ML14258A180
| ML14258A180 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/08/2014 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML14258A180 (9) | |
Text
1 IPRenewal NPEmails From:
Wentzel, Michael Sent:
Monday, September 08, 2014 4:13 PM To:
Bob Walpole (rwalpol@entergy.com)
Subject:
Draft RAIs re: Indian Point SAMA Cost Estimates Attachments:
Draft Indian Point SAMA RAIs - 09814.docx
- Bob, Ive attached a draft copy of RAIs related to the NRCs review of Entergys revised SAMA cost estimates.
Please let me know if you feel a clarifying phone call would be helpful prior to issuance.
- Thanks, Mike Michael Wentzel Project Manager NRR/DLR/RPB2 (301) 415-6459 michael.wentzel@nrc.gov
Hearing Identifier:
IndianPointUnits2and3NonPublic_EX Email Number:
4614 Mail Envelope Properties (C0A338EE37A11447B136119705BF9A3F0214F9B561D4)
Subject:
Draft RAIs re: Indian Point SAMA Cost Estimates Sent Date:
9/8/2014 4:13:19 PM Received Date:
9/8/2014 4:13:21 PM From:
Wentzel, Michael Created By:
Michael.Wentzel@nrc.gov Recipients:
"Bob Walpole (rwalpol@entergy.com)" <rwalpol@entergy.com>
Tracking Status: None Post Office:
HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 386 9/8/2014 4:13:21 PM Draft Indian Point SAMA RAIs - 09814.docx 110713 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 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 FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW - REFINED COST ESTIMATE (TAC NOS. MD5411 AND MD5412)
Dear Sir or Madam:
By letter dated April 23, 2007, Entergy Nuclear Operations, Inc. (Entergy), submitted an application and associated environmental report pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 51 and 10 CFR Part 54, to renew the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff documented its findings related to the environment review of Entergys license renewal application in Supplement 38 to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS)
(SEIS), which was issued in December 2010. In June 2013, NRC issued a supplement to the final plant-specific Supplement to the GEIS. The 2013 supplement to the final SEIS included corrections to impingement and entrainment data presented in the final SEIS, revised conclusions regarding thermal impacts based on newly available thermal plume studies, and an update of the status of the NRC's consultation under section 7 of the Endangered Species Act with the National Marine Fisheries Service regarding the shortnose sturgeon and Atlantic sturgeon.
By letter dated May 6, 2013, you provided refined engineering project cost estimates for the 22 potentially cost-beneficial severe accident mitigation alternatives (SAMAs) previously identified in your revised SAMA analysis. The NRC staff is reviewing the updated information and has identified in the enclosed enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.
Items in the enclosure were discussed with Ms. Dara Gray, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-287-9249, or by e-mail michael.wentzel@nrc.gov.
Sincerely, Michael Wentzel, 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/encl: Listserv
- concurred via email OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR NAME IKing MWentzel BWittick MWentzel DATE 9/2/14
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW (TAC NOS. MD5411 AND MD5412)
DISTRIBUTION:
HARD COPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRerb Resource RidsNrrDlrRsrg Resource RidsNrrDraAfpb Resource RidsOgcMailCenter Resource MWentzel MGray, RI DLogan ABurritt, RI BWittick DonaldJackson, RI DWrona GMeyer, RI DPickett MModes, RI STurk, OGC NSheehan, RI OPA BMizuno, OGC DScrenci, RI OPA DRoth, OGC DTifft, RI BHarris, OGC NMcNamara, RI SBurnell, OPA GNewman, RI DMcIntyre, OPA JSStewart, RI EDacus, OCA AmiPatel, RI
ENCLOSURE REQUESTS FOR ADDITIONAL INFORMATION RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW DRAI 1 You explained that the refined cost estimates incorporate a site encumbrance premium to reflect NRC-imposed site access restrictions, including security and personnel access training and controls, some of which were not in effect when the initial conceptual cost estimates were prepared. In the refined cost estimates, a site encumbrance of 20 percent is added to the subtotal for each severe accident mitigation alternatives (SAMAs).
Please provide the basis for the value used as the site encumbrance premium, e.g., its based on historical costs attributed to security-related activities associated with modifications made at the site. In addition, explain why the premium is levied against all aspects of the modification, especially materials. Lastly, indicate if the addition of the premium is applied for all cost estimates for all modifications planned at the site (i.e., not just the SAMAs).
DRAI 2 For each of the refined cost estimates, loaders of 30 percent are applied; however, no explanation is provided for what is included in the loaders.
Please explain what is included in the term loaders, and provide a basis for the value. Also indicate if loaders are applied for all cost estimates for all modifications planned at the site (i.e., not just the SAMAs).
DRAI 3 For work that is conducted during outages, a factor of 1.7 is applied to the labor.
Please provide a brief explanation for the use of this factor, the basis for the value used as the factor, and indicate if the application of this factor is a standard practice for Entergy for all cost estimates associated with modifications at the site.
DRAI 4 For several of the labor categories, various values are used for the same labor category.
However, an explanation for the labor categories is not given. Therefore, the staff cannot readily determine why different labor rates are used for the same labor category. A list of the labor categories of interest and values used is given below. Please explain the difference for the labor rates used for the same labor category.
Labor Categories Rate in Refined Cost Estimates (Inflated to 2014)
Craft Labor Categories LB 78.15, 78.65, 78.50, or 76.46 OP 115.00 or 100.00 PF 120.71 or 106.40 EL 123.32 or 111.84 FW 53.60 or 50.53 PL 100.00, or (60.00 or 80.00 for EL but listed as plant to develop electrical procedures for IP2-028)
Non Manual Labor Categories -- Implementation/Installation Support sys engineering -- civil structural 100.00 (except for SAMA IP2-009 uses 150.00)
Project Management 120.00 (or 100.00)
HP/RP/ALARA 100.00, 80.00, or 79.56 Contractor Support Mods planning & sch - SWEC (Incl Per Diem) 100.00 or 80.00 QA/QC verification 80.00 or 75.00 Safety (2%)
68.00 or 72.14 If, from your review of the labor rates, you determine that your refined cost estimates should be adjusted, please indicate which cost estimates are affected, and if such an adjustment would alter your conclusion about the economic feasibility of the SAMA.
DRAI 5 For several of the SAMAs (e.g., IP2-021, IP2-022, IP2-028, IP2-044), on the Impact Screening Summary (Attachment 9.3 to EN-DC-115), the Nuclear Analysis item is checked YES, indicating that the proposed modification involves changes to plant evaluations, Technical Specifications, Technical Requirements Manual, or a full 50.59 evaluation. However, it does not appear that a cost for this activity has been included. In contrast, for SAMA IP2-009, the Nuclear Analysis item is checked YES, yet a cost of $81,000 (675 hours0.00781 days <br />0.188 hours <br />0.00112 weeks <br />2.568375e-4 months <br />) was included for Tech Specs/FSAR, Analysis Calcs. Yet for other SAMAs (e.g., IP-054, IP2-061), an assumption on the Implementation Estimate states that the estimate does not include funding for unreviewed safety questions or NRC submittals, but if required, the additional cost will be added. Please indicate if a cost for such an evaluation should have been included. Also explain why this activity/task was treated differently for the SAMAs.
If from your review of the cost information you determine that your refined cost estimates should be adjusted to account for a nuclear analysis, please indicate which cost estimates are affected, and if such an adjustment would alter your conclusion about the economic feasibility of the SAMA.
DRAI 6 For several of the SAMAs (e.g., IP2-028, IP2-053, IP2-062), on the Impact Screening Summary (Attachment 9.3 to EN-DC-115), the Simulator Impact item is checked YES, indicating that the proposed modification impacts or involves changes to the simulator. However, it does not appear that a cost for this activity has been included. In contrast, for SAMAs IP2-054, IP2-056, IP2-060, IP2-061, and IP3-062, the Simulator Impact item is checked YES, and a cost was included for Simulator Changes. For those SAMAs where the item is checked YES but a cost was not included, please indicate if a cost for simulator changes should have been included. Also explain why this activity/task was treated differently for the SAMAs.
If from your review of the cost information you determine that your refined cost estimates should be adjusted to account for a simulator impact, please indicate which cost estimates are affected, and if such an adjustment would alter your conclusion about the economic feasibility of the SAMA.