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Category:Legal-Intervention Petition
MONTHYEARML11257A1102011-09-14014 September 2011 Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions ML11257A1092011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A1112011-09-13013 September 2011 Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report ML11228A0302011-08-11011 August 2011 the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17 ML11217A0662011-07-29029 July 2011 Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36 ML11210B4192011-07-26026 July 2011 State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37 ML11179A0922011-06-21021 June 2011 Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals ML11133A2882011-04-29029 April 2011 Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25 ML11117A1462011-04-19019 April 2011 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident ML11229A8022011-03-22022 March 2011 Supplementary Certification Regarding Consultation ML11108A1062011-03-21021 March 2011 Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3 ML1108307802011-03-18018 March 2011 State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives ML1107601812011-03-16016 March 2011 Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement ML1107000972011-03-0404 March 2011 State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B ML1106703812011-02-25025 February 2011 Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions ML1107402862011-02-23023 February 2011 State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36 ML1106604252011-02-23023 February 2011 State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1105602702011-02-18018 February 2011 Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule ML1105605892011-02-18018 February 2011 Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b) ML1104604922011-02-10010 February 2011 State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions ML1106802122011-02-0303 February 2011 State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area ML1030000602010-10-22022 October 2010 State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25 ML1030101042010-10-12012 October 2010 Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals ML1029101452010-10-0404 October 2010 Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1028802972010-10-0404 October 2010 Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B ML1029101422010-10-0404 October 2010 Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1030105182010-09-14014 September 2010 State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean.. ML1023712142010-08-16016 August 2010 Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion) ML1023001462010-08-13013 August 2010 Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents ML1022405782010-08-0202 August 2010 Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13 ML1021100862010-07-26026 July 2010 the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10- ML1020300502010-07-15015 July 2010 Applicant'S Petition for Interlocutory Review of LBP-10-13 ML1011604152010-04-12012 April 2010 State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1014503282010-04-0505 April 2010 Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis ML1011004732010-04-0101 April 2010 Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives ML1005702402009-11-20020 November 2009 Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point ML0934803252009-11-20020 November 2009 Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML0934910432009-11-20020 November 2009 Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information ML0935101942009-11-20020 November 2009 Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point ML1005700112009-11-20020 November 2009 Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML1008200282009-11-19019 November 2009 Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point ML0930801292009-10-26026 October 2009 Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information ML0909802072009-04-0707 April 2009 Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply ML0910502112009-04-0606 April 2009 Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2 ML0909604702009-03-31031 March 2009 State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34 ML0909302042009-03-24024 March 2009 Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State ML0908401162009-03-24024 March 2009 Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement ML0908608682009-03-18018 March 2009 Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items ML0906903032009-02-27027 February 2009 State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement ML0904105002009-01-26026 January 2009 Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention 2011-09-14
[Table view] Category:Responses and Contentions
MONTHYEARML11257A1102011-09-14014 September 2011 Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions ML11257A1092011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A1112011-09-13013 September 2011 Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report ML11228A0302011-08-11011 August 2011 the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17 ML11217A0662011-07-29029 July 2011 Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36 ML11210B4192011-07-26026 July 2011 State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37 ML11179A0922011-06-21021 June 2011 Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals ML11133A2882011-04-29029 April 2011 Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25 ML11117A1462011-04-19019 April 2011 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident ML11229A8022011-03-22022 March 2011 Supplementary Certification Regarding Consultation ML11108A1062011-03-21021 March 2011 Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3 ML1108307802011-03-18018 March 2011 State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives ML1107601812011-03-16016 March 2011 Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement ML1107000972011-03-0404 March 2011 State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B ML1106703812011-02-25025 February 2011 Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions ML1107402862011-02-23023 February 2011 State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36 ML1106604252011-02-23023 February 2011 State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1105602702011-02-18018 February 2011 Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule ML1105605892011-02-18018 February 2011 Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b) ML1104604922011-02-10010 February 2011 State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions ML1106802122011-02-0303 February 2011 State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area ML1030000602010-10-22022 October 2010 State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25 ML1030101042010-10-12012 October 2010 Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals ML1029101452010-10-0404 October 2010 Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1028802972010-10-0404 October 2010 Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B ML1029101422010-10-0404 October 2010 Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1030105182010-09-14014 September 2010 State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean.. ML1023712142010-08-16016 August 2010 Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion) ML1023001462010-08-13013 August 2010 Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents ML1022405782010-08-0202 August 2010 Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13 ML1021100862010-07-26026 July 2010 the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10- ML1020300502010-07-15015 July 2010 Applicant'S Petition for Interlocutory Review of LBP-10-13 ML1011604152010-04-12012 April 2010 State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1014503282010-04-0505 April 2010 Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis ML1011004732010-04-0101 April 2010 Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives ML1005702402009-11-20020 November 2009 Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point ML0934803252009-11-20020 November 2009 Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML0934910432009-11-20020 November 2009 Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information ML0935101942009-11-20020 November 2009 Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point ML1005700112009-11-20020 November 2009 Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML1008200282009-11-19019 November 2009 Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point ML0930801292009-10-26026 October 2009 Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information ML0909802072009-04-0707 April 2009 Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply ML0910502112009-04-0606 April 2009 Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2 ML0909604702009-03-31031 March 2009 State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34 ML0909302042009-03-24024 March 2009 Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State ML0908401162009-03-24024 March 2009 Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement ML0908608682009-03-18018 March 2009 Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items ML0906903032009-02-27027 February 2009 State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement ML0904105002009-01-26026 January 2009 Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention 2011-09-14
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fi!5I-s1 V
&L1( DOCKETED USNRC THE ASSEMBLY December 4, 2007 (4:56pm)
STATE OF NEW YORK OFFICE OF SECRETARY RULEMAKINGS AND ALBANY ADJUDICATIONS STAFF RICHARD L. BRODSKY CHAIRMAN Assemblyman 92': District Committee on Corporations, Authorities Westchester County and Commissicns December 4, 2007 VIA ELECTRONIC & FIRST CLASS MAIL Administrative Law Judge Administrative Law Judge Hon. Lawrence G. McDade, Chair Hon. Richard E. Wardwell 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 (E-Mail: lm(@'nrc.gov) (E-Mail: rewavnrc.Qov)
Administrative Law Judge Office of the Secretary Hon. Kaye D. Lathrop Attn: Rulemakings & Adjudications Staff 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 (E-Mail: hearingdocketvdnrc. aov)
Washington, D.C. 20555-0001 (E-Mail: kdl2*nrc.Luov)
Re: Request for Extension to file Formal Requests for Hearing and Petitions to Intervene with Contentions in Docket Nos. 50-247-LR; 50-286-LR: ASLBP No. 07-858-03-LR-BD01
Dear Chairman McDade,
Judge Wardwell and Judge Lathrop:
Assemblyman Richard L. Brodsky ("Assemblyman Brodsky") hereby respectfully requests on his own behalf, on behalf of his constituents, on behalf of the Westchester-Rockland Delegation to the New York State Assembly, including but not limited to, Assemblyman Adam Bradley, Assemblywoman Ellen Jaffee, Assemblyman George Latimer and Assemblyman Kenneth Zerbrowski, and the associated Members of the Delegation, and on behalf of all similarly situated stakeholders, that he and those other similarly situated stakeholders referenced above, be granted a ten (10) day extension of time, from November 30, 2007 to December 10, 2007, for filing a Petition to Intervene and Request for Hearing in the above-referenced license renewal proceeding. Based on information and belief, he understands that the Nuclear Regulatory Commission ("Commission") has granted a ten day extension to other persons by Order dated November 16, 2007, and that review of further applications for extension was contemplated by the Commission in its November 16 Order.'
See e-mail from Emile Julian, NRC, to Susan Shapiro, FUSE, dated November 20, 2007. "The Order explicitly states that any further requests shall be referred to the ASLB. Thus, the Commission contemplates that there may be additional persons who believe that they should receive additional time because of the malfunction of ADAMS and that those requests should be forwarded to the ASLB for appropriate review."
o_/ - 0 3 ALBANY OFFICE: Room 422, Legislative Office Building, Albany, New York 12248, (518) 455-5753 Q DISTRICT OFFICE: 5 West Main Street, Suite 205, Elmstord, New York 10523, (914) 345-0432
The original deadline for Requests for Hearing or Petitions for Leave to Intervene in the license renewal proceeding was October 1, 2007, but was extended by the Commission on October 1, 2007 until November 30, 2007.: During much of the two months between such extension and this filing, the Commission's ADAMS system for document research and retrieval functioned intermittently or was completely inaccessible to the public because of systems crashing. Specifically, in or around late October, ADAMS became completely inaccessible to the public in excess of two weeks. Consequently, Assemblyman Brodsky and other stakeholders were unable to gain access to documents of critical importance in the formation of their Requests for Hearing and Petitions to Intervene, including but not limited to the license renewal application itself. Assemblyman Brodsky asserts therefore that the extension requested herein is in the public interest because his participation in this proceeding on his own behalf, and on behalf of the Westchester-Rockland Delegation, Assemblymembers Bradley, Jaffee, Latimer and Zerbrowski, and the other stakeholders referenced above, will assist in the development of a sound record, as his repeated, unique and successful involvement 3 in legal proceedings, policy issues and legislative considerations concerning Indian Point has shown.
Due to the time-sensitive nature of this request, Assemblyman Brodsky respectfully requests a response as soon as is reasonably possible.
Sincerely, Richard A. Berkley, Esq.
Counsel to Assemblyman Richar1d-L-Brods-'
(
cc:
Susan Shapiro, Esq.
Office of Commission Appellate Adjudication FUSE U.S. Nuclear Regulatory Commission 21 Perlman Drive Washington, D.C. 20555-0001 Spring Valley, NY 10077 (E-mail: ocaamailI(nrc.gov) (E-mail: palisadesart(aol.coni)
Joan Leary Matthews, Esq. Sherwin E. Turk, Esq.
NYS Dept. of Env. Conserv. Lloyd B. Subin, Esq.
625 Broadway, 140' Floor Beth N. Mizuno, Esq.
Albany, NY 12233-5500 Office of the General Counsel (E-mail: ilmatthews(cw.dec.state.nv.us) (E-mail: set Qnrc.gov)
(E-mail: lbs3(@nrc.gov)
(E-mail: bnm I anrc.gov) 2See 72 Fed. Reg. 55834.
3 See, e.g., Brodskv v. Crottv, 766 N.Y.S.2d 277 (2003)(litigation mandating the commencement of the SPDES permitting process at Indian Point), Entergv v. DEC, 777 N.Y.S.2d 591 (2004)(successfully defending the constitutionality of a state regulation imposing a BTA requirement upon Indian Point's cooling intakes), and PSC-NY Case 00-E-0612, Matter of the Forced Outage of Indian Point No. 2 Nuclear Generating Facility (Feb. 12, 2004)(Order settling prudence litigation sought by petition entered by Assemblyman Brodsky and other members of the legislature); See also, Interim Report on the Evacuation Plan for the Indian Point Nuclear Facility, February 20, 2002(analyzing and reporting upon the deficiencies in the evacuation plan).
Shenvood Martinelli Zachary S. Khan, Law Clerk FUSE Atomic Safety & Licensing Board 351 Dykman Street Mail Stop: T-3 F23 Peekskill, NY 19566 U.S. Nuclear Regulatory Commission (E-mail: rovcepenstiner~h-aol.co m) (E-mail: zxkl@nrc.,ov)
Michael J. Delaney Kathryn M. Sutton, Esq.
V.P. - Energy Paul M. Bessette, Esq.
New York City Martin J. O'Neill, Esq.
Economic Development Corp. Morgan, Lewis & Bockius 110 William Street 1111 Pennsylvania Avenue, N.W.
New York, NY 10038 Washington, D.C. 20004 (E-mail: mdelanev(j)nvcedc.com) (E-mail: ksutton ,morganlewis.com)
(E-mail: pbessettec.morganlewis.com)
(E-mail: martin.o.neill@mor~anlewis.com)
Arthur J. Kremer, Chair Manna Jo Greene The New York Affordable Reliable Member-Authorized Representative Electricity Alliance Hudson River Sloop Clearwater 347 Fifth Avenue, Suite 508 112 Little Market Street New York, NY 10016 Poughkeepsie, NY 12601 (E-mail: kremer 0area-alliance.ort) (E-mail: officeamail.clearwater.orf William C. Dennis, Esq. John J. Sipos, Esq.
Assistant. General Counsel Assistant Attomey General Entergy Nuclear Operations, Inc. Office of the New York State Attorney General 440 Hamilton Avenue The Capitol - State Street White Plains, NY 10601 Albany, NY 12224 (E-mail: wdennis('i@entergv.co m) (E-mail: John.Siposwuoa2.state.nv.us)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
ENTERGY NUCLEAR OPERATIONS, INC. ) Docket Nos. 50-247-LR
) and 50-286-LR
)
(Indian Point Nuclear Generating, )
Units 2 & 3) )
CERTIFICATE OF SERVICE I hereby certify that copies of the enclosed Request for Extension to File Formal Requests for Hearing and Petitions to Intervene have been served upon the following persons by electronic mail, followed by deposit of paper copies in the U.S. mail, first class.
Administrative Law Judge Administrative Law Judge Hon. Lawrence G. McDade, Chair Hon. Richard E. Wardwell 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 (E-Mail: lam0wnrc.gov) (E-Mail: rewi).nrc.aov)
Administrative Law Judge Office of the Secretary Hon. Kaye D. Lathrop Attn: Rulemakings & Adjudications Staff 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 (E-Mail: hearingdocket(rnrc.gov)
Washington, D.C. 20555-0001 (E-Mail: kdl2(-).nrc.,ov)
Susan Shapiro, Esq.
Office of Commission Appellate Adjudication FUSE U.S. Nuclear Regulatory Commmission 21 Perlman Drive Washington, D.C. 20555-0001 Spring Valley, NY 10077 (E-mail: ocaamailhinrc.aov) (E-mail: palisadesart*aol.com)
Joan Leary Matthews, Esq. Sherwin E. Turk, Esq.
NYS Dept. of Env. Conserv. Lloyd B. Subin, Esq.
625 Broadway, 14 th Floor Beth N. Mizuno, Esq.
Albany, NY 12233-5500 Office of the General Counsel (E-mail: i lmatthews(d!w.dec.state.nv.us) (E-mail: setnanrc. ov)
(E-mail: lbs3@nrc.aov)
(E-mail: bnm I nrc.aov)
Sherwood Martinelli Zachary S. Khan, Law Clerk FUSE Atomic Safety & Licensing Board 351 Dykman Street Mail Stop: T-3 F23 Peekskill, NY 19566 U.S. Nuclear Regulatory Commission (E-mail: rovcepenstinger aol.com) (E-mail: zxkl(a-nrc.2ov)
Mlichael J. Delaney Kathryn M. Sutton, Esq.
V.P. - Energy Paul M. Bessette, Esq.
New York City Martin J. O'Neill, Esq.
Economic Development Corp. Morgan, Lewis & Bockius 110 William Street 1111 Pennsylvania Avenue, N.W.
New York, NY 10038 Washington, D.C. 20004 (E-mail: mdelanevcwnveedc.eom) (E-mail: ksuttona.morganleyis.com)
(E-mail: pbessette(@mor,.anlewis.com)
(E-mail: martin.o.neill(moruanlewis.corn)
Arthur J. Kremer, Chair Manna Jo Greene The New York Affordable Reliable Member-Authorized Representative Electricity Alliance Hudson River Sloop Clearwater 347 Fifth Avenue, Suite 508 112 Little Market Street New York, NY 10016 Poughkeepsie, NY 12601 (E-mail: kremer(@iarea-alliance.org) (E-mail: officenamail.clearwater.org.
William C. Dennis, Esq. John J. Sipos, Esq.
Assistant. General Counsel Assistant Attorney General Entergy Nuclear Operations, Inc. Office of the New York State Attorney General 440 Hamilton Avenue The Capitol - State Street White Plains, NY 10601 Albany, NY 12224 (E-mail: wdennis(ihentergv.com) (E-mail: John.Siposraboag.state.nv.us)
Richard A. Berkley, Esq. )
Counsel to Assemblyman Richard L.*rodsky Signed and Dated at Albany, New York This 4th day of December, 2007.