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Category:Legal-Correspondence
MONTHYEARML22222A0872022-08-10010 August 2022
Stations, Units 1 & 2, Amended and Restated Master Decommissioning Trust Agreement
ML21099A0462021-04-0808 April 2021
4-8-21 Docketing Statement (DC Cir.)(Case No. 21-1084)
ML21099A0492021-04-0808 April 2021
Nonbinding Statement of Issues (DC Cir.)(Case No. 21-1084)
ML21097A2272021-04-0707 April 2021
4-7-21 F.R.A.P 26.1 Corporate Disclosure Statement (DC Cir.)(Case No. 21-1080)
ML21097A2292021-04-0707 April 2021
4-7-21 Docketing Statement (DC Cir.)(Case No. 21-1080)
ML21097A2282021-04-0707 April 2021
4-7-21 Nonbinding Statement of Issues (DC Cir.)(Case No. 21-1080)
ML21097A0252021-03-12012 March 2021
3-12-21 Amended Petition for Review (DC Cir.)(Case No. 21-1084)
ML21054A3122021-02-19019 February 2021
Entry of Appearance (DC Cir.)(Case No. 21-1037)
ML21029A1172021-01-28028 January 2021
1-28-21 Notice of Docketing (DC Cir.)(Case No. 21-1037)
ML21029A1282021-01-28028 January 2021
Entry of Appearance (DC Cir.)(Case No. 21-1037)
ML21029A1102021-01-22022 January 2021
1-22-21 Petition for Review (DC Cir.)(Case No. 21-1037)
ML17065A0302017-04-13013 April 2017
OEDO-16-00411: Final Director'S Decision DD-17-01 Under 10 CFR 2.206 in the Matter of Entergy Nuclear Operations, Inc., Et Al
ML16193A3522016-06-23023 June 2016
Friends of the Earth Reply to Mandamus Petition (DC Cir) 06-23-2016
ML15317A5312015-11-13013 November 2015
NYS Cover Letter
ML14093A1852014-03-31031 March 2014
New York State Department of State File #F-2012-1028 Consistency Certification for Entergy Nuclear Indian Point 2 and Entergy Nuclear Indian Point 3 License Renewal Application
ML14056A3972014-02-14014 February 2014
from Robert Brodsky to Nrc/Ogc Brodsky Remand Brief Full
ML13199A0232013-01-0707 January 2013
Brodsky V. U.S. Nuclear Regulatory Commission
ML12343A0272012-12-0707 December 2012
NRC Staff Pre-Filed Evidentiary Hearing Exhibit NRCR20015, NRC Staff'S Statement of Position Concerning Contention NYS-5 (Buried Pipes and Tanks), Revised
ML11346A0102011-12-0101 December 2011
Clearwater Inc'S Mandatory Witness Disclosure Update Pursuant to CFR Section 2.336 and Letter
ML11243A1092011-08-31031 August 2011
2011/08/31 - Indian Point - Letter to Atomic Safety and Licensing Board, NRC Staff Has Issued Supplement 1 to the Safety Evaluation Report Related to the License Renewal of Indian Point Nuclear Generation Unit No. 2 & 3 (SER)
ML11230B3542011-08-18018 August 2011
Letter to Indian Point License Renewal Board Re Status of SER Supplement
ML11220A3482011-07-29029 July 2011
Hudson River Sloop Clearwater, Inc'S Mandatory Disclosure Update Pursuant to 10CFR2.336
ML11208C3092011-07-27027 July 2011
Indian Point - Letter from Sherwin Turk to Licensing Board
ML11195A1262011-07-14014 July 2011
Indian Point - Letter from Sherwin Turk to the Licensing Board, Advising That Consultations Between NMFS, the Staff and the Applicant Have Been Extended
ML11182B0242011-07-0101 July 2011
Indian Point - Letter to ASLB
ML11181A3792011-06-30030 June 2011
06/30/2011 Indian Point License Renewal - Letter to Aslb Re Adoption of Electronic Information Exchange
ML11152A1292011-05-27027 May 2011
State of New York Supports NRC Staff'S Suggestion That the ASLB Convene a Conference to Discuss Potential Impacts on the Schedule for Filing Testimony
ML11159A2362011-05-26026 May 2011
2011/05/26-New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement for the License Renewal of Indian Point Units 2 and 3, Buchanan, New York
ML11146A1662011-05-26026 May 2011
License Renewal - Letter to Aslb Regarding SER Supplement
ML11146A0772011-05-25025 May 2011
Indian Point - Ltr to ASLB Frm S. Turk
ML11146A0582011-05-25025 May 2011
Indian Point - Ltr to J. Dean from S. Turk
ML11136A1932011-05-13013 May 2011
Indian Point - Letter to Atomic Safety and Licensing Board
ML11133A1092011-05-12012 May 2011
Indian Point - Letter to Licensing Board
ML11133A1122011-05-12012 May 2011
Indian Point - Corrected Log Supplement 26 Hearing File - Transmittal Letter
ML11117A1892011-04-19019 April 2011
Submittmal of Declaration of Dr. Arjun Makhijani in Support of Emergency Petition to Suspend All Pending Reactor Licensing Decisions & Relating Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Daiichi Nuclear ...
ML1112404372011-03-18018 March 2011
State of New York'S Combined Reply to NRC Staff and Entergy'S Answers to Contention 12-C Concerning NRC Staff'S December 2010 Feis and the Underestimation of Decontamination and Clean Up Costs Associated with a Severe Reactor Accident in Ny
ML1107701442011-03-0404 March 2011
Hudson River Sloop Clearwater, Inc.'S, Urgent Request for Extension of Time to Reply to NRC Staff and Entergy'S Answer to Amended Environmental Justice Contention
ML1107000512011-03-0303 March 2011
Hudson River Sloop Clearwater, Inc.'S Request for Extension of Time and Answer in Support of New York State'S Analysis of Alternatives Contention
ML1034908202010-12-15015 December 2010
Indian Point - Letter to ASLB
ML1036203112010-12-10010 December 2010
City of New York Requests That the Contact Information for Michael Delaney as Its Representative in the Matter of Entergy Nuclear Operations, Inc., Be Updated to Reflect New Address
ML1032104242010-10-25025 October 2010
Contact Information Change
ML1028507462010-10-12012 October 2010
NRC Staff Letter to Ny State on Contention 35 and 36
ML1025304342010-09-0101 September 2010
Notification of Change in Business Address for Riverkeeper
ML1023001472010-08-12012 August 2010
State of New York'S Request for Oral Argument on the Merits of Entergy and Staff'S Appeal Should the Commission Accept Interlocutory Review
ML1023103252010-08-10010 August 2010
Entergy Nuclear Operations Inc. (Indian Point Nuclear Generating Units 1 & 2), Notification of Entergy'S Submittal Regarding Completion of Commitment 33 for Indian Point Units 2 & 3
ML1025304352010-07-27027 July 2010
Notification of Change in Business Address for Manna Jo Greene, Environmental Director, Hudson River Sloop Clearwater, Inc
ML1020301202010-07-15015 July 2010
Notification of Entergy'S Submittal of the Reactor Vessel Internals Program for Indian Point Units 2 & 3
ML1017301812010-06-16016 June 2010
2010/06/16-Entergy's Comments on the Draft Scheduling Order for the IPEC License Renewal Proceeding
ML1014701752010-05-27027 May 2010
2010/05/27-Indian Point - Letter to Aslb Attaching a Revised Schedule for the Staff'S Review of the Indian Point Units 2 and 3 License Renewal Application
ML1013106012010-05-0404 May 2010
2010/05/04-Pre-Hearing Litigation Milestone Events on Proposed Dates, License Renewal Application for Indian Point Units 2 & 3
2022-08-10
[Table view]
Category:Legal-Correspondence/Maintenance
MONTHYEARML0417503332004-06-10010 June 2004
G20040419/LTR-04-0388 - Ltr. Nancy Yatten Borough of Tenafly Resolution R04-167 Regarding Concerns of Terrorists Focusing on Nuclear Power Plants, Resolution Urging the Commission to Close Indian Point
NL-04-026, Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Stations 2 and 3, Answer to February 20, 2004 Revised NRC Order Regarding Interim Inspection Requirements for Reactor Pressure Vessel Heads2004-03-11011 March 2004
Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Stations 2 and 3, Answer to February 20, 2004 Revised NRC Order Regarding Interim Inspection Requirements for Reactor Pressure Vessel Heads
ML0406805862004-02-24024 February 2004
Riverkeeper, Inc. Vs Collins - District Courts Decision Dismissed
ML0329703392003-10-15015 October 2003
Letter Requesting Availability for Oral Argument, Dated October 15, 2003
ML0329703452003-09-22022 September 2003
Letter to Court of Appeals Enclosing Brief of Petitioner, Dated September 22, 2003
ML0327213022003-09-12012 September 2003
Declaration of Karl Coplan in Response to Federal Respondents Motion to Dismiss, Dated 09/12/03
ML0323906202003-08-18018 August 2003
Request to Remove Supplemental Reports from the Amicus Briefs, Dated 08/18/03
ML0323003892003-08-0505 August 2003
Letter to Court Informing of Additional Staff Names, Dated 08/05/03
ML0325102492003-08-0202 August 2003
Nrc'S Motion to Dismiss Petition for Review for Lack of Jurisdiction Referred to Merits Panel, Dated 08/28/03
ML0323800212003-07-30030 July 2003
Motion for Leave to File Memorandum in Opposition to Respondent'S Motion to Dismiss, Dated 07/30/03
ML0319900412003-07-0707 July 2003
Oral Argument, Dated July 7, 2003
ML0417602742003-06-18018 June 2003
Petitioner'S Comments to the Commission'S Draft Decision Petitioner'S Section 2.206 Request for Review of Indian Point Energy Center Units 2 and 3
ML0318903502003-06-16016 June 2003
Letter Enclosing Utility Respondents' Response in Support of Federal Respondents' Motion to Dismiss, Dated June 16, 2003
ML0318903342003-06-16016 June 2003
Memorandum in Opposition to Federal Respondents' Motion to Dismiss, Dated June 16, 2003
ML0316007882003-05-21021 May 2003
Court'S Notification of Temporarily Retention of Certified Index of Record, Dated 5/21/03
ML0319005622003-05-15015 May 2003
Joint Appendix: Volume 1 of 3
ML0319103122003-05-15015 May 2003
Joint Appendix: Volume 3 of 3
ML0307806992003-02-12012 February 2003
Pre-Argument Statement, Dated February 12, 2003
ML0307806912003-02-12012 February 2003
Amended Petition for Review, Dated February 12, 2003
ML0307806732003-02-10010 February 2003
Petition for Review, Dated February 11, 2003
ML0318903582002-11-18018 November 2002
Special Appendix, Dated November 18, 2002
ML0224703532002-08-22022 August 2002
Response of Proposed Intervenors to Respondents' Motions to Suspend Briefing Schedule for Consideration of Motion to Dismiss & Motion to Dismiss
ML0224006402002-08-21021 August 2002
Letter from L. Michael Rafky to the Licensing Board Informing That Entergy Does Not Intend to Submit Written Filings in This Proceeding Prior to the Scheduled August 27, 2002 Prehearing Conference
ML0311504372002-08-20020 August 2002
Letter from Jared K. Heck to Administrative Judges Informing That the NRC Staff Does Not Intend to File an Answer to Contentions by the August 22, 2002, Deadline, But Will Respond to Riverkeeper'S Petition for Intervention and Subsequent Fi
ML0303706392002-08-14014 August 2002
Respondents' Motion to Dismiss, Dated August 14, 2002
ML0319005362002-08-0909 August 2002
Joint Appendix: Volume 2 of 3
ML0222101582002-08-0505 August 2002
Letter from Sara E. Brock to Administrative Judges Re Entergy'S Amendment Request for a one-time Change to the Technical Specification Surveillance Requirement 4.4.A.3 to Revise the Frequency of the Containment Integrated Leak Rate Test
ML0303706572002-07-26026 July 2002
Letter to R. Mackechnie, U.S. Court of Appeals, Dated July 26, 2002, Acknowledging Court'S Docketing Letter and Certified Index of Record
ML0218406022002-06-0404 June 2002
Letter from the Secretary to the Parents Concerned About Indian Point Denying That Organization'S Motion for Reconsideration of the Secretary'S 3/28/2002 Denial of the Organization'S Petition to Reopen the Record
ML0212203602002-05-0202 May 2002
5/2/2002 - Letter to Administrative Judges, Correcting Error in Footnote 8 on Page 7 of the Filing Lists for NRC Staff'S Response to Riverkeeper, Inc.'S for Leave to Intervene and Request for a Hearing
ML0527001922002-04-0101 April 2002
Letter from Janice E. Moore to Annette Vietti-Cook Regarding the Petition for Leave to Intervene and Request for Hearing Filed by the Pace Environmental Litigation Clinic, Inc. on Behalf of Riverkeeper, Inc
ML0218405662002-03-28028 March 2002
Letter from the Secretary to the Parents Concerned About Indian Point Denying That Organization'S Petition to Reopen the Record Concerning the Indian Point Emergency Evacuation Plan
ML0226805752002-03-16016 March 2002
Summons Issued to NRC by Us District Court for Southern New York in Matter of Case No. 02 Cv 2474 Re Request That Commission & Commisioners Promulagate & Enforce Regulations for Installation of Appropriate Technology to Protect Nuclear Powe
2004-06-10
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Text
ShawPittman LLP A Limited Liability Pmesnhlp IdbdidgPftiunmal Ac prations JAY E SILBERG (202) 663-8063 Jayslbergeshawpttmanrom July 7, 2003 BY FACSIMILE AND U.S. MAIL Roseann B. MacKechnie, Clerk of the Court U.S. Court of Apeals for the Second Circuit United States Court House 40 Foley Square New York, NY 10007 Attention: Operations Division, Calendar Team RE: Riverkeeper. Inc. v. Collins et al., Docket No. 034313
Dear Ms. MacKechnie:
On June 3, 2003, the Federal Respondents filed a motion to dismiss this case for lack ofjurisdiction. The Utility Respondents (Entergy Nuclear Indian Point 2, LLC; Entergy Nuclear Indian Point 3, LLC; and Entergy Nuclear Operations, Inc.) filed a response in support of the motion on June 16, 2003 and Petitioner filed a memorandum in opposition on June 17, 2003. We understand that the motion is scheduled to be decided on submission on July 28, 2003. In a June 26, 2003 letter, Petitioner requested that the Court hear oral argument on the motion. By letter dated July 2, 2003, the Federal Respondents stated their belief that no oral argument was necessary.
The Utility Respondents agree that oral argument is not necessary. As set forth in our June 16 response, we believe that the Supreme Court's Hecder v. Chaney decision, 470 U.S. 821 (1985), is clearly dispositive, a conclusion supported by the Second Circuit cases applying Heckler v. Chaney as well as the cases in the First, Seventh and D.C.
Circuits involving the Nuclear Regulatory Commission, all of which are discussed in the pleadings already before the Court.
Nor do we believe that Local Rule 27(b) requires that oral argument be provided merely because the party opposing the motion requests it. Of course, should the Court Washington DC Northem Vlrgin12 New York Los Angeles 2300 N Stfeet, NW Washington, DC 20037-1128 202.653.6000 Fax:202.663.8007 www.showpittman.com London
ShawPittman LLP Roseann B. MacKechnie, Clerk of the Court July 7, 2003 Page 2 chose to hear oral argument, the Utility Respondents would participate. However, based on the well established legal principles involved, we would request that the Court decide the case as presented.
Sincerely, -s .d-
. Sberg Counsel for Utility Respondents cc: Aavid Cummings, Esq.
Karl Coplan, Esq.
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