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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
[Table view] |
Text
P'A T)/13 // qa March 27, 2006 UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC March 27, ,!006 (4:36pm)
Before the Atomic Safety and Licensing Board OFFICE OF SECRETARY
) RULEMAKINGS AND In the Matter of ) ADJUDICATIONS STAFF
) Docket No. 50-271 ENTERGY NUCLEAR VERMONT )
YANKEE, LLC and ENTERGY ) ASLBP No. 04-832-02-OLA NUCLEAR OPERATIONS, INC. ) iAm-e-ndment) ceOnnehLice
- -(Vermont Yankee Nuclear Power Station) )
)
ENTERGY'S RESPONSE TO NEW ENGLAND COALITION'S STATEMENT ON THE SCOPE OF NEW ENGLAND COALITION CONTENTION 3 Pursuant to the Atomic Safety and Licensing Board's ("Board") Order (Supplemental Schedule) dated March 14, 2006 ("Order") and its subsequent Order (Granting Motion for Enlargement of Time Related to NEC Contention 4 and Granting Enlargement of Time, Subject to Sanction, Related to NEC Contention 3) and subsequent Memorandum, both dated March 23, 2006, Applicants Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, tic.
(collectively "Entergy") hereby respond to the New England Coalition's ("NEC") Statement on the Scope of New England Coalition Contention 3 ("NEC Statement") dated March 20, 2006 (but actually served on the parties and the Board on March 21, 2006). In its Statement, NEC asserts that it "is convinced that any additional type of Large Transient Testing beyond the main steam isolation valve closure test and the generator load rejection test is not within the scope of Conten-tion 3 as admitted." Id. X As a result, Applicants see no need to reply to NEC's irrelevant discussion that it "has considered whether a full-transient test involving station blackout should be required" and that it "believes that it should and has considered whether a requirement for full-As a(nmitted by the Board, NEC Contention 3 reads: "The license amendment should not be approved unles; Large Trans;ient Testing is a condition of the Extended Power Uprate." Memorandum and Order, LBP-04-28, 60 NTRC 548, 580 (2004).
Tem(ncp ie g5,6C - t037'
transient testing involving station blackout could be drawn from Contention 3." NEC Statement at 1-2.
Affirmatively stated, NEC agrees that the only two Large Transients Tests ("LTTs") within the scope of NEC Contention 3 are the Main Steam Isolation Valve ("MSIV") Closure Test and the Generator Load Rejection Test. That has of course been Entergy's position since this conten-tion was first submitted and was also the clearly the intent of the Board when ruling on the pro-posed contention. The Board admitted NEC Contention 3 because "the request to be relieved from LTT is part of the EPU application," therefore "this contention is within the scope of the proceed-ing." Memorandum and Order, LBP-04-28, 60 NRC 548, 572 (2004).
Indeed, Entergy's request to be relieved from LTT was contained in an attachment to its ex-tended power uprate ("EPU") Application, in which Entergy took exception to two tests, the MSIV Closure Test and the Turbine Generator Load Rejection Test: "Therefore, on a plant-specific basis, Vermont Yankee Nuclear Power Station (VYNPS) is taking exception to the large transient tests; MSIV closure and turbine generator load rejection." Att. 7 to EPU Application, "Justification for Exception to Large Transient Testing" (September 2003), BVY 03-80 at 1. En-tergy's exemption request frames the issues in controversy in this contention.
Therefore, the scope of NEC Contention 3 is and has always been clearly defined, and is limited to the above referenced two tests.
Respectfully submitted, Jay E( ilterg Matias F. Wravieso-Diaz PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W.
Washington, DC 20037-1128 Tel. (202) 663-8063 Counsel for Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.
Dated: March 27, 2006 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of )
) Docket No. 50-271 ENTERGY NUCLEAR VERMONT )
YANKEE, LLC and ENTERGY ) ASLBP No. 04-832-02-OLA NUCLEAR OPERATIONS, INC. ) (Operating License Amendment) v(Wermont Yankee Nuclear Power Station) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of "Entergy's Response to New England Coalition's State-ment on the Scope of New England Coalition Contention 3" were served on the persons listed below by deposit in the U.S. mail, first class, postage prepaid, and where indicated by an asterisk by electronic mail, this 271h day of March, 2006.
- Admninistrative Judge *Administrative Judge Alex S3. Karlin, Chair Lester S. Rubenstein Atomic Safety and Licensing Board Panel 4760 East Country Villa Drive Mail Stop T-3 F23 Tucson AZ 85718 U.S. Nuclear Regulatory Commission IesrrT(-,comcast.net Washington, D.C. 20555-0001 ask2 'nrc.gov
- AdriTinistrative Judge Atomic Safety and Licensing Board Dr. Anthony J. Baratta Mail Stop T-3 F23 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop T-3 F23 Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 aib5 a)nrc.gov
a I
- Secretary Office of Commission Appellate Adjudica-Att'n: Rulemakings and Adjudications Staff tion Mail Stop 0-16 Cl Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 secy( nrc.gov, hearingdocket(nrc.gov
- Saraht Hofmann *Sherwin E. Turk, Esq.
Special Counsel *Robert Weisman, Esq.
Department of Public Service *Steven C. Hamrick, Esq.
112 State Street - Drawer 20 Office of the General Counsel Montpelier, VT 05620-2601 Mail Stop 0-15 D21 Sarah.Hofmann(2iistate.vt.us U.S. Nuclear Regulatory Commission
-Washington,-D.C. 20555-0001 set(anrc.gov, rmw(,tnrc.gov, schl1(nrc.gov
- Anthony Z. Roisman *Raymond Shadis National Legal Scholars Law Firm New England Coalition 84 East Thetford Rd. P.O. Box 98 Lyme, NH 03768 Shadis Road aroisman(tnationallegalscholars.com Edgecomb ME 04556 shadis(),prexar.com
- Jonalhan Rund *Jered Lindsay Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 1mr3 Inrc.gov JJL5a).nrc.gov Jay E rgI 2
