ML15247A192
| ML15247A192 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/04/2015 |
| From: | Sutton K Entergy Nuclear Operations, Morgan, Morgan, Lewis & Bockius, LLP |
| To: | Kennedy M, Lawrence Mcdade, Wardell R Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, RAS 28255 | |
| Download: ML15247A192 (2) | |
Text
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Tel. 202.739.3000 Fax: 202.739.3001 www.morganlewis.com Kathryn M. Sutton Partner 202.739.5738 ksutton@MorganLewis.com Paul M. Bessette Partner 202.739.5796 pbessette@MorganLewis.com September 4, 2015 Lawrence G. McDade, Chairman Dr. Michael F. Kennedy Dr. Richard E. Wardwell Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re:
Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), Docket Nos. 50-247-LR and 50-286-LR - Notice of Correction to Position Statement for Contention NYS-25
Dear Administrative Judges:
On August 10, 2015, Entergy Nuclear Operations, Inc. (Entergy) filed its Statement of Position Regarding Contention NYS-25 (Embrittlement) (Position Statement). Pursuant to the Atomic Safety and Licensing Boards (Board) October 7, 2011 Order (Procedures for Evidentiary Filings), Entergy is filing a corrected version of its Position Statement. As a threshold matter, the corrections involve unintentional grammatical and administrative errors introduced into the document. The corrections do not involve any substantive changes.
However, as a practical and professional matter, Counsel for Entergy sincerely regrets any misunderstanding that may have been caused by these inadvertent mistakes, particularly the unintended reference to Dr. Lahey listed below in bullet number two. We apologize for the erroneous and unintended insertion of the word in the document during the drafting process.
The following items have been corrected:
- On page 9, a grammatical error is corrected. The revised sentence now states as follows (addition shown as underlined text): Neither the State nor Dr. Lahey provides any specific challenge to this information.
Administrative Judges September 4, 2015 Page 2
- On page 33, the word Pathetic is removed at the start of the third paragraph.
- On page 35, footnote 176, a period is added at the end of the citation.
- On page 38, footnote 194, the second period is removed.
- On page 38, footnote 196, a period is added at the end of the citation.
- On page 42, footnote 213, the second period is removed.
- On page 53, footnote 290, a period is added at the end of the citation.
- On page 54, footnote 301, a period is added at the end of the citation.
- On page 58, footnote 324, a space is added between Lahey and Testimony.
In accordance with paragraphs A and K of the Protective Order, the corrected Position Statement is being served via the NRCs Electronic Information Exchange upon the Board, its law clerks, the Office of the Secretary, and representatives of Hearing Participants that are authorized to receive such information pursuant to the Protective Order.
Respectfully submitted, Executed in accord with 10 C.F.R. § 2.304(d)
Kathryn M. Sutton, Esq.
Paul M. Bessette, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Phone: (202) 739-3000 Fax: (202) 739-3001 E-mail: ksutton@morganlewis.com E-mail: pbessette@morganlewis.com Counsel for Entergy Nuclear Operations, Inc.