ML061720384

Pilgrim - Notice of Adoption of Contention by Pilgrim Watch

ML061720384
Person / Time
Site:	Pilgrim
Issue date:	06/05/2006
From:	Matt Bartlett Pilgrim Watch
To:	Atomic Safety and Licensing Board Panel
Giitter R
References
05-293-LR, ASLBP 06-848-02-LR, RAS 11821
Download: ML061720384 (4)

Text

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DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD June 6,2006 (8:00am)

OFFICE OF SECRETARY RULEMAKINGS AND In the matter of Docket # 50-293 ADJUDICATIONS STAFF Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application June 5, 2006 NOTICE OF ADOPTION OF CONTENTION BY PILGRIM WATCH Pilgrim Watch hereby gives notice pursuant to 10 C.F.R. § 2.309(f)(3) and 10 C.F.R. § 2.323 that it is adopting the Contention filed by the State of Massachusetts on May 26, 2006.

1. Pilgrim Watch filed a Request for a Hearing and Petition to Intervene in the license renewal for Pilgrim Nuclear Power Plant on May 26, 2006. In that Petition Pilgrim Watch submitted five of its own Contentions pursuant to the requirements of 10 CFR § 2.309.

2. On May 26, 2006, the Attorney General of the State of Massachusetts filed a "Request for a Hearing and Petition for Leave to Intervene with Respect to Entergy Nuclear Operations Inc.'s Application for Renewal of the Pilgrim Nuclear Power Plant Operating License and Petition for Backfit Order Requiring New Design Features to Protect Against Spent Fuel Accidents." In that Petition the State of Massachusetts raised a Contention that the Environmental Report for Renewal of the Pilgrim Nuclear Power Plant fails to satisfy NEPA because it does not address the environmental impacts of severe spent fuel pool accidents.

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3. Pilgrim Watch adopts the Contention filed by the Commonwealth of Massachusetts on May 26, 2006 in this proceeding and has consulted with the Commonwealth pursuant to 10 C.F.R. § 2.309(f)(3) and through its counsel, Assistant Attorney General Matthew Brock. The Commonwealth of Massachusetts concurs in this arrangement provided that the Commonwealth shall be the representative for its Contention.

4. In addition, Pilgrim Watch adopts the Reports prepared in support of the Contention by Gordon R. Thompson entitled "Risks and Risk-Reducing Options Associated with Pool Storage of Spent Nuclear Fuel at the Pilgrim and Vermont Yankee Nuclear Power Plants" and by Jan Beyea entitled "Report To The Massachusetts Attorney General On The Potential Consequences Of A Spent-Fuel-Pool Fire At The Pilgrim Or Vermont Yankee Nuclear Plant. "

5. Pilgrim Watch has standing to adopt and pursue the Commonwealth's Contention. Indeed, the standing declaration submitted in support of Pilgrim Watch's Petition amply demonstrates standing for Pilgrim Watch's adoption of the State's Contention. Further, Pilgrim Watch has the resources and expertise to pursue this Contention in the event that a designated representative cannot.

WHEREFORE, Pilgrim Watch respectfully gives notice of and requests to adopt the Contention filed by the Commonwealth of Massachusetts.

June 5, 2006

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Docket # 50-293 Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application June 5, 2006 CERTIFICATE OF SERVICE I hereby certify that the foregoing Notice of Adoption of Contention was sent this 5h day of June, 2006 via email and U.S. Postal Service as designated to each of the following:

Secretary of the Commission (Email and 2 copies via U.S Postal Service)

United States Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemaking and Adjudications Staff Email: HEARINGDOCKET@,NRC.GOV Office of General Counsel (Email and U.S. Postal Service)

United States Nuclear Regulatory Commission Washington, DC 20555-0001 Email: OGCMailCenter@nrc.gov Mr. Terence A. Burke, Esq. (U.S. Postal Service)

Entergy Nuclear 1340 Echelon Parkway Mail Stop M-ECH-62 Jackson, MS 39213 Mary Elizabeth Lampert (Email)

Pilgrim Watch 148 Washington Street Duxbury, MA 02332 Email: lampert@adelphia.net W114H~~

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Molly H. Bartlett Attorney at Law 52 Crooked Lane phone:781-934-9473 Duxbury, MA 02332 mollyhbartlett~hotmail.com June 5, 2006 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemaking and Adjudications Staff

Subject:

Notice of Adoption of Contention by Pilgrim Watch Docket 4 50-293

Dear Mr. Secretary,

On behalf of Pilgrim Watch, I am enclosing the original and two copies of the Notice of Adoption of Contention by Pilgrim Watch in the above referenced proceeding.

In addition, this document is being filed electronically. Please file this document and take appropriate steps to assure that it is processed in accordance with the Code of Federal Regulations. If you have any questions or problems with regard to this Notice, please let me know immediately. I look forward to, and appreciate in advance, your confirmation of the receipt of this filing.

cry truly yours, Moll H Wrtlett