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Category:Legal-Exhibit
MONTHYEARML15337A3522015-11-17017 November 2015 Official Exhibit - NYS000582-00-BD01 - Diagram of Strength Vs Amplitude by Dr. Richard T. Lahey ML15337A3372015-11-11011 November 2015 Official Exhibit - ENTR00726-00-BD01 - Track 2 Hearing Exhibit List ML15337A3322015-11-0505 November 2015 Official Exhibit - ENT000726-00-BD01 - Entergy Track 2 Hearing Exhibit List ML15337A3352015-11-0505 November 2015 Official Exhibit - RIVR14001-00-BD01 - Riverkeeper Tailored Track 2 Exhibit List ML15337A3362015-11-0505 November 2015 Official Exhibit - NRCR10001-00-BD01 - NRC Staff Track 2 Exhibit List ML15337A3332015-11-0404 November 2015 Official Exhibit - NYSR25001-00-BD01 - NYS Revised Tailored Exhibits List Relevant to Track 2 Contentions ML15337A3312015-11-0303 November 2015 Official Exhibit - NRC000230-00-BD01 - Corrections to Prefiled Testimony NRC000168 and NRC000197 ML15337A3262015-10-29029 October 2015 Official Exhibit - ENT000722-00-BD01 - Supplemental Testimony of Entergy Witnesses Nelson Azevedo, Timothy Griesbach & Randy Lott ML15337A3292015-10-29029 October 2015 Official Exhibit - ENTR16001-00-BD01 - Entergy Revised Exhibit List ML15337A3242015-09-23023 September 2015 Official Exhibit - NYS000576-00-BD01 - Pre-Filed Supplemental Testimony of Richard T. Lahey Re Contentions NYS-25, NYS-26B/RK-TC-1B & NYS-38/RK-TC-5 ML15337A3072015-09-0909 September 2015 Official Exhibit - NYS000573-PUB-00-BD01 - 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) ML15337A2962015-09-0909 September 2015 Official Exhibit - NYS000570-PUB-00-BD01 - 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) ML15337A2832015-09-0909 September 2015 Official Exhibit - NYS000563-00-BD01 - Pressurized Water Reactor (PWR) Systems, USNRC Technical Training Center, Reactor Concepts Manual, Pages 4-1 to 4-28 ML15337A2952015-09-0909 September 2015 Official Exhibit - NYS000569-PUB-00-BD01 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-26B/RK-TC-1B (Public, Redacted) (September 9, 2015) ML15337A2942015-09-0909 September 2015 Official Exhibit - NYS000568-PUB-00-BD01 - Supplemental Reply Statement of Position of the State of New York in Support of Contention NYS-25 (Public, Redacted) (September 9, 2015) ML15337A2932015-09-0909 September 2015 Official Exhibit - NYS000567-PUB-00-BD01 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-25 (Public, Redacted) (September 9, 2015) ML15337A3042015-09-0909 September 2015 Official Exhibit - NYS000571-PUB-00-BD01 - Pre-filed Supplemental Reply Testimony of David J. Duquette in Support of Contention NYS-38/RK-TC-5 (Public, Redacted) (September 9, 2015) ML15337A2972015-09-0909 September 2015 Official Exhibit - RIV000164-00-BD01 - 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) ML15337A3062015-09-0909 September 2015 Official Exhibit - NYS000572-PUB-00-BD01 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-38/RK-TC-5 (Public, Redacted) (September 9, 2015) ML15337A2822015-09-0909 September 2015 Official Exhibit - NYS000566-00-BD01 - Figure 1 for Supplemental Reply Testimony of Dr. Richard T. Lahey ML15337A3142015-09-0404 September 2015 Official Exhibit - ENTR00615-PUB-00-BD01 - Entergy'S Statement of Position Re Contention NYS-25 (Embrittlement) - Redacted ML15334A2842015-08-10010 August 2015 Official Exhibit - ENT000687-00-BD01 - 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) ML15335A2932015-08-10010 August 2015 Official Exhibit - NRCR00104-00-BD01 - on Yee Statement of Professional Qualifications (Revised) ML15337A2642015-08-10010 August 2015 Official Exhibit - NRC000196-PUB-00-BD01 - NRC Staff'S Initial Statement of Position on Contention NYS-25 (Reactor Vessel Internals) ML15337A3192015-08-10010 August 2015 Official Exhibit - ENT000698-PUB-00-BD01 - Entergy'S Revised Statement of Position Regarding Contention NYS-38/RK-TC-5(Safety Commitments) (Aug. 10, 2015)Redacted ML15337A3202015-08-10010 August 2015 Official Exhibit - ENT000699-PUB-00-BD01 - Redacted Revised Testimony of Entergy Witnesses Nelson Azevedo, Robert Dolansky, Alan Cox, Jack Strosnider, Timothy Griesbach, Barry Gordon, Randy Lott, and Mark Gray Regarding Contention NYS-38/RK ML15337A3172015-08-10010 August 2015 Official Exhibit - ENT000678-PUB-00-BD01 - 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 ML15337A2652015-08-10010 August 2015 Official Exhibit - NRC000197-PUB-00-BD01 - NRC Staff Testimony of Dr. Allen Hiser, Jeffrey Poehler, and Gary Stevens on NYS-25 and NYS-38/RK-TC-5 ML15337A2412015-08-10010 August 2015 Official Exhibit - NRCR00147-00-BD01 - NRC Staff'S Revised Statement of Position on State of New York and Riverkeeper'S Joint Contention NYS-38/RK-TC5 (Revised) ML15335A2902015-08-10010 August 2015 Official Exhibit - NRC000222-00-BD01 - IP3 FSAR Rev. 04 Chapter 3 (2011) (Excerpt) ML15334A2632015-08-10010 August 2015 Official Exhibit - ENT000648-00-BD01 - 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 Evaluat ML15337A2622015-08-10010 August 2015 Official Exhibit - NRC000228-00-BD01 - Indian Point Unit 2 Technical Specifications 3.1.4 ML15337A2452015-08-10010 August 2015 Official Exhibit - NRC000227-00-BD01 - Gary Stevens Statement of Professional Qualifications ML15337A2632015-08-10010 August 2015 Official Exhibit - NRC000229-00-BD01 - Indian Point, Unit 3 Technical Specifications 3.1.4 ML15335A2192015-08-10010 August 2015 Official Exhibit - ENTR00031-00-BD01 - Curriculum Vitae of Alan B. Cox ML15335A2112015-08-10010 August 2015 Official Exhibit - ENTR20186-00-BD01 - Curriculum Vitae of Mark A. Gray ML15337A3162015-08-10010 August 2015 Official Exhibit - ENT000616-PUB-00-BD01 - Testimony of Entergy Witnesses Nelson F. Azevedo, Robert J. Dolansky, Alan B. Cox, Jack R. Strosnider, Timothy J. Griesbach, Randy G. Lott, and Mark A. Gray Regarding Contention NYS-25 (Embrittleme ML15337A2782015-08-10010 August 2015 Official Exhibit - NRC000168-PUB-00-BD01 - NRC Staff Testimony of Dr. Allen Hiser, Dr. Ching Ng, Mr. Gary Stevens, P.E., and Mr. on Yee, Concerning Contentions NYS-26B/RK-TC-1B and NYS-38/RK-TC-5 ML15337A2712015-08-10010 August 2015 Official Exhibit - NRC000223-00-BD01 - IP3 FSAR Rev. 04 Chapter 14 (2011) ML15337A2592015-08-10010 August 2015 Official Exhibit - NRC000224-00-BD01 - IP3 FSAR Rev. 04 Chapter 16 ML15337A2442015-08-10010 August 2015 Official Exhibit - NRCR00161-00-BD01 - NRC Staff Testimony of Dr. Allen L. Hiser and Mr. Kenneth J. Karwoski Concerning Portions of State of New York and Riverkeeper, Inc. Joint Contention NYS-38/RK-TC5 (Revised) ML15334A2822015-08-10010 August 2015 Official Exhibit - ENT000680-00-BD01 - Curriculum Vitae of Barry M. Gordon ML15335A2912015-08-10010 August 2015 Official Exhibit - NRCR00118-00-BD01 - Indian Point Unit 3 Technical Specifications (Excerpt) (Revised) ML15334A2282015-08-10010 August 2015 Official Exhibit - ENT000634-00-BD01 - Entergy, IP2, FSAR Update, Revision 25 (2014) (Excerpts) ML15335A2822015-08-10010 August 2015 Official Exhibit - NRC000220-00-BD01 - Pressurized Water Reactor Owners Group (PWROG) Presentation Slides, Industry and NRC Coordination Meeting Materials Programs Technical Exchange: Clevis Insert Bolt Update, (June 2014) ML15337A2692015-08-10010 August 2015 Official Exhibit - NRC000169-00-BD01 - NRC000169 - Indian Point, Unit 2 Technical Specifications (Excerpt) ML15337A2602015-08-10010 August 2015 Official Exhibit - NRC000226-00-BD01 - Jeffrey C. Poehler Statement of Professional Qualifications ML15335A2732015-08-10010 August 2015 Official Exhibit - NRC000183-00-BD01 - NRC Inspection Manual, Inspection Procedure 71013, Site Inspection for Plants with a Timely Renewal Application (Sept. 25, 2013) ML15335A2202015-08-10010 August 2015 Official Exhibit - ENTR00184-00-BD01 - Curriculum Vitae of Jack R. Strosnider ML15335A3012015-08-10010 August 2015 Official Exhibit - NRC000206-00-BD01 - Indian Point, Unit 2, Updated Final Safety Analysis Report (Ufsar), Rev. 25, Chapter 14 - Safety Analysis (2014) 2015-09-09
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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 Docket #: 05000247 l 05000286 Exhibit #: CLE000025-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn: Exhibit CLE000025 Rejected: Stricken:
Submitted 12/22/11 Other:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-247-LR
) and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
_______________________________ ) March 20, 2011 DECLARATION OF DREW CLAXTON REGARDING HUDSON RIVER SLOOP CLEARWATER, INC.S COMBINED REPLY TO NRC STAFF AND ENTERGYS ANSWER TO AMENDED ENVIRONMENTAL JUSTICE CONTENTION I, Drew Claxton, do hereby state as follows:
- 1. I reside at reside at 601 Kissam Road, Peekskill, NY and have lived in Peekskill NY for 40 years. In 2000, I founded the Hudson Valley Chapter of Citizens for Equal Environmental Protection (CEEP), an environmental justice organization that works to ensure that low-income and minority communities in Peekskill and surrounding areas in the Hudson Valley are represented in the regional planning decisions that affect their environment, quality of life, and health. In 2001, I was elected to serve as Councilwoman on the City of Peekskill Common Council and am now serving my third term. As a City with population that is 48%
Hispanic and African American and 4% other ethnic minorities, Peekskill qualifies as what the NY State Office of Environmental Justice calls a potential environmental justice area (PEJA). In addition, CEEP has found that our Peekskill community, as compared to higher income Westchester communities, shoulders a disproportionate share of environmental burdens.
- 2. In 2001 and again in 2010, CEEP did a study of environmental and health burdens in and around Peekskill. Peekskill includes or is in close proximity to multiple pollution sources, including the Westchester Countys sewage treatment plant that treats sewage for Peekskill, Cortlandt and Yorktown and for which the County is pushing to extend district boundaries to include other higher-income northern-Westchester communities (e.g., Somers), the Wheelabrator/RESCO incinerator which burns much of Westchester Countys garbage, the Indian Point nuclear power plants, an ash landfill, a waster transfer stations, and a number of other industrial uses requiring hazardous waste permits. See Attachment 1-EJ Map of Westchester County. We have also found that Peekskill has what appears to be a relatively low health status, including a disproportionately high rate of low-birth weight babies and asthma hospitalizations.
3.) For the past two years I have also actively served the Peekskill Environmental Justice Council as we completed the Peekskill Community-based Environmental Justice Inventory (CBEJI).
Peekskill Demographics Peekskill NYS 1
Population (2000 Census) 22,441 18,976,457 2
Ethnicity Hispanic/Latino 0.22 0.15 Black/African-American 0.26 0.16 Non-Hispanic White 0.48 0.68 0.96 0.99 3
Median Income $57,343 $54,422 4
Median Home Value $285,900 5
depreciation since '09 6.04%
6 Cost of living r/t US average 26.80% Higher 7
Unemployment Rate US = 10.2% 7.20% 8.30%
8 Recent job loss 2.79%
- 4. With regard to Indian Point, I have serious concerns about the feasibility of evacuating area residents in the event of a nuclear accident or incident at Indian Point.
- School Districts. The City of Peekskill has a number of pre-school, Head Start, and day care centers, which do not have their own means to transport children to safety. In addition, the Peekskill City School District (in which, based on income, 67% of all children receive free or reduced lunches) are organized based on the Princeton Plan where children of the same age, not the same neighborhood, attend the same schools.
Therefore, it is often the case that children from the same family attend different elementary schools. The Princeton Plan is also in effect for public schools in the Village of Ossining, which is also a low-income and high minority community. Where the children of most Westchester school districts are transported to only one location, children from Peekskill City Schools and Ossining Village Schools are transported to different locations based on the schools that they attend. This makes it more difficult for 1
http://www.clrsearch.com/Search?query=&type=community 2
ibid.
3 ibid.
4 ibid.
5 http://www.bestplaces.net/find/
6 ibid.
7 ibid.
8 ibid.
2
Peekskill and Ossining parents to reunite with all of their children, and particularly hard if they do not have their own private transportation.
- Nursing homes, assisted-living facilities, group homes and shelters. The City of Peekskill, includes or is in close proximity to a number of nursing homes, assisted living facilities, and low-income senior citizens housing. In addition, the City of Peekskill, as compared to higher-income communities in Westchester, have a higher proportion of physically and/or mentally disabled persons living in group homes. We are also home to the JanPeek Shelter for homeless individuals. These populations are harder to evacuate during crisis.
- Hospitals. The Hudson Valley Hospital Center and FDR Veterans Administration Hospital and Nursing Home at Montrose are within 10 miles of Indian Point. As a Veteran of the U.S. Air Force myself, this concern for the safe evacuation of our veterans is near and dear to my heart.
- Correctional facilities and jails. Finally, within or bordering the 17.5 mile radius of the peak fatality zone around Indian Point, there are a number of local jails, the Westchester County Jail, and the Ossining Correctional Facility (Sing Sing) which house EJ populations and are near enough to Indian Point to disproportionately impacted by the inability to evacuate.
- Disproportionately less private transportation. As compared to higher-income communities, the City of Peekskill has a larger percentage of residents without private transportation, who are similarly more difficult to evacuate.
- 5. Given the recent disaster in Japan, the Nuclear Regulatory cannot be dismissive of potential environment justice matters, especially as they relate to human health and the environment and to evacuation of institutionalized populations.
- 6. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief.
Drew Claxton Executed in Peekskill, New York this 20th day of March, 2011 3