Entergy'S Response in Opposition to New England Coalition'S Stay RequestML100740370 |
Person / Time |
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Site: |
Vermont Yankee |
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Issue date: |
03/12/2010 |
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From: |
Doris Lewis Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee, Pillsbury, Winthrop, Shaw, Pittman, LLP |
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To: |
NRC/OCM |
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SECY RAS |
References |
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2.206, 50-271-LR, ASLBP 06-849-03-LR, LBP-09-09, RAS M-439 |
Download: ML100740370 (8) |
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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 March 12, 2010 (2:15pm)
March 12, 2010 OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission 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 IN OPPOSITION TO NEW ENGLAND COALITION'S STAY REOUEST Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.
("Entergy") submit this response opposing the stay requested in this docket in New England Coalition's ("NEC") March 2, 2010 letter to the Commission ("Request"). NEC requests that the Commission "stay any further action" on NEC's Petition for Review of the Licensing Board's Full Initial Decision, LBP-09-09 (July 23, 2009) ("Appeal") in the Vermont Yankee license renewal proceeding until NEC's February 8, 2010 petition under 10 C.F.R. § 2.206 ("2.206 Petition") and the Commission's March 1, 2010 Demand For Information ("DFI") are resolved.
For the reasons discussed below, NEC's Request is not only procedurally deficient but also baseless. It should therefore be denied.
First, NEC has not met any of the procedural or substantive requirements for requesting a stay. This alone is sufficient grounds for denial.
Second, apart from its deficiencies in form and substance, NEC's Request is not warranted by any facts. The issues that NEC has raised before the Commission in its Appeal in this license renewal proceeding are limited to: (1) whether the Licensing Board treated NEC's
witness fairly in the hearing on Entergy's program for managing the effects of environmentally assisted fatigue on VY's critical reactor components, and (2) whether the Board erred in later rejecting a late-filed contention on the same topic. See Appeal at 12, 14. Neither the 2.206 Petition nor the DFI have anything to do with these issues on appeal.,
NEC's Request and 2.206 Petition do not refer to, or even mention, environmentally assisted fatigue of reactor components. The Request and the 2.206 Petition focus entirely on the
"[i]ncreasing concentrations of radio-contaminants in the soil and groundwater" that have been recently discovered at Vermont Yankee and whose causes are under investigation. See 2.206 Petition at 1. There is no relationship between possible releases of radionuclides to the soil and groundwater and the issues that NEC has raised before the Commission in its Appeal in this matter.
Similarly, there is no relationship between the DFI and the issues raised by NEC's Appeal. The DFI has nothing to do with whether the Licensing Board treated NEC's witness fairly or whether it was correct in later denying admission of an additional late-filed contention on the same topic.
Moreover, none of Entergy's witnesses in the hearing before the Licensing Board in this NRC license renewal proceeding are the subject of the DFI. Further, NEC received extensive document disclosure in the adjudicatory proceeding, including the engineering calculations and analyses demonstrating that environmentally-assisted fatigue will be adequately managed.
NEC's own expert had the opportunity to examine this documentation. NEC also had the opportunity to submit proposed questions for the Licensing Board to ask Entergy's witnesses, Indeed, it is improper for a 10 C.F.R. § 2.206 petition to raise any matter that could be addressed in an ongoing licensing proceeding, particularly one where the petitioner is already a party. NRC Management Directive 8.11, "Review Process for 10 C.F.R. 2.206 Petitions" (Oct. 25, 2000), Handbook 8.11 at 11. See, e.g., Entergy Nuclear Vermont Yankee, LLC (Vermont Yankee Nuclear Power Station), DD-05-2, 62 N.R.C. 389, 390 (2005).
2
and the Board conducted an extensive examination of the witnesses. In sum, NEC had ample opportunity to litigate its Contention and probe the evidence.
Finally, any further delay in the resolution of NEC's Appeal would be contrary to the longstanding Commission commitment to the expeditious completion of adjudicatory proceedings. See, e.g*, Statement of Policy on the Conduct of Adjudicatory Proceedings, CLI-98-12, 48 N.R.C. 18, 24 (1998). As the Commission stated, "applicants for a license are...
entitled to a prompt resolution of disputes concerning their applications." Id. at 19. Consistent with the Commission's Policy Statement, Entergy urges the Commission to complete its review and render a timely decision on the issues that have been raised in NEC's Appeal in this proceeding.
For all of these reasons, the Commission should deny NEC's Request for a stay of action on NEC's Appeal in the Vermont Yankee license renewal proceeding.
Respectfully submitted,
[original signed by David R. Lewis]
David R. Lewis Matias F. Travieso-Diaz Blake J. Nelson PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037-1128 Tel. (202) 663-8000 Counsel for Entergy Dated: March 12, 2010 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission 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 In Opposition To New England Coalition's Stay Request" dated March 12, 2010, 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 12th day of March, 2010.
- Office of Commission Appellate Adjudication
- Secretary Mail Stop 0-16 C I Att'n: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Mail Stop 0-16 C I Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission OCAAmail@nrc.gov Washington, DC 20555-0001 hearingdocket@nrc.gov
- Hon. Gregory B. Jaczko *Hon. Kristine L. Svinicki Chairman Commissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 chairman@nrc.gov cmrsvinicki@nrc.gov
- Hon. Dale E. Kline Atomic Safety and Licensing Board Commissioner Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 cmrklein@nrc.gov
- 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, DC 20555-0001 Washington, DC 20555-0001 Alex.Karlin@nrc.gov Richard.Wardwell@nrc.gov
- Administrative Judge *Lloyd Subin, Esq.
William H. Reed *Susan L. Uttal, Esq.
1819 Edgewood Lane *Maxwell C. Smith, Esq.
Charlottesville, VA 22902 *Mary B. Spencer, Esq.
whrcville@embarqmail.com Office of the General Counsel Mail Stop O-15-D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 lloyd.subin@nrc.gov; susan.uttal@nrc.gov; maxwell.smith@nrc.gov; Mary.Baty@nrc.gov
- Raymond Shadis *Sarah Hofmann, Esq.
New England Coalition Pro Se Representative Director of Public Advocacy Post Office Box. 98 Department of Public Service Edgecomb, ME 04556 112 State Street - Drawer 20 shadis@prexar.com Montpelier, VT 05620-2601 Sarah.hofmann@state.vt.us
- Matthew Brock National Legal Scholars Law Firm Assistant Attorney General 84 East Thetford Road Office of the Attorney General Lyme, NH 03768 One Ashburton Place, 1 8 th Floor aroisman@nationallegalscholars.com Boston, MA 02108 Matthew.Brock@state.ma.us
- Zachary Kahn 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, DC 20555-0001 zachary.kahn@nrc.gov
[original signed by David R. Lewis]
David Lewis 2
IHearing Docket From: Lewis, David R. [david.lewis@pillsburylaw.com]
Sent: Friday, March 12, 2010 2:15 PM To: OCAAMAIL Resource; Docket, Hearing; CHAIRMAN Resource; CMRSVINICKI Resource; CMRKLEIN; Karlin, Alex; Wardwell, Richard; whrcville@embarqmail.com; Uttal, Susan; Subin, Lloyd; Smith, Maxwell; Spencer, Mary; Mr. Raymond Shadis; Sarah.hofmann@state.vt.us; aroisman@nationallegalscholars.com; peter.roth@doj.nh.gov; Matthew.Brock@state.ma.us; Cc: Kahn, Zachary Travieso-Diaz, Matias F.
Subject:
Entergy Nuclear Vermont Yankee, LLC, and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), Docket No. 50-271-LR, ASLBP No. No. 06-849-03-LR Attachments: Entergy Opposition to NEC Stay Reques.pdf Attached please find "Entergy's Response in Opposition to New England Coalition's Stay Request" in the above captioned proceeding. A copy of this pleading has also been served by mail. If you have any difficulty opening this attachment, please contact me at the number below.
David Lewis Counsel for Entergy
<<Entergy Opposition to NEC Stay Reques.pdf>>
David Lewis I Pillsbury Winthrop Shaw Pittman LLP Tel: 202.663.84741 Fax: 202.663.8007 I Cell: 703.501.7708 2300 N Street, N.W. I Washington, DC 20037-1122 Email: david.lewisapillsburylaw.com Bio: www.pillsburylaw.com/firstname.lastname www.pillsburylaw.com 1
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Subject:
Entergy Nuclear Vermont Yankee, LLC, and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), Docket No.
50-271-LR, ASLBP No. No. 06-849-03-LR Date: Fri, 12 Mar 2010 14:14:42 -0500 Message-ID:
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From: "Lewis, David R." <david.lewis@pillsburylaw.com>
To: <OCAAMAIL@nrc.gov>, <hearingdocket@nrc.gov>, <chairman@nrc.gov>,
<cmrsvinicki@nrc.gov>, <cmrkleih@nrc.gov>, <ask2@nrc.gov>, <rew@nrc.gov>,
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<maxwell.smith@nrc.gov>, <Mary.Baty@nrc.gov>, "Mr. Raymond Shadis"
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<aroisman@nationallegalscholars.com>, <peter.roth@doj.nh.gov>,
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CC: "Travieso-Diaz, Matias F." <matias.travieso-diaz@pillsburylaw.com>
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