ML081560329

Pilgrim Watch Reply to Entergy'S & Nrc'S Responses to Pilgrim Watch Motion to Add New Contention Regarding the Cumulative Usage Factor (CUF)

ML081560329
Person / Time
Site:	Pilgrim
Issue date:	05/27/2008
From:	Lampert M Pilgrim Watch
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-293-LR, ASLBP 06-848-02-LR, RAS J-129
Download: ML081560329 (16)

Text

TIs j- /cz9 DOCKETED USNRC UNITED STATES -OF.AMERICA May 27, 2008 1:04 pm NUCLEAR REGULATORY COMMISSION OFFICE OF SECRETARY RULEMAKINGS AND BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ADJUDICATIONS STAFF In-the matter of Docket # 50-293 Entergy Corporation Pilgrim Nuclear Power Station License. Renewal Application ..May 27, 2008

PILGRIM WATCH, REPLY TO ENTERGY'S & NRC'S :RESPONSES TO PILGRIM WATCHMOTION TO ADD NEW CONTENTION'REGARDING THE CUMULATIVE USAGE FACTOR (CUF)

INTRODUCTION Pursuant to the Board's Order (Setting Deadlines for Provisional Proposed Findings and Conclusions on Contention 1 and for Pleadings to Pilgrim Watch's Recent Motion Regarding CUFs) ASLBP No. 06-848-02-LR (May 12,: 2008) Pilgrim Watch responds to NRC Staff and Entergy's responses regarding the admissibility of Pilgrim Watch's Recent Motion Regarding CUF under 10 CFR 2.309 (f)(1).

10 CFR 2.309 (f)(1): A request for hearing or petition for leave to intervene must set forth with particularity the contentions sought to be raised. For each contention, the request or petition must:(i) Provide a. specific statement of the issue of law or fact to be raised or controverted, providedfurther, that the issue of law or fact to be raised in a request for hearing under 10 CFR 52.103(b) must be directed at demonstrating that one or more of the acceptance criteria in the combined license have not been, or will not be met, 77~irtp ý).s 0 ;

and that the specific operational consequences of nonconformance would be contrary to providing reasonable assurance of adequate protection of the .public health and safety.

BACKGROUND Submissions, by -Pilgrim-.ýWatch .priorto: May_:: 5, 2008, simply addressed, a request toý.keep 'the record open that turned out not -to be necessarybecause of the, Federal First Circuit Court's Order. Therefore, those filings are, not relevant. What remains relevant is whether orsnot ,the contention is admissible ,:under 10 CFR *2309 (f)(1).: A;summary -of submissionson this' issue are as follows.

April 9, Pilgrim -Watch.' filed: a :motion regarding the Cumulative: Usage Factor (hereinafter CUF), asking that the Board keep the record open so that the Board could address the CUF issue being raised based upon new and significant information.'

April 21, 2008 both NRC and Entergy filed responses objecting, to Pilgrim Watch's Motion.2 3

April 30, 2008 Pilgrim watch replied to Entergy's and NRC's April 21 responses.

May 2, 2008 both Entergy and NRC filed motions to strike Pilgrim Watch's replyon the grounds that they believed Pilgrim Watch had not satisfied regulations restricting replies to situations where leave is granted following the. demonstration of "compelling 4

circumstances."

'Pilgrim Watch Motion Requesting the Record be Held Open so. that the Board May Address a New and Significant Issue [Method to Calculate Cumulative usage factors (CUF)] Sua Sponte and Provide Pilgrim Watch an Opportunity for Hearing, April10, 2008 2Entergy's Response in Opposition to Pilgrim Watch's Motion Requesting the Recordbe Held Open for Sua Sponte Consideration of Cumulative Usage factors, April 30, 2008; NRC Staff Response. To Pilgrim watch Motion Requesting Record Be Held Open, April 21, 2008.

3 Pilgrim Watch Replies to Entergy's and NRC's Responses Opposing Pilgrim watch's Motion Requesting that the record be Held Open. for Sua Sponte Consideration of Cumulative Usage factors, April 30, 2008&

4 Entergy's Motion to Strike Pilgrim Watch's reply to Entergy's and NRC's Responses Opposing Pilgrim Watch's Motion Requesting.that the Record beHeld Open for Sua Sponte Consideration of Cumulative Usage factor, May 1, 2

5 May 5,-2008 Pilgrim Watch filed a motion. regarding.Cumulative Usage-Factor.

May 8, 2008 NRC Staff filed a motion to.'strike Pilgrim Watch's May 5 motion saying 6

that it was.an impermissible reply.

May 12, 2008 The Board treating Pilgrim Watch's May 5, 2008 Motion as being a

.submission- of a -new-,contention *directed Eitergy-and NRC to respond- regarding the admissibility of the, contentionr underi0 CFR 2.309 (f)(1)?7 Pilgrim Watch's Reply addresses two issues': First, whether the contention is within scope, is material and:has basis; and second, its timeliness.

THE CONTENTION'S ADMISSIBILITY - SUBSTANCE The-,contention is within scope of these proceedings; the issue raised is material; and there is substantial basis for the.contention.

The Contention The LRA and accompanying commitments do not include an adequate plan to monitor and manage the effects of aging due to metal fatigue on key reactor components that are subject to an aging management review, pursuant to 10 C.F.R. § 54.21(a), and an evaluation of time limited aging analysis, pursuant to 10 C.F.R. § 54.21 (c).

The commitments are vague, incomplete and lack transparency and do 'not demonstrate that the effects of aging will be adequately managed before the close of the hearing. Entergy's commitments do not explain with requisite' specificity'how the CUFs for plant components will 2008; NRC Staff Motion to Strike Pilgrim Watch Reply to NRC Staff response to Pilgrim Watch's Motion to Hold the Record Open, May 2, 2008.

5 Pilgrim Watch Motion Regarding Cumulative Usage Factor, May 5, 200.8 6NRC Staff Motion to Strike Pilgrim Watch Motion regarding the Cumulative Usage factor, May 8, 2008 7 May 12, Order at 3 3

be recalculated to yield acceptable values; do not explain precisely what Entergy must demonstrate. in order to. appy CUF values, from other plants to, Pilgrim; do not contain a clearly stated inspection schedule;,anddo not!provide ýspecific information.on how:Entergy will,repair or replace affected components.

In the-absence of more specific i"formation~and recalculation ofCUFs greater-than 1.0:prior'to the close of the hearing, Entergy's Aging .Management PlanI for .metal'fatigue is simply a "promise" asking the public-andBoard for their trust. Trust without verification:does-not provide re asonableassurance 'thatpublic health and' safety :will be .protected; ,nor will, it provide public xesnbe, Aa. *

• alkan. ....

confidence in the licensing review process.

The Contention, Is. Within, the Scope of the Proceedings 10g..CFR §2.309(f)(iii) requires that, the: Petitioner "Demonstrate .that the issue raised in the contention is within the scope of the:proceeding." In. proceedings concerning the renewal of an operating license, the scope is %limitedto "a review of the plant structures and components that will: require an aging. management review for the period of extended operation and the plant's systems, structures, and components that are subject to.an evaluation of time limited aging analysis." See FloridaPower and Light Co.. (Turkey Point Nuclear Generating Plant, Units 3 and 4), CLI-00-23, 52 NRC 327, 329 (2000).

In reactor license renewals,. 10 CFR §. 54'requires the Applicant to submit as part of, its application an Aging Management Program for all passive systems at the facility, which includes the methods they use to monitor the condition of important equipment so that they can make repairs and replacements before safety margins are compromised.

In order to renew its license for another 20 years Pilgrim is required, 'under 10 CFR § 54.21- to demonstrate that for each structure and component identified in that sectionthe effects of aging will be adequately managed for the period of extended operation.

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The Pilgrim Nuclear Power Plant Application for.LicenseRenewal, includes alist-of systems that require aging management. Among them.are the components that are listed in Pilgrim's SER that must havean environmentally adjusted CUF less -than-1.0;* however there ::are some with CUFs greater than 1.0. 8 Specifically. the ,applicants -- wn data: demonstrates that: (a):.the. reactor vessel shell and lower head, (b) reactor vessel feedwater nozzles, (c).reactorrecirculation system piping (including inlet and outlet nozzles), and (d):feedwater piping have an -environmentally adjusted:CUF greater than 1.0 9 .:and'thus, are at a higher risk .for failure due to-metal, fatigue.. These, (4). systems, were identified- by NUREGiCR-6260;Sectionri5.71 to be-:among'the nine:, systems :most -.sensitive to environmental effects for PNPSvntage' GeneralElectric plants.' 0 Data in NUREG-1891, referred: to above, indicates that the requirements of 10 CFR 54,21(c)( 1)(i)(ii) are not satisfied because they exceedithe CUF on their face.

Because the issue of metal fatigue of plant systems requires aging management review this issue is within the scope of this license renewal proceeding.

The Issue Raised In the Contention Is Material to te Findings Of These Proceedings 10 CFR §2.309(f)(iv) requires that the Petitioner "Demonstrate that the issue raised in the contention is material to the findings the NRC must make to support the action that is involved in the proceeding."

In discussing the materiality requirement, the Atomic Safety and Licensing Board (ALSB) considering the license renewal for Millstone Nuclear Power Station stated, In order to be admissible, the regulations require that all contentions assert an issue of law or fact that is material to the outcome of a licensing proceeding; that is, the subject 8 NUREG- 1891, Safety Evaluation Report Related .to the License Renewal of Pilgrim Nuclear Power Station, Docket No. 50-293,section 4.3.3.1, Adams Accession number M1073241016 9 Ibid, 4.3.3.1 Summary of Technical Information in the Application

'0 l bid 5

matter of the contention must impact the-grant or denial of a pending .license application.

Where a contentionmalleges a deficiency or~error in the application;:the: deficiency or error must have someaindependentIhealth" and- safety. significance.

In the Matter of Dominion Nuclear Connecticut,Inc.(Millstone Nuclear :Power Station, Units-2 and 3)Docket Nos. 50-'336-LR,, 50-423-LR ASLBP NO. 04ý-824-,01LR -July?28,".2004, p. 7. See Private Fuel Storage, L.L.C. (Independent Spent Fuel StoragelInstalliation),,LBP- 98-7, 47 NRC 142, 179-80 (1998), affd in part, CLI-98-13, 48 NRC 26 (1998).

The sufficiency ¢of .the':Agingw,Management Planwfor- assuring, CUFs do -not -:exceed (1.0). is material.. to the .renewal of ,this.license.:. 'Comnponent; fatigue .canlead to zultimate :failure. ,Failure from fatigue can result.in dangerous pipe ruptures, component malfunction, or migration of loose pieces of metal throughthe reactor p system which.can interfere with safe operation of the plant.

These potential consequences :could significantly impact lhealth and safety. Therefore the NRC must,'make certain--findings .to protect .the-public ýhealth and safety, and the environment, and either deny the license extension, or impose significantmodifications.to- the commitments.

There is a Substantial Basis for This Contention

1. Eitergy must comply with the following requirements of 10 C.F.R. § 54.21(c) (1):

Each application must contain the following information:

(c) An evaluation of time-limited aging analyses.

(1) A list of time-limited aging analyses, as defined in § 54.3, must be provided.

The applicant shall demonstrate that--

(i) The analyses remain valid for the period of extended operation; (ii) The analyses have been projected to the end of the period of extended operation; or (iii) The effects of aging on the intended function(s) will be adequately managed for the period of extended operation [10 C.F.R. § 54.21(c)(1)].

Data in the SER indicates that some key reactor components will have a greater potential for cracking due to metal fatigue before the year 2032, during the 20 year period of extended plant operation.

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2. Component Plant Environmentally Adjusted CUF (Entergy's data), that_ exceeds 1.0 CUF criterion.inclUdes [NUREG-1891, SER 4.313.1 at,,_444]:: reactor vessel shell and lower head; reactor vessel feedwater nozzles; reactor recirculation system piping (including inlet and. outlet nozzles); and feedwaterpiping- fourout of nine potential components.

3. Component fatigue, which can lead to. ultimate failure, is anh! aging phenomenon, that results from cyclic mechanical* and,.thennal stressesT.Failure from -fatigue ,canresult :in:dangerous pipe ruptures, component malfunction, or :the:.migration of loose pieces. of metal-throughlthe reactor system, which canrinterfere withsafe operation of a plant.

3. Data in NUREG- 1891, referred to above`,indicates that the requirements of 10 C.F.R. §§ 54.21 (c)(1)(i) and (ii) are not satisfied because they exceed the CUF limits on their face.

4. Commitments: To satisfy section 54.21(c)(i)(iii) - that "the effect of aging on the intended functibns(s) will be adequately managed for the period of extended operation" - Entergy agreed toikense Renewal Commitments 31 and 35 (NUREG-1891, SER, Appendix A, A-10 thru A-13].

A. Commitment 31, says that: At least 2 yearsprior to entering the period of extended operation, for the locations identified in NUREG/CR-6260, for BWRs of the PNPS vintage, PNPS will refine our current fatigue analyses to include the effects of reactor water environment and verify that the cumulative usage factors (CUFs) are less than 1.0. This includes applying the appropriate Fen [sic] factors tO valid CUFs determined in accordance with one of the following:

(i) For locations, including NUREG/CR-6260 locations, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to determine the environmentally adjusted CUF.

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(ii) More limiting PNPS-specific locations with a valid CUF may be added in addition to the NUREG/CR-6260 locations.

(iii) Representative CUF values from other plants, adjusted. to or- enveloping the PNPS plant specific external 4loads~may be.,used if demonstrated-applicable.to PNPS.

(iv) An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) maybe performedto determine a valid-CUFP (v) During the period of extended operation, *PNPSmay also~use:one of the following options for fatigue management if ongoing- mnitoring indicates a-,potential' for a condition outside the analysis bounds-noted above:

• Update and/or refine the affected analyses described above.

• Implement an inspection program that has been reviewed and approved by the NRC (e.g.,

- periodic nondestructive examination of theaffected locations at inspection intervals to be determined by.amethod acceptable.to theNRC).

• Repair or replace the affected locations before exceeding a CUF of 1.0.

Enhancement or Implementation Schedule: June 8, 2012; June 8, 2010 for submitting the AMP PNPS selects the option of managing the effects of aging due to environmentally assisted, fatigue B. Commitment 35 says that: At least 2 years prior to entering the period of extended operation, for reactor vessel components, including the feedwater nozzles, PNPS will implement one or more of the following [emphasis added]:

(i) Refine the fatigue analyses to determine valid CUFs less than 1.0. Determine valid CUFs based on numbers of transient cycles projected to be valid for the period of extended operation.

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Determine CUFs in. accordance with an NRC-approved version of the ASME code or NRC-approved alternative.(e.g,, NRC- approed codecase).

(ii) Manage the effects of agingdue to fatigue at. the affected locations by an inspection program that has.,been reviewed and approved bytthe NRC (e.g., periodic non-destructive examination .of the affected- -locations °at inspection intervals, to be .determine&by a method acceptable to the NRC).

(iii) Repair or replace the affected locations, before exceeding a CUF of 1.0: Should'PNPS, select the option to manage .the.,aging ,-effects.dueiti fatigueduring the period of extended operation, details of the AMP such as scope,: qualification,: method, and frequencywill be submitted to the NRC at least 2 years prior tothe period of extended operation.

Should PNPS select the option. to manage the aging: effects :due to fatigue during the period of extended operation, details ofthe AMP such as scope, qualification, method, and frequency will be submitted to the NRC at least 2 years prior to the period of extended operation.

Enhancement or Implementation Schedule: June 8, 2012;.June 8,"2010 for submitting the AMP if PNPS selects the option of managing the effects of aging due to environmentally assisted fatigue C. The Commitments do not provide reasonable assurance; :they are vague, incomplete, and lacking in transparency.

(i) Recalculations: The commitment says they will "refine the current fatigue analyses to include the effects of reactor water environment and verify that the cumulative usage factors (CUFs) are less than 1.0." We note that "verify that the cumulative usage factors (CUFs) are less than 1.0" appears to suggest doing the math to get the "right" answer.

There is no requirement, as there should be, to do the recalculations prior to the close of the hearing so that the methodology, assumptions and calculations are available for the Board's and stakeholder's scrutiny. The Intervenor's (NEC's) analysis of Entergy's CUF recalculations at 9

Vermont Yankee, :new and significant information discussed below, point to the importance of having the recalculations done before, not :after,; the hearingcloses.

(ii) The commitments: allow for representative CUF values from other plants, adjusted to or enveloping the PNPS :plant.specific external loads, to ,ýbe ,,used ifdemonstrated applicable to PNPS. There is no set standard laid out describing exactly what "'demonstrated applicable" must entail.

(iii) The mcomitments alloWEntergy to cehoose to do :more' inspections or fix: or ,replace the component. Instead, :any component :with: a CUF value exceeding 1.0 should be -required to be fixed or replaced in order to meet the CLB, an obligation of the licensee during license renewal.

In summary there is truth is the saying that, "The Devil is in the details" and the details are absent.

THE CONTENTION'S, ADMISSIBILITY - TIMELINESS Both ,Entergy and NRC complain,thatthe motion did not properly address the criteria for filing a late-filed contention. Contrary to their assertions, Pilgrim Watch previously explained that new and significant information affecting public health and safety came forward in press reports, April 2008. The news reports resulted from-new and significant developments in New England Coalition's (NEC) intervention at Entergy's Vermont Yankee (hereinafter VY) LRA on CUF.

We learned, among other things, that NRC had made note that the issues at Vermont Yankee could apply to other reactor sites.

New and Significant Lessons Learned from VY's Interventioni: VY, like Pilgrim, had CUFs exceeding 1.0. At VY, Entergy' recalculated the CUF twice. NEC's expert demonstrated repeated inadequacies in Entergy' s recalculations. NEC filed an amended contention. The VY ASLB will hear arguments from both sides as to the validity of the findings at the July 21-25 evidentiary hearing. VY's latest experience alerted Pilgrim Watch to the serious shortcomings in Pilgrim's 10

commitments; mainly because, as it stands. now, Pilgrim would not recalculate the CUFs prior to the close of the hearing.

The public learned from Vermont Yankee's experience not to blindly trust in Entergy's recalculations as the commitments ask the.public to do - "once burned,.twice warned."

It appears that Entergy and NRC have taken a different lesson away from VY's experience. Craft commitments that postpone recalculations until after 'the hearing closes to avoid getting burned again by public-,scrutiny - an ý"'en&run."

If the commitments are allowed to- stand,' the 'Board and publicý will-have no opportunity to verify Entergy's:recalculations arid check/verifyitheir assumptions.

Therefore, the new and significant. informationfrom NEC's experience at VermontYankee is that igPilgrim':s CUF commitments do not provide reasonable :assurance. The essence of Pilgrim Watch's current motion is a challenge to the manner in which Entergy intends to !deal with the issue;of metal fatigue at Pilgrim. The commitments lack the detail necessary so that the public and :ASLB can determine precisely what will be done and how it will bedone.

From reading the commitments, all we are told is that Entergy has committed to do recalculations using an ASME-type code methodology or NRC-approved alternative to show that the CUF values fall below 1.0 that does not tell us enough. They do not disclose the assumptions they will use to do the calculations, describe how they will implement the methodology, nor even hint at what a.NRC- approved alternative might be.

The Vermont Yankee CUF Experience In support of NEC's amended contention, NEC submitted a declaration from their expert Dr.

Joram Hopenfeld. According to Dr. Hopenfeld, the environmentally corrected cumulative use factors (CUFens) that Entergy and its consultants calculated as part of their August 3, 2007 11

reanalysis reports were "unrealistically low."' 'Among Dr. Hopenfeld's specific allegations are that .Entergy failed.to perform an error analysis to show the error range foreach variable in the CUFen analyses,: relied, on incorrect' guidance when, calculating'environmental fatigue. correction factors (FENS), failed to use sufficient -care in adapting equations derived from laboratory experiments to,actual reactor.,components, and,",did not use, theequations properly at low oxygen andlo temp eratures" [Id,. at 1t6 -118].,, Dr. Hopenfeld* also,alleges that Entergy's calcul ation of,60-year CUFs does not ýprovide sufficient: informnation, about key: assumptions'to 'substantiate -the claim that the'result is "conservative" or "'bounding'-[Id;, at .-20] . Dr.- H6penfeld includes his own proposed' :recalculation--of :CUFen .-values: (someeexceeding1..lO) :*based ,on'_the ,.CUF.: values originally presented, inr the ,-Application and on what, Dr. .Hopenfeld: asserts are, appropriate "bounding" values for the Fens [id. at:28-32 and Tabie 1].

Irrespective of whether or not Entergy plans to use the.same or different methodology at Pilgrim is not relevant.. Whatý is relevant is that we do not 'have specific information about what they do intend to use.. It is obvious from VY's experience that merely agreeing to vague commitments, and to do recalculations afteruthe hearing is closed,. does 'not allow any party, including the Board, an opportunity make, an.; assessment that the calculations/formula is appropriate, is based on the right assumptions,-or that it is applied correctly.

The real issue is not whether there should be commitments but the lack of detail in the commitments so that no one knows whether the CLB, will be met. 10 CFR 54.2 1(a)(3) requires

,Entergy, for each structure and component identified in paragraph (a)(1) of this section [must]

demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

In the Matter of Entergy Nuclear Vermont Yankee, L.L.C., and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station) LBP-06-20, 64 NRC at 186-87, at 9.

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The components that have CUF values > 1.0 require proper management. The. commitments do not provide-. assurance.

The question- for-the Board to-address;based-on the inew and significant informationr from NEC's intervention, is whether Entergy's cormitments to do. a recalculation will meet the -requirements of 54.21 and5,54.29. We need to know the details, about the,analytical method and approach that Entergy will use;ý because depending on the calculation'method and assumptions, Entergy can get almost any answer that it wishes. We also need to know how its new calculation methodwill be bench-marked so that it can be judged by,the Board and stakeholders beforelicenseapproval.

In Entergy's and NRC Staff's May.:19" answers;-neither offered evidence supporting-the claim that by merely saying that they Will 'do -calculations.approved: by ASME and NRC Staff-that it has-demonstrated that it willhave adequately maraged aging related-to metal fatigue.

As -authorized by 10 CFR 2.309(f)(1)(vi) this contention is based -on the absence of specific information that is required by law to,be-included- in the LRA. Pilgrim Watch cannot identify the flaws÷ in information that Entergy has not provided. We can only identify that the information is not provided and will not be provided unless the Board accepts this contention and requires Ente-rgy to be transparent.

Entergy complained [Entergy's Answer at 6] that "Pilgrim Watch has neither identified a witness on this issue nor summarized their proposed testimony." First we are not required to present a witness at this stage; and second until Entergy is required to produce a recalculation and its methodology, there is nothing for an expert to analyze.

The Dispute Entergy, NRC Staff and Pilgrim Watch agree that there is more to be done. The dispute is that Entergy and NRC Staff do not want outside involvement. They wish to be secretive and to deprive the Board and public of any role in reviewing how Entergy meets its commitments. They expect us to blindly trust NRC Staff and Entergy. When the public is excluded, nuclear safety suffers and public confidence in the NRC as a fair and responsible regulator erodes.

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NEC's analyses of Entergy's recalculations at Vermont Yankee, what- we are calling -new and significant .information, -strongly,.supports .the- ,view,that-only if theBBoard -requires that.-Pilgrim recalculates the CUF's prior to-the close of .the hearing so:that, they can be independently analyzed can the adequacy of the aging management plan be evaluated.

In Vermont, after Entergy produced its fir st, set of recalculations and they were.* examined by NEC and its expert,-Entergy found it necessary to produce asecond set of recalculations to attempt to-address the problems:identified with -theýfirst set ofcalculations; 12 This significant development at; VY underscores how much moireEntergy has to do at Pilgrim before t1he public and Board have',l suffic*ient detail to. iallow a. decision to be reached on-whether Entergy has adequately dealt with aging of critical components subject to metal fatigue.

CONCLUSION In conclusion mere "promises to do the "right thing" without providing sufficient. details and the opportunity to verify assumptions and calculations, does not meet the safety obligations imposed by the Atomic Energy Act.

Thank you in advance for your consideration.

Mary Lampert Pilgrim Watch, pro se 148 Washington Street Duxbury,. MA 02332 12 In the Matter of Entergy Nuclear Vermont Yankee, L.L.C., and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station) ASLBP No. 06-849-03-LR(April 24, 2008)Order (Granting Motion to Amend NEC Contention 2A) at 1 14

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE-ATOMIC, SAFETYVAND. LICENSING BOARD In the matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application May 27,2008 CERTIFICATE-OF-SERVICE LIhereby certify that the foilow.ing was servedMay. 27, 2008 by electronic mail and by U.S. Mail, First Class to the. Service List:. Pilgrim Watch Reply to.Entergy's and NRC's Responses to Pilgrim Watch's Motion to Add New Contention Regarding the Cumulative Usage factor (CUF)

Administrative Judge Administrative. Judge Ann Marshall Young, Chair. Richard F. Cole Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail. Stop - T-3 F23 Mail Stop -T-3 F23 US NRC US NRC Washington, DC 20555-0001 Washington,-DC 20555-0001 Administrative Judge Secretary of the Commission Paul B. Abramson Attn: Rulemakings and Adjudications Atomic Safety and Licensing Board Staff Mail Stop T-3 F23 Mail. Stop 0-16 C1 US NRC United States Nuclear Regulatory Washington, DC 20555-0001 Commission

Office of Commission Appellate Mr. Mark Sylvia Adjudication Town Manager, Town of Plymouth Mail Stop 0*16: :C1 11 Lincoln Street.

United States .Nuclear Regulatory PlyfmouthMA 02360 Commission Washington, DC 20555-0001 Sheila Slocum Hollis, Esq.

To of PlymouthMA Duane Morris,'LLP:

Atomic Safe, and Licensing Board 5056 Street, N.W. 10,00 Mail Stop T-3 F23 Washington D.C'. 20004-2166 United States: Nuclear Regulatory Commission Richard:R. MacDonald Washiigton, DC'2055-5-0001 Tomw Manager, Town of Duxbury

,878 Trm6ont Stieet Susan L.. Ut.talEsq. Duxbur.y,-A 02332 Kimberly- Sexton, Esq.

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,Mail Stop 15 D21 P.O. Box,2824 United States Nuclear Regulatory Duxbury, MA 02331 Commission Washington, DC* 20555-0001 Paul A. Gaukler, Esq.

David R. Lewis, Esq.

Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W.

Washington, DC.20037-1138 Mary Lampert Pilgrim Watch, pro se 148 Washington St.

Duxbury, MA 023332 2