ML15293A576

NYS Declaration of Lisa S. Kwong

ML15293A576
Person / Time
Site:	Indian Point
Issue date:	10/19/2015
From:	Kwong L State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML15293A572	List: ML15293A573 ML15293A575 ML15293A576 ML15293A577 ML15293A579
References
50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, RAS 28418
Download: ML15293A576 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION 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.

October 19, 2015

---

x DECLARATION OF LISA S. KWONG Pursuant to 28 U.S.C. § 1746, Lisa S. Kwong hereby declares as follows:

1.

I serve as an Assistant Attorney General for the State of New York, counsel for petitioner-intervenor State of New York in this proceeding. I submit this declaration and accompanying attachments in support of the State of New Yorks motion for public disclosure of various Westinghouse documents.

2.

Attached to this declaration as Attachment 1 is a true and correct copy of the NYS Table of 10 Documents Subject to the States Motion.

3.

Attached to this declaration as Attachment 2 is a true and correct copy of Exhibit ENT000681; Westinghouse, WCAP-17199-P, Rev. 1; Environmental Fatigue Evaluation for Indian Point Unit 2; December 2014.

4.

Attached to this declaration as Attachment 3 is a true and correct copy of Exhibit ENT000682; Westinghouse, WCAP-17200-P, Rev. 1; Environmental Fatigue Evaluation for Indian Point Unit 3; December 2014.

5.

Attached to this declaration as Attachment 4 is a true and correct copy of Exhibit ENT000683; Westinghouse, Calculation Note CN-PAFM-13-32, Rev. 3; Indian Point Unit 2 (IP2) and Unit 3 (IP3) Refined EAF Analyses and EAF Screening Evaluations; June 25, 2015.

2

6.

Attached to this declaration as Attachment 5 is a true and correct copy of Exhibit ENT000688; Westinghouse, Calculation Note CN-PAFM-13-40, Rev. 1; Indian Point Unit 2 and Unit 3 Pressurized Spray Nozzle Transfer Function Database Development and Environmental Fatigue Evaluations; January 15, 2015.

7.

Attached to this declaration as Attachment 6 is a true and correct copy Exhibit ENT000689; Westinghouse, WCAP-12191, Rev. 4; Transient and Fatigue Cycle Monitoring Program Transient History Evaluation Report for Indian Point Unit 2; December 2014.

8.

Attached to this declaration as Attachment 7 is a true and correct copy of Exhibit ENT000690; Westinghouse, WCAP-16898-P, Rev. 1; Indian Point Unit 3 Transient and Fatigue Cycle Monitoring Program Transient History Evaluation; May 2015.

9.

Attached to this declaration as Attachment 8 is a true and correct copy of Exhibit NYS000363; Westinghouse, WCAP-17149-P, Rev. 1, Evaluation of Pressurizer Insurge/Outsurge Transients for Indian Point Unit 2 and Westinghouse, WCAP-17162-P, Rev.

1, Evaluation of Pressurizer Insurge/Outsurge Transients for Indian Point Unit 3; July 2010

10.

Attached to this declaration as Attachment 9 is a true and correct copy of Exhibit NYS000364; Westinghouse, Calculation Note CN-PAFM-09-21; Indian Point Units 2 and 3 Charging Nozzles Environmental Fatigue Evaluation; June 18, 2010.

11.

Attached to this declaration as Attachment 10 is a true and accurate copy of Exhibit NYS000365; Westinghouse, Calculation Note CN-PAFM-09-67; Pressurizer Surge Nozzle and Lower Head Transfer Functions for Indian Point Units 2 and 3; June 18, 2010.

12.

Attached to this declaration as Attachment 11 is a true and accurate copy Exhibit NYS000367; Westinghouse, Calculation Note CN-PAFM-09-79; Indian Point Unit 2 Boron Injection Tank Nozzle Environmental Fatigue Evaluations; June 18, 2010.

13.

Attached to this declaration as Attachment 12 is a true and correct copy of Exhibit

3 NYS000352; Entergy Communication, NL-10-082, Attachment 1 (NYS000352) (August 2010).

14.

Attached to this declaration as Attachment 13 is a true and correct copy of E-mail from Lisa S. Kwong to Paul M. Bessette; Ccing Kathryn M. Sutton, Raphael Philip Kuyler, Sherwin Turk, Brian Harris, Deborah Brancato, Lisa M. Burianek, John J. Sipos, Mihir Desai, Brain Lusignan, and Teresa Manzi;

Subject:

IP - Notice of objection to proprietary/confidentiality designation; Attachments: 2015 09 17 NYS Notice of Objection to Proprietary Designation FINAL.pdf ; Sent: Thursday, September 17, 2015, 4:39 PM.

15.

Attached to this declaration as Attachment 14 is a true and correct copy of E-mail from John J. Sipos to Paul M. Bessette and Raphael Philip Kuyler; Ccing Lisa M. Burianek, Brain Lusignan, Mihir Desai, Teresa Manzi, and Deborah Brancato;

Subject:

Entergys August Non-Public Filings; Sent: Monday, August 31, 2015, 6:31 PM

16.

Attached to this declaration as Attachment 15 is a true and correct copy of E-mail from Raphael Philip Kuyler to John J. Sipos and Paul M. Bessette; Ccing Lisa M. Burianek, Brain Lusignan, Mihir Desai, Teresa Manzi, Deborah Brancato, Kathryn M. Sutton, Sherwin Turk, and Martin ONeill;

Subject:

RE: Entergys August Non-Public Filings; Sent: Thursday, September 3, 2015, 8:55 AM.

17.

Attached to this declaration as Attachment 16 is a true and correct copy of letter from Kathryn M. Sutton and Paul M. Bessette to Administrative Judges Lawrence G. McDade, Dr. Michael F. Kennedy and Dr. Richard E. Wardwell; Re: Entergy Nuclear Operations, Inc.,

(Indian Point Nuclear Generating Units 2 and 3), Docket Nos. 50-247-LR and 50-286-LR -

Redacted Filings for Track 2 Contentions; Sent: September 18, 2015.

18.

Attached to this declaration as Attachment 17 is a true and correct copy of E-mail from Raphael Philip Kuyler to Lisa S. Kwong and Paul M. Bessette; Ccing Kathryn M. Sutton,

4 Sherwin Turk, Brian Harris, Deborah Brancato, Lisa M. Burianek, John J. Sipos, Mihir Desai, Brian Lusignan, Teresa Manzi and Martin ONeill;

Subject:

RE: IP - Notice of objection to proprietary/confidentiality designation; Sent: Monday, October 5, 2015, 1:34 PM.

19.

Attached to this declaration as Attachment 18 is a true and correct copy of Topical Report on ASME Section III Piping and Component Fatigue Analysis Utilizing the WESTEMS Computer Code, WCAP-17577-NP, Rev. 2, June 2013 (ML13170A026).

20.

Attached to this declaration as Attachment 19 is a true and correct copy of Ex.

NYS000513, Kupper, C. and M. Gray, License Renewal Environmental Fatigue Screening Application, PVP2014-29093, ASME Pressure Vessels and Piping Conference in Anaheim, California (2014).

21.

Attached to this declaration as Attachment 20 is a true and correct copy of WESTEMSTM Integrated Diagnostics and Monitoring Systems; Westinghouse Nuclear Services

/ Engineering Services; NS-ES 0078; March 2015.

22.

Attached to this declaration as Attachment 21 is a true and correct copy of EAF Screening: Process and Technical Basis for Identifying EAF Limiting Locations, EPRI Report 1024995 (August 2012).

23.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 19, 2015 Signed (electronically) by Lisa S. Kwong Assistant Attorney General Office of the Attorney General of the State of New York The Capitol Albany, New York 12224 (518) 776-2422 Lisa.Kwong@ag.ny.gov

UNITED STATES NUCLEAR REGULATORY COMMISSION 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.

October 19, 2015

---

x DECLARATION OF LISA S. KWONG Pursuant to 28 U.S.C. § 1746, Lisa S. Kwong hereby declares as follows:

1.

I serve as an Assistant Attorney General for the State of New York, counsel for petitioner-intervenor State of New York in this proceeding. I submit this declaration and accompanying attachments in support of the State of New Yorks motion for public disclosure of various Westinghouse documents.

2.

Attached to this declaration as Attachment 1 is a true and correct copy of the NYS Table of 10 Documents Subject to the States Motion.

3.

Attached to this declaration as Attachment 2 is a true and correct copy of Exhibit ENT000681; Westinghouse, WCAP-17199-P, Rev. 1; Environmental Fatigue Evaluation for Indian Point Unit 2; December 2014.

4.

Attached to this declaration as Attachment 3 is a true and correct copy of Exhibit ENT000682; Westinghouse, WCAP-17200-P, Rev. 1; Environmental Fatigue Evaluation for Indian Point Unit 3; December 2014.

5.

Attached to this declaration as Attachment 4 is a true and correct copy of Exhibit ENT000683; Westinghouse, Calculation Note CN-PAFM-13-32, Rev. 3; Indian Point Unit 2 (IP2) and Unit 3 (IP3) Refined EAF Analyses and EAF Screening Evaluations; June 25, 2015.

2

6.

Attached to this declaration as Attachment 5 is a true and correct copy of Exhibit ENT000688; Westinghouse, Calculation Note CN-PAFM-13-40, Rev. 1; Indian Point Unit 2 and Unit 3 Pressurized Spray Nozzle Transfer Function Database Development and Environmental Fatigue Evaluations; January 15, 2015.

7.

Attached to this declaration as Attachment 6 is a true and correct copy Exhibit ENT000689; Westinghouse, WCAP-12191, Rev. 4; Transient and Fatigue Cycle Monitoring Program Transient History Evaluation Report for Indian Point Unit 2; December 2014.

8.

Attached to this declaration as Attachment 7 is a true and correct copy of Exhibit ENT000690; Westinghouse, WCAP-16898-P, Rev. 1; Indian Point Unit 3 Transient and Fatigue Cycle Monitoring Program Transient History Evaluation; May 2015.

9.

Attached to this declaration as Attachment 8 is a true and correct copy of Exhibit NYS000363; Westinghouse, WCAP-17149-P, Rev. 1, Evaluation of Pressurizer Insurge/Outsurge Transients for Indian Point Unit 2 and Westinghouse, WCAP-17162-P, Rev.

1, Evaluation of Pressurizer Insurge/Outsurge Transients for Indian Point Unit 3; July 2010

10.

Attached to this declaration as Attachment 9 is a true and correct copy of Exhibit NYS000364; Westinghouse, Calculation Note CN-PAFM-09-21; Indian Point Units 2 and 3 Charging Nozzles Environmental Fatigue Evaluation; June 18, 2010.

11.

Attached to this declaration as Attachment 10 is a true and accurate copy of Exhibit NYS000365; Westinghouse, Calculation Note CN-PAFM-09-67; Pressurizer Surge Nozzle and Lower Head Transfer Functions for Indian Point Units 2 and 3; June 18, 2010.

12.

Attached to this declaration as Attachment 11 is a true and accurate copy Exhibit NYS000367; Westinghouse, Calculation Note CN-PAFM-09-79; Indian Point Unit 2 Boron Injection Tank Nozzle Environmental Fatigue Evaluations; June 18, 2010.

13.

Attached to this declaration as Attachment 12 is a true and correct copy of Exhibit

3 NYS000352; Entergy Communication, NL-10-082, Attachment 1 (NYS000352) (August 2010).

14.

Attached to this declaration as Attachment 13 is a true and correct copy of E-mail from Lisa S. Kwong to Paul M. Bessette; Ccing Kathryn M. Sutton, Raphael Philip Kuyler, Sherwin Turk, Brian Harris, Deborah Brancato, Lisa M. Burianek, John J. Sipos, Mihir Desai, Brain Lusignan, and Teresa Manzi;

Subject:

IP - Notice of objection to proprietary/confidentiality designation; Attachments: 2015 09 17 NYS Notice of Objection to Proprietary Designation FINAL.pdf ; Sent: Thursday, September 17, 2015, 4:39 PM.

15.

Attached to this declaration as Attachment 14 is a true and correct copy of E-mail from John J. Sipos to Paul M. Bessette and Raphael Philip Kuyler; Ccing Lisa M. Burianek, Brain Lusignan, Mihir Desai, Teresa Manzi, and Deborah Brancato;

Subject:

Entergys August Non-Public Filings; Sent: Monday, August 31, 2015, 6:31 PM

16.

Attached to this declaration as Attachment 15 is a true and correct copy of E-mail from Raphael Philip Kuyler to John J. Sipos and Paul M. Bessette; Ccing Lisa M. Burianek, Brain Lusignan, Mihir Desai, Teresa Manzi, Deborah Brancato, Kathryn M. Sutton, Sherwin Turk, and Martin ONeill;

Subject:

RE: Entergys August Non-Public Filings; Sent: Thursday, September 3, 2015, 8:55 AM.

17.

Attached to this declaration as Attachment 16 is a true and correct copy of letter from Kathryn M. Sutton and Paul M. Bessette to Administrative Judges Lawrence G. McDade, Dr. Michael F. Kennedy and Dr. Richard E. Wardwell; Re: Entergy Nuclear Operations, Inc.,

(Indian Point Nuclear Generating Units 2 and 3), Docket Nos. 50-247-LR and 50-286-LR -

Redacted Filings for Track 2 Contentions; Sent: September 18, 2015.

18.

Attached to this declaration as Attachment 17 is a true and correct copy of E-mail from Raphael Philip Kuyler to Lisa S. Kwong and Paul M. Bessette; Ccing Kathryn M. Sutton,

4 Sherwin Turk, Brian Harris, Deborah Brancato, Lisa M. Burianek, John J. Sipos, Mihir Desai, Brian Lusignan, Teresa Manzi and Martin ONeill;

Subject:

RE: IP - Notice of objection to proprietary/confidentiality designation; Sent: Monday, October 5, 2015, 1:34 PM.

19.

Attached to this declaration as Attachment 18 is a true and correct copy of Topical Report on ASME Section III Piping and Component Fatigue Analysis Utilizing the WESTEMS Computer Code, WCAP-17577-NP, Rev. 2, June 2013 (ML13170A026).

20.

Attached to this declaration as Attachment 19 is a true and correct copy of Ex.

NYS000513, Kupper, C. and M. Gray, License Renewal Environmental Fatigue Screening Application, PVP2014-29093, ASME Pressure Vessels and Piping Conference in Anaheim, California (2014).

21.

Attached to this declaration as Attachment 20 is a true and correct copy of WESTEMSTM Integrated Diagnostics and Monitoring Systems; Westinghouse Nuclear Services

/ Engineering Services; NS-ES 0078; March 2015.

22.

Attached to this declaration as Attachment 21 is a true and correct copy of EAF Screening: Process and Technical Basis for Identifying EAF Limiting Locations, EPRI Report 1024995 (August 2012).

23.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 19, 2015 Signed (electronically) by Lisa S. Kwong Assistant Attorney General Office of the Attorney General of the State of New York The Capitol Albany, New York 12224 (518) 776-2422 Lisa.Kwong@ag.ny.gov