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Category:Legal-Pre-Filed Exhibits
MONTHYEARML16081A3252016-03-21021 March 2016
NRCR12001 - NRC Staff Prefiled Hearing Exhibit List (Revised)
ML16078A4172016-03-18018 March 2016
ENTR20726 - Entergy Track 2 Exhibit List
ML16078A4122016-03-18018 March 2016
NRC000236 - Crack Growth Rate Comparison - Eason Pathania Model to MRP Model- Excel Spreadsheet
ML16078A4132016-03-18018 March 2016
NRCR11001 - Exhibt List NRC Staff Prefiled Hearing Exhibit List (Revised)
ML15321A0352015-11-17017 November 2015
NYS000582 - Diagram of Strength Vs Amplitude by Dr. Richard T. Lahey
ML15315A0132015-11-11011 November 2015
ENTR00726 - Track 2 Hearing Exhibit List
ML15309A1292015-11-0505 November 2015
ENT000726 - Entergy Track 2 Hearing Exhibit List
ML15309A1712015-11-0505 November 2015
RIVR14001 - Riverkeeper Tailored Track 2 Exhibit List
ML15309A2212015-11-0505 November 2015
NRCR10001 - NRC Staff Track 2 Exhibit List
ML15309A1552015-11-0404 November 2015
NYSR25001 - NYS Revised Tailored Exhibits List Relevant to Track 2 Contentions
ML15313A4602015-11-0404 November 2015
NYSR25001 - Corrected Page 24 to Exhibits List Relevant to Track 2 Contentions
ML15307A1152015-11-0303 November 2015
NYSR24001 - State of Ny Revised Hearing Exhibits List
ML15307A8112015-11-0303 November 2015
NRC000230 - Corrections to Prefiled Testimony NRC000168 and NRC000197
ML15302A4672015-10-29029 October 2015
ENTR16001 - Entergy Revised Exhibit List
ML15252A4442015-09-0909 September 2015
NYS000563 - Pressurized Water Reactor (PWR) Systems, USNRC Technical Training Center, Reactor Concepts Manual, Pages 4-1 to 4-28
ML15252A4432015-09-0909 September 2015
NYS000566 - Figure 1 for Supplemental Reply Testimony of Dr. Richard T. Lahey
ML15252A5042015-09-0909 September 2015
NYS000568 - Supplemental Reply Statement of Position of the State of New York in Support of Contention NYS-25 (Public, Redacted) (September 9, 2015)
ML15252A5062015-09-0909 September 2015
NYS000570 - Supplemental Reply Statement of Position of the State of New York and Riverkeeper, Inc. in Support of Contention NYS-26B/RK-TC-1B (Public, Redacted) (September 9, 2015)
ML15252A5092015-09-0909 September 2015
RIV000164 - NUREG-1740, ACRS, Voltage-Based Alternative Repair Criteria: a Report to the Advisory Committee on Reactor Safeguards by the Ad Hoc Subcommittee on a Differing Professional Opinion (2001)
ML15252A5112015-09-0909 September 2015
RIVR13001 - Riverkeeper Updated Exhibit List
ML15252A5752015-09-0909 September 2015
NYS000573 - Supplemental Reply Statement of Position of the State of New York and Riverkeeper, Inc. in Support of Contention NYS-38/RK-TC-5 (Public, Redacted) (September 9, 2015)
ML15252A5792015-09-0909 September 2015
NYS Updated Exhibit List
ML15261A8302015-09-0404 September 2015
ENTR00615 - Entergy'S Statement of Position Re Contention NYS-25 (Embrittlement) - Redacted
ML15222A9152015-08-10010 August 2015
ENT000648 - M. Mitchell, Chief, Vessels and Internals Integrity Branch, Response to Non-Concurrence Regarding Safety Evaluation for Topical Report MRP-227, Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (Undated)
ML15223A4512015-08-10010 August 2015
NRC000206 - Indian Point, Unit 2, Updated Final Safety Analysis Report (Ufsar), Rev. 25, Chapter 14 - Safety Analysis (2014)
ML15223A4542015-08-10010 August 2015
NRC000207 - Regulatory Information Conference Presentation Slides, Recent Materials Inspections of PWR Reactor Internals (Mar. 2015)
ML15223A4502015-08-10010 August 2015
NRC000205 - Indian Point, Unit 2, Updated Final Safety Analysis Report (Ufsar), Rev. 25, Chapter 3 - Reactor (2014)
ML15223A3932015-08-10010 August 2015
NRCR00104 - on Yee Statement of Professional Qualifications (Revised)
ML15223A3912015-08-10010 August 2015
NRCR00105 - Ching Ng Statement of Professional Qualifications (Revised)
ML15222A8212015-08-10010 August 2015
ENT000617 - Curriculum Vitae of Timothy J. Griesbach
ML15223A6712015-08-10010 August 2015
NRCR00147- NRC Staff'S Revised Statement of Position on State of New York and Riverkeeper'S Joint Contention NYS-38/RK-TC5 (Revised)
ML15223A6752015-08-10010 August 2015
NRC000227 - Gary Stevens Statement of Professional Qualifications
ML15222A8222015-08-10010 August 2015
ENT000618 - Curriculum Vitae of Randy G. Lott
ML15223A7022015-08-10010 August 2015
NRCR900001 - NRC Staff Pre-filed Hearing Exhibit List (Revised)
ML15222A8252015-08-10010 August 2015
ENT000629 - Letter from C. Grimes, NRC, to D. Walters, NEI, License Renewal Issue No. 98-0030 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Components (May 19, 2000)
ML15222A8302015-08-10010 August 2015
ENT000634 - Entergy, IP2, FSAR Update, Revision 25 (2014) (Excerpts)
ML15223A7792015-08-10010 August 2015
NRC000224 - IP3 FSAR Rev. 04 Chapter 16
ML15223A7812015-08-10010 August 2015
NRC000226 - Jeffrey C. Poehler Statement of Professional Qualifications
ML15223A7832015-08-10010 August 2015
NRC000228 - Indian Point Unit 2 Technical Specifications 3.1.4
ML15223A7852015-08-10010 August 2015
NRC000229 - Indian Point, Unit 3 Technical Specifications 3.1.4
ML15223A7872015-08-10010 August 2015
NRC000196 - NRC Staff'S Initial Statement of Position on Contention NYS-25 (Reactor Vessel Internals)
ML15223A3872015-08-10010 August 2015
NRCR00118 - Indian Point Unit 3 Technical Specifications (Excerpt) (Revised)
ML15222A8352015-08-10010 August 2015
ENT000621 - Westinghouse, WCAP-17894-NP, Rev. 0, Component Inspection Details Supporting Aging Management of Reactor Internals at Indian Point Unit 2 (Sept. 2014)
ML15223A8052015-08-10010 August 2015
NRC000169 - Indian Point, Unit 2 Technical Specifications (Excerpt)
ML15223A9452015-08-10010 August 2015
NRC000223 - IP3 FSAR Rev. 04 Chapter 14 (2011)
ML15223A3862015-08-10010 August 2015
NRC000222 - IP3 FSAR Rev. 04 Chapter 3 (2011) (Excerpt)
ML15222B1242015-08-10010 August 2015
ENT000680 - Curriculum Vitae of Barry M. Gordon
ML15222B1262015-08-10010 August 2015
ENT000687 - NRC, Safety Evaluation Report, Topical Report on ASME Section III Piping and Component Fatigue Analysis Utilizing the Westems Computer Code (WCAP-17577, Revision 2) (Undated)
ML15222B1612015-08-10010 August 2015
ENTR00186 - Curriculum Vitae of Mark A. Gray
ML15222A8482015-08-10010 August 2015
ENT000637 - NUREG-1874, Recommended Screening Limits for Pressurized Thermal Shock (PTS) (March 2010)
2016-03-21
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Text
RIV000125 Submitted: July 13, 2012 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of ) Docket Nos.
) 50-247-LR Entergy Nuclear Operations, Inc. ) and 50-286-LR (Indian Point Nuclear Generating )
Units 2 and 3) ) July 13, 2012
___________________________________________ )
Declaration of Phillip Musegaas in Support of Intervenors Rebuttal to Entergys Initial Hearing Submissions Pertaining to Consolidated Contention RK-EC-3/CW-EC-1 Phillip Musegaas hereby declares under penalty of perjury that the following is true and correct:
- 1. I am currently employed by Riverkeeper, Inc., and hold the position of Hudson River Program Director.
- 2. I am co-counsel for petitioner-intervenor Riverkeeper in the above-referenced proceeding concerning the application by Entergy Nuclear Operations, Inc. (Entergy) for a renewal of the two separate operating licenses for the nuclear power generating facilities located at Indian Point on the east bank of the Hudson River in the Village of Buchanan, Westchester County, New York, for twenty years beyond their current expiration dates.
- 3. I submit this declaration in support of Riverkeeper and Hudson River Sloop Clearwater, Inc.s Consolidated Contention RK-EC-3/CW-EC-1 concerning the inadequate environmental review of spent fuel pool leaks and radiological contamination at Indian Point.
- 4. I began my employment with Riverkeeper in August, 2005.
- 5. From August 2005 - October 2006, I was a Policy Analyst for Riverkeeper.
- 6. From October 2006 - September 2008, I was a Staff Attorney for Riverkeeper, assigned to work on Riverkeepers Indian Point Campaign, which included preparing to participate in the Indian Point license renewal process before the Nuclear Regulatory Commission.
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- 7. From September 2008 to the present, I have held the position of Hudson River Program Director.
- 8. In the course of my employment at Riverkeeper, in the spring of 2007, I was personally and directly involved in a project concerning a proposed study of the impact of radiological leaks from Indian Point on the Hudson River ecosystem.
- 9. In particular, at that time, I contacted Dr. Chris Gobler, an Associate Professor at Stony Brook University, to discuss a possible study of Hudson River sediments, fish and shellfish in the vicinity of the Indian Point nuclear power plant, to determine whether the aforementioned biota or sediment contained elevated levels of radionuclides. Riverkeepers interest in having this study conducted arose following the disclosure by Entergy of leaks of radioactively contaminated water from Indian Points spent fuel pools in 2005. At the time, I was responsible for Riverkeepers efforts to commission this study.
- 10. On August 17, 2007, Dr. Gobler submitted a study proposal to Riverkeeper, which Entergy has offered in this proceeding as Exhibit ENT000367.
- 11. Riverkeeper accepted the proposal, and Dr. Gobler began collecting samples in October 2007. Some limited collection of clam and sediment samples was performed using Riverkeepers boat, under the supervision of John Lipscomb, Riverkeepers boat captain and manager of the Boat Program. Dr. Gobler also collected samples independently, without Riverkeepers assistance.
- 12. On July 10, 2008, Dr. Gobler sent an e-mail to me and other Riverkeeper staff, describing the initial results of his analysis of samples collected during the previous year. A copy of this email was submitted into this proceeding by Entergy as Entergy Exhibit ENT000368.
- 13. As described in the email from Dr. Gobler, none of the shellfish samples he collected and analyzed had detectable levels of the radionuclides being tested for. In the same email message, Dr. Gobler expressed interest in conducting further sample collection and continuing the study.
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- 14. As of July 2008, samples of aquatic biota and sediments in the Hudson River had only been collected during the fall of 2007, in one sampling season.
- 15. Due to staffing and resource constraints, Riverkeeper did not ask Dr. Gobler to collect additional samples of aquatic biota or Hudson River sediments subsequent to the initial 2007 sample collection effort.
- 16. Dr. Gobler was also not asked by Riverkeeper to prepare a final report summarizing his initial study, due to Riverkeepers limited resources.
- 17. In my capacity as the Riverkeeper employee responsible for this work, and based on my discussions with Dr. Gobler, I did not consider the sample collection and analysis done by Dr.
Gobler to be a complete study. For that reason, the initial results of the study, documented in Dr.
Goblers July 10, 2008 email, ENT000368, were not cited or referenced in Riverkeepers pre-filed direct testimony on Contention RK-EC-3/CW-EC-1.
- 18. Based on the incomplete nature of the work conducted by Dr. Gobler, it is my understanding that generic conclusions were not, nor could be, made based upon the sampling results obtained.
- 19. I declare under penalty of perjury that the foregoing is true and correct.
Executed on July 13, 2012.
Signed (electronically) by Phillip Musegaas Phillip Musegaas, Esq.
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