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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
DOCKETED USNRC July. 15, 2008 (1:43pm)
July 15, 2008 OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF 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) )
ENTERGY'S RESPONSE TO JULY 11, 2008 BOARD ORDER On July 11, 2008, at approximately 1:19 p.m., counsel for the NRC staff notified the Atomic Safety and Licensing Board ("Board") and counsel for the other parties to this matter by electronic mail that the New England Coalition's ("NEC") direct examination plan had been inadvertently made publicly available on the Electronic Hearing Docket and ADAMS. At approximately 1:39 p.m., the Board provided instructions by electronic mail that counsel talk to their legal teams, including all expert witnesses, and direct them not to access NEC's direct examination plan. The Board further ordered the parties to file a short report with the Board regarding the implementation of the Board's Order on July 17, 2008. Applicants Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (collectively "Entergy")
provide the following response to the Board's Order.
On July 11, 2008, a few minutes after approximately 1:19 p.m., after receipt of the NRC Staff s communication but prior to his receipt of the Board's instructions, David R. Lewis, counsel for Entergy, accessed the Electronic Hearing Docket to assess the situation, determine whether Entergy's questions had also been disclosed, and determine what actions to take. Mr.
Lewis saw a link identified as "Letter to Board Transmitting Proposed Questions" and opened
that document to confirm that it was not an additional release of questions for witnesses. Mr.
Lewis confirmed that this document was merely the NRC, Staff's transmittal letter without questions attached. Mnr Lewis then opened NEC's document to confirm that it was not just a transmittal letter,-too. As soon as he saw it was not a transmittal letter, he closed the document immediately without reading any of its contents or downloading it.
On July 11, 2008, immediately upon receipt of the Board's Order, counsel for Entergy contacted all members of its legal team. Counsel for Entergy directly spoke to each member of its legalteam, including its expert witnesses, except one, for whom a voice mail was left, to confirm that they had not accessed-NEC's direct examination plan and to instruct them not to do so. No Entergy witness had accessed NEC's direct examination plan. Counsel for Entergy further sent an electronic mail to all members of its legal team, including its expert witnesses, directing them not to access NEC's direct examination plan. Counsel for Entergy spoke to its one remaining expert witness on July 14, 2008. That witness had not accessed the NEC direct examination plan and was again instructed not to do so.
No member of Entergy's legal team other than Mr. Lewis accessed NEC's direct examination plan, and Mr. Lewis did not read its contents. Because no member of the Entergy legal team read the contents of NEC's direct examination plan, Entergy respectfully submits that no further action is necessary.
2
Respectfully Submitted, David R. Lewis Matias F. Travieso-Diaz Blake J. Nelson PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037-1122 Tel. (202) 663-8000 Counsel for Entergy Dated: July 15, 2008 3
UNITED STATES OFAMERICA 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 hereby certify that copies of"Entergy's Response to July 11, 2008 Board Order" 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 15th day of July, 2008.
- Administrative Judge *Administrative Judge Alex S. Karlin, Esq., Chairman Dr. Richard E. Wardwell Atomic Safety and Licensing Board Atomic Safety and Licensing Board 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 ask2@Lwnrc. gov rew@nrc.gov
- Administrative Judge *Secretary William H. Reed Att'n: Rulemakings and Adjudications Staff 1819 Edgewood Lane Mail Stop 0-16 C1 Charlottesville, VA 22902 U.S. Nuclear Regulatory Commission whrcville(ýembaramail.com Washington, D.C. 20555-0001 secy@nrc.gov, hearingdocket(&)nrc.gov
- Office of Commission Appellate Adjudication Atomic Safety and Licensing Board Mail Stop 0- 16 C I 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 OCAAmail nrc.gov
-*Lloyd Subin, Esq. *Sarah Hofmann, Esq.
- Mary Baty, Esq. Director of Public Advocacy
- Jessica A. Bielecki, Esq. Department of Public Service
- Susan L. Uttal, Esq. 112 State Street - Drawer 20 Office of the General Counsel Montpelier, VT 05620-2601 Mail Stop O-15-D21 Sarah.hofmann@state.vt.us U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 LBS3(@i)nrc.gov; mcb 1@(nrc.gov; jessica.bielecki(inrc.gov; susan.uttaI@(nrc.,gov
- Anthony Z. Roisman, Esq. *Ronald A. Shems, Esq.
National Legal Scholars Law Firm *Karen Tyler, Esq.
84 East Thetford Road Shems, Dunkiel, Kassel & Saunders, PLLC Lyme, NH 03768 9 College Street aroisman(inationaI legalscholars.com Burlington, VT 05401 rshemsnsdksl aw.com ktyler(@sdkslaw.com
- Peter L. Roth, Esq. *Marcia Carpenter, Esq.
Office of the New Hampshire Attorney General Atomic Safety and Licensing Board Panel 33 Capitol Street Mail' Stop T-3 F23 Concord, NH 03301 U.S. Nuclear Regulatory Commission Peter.roth(doj.nh. gov Washington, D.C. 20555-0001 mxc7@nrc.gov
- Lauren Bregman, Law Clerk *Diane Curran, Esq.
Atomic Safety and Licensing Board Harmon, Curran, Spielberg, & Eisenberg, U.S. Nuclear Regulatory Commission L.L.P.
Mail Stop: T-3 F23 1726 M Street N.W., Suite 600 Washington, D.C. 20555-0001 Washington, D.C. 20036 Lauren.Bregman(a2nrc.gov dcurran(aharmoncurran. corn
- Matthew Brock Assistant Attorney General Office of the Attorney General One Ashburton Place, 1 8 th Floor Boston, MA 02108 Matthew.Brock Rcstate.ma.us pI Matias F. Travieso-Diaz 2
