ML093620026

Notification of Entergy'S Submittal of SAMA Reanalysis Using Alternate Meteorological Tower Data for Indian Point, Units 2 & 3

ML093620026
Person / Time
Site:	Indian Point
Issue date:	12/14/2009
From:	Bessette P Entergy Nuclear Operations, Morgan, Morgan, Lewis & Bockius, LLP
To:	Lathrop K, Lawrence Mcdade, Richard Wardwell Atomic Safety and Licensing Board Panel
SECY/RAS
References
50-247-LR, 50-286-LR, RAS E-313
Download: ML093620026 (42)

Text

R A-,,S' c -313 Morgan, Lewis & Bockius 1000 Louisiana Street Suite 4200 LLP Morgan Lewis COUNSELORS AT LAW Houston, TX 77002 Tel: 713.890.5000 Fax: 713.890.5001 www.morganlewis.com DOCKETED Kathryn M. Sutton USNRC Partner 202.739.5738 ksutton@morganlewis.com December 15, 2009 (8:30am)

Paul M. Bessette OFFICE OF SECRETARY Partner RULEMAKINGS AND 202.739.5796 ADJUDICATIONS STAFF pbessette@morganlewis.com December 14, 2009 Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket: Entergy Nuclear Operations,Inc. (Indian Point Nuclear Generating Units 2 and 3), Docket Nos. 50-247-LR and 50-286-LR RE: Notification of Entergy's Submittal of the SAMA Reanalysis Using Alternate Meteorological Tower Data for Indian Point Units 2 and 3

Dear Administrative Judges:

By letter dated November 17, 2009, counsel for Entergy Nuclear Operations, Inc.

("Entergy") notified the Atomic Safety and Licensing Board ("Board") and participants to this proceeding of a recently found discrepancy in the wind direction inputs to the MACCS2 code for the Indian Point Energy Center ("IPEC") severe accident mitigation alternative ("SAMA")

analysis. As counsel noted, in a letter to the U.S. Nuclear Regulatory Commission ("NRC")

dated November 16, 2009, Entergy committed to correct the wind direction inputs, re-analyze the SAMAs for both IPEC units, and provide the results to the NRC by December 16, 2009.

The purpose of this letter is to notify the Board and hearing participants that Entergy submitted the completed SAMA reanalysis for both IPEC units to the NRC on December 11, 2009. See NL-09-165, Letter from Fred Dacimo, Entergy, to NRC Document Control Desk, "License Renewal Application-SAMA Reanalysis Using Alternate Meteorological Tower Data" (Dec. 11, 2009). A copy of NL-09-165 is attached for your reference. Counsel is providing this follow-up notification insofar as the SAMA reanalysis may be relevant and T~pL~,--::L cEf 3 6_ý- 0ý

Morgan Lewis Lawrence G. McDade, Chairman COUNSELORS AT LAW Dr. Richard E. Wardwell Dr. Kaye D. Lathrop December 14, 2009 Page 2 material to admitted contentions NYS- 12/12A and NYS- 16/16A, as previously explained in counsel's November 17, 2009 letter to the Board.

Respectfully submitted,

' jk~,, A~ P,. i i Kathryn M. Sutton, Esq.

Paul M. Bessette, Esq.

Counsel for Entergy Nuclear Operations, Inc.

MJO/als Attachment cc: Service List

Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB Entergy P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President License Renewal NL-09-165 December 11, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Renewal Application - SAMA Reanalysis Using Alternate Meteorological Tower Data Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCE:

1. Entergy Nuclear Operations Inc. Letter NL-09-151, "Entergy Nuclear Operations Inc. Telephone Conference Call Regarding Met Tower Data for SAMA Analysis" dated November 16, 2009

Dear Sir or Madam:

In Reference 1 above, Entergy Nuclear Operations, Inc (Entergy) committed to providing the following information on or before December 16, 2009.

• The meteorological data and justification supporting its use in the SAMA analysis (e.g., if a single year is used or an average of several years),

• Revised estimates of the offsite population dose and offsite economic costs,

• Identification of the meteorological tower elevation from which meteorological data were obtained and the rationale for selecting the data from that tower elevation,

• Revised SAMA analysis results, specifically for the analysis case discussed in response to RAI 4e, dated February 5, 2008, and

• The complete MACCS2 input file used for the reanalysis (in electronic format).

The purpose of this letter is to transmit the requested information. Attachment 1 provides the SAMA reanalysis using alternate Meteorological Tower Data.

There are no new commitments identified in this submittal. If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-734-6710.

NL-09-165 Page 2 of 2 I declre under penalty of perjury that the foregoing is true and correct. Executed on FRD/dmt

Enclosure:

1. License Renewal Application- SAMA Reanalysis Using Alternate Meteorological Tower Data cc: Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Ms. Kimberly Green, NRC Project Manager Mr. John Boska, NRR Senior Project Manager IPEC NRC Resident Inspector's Office Mr. Paul Eddy, New York State Department of Public Service Mr. Francis J. Murray, President and CEO, NYSERDA

ATTACHMENT 1 TO NL-09-165 License Renewal Application - SAMA Reanalysis Using Alternate Meteorological Tower Data ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 LICENSE NOS. DPR-26 AND DPR-64

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 1 of 33 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION SAMA Reanalysis Using Alternate Meteorological Tower Data NRC Requests from November 9, 2009 Teleconference (1) Provide meteorological data and justification supporting its use in the SAMA analysis (e.g., if a single year is used or an average of several years).

(2) Provide revised estimates of the offsite population dose and offsite economic costs.

(3) Provide identification of the meteorological tower elevation from which meteorological data were obtained and the rationale for selecting the data from that tower elevation.

(4) Provide revised SAMA analysis results, specifically for the analysis case discussed in response to RAI 4e, dated February 5, 2008.

(5) Provide the complete MACCS2 input file used for the reanalysis (in electronic format).

Response

The following document provides responses to the requests listed above.

(1) Section [4] describes and justifies the meteorological data used in the SAMA reanalysis.

(2) Revised estimates of the offsite population dose and offsite economic costs are provided in Tables 1 and 2.

(3) Identification of the meteorological tower elevation from which meteorological data were obtained and the rationale for selecting the data from that tower elevation are provided in Section [2].

(4) Revised SAMA analysis results, specifically for the analysis case discussed in response to RAI 4e, are provided in Tables 4 and 5.

(5) The complete MACCS2 input files used for the SAMA reanalysis listed in Section

[10] are provided in electronic format.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 2 of 33 TABLE OF CONTENTS

[1] INTRO DUCTIO N ..................................................................................... 3

[2] PREPARATION OF ANNUAL METEOROLOGICAL DATA ................................... 4

[3] NON-METEOROLOGICAL LEVEL 3 MODEL INPUTS ....................................... 5

[4] MACCS2 ANALYSIS AND RESULTS ............................................................ 5

[5] COST BENEFIT ANALYSIS RESULTS .......................................................... 7

[6] REVISED COST ESTIMATES ....................................................................... 7

[7] MAIN STEAM SAFETY VALVE GAGGING SAMA (UPDATED RESPONSE TO R O U ND 2 R A I 6 ) ....................................................................................... 2 9

[8] TI-SGTR SENSITIVITY ANALYSIS (REVISED RESPONSE TO ROUND 2 RAI

5) ...................................... ......................................... . . . 2 9

[9] C O NCLU S ION ....................................................................................... 3 1

[10] MAC C S2 INPUT FILES ............................................................................ 33

[11] R EFERENC ES ................................................................................... 33

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 3 of 33 IP2 and IP3 SAMA Reanalysis

[1] Introduction The IP2 and IP3 Severe Accident Mitigation Alternative (SAMA) analyses originally described in the Environmental Report (ER) of the license renewal application, dated April 3, 2007, used site specific meteorological data (wind speed, wind direction, temperature, and accumulated precipitation) obtained from the IPEC onsite meteorological monitoring system (Reference 1).

As permitted by NEI 05-01, "Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document,"' (Reference 4) five years of meteorological data (2000-2004) were averaged and used in the original SAMA analyses. Since the SAMA analyses began in the fall of 2005, these five years were the most recent data available at the time of the original analyses. The five-year data included 43,848 (two leap years) consecutive hourly values of wind speed, wind direction, precipitation, and temperature recorded at the IPEC meteorological tower from January 2000 through December 2004. The results of the original SAMA analyses were reported in the ER and clarified in response to questions from the Nuclear Regulatory Commission (References 2 and 3).

As described above, the original SAMA analyses used five year averages of wind speed, wind direction, precipitation, and temperature. The averaging method for wind direction, however, was determined to be incorrect and, as a result, the averaged wind direction data was not representative of wind direction conditions in the region for the five year period (Reference 5).

Therefore, the SAMAs have been reanalyzed using a single representative year of meteorological data as described below. As described further in Section [41 below, Year 2000 was selected as the representative year because, of the five years of data, it is the year that resulted in the most conservative (i.e. largest) calculated population doses. Using one representative year avoids the need to average multiple years of meteorological data, including wind direction.

In accordance with NEI 05-01 recommendations, the original SAMA analyses described in the ER included multiple cases including a baseline case with uncertainty and three sensitivity cases (use of a 3 percent discount rate, use of a longer plant life, and consideration of economic losses by tourism and business). The sensitivity cases in the ER did not identify additional potentially cost beneficial SAMAs beyond those already identified by the baseline with uncertainty case.

During their review, the Nuclear Regulatory Commission (NRC) Staff noted that incorporation of tourism and business losses could result in identification of additional cost beneficial SAMAs if it was considered the baseline case and multiplied to account for uncertainties. Therefore, in response to request for additional information (RAI) 4e, Entergy provided the results of a revised uncertainty analysis in which the impact of lost tourism and business was analyzed as the baseline analysis and multiplied to account for uncertainties (Reference 2). This uncertainty case resulted in the identification of two additional potentially cost beneficial SAMAs for IP2 and one additional potentially cost beneficial SAMA for IP3. Since it resulted in the largest number of potentially cost beneficial SAMAs, the RAI 4e analysis case is the most conservative case.

The SAMA reanalysis described below was performed for the same most conservative case; I NEI 05-01 was endorsed by NRC in Federal Register / Vol. 72, No. 156 / Tuesday, August 14, 2007.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 4 of 33 i.e., the RAI 4e analysis case in which the impact of lost tourism and business was analyzed as the baseline analysis and multiplied to account for uncertainties.

Following the SAMA reanalysis, an additional sensitivity case was analyzed to provide a revised response to Round 2 RAI 5 (Reference 3). This sensitivity case determined the impact of applying values derived from NUREG-1 570, Risk Assessment of Severe Accident-Induced Steam Generator Tube Rupture, although final industry consensus on the thermally-induced steam generator tube rupture (TI-SGTR) issue has not yet been reached. See Section [8] for a description of this sensitivity case.

As a result of the SAMA reanalysis and sensitivity case using a conservatively representative, single year of meteorological data (2000), three additional SAMA candidates were found to be potentially cost beneficial for mitigating the consequences of a severe accident for IP2 and three additional SAMA candidates were found to be potentially cost beneficial for IP3 (in addition to those previously designated as cost beneficial in Section 4.21.6 of the ER and References 2 and 3).

[2] Preparation of Annual Meteorological Data The MACCS2 code accepts 8,760 consecutive hourly values (one year) of meteorological data.

Each of the five years of meteorological data used in the original analysis was prepared for input into the MACCS2 code by converting values recorded at the primary meteorological tower at the IPEC site to the units used by MACCS2, assigning an atmospheric stability class based upon the temperature data, and using data substitution to fill in limited missing data.

The primary meteorological tower at IPEC records data on an hourly basis at three elevations, 10m, 60m, and 122m. All available data from the 10m elevation of the primary meteorological tower was used in both the original SAMA analysis and reanalysis because it is closest to the assumed release height of 30m and, therefore, would be most representative of the conditions at the point of release. Both the original SAMA analysis and reanalysis assumed a release height of 30m because it is approximately half the height above grade level of the IP2 and IP3 containment buildings, as recommended by NEI 05-01 to provide adequate dispersion of the plume to the surrounding area. Data from this elevation is also currently used in calculations for the effluent release reports submitted to the NRC pursuant to 10 CFR Part 50.36a and the IPEC emergency plan.

Data substitution methods used in the SAMA reanalysis were in accordance with Environmental Protection Agency (EPA) guidance provided in Reference 6. These methods included substitution of limited missing meteorological data with data interpolated, averaged, or curve-fit from previous and subsequent hours and substitution of valid data collected from the 60m elevation. In the MACCS2 input file for 2000, which was conservatively selected for use in the SAMA reanalysis, the following data substitutions were made.

Seventy-four hours of 10-meter wind direction data was missing for day 316 hour0.00366 days <br />0.0878 hours <br />5.224868e-4 weeks <br />1.20238e-4 months <br /> 14 through day 319 hour0.00369 days <br />0.0886 hours <br />5.274471e-4 weeks <br />1.213795e-4 months <br /> 15 (in METIOO.inp). To maintain consistency and wind variability, data from the 60-meter sensor was substituted for the seventy four hours of missing 10-meter wind direction data.

.I NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 5 of 33 Eight hours of temperature data was missing for day 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> 2 through 9 (in METIOO.inp).

Values for these eight hours were obtained by linear interpolation of the preceding and subsequent valid temperature values.

Data for all meteorological parameters was missing on day 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> 10 and 11, day 104 hour0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> 19, day 255 hours0.00295 days <br />0.0708 hours <br />4.21627e-4 weeks <br />9.70275e-5 months <br /> 18 and 19, and day 294 hours0.0034 days <br />0.0817 hours <br />4.861111e-4 weeks <br />1.11867e-4 months <br /> 10 and 11 (in METIOO.inp).

Substitute values were obtained by interpolation, curve-fitting, or averaging the preceding and subsequent valid data values as appropriate.

[3] Non-Meteoroloqical Level 3 Model Inputs In addition to meteorological data, MACCS2 also uses input data for population, land fraction, watershed class, regional economic data, agriculture data, emergency response assumptions, and source terms. These inputs are described in Sections E.1.5 and E.3.5 of the ER.

For the regional average value of non-farm wealth (VALWNF), a value of $208,838.49/person was used in the SAMA reanalysis consistent with sensitivity case 3 in the ER. As mentioned in Section [1], the RAI 4e analysis case (which is ER sensitivity case 3 multiplied to account for uncertainty) is the most conservative case, resulting in the largest number of potentially cost beneficial SAMAs. The reanalysis was performed for the RAI 4e analysis case in which the impact of lost tourism and business was analyzed as the baseline analysis and multiplied to account for uncertainties. Consequently, the revised benefit results for all SAMAs include the impact of lost tourism and business, as described in the response to request for additional information (RAI) 4e (Reference 2).

The other, non-meteorological data were the same as those described for the baseline case in the ER (described in Sections E.1.5 and E.3.5 of the ER). Since the reanalysis uses the same non-meteorological input data as the original RAI 4e analysis case, the only difference between the original RAI 4e analysis and the reanalysis is the meteorological data.

[4] MACCS2 Analysis and Results As with the original SAMA analysis, the SAMA reanalysis also used MACCS2 to estimate the mean population dose risk (PDR) and offsite economic cost risk (OECR). Preliminary results from MACCS2 using each of the five years of meteorological data (2000-2004) were compared.

Since the dose and economic cost results for all of the individual years were similar, the year that resulted in the most conservative (i.e. largest) doses (year 2000) was selected as the representative year for use in the SAMA reanalysis. This method of choosing a representative year agrees with the example provided in NEI 05-01. The revised estimated mean values of PDR and OECR for IP2 and IP3 using year 2000 meteorological data are presented in Table I for IP2 and Table 2 for IP3. Comparison of the values in Tables 1 and 2 with those in ER Tables E.1-14 and E.3-14 shows that the individual year PDR and OECR values are larger than the original ER values due to removal of wind direction biases introduced by the faulty wind direction averaging method.

Table 3 provides a breakdown of the total population dose by containment failure mode, similar to information provided in response to RAI 2a (Reference 2).

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 6 of 33 Table I IP2 Mean PDR and OECR Using Year 2000 Meteorological Data Offsite Population Offsite Release Frequency Population Dose Economic Dose Risk (PnDRicCost Economic Mode (/yr) Doe Cost (PDR) Cs (person-sv)* (person- Risk (OECR)

($) rem/yr) ($/yr)

NCF 1.19E-05 4.75E+01 9.98E+04 5.64E-02"* 1.18E+00 EARLY HIGH 6.50E-07 6.51E+05 2.05E+11 4.23E+01 1.33E+05 EARLY MEDIUM 4.23E-07 1.94E+05 5.87E+10 8.21E+00 2.48E+04 EARLY LOW 1.11E-07 7.93E+04 6.39E+09 8.81E-01 7.1OE+02 LATE HIGH 6.88E-07 1,63E+05 4.64E+10 11.12E+01 3.19E+04 LATE MEDIUM 3.43E-06 6.87E+04 6.06E+09 2.36E+01 2.08E+04 LATE LOW 6.43E-07 1.61 E+04 6.59E+08 1.04E+00 4.24E+02 LATE LOWLOW 5.82E-08 1.38E+04 5.62E+08 8.04E-02 3.27E+01 Total 8.74E+01 2.12E+05

• 1sv = 100 rem

• • 5.64E-02 (person-rem/yr) = 1.19E-05 (/yr) x 4.75E+01 (person-sv) x 100 (rem/sv)

Table 2 IP3 Mean PDR and OECR Using Year 2000 Meteorological Data Offsite Population Offsite Release Frequency Population Economic Dose Risk Economic Mode (/yr) Dose Cost (PDR) Cost (person-sv)* (person- Risk (OECR)

($) rem/yr) ($/yr)

NCF 6.30E-06 8.04E+01 2.95E+05 5.06E-02** 1.86E+00 EARLY HIGH 9.43E-07 5.08E+05 1.70E+11 4.79E+01 1.60E+05

-EARLY MEDIUM 1.24E-06 2.00E+05 5.55E+10 2.47E+01 6.87E+04 EARLY LOW 1.46E-07 5.21E+04 3.58E+09 7.59E-01 5.21 E+02 LATE HIGH 4.23E-07 1.63E+05 4.61E+10 6.89E+00 1.95E+04 LATE MEDIUM 2.01E-06 6.85E+04 6.06E+09 1.37E+01 1.22E+04 LATE LOW 3.75E-07 1.61 E+04 6.58E+08 6.03E-01 2.47E+02 LATE LOWLOW 5.66E-08 1.38E+04 5.62E+08 7.81E-02 3.18E+01 Total 9.48E+01 2.61 E+05

• lsv=100rem

• • 5.06E-02 (person-rem/yr) = 6.30E-06 (fyr) x 8.04E+01 (person-sv) x 100 (remlsv)

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 7 of 33 Table 3 Breakdown of Population Dose by Containment Failure Mode IP2 IP3 Containment Failure Population Percent Population Percent Mode MdDoe Dose Contribution Dose Doe Contribution (person-rem/yr) (person-rem/yr)

Intact containment 0.06 0.06% 0.05 0.05%

Basemat melt-through 4.08 4.67% 2.42 2.56%

Gradual overpressure 28.27 32.35% 16.78 17.70%

Late hydrogen burns 3.55 4.07% 2.11 2.23%

Early hydrogen burns 8.64 9.89% 3.16 3.33%

In-vessel steam explosion 0.57 0.65% 0.21 0.22%

Ex-vessel steam explosion 0.0027 0.00% 0.0010 0.00%

Vessel overpressure 4.10 4.69% 1.50 1.58%

Containment isolation 0.0375 0.04% 0.0137 0.01%

ISLOCA 6.61 7.57% 4.18 4.41%

SGTR 31.46 36.00% 64.35 67.89%

Total 87.4 100 94.8 100

[5] Updated Cost Benefit Analysis Results The cost benefit reanalysis was performed using the MACCS2 results for year 2000. The results are reported in Table 4 for IP2 and in Table 5 for IP3. The assumptions used to determine the change in plant risk that could be realized by implementation of each of the SAMAs originally described in Sections E.2.3 and E.4.3 of the ER and subsequent RAI responses were not altered in ttiis reanalysis. Therefore, the CDF reduction for each SAMA has not been repeated in the tables. The benefit values account for risk reduction in both internal and external events (using multipliers described in Section 4.21.5.4 of the ER) and include the economic impact of lost tourism and business following a severe accident (as discussed in Section [3]). The benefit with uncertainty values account for analysis uncertainties (using multipliers described in Section 4.21.5.4 of the ER). Except as noted with "t" and as described in Section [6], the estimated cost values for SAMA candidates are the same as those reported previously (in Tables E.2-2 and E.4-2 in the ER and References 2 and 3).

[6] Revised Cost Estimates As described in Sections E.2.3 and E.4.3 of the ER, the original SAMA implementation costs were conceptually estimated to the point where conclusions regarding the economic viability of the proposed modification could be adequately gauged. Specifically, in the original analysis, the initial cost estimate for each SAMA was obtained by applying engineering judgment to determine ifthe implementation cost was clearly in excess of the estimated attainable benefit or by applying an existing estimate from a previous SAMA analysis. The engineering judgment cost estimates were conservative i.e. minimum or low cost estimates to implement the SAMA.

NL-09-165 Attachment I Docket Nos. 50-247 & 50-286 Page 8 of 33 A SAMA that appeared to be cost beneficial with the initial implementation cost estimate was subjected to successively more comprehensive and more precise cost estimating to determine if the SAMA was indeed potentially cost beneficial. Only the final cost estimate for each SAMA was reported in the ER.

This method of cost estimating is consistent with NEI 05-01 guidance which states the following.

"As SAMA analysis focuses on establishingthe economic viability of potentialplant enhancement when compared to attainablebenefit, often detailed cost estimates are not requiredto make informed decisions regardingthe economic viability of a particular modification. SAMA implementation costs may be clearly in excess of the attainable benefit estimated from a particularanalysis case. Forless clearcases, engineering judgment may be applied to determine if a more detailed cost estimate is necessaryto formulate a conclusion regardingthe economic viability of a particularSAMA.

Nonetheless, the cost of each SAMA candidate should be conceptually estimated to the point where economic viability of the proposed modification can be adequately gauged.

Forhardware modifications, the cost of implementation may be establishedfrom existing estimates of similarmodifications from previously performed SAMA and SAMDA analyses."

Comparison of Tables 4 and 5 with the tables provided in response to RAI 4e (Reference 2) shows that the benefit obtained from each of the SAMAs (except those with no benefit) has increased in the reanalysis. Consistent with the approach described in NEI 05-01 and used in the original analysis, SAMAs in the reanalysis that appeared to be cost beneficial with the new benefit estimate and the old implementation cost estimate were subjected to more comprehensive and precise cost estimating techniques to determine ifthey are indeed potentially cost beneficial. The cost estimates for SAMAs noted with "t" in Table 4 and Table 5 are those that were developed in more detail.

For example, in the reanalysis, IP3 SAMA 040, "Provide automatic nitrogen backup to steam generator atmospheric dump valves," was estimated to have a benefit with uncertainty of

$344,225 (see Table 5). If this benefit is compared to the original cost estimate of $214,000, IP3 SAMA 040 appears cost beneficial. A more comprehensive plant-specific cost estimate was performed to determine if IP3 SAMA 040 is indeed potentially cost beneficial. This more comprehensive estimate concluded that a modification to provide automatic nitrogen backup to the steam generator atmospheric dump valves at IP3 would actually cost approximately

$950,000 (see Table 5). Since this value is greater than the revised benefit with uncertainty, IP3 SAMA 040 is not potentially cost beneficial.

Also, in the reanalysis IP2 SAMA 062, "Provide a hard-wired connection to an SI pump from ASSS power supply," was estimated to have a benefit with uncertainty of $1,789,822 (See Table 4). If this benefit is compared to the original cost estimate of $722,000, IP2 SAMA 062 appears cost beneficial. The original cost estimate was reviewed and found to have conservatively not included some of the expenses necessary to implement the modification.

Therefore, a more comprehensive cost estimate was performed to determine ifthis SAMA is indeed potentially cost beneficial. This estimate concluded that a modification to provide a hard-wired connection to a safety injection pump from an alternate safe shutdown system power

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 9 of 33 supply would actually cost approximately $1,500,000 (See Table 4). Since the more comprehensive cost estimate is still smaller than the revised benefit, IP2 SAMA 062 is potentially cost beneficial following the reanalysis.

Entergy's standard process for development of conceptual level project estimates was followed for the new, more comprehensive SAMA implementation cost estimates. The estimates capture anticipated expenses by identifying all parts of the organization that must support the proposed SAMA modification from the conceptual perspective. Typical expenses associated with project cost estimating include calculations, drawing updates, specification updates, bid evaluations, contract issuance, design package preparation, walkdowns, planning and scheduling, estimating, procurement, configuration management, as-low-as-reasonably-achievable (ALARA), quality control and quality assurance, training, simulator changes, information technology, design basis update, construction, multi-discipline and independent review of design concepts and calculations, 50.59 review, final safety analysis report (FSAR) update, cost control, contingency, security, procedures, post work testing, and project management and close-out. In addition, the project cost estimates include corporate indirect charges.

N NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 10 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction Benefit with IP2 Phase II SAMA Benefit Uncertainty Estimated Cost Conclusion PDR OECR Uncertainty 001 - Create an Not cost independent ROP seal $374,757 $788,963 $1,137,000 Notect injpnenste R sal 1.60% 1.42%

injection system with a effective dedicated diesel.

002 - Create an seal Not cost independent RCP $350,396 $737,676 $1,000,000 Notect indepeneonste w sal 1.49% 1.42%

injection system without a effective dedicated diesel.

003 - Install an additional 0.00% 0.00% $0 $0 $1,500,000 Not cost CCW pump. effective 004 - Enhance procedural Not cost guidance for use of 0.23% 0.00% $48,723 $102,574 $1,750,000 effective service water pumps.

005 - Improve ability to cool the RHR heat exchangers by allowing 0.34% 0.47% $105,892 $222,931 $565,000 effective manual alignment of the fire protection system.

006 - Add a diesel building 0.11% 0.07% $30,496 $64,202 $274,000 Not cost high temperature alarm. effective 007 - Install a filtered containment vent to 16.70% 6.13% $1,725,939 $3,633,555 $5,700,000 Not cost provide fission product effective scrubbing.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 11 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction Bnftwt IP2 Phase II SAMA RsReut(%)

PDR OE) R Benefit Benefit with Estimated Cost Conclusion Uncertainty 008 - Create a large concrete crucible with heat removal potential 47.03% 34.43% $6,347,528 $13,363,217 $108,000,000 Not cost under the base mat to effective contain molten core debris.

009 - Create a reactor 00-Caty fd sycte. 47.03% 34.43% $6,347,528 $13,363,217 $4,100,000t Retain cavity flooding system.

010 - Create a core melt Not cost source reduction system. 47.03% 34.43% $6,347,528 $13,363,217 $90,000,000 effective 011 - Provide a means to Not cost inert containment. 17.51% 21.23% $3,091,966 $6,509,402 $10,900,000 effective 012 - Use the fire protection system as a Not cost backup source for the 0.00% 0.00% $0 $0 $565,000 effective containment spray system.

013- Install a passive Not cost containment spray 0.00% 0.00% $0 $0 $2,000,000 effective system. effective 014 - Increase the depth of the concrete base mat or use an alternative Not cost concrete material to 11.56% 4.25% $1,194,251 $2,514,214 >$5,000,000 effective ensure melt-through does not occur.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 12 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction Benefit with IP2 Phase IISAMA ( Benefit Uncertainty PDR OECR 015 - Construct a building connected to primary 40.50% 35.38% $5,963,077 $12,553,847 $61,000,000 Not cost containment that is effective maintained at a vacuum.

016 - Install a redundant Not cost containment spray 0.00% 0.00% $0 $0 $5,800,000 effective system.

017 - Erect a barrier that provides containment liner Not cost protection from ejected 10.07% 11.79% $1,742,298 $3,667,996 $5,500,000t effective core debris at high pressure. ._.

018 - Install a highly reliable steam generator shell-side heat removal 0.46% 0.47% $73,618 $154,986 $7,400,000 Not cost system that relies on effective natural circulation and stored water sources.

019 - Increase secondary side pressure capacity Not cost such that a SGTR would 30.21% 39.15% $5,594,541 $11,777,981 >$100,000,00Ot effective not cause the relief valves to lift.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 13 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction Benefit with Estimated Cost Conclusion IP2 Phase IISAMA 6%) Benefit Uncertainty PDR OECR 020 - Route the discharge from the main steam safety valves through a Not cost structure where a water 2.97% 4.25% $580,766 $1,222,665 $9,700,000 effective spray would condense the steam and remove most of the fission products.

021 - Install additional pressure or leak Retain monitoring 11.33% 14.62% $2,093,852 $4,408,109 $3,200,000"t (New) instrumentation for ISLOCAs.

022 - Add redundant and divese imi swiche toRetain eachrselimit switches to 5.72% 7.55% $1,071,465 $2,255,716 $2,200,000t (New) isolation valve.

023 - Increase leak testing Not cost of valves in ISLOCA 5.72% 7,55% $1,071,465 $2,255,716 $7,964,000 effective paths.

024 - Ensure all ISLOCA Not cost releases are scrubbed. 11.33% 14.62% $2,093,852 $4,408,109 $9,700,000 effective 025 - Improve MSIV $476000 Not cost design. 0.57% 0.94% $122,697 $258,310 effective 026 - Provide additional Not cost DC battery capacity. 0.23% 0.00% $48,723 $102,574 >$1,875,000 effective 027 - Use fuel cells Not cost instead of lead-acid 0.23% 0.00% $48,723 $102,574 $2,000,000 effective batteries. I

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 14 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction IP2 Phase II SAMA PDR (%)OECR Benefit Benefit with Estimated Cost Conclusion Uncertainty 028 - Provide a portable diesel-driven battery 9.38% 7.08% $1,357,046 $2,856,939 $938,000t Retain charger.

029 - Increase/improve 0.23% 0.00% $48723 $102574 $460 Not cost DC bus load shedding. 0.23% effective 030 - Create AC power Not cost cross-tie capability with 0.23% 0.00% $56,813 $119,607 $1,156,000 effective other unit.

031 - Create a backup Not cost source for diesel cooling 0.23% 0.00% $40,632 $85,541 $1,700,000 effective (not from existing system).

032 - Use fire protection Not cost system as a backup 0.23% 0.00% $40,632 $85,541 $497,000 effective source for diesel cooling.

033 - Convert under-voltage AFW and reactor protective system 0.00% 0.00% $0 $0 $1,254,000 Not cost actuation signals from 2- effective out-of-4 to 3-out-of-4 logic.

034 - Provide capability Not cost for diesel-driven, low 0.06% 0.05% $8,180 $17,221 >$632,000 effective pressure vessel makeup.

035 - Provide an additional high pressure 0.34% 0.47% $73,529 $154,798 $5,000,000 Not cost injection pump with effective independent diesel.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 15 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction IP2 Phase II SAMA Risk Benefit Benefit with Estimated Cost Conclusion PDR PDR O)C OECR Uncertainty 036 - Create automatic swap-over to recirculation 0.46% 0.7% $134 $291 >$. 0000 Not cost cooling upon RWST 06 .47% $13,34 $21,5 >$1,000,000 effective depletion.

037 - Provide capability Not cost for alternate injection via 0.06% 0.05% $8,180 $17,221 $750,000 effective diesel-driven fire pump. ......

038 - Throttle low pressure injection pumps earlier in medium or large- Not cost break LOCAs to maintain 0.11% 0.07% $22,405 $47,169 $82,000 effective reactor water storage tank inventory.

039 - Replace two of three motor-driven SI pumps Not cost with diesel-powered 0.34% 0.47% $73,529 $154,798 $2,000,000 effective pumps.

040 - Create/enhance a Not cost reactor coolant 3.20% 3.77% $572,408 $1,205,070 $2,000,000t effective depressurization system.

041 - Install a digital feed Not cost water upgrade. 0.92% 0.47% $179,154 $377,167 $900,000 effective 042 - Provide automatic nitrogen backup to steam Not cost generator atmospheric 0.23% 0.00% $16,360 $34,441 $214,000 effective dump valves.

043 - Add a motor-driven Not cost feed water pump. 0.92% 0.47% $179,154 $377,167 $2,000,000 effective

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 16 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction Benefit with IP2 Phase IISAMA (%) Benefit Uncertainty Estimated Cost Conclusion PDR OECR 044 - Use fire water system as backup for 14.19% 9.91% $2,350,530 $4,948,485 $1,656,000 Retain steam generator inventory..

045 - Replace current pilot operated relief valves with larger ones such that only Not cost one is required for 3.32% 1.89% $667,806 $1,405,907 $2,700,000 effective successful feed and bleed.

046 - Modify emergency operating procedures for Not cost ability to align diesel 0.00% 0.00% $0 $0 $82,000 effective power to more air compressors. ._.....

047 - Add an independent Not cost boron injection system. 0.00% 0.00% $0 $0 $300,000 effective 048 - Add a system of relief valves that prevent Not cost equipment damage from a 0.46% 0.47% $105,981 $223,119 $615,000 effective pressure spike during an ATWS.

049 - Install motor Not cost generator set trip breakers 0.23% 0.00% $32,541 $68,508 $716,000 effective in control room.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 17 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction Benefit with IP2 Phase II SAMA Benefit Estimated Cost Conclusion Uncertainty PDR IOECR 050 - Provide capability to remove power from the 0.23% 0.00% $32,541 $68,508 $90,000 Not cost bus powering the control effective rods.

051- Provide digital large Not cost break LOCA protection. 0.00% 0.00% $0 $0 $2,036,000 effective 052 - Install secondary Not cost side guard pipes up to the 1.72% 1.89% $294,384 $619,756 $1,100,000 Notect MSIVs. effective 053 - Keep both pressurizer PORV block 3.32% 1.89% $659,715 $1,388,873 $800,000 Retain valves open.

054 - Install flood alarm in the 480V switchgear 39.24% 28.77% $5,591,781 $11,772,170 $200,000 Retain room.

055 - Perform a hardware modification to allow high- Not cost head recirculation from 0.00% 0.00% $0 $0 $1,330,000 effective either RHR heat exchanger.

056 - Keep RHR heat exchanger discharge 0.23% 0.00% $48,723 $102,574 $82,000 Retain motor operated valves (MOVs) normally open.

057 - Provide DC power 0.46% 0.47% $89,800 $189,052 $376,000 Not cost backup for the PORVs. I IIIIeffective

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 18 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction Benefit with IP2 Phase II SAMA enefit Bencertaint B%_ Estimated Cost Conclusion PDR OECR 058 - Provide procedural guidance to allow high- Not cost head recirculation from 0.00% 0.00% $0 $0 $82,000 effective either RHR heat exchanger.

059 - Re-install the low pressure suction trip on the AFW pumps and 0.23% 0.00% $24,450 $51,474 $318,000 Not cost enhance procedures to effective respond to loss of the normal suction path.

060 - Provide added protection against flood propagation from 8.92% 6.60% $1,275,337 $2,684,920 $216,000 Retain stairwell 4 into the 480V switchgear room.

061 - Provide added protection against flood propagation from the 19.34% 14.15% $2,754,991 $5,799,982 $192,000 Retain deluge room into the 480V switchgear room.

062 - Provide a hard-wired connection to an 6.06% 4.25% $850,165 $1,789,822 $1,500,000t Retain SI pump from ASSS (New) power supply.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 19 of 33 Table 4 Results of Cost Benefit Analysis of IP2 SAMA Candidates Risk Reduction Benefit with IP2 Phase II SAMA __ (%6) Benefit Uncertainty Estimated Cost Conclusion PDR OECR 063 - Provide a water-tight door for additional Not cost protection of the RHR 0.11% 0.00% $32,452 $68,320 $324,000 effective pumps against flooding.

064 - Provide backup cooling water source for Not cost the CCW heat 0.23% 0.00% $40,632 $85,541 $710,000 effective exchangers.

065 - Upgrade the ASSS to allow timely 39.24% 28.77% $5,591,781 $11,772,170 $560,000 Retain restoration of seal injection and cooling.

066 - Harden the EDG building and fuel oil Not cost transfer pumps against 8.96% 6.19% $2,505,846 $5,275,465 $33,500,000$ effective tornados and high winds.

067 - Provide hardware connections to allow the Not cost primary water system to 0.02% 0.00% $9,727 $20,477 $576,000 effective cool the charging pumps.

068 - Provide independent source of cooling for the Not cost recirculation pump 0.06% 0.01% $13,408 $28,227 $710,000 effective motors.

t Cost estimate revised from what was previously reported. See Section [6] for more information.

I NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 20 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Benefit with IP3 Phase IISAMA Risk Benefit U wcinty Estimated Cost Conclusion PDR OECR 001 - Create an independent RCP seal 0.74% 0,38% $236,610 $342,913 $1,137,000 Not cost injection system with a effective dedicated diesel.

002 - Create an independent RCP seal 0.63% 0.38% $201,222 $291,626 $1,000,000 Not cost injection system without a effective dedicated diesel.

003 - Install an additional Not cost CCW pump. 0.00% 0.00% $0 $0 $1,500,000 effective 004 - Improved ability to cool the RHR heat Not cost 0.53% 0.38% $130,575 $189,240 $565,000 effective exchangers by allowing manual alignment of the fire protection system.

005 - Install a filtered containment vent to Not cost provide fission product 9.60% 2.68% $1,497,163 $2,169,801 $5,700,000 effective scrubbing.

006 - Create a large concrete crucible with heat removal potential 24.16% 14.94% $5,038,071 $7,301,552 $108,000,000 Not cost under the base mat to effective contain molten core debris.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 21 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Benefit with Estimated Cost Conclusion P3 Phase IISAMA )Benefit Uncertainty PDR OECR 007 - Create a reactor Retain cavity flooding system. 24.16% 14.94% $5,038,071 $7,301,552 $4,100,0001 (New) 008 - Create a core melt 14.94% $5,038,071 $7,301,552 $90,000,000 Not cost 008u-rCreateuactore mte 24.16%

source reduction system. I effective 009 - Provide means to Not cost inert containment. 8.76% 9.20% $2,412,095 $3,495,790 $10,900,000 effective 010 - Use the fire protection system as a Not cost backup source for the 0.00% 0.00% $0 $0 $565,000 effective containment spray system.

011 - Install a passive Not cost containment spray 0.00% 0.00% $0 $0 $2,000,000 effective'-

system.

012 - Increase the depth of the concrete base mat or use an alternative Not cost concrete material to 5.59% 1.53% $867,404 $1,257,107 >$5,000,000 effective ensure melt-through does not occur.

013 - Construct a building connected to primary $61,000,000 Not cost containment that is 21.73% 15.71% $4,883,602 $7,077,683 effective maintained at a vacuum.

014 - Install a redundant Not cost containment spray 0.00% 0.00% $0 $0 $5,800,000 effective system. I

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 22 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Benefit with P3 Phase II SAMA (Benefit Estimated Cost Conclusion

___ ___ __ ___ __ P OR OECR _ _ _ _

barrier that 015 - Erect a provides containment liner Not cost 4.32% 4.21% $1,140,695 $1,653,182 $5,500,000t effective protection from ejected core debris at high pressure.

016 - Install a highly reliable steam generator shell-side heat removal Not cost system that relies on 5.27% 4.98% $1,401,717 $2,031,473 $7,400,000 effective natural circulation and stored water sources.

017 - Increase secondary side pressure capacity Not cost 53.64% $13,520,698 $19,595,215 >$100,000,000t efet Not such that an SGTR would 45.15% effective not cause the relief valves to lift.

018 - Route the discharge from the main steam safety valves through a 11.08% 13.41% $3,327,028 $4,821,779 $12,000,000t effective structure where a water -

spray would condense the steam and remove most of the fission products.

019 - Install additional pressure or leak 7.07% 8.43% $2,126,663 $3,082,120 $2,800,0001" (New) monitoring instrumentation for ISLOCAs.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 23 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Bnftwt IP3 Phase II SAMA Risk Benefit Uncertainth Estimated Cost Conclusion OECR UncyPDR and 020 - Add redundant diverse limit switches to 3.59% 4.21% $1,069,272 $1,549,670 $4,000,000t Not cost each containment effective isolation valve.

021 - Increase leak testing Not cost 3.59% 4.21% $1,069,272 $1,549,670 $10,604,000 of valves in ISLOCA paths. _effective 022 - Ensure all ISLOCA 7.07% 8.43% $2,126,663 Not cost releases are scrubbed. $3,082,120 $9,700,000 effective 023 - Improve MSIV Not cost design. 0.00% 0.00% $0 $0 $476,000 effective 024 - Provide additional Not cost DC battery capacity. 0.11% 0.00% $47,141 $68,320 >$1,875,000 effective 025 - Use fuel cells Not cost 0.11% 0.00% $47,141 $68'320 $2,000,000 effect instead of lead-acid effective batteries.

026 - Increase/ improve Not cost DC bus load shedding. 0.11% 0.00% $47,141 $68,320 $460,000t effective 027 - Create AC power Not cost 0.11% 0.00% $70,647 $102,387 $1,156,000 effect cross-tie capability with effective other unit.

028 - Create a backup Not cost 0.03% 0.00% $15,318 $22,199 $1,700,000 effective source for diesel cooling effective (not from existing system). N 029 - Use fire protection system as a backup 0.03% 0.00% $15,318 $22,199 $497,000 Not cost effective source for diesel cooling.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 24 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Bnftwt IP3 Phase 1I SAMA Ris Benefit Uncertainty Estimated Cost Conclusion PDR OECR 030 - Provide a portable Not cost diesel-driven battery 0.95% 0.38% $213,363 $309,222 $938,000t effective charger.

031 - Convert under-voltage, AFW and reactor Not cost protective system 0.53% 0.38% $118,822 $172,206 $1,254,000 effective actuation signals from 2-out-of-4 to 3-out-of-4 logic.

032 - Provide capability Not cost for diesel-driven, low 0.21% 0.00% $23,764 $34,441 >$632,000 effective pressure vessel makeup.

033 - Provide an additional high pressure 0.42% 0.38% $118,693 $172,019 $5,000,000 Not cost injection pump with effective independent diesel.

034 - Create automatic Not cost swap-over to recirculation 1.27% 0.77% $530,551 $768,914 >$1,000,000 effective upon RWST depletion.

035 - Provide capability Not cost for alternate injection via 0.21% 0.00% $23,764 $34,441 $750,000 effective diesel-driven fire pump.

036 - Throttle low pressure injection pumps earlier in medium or large- 0.00% 0.00% $11,753 $17,033 $82,000 Not cost break LOCAs to maintain effective reactor water storage tank inventory.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 25 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Benefit with IP3 Phase IISAMA (%) Benefit Un in Estimated Cost Conclusion PDR OECR 037 - Replace two of three motor-driven SI pumps Not cost with diesel-powered 0.42% 0.38% $118,693 $172,019 $2,000,000 effective pumps.

038 - Create/enhance a Not cost reactor coolant 0.95% 0.77% $237,516 $344,225 $4,600,000 effective depressurization system. I 039 - Install a digital feed Not cost water0.95% 0.00% $271,481 $393,450 $900,000 effective 040 - Provide automatic backup to steam nitrogengnrtramshrc 0.95% 0.77% $237,516 $344,225 $950,00?Offctv Not cost generator atmospheric effective dump valves.

041 - Add a motor-driven Not cost feedwater pump. 0.95% 0.00% $271,481 $393,450 $2,000,000 effective 042 - Provide hookup for portable generators to power the turbine-driven 0.11% 0.00% $47,141 $68,320 $1,072,000 effective AFW pump after station batteries are depleted.

043 - Use fire water system as backup for 1.58% 1.15% $450,490 $652,885 $1,656,000 Not cost steam generator effective inventory.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 26 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Benefit with IP3 Phase IISAMA (%) Benefit Uncertainty Estimated Cost Conclusion PDR OECR 044 - Replace current pilot operated relief valves with larger ones such that only 4.75% 4.21% $1,246,989 $1,807,230 $2,700,000 Not cost one is required for effective successful feed and bleed. _

045 - Add an independent 0.00% 0.00% $0 $0 $300,000 Not cost boron injection system. 0.0% _000 effective 046 - Add a system of relief valves that prevent 0.00% $224,210 $324,943 $615,000 Not cost equipment damage from a 0.74%

pressure spike during an ATWS.

047 - Install motor effective generator set trip breakers 0.11% 0.00% $35,388 $51,287 $716,000 effective in control room.

048 - Provide capability to remove power from the 0.11% 0,00% $35,388 $51,287 $90,000" Not cost bus powering the control effective rods.

049 - Provide digital large 0.00% 0.00% $0 $0 $2,036,000cost break LOCA protection. 0.0% 0.0 $0_$0 $2,036,000 effective 050 - Install secondary Not cost 9.07% 8.81% $2,447,095 $3,546,515 $9,671,000tt effective side guard pipes up to the effective MSIVs. Not cost 051 - Operator action:

0.11% 0.00% $23,635 $34,254 $55,000 effective Align main feedwater for effective secondary heat removal.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 27 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Benefit with IP3 Phase II SAMA (%) Benefit Uncertainty Estimated Cost Conclusion PDR OECR 052 - Open city water supply alteratvevalve for Rti fo 1.05% 0.77% $249,398 $361,446 $50,000 Retain alternative AFW pump suction.

053 - Install an excess flow valve to reduce the 2.07% 1.51% $498,795 $722,892 $228,000 Retain risk associated with hydrogen explosions.

054 - Provide DC power 0.00% 0.00% $0 $0 $376,000 Not cost backup for the PORVs. _ _ effective 055 - Provide hard-wired connection to a SI or RHR pump from the 18.35% 11.49% $4,073,152 $5,903,118 $1,288,000 Retain Appendix R bus (MCC 312A).

056 - Install pneumatic controls and indication for Not cost the turbine-driven AFW 0.11% 0.00% $47,141 $68,320 $982,000 effective--

pump.

057 - Provide backup cooling water source for 0.21% 0.00% $59,023 $85,541 $109,000 Not cost the CCW heat effective exchangers.

058 - Provide automatic Not cost DC power backup. 0.21% 0.00% $94,282 $136,640 $1,868,000 effective

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 28 of 33 Table 5 Results of Cost Benefit Analysis of IP3 SAMA Candidates Risk Reduction Benefit with IP3 Phase 11SAMA (%0) Benefit Uncertainty Estimated Cost Conclusion PDR OECR 059 - Provide hardware connections to allow the Not cost primary water system to 0.00% 0.00% $0 $0 $576,000 effective cool the charging pumps.

060 - Provide independent Not cost source of cooling for the 0.00% 0.00% $0 $0 $710,000 effective recirculation pump motors..

061allow to timely the ASSS

- Upgrade restoration of seal 19.73% 12.26% $4,359,371 $6,317,929 $560,000 Retain injection and cooling.

062 - Install flood alarm in the 480 VAC 19.73% 12.26% $4,359,371 $6,317,929 $196,800 Retain switchgear room.

• IP3 SAMA 048 - Cost as corrected in response to RAI 4e (Reference 2) t Cost estimate revised from what was previously reported. See Section [6] for more information.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 29 of 33 (7] Main Steam Safety Valve Gagging SAMA (Updated Response to Round 2 RAI 6)

The benefit associated with installing a device to gag a stuck-open main steam safety valve following a steam generator tube rupture (SGTR) was originally assessed in response to Round 2 RAI 6 (Reference 3). In that response, the estimated benefit with uncertainty assuming that this SAMA is fully successful in preventing all thermally-induced steam generator tube ruptures was almost $3 million for IP2 and over $4 million for IP3. As indicated in that response, with an estimated cost of $50,000, this additional SAMA is potentially cost beneficial and it has been submitted for engineering project cost benefit analysis for more detailed examination of viability and implementation cost. With the revised meteorological input data used for the SAMA reanalysis, the total benefit of this SAMA is now estimated to be about $13 million for IP2 and $19 million for IP3.

[8] TI-SGTR Sensitivity Analysis (Revised Response to Round 2 RAI 5)

In response to Round 2 RAI 5 (Reference 3), a sensitivity study was performed to determine the impact of applying values derived from NUREG-1570. The TI-SGTR sensitivity study was performed again, as described below, to determine the impact of applying NUREG-1570 values to the SAMA reanalysis and provide an updated response to Round 2 RAI 5.

The full lists of IP2 and IP3 Phase II SAMAs were reviewed for impact. Of those, the following twenty-seven IP2 SAMAs and twenty-two IP3 SAMAs were identified as potentially impacted by the TI-SGTR assumption.

IP2 SAMAs: 1, 6, 18, 19, 20, 25, 26, 27, 28, 29,30, 31, 32, 35, 39, 40, 42, 44, 46, 52, 54, 59, 60,61,62,65,66 IP3 SAMAs: 1, 16, 17, 18, 23, 24, 25, 26, 27, 28, 29, 30, 33, 38, 40, 42, 43, 55, 56, 58, 61, 62 Since IP2 SAMAs 28, 44, 54, 60, 61, 62 and 65 and iP3 SAMAs 55, 61 and 62 were previously determined to be potentially cost beneficial, they were not re-evaluated. Of the remaining SAMAs, those for which the implementation cost outweighed the benefit by less than a factor of five were re-evaluated. This screening criterion was applied to facilitate the re-evaluation by limiting it to those potentially impacted SAMA candidates with a realistic possibility of becoming cost beneficial. The appropriateness of this screening criterion is justified by the fact that only one of the twelve SAMAs evaluated was found to be potentially cost beneficial following this conservative sensitivity analysis. See paragraph prior to Table 6 for discussion of conservatism.

The SAMAs re-evaluated were:

IP2 SAMAs: 1, 6, 25, 29, 40, 52 IP3 SAMAs: 1, 16, 18, 30, 40, 43 The baseline case (Table 5.8 of NUREG-1 570) associated with moderate tube degradation was used for this sensitivity study. The full conditional induced SGTR value (0.25) shown for that case was used. The NUREG-1570 conditional probability was applied to all high/dry sequences in the Level 2 model for each unit; in both station blackout and transient sequences. The benefit values in this sensitivity analysis included the additional impact of the loss of tourism and business. Tables 6 and 7 show the values for the IP2 and IP3 SAMAs evaluated in this

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 30 of 33 sensitivity analysis. While the severe accident costs of both the baseline case and the individual SAMAs increased, the extent to which the revised TI-SGTR assumption impacted the benefit varied, based on the nature of the specific SAMA.

IP3 SAMA 18 was found potentially cost beneficial as a result of this sensitivity analysis.

Although the NUREG-1 570 baseline case values were used for this sensitivity analysis, the baseline case applies to a steam generator with a moderate flaw distribution. The IP2 and IP3 steam generators have been replaced and are being maintained in accordance with the stringent standards recommended by NEI 97-06. The IP2 and IP3 steam generators have only 0.19% and 0.12% of the tubes plugged, and would be classified as "pristine" in accordance with generic criteria established by Westinghouse for categorizing steam generator tube integrity.

Corrosion has not been observed in either the IP2 or IP3 steam generators. Therefore, use of the baseline case for this sensitivity study is conservative relative to application of the NUREG-1570 results for pristine generators (Table 5.8, Case 8).

Table 6 - IP2 TI-SGTR Sensitivity Results Original TI-SGTR Revised IP2 Phase IISAMA Benefit with Benefit with Estimated Cost Conclusion

,._Uncertainty Uncertainty 001 - Create an independent RCP seal $788,963 $892,287 $1,137,000 Not cost injection system with a effective dedicated diesel.

006 - Add a diesel building $64,202 $223,493 $274,000 Not cost high temperature alarm. effective Not cost

$258,310 $430,516 $476,000 effective 025 - Improve MSIV design.

029 - Increase/improve DC Not cost bus load shedding. $102,574 $257,560 $460,000t effective 040 - Create/enhance a reactor coolant $1,205,070 $1,325,614 $2,000,000t effective depressurization system.

052 - Install secondary side Not cost guard pipes up to the $619,756 $878,065 $1,100,000 effective MSIVs.

t Cost estimate revised from what was previously reported. See Section [6] for more information.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 31 of 33 Table 7 - IP3 TI-SGTR Sensitivity Results Original TI-SGTR Revised IP3 Phase IISAMA Benefit with Benefit with Estimated Cost Conclusion Uncertainty Uncertainty 001 - Create an independent RCP seal $342,913 $480,678 $1,137,000 Not cost injection system with a effective dedicated diesel.

016 - Install a highly reliable steam generator shell-side Not cost heat removal system that $2,031,473 $2,289,783 $7,400,000 effective relies on natural circulation and stored water sources.

018 - Route the discharge from the main steam safety valves through a Retain structure where a water $4,821,779 $14,637,545 $12,000,000t (New) spray would condense the steam and remove most of the fission products.

030 - Provide a portable Not cost diesel-driven battery $309,222 $515,869 $938,000t effective charger.

040 - Provide automatic nitrogen backup to steam $344225 $950,000t Not cost generator atmospheric effective dump valves. L 043 - Use fire water system Not cost as backup for steam $652,885 $825,091 $1,656,000 effective effective generator inventory.

t Cost estimate revised from what was previously reported. See Section [6] for more information.

[9] Conclusion In the SAMA reanalysis using a conservatively representative, single year of meteorological data (2000), the following additional three SAMA candidates were found to be potentially cost beneficial for mitigating the consequences of a severe accident for IP2 (in addition to those previously designated as cost beneficial in Section 4.21.6 of the ER and References 2 and 3).

021 - Install additional pressure or leak monitoring instrumentation for interfacing system loss of coolant accidents (ISLOCAs) 022 - Add redundant and diverse limit switches to each containment isolation valve 062 - Provide a hard-wired connection to a safety injection (SI) pump from the alternate safe shutdown system (ASSS) power supply

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 32 of 33 In the SAMA reanalysis using a conservatively representative, single year of meteorological data, the following three SAMA candidates were found to be potentially cost beneficial for mitigating the consequences of a severe accident for IP3 (in addition to those previously designated as cost beneficial in Section 4.21.6 of the ER and References 2 and 3).

007 - Create a reactor cavity flooding system 018 - Route the discharge from the main steam safety valves through a structure where a water spray would condense the steam and remove most of the fission products (cost beneficial in TI-SGTR sensitivity in Section (8])

019 - Install additional pressure or leak monitoring instrumentation for ISLOCAs As described in the aging management review results for the integrated plant assessment presented in Sections 3.1 through 3.6 of the license renewal application, IP2 and IP3 have programs for managing aging effects for components within the scope of license renewal (Reference 1). Since these programs are sufficient to manage the effects of aging during the license renewal period without implementation of the above SAMA candidates for IP2 and IP3, these potentially cost beneficial SAMAs need not be implemented as part of license renewal pursuant to 10 CFR Part 54. However, consistent with those SAMAs identified previously as cost beneficial, the above potentially cost beneficial SAMAs have been submitted for engineering project cost benefit analysis.

Since some of the potentially cost beneficial SAMAs address the same risk contributors, implementation of an optimal subset of these SAMAs could achieve a large portion of the total risk reduction at a fraction of the cost, and render the remaining SAMAs no longer cost beneficial.

IP2 SAMAs 54, 65, and the main steam safety valve gagging SAMA have the highest priority for implementation due to their potential for significant nsk reduction and relatively low implementation cost (cost estimate is less than 20% of the benefit with uncertainty). SAMAs 9, 21, 28, 44, 53, and 56 would have second priority based on their potential for risk reduction and their mitigation of plant risk contributors not addressed by the highest priority SAMAs. The remaining potentially cost beneficial SAMAs (22, 60, 61, and 62) are considered lowest priority because their benefit and cost estimates are similar or because their benefit is expected to be reduced significantly if the higher priority SAMAs are implemented.

IP3 SAMAs 52, 61, 62, and the main steam safety valve gagging SAMA have the highest priority for implementation due to their potential for significant risk reduction and relatively low implementation cost (cost estimate is less than 20% of the benefit with uncertainty). SAMAs 7, 53, and 55 would have second priority based on their potential for risk reduction and their mitigation of plant risk contributors not addressed by the highest priority SAMAs. The remaining potentially cost beneficial SAMAs (18 and 19) are considered lowest priority because their benefit and cost estimates are similar or because their benefit is expected to be reduced significantly if the higher priority SAMAs are implemented.

NL-09-165 Attachment 1 Docket Nos. 50-247 & 50-286 Page 33 of 33

[10] MACCS2 Input Files The following MACCS2 input files, used in the analysis described above, are provided in electronic format.

Filename Description siteiec.inp site input file with loss of tourism and business metiO0.inp meteorological data for year 2000 chrbiec.inp chronc input file with loss of tourism and business earbi-noE.inp early input file atmbi2ns.inp atmos input file for IP2 atmbi3ns.inp atmos input file for IP3

[11] References

1. Entergy Letter NL-07-039, Indian Point Energy Center License Renewal Application, April 23, 2007

2. Entergy Letter NL-08-028, Reply to Request for Additional Information Regarding License Renewal Application - Severe Accident Mitigation Alternatives Analysis, February 05, 2008

3. Entergy Letter NL-08-086, Supplemental Reply to Request for Additional Information Regarding License Renewal Application - Severe Accident Mitigation Alternatives Analysis, May 22, 2008

4. NEI 05-01, Severe Accident Mitigation Alternatives (SAMA)Analysis Guidance Document [Revision A], November 2005

5. Entergy Letter NL-09-151, Entergy Nuclear Operations Inc. Telephone Conference Call Regarding Met Tower Data for SAMA Analysis Indian Point Nuclear Generating Unit Nos. 2 & 3, November 16, 2009

6. Procedures for Substituting Values for Missing NWS Meteorological Data for Use in Regulatory Air Quality Models, Dennis Atkinson and Russell F. Lee, July 7, 1992

[May be found on the "Meteorological Guidance" page at epa.gov.]

7. Severe Accident Mitigation Alternatives Analysis Applicant's Environmental Report for License Renewal, Calvert Cliffs Nuclear Power, April 1998.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-247-LR and

) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )

)

(Indian Point Nuclear Generating Units 2 and 3) )

.) December 14, 2009 CERTIFICATE OF SERVICE I hereby certify that copies of the letter entitled "Notification of Entergy's Submittal of the SAMA Reanalysis Using Alternate Meteorological Tower Data for Indian Point Units 2 and 3," dated December 14, 2009, were served this 14th day of December, 2009 upon the persons listed below, by first class mail and e-mail as shown below.

Administrative Judge Administrative Judge Lawrence G. McDade, Chair Kaye D. Lathrop Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 190 Cedar Lane E.

U.S. Nuclear Regulatory Commission Ridgway, CO 81432 Washington, DC 20555-0001 (E-mail: kdl2gnrc.gov)

(E-mail: lgmlgnrc.gov)

Administrative Judge Office of the Secretary*

Richard E. Wardwell Attn: Rulemaking and Adjudications Staff Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission (E-mail: hearingdocketgnrc, gov)

Washington, DC 20555-0001 (E-mail: rewknrc.gov)

Office of Commission Appellate Adjudication Zachary S. Kahn, Law Clerk U.S. Nuclear Regulatory Commission Josh Kirstein, Law Clerk Mail Stop: O-16G4 Atomic Safety and Licensing Board Panel Washington, DC 20555-0001 Mail Stop: T-3 F23 (E-mail: ocaamailgnrc.gov) U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: zxkl (@nrc.gov)

(E-mail: Josh.Kirsteingnrc.gov)

Sherwin E. Turk, Esq. Greg Spicer, Esq.

Beth N. Mizuno, Esq. Office of the Westchester County Attorney David E. Roth, Esq. 148 Martine Avenue, 6th Floor Brian G. Harris, Esq. White Plains, NY 10601 Andrea Z. Jones, Esq. (E-mail: gsslwestchestergov.com)

Office of the General Counsel Mail Stop: 0-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: set@nrc.gov)

(E-mail: bnml )nrc.gov)

(E-mail: david.roth@nrc.gov)

(E-mail: brian.harrisgnrc.gov)

(E-mail: andrea.jones@nrc.gov)

Manna Jo Greene Thomas F. Wood, Esq.

Environmental Director Daniel Riesel, Esq.

Hudson River Sloop Clearwater, Inc. Ms. Jessica Steinberg, J.D.

112 Little Market Street Sive, Paget & Riesel, P.C.

Poughkeepsie, NY 12601 460 Park Avenue (E-mail: mannai o@clearwater.org) New York, NY 10022 (E-mail: driesel(2sprlaw.com)

(E-mail: isteinberg(osprlaw.com)

Stephen C. Filler, Board Member John Louis Parker, Esq.

Hudson River Sloop Clearwater, Inc. Regional Attorney 303 South Broadway, Suite 222 Office of General Counsel, Region 3 Tarrytown, NY 10591 NYS Dept. of Environmental Conservation (E-mail: sfillergnylawline.com) 21 S. Putt Comers Road New Paltz, New York 12561-1620 (E-mail: j lparker(gw.dec.state.ny.us)

Ross Gould, Member Michael J. Delaney, V.P. - Energy Hudson River Sloop Clearwater, Inc. New York City Economic Development 10 Park Avenue, #5L Corp.

New York, NY 10016 110 William Street (E-mail: rgouldesqcgmail.com) New York, NY 10038 (E-mail: mdelaney@nycedc.com)

Phillip Musegaas, Esq. Daniel E. O'Neill, Mayor Deborah Brancato, Esq. James Siermarco, M.S.

Riverkeeper, Inc. Liaison to Indian Point 828 South Broadway ... Village of Buchanan Tarrytown, NY 10591 Municipal Building (E-mail: phillip@riverkeeper.org) 236 Tate Avenue (E-mail: dbrancatogriverkeeper.org) Buchanan, NY 10511-1298 (E-mail: vob(bestweb.net)

Robert D. Snook, Esq. Mylan L. Denerstein, Esq.

Assistant Attorney General Executive Deputy Attorney General, Office of the Attorney General Social Justice State of Connecticut Office of the Attorney General 55 Elm Street of the State of New York P.O. Box 120 120 Broadway, 2 5th Floor Hartford, CT 06141-0120 New York, New York 10271 (E-mail: Robert. Snookgjpo.state.ct.us) (E-mail: Mylan. DenersteinCoag.state.ny.us)

Andrew M. Cuomo, Esq. Janice A. Dean Attorney General of the State of New York Office of the Attorney General John J. Sipos, Esq. of the State of New York Charlie Donaldson.Esq. Assistant Attorney General Assistants Attorney General 120 Broadway, 26th Floor The Capitol New York, New York 10271 Albany, NY 12224-0341 (E-mail: Janice.Dean(d-oag.state.ny.us)

(E-mail: John.sipos(2oag.state.ny.us)

Joan Leary Matthews, Esq.

Senior Attorney for Special Projects Office of the General Counsel New York State Department of Environmental Conservation 625 Broadway, 14th Floor Albany, NY 12207 (E-mail: ilmattheggw.dec.state.ny.us)

Original and 2 copies provided to the Office of the Secretary.

Martin J. O'Neill, Esq.

Counsel for Entergy Nuclear Operations, Inc.

DB 1/6410302 1.1