ML053000156

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Entergy'S Tenth Supplemental Discovery Disclosures
ML053000156
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 10/14/2005
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 10669
Download: ML053000156 (10)
v • d • e


Text

4t RA /066 9 RM1ANM CORPRESPONDMt October 14, 2005 DOCKETED UNITED STATES OF AMERICA . USNRC NUCLEAR REGULATORY COMMISSION October 14, 2005 (3:36pm)

Before the Atomic Safety and Licensing Board OFFICE OF SECRETARY RULEMAKINGS AND 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 TENTH 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 I and 2; one compact disk is being provided to the New England Coalition ("NEC") with respect to Contentions NEC 3 and 4; and two compact disks are being provided to the NRC Staff with respect to Contentions DPS I and 2 and NEC 3 and 4.

Remplate - seC-0 35

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 Title _______________________________________

IPU 122635 - ngineering Report: Containment Isolation. Contains details of EPU004990 EPU 12263 E's methodology, assumptions, and results for performing GE PU 122683 nalyses in support of a Constant Pressure Power Uprate.

ngineering Report: Standby Liquid Control System. Contains EPU004991 EPU 122684 - etails of GE's methodology, assumptions and results for GE EPU 122739 erforming analyses in support of a Constant Pressure Power

_prate.

PU 122740 - ngineering Report: ECCS-LOCA SAFERIGESTR. Contains EPU004992 PU 122838 ssumptions and discussion of results from GE's proprietary GE LOCA methodology.

ngineering Report Cover Sheet: Reactor Vessel Integrity-Stress EPU004994 EPU 122839 - valuation. Contains details fo GE's methodology, assumptions GE EPU 122947 nd results for performing Reactor Pressure Vessel integrity evaluations.

PU 122948 - ngineering Report: ECCS-LOCA SAFER/GESTR. Contains EPU004995 U 12946 assumptions and discussion of results from GE's proprietary GE LOCA methodology.

U 123047 - Nuclear Management Manual: Containment System Response.

EPU004997 PU 123179 ontains details of GE's methodology, assumptions and inputs GE for performing containment analysis.

The S&W portion of this document is Response to RAI 1EPB-B-

. S&W Proprietary Basis: This document reveals a portion of he S&W BOP power uprate evaluation process and specifically PU 123180 - escribes the methods used to assess the impact of extended U005093 PU 123479 ower uprate on radiation levels on-site and off-site. GE GE & S&W roprietary Basis: Response to Request for Additional Information. Contains details of GE's methodology, assumptions, nd results for performing analysis in support of a Constant Pressure Power Uprate.

EPU 123480 - evised Response to RAI SRXB-A-6. Contains details of GE's EPU005094 EPU 123500 roprietary core analysis methods including results and GE Pomparison to plant data.

PU 123501 - evised Response to RAI SRXB-A-6. Contains details of GE's PU005095 U 123521 roprietary core analysis methods including results and GE

_ _ comparison to plant data.

Document Bates Range Document Title Company Responses to RAls SRXB-A-7 through SRXB-A-58. Contains cPU005096 EPU 123522 - details of GE's methodology, assumptions and results for EPL0056 EPU 123657 erforming analyses in support of a Constant Pressure Power GE e .

PU PU07123658 - sponses to RAI SRXB-7. Contains details of GE's proprietary EPU005097 *PU 123784 ore analysis methods including results and comparison to plant GE data.

EPU 123785 - esponses to RAI SRXB-7. Contains details of GE's proprietary EPU005098 EPU 123911 ore analysis methods including results and comparison to plant GE data.

UPU 123912 - esponses to RAI SRXB-7. Contains details of GE's proprietary EPU005099 EPU 124038 ore analysis methods including results and comparison to plant GE

_ __ _ _ _ _ _ _ _ _ _ _ _ ata.

EPU005100 EPU 124039- Draft for review - unverified RAT's SRXB-7, 9, 19, 21, and 22 GE EPU 124040 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

tter: Responses to NRC RAls SPSB-51 and SRXB-7, 8, 9, 10, PU 124041 - 13, 14,15,16,17, 19,20,21,22, and 23 GE-VYNPS-AEP-395.

EPU005 101 PU 124091 ontains details of GE's methodology, assumptions and results GE or performing analyses in support of a Constant Pressure Power

_ _prate.

Leter: Responses to NRC RAls SPSB-51 and SRXB-7, 8, 9, 10, U 124092 - 13, 14, 15, 16, 17, 19,20,21,22, and 23 GE-VYNPS-AEP-395.

PU005102 EPU 124142 Contains details of GE's methodology, assumptions and results GE for performing analyses in support of a Constant Pressure Power Uprate Letter: Responses to NRC RAls SPSB-51 and SRXB-7, 8, 9, 10, U10U 124143- 13, 14,15, 16, 17, 19,20, 21, 22, and 23 GE-VYNPS-AEP-395.

PU005103 -PU 124196 Contains details of GE's methodology, assumptions and results GE for performing analyses in support of a Constant Pressure Power Uprate Letter: Responses to NRC RAls SPSB-51 and SRXB-7, 8, 9, 10, TU 124197 - 13, 14,15, 16,17, 19,20,21,22, and 23 GE-VYNPS-AEP-395.

PU005104 U 124250 Contains details of GE's methodology, assumptions and results GE for performing analyses in support of a Constant Pressure Power

_prate Request for Additional Information Regarding Proposed License U 124251 - Amendment Extended Power Uprate. Discloses CDI proprietary PU005105 U 124306 aspects of a loads transfer algorithm that, if disclosed to CDI competitors; would permit duplication of the algorithm and result in a loss of competitive advantage in the industry.

Request for Additional Information Regarding Proposed License PU 124307 - Amendment Extended Power Uprate. Discloses CDI proprietary PU005106 U 124363 aspects of a loads transfer algorithm that, if disclosed to CDI 146 competitors, would permit duplication of the algorithm and result in a loss of competitive advantage in the industry.

Request for Additional Information Regarding Proposed License PU7 124364 - Amendment Extended Power Uprate. Discloses CDI proprietary EPU005107 EPU 124430 aspects of a loads transfer algorithm that, if disclosed to CDI competitors, would permit duplication of the algorithm and result in a loss of competitive advantage in the industry.

Document Bates Range Document Title Company Title _____________________________________

Request for Additional Information Regarding Proposed License EPU 124431 - Amendment Extended Power Uprate. Discloses CDI proprietary U005 108 PU 124498 aspects of a loads transfer algorithm that, if disclosed to CDI competitors, would permit duplication of the algorithm and result in a loss of competitive advantage in the industry.

Request for Additional Information Regarding Proposed License EPU005109 PU 124499 - Aendment Extended Power Uprate. Discloses CDI proprietary PU 124564 aspects of a loads transfer algorithm that, if disclosed to CDI competitors, would permit duplication of the algorithm and result in a loss of competitive advantage in the industry.

Request for Additional Information Regarding Proposed License UPU 124565 - Amendment Extended Power Uprate. Discloses CDI proprietary PU005110 EPU 124626 aspects of a loads transfer algorithm that, if disclosed to CDI competitors, would permit duplication of the algorithm and result in a loss of competitive advantage in the industry.

PU 124627 - Response to RAI SRXB-A-10. Contains details of GE's EPU005111 U 124632 ethodology, assumptions and results for performing analyses in GE support of a Constant Pressure Power Uprate.

gineering Report: Reactor Core Isolation Cooling System.

PU005 12 PU 124633 - ontains details of GE's methodology, assumptions and results EP05112 PU 124679 or performing analyses in support of a Constant Pressure Power GE

_prate.

Engineering Report: High Pressure Coolant Injection System.

PU005 113 PU 124680 - Contains details of GE's methodology, assumptions and results PU 124716 for performing analyses in support of a Constant Pressure Power

_ _Uprate.

Engineering Report: Post-LOCA Combustible Gas Control.

UQ005 14 PU 124717 - Contains details of GE's methodology, assumptions and results GE PU 124765 for performing analyses in support of a Constant Pressure Power Uprate.

Engineering Report: Anticipated Transients Without Scram.

EU005115 U 124766 - Contains details of GE's methodology, assumptions and results GE PU 124929 for performing analyses in support of a Constant Pressure Power

_prate.

FpU005002 PU 124930 - Round 7 draft RAls. Contains details of GE's proprietary core E E_00500_ UP124962 analysis methods including results and comparison to plant data. GE EPU005004 PU 124963 - Revised RAls. Contains details of GE's proprietary core analysis GE EPU 125002 methods including results and comparison to plant data.

EPU005006 PU 125003 - Revised RAls. Contains details of GE's proprietary core analysis GE

_U 125038 methods including results and comparison to plant data. _ __

EPU005010 PU 125039 - Revised RAI Draft 5. Contains details of GE's proprietary core E EPU 125084 nalysis methods including results and comparison to plant data.

EPU 125085 - evised RAI Draft 5 on Steam Dryer and SBO. Contains details EPU005011 EPU 125128 f GE's proprietary core analysis methods including results and E comparison to plant data.

EPU005013 PU 125129 - evised RAI Draft 5. Contains details of GE's proprietary core E EPU 125171 analysis methods including results and comparison to plant data.

E U005015 PU 125172 - Revised RAI Draft S. Contains details of GE's proprietary core GE

_ PU 125214 nalysis methods including results and comparison to plant data.

vPU 125215 - Attachment 9 to RAI letter. Contains details of GE's PU005117 PU 125220 methodology assumptions and results for performing analyses in E U_12522 support of a Constant Pressure Power Uprate.

ology assumptions and results for performing analyses in of a Constant Pressure Power Uprate.

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.

Entergy is providing documents relating to NEC Contention 4, which was dismissed by the Board as moot in its Memorandum and Order LBP-05-24 (September 1, 2005). This discovery is provided for completeness, since the Board's Memorandum and Order granted NEC leave to file a new or amended contention challenging the adequacy of Entergy's seismic and structural analysis of the Vermont Yankee cooling towers, and NEC filed a request for admission of such a contention on September 21, 2005. Provision of this discovery does not constitute an admission by Entergy that the new contention proposed by NEC is admissible.

As provided in 10 CFR § 2.336(c), this filing is accompanied by a Certification of Entergy's Tenth Supplemental Discovery Disclosures in the form of an Affidavit by Craig J.

Nichols, the Extended Power Uprate Project Manager for Entergy Nuclear Operations, Inc. The Affidavit is submitted unsigned because Mr. Nichols is on travel. A duly executed and notarized affidavit will be filed upon Mr. Nichols' return.

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: October 14, 2005 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 Tenth Supplemental Discovery Disclosures" and "Certification of Entergy's Tenth 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 14th day of October, 2005.

  • 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 lesn-r(icomcast.net Washington, D.C. 20555-0001 ask2(anrc.Rov
  • 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 aib5(0nrc.gov
  • Secretary Office of Commission Appellate Att'n: Rulemakings and Adjudications Staff Adjudication Mail Stop 0-16 CI Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 secy()nrc.gov hearingdocket(a-)nrc.gov
  • Sarah Hofinann *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(~nrc.gov. rmwv(nrc.gov. icz(a).nrc.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 aroisman(-nationallegalscholars.com Edgecomb ME 04556 shadis()prexar.com
  • Jonathan Rund Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Jmr3P)nrc.gov

/ tIf A Matias F. Travieso-Diaz a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matterof )

) 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 TENTH 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 tenth 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 Tenth Supplemental Discovery Disclosures, dated October 14, 2005, 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 Subscribed and sworn to before me this day of October, 2005.

Notary Public My commission expires

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