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| issue date = 12/14/2011
| issue date = 12/14/2011
| title = Declaration of Susan C. Von Reusner
| title = Declaration of Susan C. Von Reusner
| author name = VonResusner S C
| author name = Vonresusner S
| author affiliation = State of NY, Office of the Attorney General
| author affiliation = State of NY, Office of the Attorney General
| addressee name =  
| addressee name =  
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=Text=
=Text=
{{#Wiki_filter: UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD  
{{#Wiki_filter: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.                             December 13, 2011
------------x In re:           Docket Nos. 50-247-LR; 50-286-LR  
------------------------------------------------------------x DECLARATION OF SUSAN C. VON REUSNER Pursuant to 28 U.S.C. § 1746, Susan C. von Reusner 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 contention, NYS 33-37 (hereinafter NYS-37) which asserts that the FSEISs analysis of replacement power is deficient under the National Environmental Policy Act (NEPA), Council of Environmental Quality (CEQ) regulations, and NRCs relicensing regulations.
License Renewal Application Submitted by     ASLBP No. 07-858-03-LR-BD01
: 2.       The accompanying exhibits are discussed in more detail in the States Statement of Position, or were previously submitted as supporting evidence for the States contention.
 
: 3.       Attached to this declaration as Exh. NYS000125 is a true and correct copy of the publicly available document entitled Proposed Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Review for Renewal of Operating Licenses - Part 51, 56 Fed. Reg. 47,016 (September 17, 1991) (56 Fed. Reg. 47,016).
Entergy Nuclear Indian Point 2, LLC,     DPR-26, DPR-64 Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc.       December 13, 2011  
: 4.       Attached to this declaration as Exh. NYS000126 is a true and correct copy of the publicly available document entitled NUREG-1440, Regulatory Analysis of Proposed Amendments to Regulations Concerning the Environmental Review for Renewal of Nuclear Power Plant Operating Licenses: Draft Report for Comment (August 1991) (1991 NUREG-1440 Draft for Comment).
------------------------------------------------
: 5.     Attached to this declaration as Exh. NYS000127 is a true and correct copy of the publicly available document entitled Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, 61 Fed. Reg. 28,467 (June 5, 1996) (61 Fed. Reg. 28,467).
------------x DECLARATION OF SUSAN C. VON REUSNER Pursuant to 28 U.S.C. § 1746, Susan C. von Reusner hereby declares as follows:  
: 6.     Attached to this declaration as Exh. NYS000128 is a true and correct copy of the publicly available document entitled Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, 61 Fed. Reg. 66,537 (December 18, 1996) (61 Fed. Reg. 66,537).
: 1. I serve as an Assistant A ttorney 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 York's consolidated contention, NYS 33-37 (hereinafter "NYS-37) which asserts that the FSEIS's analysis of replacement power is deficient under the National Environmental Policy Act ("NEPA"), Council of Environmental Quality ("CEQ") regulations, and NRC's relicensing regulations.  
: 7.     Attached to this declaration as Exh. NYS000129 is a true and correct copy of the publicly available document entitled National Renewable Energy Laboratory, Land-Use Requirements of Modern Wind Power Plants in the United States, by Paul Denholm, Maureen Hand, Maddalena Jackson, and Sean Ong dated August 2009.
: 2. The accompanying exhibits are discussed in more detail in the State's Statement of Position, or were previously submitted as supporting evidence for the State's contention.  
: 8.     Attached to this declaration as Exh. NYS000130 is a true and correct copy of the publicly available document entitled Proposed Rules Nuclear Regulatory Commission 10 CFR Part 52 Nuclear Energy Institute; Denial of Petition for Rulemaking, 68 Fed. Reg. 55,905 (September 29, 2003) (68 Fed. Reg. 55,905).
: 3. Attached to this declaration as Exh. NYS 000125 is a true and correct copy of the publicly available document entitled Proposed Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Revi ew for Renewal of Operating Licenses - Part 51, 56 Fed. Reg. 47,016 (September 17, 1991) ("56 Fed. Reg. 47,016").
: 9.     Attached to this declaration as Exh. NYS00131A through NYS00131I is a true and correct copy of the publicly available document entitled Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Main Report (NUREG-1437, Volume 1) (May 1996) (hereinafter GEIS).
: 4. Attached to this declaration as Exh. NYS 000126 is a true and correct copy of the publicly available document entitled NUREG-1440, Regulatory Analysis of Proposed Amendments to Regulations Concerning the Environmental Review for Renewal of Nuclear   Power Plant Operating Licenses: Draft Report for Comment (August 1991) ("1991 NUREG-1440 Draft for Comment").  
: 10. Attached to this declaration as Exh. NYS00132A through NYS000132D is a true and correct copy of the publicly available document entitled Draft Supplemental Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Indian Points Units 2 and 3,
: 5. Attached to this declaration as Exh. NYS 000127 is a true and correct copy of the publicly available document entitled Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Review for Renewa l of Nuclear Power Plant Operating Licenses , 61 Fed. Reg. 28,467 (June 5, 1996) ("61 Fed. Reg. 28,467").  
( NUREG-1437, Supplement 38, Vol. 1) dated December 2008 (DSEIS).
: 6. Attached to this declaration as Exh. NYS 000128 is a true and correct copy of the publicly available document entitled Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Review for Renewa l of Nuclear Power Plant Operating Licenses , 61 Fed. Reg. 66,537 (December 18, 1996) ("61 Fed. Reg. 66,537").  
: 11. Attached to this declaration as Exh. NYS00133A through NYS00133D is a true and correct copy of the publicly available document entitled Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 (NUREG-1437, Supplement 38, Vol. 1) published December 2010 ( FSEIS).
: 7. Attached to this declaration as Exh. NYS 000129 is a true and correct copy of the publicly available document entitled National Renewable Energy Laboratory, Land-Use Requirements of Modern Wind Power Plants in the United States, by Paul Denholm, Maureen Hand, Maddalena Jackson, and Sean Ong dated August 2009.  
: 12. Attached to this declaration as Exh. NYS000134 is a true and correct copy of the publicly available document entitled Comments Submitted by the New York State Office of the Attorney General on the Draft Supplemental Environmental Impact Statement Prepared by Staff on the Nuclear Regulatory Commission for the Renewal of the Operating Licenses for Indian Point Units 2 and 3, Buchanan, New York, submitted to the U.S. N.R.C. on March 18, 2009 (ML090771328) ( 2009 NYS AG Comments).
: 8. Attached to this declaration as Exh. NYS 000130 is a true and correct copy of the publicly available document entitled Proposed Rules Nuclear Regulatory Commission 10 CFR Part 52 Nuclear Energy Institute; Denial of Petition for Rulemaking , 68 Fed. Reg. 55,905 (September 29, 2003) ("68 Fed. Reg. 55,905").  
: 13. Attached to this declaration as Exh. NYS000101 is a true and correct copy of the publicly available judicial decision entitled Wilderness Society et al. U.S. Department of Energy, 2011 WL 294087, slip op. Feb. 1, 2011 (9th Cir. No. 08-71074).
: 9. Attached to this declaration as Exh. NYS00131A through NYS00131I is a true and correct copy of the publicly available document entitled Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Main Report (NUREG-1437, Volume 1) (May 1996) (hereinafter "GEIS").  
: 14. I declare under penalty of perjury that the foregoing is true and correct.
: 10. Attached to this declaration as Exh. NYS00132A through NYS000132D is a true and correct copy of the publicly available document entitled Draft Supplemental Environmental   Impact Statement for License Renewal of Nuclea r Plants Regarding Indian Points Units 2 and 3 , ( NUREG-1437, Supplement 38, Vol. 1) dated December 2008 ("DSEIS").  
Executed on December 13, 2011 Signed (electronically) by Susan C. von Reusner Assistant Attorneys General Office of the Attorney General of the State of New York The Capitol Albany, New York 12224 (518) 474-1968
: 11. Attached to this declaration as Exh. NYS00133A through NYS00133D is a true and correct copy of the publicly available document entitled Generic Environmental Impact Statement for License Renewal of Nuclear Pl ants: Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 (NUREG-1437, Supplement 38, Vol. 1) published December 2010 ( "FSEIS").  
                                                }}
: 12. Attached to this declaration as Exh. NYS 000134 is a true and correct copy of the publicly available document entitled Comments Submitted by the New York State Office of the Attorney General on the Draft Suppl emental Environmental Impact St atement Prepared by Staff on the Nuclear Regulatory Commission for the Re newal of the Operating Licenses for Indian Point Units 2 and 3, Buchanan, New York, submitted to the U.S. N.R.C. on March 18, 2009 (ML 090771328) ( "2009 NYS AG Comments").  
: 13. Attached to this declaration as Exh. NYS 000101 is a true and correct copy of the publicly available judicial decision entitled Wilderness Society et al. U.S. Department of Energy, 2011 WL 294087, slip op. Feb. 1, 2011 (9th Cir. No. 08-71074). 14. I declare under penalty of perjury that the foregoing is true and correct.
Executed on December 13, 2011 Signed (electronically) by
_______________________
 
Susan C. von Reusner Assistant Attorneys General Office of the Attorney General of the State of New York  
 
The Capitol  
 
Albany, New York 12224  
 
(518) 474-1968}}

Latest revision as of 20:38, 6 February 2020

Declaration of Susan C. Von Reusner
ML11348A156
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/14/2011
From: Vonresusner S
State of NY, Office of the Attorney General
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21536, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML11348A156 (3)
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. December 13, 2011

x DECLARATION OF SUSAN C. VON REUSNER Pursuant to 28 U.S.C. § 1746, Susan C. von Reusner 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 contention, NYS 33-37 (hereinafter NYS-37) which asserts that the FSEISs analysis of replacement power is deficient under the National Environmental Policy Act (NEPA), Council of Environmental Quality (CEQ) regulations, and NRCs relicensing regulations.
2. The accompanying exhibits are discussed in more detail in the States Statement of Position, or were previously submitted as supporting evidence for the States contention.
3. Attached to this declaration as Exh. NYS000125 is a true and correct copy of the publicly available document entitled Proposed Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Review for Renewal of Operating Licenses - Part 51, 56 Fed. Reg. 47,016 (September 17, 1991) (56 Fed. Reg. 47,016).
4. Attached to this declaration as Exh. NYS000126 is a true and correct copy of the publicly available document entitled NUREG-1440, Regulatory Analysis of Proposed Amendments to Regulations Concerning the Environmental Review for Renewal of Nuclear Power Plant Operating Licenses: Draft Report for Comment (August 1991) (1991 NUREG-1440 Draft for Comment).
5. Attached to this declaration as Exh. NYS000127 is a true and correct copy of the publicly available document entitled Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, 61 Fed. Reg. 28,467 (June 5, 1996) (61 Fed. Reg. 28,467).
6. Attached to this declaration as Exh. NYS000128 is a true and correct copy of the publicly available document entitled Rules And Regulations Nuclear Regulatory Commission 10 CFR Part 51 Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, 61 Fed. Reg. 66,537 (December 18, 1996) (61 Fed. Reg. 66,537).
7. Attached to this declaration as Exh. NYS000129 is a true and correct copy of the publicly available document entitled National Renewable Energy Laboratory, Land-Use Requirements of Modern Wind Power Plants in the United States, by Paul Denholm, Maureen Hand, Maddalena Jackson, and Sean Ong dated August 2009.
8. Attached to this declaration as Exh. NYS000130 is a true and correct copy of the publicly available document entitled Proposed Rules Nuclear Regulatory Commission 10 CFR Part 52 Nuclear Energy Institute; Denial of Petition for Rulemaking, 68 Fed. Reg. 55,905 (September 29, 2003) (68 Fed. Reg. 55,905).
9. Attached to this declaration as Exh. NYS00131A through NYS00131I is a true and correct copy of the publicly available document entitled Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Main Report (NUREG-1437, Volume 1) (May 1996) (hereinafter GEIS).
10. Attached to this declaration as Exh. NYS00132A through NYS000132D is a true and correct copy of the publicly available document entitled Draft Supplemental Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Indian Points Units 2 and 3,

( NUREG-1437, Supplement 38, Vol. 1) dated December 2008 (DSEIS).

11. Attached to this declaration as Exh. NYS00133A through NYS00133D is a true and correct copy of the publicly available document entitled Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 (NUREG-1437, Supplement 38, Vol. 1) published December 2010 ( FSEIS).
12. Attached to this declaration as Exh. NYS000134 is a true and correct copy of the publicly available document entitled Comments Submitted by the New York State Office of the Attorney General on the Draft Supplemental Environmental Impact Statement Prepared by Staff on the Nuclear Regulatory Commission for the Renewal of the Operating Licenses for Indian Point Units 2 and 3, Buchanan, New York, submitted to the U.S. N.R.C. on March 18, 2009 (ML090771328) ( 2009 NYS AG Comments).
13. Attached to this declaration as Exh. NYS000101 is a true and correct copy of the publicly available judicial decision entitled Wilderness Society et al. U.S. Department of Energy, 2011 WL 294087, slip op. Feb. 1, 2011 (9th Cir. No. 08-71074).
14. I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 13, 2011 Signed (electronically) by Susan C. von Reusner Assistant Attorneys General Office of the Attorney General of the State of New York The Capitol Albany, New York 12224 (518) 474-1968

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