ML093140111

2009/11/02 Indian Point Lr Hearing - Comments on Telecon Summary

ML093140111
Person / Time
Site:	Indian Point
Issue date:	11/02/2009
From:	- No Known Affiliation
To:	Division of License Renewal
References
Download: ML093140111 (4)

Text

IPRenewal NPEmails From: Gray, Dara F [DGray@entergy.com]

Sent: Monday, November 02, 2009 1:33 PM To: Green, Kimberly Cc: STROUD, MICHAEL D; YOUNG, GARRY G

Subject:

Comments on Telecon Summary Attachments: Entergy comments on Draft Telecon Notes.DOC Kim Attached are Entergy's comments on the teleconference summary which Drew Stuyvenberg provided to us on Thursday, October 29, 2009. Per my discussions with Drew, they are being sent to you, since he is on vacation.

We appreciate this opportunity to provide our comments on the summary, especially given the iterative nature of the process to help identify the best data set to be used by staff in their on-going evaluation of Indian Point's aquatic impacts. Please let me know if you have any questions or concerns.

Thank you.

Dara Gray, REM Chemistry/Environmental Indian Point Energy Center (914) 736-8414 DGray@Entergy.com This e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and contain proprietary and confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution, or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify me by telephone and permanently delete the original and any copy of any e-mail and any printout thereof.

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Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 1848 Mail Envelope Properties (DCB622189B67AD49AE39CD3ED1B4D99D05579A49)

Subject:

Comments on Telecon Summary Sent Date: 11/2/2009 1:32:44 PM Received Date: 11/2/2009 1:32:47 PM From: Gray, Dara F Created By: DGray@entergy.com Recipients:

"STROUD, MICHAEL D" <MSTROUD@entergy.com>

Tracking Status: None "YOUNG, GARRY G" <GYOUNG4@entergy.com>

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

Tracking Status: None Post Office: IPCEXETSP001.etrsouth.corp.entergy.com Files Size Date & Time MESSAGE 1196 11/2/2009 1:32:47 PM Entergy comments on Draft Telecon Notes.DOC 31808 Options Priority: Standard Return Notification: Yes Reply Requested: Yes Sensitivity: Normal Expiration Date:

Recipients Received:

DRAFT Telephone Conference Call Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application October 28, 2009 Participants:

Drew Stuyvenberg U.S. Nuclear Regulatory Commission (NRC)

Valerie Cullinan NRC Dara Gray Entergy Nuclear Operations, Inc. (Entergy)

Mike Stroud Entergy Mark Mattson Entergy Susan Ward Entergy Summary:

As a result of ongoing discussions between NRC staff and Entergy regarding the data used to determine fish impingement and entrainment at Indian Point, NRC staff conducted a teleconference with Entergy staff to discuss the NRC staffs new request for data on fish impinged at the Indian Point site. Summaries of previous teleconferences held on August 11 and 19, 2009 are available at ML092570752. Summary data submitted by Entergy in response to previous teleconferences on September 24, 2009 (teleconference summary at ML092570752, response at ML092810351) were the best data available on impingement at the site. As a result on October 28, NRC staff requested that Entergy submit a new data set similar to the data Entergy submitted prior to the NRC staffs publication of the draft SEIS containing, on a seasonal basis for all years of impingement sampling, these best available data.

As previously noted, Entergy has reasonably explained that over-estimates of fish impingement in data submitted to NRC prior to the NRCs publication of the draft SEIS (in ML080080313) were a result of a zero-filling error, whereby the Indian Point impingement SAS data files were designed (to save computer storage space which was limiting in the 1970s) without placeholders to indicate instances where an impingement sample had been collected but zero individuals of a given taxa were captured in that sample. Subsequent analysis of daily average catch per sample using these SAS data files must be preceded by a data processing step that adds a zero catch value for each fish species that could be present in each sample, referred to as zero-filling. Seasonal or annual total catch derived from the average catch per sample from non-zero-filled SAS data files would result in higher numbers of impinged organisms than shown in annual reports.

Entergy indicated that correction for collection efficiency due to the effects of water temperature was also a complicating factor, as a series of different collections had been performed for the previous plant owners in different years and the statistical programs used to produce each annual report were not included in the reports; rather, only the output of those programs was included. Therefore, the computer code specifying the analytical steps used to produce each annual impingement abundance report from the SAS data files (like zero-filling), and any computer code specifying how anomalies such as missing water temperature data were handled, were not available as part of the historical documentation. Even when Entergy attempted to correct for the zero-fill issue, inconsistencies remained. As a result, the data set Entergy submits to NRC will be based on values taken directly from the annual reports of the Hudson River Ecological Study in the Area of Indian Point

The replacement data file newly requested by the NRC staff will derive from the results provided in each annual Indian Point impingement report. Entergy has indicated that the replacement Excel data file will be provided in the same format as the one labeled Imp19811990.csv (12/06/2007) and contain impingement information by Unit (Unit 2 or Unit 3), strata (four seasons), year (1981-1990), and fish taxa. It will include 16 fish taxa (species) plus blue crabs along with annual totals for all fish species combined (i.e., the 16 taxa plus all other taxa combined) and the associated standard error of the estimated number of fish impinged for the annual totals. Standard error for each stratum was not reported in the annual reports, nor was the estimated number impinged for each life stage, and will not be provided in the replacement data file. Remaining fish species (outside of the 16) will be included in a summed total of impinged fish recorded by unit, strata, and year. Entergy indicated that it would deliver the data to NRC by November 26, 2009..

NRC staff indicated that this new data submission may have an effect on the schedule for final SEIS issuance. Staff will review the data when it arrives from Entergy and determine what specific effect this submission may have on the schedule for issuing the final SEIS at that time.