ML15152A490
| ML15152A490 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/01/2015 |
| From: | Bessette P Entergy Nuclear Operations, Morgan, Morgan, Lewis & Bockius, LLP |
| To: | Kennedy M, Lawrence Mcdade, Richard Wardwell Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, RAS 27877 | |
| Download: ML15152A490 (13) | |
Text
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Tel. 202.739.3000 Fax: 202.739.3001 www.morganlewis.com Paul M. Bessette Partner 202.739.5796 pbessette@morganlewis.com June 1, 2015 Lawrence G. McDade, Chairman Dr. Michael F. Kennedy Dr. Richard E. Wardwell Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket:
Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), Docket Nos. 50-247-LR and 50-286-LR RE:
Notification Regarding Entergy Expert Witnesses
Dear Administrative Judges:
The purpose of this letter is to inform the Atomic Safety and Licensing Board (Board) regarding certain changes in Entergy Nuclear Operations, Inc.s (Entergy) expert witnesses supporting the Track 2 contentions and hearing. Entergys expert, Dr. Robert E. Nickell, passed away unexpectedly this past January. Entergy has retained three additional expert witnesses for the Track 2 contentionsMr. Barry M. Gordon, Mr. Timothy J. Griesbach, and Dr. Randy G. Lott and disclosed those witnesses to the other parties. For the Boards information, enclosed is a copy of Entergys most recent monthly disclosure update listing all of Entergys Track 2 expert witnesses.
Administrative Judges June 1, 2015 Page 2 Respectfully submitted, Executed in accord with 10 C.F.R. § 2.304(d)
Paul M. Bessette, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Phone: (202) 739-5796 Fax: (202) 739-3001 E-mail: pbessette@morganlewis.com Counsel for Entergy Nuclear Operations, Inc.
cc:
Service List Enclosure
Kathryn M. Sutton Partner 202.739.5738 ksutton@MorganLewis.com Paul M. Bessette Partner 202.739.5796 pbessette@MorganLewis.com Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Tel. +1.202.739.3000 Fax: +1.202.739.3001 www.morganlewis.com Almaty Astana Beijing Boston Brussels Chicago Dallas Dubai Frankfurt Harrisburg Hartford Houston London Los Angeles Miami Moscow New York Orange County Paris Philadelphia Pittsburgh Princeton San Francisco Santa Monica Silicon Valley Tokyo Washington Wilmington June 1, 2015 John J. Sipos Assistant Attorney General Environmental Protection Bureau Office of the New York State Attorney General State Capitol Albany, NY 12224 Deborah Brancato Staff Attorney Riverkeeper, Inc.
20 Secor Road Ossining, NY 10562 Sherwin Turk Office of the General Counsel Mail Stop: O-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re:
Seventy-sixth Update to Disclosures Pursuant to 10 C.F.R. § 2.336; Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), Docket Nos. 50-247-LR and 50-286-LR Pursuant to 10 C.F.R. § 2.336 and the agreement among the parties, as submitted to the Atomic Safety and Licensing Board on January 13, 2009, Entergy Nuclear Operations, Inc. (Entergy) is providing this seventy-sixth update to its disclosures with respect to Contentions (1) NYS-25, (2) NYS-26B/Riverkeeper TC-1B, (3) NYS-35/36, and (4) NYS-38/RK-TC-5, as admitted by the Board on July 31, 2008 (LBP-08-13), November 4, 2010, July 6, 2011, and November 10, 2011.
Entergys seventy-sixth update to the disclosures consists of the following:
Enclosure 1 lists the names, addresses, and telephone numbers of persons upon whose opinion Entergy may base its positions on the contentions and upon whom Entergy may rely
John J. Sipos Deborah Brancato Sherwin Turk June 1, 2015 Page 2 as a witness. The bases for these opinions are provided in Enclosures 2, 3, and 4 of previous disclosures and supplements thereto. Entergy will continue to update Enclosure 1 if and when it identifies additional witnesses or changes thereto.
Enclosure 2 is reserved for a description by category and location of all relevant non-privileged documents, data compilations, and tangible things in the possession, custody, or control of Entergy that may be relevant to the admitted contentions in this proceeding.
Enclosure 3 is reserved for an index of documents, data compilations, or tangible things that may be relevant to the contentions but that contain proprietary information, Sensitive Unclassified Non-Safeguards Information (SUNSI), or otherwise protected information.
Enclosure 4 provides an index of relevant documents that are otherwise publicly available.
In order to compile these Enclosures, a reasonable search was conducted of documents in Entergys possession, custody, or control. We are attaching an affidavit, which attests that all relevant materials identified by this search have been disclosed and that the disclosures are accurate and complete as of May 20, 2015. We will supplement this disclosure with our next disclosure update, which will include any additional relevant documents and witnesses for any hearing on the contentions to the extent Entergy identifies them. Entergy will update these disclosures within 30 days of the date of this letter, as required by 10 C.F.R. § 2.336(d), and pursuant to the joint agreement among the parties on mandatory disclosures.
Entergy has been conservative in identifying documents for inclusion in Enclosures 2, 3, and 4.
By identifying documents on those Enclosures, Entergy does not necessarily concede that the documents are in fact relevant or material to the admitted contentions. As we indicated to you previously, in order to facilitate your review of these disclosures, we have made a good faith effort to identify the contention number(s) to which each record is responsive. In the event that a record appears to be responsive to two or more contentions, we have indicated that the record is generally applicable. These determinations, however, do not constitute an admission that each and every record is necessarily responsive to that contention or contentions identified, and documents may be responsive to additional contentions not necessarily identified. In addition, Entergy is continuing to review those documents listed on Enclosure 2 to determine whether they contain proprietary information. To the extent Entergy determines that additional documents contain proprietary information, Entergy will continue to update Enclosures 2 and 3 accordingly.
John J. Sipos Deborah Brancato Sherwin Turk June 1, 2015 Page 3 Sincerely, Signed (electronically) by Paul M. Bessette Kathryn M. Sutton, Esq.
Paul M. Bessette, Esq.
Counsel for Entergy Nuclear Operations, Inc.
Enclosures cc:
Melissa-Jean Rotini Daniel Riesel Victoria Treanor Robert D. Snook Michael J. Delaney Sean Murray Jay Goodman Robert Loughney Manna Jo Greene
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Docket Nos. 50-247-LR and
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50-286-LR ENTERGY NUCLEAR OPERATIONS, INC.
)
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(Indian Point Nuclear Generating Units 2 and 3)
)
)
June 1, 2015 AFFIDAVIT
- 1.
My name is John J. Curry. My title is Project Manager, Entergy Nuclear Operations, Inc.
(Entergy). Working with the attorneys for Entergy, I have been responsible for managing the searches, collection, and compilation of documents, data compilations, and tangible things to comply with the mandatory disclosure requirements in 10 C.F.R.
§ 2.336.
- 2.
This Affidavit relates to the disclosures that Entergy is providing on June 1, 2015, in the above-captioned proceeding pursuant to 10 C.F.R. § 2.336, and the agreement among the parties, as submitted to the Atomic Safety and Licensing Board on January 13, 2009.
- 3.
A search was conducted of documents, data compilations, and tangible things potentially relevant to the admitted contentions under the custody and control of Entergy for the types of information specified in 10 C.F.R. § 2.336(a). As provided in 10 C.F.R.
§ 2.336(c), this search was conducted based on information and documents reasonably available to Entergy:
- a.
The searches encompassed both electronic and paper documents.
- b.
The searches encompassed Indian Point Nuclear Generating Units 2 and 3 license renewal-related files and documents in the possession and control of individuals
who have worked on the IP2 and IP3 license renewal project, including contractors to Entergy to the extent that they and their employees worked on the IP2 and IP3 license renewal project.
- c.
Searches did not encompass documents in the possession of individuals who did not work on the IP2 and IP3 license renewal project or files unrelated to the IP2 and IP3 license renewal project.
- 4. is reserved for an index of relevant non-privileged, non-protected documents, data compilations, and tangible things that were located as a result of this search.
- 5. is reserved for an index of relevant documents, data compilations, and tangible things containing proprietary-related information.
- 6. provides an index of relevant documents, data compilations, and tangible things that are publicly available.
- 7.
Entergy has identified documents for inclusion in Enclosure 4. By identifying documents on this Enclosure, Entergy does not necessarily concede that the documents are in fact relevant or material to the admitted contentions.
- 8.
These disclosures are accurate and complete as of May 20, 2015.
I declare under penalty of perjury that the foregoing information, whether known to me personally or supplied to me by others upon whom I have relied, is true and accurate, to the best of my knowledge, information, and belief.
Executed in Accord with 10 C.F.R. § 2.304(d)
John J. Curry Project Manager Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway Buchanan, NY 10511 Phone: 914-254-7776 Email: jcurry2@entergy.com Executed this 1st day of June 2015.
ENCLOSURE 1 ENTERGY WITNESSES The name and, if known, the address and telephone number of any person, including any expert, upon whose opinion the party bases its claims and contentions and may rely upon as a witness:
Response
Nelson F. Azevedo (NYS-25, NYS-26B/RK TC-1B, NYS-38/RK TC-5)
Entergy Nuclear Generation Co.
295 Broadway, Suite 1 Buchanan, NY 10511 914-254-6775 Alan B. Cox (NYS-25, NYS-26B/ RK TC-1B, NYS-38/RK TC-5)
Entergy License Renewal Services (Retired) 1448 SR 333 N-GSB-45 Russellville, AR 72802 479-858-3173 Robert J. Dolansky (NYS-25, NYS-38/RK TC-5)
Entergy Nuclear Generation Co.
295 Broadway, Suite 1 Buchanan, NY 10511 914-254-6737 Mark A. Gray (NYS-26B/RK TC-1B, NYS-38/RK TC-5)
Westinghouse Electric Company LLC Nuclear Services 1000 Westinghouse Drive Cranberry Township, PA 16066 412-374-4602 Barry M. Gordon (NYS-38/RK TC-5)
Structural Integrity Associates, Inc.
5215 Hellyer Avenue, Suite 210 San Jose, CA 95138-1025 408-978-8200 Timothy J. Griesbach (NYS-25, NYS-38/RK TC-5)
Structural Integrity Associates, Inc.
5215 Hellyer Avenue, Suite 210 San Jose, CA 95138-1025 408-978-8200
Ted S. Ivy (NYS-25)
Entergy License Renewal Services Entergy Nuclear Inc.
1448 S.R. 333 N-GSB-45 Russellville, AR 72802 Dr. Randy G. Lott (NYS-25, NYS-26B/RK TC-1B, NYS-38/RK TC-5)
Westinghouse Electric Company LLC Nuclear Services 1000 Westinghouse Drive Cranberry Township, PA 16066 412-374-4157 Dr. Robert E. Nickell* (NYS-25, NYS-26B/RK TC-1B, NYS-38/RK-TC-5)
Applied Science & Technology 4043 Porte de Palmas, Unit 97 San Diego, CA 92122 619-255-9930 Jack R. Strosnider (NYS-25, NYS-26B/RK TC-1B, NYS-38/RK TC-5)
Talisman International, LLC 9712 Breckenridge Pl.
Montgomery Village, MD 20886 202-471-4244 Entergy will update this disclosure if and when it has identified additional persons that it may use as witnesses.
- Dr. Nickell passed away unexpectedly on January 21, 2015.
DB1/ 83580510.1 A copy of the analysis or other authority upon which that person bases his or her opinion:
Response
In addition to the documents identified in Entergys initial and updated mandatory disclosures, the analyses and authorities upon which the persons identified above base their opinions are included in Entergy Exhibits ENTR14001 through ENT000614.
Entergy-Indian Point License Renewal Proceeding Seventy-sixth Publicly Available Log June 1, 2015 NO.
DATE CATEGORY SUBJECT MATTER/DESCRIPTION CONTENTION 1714 3/6/2015 Amendment Union Electric Co., Docket No. STN 50-483, Callaway Plant Unit No. 1, Renewed Facility Operating License, Renewed License NPF-30 (ML053110040)
NYS-38/RK-TC-5 1715 10/20/2014 Amendment Exelon Generation Co., LLC, Docket No. 50-352, Limerick Generating Station, Unit 1, Renewed Facility Operating License (ML052780034)
NYS-38/RK-TC-5 1716 10/20/2014 Amendment Exelon Generation Co., LLC, Docket No. 50-353, Limerick Generating Station, Unit 2, Renewed Facility Operating License (ML052780037.)
NYS-38/RK-TC-5 1717 9/16/2013 Report Final Safety Evaluation Report for WCAP-17577, Rev. 2 (ML13248A423)
NYS-26B/RK-TC-1B; NYS-38/RK-TC-5 1718 6/17/2013 Report WCAP-17577-NP, Rev. 2, "Topical Report on ASME Section III Piping and Component Fatigue Analysis Utilizing the WESTEMS Computer Code" (ML13170A026)
NYS-26B/RK-TC-1B; NYS-38/RK-TC-5 1
DB1/ 83586253 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket Nos. 50-247-LR and
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50-286-LR ENTERGY NUCLEAR OPERATIONS, INC.
)
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(Indian Point Nuclear Generating Units 2 and 3)
)
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June 1, 2015 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, a copy of Entergys letter to the Administrative Judges was served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned proceeding.
Signed (electronically) by Raphael P. Kuyler Raphael P. Kuyler, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Phone: (202) 739-5146 Fax: (202) 739-3001 E-mail: rkuyler@morganlewis.com