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| Line 5: |
Line 5: |
| | author name = Curran D | | | author name = Curran D |
| | author affiliation = US Federal Judiciary, Court of Appeals, 1st Circuit | | | author affiliation = US Federal Judiciary, Court of Appeals, 1st Circuit |
| | addressee name = Donovan R C | | | addressee name = Donovan R |
| | addressee affiliation = NRC/NRR, US Federal Judiciary, Court of Appeals, 1st Circuit | | | addressee affiliation = NRC/NRR, US Federal Judiciary, Court of Appeals, 1st Circuit |
| | docket = 05000271 | | | docket = 05000271 |
| | license number = | | | license number = |
| | contact person = Hamrick C S, OGC, 301-415-4106 | | | contact person = Hamrick C, OGC, 301-415-4106 |
| | case reference number = 07-1482, 07-1483 | | | case reference number = 07-1482, 07-1483 |
| | document type = Legal-Brief, Legal-Correspondence | | | document type = Legal-Brief, Legal-Correspondence |
| Line 19: |
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| ==Subject:== | | ==Subject:== |
| Commonwvealth of Massachusetts | | Commonwvealth of Massachusetts |
| : v. NRC, No. 07-1482 | | : v. NRC, No. 07-1482 |
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Revision as of 18:04, 12 July 2019
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Category:Legal-Brief
MONTHYEARML12066A1802012-03-0606 March 2012
Petitioners Reply Brief 11-1168, on Petition for Review of a Decision of U.S. Nuclear Regulatory Commission, Joint Reply Brief of Vermont Dept. of Public Service and New England Coalition, Inc
Information Notice 2010-26, 2010/12/21-NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-262010-12-21021 December 2010
2010/12/21-NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26
ML1035703562010-12-13013 December 2010
Supplement to New England Coalition'S Petition for Commission Review of ASLBP Memorandum and Order (Ruling on New England Coalition Motion to Reopen and Proffering New Contention)
ML1032607072010-11-22022 November 2010
NRC Staff'S Answer in Opposition to New England Coalition'S Petition for Review of Licensing Board Memorandum and Order LBP-10-19
ML1032104212010-11-12012 November 2010
Petition for Commission Review of ASLBP Memorandum and Order (Ruling on New England Coalition Motion to Reopen and Proffering New Contention)
ML0921706402009-08-0303 August 2009
the States of New York, Connecticut, and Massachusetts V. USNRC and Entergy Nuclear Operations Inc., 08-3903ag(L) - Federal Respondents Brief (Entergy)
ML0835900282008-12-23023 December 2008
Vermont Yankee - NRC Staff'S Reply to Vermont Department of Public Service'S Answer to NRC Staff'S Petition for Review of LBP-08-25
ML0834602262008-12-10010 December 2008
Vermont Yankee - NRC Staff'S Answer in Opposition to the Commonwealth of Massachusetts' Petition for Review of LBP-08-25
ML0834703372008-12-0202 December 2008
Petition for Review of LBP-08-25
ML0820501042008-07-15015 July 2008
New England Coalition, Inc. Supplemental Prehearing Reply Brief
ML0819704832008-07-0909 July 2008
DPS Brief in Response to the Board'S June 27, 2008 Order Seeking the Parties' Position on Three Legal Issues
ML0819704812008-06-0909 June 2008
New England Coalition, Inc. Supplemental Prehearing Brief
ML0817500352008-05-13013 May 2008
Entergy'S Initial Statement of Position on New England Coalition Contentions
ML0817500382008-05-12012 May 2008
Exhibits to Entergy'S Direct Testimony on NEC Contention 4 - Flow-Accelerated Corrosion Includes Exhibits E4-02 Through E4-29, Volume 1
ML0817500392008-05-12012 May 2008
Exhibits to Entergy'S Direct Testimony on NEC Contention 4 - Flow-Accelerated Corrosion Includes Exhibits E4-30 Through E4-42, Volume 2
ML0817500362008-05-12012 May 2008
Exhibits to Entergy'S Direct Testimony on NEC Contention 2 - Environmentally Assisted Fatigue - Includes Exhibits E2-02 Through E2-20, Volume 1
ML0803806322008-01-18018 January 2008
2008/01/18-Answer of Crorip and Nancy Burton to the Petition by Nuclear Information and Resource Service Et Al. to Suspend License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim and Vermont Yankee Nuclear Power Plants Pending Inves
ML0803005302008-01-18018 January 2008
2008/01/18-State of New York'S Response in Support of the Petition to Suspend License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants Pending Investigation of NRC Staff Review Process.
ML0803005312008-01-18018 January 2008
2008/01/18-Answer of the Vermont Department of Public Service to the Petition by Nuclear Information and Resource Service Et Al to Suspend License Renewal Review For...Vermont Yankee Nuclear Power Plants Pending Investigation of NRC Staff R
ML0802205872008-01-14014 January 2008
2008/01/14-Errata to Petition to Suspend License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants Pending Investigation of NRC Staff Review Process and Correction of Deficiencies
ML0800904272008-01-0303 January 2008
2008/01/03-Petition by Nirs Et. Al., to Suspend License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants, Pending Investigation of NRC Staff Review Process and Correction of Deficiencies
ML0732503512007-11-0808 November 2007
Commonwealth of Massachusetts V. United States and U.S. Nuclear Regulatory Commission, Nos 07-1482; 07-1483; Reply Brief for Petitioner Commonwealth of Massachusetts
ML0730502172007-10-31031 October 2007
Commonwealth of Massachusetts V. NRC, No. 07-1482
ML0724904972007-08-22022 August 2007
Commonwealth of Massachusetts V. USNRC; Nos. 07-1482 and 07-1483; Brief for Petitioner
ML0704500362007-02-0606 February 2007
Entergy'S Reply to New England Coalition'S Brief on Review of LBP-06-20
ML0703800522007-02-0606 February 2007
Vermont Yankee - NRC Staff Reply Brief in Response to CLI-07-01
ML0704500332007-02-0505 February 2007
Appellee New England Coalition'S Reply Brief
ML0703302172007-01-29029 January 2007
Appellee New England Coalition'S Brief
ML0703706102007-01-29029 January 2007
Entergy'S Brief on Review of LBP-06-20
ML0703000322007-01-29029 January 2007
NRC Staff Brief in Response to CLI-07-01
ML0634706192006-12-0707 December 2006
Joint Submittal of Proposed Protective Order and Confidentiality Agreement Regarding Proprietary Documents
ML0631700512006-11-0303 November 2006
Entergy'S Objections to New England Coalition'S Proposed Hearing Transcript Corrections
ML0629903302006-10-20020 October 2006
New England Coalition, Inc.'S Opposition to Entergy'S Petition for Interlocutory Review of LBP-06-20 Admitting New England Coalition'S Contention 1
ML0629603202006-10-20020 October 2006
Vermont Yankee - NRC Staff Answer to Entergy'S Petition for Interlocutory Review of LBP-06-20
ML0629300382006-10-13013 October 2006
Entergy'S Brief in Opposition to the Massachusetts Attorney General'S Appeal of LBP-06-20
ML0628904532006-10-13013 October 2006
Vermont Yankee - NRC Staff Brief in Opposition to Massachusetts Attorney General'S Appeal of LBP-06-20
ML0629205442006-10-10010 October 2006
Entergy'S Petition for Interlocutory Review of LBP-06-20 Admitting New England Coalition'S Contention 1
ML0628601562006-10-0303 October 2006
Massachusetts Attorney General'S Notice of Appeal of LBP-06-20, with Accompanying Brief
ML0627603902006-09-25025 September 2006
Entergy'S Response to New England Coalition'S Letter to Board
ML0617700392006-06-14014 June 2006
New England Coalition'S Response to the Statements of Position of Entergy and NRC Staff, with Declaration of Dr. Joram Hopenfeld in Support of New England Coalition'S Response to the Statements of Position of Entergy and NRC Staff
ML0616700922006-06-14014 June 2006
NRC Staff'S Response to the Initial Statements of Position Filed by Other Parties
ML0614203882006-05-17017 May 2006
NRC Staff'S Initial Statement of Position Concerning NEC Contention 3
ML0614203692006-05-17017 May 2006
Nrc'S Staff Initial Statement of Position Concerning NEC Contention 4
ML0609000062006-03-30030 March 2006
Vermont Yankee - NRC Staff'S Answer to New England Coalition'S Brief on the Legal Scope of New England Coalition Contention 4
ML0606502992006-02-21021 February 2006
Entergy'S Response to the New England Coalition'S Brief on the Scope of Modified Contention NEC 4
ML0605301562006-02-21021 February 2006
Vermont Yankee - NRC Staff'S Response to New England Coalition'S Brief Concerning the Scope of NEC Contention 4
ML0605401782006-02-14014 February 2006
New England Coalition'S Brief on the Scope of Its Contention Regarding Inadequate Analysis of the Vermont Yankee Alternate Cooling System Performance Under Conditions of Extended Power Uprate
ML0534100082005-12-0202 December 2005
Vermont Yankee - NRC Staff'S Answer to Vermont Department of Public Service'S Third Motion to Compel
ML0530002512005-10-21021 October 2005
NRC Staff Response to the Atomic Safety and Licensing Board'S Order of September 30, 2005, Regarding Vermont Department of Public Service'S First Motion to Compel
2012-03-06
[Table view]
Category:Legal-Correspondence
MONTHYEARML12181A4902012-06-26026 June 2012
6/26/12 - Vermont Pub Serv V NRC Opinion
ML12181A5092012-06-26026 June 2012
Order Denying Petitions for Review
ML12146A1592012-05-21021 May 2012
5/25/12 - Fed Respondents Post Argument Filing
ML1211006992012-04-13013 April 2012
Order - Deferring Motion to Strike
ML1211006872012-04-12012 April 2012
Motion for Admission Pro Hac Vice
ML1211007042012-04-0909 April 2012
Order - VY Order Support Appendix
ML12152A0802012-03-19019 March 2012
Final Respondents Brief
ML12152A1062012-03-19019 March 2012
Entergy Final Brief
ML1203004582012-01-27027 January 2012
Oral Argument Scheduled for May 9, 2012, Vermont Dept of Public Service,Et, Al., Petitioners V. USNRC, Et Al., Respondents
ML1105407332011-02-23023 February 2011
Letter from Annette L. Vietti-Cook to the Honorable Paul W. Hodes Re Director'S Decision 11-01
ML1019305132010-07-12012 July 2010
Memorandum to the Participants Chairman Gregory B. Jaczko'S Upcoming Tour of the Vermont Yankee Nuclear Power Station and Round Table Discussion
ML0914106802009-05-21021 May 2009
2009/05/21-Vermont Yankee - Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station - Supplement 1
ML0906903022009-02-26026 February 2009
Letter to Board Advising of Some Inconsequential Cha Nges in the Confirmatory Environmentally Assisted Fatigue Analyses That Were Provided to the Parties on January 9, 2009
ML0902305552009-01-0808 January 2009
in the Matter of Entergy Nuclear Vermont Yankee, LLC, and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station). CUF Analyses on CS Nozzle and RO Nozzle at Vermont Yankee Nuclear Power Station
ML0903303352009-01-0808 January 2009
Entergy Nuclear Vermont Yankee, LLC, and-Entergy Nuclear Operations, Inc., (Vermont Yankee), Corrected Letter to Board & Parties Re Confirmatory Calculations for CS & RO
ML0900502542008-12-23023 December 2008
Motion for Leave and Brief Amicus Curiae on Parties in the Matter of Entergy Nuclear Vermont Yankee, and Entergy Nuclear Operations in Reliance Upon Certificate of Service List from NRC Staff'S Petition for Review Dated December 9, 2008
ML0823211072008-08-13013 August 2008
Joint Proposed Transcript Corrections
ML0821200552008-07-18018 July 2008
Request for Explanation Re. Absence of Kenneth Chang to Testify
ML0820605492008-07-18018 July 2008
State of New Hampshire List of Hearing Attendees
ML0820406362008-07-15015 July 2008
New England Coalition, Inc.'S List of Hearing Attendees
ML0820406162008-07-14014 July 2008
Entergy'S List of Hearing Attendees
ML0819602912008-07-11011 July 2008
Vermont Yankee - Letter to Administrative Judges Transmitting Staff Non- Disclosure Agreements for Hearing
ML0819602392008-07-11011 July 2008
Vermont Yankee - Letter to Administrative Judges Regarding Unavailability of NRC Staff Witness for Hearing July 20, 2008
ML0817506792008-06-20020 June 2008
Vermont Yankee - Letter to Board Transmitting Proposed Questions
ML0816908252008-06-17017 June 2008
Vermont Yankee - NRC Staff Hearing File Update Supplement 23
ML0815504222008-05-28028 May 2008
Commonwealth of Massachusetts' Designation of Single Representative
ML0814906312008-05-28028 May 2008
2008/05/28-Letter to Board from Staff Transmitting NUREG-1907-Safety Evaluation Report Related to License Renewal of Vermont Yankee Nuclear Power Station, Volumes 1 and 2
ML0814306822008-05-22022 May 2008
Letter to Atomic Safety and Licensing Board Corrected Affidavit of Kenneth Chang (Exhibit 2) and Missing Page 4-43 to Staff Exhibit 1
ML0812903772008-05-0202 May 2008
2008/05/02-Memorandum to Chairman Klein from the Inspector General on the Subject of NRC Staff Review of License Renewal Applications
ML0812805922008-04-29029 April 2008
New England Coalition, Inc.'S (NEC) Motion to Withdraw Motion to Compel and for Subpoena
ML0812603282008-04-25025 April 2008
in the Matter of Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 & 3), Forwarding Courtesy Copy of Court of Appeals Decision to Deny Commonwealth of Massachusetts' Petitions for Review for Pilgrim and Vermont Yanke
ML0810704562008-04-0404 April 2008
Entergy'S Statement of Witness Availability
ML0810502602008-04-0404 April 2008
New England Coalition, Inc.'S (NEC) Statement of Witness Availability
ML0810501382008-04-0404 April 2008
Transmittal of State of New Hampshire'S Statement of Date Blackout
ML0810603232008-04-0303 April 2008
2008/04/03-State of Vermont Response to Order Requiring Information of Anticipated Schedule Conflicts in August and September Evidentiary Hearings for Vermont Yankee Nuclear Power Station License Renewal
ML0807204812008-03-12012 March 2008
Vermont Yankee - NRC Staff Declaration of Position
ML0807401992008-03-0707 March 2008
New England Coalition, Inc.'S (NEC) Final Witness List
ML0807204262008-03-0606 March 2008
Entergy'S Final List of Witnesses
ML0806700882008-03-0606 March 2008
Vermont Yankee - NRC Staff Final Witness List
ML0805706532008-02-26026 February 2008
Vermont Yankee - Letter to the Licensing Board Regarding Issuance of SER
ML0733212822007-11-26026 November 2007
E-mail from Sarah Hofmann to the Board and Parties Re Black Out Dates for Evidentiary Hearings
ML0731204512007-11-0808 November 2007
Commonwealth of Massachusetts V. United States Nuclear Regulatory Commission and the United States of America, Nos. 07-1482, 07-1483 (Consolidated)
ML0731204532007-11-0101 November 2007
Commonwealth of Massachusetts V. United States and Unites States Nuclear Regulatory Commission Nos. 07-1482; 07-1483
ML0730502172007-10-31031 October 2007
Commonwealth of Massachusetts V. NRC, No. 07-1482
ML0727500532007-10-0101 October 2007
Letter from J. Samuel Walker to Scott H. Strauss and Rebecca J. Baldwin Re Local 369 Petition for Leave to Intervene
ML0725601052007-08-29029 August 2007
Commonwealth of Massachusetts V. USNRC, Nos. 07-1482 and 07-1483; Unopposed Motion for Extension of Time to File Respondents' Brief
ML0721900342007-07-24024 July 2007
Letter from Karen Tyler Enclosing a Complete Copy of Attachment A. an Incomplete Copy Was Erroneously Filed with New England'S Coalition, Inc.'S Supplement to Opposition to Entergy'S Motion for Summary Disposition...Dated 07/19/07
ML0719302612007-07-11011 July 2007
Notice of Withdrawal of Mitzi A. Young
ML0719903452007-06-29029 June 2007
Letter from Sarah Hofmann to Administrative Judges Informing That the Counsel for the Vermont Department of Public Service Are Available Any of the Dates for the Site Visit Except for October 5, 8, 9 and 10
ML0718702962007-06-29029 June 2007
Letter from Sarah Hofmann to Administrative Judges Informing That Counsel for the Vermont Department of Public Service Are Available Throughout February and March of 2008 for Hearings
2012-06-26
[Table view] |
Text
mHARMON, CURRAN, SPlILBERG, / EISENBERG, LLP 1726 M Street, NW, Suite 600 Washington, DC 20036 328-3500 (202) 328-6918 fax August 29, 2007 BY FEDERAL EXPRESS Richard Cushing Donovan, Clerk United States Court of Appeals for the First Circuit 1 Courthouse Way, Suite 2500 Boston, MA 02110 617-748-9057
Subject:
Commonwvealth of Massachusetts
- v. NRC, No. 07-1482
Dear Mr. Donovan:
Enclosed for filing please find the original and ten copies of an Errata to Commonwealth of Massachusetts' Opening Brief. Copies have been served on the parties by first class mail.Thank you for your consideration.
Sincerely, Diane Curran Cc: Service list UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT)COMMONWEALTH OF )MASSACHUSETTS, ))Petitioner, ))v. ) Nos. 07-1482 and) 07-1483 UNITED STATES NUCLEAR REGULATORY
)COMMISSION, and the UNITED STATES )OF AMERICA ))Respondents
))and ))ENTERGY NUCLEAR OPERATIONS, INC., )ENTERGY NUCLEAR VERMONT )YANKEE LLC, and ENTERGY NUCLEAR )GENERATION COMPANY ))Intervenors
))ERRATA TO COMMONWEALTH OF MASSACHUSETTS' OPENING BRIEF Petitioner, the Commonwealth of Massachusetts, hereby submits a list of clerical corrections to its opening brief, filed on August 22, 2007.Page Line Correction 11 2 Change "the expert report" to "an expert report" 21 7 Change "462 U.S. at 101 (1983)" to "462 U.S. 87, 101 (1983)"
Page Line Correction 29 7 Insert "(McGuire/Catawba)" after "(2002)" 29 10 Change "51.71(d)(4)" to "51.95(d)(4)" 30 2 Change "51.71(d)(3)" to "51.95(d)(3)" 30 n.13 On line 5, insert "(ADAMS Accession Nos. ML071990020 and ML071990027)" after "(July 2007)" 30 n.13 On line 7, insert "(ADAMS Accession Nos. ML0702050012 and ML072050013)" after "(July 2007)" 33 n.15 On line 33, change "delcaring" to "declaring" Respectfully submitted, By its Attorneys MARTHA COAKLEY ATTORNEY GENERAL Diane Curran Harmon, Curran, Spielberg,& Eisenberg, L.L.P.1726 M Street N.W., Suite 600 Washington, DC 20036 (202) 328-3500 Matthew Brock Assistant Attorney General Environmental Protection Division Office of the Attorney General One Ashburton Place Boston, MA 02108 (617) 727-2200 X 2425 Date: August 29, 2007 2 Certificate of Service I hereby certify that on August 29, 2007, copies of the Errata to Commonwealth of Massachusetts' Opening Brief were served by first class mail upon the following:
John F. Cordes, Jr. Esq.Solicitor Office of General Counsel U.S. Nuclear Regulatory Commission U.S. NRC Mail Stop 0-15D21 Washington, D.C. 20555-0001 Steven C. Hamrick, Esq.Office of the General Counsel U.S. Nuclear Regulatory Commission U.S. NRC Mail Stop 0-15D21 Washington, DC 20555 Paul A. Gaukler, Esq.David R. Lewis, Esq.Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street N.W.Washington, DC 20037 Alberto Gonzales, Esq.Attorney General of the United States U.S. Department of Justice 950 Pennsylvania Avenue Washington, D.C. 20530 Diane Curran
