ML12334A484

Official Exhibit - NYS000044-00-BD01 - Declaration of Assistant Attorney General Lisa M. Burianek (Pft Burianek Decl. NYS-8)

ML12334A484
Person / Time
Site:	Indian Point
Issue date:	12/09/2011
From:	Burianek L State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21523, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12334A484 (3)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #: NYS000044-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn: NYS000044 Rejected: Stricken: Submitted: December 12, 2011 Other:

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 9, 2011

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x DECLARATION OF LISA M. BURIANEK Pursuant to 28 U.S.C. § 1746, Lisa M. Burianek 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 the State of New Yorks contention, NYS-8 (hereinafter NYS-8) which asserts that transformers are static devices that belong within the category of components for which an aging management program (AMP) is required under 10 C.F.R. § 54.21(a)(1)(i). NYS-8 also asserts that transformers are more similar to components which for which an AMP is required than those components for which an AMP is not required.

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

3. Attached to this declaration as Exhibit NYS000001 is a true and correct copy of the document entitled State of New York Hearing Exhibits List ("NYS Exhibits List"), Exh.

000001. NYS Exhibits List includes those exhibits relied upon and referenced in support of Contention NYS-8, NYS000002 through NYS000043.

4. Attached to this declaration as Exhibit NYS000039 is a true and correct copy of the document entitled Entergy Nuclear Northeast, Power Transformer Spare Purchase Recommendations, January 4, 2006, John Bonner (IPEC00071713-IPEC00071726).

5. Attached to this declaration as Exhibit NYS000040 is a true and correct copy of the document entitled EN Large Power Transformer Status (Feb. 15, 2007) (IPEC00071764-IPEC00071769)

6. Attached to this declaration as Exhibit NYS000041 is a true and correct copy of the document entitled Email; July 18, 2005 6:26 PM;

Subject:

IPEC Transformer Review; From:

J. Bonner; To: G. Bijoor, T.S. McCaffrey, V. Andreozzi; CC: R. Penny, J. Bonner, D. Morris (IPEC00071776-IPEC00071777).

7. Attached to this declaration as Exhibit NYS000042 is a true and correct copy of the document entitled Email String; August 7, 2008 2:46 PM;

Subject:

Risks; From: C. Jackson; To: J.J. Curry; August 7, 2008 3:02 PM;

Subject:

FW: Risks; From: J.J. Curry; To: C. Caputo; August 11, 2008 2:25 PM;

Subject:

RE: Risks; From: C. Caputo; To: J.J. Curry, C. Jackson; August 11, 2008 3:11 PM;

Subject:

RE: Risks; From: C. Jackson; To: C. Caputo, J.J. Curry; August 11, 2008 3:23 PM;

Subject:

RE: Risks; From: C. Caputo; To: C. Jackson, J.J. Curry (IPEC00091098-IPEC00091098).

8. Attached to this declaration as Exhibit NYS000043 is a true and correct copy of the publicly available document entitled Letter, M.H. Philips, Jr. and W.A. Horin, Nuclear Utility Group on Equipment Qualification to J.C. Hoyle, Acting Secretary, U.S. Nuclear Regulatory Commission (PDR Fiche 9412130158 941208) (Dec. 8, 1994)

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

Executed on December 9, 2011 Signed (electronically) by Lisa M. Burianek Assistant Attorneys General Office of the Attorney General of the State of New York The Capitol Albany, New York 12224 (518) 476-7398