ML060260043

2006/01/13-Entergy's Thirteenth Supplemental Discovery Disclosures and Certification of Entergy'S Thirteenth Supplemental Discovery Disclosures

ML060260043
Person / Time
Site:	Vermont Yankee
Issue date:	01/13/2006
From:	Travieso-Diaz M Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:	Atomic Safety and Licensing Board Panel
Byrdsong A T
References
50-271-OLA, ASLBP 04-832-02-OLA, RAS 11098
Download: ML060260043 (7)

Text

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,1AtEVDEOPRRESPQND January NQRCED UJSNRC UNITED STATES OF AMERICA January 13, 2006 (2:28pm)

NUCLEAR REGULATORY COMMISSION OFFICE OF SECRETARY RULEMAKINGS AND Before the Atomic Safety and Licensing Board ADJUDICATIONS STAFF

)

In the Matter of )

) Docket No. 50-271 ENTERGY NUCLEAR VERMONT )

YANKEE, LLC and ENTERGY ) ASLBP No. 04-832-02-OLA NUCLEAR OPERATIONS, INC. ) (Operating License Amendment)

(Vermont Yankee Nuclear Power Station) )

)

ENTERGY'S THIRTEENTH SUPPLEMENTAL DISCOVERY DISCLOSURES Pursuant to 10 C.F.R. § 2.336(d), Applicants Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. ("Entergy") hereby make the following supplemental discovery disclosures.

Documents and Data Compilations Additional non-privileged, non-proprietary documents and data compilations relevant to the admitted contentions are being provided to the parties as follows: one compact disk is being provided to the Vermont Department of Public Service ("DPS") with respect to Contentions DPS 1 and 2; one compact disk is being provided to the New England Coalition ("NEC") with respect to Contentions NEC 3 and 4 (Modified); and two compact disks are being provided to the NRC Staff with respect to Contentions DPS 1 and 2 and NEC 3 and 4 (Modified).

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In addition, following is a supplement to the log provided on March 31, 2005 of documents ("Proprietary Documents") that counsel for Entergy in good faith believes contain information that qualifies under 10 C.F.R. § 2.390(a)(4) and (b)(4)(i)-(v) as a trade secret and commercial or financial information of Entergy or its vendors and contractors and should be protected in accordance with the terms of the Board's Order (Protective Order Governing Non-Disclosure of Proprietary Information) dated March 1, 2005:

Documents relating to Contentions DPS 1&2:

Document Bates Range Document Title Company Number ____________________________________

RAI Response: "Safety Analysis Report for Vermont Yankee Nuclear EPU005439 EPU 135656 - Power Station Constant Pressure Power Uprate." Contains details of GE's GE EPU 135822 methodology, assumptions and inputs for performing containment analysis.

oomments on Draft Safety Evaluation. Contains details of GE's EPU 135823 - proprietary core analysis methods including results and comparison to PU005442 EPU 135887 plant data; also contains details of GE's methodology, assumptions and GE esults for performing analyses in support of a Constant Pressure Power

____ _______ ____ ____ prate.

These documents are being provided to DPS pursuant to the terms of the Board's March 1, 2005 Protective Order, under which the documents and the proprietary information they contain can only be made available to persons executing Confidentiality and Non-Disclosure Agreements substantially identical to the form included in Attachment A to the Protective Order.

Also, one additional proprietary document relating to NEC Contentions 3 and 4 (Modified) has been identified. It is:

Documents relating to Contentions NEC 3 and NEC 4 (Modified):

Respectfully submitted, Jay E. Silberg Matias F. Travieso-Diaz PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W.

Washington, DC 20037-1128 Tel. (202) 663-8063 Counsel for Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

Dated: January 13, 2006

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of }

Docket No. 50-271 ENTERGY NUCLEAR VERMONT )

YANKEE, LLC and ENTERGY ) ASLBP No. 04-832-02-OLA NUCLEAR OPERATIONS, INC. ) (Operating License Amendment)

(Vermont Yankee Nuclear Power Station) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of "Entergy's Thirteenth Supplemental Discovery Disclosures" and "Certification of Entergy's Thirteenth Supplemental Discovery Disclosures -

Affidavit of Craig J. Nichols" were served on the persons listed below by deposit in the U.S.

mail, first class, postage prepaid, and where indicated by an asterisk by electronic mail, this 13th day of January, 2006.

• Administrative Judge *Administrative Judge Alex S. Karlin, Chair Lester S. Rubenstein Atomic Safety and Licensing Board Panel 4760 East Country Villa Drive Mail Stop T-3 F23 Tucson AZ 85718 U.S. Nuclear Regulatory Commission lesrrr()comcast.net Washington, D.C. 20555-0001 ask2Qnrc. gov

• Administrative Judge Atomic Safety and Licensing Board Dr. Anthony J. Baratta Mail Stop T-3 F23 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop T-3 F23 Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ajb5(Rnrc.gov

• Secretary Office of Commission Appellate Att'n: Rulemakings and Adjudications Staff Adjudication Mail Stop 0-16 CI Mail Stop 0-16 CI U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 secy(-),nrc.gov, hearingdocket(anrc.gov

• Sarah Hofmann *Sherwin E. Turk, Esq.

Special Counsel *Robert Weisman, Esq.

Department of Public Service *Jason C. Zorn, Esq.

112 State Street - Drawer 20 Office of the General Counsel Montpelier, VT 05620-2601 Mail Stop 0-15 D21 Sarah.Hofmann(istate.vt.us U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 set(a)nrc.gov, rmw(inrc.gov, icz(cnrc.gov

• Anthony Z. Roisman *Raymond Shadis National Legal Scholars Law Firm New England Coalition 84 East Thetford Rd. P.O. Box 98 Lyme, NH 03768 Shadis Road aroismantanationallegalscholars.com Edgecomb ME 04556 shadis(oprexar.com

• Jonathan Rund *Jered Lindsay Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 jmr3ARnrc.gov JJL5(anrc.gov 4,4, F. / X Matias F. Travieso-Diaz 'I

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

) Docket No. 50-271 ENTERGY NUCLEAR VERMONT )

YANKEE, LLC and ENTERGY ) ASLBP No. 04-832-02-OLA NUCLEAR OPERATIONS, INC. ) (Operating License Amendment)

(Vermont Yankee Nuclear Power Station) )

)

CERTIFICATION OF ENTERGY'S THIRTEENTH SUPPLEMENTAL DISCOVERY DISCLOSURES AFFIDAVIT OF CRAIG J. NICHOLS County of Windham )

)

State of Vermont )

I, Craig J. Nichols, being duly sworn according to law, depose and state the following:

1. I am the Extended Power Uprate Project Manager for Entergy Nuclear Operations, Inc. My business address is 320 Governor Hunt Road, P.O. Box 250, Vernon, VT 05354. I am authorized to provide this certification, pursuant to 10 C.F.R. § 2.336(c), on behalf of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. ("Entergy").

2. As Extended Power Uprate Project Manager I am responsible for the gathering and preparation of all of the analyses and documentation associated with the Extended Power Uprate for Vermont Yankee Nuclear Power Station. In connection with Entergy's thirteenth supplemental document disclosures in this proceeding, I have personally overseen the review and classification of all relevant documents and the production of the file compilations being provided by Entergy.

3. To the best of my knowledge, information and belief, Entergy's Thirteenth Supplemental Discovery Disclosures, dated January 13, 2006, describe and transmit all materials required to be disclosed by 10 C.F.R. § 2.336(d) that were identified as relevant to the admitted contentions through a search of the information and documentation reasonably available to and under Entergy's possession, custody, or control.

4. Further, to the best of my knowledge, information, and belief, and based on a review of the information and documentation currently reasonably available to and under the possession, custody, or control of Entergy, these disclosures are accurate and complete as of the date of this certification.

Further, the affiant sayeth not.

Craig J. Nichols Subscnibed and sworn to before me this // day of January, 2006.

Notary c i eL My commission expires ZI Lo /