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| | number = ML081910672 | | | number = ML081910672 |
| | issue date = 06/30/2008 | | | issue date = 06/30/2008 |
| | title = 2008/06/30-Vermont Department of Public Service Request for Clarification And/Or Request Leave to File Separate Brief | | | title = Vermont Department of Public Service Request for Clarification And/Or Request Leave to File Separate Brief |
| | author name = Hofmann S | | | author name = Hofmann S |
| | author affiliation = National Legal Scholars Law Firm, PC, State of VT, Dept of Public Service | | | author affiliation = National Legal Scholars Law Firm, PC, State of VT, Dept of Public Service |
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Category:Legal-Motion
MONTHYEARML18348A9852018-12-14014 December 2018
New England Coalition'S Withdrawal of Its Request for a Hearing and Petition for Leave to Intervene
ML18071A4142018-03-12012 March 2018
Amended Motion to Hold in Abeyance Action on New England Coalition'S Petition for Leave to Intervene and Hearing Request in Consideration of Anticipated Withdrawal
ML17164A2682017-06-13013 June 2017
Attachment Two - Five E-mails Tracing Efforts on June 9, 2017 to File a Request for an Extension of Time
ML17164A2382017-06-13013 June 2017
Resubmitted Request for Extension of Time to File Request for Hearing and Petition for Leave to Intervene
ML17164A2392017-06-13013 June 2017
Request for Leave to Reply and Reply to Applicants' Response to New England Coalition'S Request for Extension
ML16005A6232016-01-0505 January 2016
Unopposed Motion by the States for an Enlargement of Time to File an Answer to Entergy Motion to Strike the States Reply
ML15362A5192015-12-28028 December 2015
Entergy Motion to Strike Impermissible December 17, 2015 Reply Filed by the Commonwealth of Massachusetts and the States of Connecticut and New Hampshire
ML15362A4902015-12-28028 December 2015
Motion to Strike Portions of December 17, 2015, Reply Filed by the State of Vermont, Vermont Yankee Nuclear Power Corporation, and Green Mountain Power Corporation
ML15299A2602015-10-26026 October 2015
NRC Staff Motion to Vacate LBP-15-24
ML15286A4422015-10-13013 October 2015
Entergy Motion for Leave to File Reply and Reply Re Motion to Withdraw LAR
ML15275A3222015-10-0202 October 2015
Staff Answer to Motion to Withdraw
ML15271A3112015-09-23023 September 2015
Federal Respondents' Motion for Extension of Time to File Dispositive Motions and Certified Index 9-23-15
ML15265A5832015-09-22022 September 2015
Entergy'S Motion to Withdraw Its September 4, 2014 License Amendment Request
ML15265A5862015-09-22022 September 2015
Entergy'S Unopposed Motion to Extend the Time to Appeal LBP-15-24
ML15260B2782015-09-17017 September 2015
Joint Motion on Mandatory Disclosures and Schedule
ML15201A1752015-07-20020 July 2015
Joint Proposed Corrections to Oral Argument Transcript Held on July 7, 2015
ML15072A4622015-03-13013 March 2015
Entergy Answer Opposing State of Vermont'S Motion to Stay the License Amendment Proceeding Pending Commission Reconsideration
ML14352A2082014-12-18018 December 2014
NRC Staff Answer to State of Vermont'S Submission of Additional Information and Request to File Supplemental Briefing Addressing New Information and Argument Raised at Oral Argument
ML12088A0852012-03-15015 March 2012
Fed Respondents Opposition to Motion to Strike No.11-1168 and 11-1177 (Consolidated)
ML12067A0892012-03-0707 March 2012
State of Vermont Motion to Strike, Petitioners' Motion to Strike Four Extra-Record References Contained in Respondents' Recently Filed Amended Certified Index of the Record and in Respondents' and Interveners Briefs
ML12066A1772012-03-0606 March 2012
Petitioners Motion to Strike Amended Cert 11-1168
ML1107703932011-03-10010 March 2011
Motion to Stay Any and All Final Commission Decisions in the Matter of 50-271 Lr and Request for Hearing on Entergy License Renewal Application Amendments
Information Notice 2010-26, New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review2010-12-30030 December 2010
New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-19
Information Notice 2010-26, New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-2010-12-30030 December 2010
New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-19
ML1027204012010-09-23023 September 2010
Entergy'S Motion to Strike the Declaration of Paul Blanch
ML1025800092010-09-14014 September 2010
NRC Staff'S Opposition to New England Coalition'S Motion to Reopen the Hearing and Answer to Proposed New Contention and Affidavit of Roy K. Mathew
ML1024200422010-08-20020 August 2010
New England Coalition'S Motion to Reopen the Hearing and for the Admission of New Contentions
ML1006304252010-03-0202 March 2010
New England Coalition'S Petition for Review of Licensing Board'S Full Initial Decision
ML0921509462009-08-0303 August 2009
NRC Staff'S Answer to Nec'S Petition for Review of the Licensing Board'S Full Initial Decision, LBP-09-09
ML0917405782009-06-15015 June 2009
New England Coalition'S Request for Leave to Reply to Entergy'S Answer to Nec'S Request for Extension of Time to Reply to Entergy NRC Staff Oppositions to New England Coalition'S Motion for Leave to File a Timely New Contention
ML0916702672009-06-10010 June 2009
Entergy'S Oppositions to Nec'S Request for an Ex-Post-Facto Extension of Time to File a Reply to the NRC Staff and Entergy'S Oppositions to Nec'S Motion to File a Timely New Contention
ML0916000212009-06-0808 June 2009
Vermont Yankee - NRC Staff'S Answer to Entergy'S Motion to Strike New England Coalition'S Reply to NRC Staff Entergy Oppositions to Nec'S Motion to File a Timely New Contention
ML0916101422009-06-0202 June 2009
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
ML0913907852009-05-19019 May 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to Nec'S Motion for Leave to File a New Contention
ML0912100122009-04-30030 April 2009
NRC Staff'S Answer in Opposition to NEC Motion to Hold in Abeyance Action on Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report
ML0912005142009-04-24024 April 2009
New England Coalition, Inc.'S Motion for Leave to File a Timely New Contention and Motion to Hold in Abeyance Action on This Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report
ML0906800032009-03-0606 March 2009
Oyster Creek - Notice of Appearance of Maxwell Smith and Notice of Withdrawal of Mary Baty
ML0906800082009-03-0606 March 2009
Vermont Yankee - Notice of Appearance of Maxwell Smith and Notice of Withdrawal of Mary Baty
ML0907711412009-03-0606 March 2009
New England Coalition'S Motion to Alter or Amend the Schedule in the Above Captioned Proceeding
ML0902601102009-01-26026 January 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to Nec'S Motion for Leave to Reply
ML0903501142009-01-25025 January 2009
Vermont Department of Public Service Unopposed Motion for Extension of Time to Respond to Energy'S Confirmatory Cufen Analyses
ML0903606582009-01-23023 January 2009
Entergy'S Opposition to New England Coalition'S Motion for Leave to Reply
ML0903001122009-01-14014 January 2009
New England Coalition'S Motion for Leave to Reply to NRC Staff and Entergy Nuclear Vermont Yankee, L.L.C., and Entergy Nuclear Operations, Inc.'S Answers to New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial
ML0900800242009-01-0707 January 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to New England Coalition'S Motion for Reconsideration and Notice of Withdrawal of Jessica Bielecki
ML0835900532008-12-23023 December 2008
Vermont Yankee - NRC Staff'S Reply to Nec'S Answer to NRC Staff'S Petition for Review of LBP-08-25
ML0835900722008-12-23023 December 2008
Vermont Yankee - NRC Staff'S Reply to Motion to Submit Brief Amicus Curiae
ML0900202572008-12-19019 December 2008
Motion for Leave by the States of New York and Connecticut, Et. Al., to Submit Brief Amici Curiae in Opposition to Staff'S Petition for Review and in Support of Intervenors State of Vermont and the New England Coalition
ML0901603582008-12-17017 December 2008
New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial Initial Decision
ML0836593462008-12-15015 December 2008
New England Coalition, Inc.'S Motion for a Second Extension of Time in Which to File a Motion for Reconsideration
ML0835304522008-12-12012 December 2008
the State of New York, V USNRC and Entergy Nuclear Operations Inc; 08-3903-ag(L)/08-4833-ag(CON) - Motion Out of Time
2018-03-12
[Table view] |
Text
DOCKETED 12A H-/(o USNRC June 30, 2008 (4:55pm)
OFFICE OF SECRETARY June30 2008 RULEMAKINGS AND ADJUDICATIONS STAFF UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
ENTERGY NUCLEAR VERMONT ) Docket No. 50-271-LR YANKEE LLC AND ENTERGY NUCLEAR ) ASLBP No. 06-849-03-LR OPERATIONS, INC. )
(Vermont Yankee Nuclear Power Station) )
VERMONT DEPARTMENT OF PUBLIC SERVICE' REQUEST FOR CLARIFICATION AND/OR REQUEST LEAVE TO FILE SEPARATE BRIEF On June 27, 2008, the Board issued an Order (Regarding the Briefing of Certain Legal Issues). The Order specified the "parties, NRC Staff, and the interested States are instructed to submit their respective initial briefs". Id. at 6. Vermont, in this proceeding, is a party and not an interested state. The Order could be read to authorize Vermont to file a brief as one of the "parties" but it could also be read to restrict Vermont to being a co-party with NEC since, on specific contentions, Vermont has adopted the position of NEC or has not taken a position on the contention. Vermont believes the former interpretation, allowing it to file its own brief on these important questions, is the most reasonable and respectfully suggests the following reasoning as supporting such a view of the Order.
Since the issues on which briefing is sought are generic issues that could have broad implications beyond individual contentions in this case, Vermont believes it would
be appropriate to allow it to file independent briefing on these questions, rather than to be bound to filing one brief with NEC. In addition, the short time available to file the pleadings, with the intervening holiday, and the generic nature of the issues, will make it difficult to file a coordinated brief with NEC and get all the necessary clearances for the final brief while also working with NEC to produce a single document. Finally, although the position of Staff and Entergy may be expected to be similar on these issues, they will be filing two separate briefs and it does not seem unfair or unreasonable for Vermont and NEC to file two separate briefs in Which similar positions may not be presented.
For all these reasons Vermont respectfuilly requests the Board allow it to file a separate brief and reply brief on the issues identified in the Boards June 27, 2008 Order.
Vermont consulted with the other parties regarding the merits of this motion, explaining its position, and none of the parties objected to the filing of this motion.
Respectfully submitted, Sarah Hofe Director for Public Advocacy Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620-2601 Anthony Z. Roisman National Legal Scholars Law Firm 84 East Thetford Rd.
Lyme, NH 03768 Filed: June 30, 2008
June 27, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
ENTERGY NUCLEAR VERMONT ) Docket No. 50-271-LR YANKEE LLC AND ENTERGY NUCLEAR ) ASLBP No. 06-849-03-LR OPERATIONS, INC. )
(Vermont Yankee Nuclear Power Station) )
- CERTIFICATE OF SERVICE I hereby certify that copies of the Vermont Department of Public Service Request for Clarification And/Or Request Leave to File Separate Brief were served on the persons listed below by deposit in the U.S. Mail, first class, postage prepaid on July 1, 2008, and where indicated by an asterisk by electronic mail, this 30- day of June, 2008.
- AdministratiVe- Judge *Office of the Secretary Alex S. Karlin, Esq., Chairman Attn: Rtilemaking and Adjudications Staff Atomic Safety and Licensing Board Mail Stop: 0-16 Cl Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington D.C, 20555-0001 Washington, DC 20555-0001 hearingdocket@nrc.gov ask2@a nrc.gov secygnrc. gov
- Administrative Judge *Office of Commission Dr. Richard- E-Wardwell-- --- Appellate--Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 C1 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 OCAAmaila.(nrc. gov rew(enrc. gov Atomic Safety and Licensing Board
- Administrative Judge Mail Stop T-3 F23 William H. Reed US Nuclear Regulatory Commission 1819 Edgewood Lane Washington, DC 20555-0001 Charlottesville, VA( 22902 whrcville(d-embarqmail .com
'Lloyd B. Subin, Esq. *David R. Lewis, Esq.
- Mary C. Baty, Esq. *Matias F. Travieso-Diaz
- Jessica A. Bielecki *Blake J. Nelson
- Susan Uttal Pillsbury, Winthrop, Shaw, Pittman, LLP.
Office of the General Counsel 2300 N Street, N.W.
Mail Stop 0- 15 D21 Washington, DC 2003 7-1128 U.S. Nuclear Regulatory Commission david.lewiscpillsburylaw.com Washington, DC 20555-0001 matias.travieso-diaz(&pillsburylaw.com lbs3 @nrc.gov blake.nelsonrapillsburylaw.com mcb 1@nrc.g ov iessica.bieleckianrc.gov *Marcia Carpenter, Esq.
susan.uttal awnrc .gov Atomic Safety and Licensing Board Panel Mail Stop T-3 F23
- Anthony Z. Roisman, Esq. US Nuclear Regulatory Commission National Legal Scholars Law Firm Washington, DC 20555-0001 84 East Thetford Road mxc7gnrc.gov Lyme, NH 03768 aroisman (@cnationallegalscholars.com *Lauren Bregman, Law Clerk Atomic Safety and Licensing Board
- Ronald A. Shems, Esq. US Nuclear Regulatory Commission
- Karen Tyler, Esq. Mail Stop: T-3 F23
- Andy Raubvogel Washington, DC 20555-0001 Shems, Dunkiel, Kassel & Saunders, PLLC. Lauren.Bregmang~nrc.gov 91 College Street Burlington, VT 05401 *Matthew Brock rshernsnasdkslaw.com Assistant Attorney General ktyler(asdkslaw.com Office of the Attorney General araubvogel(Thskdslaw.com One Ashburton Place.- 1 8 th Floor Boston, MA 02108 Diane Curran Matthew.Brockk~state.ma.us Harmon, Curran, Spielberg & Eisenberg 1726 M. Street NW - Suite 600 *Peter L. Roth, Esq.
Washington, D.C. 20036 Office of the New Hampshire Attorney
- dcurran(aharmoncurran.com General 33 Capitol Street Concord, NH 03301 Peter.roth(&doj .nh.gov Respectfully submitted, Vermont Vt of Public Service
