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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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DOCKETED USNRC C-5 ugust 21, 2008 (8:30am)
)FFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND DJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matterof )
ENTERGY NUCLEAR OPERATIONS, INC. ) Docket Nos. 50-247- LR and 50-286-LR (Indian Point Nuclear Generating )
Units 2 and 3) August 20, 2008
)
TOWN OF CORTLANDT'S REQUEST FOR PARTICIPATION BY A PERSON NOT A PARTY I. Introduction The Town of Cortlandt ("Cortlandt"), a local governmental body within the meaning of 10 C.F.R. § 2.315(c), hereby requests participation in the above-captioned proceedings, pursuant to 10 C.F.R. § 2.315(c). Cortlandt's right to participate is established by the fact that Indian Point Nuclear Generating Units 2 and 3 are located within Cortlandt.
On July 31, 2008, the Atomic Safety and Licensing Board (the "Board") issued an Order on Petitions to Intervene and Requests for Hearing by Cortlandt, inter alia.1 Although the Board denied Cortlandt's Request for Hearing and Petition to Intervene, it stated that Cortlandt "may participate in the hearing as [an] interested governmental entit[y] pursuant to 10 C.F.R. § 2
2.315(c).",
See Board Order (Ruling on Petitions to Intervene and Requests for Hearing), LBP-08-13 (July 31, 2008)
(unpublished) 2 (the "Order").
Id. at 4.
~M~LA7 eS3 '
II. Background On April 23, 2007, Entergy Nuclear Operations, Inc. ("Entergy") submitted a License Renewal Application for Indian Point Units 2 and 3 to the Nuclear Regulatory Commission
("NRC"). On August 1, 2007, the NRC published a notice of opportunity for hearing in the Federal Register, 3 and later extended the time for filing requests until November 30, 2007.' On November 29, 2007,, Cortlandt filed its Petition to Intervene and Request for Hearing.
Subsequent to Answers- by the NRC and Entergy, Cortlandt filed its Reply on February 8, 2007.
On July 31, 2008, the Board denied Cortlandt's Request for Hearing and Petition to Intervene, but stated that Cortlandt may participate as an interested governmental entity on the admitted contentions, pursuant to 10 C.F.R. § 2.315(c). 5 In its Order, the Board stated that § 2.315(c) 6 Petitions must be submitted within thirty (30) days after the admission of any contention.
III. Cortlandt's Right to Participate in the Hearing Cortlandt is a local governmental body, within whose boundaries the Indian Point facility is located. As the Board stated,7 and neither NRC nor Entergy dispute,8 Cortlandt has standing in this proceeding and the right to participate as an interested local governmental body. See 10 C.F.R. § 2.315(c). Pursuant to § 2.315(c), Cortlandt designates Daniel Riesel, Esq., of Sive, Notice of Acceptance for Docketing of the Application & Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Nos. DPR-26 & DPR-64 for an Additional 20-Year Period, 72 Fed. Reg. 42,134 (Aug.
1,2007).
4 See Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Nos. DPR-26 & DPR-64 for an Additional 20-Year Period: Extension of Time for Filing of Requests for Hearing or Petitions for Leave to Intervene in the License Renewal Proceeding, 72 Fed. Reg. 55,8.34 (Oct. 1, 2007).
5 See Order at 4.
6 Id. at 225. Thirty days from July 31, 2008, the date the Board admitted 15 contentions, two of which were consolidated, is August 30, 2008. Because August 30, 2008 is a Saturday, and the following Monday is a federal legal holiday, the deadline for submitting a § 2.315(c) Petition is September 2, 2008. See 10 C.F.R. § 2.306(a).
7 See Order at 4.
' See NRC Staffs Response to Petitions for Leave to Intervene Filed by Seven Petitioners at 15 (January 22, 2008);
Answer of Entergy Nuclear Operations, Inc. Opposing Town of Cortlandt Request for Hearing and Petition to Intervene at 5 (January 22, 2008).
2
Paget & Riesel, P.C., as its representative for the hearing. Further, Cortlandt requests the opportunity to participate in the following contentions that the Board admitted in its July 31, 2008 Order: (1) NYS-5; (2) NYS-6/7; (3) NYS-8; (4) NYS-9; (5) NYS-12; (6) NYS-16; (7)
NYS-17; (8) NYS-24; (9) NYS-25; (10) NYS-26A (consolidated with Riverkeeper TC-1A); (11)
Riverkeeper TC-1A (consolidated with NYS-26A); (12) Riverkeeper TC-2; (13) Riverkeeper EC-3 (consolidated with Clearwater EC-1); (14) Clearwater EC-1 (consolidated with Riverkeeper EC-3); and (15) Clearwater EC-3. Cortlandt reserves the right to participate in such other contentions as the Board or Nuclear Regulatory Commission may subsequently establish as subject to adjudication.
Dated:
August 20, 2008 New York, New York Respectfully Submitted, Thomas F. Wood Town Attorney Town of Cortlandt And Sive, Paget & Riesel, P.C.
By_
Daniel Riesel 460 Park Avenue New York, New York 10022 Phone: (212) 421-2150 Facsimile: (212) 421-1891 Email: driesel@sprlaw.com 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
ENTERGY NUCLEAR OPERATIONS, INC. ) Docket Nos. 50-247- LR and 50-286-LR (Indian Point Nuclear Generating ) August 20, 2008 Units 2 and 3)
)
&,
CERTIFICATE OF SERVICE I hereby certify that on August 20, 2008 true copies of the foregoing TOWN OF CORTLANDT'S REQUEST FOR PARTICIPATION BY A PERSON NOT A PARTY, were served by electronic mail and by first class mail upon all parties, upon the following parties and participants:
Lawrence G. McDade, Chair Atomic Safety and Licensing Board Panel Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 Mail Stop - T-3 F23 Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Office of Commission Appellate E-mail: LGM1 @nrc.gov Adjudication U.S. Nuclear Regulatory Commission Dr. Richard E. Wardwell Mail Stop: O-16G4 Administrative Judge Washington, D.C. 20555-0001 Atomic Safety and Licensing Board Panel E-mail: OCAAMAIL@nrc.gov Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Office of the Secretary
- Washington, D.C. 20555-0001 Attn: Rulemaking and Adjudications Staff E-mail: REW@nrc.gov Mail Stop: O-16G4 U.S. Nuclear Regulatory Commission Dr. Kaye D. Lathrop Washington, D.C. 20555-0001 Administrative Judge E-mail: HEARINGDOCKET@nrc.gov Atomic Safety and Licensing Board Panel 190 Cedar Lane E.
Ridgway, CO 81432 E-mail: KDL2@nrc.gov Sherwin E. Turk, Esq.
Jessica A. Bielecki, Esq.
Beth N. Mizuno, Esq.
David E. Roth, Esq.
Marcia J. Simon, Esq.
Office of the General Counsel Joan Leary Matthews, Esq.
Mail Stop 0-15-D-21 Senior Attorney for Special Projects U.S. Nuclear Regulatory Commission New York State Department of Washington, D.C. 20555 Environmental Conservation E-mail: set@nrc.gov Office of the General Counsel E-mail: jessica.bielecki@nrc.gov 625 Broadway, 14th Floor E-mail: bnml@nrc.gov Albany, NY 12233-1500 E-mail: david.roth@nrc.gov E-mail: j lmatthe@gw.dec.state.ny.us E-mail: marcia.simon@nrc.gov Zachary S. Kahn, Esq.
Law Clerk Atomic Safety and Licensing Board Panel Mail Stop: T-2 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 E-mail: ZXK1 @nrc.gov William C. Dennis, Esq.
Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 E-mail: wdennis@entergy.com Elise N. Zoli, Esq.
Kathryn M. Sutton, Esq. Goodwin Procter, LLP Paul M. Bessette, Esq. Exchange Place Martin J. O'Neill, Esq. 53 State Street Morgan, Lewis & Bockius, LLP Boston, MA.02109 1111 Pennsylvania Avenue, NW E-mail: ezoli@goodwinprocter.corm Washington, D.C. 20004 E-mail: ksutton@morganlewis.com Justin D. Pruyne, Esq.
E-mail: pbessette@morganlewis.com Assistant County Attorney E-mail: martin.o'neill@morganlewis.com Office of Westchester County Attorney 148 Martine Avenue,6th Floor Michael J. Delaney, Esq. White Plains, NY 10601 Vice President - Energy E-mail: jdp3@westchestergov.com New York City Economic Development Corporation (NYCDEC) Daniel E. O'Neill, Mayor 110 William Street James Seirmarco, MS.
New York, NY 10038 Village of Buchanan E-mail: mdelaney@nycedc.com Municipal Building Buchanan, NY 10511-1298 E-mail: vob@bestweb.net 2
Richard L. Brodsky, Esq.
5 West Main Street John J. Sipos, Esq.
Elmsford, NY 10523 Charlie Donaldson, Esq.
E-mail: brodskr@assembly.state.ny.us Assistants Attorney General richardbrodsky@msn.com New York State Department of Law Environmental Protection Bureau Susan Shapiro, Esq. The Capitol 21 Perlman Drive Albany, NY 12224 Spring Valley, NY 10977 E-mail: john.sipos@oag. state.ny.us E-mail: mbs@ourrocklandoffice.com Arthur J. Kremer, Chairman John LeKay New York Affordable Reliable FUSE USA Electricity Alliance (AREA) 351 Dyckman Street 347 Fifth Avenue, Suite 508 Peekskill, NY 10566 New York, NY 10016 E-mail: fuse usa@yahoo.com E-mail: ajkremer@rmfpc.com kremer@area-alliance.org Manna Jo Greene Hudson River Sloop Clearwater, Inc.
112 Little Market Street Robert Snook, Esq.
Poughkeepsie, NY 12601 Office of the Attorney General E-mail: Mannajo@clearwater.org State of Connecticut 55 Elm Street Diane Curran, Esq. P.O. Box 120 Harmon, Curran, Spielberg & Eisenberg, Hartford, CT 06141-0120 LLP E-mail: Robert. snook@po. state.ct.us 1726 M Street, NW, Suite 600 Washington, D.C. 20036 Ms. Nancy Burton E-mail: dcurran@harmoncurran. corn 147 Cross Highway Redding Ridge, CT 06876 Victor Tafur, Esq. E-mail: nancyburtonct@aol.com Phillip Musegaas, Esq.
Riverkeeper, Inc. Sarah Wagner, Esq.
828 South Broadway Legislative Office Building, Room 422 Tarrytown, NY 10591 Albany, NY 12248 E-mail: phillip@riverkeeper.org E-mail: sarahwagneresq@gmail.com vtafur@riverkeeper.org John Louis Parker, Esq.
Janice Dean, Esq. Regional Attorney Assistant Attorney General Office of General Counsel, Region 3 Office of the Attorney General New York State Department of 120 Broadway, 2 6 th Floor Environmental Conservation New York, NY 10271 21 South Putt Comers Road E-mail: Janice.dean@oag.state.ny.us New Paltz, NY 12561-1620 E-mail: jlparker@gw.dec.state.ny.us 3
Marcia Carpentier Mylan L. Denerstein, Esq.
Law Clerk Executive Deputy Attorney General Atomic Safety and Licensing Board Office of the Attorney General Mail Stop: T-3 E2B 120 Broadway, 2 5 th Floor U.S. Nuclear Regulatory Commission New York, NY 10271 Washington, D.C. 20555-0001 E-mail: Mylan.Denerstein@oag.state.ny.us E-mail: Marcia.Carpentier@nrc.gov Stephen C. Filler, Esq.
Board Member Hudson River Sloop Clearwater, Inc.
303 South Broadway, Ste 222 Tarrytown, NY 10592 E-mail: sfiller@nylawline.com By:
Thomas F. Wood Town Attorney Town of Cortlandt And Sive, Paget & Riesel, P.C.
Daniel Riesel 460 Park Avenue New York, New York 10022 Phone: (212) 421-2150 Facsimile: (212) 421-1891 Email: diiesel@sprlaw.com