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Category:Legal-Pre-Filed Exhibits
MONTHYEARML16081A3252016-03-21021 March 2016 NRCR12001 - NRC Staff Prefiled Hearing Exhibit List (Revised) ML16078A4172016-03-18018 March 2016 ENTR20726 - Entergy Track 2 Exhibit List ML16078A4122016-03-18018 March 2016 NRC000236 - Crack Growth Rate Comparison - Eason Pathania Model to MRP Model- Excel Spreadsheet ML16078A4132016-03-18018 March 2016 NRCR11001 - Exhibt List NRC Staff Prefiled Hearing Exhibit List (Revised) ML15321A0352015-11-17017 November 2015 NYS000582 - Diagram of Strength Vs Amplitude by Dr. Richard T. Lahey ML15315A0132015-11-11011 November 2015 ENTR00726 - Track 2 Hearing Exhibit List ML15309A2212015-11-0505 November 2015 NRCR10001 - NRC Staff Track 2 Exhibit List ML15309A1712015-11-0505 November 2015 RIVR14001 - Riverkeeper Tailored Track 2 Exhibit List ML15309A1292015-11-0505 November 2015 ENT000726 - Entergy Track 2 Hearing Exhibit List ML15313A4602015-11-0404 November 2015 NYSR25001 - Corrected Page 24 to Exhibits List Relevant to Track 2 Contentions ML15309A1552015-11-0404 November 2015 NYSR25001 - NYS Revised Tailored Exhibits List Relevant to Track 2 Contentions ML15307A1152015-11-0303 November 2015 NYSR24001 - State of Ny Revised Hearing Exhibits List ML15307A8112015-11-0303 November 2015 NRC000230 - Corrections to Prefiled Testimony NRC000168 and NRC000197 ML15302A4672015-10-29029 October 2015 ENTR16001 - Entergy Revised Exhibit List ML15252A4442015-09-0909 September 2015 NYS000563 - Pressurized Water Reactor (PWR) Systems, USNRC Technical Training Center, Reactor Concepts Manual, Pages 4-1 to 4-28 ML15252A5792015-09-0909 September 2015 NYS Updated Exhibit List ML15252A5752015-09-0909 September 2015 NYS000573 - 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) ML15252A5112015-09-0909 September 2015 RIVR13001 - Riverkeeper Updated Exhibit List ML15252A5092015-09-0909 September 2015 RIV000164 - 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) ML15252A5062015-09-0909 September 2015 NYS000570 - 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) ML15252A5042015-09-0909 September 2015 NYS000568 - Supplemental Reply Statement of Position of the State of New York in Support of Contention NYS-25 (Public, Redacted) (September 9, 2015) ML15252A4432015-09-0909 September 2015 NYS000566 - Figure 1 for Supplemental Reply Testimony of Dr. Richard T. Lahey ML15261A8302015-09-0404 September 2015 ENTR00615 - Entergy'S Statement of Position Re Contention NYS-25 (Embrittlement) - Redacted ML15222A9152015-08-10010 August 2015 ENT000648 - 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 Evaluation Guidelines (Undated) ML15222B1242015-08-10010 August 2015 ENT000680 - Curriculum Vitae of Barry M. Gordon ML15223A4542015-08-10010 August 2015 NRC000207 - Regulatory Information Conference Presentation Slides, Recent Materials Inspections of PWR Reactor Internals (Mar. 2015) ML15223A6752015-08-10010 August 2015 NRC000227 - Gary Stevens Statement of Professional Qualifications ML15223A7792015-08-10010 August 2015 NRC000224 - IP3 FSAR Rev. 04 Chapter 16 ML15222B1692015-08-10010 August 2015 ENTR00031 - Curriculum Vitae of Alan B. Cox ML15222A8482015-08-10010 August 2015 ENT000637 - NUREG-1874, Recommended Screening Limits for Pressurized Thermal Shock (PTS) (March 2010) ML15261A8342015-08-10010 August 2015 ENT000698 - Entergy'S Revised Statement of Position Regarding Contention NYS-38/RK-TC-5(Safety Commitments) (Aug. 10, 2015)Redacted ML15261A8322015-08-10010 August 2015 ENT000678 - 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 ML15223A3452015-08-10010 August 2015 ENTR15001 - Entergy Hearing Exhibit List (Ent Exhibit List) ML15223A3932015-08-10010 August 2015 NRCR00104 - on Yee Statement of Professional Qualifications (Revised) ML15222B1262015-08-10010 August 2015 ENT000687 - 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) ML15223A3862015-08-10010 August 2015 NRC000222 - IP3 FSAR Rev. 04 Chapter 3 (2011) (Excerpt) ML15222B1612015-08-10010 August 2015 ENTR00186 - Curriculum Vitae of Mark A. Gray ML15223A3702015-08-10010 August 2015 NRC000220 - Pressurized Water Reactor Owners Group (PWROG) Presentation Slides, Industry and NRC Coordination Meeting Materials Programs Technical Exchange: Clevis Insert Bolt Update, (June 2014) ML15223A8052015-08-10010 August 2015 NRC000169 - Indian Point, Unit 2 Technical Specifications (Excerpt) ML15223A2722015-08-10010 August 2015 NRC000226 - Jeffrey C. Poehler Statement of Professional Qualifications ML15223A7872015-08-10010 August 2015 NRC000196 - NRC Staff'S Initial Statement of Position on Contention NYS-25 (Reactor Vessel Internals) ML15223A7832015-08-10010 August 2015 NRC000228 - Indian Point Unit 2 Technical Specifications 3.1.4 ML15223A9452015-08-10010 August 2015 NRC000223 - IP3 FSAR Rev. 04 Chapter 14 (2011) ML15223A6122015-08-10010 August 2015 NRCR20101 - NRC Staff'S Revised Statement of Position Regarding NYS 26B/RK-TC-1B ML15223A4512015-08-10010 August 2015 NRC000206 - Indian Point, Unit 2, Updated Final Safety Analysis Report (Ufsar), Rev. 25, Chapter 14 - Safety Analysis (2014) ML15223A2692015-08-10010 August 2015 NRC000183 - NRC Inspection Manual, Inspection Procedure 71013, Site Inspection for Plants with a Timely Renewal Application (Sept. 25, 2013) ML15223A6712015-08-10010 August 2015 NRCR00147- NRC Staff'S Revised Statement of Position on State of New York and Riverkeeper'S Joint Contention NYS-38/RK-TC5 (Revised) ML15222B1702015-08-10010 August 2015 ENTR00184 - Curriculum Vitae of Jack R. Strosnider ML15223A7022015-08-10010 August 2015 NRCR900001 - NRC Staff Pre-filed Hearing Exhibit List (Revised) ML15223A7812015-08-10010 August 2015 NRC000226 - Jeffrey C. Poehler Statement of Professional Qualifications 2016-03-21
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
___________________________________________ )
In the Matter of ) Docket Nos. ) 50-247-LR Entergy Nuclear Operations, Inc. ) and 50-286-LR (Indian Point Nuclear Generating )
Units 2 and 3) ) July 13, 2012
___________________________________________ )
Declaration of Phillip Musegaas in Support of Intervenors' Rebuttal to Entergy's Initial Hearing Submissions Pertaining to Consolidated Contention RK-EC-3/CW-EC-1 Phillip Musegaas hereby declares under penalty of perjury that the following is true and correct: 1. I am currently employed by Riverkeeper, Inc., and hold the position of Hudson River Program Director. 2. I am co-counsel for petitioner-intervenor Riverkeeper in the above-referenced proceeding concerning the application by Entergy Nuclear Operations, Inc. ("Entergy") for a renewal of the two separate operating licenses for the nuclear power generating facilities located at Indian Point on the east bank of the Hudson River in the Village of Buchanan, Westchester County, New York, for twenty years beyond their current expiration dates. 3. I submit this declaration in support of Riverkeeper and Hudson River Sloop Clearwater, Inc.'s Consolidated Contention RK-EC-3/CW-EC-1 concerning the inadequate environmental review of spent fuel pool leaks and radiological contamination at Indian Point.
- 4. I began my employment with Riverkeeper in August, 2005. 5. From August 2005 - October 2006, I was a Policy Analyst for Riverkeeper. 6. From October 2006 - September 2008, I was a Staff Attorney for Riverkeeper, assigned to work on Riverkeeper's Indian Point Campaign, which included preparing to participate in the Indian Point license renewal process before the Nuclear Regulatory Commission.
2 7. From September 2008 to the present, I have held the position of Hudson River Program Director
. 8. In the course of my employment at Riverkeeper, in t h e s p r i n g o f 2007 , I was personally and directly involved in a project concerning a proposed study of the impact of radiological leaks from Indian Point on the Hudson River ecosystem.
- 9. I n p a r t i c u l a r , a t t h a t t i m e , I contacted Dr. Chris Gobler, an Associate Professor at Stony Brook University, to discuss a possible study of Hudson River sediments, fish and shellfish in the vicinity of the Indian Point nuclear power plant, to determine whether the aforementioned biota or sediment contained elevated levels of radionuclides. Riverkeeper's interest in having this study conducted arose following the disclosure by Entergy of leaks of radioactively contaminated water from Indian Point's spent fuel pools in 2005. At the time, I was responsible for Riverkeeper's efforts to commission this study.
1 0. On August 17, 2007, Dr. Gobler submitted a study proposal to Riverkeeper, which Entergy has offered in this proceeding as Exhibit ENT000367.
1 1. Riverkeeper accepted the proposal, and Dr. Gobler began collecting samples in October 2007. Some limited collection of clam and sediment samples was performed using Riverkeeper's boat, under the supervision of John Lipscomb, Riverkeeper's boat captain and manager of the Boat Program.
Dr. Gobler also collected samples independently, without Riverkeeper's assistance.
1 2. On July 10, 2008, Dr. Gobler sent an e
-mail to me and other Riverkeeper staff, describing the initial results of his analysis of samples collected during the previous year.
A copy of this email was submitted into this proceeding by Entergy as Entergy Exhibit ENT000368.
1 3. As described in the email from Dr. Gobler, none of the shellfish samples he collected and analyzed had detectable levels of the radionuclides being tested for. In the same email message, Dr. Gobler expressed interest in conducting further sample collection and continuing the study
.
3 1 4. As of July 2008, samples of aquatic biota and sediments in the Hudson River h a d only b e e n collected during the fall of 2007, in one sampling season.
1 5. Due to staffing and resource constraints, Riverkeeper d i d n o t a s k Dr. Gobler to collect additional samples of aquatic biota or Hudson River sediments subsequent to the initial 2007 sample collection effort.
1 6. Dr. Gobler was also not asked by Riverkeeper to prepare a final report summarizing his initial study, due to Riverkeeper's limited resources.
1 7. In my capacity as the Riverkeeper employee responsible for this work, and based on my discussions with Dr. Gobler, I did not consider the sample collection and analysis done by Dr. Gobler to be a complete study. For that reason, the initial results of the study, documented in Dr. Gobler's July 10, 2008 email, ENT000368, were not cited or referenced in Riverkeeper's pre
-filed direct testimony on Contention RK
-EC-3/CW-EC-1. 1 8. B a s e d o n t h e i n c o m p l e t e n a t u r e o f t h e w o r k c o n d u c t e d b y D r. G o b l e r , i t i s m y u n d e r s t a n d i n g t h a t g e n e r i c c o n c l u s i o n s w e r e n o t , n o r c o u l d b e , m a d e b a s e d u p o n t h e s a m p l i n g r e s u l t s o b t a i n e d. 1 9. I declare under penalty of perjury that the foregoing is true and correct.
Executed on July 13, 20 1 2. Signed (electronically) by Phillip Museg a as Phillip Musegaas, Esq.