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| | number = ML081050262 | | | number = ML081050262 |
| | issue date = 04/07/2008 | | | issue date = 04/07/2008 |
| | title = 2008/04/07-Connecticut Residents Opposed to Relicensing of Indian Point and Its Designated Representative'S Response to April 1, 2008, Order Regarding Service by Westcan | | | title = Connecticut Residents Opposed to Relicensing of Indian Point and Its Designated Representative'S Response to April 1, 2008, Order Regarding Service by Westcan |
| | author name = Burton N | | | author name = Burton N |
| | author affiliation = Connecticut Residents Opposed to Relicensing of Indian Point | | | author affiliation = Connecticut Residents Opposed to Relicensing of Indian Point |
| | addressee name = Lathrop K D, McDade L G, Wardwell R E | | | addressee name = Lathrop K, Mcdade L, Wardwell R |
| | addressee affiliation = NRC/ASLBP | | | addressee affiliation = NRC/ASLBP |
| | docket = 05000247, 05000286 | | | docket = 05000247, 05000286 |
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| {{#Wiki_filter:LAS- ~DOCKETED USNRC April 7, 2008 (2:44pm)UNITED STATES OF AMERICA OFFICE OF SECRETARY RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop In the matter of DOCKET NOS.ENTERGY NUCLEAR OPERATIONS, INC. 50-247-LR (Indian Point Nuclear Generating Units 50-286-LR 2 and 3) APRIL 7, 2008 CONNECTICUT RESIDENTS OPPOSED TO RELICENSING OF INDIAN POINT AND ITS DESIGNATED REPRESENTATIVE'S RESPONSE TO APRIL 1, 2008, ORDER REGARDING SERVICE BY WESTCAN Connecticut Residents Opposed to Relicensing of Indian Point and its designated representative, Nancy Burton (collectively "CRORIP"), respectfully respond herewith to the Third Order Relating to the Service and Content of WestCAN's Reply Dated Feb.15, 2008 issued by the Atomic Safety and Licensing Board on April 1, 2008.Contemporaneously herewith, CRORIP is forwarding messages received electronically from West CAN on March 21, 2008 to the Office of the Secretary. | | {{#Wiki_filter:LAS- ~DOCKETED USNRC April 7, 2008 (2:44pm) |
| CRORIP received two e-mail messages from Sarah L. Wagner on March 21, 2008.The first, entitled "WestCAN's Reply to the ASLB Order 3.7.08," stated that it was the first of two e-mails enclosing WestCAN's Reply Brief in response to the Atomic Safety and Licensing Board Order of March 7, 2008. One of the attachments to the e-mail was a document entitled "Table of Contents" which listed Exhibits A through G but did not include Exhibits H or I. I did not find Exhibits H and I in the e-mail attachments. | | UNITED STATES OF AMERICA OFFICE OF SECRETARY RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: |
| With regard to the second e-mail from Sarah Wagner on March 21, 2008, I could not open the attachment. | | Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop In the matter of DOCKET NOS. |
| Apparently, there was a delivery failure.OF* *1 CONNECTICUT RESIDENTS. | | ENTERGY NUCLEAR OPERATIONS, INC. 50-247-LR (Indian Point Nuclear Generating Units 50-286-LR 2 and 3) APRIL 7, 2008 CONNECTICUT RESIDENTS OPPOSED TO RELICENSING OF INDIAN POINT AND ITS DESIGNATED REPRESENTATIVE'S RESPONSE TO APRIL 1, 2008, ORDER REGARDING SERVICE BY WESTCAN Connecticut Residents Opposed to Relicensing of Indian Point and its designated representative, Nancy Burton (collectively "CRORIP"), respectfully respond herewith to the Third Order Relating to the Service and Content of WestCAN's Reply Dated Feb. |
| OPPOSED TO RELICENSING OF INDIAN POINT NANCY BURTON By: cýNanc Bun 147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 NancyBurtonCT@aol.com 2 | | 15, 2008 issued by the Atomic Safety and Licensing Board on April 1, 2008. |
| UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.(Indian Point Nuclear Generating Units Docket Nos.50-247-LR and 50-286-LR 2 and 3) APRIL 7, 2008 CERTIFICATE OF SERVICE I hereby certify that copies of the April 7, 2008 "CONNECTICUT RESIDENTS OPPOSED TO RELICENSING OF INDIAN POINT AND ITS DESIGNATED REPRESENTATIVE'S RESPONSE TO APRIL 1, 2008, ORDER REGARDING SERVICE BY WESTCAN" were served on this 7 th day of April, 2008 upon the persons listed below, by first class mail and by email as shown below.Nancy ýU 147 Cross Highway Redding Ridge CT 06876 Tel./Fax 203-938-3952 NancvBurtonCT~aol.com Office of the Secretary Attn: Adjudications and Rulemakings Staff U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Email: HearingDocketanrc.gov Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Email: ocaamaila(nrc.gov Administrative Judge Lawrence G. McDade, Chair Administrative Judge Dr. Richard E. Wardwell 3 Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 U,S. Nuclear Regulatory Commission Washington DC 20555-0001 Email: lgml1nrc.qov Administrative Judge Dr. Kaye D. Lathrop Atomic Safety and Licensing Board Panel 190 Cedar Lane East Ridgeway CO 81432 Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Email: REW@nrc.gov Susan Shapiro, Esq.21 Perlman Drive Spring Valley NY Email: Palisadesart@aol.com Email: kd112@nrcgov Sherwood Martinelli Michael J. Delaney Friends United for Sustainable Energy USA, Inc. Vice President-Energy 351 Dykman Street New York City Peekskill NY 19566 Economic Development Corporation Email: roycepenstingerDaol.com 110 William Street New York NY 10038 Email: mdelaney@nycedc.com Sherwin E. Turk, Esq. Arthur J. Kremer, Chairman Lloyd B. Subin, Esq. New York AREA Beth N. Mizuno, Esq. 347 Fifth Avenue, Suite 508 Office of the General Counsel New York NY 10016 Mail Stop 0-15 D21 Email: kremer@area-alliance.org U,S. Nuclear Regulatory Commission Washington DC 20555-0001 Email: set(nrc.gov, Ibs3@-nrc.gov, bnm1()nrc.gov Zachary S. Khan, Law Clerk Kathryn M. Sutton, Esq.Atomic Safety and Licensing Board Paul M. Bessette, Esq.Mail Stop: T-3 F23 Martin J. O'Neill, Esq.U.S. Nuclear Regulatory Commission MORGAN LEWIS BOCKIUS LLP 4 Washington DC 20555-0001 Email: zxklknrc.gov Kathryn M. Sutton, Esq.Diane Curran, Esq.Harmon, Curran, Spielberg | | Contemporaneously herewith, CRORIP is forwarding messages received electronically from West CAN on March 21, 2008 to the Office of the Secretary. |
| & Eisenberg, LLP 1726 M Street NW, Suite 600 Washington DC 20036 Email: dcurran@harmoncurran.com Phillip Musegaas, Esq.Staff Attorney Riverkeeper, Inc.828 South Broadway Tarrytown NY 10591 Email: phillip(riverkeeper.org Victor M. Tafur, Esq.Senior Attorney Riverkeeeper, Inc.828 South Broadway Tarrytown NY 10591 Email: vtafu r@riverkeeper.org William C. Dennis, Esq.Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains NY 10601 wdennis@entergy.com Thomas F. Wood, Esq.Sive, Paget and Riesel, P.C.460 Park Avenue New York NY 10022 drieselksprlaw.com Mylan L. Denerstein, Esq.Executive Deputy Attorney General 120 Broadway, 25th Floor New York NY 10271 mylan.denerstein@oag.
| | CRORIP received two e-mail messages from Sarah L. Wagner on March 21, 2008. |
| state. ny. us 1111 Pennsylvania Avenue NW Washington DC 20004 Email: ksuttonDmorganlewis.com, pbessette(@morganlewis.com, martino'neill@morganlewis.com John J. Sipos, Esq.Assistant Attorney General The Capitol Albany N Y 12224-0341 Email: John.Sipos@oag.state.ny.us Robert Snook, Esq.Assistant Attorney General 55 Elm Street Hartford CT 06106 Robert.Snook@po.state.ct.
| | The first, entitled "WestCAN's Reply to the ASLB Order 3.7.08," stated that it was the first of two e-mails enclosing WestCAN's Reply Brief in response to the Atomic Safety and Licensing Board Order of March 7, 2008. One of the attachments to the e-mail was a document entitled "Table of Contents" which listed Exhibits A through G but did not include Exhibits H or I. I did not find Exhibits H and I in the e-mail attachments. |
| us Manna Jo Greene Hudson River Sloop Clearwater, Inc.112 Little Market Street Poughkeepsie NY 12601 Email: Mannajo@Clearwater.org Joan Leary Mathews, Esq.NYS Dept. Environmental Conservation 625 Broadway, 1 4 th Floor Albany NY 12233-5500 J lmatthews@gw.dec. | | With regard to the second e-mail from Sarah Wagner on March 21, 2008, I could not open the attachment. Apparently, there was a delivery failure. |
| state. ny. us Elise N. Zoli, Esq., Law Clerk Atomic Safety and Licensing Board Mail Stop: T-3 E2B U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Sarah Wagner, Esq.L.O.B. Room 422 Albany NY 12248 sarah.wagner@gmail.com 5}} | | OF* *1 |
| | |
| | CONNECTICUT RESIDENTS. OPPOSED TO RELICENSING OF INDIAN POINT NANCY BURTON By: cý Nanc Bun 147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 NancyBurtonCT@aol.com 2 |
| | |
| | UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: |
| | Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop In the Matter of Docket Nos. |
| | ENTERGY NUCLEAR OPERATIONS, INC. 50-247-LR and 50-286-LR (Indian Point Nuclear Generating Units 2 and 3) APRIL 7, 2008 CERTIFICATE OF SERVICE I hereby certify that copies of the April 7, 2008 "CONNECTICUT RESIDENTS OPPOSED TO RELICENSING OF INDIAN POINT AND ITS DESIGNATED REPRESENTATIVE'S RESPONSE TO APRIL 1, 2008, ORDER REGARDING SERVICE BY WESTCAN" were served on this 7 th day of April, 2008 upon the persons listed below, by first class mail and by email as shown below. |
| | Nancy ýU 147 Cross Highway Redding Ridge CT 06876 Tel./Fax 203-938-3952 NancvBurtonCT~aol.com Office of the Secretary Office of Commission Appellate Adjudication Attn: Adjudications and Rulemakings Staff U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Washington DC 20555-0001 Email: HearingDocketanrc.gov Email: ocaamaila(nrc.gov Administrative Judge Administrative Judge Lawrence G. McDade, Chair Dr. Richard E. Wardwell 3 |
| | |
| | Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Mail Stop: T-3 F23 Panel U,S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington DC 20555-0001 U.S. Nuclear Regulatory Commission Email: lgml1nrc.qov Washington DC 20555-0001 Email: REW@nrc.gov Administrative Judge Susan Shapiro, Esq. |
| | Dr. Kaye D. Lathrop 21 Perlman Drive Atomic Safety and Licensing Board Panel Spring Valley NY 190 Cedar Lane East Email: Palisadesart@aol.com Ridgeway CO 81432 Email: kd112@nrcgov Sherwood Martinelli Michael J. Delaney Friends United for Sustainable Energy USA, Inc. Vice President-Energy 351 Dykman Street New York City Peekskill NY 19566 Economic Development Corporation Email: roycepenstingerDaol.com 110 William Street New York NY 10038 Email: mdelaney@nycedc.com Sherwin E. Turk, Esq. Arthur J. Kremer, Chairman Lloyd B. Subin, Esq. New York AREA Beth N. Mizuno, Esq. 347 Fifth Avenue, Suite 508 Office of the General Counsel New York NY 10016 Mail Stop 0-15 D21 Email: kremer@area-alliance.org U,S. Nuclear Regulatory Commission Washington DC 20555-0001 Email: set(nrc.gov, Ibs3@-nrc.gov, bnm1()nrc.gov Zachary S. Khan, Law Clerk Kathryn M. Sutton, Esq. |
| | Atomic Safety and Licensing Board Paul M. Bessette, Esq. |
| | Mail Stop: T-3 F23 Martin J. O'Neill, Esq. |
| | U.S. Nuclear Regulatory Commission MORGAN LEWIS BOCKIUS LLP 4 |
| | |
| | Washington DC 20555-0001 1111 Pennsylvania Avenue NW Email: zxklknrc.gov Washington DC 20004 Kathryn M. Sutton, Esq. Email: ksuttonDmorganlewis.com, pbessette(@morganlewis.com, martino'neill@morganlewis.com Diane Curran, Esq. John J. Sipos, Esq. |
| | Harmon, Curran, Spielberg & Eisenberg, LLP Assistant Attorney General 1726 M Street NW, Suite 600 The Capitol Washington DC 20036 Albany N Y 12224-0341 Email: dcurran@harmoncurran.com Email: John.Sipos@oag.state.ny.us Phillip Musegaas, Esq. Robert Snook, Esq. |
| | Staff Attorney Assistant Attorney General Riverkeeper, Inc. 55 Elm Street 828 South Broadway Hartford CT 06106 Tarrytown NY 10591 Robert.Snook@po.state.ct. us Email: phillip(riverkeeper.org Victor M. Tafur, Esq. Manna Jo Greene Senior Attorney Hudson River Sloop Clearwater, Inc. |
| | Riverkeeeper, Inc. 112 Little Market Street 828 South Broadway Poughkeepsie NY 12601 Tarrytown NY 10591 Email: Mannajo@Clearwater.org Email: vtafu r@riverkeeper.org William C. Dennis, Esq. Joan Leary Mathews, Esq. |
| | Entergy Nuclear Operations, Inc. NYS Dept. Environmental 440 Hamilton Avenue Conservation White Plains NY 10601 625 Broadway, 14 th Floor wdennis@entergy.com Albany NY 12233-5500 J lmatthews@gw.dec. state. ny. us Thomas F. Wood, Esq. |
| | Sive, Paget and Riesel, P.C. Elise N. Zoli, Esq., Law Clerk 460 Park Avenue Atomic Safety and Licensing Board New York NY 10022 Mail Stop: T-3 E2B drieselksprlaw.com U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Mylan L. Denerstein, Esq. |
| | Executive Deputy Attorney General Sarah Wagner, Esq. |
| | 120 Broadway, 25th Floor L.O.B. Room 422 New York NY 10271 Albany NY 12248 mylan.denerstein@oag. state. ny. us sarah.wagner@gmail.com 5}} |
|
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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
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LAS- ~DOCKETED USNRC April 7, 2008 (2:44pm)
UNITED STATES OF AMERICA OFFICE OF SECRETARY RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop In the matter of DOCKET NOS.
ENTERGY NUCLEAR OPERATIONS, INC. 50-247-LR (Indian Point Nuclear Generating Units 50-286-LR 2 and 3) APRIL 7, 2008 CONNECTICUT RESIDENTS OPPOSED TO RELICENSING OF INDIAN POINT AND ITS DESIGNATED REPRESENTATIVE'S RESPONSE TO APRIL 1, 2008, ORDER REGARDING SERVICE BY WESTCAN Connecticut Residents Opposed to Relicensing of Indian Point and its designated representative, Nancy Burton (collectively "CRORIP"), respectfully respond herewith to the Third Order Relating to the Service and Content of WestCAN's Reply Dated Feb.
15, 2008 issued by the Atomic Safety and Licensing Board on April 1, 2008.
Contemporaneously herewith, CRORIP is forwarding messages received electronically from West CAN on March 21, 2008 to the Office of the Secretary.
CRORIP received two e-mail messages from Sarah L. Wagner on March 21, 2008.
The first, entitled "WestCAN's Reply to the ASLB Order 3.7.08," stated that it was the first of two e-mails enclosing WestCAN's Reply Brief in response to the Atomic Safety and Licensing Board Order of March 7, 2008. One of the attachments to the e-mail was a document entitled "Table of Contents" which listed Exhibits A through G but did not include Exhibits H or I. I did not find Exhibits H and I in the e-mail attachments.
With regard to the second e-mail from Sarah Wagner on March 21, 2008, I could not open the attachment. Apparently, there was a delivery failure.
OF* *1
CONNECTICUT RESIDENTS. OPPOSED TO RELICENSING OF INDIAN POINT NANCY BURTON By: cý Nanc Bun 147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 NancyBurtonCT@aol.com 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop In the Matter of Docket Nos.
ENTERGY NUCLEAR OPERATIONS, INC. 50-247-LR and 50-286-LR (Indian Point Nuclear Generating Units 2 and 3) APRIL 7, 2008 CERTIFICATE OF SERVICE I hereby certify that copies of the April 7, 2008 "CONNECTICUT RESIDENTS OPPOSED TO RELICENSING OF INDIAN POINT AND ITS DESIGNATED REPRESENTATIVE'S RESPONSE TO APRIL 1, 2008, ORDER REGARDING SERVICE BY WESTCAN" were served on this 7 th day of April, 2008 upon the persons listed below, by first class mail and by email as shown below.
Nancy ýU 147 Cross Highway Redding Ridge CT 06876 Tel./Fax 203-938-3952 NancvBurtonCT~aol.com Office of the Secretary Office of Commission Appellate Adjudication Attn: Adjudications and Rulemakings Staff U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Washington DC 20555-0001 Email: HearingDocketanrc.gov Email: ocaamaila(nrc.gov Administrative Judge Administrative Judge Lawrence G. McDade, Chair Dr. Richard E. Wardwell 3
Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Mail Stop: T-3 F23 Panel U,S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington DC 20555-0001 U.S. Nuclear Regulatory Commission Email: lgml1nrc.qov Washington DC 20555-0001 Email: REW@nrc.gov Administrative Judge Susan Shapiro, Esq.
Dr. Kaye D. Lathrop 21 Perlman Drive Atomic Safety and Licensing Board Panel Spring Valley NY 190 Cedar Lane East Email: Palisadesart@aol.com Ridgeway CO 81432 Email: kd112@nrcgov Sherwood Martinelli Michael J. Delaney Friends United for Sustainable Energy USA, Inc. Vice President-Energy 351 Dykman Street New York City Peekskill NY 19566 Economic Development Corporation Email: roycepenstingerDaol.com 110 William Street New York NY 10038 Email: mdelaney@nycedc.com Sherwin E. Turk, Esq. Arthur J. Kremer, Chairman Lloyd B. Subin, Esq. New York AREA Beth N. Mizuno, Esq. 347 Fifth Avenue, Suite 508 Office of the General Counsel New York NY 10016 Mail Stop 0-15 D21 Email: kremer@area-alliance.org U,S. Nuclear Regulatory Commission Washington DC 20555-0001 Email: set(nrc.gov, Ibs3@-nrc.gov, bnm1()nrc.gov Zachary S. Khan, Law Clerk Kathryn M. Sutton, Esq.
Atomic Safety and Licensing Board Paul M. Bessette, Esq.
Mail Stop: T-3 F23 Martin J. O'Neill, Esq.
U.S. Nuclear Regulatory Commission MORGAN LEWIS BOCKIUS LLP 4
Washington DC 20555-0001 1111 Pennsylvania Avenue NW Email: zxklknrc.gov Washington DC 20004 Kathryn M. Sutton, Esq. Email: ksuttonDmorganlewis.com, pbessette(@morganlewis.com, martino'neill@morganlewis.com Diane Curran, Esq. John J. Sipos, Esq.
Harmon, Curran, Spielberg & Eisenberg, LLP Assistant Attorney General 1726 M Street NW, Suite 600 The Capitol Washington DC 20036 Albany N Y 12224-0341 Email: dcurran@harmoncurran.com Email: John.Sipos@oag.state.ny.us Phillip Musegaas, Esq. Robert Snook, Esq.
Staff Attorney Assistant Attorney General Riverkeeper, Inc. 55 Elm Street 828 South Broadway Hartford CT 06106 Tarrytown NY 10591 Robert.Snook@po.state.ct. us Email: phillip(riverkeeper.org Victor M. Tafur, Esq. Manna Jo Greene Senior Attorney Hudson River Sloop Clearwater, Inc.
Riverkeeeper, Inc. 112 Little Market Street 828 South Broadway Poughkeepsie NY 12601 Tarrytown NY 10591 Email: Mannajo@Clearwater.org Email: vtafu r@riverkeeper.org William C. Dennis, Esq. Joan Leary Mathews, Esq.
Entergy Nuclear Operations, Inc. NYS Dept. Environmental 440 Hamilton Avenue Conservation White Plains NY 10601 625 Broadway, 14 th Floor wdennis@entergy.com Albany NY 12233-5500 J lmatthews@gw.dec. state. ny. us Thomas F. Wood, Esq.
Sive, Paget and Riesel, P.C. Elise N. Zoli, Esq., Law Clerk 460 Park Avenue Atomic Safety and Licensing Board New York NY 10022 Mail Stop: T-3 E2B drieselksprlaw.com U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Mylan L. Denerstein, Esq.
Executive Deputy Attorney General Sarah Wagner, Esq.
120 Broadway, 25th Floor L.O.B. Room 422 New York NY 10271 Albany NY 12248 mylan.denerstein@oag. state. ny. us sarah.wagner@gmail.com 5