Citizens Supplemental Citation in Support of Admission of Pending Contention Regarding Metal FatigueML082070077 |
Person / Time |
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Site: |
Oyster Creek |
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Issue date: |
07/18/2008 |
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From: |
Webster R Eastern Environmental Law Ctr, Grandmothers, Mothers & More for Energy Safety, Jersey Shore Nuclear Watch, New Jersey Environmental Federation, Nuclear Information & Resource Service (NIRS), Public Interest Research Group, Sierra Club, New Jersey Chapter |
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To: |
Abramson P, Barrata A, Hawkins E Atomic Safety and Licensing Board Panel |
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SECY RAS |
References |
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50-219-LR, ASLBP 06-844-01-LR, FOIA/PA-2008-0306, RAS-H-50 |
Download: ML082070077 (5) |
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Category:Legal-Intervention Petition
MONTHYEARML0907001332009-02-27027 February 2009 Exelon'S Answer Opposing Citizens' Petition to Require the NRC to Supplement the Safety Evaluation Report for Oyster Creek ML0904306062009-02-12012 February 2009 Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Motion to Reopen the Record and to Postpone Final Disposition of the Licensing Decision ML0902902612009-01-22022 January 2009 2009/01/22-In the Matter of Amergen Energy Company, LLC (License Renewal for Oyster Creek Nuclear Generating Station) Docket No. 50-219-LR ML0832903412008-11-19019 November 2008 Amergen'S Answer Opposing Citizens' Motion for Clarification of Certain Findings of Fact and Other Appropriate Relief ML0832204242008-11-0505 November 2008 Citizens' Answer to NRC Staff Motion to Respond to Citizens' October 14, 2008 Letter ML0823809952008-08-19019 August 2008 Oyster Creek - Notice of Withdrawal (J. Adler) ML0823906382008-08-19019 August 2008 Oyster Creek - Notice of Appearance (M. Simon) ML0824015522008-08-18018 August 2008 Citizens' Consolidated Reply Regarding Petition for Review of LBP-08-12 ML0822502302008-08-11011 August 2008 Oyster Creek - NRC Staff'S Answer in Opposition to Citizens' Petition for Review of LBP-08-12 ML0822800792008-08-11011 August 2008 Amergen'S Answer Opposing Citizens' Petition for Review of LBP-08-12 ML0822613082008-08-0101 August 2008 Citizens' Petition for Review of LBP-08-12 ML0820700772008-07-18018 July 2008 Citizens Supplemental Citation in Support of Admission of Pending Contention Regarding Metal Fatigue ML0815504232008-05-27027 May 2008 Citizens' Response to Board Order and Motion to Supplement the Basis of Their Contention, Preliminary Statement ML0814904652008-05-23023 May 2008 Amergen'S Answer Opposing Citizens' Supplemental Petition 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 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.. 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 ML0814005782008-05-0505 May 2008 Reply by Nuclear Information and Resource Service, Et. Al., to Amergen'S Opposition to Their Petition to Add a New Contention ML0806701082008-03-0404 March 2008 Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Motion for Clarification 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 ML0802205772008-01-14014 January 2008 Citizens' Petition for Review of LBP-07-17 and the Interlocutory Decisions in the Oyster Creek Proceeding ML0709406512007-03-27027 March 2007 Petitioners' Opposition to Amergen Motion to Strike ML0708002202007-03-13013 March 2007 Citizens' Combined Reply to Amergen'S and NRC Staff'S Answer to Their Petition to Add a New Contention ML0703101252007-01-23023 January 2007 Citizens' Combined Reply to Amergen'S and NRC Staff'S Answer to Their Petition to Add New Contentions ML0701700452007-01-16016 January 2007 Oyster Creek - NRC Staff Reply to Citizens' Motion for Leave to Add Contentions and Motion to Add Contentions ML0625000882006-08-29029 August 2006 Oyster Creek - Citizens' Reply to NRC Staff'S Answer to the Petition to Add a New Contention and Supplement Thereto ML0623400612006-08-21021 August 2006 NRC Staff Answer to Petition to Add a New Contention and Petition Supplement ML0624001242006-08-18018 August 2006 Citizens' Reply to Amergen'S Answer to the Petition to Add a New Contention and Supplement Thereto ML0622704312006-08-11011 August 2006 Amergen'S Answer to Citizens' Petition to Add a New Contention and Supplement Thereto ML0621404182006-07-25025 July 2006 Supplement to Petition to Add a New Contention ML0603102372006-01-30030 January 2006 Oyster Creek - NRC Staff'S Response to Licensing Board'S Order Directing Supplemental Briefing ML0602505772006-01-17017 January 2006 Letter from John A. Covino to Administrative Judges Responding to the Board'S Order of 01/10/06 Directing Additional Briefing on Two Points ML0603100322006-01-17017 January 2006 Oyster Creek - NRC Staff'S Response to Licensing Board'S Order Directing Supplemental Briefing ML0535601652005-12-19019 December 2005 Petitioners' Exhibits 10 - 14 Supporting the Petitioners' Combined Reply to the Answers of Amergen and the NRC Staff, Dated 12/19/05 ML0535601682005-12-19019 December 2005 Combined Reply of Petitioners to the Answers of Amergen and the NRC Staff ML0534900822005-12-14014 December 2005 Oyster Creek - NRC Staff Answer to Request for Hearing and Petition to Intervene ML0535500932005-12-12012 December 2005 Oyster Creek - NRC Staff Answer to Request for Hearing and Petition to Intervene of the State of New Jersey Department of Environmental Protection ML0534903402005-12-12012 December 2005 Amergen'S Answer Opposing Njdep'S Request for Hearing and Petition to Intervene; Amergen'S Answer Opposing Nirs Et Al. Request for Hearing and Petition to Intervene; and Notices of Appearance of Donald J. Silverman, Kathryn M. Sutton. ML0533900482005-11-14014 November 2005 Additional Petitioners' Declarations ML0533605792005-11-14014 November 2005 Certificate of Service for Petitioners Exhibits 1 Through 9 ML0533605622005-11-14014 November 2005 Request for Hearing and Petition to Intervene by M. Donato ML17037B7821973-10-0505 October 1973 Letter Regarding Notice of Intent to Intervene Filed with the Commission on Behalf of the Friends of the Earth 2009-02-27
[Table view] Category:Responses and Contentions
MONTHYEARML0907001332009-02-27027 February 2009 Exelon'S Answer Opposing Citizens' Petition to Require the NRC to Supplement the Safety Evaluation Report for Oyster Creek ML0904306062009-02-12012 February 2009 Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Motion to Reopen the Record and to Postpone Final Disposition of the Licensing Decision ML0902902612009-01-22022 January 2009 2009/01/22-In the Matter of Amergen Energy Company, LLC (License Renewal for Oyster Creek Nuclear Generating Station) Docket No. 50-219-LR ML0832903412008-11-19019 November 2008 Amergen'S Answer Opposing Citizens' Motion for Clarification of Certain Findings of Fact and Other Appropriate Relief ML0832204242008-11-0505 November 2008 Citizens' Answer to NRC Staff Motion to Respond to Citizens' October 14, 2008 Letter ML0823809952008-08-19019 August 2008 Oyster Creek - Notice of Withdrawal (J. Adler) ML0823906382008-08-19019 August 2008 Oyster Creek - Notice of Appearance (M. Simon) ML0824015522008-08-18018 August 2008 Citizens' Consolidated Reply Regarding Petition for Review of LBP-08-12 ML0822502302008-08-11011 August 2008 Oyster Creek - NRC Staff'S Answer in Opposition to Citizens' Petition for Review of LBP-08-12 ML0822800792008-08-11011 August 2008 Amergen'S Answer Opposing Citizens' Petition for Review of LBP-08-12 ML0822613082008-08-0101 August 2008 Citizens' Petition for Review of LBP-08-12 ML0820700772008-07-18018 July 2008 Citizens Supplemental Citation in Support of Admission of Pending Contention Regarding Metal Fatigue ML0815504232008-05-27027 May 2008 Citizens' Response to Board Order and Motion to Supplement the Basis of Their Contention, Preliminary Statement ML0814904652008-05-23023 May 2008 Amergen'S Answer Opposing Citizens' Supplemental Petition 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 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.. 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 ML0814005782008-05-0505 May 2008 Reply by Nuclear Information and Resource Service, Et. Al., to Amergen'S Opposition to Their Petition to Add a New Contention ML0806701082008-03-0404 March 2008 Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Motion for Clarification 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 ML0802205772008-01-14014 January 2008 Citizens' Petition for Review of LBP-07-17 and the Interlocutory Decisions in the Oyster Creek Proceeding ML0709406512007-03-27027 March 2007 Petitioners' Opposition to Amergen Motion to Strike ML0708002202007-03-13013 March 2007 Citizens' Combined Reply to Amergen'S and NRC Staff'S Answer to Their Petition to Add a New Contention ML0703101252007-01-23023 January 2007 Citizens' Combined Reply to Amergen'S and NRC Staff'S Answer to Their Petition to Add New Contentions ML0701700452007-01-16016 January 2007 Oyster Creek - NRC Staff Reply to Citizens' Motion for Leave to Add Contentions and Motion to Add Contentions ML0625000882006-08-29029 August 2006 Oyster Creek - Citizens' Reply to NRC Staff'S Answer to the Petition to Add a New Contention and Supplement Thereto ML0623400612006-08-21021 August 2006 NRC Staff Answer to Petition to Add a New Contention and Petition Supplement ML0624001242006-08-18018 August 2006 Citizens' Reply to Amergen'S Answer to the Petition to Add a New Contention and Supplement Thereto ML0622704312006-08-11011 August 2006 Amergen'S Answer to Citizens' Petition to Add a New Contention and Supplement Thereto ML0621404182006-07-25025 July 2006 Supplement to Petition to Add a New Contention ML0603102372006-01-30030 January 2006 Oyster Creek - NRC Staff'S Response to Licensing Board'S Order Directing Supplemental Briefing ML0602505772006-01-17017 January 2006 Letter from John A. Covino to Administrative Judges Responding to the Board'S Order of 01/10/06 Directing Additional Briefing on Two Points ML0603100322006-01-17017 January 2006 Oyster Creek - NRC Staff'S Response to Licensing Board'S Order Directing Supplemental Briefing ML0535601652005-12-19019 December 2005 Petitioners' Exhibits 10 - 14 Supporting the Petitioners' Combined Reply to the Answers of Amergen and the NRC Staff, Dated 12/19/05 ML0535601682005-12-19019 December 2005 Combined Reply of Petitioners to the Answers of Amergen and the NRC Staff ML0534900822005-12-14014 December 2005 Oyster Creek - NRC Staff Answer to Request for Hearing and Petition to Intervene ML0535500932005-12-12012 December 2005 Oyster Creek - NRC Staff Answer to Request for Hearing and Petition to Intervene of the State of New Jersey Department of Environmental Protection ML0534903402005-12-12012 December 2005 Amergen'S Answer Opposing Njdep'S Request for Hearing and Petition to Intervene; Amergen'S Answer Opposing Nirs Et Al. Request for Hearing and Petition to Intervene; and Notices of Appearance of Donald J. Silverman, Kathryn M. Sutton. ML0533900482005-11-14014 November 2005 Additional Petitioners' Declarations ML0533605792005-11-14014 November 2005 Certificate of Service for Petitioners Exhibits 1 Through 9 ML0533605622005-11-14014 November 2005 Request for Hearing and Petition to Intervene by M. Donato ML17037B7821973-10-0505 October 1973 Letter Regarding Notice of Intent to Intervene Filed with the Commission on Behalf of the Friends of the Earth 2009-02-27
[Table view] |
Text
12 +,r_ 14 - ý D DOCKETED USNRC July 18, 2008 (2:39pm)
OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
E. Roy Hawkins, Chair Dr. Paul B. Abramson Dr. Anthony J. Baratta In the Matter of )
) Docket No. 50-0219-LR AMERGEN ENERGY COMPANY, LLC )
) ASLB No. 06-844-01-LR (License Renewal for the Oyster Creek )
Nuclear Generating Station) ) July 18, 2008 CITIZENS SUPPLEMENTAL CITATION IN SUPPORT OF ADMISSION OF PENDING CONTENTION REGARDING METAL FATIGUE 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, and New Jersey Environmental Federation (collectively "Citizens") would like to draw the Board's attention to Shaw Areva MOX Services (Mixed Oxide Fuel Fabrication Facility, LBP-08-1 1, slip op. at 52-55 (Concurring Opinion of Judge Farrar, June 27, 2008) available at ML081790253.
Respectfully submitted,,
Richard Webster, Esq Eastern Environmental Law Center Attorneys for Citizens .
Dated: July 18, 2008
I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
E. Roy Hawkins, Chair Dr. Paul B. Abramson Dr. Anthony J. Baratta In the Matter of )
) Docket No. 50-0219-LR AMERGEN ENERGY COMPANY, LLC )
) ASLB No. 06-844-01-LR (License Renewal for the Oyster Creek Nuclear Generating Station) ) July 18, 2008
, )
CERTIFICATE OF SERVICE I, Richard Webster, of full age, certify as follows:
I hereby certify that on July 18, 2008, I caused Citizens' Supplemental Citation In Support of Admission of Pending Contention Regarding Metal Fatigue to be served via email and U.S.
Postal Service (as indicated) on the following:
Secretary of the Commission (Email and original and 2 copies via U.S Postal Service)
United States Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemaking and Adjudications Staff E-mail: HEARINGDOCKET@NRC.GOV ,
Office of Commission Appellate Adjudication (Email and U.S. Postal Service)
United States Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemaking and Adjudications Staff E-mail: OCAAMailgnrc.gov Administrative Judge E. Roy Hawkens, Chair (Email and U.S. Postal Service)
Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 United States Nuclear Regulatory Commission Washington,.DC 20555-0001 E-mail: erhlinrc.gov I
Administrative Judge Dr. Paul B. Abramson (Email and U.S. Postal Service)
Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 United States Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: pba@nrc.gov Administrative Judge Dr. Anthony J. Baratta (Email and U.S. Postal Service)
Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 United States Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: ajb5@nrc.gov Law Clerk Emily Krause (Email and U.S. Postal Service)
Atomic Safety & Licensing Board Panel Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: DAW 1@lnrc. gov Office of General Counsel (Email and U.S. Postal Service)
United States Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: OGCMAILCENTER@aNRC.GOV James E. Adler (Email and U.S. Postal Service)
U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop: 0-15 D21 Washington, DC 20555-0001 E-mail: jealgarc.gov Mary C. Baty (Email and U.S. Postal Service)
U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop: 0-15 D21 Washington, DC 20555-0001 E-mail: mcb I@nrc.gov Alex S. Polonsky, Esq. (Email and U.S. Postal Service)
Morgan, Lewis, &Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 E-mail: apol onskyi(dm organlewis. corn 2
Kathryn M. Sutton, Esq. (Email and U.S. Postal Service)
Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 E-mail: ksuttonCa morganlewis.corn Donald Silverman, Esq. (Email and U.S. Postal Service)
Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 E-mail: dsilvermnanimorganlewis.corn J. Bradley Fewell (Email and U.S. Postal Service)
Exelon Corporation 200 Exelon Way, Suite 200 Kennett Square, PA 19348 E-mail: bradley .fewellgexcel oncorp.com John Covino, DAG (Email and U.S. Postal Service)
State of New Jersey Department of Law and Public Safety Office of the Attorney General Hughes Justice Complex 25 West Market Street P.O. Box 093 Trenton, NJ 08625 E-mail: john.corvino(h,dol.lps. state.ni, us Valerie Gray (Email)
State of New Jersey Department of Law and Public Safety Office of the Attorney General Hughes Justice Complex 25 West Market Street P.O. Box 093 Trenton, NJ 08625 E-mail: valerie.gray@dol.lps.state.nj.us.
Paul Gunter (Email and U.S. Postal Service) c/o Nuclear Information and Resource Service 6930 Carroll Ave., Suite 340 Takoma Park, MD 20912-4446 E-mail: n~aul*.bevondnuclear.orQ ° 3
"4 Edith Gbur (Email)
Jersey Shore Nuclear Watch, Inc.
364 Costa Mesa Drive. Toms River, New Jersey 08757 E-mail: gburl dcorncast.net Paula Gotsch (Email)
GRAMMIES 205 6 th Avenue Normandy Beach, New Jersey 08723 E-mail: paulagotsch@verizon.net Jeff Tittel (Email)
New Jersey SierraClub 139 West Hanover Street Trenton New Jersey 08618 E-mail: Jeff.Tittel@)sierraclub.org Peggy Sturmfels (Email)
New Jersey Environmental Federation 1002 Ocean Avenue Belmar, New Jersey 07319 E-mail: psturmfe1s(wcleanwaer. org Michele Donato, Esq. (Email)
PO Box 145 Lavalette, NJ 08735 E-mail: mdonato~nmicheledonatoesq.com Signed: __
Richard Webster Dated: July 18, 2008 4