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Category:Legal-Pleading
MONTHYEARML20317A2962020-11-12012 November 2020
Applicants Answer Opposing Riverkeepers Motion to Supplement the Basis of Its Contention
ML20317A3292020-11-12012 November 2020
Applicants Answer Opposing Riverkeepers November 6, 2020 Motion
ML20111A3292020-04-20020 April 2020
Applicants Answer to the State of New Yorks Motion for Leave to Amend Contentions NY-2 and NY-3
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Petitioner Riverkeeper, Inc.'S Reply Memorandum in Further Support of Petition to Intervene and for a Hearing
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Reply in Support of the State of New York'S Petition for Leave to Intervene and for a Hearing
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Applicants Answer Opposing Petition for Leave to Intervene and Hearing Request Filed by the State of New York
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Notices of Appearance for Peter Lejeune, Alan Lovett, Jason Tompkins and William Gill, IV on Behalf of Holtec International
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Applicants Answer Opposing Petition for Leave to Intervene and Hearing Request Filed by the Town of Cortlandt Village of Buchanan and Hendrick Hudson School District
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Applicants Answer Opposing Safe Energy Rights Group Letter Requesting a Hearing
ML20069L6132020-03-0909 March 2020
Applicants Answer Opposing Riverkeeper Inc.S Petition to Intervene and for a Hearing
ML17006A3872017-01-0606 January 2017
NRC Staff'S Response to the Atomic Safety and Licensing Board'S Order of December 8, 2016
ML16333A4152016-11-28028 November 2016
Entergy'S Answer Opposing Request for Hearing
ML16321A3762016-11-16016 November 2016
Entergy Nuclear Operations, Inc., Response to the Licensing Board 11/02/2016 Directive Regarding the Timing of Certain Mandatory Disclosures
ML16210A4442016-07-28028 July 2016
Notice of Appearance Vinh D. Hoang on Indian Point
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NYS Notice of Withdrawal, Cover Letter, Cos
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Notice of Appearance by Diane Curran in the Matter of Entergy Nuclear Operations, Inc. Indian Point Nuclear Generating Units 2 and 3
ML16195A3782016-07-13013 July 2016
NYS Cover Letter, Nda, and Cos
ML16193A7082016-07-11011 July 2016
Entergy Answer to State of New York Motion to Establish a Schedule for Waiver Petition and Contentions Related to NRC Continued Storage Rule
ML16193A7092016-07-11011 July 2016
NRC Staff'S Answer to New York'S Motion to Set a Schedule for the Filing of a Waiver Petition And/Or Contentions Related to Spent-Fuel Storage at Indian Point
ML16193A6852016-07-11011 July 2016
State of New York Notice of Withdrawal for Aag Kathryn Deluca
ML16180A5482016-06-28028 June 2016
2016-6-28 Third Joint Status Report Re Track 2 Schedule
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Second Joint Status Report Regarding Track 2 Schedule Deferral
ML16095A4012016-04-0404 April 2016
2016-4-4 Entergy Opposition to Riverkeeper Contention RK-EC-11
ML16095A3762016-04-0404 April 2016
NRC Staff Answer to Contention RK-EC-11
ML16092A3052016-04-0101 April 2016
NYS Certificate of Service
ML16092A3032016-04-0101 April 2016
NYS Cover Letter Submitting a Notice of Subsequent Event Concerning the Pending Appeal of ASLB Decision LBP-15-26
ML16092A3042016-04-0101 April 2016
State of New York Notice of Subsequent Event Concerning Pending Appeal of Atomic Safety and Licensing Board Decision LBP-15-26 and License Amendment for Entergy Indian Point Unit 2 to Delay the Containment Leak Rate Test for Five Years
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Joint Motion for Track 2 Hearing Schedule Deferral
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Certificate of Service for Corrected Staff Testimony
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NRC Staff'S Answer to State of New York'S Motion for Leave to File Contention NYS-40
ML16078A4142016-03-18018 March 2016
Certificate of Service for NRC Staff Testimony
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Entergy Opposition to Proposed New York State Contention NYS-40 Regarding Severe Accident Mitigation Alternatives
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NRC Staff'S Answer in Opposition to State of New York Motion to Vacate or Stay Issuance of License Amendment
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Entergy Answer Opposing New York State Motion for a Stay
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Notification of Issuance of License Amendment
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Revised Certificate of Service
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Commission Notification of Significant Licensing Action
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NYS Contention 40
ML15357A2552015-12-23023 December 2015
Westinghouse Electric Company'S Opposition to New York State'S Motion for Disclosure of Proprietary Documents
ML15356A8462015-12-22022 December 2015
Attachments 1 and 2 to NRC Staff Answer in Opposition to the State of New York'S Third Motion to Compel Public Disclosure of Confidential Westinghouse Documents
ML15356A8452015-12-22022 December 2015
NRC Staff'S Answer to New York Third Motion to Compel Public Disclosure of Confidential Westinghouse Documents
ML15348A4562015-12-14014 December 2015
Declaration of Dr. Joram Hopenfeld in Support of State of New York Motion to Withdraw Proprietary Designations of Westinghouse Documents
ML15320A5032015-11-16016 November 2015
NRC Staff Answer to New York Appeal of LBP-15-26
ML15320A5502015-11-16016 November 2015
Entergy Answer Opposing NYS Appeal of LBP-15-26
ML15319A0052015-11-15015 November 2015
Entergy Answer Opposing New York Motion for Leave to File Five Hearing Exhibits (Corrected)
ML15316A3032015-11-12012 November 2015
NYS Supplemental Briefing on Motion for Public Disclosure of Various Westinghouse Documents
ML15316A3042015-11-12012 November 2015
NYS Certificate of Service
ML15315A0242015-11-11011 November 2015
Westinghouse'S Supplemental Response Re Westinghouse'S Appearance and Proprietary Documents
ML15313A4612015-11-0909 November 2015
NYS Certificate of Service
ML15309A1562015-11-0505 November 2015
NYS Certificate of Service for Revised Tailored Exhibit List
2020-04-20
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
x In re: Docket Nos. 50-247-LR; 50-286-LR License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. November 1, 2011
x DECLARATION OF DR. RICHARD T. LAHEY, JR.
I, Richard T. Lahey, Jr., declare under penalty of perjury that the following is true and correct:
- 1. I submit this declaration in response to Entergy NL-11-107 communication with NRC Staff and in support of the proposed contention pending before the Board.
- 2. I am the Edward E. Hood Professor Emeritus of Engineering at Rensselaer Polytechnic Institute (RPI) in Troy, New York, a member of the National Academy of Engineering (NAE), a Fellow of the American Nuclear Society (ANS) and the American Society of Mechanical Engineers (ASME), and an expert in matters relating to the operations, safety, and the aging of nuclear power plants. I have previously submitted declarations in this proceeding and for the sake of brevity refer the parties and the Board to those submissions with respect to my qualifications and experience. My curricula vitae, which more fully describes my November 1, 2011 Lahey Declaration 1
educational and professional background and qualifications, is available at:
http://www.rpi.edu/~laheyr/laheyvita.html.
- 3. The September 28, 2011 Entergy NL-11-107 document on reactor pressure vessel internals is claimed by them to contain the completion of commitment #30 to their license renewal application for the Indian Point reactors and the aging management programs for RPV internals. While this document does give a comprehensive list of the Indian Point RPV internal structures, components and fittings to be evaluated, and the NDT techniques they plan to employ in these inspections, no details are given on the timing for these inspections. Moreover, in some cases, instead of details, Entergy simply states: In accordance with SER Section 4.2.7, IPEC will submit this information to the NRC as part of the submittal to apply the approved version of MRP-227(e.g., see compliance item-7 on page-22 of Section 3.6). Since MRP-227A is not expected to be released until year end (i.e.,
December 2011), this information will not be available in time for review and discussion in the State's upcoming submissions and consideration in the ASLB hearings on IP license renewal.
- 4. In addition, Entergy frequently states that the NDT inspections of 100% of the RPV internal structures, components and fittings of interest are not possible. Moreover, Entergy even states that in some cases failed or missing bolts can be considered the indicated aging effect (see Table 5-2, page - 36). Significantly, they also state that planar flaws in bolts can be reliably detected if - and only if -
these flaws occupy more than 30% of the bolt's cross-sectional area (see Section November 1, 2011 Lahey Declaration 2
4.1.5, page-25). This means that - under Entergy's proposal - incore bolts can be deemed adequate for continued operations even if they are significantly degraded.
While these type of acceptance criteria might make some sense when considering steady-state and normal plant transients, it is not at all clear that they are adequate to assure core coolability subsequent to various accidents which produce severe shock loads on highly embrittled and fatigued RPV internals and which may result in an uncoolable core geometry. As USNRC Staff and Entergy are aware, the State of New York has significant safety concerns about this interrelationship between fatigue and embrittlement and the adequacy of the AMPs of RPV internals, and, unfortunately, the State's concerns have not been addressed at all by Entergy or USNRC Staff.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.
November 1, 2011 Signed (electronically) by Dr. Richard T. Lahey, Jr.
November 1, 2011 Lahey Declaration 3
