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Category:Legal-Correspondence
MONTHYEARML20183A1222020-06-30030 June 2020
6-30-20 Dismissal Agreement (DC Cir.)(Case No. 19-1198)(Consolidated with 20-1019)
ML20063N0002020-02-26026 February 2020
2-26-20 Statement of Intent to Utilize Deferred Joint Appendix (DC Cir.)(Case No. 20-1019)
ML20035C7762020-01-31031 January 2020
1-31-20 Entergy Entry of Appearance (DC Cir.)(Case No. 20-1019)
ML20024D6912020-01-21021 January 2020
1-21-20, Intervenors Motion for Additional Time to File Reply (DC Cir.)(Case No. 19-1198)
ML20016A3662020-01-10010 January 2020
Massachusetts' Opposition to Respondents' and Intervenor-Respondents' Motions to Dismiss
ML19309E7632019-11-0101 November 2019
Intervenors' Opposed Motion for Extension of Time (DC Cir.)(Case No. 19-1198) 11-01-19
ML19303B3162019-10-28028 October 2019
Docketing Statement (DC Cir.)(Case No. 19-1198) 10-28-19
ML19303B3142019-10-28028 October 2019
Underlying Decisions from Which Appeal or Petition Arises (DC Cir.)(Case No. 19-1198) 10-28-19
ML19274B3432019-09-25025 September 2019
Petition for Review (DC Cir.) (Case No. 19-1198)- 9-27-19
ML13168A4732013-06-14014 June 2013
G20130461/LTR-13-0523 - Mary Lampert, Director, Pilgrim Watch, Et Al., Email 2.206 - Immediately Suspend the Operating License of Pilgrim Station Until the Provisions of EA-12-050 and EA-13-109 Are Fully Implemented
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Ltr Margaret Sheehan Re Request to Reinitiate ESA Section 7 Consultation with Regard to Roseate Tern - Pilgrim Nuclear Power Station
ML12179A3152012-06-26026 June 2012
6/26/12 - Entergy Motion to Intervene in 12-1772
ML12172A3552012-06-18018 June 2012
Mass V NRC - 1st Cir 12-1772 - Mass Petition for Review and Court Notices
ML1211004862012-04-0909 April 2012
Case Opening Notice - Commonwealth of Massachusetts V. USNRC
ML11223A0642011-08-10010 August 2011
Letter to Senator Daniel a Wolf Regarding Concerns About the Safety of Extended Operating of Pilgrim Nuclear Power Station
ML11133A3792011-05-0505 May 2011
E-Mail with Attachment from Susan Uttal, Esq. to Pilgrim Board Re Receipt of Letter from Coulter
ML1101403242011-01-14014 January 2011
Certificate of Service
ML1100503312010-12-29029 December 2010
Entergy'S Twenty-Second Supplemental Disclosure
ML1033403302010-11-22022 November 2010
Entergy'S Notice of Filing Affidavit
ML1032603012010-11-18018 November 2010
Affidavit of Dr. Nathan E. Bixler Re Board'S Questions from Board Majority on the Mechanics of Computing Mean Consequences in SAMA Analyses.
ML1033403272010-11-17017 November 2010
Pilgrim Watch Memo to Gaukler'S Request for Citations and Copies of Specified Documents in Disclosures 6 and 7
ML1032103112010-11-11011 November 2010
Entergy'S Twentieth Supplemental Disclosure
ML1030903772010-11-0505 November 2010
Email Pilgrim Watch Oct. 27 Letter Re Pw 6th and 7th Supplemental Disclosures and Transmitting Lyman Cv
ML1030800762010-10-27027 October 2010
Response to Paul Gaukler'S Letter of October 20 Regarding Three Issues Raised, (Witness List, Sixth & Seventh Disclosures and Sworn Affidavit on 7th Disclosure)
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Supplement to Seventh Disclosure Statements by Pilgrim Watch
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Request for Pilgrim Watch Witness List and the Relied Upon Bases of Experts in Accordance with 10 CFR Section 2.336(a)(1)
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Pilgrim Watch Seventh Disclosure Statement
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Entergy'S Nineteenth Supplemental Disclosure
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Entergy'S Eighteenth Supplemental Disclosure
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Entergy'S Seventeenth Supplemental Disclosure
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Email from Mary Lampert Regarding Commission Notification Relating to Pilgrim Nuclear Power Station
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Commission Notification Letter on Pilgrim
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Email from Mary Lampert Regarding Commission Notification Relating to Pilgrim Nuclear Power Station
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Notification of Information in the Matter of Pilgrim Nuclear Power Station
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Entergy'S Sixteenth Supplemental Disclosure
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Entergy'S Fifteenth Supplemental Disclosure
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Pilgrim Watch Supplement to Sixth Disclosure Statement
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Request for Identity and Related Information for the Witnesses Mary Lampert Identified to the Board in May 4 Telephone Conference
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Pilgrim Watch Sixth Disclosure Statement
ML1016100822010-06-0303 June 2010
Entergy'S Fourteenth Supplemental Disclosure
ML1015404222010-05-25025 May 2010
Index of Documents Previously Produced as Part of Entergy'S Initial and Twelve Supplemental Productions That Are Relevant to Pilgrim Watch Contention 3
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Pw Request for Permission & Reply to Entergy Opposition to Pw Motion to Disqualify Judge Abramson 05.24.10 and Certificate Service
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Pilgrim Watch Request for Information Relating to Previous Disclosures and Request for Additional Information
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Entergy'S Twelfth Supplemental Disclosure
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Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc. (Pilgrim Nuclear Power Station) Intends to Submit Answers Opposing Pilgrim Watch'S Motion and Town of Plymouth'S Motion to Reschedule April 8 Conference Call
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Pilgrim Watch Notice to Commission Regarding New and Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848
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Commission Response to Pilgrim Watch'S Request for Information Regarding the Appointment of an Adjudicatory Employee
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Commissioner Svinicki'S Visit to Pilgrim NPS
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Commissioner Svinicki'S Visit to Pilgrim NPS
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Response of Legal Counsel to Commissioner Svinicki to the Invitation to Meet with Pilgrim Watch (with Attached Emails from Mary Lampert)
2020-06-30
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Text
Judge Trikouros statement regarding t h e P~lgr~m LR Hearing Page 1
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RAS 12048 DOCKETED USNRC Docket ID 50-293-LR July 27, 2006 (1:53pm))
OFFICE OF SECRETARY DISCLOSURE STATEMENT OF JUDGE NICHOLAS TRIKOUROS RULEMAKINGS AND I am placing this statement in the record of the Pilgrim boiling water reactor License Renewal proceeding in order to provide full disclosure of certain information which may be perceived to be a conflict of interest in this proceeding.
Early in 2004. Panlyon Technologies, of which I was a Principal, was commissioned by Entergy Northeast to provide best estimate separate effects evaluations of the time avuilablc for rccovcry actions given a loss of coolant from potential n~aliciousacts in an Entergy-owned pressurized bvater reactor spent fuel pool. Scenarios considered included various degrees of partial uncovery of spent fuel as well as complete drainage of the pool. While I was not the principal investigator.
I did provide a management overview of the project and was consulted regarding modeling assumptions and thc viability of thc rcsults as they progressed. The work was completed in 2005.
Entergy provided preliminary results from this work in a presentation to the National Academy of Sciences (NAS) in Wash D.C. on May 10, 2004, in which I participated as one of several presenters. I have had no other communications with the National Academy prior to or since that day. As it turned out, statemenls regal-ding these presentations were included in support of the findings in Section 3 of the subsequent NAS report entitled "Safety and Security of Commercial Spent Nuclear Fuel Storage: Public Report." which has been referenced in the contentions of the Massachusetts Attorney General and Pilgrim Watch in this case.
I have evaluated the impact of my involvenlent in the technical effort described above and I have concluded that a reasonable person, h o m i n g all of the relevant facts and circumstances about my work for Entergy. would have no reasonable basis to question my impartiality in this case. The work was not associated with the Pilgrim Nuclear Plant nor with any other boiling water reactor.
The study was performed in an independent manner using a commonly accepted methodology.
We had complete freedom to choose the methodology, the modeling inputs and the analysis assun~ptions.At Entergy's request, the final documentation of this work was provided to the NRC Staff.
This was just one of many techn~caltasks regarding spent fuel pool cooling that 1 havc bcen associated with throughout my career. The background understanding I bring to my current adjudicatory role was generated in part by carrying out consulting work for more than a dozen clients in the nuclear industry. including Entergy. This work put me in a better position to fulfill one of the responsibilities as a Licensing Board Judge, i.e.. to review and to question the material presented from a knowledgeable technical perspective.
The above circumstances will not affect my impartiality or independence of judgment in this case. but I have concluded that disclosure was necessary to avoid the possibility of any misundc~standingor mispcrccption.
HearinaDocket - Disclosure of Judae Nicholas Trikouros Paae 1 From: Ann Young To: AMY@nrc.gov; David.Lewis@Pillsburylaw.com; dcurran @ harmoncurran.com; hearingdocket @ nrc.gov; JJL5@nrc.gov; KSV@nrc.gov; lampert @adelphia.net; Matthew.brock@ago.state.ma.us; mollyhbartlett@hotmail.com; msylvia@townhall.plymouth.ma.us; NGT@nrc.gov; OCAAMail@nrc.gov; Paul.Gaukler@pillsburylaw.com; RFC1 @nrc.gov; SECY @nrc.gov; SLU @ nrc.gov; SSHollis @duanemorris.com Date: Thu, Jul 27, 2006 1.53 PM
Subject:
Disclosure of Judge Nicholas Trikouros Judge Trikouros has asked me to send the attached statement to all participants in the Pilgrim proceeding.
Judge Young
Mail Envelope Properties (44C8FD96.ABA : 0 : 35784)
Subject:
Disclosure of Judge Nicholas Ti-ihouros Creation Date Thu, Jul 27, 2006 1:53 PM From: Ann Young Created By: AMY @nrc.gov Recipients adelphia.net lampert (larnpert@adelphia.net) ag0.state.ma.m Matthew.brock (Matthew .brock@ag0.state.ma.u~)
harmoncuiran.com dcurran (dcurran @ harmoncuiran.com) hotmail.com mollyhbartlett (rnollyhbartlett@hotmail.com) nrc.gov OWGWP002.HQGWDOO 1 HearingDocket (HearingDocket) nrc.gov OWGWP003.HQGWDOOl RFC 1 (Richard Cole) nrc.gov TWGWPOO1.HQGWDOO 1 JJLS (Jered Lindsay) nrc.gov TWGWP002.HQGWD001 NGT (Nicholas Trikouros)
SECY (SECY) nrc.gov TWGWP004.HQGWDOOl AMY (Ann Young)
KSV (Karcn Valloch)
OCAAMAlL (OCAAMai18nrc.gov)
SLU (Susan Uttal) townhall .plymouth.ma.us msylvia (msylvia@townhall.plymouth.ma.us)
Post Office Route adelphia.net ago.state.ma.us duanemorris.com h;~rmon~urrm.com hotmail .com nrc.gov nrc.gov nrc.gov m-c.gov nrc.gov Pillsburylaw.com Files Size Date & Time MESSAGE 428 Thursday, July 27, 2006 1:53 PM Judge Trikouros disclosure statement regarding the Pilgrim LR Hearing Request.wpd 12668 Wednesday, July 26, 2006 8:52 AM Options Expiration Date: None Priority: Standard Rep1yRequested: No Return Notification: None Concealed
Subject:
No Security: Standard