ML080920983

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03/18/2008-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  Entergy icon.png
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

SUBJECT:

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:

SUBJECT:

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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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 Robert Snook 1750 Ben Franklin Drive, 7E Assistant Attorney General PWR SRC Consultant Office of the Attorney General Sarasota, FL 34236 State of Connecticut 55 Elm Street Mr. William T. Russell P.O. Box 120 PWR SRC Consultant Hartford, CT 06141-0120 400 Plantation Lane Stevensville, MD 21666-3232 Ms. Kathryn M. Sutton, Esq.

Morgan, Lewis & Bockius, LLP Mr. Jim Riccio 1111 Pennsylvania Avenue, NW Greenpeace Washington, DC 20004 702 H Street, NW Suite 300 Mr. Paul M. Bessette, Esq.

Washington, DC 20001 Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Mr. Phillip Musegaas Washington, DC 20004 Riverkeeper, Inc.

828 South Broadway Mr. Martin J. ONeill, Esq.

Tarrytown, NY 10591 Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Mr. Mark Jacobs Washington, DC 20004 IPSEC 46 Highland Drive The Honorable Nita Lowey Garrison, NY 10524 222 Mamaroneck Avenue, Suite 310 White Plains, NY 10605 Mr. R. M. Waters Technical Specialist Licensing Joan Leary Matthews 450 Broadway Senior Counsel for Special Projects P.O. Box 0249 Office of General Counsel Buchanan, NY 10511-0249 NYS Department of Environmental Conservation Mr. Sherwood Martinelli 625 Broadway 351 Dyckman Albany, NY 12233-5500 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