ML16060A586

NYS Cover Letter Submitting Supplement to February 22, 2016 Motion for Leave

ML16060A586
Person / Time
Site:	Indian Point
Issue date:	02/29/2016
From:	Sipos J State of NY, Office of the Attorney General
To:	Kennedy M, Lawrence Mcdade, Richard Wardwell Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML16060A585	List: ML16060A586 ML16060A587 ML16060A588
References
50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, RAS 50971
Download: ML16060A586 (1)

Text

STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL ERIC T. SCHNEIDERMAN DIVISION OF SOCIAL JUSTICE ATTORNEY GENERAL ENVIRONMENTAL PROTECTION BUREAU February 29, 2016 Lawrence G. McDade, Chair Richard E. Wardwell Michael F. Kennedy Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop - T-3 F23 Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 Re: Indian Point Nuclear Generating Station, Unit 2 and Unit 3 Docket Nos. 50-247-LR/50-286-LR; ASLBP No. 07-858-03-LR-BD01

Dear Administrative Judges:

In reviewing the States February 22, 2016 motion for leave I noticed that it did not address certain regulatory criteria for the admission of contentions. While the motion discussed various criteria including C.F.R. §§ 2.309(f)(2) and 2.309(c), it inadvertently did not address another set of criteria -- those contained in § 2.309(f)(1). To correct this, the State respectfully submits the accompanying supplement that discusses the § 2.309(f)(1) criteria in the context of Proposed Contention NYS-40. I apologioze to the Board, its staff, and the parties for this oversight.

Respectfully submitted, Signed (electronically) by John Sipos Assistant Attorney General cc: All individuals, parties, or NRC offices on the Service List THE CAPITOL, ALBANY, N.Y. 12224-0341 PHONE (518) 776-2400 FAX (518) 650-9363 WWW.AG.NY.GOV

STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL ERIC T. SCHNEIDERMAN DIVISION OF SOCIAL JUSTICE ATTORNEY GENERAL ENVIRONMENTAL PROTECTION BUREAU February 29, 2016 Lawrence G. McDade, Chair Richard E. Wardwell Michael F. Kennedy Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop - T-3 F23 Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 Re: Indian Point Nuclear Generating Station, Unit 2 and Unit 3 Docket Nos. 50-247-LR/50-286-LR; ASLBP No. 07-858-03-LR-BD01

Dear Administrative Judges:

In reviewing the States February 22, 2016 motion for leave I noticed that it did not address certain regulatory criteria for the admission of contentions. While the motion discussed various criteria including C.F.R. §§ 2.309(f)(2) and 2.309(c), it inadvertently did not address another set of criteria -- those contained in § 2.309(f)(1). To correct this, the State respectfully submits the accompanying supplement that discusses the § 2.309(f)(1) criteria in the context of Proposed Contention NYS-40. I apologioze to the Board, its staff, and the parties for this oversight.

Respectfully submitted, Signed (electronically) by John Sipos Assistant Attorney General cc: All individuals, parties, or NRC offices on the Service List THE CAPITOL, ALBANY, N.Y. 12224-0341 PHONE (518) 776-2400 FAX (518) 650-9363 WWW.AG.NY.GOV