Entergy'S Motion for Leave to File, and to Request the Admission of Hearing Exhibit ENT000608| ML13171A374 |
| Person / Time |
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| Site: |
Indian Point  |
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| Issue date: |
06/20/2013 |
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| From: |
Bessette P, Dennis W, Glew W, O'Neil M, Sutton K
Entergy Services, Morgan, Morgan, Lewis & Bockius, LLP, Entergy Nuclear Operations |
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| To: |
Atomic Safety and Licensing Board Panel |
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| SECY RAS |
| References |
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| RAS 24708, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 |
| Download: ML13171A374 (4) |
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[Table view] |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-247-LR and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
) June 20, 2013 ENTERGYS MOTION FOR LEAVE TO FILE, AND TO REQUEST THE ADMISSION OF, HEARING EXHIBIT ENT000608 In accordance with 10 C.F.R. § 2.323(a), and the Atomic Safety and Licensing Boards (Board) Order dated June 12, 2013,1 Entergy Nuclear Operations, Inc. (Entergy) seeks leave to file Entergy communication NL-13-075,2 in its entirety, as additional hearing exhibit ENT000608, and requests that the Board admit ENT000608 into evidence. In addition, Entergy is filing a revised exhibit list (ENTR13001) that reflects the submission of this exhibit.
Good cause has been shown for the admission of this exhibit into evidence.3 In admitting an excerpt from NL-13-075 as exhibit NYS000476 in connection with Contention NYS-16B, the Board stated that if Entergy submits NL-13-075 in its entirety as ENT000608 it will be admitted upon receipt.4 Pursuant to 10 C.F.R. § 2.323(b), counsel for Entergy consulted with the other parties counsel concerning this Motion. The NRC Staff does not oppose Entergys Motion.
1 See Licensing Board Order (Granting New Yorks Motions, Denying Clearwaters Motion, and Denying CZMA Motions) at 2 (June 12, 2013) (unpublished) (June 12 Order).
2 See NL-13-075, Letter from F. Dacimo, Vice President, Indian Point Energy Center, to NRC Document Control Desk, License Renewal Application - Completed Engineering Project Cost Estimates for SAMAs Previously Identified as Potentially Cost-Beneficial (May 6, 2013).
3 See Entergys Answer Opposing State of New York Motion Seeking Leave to File an Additional Exhibit and Supplemental Findings of Fact and Conclusions of Law on Contention NYS-16B at 5 n.21 (May 28, 2013)
(stating that admitting NL-13-075 in its entirety would provide appropriate factual and legal context for the two-page table excerpted by New York State in exhibit NYS000476.).
4 June 12 Order at 2.
Riverkeeper and Clearwater take no position on the Motion. New York State continues to object to the submission and admission of the entirety of Entergy communication NL-13-075 as an exhibit concerning Contention NYS-16 for the reasons stated in the States answer filed on June 6, 2013 and discussed during the June 10, 2013 conference call;5 the State reserves the right to pursue those objections in this proceeding. However, given the text of the Boards June 12, 2013 Order, the State does not intend to submit additional opposition arguments to the Board on this point at this time assuming that other parties do not submit additional arguments.
Respectfully submitted, Executed in accord with 10 C.F.R. § 2.304(d)
William B. Glew, Jr., Esq. Kathryn M. Sutton, Esq.
William C. Dennis, Esq. Paul M. Bessette, Esq.
ENTERGY SERVICES, INC. MORGAN, LEWIS & BOCKIUS LLP 440 Hamilton Avenue 1111 Pennsylvania Avenue, N.W.
White Plains, NY 10601 Washington, D.C. 20004 Phone: (914) 272-3202 Phone: (202) 739-5738 E-mail: wglew@entergy.com E-mail: ksutton@morganlewis.com E-mail: wdennis@entergy.com E-mail: pbessette@morganlewis.com Martin J. ONeill, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1000 Louisiana Street Suite 4000 Houston, TX 77002 Phone: (713) 890-5710 Counsel for Entergy Nuclear Operations, Inc.
Dated in Washington, D.C.
this 20th day of June 2013 5
See State of New Yorks Answer to Entergys Request for Leave to File an Additional Exhibit and Supplemental Proposed Findings of Fact and Conclusions of Law In Response to New Yorks Supplemental Proposed Findings of Fact and Conclusions of Law on Contention NYS-16B at 2-5 (June 6, 2013); Official Transcript of Proceedings, Indian Point Nuclear Generating Units 2 & 3 at 4525-27 (June 10, 2013).
2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-247-LR and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
) June 20, 2013 MOTION CERTIFICATION Pursuant to 10 C.F.R. § 2.323(b), counsel for Entergy certifies that he made a sincere effort to contact 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 he certifies that the views of the other parties are appropriately reflected in the Motion.
Executed in accord with 10 C.F.R. § 2.304(d)
Signed (electronically) by Martin J. ONeill Martin J. ONeill, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1000 Louisiana Street, Suite 4000 Houston, TX 77002 Phone: (713) 890-5710 Fax: (713) 890-5001 E-mail: martin.oneill@morganlewis.com COUNSEL FOR ENTERGY NUCLEAR OPERATIONS, INC.
1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-247-LR and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
) June 20, 2013 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305 (as revised), I hereby certify that, on this date, a copy of Entergys Motion for Leave to File, and to Request the Admission of, Hearing Exhibit ENT000608 was served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned proceeding.
Signed (electronically) by Lance A. Escher Lance A. Escher, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1111 Pennsylvania Ave. NW Washington, DC 20004 Phone: (202) 739-5080 Fax: (202) 739-3001 E-mail: lescher@morganlewis.com COUNSEL FOR ENTERGY NUCLEAR OPERATIONS, INC.
DB1/ 74498629.1