Response of Town of Cortlandt to Board'S April 1, 2008 Order Relating to the Service and Content of Westcan'S Reply Dated Feb. 15, 2008ML081050261 |
Person / Time |
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Site: |
Indian Point |
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Issue date: |
04/04/2008 |
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From: |
Riesel D Sive, Paget & Riesel, PC, Town of Cortlandt, NY |
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To: |
Lathrop K, Lawrence Mcdade, Richard Wardwell Atomic Safety and Licensing Board Panel |
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SECY RAS |
References |
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50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, RAS E-51 |
Download: ML081050261 (6) |
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Category:Legal-Intervention Petition
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[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. 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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] |
Text
PA$ F"~51 DOCKETED USNRC April 4, 2008 (4:47pm)
UNITED STATES OF AMERICA OFFICE OF SECRETARY RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges Lawrence G. McDade, Chairman Dr. Kaye D. Lathrop Dr. Richard E. Wardwell In the Matter of )
Docket Nos. 50-247- LR and ENTERGY NUCLEAR OPERATIONS, INC. ) 50-286-LR (Indian Point Nuclear Generating ) ASLBP No. 07-858-03-LR-BDO0 Units 2 and 3)
April 4, 2008 RESPONSE OF TOWN OF CORTLANDT TO BOARD'S APRIL 1, 2008 ORDER RELATING TO THE SERVICE AND CONTENT OF WESTCAN'S REPLY DATED FEB. 15, 2008 On April 1, 2008, the Atomic Safety and Licensing Board (the "Board") ordered all participants in the above-captioned proceeding to advise the Board "whether, in the electronic transmissions that were sent to them by WestCAN on Friday, March 21, 2008, they received copies of WestCAN Exhibits H and I, and also whether those Exhibits were listed in the electronic Table of Contents that they received from WestCAN on March 21, 2008." Board Order (Third Order Relating to the Service and Content of WestCAN's Reply Dated Feb. 15, 2008) (Apr. 1, 2008).
The Town of Cortlandt received copies of WestCAN Exhibits H and I in WestCAN's electronic transmission dated March 21, 2008. However, Exhibits H and I were not listed in the electronic Table of Contents. Copies of WestCAN's electronic transmissions dated March 21, 2008 were forwarded in a separate transmission to the Office of the Secretary, Nuclear Regulatory Commission, at HEARINGDOCKET@nrc.gov, as per the Board's Order.
On Behalf of Linda D. Puglisi, Supervisor of the Town of Cortlandt, and the Town of Cortlandt Dated:
April 4, 2008 New York, New York Respectfully Submitted, Thomas F. Wood Town Attorney Town of Cortlandt And Sive, Paget & Riesel, P.C.
By_4 Daniel Riesel 460 Park Avenue New York, New York 10022 Phone: (212) 421-2150 Facsimile: (212) 421-1891 Email: driesel@sprlaw.com
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
Docket Nos. 50-247- LR and ENTERGY NUCLEAR OPERATIONS, INC. ) 50-286-LR (Indian Point Nuclear Generating ) ASLBP No. 07-858-03-LR-BDO0 Units 2 and 3)
) April 4, 2008 CERTIFICATE OF SERVICE I hereby certify that on April 4, 2008 a true copy of the foregoing RESPONSE OF TOWN OF CORTLANDT TO BOARD'S APRIL 1, 2008 ORDER RELATING TO THE SERVICE AND CONTENT OF WESTCAN'S REPLY DATED FEB. 15, 2008 was served by electronic mail and by first class mail upon all parties, upon the following parties and participants:
Lawrence G. McDade, Chair Atomic Safety and Licensing Board Panel Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 Mail Stop - T-3 F23 Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Office of Commission Appellate E-mail: LGMl@nrc.gov Adjudication U.S. Nuclear Regulatory Commission Dr. Richard E. Wardwell Mail Stop: O-16G4 Administrative Judge Washington, D.C. 20555-0001 Atomic Safety and Licensing Board Panel E-mail: OCAAMAIL@nrc.gov Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Office of the Secretary
- Washington, D.C. 20555-0001 Attn: Rulemaking and Adjudications Staff E-mail: REW@nrc.gov Mail Stop: O-16G4 U.S. Nuclear Regulatory Commission Dr. Kaye D. Lathrop Washington, D.C. 20555-0001 Administrative Judge E-mail: HEARINGDOCKET@nrc.gov Atomic Safety and Licensing Board Panel 190 Cedar Lane E.
Ridgway, CO 81432 E-mail: KDL2@nrc.gov Sherwin E. Turk, Esq. Joan Leary Matthews, Esq.
Lloyd B. Subin, Esq. Senior Attorney for Special Projects Beth N. Mizuno, Esq. New York State Department of
David E. Roth Office of the General Counsel Environmental Conservation Mail Stop 0-15-D-21 Office of the General Counsel U.S. Nuclear Regulatory Commission 625 Broadway, 14th Floor Washington, D.C. 20555 Albany, NY 12233-1500 E-mail: set@nrc.gov E-mail: jlmatthe@gw.dec.state.ny.us E-mail: lbs3@nrc.gov E-mail: bnml@nrc.gov E-mail: der@nrc.gov Zachary S. Kahn, Esq. Kimberly A. Sexton Law Clerk U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Mail Stop: T-2 F23 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission E-mail: Kimberly.sexton@nrc. gov Washington, D.C. 20555-0001 E-mail: ZXKl @nrc.gov William C. Dennis, Esq. Christopher C. Chandler Assistant General Counsel U.S. Nuclear Regulatory Commission Entergy Nuclear Operations, Inc. Office of the General Counsel 440 Hamilton Avenue Washington, D.C. 20555 White Plains, NY 10601 E-mail: Christopher.chandler@nrc.gov E-mail: wdennis@entergy.com Elise N. Zoli, Esq.
Kathryn M. Sutton, Esq. Goodwin Procter, LLP Paul M. Bessette, Esq. Exchange Place Martin J. O'Neill, Esq. 53 State Street Morgan, Lewis & Bockius, LLP Boston, MA 02109 1111 Pennsylvania Avenue, NW E-mail: ezoli@goodwinprocter.com Washington, D.C. 20004 E-mail: ksutton@morganlewis.com Justin D. Pruyne, Esq.
E-mail: pbessette@morganlewis.com Assistant County Attorney E-mail: martin.o'neill@morganlewis.com Office of Westchester County Attorney 148 Martine Avenue, 6 th Floor Michael J. Delaney, Esq. White Plains, NY 10601 Vice President - Energy E-mail: jdp3@westchestergov.com New York City Economic Development Corporation (NYCDEC) Daniel E. O'Neill, Mayor 110 William Street James Seirmarco, M.S.
New York, NY 10038 Village of Buchanan E-mail: mdelaney@nycedc.com Municipal Building Buchanan, NY 10511-1298 E-mail: vob@bestweb.net
Richard L. Brodsky, Esq.
5 West Main Street John J. Sipos, Esq.
Elmsford, NY 10523 Charlie Donaldson, Esq.
E-mail: brodskr@assembly.state.ny.us Assistants Attorney General richardbrodsky@msn.com New York State Department of Law Environmental Protection Bureau Susan Shapiro, Esq. The Capitol 21 Perlman Drive Albany, NY 12224 Spring Valley, NY 10977 E-mail: john.sipos@oag.state.ny.us E-mail: mbs@ourrocklandoffice.com Arthur J. Kremer, Chairman John LeKay New York Affordable Reliable FUSE USA Electricity Alliance (AREA) 351 Dyckman Street 347 Fifth Avenue, Suite 508 Peekskill, NY 10566 New York, NY 10016 E-mail: fuseusa@yahoo.com E-mail: ajkremer@rmfpc.com kremer@area-alliance.org Manna Jo Greene Hudson River Sloop Clearwater, Inc.
112 Little Market Street Robert Snook, Esq.
Poughkeepsie, NY 12601 Office of the Attorney General E-mail: Mannajo@clearwater.org State of Connecticut 55 Elm Street Diane Curran, Esq. P.O. Box 120 Harmon, Curran, Spielberg & Eisenberg, Hartford, CT 06141-0120 LLP E-mail: Robert.snook@po.state.ct.us 1726 M Street, NW, Suite 600 Washington, D.C. 20036 Ms. Nancy Burton E-mail: dcurran@harmoncurran. com 147 Cross Highway Redding Ridge, CT 06876 Victor Tafur, Esq. E-mail: nancyburtonct@aol.com Phillip Musegaas, Esq.
Riverkeeper, Inc. Sarah Wagner, Esq.
828 South Broadway Legislative Office Building, Room 422 Tarrytown, NY 10591 Albany, NY 12248 E-mail: phillip@riverkeeper.org E-mail: sarahwagneresq@gmail.com vtafur@riverkeeper.org John Louis Parker, Esq.
Janice Dean, Esq. Regional Attorney Assistant Attorney General Office of General Counsel, Region 3 Office of the Attorney General New York State Department of 120 Broadway, 26 h Floor Environmental Conservation New York, NY 10271 21 South Putt Comers Road E-mail: Janice. dean@oag.state.ny.us New Paltz, NY 12561-1620
E-mail: j lparker@gw.dec.state.ny.us Marcia Carpentier Mylan L. Denerstein, Esq.
Law Clerk Executive Deputy Attorney General Atomic Safety and Licensing Board Office of the Attorney General Mail Stop: T-3 E2B 120 Broadway, 2 5 th Floor U.S. Nuclear Regulatory Commission New York, NY 10271 Washington, D.C. 20555-0001 E-mail: Mylan.Denerstein@oag.state.ny.us E-mail: Marcia.Carpentier@nrc.gov Stephen C. Filler, Esq.
Board Member Hudson River Sloop Clearwater, Inc.
303 South Broadway, Ste 222 Tarrytown, NY 10592 E-mail: sfiller@nylawline.com By:
Thomas F. Wood Town Attorney Town of Cortlandt And Sive, Paget & Riesel, P.C.
Daniel Riesel 460 Park Avenue New York, New York 10022 Phone: (212) 421-2150 Facsimile: (212) 421-1891 Email: driesel@sprlaw.com