ML12334A806

Official Exhibit - NYS000292-00-BD01 - Declaration of Assistant Attorney General Kathryn M. Liberatore (Pft Liberatore Decl. NYS- 12C)

ML12334A806
Person / Time
Site:	Indian Point
Issue date:	12/21/2011
From:	Liberatore K State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21598, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12334A806 (2)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 NYS000292 Docket #: 05000247 l 05000286 Submitted: December 21, 2011 Exhibit #: NYS000292-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

---

x In re: Docket Nos. 50-247-LR; 50-286-LR License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. December 21, 2011

---

x DECLARATION OF KATHRYN M. LIBERATORE Pursuant to 28 U.S.C. § 1746, Kathryn M. Liberatore hereby declares as follows:

1. I serve as an Assistant Attorney General for the State of New York, counsel for petitioner-intervenor State of New York in this proceeding. I submit this declaration and accompanying exhibits in support of the State of New Yorks contention, NYS-12/12-A/12-B/12-C (hereinafter Consolidated Contention 12-C), which asserts that the analysis set forth in the Nuclear Regulatory Commission (NRC) Staffs December 2010 Final Supplemental Environmental Impact Statement concerning the Severe Accident Mitigation analysis and the inputs to the computer code that were used to evaluate the decontamination and cleanup costs associated with severe accidents, does not meet the requirements of National Environmental Policy Act (NEPA), and the regulations implementing NEPA adopted by the NRC and the Council on Environmental Quality.

2. The accompanying exhibits are discussed in more detail in the States Statement of Position, and/or were previously submitted as supporting evidence for the States contentions.

3. Attached to this declaration as Exhibit NYSR70001 is a true and correct copy of the document entitled State of New York Hearing Exhibits List ("NYS Exhibits List"), Exh.

NYSR70001. NYS Exhibits List includes those exhibits relied upon and referenced in support of Consolidated Contention 12-C, NYS000240 through NYS000292.

4. Attached to this declaration as Exhibit NYS000288 is a true and correct copy of the document entitled NUREG/CR-4691, SAND86-1562, Vol. 2, MELCOR Accident Consequence Code System (MACCS) (February 1990).

5. Attached to this declaration as Exhibit NYS000287 is a true and correct copy of the document entitled NEI 05-01 [Rev A], Severe Accident Mitigation Alternatives (SAMA)

Analysis, Guidance Document (November 2005).

6. Attached to this declaration as Exhibit NYS000286 is a true and correct copy of the document entitled Indian Point: The Next Fukushima?, V. Gilinsky, The New York Times (Dec. 16, 2011).

7. I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 21, 2011 Signed (electronically) by Kathryn M. Liberatore Assistant Attorney General Office of the Attorney General of the State of New York 120 Broadway New York, New York 10271 (212) 416-8482