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Category:Legal-Motion
MONTHYEARML23136B1622023-05-15015 May 2023 Town of North Salem, County of Westchester, New York Board Resolution Letter Regarding Treated Water Release from Indian Point Site ML21153A0072021-05-28028 May 2021 5-28-21 Motion for Voluntary Dismissal (DC Cir.)(Case No. 21-1084) ML21050A4322021-02-18018 February 2021 2-18-21 Motion to Intervene (DC Cir.)(Case No. 21-1037) ML20311A6602020-11-0606 November 2020 Motion of Riverkeeper, Inc. for Full Adjudication of Its Pending Contention Prior to Any Decision by NRC on the License Transfer ML20311A6612020-11-0606 November 2020 Declaration of David Lochbaum in Support of Riverkeeper'S Motion for Full Adjudication of Its Pending Contention Prior to Any Decision by NRC on the License Transfer ML20296A2832020-10-20020 October 2020 Resubmission of Motion of Riverkeeper, Inc. to Supplement the Basis for Its Contention with New Evidence Not Previously Available (Technical Correction) ML20084Q1912020-03-24024 March 2020 New York State Motion for Leave to Amend Contentions NY-2 and NY-3 ML20072K2862020-03-12012 March 2020 Unopposed Motion of Riverkeeper, Inc. for an Enlargement of Time to File Its Reply ML20071J9722020-03-11011 March 2020 Unopposed Motion of the Town of Cortlandt, Village of Buchanan and Hendrick Hudson School District for an Enlargement of Time to File Its Reply ML20071D8392020-03-11011 March 2020 Unopposed Motion of the State of New York for an Enlargement of Time to File Its Reply ML18347B0662018-12-13013 December 2018 Intervenors' Motion for Production by the Regulatory Staff of Post Operational Inspection Reports ML17039B0912017-02-0808 February 2017 Kwong Declaration of Lisa Kwong ML17039B0922017-02-0808 February 2017 Declaration of Diane Curran ML17039B0902017-02-0808 February 2017 NYS and Riverkeeper Notice of Withdrawal and Unopposed Motion to Dismiss Contentions and Proceeding ML16300A3882016-10-26026 October 2016 Unopposed Joint Motion to Extend Track 2 Hearing Schedule Deadlines ML16207A7132016-07-25025 July 2016 Joint Motion for Reconsideration or, in the Alternative, Clarification of the July 13, 2016 Licensing Board Order Scheduling Further Filings on the Track 2 Contentions ML16182A5112016-06-30030 June 2016 State of New York Motion to Establish Schedule ML16189A3182016-06-16016 June 2016 Entergy Motion to Intervene (D C Cir 6-16-16 ML16085A2122016-03-25025 March 2016 NYS Certificate of Service ML16085A2112016-03-25025 March 2016 NYS Reply in Support of Contention NYS-40 ML16069A2922016-03-0909 March 2016 NYS Cover Letter Regarding February 19, 2016, Order (Requesting Expert Testimony on New York'S Proposed Exhibits and Suspending Deadline for Filing Proposed Findings of Fact and Law) ML16069A2932016-03-0909 March 2016 NYS Unopposed Motion for Extension of Time to File Reply Expert Testimony ML16069A2942016-03-0909 March 2016 NYS Cos Regarding Unopposed Motion for Extension of Time to File Reply Expert Testimony ML16068A4412016-03-0808 March 2016 Riverkeeper Motion to Admit New Contention in Indian Point Case ML16060A5872016-02-29029 February 2016 NYS Supplement to February 22, 2016 Motion for Leave ML16060A5882016-02-29029 February 2016 NYS Certificate of Service ML16057A5322016-02-26026 February 2016 NYS Motion for Stay or to Vacate ML16057A5542016-02-26026 February 2016 NYS Certificate of Service ML16057A5332016-02-26026 February 2016 NYS Declaration in Support of Motion ML16057A5532016-02-24024 February 2016 NYS Exhibit 14 on Notification of Issuance of License Amendment ML16057A5522016-02-23023 February 2016 NYS Exhibit 13 on NRC Issuance of Amendment Re Extension of Containment Integrated Leak Rate Test to 15 Years ML16054A6712016-02-22022 February 2016 NYS Motion for Leave Re Contention NYS-40 ML16057A5492016-02-22022 February 2016 NYS Exhibit 12 on Commission Notification of Significant Licensing Action ML16047A4252016-02-16016 February 2016 NRC Staff Answer to New York Motion for Leave to File Six Documents as Additional Exhibits ML16036A3512016-02-0505 February 2016 NYS Cover Letter - Submitting Motion for Leave to File Additional Exhibits ML16036A3552016-02-0505 February 2016 Attachment 2 - to State of New York Kwong Declaration Dated February 5, 2016 ML16036A3622016-02-0505 February 2016 NYS000589 - Revised Track 2 New York State Exhibits List ML16036A3612016-02-0505 February 2016 NYS000588 - NRC Inspection Report, Indian Point Unit 3, 05000286/2015011 (November 19, 2015) (ML15323A026) ML16036A3632016-02-0505 February 2016 Declaration for Lisa S. Kwong ML16036A3722016-02-0505 February 2016 NYS Motion for Leave Cos Public EIE ML16036A3732016-02-0505 February 2016 NYS Motion for Leave Coa Non Public EIE ML16036A3542016-02-0505 February 2016 Attachment 1- New York State List of Attachments and Proposed Exhibits Table ML16036A3532016-02-0505 February 2016 NYS Motion for Leave to File Six Documents as Additional Exhibits ML15357A5562015-12-23023 December 2015 Entergy'S Answer to Opposing State of New York Motion for Public Disclosure of Six Revised Westinghouse Documents ML15348A4382015-12-14014 December 2015 Attachment 4 - Cover Page of ENTR00681 WCAP-17199-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted ML15348A4392015-12-14014 December 2015 Attachment 5 - Cover Page of ENTR00682 WCAP-17200-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted ML15348A4402015-12-14014 December 2015 Attachment 6 - Cover Page of ENTR00683 CN-PAFM-13-32, Revision 4, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted ML15348A4412015-12-14014 December 2015 Attachment 7 - Cover Page of ENTR00689 WCAP-12191, Revision 5, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted ML15348A4422015-12-14014 December 2015 Attachment 8 - Cover Page of ENTR00690 WCAP-16898-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement, Full Text Copyrighted ML15348A4432015-12-14014 December 2015 Attachment 9 - Cover Page of ENTR00727 CN-PAFM-09-21, Revision 4, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted 2023-05-15
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Lawrence G. McDade, Chairman Dr. Kaye D. Lathrop Dr. Richard E. Wardwell In the Matter of ) Docket Nos. 50-247-LR
) and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
__ ) Date: November 26, 2012 HUDSON RIVER SLOOP CLEARWATER, INC.S NOTICE OF SUPPLEMENTAL EXHIBITS TO MOTION TO SUPPLEMENT THE RECORD WITH RELEVANT NEW INFORMATION THAT BECAME APPARENT AFTER HURRICANE SANDY On November 14, 2012, Hudson River Sloop Clearwater, Inc. (Clearwater) filed a Motion to Supplement the Record with Relevant New Information that Became Apparent after Hurricane Sandy. The Motion included evidence of how Hurricane Sandy had a disparate impact on environmental justice populations, including low income individuals, the elderly and the disabled, as well as those in prisons, hospitals, and nursing homes. Moreover, through its Motion, Clearwater indicated that it would continue to send the Atomic Safety and Licensing Board (the Board) additional information on relevant topics as more analyses of the disparate impact of Hurricane Sandy become available. To that end, Clearwater files four additional articles for the Boards consideration.
The first article illustrates how Hurricane Sandy added thousands to New York Citys homeless populations while the storm exposed the citys acute lack of affordable housing options, 1
revived outlawed practices of housing the homeless on armory floor, led chaotic, unsanitary conditions, and scattered hundreds of homeless people all oer New York City. CLE000072. The second article explores the disparate impact that the storm had on those living in New York Citys public housing developments. CLE000073. Speaking about a meeting with public housing residents, The New York Times reports that in addition to power outages far more prolonged than private residents experienced, mostly what one heard was a litany of miseries, testament to all the ancillary misfortunes of poverty and all the accompanying expressions of frustration and rage: from the diabetic woman who had no place to safely store her insulin during the power failure and nowhere to safely care for her autistic son; from the woman with sickle-cell anemia whose apartment was still cold; from the lifelong resident who spoke of a young girls rape. Id. The third article explains how the natural disaster has added to the ranks of the unemployed, CLE000074, while the fourth article describes the difficulties that area food banks have had in their attempt to provide services to disaster-affected families in low income communities. CLE000075.
These articles present new materially different relevant information because they illustrate yet more ways in which environmental justice communities are disparately affected by major disasters such as storms and nuclear accidents. This Board should therefore admit these Exhibits.
Clearwater consulted regarding this Motion on 11/21/2012. Entergy intends to oppose this Motion, while Clearwater did not yet hear from the NRC Staff.
Respectfully Submitted,
_________/s/__________
Richard Webster, Esq.
Public Justice, P.C.
1825 K Street, NW Suite 200 Washington, D.C. 20006 rwebster@publicjustice.net 202 797-8600 2
_________/s/____________
Karla Raimundi, Esq.
Hudson River Sloop Clearwater, Inc.
724 Wolcott Avenue Beacon, N.Y. 12508 karla@clearwater.org 845-265-8080 Dated: November 26, 2012 3