NL-09-033, Response to Safety Evaluation Report with Open Items Related to the License Renewal

Response to Safety Evaluation Report with Open Items Related to the License Renewal

ML090830518
Person / Time
Site:	Indian Point
Issue date:	03/12/2009
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-09-033
Download: ML090830518 (30)

Text

Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB

- Entergy P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 788 2055 Fred Dacimno Vice President License Renewal March 12, 2009 Re: Indian Point Units 2 & 3 Docket Nos. 50-247 & 50-286 NL-09-033 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

. Response to Safety Evaluation Report with Open Items Related To the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3

Reference:

1. NRC letter dated January 15, 2009, "Safety Evaluation Report with Open Items Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3"

2. Entergy letter dated January 27, 2009, "Reply to Request for Additional Information - Miscellaneous Items"

Dear Sir or Madam:

The NRC issued Safety Evaluation Report (SER) (Reference 1) with open items related to the license renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3 to request a review of the SER, verification of its accuracy, and to provide comments and responses to open items to the staff. to this letter provides the Entergy Nuclear Operations, Inc. (ENO) response for Indian Point Unit 2 and 3 to the SER. Responses to open items were previously submitted to the staff for their review in Reference 2 noted above.

There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. R. Walpole, Manager, Licensing at (914) 734-6710.

NL-09-033 Docket Nos. 50-247 & 50-286 Page 2 of 2 I31 declare a O9under penalty of perjury that the foregoing is true and correct. Executed on Sý r Fred R. Dacimo Vice President License Renewal - Comments from Indian Point Units 2 and 3 on License Renewal SER cc: Mr. Bo M. Pham, NRC Environmental Project Manager Ms. Kimberly Green, NRC Safety Project Manager Mr. John P. Boska, NRC NRR Senior Project Manager Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Mark Cox, NRC Senior Resident Inspector, IP2 Mr. Paul Cataldo, NRC Senior Resident Inspector, IP3 Mr. Robert Callender, Vice President, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service

ATTACHMENT I TO NL-09-033 Comments from Indian Point Units 2 and 3 on License Renewal SER ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKETS 50-247 and 50-286

NL-09-033 Attachment I Page 1 of 27 Comments from Indian Point Units 2 and 3 on License Renewal SER Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment No. Section/Pg.# Comment 1 Page ix (table Typo in table Of contents. There is no section 3.3A.2.2 on page 3-328. Remove the 'A'.

of contents) 2 1.1/ First paragraph, the Entergy letter submitting the LRA was dated April 23, 2007, not April 30, 2007.

Pg 1-1 3 01 2.3A.4.5-1/ The last sentence of the 01 description that describes the question states "not already in scope for 10 CFR pg 1-9 54.4(a)(2)." The actual question sent out in the December 30, 2008 letter stated "not already in scope for 10 CFR 54.4(a)(1 ) or (a)(2)".

4 3.0.3.2.15/ Says "the presence of tritium in groundwater would be indicative of a continuing leak..." but that is not Pg 1-11 accurate.

Reword to say that:

An increasing trend of tritium in the groundwater could be indicative of a continuing leak from the spent fuel pool.

5 2.1.3/ Last paragraph, "located outside Tarrytown, New York" appears to be in error. Perhaps "located outside Pg 2-2 Buchanan, New York" would be better.

6 2.1.3.1.1/ The list of information sources for the license renewal scoping and screening process should include the IP2 pg 2-3 and IP3 UFSARs.

7 2.1.3.1.2/ Next to last paragraph (starting, The IP2 and IP3.. .), seventh line is pg 2-4 and IP3 equipment database component and system safety function sheets, the staff concludes The word "component" is out of place here. Unless it is meant to be applied to the equipment database (seems unnecessary), the word should be deleted.

NL-09-033 Attachment I Page 2 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

8 2.1.4/ pg 2-7 The single paragraph of this section contains the following three sentences:

Specifically, the scoping process consisted of developing a list of plant systems and structures, identifying their intended functions, and determining which functions meet one or more of the three criteria pursuant to 10 CFR 54.4(a). The applicant developed the system list using the system functions identified on the IP2 and IP3 safety system function sheets (SSFSs). The applicant obtained additional information on mechanical system functions from the UFSAR, the maintenance rule documents, piping flow diagrams, and DBDs.

The first sentence describes three steps of scoping. The underlined sentence then starts to discuss the first step of developing a list of systems and structures, but segues into the step on function identification without finishing the thought on the first step. Suggest replacing the underlined sentence with the following or something similar:

The applicant developed the list of systems using the equipment database; the list of plant structures was developed from a review of plant layout drawings, maintenance rule documentation, design basis documents, and the UFSARs. Mechanical system functions were identified from the IP2 and IP3 safety system function sheets (SSFSs).

9 2.1.4.1.1/ Add the word "functions" and delete text with strikethrough, so that the second sentence reads as follows:

pg 2-7 With respect to the safety-related criterion, the applicant stated that the safety-related systems and structures functions are initially identified through a review of the SSFSs and then confirmed by a review of the UFSAR, maintenance rule documents, piping flow diagrams, and DBDs, as applicable.

NL-09-033 Attachment I Page 3 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No. _ _ _ _ _

10 2.1.4.1.2/ The discussion of dose criteria applicable to IP2 and IP3 is presented in LRA Section 2.1.1.1 and its pg 2-8 subsections. This multipart discussion has resulted in some confusion in the applicability of the criteria; specifically that 10 CFR 50.67 does not apply to IP2. The third full paragraph on page 2-8 of the draft SER contains the following (middle of paragraph):

The dose criteria are set forth in 10 CFR 100.11 for IP2, as reflected in the LRA. The staff determined that the requirements of 10 CFR 50.67(b)(2), which concern the use of an alternate source term in the dose analysis, are not applicable to IP2 but are applicable to IP3, which has been approved for the use of an alternate source term.

The definition of safety related in section 2.1.1.1 of the LRA which addresses IP2 and IP3 in general terms, includes 10 CFR 50.67. This is correct in that both IP2 and IP3 credit the alternate source term in their dose analyses (see respective UFSARs), and SSC functions needed to meet the dose limits of 10 CFR 50.67 are considered safety functions for both IP2 and IP3. However, in the plant specific definitions of safety related used for SSC classifications, the IP2 definition included 10 CFR 50.67 but the IP3 definition did not. Since the IP3 definition did not include 10 CFR 50.67, this difference was discussed in Section 2.1.1.1.2 of the LRA as recognized by the SER. Since the IP2 definition (and thus, the determination of safety functions and the classification of SSC as safety-related) matched 10 CFR 54.4(a)(1) in this regard, no further discussion was provided in LRA section 2.1.1.1.1.

Suggest changing the text above as follows to correct the characterization of the IP2 dose requirements:

The dose criteria are set forth in 10 CFR 50.67(b)(2) and 10 CFR 100.11 for IP2, as reflected in the LRA.

Although the IP3 CLB definition of "safety-related" did not explicitly include reference to 10 CFR 50.67(b)(2),

the requirements of 10 CFR 50.67(b)(2), which concern the use of an alternate source term in the dose analysis, aFe not applicable to ,P2 but are also applicable to IP3, which has been approved for the use of an alternate source term.

NL-09-033 Attachment I Page 4 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

11 2.1.4.1.3/ In the first line, add "of" between the words "basis its."

pg 2-10 12 2.1.4.2.2/ First full paragraph, third sentence. Delete "Q"from "SER Section 2.3A.3.19Q."

pg 2-15 13 2.3A.2.1.1/ Paragraph 1, line 10: SER states "high-end safety pumps". LRA states "high-head safety injection pumps" pg 2-46 14 2.3A.3.3.2/ In 4 th paragraph, the discussion of RAI 2.3A.2.2-1 does not appear to accurately reflect the actual RAI. It pg 2-59 says the RAI asks applicant to identify systems not in scope for (a)(2) that had nonsafety-related components that were not identified as in scope for (a)(2). All systems not in for (a)(2) will have components that are not identified as in for (a)(2).

15 2.3A.3.3.2/ CCW system, item (d) and (e), Change "four component types" to "five component types" that are identified pg 2-60 in the tables referenced.

16 2.3A.3.11/ 1 st paragraph third sentence; change "IP2" to IP1 (...some associated "IP2" (should be IP1) fire protection pg 2-71 components such as hydrants...)

17 2.3A.3.11.2/ Last paragraph; change LRA-22751 -0 to LRA-227551 -0.

pg 2-74 18 2.3A.3.11.2/ 1st paragraph; add hydrant (#18) to the list of hydrants that are not highlighted. See response to RAI pg 2-79 2.3A.3.11-1 and previous page 2-78.

19 2.3A.3.11.2/ 6 th paragraph starting with "Lubricating oil collection system (...in LRA Section 2.3.3.12 and Tables 3.3.2 pg 2-84 IP2 and 3.3.2-12-1P3...), change table reference from "3.3.2-12-1P2 and 3.3.2-12-1P3" to "2.3.3-12-1P2 and 2.3.3-12-1P3".

20 2.3A.3.11.2/ Editorial, 3rd paragraph; 3 rd sentence starting with (..."Plant Drains" and Tables 2.3.3-18-1P2 and 2.3.3 pg 2-85 IPE...), change last table reference from IPE to IP3.

NL-09-033 Attachment I Page 5 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

21 2.3A.3.11.2/ Last paragraph; 1 st sentence, remove "strainer housings" and "heater housings" from the list that identifies pg 2-85 these component types as "valve body". Strainer housings and heater housings are included as component type "strainer housing" and "heater housing" respectively, in LRA Tables 2.3.3-11-1P2 and 2.3.3-11-1P3&

Reference; response to RAI 2.3A.3.11-2.

22 2.3A.3.11.2/ 2nd paragraph; The paragraph states that heat exchanger (tube) is not a component of the fire protection pg 2-86 systems in IP2 and IP3. IP3 FP - C02 system includes a heat exchanger consisting of a coil (tube) in air, which is addressed in LRA table 2.3.3.12-1P3 as component type "heat exchanger (tube)" with the aging management review results in LRA table 3.3.2-12-1P3.

Remove "heat exchanger (tube)" from this paragraph. See response to RAI 2.3A.3.11-2.

23 2.3A.3.19.2/ Bullet item: integrated liquid waste handling. Need to clarify that the referenced section "11.1.2.1" is UFSAR pg 2-107 (1P2).

24 2.3A.4.1.1/ 1 st paragraph / 7 th line, the flow venturi is to measure flow. Pressure is measured by separate pressure Pg 2-109 transmitters.

25 2.3B.3.11.2/ 4 th paragraph, third sentence should be revised to state that "the foam suppression systems for various pg 2-162 areas in the turbine building meet the scoping criterion of 10 CFR 54.4(a)(3), in addition to 10 CFR 54.4(a)(2)". The last sentence of the paragraph should state that '"the aging management review results for components with an internal environment of air summarized in table 3.3.2-11-1P3 are applicable to the portions of the foam suppression systems normally containing air".

5 th paragraph; in the discussion of the fluid-containing portions of the foam systems for various areas in the turbine building that have been identified as beingq within scope of license renewal, the table referenced "3.3.2-19-1P3" is incorrect. Table "3.3.2-19-20-1P3" is the applicable table for this portion of the system.

26 2.3B.3.17/ 8th paragraph last sentence ... LRA Section 2.3.3.17, page 2.3-141 ... (should be page 2.3-67 not 2.3-141) pg 2-173 and 2-174

NL-09-033 Attachment I Page 6 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.Comn 27 2.3B.3.17/ 1st paragraph references pg 2.3-141, (should be page 2.3-67) pg 2-174 28 2.3B.3.17.2/ Response item (C); The EDG jacket water expansion tanks are 40-gallon. Change 46-gallon to 40-gallon.

pg 2-175 See drawing 9321-H-20283 29 2.3B.3.19/ Says the ammonia/morpholine system supplies ammonia or morpholine for pH control to the condensate pg 2-179 system. While the system's purpose is to supply ammonia or morpholine as stated in the LRA, it may be used to supply alternate water treatment chemicals, such as hydrazine or ethanolamine.

Revise SER to reflect LRA description "The purpose of the ammonia/morpholine addition (AMA) system is to provide..."

30 2.3A.4.1 / The SER states:

Page 2-110 "The applicant stated that an exception to this is the atmospheric dump valves and MSIVs, which close on and 2.3B.4.1 / loss of air but are credited with being re-opened, as necessary, in an accident scenario, using standby Page 2-187 nitrogen in bottles or compressed air stored in accumulators."

The discussion should be revised to state the exception in more general terms as follows.

"The applicant stated that a-n-exceptions to this is-are valves the atmsphe.F,* dump valves; and,S V.. which that close on loss of air but are credited with being re-opened, as necessary, in an accident scenario, using standby nitrogen in bottles or compressed air stored in accumulators."

31 2.3B4.1.1/ 2nd paragraph / 6 th line, the flow venture is to measure flow. Pressure is measured by separate pressure Pg 2-185 transmitters.

32 2.4/ pg 2-196 In the 4th paragraph change the 5 th sentence from, "The staff further confirmed from USFSAR Section 16.12 for IP3 that the liquid waste storage building is a seismic class Ill..." to "The staff further confirmed from UFSAR Section 16.12 for IP3 that the liquid waste storage building is a seismic Class Ill..

NL-09-033 Attachment I Page 7 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.Comn 33 2.4/ pg 2-202 In the paragraph at the very top of the page, change the sentence continued from the previous page from

"...which is exposed to mild environment..." to "...which is exposed to an air-indoor environment...".

34 2.4/ pg 2-218 Change the 3 r" sentence of the last paragraph from "...pressure boundary intended function for the below-grade spent fuel pit wall." to "...pressure boundary intended function for exterior walls below grade, which includes the spent fuel pit wall."

35 2.5.1.1 / page The last bullet for the list of electrical commodities subject to AMR states, "138 kV and 13.8 kV direct burial 2-226 insulated transmission cables." This commodity should not include the 13.8 kV cables, because this belongs with the electrical commodity, "inaccessible medium-voltage (2kV to 35kV) cables not subject to 10CFR 50.49 EQ Requirements."

36 2.5.1.2/ page The reference to UFSAR Section 8.2.1 does not state which unit. This is a quote from IP2 UFSAR, Section 2-227 8.2.1. This quote provides the information for how the Buchanan 138kV Substation is further connected to the grid, but this is not information needed for the IP2 or IP3 connection to the 138 kV Buchanan Substation.

The recommended change from RAI response 2.5-1 (11/16/07) is:

The staff notes that, as discussed in Section 8.1.2.1, "10 CFR 50 Appendix A General Design Criterion 17 -

Electric Power Systems," of the IP2 UFSAR.

The two physically independent circuits supplying offsite power to IP2 are the Buchanan Substation via the Con Edison 138 kV system feeder and the Buchanan 13.8 kV system feeder. The 138 kV system feeder is the primary offsite power source connected to the 6.9 kV buses through the station auxiliary transformer.

The 13.8 kV system feeder is the secondary offsite power source connected to the 6.9 kV buses through the GT autotransformer.

NL-09-033 Attachment I Page 8 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.Comn 37 2.5.1.2 / page The reference to UFSAR Section 8.2.1.1 does not state which unit. This is a quote from IP2 UFSAR, 2-227 Section 8.2.1.1. The first sentence of the quote should be, "Three external sources of standby power are available to Indian Point Unit 2." This quote is from the "Reliability Assurance" section, and is misleading, in the fact that it provides the information for how the Buchanan 138kV Substation is further connected to the grid, but this is not information needed for the IP2 or IP3 connection to the 138 kV Buchanan Substation.

The recommended change from RAI response 2.5-1 (11/16/07) is:

As discussed in Section 8.2.1, "Network Interconnection", and 8.2.3, "Emergency Power - Sources Description," of the IP3 UFSAR.

The two physically independent circuits supplying offsite power to IP3 are the Buchanan Substation via the Con Edison 138 kV system feeder and the Buchanan 13.8 kV system feeder. The 138 kV system feeder is the primary offsite power source connected to the 6.9 kV buses through the station auxiliary transformer.

The 13.8 kV system feeder is the secondary offsite power source connected to the 6.9 kV buses through the GT autotransformer.

NL-09-033 Attachment I Page 9 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

38 2.5.1.2 / page The majority of the response to RAI 2.5-1 NL-07-138, (11/16/07) was omitted from the SER description. The 2-228 RAI response provided UFSAR references for both IP2 and IP3, which were directed at the questions asked.

These are better UFSAR references than those cited in the draft SER.

IP2 UFSAR Section 8.1.2.1, "10 CFR 50 Appendix A General Design Criterion 17 - Electric Power Systems,"

IP3 UFSAR Section 8.2.1, "Network Interconnection", and 8.2.3, "Emergency Power - Sources Description,"

The recommended change from RAI response 2.5-1 (11/16/07) could be added after the UFSAR discussion:

Based on the guidance, the definition of the offsite power source is:

"The offsite power systems of U.S. nuclear power plants consist of a transmission system (grid) component that provides a source of power and a plant system component that connects that power source to a plant's onsite electrical distribution system which powers safety equipment. The staff has historically relied upon the well-distributed, redundant, and interconnected nature of the grid to provide the necessary level of reliability to support nuclear power plant operations."

The Buchanan substation, which includes the 345 kV, the 138 kV, and the 13.8 kV sections, is a key element of the well-distributed, redundant and interconnected grid or transmission system that constitutes the offsite power source for IP2 and IP3. The Buchanan substation provides for the interconnection of multiple sources of power and provides dispatch control for a multiple county transmission network. The multiple power sources are interconnected through switchyard bus, transmission conductors, and breakers within the substation.

NL-09-033 Attachment I Page 10 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

39 2.5.1.2 / page The discussion for RAI 2.5-3 is not complete as it fails to address isolated phase bus. The following 2-228 changes are recommended.

In its response, dated November 16, 2007, the applicant stated that these components electrical splices, terminal blocks, and control cables were included in the commodity group "electrical cables and connections not subject to 10 CFR 50.49 EQ requirements." Thus, these components are subject to an aging management review. Isolated-phase bus is not subiect to an aging management review, because it does not perform an intended function.

40 3.0.3.1.7 / The title of the program used throughout this section should match the title of the program given in the page 3-30 section heading. There are numerous slight variations used throughout the section.

through 3-32 41 3.0.3.1.7/ Operating Experience Second sentence is:

pg 3-32 When implementing this new program, the applicant will consider industry operating and plant-specific operating experience when implementing this program.

Delete one of the underlined phrases.

Also, in first line of following paragraph, "Non-QE" should be "Non-EQ."

42 3.0.3.1.8 / A correction is needed for the statements in the staff evaluation.

page 3-33 "As documented in the report, the staff found that the Non-EQ Insulated Cables and Connections Program Non-EQ Modium Voltage Cable Progrgam elements (1) through (6) are consistent with the hnaccossibo corresponding elements in the GALL Report AMP XI.E1 except for the following area."

NL-09-033 Attachment I Page 11 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Coe Section/Pg.# Comment No.

43 3.0.3.1.9/ UFSAR Supplement Third sentence should be:

pg 3-37 Additionally, the applicant revised these sections for several one-time inspection activities that used the term "components" to replace the term "components" with the term "tanks, pump casings, piping, piping elements and components" as appropriate.

Add underlined words as included in the audit report, since some component types (e.g., tanks and pump casings) are not applicable to all systems.

44 3.0.3.1.11/ Third paragraph. Suggest the following changes to the second sentence:

pg 3-42 The applicant also clarified that the inservice inspection requirements in the 1998 Edition of the ASME Code Section XI, inclusive of the 2000 Addenda, and that this edition of the Codo requires either a surface examination or volumetric examination of the closure studs when they are removed.--4 This is the same examination requirement G6rte-iGR for these studs that is provided in the 2001 Edition of ASME Code Section XI, inclusive of the 2003 Addenda, and with tho guidaco that is providod referenced in GALL AMP XI.M3.

Suggest the following change to the fourth sentence to be consistent with ML081760265:

The staff also noted that, in the applicant's letter of June 11, 2008 (ML081760265), the applicant clarified that the updated Code of Record for IP2 is the 2001 Edition of the ASME Code Section Xl, inclusive of the 2003 Addenda, and that the Code of Record for IP3 is the 1989 Edition of the ASME Code Section X1.

Nottluhiv of the 2000 Addenda.

_________ ___________Note that this change may require a change to the sixth sentence.

NL-09-033 Attachment I Page 12 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

45 3.0.3.1.11/ First full paragraph. Contrary to the discussion starting with the second sentence, the response to audit item pg 3-43 81 is as follows:

Results of testing shown on available test reports for the actual reactor head closure stud and nut material showed an average measured tensile strength value for each heat number < 170ksi.

Documentation of available test results were provided for on-site review.

Although the details presented in the SER were part of the discussion during the audit, this response does not support the SER discussion as written. Suggest attributing discussion to audit and deleting reference to response in letter.

46 3.0.3.1.12/ Fourth bulleted item, last line. "IP2" should be "IP3."

pg 3-46 47 3.0.3.1.12/ Third bulleted item, last line. "IP2" should be "IP3."

pg 3-48 Fourth bulleted item, second line. "97" should be "78."

48 3.0.3.2.1/ 3rd paragraph - Typo should be Aboveground Steel Tank program, instead of "Thermal Aging and Neutron Pg 3-58 Irradiation Embrittlement of Cast Austenitic Stainless Steel".

49 3.0.3.2.2 "The applicantagreedto include loss of preloadas an aging effect and listed the Bolting Integrity Programas Bolting the program used to manage the aging effect. By letter, dated December 18, 2007, the applicantrevised its Integrity commitment and amended the LRA to manage the aging effect of loss of preload."are incorrect statements.

Program / The referenced letter of 12/18/2007 actually states "loss of pre-load is a design-driven effect and not an page 3-60 aging effect requiring management.

This SER statement should be changed to read "The applicant stated that the Bolting Integrity Program includes provisions to manage loss of preload. By letter, dated December 18, 2007, the applicant revised its commitment for implementing the Bolting Integrity Program to explicitly state that the Bolting Integrity Program manages loss of preload."

NL-09-033 Attachment I Page 13 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.Comn 50 3.0.3.2.8 Fire In the third paragraph, the staff refers to audit item 152. The SER discussion is not exactly correct as the Water System audit item requests justification for excluding the jockey pumps from the HP fire water systems and refers to Program / a number of testing documents. These documents are not part of the IP Fire Water System Program page 3-85 proposed for license renewal which is essentially consistent with the NUREG-1801 recommended program.

The jockey pumps were never excluded from the Fire Water System Program. The part of the response to audit item 152 that states that "fire waterjockey pumps support standby operation of the fire water system and are conservatively included in the scope of the license renewal and subject to an AMR. The Fire Water System Programmanages component aging effects [loss of material from internalsurfaces of fire water system components]"adequately characterizes their treatment in the aging management review.

Since the NUREG-1801 program does not specify testing of jockey pumps, the three paragraphs discussing testing of the jockey pumps do not appear relevant to discussion of this program for license renewal.

51 3.0.3.2.9/ 3rd paragraph, last word - Could not locate footnote 2. Should this be footnote 6?

Pg 3-91 52 3.0.3.2.11 / A correction is needed for the following statement in the staff evaluation.

page 3-98 "In LRA Amendment 1, dated December 18, 2007,^Amn,.....Mt 3, dated March 24, 2008, the applicant revised LRA Section B.1.20, "Metal Enclosed Bus Inspection," Program Description, second paragraph, and the enhancements as follows:"

NL-09-033 Attachment I Page 14 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No. __ _ _ _ _

53 3.0.3.2.15 IP2 Spent Fuel Pool Crack/Leak Paths (Audit Item 360)

Structures Monitoring The "presence of tritium in groundwater" is NOT by itself an indicator of a continuing leak. There is tritium Program / remaining in the ground water in the vicinity of the pool as described in the Hydrology Report that Entergy Page 3-123 submitted to NRC in January 2008. This tritium is residual contamination which is expected over time to attenuate away. Suggest revising as follows.

To provide additional indication of potential spent fuel pool leakage, the applicant has committed to test the groundwater in monitoring wells outside the IP2 spent fuel pool for the concentration of tritium, every 3 months. An increasing trend of tritium in the groundwater could be indicative of a continuing leak from the spent fuel pool (Commitment 25).

54 3.0.3.3.1/ Typo. Remove quotes after the word density at the end of the page.

pg 3-134 55 3.0.3.3.2/ In the third paragraph of the staff evaluation, the staff discusses the response to audit item 26 provided in pg 3-137 letter dated December 18, 2007. The comparison requested by the staff in audit item 26 is shown in Attachment 1 to the letter. Consider removing the sentence indicating that the staff "found the response to be unacceptable because it did not answer the question" since the discussion does not clearly identify the applicable question and response or indicate why the response did not answer the question.

Based on the discussion of audit item 26 and its response, it appears the staff asked for the comparison and it was provided as requested.

56 3.0.3.3.2/ In the 2 nd paragraph, change the 2 nd sentence from "The IP2 uses..." to "The IP2 program uses...".

pg 3-138 57 3.0.3.3.4/ In the second and third paragraphs under item 2 near the bottom of the page, two typos were noticed. Add pg 3-156 an 's' to "program" in the second paragraph. In the third paragraph, a word appears to be missing "The staff that the applicant..."

NL-09-033 Attachment I Page 15 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

58 3.0.3.3.4/ Item 10, page 3-165, middle of page paragraph - AMP B.1.35 is the Steam Generator Integrity Program, not pg 3-165 Steam Generator TUBE Integrity Program. This should be corrected in three places in the paragraph.

59 3.0.3.3.7 / (Electrical Review Only) Ensure Open Item 3.0.3.3.7-1 addresses the "U2 offsite power feeder 138 kV page 3-177 underground transmission cable" as committed to in letter NL-08-127 (8/14/08), and discussed in SER section 3.6.2.3, "High Voltage Power Cables".

60 3.0.3.3.7/ Item (1) under staff evaluation - typo "IPNG" should be "IP". Should also change in three other locations pg 3-178 throughout the SER. In the third paragraph in item (1), the phrase "that the applicant had identified" is repeated.

61 3.0.3.3.7/ The list of systems and structures inspected by the PSPM program should also include Main Steam (letter pg 3-177 dated December 18, 2007) and offsite power feeder 138 kV underground transmission cable (letter dated April 14, 2008).

62 3.0.3.3.7/ The issues listed for parameters monitored or inspected are not consistent with Open Item 3.0.3.3.7-1, Part pg 3-180, 1 on page 1-13. Also these questions do not match RAI-3.0.3.3.7-1. For example a question about "fouling" 3-181 was not in the RAI nor is it listed with the open item.

At the top of page 3-181, Open Item 3.0.3.3.7-1 Part 2 is referenced rather than Part 1.

63 3.0.3.3.7/ Section (4) contains discussion of Section 5.5.2 of each technical specification. At the bottom of the page, pg 3-182 the staff states that "...it is not clear to the staff on whether the requirements in TS 5.5.2 for IP2 and TS 5.5.2 for IP3 were being credited to aging management..." The relationship between the aging management PSPM program and program cited in technical specifications was dropped from open item 3.0.3.3.7-1, Part 1 during discussion with the staff. Technical specification requirements for PSPM are not credited with aging management. Consider removing this discussion and open item link.

Section 3.0.3.3.7 should be revised to reflect the latest RAIs and open item list.

NL-09-033 Attachment I Page 16 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

64 3.0.3.3.8/ pg Section (6). Remove reference to the NaOH shipments and house service boiler systems since the program 3-190 only applies to stator cooling water. (Reference audit item 90 in Attachment 1 of Entergy letter dated December 18, 2007.)

65 3.1.2, Table Bottom row, line 3.1.1-30. Entry in AMP in LRA column should include 'Water Chemistry Control - Primary 3.1-1/ and Secondary" pg 3-200 66 3.1.2, Middle row, line 3.1.1-36. Entry in Staff Evaluation column should state "Not applicable" rather than Table 3.1-1/ "Consistent with GALL Report."

pg 3-202 67 3.1.2, Second row, line 3.1.1-74. The entry in the Staff Evaluation column refers to SER Section 3.1.2.1.4. SER Table 3.1-1/ Sections 3.1.2.1.7 and 3.1.2.1.8 should also be referenced since they are also relevant to this table line.

pg 3-210 Also, in the AMP in LRA column, the reference to the One Time Inspection program should be deleted (or at the very least the parenthetical phrase referring to certain other components) The response to Item 209 applied the Steam Generator Integrity program to these "other components" negating the need to specifically mention One Time Inspection. Although as indicated in the LRA, OTI will be used to verify effectiveness of the water chemistry programs, OTI need not be listed to be consistent with the AMP in GALL Report for this line.

68 3.1.2, First row, line 3.1.1-84. Entry in AMP in LRA column should say "Not applicable for IP2" and include 'Water Table 3.1-1/ Chemistry Control - Primary and Secondary and One Time Inspection-for IP3" pg 3-212 69 3.1.2.1.2/ Quoted response in first paragraph. Text with strikethrough shows text deleted from the line 3.1.1-52 of the pg 3-218 LRA. To be consistent, the sentence "Nevertheless, the Bolting Integrity Program ... reactor vessel studs."

should be marked as added text (underlined). Also in this paragraph, "7000F" should be "700°F" in two places.

NL-09-033 Attachment I Page 17 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

70 3.1.2.1.2/ The last part of the top paragraph on the page reads as follows (underlining added):

pg 3-219 The staff finds this to be an acceptable basis for concluding that cracking due to In the staff's SE on WCAP-14574-NP-A dated October 26, 2000, the staff provided it basis that cracking due to SCC does not need to be managed in SA-193 Grade B7 bolting materials if it was confirmed that the materials for the bolting components were procured to either yield strengths less than 150 ksi (considered high yield strengths) or to hardness values less than or equal to 32 on a Rockwell C Hardness scale. The staff finds that the applicant has provided an acceptable basis for concluding that cracking due to SCC is not an agingq effect requiring management for these bolting components because it is consistent with the staff's basis in its SE on WCAP-14574-NPA that cracking of SA-193, Grade B7 would not need to be managed ifthe materials for the bolting components were procured to either yield strengths less than 150 ksi or to hardness values less than or equal to 32 on a Rockwell C Hardness scale.

The first underlined text is not a complete sentence and should be completed or deleted. The text underlined at the end of the paragraph is redundant to the preceding text (assuming first sentence is completed); suggest the preceding text be deleted.

71 3.1.2.1.3/ First full paragraph, last line. Both the IP2 and IP3 CASS pressurizer spray heads are addressed in SER pg 3-221 Section 3.1.2.2.7. Either add IP3 or delete IP2 from the sentence.

72 3.1.2.1.3/ First paragraph describes reactor vessel bottom head drains. There are no reactor vessel bottom head Pg 3-225 drains on either IP2 or IP3.

73 3.1.2.1.5/ In this section there is a discussion of Steam Generator Aux. Feedwater nozzles. There are no Aux.

Pg 3-228 & 3- Feedwater nozzles in IP2 or IP3 Steam Generators. Aux. Feedwater connects to the main feedwater pipe 229 outside containment.

74 3.1.2.2.2/ First full paragraph (beginning LRA Table 3.1-1 ..) Next to last line, add the word "staff" between the words pg 3-237 "the finds."

75 3.1.2.2.13/ Last paragraph, first line. First phrase of sentence (The staff that in.. ) is incomplete.

pg 3-251

NL-09-033 Attachment I Page 18 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

76 3.1.2.2.15/ Second full paragraph (beginning Thus, based on this review.. ). This paragraph is part of the evaluation in pg 3-255 section 3.1.2.2.12 for management of cracking. It should be revised to address the section 3.1.2.2.15 discussion of void swelling, including the relevant GALL references for void swelling.

77 3.1.2.2.16/ Final paragraph of section. Although this will likely be corrected when the open item is resolved, the current pg 3-257 reference to "Open Item 3.1.2-1, Part B" should be to "Open Item 3.1.2-1, Part A."

78 3.2.2.1.2/ Third line from the bottom of the page, "consider potential doe this mechanism." Sentence does not make Pg 3-275 sense. Should say, "installation that doesn't properly consider the potential for this mechanism."

79 Table 3.3-1/ For Item number 3.3.1-26, the LRA states "The Oil Analysis Program manages loss of material in copper pg 3-305 alloy components. The One-Time Inspection Program will be used to confirm the effectiveness of the Oil Analysis Program." The SER list the AMP in LRA column as "not applicable". The programs listed should be Oil Analysis and One-Time Inspection consistent with GALL.

80 Table 3.3-1/ For item number 3.3.1-80, the AMP in LRA item lists both service water integrity and one-time inspection.

pg 3-314 The LRA only uses service water integrity for this line item. One-time inspection should be removed.

81 Section For Item 5; third paragraph, The One-time Inspection Program should be listed with the Bolting Integrity, 3.3.2.2.10/ pg External Surfaces, and Periodic Surveillance and Preventive Maintenance Programs.

3-342 82 Section For Item 2, third paragraph, reference to the "Diesel Fuel Monitoring Program" should be "Oil Analysis 3.3.2.2.12/ pg Program".

3-345 83 3.3A.2.3.12/ In paragraph 2 first sentence, the SER refers to flexible bellows being carbon steel but LRA table 3.3.2 pg IP2 specifies stainless steel as the material for flexible bellows for IP2 security generator.

3-362

NL-09-033 Attachment I Page 19 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.Comn 84 3.3A.2.3.13/ Paragraph 3 first sentence, the SER states that aging effect fouling for carbon steel heat exchanger housing pg exposed to an external environment of air-indoor but LRA table 3.3.2-16-1P2 calls out loss of material.

3-363 Fouling is identified as aging effect for heat exchanger fins. In same paragraph, the reference to GALL item VII.H2-3 applies to heat exchanger shell. These inconsistencies should be resolved.

85 3.3A.2.3.15/ Next to last paragraph, 6 lines from the bottom - remove "for inspected". This line should read "to inspect pg 3-365 for leakage".

86 3.3A.2.3.22/ Paragraph 1 first sentence the SER states that the Water Chemistry Control - Auxiliary Systems Program pg 3-370 utilized but it should be Primary and Secondary.

87 3.3B.2.3.9/ Paragraph 2 first sentence should be filter rather than nozzle.

pg 3-384 88 3.3B.2.3.21/ Paragraph 2 first sentence there are no pump casings or strainer housings with copper alloy shown in LRA pg 3-391 Table 3.3.2-19-13-1P3. Pump casings and strainer housings should be omitted from this paragraph. In paragraph 3, "managing" should be "manage".

89 Table 3.4-1 The "Not applicable to IP2 Steam and Power Conversion System" entry in the Staff Evaluation column is not item 3.4.1-3/ correct and should be deleted. Item 3.4.1-3 is applicable to IP2 Steam and Power Conversion System. See pg 3-405 LRA Table 3.3.2-19-1-1P2, Auxiliary Steam System.

And Section Additionally; 3.4.2.1.1/pg 3-413 In the associated section 3.4.2.1.1, pg 3-413 second paragraph should be revised to include IP2 steam and power conversion system that references item 3.4.1-3. See reference Table listed above.

NL-09-033 Attachment I Page 20 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.Comn 90 Table 3.4-1 The "Not applicable to IP3" entry in the Staff Evaluation column is not correct and should be deleted. Item Item 3.4.1-8/ 3.4.1-8 does apply to IP3. See LRA Table 3.3.2-19-12-1P3.

pg 3-406 And Additionally; Section 3.4.2.2.3/ In the associated section 3.4.2.2.3; pg 3-424 last paragraph should be revised to include IP3 and pg 3-425, pg 3-424 and of the same section, first paragraph should be revised to include IP3 for Item 3.4.1-8. See Table 3.3.2 3-425 12-1P3.

91 Table 3.4-1 LRA Table 3.4.1, Item Number 3.4.1-30, was revised to include carbon steel components, main steam safety Item 3.4.1-30/ valve (MSSV) tailpipes (component type "piping") and the atmospheric dump valve (ADV) silencers with pg internal surfaces exposed to outdoor air or condensation. Loss of material for the MSSV tailpipes and the 3-409 ADV silencers will be managed by the Periodic Surveillance and Preventive Maintenance (PSPM) Program.

And section SER Table 3.4-1 item 3.4.1-30 should be revised to include the PSPM program along with the applicable 3.4.2.1.6, pg programs already identified. See response to Audit Item 240 in Attachment 1 of Entergy letter dated 3-417 December 18, 2007.

Additionally; In the associated section 3.4.2.1.6, pg 3-417 first paragraph should be revised to include the "main steam safety valve (MSSV) tailpipes and the atmospheric dump valve (ADV) silencers" along with the condensate storage tanks (CSTs), in the discussion of internal surface exposed to outdoor air or condensation.

NL-09-033 Attachment I Page 21 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment No. Section/Pg.# Comment 92 Table 3.4-1 The "External Surfaces Monitoring" entry in the "AMP in LRA" column of table 3.4-1 item 3.4.1-32 should be Item 3.4.1-32/ deleted.

pg 3-410 And Additionally; Section 3.4.2.1.8/ In the associated section 3.4.2.1.8 (first and second paragraphs) the discussion of the external surface pg 3-418 monitoring program for stainless steel tubing exposed to indoor air is not correct. The references to 3.4.1-32 in LRA Table 3.3.2-19-6-1P2 are only for the "internal" surface of components exposed to raw water, with loss of material managed by the Periodic Surveillance and Preventive Maintenance and One Time Inspection programs.

93 3.4.2.2.5/ Last paragraph; Table reference "3.3.2-19-1P3" should be "3.3.2-19-23-1P3" for the Main Feedwater and pg 3-428 Service System Heat Exchanger (Shell), carbon steel, component exposed to lubricating oil.

94 3.4.2.2.7/ First paragraph; Item 3.4.1-15 is not used in Table 3.3.2-19-4-1P3. Table 3.3.2-19-4-1P3 does not contain the pg 3-432 material type and aging effect combination discussed in this paragraph. Remove table 3.3.2-19-4-1P3 reference.

95 3.5/ For Item No. 3.5.1-1, column "AMP in LRA, Supplements, or Amendments" change from "Containment pg 3-449 Inservice Inspection (CII)-IWL" to "Containment Inservice Inspection (CII)-IWL and Structures Monitoring Program". Structures Monitoring Program provides for groundwater monitoring.

96 3.5/ pg 3-453 For Item No. 3.5.1-24, column "AMP in LRA, Supplements, or Amendments", change from "Structures Monitoring Program" to "CII-IWL supplemented by Structures Monitoring Program".

97 3.5/ pg 3-454 For Item No. 3.5.1-26 change the column "AMP in LRA, Supplements, or Amendments" column from "Not Applicable" to "CII-IWL supplemented by Structures Monitoring Program. In some cases Fire Protection Program supplements the Structures Monitoring program".

NL-09-033 Attachment I Page 22 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

98 3.5/ pg 3-454 For Item No. 3.5.1-27, column "AMP in LRA, Supplements, or Amendments", change from "Not Applicable" to "CII-IWL supplemented by Structures Monitoring Program. In some cases Fire Protection Program supplements the Structures Monitoring program".

99 3.5/ pg 3-455 For Item No. 3.5.1-30, column "AMP in LRA, Supplements, or Amendments", change from "CI-I4WL" to "ISI-IWF".

100 3.5/ pg 3-457 For Item No. 3.5.1-40, column "AMP in LRA, Supplements, or Amendments", change from "Structures Monitoring Program and ISI-IWF" to "Structures Monitoring Program".

101 3.5/ pg 3-458 For Item No. 3.5.1-43, column "AMP in LRA, Supplements, or Amendments", change from "Masonry Wall Program" to "Masonry Wall Program Supplemented by Fire Protection Program in some cases".

102 3.5/ pg 3-467 For Section 3.5.1.2, change "Tank Liners of Stainless Steel (LRA Table 3.5.1, Item 3.5-38)" to "Tank Liners of Stainless Steel (LRA Table 3.5.1, Item 38)".

103 3.5/ pg 3-467 For Section 3.5.1.3, change "Vibration Isolation Elements (LRA Table 3.5.1, Items 3.5-41 and 3.5-57)" to "Vibration Isolation Elements (LRA Table 3.5.1, Items 3.5.1-41 and 3.5.1-57)".

104 3.5/ For Section 3.5.1.4, change "Earthen Water Control Structures (LRA Table 3.5.1, Item 3.5-48)" to "Earthen pg 3-467 Water Control Structures (LRA Table 3.5.1, Item 3.5.1-48)".

105 3.5/ For Section 3.5.1.2, change "Group B1.1 High Strength Low-Alloy Bolts (LRA table 3.5.1, Item 3.5-51)" to pg 3-467 ""Group B1.1 High Strength Low-Alloy Bolts (LRA Table 3.5.1, Item 51)".

106 3.5/ For the sentence following (1), change "The applicant had also made commitments to enhance the pg 3-486 Structures Monitoring AMP, for to managing aging of inaccessible areas for all structures groups:" to the following sentence, 'The applicant had also made commitments to enhance the Structures Monitoring AMP, for managing aging of inaccessible areas for all structures groups:".

NL-09-033 Attachment I Page 23 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

107 Table 3.6-1 / Component group "Metal-enclosed bus - enclosure assemblies" is listed as not consistent with GALL, yet page 3-496 this line item has a Note E in LRA Table 3.6.2-1. This should be listed as consistent with GALL for the same reason as component group "Cable connections - metallic parts". Also, this item is not discussed in SER Section 3.6.2.3.

108 3.6.2.3 (High- The statement in the 4th bullet on this page should be revised to say 60 hertz consistent with Entergy's Voltage response to RAI 3.6.2.3-2.

Power Cables) / "The cable was tested at the manufacturing plant using 60 66-hertz alternating current voltage."

page 3-506

NL-09-033 Attachment I Page 24 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment 109 3.6.2.3 (High- This section discusses Entergy's response to GL 2007-01 for Indian Point and related industry operating Voltage experience.

Power Cables) / Section 3.6.2.3 states, in part:

page 3-508 "The applicant's response to Generic Letter 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," dated May 7, 2008 (ADAMS Accession number ML071350410), indicates that there were two 600-V cable failures that had lead jackets which were installed in a wet environment. Contributing causes to the degradation of these cables were submergence or wet conditions for an extended period of time and installation issues."

Entergy's response to GL 2007-01 states that one 600 VAC lead-sheathed cable failed after 19 years of service. The root cause is described as "Mechanically induced damage resulted in arcing as a result of moisture and accumulation of corrosion product in the damaged area. Damage possibly due to cable installation or installation of a new adjacent duct bank. No cable degradation due to moisture ingress.

Analysis of cable failure performed by Lucius Pitkin."

Therefore, this failure was from mechanical damage to the lead sheath, but the cable failure analysis stated there was no cable degradation due to moisture ingress [into the cable insulation].

The response to GL 2007-01 states the other 600 VAC lead-sheathed cable was replaced after 30 years of service, because of a degraded condition found during testing. The Root Cause states, "Probable cause was insulation thinning during original installation with subsequent degradation or damage during the duct back collapse repaired in 1994. Degradation contributing cause was submergence of cable for extended period of time."

NL-09-033 Attachment I Page 25 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment No. Section/Pg.# Comment 109 3.6.2.3 (High- This was not a cable failure, because it was replaced after testing found a degraded condition. Also, the (cont.) Voltage cable sheath (lead) was damaged by a duct bank collapse 11 years prior to the degraded condition being Power unacceptable.

Cables) /

page 3-508 110 4.1.1/ In the first paragraph, the listing of CLB documents does not match the listing provided in LRA section 4.1.1.

pg 4-1 Some of these differences may just be considered more generic descriptions, but other differences such as "engineering work requests" do not appear consistent with LRA section 4.1.1.

111 4.2.4.4/ In conclusion regarding UFSAR supplement, the SER states "...except for the revisions described above...".

Pg 4-14 No revisions appear to be described above. Suggest deleting this phrase. Perhaps it was intended for Section 4.2.5.4.

112 4.2.5.2; last The RTpts value at the end of the period of extended operation for IP3 plate B2803-3 is 279.50 F instead of paragraph on 279.9 0 F as amended by letter dated January 17, 2008.

page 4-16 113 4.3 last Per audit item 118 (in Amendment 3, NL-08-057), component replacement was also listed as an option to paragraph/ disposition a flaw. The sentence was changed to 'When a flaw is detected during in-service inspections, pg 4-19 either the component may be replaced, repaired, or evaluated for continued service in accordance with ASME Section XI. Revise the SER to reflect the component replacement option.

114 4.3.1.8.1/ 1 st complete paragraph / 1 st sentence, typo "The staff noted the that applicant" should be "The staff noted Pg 4-38 that the applicant".

NL-09-033 Attachment I Page 26 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment Section/Pg.# Comment No.

115 4.3.3.1/ Last sentence of the first paragraph states, "The staff concluded that the effects of the reactor coolant Pg 4-41 environment should be included in the calculated fatigue life of components, and it closed GSI-190." This phrase is not found in the memo that closed out GSI-190. It appears that this sentence should be revised to more accurately reflect the December 26, 1999, Thadani memo that closed out GSI-190. Suggested revision would say, "The staff concluded that licensees should address the effects of the coolant environment on component fatigue life as aging management programs are formulated in support of license renewal, and it closed GSI-190."

116 4.3.3.2/ First full paragraph ends with a sentence referring to meeting the requirements of 54.21 (c)(1)(ii). This Pg 4-42 regulation is one of three options for evaluating TLAAs. As an option, it should not be referred to as a requirement. A more accurate presentation of the approach would be projecting the analysis in accordance with the option provided by 54.21 (c)(1)(ii).

117 4.3.3.2/ In second paragraph on this page, the third sentence says, "As stated in Commitment 33, the applicant's Pg 4-43 Fatigue Monitoring Program now includes the assessment of the impact of the reactor water environment on critical components, as identified in NUREG/CR-6260." The assessment of reactor environmental effects was included in the program as described in the original LRA. This sentence should be replaced with text indicating that the exception noted in the previous sentence regarding the periodic updates of fatigue usage calculations was eliminated. The following sentence appropriately refers to SER Section 3.0.3.2.6 that provides the staff's evaluation of the removal of this exception.

118 4.3.3.2/ First paragraph refers to LRA Tables 4.3-12 and 4.3-13. The correct references are 4.3-13 and 4.3-14.

Pg 4-45 119 4.4/ First sentence states the EQ Program is a TLAA. Sentence should be clarified to say that the EQ Program Pg 4-47 is an aging management program to manage the effects of aging for EQ TLAAs in accordance with 10 CFR 54.21(c)(1)(iii). The program itself is not a TLAA according to the definition of TLAA in 10 CFR 54.3.

NL-09-033 Attachment I Page 27 of 27 Comment Form License Renewal Project Report Title: Indian Point Draft Safety Evaluation Report January 2009 License Renewal Project Report Number: LRA SER with Open Items Comment No. Section/Pg.# Comment 120 4.4/ Recommend the following change in the first paragraph, fourth sentence:

Pg 4-47 EQ equipment comprises safety-related and Qlist electrical equipment, nonsafety-related equipment whose failure could prevent satisfactory accomplishment of any safety-related function, and Reoeesary certain post-accident monitoring equipment.

121 4.4.1/ First paragraph should be revised to clarify that LRA section 4.4 summarizes the evaluation of TLAAs Pg 4-47 associated with EQ of electric equipment. The referenced section does not address evaluation of EQ of electric equipment except for that equipment with an associated EQ TLAA.

122 4.4/ Second paragraph misquotes the license renewal rule. The rule does not specify "EQ TLAAs" or discuss Pg 4-47 "each type of EQ equipment". The rule addresses analyses. Not all EQ equipment has associated analyses that meet the definition of TLAA. The emphasis should be shifted to address analyses rather than equipment. The equipment that is included in the EQ program is irrelevant in a discussion of TLAAs since not all EQ equipment is associated with a TLAA. These changes should ensure consistency with first paragraph of Section 4.4.1.

123 4.7.1.1 third Minor typo- should be WCAP-15666-A (two places) paragraph/

pg 4-51 124 IPEC letter Response for RAI-2.3B.4.2-2 (Unit3) has a typo as shown below.

NL-09-018 "are nonsafety-related valves as indicated by their location inside the Class 1 Boundary" Should say, dated "are nonsafety-related valves as indicated by their location outside the Class 1 boundary".

1/27/2009