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Category:Legal-Intervention Petition
MONTHYEARML11346A3012011-06-27027 June 2011 Declaration of Joseph R. Lynch, Lori Ann Potts, and Dr. Kevin R. O'Kula in Support of Entergy'S Answer Opposing Pilgrim Watch Request for Hearing on a New Contention Regarding Inadequacy of Environmental Report, Post-Fukushima ML1102503532011-01-0101 January 2011 Pilgrim Watch Reply to Entergy'S Request to Change the Hearing Date ML1100401252010-12-27027 December 2010 Entergy Answer Opposing Pilgrim Watch Request for Hearing on a New Contention ML1033403262010-11-22022 November 2010 Pilgrim Watch Reply to Order (October 26, 2010) - Questions from Board Majority Regarding the Mechanics of Computing Mean Consequences ML1030810622010-11-0303 November 2010 Response to Pilgrim Watch October 27 Letter Regarding Pilgrim Watch 6th and 7th Supplemental Disclosures ML1028711332010-10-0808 October 2010 Pilgrim Watch Reply to Entergy'S & NRC Staff'S Briefs Regarding Timeliness of Pilgrim Watch'S Raising Averaging Practice Concerns ML1027203992010-09-21021 September 2010 Entergy'S Response to Pilgrim Watch'S Memo Re Proposed Schedule ML1027307882010-09-21021 September 2010 Pilgrim Watch'S Reply to Entergy'S Response to Pilgrim Watch'S Memo Regarding Proposed Schedule ML1027307892010-09-21021 September 2010 Memo Regarding Proposed Schedule ML1021104482010-07-25025 July 2010 Pilgrim Watch Notice to Commission Regarding New and Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848 ML1020900242010-07-19019 July 2010 Pilgrim Watch 2.206 Petition Regarding Inadequacy of Entergy'S Management of Non-Environmentally Qualified Inaccessible Cables & Wiring at Pilgrim Station ML1018000932010-06-28028 June 2010 NRC Staff'S Opposition to Pilgrim Watch'S Motion Requesting Leave to File Response to Judge Paul B. Abramson Decision on Recusal Motion (June 10, 2010) ML1018004862010-06-23023 June 2010 Entergy'S Opposition to Pilgrim Watch'S Motion Requesting Leave to File Response to Judge Abramson'S Decision on Recusal Motion ML1017301832010-06-16016 June 2010 Pilgrim Watch Response to Judge Paul B. Abramson Decision on Recusal Motion ML1014605742010-05-21021 May 2010 Entergy'S Opposition to Pilgrim Watch Motion to Disqualify Judge Abramson ML1014402032010-05-17017 May 2010 Entergy'S Reply to Pilgrim Watch'S Response to Aslb'S May 5, 2010 Order ML1015404212010-05-17017 May 2010 Pilgrim Watch'S Reply to Entergy'S Submission on Scope and Schedule for Remanded Hearing ML1014503232010-05-17017 May 2010 Pilgrim Watch'S Reply to NRC Staff'S Initial Brief to the Board'S Order (Regarding Deadlines for Submission of Parties) ML1014107452010-05-12012 May 2010 Pilgrim Watch Response to Aslb'S May 5, 2010 Order ML1014107432010-05-12012 May 2010 Entergy'S Submission on Scope and Schedule for Remanded Hearing ML1010504322010-04-15015 April 2010 NRC Staff'S Response in Opposition to Pilgrim Watch'S Motion for Reconsideration of CLI-10-11 ML1010408202010-04-0808 April 2010 Entergy'S Opposition to Pilgrim Watch'S Motion for Reconsideration of CLI-10-11 ML1010408192010-04-0707 April 2010 Entergy'S Opposition to Pilgrim Watch'S Motion to Reschedule Telephone Conference ML1010408212010-04-0707 April 2010 Entergy'S Opposition to Town of Plymouth'S Motion to Reschedule Telephone Conference ML1004808082010-02-0202 February 2010 Pilgrim Watch'S Reply to NRC Staff'S Response to Pilgrim Watch Notice to Commission Regarding New & Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848 ML0823700122008-08-19019 August 2008 Pilgrim - Notice of Withdrawal of Appearance for James E. Adler 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 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.. ML0808600962008-03-17017 March 2008 Pilgrim Watch Reply to NRC Staff'S Motion in Limine to Strike Exhibits and Testimony Filed by Pilgrim Watch, March 10, 2008 ML0808600952008-03-17017 March 2008 Pilgrim Watch Reply to Entergy'S Motion in Limine to Strike Exhibits and Testimony Filed by Pilgrim Watch, March 10, 2008 ML0807402022008-03-0707 March 2008 Entergy'S Eleventh Supplemental Disclosure ML0802904142008-01-18018 January 2008 2008/01/18-Answer of Entergy Nuclear Operation, Inc. Opposing Petition to Suspend License Renewal Reviews and Proceedings ML0802803052008-01-18018 January 2008 2008/01/18-NRC Staff Answer to Petition for Suspension of License Renewal Reviews Pending Investigation of NRC Staff License Renewal Process ML0735403732007-12-14014 December 2007 Entergy'S Eighth Supplemental Disclosure ML0726901592007-09-20020 September 2007 Entergy Nuclear Operations Inc. Answer Opposing Intervention Petition of Local 369, Utility Workers Union of America, AFL-CIO ML0726205402007-09-18018 September 2007 Motion to Intervene of Local 369, Utility Workers Union of America, AFL-CIO ML0721901912007-07-30030 July 2007 Pilgrim Watch'S Answer Opposing NRC Staff'S Motion Requesting That Pilgrim Watch'S Answer Opposing NRC Staff Support of Entergy'S Motion to Strike Pilgrim Watch'S Answer to Entergy'S Summary Disposition Motion Not Be Considered by the Board ML0721302252007-07-26026 July 2007 Pilgrim - Pilgrim Watch'S Answer Opposing NRC Staff'S Support of Entergy'S Motion to Strike Portions of Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Contention 3 ML0720501452007-07-17017 July 2007 Pilgrim - Pilgrim Watch'S Answer Opposing Entergy'S Motion to Strike Portions of Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3 ML0718405682007-06-29029 June 2007 Pilgrim - Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3 ML0718000592007-06-28028 June 2007 Pilgrim - NRC Staff Response to Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 1 ML0716303952007-06-0505 June 2007 Pilgrim - Entergy'S Sixth Supplemental Disclosure ML0715002992007-05-24024 May 2007 Pilgrim - Entergy'S Opposition to Pilgrim Watch Request to Extend Time to Respond to Summary Disposition of Pilgrim Watch Contention 3 ML0715201682007-05-22022 May 2007 Pilgrim - Notice of Appearance of Mary Elizabeth Lampert ML0711702672007-04-18018 April 2007 Pilgrim - Second Disclosure Statement by Pilgrim Watch ML0711702602007-04-16016 April 2007 Pilgrim - Entergy'S Fourth Supplemental Disclosure ML0708002172007-03-15015 March 2007 Pilgrim - Entergy'S Third Supplemental Disclosure ML0707301912007-03-0606 March 2007 Pilgrim - Letter to Judge Cole from S. Uttal, OGC Providing (Cd) Version of Safety Evaluation Report with Open Items ML0634803752006-12-0808 December 2006 Pilgrim- Entergy'S Comments on Proposed Schedule 2011-06-27
[Table view] Category:Responses and Contentions
MONTHYEARML11346A3012011-06-27027 June 2011 Declaration of Joseph R. Lynch, Lori Ann Potts, and Dr. Kevin R. O'Kula in Support of Entergy'S Answer Opposing Pilgrim Watch Request for Hearing on a New Contention Regarding Inadequacy of Environmental Report, Post-Fukushima ML1102503532011-01-0101 January 2011 Pilgrim Watch Reply to Entergy'S Request to Change the Hearing Date ML1100401252010-12-27027 December 2010 Entergy Answer Opposing Pilgrim Watch Request for Hearing on a New Contention ML1033403262010-11-22022 November 2010 Pilgrim Watch Reply to Order (October 26, 2010) - Questions from Board Majority Regarding the Mechanics of Computing Mean Consequences ML1030810622010-11-0303 November 2010 Response to Pilgrim Watch October 27 Letter Regarding Pilgrim Watch 6th and 7th Supplemental Disclosures ML1028711332010-10-0808 October 2010 Pilgrim Watch Reply to Entergy'S & NRC Staff'S Briefs Regarding Timeliness of Pilgrim Watch'S Raising Averaging Practice Concerns ML1027203992010-09-21021 September 2010 Entergy'S Response to Pilgrim Watch'S Memo Re Proposed Schedule ML1027307882010-09-21021 September 2010 Pilgrim Watch'S Reply to Entergy'S Response to Pilgrim Watch'S Memo Regarding Proposed Schedule ML1027307892010-09-21021 September 2010 Memo Regarding Proposed Schedule ML1021104482010-07-25025 July 2010 Pilgrim Watch Notice to Commission Regarding New and Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848 ML1020900242010-07-19019 July 2010 Pilgrim Watch 2.206 Petition Regarding Inadequacy of Entergy'S Management of Non-Environmentally Qualified Inaccessible Cables & Wiring at Pilgrim Station ML1018000932010-06-28028 June 2010 NRC Staff'S Opposition to Pilgrim Watch'S Motion Requesting Leave to File Response to Judge Paul B. Abramson Decision on Recusal Motion (June 10, 2010) ML1018004862010-06-23023 June 2010 Entergy'S Opposition to Pilgrim Watch'S Motion Requesting Leave to File Response to Judge Abramson'S Decision on Recusal Motion ML1017301832010-06-16016 June 2010 Pilgrim Watch Response to Judge Paul B. Abramson Decision on Recusal Motion ML1014605742010-05-21021 May 2010 Entergy'S Opposition to Pilgrim Watch Motion to Disqualify Judge Abramson ML1014402032010-05-17017 May 2010 Entergy'S Reply to Pilgrim Watch'S Response to Aslb'S May 5, 2010 Order ML1015404212010-05-17017 May 2010 Pilgrim Watch'S Reply to Entergy'S Submission on Scope and Schedule for Remanded Hearing ML1014503232010-05-17017 May 2010 Pilgrim Watch'S Reply to NRC Staff'S Initial Brief to the Board'S Order (Regarding Deadlines for Submission of Parties) ML1014107452010-05-12012 May 2010 Pilgrim Watch Response to Aslb'S May 5, 2010 Order ML1014107432010-05-12012 May 2010 Entergy'S Submission on Scope and Schedule for Remanded Hearing ML1010504322010-04-15015 April 2010 NRC Staff'S Response in Opposition to Pilgrim Watch'S Motion for Reconsideration of CLI-10-11 ML1010408202010-04-0808 April 2010 Entergy'S Opposition to Pilgrim Watch'S Motion for Reconsideration of CLI-10-11 ML1010408192010-04-0707 April 2010 Entergy'S Opposition to Pilgrim Watch'S Motion to Reschedule Telephone Conference ML1010408212010-04-0707 April 2010 Entergy'S Opposition to Town of Plymouth'S Motion to Reschedule Telephone Conference ML1004808082010-02-0202 February 2010 Pilgrim Watch'S Reply to NRC Staff'S Response to Pilgrim Watch Notice to Commission Regarding New & Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848 ML0823700122008-08-19019 August 2008 Pilgrim - Notice of Withdrawal of Appearance for James E. Adler 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 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.. ML0808600962008-03-17017 March 2008 Pilgrim Watch Reply to NRC Staff'S Motion in Limine to Strike Exhibits and Testimony Filed by Pilgrim Watch, March 10, 2008 ML0808600952008-03-17017 March 2008 Pilgrim Watch Reply to Entergy'S Motion in Limine to Strike Exhibits and Testimony Filed by Pilgrim Watch, March 10, 2008 ML0807402022008-03-0707 March 2008 Entergy'S Eleventh Supplemental Disclosure ML0802904142008-01-18018 January 2008 2008/01/18-Answer of Entergy Nuclear Operation, Inc. Opposing Petition to Suspend License Renewal Reviews and Proceedings ML0802803052008-01-18018 January 2008 2008/01/18-NRC Staff Answer to Petition for Suspension of License Renewal Reviews Pending Investigation of NRC Staff License Renewal Process ML0735403732007-12-14014 December 2007 Entergy'S Eighth Supplemental Disclosure ML0726901592007-09-20020 September 2007 Entergy Nuclear Operations Inc. Answer Opposing Intervention Petition of Local 369, Utility Workers Union of America, AFL-CIO ML0726205402007-09-18018 September 2007 Motion to Intervene of Local 369, Utility Workers Union of America, AFL-CIO ML0721901912007-07-30030 July 2007 Pilgrim Watch'S Answer Opposing NRC Staff'S Motion Requesting That Pilgrim Watch'S Answer Opposing NRC Staff Support of Entergy'S Motion to Strike Pilgrim Watch'S Answer to Entergy'S Summary Disposition Motion Not Be Considered by the Board ML0721302252007-07-26026 July 2007 Pilgrim - Pilgrim Watch'S Answer Opposing NRC Staff'S Support of Entergy'S Motion to Strike Portions of Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Contention 3 ML0720501452007-07-17017 July 2007 Pilgrim - Pilgrim Watch'S Answer Opposing Entergy'S Motion to Strike Portions of Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3 ML0718405682007-06-29029 June 2007 Pilgrim - Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3 ML0718000592007-06-28028 June 2007 Pilgrim - NRC Staff Response to Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 1 ML0716303952007-06-0505 June 2007 Pilgrim - Entergy'S Sixth Supplemental Disclosure ML0715002992007-05-24024 May 2007 Pilgrim - Entergy'S Opposition to Pilgrim Watch Request to Extend Time to Respond to Summary Disposition of Pilgrim Watch Contention 3 ML0715201682007-05-22022 May 2007 Pilgrim - Notice of Appearance of Mary Elizabeth Lampert ML0711702672007-04-18018 April 2007 Pilgrim - Second Disclosure Statement by Pilgrim Watch ML0711702602007-04-16016 April 2007 Pilgrim - Entergy'S Fourth Supplemental Disclosure ML0708002172007-03-15015 March 2007 Pilgrim - Entergy'S Third Supplemental Disclosure ML0707301912007-03-0606 March 2007 Pilgrim - Letter to Judge Cole from S. Uttal, OGC Providing (Cd) Version of Safety Evaluation Report with Open Items ML0634803752006-12-0808 December 2006 Pilgrim- Entergy'S Comments on Proposed Schedule 2011-06-27
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March 7, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED USNRC Before the Atomic Safety and Licensing Board March 10, 2008 (9:00am)
OFFICE OF SECRETARY In the Matter of )) RULEMAKINGS AND ADJUDICATIONS STAFF Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR
)
(Pilgrim Nuclear Power Station) )
ENTERGY'S ELEVENTH SUPPLEMENTAL DISCLOSURE Pursuant to 10 C.F.R. § 2.336(d), Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc. ("Entergy") hereby supplements its disclosures as follows. Entergy is providing by separate cover letter to counsel for Pilgrim Watch and the NRC Staff a compact disk that contains documents that Entergy's witnesses will or may rely upon in their testimony.
Please note that these documents could duplicate some of the information provided in Entergy's previous disclosures.
Respectfully Submitted, David R. Lewis Paul A. Gaukler PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W.
Washington, DC 20037-1128 Tel. (202) 663-8474 Counsel for Entergy Dated: March 7, 2008 Sec-yc rc-mPL -T t C---SO /'-, Ij-O37
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR
)
(Pilgrim Nuclear Power Station) )
Certification of Supplemental Disclosure Affidavit of Fred Mowolesko County of Plymouth )
)
State of Massachusetts )
I, Fred Mogolesko, being duly sworn, state:
I am the License Renewal Project Manager for the Pilgrim Nuclear Power Station. My business address is Pilgrim Nuclear Station, 600 Rocky Hill Road, Plymouth, MA 02360. I am authorized to provide this certification, pursuant to 10 C.F.R. § 2.336(c), on behalf of Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc. (Entergy").
To the best of my knowledge, information and belief, Entergy's tenth supplemental disclosure in the above captioned proceeding discloses all materials required to be disclosed by 10 C.F.R. § 2.336(a) that were developed, obtained or identified subsequent to the previous disclosures as being relevant to the admitted contentions.
Further, to the best of my knowledge, information and belief, and based on representations of personnel who were instructed to perform a diligent search, these disclosures are accurate and complete as of this date.
Further the affiant sayeth not.
Fred Mogolesko Subscribed and sworn to before me this day of __Ik/L("L 2 00 8 Notary Public My commission expires:
JUDITH M.PLUMMER I Notary Public q ~~Cormnoweam of Maahst
March 7, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station)
))
CERTIFICATE OF SERVICE I hereby certify that copies of"Entergy's Eleventh Supplemental Disclosure" dated March 7, 2008, and Certification of Supplemental Disclosure Affidavit of Fred Mogolesko 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 7th day of March, 2008.
- Administrative Judge *Administrative Judge Ann Marshall Young, Esq., Chair Dr. Richard F. Cole Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 amy@inrc.gov rfcl @nrc.gov
- Administrative Judge *Secretary Paul B. Abramson Att'n: Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Mail Stop 0-16 C1 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 secy@nrc.gov, hearingdocket(Enrc. gov pba@nrc.gov
Office of Commission Appellate Atomic Safety and Licensing Board Adjudication Mail Stop T-3 F23 Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001
- Susan L. Uttal, Esq. *Mr. Mark D. Sylvia
- Kimberly Sexton, Esq. Town Manager
- James E. Adler, Esq. Town of Plymouth Office of the General Counsel 11 Lincoln St.
Mail Stop 0- 15 D21 Plymouth MA, 02360 U.S. Nuclear Regulatory Commission msylvia@townhall.plymouth.ma.us Washington, D.C. 20555-0001 slu@nrc.gov; kas2@nrc. gov; jeal@nrc.gov
- Ms. Mary Lampert *Chief Kevin M. Nord 148 Washington Street Fire Chief and Director, Duxbury Emergency Duxbury, MA 02332 Management Agency mary.lampert@comcast.net 688 Tremont Street P.O. Box 2824 Duxbury, MA 02331 nordeitown.duxburv.ma.us
- Sheila Slocum Hollis, Esq. *Richard R. MacDonald Duane Morris LLP Town Manager 1667 K Street, N.W. 878 Tremont Street Suite 700 Duxbury, MA 02332 Washington, D.C. 20006 macdonald(ý,town.duxbury.ma.us sshollis@duanemorris.com Paul A. Gaukler 2