renewal were not being pursued for IP2 and IP3, the vessel head forgings would not have been ordered. Entergy also indicated that the vessel head forgings that were procured for IP2 and IP3 may never be needed, and a decision by Entergy to replace reactor vessel heads for IP2 and/or IP3 has not been made.

Question 1:

In order for the NRC staff to better understand the specific nature of the steps taken by Entergy with respect to its plans for reactor vessel head and CRDM replacement, please identify the factors that Entergy may consider in deciding whether to replace these components. Please describe how those factors affect Entergys decision whether to replace the vessel heads and CRDMs.

ENCLOSURE

Question 2:

The staff recognizes that there is no certainty with respect to reactor vessel head and/or CRDM replacement at IP2 and/or IP3. Therefore, Entergys response to Question 1 above will be duly considered by the staff in determining whether to address the potential environmental impacts of these actions in the upcoming draft Supplemental Environmental Impact Statement.

Nevertheless, based on the information presented in the scoping comment and the conference call discussion with Entergy staff on March 18, 2008, the NRC staff may proceed with a review of the impacts associated with reactor vessel head and CRDM replacement in accordance with 10 CFR 51.71. To facilitate the staffs review and understanding of these impacts, please provide additional information and supporting analysis regarding the Category 1 and Category 2 impacts (as listed in 10 CFR 51 Subpart A, Appendix B, Table B-1) that would be associated with reactor vessel head and CRDM replacement (all issues are listed in Table B-1 and included in Chapter 3 of the GEIS). If Entergy is unable to provide information specifically addressing the likely impacts of replacing vessel heads and CRDMs at IP2 and IP3, please provide impact estimates based on Entergys experience at other plants. If Entergy-specific information is not available, please provide estimates based on industry experience in replacing these components.