ML11356A305
| ML11356A305 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/22/2011 |
| From: | Bo Pham License Renewal Projects Branch 2 |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML11356A300 | List: |
| References | |
| RAS 21618, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML11356A305 (3) | |
Text
NYS000317 Submitted: December 22, 2011 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 Entergy's January 4, 2008, response to the staff's 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 GElS.
The staff received seeping 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 seeping 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.
Entergy's 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 Entergy's 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 (GElS) 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 Entergy's pressurized-water reactors (PWRs). Entergy staff indicated that they may yet sell their spot(s) in line, or sell the forgings IPCE PA0000150 IPEC PA0000150
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 Entergy staff is additionally uncertain whether-or when-replacement will be necessary. Entergy staff noted, however, that vessel head replacement, should it occur, would likely occur during the renewal term, and that they were unable to indicate with 100% certainty that replacement would not occur. 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. fJ:..s 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 staff's review and understanding of those impacts. The NRC staff also suggested that Entergy staff use the NRC's analysis in Chapter 3 of the GElS as a starting point for Entergy's 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.
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 IPCE PA0000151 IPEC PA0000151
TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION- ENVIRONMENTAL RAJ LIST OF PARTICIPANTS March 18, 2008 PARTICIPANTS AFFILIATIONS Marty _Bortz Entergy Charlie Caputo , Entergy John Curry Entergy Dara Gray Entergy Mike Stroud Entergy Rani Franovich NRC Bo Pham NRC Drew Stuyvenberg NRC ENCLOSURE IPCE PA0000152 IPEC PA0000152