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{{#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. November 9, 2012
------------------
---------------
---------------
-----------x
PARTIALLY UNOPPOSED MOTION BY STATE OF NEW YORK FOR LEAVE TO FILE  ADDITIONAL EXHIBITS CONCERNING  CONTENTIONS NYS-37 AND NYS-5
Office of the Attorney General for the State of New York
The Capitol
State Street
Albany, New York 12224 INTRODUCTION In accordance with 10 C.F.R. § 2.323(a) and the Atomic Safety and Licensing Board's  direction during the September 24, 2012 prehearing teleconferen ce, the State of New York requests leave to file four additional New York Exhibits, NYS000447, NYS00448A/B, NYS000449, and NYS000450.
Good cause exists for allowing late-filing of these exhibits. Two of these exhibits, NYS000447 and NYS000448, were created immediately before the October 24 hearing date for Contention NYS-37, are relevant to the issues addressed in that hearing, and may be discussed during the upcoming special session in Rockville, Maryland and the testimony of New York State witness Peter Bradford.
1  The third exhibit, NYS000449, was created on October 31, 2012, and relates to Contention NYS-5, which the Board will take up on December 10. Likewise, the fourth exhibit, NYS000450, was submitted by Entergy to NRC on October 18, 2012 and may also relate to Contention NYS-5. The admission of these exhib its is necessary to develop a full hearing record and will not cause delay or harm to any party. The State has disclosed the first two documents to the parties and Staff has disclosed the second two documents to the State. The State of New York has consulted with Entergy, NRC Staff, Riverkeeper, and Clearwater pursuant to 10 C.F.R. § 2.323(b), and none of the parties oppose this motion with respect to NYS00448A/B, NYS000449, and NYS000450. Entergy opposes the admission of NYS000447. 
1 The parties have consulted about the date for this hearing in Rockville, Maryland, and have proposed a date to the Board.
See November 6, 2012 email to ASLB from AAG Sipos.
2ARGUMENT GOOD CAUSE EXISTS FOR ALLOWI NG THE STATE TO FILE THE ADDITIONAL EXHIBITS It is of the utmost importance that the Board has a full record of all material and relevant evidence when rendering its relicensing decision.
See Pacific Gas & Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 & 2), ALAB-580, 11 N.R.C. 227, 230 (Atomic Licensing Appeal Board 1980) ("No conceivable good is served by making empty findings in the absence of essential evidence."). To that end, the Board has indicated that parties may proffer newly-created, relevant documents id entified as new exhibits. See Teleconference Tr. at 1220, 1245-46 (Sept. 24, 2012). The four documents the State seeks to introduce are:  The Synapse Report: On October 11, 2012 Synapse Energy Economics, Inc. released the a report, detaili ng the capacity for generating power in the absence of Indian Point Un it 2 and Indian Point Unit 3.
Indian Point Replacement Analysis: A Clean Energy Roadmap, A Proposal for Replacing the Nuclear Plant with Clean, Sustainable Energy Resources , T. Woolf, M. Whited, T. Vitolo, K. Takahashi, D. White, October 11, 2012. The Board, on October 24, 2012, marked this document as Board Exhibit 6. New York State requests the Board admit the Synapse Report as NYS000447. Energy Highway Task Force Report: On October 22, 2012, the New York Energy Highway Task Force released a "Blueprint" describing power generation and transmission opportun ities throughout the State.
New York Energy Highway Blueprint , New York Energy Highway Task Force, October 22, 2012. The Board, on October 24, 2012, marked that document as Board Exhibit 7. New York State requests the Board admit the report as NYS00448 A/B. October 31 NRC Phone Conference Summary: On October 31, 2012, the Nuclear Regulatory Commission released a summary of a telephone conference from October 11, 2012.
Summary of Telephone Conference Call Held on October 11, 2012 Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operati ons, Inc., Concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, U.S. NRC, 10/31/2012, Adams Accession Number ML12289A880. The summary states that the call discussed recently-identified piping at the Indian Point facilities. New York State requests the Board admit the summary as NYS000449.
3 NL-12-149: On October 18, 2012, Entergy submitted communication NL-12-149 to the NRC as a result of the October 11, 2012 phone conference and set out new proposals concerning the recently-identified piping at the Indian Point facilities. New York State requests the Board admit the
summary as NYS000450. The State disclosed these documents to Entergy, NRC Staff, the State, and the other parties. These documents are relevant to recent and upcoming Evidentiary Hearings, and none of the documents-dated October 11, 2012, Oct ober 22, 2012, October 31, 2012, and October 18, 2012 respectively-were previously available to the State for incl usion in the State's June 29, 2012 rebuttal submissions. Two documents relate to Contention NY-37 and the present-and future-ability to supply electric generation capacity. The Synapse Report analyzes the capacity
for generating power in the abse nce of Indian Point Unit 2 or Indian Point Unit 3. The Energy Highway Task Force Blueprint details options to develop and update power generation and transmission throughout the State.
The issues addressed in these documents were already hearing topics, and will continue to be hearing topics during the special session at which NY State witness Peter Bradford will appear. The latter two documents relate to Contention NYS-5 and the management of piping. NRC's conference-call summary discusses recently-identified piping at Indian Point. Entergy's NL-12-149 communica tion discusses also Indian Point piping. The issues addressed in those document could well be discussed during the December hearing dates
for Contention NYS-5. The introdu ction of these exhibits will not expand the scope of the hearing, but rather provide necessary information to ensure that the Board's ultimate decision on relicensing is based on a complete record. Furthermore, the State has disclosed these documents to the parties. During the consultation process for this motion, Entergy opposed the admission of the Synapse Report at this time. Entergy's opposition is based on statements by the AAGs Dean and 4Sipos that they neither commissi oned the report nor knew of its pr eparation. Entergy also stated that no witness has yet expressly referred to the Synapse Report. The State submits that Entergy's position does not withst and scrutiny: it proves too little and too much. Suffice to say, in the past few months, several documents that relate to admitted contentions have come into existence that the State representatives (and repres entatives of other parties, including Entergy) did not commission or have advance knowledge of and the Board has seen fit to admit those documents as exhibits following motions by various parties. As to Entergy's argument that no witness has yet testified about the Synapse Report, the State submits that witnesses should be able to discuss the report at the upcoming session in Rockville. CONCLUSION  For the above reasons, the State respectfully requests that the Boar d grant the State of New York leave to file NYS000447 to NYS000450 as additional exhibits. The four documents, with exhibit markers, accompany this filing. The State also proposes to file a single updated Exhibit List following its submission of reply papers in support of Joint Contention NYS-38/RK-TC-5.
Respectfully submitted,
Signed (electronically) by Signed (electronically) by 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 Adam P. Solomon (New York Bar Membership Pending) Office of the Attorney General for the State of New York The Capitol Albany, New York  12224 (518) 474-1978 Dated: November 9, 2012 5 Certificate Pursuant to 10 C.F.R. § 2.323  In accordance with the Board's Scheduling Order of July 1, 2010 (at 8-9) and 10 C.F.R. 
§ 2.323(b), the undersigned counsel hereby certifies that counsel for the State of New York has made a sincere effort to contact other parties in the proceeding and resolve the issues raised in the motion. The State of New York's efforts to re solve the issues with the other parties has been successful, and none of the parties oppose the State's motion, with the exception, as noted in the accompanying motion, that Entergy opposes the admission of NYS000447.
Signed (electronically) by John J. Sipos Assistant Attorney General Office of the Attorney General  for the State of New York The Capitol Albany, New York  12227 (518) 402-2251 November 9, 2012
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. November 9, 2012
------------------
---------------
---------------
-----------x CERTIFICATE OF SERVICE  I hereby certify that on November 9, 2012, copies of the Unopposed Motion by State of New York Motion For Leave to File Additional Exhibits; Exhibits NYS000447 - NYS000450; were served electronically via the Electronic Information 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 Anne Siarnacki, 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
Anne.Siarnacki@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
2 Office 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
Richard A. Meserve, Esq.
Covington & Burling LLP 1201 Pennsylvania Avenue, NW
Washington, DC 20004-2401 rmeserve@cov.com
Elise N. Zoli, Esq.
Goodwin Procter, LLP
Exchange Place
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
Melissa-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 Daniel E. O'Neill, Mayor James Seirmarco, M.S.
3Village of Buchanan Municipal Building
236 Tate Avenue
Buchanan, NY 10511-1298
vob@bestweb.net
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
(718) 595-3982
mdelaney@dep.nyc.gov
Dated at Albany, New York this 9th day of November, 2012Karla Raimundi, Envt'l Justice Associate Hudson River Sloop Clearwater, Inc.
724 Wolcott Avenue
Beacon, NY 12508 Mannajo@clearwater.org
karla@clearwater.org stephenfiller@gmail.com
Richard Webster, Esq.
Public Justice, P.C.
Suite 200 1825 K Street, NW
Washington, DC 20006 rwebster@publicjustice.net
Phillip Musegaas, Esq.
Deborah Brancato, Esq.
Riverkeeper, Inc.
20 Secor Road
Ossining, NY 10562
phillip@riverkeeper.org dbrancato@riverkeeper.org
Signed (electronically) by
____________________________________ Adam P. Solomon
State of New York
(518) 474-1978}}

Revision as of 20:40, 1 August 2018

Partially Unopposed Motion by State of New York for Leave to File Additional Exhibits Concerning Contentions NYS-37 and NYS-5
ML12314A302
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 11/09/2012
From: Sipos J J, Solomon A P
State of NY, Office of the Attorney General
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NYS-37, NYS-38/RK-TC-5, NYS-5, RAS 23731
Download: ML12314A302 (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. November 9, 2012

x

PARTIALLY UNOPPOSED MOTION BY STATE OF NEW YORK FOR LEAVE TO FILE ADDITIONAL EXHIBITS CONCERNING CONTENTIONS NYS-37 AND NYS-5

Office of the Attorney General for the State of New York

The Capitol

State Street

Albany, New York 12224 INTRODUCTION In accordance with 10 C.F.R. § 2.323(a) and the Atomic Safety and Licensing Board's direction during the September 24, 2012 prehearing teleconferen ce, the State of New York requests leave to file four additional New York Exhibits, NYS000447, NYS00448A/B, NYS000449, and NYS000450.

Good cause exists for allowing late-filing of these exhibits. Two of these exhibits, NYS000447 and NYS000448, were created immediately before the October 24 hearing date for Contention NYS-37, are relevant to the issues addressed in that hearing, and may be discussed during the upcoming special session in Rockville, Maryland and the testimony of New York State witness Peter Bradford.

1 The third exhibit, NYS000449, was created on October 31, 2012, and relates to Contention NYS-5, which the Board will take up on December 10. Likewise, the fourth exhibit, NYS000450, was submitted by Entergy to NRC on October 18, 2012 and may also relate to Contention NYS-5. The admission of these exhib its is necessary to develop a full hearing record and will not cause delay or harm to any party. The State has disclosed the first two documents to the parties and Staff has disclosed the second two documents to the State. The State of New York has consulted with Entergy, NRC Staff, Riverkeeper, and Clearwater pursuant to 10 C.F.R. § 2.323(b), and none of the parties oppose this motion with respect to NYS00448A/B, NYS000449, and NYS000450. Entergy opposes the admission of NYS000447.

1 The parties have consulted about the date for this hearing in Rockville, Maryland, and have proposed a date to the Board.

See November 6, 2012 email to ASLB from AAG Sipos.

2ARGUMENT GOOD CAUSE EXISTS FOR ALLOWI NG THE STATE TO FILE THE ADDITIONAL EXHIBITS It is of the utmost importance that the Board has a full record of all material and relevant evidence when rendering its relicensing decision.

See Pacific Gas & Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 & 2), ALAB-580, 11 N.R.C. 227, 230 (Atomic Licensing Appeal Board 1980) ("No conceivable good is served by making empty findings in the absence of essential evidence."). To that end, the Board has indicated that parties may proffer newly-created, relevant documents id entified as new exhibits. See Teleconference Tr. at 1220, 1245-46 (Sept. 24, 2012). The four documents the State seeks to introduce are: The Synapse Report: On October 11, 2012 Synapse Energy Economics, Inc. released the a report, detaili ng the capacity for generating power in the absence of Indian Point Un it 2 and Indian Point Unit 3.

Indian Point Replacement Analysis: A Clean Energy Roadmap, A Proposal for Replacing the Nuclear Plant with Clean, Sustainable Energy Resources , T. Woolf, M. Whited, T. Vitolo, K. Takahashi, D. White, October 11, 2012. The Board, on October 24, 2012, marked this document as Board Exhibit 6. New York State requests the Board admit the Synapse Report as NYS000447. Energy Highway Task Force Report: On October 22, 2012, the New York Energy Highway Task Force released a "Blueprint" describing power generation and transmission opportun ities throughout the State.

New York Energy Highway Blueprint , New York Energy Highway Task Force, October 22, 2012. The Board, on October 24, 2012, marked that document as Board Exhibit 7. New York State requests the Board admit the report as NYS00448 A/B. October 31 NRC Phone Conference Summary: On October 31, 2012, the Nuclear Regulatory Commission released a summary of a telephone conference from October 11, 2012.

Summary of Telephone Conference Call Held on October 11, 2012 Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operati ons, Inc., Concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, U.S. NRC, 10/31/2012, Adams Accession Number ML12289A880. The summary states that the call discussed recently-identified piping at the Indian Point facilities. New York State requests the Board admit the summary as NYS000449.

3 NL-12-149: On October 18, 2012, Entergy submitted communication NL-12-149 to the NRC as a result of the October 11, 2012 phone conference and set out new proposals concerning the recently-identified piping at the Indian Point facilities. New York State requests the Board admit the

summary as NYS000450. The State disclosed these documents to Entergy, NRC Staff, the State, and the other parties. These documents are relevant to recent and upcoming Evidentiary Hearings, and none of the documents-dated October 11, 2012, Oct ober 22, 2012, October 31, 2012, and October 18, 2012 respectively-were previously available to the State for incl usion in the State's June 29, 2012 rebuttal submissions. Two documents relate to Contention NY-37 and the present-and future-ability to supply electric generation capacity. The Synapse Report analyzes the capacity

for generating power in the abse nce of Indian Point Unit 2 or Indian Point Unit 3. The Energy Highway Task Force Blueprint details options to develop and update power generation and transmission throughout the State.

The issues addressed in these documents were already hearing topics, and will continue to be hearing topics during the special session at which NY State witness Peter Bradford will appear. The latter two documents relate to Contention NYS-5 and the management of piping. NRC's conference-call summary discusses recently-identified piping at Indian Point. Entergy's NL-12-149 communica tion discusses also Indian Point piping. The issues addressed in those document could well be discussed during the December hearing dates

for Contention NYS-5. The introdu ction of these exhibits will not expand the scope of the hearing, but rather provide necessary information to ensure that the Board's ultimate decision on relicensing is based on a complete record. Furthermore, the State has disclosed these documents to the parties. During the consultation process for this motion, Entergy opposed the admission of the Synapse Report at this time. Entergy's opposition is based on statements by the AAGs Dean and 4Sipos that they neither commissi oned the report nor knew of its pr eparation. Entergy also stated that no witness has yet expressly referred to the Synapse Report. The State submits that Entergy's position does not withst and scrutiny: it proves too little and too much. Suffice to say, in the past few months, several documents that relate to admitted contentions have come into existence that the State representatives (and repres entatives of other parties, including Entergy) did not commission or have advance knowledge of and the Board has seen fit to admit those documents as exhibits following motions by various parties. As to Entergy's argument that no witness has yet testified about the Synapse Report, the State submits that witnesses should be able to discuss the report at the upcoming session in Rockville. CONCLUSION For the above reasons, the State respectfully requests that the Boar d grant the State of New York leave to file NYS000447 to NYS000450 as additional exhibits. The four documents, with exhibit markers, accompany this filing. The State also proposes to file a single updated Exhibit List following its submission of reply papers in support of Joint Contention NYS-38/RK-TC-5.

Respectfully submitted,

Signed (electronically) by Signed (electronically) by 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 Adam P. Solomon (New York Bar Membership Pending) Office of the Attorney General for the State of New York The Capitol Albany, New York 12224 (518) 474-1978 Dated: November 9, 2012 5 Certificate Pursuant to 10 C.F.R. § 2.323 In accordance with the Board's Scheduling Order of July 1, 2010 (at 8-9) and 10 C.F.R.

§ 2.323(b), the undersigned counsel hereby certifies that counsel for the State of New York has made a sincere effort to contact other parties in the proceeding and resolve the issues raised in the motion. The State of New York's efforts to re solve the issues with the other parties has been successful, and none of the parties oppose the State's motion, with the exception, as noted in the accompanying motion, that Entergy opposes the admission of NYS000447.

Signed (electronically) by John J. Sipos Assistant Attorney General Office of the Attorney General for the State of New York The Capitol Albany, New York 12227 (518) 402-2251 November 9, 2012

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. November 9, 2012

x CERTIFICATE OF SERVICE I hereby certify that on November 9, 2012, copies of the Unopposed Motion by State of New York Motion For Leave to File Additional Exhibits; Exhibits NYS000447 - NYS000450; were served electronically via the Electronic Information 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 Anne Siarnacki, 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

Anne.Siarnacki@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

2 Office 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

Richard A. Meserve, Esq.

Covington & Burling LLP 1201 Pennsylvania Avenue, NW

Washington, DC 20004-2401 rmeserve@cov.com

Elise N. Zoli, Esq.

Goodwin Procter, LLP

Exchange Place

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

Melissa-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 Daniel E. O'Neill, Mayor James Seirmarco, M.S.

3Village of Buchanan Municipal Building

236 Tate Avenue

Buchanan, NY 10511-1298

vob@bestweb.net

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

(718) 595-3982

mdelaney@dep.nyc.gov

Dated at Albany, New York this 9th day of November, 2012Karla Raimundi, Envt'l Justice Associate Hudson River Sloop Clearwater, Inc.

724 Wolcott Avenue

Beacon, NY 12508 Mannajo@clearwater.org

karla@clearwater.org stephenfiller@gmail.com

Richard Webster, Esq.

Public Justice, P.C.

Suite 200 1825 K Street, NW

Washington, DC 20006 rwebster@publicjustice.net

Phillip Musegaas, Esq.

Deborah Brancato, Esq.

Riverkeeper, Inc.

20 Secor Road

Ossining, NY 10562

phillip@riverkeeper.org dbrancato@riverkeeper.org

Signed (electronically) by

____________________________________ Adam P. Solomon

State of New York

(518) 474-1978

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