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Category:Legal-Intervention Petition
MONTHYEARML1107503812011-03-10010 March 2011 Entergy'S Response to New England Coalition'S Motion for Stay and Request for Further Opportunity for Hearings ML1036300302010-12-23023 December 2010 Entergy'S Response to the Supplement to New England Coalition'S Petition for Commission Review of LBP-10-19 ML1033403292010-11-22022 November 2010 Entergy'S Answer Opposing New England Coalition'S Petition for Commission Review of LBP-10-19 ML1028002492010-09-30030 September 2010 New England Coalition'S Answer & Opposition to Entergy'S Motion to Strike Declaration of Paul Blanch ML1027204022010-09-20020 September 2010 New England Coalition'S Reply to NRC Staff and Entergy Nuclear Vermont Yankee Opposition to New England Coalition'S Motion to Reopen the Hearing & Reply to NRC Staff'S Answer to Proposed New Contention ML1026003772010-09-14014 September 2010 Entergy'S Answer Opposing New England Coalition'S Motion to Reopen ML1007403702010-03-12012 March 2010 Entergy'S Response in Opposition to New England Coalition'S Stay Request ML0922400652009-08-0303 August 2009 Entergy'S Response in Opposition to New England Coalition'S Petition for Review of LBP-09-09 ML0921202202009-07-23023 July 2009 New England Coalition'S Petition for Review of the Licensing Board'S Full Initial Decision, LBP-09-09 ML0916702632009-06-0808 June 2009 New England Coalition'S Opposition to Entergy'S Motion to Strike New England Coalition'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention ML0915404042009-05-26026 May 2009 Nec'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention ML0914203732009-05-18018 May 2009 Entergy'S Opposition to Nec'S Motion to File a Timely New Contention ML0913400192009-05-0707 May 2009 New England Coalition'S Reply to Nrc'S Staff and Entergy Answers to New England Coalition'S Motion to Hold in Abeyance Action on It'S Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report ML0912708592009-05-0101 May 2009 Entergy'S Opposition to New England Coalition'S Motion to Hold Action on Proposed Contention in Abeyance Until Issuance of NRC Staff Supplemental Safety Evaluation Report ML0908404222009-03-10010 March 2009 Final Calculations of Record for the Confirmatory Environmentally Assisted Fatigue (Cufen) Analyses on the Reactor Pressure Vessel Core Spray (CS) and Recirculation Outlet (RO) Nozzles at Vermont Yankee ML0912101052009-03-0909 March 2009 New England Coalition'S Petition for Leave Reply to Entergy Responses to New England Coalition'S Motion to Alter or Amend the Schedule in the Above Captioned Proceeding ML0907711422009-03-0909 March 2009 Entergy'S Opposition to New England Coalition'S Motion to Alter or Amend the Schedule ML0901400782009-01-0707 January 2009 Entergy'S Opposition to New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial Initial Decision ML0901400792008-12-29029 December 2008 Entergy'S Answer Opposing Motion by New York Et Al. for Leave to Submit Brief Amici Curiae ML0901602092008-12-19019 December 2008 New England Coalition'S Response to NRC Staff'S Petition for Review of the Licensing Board'S Partial Initial Decision, LBP-08-25 ML0900606092008-12-19019 December 2008 Entergy'S Answer in Support of NRC Staff'S Petition for Review of the Licensing Board'S Partial Initial Decision ML0836600342008-12-19019 December 2008 Vermont Department of Public Service Opposition to Petition for Review of Partial Initial Decision LBP-08-25 ML0836401982008-12-11011 December 2008 Entergy'S Answer to Commonwealth of Massachusetts Petition for Review of LBP-08-25 and Request for Consolidated Ruling ML0835205232008-12-10010 December 2008 Entergy'S Response in Opposition to New England Coalition'S Motion to Extend Time to File Petition for Review ML0835004492008-12-0404 December 2008 Entergy'S Motion for Clarification ML0835100872008-12-0404 December 2008 Entergy'S Opposition to New England Coalition'S Motion to Extend Time to File Motion for Reconsideration ML0824018252008-08-25025 August 2008 Vermont Yankee - NRC Staff'S Proposed Findings of Fact and Conclusion of Law and Order in the Form of an Initial Decision ML0819905482008-07-15015 July 2008 Vermont Yankee - NRC Staff Letter to Board Regarding Evidentiary Hearing Attendees ML0820501022008-07-15015 July 2008 Entergy'S Response to July 11, 2008 Board Order ML0820501012008-07-15015 July 2008 Entergy'S Reply to Responses to Licensing Board'S Questions ML0820406152008-07-15015 July 2008 Vermont Department of Public Service Response to Entergy and NRC Staff Brief on Pre-Trial Legal Issues ML0819806542008-07-15015 July 2008 Vermont Yankee - NRC Staff'S Reply Brief ML0819704842008-07-0909 July 2008 Entergy'S Answers to Licensing Board Questions ML0819202482008-07-0909 July 2008 Vermont Yankee - Nrc'S Brief in Response to Board Order ML0819805252008-07-0808 July 2008 Joint Stipulation ML0819704802008-07-0707 July 2008 Entergy'S Response to Vermont Department of Public Service Motion for Modification of the Scheduling Order to Facilitate Full Compliance with 10 C.F.R. 2.323(b) ML0818504242008-07-0202 July 2008 Vermont Yankee - NRC Staff'S Response to Vermont Department of Public Service'S Motion to Modify the Schedule ML0819100872008-06-30030 June 2008 New England Coalition, Inc'S Opposition to Entergy'S and the NRC Staff'S Motions in Limine to Exclude Rebuttal Testimony of Ulrich Witte ML0819200412008-06-30030 June 2008 Entergy'S Response in Support of Staff'S Motion in Limine to Exclude Witte Rebuttal Testimony ML0818304142008-06-23023 June 2008 Entergy'S Response in Opposition to NEC Motion to File Untimely Rebuttal Testimony by Ulrich Witte ML0817807432008-06-20020 June 2008 Filing Discussing Proprietary Documents in the Matter of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc ML0817107262008-06-19019 June 2008 Vermont Yankee - NRC Staff'S Response to Nec'S Motion to Strike NRC Staff'S Rebuttal Testimony Concerning NEC Contention 4 ML0817800972008-06-19019 June 2008 Entergy'S Response in Support of Staff'S Motion in Limine ML0816305762008-06-0505 June 2008 2008/06/05-Vermont Yankee License Renewal Proceeding: June 24 Call ML0814905522008-05-20020 May 2008 Certificate of Disclosure of Sarah Hofmann, for the Vermont Department of Public Service Certifying Current with Disclosures Pursuant to 10 C.F.R. 2.336 That Are Relevant and Not Privileged to the Contentions Now Being Considered ML0814306502008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.; Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club.. ML0814906102008-05-15015 May 2008 2008/05/15-Supplemental Petition by Collective Petitioners for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0814306512008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.: Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club: New Jersey.. ML0816402452008-05-15015 May 2008 2008/05/15-Supplemental Petition by Listed Companies for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews, for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0813501902008-05-0606 May 2008 Commonwealth of Massachusetts' Notice of Intent to Participate as an Interested State 2011-03-10
[Table view] Category:Responses and Contentions
MONTHYEARML1107503812011-03-10010 March 2011 Entergy'S Response to New England Coalition'S Motion for Stay and Request for Further Opportunity for Hearings ML1036300302010-12-23023 December 2010 Entergy'S Response to the Supplement to New England Coalition'S Petition for Commission Review of LBP-10-19 ML1033403292010-11-22022 November 2010 Entergy'S Answer Opposing New England Coalition'S Petition for Commission Review of LBP-10-19 ML1028002492010-09-30030 September 2010 New England Coalition'S Answer & Opposition to Entergy'S Motion to Strike Declaration of Paul Blanch ML1027204022010-09-20020 September 2010 New England Coalition'S Reply to NRC Staff and Entergy Nuclear Vermont Yankee Opposition to New England Coalition'S Motion to Reopen the Hearing & Reply to NRC Staff'S Answer to Proposed New Contention ML1026003772010-09-14014 September 2010 Entergy'S Answer Opposing New England Coalition'S Motion to Reopen ML1007403702010-03-12012 March 2010 Entergy'S Response in Opposition to New England Coalition'S Stay Request ML0922400652009-08-0303 August 2009 Entergy'S Response in Opposition to New England Coalition'S Petition for Review of LBP-09-09 ML0921202202009-07-23023 July 2009 New England Coalition'S Petition for Review of the Licensing Board'S Full Initial Decision, LBP-09-09 ML0916702632009-06-0808 June 2009 New England Coalition'S Opposition to Entergy'S Motion to Strike New England Coalition'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention ML0915404042009-05-26026 May 2009 Nec'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention ML0914203732009-05-18018 May 2009 Entergy'S Opposition to Nec'S Motion to File a Timely New Contention ML0913400192009-05-0707 May 2009 New England Coalition'S Reply to Nrc'S Staff and Entergy Answers to New England Coalition'S Motion to Hold in Abeyance Action on It'S Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report ML0912708592009-05-0101 May 2009 Entergy'S Opposition to New England Coalition'S Motion to Hold Action on Proposed Contention in Abeyance Until Issuance of NRC Staff Supplemental Safety Evaluation Report ML0908404222009-03-10010 March 2009 Final Calculations of Record for the Confirmatory Environmentally Assisted Fatigue (Cufen) Analyses on the Reactor Pressure Vessel Core Spray (CS) and Recirculation Outlet (RO) Nozzles at Vermont Yankee ML0912101052009-03-0909 March 2009 New England Coalition'S Petition for Leave Reply to Entergy Responses to New England Coalition'S Motion to Alter or Amend the Schedule in the Above Captioned Proceeding ML0907711422009-03-0909 March 2009 Entergy'S Opposition to New England Coalition'S Motion to Alter or Amend the Schedule ML0901400782009-01-0707 January 2009 Entergy'S Opposition to New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial Initial Decision ML0901400792008-12-29029 December 2008 Entergy'S Answer Opposing Motion by New York Et Al. for Leave to Submit Brief Amici Curiae ML0901602092008-12-19019 December 2008 New England Coalition'S Response to NRC Staff'S Petition for Review of the Licensing Board'S Partial Initial Decision, LBP-08-25 ML0900606092008-12-19019 December 2008 Entergy'S Answer in Support of NRC Staff'S Petition for Review of the Licensing Board'S Partial Initial Decision ML0836600342008-12-19019 December 2008 Vermont Department of Public Service Opposition to Petition for Review of Partial Initial Decision LBP-08-25 ML0836401982008-12-11011 December 2008 Entergy'S Answer to Commonwealth of Massachusetts Petition for Review of LBP-08-25 and Request for Consolidated Ruling ML0835205232008-12-10010 December 2008 Entergy'S Response in Opposition to New England Coalition'S Motion to Extend Time to File Petition for Review ML0835004492008-12-0404 December 2008 Entergy'S Motion for Clarification ML0835100872008-12-0404 December 2008 Entergy'S Opposition to New England Coalition'S Motion to Extend Time to File Motion for Reconsideration ML0824018252008-08-25025 August 2008 Vermont Yankee - NRC Staff'S Proposed Findings of Fact and Conclusion of Law and Order in the Form of an Initial Decision ML0819905482008-07-15015 July 2008 Vermont Yankee - NRC Staff Letter to Board Regarding Evidentiary Hearing Attendees ML0820501022008-07-15015 July 2008 Entergy'S Response to July 11, 2008 Board Order ML0820501012008-07-15015 July 2008 Entergy'S Reply to Responses to Licensing Board'S Questions ML0820406152008-07-15015 July 2008 Vermont Department of Public Service Response to Entergy and NRC Staff Brief on Pre-Trial Legal Issues ML0819806542008-07-15015 July 2008 Vermont Yankee - NRC Staff'S Reply Brief ML0819704842008-07-0909 July 2008 Entergy'S Answers to Licensing Board Questions ML0819202482008-07-0909 July 2008 Vermont Yankee - Nrc'S Brief in Response to Board Order ML0819805252008-07-0808 July 2008 Joint Stipulation ML0819704802008-07-0707 July 2008 Entergy'S Response to Vermont Department of Public Service Motion for Modification of the Scheduling Order to Facilitate Full Compliance with 10 C.F.R. 2.323(b) ML0818504242008-07-0202 July 2008 Vermont Yankee - NRC Staff'S Response to Vermont Department of Public Service'S Motion to Modify the Schedule ML0819100872008-06-30030 June 2008 New England Coalition, Inc'S Opposition to Entergy'S and the NRC Staff'S Motions in Limine to Exclude Rebuttal Testimony of Ulrich Witte ML0819200412008-06-30030 June 2008 Entergy'S Response in Support of Staff'S Motion in Limine to Exclude Witte Rebuttal Testimony ML0818304142008-06-23023 June 2008 Entergy'S Response in Opposition to NEC Motion to File Untimely Rebuttal Testimony by Ulrich Witte ML0817807432008-06-20020 June 2008 Filing Discussing Proprietary Documents in the Matter of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc ML0817107262008-06-19019 June 2008 Vermont Yankee - NRC Staff'S Response to Nec'S Motion to Strike NRC Staff'S Rebuttal Testimony Concerning NEC Contention 4 ML0817800972008-06-19019 June 2008 Entergy'S Response in Support of Staff'S Motion in Limine ML0816305762008-06-0505 June 2008 2008/06/05-Vermont Yankee License Renewal Proceeding: June 24 Call ML0814905522008-05-20020 May 2008 Certificate of Disclosure of Sarah Hofmann, for the Vermont Department of Public Service Certifying Current with Disclosures Pursuant to 10 C.F.R. 2.336 That Are Relevant and Not Privileged to the Contentions Now Being Considered ML0814306502008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.; Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club.. ML0814906102008-05-15015 May 2008 2008/05/15-Supplemental Petition by Collective Petitioners for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0814306512008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.: Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club: New Jersey.. ML0816402452008-05-15015 May 2008 2008/05/15-Supplemental Petition by Listed Companies for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews, for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0813501902008-05-0606 May 2008 Commonwealth of Massachusetts' Notice of Intent to Participate as an Interested State 2011-03-10
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P.-45 H-q17 DOCKETED OPY USNRC June 20, 2008 (8:00am) June 19, 2008 OFFICE OF SECRETARY RULEMAKINGS AND UNITED STATES OF AMERICA ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ))Entergy Nuclear Vermont Yankee, LLC ) Docket No. 50-271-LR and Entergy Nuclear Operations, Inc. ) ASLBP No. 06-849-03-LR
)(Vermont Yankee Nuclear Power Station) )ENTERGY'S RESPONSE IN SUPPORT OF STAFF'S MOTION IN LIMINE Pursuant to 10 C.F.R. § 2.323(c) and paragraph 10.E of the Atomic Safety and Licensing Board ("Board")'s Initial Scheduling Order dated November 17, 2006, Applicants Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (collectively "Entergy")
hereby file their response in support of the NRC Staff's "Motion in Limine to Strike Testimony and Exhibits Filed by New England Coalition, Inc." (June 12, 2008) ("Staff Motion in Limine").The Staff's Motion in Limine seeks to exclude (1) the testimony submitted by Mr. Ulrich Witte ("Witte Direct") on behalf of intervenor New England Coalition, Inc. ("NEC"); (2) portions of the testimony submitted by Dr. Joram Hopenfeld (collectively "Hopenfeld Testimony")
on behalf of NEC; and (3) the entire testimony submitted by Dr. Hopenfeld and by Dr. Rudolf Hausler ("Hausler Direct") on behalf of NEC (on the grounds that these NEC witnesses lack adequate qualifications to testify on the contentions in controversy in this proceeding).
Entergy fully supports the Staff's Motion in Limine. With respect to Mr. Witte, Entergy has filed its own Motion in Limine to exclude the entirety of testimony and exhibits proffered by Mr. Witte on similar grounds to those raised by the Staff. Entergy's Motion in Limine (June 12, 2008). Mr. Witte is clearly unqualified to testify as an expert on flow accelerated corrosion, which is the subject of NEC Contention 4 and of the Witte Direct. See Entergy Motion in Limine at 22-23. Also, his testimony contains many statements lacking any factual support, see id. at 23-25, and in many instances the testimony does not rise above sheer speculation.
See,Staff Motion in Limine at 5-6. Finally, Mr. Witte provides opinions and. makes statements that are clearly outside the scope of this proceeding.
See id. at 7-9. For all these reasons, Mr.Witte's testimony and exhibits are inadmissible.
The Staff also seeks the exclusion of four statements included in the Hopenfeld Direct: (1) Dr. Hopenfeld's attack on the testimony of Staff witness John Fair; (2) Dr. Hopenfeld's interpretation of the binding nature of the recommendations in the American Society of Mechanical Engineers
("ASME") Code; (3) Dr. Hopenfeld's gloss on the requirements of 10 C.F.R. § 54.21; and (4) Dr. Hopenfeld's allegations as to Entergy's failure to provide documentation needed for his review. Staff Motion in Limine at 9-10. All four statements are inappropriate testimony and should be excluded.First, Dr. Hopenfeld's attack on the testimony of Mr. Fair, who Dr. Hopenfeld's accuses of blatantly distorting information in his presentation before the ACRS, is irrelevant, prejudicial and lacks probative value. Second, the ASME Code, like other industry documents, provides only guidance and does not set forth any binding standards.
Therefore, Dr. Hopenfeld's characterization of the Code as setting requirements (Pre-filed Rebuttal Testimony of Dr. Joram Hopenfeld Regarding NEC Contentions 2A, 2B, 3 and 4, NEC Exhibit NEC-JH_63)
("Hopenfeld Rebuttal")
at 3 (A5) is on its face incorrect and should be stricken.
Third, Dr.Hopenfeld seeks to expand the requirements imposed by 10 C.F.R. § 54.21(c) by adding to the regulation a requirement
("a demonstration that components will operate safely in the reactor environment," Hopenfeld Rebuttal at 6 and A5) that is not contained in the regulation and that is 2 patently wrong, as it overstates and misconstrues the requirement in the regulation that license renewal applicants perform time-limited analyses; in addition, Dr. Hopenfeld is not qualified to testify as to what NRC regulations "require." Fourth, Dr. Hopenfeld's complaints about Entergy's failure to provide documentation needed for his review are inappropriate subjects for testimony because they are irrelevant to the evidence to be presented.
If there was such a failure (which Entergy denies) it could and should have been handled by NEC through counsel requests (which were actually made in the course of discovery) or through a motion to compel discovery and a subsequent Board ruling. Indeed, NEC did not properly raised these discovery issues with Entergy or before the Board, and waived any right to complain about them at this late stage.The last element of the Staff Motion in Limine demonstrates the lack of qualifications of Dr. Hopenfeld to testify as an expert on NEC Contentions 2A, 2B and 4, and of Dr. Hausler to testify as an expert on NEC Contention
- 4. Entergy agrees with the Staff's position.
Neither witness has shown through their education and experience that they are qualified to opine on the evaluation of environmentally assisted fatigue (as Dr. Hopenfeld seeks to do on NEC Contentions 2A and 2B) or on the development and implementation of programs to manage flow accelerated corrosion in operating nuclear reactors (as both Dr. Hopenfeld and Dr. Hausler seek to do on NEC Contention 4). Their testimony should be excluded for lack of qualifications.
Respectfully Submitted, David R. Lewis Matias F. Travieso-Diaz Blake J. Nelson PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037-1122 Tel. (202) 663-8000 Counsel for Entergy Dated: June 19, 2008 3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of)Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.(Vermont Yankee Nuclear Power Station)))))Docket No. 50-271-LR ASLBP No. 06-849-03-LR CERTIFICATE OF SERVICE I hereby certify that copies of "Entergy's Response in Support of Staff's Motion in Limine" were served on the persons listed below by deposit in the U.S. Mail, first class, postage prepaid, and where indicated by an asterisk by electronic mail, this 1 9 th day of June, 2008.*Administrative Judge Alex S. Karlin, Esq., Chairman Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ask2@nrc.gov
- Administrative Judge William H. Reed 1819 Edgewood Lane Charlottesville, VA 22902 whrcville@embarqmail.com
- Administrative Judge Dr. Richard E. Wardwell Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 rew @nrc.gov* Secretary Att'n: Rulemakings and Adjudications Staff Mail Stop 0-16 C1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 secy@nrc.gov, hearingdocketpnrc.gov Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
- Office of Commission Appellate Adjudication Mail Stop 0-16 C I U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 OCAAmail(cnrc.
gov
- Lloyd Subin, Esq.*Mary Baty, Esq.* Jessica A. Bielecki, Esq.*Susan L. Uttal, Esq.Office of the General Counsel Mail Stop O-15-D21 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 LBS3.c@,nrc.gov;.mcbl
@nrc.gov;i essica.bielecki(2j)nrc.gov; susan.uttal(a),nrc.,gov
- Sarah Hofmann, Esq.Director of Public Advocacy Department of Public Service 112 State Street -Drawer 20 Montpelier, VT 05620-2601 Sarah.hofmann(&state.vt.us
- Peter L. Roth, Esq.Office of the New Hampshire Attorney General 33 Capitol Street Concord, NH 03301 Peter.roth(adoj .nh.gov*Lauren Bregman, Law Clerk Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington, D.C. 20555-0001 Lauren.BrepnanO~nrc.
gov*Ronald A. Shems, Esq.*Karen Tyler, Esq.Shems, Dunkiel, Kassel & Saunders, PLLC 9 College Street Burlington, VT 05401 rshems(asdkslaw.com ktylerna)sdkslaw.com
- Marcia Carpenter, Esq.Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 mxc7 Rcnrc.gov*Diane Curran, Esq.Harmon, Curran, Spielberg, & Eisenberg, L.L.P.1726 M Street N.W., Suite 600 Washington, D.C. 20036 dcurran(@harmoncurran.
corn* Matthew Brock Assistant Attorney General Office of the Attorney General One Ashburton Place, 18th Floor Boston, MA 02108 Matthew.Brock state.ma.us V 47 r, 7;ýo 10 CýI Matias F. Travieso-DiaAf 2