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| | issue date = 12/23/2010 | | | issue date = 12/23/2010 |
| | title = 2010/12/23-Entergy's Response to the Supplement to New England Coalition'S Petition for Commission Review of LBP-10-19 | | | title = 2010/12/23-Entergy's Response to the Supplement to New England Coalition'S Petition for Commission Review of LBP-10-19 |
| | author name = Lewis D R | | | author name = Lewis D |
| | author affiliation = Entergy Nuclear Operations, Inc, Entergy Nuclear Vermont Yankee, LLC, Pillsbury, Winthrop, Shaw, Pittman, LLP | | | author affiliation = Entergy Nuclear Operations, Inc, Entergy Nuclear Vermont Yankee, LLC, Pillsbury, Winthrop, Shaw, Pittman, LLP |
| | addressee name = | | | addressee name = |
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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 4S(December 23, 2010 (12:35p.m.)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF December 23, 2010 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of )) Docket No. 50-271-LR Entergy Nuclear Vermont Yankee, LLC )and Entergy Nuclear Operations, Inc. ) ASLBP No. 06-849-03-LR
)(Vermont Yankee Nuclear Power Station) )ENTERGY'S RESPONSE TO THE SUPPLEMENT TO NEW ENGLAND COALITION'S PETITION FOR COMMISSION REVIEW OF LBP-10-19 On December 13, 2010, the New England Coalition
("NEC") filed a "Supplement to New England Coalition's Petition for Commission Review of ASLBP Memorandum an Order (Ruling on New England Coalition Motion to Reopen and Proffering New Contention)." In this filing, NEC provides to the Commission a copy of NRC Information Notice 20 10-26: Submerged Electrical Cables (Dec. 2, 2010) and faults the NRC Staff for not having brought this information notice to the Commission's attention.
Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.("Entergy")
respectfully submit that this information notice is immaterial to the petition for review before the Commission.'
The information notice does not address or identify any inadequacy in the aging management program ("AMP") for non-EQ inaccessible medium voltage cable that Entergy has established in its license renewal application, or with the Petition for Commission Review of ASLBP Memorandum and Order (Ruling on New England Coalition Motion to Reopen and Proffering New Contention) (Nov. 12, 2010). NEC's Petition for Review seeks reversal of the Atomic Safety and Licensing Board's decision in LBP-10-19 denying NEC's motion to reopen the Vermont Yankee license renewal proceeding to admit a new contention challenging the aging management program for non-EQ inaccessible cable. See Entergy Nuclear Vermont Yankee, L.L.C. and Entergy Nuclear Operations, Inc.(Vermont Yankee Nuclear Power Station), LBP-10-19, 72 N.R.C. -(Oct. 28, 2010) ("LBP-10-19").
recommendations in the GALL Report on which Entergy's AMP is based. Thus, while the information notice may show that it is important to monitor and maintain safety-related cable, the information notice says nothing bearing on whether NEC had identified any significant deficiency in the AMP. Further, the information notice has no bearing on the Licensing Board's rulings in LBP-10-19 that NEC's motion to reopen had failed to satisfy the requirements of 10 C.F.R. § 2.326(a)(1) and (3). LBP-10-19, slip op. at 23-24, 26-27.Respectfully Submitted, David R. Lewis Matias F. Travieso-Diaz PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037-1128 Tel. (202) 663-8000 Counsel for Entergy December.
23, 2010 2 December 23, 2010 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of)) Docket No. 50-271-LR Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.(Vermont Yankee Nuclear Power Station)))))ASLBP No. 06-849-03-LR CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "Entergy's Response to the Supplement to New England Coalition's Petition for Commission Review of LBP-10-19," dated December 23, 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 2 3 rd day of December, 2010.*Hon. Gregory B. Jaczko Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 chairnan(J-,nrc.
gov*Hon. George Apostolakis Commissioner U.S. Nuclear Regulatory Conmmission Washington, DC 20555-0001 cmrapostolakis(iinrc.
gov*Hon. William C. Ostendorff Conmmissioner U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 cmrostendorff(&,nrc.
gov*Office of the Secretary of the Commission Attn: Rulelnakings and Adjudications Staff Hearing Docket Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 hearingdocket(mnrc.
gov*Hon. Kristine L. Svinicki Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 cmrsvinicki(d,)nrc .gov*Hon. William D. Magwood, IV Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 cmrmagwood( @nrc.gov*Office of Commission Appellate Adjudication Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 OCAAmail(a),nrc.gov
- Administrative Judge Dr. Richard E. Wardwell Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Richard.WardwellCnrc.gov s*Administrative Judge, Alex S. Karlin, Esq., Chairman Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Cormnission Washington, DC 20555-0001 Alex.Karlin(a?,nrc..
ov Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
- Lloyd Subin, Esq.*Susan L. Uttal, Esq.*Maxwell C. Smith, Esq.*Mary B. Spencer, Esq.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(ai',nrc.
gov;Maxwell.Smith amnrc.gov; Mary.Spencervnnrc.gov
- Administrative Judge William H. Reed 1819 Edgewood Lane Charlottesville, VA 22902 whrcville(1aembaicimail.com
- Raymnond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556 shadis(a3prexar.com
- Anthony Z. Roisman, Esq.National Legal Scholars Law Finn 84 East Thetford Road Lyme, NH 03768 aroi sman(Zýnati onallegal scholars.com
- Sarah Hofmann, Esq.Director of Public Advocacy Department of Public Service 112 State Street -Drawer 20 Montpelier, VT 05620-2601 Sarah.Hofmann(,state.vt.us
- Peter L. Roth, Esq.Office of the New Hampshire Attorney General 33 Capitol Street Concord, NH 03301 Peter.Roth(Thdoj.nh.gov
- Ann Hove, Law Clerk Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 U.S. Nuclear Regulatory Colmmission Washington, DC 20555-0001 Ann.Hove~d)nrc.gov
- Matthew Brock, Esq.Assistant Attorney General Office of the Attorney General One Ashburton Place, 1 8 th Floor Boston, MA 02108 Matthew.Brock(Th,state.ma.us David R. Lewis 2
