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Category:Legal-Motion
MONTHYEARML20079J1802020-03-19019 March 2020
Unopposed Motion of the Commonwealth of Massachusetts to Correct a Previously Filed Declaration
ML20035C7562020-01-30030 January 2020
1-30-20 Entergy Motion to Intervene (DC Cir.)(Case No. 20-1019)
ML20031D4332020-01-29029 January 2020
1-29-20 Reply to Response to Motion to Dismiss (DC Cir.)(Case No. 19-1198)
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Motion of the Commonwealth of Massachusetts to Amend Its Petition with New Information
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ML19295E6852019-10-16016 October 2019
Entergy Motion to Intervene (DC Cir.)(Case No. 19-1198) 10-16-19
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Motion of the Commonwealth of Massachusetts for a Twenty-Two Minute Enlargement of Time to File Its Stay Application and Supporting Appendix
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Application of the Commonwealth of Massachusetts for a Stay of the Effectiveness of the NRC Staff Actions Approving the License Transfer Application and Request for an Exemption to Use the Decommissioning Trust Fund for Non-Decommissioning
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Watch Motion to Stay Staff Order of August 22, 2019 Granting Exemption
ML19246A0332019-09-0303 September 2019
Watch Motion Under 10 C.F.R 2.1327 to Stay Staff Order of August 22, 2019
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Reply of the Commonwealth of Massachusetts in Support of Its Motion for an Enlargement of Time to File an Application to Stay a Nuclear Regulatory Commission Staff Order Approving the License Transfer Application
ML19227A0682019-08-15015 August 2019
Emergency Motion of the Commonwealth of Massachusetts for Clarification of the Commission'S August 14, 2019 Memorandum and Order
ML19227A3982019-08-15015 August 2019
Emergency Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application to Stay a Nuclear Regulatory Commission Staff Order Approving the License Transfer Application
ML19213A3132019-08-0101 August 2019
Motion of the Commonwealth of Massachusetts to Stay Proceeding to Complete Settlement Negotiations
ML19129A3732019-05-0909 May 2019
Commonwealth of Massachusetts' Reply in Support of Motion to Supplement Its Petition with New Information
ML19129A4732019-05-0909 May 2019
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ML19114A5192019-04-24024 April 2019
Motion of the Commonwealth of Massachusetts to Supplement Its Petition with New Information
ML19091A1892019-04-0101 April 2019
Watch Reply to Applicant'S Answer Opposing Pilgrim Watch Petition for Leave to Intervene and Hearing Request
ML19077A2092019-03-18018 March 2019
Notices of Appearance of David R. Lewis, Anne R. Leidich, and Susan H. Raimo
ML19077A2762019-03-18018 March 2019
Unopposed Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File Its Reply
ML12257A3392012-09-13013 September 2012
Filed Copy - Joint Motion to Amend Briefing Schedule - Massachusetts V NRC - 1st Cir 12-1404 and 12-1772
ML12195A0802012-07-13013 July 2012
Notice of Appearance for Joseph A. Lindell for ESA Roseate Term
ML12157A1872012-06-0505 June 2012
Notice of Appearance from Joseph A. Lindell on Entergy Nuclear Operations, Inc., (Pilgrim)
ML12137A2582012-05-16016 May 2012
Notice of Appearance for Joseph A. Lindell
ML12136A5172012-05-15015 May 2012
NRC Staff'S Unopposed Motion for an Extension of Time to Respond to Jones River Watershed Association and Pilgrim Watch'S May 14, 2012, Request to Reopen, for a Hearing and to File New Contentions
ML12132A4682012-05-11011 May 2012
Motion to Strike
ML12097A2222012-04-0505 April 2012
Entergy Motion to Strike Petitioners' Affidavit and Portions of Petitioners' Reply
ML11357A2092011-12-23023 December 2011
Commonwealth of Massachusetts' Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Appeal of LBP-11-35
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Commonwealth of Massachusetts Motion to Reply to NRC Staff Answer to Massachusetts Request to Stay Commission Decision on Pilgrim Watch Appeal or in the Alternative to Strike Reference to Massachusetts Expert
ML11258A0262011-09-15015 September 2011
Commonwealth of Massachusetts Amended Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Motion to Supplement Bases to Its Contention
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Commonwealth of Massachusetts Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Motion to Supplement Bases to Its Contention
ML11235B0962011-08-23023 August 2011
Applicant'S Motion for Issuance of Renewed License
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Commonwealth of Massachusetts Motion to Supplement Bases to Commonwealth Contention to Address NRC Task Force Report on Lessons Learned from the Radiological Accident at Fukushima
ML1115303402011-06-0202 June 2011
Commonwealth of Massachusetts' Motion to Admit Contention and, If Necessary, to Re-Open Record Regarding New and Significant Information Revealed by Fukushima Accident
ML1115303442011-06-0202 June 2011
Commonwealth of Massachusetts' Conditional Motion to Suspend Pilgrim Nuclear Power Plant License Renewal Proceeding Pending Resolution of Petition for Rulemaking to Rescind Spent Fuel Pool Exclusion Regulations
ML1113905722011-05-19019 May 2011
Commonwealth of Massachusetts Motion to Reply to Entergy'S Answer Opposing Commonwealth'S Joinder in Petition to Suspend the License Renewal Proceeding for the Pilgrim Nuclear Power Plant and Request for Additional Relief
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Commonwealth of Massachusetts Motion to Hold Licensing Decision in Abeyance Pending Commission Decision Whether to Suspend the Pilgrim Proceeding to Review the Lessons of the Fukushima Accident
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Entergy'S Motion in Limine to Exclude from Evidence Pilgrim Watch'S Sama Remand Pre-Filed Testimony and Exhibits
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Entergy Request for Change in Hearing Date
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Pilgrim Watch Request Extension Submit Affidavits
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Pilgrim Watch Motion for Clarification ASLB Order (Sept. 02, 2010)
ML1017301822010-06-16016 June 2010
Motion Requesting Leave to File Response to Judge Paul B. Abramson Decision on Recusal Motion (June 10, 2010)
ML1015404252010-05-26026 May 2010
Pilgrim Watch Request for Permission, and Reply to NRC Staff'S Response to Pilgrim Watch Motion to Disqualify Judge Abramson
ML1014500892010-05-24024 May 2010
NRC Response to Pilgrim Watch Motion to Disqualify Judge Paul B. Abramson
ML1015404242010-05-24024 May 2010
Pilgrim Watch Request for Permission, and Reply to Entergy'S Opposition to Pilgrim Watch Motion to Disqualify Judge Abramson
2020-03-19
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Text
May 30,2007 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD May 31,2007 (4:08pm)
In the Matter of ) OFFICE OF SECRETARY
) RULEMAKINGS AND
) ADJUDICATIONS STAFF Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc. ) Docket No. 50-293-LR
)
) ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station) )
NRC STAFF MOTION FOR EXTENSION OF TIME TO REPLY TO ENTERGY'S MOTION FOR
SUMMARY
DISPOSITION INTRODUCTION On May 22,2007, Pilgrim Watch, by its representative, Mary Lampert, filed a request for extension of time to reply1 to the May 17, 2007, motion for summary disposition filed by Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc.2 (collectively: Entergy). On May 25,2007, Entergy filed its response in opposition to Pilgrim Watch's request.3 On May 28, 2007, Pilgrim Watch filed a reply to Entergy's opposition to its Request.4 On May 30,2007, the Atomic Safety and Licensing Board (Board) issued an order granting the Request.5 1 See Request by Pilgrim Watch for Extension of Time to Reply to Entergy's Motion for Summary Judgment, (May 22,2007) (Request). At the same time, Pilgrim Watch filed a "Notice of Withdrawal of Molly H. Bartlett" as counsel for Pilgrim Watch, and a "Notice of Appearance of Mary Elizabeth Lampert" as representative of Pilgrim Watch.
2 See Entergy's Motion for Summary Disposition of Pilgrim Watch Contention 3, (May 17, 2007).
3 See Entergy's Opposition to Pilgrim Watch Request to Extend Time to Respond to Summary Disposition of Pilgrim Watch Contention 3, (May 24,2007).
4 See Pilgrim Watch's Reply to Entergy'sOpposition to Pilgrim Watch Request to Extend Time to Respond to Summary Disposition of Pilgrim Watch Contention 3, (May 28,2007) (May 28th Reply).
5 See Order (Granting Request for Extension), (May 30,2007).
Pursuant to 10 C.F.R. § 2.323(a), the U.S. Nuclear Regulatory Commission Staff (Staff) hereby moves the Board for an extension of time to file its response to Entergy's motion for summary disposition.
DISCUSSION The Board granted Pilgrim Watch's motion to extend time to file a response to Entergy's motion for summary disposition to June 29, 2007. The Staff respectfully requests that it be afforded an equivalent extension of time to file its response to Entergy's motion. Both the Commission's Regulations and the Board's scheduling order contemplate the simultaneous filing of responses to motions. The Board's December 20, 2006 scheduling order provides for simultaneous filings of responses to summary disposition motions,6 as does 10 C.F.R.
§ 2.1205(b) ("Any other party may serve an answer supporting or opposing the motion within twenty (20) days after service of the motion.").7 The Staff submits that it is in keeping with the intention of the Commission's Regulations and the Board's Order that the responses be filed simultaneously. In addition, granting of the Staff's request and "allowing for a response in accordance with the original response deadline does not create any delay in the already-established schedule for this proceeding."
I certify that I made a sincere effort to contact the other parties and resolve the issue raised in this motion. Mr. Lewis, counsel for Entergy, and Ms. Hollis, counsel for Plymouth Township, advised that they have no objection to the Staff's motion. I was unable to reach Ms.
Lampert or Chief Nord before filing this motion.
6 See Order (Establishing Schedule for Proceeding and Addressing Related Matters) at 6, (December 20, 2006).
7 If Pilgrim Watch had conferred with the Staff prior to filing the Request, the above position would have been relayed.
CONCLUSION Based on the foregoing, the Staff respectfully requests that its motion for an extension of time to June 29,2007 to respond to Entergy's motion for summary disposition be granted.
Respea1fully s~bmitte1J I
/L/ {i/tftJt f*
Susan L. Uttal I
I/' f Counsel for NRC Staff I
Dated at Rockville, Maryland this 30th day of May, 2007
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
ENTERGY NUCLEAR OPERATIONS, INC. ) Docket No. 50-293-LR
)
(Pilgrim Nuclear Power Station) ) ASLBP No. 06-848-02-LR
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF MOTION FOR EXTENSION OF TIME TO REPLY TO ENTERGY'S MOTION FOR
SUMMARY
DISPOSITION" in the above-captioned proceeding have been served on the following by electronic mail and deposit in the U.S. Mail Service or by deposit in the U.S. Nuclear Regulatory Commission's internal mail system as indicated by a single asterisk~*), or by deposit in the U.S. mail system, as indicated by a double asterisk (**) this 30t day of May 2007.
Administrative Judge* Administrative Judge*
Richard F. Cole Paul B. Abramson Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: rfc1 @nrc.qov E-mail: pba @nrc.qov Administrative Judge* Office of Commission Appellate
- Ann Marshall Young, Chair Adjudication Atomic Safety and Licensing Board Panel Mail Stop: 0-16C1 Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: OCAAMail @nrc.qov E-mail: amy@nrc.qov Office of the Secretary*
Sheila Slocum Hollis** Attn: Rulemaking and Adjudications Staff Duane Morris LLP Mail Stop: 0-16C1 1667 K Street, NW, Suite 700 U.S. Nuclear Regulatory Commission Washington, DC 20006 Washington, DC 20555-0001 E-mail: sshollis@duanemorris.com E-mail: hearinqdocket@nrc.qov
Atomic Safety and Licensing Board* Terence A. Burke, Esq.**
Mail Stop: T -3 F23 Entergy Nuclear U.S. Nuclear Regulatory Commission 1340 Echelon Parkway Washington, DC 20555-0001 Mail Stop: M-ECH-62 Jackson, MS 39213 Mary Lampert 148 Washington Street David R. Lewis, Esq.**
Duxbury, MA 02332 Paul A. Gaukler, Esq.
E-mail: lampert@adelphia.net Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, NW Chief Kevin M. Nord** Washington, DC 20037-1137 Fire Chief & Director Duxbury Emergency E-mail: david.lewis@pillsburvlaw.com Management Agency paul.qaukler@pillsburvlaw.com 668 Tremont Street Duxbury, MA 02332 Town Manager**
E-mail: nord@town.duxburv.ma.us Town of Plymouth Fax: 781-934-6530 11 Lincoln St.
Plymouth, MA 02360 E-mail: msylvia@townhall.plvmouth.ma.us Susan L. Uttal Counsel for the NRC Staff