ML15331A158

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Official Exhibit - NYS000464-00-BD01 - Declaration of John J. Sipos.
ML15331A158
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 11/09/2012
From: Sipos J
State of NY, Office of the Attorney General
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23737, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML15331A158 (3)


Text

United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of: Entergy Nuclear Operations, Inc.

(Indian Point Nuclear Generating Units 2 and 3) NYS000464 ASLBP #: 07-858-03-LR-BD01 Submitted: November 9, 2012 Docket #: 05000247 l 05000286 Exhibit #: NYS000464-00-BD01 Identified: 11/5/2015 Admitted: 11/5/2015 Withdrawn:

Rejected: Stricken:

Other:

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. November 9, 2012


x DECLARATION OF JOHN J. SIPOS Pursuant to 28 U.S.C. § 1746, John J. Sipos hereby declares as follows:

1. I serve as an Assistant Attorney 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 Contention NYS-38/RK-TC-5.
2. Accompanying this declaration as Exhibit NYS000454 is a true and correct copy of the document entitled Comparison of GALL Rev. 1 with GALL Rev. 2 on Steam Generator Divider Plates, that bears a date of November 9, 2012, and which was prepared by the State of New York.
3. Also accompanying this declaration as Exhibit NYS000455 is a true and correct copy of the document entitled Comparison of GALL Rev. 1 with GALL Rev. 2 on Tube Sheet Welds, that bears a date of November 9, 2012, and which was prepared by the State of New York.
4. Also accompanying this declaration as Exhibit NYS000456 is a true and correct copy of the document entitled History of Steam Generators, that bears a date of November 9, NYS000464 Submitted: November 9, 2012 2012, and which was prepared by the State of New York.
5. Also accompanying this declaration as Exhibit NYS000457 is a true and correct copy of the document prepared by the NRC Office of Inspector General entitled NRCs Response To The February 15,2000, Steam Generator Tube Rupture At Indian Point Unit 2 Power Plant, that bears a date of August 29, 2000.
6. Also accompanying this declaration as Exhibit NYS000458 is a true and correct copy of an email from Kenneth Karwoski to Meena Khanna that includes a document entitled Steam Generator Replacements Completed, that bears a date of October 8, 2009 and has an ADAMS Accession Number of 100750361.
7. Also accompanying this declaration as Exhibit NYS000459 is a true and correct copy of the document entitled Vermont Yankee Integrated Inspection Report 05000271/2011011, that bears a date of December 22, 2011 (ML113560064).
8. Also accompanying this declaration as Exhibit NYS000460 is a true and correct copy of the document entitled Letter to William Dean from Sarah Hoffman (State of Vermont DPS), that bears a date of December 23, 2011.
9. Also accompanying this declaration as Exhibit NYS000461 is a true and correct copy of the document entitled EDO Principal Correspondence Control, that includes a March 16, 2012 letter from U.S. Representative Edward Markey to U.S. NRC Chair Gregory Jaczko that bears a date of April 17, 2012 (ML12083A128).
10. Also accompanying this declaration as Exhibit NYS000462 is a true and correct copy of the document entitled NRC Inspection Report 05000271/2012008 that bears a date of April 20, 2012 (ML12103A406).
11. Also accompanying this declaration as Exhibit NYS000463 is a true and correct NYS000464 Submitted: November 9, 2012 copy of the document entitled NRC/EPRI Steam Generator Task Force Meeting that bears a date of August 21, 2012 (ML12234A683).
12. I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 9, 2012 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 United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of: Entergy Nuclear Operations, Inc.

(Indian Point Nuclear Generating Units 2 and 3) NYS000464 ASLBP #: 07-858-03-LR-BD01 Submitted: November 9, 2012 Docket #: 05000247 l 05000286 Exhibit #: NYS000464-00-BD01 Identified: 11/5/2015 Admitted: 11/5/2015 Withdrawn:

Rejected: Stricken:

Other:

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. November 9, 2012


x DECLARATION OF JOHN J. SIPOS Pursuant to 28 U.S.C. § 1746, John J. Sipos hereby declares as follows:

1. I serve as an Assistant Attorney 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 Contention NYS-38/RK-TC-5.
2. Accompanying this declaration as Exhibit NYS000454 is a true and correct copy of the document entitled Comparison of GALL Rev. 1 with GALL Rev. 2 on Steam Generator Divider Plates, that bears a date of November 9, 2012, and which was prepared by the State of New York.
3. Also accompanying this declaration as Exhibit NYS000455 is a true and correct copy of the document entitled Comparison of GALL Rev. 1 with GALL Rev. 2 on Tube Sheet Welds, that bears a date of November 9, 2012, and which was prepared by the State of New York.
4. Also accompanying this declaration as Exhibit NYS000456 is a true and correct copy of the document entitled History of Steam Generators, that bears a date of November 9, NYS000464 Submitted: November 9, 2012 2012, and which was prepared by the State of New York.
5. Also accompanying this declaration as Exhibit NYS000457 is a true and correct copy of the document prepared by the NRC Office of Inspector General entitled NRCs Response To The February 15,2000, Steam Generator Tube Rupture At Indian Point Unit 2 Power Plant, that bears a date of August 29, 2000.
6. Also accompanying this declaration as Exhibit NYS000458 is a true and correct copy of an email from Kenneth Karwoski to Meena Khanna that includes a document entitled Steam Generator Replacements Completed, that bears a date of October 8, 2009 and has an ADAMS Accession Number of 100750361.
7. Also accompanying this declaration as Exhibit NYS000459 is a true and correct copy of the document entitled Vermont Yankee Integrated Inspection Report 05000271/2011011, that bears a date of December 22, 2011 (ML113560064).
8. Also accompanying this declaration as Exhibit NYS000460 is a true and correct copy of the document entitled Letter to William Dean from Sarah Hoffman (State of Vermont DPS), that bears a date of December 23, 2011.
9. Also accompanying this declaration as Exhibit NYS000461 is a true and correct copy of the document entitled EDO Principal Correspondence Control, that includes a March 16, 2012 letter from U.S. Representative Edward Markey to U.S. NRC Chair Gregory Jaczko that bears a date of April 17, 2012 (ML12083A128).
10. Also accompanying this declaration as Exhibit NYS000462 is a true and correct copy of the document entitled NRC Inspection Report 05000271/2012008 that bears a date of April 20, 2012 (ML12103A406).
11. Also accompanying this declaration as Exhibit NYS000463 is a true and correct NYS000464 Submitted: November 9, 2012 copy of the document entitled NRC/EPRI Steam Generator Task Force Meeting that bears a date of August 21, 2012 (ML12234A683).
12. I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 9, 2012 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