ML11355A247

New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000292, Declaration of Kathryn M. Liberatore

ML11355A247
Person / Time
Site:	Indian Point
Issue date:	12/21/2011
From:	Liberatore K M State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML11355A240	List: ML11355A241 ML11355A242 ML11355A244 ML11355A245 ML11355A247 ML11355A248 ML11355A249 ML11355A251 ML11355A252
References
RAS 21598, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML11355A247 (2)

Text

- 1 -UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

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x In re: Docket Nos. 50-247-LR; 50-286-LR

License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. December 21, 2011

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x DECLARATION OF KATHRYN M. LIBERATORE Pursuant to 28 U.S.C. § 1746, Kathryn M. Li beratore hereby declares as follows:

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 Stat e of New York's contention, NYS-12/12-A/12-B/12-C (hereinafter "Consolidated Contention 12-C"), which asserts th at the analysis set forth in the Nuclear Regulatory Commission ("NRC") Staff's December 2010 Final Supplemental Environmental Impact Statement concerning the Severe Accident Mitigation analysis and the inputs to the computer code that were used to evaluate the decontamination and cleanup costs associated with severe accidents, does not meet the requirements of National Environmental Policy Act ("NEPA"), and the regulations implementing NEPA adopted by the NRC and the Council on Environmental Quality.

2. The accompanying exhibits are discussed in more detail in the State's Statement of Position, and/or were previously submitted as supporting evidence for the State's contentions.

3. Attached to this declaration as Exhib it NYSR70001 is a true and correct copy of the document entitled State of New York Hearing Exhibi ts List ("NYS Exhibits List"), Exh. NYSR70001.

NYS Exhibits List includes those exhib its relied upon and refere nced in support of Consolidated Contention 12-C, NYS000240 through NYS000292.

4. Attached to this declaration as Exhi bit NYS000288 is a true and correct copy of the document entitled NUREG/CR-4691, SAND86-1562, Vol. 2, MELCOR Accident Consequence Code System (MACCS) (February 1990).

5. Attached to this declaration as Exhi bit NYS000287 is a true and correct copy of the document entitled NEI 05-01 [Rev A], Severe Accident Mitigation Alternatives (SAMA)

Analysis, Guidance Document (November 2005).

6. Attached to this declaration as Exhi bit NYS000286 is a true and correct copy of the document entitled Indian Point: The Next Fukushima?, V. Gilinsky, The New York Times (Dec. 16, 2011).

7. I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 21, 2011 Signed (electronically) by

_______________________

Kathryn M. Liberatore Assistant Attorney General Office of the Attorney General of the State of New York

120 Broadway

New York, New York 10271

(212) 416-8482