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Category:Legal-Exhibit
MONTHYEARML15337A3522015-11-17017 November 2015 Official Exhibit - NYS000582-00-BD01 - Diagram of Strength Vs Amplitude by Dr. Richard T. Lahey ML15337A3372015-11-11011 November 2015 Official Exhibit - ENTR00726-00-BD01 - Track 2 Hearing Exhibit List ML15337A3322015-11-0505 November 2015 Official Exhibit - ENT000726-00-BD01 - Entergy Track 2 Hearing Exhibit List ML15337A3352015-11-0505 November 2015 Official Exhibit - RIVR14001-00-BD01 - Riverkeeper Tailored Track 2 Exhibit List ML15337A3362015-11-0505 November 2015 Official Exhibit - NRCR10001-00-BD01 - NRC Staff Track 2 Exhibit List ML15337A3332015-11-0404 November 2015 Official Exhibit - NYSR25001-00-BD01 - NYS Revised Tailored Exhibits List Relevant to Track 2 Contentions ML15337A3312015-11-0303 November 2015 Official Exhibit - NRC000230-00-BD01 - Corrections to Prefiled Testimony NRC000168 and NRC000197 ML15337A3262015-10-29029 October 2015 Official Exhibit - ENT000722-00-BD01 - Supplemental Testimony of Entergy Witnesses Nelson Azevedo, Timothy Griesbach & Randy Lott ML15337A3292015-10-29029 October 2015 Official Exhibit - ENTR16001-00-BD01 - Entergy Revised Exhibit List ML15337A3242015-09-23023 September 2015 Official Exhibit - NYS000576-00-BD01 - Pre-Filed Supplemental Testimony of Richard T. Lahey Re Contentions NYS-25, NYS-26B/RK-TC-1B & NYS-38/RK-TC-5 ML15337A3072015-09-0909 September 2015 Official Exhibit - NYS000573-PUB-00-BD01 - 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) ML15337A2962015-09-0909 September 2015 Official Exhibit - NYS000570-PUB-00-BD01 - 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) ML15337A2832015-09-0909 September 2015 Official Exhibit - NYS000563-00-BD01 - Pressurized Water Reactor (PWR) Systems, USNRC Technical Training Center, Reactor Concepts Manual, Pages 4-1 to 4-28 ML15337A2952015-09-0909 September 2015 Official Exhibit - NYS000569-PUB-00-BD01 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-26B/RK-TC-1B (Public, Redacted) (September 9, 2015) ML15337A2942015-09-0909 September 2015 Official Exhibit - NYS000568-PUB-00-BD01 - Supplemental Reply Statement of Position of the State of New York in Support of Contention NYS-25 (Public, Redacted) (September 9, 2015) ML15337A2932015-09-0909 September 2015 Official Exhibit - NYS000567-PUB-00-BD01 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-25 (Public, Redacted) (September 9, 2015) ML15337A3042015-09-0909 September 2015 Official Exhibit - NYS000571-PUB-00-BD01 - Pre-filed Supplemental Reply Testimony of David J. Duquette in Support of Contention NYS-38/RK-TC-5 (Public, Redacted) (September 9, 2015) ML15337A2972015-09-0909 September 2015 Official Exhibit - RIV000164-00-BD01 - 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) ML15337A3062015-09-0909 September 2015 Official Exhibit - NYS000572-PUB-00-BD01 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-38/RK-TC-5 (Public, Redacted) (September 9, 2015) ML15337A2822015-09-0909 September 2015 Official Exhibit - NYS000566-00-BD01 - Figure 1 for Supplemental Reply Testimony of Dr. Richard T. Lahey ML15337A3142015-09-0404 September 2015 Official Exhibit - ENTR00615-PUB-00-BD01 - Entergy'S Statement of Position Re Contention NYS-25 (Embrittlement) - Redacted ML15334A2842015-08-10010 August 2015 Official Exhibit - ENT000687-00-BD01 - 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) ML15335A2932015-08-10010 August 2015 Official Exhibit - NRCR00104-00-BD01 - on Yee Statement of Professional Qualifications (Revised) ML15337A2642015-08-10010 August 2015 Official Exhibit - NRC000196-PUB-00-BD01 - NRC Staff'S Initial Statement of Position on Contention NYS-25 (Reactor Vessel Internals) ML15337A3192015-08-10010 August 2015 Official Exhibit - ENT000698-PUB-00-BD01 - Entergy'S Revised Statement of Position Regarding Contention NYS-38/RK-TC-5(Safety Commitments) (Aug. 10, 2015)Redacted ML15337A3202015-08-10010 August 2015 Official Exhibit - ENT000699-PUB-00-BD01 - Redacted Revised Testimony of Entergy Witnesses Nelson Azevedo, Robert Dolansky, Alan Cox, Jack Strosnider, Timothy Griesbach, Barry Gordon, Randy Lott, and Mark Gray Regarding Contention NYS-38/RK ML15337A3172015-08-10010 August 2015 Official Exhibit - ENT000678-PUB-00-BD01 - NL-07-140, Letter from F. Dacimo, Entergy, to NRC Document Control Desk, ?Reply to Request for Additional Information Regarding License Renewal Application? (Nov. 28, 2007)Redacted ML15337A2652015-08-10010 August 2015 Official Exhibit - NRC000197-PUB-00-BD01 - NRC Staff Testimony of Dr. Allen Hiser, Jeffrey Poehler, and Gary Stevens on NYS-25 and NYS-38/RK-TC-5 ML15337A2412015-08-10010 August 2015 Official Exhibit - NRCR00147-00-BD01 - NRC Staff'S Revised Statement of Position on State of New York and Riverkeeper'S Joint Contention NYS-38/RK-TC5 (Revised) ML15335A2902015-08-10010 August 2015 Official Exhibit - NRC000222-00-BD01 - IP3 FSAR Rev. 04 Chapter 3 (2011) (Excerpt) ML15334A2632015-08-10010 August 2015 Official Exhibit - ENT000648-00-BD01 - 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 Evaluat ML15337A2622015-08-10010 August 2015 Official Exhibit - NRC000228-00-BD01 - Indian Point Unit 2 Technical Specifications 3.1.4 ML15337A2452015-08-10010 August 2015 Official Exhibit - NRC000227-00-BD01 - Gary Stevens Statement of Professional Qualifications ML15337A2632015-08-10010 August 2015 Official Exhibit - NRC000229-00-BD01 - Indian Point, Unit 3 Technical Specifications 3.1.4 ML15335A2192015-08-10010 August 2015 Official Exhibit - ENTR00031-00-BD01 - Curriculum Vitae of Alan B. Cox ML15335A2112015-08-10010 August 2015 Official Exhibit - ENTR20186-00-BD01 - Curriculum Vitae of Mark A. Gray ML15337A3162015-08-10010 August 2015 Official Exhibit - ENT000616-PUB-00-BD01 - Testimony of Entergy Witnesses Nelson F. Azevedo, Robert J. Dolansky, Alan B. Cox, Jack R. Strosnider, Timothy J. Griesbach, Randy G. Lott, and Mark A. Gray Regarding Contention NYS-25 (Embrittleme ML15337A2782015-08-10010 August 2015 Official Exhibit - NRC000168-PUB-00-BD01 - NRC Staff Testimony of Dr. Allen Hiser, Dr. Ching Ng, Mr. Gary Stevens, P.E., and Mr. on Yee, Concerning Contentions NYS-26B/RK-TC-1B and NYS-38/RK-TC-5 ML15337A2712015-08-10010 August 2015 Official Exhibit - NRC000223-00-BD01 - IP3 FSAR Rev. 04 Chapter 14 (2011) ML15337A2592015-08-10010 August 2015 Official Exhibit - NRC000224-00-BD01 - IP3 FSAR Rev. 04 Chapter 16 ML15337A2442015-08-10010 August 2015 Official Exhibit - NRCR00161-00-BD01 - NRC Staff Testimony of Dr. Allen L. Hiser and Mr. Kenneth J. Karwoski Concerning Portions of State of New York and Riverkeeper, Inc. Joint Contention NYS-38/RK-TC5 (Revised) ML15334A2822015-08-10010 August 2015 Official Exhibit - ENT000680-00-BD01 - Curriculum Vitae of Barry M. Gordon ML15335A2912015-08-10010 August 2015 Official Exhibit - NRCR00118-00-BD01 - Indian Point Unit 3 Technical Specifications (Excerpt) (Revised) ML15334A2282015-08-10010 August 2015 Official Exhibit - ENT000634-00-BD01 - Entergy, IP2, FSAR Update, Revision 25 (2014) (Excerpts) ML15335A2822015-08-10010 August 2015 Official Exhibit - NRC000220-00-BD01 - Pressurized Water Reactor Owners Group (PWROG) Presentation Slides, Industry and NRC Coordination Meeting Materials Programs Technical Exchange: Clevis Insert Bolt Update, (June 2014) ML15337A2692015-08-10010 August 2015 Official Exhibit - NRC000169-00-BD01 - NRC000169 - Indian Point, Unit 2 Technical Specifications (Excerpt) ML15337A2602015-08-10010 August 2015 Official Exhibit - NRC000226-00-BD01 - Jeffrey C. Poehler Statement of Professional Qualifications ML15335A2732015-08-10010 August 2015 Official Exhibit - NRC000183-00-BD01 - NRC Inspection Manual, Inspection Procedure 71013, Site Inspection for Plants with a Timely Renewal Application (Sept. 25, 2013) ML15335A2202015-08-10010 August 2015 Official Exhibit - ENTR00184-00-BD01 - Curriculum Vitae of Jack R. Strosnider ML15335A3012015-08-10010 August 2015 Official Exhibit - NRC000206-00-BD01 - Indian Point, Unit 2, Updated Final Safety Analysis Report (Ufsar), Rev. 25, Chapter 14 - Safety Analysis (2014) 2015-09-09
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United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.
In the Matter of:
(Indian Point Nuclear Generating Units 2 and 3) c..\,.~p..R REGlI~;. ASLBP #: 07-858-03-LR-BD01
Docket #: 05000247 l 05000286 Exhibit CLE000006 Exhibit #: CLE000006-00-BD01 Identified: 10/15/2012 Submitted 12/22/11
- ~ Admitted: 10/15/2012 Withdrawn:
~
? ~
0.... Rejected: Stricken:
","***il Other:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-247-LR
) and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
) October II , 2011 TESTIMONY OF JOHN SIMMS IN SUl>PORT OF HUDSON RIVER SLOOP CLEARWATER, INC. 's CONTENTION REGARDING ENVIRONMENTAL JUSTICE Q1. What is your name, your age, and your place of .oesidence'?
A I. My name is John Simms and I am 88 years old and I live at the Bethel Springvale Inn at 62 Springvale Road, Croton-on-Hudson, NY 10520.
Q2. In what capacity are you providing testimony today'?
A2. I am providing testimony from my personal knowledge as a resident of an assisted living facility that is located within 5 miles oflndian Point.
Q3. How long have you lived at Springvale Inn?
A3. I have lived at Springvale lrul for 2 years, since August 2009. In January 2006, I had a heart attack and a valve replacement at Westchester Medical Center at Valhalla. In between 4 hospitalizations I spent time in Taylor Nursing Home, then at Bethel's Springvale Nursing Home, which across the street from Springvale Inn. When I recovered enough to be able to be more on my own and no longer required to be in a nursing home, I was transferred here to this assisted living facility. I still have COPD in addition to my heart condition.
Q4. When did you retit-e and what was your former employment?
A4. 1 retired about 23 years ago. After serving in World War II, I studied engineering under the Gl Bill and had a 40-year long career as a product engineer. I also started my own business as an engineering consultant.
Q5. Approximately how many people are living at Spl"ingvale Inn?
A5. There are about 85 to 90 residents here; 125 being the maximum for Springvale Inn.
Q6, Do the residents at Springvale Inn have any disabilities that would make it difficult for them to evacuate in case of an emergency for which evacuation was required?
A6. Many residents here are wheelchair-bound. I would estimate that only 10-15% are ambulatory without aids. Our ability to get around leaves much to be desired. Many people here including myself are legally blind. Poor hearing and loss of memory are also a problem.
Some people have Alzheimer's and other mental disabilities; many require the help of private aides, but they may not have aides round tbe clock.
Q7, What if no aide is thue?
A 7. Some people have difficulty comprehending or following directions. An evacuation would be extremely difficult for people at Springvale.
Q8, What about language barriers? Do residents of Springvale Inn have any language ban'iers?
A8. Maybe a few are from foreign countries, but they speak and understand English, if they are able to understand what is being said. But as J said, some have comprehension problems.
Q9, Are there eligibility criteria for being a resident at Springvale Inn? Are there any criteria with I'egard to age or income?
A9. You would really need to ask the administration. J know that some people pay for some services. For example, J need eye drops. When I put them in myself, I miss or use too much, so they want me to go to the medication room for help with this. But I do not pay for this service.
Overall, I would say the average person here is at least middle class, but I do not know of any criteria.
QI0, How often do you have fire drills or other emel'gency drills that actually include evacuating the building'!
A I O. Yes, the administration has worked out a schedule for drills and for possible evacuations.
In my experience drills have been held about once a year. We had one scheduled with the local volunteer fire department recently, but it was cancelled and seems to have been postponed indefinitely, or at least they haven't told us when it would be rescheduled.
Qll. Where do people go when there is a drill and the building is evacuated?
A II. Right outside of the building.
Q12, Have you as a resident evel' been given information or prepared fOl' a radiological emugency, snch as might occur if thel'e were a severe prohlem at Indian Point?
A12. No, they've never discussed a radiological emergency. l've never been
informed of any special evacuation plan involving any emergency at Indian Point.
I don 't remember the source so this is definitely not an "official" answer, but I have heard that we would be sent to White Plains or Valhalla. In any case, I think that would be like going from the frying pan to the fire .
Q13. What about potassium iodide (KJ), which can be given to reduce the chance of thyroid cancer, if given promptly in the event of a radiological emergency? Havc they discussed this or asked for your permission to have KJ admiuistered in case of emel'gency?
A 13. No, they never discussed it. There has been no discussion by the staff about a radiological emergency.
Q14. How would pcople bc tl'3nsported to anothcl'location in thc evcnt of an emergcncy?
Are there enough vehicles to tt*anspol*t people from this assisted living facility to a safc shelter'?
A14. As far as I know Bethel doesn 't maintain a fleet of vehicles that could transport us. Only one or two residents even have personal vehicles, if any. It would take busses or vans. There is a bus line on Route 9-A, but it doesn't run that frequently; it doesn't run for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and it might not even be operational in an emergency. We also use Para-Transit; it's like a taxi service, but you must arrange for it in advance; maybe 5 days in advance. That wouldn't do us any good during a disaster. Good luck QIS. Beyond the people here at Springvale, do you think thel'c would any possible displ'oportionate impacts to people from communities of color, cthnicity or low income from an sCI'ious accident or incident at Indian Point?
A 15. I think that depends on location. The more citified communities such as Peekskill, White Plains, Mt. Kisco, Mt. Vernon and Yonkers might have a harder time evacuating and people who cannot afford personal transportation might have a harder time evacuating. As I said, even here, we depend on busses, which may not be running in a disaster.
Q16. Are there any other possible impacts ifthere were a problem at Indian Point that you have concems about?
A 16. I am concerned that power and water would be interrupted. All our systems are intertwined. The NYC water supply could become contaminated because the reservoirs are here in Croton and Yonkers. We cannot defend our basic resources.
QI7. What about possible solutions to the conccms you have raised about evacuation or other concems to reduce negative impacts?
A 17. We need an alternative means to cross the Hudson, because the two bridges might quickly become overwhelmed. During World War II , if a bridge across the Rhine was mined or blown up, we used pontoon bridges to cross the river. Could pontoons be assembled to allow the general population on the east side of the Hudson River to flee to the west?
Q18. lfyou were told to shelter in place while the general population was evacuating, how would you feel?
A18. It would depend on the circumstances. I'd have to know more.
Q19. Ifpcwerwas cut off, is there II baclmp generator?
A19. I don't believe there is a generator.
Q20. Would loss of power cause any serious medical difficulties for any of the residents?
A2D. I don't know.
In accordance with 28 U.S.C. § 1746, I state under penalty of perjury that the foregoing is true and correct:
JoJb ~~
Date: ; / - 2 2 -//