ML12341A289: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
 
(Created page by program invented by StriderTol)
Line 15: Line 15:
| page count = 9
| page count = 9
}}
}}
=Text=
{{#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 6, 2012
------------------
---------------
---------------
-----------x
STATE OF NEW YORK MOTION FOR LEAVE TO FILE ADDITIONAL EXHIBITS CONCERNING CONTENTION NYS-8
Office of the Attorney General for the State of New York
The Capitol
State Street
Albany, New York 12224 1 INTRODUCTION In accordance with 10 C.F.R. § 2.323(a) and the Atomic Safety and Licensing Board's
("Board") direction during the September 24, 2012 prehearing teleconference, the State of New York requests leave to file four additi onal New York Exhibits, NYS000468 to NYS000471.
Good cause exists for allowing the State to file these additional exhibits because they came into existence very recently and are relevant to issues likely to be discussed at the upcoming evidentiary hearing next week in Tarrytown. Their admission is necessary to develop a full
hearing record and will not cause delay or harm to any party. The State has disclosed the documents to the parties. The State of New York has consulted with Entergy, NRC Staff, Riverkeeper, and Clearwater pursuant to 10 C.F.R.
§ 2.323(b). NRC Staff, Riverk eeper, and Clearwater do not oppose this motion. Entergy opposes the admission of the four additional New York Exhibits, NYS000468 to NYS000471, on the basis of relevance. ARGUMENT  GOOD CAUSE EXISTS FOR ALLO WING 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); accord Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3) Order Denying Clearwater's Motion to Supplement the Record, at 3 (Dec. 5, 22012) (finding that 10 C.F.R. § 2.337(a) is the applicable standard for the admission of new exhibits). The four documents the State seeks to introduce are:
NRC Bulletin 2012-01: Design Vulnerability in Electric Power System, July 27, 2012, ADAMS Accession Number ML12074A115. The State of New requests that the Board admit this document as NYS000468. Entergy Letter, NL-12-141, 90-Day Response to Bulletin 2012-01, "Design Vulnerability in Electric Power System,"[
i.e., the preceding document] Indian Point Units 2 & 3, Docket Nos. 50-247 and 50-286, License Nos. DPR-26 and DPR-64, October 25, 2012, ADAMS Accession Number ML12311A014 (posted on November 15, 2012). The State of New York requests that the Board admit this document as NYS000469. Entergy Preliminary Notification of Event or Unusual Occurrence - PNO-I-12-008, James A. Fitzpatrick Nuclear Power Plant Notification of Unusual Event Due to Fire in Main Transformer and Bus Ducting, November 13, 2012, ADAMS Accession Number ML12318A299 (posted on November 14, 2012). The State of New York requests that the Board admit this document as NYS000470. Entergy Preliminary Notification of Event or Unusual Occurrence - PNO-I-12-008A, UPDATE: James A. Fitzpatric k Nuclear Power Plant Notification of Unusual Event Due to Fire in Main Transformer, November 28, 2012, ADAMS Accession Number ML12333A307 (posted on November 28, 2012). The State of New York requests that the Board admit this document as NYS000471.
The State has disclosed these documents to Entergy, NRC Staff, and the other parties and participants.
1 These documents are relevant to the upcoming Evidentiary Hearing, and none of the documents-dated July 27, 2012, October 25, 2012, November 13, 2012, and November 28, 2012 respectively-were previously available to the State for incl usion in the State's June 29, 1 The State disclosed the first three documents to the parties on November 30, 2012 and the fourth document on December 5, 2012.
32012 rebuttal submissions. The documents relate to the issues raised in Contention NYS-8 and provide additional information about the parties' positions and submissions concerning transformers and aging management of transformers.
The NRC Bulletin 2012-01 (NYS000468) discusses a design vulnerability of the electric power system that can prevent the onsite and offsite electric power system-which includes transformers-from being able to perform its intended safety functions. The Bulletin requests that licensees provide information, such as transformer configurations, to assess this condition.
Entergy's recent response to NRC Bulletin 2012-01 (NYS000469) provides information about the structure of the electrical and transformer systems at the Indian Point facilities and indicates that Indian Point Unit 2 and Unit 3 have this design vulnerability, whic h affects the electric power systems' ability to detect an open phase fault condition. The two recent Preliminary Notification of Event or Unusual Occurrence documents (NYS000470 and NYS000471) describe a transformer fire that occurred on November 11, 2012, at the James A. Fitzpatrick Nuclear Power Plan t-a facility operated by Entergy and located in New York State. Entergy's initial investigation determined that the fire was caused by a problem in the "B" Phase winding of the T1-A main transformer.
The issues addressed in these documents could well be discussed during the December hearing dates for Contention NYS-8. The introduction 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.
4CONCLUSION  For the above reasons, the State respectfully requests that the Boar d grant the State of New York leave to file NYS000468 to NYS000 471 as additional exhibits. The four documents-with exhibit markers-accompany this filing.
Respectfully submitted, Signed (electronically) by Signed (electronically) by Laura E. Heslin Assistant Attorney General Office of the Attorney General for the State of New York 120 Broadway New York, New York 10271 (212) 416-6091 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 Dated: December 6, 2012 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 he reby certifies that counsel fo r 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 resolve the issues w ith Entergy have been unsuccessful, and Entergy opposes this motion. NRC Staff, Riverkeeper, and Clearwater do not oppose the motion.
Signed (electronically) by Laura E. Heslin Assistant Attorney General Office of the Attorney General  for the State of New York 120 Broadway  New York, New York (212) 416-6091
December 6, 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. December 6, 2012
------------------
---------------
---------------
-----------x CERTIFICATE OF SERVICE  I hereby certify that on December 6, 2012, copies of the State of New York Motion For Leave to File Additional Exhibits Concer ning Contention NYS-8 and exhibits NYS000468 -
NYS000471 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 6th day of December 2012 Manna Jo Greene, Director Karla Raimundi, Environmental Justice
Associate Stephen Filler, Esq., Board Member
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
____________________________________
John J. Sipos Assistant Attorney General State of New York   
(518) 402-2251}}

Revision as of 17:14, 1 August 2018

State of New York Motion for Leave to File Additional Exhibits Concerning Contentions NYS-8
ML12341A289
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/06/2012
From: Sipos J J, Heslin L E
State of NY, Office of the Attorney General
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23854, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 DPR-026, DPR-064
Download: ML12341A289 (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. December 6, 2012

x

STATE OF NEW YORK MOTION FOR LEAVE TO FILE ADDITIONAL EXHIBITS CONCERNING CONTENTION NYS-8

Office of the Attorney General for the State of New York

The Capitol

State Street

Albany, New York 12224 1 INTRODUCTION In accordance with 10 C.F.R. § 2.323(a) and the Atomic Safety and Licensing Board's

("Board") direction during the September 24, 2012 prehearing teleconference, the State of New York requests leave to file four additi onal New York Exhibits, NYS000468 to NYS000471.

Good cause exists for allowing the State to file these additional exhibits because they came into existence very recently and are relevant to issues likely to be discussed at the upcoming evidentiary hearing next week in Tarrytown. Their admission is necessary to develop a full

hearing record and will not cause delay or harm to any party. The State has disclosed the documents to the parties. The State of New York has consulted with Entergy, NRC Staff, Riverkeeper, and Clearwater pursuant to 10 C.F.R.

§ 2.323(b). NRC Staff, Riverk eeper, and Clearwater do not oppose this motion. Entergy opposes the admission of the four additional New York Exhibits, NYS000468 to NYS000471, on the basis of relevance. ARGUMENT GOOD CAUSE EXISTS FOR ALLO WING 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); accord Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3) Order Denying Clearwater's Motion to Supplement the Record, at 3 (Dec. 5, 22012) (finding that 10 C.F.R. § 2.337(a) is the applicable standard for the admission of new exhibits). The four documents the State seeks to introduce are:

NRC Bulletin 2012-01: Design Vulnerability in Electric Power System, July 27, 2012, ADAMS Accession Number ML12074A115. The State of New requests that the Board admit this document as NYS000468. Entergy Letter, NL-12-141, 90-Day Response to Bulletin 2012-01, "Design Vulnerability in Electric Power System,"[

i.e., the preceding document] Indian Point Units 2 & 3, Docket Nos. 50-247 and 50-286, License Nos. DPR-26 and DPR-64, October 25, 2012, ADAMS Accession Number ML12311A014 (posted on November 15, 2012). The State of New York requests that the Board admit this document as NYS000469. Entergy Preliminary Notification of Event or Unusual Occurrence - PNO-I-12-008, James A. Fitzpatrick Nuclear Power Plant Notification of Unusual Event Due to Fire in Main Transformer and Bus Ducting, November 13, 2012, ADAMS Accession Number ML12318A299 (posted on November 14, 2012). The State of New York requests that the Board admit this document as NYS000470. Entergy Preliminary Notification of Event or Unusual Occurrence - PNO-I-12-008A, UPDATE: James A. Fitzpatric k Nuclear Power Plant Notification of Unusual Event Due to Fire in Main Transformer, November 28, 2012, ADAMS Accession Number ML12333A307 (posted on November 28, 2012). The State of New York requests that the Board admit this document as NYS000471.

The State has disclosed these documents to Entergy, NRC Staff, and the other parties and participants.

1 These documents are relevant to the upcoming Evidentiary Hearing, and none of the documents-dated July 27, 2012, October 25, 2012, November 13, 2012, and November 28, 2012 respectively-were previously available to the State for incl usion in the State's June 29, 1 The State disclosed the first three documents to the parties on November 30, 2012 and the fourth document on December 5, 2012.

32012 rebuttal submissions. The documents relate to the issues raised in Contention NYS-8 and provide additional information about the parties' positions and submissions concerning transformers and aging management of transformers.

The NRC Bulletin 2012-01 (NYS000468) discusses a design vulnerability of the electric power system that can prevent the onsite and offsite electric power system-which includes transformers-from being able to perform its intended safety functions. The Bulletin requests that licensees provide information, such as transformer configurations, to assess this condition.

Entergy's recent response to NRC Bulletin 2012-01 (NYS000469) provides information about the structure of the electrical and transformer systems at the Indian Point facilities and indicates that Indian Point Unit 2 and Unit 3 have this design vulnerability, whic h affects the electric power systems' ability to detect an open phase fault condition. The two recent Preliminary Notification of Event or Unusual Occurrence documents (NYS000470 and NYS000471) describe a transformer fire that occurred on November 11, 2012, at the James A. Fitzpatrick Nuclear Power Plan t-a facility operated by Entergy and located in New York State. Entergy's initial investigation determined that the fire was caused by a problem in the "B" Phase winding of the T1-A main transformer.

The issues addressed in these documents could well be discussed during the December hearing dates for Contention NYS-8. The introduction 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.

4CONCLUSION For the above reasons, the State respectfully requests that the Boar d grant the State of New York leave to file NYS000468 to NYS000 471 as additional exhibits. The four documents-with exhibit markers-accompany this filing.

Respectfully submitted, Signed (electronically) by Signed (electronically) by Laura E. Heslin Assistant Attorney General Office of the Attorney General for the State of New York 120 Broadway New York, New York 10271 (212) 416-6091 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 Dated: December 6, 2012 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 he reby certifies that counsel fo r 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 resolve the issues w ith Entergy have been unsuccessful, and Entergy opposes this motion. NRC Staff, Riverkeeper, and Clearwater do not oppose the motion.

Signed (electronically) by Laura E. Heslin Assistant Attorney General Office of the Attorney General for the State of New York 120 Broadway New York, New York (212) 416-6091

December 6, 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. December 6, 2012

x CERTIFICATE OF SERVICE I hereby certify that on December 6, 2012, copies of the State of New York Motion For Leave to File Additional Exhibits Concer ning Contention NYS-8 and exhibits NYS000468 -

NYS000471 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 6th day of December 2012 Manna Jo Greene, Director Karla Raimundi, Environmental Justice

Associate Stephen Filler, Esq., Board Member

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

____________________________________

John J. Sipos Assistant Attorney General State of New York

(518) 402-2251

Retrieved from "https://kanterella.com/w/index.php?title=ML12341A289&oldid=929506"