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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
[Table view] |
Text
DOCKETED
-P nAs E ý-q6 L5-February 23, 2011 (11:37a.m.)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL ERIC T. SCHNEIDERMAN DIVISION OF SOCIAL JUSTICE ATTORNEY GENERAL ENVIRONMENTAL PROTECTION BUREAU February 23, 2011 Lawrence G. McDade, Chair Richard E. Wardwell Dr. Kaye D. Lathrop Atomic Safety and Licensing Board Administrative Judge Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission 190 Cedar Lane E.
Two White Flint North Mail Stop - T-3 F23 Ridgway, CO 81432 11545 Rockville Pike Two White Flint North Rockville, MD 20852-2738 11545 Rockville Pike Rockville, MD 20852-2738 Re: License Renewal Application submitted by Entergy Indian Point Unit 2, LLC, Entergy Indian Point Unit 3, LLC, and Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Station, Unit 2 and Unit 3 Docket Nos. 50-247-LR/50-286-LR: ASLBP No. 07-858-03-LR-BDOI
Dear Administrative Judges:
On February 18, 2011, the State of New York filed an "Unopposed Motion For An Extension Of Time To File A Reply To Answers On The State's Motion For Leave To File.
Amended Bases On Contention 17A/B And For Enlargement Of Page Limitation For The State's Consolidated Answer To Separate Motions For Summary Disposition On Contention 35/36." The State wishes to withdraw its request for an enlargement of the page limitation, as it has been able to prepare a consolidated answer to NRC Staff and Entergy's opposition and cross-motion concerning Contentions 35 and 36 which is within the Board's 25-page limit. This reply will be filed later today. The State maintains its request for an extension of time to file a reply to answers on the State's motion for leave to file amended bases on Contention 17 A/B.
A hard copy of this. letter will be served along with the State's reply to NRC Staff and Entergy's opposition and cross-motion concerning Contentions 35 and 26 later today.
Respectfully submitted,
.-TEP90frTEa .CL( cur1 Janice A. Dean The Capitol, Albany, NY 12224 0 (518) 474-8096 & Fax (518) 473-2534 (Not for Service of Papers) @ http://www.oag.state.ny.us
Assistant Attorney General '
Office of the Attorney General 120 Broadway, 26th Floor New York, NY 212-416-8459 janice.dean@ag.ny.gov cc: Service List The Capitol, Albany, NY. 12224 0 (518) 474-8096 0 Fax (518) 473-2534 (Not for Service of Papers) 0 http://www.oag.state.ny.us
