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Category:Legal-Intervention Petition
MONTHYEARML11257A1102011-09-14014 September 2011 Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions ML11257A1092011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A1112011-09-13013 September 2011 Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report ML11228A0302011-08-11011 August 2011 the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17 ML11217A0662011-07-29029 July 2011 Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36 ML11210B4192011-07-26026 July 2011 State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37 ML11179A0922011-06-21021 June 2011 Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals ML11133A2882011-04-29029 April 2011 Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25 ML11117A1462011-04-19019 April 2011 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident ML11229A8022011-03-22022 March 2011 Supplementary Certification Regarding Consultation ML11108A1062011-03-21021 March 2011 Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3 ML1108307802011-03-18018 March 2011 State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives ML1107601812011-03-16016 March 2011 Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement ML1107000972011-03-0404 March 2011 State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B ML1106703812011-02-25025 February 2011 Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions ML1107402862011-02-23023 February 2011 State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36 ML1106604252011-02-23023 February 2011 State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1105602702011-02-18018 February 2011 Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule ML1105605892011-02-18018 February 2011 Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b) ML1104604922011-02-10010 February 2011 State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions ML1106802122011-02-0303 February 2011 State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area ML1030000602010-10-22022 October 2010 State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25 ML1030101042010-10-12012 October 2010 Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals ML1029101452010-10-0404 October 2010 Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1028802972010-10-0404 October 2010 Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B ML1029101422010-10-0404 October 2010 Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1030105182010-09-14014 September 2010 State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean.. ML1023712142010-08-16016 August 2010 Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion) ML1023001462010-08-13013 August 2010 Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents ML1022405782010-08-0202 August 2010 Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13 ML1021100862010-07-26026 July 2010 the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10- ML1020300502010-07-15015 July 2010 Applicant'S Petition for Interlocutory Review of LBP-10-13 ML1011604152010-04-12012 April 2010 State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1014503282010-04-0505 April 2010 Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis ML1011004732010-04-0101 April 2010 Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives ML1005702402009-11-20020 November 2009 Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point ML0934803252009-11-20020 November 2009 Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML0934910432009-11-20020 November 2009 Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information ML0935101942009-11-20020 November 2009 Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point ML1005700112009-11-20020 November 2009 Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML1008200282009-11-19019 November 2009 Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point ML0930801292009-10-26026 October 2009 Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information ML0909802072009-04-0707 April 2009 Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply ML0910502112009-04-0606 April 2009 Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2 ML0909604702009-03-31031 March 2009 State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34 ML0909302042009-03-24024 March 2009 Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State ML0908401162009-03-24024 March 2009 Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement ML0908608682009-03-18018 March 2009 Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items ML0906903032009-02-27027 February 2009 State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement ML0904105002009-01-26026 January 2009 Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention 2011-09-14
[Table view] Category:Responses and Contentions
MONTHYEARML11257A1102011-09-14014 September 2011 Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions ML11257A1092011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A1112011-09-13013 September 2011 Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report ML11228A0302011-08-11011 August 2011 the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17 ML11217A0662011-07-29029 July 2011 Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36 ML11210B4192011-07-26026 July 2011 State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37 ML11179A0922011-06-21021 June 2011 Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals ML11133A2882011-04-29029 April 2011 Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25 ML11117A1462011-04-19019 April 2011 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident ML11229A8022011-03-22022 March 2011 Supplementary Certification Regarding Consultation ML11108A1062011-03-21021 March 2011 Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3 ML1108307802011-03-18018 March 2011 State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives ML1107601812011-03-16016 March 2011 Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement ML1107000972011-03-0404 March 2011 State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B ML1106703812011-02-25025 February 2011 Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions ML1107402862011-02-23023 February 2011 State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36 ML1106604252011-02-23023 February 2011 State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1105602702011-02-18018 February 2011 Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule ML1105605892011-02-18018 February 2011 Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b) ML1104604922011-02-10010 February 2011 State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions ML1106802122011-02-0303 February 2011 State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area ML1030000602010-10-22022 October 2010 State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25 ML1030101042010-10-12012 October 2010 Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals ML1029101452010-10-0404 October 2010 Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1028802972010-10-0404 October 2010 Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B ML1029101422010-10-0404 October 2010 Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1030105182010-09-14014 September 2010 State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean.. ML1023712142010-08-16016 August 2010 Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion) ML1023001462010-08-13013 August 2010 Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents ML1022405782010-08-0202 August 2010 Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13 ML1021100862010-07-26026 July 2010 the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10- ML1020300502010-07-15015 July 2010 Applicant'S Petition for Interlocutory Review of LBP-10-13 ML1011604152010-04-12012 April 2010 State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1014503282010-04-0505 April 2010 Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis ML1011004732010-04-0101 April 2010 Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives ML1005702402009-11-20020 November 2009 Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point ML0934803252009-11-20020 November 2009 Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML0934910432009-11-20020 November 2009 Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information ML0935101942009-11-20020 November 2009 Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point ML1005700112009-11-20020 November 2009 Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML1008200282009-11-19019 November 2009 Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point ML0930801292009-10-26026 October 2009 Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information ML0909802072009-04-0707 April 2009 Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply ML0910502112009-04-0606 April 2009 Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2 ML0909604702009-03-31031 March 2009 State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34 ML0909302042009-03-24024 March 2009 Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State ML0908401162009-03-24024 March 2009 Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement ML0908608682009-03-18018 March 2009 Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items ML0906903032009-02-27027 February 2009 State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement ML0904105002009-01-26026 January 2009 Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention 2011-09-14
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Text
Contentionq, EC-1 DOCKETED DCKETED Exhibit 1 USNRC November 30, 2007 December 19, 2007 (9:02am)
OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop
)
Entergy Nuclear Operations, Inc. ) Docket Nos.
(Indian Point Nuclear Generating ) 50-247-LR Units 2 and 3) ) and 50-286-LR DECLARATION OF DR. PETER HENDERSON IN SUPPORT OF RIVERKEEPER'S CONTENTION EC-1 I, Peter Henderson, declare as follows:
- 1. I am a director of Pisces Conservation Ltd., ("Pisces"), a corporation based in Great Britain. Our office is located in Pennington, Lymington, Hampshire. Pisces provides expert consulting services in the United States, Great Britain, and other countries on a range of aquatic environmental issues, including effects of power plant impingement, entrainment, and thermal effluent discharge.
- 2. I am also a senior research associate at the University of Oxford where I lecture in population dynamics and ecological methods. I have extensively published on the subject of ecology and I am the co-author of the standard text book "Ecological Methods".
- 3. I am an expert in the effects of power plants on the aquatic environment, the population dynamics of fish and crustaceans, and the modeling of ecological impacts.
I received an undergraduate education in zoology at Imperial College, University of London where I obtained a Ist class Honours degree and the governors' prize for zoology. Subsequently, I pursued graduate studies at Imperial College and received a Doctorate of Philosophy in 1975, for a thesis on the analysis of population control mechanisms in crustaceans. Currently, I lecture and hold a position as a senior research associate in the department of Zoology, University of Oxford.
- 4. I have worked as an ecological consultant and research scientist for 28 years on theoretical, applied and field research. I have wide experience in the effects of power plant cooling water systems, including the preparation and presentation of evidence at public inquires and the writing of environmental impact assessments. I also have extensive experience of the management of major ecological assessment projects, including preparation and presentation of material for public enquires and liaising with conservation bodies and engineers. Projects undertaken include conservation JýC
-dA, I
planning for large tropical nature reserves, ecological effects studies of nuclear power station intakes, conservation studies of rare freshwater life and effects of climate change and drought.
- 5. My Curriculum Vitae is provided here as Attachment 1.
- 6. In support of Riverkeeper's request for a hearing and petition to intervene with respect to the license renewal proceeding for the Indian Point Nuclear Power Station, I co-authored, with Dr. Richard Seaby, the following reports: "Status of Fish Populations and the Ecology of the Hudson River" and "Analysis of Entrainment, Impingement and Thermal Impacts at Indian Point Power Station. Copies of these reports are provided as Attachments 2 and 3, respectively. The technical factual statements in the reports are true and correct to the best of my knowledge, and the opinions expressed therein are based on my best professional judgment.
- 7. I also assisted in the preparation of Riverkeeper's Contention EC-1, regarding the adverse impacts on aquatic resources by heat shock, impingement and entrainment of fish caused by Indian Point's once through cooling system. The factual assertions in these contentions are true and correct to the best of my knowledge and belief, and the opinions expressed therein are based on my best professional judgment.
- 8. In preparing my reports and Contention EC-1, I reviewed Entergy Nuclear Operations, Inc.'s April 23, 2007, license renewal application for the Indian Point nuclear power plant, including the Environmental Report.
Peter Henderson, Ph.D November 30, 2007 2
Contention EC-1 Exhibit,)2 November 30, 2007 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop
)
Entergy Nuclear Operations, Inc. ) Docket Nos.
(Indian Point Nuclear Generating ) 50-247-LR Units 2 and 3) ) and 50-286-LR DECLARATION OF DR. RICHARD SEABY IN SUPPORT OF RIVERKEEPER'S CONTENTION EC-1 I, Richard Seaby, declare as follows:
- 1. I am a managing director of Pisces Conservation Ltd., ("Pisces"), a corporation based in Great Britain. Our office is located in Pennington, Lymington, Hampshire.
Pisces provides expert consulting services in the United States, Great Britain, and other countries on a range of aquatic environmental issues, including effects of power plant impingement, entrainment, and thermal effluent discharge.
- 2. I received an undergraduate education in zoology at Goldsmiths College, University of London where I obtained a 2.1 Honors degree. Subsequently, I pursued graduate studies at Liverpool University and received a Doctorate of Philosophy in 1992, for a thesis on the coexistence of lake-dwelling triclads and leeches.
- 3. I have worked as an ecological consultant and research scientist for 15 years. I am an expert in the effects of power plants on the aquatic environment, the population dynamics of fish and crustaceans and the modeling of ecological impacts.
- 4. My Curriculum Vitae is provided here as Attachment 1.
- 5. In support of Riverkeeper's request for a hearing and petition to intervene with respect to the license renewal proceeding for the Indian Point Nuclear Power Station, I co-authored, with Dr. Peter Henderson, the following reports: "Status of Fish Populations and the Ecology of the Hudson River" and "Analysis of Entrainment, Impingement and Thermal Impacts at Indian Point Power Station. Copies of these reports are attached to Dr. Henderson's declaration as Attachments 2 and 3, respectively. The technical factual statements in the reports are true and correct to the best of my knowledge, and the opinions expressed therein are based on my best professional judgment.
1
- 6. I also assisted in the preparation of Riverkeeper's Contention EC-1, regarding the adverse impacts on aquatic resources by heat shock, impingement and entrainment of fish caused by Indian Point's once through cooling system. The factual assertions in these contentions are true and correct to the best of my knowledge and belief, and the opinions expressed therein are based on my best professional judgment.
- 7. In preparing my reports and Contention EC- 1, I reviewed Entergy Nuclear Operations, Inc.'s April 23, 2007, license renewal application for the Indian Point nuclear power plant, including the Environmental Report.
Richard Seaby, Ph.D November 30, 2007 2
HARMON, CURRAN, SPIELBER G -E1SENBERG, LLP 1726 M Street, NW, Suite 600 Washington, DC 20036 *-(.202) 328-3500 (202) 328-6918 fax December 11, 2007 Office of the Secretary Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
Filingin Indian PointLicense Renewal Proceeding, Docket Nos. 50-247LR and 50-246-LR
Dear Madam/Sir:
Enclosed please find the original and two copies of the signed declarations of Drs. Peter Henderson and Richard Seaby. Please substitute them for the faxed copies that Riverkeeper, Inc. submitted on November 30, 2007, in support of Riverkeeper's Request for Hearing and Petition to Intervene in Indian Point License Renewal Proceeding. Dr.
Henderson's declaration should be attached as Exhibit 1 to Contention EC-l and Dr.
Seaby's declaration should be attached as Exhibit 2 to contention EC-1.
Copies of the declarations have been served on the parties and the Atomic Safety and Licensing Board, as listed in the attached certificate of service.
Sincerely, ianeru~rra-n Cc: Service List
CERTIFICATE OF SERVICE I certify that on December 11, copies of the foregoing Declaration of Dr. Peter Henderson in Support of Riverkeeper's Contention EC-I and Declaration of Dr. Richard Seaby in Support of Riverkeeper's Contention EC-1 were served on the following by first-class mail:
Lawrence G. McDade, Chair Kaye D. Lathrop Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Also by e-mail: LGM1 @nrc.gov Also by e-mail: KDL2@nrc.gov Richard E. Wardwell Michael J. Delaney, V.P. - Energy Atomic Safety and Licensing Board New York City Economic Development U.S. Nuclear Regulatory Commission Corp.
Washington, D.C. 20555 110 William Street Also by e-mail: REWnrc.gov New York, NY 10038 Also by e-mail: mdelaney@nycedc.com Sherwin E. Turk, Esq. Martin J. O'Neill, Esq.
Lloyd B. Subin, Esq. Kathryn M. Sutton, Esq.
Beth N. Mizuno, Esq. Paul M. Bessette, Esq.
Atomic Safety and Licensing Board Panel Mauri T. Lemoncelli, Esq.
U.S. Nuclear Regulatory Commission Morgan, Lewis & Bockius, LLP Washington, D.C. 20555 1111 Pennsylvania Ave. N.W.
Also by e-mail: sbtanrc.gov; Washington, D.C. 20004 lbs3@nrc.gov; Also by e-mail:
bnm2@nrc. gov martin.oneill@morganlewis.com pbessette@morganlewis.com ksuttongmorganlewis.com Susan H. Shapiro, Esq. Office of Commission Appellate Adjudication 21 Perlman Drive U.S. Nuclear Regulatory Commission Spring Valley, NY 10977 Washington, D.C. 20555 Also by e-mail: mbsO,,ourrocklandoffice.com Also by e-mail: OCAAMAILknrc.gov
Joan Leary Matthews, Esq. Arthur J. Kremer, Chairman Senior Attorney for Special Projects New York AREA New York State Department 347 Fifth Avenue, Suite 508 of Environmental Conservation New York, NY 10016 625 Broadway, 14th floor Also by e-mail: aikremer@rmfpc.com Albany, New York 12233-5500 kremer(.areaalliance.org Also by e-mail: jlmatthews@gw.dec.state.ny.us Office of the Secretary William C. Dennis, Esq.
Rulemakings and Adjudications Staff Assistant General Counsel U.S. Nuclear Regulatory Commission Entergy Nuclear Operations, Inc.
Washington, D.C. 20555 440 Hamilton Avenue Also by e-mail: HEARINGDOCKET(,nrc.gov White Plains, NY 10601 Also by e-mail: wdennis@entergy.com Sherwood Martinelli Manna Jo Greene FUSE USA Hudson River Sloop Clearwater, Inc.
351 Dyckman Street 112 Little Market Street Peekskill, NY 10566 Poughkeepsie, NY 12601 Also by e-mail: fuse usagyahoo.com; Also by e-mail: Mannaio@clearwater.org roycepenstinger@aol.com Zackary S. Kahn, Esq. John J. Sipos, Esq.
Law Clerk Assistant Attorney General Atomic Safety and Licensing Board Panel Office of the Attorney General U.S. Nuclear Regulatory Commission for the State of New York Washington, D.C. 20555 The Capitol Also by e-mail: ZXK1(,nrc.gov State Street Albany, New York 12224 Also by e-mail: John.Sipos@oag.state.ny.us Diane Curran 2