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Category:Legal-Intervention Petition
MONTHYEARML11257A1102011-09-14014 September 2011 Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions ML11257A1092011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A1112011-09-13013 September 2011 Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report ML11228A0302011-08-11011 August 2011 the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17 ML11217A0662011-07-29029 July 2011 Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36 ML11210B4192011-07-26026 July 2011 State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37 ML11179A0922011-06-21021 June 2011 Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals ML11133A2882011-04-29029 April 2011 Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25 ML11117A1462011-04-19019 April 2011 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident ML11229A8022011-03-22022 March 2011 Supplementary Certification Regarding Consultation ML11108A1062011-03-21021 March 2011 Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3 ML1108307802011-03-18018 March 2011 State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives ML1107601812011-03-16016 March 2011 Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement ML1107000972011-03-0404 March 2011 State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B ML1106703812011-02-25025 February 2011 Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions ML1107402862011-02-23023 February 2011 State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36 ML1106604252011-02-23023 February 2011 State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1105602702011-02-18018 February 2011 Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule ML1105605892011-02-18018 February 2011 Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b) ML1104604922011-02-10010 February 2011 State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions ML1106802122011-02-0303 February 2011 State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area ML1030000602010-10-22022 October 2010 State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25 ML1030101042010-10-12012 October 2010 Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals ML1029101452010-10-0404 October 2010 Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1028802972010-10-0404 October 2010 Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B ML1029101422010-10-0404 October 2010 Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1030105182010-09-14014 September 2010 State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean.. ML1023712142010-08-16016 August 2010 Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion) ML1023001462010-08-13013 August 2010 Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents ML1022405782010-08-0202 August 2010 Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13 ML1021100862010-07-26026 July 2010 the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10- ML1020300502010-07-15015 July 2010 Applicant'S Petition for Interlocutory Review of LBP-10-13 ML1011604152010-04-12012 April 2010 State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1014503282010-04-0505 April 2010 Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis ML1011004732010-04-0101 April 2010 Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives ML1005702402009-11-20020 November 2009 Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point ML0934803252009-11-20020 November 2009 Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML0934910432009-11-20020 November 2009 Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information ML0935101942009-11-20020 November 2009 Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point ML1005700112009-11-20020 November 2009 Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML1008200282009-11-19019 November 2009 Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point ML0930801292009-10-26026 October 2009 Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information ML0909802072009-04-0707 April 2009 Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply ML0910502112009-04-0606 April 2009 Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2 ML0909604702009-03-31031 March 2009 State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34 ML0909302042009-03-24024 March 2009 Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State ML0908401162009-03-24024 March 2009 Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement ML0908608682009-03-18018 March 2009 Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items ML0906903032009-02-27027 February 2009 State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement ML0904105002009-01-26026 January 2009 Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention 2011-09-14
[Table view] Category:Responses and Contentions
MONTHYEARML11257A1102011-09-14014 September 2011 Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions ML11257A1092011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A1112011-09-13013 September 2011 Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report ML11228A0302011-08-11011 August 2011 the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17 ML11217A0662011-07-29029 July 2011 Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36 ML11210B4192011-07-26026 July 2011 State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37 ML11179A0922011-06-21021 June 2011 Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals ML11133A2882011-04-29029 April 2011 Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25 ML11117A1462011-04-19019 April 2011 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident ML11229A8022011-03-22022 March 2011 Supplementary Certification Regarding Consultation ML11108A1062011-03-21021 March 2011 Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3 ML1108307802011-03-18018 March 2011 State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives ML1107601812011-03-16016 March 2011 Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement ML1107000972011-03-0404 March 2011 State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B ML1106703812011-02-25025 February 2011 Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions ML1107402862011-02-23023 February 2011 State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36 ML1106604252011-02-23023 February 2011 State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1105602702011-02-18018 February 2011 Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule ML1105605892011-02-18018 February 2011 Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b) ML1104604922011-02-10010 February 2011 State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions ML1106802122011-02-0303 February 2011 State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area ML1030000602010-10-22022 October 2010 State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25 ML1030101042010-10-12012 October 2010 Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals ML1029101452010-10-0404 October 2010 Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1028802972010-10-0404 October 2010 Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B ML1029101422010-10-0404 October 2010 Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1030105182010-09-14014 September 2010 State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean.. ML1023712142010-08-16016 August 2010 Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion) ML1023001462010-08-13013 August 2010 Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents ML1022405782010-08-0202 August 2010 Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13 ML1021100862010-07-26026 July 2010 the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10- ML1020300502010-07-15015 July 2010 Applicant'S Petition for Interlocutory Review of LBP-10-13 ML1011604152010-04-12012 April 2010 State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1014503282010-04-0505 April 2010 Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis ML1011004732010-04-0101 April 2010 Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives ML1005702402009-11-20020 November 2009 Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point ML0934803252009-11-20020 November 2009 Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML0934910432009-11-20020 November 2009 Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information ML0935101942009-11-20020 November 2009 Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point ML1005700112009-11-20020 November 2009 Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML1008200282009-11-19019 November 2009 Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point ML0930801292009-10-26026 October 2009 Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information ML0909802072009-04-0707 April 2009 Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply ML0910502112009-04-0606 April 2009 Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2 ML0909604702009-03-31031 March 2009 State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34 ML0909302042009-03-24024 March 2009 Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State ML0908401162009-03-24024 March 2009 Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement ML0908608682009-03-18018 March 2009 Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items ML0906903032009-02-27027 February 2009 State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement ML0904105002009-01-26026 January 2009 Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention 2011-09-14
[Table view] |
Text
pi~{- ~fi UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC.
ATOMIC SAFETY AND LICENSING BOARD, February 27, 2008 (9:00am)
OFFICE OF SECRETARY Before Administrative Judges: RULEMAKINGS AND Lawrence G. McDade, Chair ADJUDICATIONS STAFF Dr. Richard E. Wardwell Dr. Kaye D. Lathrop In the Matter of ) Docket Nos. 50-247-LR
) and 50-286LR
)
ENTERGY'NUCLEAR OPERATIONS, INC. ) ASLBP No. 07-858-03-LR-BD0l
)) February 26,. 2008 (Indian Point Nuclear Generating Units 2 and' 3) )
)
HUDSON RIVER SLOOP CLEARWATER INC'S REPLY TO ENTERGY MOTION TO STRIKE CLEARWATER INC.'S REPLY TO ENTERY AND NRC RESPONSES TO CLEARWATER: PETITION TO INTERVENE AND REQUEST FOR HEARING The following comments are in reply to Entergy Nuclear Operations, Inc.'s ("Entergy") Motion to Strike Hudson River Sloop Clearwater, Inc.'s Reply to Entergy and NRC Responses to Clearwater Petition to Intervene and Request for Hearing, dated February 15, .2008.
Legal Standards:
A. New Arguments and Supporting Information:
Entergy dites the Nuclear Regulatory Commission ("CommissiofA") prohibition on new arguments in a reply brief as being "rooted in the Commission's'interests in conduction adjudicatory hearings efficiently and on the basis of fairness." ,Clearwater contends that not only do NRC Staff and Entergy have far greater resources, they also have far greater experience in these processes than other parties, most of whom are engaging in this process for the first time.
-In.fact both the Applicant and the Commission have rfeams-of "boiler plate" responses that can be f;f
~~1kfr b-T25 3 cK3
applied to.any-situation that may arise. We believe that this does give these parties an unfair advantage, one that may be to the detriment of the Atomic Safety and Relicensing Board
ý*.,("Board?'ý)and thepublic welfare.
"Cleatr. ha8 ho-intentioe*iýther slowing the process or asking for special or unreasonable consideration. Our sole purpose is to contribute information that will enhance and complete the record and assist the Board in making its recommendation and final decision. In that regard,-we believe our contentions and our reply to Entergy's and the NRC's challenges are of value and should be accepted, not stricken; B. Introduction of New Information Must Satisfy the Commission's Late-Filed Contention Criteria Clearwater believes the concerns raised that Part 701 of NYS environmental regulations requires that "discharge of waste shall .not impair water below its best use, which for groundwater is as a potable water supply" is entirely relevant. Further, the fact that Rockland County has authorized United Water to develop plans to-increase their capacity by taking 10 - 15 million gallons per day of Hudson River water in a -facilityproposed to be located directly across from Indian Point
- water which they will.attempt to treated to meet drinking water standards, does represent a material difference. If strontium-90, tritium and other radioactive isotopes continue-to leak into
_ the Hudson River, this and other actual and potential Hudson River water supplies may be impacted.. We believe. this matter has not be adequately investigated either by Entergy, the NRC, the Environmental Protection Agency or New York State - and must be fully evaluated as part of -
the relicensing procedure.
We are not asking the Board to "lower the bar" but to take the hard look it is required to without dismissing important and relevant information.
Conclusion:
For the foregoing reasons, the Board should allow the information provided by Clearwater to stand.
IF " i.
i;,*
2
Respectfully subniitted,
-- .,
Manna Jo Greene, Environmental Director Hudson River Sloop Clearwater, Inc.
112 Market St.
Poughkeepsie, NY 12601 845-454-7673 x 113.
mannaj o@clearwater. org February 26, 2008
.3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative. Judges:
Lawrence G. McDade, Chair-Dr. Richard E. Wardwell Dr. Kaye D. Lathrop In the Matter of Docket Nos. 50-247-LR and 50-286-LR
)
ENTERGY NUCLEAR OPERATIONS, INC. ) ASLBP No. 07-858-03-LR-BDO1 (Indian Point Nuclear Generating Units 2 and 3)).)
February 26, 2008
)
CERTIFICATE OF SERVICE I hereby certify that copies of the following document were served on the following by first class mail and e-mail ,)as indicatedbelow: .
HUDSON RIVER SLOOP CLEARWATER, INC.'S RESPONSE TO:
ENTERGY NUCLEAR OPERATIONS, INC.'S MOTION TO STRIKE HUDSON RIVER SLOOP CLEARWATER INC.'S REPLY TO ENTERGY (DATED FEBRUARY 15, 2008);
Office Of Commission Appellate Adjudication Administrative Judge U. S.' Nuclear Regulatory Commission Washington Lawrence G. McDade;-Chair Mail Stop: 0-16G4 Atomic Safety and Licensing Board Panel Washington, DC 20555-0001 Mail Stop: T-3 F23 -
(E-mail: ocaamail(nrc.gov) U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: lgm(linrc.g0v)
Adminigtrative Judge Administrative Judge Richard E. Wardwell Kaye D. Lathrop Atomic Safety and Licensing Board Panel Atomic Safety andLicensing Board Panel Mail Stop: T--3 F23, Mail Stop: T-3 F23:
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 (E-mail.: rew@nrc.gov) (E-mail: kdl2@inrc.gov) 190 Cedar Lane'E.
Ridgeway, CO 81432 4
Office of the Secretary* I' . : Sherwin E. Turk, Esq.
Attn: Rulemakings.and Adjudications Staff Lloyd B. Subin, Fisq.
- U.S. Nuclear Regulatory Commission Beth N. Mizuno, Esq.
Washington, D.C: 20555-0001 Kimberly A. Sexton, Esq.
(E-mail: hearingdocket(alinrc.gov) Christopher C. Chandler, Esq.
David E. Roth Office of the General Counsel Mail Stop 15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: set(nrc.go-)
(E-mail: lbs3(@nrc.gov) "
(E-mail: bnml @nrc.,*ov)
(E-mail: kimberly.sexton(nrc. gov)
(E-mail: christopher.chandler(cnrc.gov)
(E-mail: david.roth Q)nrc.gov)
Susan Shapiro, Esq. Sarah L. Wagner, Esq.
21 Perlman Drive Legislative Office:Building, Room 422-Spring Valley, NY 10977 Albany, NY 12248' .
(E-mail: Palisadesart(aol.com (Email: sarahwagneresqc(,gmail.com) mbs(ýourrocklandbffice.com)
Richard L. Brodsky Zachary S: Khan, Law Clerk.,
5 West Main St. Atomic Safety and Licensing Board Elmsford, NY 10523 Mail Stop: T-3 F23 * .
(E-mail: biiodskrj(assembly.state.ny.us U.S. Nuclear Regulatory Commission richardbrodsky(@,msn.com)
Washington, DC 20555-0001 (E-mail: zxkl(aiinrc.gov)
Janice A. Dean, Esq. Kathryn M. Sutton,.Esq.
Office of the Attorney General Paul M. Bessette,. Esq.
of the State of New York Martin J. O'Neill, Esq.
Assistant Attorney General. MORGAN, LEWIS & BOCKrUS, LLP.
120 Broadway, 26th Floor 1111 Pennsylvania Avenue, N.W.
New York, NY. 10271 Washington, DC 20004 (Email: Janice.dean0oag.state.ny.us) (E-mail: ksutton(rnorganlewis.com)
(E-mail: pbessette(nmirganlewis.com)
(E-mail: martin.o'neill(a-,morgahlewis.com) ,
William C. Dennis, Esq.
Joan Leary Matthews, Esq.
Senior Attorney for Special Projects Assistant General Counsel NYS Department of Environmeintal Conservatilion Entergy Nuclear Operations, Inc.
625 Broadway, 14th Floor 440 Hamilton Avenue Albany, NY 12207 White Plains, NY 10601 (Email: Jlmatthe@gw.dec. state.ny.us) (Email: wdennis(entergy.com)
Andrew M. Cuomo, Esq. Robert D. Snook, Esq.
Attorney General of the State of New York Assistant Attorney General John J. Sipos, Esq.," Office of the Attorney General for Charlie Donaldson, Esq. the State of Connecticut "
Assistants General Attorney 55 Elm Street The Capitol, State Street P.O. Box 120 Albany, NY 12224-0341 Hartford, CT 06141-0120 (Email: John. sipos(oag.state.ny.us) (Email: robert.snookppo.state.ct.us)
Daniel Riesel, Esq. Nancy Burton Thomas F. Wood, Esq. Connecticut Residences Opposed to Relicensing Ms. Jessica Steinberg, J.D. of Indian Point Town of Cortlandt 147 Cross Highway Sive, Paget & Riesel, P.C. Redding Ridge, CT 06876 460 Park Avenue (Email: NancyBurtonCT(oaol.com)
New York, NY 10022 (Email: driesel(aisprlai.c6m)
(Email:- isteinberg(sprlaw.com)
Justin Pruyne, Esq. Diane Curran, Esq.
Assistant CounIty:Attorney, Litigation Bureau Harmon,Curran, Spielberg & Eisenberg, L.L.P Of Counsel to Charlene M. Indelicato, Esq. 1726 M Street N.W., Suite 600
- Westchester County Attorney Washington, D.C. 20036.
148 Martine Avenue, 6th Floor (Email: dcurran(harmoncurran.com)
White Plains, NY 10601 (Email: jdp3@westchesiergov.coi)
Phillip Musegaas, Esq., Janice A. Dean, Esq.
Victor M. Tafur,. Esq.:,
- Office of the Attorney General, Riverkeeper, Inc. of the State of New York 828-South Broadway Assistant Attorney General Tarrytown, NY 10591 120 Broadway, 26th Floor (Email: phillip riverkeepernorg):, . New York, NY 10271 (Email: vtafurariverkeeper.org) (Email: Janice.dean@oag.state ny.us)
Original and 2 copies Executed in Accord with 10 CFR 2.304(d)
Manna Jo Greene, Environmental DirectoT.
Member and Authorized Representative Hudson River Sloop Clearwater, Inc..
112 Little MarketStreet Poughkeepsie, New! York 12601 Tel: (845) 454-7673 x'113 Mannaio(.clearwater.org Dated: Poughkeepsie, New York February 26, 2008 i'
{i 6