NL-14-139, Additional Information Regarding the Request for Review of Entergy Seismic Hazard and Screening Report (CEUS Sites), Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

Additional Information Regarding the Request for Review of Entergy Seismic Hazard and Screening Report (CEUS Sites), Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

ML14310A666
Person / Time
Site:	Indian Point
Issue date:	11/05/2014
From:	Ventosa J Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-14-139
Download: ML14310A666 (3)

Text

Entergy Nuclear Northeast Indian Point Energy Center Entergy 450 Broadway, GSB P. 0. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A Ventosa Site Vice President NL-14-139 November 5, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Additional Information Regarding the Request for Review of Entergy Seismic Hazard and Screening Report (CEUS Sites), Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Indian Point Unit No. 3 Docket No. 50-286 License No. DPR-64

REFERENCES:

1 Entergy letter (NL-14-099) to NRC, Request for Review of Entergy Seismic Hazard and Screening Report (CEUS Sites), Response NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated August 18, 2014 2 Entergy letter (NL-1 3-084) to NRC, Indian Point Nuclear Power Plant Units 2 and 3, Reassessment of the Seismic Core Damage Frequency, dated June 26, 2013 (ML13183A279 & ML13183A280) 3 Entergy letter (NL-14-042) to NRC, Entergy Seismic Hazard and Screening Report (CEUS Sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 31, 2014 (ML14099A111) 4 NRC Letter, Screening and Prioritization Results Regarding Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Seismic Hazard Re-evaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated May 9, 2014 (ML14I 11A147)

NL-14-139 Docket No. 50-286 Page 2 of 3

Dear Sir or Madam:

In Reference 1, Entergy Nuclear Operations, Inc. (Entergy) requested the NRC to review the analyses submitted in References 2 and 3, and revisit its prioritization determination contained in Reference 4. Entergy requested that the prioritization group for the additional IP3 Seismic Risk Evaluation be changed to Priority Group 3. If that is not acceptable, then Entergy requests a Priority Group 2 classification.

The reasoning behind the request was that Entergy had submitted a Reassessment of the Seismic Core Damage Frequency (SCDF) (Reference 2) that showed the SCDF for IP3 is significantly better than previous estimates due to the very conservative approach used in the past. Also, the NRC had noted that a request to review the submittal had not been made when it was sent. This request did not affect the December 2014 Expedited Seismic Evaluation Process submittal planned for IP3 or request an alteration of the schedule for the Group 1 seismic risk evaluation for IP2.

The request noted reasons for the request and the hardships that would result:

• Since the seismic risk evaluation had already been submitted, such a review should provide confidence in the IP3 seismic robustness earlier than otherwise would be obtained in following the 2017 schedule for performance and submittal of another risk evaluation.

• The requested evaluation requires specialized resources which have limited availability and Entergy has three plants categorized in Group 1 and one in Group 2. The re-categorization will allow the more appropriate focus of the limited resources available to perform a seismic risk evaluation on other Entergy plants which do not have IPEEE results which bound the reevaluated seismic hazard.

• Additionally, the Group 1 seismic risk evaluation for IP2 should provide insights concerning the seismic robustness of IP3."

Entergy would like to clarify the hardships associated with the performing the seismic risk analysis of IP2 and IP3 at the same time:

• Entergy and Duke would be the only fleet with 3 priority 1 plants performing SPRAs simultaneously. For Entergy, the priority 1 plants are Indian Point Units 2 and 3 and Pilgrim. For Duke the priority 1 plants are Oconee Units 1, 2 and 3. The Oconee Units were all designed and constructed at basically the same time so the evaluations would be similar whereas Indian Point Units 2 and 3 were several years apart and had some significant design differences. The Pilgrim Unit is of a different design (BWR versus PWR).

" Due to the design differences between IP2 and IP3, there are no economies of scale to be gained by performing the SPRAs at the same time. However, the Structural Sub-contractor for IPEC is performing the IP2 analysis and will be applying the lessons learned to Unit 3, where applicable. We are already using different Structural subcontractors, one subcontractor for IP2/IP3 and another subcontractor for Pilgrim/Palisades. The resources would be moved to the Priority 2 plants (assuming that IP3 is moved to priority 2 or 3) once the priority 1 work is completed.

NL-14-139 Docket No. 50-286 Page 3 of 3

• Similar to resource issues the NRC is experiencing, this has resulted in the position that the IPEEE analyses must be used since resources do not exist to review later submittals, the site resources for supporting and reviewing walk downs and calculations cannot handle two units simultaneously without the potential to compromise quality. The site civil resources are over committed with Fukushima FLEX support and the PRA resource is taxed by an Internal Events PRA upgrade.

• The SPRA vendor, already contracted, is resource limited performing two SPRAs simultaneously and cannot add a third without compromising quality. If IP3 is not categorized as priority group 2 or 3 then an additional contractor would have to be identified resulting in potential differences in the outputs due to differences in practices and procedures between the vendors. This would inhibit the ability to compare the results of the two units directly.

" Entergy is already merging in resources from several SPRA teams. The Industry as a whole is limited to supply sufficient resources to perform the work and still have an independent third party PEER resource available.

Your consideration of this matter is greatly appreciated.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 5, 2014.

Sincerely, JAV/sp cc: Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL Mr. David C. Lew, Acting Regional Administrator, NRC Region I NRC Resident Inspectors Office Mr. John B. Rhodes, President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service