Letter Sequence Response to RAI |
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Category:Letter type:NL
MONTHYEARNL-21-034, Notification of Expected Date of Transfer of Ownership of Nuclear Units to Holtec Indian Point 2, LLC and Holtec Indian Point 3, LLC; and Notification of Receipt of All Required Regulatory Approvals2021-05-26026 May 2021
Notification of Expected Date of Transfer of Ownership of Nuclear Units to Holtec Indian Point 2, LLC and Holtec Indian Point 3, LLC; and Notification of Receipt of All Required Regulatory Approvals
NL-21-039, Response to Request for Additional Information - License Amendment Request to Revise the Indian Point Nuclear Generating Unit No. 3 Licensing Basis to Incorporate the Installation and Use of a New Auxiliary2021-05-20020 May 2021
Response to Request for Additional Information - License Amendment Request to Revise the Indian Point Nuclear Generating Unit No. 3 Licensing Basis to Incorporate the Installation and Use of a New Auxiliary
NL-21-033, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel2021-05-11011 May 2021
Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel
NL-21-032, Termination of Emergency Response Data System Feed to the U.S. Nuclear Regulatory Commission at Indian Point Energy Center2021-05-11011 May 2021
Termination of Emergency Response Data System Feed to the U.S. Nuclear Regulatory Commission at Indian Point Energy Center
NL-21-005, Cancellation of Commitments Related to Beyond-Design-Basis External Events Seismic and Flooding Actions2021-05-11011 May 2021
Cancellation of Commitments Related to Beyond-Design-Basis External Events Seismic and Flooding Actions
NL-21-030, Submittal of 2020 Annual Radiological Environmental Operating Report2021-05-0606 May 2021
Submittal of 2020 Annual Radiological Environmental Operating Report
NL-21-027, Registration of Spent Fuel Cask Use2021-04-20020 April 2021
Registration of Spent Fuel Cask Use
NL-21-021, Registration of Spent Fuel Cask Use2021-04-19019 April 2021
Registration of Spent Fuel Cask Use
NL-21-017, Pre-Notice of Disbursement from Decommissioning Trusts2021-04-0808 April 2021
Pre-Notice of Disbursement from Decommissioning Trusts
NL-21-010, Submittal of 2020 Annual Fitness for Duty Program Performance Data Report and Fatigue Management Program Data Report2021-02-17017 February 2021
Submittal of 2020 Annual Fitness for Duty Program Performance Data Report and Fatigue Management Program Data Report
NL-21-006, Relief Request IP3-ISI-RR-16, Proposed Alternative to American Society of Mechanical Engineers Code Case N-513-4 Inspection Requirement2021-02-10010 February 2021
Relief Request IP3-ISI-RR-16, Proposed Alternative to American Society of Mechanical Engineers Code Case N-513-4 Inspection Requirement
NL-21-014, Response to 2nd Round Request for Additional Information - License Amendment Request to Revise the Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device2021-01-26026 January 2021
Response to 2nd Round Request for Additional Information - License Amendment Request to Revise the Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device
NL-20-082, Notice of Planned Transfer of Decommissioning Funds2020-12-14014 December 2020
Notice of Planned Transfer of Decommissioning Funds
NL-20-081, Pre-Notice of Disbursement from Decommissioning Trusts2020-12-0909 December 2020
Pre-Notice of Disbursement from Decommissioning Trusts
NL-20-080, Report in Accordance with 10 CFR 71.95(a) for Failure to Comply with Certificate of Compliance No. 71-93212020-11-19019 November 2020
Report in Accordance with 10 CFR 71.95(a) for Failure to Comply with Certificate of Compliance No. 71-9321
NL-20-079, (IP2 and IP3) - Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic2020-11-12012 November 2020
(IP2 and IP3) - Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic
NL-20-077, Submittal of Quality Assurance Program Manual Revision 22020-11-0909 November 2020
Submittal of Quality Assurance Program Manual Revision 2
NL-20-078, Response to Requests for Additional Information - License Amendment Request to Revise the Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device2020-11-0909 November 2020
Response to Requests for Additional Information - License Amendment Request to Revise the Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device
NL-20-076, Revision of Commitment Related to Nuclear Reactor Safeguards Interim Compensatory Measure - Section B.5.b Issue Regarding Spent Fuel Dispersal2020-11-0202 November 2020
Revision of Commitment Related to Nuclear Reactor Safeguards Interim Compensatory Measure - Section B.5.b Issue Regarding Spent Fuel Dispersal
NL-20-069, One-time Scheduler Exemption Request from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Public Health Emergency2020-10-0808 October 2020
One-time Scheduler Exemption Request from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Public Health Emergency
NL-20-070, Response to Requests for Additional Information, License Amendment Request to Revise the Indian Point Nuclear Generating Unit No. 3 Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device2020-10-0202 October 2020
Response to Requests for Additional Information, License Amendment Request to Revise the Indian Point Nuclear Generating Unit No. 3 Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device
NL-20-067, Redacted Version of Response to U.S. Nuclear Regulatory Commission Region I Letter Regarding Algonquin Incremental Market Project Pipeline2020-09-16016 September 2020
Redacted Version of Response to U.S. Nuclear Regulatory Commission Region I Letter Regarding Algonquin Incremental Market Project Pipeline
NL-20-064, 10 CFR 50.59(d)(2) Summary Report of Changes, Tests and Experiments2020-09-0101 September 2020
10 CFR 50.59(d)(2) Summary Report of Changes, Tests and Experiments
NL-20-060, Status of Remaining Actions for Generic Letter 2004-022020-08-11011 August 2020
Status of Remaining Actions for Generic Letter 2004-02
NL-20-057, Cancellation of Commitment Related to Large Break LOCA Reanalysis2020-07-30030 July 2020
Cancellation of Commitment Related to Large Break LOCA Reanalysis
NL-20-0851, 30-Day 10 CFR 21 Notification - Continuously Energized Eaton D26 Relays Could Fail to Deenergize Because of an Organic C3 Insulating Material2020-07-22022 July 2020
30-Day 10 CFR 21 Notification - Continuously Energized Eaton D26 Relays Could Fail to Deenergize Because of an Organic C3 Insulating Material
NL-20-051, Submittal of Quality Assurance Program Manual, Revision 1 for the Indian Point Energy Center2020-07-0707 July 2020
Submittal of Quality Assurance Program Manual, Revision 1 for the Indian Point Energy Center
NL-20-052, Unsatisfactory 10 CFR 26 Fitness-For-Duty Blind Performance Testing Results2020-07-0707 July 2020
Unsatisfactory 10 CFR 26 Fitness-For-Duty Blind Performance Testing Results
NL-20-012, Application to Revise Provisional Operating License and Technical Specifications2020-06-30030 June 2020
Application to Revise Provisional Operating License and Technical Specifications
NL-20-050, Response to U.S. Nuclear Regulatory Commission Region I Letter Regarding Algonquin Incremental Market Project Pipeline2020-06-24024 June 2020
Response to U.S. Nuclear Regulatory Commission Region I Letter Regarding Algonquin Incremental Market Project Pipeline
NL-20-041, Registration of Unit 3 Spent Fuel Cask Use2020-05-13013 May 2020
Registration of Unit 3 Spent Fuel Cask Use
NL-20-042, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel2020-05-12012 May 2020
Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel
NL-20-033, Technical Specifications Proposed Change - Permanently Defueled Technical Specifications2020-04-28028 April 2020
Technical Specifications Proposed Change - Permanently Defueled Technical Specifications
NL-20-038, Response to U.S. Nuclear Regulatory Commission Region I Letter Regarding Algonquin Incremental Market Project Pipeline2020-04-23023 April 2020
Response to U.S. Nuclear Regulatory Commission Region I Letter Regarding Algonquin Incremental Market Project Pipeline
NL-20-035, Response to Request for Additional Information - Temporary Exemption Request from 10 CFR Appendix R, Section Iii.H Due to COVID-19 Pandemic2020-04-16016 April 2020
Response to Request for Additional Information - Temporary Exemption Request from 10 CFR Appendix R, Section Iii.H Due to COVID-19 Pandemic
NL-20-034, Temporary Exemption Request from 10 CFR Appendix R, Section Iii.H Due to COVID-19 Pandemic2020-04-13013 April 2020
Temporary Exemption Request from 10 CFR Appendix R, Section Iii.H Due to COVID-19 Pandemic
NL-20-021, Proposed License Amendment to Revise the Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device2020-03-24024 March 2020
Proposed License Amendment to Revise the Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device
NL-20-020, Submittal of 2019 Annual Fitness for Duty Performance Data Report Update2020-02-26026 February 2020
Submittal of 2019 Annual Fitness for Duty Performance Data Report Update
NL-20-015, Submittal of 2019 Annual Fitness for Duty Program Performance Data Report and Fatigue Management Program Data Report2020-02-10010 February 2020
Submittal of 2019 Annual Fitness for Duty Program Performance Data Report and Fatigue Management Program Data Report
NL-20-008, Transmittal of Presentation Slides for Partially Closed Pre-Submittal Meeting to Discuss a Planned License Amendment Request to Replace the Fuel Handling Building Crane2020-01-0606 January 2020
Transmittal of Presentation Slides for Partially Closed Pre-Submittal Meeting to Discuss a Planned License Amendment Request to Replace the Fuel Handling Building Crane
NL-19-094, 2018 Annual 10 CFR 50.46 Emergency Core Cooling System Evaluation Changes Report2019-12-16016 December 2019
2018 Annual 10 CFR 50.46 Emergency Core Cooling System Evaluation Changes Report
NL-19-084, Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments2019-11-21021 November 2019
Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments
NL-19-093, Proposed Technical Specifications (TS) Changes - Indian Point Nuclear Generating Unit 3 TS SR 3.7.7.2 and TS 3.7.6, Required Action A.12019-11-21021 November 2019
Proposed Technical Specifications (TS) Changes - Indian Point Nuclear Generating Unit 3 TS SR 3.7.7.2 and TS 3.7.6, Required Action A.1
NL-19-092, Request for Rescission of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)2019-11-20020 November 2019
Request for Rescission of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
NL-19-043, Request for Partial Exemption from Record Retention Requirements in 10 CFR 50.122019-10-22022 October 2019
Request for Partial Exemption from Record Retention Requirements in 10 CFR 50.12
NL-19-073, Request for Relaxation of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)2019-10-22022 October 2019
Request for Relaxation of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
NL-19-078, Supplement to Technical Specifications Proposed Change - Permanently Defueled Technical Specifications2019-10-22022 October 2019
Supplement to Technical Specifications Proposed Change - Permanently Defueled Technical Specifications
NL-19-091, Independent Spent Fuel Storage Installation (Isfsi), Registration of Spent Fuel Cask Use2019-10-17017 October 2019
Independent Spent Fuel Storage Installation (Isfsi), Registration of Spent Fuel Cask Use
NL-19-090, Registration of Unit 2 Spent Fuel Cask Use2019-10-0909 October 2019
Registration of Unit 2 Spent Fuel Cask Use
NL-19-079, 50.59(d)(2) Summary Report of Changes, Tests and Experiments2019-09-26026 September 2019
50.59(d)(2) Summary Report of Changes, Tests and Experiments
2021-05-06
[Table view] |
Text
Ein Entrg Enterqy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 Lawrence Coyle Site Vice President NL-15-069 May 20, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Response to Request for Additional Information Regarding License Amendment to Permanently Extend the Frequency of the Containment Integrated Leak Rate Test (TAC NO. MF3369)
Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26
REFERENCES:
- 1. NRC Letter to Entergy, Request for Additional Information Regarding Licensing Amendment to Permanently Extend the Frequency of the Containment Integrated Leak Rate Test (TAC NO. MF5382), dated May 6, 2015
- 2. Entergy Letter NL-14-128 to NRC Regarding Proposed License Amendment Regarding Extending the Containment Type A Leak Rate Testing Frequency to 15 years, dated December 9, 2014 (ML14353A015)
Dear Sir or Madam:
Entergy Nuclear Operations, Inc., (Entergy) is hereby providing the attached response to the NRC request for additional information, Reference 1, associated with the proposed changes to the Indian Point 2 Technical Specifications (TS) in Reference 2. The response to the request for additional information is provided in Attachment 1.
No new Regulatory Commitment is made in this submittal.
A copy of this response and the associated Attachments is being submitted to the designated New York State official in accordance with 10 CFR 50.91.
Abl-7
NL-15-069 Docket No. 50-247 Page 2 of 2 If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.
I declare under penalty of perjury that the foregoing is true and correct. Executed on May __,
2015.
Sincerely,
Attachment:
Response to Request for Additional Information Regarding License Amendment to Permanently Extend the Frequency of the Containment Integrated Leak Rate Test cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. Daniel Dorman, Regional Administrator, NRC Region 1 NRC Resident Inspectors Office Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service)
ATTACHMENT TO NL-15-069 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT TO PERMANENTLY EXTEND THE FREQUENCY OF THE CONTAINMENT INTEGRATED LEAK RATE TEST ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247
NL-15-069 Docket No. 50-247 Attachment Page 1 of 2 In order to complete their review of the Entergy request for Technical Specification Amendment to extend the Containment Type A leak test the Probabilistic Risk Assessment Licensing Branch has requested additional information. These requests and Entergy's responses follow:
Probabilistic Risk Assessment Licensing Branch Question 1 Nuclear Energy Institute (NEI) 94-01, Revision 2-A (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100620847), "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," states that plant specific confirmatory analyses are required when extending the Type A integrated leak rate test (ILRT) interval beyond ten years and that the assessment should be performed using the approach and methodology described in Electric Power Research Institute (EPRI) Technical Report (TR) 1009325, Revision 2-A 1 , "Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals" (ADAMS Accession No. ML14024A045).
EPRI TR 1009325, Revision 2-A, does not address plant-specific probabilistic risk assessment (PRA) quality. In the U.S. Nuclear Regulatory Commission (NRC) safety evaluation report, dated June 25, 2008 (ADAMS Accession No. ML081140105), the NRC staff stated, in part, that:
Licensee requests for a permanent extension of the ILRT surveillance interval to 15 years pursuant to NEI TR 94-01, Revision 2, and EPRI Report No. 1009325, Revision 2, will be treated by NRC staff as risk-informed license amendment requests. Consistent with information provided to industry in Regulatory Issue Summary 2007-06, "Regulatory Guide 1.200 Implementation," the NRC staff will expect the licensee's supporting Level 1/[large early release frequency] LERF PRA to address the technical adequacy requirements of RG 1.200, Revision 1 ... Any identified deficiencies in addressing this standard shall be assessed further in order to determine any impacts on any proposed decreases to surveillance frequencies. If further revisions to RG 1.200 are issued which endorse additional standards, the NRC staff will evaluate any application referencing NEI TR 94-01, Revision 2, and EPRI Report No. 1009325, Revision 2, to examine if it meets the PRA quality guidance per the RG 1.200 implementation schedule identified by the NRC staff.
According to Regulatory Issue Summary 2007-06, the NRC staff expects that licensees fully address all scope elements with Revision 2 of Regulatory Guide (RG) 1.200 (ADAMS Accession No. ML090410014) by the end of its implementation period (i.e., one year after the issuance of Revision 2). RG 1.200, Revision 2, endorses, with exceptions and clarifications, the combined American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) PRA standard (ASME/ANS RA-Sa-2009).
In the application dated December 9, 2014 (ADAMS Accession No. ML14353A015) the licensee stated that "An internal comparison of the ASME standard to the combined ASME/ANS standard confirmed that there were few substantive changes to the internal events portion of the standard, although the expected level of documentation was increased in some cases." However, based on this statement alone, it is unclear if a full gap assessment (i.e., for each of the supporting requirements) was performed for the Indian Point Nuclear Generating Unit No. 2 (IP2) internal events PRA model to the latest endorsed version of the PRA standard.
NL-15-069 Docket No. 50-247 Attachment Page 2 of 2 Given that the implementation date of RG 1.200, Revision 2, was April 2010 and the license amendment request application was submitted in December 2014, identify and address any gaps between the IP2 PRA model used in this application and the RG 1.200, Revision 2, requirements that are relevant to this submittal, or explain why addressing the requirements would have no impact on this application.
Response
No gaps have been identified between the IP2 PRA model used in this application and the RG 1.200, Revision 2, requirements that are relevant to this submittal. Section A.4 of Attachment 3 in the IP2 ILRT submittal (NL-14-128) has the following statement:
A PRA technicaladequacy evaluation was performed consistent with the requirements of RG-1.200, Revision 2. This evaluation combined with the details of the results of this analysis demonstrates with reasonable assurancethat the proposed extension to the ILRT interval for IP2 and IP3 to fifteen years satisfies the risk acceptance guidelines in RG 1.174.
At the time the IP2 PRA model used for the ILRT submittal was developed, ASME/ANS RA-Sa-2009 had not yet been issued. Therefore, the self-assessment was performed using the latest ASME PRA Standard at that time (i.e., ASME RA Sb-2005). However, ASME/ANS RA-Sa-2009 had been issued by the time of the RG 1.200 peer review. Although the internal events self-assessment was performed based on ASME RA Sb-2005, the actual RG 1.200 peer review was performed using ASME/ANS RA-Sa-2009 given that the difference between the two versions of the PRA standard were primarily editorial in nature. Therefore, the disposition of RG 1.200 findings in Table A.2-1 of the ILRT submittal pertains to supporting requirements in ASME/ANS RA-Sa-2009.
(This can be seen by observing that the findings in Table A.2-1 associated with the internal flooding analysis are associated with supporting requirements that did not exist until the release of ASME/ANS RA-Sa-2009).
1 EPRI TR-1009325, Revision 2-A, is also identified as EPRI TR-1018243.
