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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. October 17, 2011 | |||
--------------- | |||
--------------- | |||
--------------- | |||
--------------x STATE OF NEW YORK'S MOTION FOR CLARIFICATION (Board's October 7, 2011 Order (Procedures for Evidentiary Filings)) | |||
The State of New York respectfully requests clarification of the Atomic Safety and Licensing Board's recent October 7, 2011 order concerning Procedures for Evidentiary Filings with respect to the Board's July 1, 2010 Scheduling Order. | |||
Specifically, following the Board's July 1, 2010 Scheduling Order, the State understood that with respect to pre-filed testimony, exhibits, and statements of position, the parties were required to make their presentations on a "c ontention-by-contention ba sis." July 1, 2010 Scheduling Order at ¶ K1, K2, K3. The State has been organizing its pre-filed presentations in accordance with that July 1, 2010 directive. | |||
While the October 7, 2011 Order does not expressly reference or amend the July 1, 2010 Scheduling Order, the State is concerned that the October 7, 2011 Order could be read as envisioning a different organizational and filing format from that provided in the July 1, 2010 Scheduling Order. The October 7, 2011 Order could be read as anticipating one single omnibus submission from each party commencing with a single exhibit list followed by one combined statement of position for all contentions, to be followed by testimony on all contentions, to be 2 followed by exhibits on all contentions. Oct ober 7, 2011 Order at ¶ A1. Alternatively, the October 7, 2011 Order could be read as silent on this point, in which case the July 1, 2010 Order's contention-by-contention process would remain in place. | |||
The State requests that the Board clarify whether the October 7, 2011 order modified the filing and organizational proce dures established by the July 1, 2010 Order. The State also respectfully requests and recommends that the Board retain th e contention-by-contention basis established by the July 1, 2010 or der for the below reasons. First, the State anticipates that the pre-filed submissions on the State's admitted contentions (and the combined Riverkeeper's TC | |||
-1B contention) will be extensive and involve testimony from various experts and numerous exhibits. | |||
1 In addition, with respect to a few contentions, it is possible that Riverkeeper or the State may reference material that Entergy or Westinghouse has designated as containing confidential material, which, in turn, will involve additional filings and procedures in accordance with the Board's Protective Order. Permitting parties to make their presentations on a contention-by-contention basis will likely allow the State to complete the filing of some of its pre-filed submissions for certain contentions in the days leading up to the filing deadline, thus reducing demands and stress on computer capabilities, the EIE electronic filing system, a nd paralegals and attorneys on the day of the deadline. Conversely, in this proceeding -- where there are many admitted contentions and amendments thereto -- placing the entirety of the State's multi-contention submissions in a single electronic filing where each document is "linked" to all other documents may cause unintended challenges on the filing date. | |||
2 Allowing smaller-sized filings on a contention-by-contention basis may | |||
1 This proceeding will likely involve a relatively larger set of pre-filed submissions than other contested license renewal proceedings. | |||
2 Under the EIE process, each document that is submitted by a party must be uploaded 3alleviate these concerns. Second, the State has been operating in accordance with the contention-by-contention format for the past 16 months; moving to a different organizational and filing format will complicate the State's preparation. REGULATORY BACKGROUND For the convenience of the Board and th e parties, the State provides the following excerpts of the July 1, 2010 Scheduli ng Order and the October 7, 2011 Order. The Board's July 1, 2010 Scheduling Order provides: | |||
K. Evidentiary Hearings Filings. | |||
: 1. Initial Statements of Position, Testimony, Affidavits, and Exhibits. Unless modified by the Board due to the admission of new or amended contentions or for some other due cause, ni nety (90) days after the trigger date, the intervenors shall file their initial written statement of position, written testimony with supporting affidav its, and exhibits, on a contention-by-contention basis, pursuan t to 10 C.F.R. § 2.1207(a)(1). The initial written statement should be in the nature of a trial brief that provides a precise road map of the party's case, setting out affirmative arguments and applicable legal standards, identifying witnesses and evidence, and specifying the purpose of witnesses and evidence (i.e., | |||
stating with particularity how the witness, exhibit, or evidence supports a factual or legal position). The written testimony shall be under oath or by an affidavit so that it is suitable for direct receipt into evidence, in accordance with 10 C.F.R. § 2.1207(b)(2). The exhibits shall include all documents that the party or its witn esses refer to, use, or rely upon for their statements or position. If such documents are not attached, the Board will not consider them for any purpose in making findings of fact. Such submissions shall be made on a contention-by-contention basis. | |||
: 2. Entergy's and the NRC Staff's Statements of Position, Testimony, Affidavits, and Exhibits. No later than sixty (60) days after service of the materials submitted under paragraph K.1, Entergy and the NRC Staff shall file their respective written statements of position, written testimony with supporting affidavits, and exhibits, on a contention-by-contention basis, pursuant to 10 C.F.R. § 2.1207(a)(2). | |||
and linked to the larger filing through a multi-step process -- document by document. | |||
4 * * * | |||
: 3. Optional Revised Statement of Position by Intevenors and Submissions by Interested Governmental Entities. The Intervenors may, but need not, submit a revised statement of position and rebuttal testimony with supporting affidavits and exhibits in response to the materials submitted by Entergy and/or the NRC Staff. If they choose to do so, they shall notify all parties of their intenti on no later than ten (1 | |||
: 0) days after the service of the materials submitted by Entergy and the NRC Staff under paragraph K.2 and must submit their revised statement of position and rebuttal testimony no later than sixty (60) days after the service under paragraph K.2. Likewise, the interested governmental entities who have been authorized to participate in this proceeding pursuant to 10 C.F.R. § 2.315(c) may submit a written statement of position, written testimony | |||
with supporting affidavits, and exhibits no later than sixty (60) days after the submission of materials by En tergy and/or the NRC Staff under paragraph K.2. Such submissions shall be made on a contention-by- | |||
contention basis. If interested governmental entities submit written statements of position and/or written testimony, rebuttal may be submitted within thirty (30) days of such submissions. | |||
July 1, 2010 Scheduling Order (excerpt). | |||
The Board's October 7, 2011 Order (Procedur es for Evidentiary Filings) provides: | |||
A. Format of Evidentiary Submissions | |||
: 1. Each participant's evidentiary submission shall begin with an exhibit list containing four columns: the exhibit's number, the | |||
contention(s) addressed by the exhibit, the exhibit's name (including date of creation, if useful), and the exhibit's submission date. | |||
3 That exhibit list will constitute each respective participant's first exhibit. Each participant's second exhibit will consist of its statement of position and the third exhibit will be the pre-filed testimony (which, at the participant's option, may be broken into more than one exhibit). This will be followed in numerical order by each of the exhibits supporting that testimony. | |||
October 7, 2011 Order (excerpt) (footnote omitted). | |||
CONCLUSION The requested clarification will assist the State (and possibly other participants) in preparing for the upcoming pre-filed submissions. | |||
5 Respectfully submitted, Signed (electronically) by | |||
_______________________ | |||
John J. Sipos Assistant Attorneys General Office of the Attorney General of the State of New York | |||
The Capitol | |||
Albany, New York 12224 | |||
(518) 402-2251 | |||
Dated: October 17, 2011 10 C.F.R. § 2.323(b) Certification I certify that I have made a sincere effort to c ontact the other parties in this proceeding, to explain to them the factual and legal issues raised in this motion, and to resolve those issues, and I certify that NRC Staff, Entergy, Riverkeeper , and Clearwater do not oppose the request for clarification. | |||
Signed (electronically) by | |||
______________________ | |||
John J. Sipos | |||
October 17, 2011 1UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD | |||
------------------ | |||
--------------- | |||
--------------- | |||
-----------x In re: Docket Nos. 50-247-LR and 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. October 17, 2011 | |||
------------------ | |||
--------------- | |||
--------------- | |||
-----------x CERTIFICATE OF SERVICE I hereby certify that on October 17, 2011, copies of the State of New York's Motion for Clarification (Board's October 7, 2011 Order (Procedures for Evidentiary Filings)), were served upon the following persons via U.S. Mail and e-mail at the following addresses: | |||
Lawrence G. McDade, Chair 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 E. Wardwell 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 Richard.Wardwell@nrc.gov | |||
Kaye D. Lathrop Administrative Judge Atomic Safety and Licensing Board Panel | |||
U.S. Nuclear Regulatory Commission 190 Cedar Lane E. | |||
Ridgway, CO 81432 Kaye.Lathrop@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 | |||
Josh Kirstein, 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 | |||
Josh.Kirstein@nrc.gov | |||
2 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 | |||
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. | |||
Andrea Z. Jones, Esq. | |||
Beth N. Mizuno, Esq. | |||
Brian G. Harris, 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 | |||
andrea.jones@nrc.gov | |||
david.roth@nrc.gov beth.mizuno@nrc.gov | |||
brian.harris@nrc.gov | |||
Kathryn M. Sutton, Esq. | |||
Paul M. Bessette, Esq. | |||
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW | |||
Washington, DC 20004 ksutton@morganlewis.com pbessette@morganlewis.com | |||
Martin J. O'Neill, Esq. | |||
Morgan, Lewis & Bockius LLP | |||
Suite 4000 | |||
1000 Louisiana Street | |||
Houston, TX 77002 martin.o'neill@morganlewis.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. | |||
Village of Buchanan Municipal Building | |||
236 Tate Avenue | |||
Buchanan, NY 10511-1298 | |||
vob@bestweb.net | |||
3 Daniel Riesel, Esq. Thomas F. Wood, Esq. | |||
Victoria Shiah, Esq. | |||
Sive, Paget & Riesel, P.C. | |||
460 Park Avenue | |||
New York, NY 10022 driesel@sprlaw.com vshiah@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 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 | |||
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 | |||
Dated at Albany, New York | |||
this 17th day of October 2011}} |
Revision as of 19:34, 2 August 2018
ML11290A295 | |
Person / Time | |
---|---|
Site: | Indian Point ![]() |
Issue date: | 10/17/2011 |
From: | Sipos J J State of NY, Office of the Attorney General |
To: | Atomic Safety and Licensing Board Panel |
SECY RAS | |
References | |
RAS 21254, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
Download: ML11290A295 (8) | |
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. October 17, 2011
x STATE OF NEW YORK'S MOTION FOR CLARIFICATION (Board's October 7, 2011 Order (Procedures for Evidentiary Filings))
The State of New York respectfully requests clarification of the Atomic Safety and Licensing Board's recent October 7, 2011 order concerning Procedures for Evidentiary Filings with respect to the Board's July 1, 2010 Scheduling Order.
Specifically, following the Board's July 1, 2010 Scheduling Order, the State understood that with respect to pre-filed testimony, exhibits, and statements of position, the parties were required to make their presentations on a "c ontention-by-contention ba sis." July 1, 2010 Scheduling Order at ¶ K1, K2, K3. The State has been organizing its pre-filed presentations in accordance with that July 1, 2010 directive.
While the October 7, 2011 Order does not expressly reference or amend the July 1, 2010 Scheduling Order, the State is concerned that the October 7, 2011 Order could be read as envisioning a different organizational and filing format from that provided in the July 1, 2010 Scheduling Order. The October 7, 2011 Order could be read as anticipating one single omnibus submission from each party commencing with a single exhibit list followed by one combined statement of position for all contentions, to be followed by testimony on all contentions, to be 2 followed by exhibits on all contentions. Oct ober 7, 2011 Order at ¶ A1. Alternatively, the October 7, 2011 Order could be read as silent on this point, in which case the July 1, 2010 Order's contention-by-contention process would remain in place.
The State requests that the Board clarify whether the October 7, 2011 order modified the filing and organizational proce dures established by the July 1, 2010 Order. The State also respectfully requests and recommends that the Board retain th e contention-by-contention basis established by the July 1, 2010 or der for the below reasons. First, the State anticipates that the pre-filed submissions on the State's admitted contentions (and the combined Riverkeeper's TC
-1B contention) will be extensive and involve testimony from various experts and numerous exhibits.
1 In addition, with respect to a few contentions, it is possible that Riverkeeper or the State may reference material that Entergy or Westinghouse has designated as containing confidential material, which, in turn, will involve additional filings and procedures in accordance with the Board's Protective Order. Permitting parties to make their presentations on a contention-by-contention basis will likely allow the State to complete the filing of some of its pre-filed submissions for certain contentions in the days leading up to the filing deadline, thus reducing demands and stress on computer capabilities, the EIE electronic filing system, a nd paralegals and attorneys on the day of the deadline. Conversely, in this proceeding -- where there are many admitted contentions and amendments thereto -- placing the entirety of the State's multi-contention submissions in a single electronic filing where each document is "linked" to all other documents may cause unintended challenges on the filing date.
2 Allowing smaller-sized filings on a contention-by-contention basis may
1 This proceeding will likely involve a relatively larger set of pre-filed submissions than other contested license renewal proceedings.
2 Under the EIE process, each document that is submitted by a party must be uploaded 3alleviate these concerns. Second, the State has been operating in accordance with the contention-by-contention format for the past 16 months; moving to a different organizational and filing format will complicate the State's preparation. REGULATORY BACKGROUND For the convenience of the Board and th e parties, the State provides the following excerpts of the July 1, 2010 Scheduli ng Order and the October 7, 2011 Order. The Board's July 1, 2010 Scheduling Order provides:
K. Evidentiary Hearings Filings.
- 1. Initial Statements of Position, Testimony, Affidavits, and Exhibits. Unless modified by the Board due to the admission of new or amended contentions or for some other due cause, ni nety (90) days after the trigger date, the intervenors shall file their initial written statement of position, written testimony with supporting affidav its, and exhibits, on a contention-by-contention basis, pursuan t to 10 C.F.R. § 2.1207(a)(1). The initial written statement should be in the nature of a trial brief that provides a precise road map of the party's case, setting out affirmative arguments and applicable legal standards, identifying witnesses and evidence, and specifying the purpose of witnesses and evidence (i.e.,
stating with particularity how the witness, exhibit, or evidence supports a factual or legal position). The written testimony shall be under oath or by an affidavit so that it is suitable for direct receipt into evidence, in accordance with 10 C.F.R. § 2.1207(b)(2). The exhibits shall include all documents that the party or its witn esses refer to, use, or rely upon for their statements or position. If such documents are not attached, the Board will not consider them for any purpose in making findings of fact. Such submissions shall be made on a contention-by-contention basis.
- 2. Entergy's and the NRC Staff's Statements of Position, Testimony, Affidavits, and Exhibits. No later than sixty (60) days after service of the materials submitted under paragraph K.1, Entergy and the NRC Staff shall file their respective written statements of position, written testimony with supporting affidavits, and exhibits, on a contention-by-contention basis, pursuant to 10 C.F.R. § 2.1207(a)(2).
and linked to the larger filing through a multi-step process -- document by document.
4 * * *
- 3. Optional Revised Statement of Position by Intevenors and Submissions by Interested Governmental Entities. The Intervenors may, but need not, submit a revised statement of position and rebuttal testimony with supporting affidavits and exhibits in response to the materials submitted by Entergy and/or the NRC Staff. If they choose to do so, they shall notify all parties of their intenti on no later than ten (1
- 0) days after the service of the materials submitted by Entergy and the NRC Staff under paragraph K.2 and must submit their revised statement of position and rebuttal testimony no later than sixty (60) days after the service under paragraph K.2. Likewise, the interested governmental entities who have been authorized to participate in this proceeding pursuant to 10 C.F.R. § 2.315(c) may submit a written statement of position, written testimony
with supporting affidavits, and exhibits no later than sixty (60) days after the submission of materials by En tergy and/or the NRC Staff under paragraph K.2. Such submissions shall be made on a contention-by-
contention basis. If interested governmental entities submit written statements of position and/or written testimony, rebuttal may be submitted within thirty (30) days of such submissions.
July 1, 2010 Scheduling Order (excerpt).
The Board's October 7, 2011 Order (Procedur es for Evidentiary Filings) provides:
A. Format of Evidentiary Submissions
- 1. Each participant's evidentiary submission shall begin with an exhibit list containing four columns: the exhibit's number, the
contention(s) addressed by the exhibit, the exhibit's name (including date of creation, if useful), and the exhibit's submission date.
3 That exhibit list will constitute each respective participant's first exhibit. Each participant's second exhibit will consist of its statement of position and the third exhibit will be the pre-filed testimony (which, at the participant's option, may be broken into more than one exhibit). This will be followed in numerical order by each of the exhibits supporting that testimony.
October 7, 2011 Order (excerpt) (footnote omitted).
CONCLUSION The requested clarification will assist the State (and possibly other participants) in preparing for the upcoming pre-filed submissions.
5 Respectfully submitted, Signed (electronically) by
_______________________
John J. Sipos Assistant Attorneys General Office of the Attorney General of the State of New York
The Capitol
Albany, New York 12224
(518) 402-2251
Dated: October 17, 2011 10 C.F.R. § 2.323(b) Certification I certify that I have made a sincere effort to c ontact the other parties in this proceeding, to explain to them the factual and legal issues raised in this motion, and to resolve those issues, and I certify that NRC Staff, Entergy, Riverkeeper , and Clearwater do not oppose the request for clarification.
Signed (electronically) by
______________________
John J. Sipos
October 17, 2011 1UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
x In re: Docket Nos. 50-247-LR and 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. October 17, 2011
x CERTIFICATE OF SERVICE I hereby certify that on October 17, 2011, copies of the State of New York's Motion for Clarification (Board's October 7, 2011 Order (Procedures for Evidentiary Filings)), were served upon the following persons via U.S. Mail and e-mail at the following addresses:
Lawrence G. McDade, Chair 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 E. Wardwell 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 Richard.Wardwell@nrc.gov
Kaye D. Lathrop Administrative Judge Atomic Safety and Licensing Board Panel
U.S. Nuclear Regulatory Commission 190 Cedar Lane E.
Ridgway, CO 81432 Kaye.Lathrop@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
Josh Kirstein, 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
Josh.Kirstein@nrc.gov
2 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
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.
Andrea Z. Jones, Esq.
Beth N. Mizuno, Esq.
Brian G. Harris, 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
andrea.jones@nrc.gov
david.roth@nrc.gov beth.mizuno@nrc.gov
brian.harris@nrc.gov
Kathryn M. Sutton, Esq.
Paul M. Bessette, Esq.
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW
Washington, DC 20004 ksutton@morganlewis.com pbessette@morganlewis.com
Martin J. O'Neill, Esq.
Suite 4000
1000 Louisiana Street
Houston, TX 77002 martin.o'neill@morganlewis.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.
Village of Buchanan Municipal Building
236 Tate Avenue
Buchanan, NY 10511-1298
vob@bestweb.net
3 Daniel Riesel, Esq. Thomas F. Wood, Esq.
Victoria Shiah, Esq.
Sive, Paget & Riesel, P.C.
460 Park Avenue
New York, NY 10022 driesel@sprlaw.com vshiah@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 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
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
Dated at Albany, New York
this 17th day of October 2011