ML062990329

From kanterella
Jump to navigation Jump to search
Joint Motion on Privilege Log and Disclosure
ML062990329
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 10/20/2006
From: Doris Lewis
Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:
Atomic Safety and Licensing Board Panel
Byrdsong A T
References
50-271-LR, ASLBP 06-849-03-LR, RAS 12418
Download: ML062990329 (8)


Text

October 20, 2006 DOCKETED USNRC UNITED STATES OF AMERICA October 20, 2006 (11:01am)

NUCLEAR REGULATORY COMMISSION OFFICE OF SECRETARY Before the Atomic Safety and Licensing Board RULEMAKINGS AND ADJUDICATIONS STAFF In the Matter of

))

Entergy Nuclear Vermont Yankee, LLC

)

Docket No. 50-271-LR and Entergy Nuclear Operations, Inc.

)

ASLBP No. 06-849-03-LR

)

(Vermont Yankee Nuclear Power Station)

)

JOINT MOTION ON PRIVILEGE LOG AND DISCLOSURE Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc., the Vermont Department of Public Service, the New England Coalition, Inc., and the NRC Staff (the "Parties") have agreed and move that the privilege logs required by 10 C.F.R. § 2.336(a)(3) and (b)(5) to be provided by the Parties in this proceeding need not include (1) communications that originated from counsel to the client, or from the client to counsel, when no outside person was included, or (2) documents as to which the attorney work-product privilege is asserted when the documents are authored by counsel. If the documents were not authored by counsel and the work-product privilege is claimed, the material should appear on the privilege log as required by 10 C.F.R. §§ 2.336(a)(3) and (b)(5). In entering this stipulation, the New England Coalition does not concede the deliberative process privilege and reserves any ability to seek such documents.

The Parties have also agreed and move that the disclosures required by 10 C.F.R. § 2.336(a)(2) and (b) need not include pleadings or communications that have already been Te~e~tT~

SEFC'.-

0914

exchanged, with a certificate of service, between all the parties, such as the material in, or attached to, the pleadings already served.

The Parties have authorized Entergy to file this motion with the Atomic Safety and Licensing Board on their behalf.

Respectfully Submitted, David R. Lewis Matias F. Travieso-Diaz PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W.

Washington, DC 20037-1128 Tel. (202) 663-8474 Counsel for Entergy Nuclear Vermont Yankee, LLC, and Entergy Nuclear Operations, Inc.

Dated: October 20, 2006 2

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

(Vermont Yankee Nuclear Power Station)

))

)

)

)

)

Docket No. 50-271-LR ASLBP No. 06-849-03-LR CERTIFICATE OF SERVICE I hereby certify that copies of "Joint Motion on Privilege Log and Disclosure" dated October 20, 2006, 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 20th day of October, 2006.

  • Administrative Judge Alex S, Karlin, Esq., Chairman Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ask2@nrc.gov
  • Administrative Judge Dr. Thomas S. Elleman Atomic Safety and Licensing Board 5207 Creedmoor Road, #101, Raleigh, NC 27612.

tse@nrc.gov; elleman@eos.ncsu.edu Office of Commission Appellate Adjudication Mail Stop 0-16 C l U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

  • Administrative Judge Dr. Richard E. Wardwell Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 rew@nrc.gov
  • Secretary Att'n: Rulemakings and Adjudications Staff Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 secy@nrc.gov, hearingdocket@nrc.gov Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 400471096vl
  • Mitzi A. Young, Esq.
  • Steven C. Hamrick, Esq.

Office of the General Counsel Mail Stop 0-15 D21 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 may@nrc.gov; schl@nrc.gov

  • Anthony Z. Roisman, Esq.

National Legal Scholars Law Firm 84 East Thetford Road Lyme, NH 03768 aroismanWnationallegalscholars.com

  • Sarah Hoflnann, Esq.

Director of Public Advocacy Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620-2601 Sarah.honfmann@state.vt.us

  • Ronald A. Shems, Esq.
  • Karen Tyler, Esq.

Shems, Dunkiel, Kassel & Saunders, PLLC 9 College Street Burlington, VT 05401 rshems@sdkslaw.com ktyler@sdkslaw.com David R. Lewis 4

400471096vl