ML061440156

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Entergy'S Seventeenth Supplemental Discovery Disclosures and Certification, with Affidavit of Craig J. Nichols
ML061440156
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 05/15/2006
From: Travieso-Diaz M
Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:
Atomic Safety and Licensing Board Panel
Byrdsong A T
References
50-271-OLA, ASLBP 04-832-02-A, RAS 11676
Download: ML061440156 (7)


Text

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ABATEDIOMEWO May 15, 2006 UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC May 15, 2006 (11:32am)

Before the Atomic Safety and Licensing Board OFFICE OF SECRETARY RULEMAKINGS AND

)) ADJUDICATIONS STAFF In the Matter of

) Docket No. 50-271 ENTERGY NUCLEAR VERMONT )

YANKEE, LLC and ENTERGY ) ASLBP No. 04-832-02-OLA NUCLEAR OPERATIONS, INC. ) (Operating License Amendment)

(Vermont Yankee Nuclear Power Station) )

)

ENTERGY'S SEVENTEENTH SUPPLEMENTAL DISCOVERY DISCLOSURES Pursuant to 10 C.F.R. § 2.336(d), Applicants Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. C(Entergy") hereby make the following supplemental discovery disclosures.

Documents and Data Compilations Additional non-privileged, non-proprietary documents and data compilations relevant to the admitted contentions are being provided to the parties as follows: one compact disk is being provided to the New England Coalition ("NEC") with respect to Contentions NEC 3 and 4 (Restated); and one compact disk is being provided to the NRC Staff with respect to Contentions NEC 3 and 4 (Restated).

In addition, following is a supplement to the log provided on March 31, 2005 of documents ("Proprietary Documents") that counsel for Entergy in good faith believes contain information that qualifies under 10 C.F.R. § 2.390(a)(4) and (b)(4)(i)-(v) as a trade secret and commercial or financial information of Entergy or its vendors and contractors and should be em p Iaf 56C V- 0.3 5 nEcV a-o

protected in accordance with the terms of the Board's Order (Protective Order Governing Non-Disclosure of Proprietary Information) dated March 1,2005:

Documents relating to NEC Contentions 3 and 4 (Restated):

Doc Id Bates Range Document Title Company Erf Safety Evaluation Report of Amendment 229; contains details of GE EPU501896 EPU 55278 I E's methodology, assumptions and results for performing analyses in S21 pport of a Constant Pressure Power Uprate GE PU 552782 - afety Evaluation Report of Amendment 229; contains details of GE's EPU501897 PU 553132 ethodology, assumptions and results for performing analyses in support

_f a Constant Pressure Power Uprate

- afety Evaluation Report of Amendment 229; contains details of GE's GE EPU501898 U 553133 ethodology, assumptions and results for performing analyses in support 553462 oUa Constant Pressure Power Uprate GE EPU 553463 - afety Evaluation Report of Amendment 229; contains details of GE's PU501899 5ethodology, fa assumptions and results for performing analyses in support 553822 fPUConstant Pressure Power Uprate EPU 553823 - afety Evaluation Report of Amendment 229; contains details of GE's GE EPU501900 EPU 554220 ethodology, assumptions and results for performing analyses in support Pf a Constant Pressure Power Uprate GE EPU 554221 - afety Evaluation Report of Amendment 229; contains details of GE's EPU501901 EPU 554571 ethodology, assumptions and results for performing analyses in support

_f a Constant Pressure Power Uprate EPU 554572 - afety Evaluation Report of Amendment 229; contains details of GE's GE EPU501969 EPU 554969 ethodology, assumptions and results for performing analyses in support Pfa Constant Pressure Power Uprate GE's GE EPU 554970 - afety Evaluation Report of Amendment 229; contains details of EPU501970 EPU 555320 ethodology, assumptions and results for performing analyses in support

_f a Constant Pressure Power Uprate PU 555321 - afety Evaluation Report of Amendment 229; contains details of GE's GE EPU501971 PU 555321 ethodology, assumptions and results for performing analyses in support PU 555650 f a Constant Pressure Power Uprate U 555651 - afety Evaluation Report of Amendment 229; contains details of GE's GE EPU501972 PU 556010 ethodology, assumptions and results for performing analyses in support Pf a Constant Pressure Power Uprate GE EPU 556011 - Safety Evaluation Report of Amendment 229; contains details of EU501973 EPU 556408 E's methodology, assumptions and results for performing analyses in P5548rt of a Constant Pressure Power Uprate EU 556409 - afety Evaluation Report of Amendment 229; contains details of GE's GE EPU501974 U 556759 ethodology, assumptions and results for performing analyses in support

_f a Constant Pressure Power Uprate Respectfully submitted, Jay E. Silberg Matias F. Travieso-Diaz PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W.

Washington, DC 20037-1128 Tel. (202) 663-8063 Counsel for Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

Dated: May 15, 2006 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

))

In the Matter of

) Docket No. 50-271 ENTERGY NUCLEAR VERMONT

)

YANKEE, LLC and ENTERGY ) ASLBP No. 04-832-02-OLA NUCLEAR OPERATIONS, INC.

) (Operating License Amendment)

(Vermont Yankee Nuclear Power Station) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of "Entergy's Seventeenth Supplemental Discovery Disclosures" and "Certification of Entergy's Seventeenth Supplemental Discovery Disclosures -

Affidavit of Craig J. Nichols" were served on the persons listed below by deposit in the U.S.

mail, first class, postage prepaid, and where indicated by an asterisk by electronic mail, this 15th day of May, 2006.

  • Administrative Judge *Administrative Judge Alex S. Karlin, Chair Lester S. Rubenstein Atomic Safety and Licensing Board Panel 4760 East Country Villa Drive Mail Stop T-3 F23 Tucson AZ 85718 U.S. Nuclear Regulatory Commission lesrrr(&comcast.net Washington, D.C. 20555-0001 ask2(-nrc.gov
  • Administrative Judge Atomic Safety and Licensing Board Dr. Anthony J. Baratta Mail Stop T-3 F23 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop T-3 F23 Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 aib5Qnrc.gov
  • Secretary Office of Commission Appellate Att'n: Rulemakings and Adjudications Staff Adjudication Mail Stop 0-16 C l Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 secy@,nrc.gov, hearingdocket@nrc.gov
  • Raymond Shadis *Sherwin E. Turk, Esq.

New England Coalition *Steven C. Hamrick, Esq.

P.O. Box 98 Office of the General Counsel Shadis Road Mail Stop 0-15 D21 Edgecomb ME 04556 U.S. Nuclear Regulatory Commission shadis@prexar.com Washington, D.C. 20555-0001 setanrc.gov, sch I(lnrc.gov

  • Jered Lindsay *Jonathan Rund Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 JJL5A*nrc.gov imr30,nrc.gov Matias F. Travieso-Diaz UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

)

In the Matter of )

) Docket No. 50-271 ENTERGY NUCLEAR VERMONT )

YANKEE, LLC and ENTERGY ) ASLBP No. 04-832-02-OLA NUCLEAR OPERATIONS, INC. ) (Operating License Amendment)

(Vermont Yankee Nuclear Power Station) )

)

CERTIFICATION OF ENTERGY'S SEVENTEENTH SUPPLEMENTAL DISCOVERY DISCLOSURES AFFIDAVIT OF CRAIG J. NICHOLS County of Windham )

)

State of Vermont )

I, Craig J. Nichols, being duly sworn according to law, depose and state the following:

1. I am the Extended Power Uprate Project Manager for Entergy Nuclear Operations, Inc. My business address is 320 Governor Hunt Road, P.O. Box 250, Vernon, VT 05354. I am authorized to provide this certification, pursuant to 10 C.F.R. § 2.336(c), on behalf of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. ("Entergy").
2. As Extended Power Uprate Project Manager I am responsible for the gathering and preparation of all of the analyses and documentation associated with the Extended Power Uprate for Vermont Yankee Nuclear Power Station. In connection with Entergy's seventeenth supplemental document disclosures in this proceeding, I have personally overseen the review and classification of all relevant documents and the production of the file compilations being provided by Entergy.
3. To the best of my knowledge, information and belief, Entergy's Seventeenth Supplemental Discovery Disclosures, dated May 15,2006, describe and transmit all materials required to be disclosed by 10 C.F.R. § 2.336(d) that were identified as relevant to the admitted contentions through a search of the information and documentation reasonably available to and under Entergy's possession, custody, or control.
4. Further, to the best of my knowledge, information, and belief, and based on a review of the information and documentation currently reasonably available to and under the possession, custody, or control of Entergy, these disclosures are accurate and complete as of the date of this certification.

Further, the afflant sayeth not.

t7 Craig J. Nichols Subscribed and sworn to before me this l day of May, 2006 My Publio e My commidssion expires -SIL~~