ML12340A647

Official Exhibit - NYS000432-00-BD01 - Declaration of Kathryn Liberatore (Jun. 29, 2012)

ML12340A647
Person / Time
Site:	Indian Point
Issue date:	06/29/2012
From:	Liberatore K State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 22882, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12340A647 (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 NYS000432 Docket #: 05000247 l 05000286 Submitted: June 29, 2012 Exhibit #: NYS000432-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

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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. June 29, 2012

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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 exhibit 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. Attached to this declaration as Exhibit NYS000421 is a true and correct copy of an email string containing two emails.

3. Exhibit NYS000421 contains the email I sent on April 20, 2012 at 10:55 a.m. to counsel for NRC Staff Brian Harris, Esq., with carbon copies to counsel for the State of New York Janice Dean, Esq. and John Sipos, Esq. The emails subject was NYS 12C -- request for article.

4. Exhibit NYS000421 also contains Mr. Harris response to my email, which he sent to me, carbon copying Ms. Dean and Mr. Sipos, on April 25, 2012 at 12:29 p.m. with the subject RE: NYS 12C -- request for article.

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

Executed on June 29, 2012 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