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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
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE 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) )
) May 28, 2014 ERRATUM TO APPLICANTS ANSWER OPPOSING NEW YORK STATES PETITION FOR REVIEW OF APRIL 1, 2014 BOARD ORDER DENYING RECONSIDERATION OF LBP-13-13 Entergy Nuclear Operations, Inc. (Entergy) has identified an incorrect date reference in a footnote in its May 23, 2014 Answer to the State of New Yorks second petition for review related to Contention NYS-12C.1 Accordingly, Entergy makes the following correction to footnote 19 on page 5 of its Answer:
See id. at 2, 5. New York did not actually request copies of the MACCS2 native format files until September 2013, over one year approximately three months after the draft SFP Consequence Study was published in June 2012 2013. See Declaration of Assistant Attorney General John Sipos, State of New York at 2 (Dec. 6, 2013)
(Attachment 1 to New York Motion to Reopen).
The June 2013 publication date for the draft SFP Consequence Study is correctly referenced elsewhere in the Answer (see, e.g., footnote 17 on pages 4-5). Entergy counsel regrets any confusion that may have resulted from that error.
1 See Applicants Answer Opposing the New York States Petition for Review of April 1, 2014 Board Order Denying Reconsideration of LBP-13-13 (May 23, 2014).
Respectfully submitted, Signed (electronically) by Paul M. Bessette MORGAN, LEWIS & BOCKIUS LLP Paul M. Bessette, Esq. 1111 Pennsylvania Avenue, N.W.
Kathryn M. Sutton, Esq. Washington, D.C. 20004 Martin J. ONeill, Esq. Phone: (202) 739-3000 E-mail: pbessette@morganlewis.com E-mail: ksutton@morganlewis.com E-mail: martin.oneill@morganlewis.com Counsel for Entergy Nuclear Operations, Inc.
Dated at Washington, D.C. this 28th day of May 2014 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 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) )
) May 28, 2014 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305 (as revised), I certify that, on this date, copies of the Erratum to Applicants Answer Opposing the New York States Petition for Review of April 1, 2014 Board Order Denying Reconsideration of LBP-13-13 were served upon the Electronic Information Exchange (the NRCs E-Filing System) in the above-captioned proceeding.
Signed (electronically) by Lance A. Escher Lance A. Escher, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1111 Pennsylvania Ave. NW Washington, DC 20004 Phone: (202) 739-5080 Fax: (202) 739-3001 E-mail: lescher@morganlewis.com Counsel for Entergy Nuclear Operations, Inc DB1/ 79265008