Text

Joint Motion for Correction of Transcript of April 19, 2010 Prehearing Telephone Conference
	ML101440230
Person / Time
Site:	Indian Point
Issue date:	05/21/2010
From:	Sherwin Turk; NRC/OGC
To:	; Atomic Safety and Licensing Board Panel
	Sherwin Turk - 301-415-1533
References
	50-247-LR, 50-286-LR, ASLBP 07-858-03-LR, Indian Point 2 & 3, RAS E-357
	Download: ML101440230 (8)
	v • d • e

May 21,2010 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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ENTERGY NUCLEAR OPERATIONS, INC.

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Docket Nos. 50-247 -LR/50-286-LR

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(Indian Point Nuclear Generating

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Units 2 and 3)

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JOINT MOTION FOR CORRECTION OF TRANSCRIPT OF APRIL 19.2010 PREHEARING TELEPHONE CONFERENCE Pursuant to 10 C.F.R. § 2.323(a), the NRC Staff, Entergy Nuclear Operations, Inc., the State of New York, the State of Connecticut, Riverkeeper, Inc., Hudson Sloop Clearwater, Inc.,

and the Town of Cortlandt (collectively, "Joint Parties") hereby request that the transcript ofthe prehearing telephone conference held on April 19, 2010, be corrected in the manner set forth in Attachment A hereto.1 In support of this motion, the Joint Parties state as follows:

1.

On April 19, 2010, the Atomic Safety and Licensing Board ("Board") conducted a telephone conference with the participants in this proceeding. The telephone conference was recorded, and a transcript of the conference was then prepared. Upon review of that transcript, certain of the Joint Parties observed that it contains various inaccuracies that require correction.

2.

On May 14, 2010, the NRC Staff ("Staff") filed a motion2 in which it requested (a) that the parties be permitted to file a further motion requesting that the transcript be 1 S99 Attachment A, "Proposed Corrections to Transcript of April 19, 2010 Teleconference from the State of New York, Riverkeeper, Inc., the Town of Cortlandt, the State of Connecticut, Hudson River Sloop Clearwater, Inc., Entergy Nuclear Operations, Inc., and NRC Staff."

2 S99 "NRC Staff's Request for Leave to Propose Transcript Corrections and for the Scheduling of a Prehearing Telephone Conference," dated May 14,2010 ("Staff Motion"),

In the Matter of UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD May 21,2010 ENTERGY NUCLEAR OPERATIONS, INC.

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Docket Nos. 50-247 -LR/50-286-LR (Indian Point Nuclear Generating Units 2 and 3)

JOINT MOTION FOR CORRECTION OF TRANSCRIPT OF APRIL 19.2010 PREHEARING TELEPHONE CONFERENCE Pursuant to 10 C.F.R. § 2.323(a), the NRC Staff, Entergy Nuclear Operations, Inc., the State of New York, the State of Connecticut, Riverkeeper, Inc., Hudson Sloop Clearwater, Inc.,

and the Town of Cortlandt (collectively, "Joint Parties") hereby request that the transcript ofthe prehearing telephone conference held on April 19, 2010, be corrected in the manner set forth in Attachment A hereto.1 In support of this motion, the Joint Parties state as follows:

1.

On April 19, 2010, the Atomic Safety and Licensing Board ("Board") conducted a telephone conference with the participants in this proceeding. The telephone conference was recorded, and a transcript of the conference was then prepared. Upon review of that transcript, certain of the Joint Parties observed that it contains various inaccuracies that require correction.

2.

On May 14, 2010, the NRC Staff ("Staff") filed a motion2 in which it requested (a) that the parties be permitted to file a further motion requesting that the transcript be 1 S99 Attachment A, "Proposed Corrections to Transcript of April 19, 2010 Teleconference from the State of New York, Riverkeeper, Inc., the Town of Cortlandt, the State of Connecticut, Hudson River Sloop Clearwater, Inc., Entergy Nuclear Operations, Inc., and NRC Staff."

2 S99 "NRC Staff's Request for Leave to Propose Transcript Corrections and for the Scheduling of a Prehearing Telephone Conference," dated May 14,2010 ("Staff Motion"),

- 2 corrected, and (b) that a further prehearing telephone conference be scheduled. The Board has not yet ruled on that motion.

3.

In its Motion of May 14, 2010, the Staff noted that it had circulated its proposed transcript corrections to the other parties and participants in this proceeding, and that certain parties indicated they may seek to propose additional corrections to the transcript. Further, the Staff noted that certain parties had expressed support for the filing of a single, joint motion to correct the transcript. Staff Motion at 1-2. Accordingly, the Staff requested leave for the parties to file a motion proposing corrections to the transcript on or before May 21, 2010. Id. at 2.3

4.

The Joint Parties have now completed their review of the transcript and have circulated their proposed transcript corrections for each others' consideration. During these communications, the Joint parties cooperatively developed a list of proposed transcript corrections, set forth in Attachment A hereto, with which they are in agreement. In accordance with 10 C.F.R. § 2.323(b), the Joint Parties have reached agreement on this Motion, and support the Board's adoption of the proposed corrections set forth in Attachment A heret04*

WHEREFORE, the Joint Parties respectfully request that the transcript of the April 19, 2010 telephone conference call be corrected as set forth in Attachment A hereto.

Respectfully subm~

.~UJ~Et~

Sherwin E. Turk Counsel for NRC Staff Dated at Rockville, Maryland this 21 st day of May 2010 3 The Staff attached to its motion a list of its proposed transcript corrections, but noted that "the Staff does not seek the Board's approval of these proposed corrections at this time, but will attempt to incorporate its proposed transcript corrections into a joint motion to be submitted by the parties during the coming week.* Staff Motion at 1 n.1.

4 Westchester County. the Village of Buchanan, and the New York City Economic Development Corporation did not participate in the telephone conference call of April 19.2010 (see Tr. 802, 900) and did not comment on the proposed transcript corrections. corrected, and (b) that a further prehearing telephone conference be scheduled. The Board has not yet ruled on that motion.

3.

In its Motion of May 14, 2010, the Staff noted that it had circulated its proposed transcript corrections to the other parties and participants in this proceeding, and that certain parties indicated they may seek to propose additional corrections to the transcript. Further, the Staff noted that certain parties had expressed support for the filing of a single, joint motion to correct the transcript. Staff Motion at 1-2. Accordingly, the Staff requested leave for the parties to file a motion proposing corrections to the transcript on or before May 21, 2010. Id. at 2.3

4.

The Joint Parties have now completed their review of the transcript and have circulated their proposed transcript corrections for each others' consideration. During these communications, the Joint parties cooperatively developed a list of proposed transcript corrections, set forth in Attachment A hereto, with which they are in agreement. In accordance with 10 C.F.R. § 2.323(b), the Joint Parties have reached agreement on this Motion, and support the Board's adoption of the proposed corrections set forth in Attachment A heret04*

WHEREFORE, the Joint Parties respectfully request that the transcript of the April 19, 2010 telephone conference call be corrected as set forth in Attachment A hereto.

Dated at Rockville, Maryland this 21 st day of May 2010 Respectfully subm~

.~UJ~Et~

Sherwin E. Turk Counsel for NRC Staff 3 The Staff attached to its motion a list of its proposed transcript corrections, but noted that "the Staff does not seek the Board's approval of these proposed corrections at this time, but will attempt to incorporate its proposed transcript corrections into a joint motion to be submitted by the parties during the coming week.* Staff Motion at 1 n.1.

4 Westchester County. the Village of Buchanan, and the New York City Economic Development Corporation did not participate in the telephone conference call of April 19.2010 (see Tr. 802, 900) and did not comment on the proposed transcript corrections.

ATIACHMENTA Proposed Corrections to Transcript of April 19. 2010 Teleconference from the State of New York. Riverkeeper, Inc., the Town of Cortlandt, the State of Connecticut, Hudson River Sloop Clearwater, Inc.,

Entergy Nuclear Operations, Inc., and NRC Staff 796/5 798/2 798/20 800/14 Esq. (after Andrew Stuyvenberg)

Assistant Attorney Genera J.D.

Esq.

if is report reporter 801/13-14 another line manager green manager on another line, Manna Jo Greene, Director two Conservation Assistant Attorney 802/16 was we 802/17 where for 804/1 to a to be a 804/22 Kirk Turk 808/6 ending pending 811/1 simultaneously simUltaneous 832/8 Commissions Commissioners 834116 state State

. 839/21 al a

revise under estimate do are 796/5 798/2 798/20 800/14 ATIACHMENTA Proposed Corrections to Transcript of April 19. 2010 Teleconference from the State of New York. Riverkeeper, Inc., the Town of Cortlandt, the State of Connecticut, Hudson River Sloop Clearwater, Inc.,

Entergy Nuclear Operations, Inc., and NRC Staff Esq. (after Andrew Stuyvenberg)

Assistant Attorney J.D.

Esq.

if is report reporter 801/13-14 another line manager green manager on another line, Manna Jo Greene, Director two Conservation Assistant Attorney 802/16 was we 802/17 where for 804/1 to a to be a 804/22 Kirk Turk 808/6 ending pending 811/1 simultaneously simUltaneous 832/8 Commissions Commissioners 834116 state State

. 839/21 al a

revise under estimate do are

-2 would not have would have 841121 SAMAs. Drilling SAMAs, drilling 841/21 used use 842/23 in a

843/8 potentially cost beneficial beneficial potentially beneficial costs, cost 843/10 or 845/3 of We believe what we've done is sufficient.

We believe we've done sufficient 845/18-19 I

can 849/20 can't data 85117 date i

significantly significant 852/24 you're now in the beyond design basis accident space you're now in the design basis 85414-5 accident space operating license.

855/8 ued operator license.

854113 issue Commissions Commission's 855/12 254 856/24 I to a Part 54 Part 54 Part 34 857/20 it therefore becomes it there might becomes 858/2 cost 858/1 cross the nature.

the trier.

859/10 effect of 862/23 Is is 868/1 2.206 2206 869/2 exemption exception 869/20 to issuing to issue 871/9 5109(a)© 50.109(a)(3) 871/23 (c) 872/4

which are outside CLB space.

re-addressed.

redressed.

881/6 that licensing will stage.

at the license renewal stage.

881/25 I

882/1 882/7 as a at the SAMA.

883/11 SAMAs.

883/12 stood said 841121 would have would not have 841/21 SAMAs, drilling SAMAs. Drilling 842/23 use used 843/8 a

in 843/10 potentially beneficial costs, cost potentially cost beneficial beneficial 845/3 of or 845/18-19 We believe we've done sufficient We believe what we've done is I

sufficient.

849/20 can't can i

85117 date data 852/24 significant significantly 85414-5 you're now in the design basis you're now in the beyond design basis accident space accident space 854113 operator license.

operating license.

855/8 ued issue 855/12 Commissions Commission's 856/24 254 I to a Part 54 857/20 Part 34 Part 54 858/2 it there might becomes it therefore becomes 858/1 cross cost 859/10 the trier.

the nature.

862/23 effect of 868/1 is Is 869/2 2206 2.206 869/20 exemption exception 871/9 to issuing to issue 871/23 5109(a)© 50.109(a)(3) 872/4

50. 1 09(a)© 50.109(a}(3) 875/24-25 where were excessive to CLB states.

which are outside CLB space.

881/6 re-addressed.

redressed.

I 881/25 -

that licensing will stage.

at the license renewal stage.

882/1 882/7 as a at the 883/11 SAMA.

SAMAs.

883/12 stood said

- 3 883/12 NEPA "NEPA 883/13 imposed imposes 883/13 taken.

taken."

887/24 IP 209, IP 253, and IP 353, IP2-09, IP2-53, and IP3-53, 888/8-9 IP 209, IP 253, and IP 353, IP2-09, IP2-53, and IP3-53 889/11 890/18-19 890/20 for only SAMAs of 33 identified as for 035 were only SAMAs. Footnote 33 identifies the footnote 35 891/5 IP 29, IP 253, and IP 353 IP2 9, IP2 53, and IP3 53 891/7 February 2008. And Entergy's*

February 2008 in Entergy's 891110 provided additional provided an additional 891/14 cost beneficial. In February 2008 cost beneficial in February 2008 893/22 895/2 MR. SIPOS:

that's MR. TURK:

they're 895/3 It's That's 89617 would change would not change 897/19 that ofa 897/20 divide device 897/20 generated generator 897/22 numbered unnumbered 89811 in order on the order 899/3 Cannon Chanin 899/9 899/12 899115 899/17-18 899118 899/19-20 900/16 preventative t

Brenda State of Environmental Conversation specification 18.2 continuing operating for license units 2 and 3B, renewed.

SPEC. AGENT HANNON benefit it Deborah State Department of Environmental Conservation certification the operating licenses of Indian POint Units 2 and 3 to be renewed, CHAIRMAN McDADE Dated: May 21,2010 883/12 NEPA "NEPA 883/13 imposed imposes 883/13 taken.

taken."

887/24 IP 209, IP 253, and IP 353, IP2-09, IP2-53, and IP3-53, 888/8-9 IP 209, IP 253, and IP 353, IP2-09, IP2-53, and IP3-53 889/11 for only were only 890/18-19 SAMAs of 33 identified as SAMAs. Footnote 33 identifies the 890/20 for 035 footnote 35 891/5 IP 29, IP 253, and IP 353 IP2 9, IP2 53, and IP3 53 891/7 February 2008. And Entergy's*

February 2008 in Entergy's 891110 provided additional provided an additional 891/14 cost beneficial. In February 2008 cost beneficial in February 2008 893/22 MR. SIPOS:

MR. TURK:

895/2 that's they're 895/3 It's That's 89617 would change would not change 897/19 that ofa 897/20 divide device 897/20 generated generator 897/22 numbered unnumbered 89811 in order on the order 899/3 Cannon Chanin 899/9 preventative benefit 899/12 t

it 899115 Brenda Deborah 899/17-18 State of Environmental Conversation State Department of Environmental Conservation 899118 specification certification 899/19-20 18.2 continuing operating for license the operating licenses of Indian POint units 2 and 3B, renewed.

Units 2 and 3 to be renewed, 900/16 SPEC. AGENT HANNON CHAIRMAN McDADE Dated: May 21,2010

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-LR/50-286-LR

)

(Indian Point Nuclear Generating

)

Units 2 and 3)

)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing"JOINT MOTION FOR CORRECTIONS TO TRANSCRIPT OF APRIL 19, 2010 PREHEARING TELEPHONE CONFERENCE," dated May 21,2010, have been served upon the following through deposit in the NRC's internal mail system, with copies by electronic mail, as indicated by an asterisk, or by deposit in the U.S.

Postal Service, as indicated by double asterisk, with copies by electronic mail this 21 st day of May, 2010:

Lawrence G. McDade, Chair*

Atomic Safety and Licensing Board Panel Mail Stop - T -3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 E-mail: Lawrence. McDade@nrc.gov Dr. Richard E. Wardwell*

Atomic Safety and Licensing Board Panel Mail Stop - T -3 F23 U.S. Nuclear Regulatory Commission Washington. D.C. 20555-0001 E-mail: Richard. Wardwell@nrc.gov Dr. Kaye D. Lathrop*

Atomic Safety and Licensing Board Panel 190 Cedar Lane E.

Ridgway, CO 81432 E-mail: Kaye. Lathrop@nrc.gov Office of Commission Appellate Adjudication*

U.S. Nuclear Regulatory Commission Mail Stop: 0-16G4 Washington, DC 20555-0001 E-mail: OCAAMAIL.resource@nrc.gov Office of the Secretary*

Attn: Rulemaking and Adjudications Staff Mail Stop: 0-16G4 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: Hearing.Docket@nrc.gov Zachary S. Kahn*

Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: Zacharv.Kahn@nrc.gov UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

ENTERGY NUCLEAR OPERATIONS, INC. )

(Indian Point Nuclear Generating Units 2 and 3)

)

Docket Nos. 50-247-LR/50-286-LR CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing" JOINT MOTION FOR CORRECTIONS TO TRANSCRIPT OF APRIL 19, 2010 PREHEARING TELEPHONE CONFERENCE," dated May 21,2010, have been served upon the following through deposit in the NRC's internal mail system, with copies by electronic mail, as indicated by an asterisk, or by deposit in the U.S.

Postal Service, as indicated by double asterisk, with copies by electronic mail this 21 st day of May, 2010:

Lawrence G. McDade, Chair*

Atomic Safety and Licensing Board Panel Mail Stop - T -3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 E-mail: Lawrence. McDade@nrc.gov Dr. Richard E. Wardwell*

Atomic Safety and Licensing Board Panel Mail Stop - T -3 F23 U.S. Nuclear Regulatory Commission Washington. D.C. 20555-0001 E-mail: Richard. Wardwell@nrc.gov Dr. Kaye D. Lathrop*

Atomic Safety and Licensing Board Panel 190 Cedar Lane E.

Ridgway, CO 81432 E-mail: Kaye. Lathrop@nrc.gov Office of Commission Appellate Adjudication*

U.S. Nuclear Regulatory Commission Mail Stop: 0-16G4 Washington, DC 20555-0001 E-mail: OCAAMAIL.resource@nrc.gov Office of the Secretary*

Attn: Rulemaking and Adjudications Staff Mail Stop: 0-16G4 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: Hearing.Docket@nrc.gov Zachary S. Kahn*

Atomic Safety and Licensing Board Panel Mail Stop - T -3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: Zacharv.Kahn@nrc.gov

- 2 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop: T -3 F23 Washington, DC 20555-0001 (Via Internal Mail Only)

Kathryn M. Sutton, Esq.**

Paul M. Bessette, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, D.C. 20004 E-mail: ksutton@morganlewis.com E-mail: pbessette@morganlewis.com Martin J. O'Neill, Esq. **

Morgan, Lewis & Bockius, LLP 1000 Louisiana Street, Suite 4000 Houston, TX 77002 E-mail: martin.o.neill@morganlewis.com Elise N. Zoti, Esq.

Goodwin Procter, LLP Exchange Place 53 State Street Boston, MA 02109 E-mail: ezoli@goodwinprocter.com William C. Dennis, Esq.**

Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 E-mail: wdennis@entergy.com Josh Kirstein, Esq.

Atomic Safety and Licensing Board Panel Mail Stop - T -3 F23 U. S, Nuclear Regulatory Commission Washington, D.C. 20555-0001 E-Mail: Josh.Kirstein@nrc.gov Mylan L. Denerstein, Esq.**

Janice A. Dean, Esq.

Executive Deputy Attorney General, Social Justice Office of the Attorney General of the State of New York 120 Broadway, 25th Floor New York, NY 10271 E-mail: mylan.denerstein@oag.state.ny.us janice.dean@oag.state.ny.us John J. Sipos, Esq.**

Charlie Donaldson, Esq.

Assistants Attorney General New York State Department of Law Environmental Protection Bureau The Capitol Albany, NY 12224 E-mail: john.sipos@oag.state.ny.us Joan Leary Matthews, Esq. **

Senior Attorney for Special Projects New York State Department of Environmental Conservation Office of the General Counsel 625 Broadway, 14th Floor Albany, NY 12233-1500 E-mail: ilmatthe@gw.dec.state.ny.us John Louis Parker, Esq.**

Office of General Counsel, Region 3 New York State Department of Environmental Conservation 21 South Putt Corners Road New Paltz, NY 12561-1620 E-mail: ilparker@gw.dec.state.ny.us Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop: T -3 F23 Washington, DC 20555-0001 (Via Internal Mail Only)

Kathryn M. Sutton, Esq.**

Paul M. Bessette, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, D.C. 20004 E-mail: ksutton@morganlewis.com E-mail: pbessette@morganlewis.com Martin J. O'Neill, Esq. **

Morgan, Lewis & Bockius, LLP 1000 Louisiana Street, Suite 4000 Houston, TX 77002 E-mail: martin.o.neill@morganlewis.com Elise N. Zoti, Esq.-

Goodwin Procter, LLP Exchange Place 53 State Street Boston, MA 02109 E-mail: ezoli@goodwinprocter.com William C. Dennis, Esq.**

Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 E-mail: wdennis@entergy.com Josh Kirstein, Esq.

Atomic Safety and Licensing Board Panel Mail Stop - T -3 F23 U. S, Nuclear Regulatory Commission Washington, D.C. 20555-0001 E-Mail: Josh.Kirstein@nrc.gov Mylan L. Denerstein, Esq.**

Janice A. Dean, Esq.

Executive Deputy Attorney General, Social Justice Office of the Attorney General of the State of New York 120 Broadway, 25th Floor New York, NY 10271 E-mail: mylan.denerstein@oag.state.ny.us janice.dean@oag.state.ny.us John J. Sipos, Esq.**

Charlie Donaldson, Esq.

Assistants Attorney General New York State Department of Law Environmental Protection Bureau The Capitol Albany, NY 12224 E-mail: john.sipos@oag.state.ny.us Joan Leary Matthews, Esq. **

Senior Attorney for Special Projects New York State Department of Environmental Conservation Office of the General Counsel 625 Broadway, 14th Floor Albany, NY 12233-1500 E-mail: ilmatthe@gw.dec.state.ny.us John Louis Parker, Esq.**

Office of General Counsel, Region 3 New York State Department of Environmental Conservation 21 South Putt Corners Road New Paltz, NY 12561-1620 E-mail: ilparker@gw.dec.state.ny.us

-3 Manna Jo Greene"'

Hudson River Sloop Clearwater, Inc.

112 Little Market Street Poughkeepsie, NY 12601 E-mail: Mannajo@clearwater.org Ross H. Gould, Esq."'

10 Park Ave, 5L New York, NY 10016 E-mail: rgouldesg@gmail.com Daniel E. O'Neill, Mayor" James Seirmarco, M.S.

Village of Buchanan Municipal Building Buchanan, NY 10511-1298 E-mail: vob@bestweb.net Daniel Riesel, Esq"'.

Thomas F. Wood, Esq.

Ms. Jessica Steinberg, J.D.

Sive, Paget & Riesel, P.C.

460 Park Avenue New York, NY 10022 E-mail: driesel@sprlaw.com jsteinberg@sprlaw.com Michael J. Delaney, Esq,"'

Vice President - Energy Department New York City Economic Development Corporation (NYCDEC) 110 William Street New York, NY 10038 E-mail: mdelaney@nycedc.com Justin D. Pruyne, Esq."'

Assistant County Attorney Office of the Westchester County Attorney 148 Martine Avenue, 6th Floor White Plains, NY 10601 E-mail: jdp3@westchestergov.com Robert Snook, Esq. "'

Office of the Attorney General State of Connecticut 55 Elm Street P.O. Box 120 Hartford, CN 06141-0120 E-mail: robert.snook@ct.gov Phillip Musegaas, Esq.*'"

Deborah Brancato, Esq.

Riverkeeper, Inc.

828 South Broadway Tarrytown, NY 10591 E-mail: phillip@riverkeeper.org dbrancato@riverkeeper.org Sherwin E. Turk Counsel for NRC Staff Manna Jo Greene"'