ML17039B092

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Declaration of Diane Curran
ML17039B092
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 02/08/2017
From: Curran D
Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-247-LR, 50-286-LR, ASLABP 07-858-03-LR-BD01, RAS 51581
Download: ML17039B092 (2)


Text

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) )

) February 8, 2017 DECLARATION OF DIANE CURRAN Pursuant to 28 U.S.C. § 1746, Diane Curran hereby declares as follows:

1. I serve as counsel to Intervenor Riverkeeper, Inc. in this USNRC relicensing proceeding.
2. I submit this declaration in support of Intervenors Notice of Withdrawal of Track 2 Contentions and Unopposed Motion to Dismiss Those Contentions and This Proceeding in its Entirety (Feb. 8, 2017) (Intervenors Motion).

Purpose of My Declaration

3. The purpose of my declaration is to explain the basis for Riverkeepers decision to withdraw its Track 2 contentions (NYS-26B/RK-TC-1B and NYS-38/RK-TC-5) and seek dismissal of these contentions from this proceeding. My declaration is filed today along with the Declaration of Lisa Kwong (Feb. 8, 2017). Ms. Kwongs declaration was submitted on behalf of New York State (NYS). As co-Intervenor with NYS, Riverkeeper agrees with the statements in Ms. Kwongs declaration. Therefore I adopt and incorporate by reference paragraphs. 4 through 23 of Ms. Kwongs declaration.

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

Executed on February 8, 2017 Signed (electronically) by Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.

1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com February 8, 2017 2