|
|---|
Category:Legal-Intervention Petition
MONTHYEARML11257A1102011-09-14014 September 2011
Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions
ML11257A1092011-09-13013 September 2011
Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings
ML11257A1112011-09-13013 September 2011
Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report
ML11228A0302011-08-11011 August 2011
the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17
ML11217A0662011-07-29029 July 2011
Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36
ML11210B4192011-07-26026 July 2011
State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37
ML11179A0922011-06-21021 June 2011
Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals
ML11133A2882011-04-29029 April 2011
Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25
ML11117A1462011-04-19019 April 2011
Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident
ML11229A8022011-03-22022 March 2011
Supplementary Certification Regarding Consultation
ML11108A1062011-03-21021 March 2011
Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3
ML1108307802011-03-18018 March 2011
State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives
ML1107601812011-03-16016 March 2011
Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement
ML1107000972011-03-0404 March 2011
State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B
ML1106703812011-02-25025 February 2011
Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions
ML1107402862011-02-23023 February 2011
State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36
ML1106604252011-02-23023 February 2011
State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis
ML1105602702011-02-18018 February 2011
Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule
ML1105605892011-02-18018 February 2011
Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b)
ML1104604922011-02-10010 February 2011
State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions
ML1106802122011-02-0303 February 2011
State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area
ML1030000602010-10-22022 October 2010
State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25
ML1030101042010-10-12012 October 2010
Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals
ML1029101452010-10-0404 October 2010
Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue)
ML1028802972010-10-0404 October 2010
Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B
ML1029101422010-10-0404 October 2010
Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue)
ML1030105182010-09-14014 September 2010
State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean..
ML1023712142010-08-16016 August 2010
Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion)
ML1023001462010-08-13013 August 2010
Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents
ML1022405782010-08-0202 August 2010
Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13
ML1021100862010-07-26026 July 2010
the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10-
ML1020300502010-07-15015 July 2010
Applicant'S Petition for Interlocutory Review of LBP-10-13
ML1011604152010-04-12012 April 2010
State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis
ML1014503282010-04-0505 April 2010
Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis
ML1011004732010-04-0101 April 2010
Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives
ML1005702402009-11-20020 November 2009
Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point
ML0934803252009-11-20020 November 2009
Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1
ML0934910432009-11-20020 November 2009
Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information
ML0935101942009-11-20020 November 2009
Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point
ML1005700112009-11-20020 November 2009
Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1
ML1008200282009-11-19019 November 2009
Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point
ML0930801292009-10-26026 October 2009
Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information
ML0909802072009-04-0707 April 2009
Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply
ML0910502112009-04-0606 April 2009
Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2
ML0909604702009-03-31031 March 2009
State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34
ML0909302042009-03-24024 March 2009
Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State
ML0908401162009-03-24024 March 2009
Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement
ML0908608682009-03-18018 March 2009
Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items
ML0906903032009-02-27027 February 2009
State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement
ML0904105002009-01-26026 January 2009
Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention
2011-09-14
[Table view]
Category:Responses and Contentions
MONTHYEARML11257A1102011-09-14014 September 2011
Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions
ML11257A1092011-09-13013 September 2011
Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings
ML11257A1112011-09-13013 September 2011
Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report
ML11228A0302011-08-11011 August 2011
the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17
ML11217A0662011-07-29029 July 2011
Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36
ML11210B4192011-07-26026 July 2011
State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37
ML11179A0922011-06-21021 June 2011
Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals
ML11133A2882011-04-29029 April 2011
Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25
ML11117A1462011-04-19019 April 2011
Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident
ML11229A8022011-03-22022 March 2011
Supplementary Certification Regarding Consultation
ML11108A1062011-03-21021 March 2011
Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3
ML1108307802011-03-18018 March 2011
State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives
ML1107601812011-03-16016 March 2011
Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement
ML1107000972011-03-0404 March 2011
State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B
ML1106703812011-02-25025 February 2011
Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions
ML1107402862011-02-23023 February 2011
State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36
ML1106604252011-02-23023 February 2011
State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis
ML1105602702011-02-18018 February 2011
Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule
ML1105605892011-02-18018 February 2011
Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b)
ML1104604922011-02-10010 February 2011
State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions
ML1106802122011-02-0303 February 2011
State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area
ML1030000602010-10-22022 October 2010
State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25
ML1030101042010-10-12012 October 2010
Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals
ML1029101452010-10-0404 October 2010
Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue)
ML1028802972010-10-0404 October 2010
Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B
ML1029101422010-10-0404 October 2010
Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue)
ML1030105182010-09-14014 September 2010
State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean..
ML1023712142010-08-16016 August 2010
Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion)
ML1023001462010-08-13013 August 2010
Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents
ML1022405782010-08-0202 August 2010
Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13
ML1021100862010-07-26026 July 2010
the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10-
ML1020300502010-07-15015 July 2010
Applicant'S Petition for Interlocutory Review of LBP-10-13
ML1011604152010-04-12012 April 2010
State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis
ML1014503282010-04-0505 April 2010
Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis
ML1011004732010-04-0101 April 2010
Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives
ML1005702402009-11-20020 November 2009
Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point
ML0934803252009-11-20020 November 2009
Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1
ML0934910432009-11-20020 November 2009
Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information
ML0935101942009-11-20020 November 2009
Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point
ML1005700112009-11-20020 November 2009
Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1
ML1008200282009-11-19019 November 2009
Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point
ML0930801292009-10-26026 October 2009
Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information
ML0909802072009-04-0707 April 2009
Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply
ML0910502112009-04-0606 April 2009
Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2
ML0909604702009-03-31031 March 2009
State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34
ML0909302042009-03-24024 March 2009
Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State
ML0908401162009-03-24024 March 2009
Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement
ML0908608682009-03-18018 March 2009
Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items
ML0906903032009-02-27027 February 2009
State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement
ML0904105002009-01-26026 January 2009
Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention
2011-09-14
[Table view] |
Text
DOCKETED
OFFICE OF SECRETARY
- RULEMAKINGS AND ADJUDICATIONS STAFF
.STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL ANDREw M. Cuomo DivqsioN,, OF SOCIAL JUSTICE ATTORNEY GENERAL ENVIRONMENTAL PROTECTION BUREAU January 7, 2008
- Office of the Secretary of the Commission United States Nuclear Regulatory Commission One White Flint North, 16'"Floor 11555 Rockville Pike Rockville, MID 20852-273 8 Attention: Rulemaking and Adjudications Staff Re: Indian Point Nuclear Generating Unit Nos. 2 and 3: Renewal of Operating License Nos. DPR-26 and DPR for an Additional 20-Year Period (ASLBP No. 07-858-03-LR-BDOI)
Dear Sir/Madam:
The State of New York, a petitioner in the above referenced proceeding, hereby submits the following errata sheet to correct various typographic errors contained in the State's November 30, 2007 petition to intervene in the proceeding.
New York respectfully requests that the errata sheet be added to the docket in this proceeding.
-Respectfully submitted, - -. ~. . ~ __
John J. Sipos Joan Leary Matthews Assistant Attorney General Senior Counsel for Special Projects Office of the Attorney General Department of Environmental. Conservation cc: attached service list
.- FftL~-T- s~ v-027 The Capitol, Albany, NY 1222460 (518) 474-8096 0 Fax (518) 473-2534 (Not for Service of Papers)Chttp://fww~v.oag.state.ny.us
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
x In re:
Docket Nos. 50-247-LR and 50-286-LR License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BDOI Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC, and DPR-26, DPR-64 Entergy Nuclear Operations, Inc.
x ERRATA For November 30, 2007 Notice of Intention to Participate and Petition to Intervene Submitted by the State of New York Underscored text has been added or corrected; text in brackets has been deleted.
Page 12, line 6: ...the SAMA analysis does not consider...
Page 13, line 12: *... federal requirements...
Page 14, line 11: ...licenses...
Page 17, line 4: Contention Thirty Two [One]
Page 17, line 13: Contention Thirty On [Two]
Page 17, ine 16:
Page 22, line 18: *....has requested...
Page 26, line 2: ...(NRC) *64. slip op. at 121 [85 (quoting Oconee, 49 NRC at 342)] )
line 4: ..(f )(1)(v) ["]does not...
line 12: The requirement ["]generally...
line 15: ...Pilgrimn at *64, slip op. at 121-22 [84]...
-I-
Page 28, n. 7, line 3: ...contentions 18-22 [20] and 29 [27-30]...
Page 39, line 6: ... .contentions...
Page 43, line 15: ... .Jan. 14...
Page 50, line 20: ...by the~ generic letter...
Page 51, line 5: ..that it has identified ...
Page 73, line 20: ...attached to the Declaration of Paul Blanch, for a comparison...
Page 79, lines 5-6: ... Contentions 10 and..9 [11, infra...
Page 86, line 6: ..that it had begun ...
Page 92, line 4: ...components of IP I..
Page 98, line 16: ... IP2 or1IN AMP ...
Page 100, line 8: ... IP2 or IN AMP ...
Page 101, line 19: ...cables; however., these cables [however,] exist...
Page 103, line 10: ...conducted by Sandia (SAND96-0344) confirmed...
Page 105, line 5: ... P2 includes [is] a one line diagram...
46 line 22: ...at p. 10 (emphasis added).
Page 109, line 15: ...Transportation of Fuel...
Page 122, line 16:,- ... is probable that....
Page 130, line 3-4: Energy efficiency Page 130, fn. 25: Energi, Efficiency and Renewable Ene=~ Deielovrent Potential,at Page 130, fn. 27: ...Figure...
Page 139, line 19: -Contentions 10 and 9 [11], supra.
Page 142, line 1: -presented [to] in.'..
Page 150, line 12: ouse [to] IPI's...
Page 152, line 7: ....nation.[...]
Page 154, line 13: ...Leonardo Seeber...
Page 159, line 12: ...State's [our] experts...
line 15: (Contention 14, ¶ 10).
Page 171, line 13:
Page 176, line 8-9: ... .by th generic letter...
line 15: .... thus violating...
Page 199, line 12: ...attached to the Declaration of Paul Blanch, for a comparison...
Page 202, line 14: ... .the Chart attached to...
Page 207, line 19: ... to use [to] IP1I's...
Page 220, line 16: ...Lahey Declaration ¶27 [26].
Page 223, line 2-3: ... .not only mandates enhanced inspections...
Page 252, line 5: ...within...
Page 266, line 14: ... .makes clear, there would be "a 66% increase Page 272, line 3: ...As Lis [was] stated in the subseqiuent [above] contention...
line-10: ...Once.-through cooling...
Page 273, line 2: ...As stated in the subseg uent [above] contention...
- Page 274, linel1: ...impacts of thermal discharges [impingement and entrainiment] from the once-through...
- Page 293, line 14-15: ...isviolating [of] the ESA.
Page 297, line 3: A. Contentions 1-17., [and] 23-28 [ 2 1-2 6 ], nd 30-32 Are Plainly Admissible Page 297, line 17: (Contentions 4., [and] 9-11, 17, 28, and 30-32)...
Page 298, line 5: ...(Contentions 12-16 and 27 [21-22])...
94 line 10: ... analysis wijth. [on] accurate...
64 line 15: B. Contentions 18-22 [20] and [27-] 29 Are Also Admissible Page 303, line 3-4: ... Contentions 1, 2, and 3 [4 and 18] and require...
Page 305, line 3: [16.]
Page 305, line 18: C. Contentions 1-4 [17-20 and 27-32] Are Admissible Page 308, line 5: 1978) ("CCRJ").
Page 309, line 15-7: ...to put "[']~other parties in the proceeding on notice of the petitioners' specific grievances' [claims'] in order to -"[']give[]them a good idea of the claims they will be either supporting or opposing[']...
Page 309, line 18: ...49 NTRC 328, 334 [333]...
Page 310, line 11: ... supporting evidence for Contention 1, allowing...'
Page 313, line 14: jImnatthewv gw. dec. state. ny.us Dated: January 7, 2008 Albany, New York UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ENTERGY NUCLEAR OPERATIONS, INC. ) Docket Nos. 50-247/286-I.R
)
(Indian Point Nuclear Generating Units 2 and 3)
DECLARATION OF SERVICE Pursuant to 28 U.S.C. §1746, Teresa Fountain hereby declares upon penalty of perjury that:
- 1. I am over 18 years old and am an employee of the Office of the Attorney Genreal for the State of New York, counsel for the petitioner State of New York.
- 2. On January 7, 2008, I served the attached letter and errata sheet by placing a true and correct copy thereof in a Federal Express pre-paid envelope directed to the following judges, law clerk, offices, organizations, attorneys, and/or petitioners at the following addresses and depositing those envelopes in a Federal Express drop box located at 146 State Street in Albany, Newi York:
- 3. Also, on January 7, 2008, I forwarded the referenced letter and errata to the e-mail addresses that follow:
Lawrence G. McDade, Chair Atomic Safety and Licensing Board Panel Administrative Judge Mail Stop - T-3 F23 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop - T-3 F23 11555 Rockville Pike U.S. Nuclear Regulatory Commission Rockville, MD 20852 11555 Rockville Pike Rockville, MD 20852 Zachary S. Kahn, Esq.
lgml@nrc.gov Law Clerk Atomic Safety and Licensing Board Panel Richard E. Wardwell Mail Stop - T-3 F23 Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel 11555 Rockville Pike Mail Stop - T-3 F23 Rockville, MD 20852 U.S. Nuclear Regulatory Commission zxkl ~nrc.gov 11555 Rockville Pike Rockville, MD 20852 Office of Commission Appellate Adjudication rew@nrc.gov Mailstop O-16G4 U.S. Nuclear Regulatory Commission Kaye D. Lath rop 11555 Rockville Pike Administrative Judge Rockville, MD 20852 Atomic Safety and Licensing Board Panel ocaamail@nrc.gov Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 kdl2@nrc.gov
Office of the Secretary Justin D. Pruyne, Esq.
Attn: Rulemaking and Adjudications Staff Assistant County Attorney Mail Stop T-3 F23 Office of the Westchester County Attorney U.S. Nuclear Regulatory Commission Michaelian Office Building 11555 Rockville Pike 148 Martine Avenue, 6th Floor Rockville, MD 20852 White Plains, NY 10601 hearingdocket~nrc.gov jdp3@westchestergov.com Sherwin E. Turk, Esq. Daniel E. O'Neill, M ayor Lloyd B. Subin, Esq. James Seirmarco, M.S.
Beth N. Mizuno, Esq. Village of Buchanan David E. Roth, Esq. Municipal Building Herald Speiser, Esq. 236 Tate Avenue Office of the General Counsel Buchanan, NY 10511-1298 Mail Stop 15 D21 vob@bestweb.net U.S. Nuclear Regulatory Commission 11555 Rockville Pike Daniel Riesel, Esq.
Rockville, MD 20852 Thomas F. Wood, Esq.
set@nrc.gov Jessica Steinberg, J.D.
lbs3@nrc.gov Sive, Paget & Riesel, P.C.
bnml@nrc.gov 460 Park Avenue der@nrc.gov New York, NY 10022 hmsl ~nrc.gov driesel@sprlaw.com jsteinberg@sprlaw.com Kathryn M. Sutton, Esq.
Paul M. Bessette, Esq. Michael J. Delaney, Esq.
Martin J. O'Neill, Esq. Vice President - Energy Department Mauri T. Lemoncelli, Esq. New York City Economic Development Morgan, Lewis & Bockius LLP Corporation (NYCEDC)
.1111 Pennsylvania Avenue, NW 110 William Street Washington, DC 20004 New York, NY 10038 ksutton@morganlewis.com mdelaney@nycedc.com pbessette@morganlewis.com martin.o'neill~morganlewis.com Arthur J. Kremer, Chairman mlemoncelli@morganlewis.com New York Affordable Reliable Electricity Alliance cadams@morganlewis.com (AREA) 347 Fifth Avenue, Suite 508 William C. Dennis, Esq. New York, NY 10016 Assistant General Counsel kremer~area-alliance.orgc Entergy Nuclear Operations, Inc. ajkremer@rmfpc.com 440 Hamilton Avenue White Plains, NY 10601 Diane Curran, Esq.
wdennis@entergy.com Harmon, Curran, Speilberg & Eisenberg, LLP Suite 600 Robert D. Snook, Esq. 1726 M Street, NW Assistant Attorney General Washington, DC 20036 Office of the Attorney General dcurran@harmoncurran.com State of Connecticut 55 Elm Street Phillip Musegaas, Esq.
P.O. Box 120 Victor Tafur, Esq.
Hartford, CT 06141-0120 Riverkeeper, Inc.
robert.snook@po.state.ct.us 828 South Broadway Tarrytown, NY 10591 phillip@riverkeeper.org vtafur@riverkeeper.org
Manna Jo Greene, Director Hudson River Sloop Clearwater, Inc.
112 Little Market St.
Poughkeepsie, NY 12601 Mannajo@clearwater.org Susan H. Shapiro, Esq.
Weschester Citizen's Awareness Network (WestCan), Citizens Awareness Network (CAN),etc.
21 Perlman Drive Spring Valley, NY 10977 mbs@ourrocklandoffice.com Nancy Burton 147 Cross Highway Redding Ridge, CT 06876 NancyBurtonCT@aol.com Richard L. Brodsky, Esq.
Assemblyman Suite 205 5 West Main Street Elmsford, NY 10523 brodskr@assembly.state.ny.us richardbrodsky@msn.com John LeKay FUSE USA 351 Dyckman Street Peekskill, New York 10566 fuse_usa@yahoo.com Executed on:
Janaury 7, 2008 Albany, New York Teresa Fountain Office of the Attorney General State of New York The Capitol Albany, New York 12224-0341 (518) 474-1978 Teresa. Fountain @oag.s tat e.ny.us
