ML063280030

Entergys Initial Disclosures

ML063280030
Person / Time
Site:	Pilgrim
Issue date:	11/15/2006
From:	Gaukler P Entergy Nuclear Generation Co, Entergy Nuclear Operations, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:	Atomic Safety and Licensing Board Panel
Giitter R
References
50-293-LR, ASLBP 06-848-02-LR, RAS 12575
Download: ML063280030 (8)

Text

P, A-S /;)-s *19--

November 15,2006 UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC November 15, 2006 (4:13pm)

Before the Atomic Safety and Licensing Board OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF In the Matter of

))

Entergy Nuclear Generation Company and )

Docket No. 50-293-LR Entergy Nuclear Operations, Inc.

)

ASLBP No. 06-848-02-LR

)

(Pilgrim Nuclear Power Station)

)

ENTERGY'S INITIAL DISCLOSURES Pursuant to 10 C.F.R. § 2.336(a), Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc. ("Entergy") hereby make the following initial disclosures.

1.

Testifying Witnesses Entergy has not yet identified the persons upon whom it will rely as witnesses with respect to the admitted contentions. In accordance with 10 C.F.R. § 2.336(d), Entergy will supplement this disclosure after testifying witnesses are identified.

2.

Documents and Data Compilations Documents and data compilations that are relevant to Pilgrim Watch Contention 1 and Pilgrim Watch Contention 3, as admitted by the Atomic Safety and Licensing Board and that are not privileged or otherwise subject to protected status, are being provided on compact disks to the Pilgrim Watch and the NRC Staff. Entergy is not, however, providing copies of pleadings and attachments that have been served on the Board and pahrties in this licensing proceeding. provides a description and location of additional documents, or categories of SeSY- 03 7

s

-~-a1

documents, that have been identified by Entergy as relevant to these contentions, but have not yet been provided on compact disks.

3.

Tangible Things Other than documents provided or listed, no relevant tangible things have been identified.

4.

Privilege Log As set forth in the parties' "Joint Stipulation and Motion on Disclosure" dated November 14, 2006, counsel for the parties have agreed that the privilege logs required by 10 C.F.R. § 2.336(a)(3) and (b)(5) need not identify documents that are subject to the attorney-client or work product privileges. The list of documents to which other privileges would apply or that have protected status because they contain proprietary information, is provided as Attachment 2. With respect to documents containing proprietary information, Entergy is prepared to seek any necessary authorization from other entities to provide copies of proprietary documents to those parties and their representatives executing a mutually acceptable confidentiality agreement, or otherwise disclose such documents pursuant to a protective order.

Respectfully Submitted, David R. Lewis Paul A. Gaukler PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W.

Washington, DC 20037-1128 Tel. (202) 663-8474 Counsel for Entergy Nuclear Generation Company, and Entergy Nuclear Operations, Inc.

Dated: November 15, 2006 2

Attachment I Additional Documents, or Categories and Locations, Relevant to the Admitted Contentions Relevant Document/Cateeorv Location Contention NUREG-1801, Generic Aging Lessons Learned, Rev. 1 www.nrc.gov PW-1 Safety Guide 23: Onsite Meteorological Programs www.nrc.gov PW-I Reg. Guide 1.145: Atmospheric Dispersion Models for Potential www.nrc.gov PW-3 Accident Consequence Assessment at Nuclear Power Plants Log of Documents Containing Proprietary Information No.

Document Date Entity Claiming Document Description Proprietary Status 1

02/02/1998 KLD KLD Proposal for Revision 5 ETE Associates/Entergy

2.

08/18/1998 KLD Purchase Order Request for Revision 5 ETE Associates/Entergy

3.

02/13/1998 KLD Budget Oversight Committee Agenda and Associates/Entergy Attachments

4.

05/19/1998 KLD Work Order for Revision 5 ETE Associates/Entergy

5.

01/22/1998 KLD Sole Purchase Order Request for Revision 5 Associates/Entergy ETE

6.

01/14/1998 KLD Draft Sole Purchase Order Request for Associates/Entergy Revision 5 ETE 7

02/03/2003 KLD Contract Request for Revision 6 ETE with Associates/Entergy Attachments.

8 02/19/2003 KLD KLD Draft Proposal for Revision 6 ETE Associates/Entergy

9.

08/16/2004 KLD KLD Invoice and Progress Report Associates/Entergy

10.

08/17/2004 KLD KLD Facsimile with Invoices and Progress Associates/Entergy Reports 11 01/27/2004 KLD KLD Draft Scope of Work and Proposal for Associates/Entergy Revision 6 ETE 12 12/01/2004 KLD KLD Invoices Associates/Entergy II

November 15, 2006 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

))

Entergy Nuclear Generation Company and )

Entergy Nuclear Operations, Inc.

)

)

(Pilgrim Nuclear Power Station)

)

Docket No. 50-293-LR ASLBP No. 06-848-02-LR CERTIFICATE OF SERVICE I hereby certify that copies of "Entergy's Initial Disclosures" dated November 15, 2006, and Certification of Initial Disclosure Affidavit of Fred Mogolesko executed November 13, 2006, 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 15th day of November, 2006.

• Administrative Judge Ann Marshall Young, Esq., Chair Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 amy('nrc.gov

• Administrative Judge Paul B. Abramson Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 pba@nrc.gov

• Administrative Judge Dr. Richard F. Cole Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 rfcl@nrc.gov

• Secretary Att'n: Rulemakings and Adjudications Staff Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 secy@nrc.gov, hearingdocket(@nrc.gov

Office of Commission Appellate Adjudication Mail Stop 0-16 C I U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

• Susan L. Uttal, Esq.

• Marian L. Zobler, Esq.

Office of the General Counsel Mail Stop 0-15 D21 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 slu~nrc.gov; mlz@nrc.gov

• Ms. Mary Lampert 148 Washington Street Duxbury, MA 02332 lampert@adelphia.net

• Sheila Slocum Hollis, Esq.

Duane Morris LLP 1667 K Street, N.W.

Suite 700 Washington, D.C. 20006 sshollis@duanemorris.com

• Chief Kevin M. Nord Fire Chief and Director, Duxbury Emergency Management Agency 688 Tremont Street P.O. Box 2824 Duxbury, MA 02331 nord@town.duxbury.ma.us Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

• Mr. Mark D. Sylvia Town Manager Town of Plymouth I 1 Lincoln St.

Plymouth MA, 02360 msylvia@townhall.plymouth.ma.us

• Molly H. Bartlett, Esq.

52 Crooked Lane Duxbury, MA 02332 mollyhbartlett@,hotmail.com

• Richard R. MacDonald Town Manager 878 Tremont Street Duxbury, MA 02332 macdonald@town.duxbury.ma.us Paul A. Ga*er L~2QL~

2 400486640vl

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

))

Entergy Nuclear Generation Company and )

Docket No. 50-293-LR Entergy Nuclear Operations, Inc.

)

ASLBP No. 06-848-02-LR

)

(Pilgrim Nuclear Power Station)

)

Certification of Initial Disclosure Affidavit of Fred Mogolesko County of Plymouth

))

State of Massachusetts

)

I, Fred Mogolesko, being duly sworn, state:

I am the License Renewal Project Manager for the Pilgrim Nuclear Power Station. My business address is Pilgrim Nuclear Station, 600 Rocky Hill Road, Plymouth, MA 02360. I am authorized to provide this certification, pursuant to 10 C.F.R. § 2.336(c), on behalf of Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc. ("Entergy").

To the best of my knowledge, information and belief, the initial disclosures in the above captioned proceeding contain all materials required to be disclosed by 10 C.F.R. § 2.336(a) that were identified as relevant to the admitted contentions through a search of the information and documentation reasonably available to Entergy.

Further, to the best of my knowledge, information and belief, and based on representations of personnel who were instructed to perform a diligent search, these disclosures are accurate and complete as of this date.

Further the affiant sayeth not.

Fred Mogolesko Subscribed and sworn to before me this A-day of,(4 4

, 2006 Notary Public My commission expires: /

Notary Pl msO M.

PLUMMER CamoaWt of Mmawb