ML081500735

Lr Hearing - Draft Refurb Rai.Doc

ML081500735
Person / Time
Site:	Indian Point
Issue date:	04/03/2008
From:	- No Known Affiliation
To:	Division of License Renewal
References
Download: ML081500735 (4)

Text

IPRenewal NPEmails From: STROUD, MICHAEL D [MSTROUD@entergy.com]

Sent: Thursday, April 03, 2008 12:52 PM To: Bo Pham Cc: 'ALAN B COX'; 'GARRY G YOUNG'; Kimberly Green

Subject:

DRAFT Refurb RAI.doc Attachments: DRAFT Refurb RAI.doc Bo, See attached comment on the draft RAI for refurbishment.

Also, we do not need a phone call to talk about this RAI.

Thanks Mike

<<DRAFT Refurb RAI.doc>>

1

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 120 Mail Envelope Properties (83F82891AF9D774FBBB39974B6CB134F2B72807959)

Subject:

DRAFT Refurb RAI.doc Sent Date: 4/3/2008 12:52:13 PM Received Date: 4/3/2008 12:52:13 PM From: STROUD, MICHAEL D Created By: MSTROUD@entergy.com Recipients:

"'ALAN B COX'" <acox@entergy.com>

Tracking Status: None

"'GARRY G YOUNG'" <GYOUNG4@entergy.com>

Tracking Status: None "Kimberly Green" <Kimberly.Green@nrc.gov>

Tracking Status: None "Bo Pham" <Bo.Pham@nrc.gov>

Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 177 4/3/2008 12:52:13 PM DRAFT Refurb RAI.doc 31296 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Draft 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 Comment [E1]: While CRDMs are mentioned and IP3 in October of 2011 and 2012, respectively. Based on this information, the staff on the Doosan slide, they are not cited in the public comments that are cited via the requested, by letter to Entergy dated December 5, 2007, additional information regarding referenced ML numbers. CRDMs should not be refurbishment. included in the RAI as they are small piece parts that are routinely maintained as spare parts and would not constitute items for Entergys response, dated January 4, 2008, indicated that no reactor vessel head refurbishment.

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 any futurea decision by Entergy to replace reactor vessel heads for IP2 and/or IP3 is as yet uncertainhas 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 eachthose factors affects Entergys decision whether to replace the vessel heads and CRDMs.

Question 2:

The staff recognizes that there may beis 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.