ML092230093
| ML092230093 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/11/2009 |
| From: | Office of Nuclear Reactor Regulation |
| To: | Division of License Renewal |
| References | |
| Download: ML092230093 (10) | |
Text
IPRenewal NPEmails From: Stuyvenberg, Andrew Sent: Tuesday, August 11, 2009 8:32 AM To: Gray, Dara F Cc: Logan, Dennis; Valerie Cullinan; Ward, Jeffrey A; IPRenewal NPEmails
Subject:
RE: Conference Call Details Attachments: 8-11-09_NRC Conference Call Items.doc Dara -
Attached is the more-detailed description of specific informational issues that I mentioned yesterady. I recognize that your team will not have much time to review it prior to the call, but it may be a useful preface.
The attached document describes in greater depth the two issues from my previous e-mail (items 2 and 3, respectively, on the attached document) and also identifies an additional issue (item 1 in the attachment) that we would like to resolve, if possible, during this conference call.
In addition, during the conference call, please have copies of NL-07-156, as well as the dSEIS comments handy for the discussion (or have them available electronically).
Many thanks, and please let me know if you have any additional questions.
Best regards, Drew From: Stuyvenberg, Andrew Sent: Thursday, August 06, 2009 4:07 PM To: Gray, Dara F Cc: IPRenewal NPEmails
Subject:
Conference Call Details Dara -
The NRC staff biologists have two specific needs in this conference call. Both issues are closely related.
1.) NRC staff has been unable to generate the same impingement densities that Entergy produced in Table C-7 of Entergy's comments on the dSEIS using the data Entergy submitted in NL-07-156.
2.) NRC staff has also been unable to generate the same entrainment densities that Entergy produced in Table C-9 of Entergy's comments on the dSEIS using the data Entergy submitted in NL-07-156.
We're looking to determine whether we've missed something, whether there are differences between the data in NL-07-156 and the data used to produce the dSEIS comments, or whether Entergy has performed additional modifications, calculations, etc. to arrive at the numbers presented in the dSEIS comments. Dennis Logan, our senior biologist on the project, has also indicated that it may be worthwhile to have ASA's programmer for the data supplied in NL-07-156 available on the call, if possible. (If that's possible, and you require an extra line for that person, please let me know at your earliest convenience.)
Please let me know if you need any additional information, and please be in touch if there's anything you'd like to clarify in advance of call.
- Best, Drew 1
Drew Stuyvenberg U.S. Nuclear Regulatory Commission 3014154006 Andrew.Stuyvenberg@nrc.gov 2
Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 1541 Mail Envelope Properties (AC3D8151B0831F4EAFFB2501B87BF90510CBD2C07E)
Subject:
RE: Conference Call Details Sent Date: 8/11/2009 8:32:27 AM Received Date: 8/11/2009 8:32:24 AM From: Stuyvenberg, Andrew Created By: Andrew.Stuyvenberg@nrc.gov Recipients:
"Logan, Dennis" <Dennis.Logan@nrc.gov>
Tracking Status: None "Valerie Cullinan" <valerie.cullinan@pnl.gov>
Tracking Status: None "Ward, Jeffrey A" <ja.ward@pnl.gov>
Tracking Status: None "IPRenewal NPEmails" <IPRenewal.NPEmails@nrc.gov>
Tracking Status: None "Gray, Dara F" <DGray@entergy.com>
Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 2454 8/11/2009 8:32:24 AM 8-11-09_NRC Conference Call Items.doc 773114 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Issue 1. Entergy provided impingement data to NRC in Enclosure 3 to RAI response NL-07-156 dated 12/20/07 (ML080080313; cover letter at ML080080205). The impingement data included in NL-07-156 in file contains estimated numbers of the total seasonal impingement for many taxa. During a May 11, 2009, conference call between NRC staff and Entergy (Summary at ML0914200362), Entergy staff suggested that all of the impingement data may be incorrect and could be divided by the number of days sampled for the given year (paragraph 2 of enclosure 2 to ML0914200362, excerpted in Figure 1) in order to derive correct estimates. However, NRC staff have found that the estimates of the seasonal total number impinged included in NL-07-156 do not match the estimated seasonal total number impingement reported in the annual reports of the Hudson River Ecological Study in the Area of Indian Point (ML080080209, ML080080214, ML080080216, ML080080291, ML080080298, ML080080306), even when NRC staff divides the Entergy-reported values by the number of days sampled (see example in Table 1 and Figure 2). The NRC staff needs to know which data (annual reports, Entergy-supplied, corrected figures, or other data) are correct and what correction values, if any, have been applied to historical data to derive the correct data.
Figure 1. First two paragraphs of Enclosure 2 of ML0914200362.
Winter Spring Summer Fall Total Number of Days Sampled 23 8 11 41 83 ALEWIFE 315 659 3,088 2,662 6,724 BAY ANCHOVY 394 519 21,000 30,717 52,630 AMERICAN SHAD 178 503 3,249 3,043 6,973 BLUEFISH 11,465 4,622 1,247 17,335 HOGCHOKER 567 18,377 12,838 14,217 45,999 STRIPED BASS 2,918 702 15,911 18,663 38,194 Table 1. Estimated combined (EstComb) seasonal total number of fish impinged and the number of days sampled at IP 2 during 1987 from ML080080313 (NRC staff took seasonal values directly from the EstComb field in ML080080313 and summed each seasons results to produce the value in the Total column; numbers rounded to the whole number).
Figure 2. Table 4-1 from Hudson River Ecological Study in the Area of Indian Point 1987 Annual Report; values in the table do not match the values excerpted in Table 1.
Issue 2. Entergys comments on the DSEIS dated March 18, 2009 (ML091040133) included a Review of Strength of Connection Analysis Presented in 2008 NRC DSEIS for Indian Point Nuclear Power Plant as Appendix C. Entergy staff conducted an alternative strength of connection (SOC) analysis based on the same input datasets that NRC staff used in the DSEIS analysis (Figures 3 and 4). The alternative analysis provided, Entergy indicated, consistent measures of impingement and entrainment densities and regional river densities, while removing inappropriate data use. NRC staff has been unable to generate the same impingement densities documented in Table C-7 of Entergys comments on the DSEIS (Table 2 of this document) using the data Entergy submitted in NL-07-156. Unless NRC staff can resolve the apparent data discrepancies, NRC staff may need the annual total of each RIS fish impinged and the volume of water withdrawn during all weeks of sampling for both Units 2 and 3 in order to independently calculate the impingement results provided by Entergy (NL-07-156).
Figure 3. Appendix C of Entergys comments on the DSEIS dated March 16, 2009 page 77 of 129
Figure 4. From Appendix C of Entergys comments on the DSEIS dated March 16, 2009 page 80 of 129
Table 2. Impingement Density from Entergys Comments Appendix C Table C-7 (page 84 of 129) and calculated from impingement data provided in NL-07-156 75th Percentile of Annual Measure of Impingement Density Species from Entergys Comments Appendix C Impingement Density (from Impingement Data Table C-7 (page 84 of 129) following formula from Figure 8)
Alewife 8.6 7.62 American Shad 24 15.11 Atlantic Menhaden 2.3 1.92 Atlantic Sturgeon 0.3 0.30 Atlantic Tomcod 250 205.80 Bay Anchovy 142.9 121.39 Blueback Herring 68.6 55.99 Bluefish 12.1 11.55 Gizzard Shad 8.3 7.20 Hogchoker 47.4 41.88 Rainbow Smelt 11.3 10.52 Shortnose Sturgeon < 0.1 0.02 Spottail Shiner 3.8 2.92 Striped Bass 46.1 42.15 Weakfish 36.6 33.85 White Catfish 4.5 3.91 White Perch 995.6 965.09 Issue 3. In the NRC DSEIS, the staff included measurements of entrainment density as part of the SOC analysis. Entergy included, in Appendix C to their comments, an alternative measure of entrainment density (Figure 5). As a result, Table C-9 of Entergys comments on the DSEIS contained different density results than those developed by the NRC staff. The NRC staff has attempted to generate the same entrainment densities documented in Table C-9 of Entergys comments on the DSEIS, but has been unable to do so using the data provided in NL-07-156 (see Table 4). Unless NRC staff can resolve the apparent data discrepancies, NRC may need the annual total of each RIS fish entrained and volume of water withdrawn for both Units 2 and 3 in order to independently calculate entrainment density rather than relying on the values in NL 156. (Note: As sampling during weeks 2 through 17 occurred only during one year, the NRC staffs calculation of entrainment density included only entrainment data from weeks 18 through
- 32. This is consistent with the approach suggested in Entergys comments.)
Figure 5. Table C-5 from Appendix C of Entergys comments on the DSEIS dated March 16, 2009 page 82 of 129
Table 3. Entrainment Density values from Entergys Comments Appendix C Table C-9 (page 86 of 129) and values calculated by NRC staff from impingement data provided in NL-07-156 75th Percentile of Annual Measure of Entrainment Density from Species Entergys Comments Appendix C Table Entrainment Density (from Entrainment Data C-9 (page 86 of 129) following formula from Figure 9)
Alewife 503500 410077.7 American Shad 4037 600.3 Atlantic Menhaden 177 133.6 Atlantic Sturgeon NA NA Atlantic Tomcod 9904 7871.4 Bay Anchovy 730827 751264.6 Blueback Herring 503500 410077.7 Bluefish 14 4.9 Gizzard Shad NA NA Hogchoker 2449 3133.2 Rainbow Smelt 10773 1801.5 Shortnose Sturgeon NA NA Spottail Shiner 8 5.0 Striped Bass 66607 141334.1 Weakfish 8647 5999.2 White Catfish 14 4.4 White Perch 61793 118587.7