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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
{{#Wiki_filter: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 6, 2013
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-----------------------------------------------------------x STATE OF NEW YORKS ANSWER TO ENTERGYS REQUEST FOR LEAVE TO FILE AN ADDITIONAL EXHIBIT AND SUPPLEMENTAL PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN RESPONSE TO NEW YORKS SUPPLEMENTAL PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON CONTENTION NYS-16B Office of the Attorney General for the State of New York The Capitol State Street Albany, New York 12224
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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 6, 2013
INTRODUCTION Pursuant to 10 C.F.R. § 2.323(2)(c), the State of New York responds to Entergys request for leave to file supplemental Proposed Findings of Fact and Conclusions of Law (Proposed Findings) in response to the States supplemental Proposed Findings for Consolidated Contention NYS-16B, and to enter the entirety of NL-13-075, License Renewal Application-Completed Engineering Project Cost Estimates for SAMAs Previously Identified as Potentially Cost-Beneficial (May 6, 2013) (ML13127A459) (NL-13-075) as an exhibit instead of the excerpted table proffered by the State. Entergys Answer Opposing State of New York Motion Seeking Leave to File an Additional Exhibit and Supplemental Findings of Fact and Conclusions of Law (May 28, 2013) (Entergy Oppn) at 1, 5, n.21 (ML13148A498).1 Todays answer by the State is timely was filed 9 days after Entergys submission.
While the State does not object to Entergy responding to the States Proposed Findings, the State does object to Entergys request that the entirety of NL-13-075 be admitted as an exhibit. 2 As explained in more detail below, only the excerpted tablecontaining Entergys revised cost-benefit conclusionsis relevant to NYS-16B. This table has been offered as an exhibit for the sole purpose of rebutting Entergys and Staffs argument that including commuters and undercounted minority residents in the population estimate will not have a material impact on the Severe Accident Mitigation Alternatives (SAMA) analysis. The remainder of NL-13-075which contains Entergys decision to implement some cost-beneficial 1
Instead of filing a separate motion for leave, Entergy requested leave to file responsive findings in its answer to the States motion. Entergys proposed supplemental findings are attached to its answer.
2 During consultation for the States motion, the parties discussed the States proposal to submit an excerpt of NL-13-075 containing Table 1 as an exhibit, but Entergy did not indicate that it would seek to have the entirety of NL-13-075 entered as an exhibit.
1


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SAMA candidates and defer consideration of othersmay be relevant to NRC Staffs efforts to remedy the deficiencies in the Final Supplemental Environmental Impact Statement (FSEIS) set forth by the Board in its July 14, 2011 summary disposition of NYS-35/36, but it is not relevant to the issues raised in NYS-16Bi.e., whether commuters and undercounted minority residents should be included in the population estimate for Indian Point. Additionally, now that Entergy has submitted responsive findings, the State reiterates its request to submit brief reply findings.3 ARGUMENT The State does not object to Entergys request to submit supplemental Proposed Findings.
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The State does, however, object to Entergys request that the entirety of NL-13-075 be admitted as an exhibit. Aside from the excerpted table submitted by the State (NYS000476), NL-13-075 is not relevant to NYS-16B. The relevant portion of NL-13-075 is the revised SAMA cost-benefit table reclassifying previously cost-beneficial SAMA candidates as no longer cost-beneficial. NL-13-075, attach. 1 at 4-5. Upon reviewing the costs and benefits reported in this table, the State determined that two SAMA candidates Entergy wishes to reclassify as not cost-beneficial would still be cost-beneficial if the increases in population set forth in NYS-16B were taken into account. This evidence directly rebuts Entergys argument that the population errors identified in NYS-16B will not have a material impact on the SAMA analysis. The excerpt was submitted by the State solely for this purpose.
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3 NRC Staff requested an opportunity to submit responsive findings, but did not attach any proposed findings to its answer to the States motion. NRC Staffs Opposition to State of New York Motion Seeking Leave to File an Additional Exhibit and Supplemental Proposed Findings of Fact and Conclusions of Law on Contention NYS-16B at 1 n.2 (May 23, 2013)
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(ML13134A354). The State respectfully requests that it be permitted to file a single reply to both the Entergy and Staff supplemental Proposed Findings after Staff tenders its supplemental Proposed Findings.
2


STATE OF NEW YORK'S ANSWER TO ENTERGY'S REQUEST FOR LEAVE TO FILE AN ADDITIONAL EXHIBIT AND SUPPLEMENTAL PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN RESPONSE TO NEW YORK'S SUPPLEMENTAL PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON CONTENTION NYS-16B  
The remainder of NL-13-075, however, has no bearing on NYS-16B. Although it is generally inappropriate to communicate matters of substance to the Board via letter or e-mail,4 Entergy informed the Atomic Safety and Licensing Board via letter that it submitted this information [in NL-13-075] to the NRC to support resolution of certain issues identified by the Board in its July 14, 2011 decision granting New York States motion for summary disposition of Consolidated Contention NYS-35/36. Entergy Letter to ASLB, Re: Notification of Entergys Submission of the Results of Completed Engineering Project Cost Estimates for SAMAs Previously Identified as Potentially Cost-Beneficial (May 7, 2013) (ML13127A458).
The majority of the document explains Entergys decision to implement some cost-beneficial SAMA candidates and its decision to defer consideration of other cost-beneficial SAMA candidates. For example, in NL-13-075 Entergy discloses for the first time that it has implemented a SAMA candidate at Indian Point Unit 3, and plans to implement three more SAMA candidates (two at Unit 3 and one at Unit 2) by August 31, 2014. Putting aside the fact that NL-13-075 fails to explain why Entergy chose to implement any SAMA candidates at all and why it chose to implement these four as compared to the other cost-beneficial candidates, providing a rational basis for the implementation of SAMA candidates is not the subject of NYS-16B.
Entergys only justification for seeking admission of the entire NL-13-075 document is that it will provide appropriate factual and legal context. Entergy Oppn at 5, n.21. But the 4
The record should not be cluttered with such casual for your information letters. Entergy Nuclear Vermont Yankee L.L.C. and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), Order Striking New England Coalitions Letter to the Board at 1-2 (May 12, 2005). Instead, matters of substance should be communicated to the Board in formal filings, with the caption of the case, signature of counsel, and affidavits to support any factual statements. Id; see also 10 C.F.R. § 2.323(2)(b) (a motion must state with particularity the grounds and the relief sought).
3


Office of the Attorney General 
States supplemental Proposed Findings and Entergys responsive Proposed Findings already provide that context. See State supplemental Proposed Findings at 2-5, ¶¶207-214; Entergy supplemental Proposed Findings at 4, ¶6. As NL-13-075 does not mention NYS-16B, and only Table 1 of that document is relevant to Entergys and Staffs materiality defense for NYS-16B, admitting the entire document will not provide the necessary context.
Moreover, entering the entirety of NL-13-075 as an exhibit to NYS-16B would also be inappropriate because it represents an attempt by Entergy to circumvent the proper process for remedying the National Environmental Policy Act (NEPA) deficiencies outlined in the Boards summary disposition order on NYS-35/36. In granting summary disposition to the State, the Board found that the NRC Staffs decision to allow Entergy to complete its SAMA review outside of the license renewal process, by deferring the evaluation of SAMAs found to be potentially cost-beneficial until after relicensing, does not provide an adequate record for the agency to make its decision on the impacts of relicensing IP2 and IP3. Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), (Ruling on Motion and Cross-Motions for Summary Disposition of NYS-35/36), LBP-11-17, 74 N.R.C. 11, 16-17 (Jul. 14, 2011), interlocutory review denied, CLI-11-14, __ N.R.C. ___ (Dec. 22, 2011). Thus, at present NRC Staffs FSEIS for the proposed license renewal of Indian Point Unit 2 and Unit 3 has been found to be insufficient and it cannot now provide the basis to issue a renewed operating license for Indian Point Unit 2 or Indian Point Unit 3 under the NEPA. While NL-13-075 highlights the fact that the SAMA analysis is incomplete, the only way to remedy the deficiencies in NYS-35/36 is for NRC Staff to follow the Boards order:
[U]nder NRC Regulations, the APA, and NEPA, Entergys licenses cannot be renewed unless and until the NRC Staff reviews Entergys completed SAMA analyses and either incorporates the result of these reviews into the FSEIS or, in the alternative, modifies its FSEIS to provide a valid reason for recommending the 4


for the State of New York
renewal of the licenses before the analysis of potentially cost effective SAMAs is complete and for not requiring the implementation of cost-beneficial SAMAs.
 
The Capitol
 
State Street
 
Albany, New York 12224
 
1 INTRODUCTION Pursuant to 10 C.F.R. § 2.323(2)(c), the State of New York responds to Entergy's request for leave to file supplemental Proposed Findings of Fact and Conclusions of Law ("Proposed Findings") in response to the State's supplemental Proposed Findings for Consolidated Contention NYS-16B, and to enter the entirety of NL-13-075, License Renewal Application-Completed Engineering Project Cost Estimates for SAMAs Previously Identified as Potentially Cost-Beneficial (May 6, 2013) (ML13127A459) ("NL 075") as an exhi bit instead of the excerpted table proffered by the State.
Entergy's Answer Opposing State of New York Motion Seeking Leave to File an Additional Exhibit and Supplemental Findings of Fact and Conclusions of Law (May 28, 2013) ("Entergy Opp'n") at 1, 5, n.21 (ML13148A498).
1  Today's answer by the State is timely was filed 9 days after Entergy's submission.
While the State does not object to Entergy responding to the State's Proposed Findings, the State does object to Entergy's request that the entirety of NL-13-075 be admitted as an exhibit. 2  As explained in more detail below, only the excerpted tabl e-containing Entergy's revised cost-benefit conclusions-is relevant to NYS-16B. This table has been offered as an exhibit for the sole purpose of rebutting Entergy's and Staff's argument that including commuters and undercounted minority residents in the population estimate will not have a material impact on the Severe Accident Mitig ation Alternatives ("SAMA") analysis. The remainder of NL-13-075-which contains Entergy's decision to implement some cost-beneficial
 
1 Instead of filing a separate motion for leave, En tergy requested leave to file responsive findings in its answer to the State's motion. Entergy's proposed supplemen tal findings are attached to its answer.
2 During consultation for the State's motion, the pa rties discussed the State's proposal to submit an excerpt of NL-13-075 containing Table 1 as an exhibit, but En tergy did not indicate that it would seek to have the entirety of NL-13-075 entered as an exhibit.
2 SAMA candidates and defer consideration of others-may be relevant to NRC Staff's efforts to remedy the deficiencies in the Final Supplemental Environmental Impact Statement ("FSEIS")
set forth by the Board in its July 14, 2011 summa ry disposition of NYS-35/36, but it is not relevant to the issues raised in NYS-16B-i.e., whether commuters and undercounted minority residents should be included in the population estimate for Indian Point.
Additionally, now that Entergy has submitted responsive findings, the State reiterates its request to submit brief reply findings.3 ARGUMENT The State does not object to Entergy's request to submit supplemental Proposed Findings. The State does, however, object to Entergy's request that the entirety of NL-13-075 be admitted as an exhibit. Aside from the excerpted table submitted by the State (NYS000476), NL-13-075 is not relevant to NYS-16B. The relevant portion of NL-13-075 is th e revised SAMA cost-benefit table reclassifying pr eviously cost-beneficial SAMA candidates as no longer cost-beneficial. NL-13-075, attach. 1 at 4-5. Upon reviewing the costs a nd benefits reported in this table, the State determined that two SAMA candidates Entergy wish es to reclassify as not cost-beneficial would still be cost-beneficial if the increases in population se t forth in NYS-16B were taken into account. This eviden ce directly rebuts Entergy's argument that the population errors identified in NYS-16B will not have a material impact on the SAMA analysis. The excerpt was submitted by the State solely for this purpose.
 
3 NRC Staff requested an opportunity to submit responsive find ings, but did not attach any proposed findings to its answer to the State's motion.
NRC Staff's Opposition to State of New York Motion Seeking Leave to File an Additional Exhibit and Supplemental Proposed Findings of Fact and Conclusions of Law on Contention NYS-16B at 1 n.2 (May 23, 2013) (ML13134A354). The State respectfully requests that it be permitted to file a single reply to both the Entergy and Staff supplemental Proposed Findings after Staff tenders its supplemental Proposed Findings.
3The remainder of NL-13-075, however, has no bearing on NYS-16B. Although it is generally inappropriate to communicate matters of substance to the Board via letter or e-mail, 4 Entergy informed the Atomic Safety and Licensing Board via letter that it "submitted this information [in NL-13-075] to the NRC to support resolution of certain is sues identified by the Board in its July 14, 2011 decision granting New York State's motion for summary disposition of Consolidated Contention NYS-35/36."
Entergy Letter to ASLB, Re: Notification of Entergy's Submission of the Results of Completed Engineering Project Cost Estimates for SAMAs Previously Identified as Potentially Cost-Beneficia l (May 7, 2013) (ML13127A458). The majority of the document explains Entergy's decision to implement some cost-beneficial SAMA candidates and its decision to defer consideration of other cost-beneficial SAMA candidates. For example, in NL-13-075 Entergy discloses for the first time that it has implemented a SAMA candidate at Indian Point Unit 3, and plans to implement three more SAMA candidates (two at Unit 3 and one at Unit 2) by August 31, 2014. Putting aside the fact that NL-13-075 fails to explain why Entergy chose to implement any SAMA candidates at all and why it chose to implement these four as compared to the other cost-beneficial candidates, providing a rational basis for the implementation of SAMA candidates is not the subject of NYS-16B. Entergy's only justification for seeking admission of the entire NL-13-075 document is that it will "provide appropriate factual and legal context."
Entergy Opp'n at 5, n.21. But the
 
4 The "record should not be clut tered with such casual 'for your information' letters."
Entergy Nuclear Vermont Yankee L.L.C. and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), Order St riking New England Coalition's Letter to the Board at 1-2 (May 12, 2005). Instead, matters of substance should be communicated to the Board in formal filings, with the caption of the case, signature of c ounsel, and affidavits to support any factual statements. Id; see also 10 C.F.R. § 2.323(2)(b) (a motion must "state with particularity the grounds and the relief sought").
4State's supplemental Proposed Findings and Entergy's responsive Pr oposed Findings already provide that context. See State supplemental Proposed Fi ndings at 2-5, ¶¶207-214; Entergy supplemental Proposed Findings at 4, ¶6. As NL-13-075 does not mention NYS-16B, and only Table 1 of that document is relevant to Entergy's and Staff's material ity defense for NYS-16B, admitting the entire document will not provide the necessary context.
Moreover, entering the entirety of NL-13-075 as an exhibit to NYS-16B would also be inappropriate because it represents an attempt by Entergy to circumvent the proper process for remedying the National Environmental Policy Act ("NEPA") deficiencies outlined in the Board's summary disposition order on NYS-35/36.
In granting summary disposition to the State, the Board found "that the NRC Staff's decision to allow Entergy to complete its SAMA review outside of the license renewal process, by deferring the evaluation of SAMAs found to be potentially cost-beneficial until after relicensing, does not provide an adequate record for the agency to make its decision on the impacts of relicensing IP2 and IP3."
Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), (Ruling on Motion and Cross-Motions for Summary Disposition of NYS-35/36), LBP-11-17, 74 N.R.C. 11, 16-17 (Jul. 14, 2011), interlocutory review denied , CLI-11-14, __ N.R.C. ___ (Dec. 22, 2011). Thus, at present NRC Staff's FSEIS for the proposed license renewa l of Indian Point Unit 2 and Unit 3 has been found to be insufficient and it ca nnot now provide the basis to i ssue a renewed operating license for Indian Point Unit 2 or Indian Point Unit 3 under the NEPA. While NL-13-075 highlights the fact that the SAMA analysis is incomplete, the only way to remedy the deficiencies in NYS-35/36 is for NRC Staff to fo llow the Board's order:    [U]nder NRC Regulations, the APA, and NEPA, Entergy's licenses cannot be renewed unless and until the NRC Staff reviews Entergy's completed SAMA analyses and either incorporates the result of these reviews into the FSEIS or, in the alternative, modifies its FSEIS to provide a valid reason for recommending the 5renewal of the licenses before the analysis of potentially cost effective SAMAs is complete and for not requiring the implementation of cost-beneficial SAMAs.
Id. at 17.
Id. at 17.
As such, NL-13-075 should not be entered in it s entirety as an exhibit for NYS-16B. The Board should admit only the excerpt of Table 1 (NYS000476), for the sole purpose of rebutting Entergy's and NRC Staff's materiality defense in NYS-16B. CONCLUSION For the foregoing reasons, New York State opposes Entergy's request that the Board admit NL-13-075 in its entirety. Additionally, now that Entergy has submitted responsive Proposed Findings, the State reiterates its request to submit brie f reply Proposed Findings. For the sake of efficiency, the State respectfully requests that it be permitted to file combined Proposed Findings, replying to both Entergy and NRC Staff, 10 days after the date of Staff's filing of responsive findings.
As such, NL-13-075 should not be entered in its entirety as an exhibit for NYS-16B. The Board should admit only the excerpt of Table 1 (NYS000476), for the sole purpose of rebutting Entergys and NRC Staffs materiality defense in NYS-16B.
Respectfully submitted, Signed (electronically) by Signed (electronically) by Laura E. Heslin Kathryn M. Liberatore Assistant Attorneys General Office of the Attorney General for the State of New York 120 Broadway New York, New York 10271 (212) 416-6091 (212) 416-8482 John J. Sipos Assistant Attorney General Office of the Attorney General for the State of New York The Capitol Albany, New York 12224 (518) 402-2251 June 6, 2013 1UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
CONCLUSION For the foregoing reasons, New York State opposes Entergys request that the Board admit NL-13-075 in its entirety. Additionally, now that Entergy has submitted responsive Proposed Findings, the State reiterates its request to submit brief reply Proposed Findings. For the sake of efficiency, the State respectfully requests that it be permitted to file combined Proposed Findings, replying to both Entergy and NRC Staff, 10 days after the date of Staffs filing of responsive findings.
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Respectfully submitted, Signed (electronically) by                             Signed (electronically) by Laura E. Heslin                                         John J. Sipos Kathryn M. Liberatore                                   Assistant Attorney General Assistant Attorneys General                            Office of the Attorney General Office of the Attorney General                           for the State of New York for the State of New York                             The Capitol 120 Broadway                                            Albany, New York 12224 New York, New York 10271                                (518) 402-2251 (212) 416-6091 (212) 416-8482 June 6, 2013 5
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-----------x In re: Docket Nos. 50-247-LR and 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 6, 2013  
 
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-----------x CERTIFICATE OF SERVICE I hereby certify that on June 6, 2013, copies of the accompanying State of New York Answer to Entergy's Request to File and Additional Exhib it Concerning Contention NYS-16B were served electronically via the Electronic Informa tion Exchange on the following recipients:
 
Lawrence G. McDade, Chair
 
Richard E. Wardwell, Administrative Judge Michael F. Kennedy, Administrative Judge Atomic Safety and Licensing Board Panel
 
U.S. Nuclear Regulatory Commission Mailstop 3 F23 Two White Flint North
 
11545 Rockville Pike
 
Rockville, MD 20852-2738
 
Lawrence.McDade@nrc.gov Richard.Wardwell@nrc.gov
 
Michael.Kennedy@nrc.gov
 
Atomic Safety and Licensing Board Panel
 
U.S. Nuclear Regulatory Commission Mailstop 3 F23 Two White Flint North
 
11545 Rockville Pike
 
Rockville, MD 20852-2738
 
Shelbie Lewman, Esq., Law Clerk Carter Thurman, Esq., Law Clerk James Maltese, Esq., Law Clerk Atomic Safety and Licensing Board Panel
 
U.S. Nuclear Regulatory Commission Mailstop 3 F23 Two White Flint North
 
11545 Rockville Pike
 
Rockville, MD 20852-2738 Shelbie.Lewman@nrc.gov Carter.Thurman@nrc.gov James.Maltese@nrc.gov
 
Office of Commission Appellate
 
Adjudication
 
U.S. Nuclear Regulatory Commission Mailstop 16 G4 One White Flint North
 
11555 Rockville Pike
 
Rockville, MD 20852-2738 ocaamail@nrc.gov
 
2Office of the Secretary Attn: Rulemaking and Adjudications Staff
 
U.S. Nuclear Regulatory Commission Mailstop 3 F23 Two White Flint North
 
11545 Rockville Pike
 
Rockville, MD 20852-2738
 
hearingdocket@nrc.gov
 
Sherwin E. Turk, Esq.
 
David E. Roth, Esq.
 
Beth N. Mizuno, Esq.
 
Brian G. Harris, Esq.
 
Anita Ghosh, Esq.
 
Joseph A. Lindell, Esq.
 
Office of the General Counsel
 
U.S. Nuclear Regulatory Commission Mailstop 15 D21 One White Flint North
 
11555 Rockville Pike
 
Rockville, MD 20852-2738
 
sherwin.turk@nrc.gov
 
david.roth@nrc.gov beth.mizuno@nrc.gov
 
brian.harris@nrc.gov
 
anita.ghosh@nrc.gov Joseph.Lindell@nrc.gov
 
Kathryn M. Sutton, Esq.
 
Paul M. Bessette, Esq.
 
Jonathan Rund, Esq.
 
Raphael Kuyler, Esq.
 
Morgan, Lewis & Bockius LLP
 
1111 Pennsylvania Avenue, NW
 
Washington, DC 20004
 
ksutton@morganlewis.com pbessette@morganlewis.com jrund@morganlewis.com rkuyler@morganlewis.com
 
Martin J. O'Neill, Esq.
 
Morgan, Lewis & Bockius LLP
 
Suite 4000
 
1000 Louisiana Street
 
Houston, TX 77002 martin.o'neill@morganlewis.com Bobby R. Burchfield, Esq.
Matthew M. Leland, Esq.
Clint A. Carpenter, Esq.
McDermott Will & Emery LLC
 
600 13th Street, NW


Washington, DC 20005-3096 bburchfield@mwe.com mleland@mwe.com ccarpenter@mwe.com
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
-----------------------------------------------------------x In re:                                                          Docket Nos. 50-247-LR and 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 6, 2013
-----------------------------------------------------------x CERTIFICATE OF SERVICE I hereby certify that on June 6, 2013, copies of the accompanying State of New York Answer to Entergys Request to File and Additional Exhibit Concerning Contention NYS-16B were served electronically via the Electronic Information Exchange on the following recipients:
Lawrence G. McDade, Chair                                    Shelbie Lewman, Esq., Law Clerk Richard E. Wardwell, Administrative Judge                    Carter Thurman, Esq., Law Clerk Michael F. Kennedy, Administrative Judge                    James Maltese, Esq., Law Clerk Atomic Safety and Licensing Board Panel                      Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission                          U.S. Nuclear Regulatory Commission Mailstop 3 F23                                              Mailstop 3 F23 Two White Flint North                                        Two White Flint North 11545 Rockville Pike                                        11545 Rockville Pike Rockville, MD 20852-2738                                    Rockville, MD 20852-2738 Lawrence.McDade@nrc.gov                                      Shelbie.Lewman@nrc.gov Richard.Wardwell@nrc.gov                                    Carter.Thurman@nrc.gov Michael.Kennedy@nrc.gov                                      James.Maltese@nrc.gov Atomic Safety and Licensing Board Panel                      Office of Commission Appellate U.S. Nuclear Regulatory Commission                          Adjudication Mailstop 3 F23                                              U.S. Nuclear Regulatory Commission Two White Flint North                                        Mailstop 16 G4 11545 Rockville Pike                                        One White Flint North Rockville, MD 20852-2738                                    11555 Rockville Pike Rockville, MD 20852-2738 ocaamail@nrc.gov 1


Richard A. Meserve, Esq.
Office of the Secretary                    Bobby R. Burchfield, Esq.
Matthew W. Swinehart, Esq.
Attn: Rulemaking and Adjudications Staff  Matthew M. Leland, Esq.
Covington & Burling LLP  
U.S. Nuclear Regulatory Commission        Clint A. Carpenter, Esq.
 
Mailstop 3 F23                            McDermott Will & Emery LLC Two White Flint North                      600 13th Street, NW 11545 Rockville Pike                      Washington, DC 20005-3096 Rockville, MD 20852-2738                  bburchfield@mwe.com hearingdocket@nrc.gov                      mleland@mwe.com ccarpenter@mwe.com Sherwin E. Turk, Esq.
1201 Pennsylvania Avenue, NW  
David E. Roth, Esq.                        Richard A. Meserve, Esq.
 
Beth N. Mizuno, Esq.                      Matthew W. Swinehart, Esq.
Washington, DC 20004-2401 rmeserve@cov.com mswinegart@cov.com  
Brian G. Harris, Esq.                      Covington & Burling LLP Anita Ghosh, Esq.                          1201 Pennsylvania Avenue, NW Joseph A. Lindell, Esq.                    Washington, DC 20004-2401 Office of the General Counsel              rmeserve@cov.com U.S. Nuclear Regulatory Commission        mswinegart@cov.com Mailstop 15 D21 One White Flint North                      Elise N. Zoli, Esq.
 
11555 Rockville Pike                      Goodwin Procter, LLP Rockville, MD 20852-2738                  Exchange Place sherwin.turk@nrc.gov                      53 State Street david.roth@nrc.gov                        Boston, MA 02109 beth.mizuno@nrc.gov                        ezoli@goodwinprocter.com brian.harris@nrc.gov anita.ghosh@nrc.gov                        William C. Dennis, Esq.
Elise N. Zoli, Esq.
Joseph.Lindell@nrc.gov                    Assistant General Counsel Entergy Nuclear Operations, Inc.
Goodwin Procter, LLP  
Kathryn M. Sutton, Esq.                    440 Hamilton Avenue Paul M. Bessette, Esq.                    White Plains, NY 10601 Jonathan Rund, Esq.                        wdennis@entergy.com Raphael Kuyler, Esq.
 
Morgan, Lewis & Bockius LLP                Robert D. Snook, Esq.
Exchange Place  
1111 Pennsylvania Avenue, NW              Assistant Attorney General Washington, DC 20004                      Office of the Attorney General ksutton@morganlewis.com                    State of Connecticut pbessette@morganlewis.com                  55 Elm Street jrund@morganlewis.com                      P.O. Box 120 rkuyler@morganlewis.com                    Hartford, CT 06141-0120 robert.snook@ct.gov Martin J. ONeill, Esq.
 
Morgan, Lewis & Bockius LLP Suite 4000 1000 Louisiana Street Houston, TX 77002 martin.oneill@morganlewis.com 2
53 State Street  
 
Boston, MA 02109  
 
ezoli@goodwinprocter.com  
 
William C. Dennis, Esq.
Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue  
 
White Plains, NY 10601 wdennis@entergy.com  
 
Robert D. Snook, Esq.
Assistant Attorney General Office of the Attorney General  
 
State of Connecticut 55 Elm Street  
 
P.O. Box 120  
 
Hartford, CT 06141-0120  
 
robert.snook@ct.gov  
 
3Melissa-Jean Rotini, Esq.
Assistant County Attorney Office of the Westchester County Attorney Michaelian Office Building
 
148 Martine Avenue, 6th Floor
 
White Plains, NY 10601
 
MJR1@westchestergov.com
 
Sean Murray, Mayor Kevin Hay, Village Administrator Village of Buchanan Municipal Building
 
236 Tate Avenue
 
Buchanan, NY 10511-1298 Administer@villageofbuchanan.com
 
Daniel Riesel, Esq.
Thomas F. Wood, Esq.  
 
Victoria S. Treanor, Esq.  
 
Sive, Paget & Riesel, P.C.
 
460 Park Avenue
 
New York, NY 10022
 
driesel@sprlaw.com vtreanor@sprlaw.com  
 
Michael J. Delaney, Esq. Director Energy Regulatory Affairs NYC Department of Environmental Protection
 
59-17 Junction Boulevard
 
Flushing, NY 11373
 
mdelaney@dep.nyc.govKarla Raimundi,  Environmental Justice Associate
 
Hudson River Sloop Clearwater, Inc.
724 Wolcott Avenue
 
Beacon, NY 12508 karla@clearwater.org
 
Richard Webster, Esq.
Public Justice, P.C.
 
Suite 200
 
1825 K Street, NW
 
Washington, DC 20006 rwebster@publicjustice.net
 
Phillip Musegaas, Esq.


Melissa-Jean Rotini, Esq.                  Karla Raimundi, Assistant County Attorney                  Environmental Justice Associate Office of the Westchester County Attorney  Hudson River Sloop Clearwater, Inc.
Michaelian Office Building                  724 Wolcott Avenue 148 Martine Avenue, 6th Floor              Beacon, NY 12508 White Plains, NY 10601                      karla@clearwater.org MJR1@westchestergov.com Richard Webster, Esq.
Sean Murray, Mayor                          Public Justice, P.C.
Kevin Hay, Village Administrator            Suite 200 Village of Buchanan                        1825 K Street, NW Municipal Building                          Washington, DC 20006 236 Tate Avenue                            rwebster@publicjustice.net Buchanan, NY 10511-1298 Administer@villageofbuchanan.com            Phillip Musegaas, Esq.
Deborah Brancato, Esq.
Deborah Brancato, Esq.
Riverkeeper, Inc.  
Daniel Riesel, Esq.                        Riverkeeper, Inc.
 
Thomas F. Wood, Esq.                        20 Secor Road Victoria S. Treanor, Esq.                  Ossining, NY 10562 Sive, Paget & Riesel, P.C.                  phillip@riverkeeper.org 460 Park Avenue                            dbrancato@riverkeeper.org New York, NY 10022 driesel@sprlaw.com vtreanor@sprlaw.com Michael J. Delaney, Esq.
20 Secor Road  
Director Energy Regulatory Affairs NYC Department of Environmental Protection 59-17 Junction Boulevard Flushing, NY 11373 mdelaney@dep.nyc.gov Signed (electronically) by
 
____________________________________
Ossining, NY 10562 phillip@riverkeeper.org dbrancato@riverkeeper.org  
Kathryn M. Liberatore Assistant Attorney General State of New York (212) 416-8482 Dated at New York, New York this 6th day of June 2013 3}}
 
Signed (electronically) by
____________________________________         Kathryn M. Liberatore Assistant Attorney General State of New York (212) 416-8482  
 
Dated at New York, New York  
 
this 6th day of June 2013}}

Revision as of 17:14, 4 November 2019

State of Ny'S Answer to Entergy'S Request for Leave to File Additional Exhibit & Supplemental Proposed Findings of Fact & Conclusions of Law in Response to New York'S Supplemental Proposed Findings of Fact & Conclusions of Law on Contention
ML13157A457
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/06/2013
From: Heslin L, Liberatore K, Sipos J
State of NY, Office of the Attorney General
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 24655, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML13157A457 (9)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

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 6, 2013

x STATE OF NEW YORKS ANSWER TO ENTERGYS REQUEST FOR LEAVE TO FILE AN ADDITIONAL EXHIBIT AND SUPPLEMENTAL PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN RESPONSE TO NEW YORKS SUPPLEMENTAL PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON CONTENTION NYS-16B Office of the Attorney General for the State of New York The Capitol State Street Albany, New York 12224

INTRODUCTION Pursuant to 10 C.F.R. § 2.323(2)(c), the State of New York responds to Entergys request for leave to file supplemental Proposed Findings of Fact and Conclusions of Law (Proposed Findings) in response to the States supplemental Proposed Findings for Consolidated Contention NYS-16B, and to enter the entirety of NL-13-075, License Renewal Application-Completed Engineering Project Cost Estimates for SAMAs Previously Identified as Potentially Cost-Beneficial (May 6, 2013) (ML13127A459) (NL-13-075) as an exhibit instead of the excerpted table proffered by the State. Entergys Answer Opposing State of New York Motion Seeking Leave to File an Additional Exhibit and Supplemental Findings of Fact and Conclusions of Law (May 28, 2013) (Entergy Oppn) at 1, 5, n.21 (ML13148A498).1 Todays answer by the State is timely was filed 9 days after Entergys submission.

While the State does not object to Entergy responding to the States Proposed Findings, the State does object to Entergys request that the entirety of NL-13-075 be admitted as an exhibit. 2 As explained in more detail below, only the excerpted tablecontaining Entergys revised cost-benefit conclusionsis relevant to NYS-16B. This table has been offered as an exhibit for the sole purpose of rebutting Entergys and Staffs argument that including commuters and undercounted minority residents in the population estimate will not have a material impact on the Severe Accident Mitigation Alternatives (SAMA) analysis. The remainder of NL-13-075which contains Entergys decision to implement some cost-beneficial 1

Instead of filing a separate motion for leave, Entergy requested leave to file responsive findings in its answer to the States motion. Entergys proposed supplemental findings are attached to its answer.

2 During consultation for the States motion, the parties discussed the States proposal to submit an excerpt of NL-13-075 containing Table 1 as an exhibit, but Entergy did not indicate that it would seek to have the entirety of NL-13-075 entered as an exhibit.

1

SAMA candidates and defer consideration of othersmay be relevant to NRC Staffs efforts to remedy the deficiencies in the Final Supplemental Environmental Impact Statement (FSEIS) set forth by the Board in its July 14, 2011 summary disposition of NYS-35/36, but it is not relevant to the issues raised in NYS-16Bi.e., whether commuters and undercounted minority residents should be included in the population estimate for Indian Point. Additionally, now that Entergy has submitted responsive findings, the State reiterates its request to submit brief reply findings.3 ARGUMENT The State does not object to Entergys request to submit supplemental Proposed Findings.

The State does, however, object to Entergys request that the entirety of NL-13-075 be admitted as an exhibit. Aside from the excerpted table submitted by the State (NYS000476), NL-13-075 is not relevant to NYS-16B. The relevant portion of NL-13-075 is the revised SAMA cost-benefit table reclassifying previously cost-beneficial SAMA candidates as no longer cost-beneficial. NL-13-075, attach. 1 at 4-5. Upon reviewing the costs and benefits reported in this table, the State determined that two SAMA candidates Entergy wishes to reclassify as not cost-beneficial would still be cost-beneficial if the increases in population set forth in NYS-16B were taken into account. This evidence directly rebuts Entergys argument that the population errors identified in NYS-16B will not have a material impact on the SAMA analysis. The excerpt was submitted by the State solely for this purpose.

3 NRC Staff requested an opportunity to submit responsive findings, but did not attach any proposed findings to its answer to the States motion. NRC Staffs Opposition to State of New York Motion Seeking Leave to File an Additional Exhibit and Supplemental Proposed Findings of Fact and Conclusions of Law on Contention NYS-16B at 1 n.2 (May 23, 2013)

(ML13134A354). The State respectfully requests that it be permitted to file a single reply to both the Entergy and Staff supplemental Proposed Findings after Staff tenders its supplemental Proposed Findings.

2

The remainder of NL-13-075, however, has no bearing on NYS-16B. Although it is generally inappropriate to communicate matters of substance to the Board via letter or e-mail,4 Entergy informed the Atomic Safety and Licensing Board via letter that it submitted this information [in NL-13-075] to the NRC to support resolution of certain issues identified by the Board in its July 14, 2011 decision granting New York States motion for summary disposition of Consolidated Contention NYS-35/36. Entergy Letter to ASLB, Re: Notification of Entergys Submission of the Results of Completed Engineering Project Cost Estimates for SAMAs Previously Identified as Potentially Cost-Beneficial (May 7, 2013) (ML13127A458).

The majority of the document explains Entergys decision to implement some cost-beneficial SAMA candidates and its decision to defer consideration of other cost-beneficial SAMA candidates. For example, in NL-13-075 Entergy discloses for the first time that it has implemented a SAMA candidate at Indian Point Unit 3, and plans to implement three more SAMA candidates (two at Unit 3 and one at Unit 2) by August 31, 2014. Putting aside the fact that NL-13-075 fails to explain why Entergy chose to implement any SAMA candidates at all and why it chose to implement these four as compared to the other cost-beneficial candidates, providing a rational basis for the implementation of SAMA candidates is not the subject of NYS-16B.

Entergys only justification for seeking admission of the entire NL-13-075 document is that it will provide appropriate factual and legal context. Entergy Oppn at 5, n.21. But the 4

The record should not be cluttered with such casual for your information letters. Entergy Nuclear Vermont Yankee L.L.C. and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), Order Striking New England Coalitions Letter to the Board at 1-2 (May 12, 2005). Instead, matters of substance should be communicated to the Board in formal filings, with the caption of the case, signature of counsel, and affidavits to support any factual statements. Id; see also 10 C.F.R. § 2.323(2)(b) (a motion must state with particularity the grounds and the relief sought).

3

States supplemental Proposed Findings and Entergys responsive Proposed Findings already provide that context. See State supplemental Proposed Findings at 2-5, ¶¶207-214; Entergy supplemental Proposed Findings at 4, ¶6. As NL-13-075 does not mention NYS-16B, and only Table 1 of that document is relevant to Entergys and Staffs materiality defense for NYS-16B, admitting the entire document will not provide the necessary context.

Moreover, entering the entirety of NL-13-075 as an exhibit to NYS-16B would also be inappropriate because it represents an attempt by Entergy to circumvent the proper process for remedying the National Environmental Policy Act (NEPA) deficiencies outlined in the Boards summary disposition order on NYS-35/36. In granting summary disposition to the State, the Board found that the NRC Staffs decision to allow Entergy to complete its SAMA review outside of the license renewal process, by deferring the evaluation of SAMAs found to be potentially cost-beneficial until after relicensing, does not provide an adequate record for the agency to make its decision on the impacts of relicensing IP2 and IP3. Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), (Ruling on Motion and Cross-Motions for Summary Disposition of NYS-35/36), LBP-11-17, 74 N.R.C. 11, 16-17 (Jul. 14, 2011), interlocutory review denied, CLI-11-14, __ N.R.C. ___ (Dec. 22, 2011). Thus, at present NRC Staffs FSEIS for the proposed license renewal of Indian Point Unit 2 and Unit 3 has been found to be insufficient and it cannot now provide the basis to issue a renewed operating license for Indian Point Unit 2 or Indian Point Unit 3 under the NEPA. While NL-13-075 highlights the fact that the SAMA analysis is incomplete, the only way to remedy the deficiencies in NYS-35/36 is for NRC Staff to follow the Boards order:

[U]nder NRC Regulations, the APA, and NEPA, Entergys licenses cannot be renewed unless and until the NRC Staff reviews Entergys completed SAMA analyses and either incorporates the result of these reviews into the FSEIS or, in the alternative, modifies its FSEIS to provide a valid reason for recommending the 4

renewal of the licenses before the analysis of potentially cost effective SAMAs is complete and for not requiring the implementation of cost-beneficial SAMAs.

Id. at 17.

As such, NL-13-075 should not be entered in its entirety as an exhibit for NYS-16B. The Board should admit only the excerpt of Table 1 (NYS000476), for the sole purpose of rebutting Entergys and NRC Staffs materiality defense in NYS-16B.

CONCLUSION For the foregoing reasons, New York State opposes Entergys request that the Board admit NL-13-075 in its entirety. Additionally, now that Entergy has submitted responsive Proposed Findings, the State reiterates its request to submit brief reply Proposed Findings. For the sake of efficiency, the State respectfully requests that it be permitted to file combined Proposed Findings, replying to both Entergy and NRC Staff, 10 days after the date of Staffs filing of responsive findings.

Respectfully submitted, Signed (electronically) by Signed (electronically) by Laura E. Heslin John J. Sipos Kathryn M. Liberatore Assistant Attorney General Assistant Attorneys General Office of the Attorney General Office of the Attorney General for the State of New York for the State of New York The Capitol 120 Broadway Albany, New York 12224 New York, New York 10271 (518) 402-2251 (212) 416-6091 (212) 416-8482 June 6, 2013 5

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

x In re: Docket Nos. 50-247-LR and 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 6, 2013

x CERTIFICATE OF SERVICE I hereby certify that on June 6, 2013, copies of the accompanying State of New York Answer to Entergys Request to File and Additional Exhibit Concerning Contention NYS-16B were served electronically via the Electronic Information Exchange on the following recipients:

Lawrence G. McDade, Chair Shelbie Lewman, Esq., Law Clerk Richard E. Wardwell, Administrative Judge Carter Thurman, Esq., Law Clerk Michael F. Kennedy, Administrative Judge James Maltese, Esq., Law Clerk Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Mailstop 3 F23 Mailstop 3 F23 Two White Flint North Two White Flint North 11545 Rockville Pike 11545 Rockville Pike Rockville, MD 20852-2738 Rockville, MD 20852-2738 Lawrence.McDade@nrc.gov Shelbie.Lewman@nrc.gov Richard.Wardwell@nrc.gov Carter.Thurman@nrc.gov Michael.Kennedy@nrc.gov James.Maltese@nrc.gov Atomic Safety and Licensing Board Panel Office of Commission Appellate U.S. Nuclear Regulatory Commission Adjudication Mailstop 3 F23 U.S. Nuclear Regulatory Commission Two White Flint North Mailstop 16 G4 11545 Rockville Pike One White Flint North Rockville, MD 20852-2738 11555 Rockville Pike Rockville, MD 20852-2738 ocaamail@nrc.gov 1

Office of the Secretary Bobby R. Burchfield, Esq.

Attn: Rulemaking and Adjudications Staff Matthew M. Leland, Esq.

U.S. Nuclear Regulatory Commission Clint A. Carpenter, Esq.

Mailstop 3 F23 McDermott Will & Emery LLC Two White Flint North 600 13th Street, NW 11545 Rockville Pike Washington, DC 20005-3096 Rockville, MD 20852-2738 bburchfield@mwe.com hearingdocket@nrc.gov mleland@mwe.com ccarpenter@mwe.com Sherwin E. Turk, Esq.

David E. Roth, Esq. Richard A. Meserve, Esq.

Beth N. Mizuno, Esq. Matthew W. Swinehart, Esq.

Brian G. Harris, Esq. Covington & Burling LLP Anita Ghosh, Esq. 1201 Pennsylvania Avenue, NW Joseph A. Lindell, Esq. Washington, DC 20004-2401 Office of the General Counsel rmeserve@cov.com U.S. Nuclear Regulatory Commission mswinegart@cov.com Mailstop 15 D21 One White Flint North Elise N. Zoli, Esq.

11555 Rockville Pike Goodwin Procter, LLP Rockville, MD 20852-2738 Exchange Place sherwin.turk@nrc.gov 53 State Street david.roth@nrc.gov Boston, MA 02109 beth.mizuno@nrc.gov ezoli@goodwinprocter.com brian.harris@nrc.gov anita.ghosh@nrc.gov William C. Dennis, Esq.

Joseph.Lindell@nrc.gov Assistant General Counsel Entergy Nuclear Operations, Inc.

Kathryn M. Sutton, Esq. 440 Hamilton Avenue Paul M. Bessette, Esq. White Plains, NY 10601 Jonathan Rund, Esq. wdennis@entergy.com Raphael Kuyler, Esq.

Morgan, Lewis & Bockius LLP Robert D. Snook, Esq.

1111 Pennsylvania Avenue, NW Assistant Attorney General Washington, DC 20004 Office of the Attorney General ksutton@morganlewis.com State of Connecticut pbessette@morganlewis.com 55 Elm Street jrund@morganlewis.com P.O. Box 120 rkuyler@morganlewis.com Hartford, CT 06141-0120 robert.snook@ct.gov Martin J. ONeill, Esq.

Morgan, Lewis & Bockius LLP Suite 4000 1000 Louisiana Street Houston, TX 77002 martin.oneill@morganlewis.com 2

Melissa-Jean Rotini, Esq. Karla Raimundi, Assistant County Attorney Environmental Justice Associate Office of the Westchester County Attorney Hudson River Sloop Clearwater, Inc.

Michaelian Office Building 724 Wolcott Avenue 148 Martine Avenue, 6th Floor Beacon, NY 12508 White Plains, NY 10601 karla@clearwater.org MJR1@westchestergov.com Richard Webster, Esq.

Sean Murray, Mayor Public Justice, P.C.

Kevin Hay, Village Administrator Suite 200 Village of Buchanan 1825 K Street, NW Municipal Building Washington, DC 20006 236 Tate Avenue rwebster@publicjustice.net Buchanan, NY 10511-1298 Administer@villageofbuchanan.com Phillip Musegaas, Esq.

Deborah Brancato, Esq.

Daniel Riesel, Esq. Riverkeeper, Inc.

Thomas F. Wood, Esq. 20 Secor Road Victoria S. Treanor, Esq. Ossining, NY 10562 Sive, Paget & Riesel, P.C. phillip@riverkeeper.org 460 Park Avenue dbrancato@riverkeeper.org New York, NY 10022 driesel@sprlaw.com vtreanor@sprlaw.com Michael J. Delaney, Esq.

Director Energy Regulatory Affairs NYC Department of Environmental Protection 59-17 Junction Boulevard Flushing, NY 11373 mdelaney@dep.nyc.gov Signed (electronically) by

____________________________________

Kathryn M. Liberatore Assistant Attorney General State of New York (212) 416-8482 Dated at New York, New York this 6th day of June 2013 3

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