ML080940408

Request for Additional Information Regarding the Review of the License Renewal Application for Indian Point Nuclear Generating Unit Nos. 2 & 3

ML080940408
Person / Time
Site:	Indian Point
Issue date:	04/14/2008
From:	Bo Pham NRC/NRR/ADRO/DLR
To:	Entergy Nuclear Generation Co
Pham B
References
FOIA/PA-2009-0193, TAC MD5411, TAC MD5412
Download: ML080940408 (7)

Text

April 14, 2008 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 REGARDING THE REVIEW OF THE LICENSE RENEWAL APPLICATION FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 (TAC NOS. MD5411 AND MD5412)

Dear Sir or Madam:

By letters to Entergy Nuclear Operation, Inc. (Entergy), dated December 5 and 7, 2008, the U.S.

Nuclear Regulatory Commission (NRC or staff) requested that additional information be provided in order for the staff to complete its review of the license renewal application (LRA) for Indian Point Nuclear Generating Unit Nos. 2 and 3. By letters dated January 4, 10, 30, and February 5, 20, and March 7, 2008, Entergy provided responses to the staffs requests for additional information (RAIs). Upon review of your responses, the staff has identified areas where additional information is needed in order to complete its review.

Enclosed is the staffs RAI regarding refurbishment. As discussed with Mr. Mike Stroud of your staff, we request that you provide your responses to these questions no later than 30 days after the issuance of this letter, in order to facilitate an expeditious review. If you have any questions, please contact me at (301) 415-8450 or at BMP@nrc.gov.

Sincerely,

\\RA\\

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

Enclosure:

As stated cc w/enclosure: See next page

ML080940408 OFFICE LA:DLR PM:DLR:RPB2 OGC BC:DLR:RPB2 NAME SFigueroa BPham STurk RFranovich DATE 04/09/08 04/11/08 04/02/08 04/14/08

Letter to Entergy From B. Pham dated: April 14, 2008 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE LICENSE RENEWAL APPLICATION FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 (TAC NOS. MD5411 AND MD5412)

HARD COPY:

DLR RF E-MAIL:

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Indian Point Nuclear Generating Units 2 and 3 cc:

Senior Vice President Entergy Nuclear Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Vice President Oversight Entergy Nuclear Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety &

Licensing Entergy Nuclear Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President and COO Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Manager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Paul D. Tonko President and CEO New York State Energy Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. John P. Spath New York State Energy, Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspectors Office Indian Point 2 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Senior Resident Inspectors Office Indian Point 3 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. William DiProfio PWR SRC Consultant 48 Bear Hill Road Newton, NH 03858

Indian Point Nuclear Generating Units 2 and 3 cc:

Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001 Mr. Phillip Musegaas Riverkeeper, Inc.

828 South Broadway Tarrytown, NY 10591 Mr. Mark Jacobs IPSEC 46 Highland Drive Garrison, NY 10524 Mr. R. M. Waters Technical Specialist Licensing 450 Broadway P.O. Box 0249 Buchanan, NY 10511-0249 Mr. Sherwood Martinelli 351 Dyckman Peekskill, NY 10566 Ms. Susan Shapiro, Esq.

21 Perlman Drive Spring Valley, NY 10977 John Sipos Assistant Attorney General New York State Department of Law Environmental Protection Bureau The Capitol Albany, NY 12224 Robert Snook Assistant Attorney General Office of the Attorney General State of Connecticut 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Ms. Kathryn M. Sutton, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. Paul M. Bessette, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. Martin J. ONeill, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 The Honorable Nita Lowey 222 Mamaroneck Avenue, Suite 310 White Plains, NY 10605 Joan Leary Matthews Senior Counsel for Special Projects Office of General Counsel NYS Department of Environmental Conservation 625 Broadway Albany, NY 12233-5500

Request for Additional Information (RAI)

Regarding Refurbishment for Indian Point Nuclear Generating Unit Nos. 2 And 3 The staff received scoping comments during its review of the License Renewal Application (LRA) for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) indicating that Entergy had taken steps toward procuring replacement reactor vessel heads for IP2 and IP3 (ADAMS accession nos. ML071990093 and ML073100985). The scoping comments contained excerpts from a presentation by Doosan Heavy Industries indicating that Doosan plans to deliver replacement reactor vessel heads and control rod drive mechanisms (CRDMs) 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.

Entergys 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 Entergys Environmental Report.

During a telephone conference call on March 18, 2008 (ADAMS accession number forthcoming), the staff acknowledged that while there may be no requirement to replace the reactor vessel heads at IP2 and IP3 for license renewal, Section 2.6.1 of the Generic Environmental Impact Statement for License Renewal (GEIS) discusses environmental impact-initiating actions associated with license renewal. These actions include: (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, and (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. Since the GEIS considers refurbishment activities beyond those that are related to aging management during the period of extended operation, Entergys response to the staffs RAI related to refurbishment did not effectively address the scoping comment regarding this potential refurbishment activity.

During the conference call, Entergy indicated that, if license renewal were not being pursued for IP2 and IP3, the vessel head forgings would not have been ordered. Entergy also indicated that the vessel head forgings that were procured for IP2 and IP3 may never be needed, and a decision by Entergy to replace reactor vessel heads for IP2 and/or IP3 has not been made.

Question 1:

In order for the NRC staff to better understand the specific nature of the steps taken by Entergy with respect to its plans for reactor vessel head and CRDM replacement, please identify the factors that Entergy may consider in deciding whether to replace these components. Please describe how those factors affect Entergys decision whether to replace the vessel heads and CRDMs.

ENCLOSURE

Question 2:

The staff recognizes that there is no certainty with respect to reactor vessel head and/or CRDM replacement at IP2 and/or IP3. Therefore, Entergys response to Question 1 above will be duly considered by the staff in determining whether to address the potential environmental impacts of these actions in the upcoming draft Supplemental Environmental Impact Statement.

Nevertheless, based on the information presented in the scoping comment and the conference call discussion with Entergy staff on March 18, 2008, the NRC staff may proceed with a review of the impacts associated with reactor vessel head and CRDM replacement in accordance with 10 CFR 51.71. To facilitate the staffs review and understanding of these impacts, please provide additional information and supporting analysis regarding the Category 1 and Category 2 impacts (as listed in 10 CFR 51 Subpart A, Appendix B, Table B-1) that would be associated with reactor vessel head and CRDM replacement (all issues are listed in Table B-1 and included in Chapter 3 of the GEIS). If Entergy is unable to provide information specifically addressing the likely impacts of replacing vessel heads and CRDMs at IP2 and IP3, please provide impact estimates based on Entergys experience at other plants. If Entergy-specific information is not available, please provide estimates based on industry experience in replacing these components.