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Category:Legal-Motion
MONTHYEARML18348A9852018-12-14014 December 2018
New England Coalition'S Withdrawal of Its Request for a Hearing and Petition for Leave to Intervene
ML18071A4142018-03-12012 March 2018
Amended Motion to Hold in Abeyance Action on New England Coalition'S Petition for Leave to Intervene and Hearing Request in Consideration of Anticipated Withdrawal
ML17164A2682017-06-13013 June 2017
Attachment Two - Five E-mails Tracing Efforts on June 9, 2017 to File a Request for an Extension of Time
ML17164A2382017-06-13013 June 2017
Resubmitted Request for Extension of Time to File Request for Hearing and Petition for Leave to Intervene
ML17164A2392017-06-13013 June 2017
Request for Leave to Reply and Reply to Applicants' Response to New England Coalition'S Request for Extension
ML16005A6232016-01-0505 January 2016
Unopposed Motion by the States for an Enlargement of Time to File an Answer to Entergy Motion to Strike the States Reply
ML15362A5192015-12-28028 December 2015
Entergy Motion to Strike Impermissible December 17, 2015 Reply Filed by the Commonwealth of Massachusetts and the States of Connecticut and New Hampshire
ML15362A4902015-12-28028 December 2015
Motion to Strike Portions of December 17, 2015, Reply Filed by the State of Vermont, Vermont Yankee Nuclear Power Corporation, and Green Mountain Power Corporation
ML15299A2602015-10-26026 October 2015
NRC Staff Motion to Vacate LBP-15-24
ML15286A4422015-10-13013 October 2015
Entergy Motion for Leave to File Reply and Reply Re Motion to Withdraw LAR
ML15275A3222015-10-0202 October 2015
Staff Answer to Motion to Withdraw
ML15271A3112015-09-23023 September 2015
Federal Respondents' Motion for Extension of Time to File Dispositive Motions and Certified Index 9-23-15
ML15265A5832015-09-22022 September 2015
Entergy'S Motion to Withdraw Its September 4, 2014 License Amendment Request
ML15265A5862015-09-22022 September 2015
Entergy'S Unopposed Motion to Extend the Time to Appeal LBP-15-24
ML15260B2782015-09-17017 September 2015
Joint Motion on Mandatory Disclosures and Schedule
ML15201A1752015-07-20020 July 2015
Joint Proposed Corrections to Oral Argument Transcript Held on July 7, 2015
ML15072A4622015-03-13013 March 2015
Entergy Answer Opposing State of Vermont'S Motion to Stay the License Amendment Proceeding Pending Commission Reconsideration
ML14352A2082014-12-18018 December 2014
NRC Staff Answer to State of Vermont'S Submission of Additional Information and Request to File Supplemental Briefing Addressing New Information and Argument Raised at Oral Argument
ML12088A0852012-03-15015 March 2012
Fed Respondents Opposition to Motion to Strike No.11-1168 and 11-1177 (Consolidated)
ML12067A0892012-03-0707 March 2012
State of Vermont Motion to Strike, Petitioners' Motion to Strike Four Extra-Record References Contained in Respondents' Recently Filed Amended Certified Index of the Record and in Respondents' and Interveners Briefs
ML12066A1772012-03-0606 March 2012
Petitioners Motion to Strike Amended Cert 11-1168
ML1107703932011-03-10010 March 2011
Motion to Stay Any and All Final Commission Decisions in the Matter of 50-271 Lr and Request for Hearing on Entergy License Renewal Application Amendments
Information Notice 2010-26, New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review2010-12-30030 December 2010
New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-19
Information Notice 2010-26, New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-2010-12-30030 December 2010
New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-19
ML1027204012010-09-23023 September 2010
Entergy'S Motion to Strike the Declaration of Paul Blanch
ML1025800092010-09-14014 September 2010
NRC Staff'S Opposition to New England Coalition'S Motion to Reopen the Hearing and Answer to Proposed New Contention and Affidavit of Roy K. Mathew
ML1024200422010-08-20020 August 2010
New England Coalition'S Motion to Reopen the Hearing and for the Admission of New Contentions
ML1006304252010-03-0202 March 2010
New England Coalition'S Petition for Review of Licensing Board'S Full Initial Decision
ML0921509462009-08-0303 August 2009
NRC Staff'S Answer to Nec'S Petition for Review of the Licensing Board'S Full Initial Decision, LBP-09-09
ML0917405782009-06-15015 June 2009
New England Coalition'S Request for Leave to Reply to Entergy'S Answer to Nec'S Request for Extension of Time to Reply to Entergy NRC Staff Oppositions to New England Coalition'S Motion for Leave to File a Timely New Contention
ML0916702672009-06-10010 June 2009
Entergy'S Oppositions to Nec'S Request for an Ex-Post-Facto Extension of Time to File a Reply to the NRC Staff and Entergy'S Oppositions to Nec'S Motion to File a Timely New Contention
ML0916000212009-06-0808 June 2009
Vermont Yankee - NRC Staff'S Answer to Entergy'S Motion to Strike New England Coalition'S Reply to NRC Staff Entergy Oppositions to Nec'S Motion to File a Timely New Contention
ML0916101422009-06-0202 June 2009
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
ML0913907852009-05-19019 May 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to Nec'S Motion for Leave to File a New Contention
ML0912100122009-04-30030 April 2009
NRC Staff'S Answer in Opposition to NEC Motion to Hold in Abeyance Action on Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report
ML0912005142009-04-24024 April 2009
New England Coalition, Inc.'S Motion for Leave to File a Timely New Contention and Motion to Hold in Abeyance Action on This Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report
ML0906800032009-03-0606 March 2009
Oyster Creek - Notice of Appearance of Maxwell Smith and Notice of Withdrawal of Mary Baty
ML0906800082009-03-0606 March 2009
Vermont Yankee - Notice of Appearance of Maxwell Smith and Notice of Withdrawal of Mary Baty
ML0907711412009-03-0606 March 2009
New England Coalition'S Motion to Alter or Amend the Schedule in the Above Captioned Proceeding
ML0902601102009-01-26026 January 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to Nec'S Motion for Leave to Reply
ML0903501142009-01-25025 January 2009
Vermont Department of Public Service Unopposed Motion for Extension of Time to Respond to Energy'S Confirmatory Cufen Analyses
ML0903606582009-01-23023 January 2009
Entergy'S Opposition to New England Coalition'S Motion for Leave to Reply
ML0903001122009-01-14014 January 2009
New England Coalition'S Motion for Leave to Reply to NRC Staff and Entergy Nuclear Vermont Yankee, L.L.C., and Entergy Nuclear Operations, Inc.'S Answers to New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial
ML0900800242009-01-0707 January 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to New England Coalition'S Motion for Reconsideration and Notice of Withdrawal of Jessica Bielecki
ML0835900532008-12-23023 December 2008
Vermont Yankee - NRC Staff'S Reply to Nec'S Answer to NRC Staff'S Petition for Review of LBP-08-25
ML0835900722008-12-23023 December 2008
Vermont Yankee - NRC Staff'S Reply to Motion to Submit Brief Amicus Curiae
ML0900202572008-12-19019 December 2008
Motion for Leave by the States of New York and Connecticut, Et. Al., to Submit Brief Amici Curiae in Opposition to Staff'S Petition for Review and in Support of Intervenors State of Vermont and the New England Coalition
ML0901603582008-12-17017 December 2008
New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial Initial Decision
ML0836593462008-12-15015 December 2008
New England Coalition, Inc.'S Motion for a Second Extension of Time in Which to File a Motion for Reconsideration
ML0835304522008-12-12012 December 2008
the State of New York, V USNRC and Entergy Nuclear Operations Inc; 08-3903-ag(L)/08-4833-ag(CON) - Motion Out of Time
2018-03-12
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A'4 /3995 DOCKETED USNRC UNITED STATES August 10, 2007 (1:19pm)
NUCLEAR REGULATORY COMMISSION OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF In the Matter of )
ENTERGY NUCLEAR.VERMONT YANKEE, LLC ) Docket No. 50-271-LR and ENTERGY NUCLEAR OPERATIONS, INC. ASLB No. 06-849-03-LR
)
Vermont Yankee Nuclear Power Station )
NEW ENGLAND COALITION. INC. (NEC) REPLY TO ENTERGY AND NRC STAFF ANSWERS TO NEC MOTION TO FILE A TIMELY NEW OR AMENDED CONTENTION Pursuant to 10 C.F.R. § 2.309(h)(2) and the Initial Scheduling Order ¶ 5(A), New England Coalition, Inc. (NEC) files the following reply to the Entergy and NRC Staff Answers to NEC's Motion to File a Timely New or Amended Contention.
NEC agrees with Entergy that further proceedings on NEC's New or Amended Contention addressing Entergy's preliminary environmentally assisted metal fatigue analysis should be held in abeyance pending NEC's review of Entergy's final environmentally assisted metal fatigue analysis. NEC received Entergy's reports of this final analysis on August 3, 2007. NEC may file a new Contention addressing them by September 3, 2007, which would supersede NEC's New or Amended Contention. Initial Scheduling Order ¶ 5(B).
NEC's original Contention 2 should also be held in abeyance, pending resolution of NEC's new Contention concerning the validity of Entergy's revised fatigue analysis.
NEC disagrees with Entergy that NEC's original Contention 2 should now be dismissed.
NEC's original Contention 2 is that Entergy's License Renewal Application (LRA) does not include any specific plan to monitor and manage reactor components identified in i em a ey -/ cy- 0
LRA Table 4.3-3 as vulnerable to environmentally assisted fatigue failure during the license renewal period. If NEC prevails in its new Contention that Entergy's revised fatigue analysis fails to demonstrate that these components are safe from fatigue failure, then NEC's Contention 2 remains relevant, and the Board should. adjudicate it.
August 10, 2007 New England Coalition
'by:'
Ronald A. Shems Karen Tyler SHEMS DUNKIEL KASSEL & SAUNDERS PLLC For the firm Attorneys for NEC 2
UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of )
ENTERGY NUCLEAR VERMONT YANKEE, LLC ) Docket No. 50-27i-LR and ENTERGY NUCLEAR OPERATIONS, INC. ) ASLB No. 06-849-03-LR
).
Vermont Yankee Nuclear Power Station )
NOTICE OF APPEARANCE OF ANDREW RAUBVOGEL Andrew Raubvogel, an attorney in good standing admitted to practice before the courts of the State of Vermont, hereby enters his appearance as counsel on behalf of New England Coalition, Inc. in the above-captioned matter.
Respectfully Submitted, Andrew Raubvogel SHEMS DUNKIEL KASSEL
& SAUNDERS PLLC 91 College Street Burlington, Vermont 05401 Tel. (802) 860-1003 x. 107 araubvogel@sdkslaw.com Counsel for NEC Dated: August 9, 2007
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 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) )
CERTIFICATE OF SERVICE I,.Michelle Cronin, hereby certify that copies of NEW ENGLAND COALITION, INC.'S (NEC) REPLY TO ENTERGY AND NRC STAFF ANSWERS TO NEC MOTION TO FILE A TIMELY NEW OR AMENDED CONTENTION and NOTICE OF APPEARANCE OF ANDREW RAUBVOGEL in the above-captioned proceeding were served on the persons listed below, by U.S, Mail, first class, postage prepaid; by Fed Ex overnight to Judge Elleman; and, where indicated by an e-mail address below, by electronic mail, on the 10th day of August, 2007.
Administrative Judge Office of the Secretary Alex S. Karlin, Esq., Chair Attn: Rulemaking and Adjudications Staff Atomic Safety and Licensing Board Mail Stop: O-16C1 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission
.U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: hearingdocket@,nrc.gov E-mail: ask2@,nrc.gov Sarah Hofmann, Esq.
Administrative Judge Director of Public Advocacy Thomas S. Ellernan Department of Public Service Atomic Safety and Licensing Board Panel 112 State Street, Drawer 20 5207 Creedmoor Road, #101 Montpelier, VT 05620-2601 Raleigh, NC 27612 E-mail: sarah.hofmannA~state.vt.us E-mail: elleman@eos.ncsu.edu Lloyd B.. Subin, Esq.
Office of Commission Appellate Adjudication Mary C. Baty, Esq.
Mail Stop: O-16C1 Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop 0-15 D21 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission E-mail: OCAAmailCanrc.gov Washington, DC 20555-0001 E-mail: lbs3@nrc.gov; mcbl@nrc.gov Administrative Judge Dr. Richard E. Wardwell Dan MacArthur, Director Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 Town of Marlboro U.S. Nuclear Regulatory Commission Emergency Management Washington, DC 20555-0001 P.O. Box 30 E-mail: rew@nrc.gov Marlboro, VT 05344 E-mail: dmacarthur@igc.org
Marcia Carpentier, Esq. David R. Lewis, Esq.
Atomic Safety and Licensing Board Panel Matias F. Travieso-Diaz Mail Stop T-3 F23 Pillsbury Winthrop Shaw Pittman LLP U.S. Nuclear Regulatory Commission 2300 N Street NW Washington, DC 20555-0001 Washington, DC 20037-1128 E-mail mxc7a@nrc.gov E-mail: david.lewis@pillsburylaw.com matias.travieso-diaz@pillsburylaw.com Anthony Z. Roisman, Esq.
National Legal Scholars Law Finn Peter C. L. Roth, Esq.
84 East Thetford Road Office of the Attorney General Lyme; NH 03768 33 Capitol Street E-mail: aroismanoanationallegalscholars.com Concord, NH 03301 Peter.r6th(adoj.nh.gov Callie B. Newton, Chair Gail MacArthur Lucy Gratwick Marcia Hamilton Town of Marlboro Selectboard P.O. Box 518 Marlboro, VT .05344 E-mail: cbnewton@sover.net; marcialynn@evl .net SHEMS DUNKIEL KASSEL & SAUNDERS, PLLC by;:
Midhelle Cronin, for Ronald A. Shems, Esq. and Karen Tyler, Esq.
91 College Street Burlington, VT 05401 802 860 1003 802 860 1208 (fax) rshems(&sdkslaw.com.
ktyler(Qsdksiaw.com for the firm Attorneys for New England Coalition, Inc.
