ML12340A673

Official Exhibit - NYS000162-00-BD01 - Declaration of Assistant Attorney General Lisa Feiner (Pft Feiner Decl.)

ML12340A673
Person / Time
Site:	Indian Point
Issue date:	12/15/2011
From:	Feiner L State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23294, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12340A673 (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 NYS000162 Docket #: 05000247 l 05000286 Submitted: December 15, 2011 Exhibit #: NYS000162-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn: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. December , 2011

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x DECLARATION OF LISA FEINER Pursuant to 28 U.S.C. § 1746, Lisa Feiner 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 consolidated contentions, NYS-6 and NYS -7 (hereinafter NYS-6 & 7) which assert that Entergy's Aging Management Program for non-environmentally qualified low and medium voltage power cables exposed to localized adverse environmental conditions is so devoid of essential information that Entergy has not demonstrated that it will adequately manage the effects of aging on these cables during the license renewal period. The accompanying exhibits are discussed in more detail in the States Statement of Position.

2. Attached to this declaration as Exhibit NYS is a true and correct copy of the document entitled State of New York Hearing Exhibits List ("NYS Exhibits List"), Exh. 000001.

NYS Exhibits List includes those exhibits relied upon and referenced in support of Contentions 6

& 7, NYS000135 through NYS000161.

3. Attached to this declaration as Exhibit NYS000161-- is a true and correct copy of

the document entitled NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian point Nuclear Generating Unit Nos. 2 and 3, Supplement No. 1, Docket Nos. 50-247 and 50-286 (August 2011).

4. Attached to this declaration as Exhibit NYS000161 is a true and correct copy of the document entitled NUREG-1800, Final Report, Rev. 2, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (December 2010).

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

Executed on December 15, 2011 Signed (electronically) by Lisa Feiner Assistant Attorney General Office of the Attorney General of the State of New York The Capitol Albany, New York 12224 (518) 476-7398