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Category:Legal-Pleading
MONTHYEARML20317A2962020-11-12012 November 2020
Applicants' Answer Opposing Riverkeeper'S Motion to Supplement the Basis of Its Contention
ML20317A3292020-11-12012 November 2020
Applicants' Answer Opposing Riverkeeper'S November 6, 2020 Motion
ML20111A3292020-04-20020 April 2020
Applicants' Answer to the State of New York'S Motion for Leave to Amend Contentions NY-2 and NY-3
ML20083G7362020-03-23023 March 2020
Petitioner Riverkeeper, Inc.'S Reply Memorandum in Further Support of Petition to Intervene and for a Hearing
ML20083K8462020-03-23023 March 2020
Reply in Support of the State of New York'S Petition for Leave to Intervene and for a Hearing
ML20069K7562020-03-0909 March 2020
Applicants' Answer Opposing Petition for Leave to Intervene and Hearing Request Filed by the State of New York
ML20069G1632020-03-0909 March 2020
Notices of Appearance for Peter Lejeune, Alan Lovett, Jason Tompkins and William Gill, IV on Behalf of Holtec International
ML20069K7612020-03-0909 March 2020
Applicants' Answer Opposing Petition for Leave to Intervene and Hearing Request Filed by the Town of Cortlandt Village of Buchanan and Hendrick Hudson School District
ML20069K7652020-03-0909 March 2020
Applicants' Answer Opposing Safe Energy Rights Group Letter Requesting a Hearing
ML20069L6132020-03-0909 March 2020
Applicants' Answer Opposing Riverkeeper Inc.'S Petition to Intervene and for a Hearing
ML17006A3872017-01-0606 January 2017
NRC Staff'S Response to the Atomic Safety and Licensing Board'S Order of December 8, 2016
ML16333A4152016-11-28028 November 2016
Entergy'S Answer Opposing Request for Hearing
ML16321A3762016-11-16016 November 2016
Entergy Nuclear Operations, Inc., Response to the Licensing Board 11/02/2016 Directive Regarding the Timing of Certain Mandatory Disclosures
ML16210A4442016-07-28028 July 2016
Notice of Appearance Vinh D. Hoang on Indian Point
ML16204A3672016-07-22022 July 2016
NYS Notice of Withdrawal, Cover Letter, Cos
ML16202A4772016-07-20020 July 2016
Notice of Appearance by Diane Curran in the Matter of Entergy Nuclear Operations, Inc. Indian Point Nuclear Generating Units 2 and 3
ML16195A3782016-07-13013 July 2016
NYS Cover Letter, Nda, and Cos
ML16193A7082016-07-11011 July 2016
Entergy Answer to State of New York Motion to Establish a Schedule for Waiver Petition and Contentions Related to NRC Continued Storage Rule
ML16193A7092016-07-11011 July 2016
NRC Staff'S Answer to New York'S Motion to Set a Schedule for the Filing of a Waiver Petition And/Or Contentions Related to Spent-Fuel Storage at Indian Point
ML16193A6852016-07-11011 July 2016
State of New York Notice of Withdrawal for Aag Kathryn Deluca
ML16180A5482016-06-28028 June 2016
2016-6-28 Third Joint Status Report Re Track 2 Schedule
ML16159A2612016-06-0707 June 2016
Second Joint Status Report Regarding Track 2 Schedule Deferral
ML16095A4012016-04-0404 April 2016
2016-4-4 Entergy Opposition to Riverkeeper Contention RK-EC-11
ML16095A3762016-04-0404 April 2016
NRC Staff Answer to Contention RK-EC-11
ML16092A3052016-04-0101 April 2016
NYS Certificate of Service
ML16092A3032016-04-0101 April 2016
NYS Cover Letter Submitting a Notice of Subsequent Event Concerning the Pending Appeal of ASLB Decision LBP-15-26
ML16092A3042016-04-0101 April 2016
State of New York Notice of Subsequent Event Concerning Pending Appeal of Atomic Safety and Licensing Board Decision LBP-15-26 and License Amendment for Entergy Indian Point Unit 2 to Delay the Containment Leak Rate Test for Five Years
ML16090A3562016-03-30030 March 2016
Joint Motion for Track 2 Hearing Schedule Deferral
ML16081A3262016-03-21021 March 2016
Certificate of Service for Corrected Staff Testimony
ML16078A4312016-03-18018 March 2016
NRC Staff'S Answer to State of New York'S Motion for Leave to File Contention NYS-40
ML16078A4142016-03-18018 March 2016
Certificate of Service for NRC Staff Testimony
ML16078A4152016-03-18018 March 2016
Entergy Opposition to Proposed New York State Contention NYS-40 Regarding Severe Accident Mitigation Alternatives
ML16067A3802016-03-0707 March 2016
NRC Staff'S Answer in Opposition to State of New York Motion to Vacate or Stay Issuance of License Amendment
ML16067A3892016-03-0707 March 2016
Entergy Answer Opposing New York State Motion for a Stay
ML16055A2092016-02-24024 February 2016
Notification of Issuance of License Amendment
ML16054A7792016-02-23023 February 2016
Revised Certificate of Service
ML16053A2142016-02-22022 February 2016
Commission Notification of Significant Licensing Action
ML16054A6722016-02-22022 February 2016
NYS Contention 40
ML15357A2552015-12-23023 December 2015
Westinghouse Electric Company'S Opposition to New York State'S Motion for Disclosure of Proprietary Documents
ML15356A8462015-12-22022 December 2015
Attachments 1 and 2 to NRC Staff Answer in Opposition to the State of New York'S Third Motion to Compel Public Disclosure of Confidential Westinghouse Documents
ML15356A8452015-12-22022 December 2015
NRC Staff'S Answer to New York Third Motion to Compel Public Disclosure of Confidential Westinghouse Documents
ML15348A4562015-12-14014 December 2015
Declaration of Dr. Joram Hopenfeld in Support of State of New York Motion to Withdraw Proprietary Designations of Westinghouse Documents
ML15320A5032015-11-16016 November 2015
NRC Staff Answer to New York Appeal of LBP-15-26
ML15320A5502015-11-16016 November 2015
Entergy Answer Opposing NYS Appeal of LBP-15-26
ML15319A0052015-11-15015 November 2015
Entergy Answer Opposing New York Motion for Leave to File Five Hearing Exhibits (Corrected)
ML15316A3032015-11-12012 November 2015
NYS Supplemental Briefing on Motion for Public Disclosure of Various Westinghouse Documents
ML15316A3042015-11-12012 November 2015
NYS Certificate of Service
ML15315A0242015-11-11011 November 2015
Westinghouse'S Supplemental Response Re Westinghouse'S Appearance and Proprietary Documents
ML15313A4612015-11-0909 November 2015
NYS Certificate of Service
ML15309A1562015-11-0505 November 2015
NYS Certificate of Service for Revised Tailored Exhibit List
2020-04-20
[Table view] |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Docket Nos. 50-247-LR
) and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
) April 7, 2014 HUDSON RIVER SLOOP CLEARWATER, INC.
COMBINED REPLY TO ANSWERS OF APPLICANT AND NRC STAFF TO CLEARWATER, INC.S PETITION FOR REVIEW OF LBP-13-13, REGARDING CONTENTION CW-EC-3A (ENVIRONMENTAL JUSTICE)
HUDSON RIVER SLOOP CLEARWATER, INC.
Andrew B. Reid, Esq.
Springer & Steinberg, P.C.
1600 Broadway, Suite 1200 Denver, CO 80202 Tel: 303.861.2800 / Fax: 303.832.7116 Email: areid@springer-and-steinberg.com 1
Intervenor Hudson River Sloop Clearwater, Inc. [hereinafter Clearwater] hereby makes its combined Reply to the March 25, 2014 Answers of Applicant and NRC Staff to Clearwaters February 14, 2014, Petition for Review of LBP-13-13, regarding contention CW-EC-3A on Environmental Justice (hereinafter Clearwaters Petition for Review).
Clearwater joins and adopts as though set forth here in full the March 11, 2014, State of New York Answer in Support of Clearwater Inc.s Petition for Review.
Further, in that Applicant and NRC Staff in their Answers reassert arguments made in their related and separate February 14, 2014, Petitions for Commission Review of LBP-13-13, Clearwater adopts and reasserts its March 25, 2014, Combined Answer in Opposition to those Petitions for Review as though set forth here in full.
Wherefore, Clearwater requests that the Commission grant Clearwaters Petition for Review and deny the Petitions for Review of Applicant and NRC Staff in regard to LBP-13-13 contention CW-EC-3A (Environmental Justice).
Respectfully Submitted, Signed (electronically) by Andrew B. Reid Andrew B. Reid, Esq.
Springer & Steinberg, P.C.
1600 Broadway, Suite 1200 Denver, CO 80202 Tel: 303.861.2800 / Fax: 303.832.7116 Email: areid@springer-and-steinberg.com Dated: April 7, 2014, Denver, Colorado.
2
3 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305 (as revised), I certify that, on this date, copies of the HUDSON RIVER SLOOP CLEARWATER, INC. COMBINED REPLY TO ANSWERS OF APPLICANT AND NRC STAFF TO CLEARWATER, INC.S PETITION FOR REVIEW OF LBP-13-13, REGARDING CONTENTION CW-EC-3A (ENVIRONMENTAL JUSTICE) were served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned proceeding.
Dated: April 7, 2014.
Signed (electronically) by Andrew B. Reid Andrew B. Reid, Esq.
Springer & Steinberg, P.C.
1600 Broadway, Suite 1200 Denver, CO 80202 Tel: 303.861.2800 / Fax: 303.832.7116 Email: areid@springer-and-steinberg.com 4
