ML062430029
| ML062430029 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/24/2006 |
| 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-OLA, RAS 12170 | |
| Download: ML062430029 (4) | |
Text
RAS. PI P70 August 24, 2006 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board DOCKETED USNRC August 24, 2006 (3:56pm)
RULEMAK In the Matter of
)
ADJUDICAl
)
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 ANSWER IN SUPPORT OF STAFF'S MOTION FOR LEAVE TO INTRODUCE TWO ADDITIONAL HEARING EXHIBITS
- INGS AND IONS STAFF Pursuant to 10 C.F.R. § 2.323(c), Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.'. (collectively "Entergy") hereby answer the NRC Staff's Motion for Leave to Introduce two Additional Hearing Exhibits ("Motion") dated August 23, 2006. For the reasons stated in the Motion and those summarized below, Entergy submits that the Motion should be granted.
DISCUSSION There is no doubt that the two Generic Letters that the Staff seeks to introduce (Generic Letters 80-91 and 81-08) are relevant to NEC Contention 3, since NEC has questioned the appropriateness of using the ODYN code to predict the response of VY to generator load Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. are the licensees of the Vermont Yankee Nuclear Power Station ("VY").
T.E MPLA-E; C-s 4
"7 2;,7 TEMPLATE=SECY-041 SECY-02
rejection and main steam isolation valve ("MSIV') closure transients. See, e.g., Declaration of Dr. Joram Hopenfeld in Support of New England Coalition's Response to the Statements of Position of Entergy and NRC Staff dated June 14, 2006 at 5. The Generic Letters call for the use of ODYN by licensees to analyze, among other plant operating events, generator load rejection and MSIV closure transients. See Generic Letter 80-91. The letters are also evidence of the NRC Staff s acceptance of ODYN as providing "acceptable best estimate calculation predictions of the core responses to pressurization transients."' Id.
There-would be no significant impacts on any-party-as a result of the admission of these clearly relevant documents into evidence. They do not represent a change in position by the Staff, nor raise issues that have not been previously'addressed. As such, they neither require nor are amenable to response by the other parties. Their admission would not delay or expand the hearing or require the Board to address matters that it would not have otherwise been considered.
In short, admission of these documents would have no adverse effect on the proceeding.
CONCLUSION For the reasons stated, the Staffs Motion should be granted.
Respectfully submitted,
(*
Jay E. Silberg 7y Matias F. Travieso-Diaz Scott A. Vance PILLSBURY WINTHROP SHAW PIT=MAN LLP 2300 N Street, N.W.
Washington, DC 20037-1128 Counsel for Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc..
August 24, 2006 2
- 1.. I UNITED STATES OF AMERICA
'NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
ENTERGY NUCLEA.R VERMONT YANKEE, LLC and ENTERGY NUCLEAR OPERATIONS, INC.
(Vermont Yankee Nuclear Power Station)
)!
.)
)
)
Docket No. 50-271 ASLBP No. 04-832-02-OLA (Operating License Amendment)
CERTIFICATE OF SERVICE I hereby certify that copies of "Entergy's Answer in Support of Staff's Motion for Leave to Introduce two Additional Hearing Exhibits" 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 24th day of August, 2006.
- Administrative Judge Alex S. Karlin, Chair Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ask2(anrc.gov
- Administrative Judge Dr. Anthony J. Baratta Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 aib5@Pnrc.gov
- Administrative Judge Lester S. Rubenstein 1750 Avenida del Mundo Apartment. 1106 Coronado, CA 92118 lesrrr(comcast.net Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
- Secretary Att'n: Rulemakings and Adjudications Staff Mail Stop 0-16 CI U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 secy@nrc.gov. hearingdocket@nrc.gov
- Raymond Shadis New England Coalition P.O. Box 98 Shadis Road Edgecomb, ME 04556 shadis(aprexar.com
- JeeredL.indsay-_
Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 JJL5@nrc.gov Office of Commission Appellate Adjudication Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
- Sherwin E. Turk, Esq.
- Steven C. Hamrick, Esq.
Office of the General Counsel Mail Stop 0-15 D21 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 set(@nrc.gov, schl@,nrc.gov
- Jonathan-Rund---
Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 imr3(@nrc.gov J
Matias F. Travieso-Diaz 2