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Category:Legal-Intervention Petition
MONTHYEARML1107503812011-03-10010 March 2011 Entergy'S Response to New England Coalition'S Motion for Stay and Request for Further Opportunity for Hearings ML1036300302010-12-23023 December 2010 Entergy'S Response to the Supplement to New England Coalition'S Petition for Commission Review of LBP-10-19 ML1033403292010-11-22022 November 2010 Entergy'S Answer Opposing New England Coalition'S Petition for Commission Review of LBP-10-19 ML1028002492010-09-30030 September 2010 New England Coalition'S Answer & Opposition to Entergy'S Motion to Strike Declaration of Paul Blanch ML1027204022010-09-20020 September 2010 New England Coalition'S Reply to NRC Staff and Entergy Nuclear Vermont Yankee Opposition to New England Coalition'S Motion to Reopen the Hearing & Reply to NRC Staff'S Answer to Proposed New Contention ML1026003772010-09-14014 September 2010 Entergy'S Answer Opposing New England Coalition'S Motion to Reopen ML1007403702010-03-12012 March 2010 Entergy'S Response in Opposition to New England Coalition'S Stay Request ML0922400652009-08-0303 August 2009 Entergy'S Response in Opposition to New England Coalition'S Petition for Review of LBP-09-09 ML0921202202009-07-23023 July 2009 New England Coalition'S Petition for Review of the Licensing Board'S Full Initial Decision, LBP-09-09 ML0916702632009-06-0808 June 2009 New England Coalition'S Opposition to Entergy'S Motion to Strike New England Coalition'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention ML0915404042009-05-26026 May 2009 Nec'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention ML0914203732009-05-18018 May 2009 Entergy'S Opposition to Nec'S Motion to File a Timely New Contention ML0913400192009-05-0707 May 2009 New England Coalition'S Reply to Nrc'S Staff and Entergy Answers to New England Coalition'S Motion to Hold in Abeyance Action on It'S Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report ML0912708592009-05-0101 May 2009 Entergy'S Opposition to New England Coalition'S Motion to Hold Action on Proposed Contention in Abeyance Until Issuance of NRC Staff Supplemental Safety Evaluation Report ML0908404222009-03-10010 March 2009 Final Calculations of Record for the Confirmatory Environmentally Assisted Fatigue (Cufen) Analyses on the Reactor Pressure Vessel Core Spray (CS) and Recirculation Outlet (RO) Nozzles at Vermont Yankee ML0912101052009-03-0909 March 2009 New England Coalition'S Petition for Leave Reply to Entergy Responses to New England Coalition'S Motion to Alter or Amend the Schedule in the Above Captioned Proceeding ML0907711422009-03-0909 March 2009 Entergy'S Opposition to New England Coalition'S Motion to Alter or Amend the Schedule ML0901400782009-01-0707 January 2009 Entergy'S Opposition to New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial Initial Decision ML0901400792008-12-29029 December 2008 Entergy'S Answer Opposing Motion by New York Et Al. for Leave to Submit Brief Amici Curiae ML0901602092008-12-19019 December 2008 New England Coalition'S Response to NRC Staff'S Petition for Review of the Licensing Board'S Partial Initial Decision, LBP-08-25 ML0900606092008-12-19019 December 2008 Entergy'S Answer in Support of NRC Staff'S Petition for Review of the Licensing Board'S Partial Initial Decision ML0836600342008-12-19019 December 2008 Vermont Department of Public Service Opposition to Petition for Review of Partial Initial Decision LBP-08-25 ML0836401982008-12-11011 December 2008 Entergy'S Answer to Commonwealth of Massachusetts Petition for Review of LBP-08-25 and Request for Consolidated Ruling ML0835205232008-12-10010 December 2008 Entergy'S Response in Opposition to New England Coalition'S Motion to Extend Time to File Petition for Review ML0835004492008-12-0404 December 2008 Entergy'S Motion for Clarification ML0835100872008-12-0404 December 2008 Entergy'S Opposition to New England Coalition'S Motion to Extend Time to File Motion for Reconsideration ML0824018252008-08-25025 August 2008 Vermont Yankee - NRC Staff'S Proposed Findings of Fact and Conclusion of Law and Order in the Form of an Initial Decision ML0819905482008-07-15015 July 2008 Vermont Yankee - NRC Staff Letter to Board Regarding Evidentiary Hearing Attendees ML0820501022008-07-15015 July 2008 Entergy'S Response to July 11, 2008 Board Order ML0820501012008-07-15015 July 2008 Entergy'S Reply to Responses to Licensing Board'S Questions ML0820406152008-07-15015 July 2008 Vermont Department of Public Service Response to Entergy and NRC Staff Brief on Pre-Trial Legal Issues ML0819806542008-07-15015 July 2008 Vermont Yankee - NRC Staff'S Reply Brief ML0819704842008-07-0909 July 2008 Entergy'S Answers to Licensing Board Questions ML0819202482008-07-0909 July 2008 Vermont Yankee - Nrc'S Brief in Response to Board Order ML0819805252008-07-0808 July 2008 Joint Stipulation ML0819704802008-07-0707 July 2008 Entergy'S Response to Vermont Department of Public Service Motion for Modification of the Scheduling Order to Facilitate Full Compliance with 10 C.F.R. 2.323(b) ML0818504242008-07-0202 July 2008 Vermont Yankee - NRC Staff'S Response to Vermont Department of Public Service'S Motion to Modify the Schedule ML0819100872008-06-30030 June 2008 New England Coalition, Inc'S Opposition to Entergy'S and the NRC Staff'S Motions in Limine to Exclude Rebuttal Testimony of Ulrich Witte ML0819200412008-06-30030 June 2008 Entergy'S Response in Support of Staff'S Motion in Limine to Exclude Witte Rebuttal Testimony ML0818304142008-06-23023 June 2008 Entergy'S Response in Opposition to NEC Motion to File Untimely Rebuttal Testimony by Ulrich Witte ML0817807432008-06-20020 June 2008 Filing Discussing Proprietary Documents in the Matter of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc ML0817107262008-06-19019 June 2008 Vermont Yankee - NRC Staff'S Response to Nec'S Motion to Strike NRC Staff'S Rebuttal Testimony Concerning NEC Contention 4 ML0817800972008-06-19019 June 2008 Entergy'S Response in Support of Staff'S Motion in Limine ML0816305762008-06-0505 June 2008 2008/06/05-Vermont Yankee License Renewal Proceeding: June 24 Call ML0814905522008-05-20020 May 2008 Certificate of Disclosure of Sarah Hofmann, for the Vermont Department of Public Service Certifying Current with Disclosures Pursuant to 10 C.F.R. 2.336 That Are Relevant and Not Privileged to the Contentions Now Being Considered ML0814306502008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.; Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club.. ML0814906102008-05-15015 May 2008 2008/05/15-Supplemental Petition by Collective Petitioners for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0814306512008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.: Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club: New Jersey.. ML0816402452008-05-15015 May 2008 2008/05/15-Supplemental Petition by Listed Companies for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews, for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0813501902008-05-0606 May 2008 Commonwealth of Massachusetts' Notice of Intent to Participate as an Interested State 2011-03-10
[Table view] Category:Responses and Contentions
MONTHYEARML1107503812011-03-10010 March 2011 Entergy'S Response to New England Coalition'S Motion for Stay and Request for Further Opportunity for Hearings ML1036300302010-12-23023 December 2010 Entergy'S Response to the Supplement to New England Coalition'S Petition for Commission Review of LBP-10-19 ML1033403292010-11-22022 November 2010 Entergy'S Answer Opposing New England Coalition'S Petition for Commission Review of LBP-10-19 ML1028002492010-09-30030 September 2010 New England Coalition'S Answer & Opposition to Entergy'S Motion to Strike Declaration of Paul Blanch ML1027204022010-09-20020 September 2010 New England Coalition'S Reply to NRC Staff and Entergy Nuclear Vermont Yankee Opposition to New England Coalition'S Motion to Reopen the Hearing & Reply to NRC Staff'S Answer to Proposed New Contention ML1026003772010-09-14014 September 2010 Entergy'S Answer Opposing New England Coalition'S Motion to Reopen ML1007403702010-03-12012 March 2010 Entergy'S Response in Opposition to New England Coalition'S Stay Request ML0922400652009-08-0303 August 2009 Entergy'S Response in Opposition to New England Coalition'S Petition for Review of LBP-09-09 ML0921202202009-07-23023 July 2009 New England Coalition'S Petition for Review of the Licensing Board'S Full Initial Decision, LBP-09-09 ML0916702632009-06-0808 June 2009 New England Coalition'S Opposition to Entergy'S Motion to Strike New England Coalition'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention ML0915404042009-05-26026 May 2009 Nec'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention ML0914203732009-05-18018 May 2009 Entergy'S Opposition to Nec'S Motion to File a Timely New Contention ML0913400192009-05-0707 May 2009 New England Coalition'S Reply to Nrc'S Staff and Entergy Answers to New England Coalition'S Motion to Hold in Abeyance Action on It'S Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report ML0912708592009-05-0101 May 2009 Entergy'S Opposition to New England Coalition'S Motion to Hold Action on Proposed Contention in Abeyance Until Issuance of NRC Staff Supplemental Safety Evaluation Report ML0908404222009-03-10010 March 2009 Final Calculations of Record for the Confirmatory Environmentally Assisted Fatigue (Cufen) Analyses on the Reactor Pressure Vessel Core Spray (CS) and Recirculation Outlet (RO) Nozzles at Vermont Yankee ML0912101052009-03-0909 March 2009 New England Coalition'S Petition for Leave Reply to Entergy Responses to New England Coalition'S Motion to Alter or Amend the Schedule in the Above Captioned Proceeding ML0907711422009-03-0909 March 2009 Entergy'S Opposition to New England Coalition'S Motion to Alter or Amend the Schedule ML0901400782009-01-0707 January 2009 Entergy'S Opposition to New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial Initial Decision ML0901400792008-12-29029 December 2008 Entergy'S Answer Opposing Motion by New York Et Al. for Leave to Submit Brief Amici Curiae ML0901602092008-12-19019 December 2008 New England Coalition'S Response to NRC Staff'S Petition for Review of the Licensing Board'S Partial Initial Decision, LBP-08-25 ML0900606092008-12-19019 December 2008 Entergy'S Answer in Support of NRC Staff'S Petition for Review of the Licensing Board'S Partial Initial Decision ML0836600342008-12-19019 December 2008 Vermont Department of Public Service Opposition to Petition for Review of Partial Initial Decision LBP-08-25 ML0836401982008-12-11011 December 2008 Entergy'S Answer to Commonwealth of Massachusetts Petition for Review of LBP-08-25 and Request for Consolidated Ruling ML0835205232008-12-10010 December 2008 Entergy'S Response in Opposition to New England Coalition'S Motion to Extend Time to File Petition for Review ML0835004492008-12-0404 December 2008 Entergy'S Motion for Clarification ML0835100872008-12-0404 December 2008 Entergy'S Opposition to New England Coalition'S Motion to Extend Time to File Motion for Reconsideration ML0824018252008-08-25025 August 2008 Vermont Yankee - NRC Staff'S Proposed Findings of Fact and Conclusion of Law and Order in the Form of an Initial Decision ML0819905482008-07-15015 July 2008 Vermont Yankee - NRC Staff Letter to Board Regarding Evidentiary Hearing Attendees ML0820501022008-07-15015 July 2008 Entergy'S Response to July 11, 2008 Board Order ML0820501012008-07-15015 July 2008 Entergy'S Reply to Responses to Licensing Board'S Questions ML0820406152008-07-15015 July 2008 Vermont Department of Public Service Response to Entergy and NRC Staff Brief on Pre-Trial Legal Issues ML0819806542008-07-15015 July 2008 Vermont Yankee - NRC Staff'S Reply Brief ML0819704842008-07-0909 July 2008 Entergy'S Answers to Licensing Board Questions ML0819202482008-07-0909 July 2008 Vermont Yankee - Nrc'S Brief in Response to Board Order ML0819805252008-07-0808 July 2008 Joint Stipulation ML0819704802008-07-0707 July 2008 Entergy'S Response to Vermont Department of Public Service Motion for Modification of the Scheduling Order to Facilitate Full Compliance with 10 C.F.R. 2.323(b) ML0818504242008-07-0202 July 2008 Vermont Yankee - NRC Staff'S Response to Vermont Department of Public Service'S Motion to Modify the Schedule ML0819100872008-06-30030 June 2008 New England Coalition, Inc'S Opposition to Entergy'S and the NRC Staff'S Motions in Limine to Exclude Rebuttal Testimony of Ulrich Witte ML0819200412008-06-30030 June 2008 Entergy'S Response in Support of Staff'S Motion in Limine to Exclude Witte Rebuttal Testimony ML0818304142008-06-23023 June 2008 Entergy'S Response in Opposition to NEC Motion to File Untimely Rebuttal Testimony by Ulrich Witte ML0817807432008-06-20020 June 2008 Filing Discussing Proprietary Documents in the Matter of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc ML0817107262008-06-19019 June 2008 Vermont Yankee - NRC Staff'S Response to Nec'S Motion to Strike NRC Staff'S Rebuttal Testimony Concerning NEC Contention 4 ML0817800972008-06-19019 June 2008 Entergy'S Response in Support of Staff'S Motion in Limine ML0816305762008-06-0505 June 2008 2008/06/05-Vermont Yankee License Renewal Proceeding: June 24 Call ML0814905522008-05-20020 May 2008 Certificate of Disclosure of Sarah Hofmann, for the Vermont Department of Public Service Certifying Current with Disclosures Pursuant to 10 C.F.R. 2.336 That Are Relevant and Not Privileged to the Contentions Now Being Considered ML0814306502008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.; Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club.. ML0814906102008-05-15015 May 2008 2008/05/15-Supplemental Petition by Collective Petitioners for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0814306512008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.: Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club: New Jersey.. ML0816402452008-05-15015 May 2008 2008/05/15-Supplemental Petition by Listed Companies for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews, for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0813501902008-05-0606 May 2008 Commonwealth of Massachusetts' Notice of Intent to Participate as an Interested State 2011-03-10
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September 3, 2004 In the Matter of Docket No. 5 0-27 1 ENTERGY NUCLEAR VEMQNT YAP4 and ENTERGY NUCLEAR OPEUTIOWS, WC. DOCKETED USNRC (Vermont Yankee Nuclear Power Station)
I September 10, 2004 (1:30PM)
OFFICE OF SECRETARY Secretary RULEMAKINGS AND United States Nuclear Regulatory Commission ADJUDICATIONS STAFF Washington, DC 20555-0001 ATT: Rulemakings and Adjudications Staff Dear Rdernakings and Adjudications Staff Enclosed please find for filing in the above captioned matter an original and two copies of EXHIBIT F of DEMQNSTRATTON OF STANDING, DISCUSSION OF SCOPE OF PROCEEDING AND CONTENTIONS. The Document offered as EXHIBIT F is an Entergy Inter-Ofice Correspondence, titled Transition of Quality Control Fiincticams From Quality Assurance to Engineering Maintenance For Fleet Alignment, Rev 0, On September 2,2003, New England Coalition was made aware by counsel for Entergy that EXMIBIT F was not iizcluded with NEW E~~~~~~ GOALLTlONS REQUEST FOR A H EARWG, ETC. ,filed on Augusts 30,2004, even though EXHIBIT F was referenced on Page 10 under Basis for ~ o ~ 1. ~ e ~ ~ ~ o ~
New England Coalition found that EXHIBIT F had been omitted through a simple clerical e r m and promptly provided a copy via elertronic facsimile to Entergys counsel.
An electronically scanned version of EXHTSZT F was forwarded to all parties via e-mail on September 3, 2004. Service to all parties is also been pmvided to all parties via First Class U.S.Mai1.
New England Goalition sincerely regrets any confusion or inconvenience this inadvertent omission majj have caused Nit@or the parties.
Thank you for your consideration,
- Sincerely, Raymond Shadis Pro §e Representative New England Coaliticm Post Office Box 98 Edgecomb, Maine 04556 207-882-7SO1
~~~~~~~~~~~~~~~~~~~,~~~~~
E F
The line individualsw h perform inspections require a clarification $0mderstaand &e QAPM Section B.12.fantitjed, Tnnsgmtions.. This section stares, Inspections we pedomed by qualified personnel other than those who perfinned OK directly sbipelu-ised the work being inspected. Gihiie perfoming the inspections activity the inspectors hncti~ndlyreport t o the associated manager responsible for quality assurance. In ordm to address this sectim three topics need to be addressed; 6~71i& are tbe inspection functions, define what fwctionaliy reporting entails, and how will ~ c t i o n a l l yreporting be conununicated to maintenance and station personnel. The Corpomte Qudity Assurance mganhtion addressed each ofthe Ispics:
What are the InsPeeltima ~~~~~~~~s
- 1) Inspectian PIaPlning a. What activities are to be inspected
- b. What are the inspection techniques to be employed
- c. what is the acceptance criteria
- d. Identifyng who is responsible to perform the inspection
- 3) Results Documented a. Identification oftha inspector b.Type of observation utilized
- c. Record thc results ofthe inspection
- d. Were the results acceptable or unacceptable taken to rt~16redeficiency, generation ofa CR
- e. A~titiopa~
- 4) Unacceptable Rcsultts Evaluated h e C R issued resulted in an evaluation in the CR SySkem hanctisnalllv Remrting When performing my ofthe inspection functions, the inspector requires clarification, guidancc, intervention or resolution, this should be reported to fhe QA Manager W ~ will O take the necessary and apprapriate action.
CE I certifl that on September 4, 2004, copies of the foregoing -NEW ENGLAND COALITION'S REQTJEST FOR A E m G , EX IT F were served on the following by first-class mail (and/or e-mail on Segtsmber 3, 20041, as indicated below:
Rulemakings and Adjudications Staff Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 E-mail. 134 ~-2-1 h z ; D ~ ~ t ~ $.i.'< ~ikt-
- < ' +2 ld Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 7rc1 .--
E-mail: iJ.j, ?
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- I; 2~~
John M, Fulton, Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Sarah Hofmann Esq.
Special Counsel Department of Public Service 112 State Street -Drawer 20 Montpelier, VT 05620-2601 E-mail. S a c k Sq~fm.m: iiLiz . t 9
tl-b Anthony Z. Roisman, Esq.
National Legal Scholars Law Firin Stonewall Farm 84 East Thetford Road Lyme,NH 03786 E-mail: ai-ojsinar.,i~,~.iailev,
~;g:
Raymond Shadis