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Category:Legal-Correspondence
MONTHYEARML0931001372009-11-0505 November 2009
E-mail from Ray P. Kuyler, Counsel for PSEG Nuclear in Response to Petitioner'S Request for Extension of Time to File a Request for Hearing and Petition to Intervene
ML0931001452009-11-0404 November 2009
Letter from Alex Polonsky, Counsel for PSEG Nuclear in Response to Nov. 2, 2009 Request for Extension of Time to File by Delaware Riverkeeper and the New Jersey Environmental Federation
ML0931001552009-11-0404 November 2009
2009/11/04- Notice of Appearances of Vincent C. Zabielski, Kathryn M. Sutton, Alex S. Polonsky, and Raphael P. Kuyler, Counsel for PSEG Nuclear in the Salem 1 and 2 License Renewal Proceeding
ML0931001532009-11-0404 November 2009
2009/11/04- Notice of Appearances by Vincent C. Zabielski, Kathryn M. Sutton, Alex S. Polonsky, and Raphael P. Kuyler, Morgan, Counsel for PSEG Nuclear in the Hope Creek License Renewal Proceeding
ML0931001522009-11-0404 November 2009
2009/11/04- Letter from Alex Polonsky, Counsel for PSEG Nuclear Petitioner'S Request for Extension of Time to File a Request for a Hearing in the Hope Creek License Renewal Proceeding
ML0931006172009-11-0202 November 2009
2009/11/02- Letter to Chairman Jaczko from Jane Nogaki, Nj Environmental Federation Requesting a 60 Day Extension to File a Hearing Request in the Hope Creek and Salem 1 and 2 License Renewal Proceedings
ML0931006042009-11-0202 November 2009
2009/11/02 - Email from Fred Stein, Maya K. Van Rossum, Delaware Riverkeeper Requesting a 60 Day Extension to File a Request for Hearing in the Hope Creek and the Salem 1 and 2 License Renewal Proceeding
ML0309700872003-03-25025 March 2003
Rothschild Inc.'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period February 1, 2003 - February 28, 2003
ML0234003322002-12-0606 December 2002
Memorandum from Emile L. Julian to Recipients of Letter Dated 12/04/02 from Annette L. Vietti-Cook to Norm Cohen Regarding DD-02-03
ML19029A8491981-02-17017 February 1981
02/17/1981 Certificate of Service on Copies of Licensee'S Response to Briefs in Support of Exceptions of Lower Alloways Creek Township and Mr. and Mrs. Alfred C. Coleman, Jr
ML19029A8531980-11-30030 November 1980
11/30/1980 Legal Correspondence Intervenors' Exception to Initial Decision of October 27, 1980
ML19029A8851980-05-13013 May 1980
Certificate of Service of Copies of Licensee'S Request for Extension of Time & Response to NRC Staff Motion for Extension of Time & Licensee'S Proposed Transcript Corrections for the Evidentiary Hearings of 3/28-29/1980.
ML19029A8861980-05-0202 May 1980
05/02/1980 Legal Correspondence Delaware'S Corrections of Transcript
ML19029A8781980-04-10010 April 1980
04/10/1980 Legal Correspondence Licensee'S Response to Licensing Board Question 5 on 'Gross Loss of Water' from the Salem Spent Fuel Pool
ML19029A8811980-04-0909 April 1980
04/09/1980 Legal Correspondence Submittal of Technical Report of Dr. Richard E. Webb in Response to ASLB Order of February 22, 1980
ML19029A8791980-04-0909 April 1980
04/09/1980 Legal Correspondence Written Testimony and Qualifications of Dr. David B. Fankhauser, in Response to ASLB Order of February 22, 1980
ML19029A8821980-04-0707 April 1980
04/07/1980 Legal Correspondence Intervenors' Inability to Prepare Written Testimony in Requisite Time to Most Recent Question Posed by Board
ML19029A7781979-12-13013 December 1979
Informing Licensee'S Installation Procedure for Increased Capacity Spent Fuel Racks Has Been Submitted
ML19029A7651979-08-31031 August 1979
Certify Copies of Licensee'S Response to Motion for Reconsideration of Coleman'S Contention No. 13 & Licensee'S Response to Motion to Re-open Coleman'S Contention 2 & 6 for Receipt of Newly Discovered Evidence.
ML19029A7641979-08-31031 August 1979
Licensee'S Response to Motion for Reconsideration of Colemans' Contention No. Thirteen
ML19029A7551979-08-22022 August 1979
Unit #1 - Intervenors', Coleman, Response to Boards Question Number Four: Was TMI a Class Nine Accident?
ML19029A7601979-08-10010 August 1979
Applicant'S Request for an Extension of Time to Respond to Intervenors' Motion to Reopen Coleman'S Contentions Two & Six for Receipt of Newly Discovered Evidence & Motion for Reconsideration of Dismissal of Coleman'S Contention No. 13.
ML19029A8181979-06-26026 June 1979
06/26/1979 Licensee'S Answer to Motion by Intervensors, Coleman, to Compel Supplementation of Answers to Interrogatories by Licensee
ML19029A8211979-06-25025 June 1979
Intervenor Township of Lower Alloways Creek Response to NRC Staff Objection to Board Question
ML19029A8231979-06-18018 June 1979
Licensee'S Response to NRC Staff Objection to Board Question and Motion for Extension of Time to File Response to Board Question Relating to Class 9 Accidents
ML19029A8251979-06-14014 June 1979
Enclosed Brief on Behalf of Interveners in Opposition to Staff'S Objection to Board'S Consideration of Impacts of Class Nine Accident on Salem Spent Fuel Pool
ML19029A8281979-06-12012 June 1979
06/12/1979 Legal Correspondence Response to the Atomic Safety and Licensing Board Order Dated April 18, 1979
ML19029A8301979-06-11011 June 1979
06/11/1979 Legal Correspondence Intervenor Township of Lower Alloways Creek Motion for Extension of Time to Respond to NRC Staff Objection to Board Question
ML19029A8541979-04-26026 April 1979
04/26/1979 Legal Correspondence Professional Qualifications of Warren S. Nechodom
ML19029A8631979-04-25025 April 1979
04/25/1979 State of New Jersey'S Outline of Cross-Examination
ML19029A8611979-04-25025 April 1979
04/25/1979 Licensee'S Outline of Cross-Examination
ML19029A8601979-04-25025 April 1979
04/25/1979 Legal Correspondence Outline of Cross-Examination of Evidence Submitted by the Nuclear Regulatory Commission
ML19029A8581979-04-25025 April 1979
04/25/1979 Legal Correspondence Outline of Areas of Cross-Examination
ML19029A8571979-04-25025 April 1979
04/25/1979 Intervenors' Response to ASLBP Order Dated April 18, 1979
ML19029A8561979-04-25025 April 1979
04/25/1979 Outline of Intervenors, Colemans, Cross-Examination; Contentions Two and Six
ML19029A8641979-04-24024 April 1979
04/24/1979 Legal Correspondence Non-Proprietary Version of Exxon Nuclear Company'S Report on Fuel Storage Racks Corrosion Program
ML19029A8671979-04-23023 April 1979
04/23/1979 Licensee'S Objections to Intervenors' Profferred Testimony
ML19029A8731979-04-12012 April 1979
04/12/1979 Legal Correspondence Application for Stay by the Township of Lower Alloways Creek
ML19029A8741979-04-11011 April 1979
04/11/1979 Legal Correspondence Intervenors Submit Their Proposed Direct Testimony to Be Elicited from Robert M. Crockett, Vice President for Fuel Supply, Public Service Electric and Gas Company
ML19029A8771979-04-0707 April 1979
04/07/1979 Legal Correspondence Township of Lower Alloways Creek Objections to Prehearing Order and Requests for Revision of Order or Recertification
ML19029A4421979-04-0202 April 1979
Letter Re Prehearing Conference to Fulfill the Requirements by the ASLBP for the Identification of Written Testimony and the Proposed Order or Proof
ML19029A8471979-04-0202 April 1979
04/02/1979 Legal Correspondence Identification of Written Testimony to Be Filed
ML19029A4541979-03-26026 March 1979
Interveners, Colemans' Memorandum in Opposition to the Licensee'S Motion for Summary Disposition, Interveners' Statement of Material Facts in Dispute Pertaining to Contention Two
ML19029A4571979-03-20020 March 1979
Interested State of Delaware'S Answer to Licensee'S Motion for Summary Judgment
ML19029A4591979-03-12012 March 1979
Intervenor Township of Lower Alloways Creek'S Answer to Motion for Summary Disposition
ML19029A4601979-03-12012 March 1979
Request for Report & Correspondence for Constituent'S Inquiry
ML19029A4641979-03-0707 March 1979
Intervenors, Colemans, Motion to Consolidate Prehearing Conference with Special Prehearing Conference for Purposes of Prehearing Order
ML19029A4651979-03-0606 March 1979
Letter Re Resolution Which Was Approved & Adopted by Township Committee of Township of Pennsville
ML19029A4691979-02-27027 February 1979
Public Service Electric & Gas Co. - Licensee'S Memorandum in Support of Its Motion for Summary Disposition
ML19029A4731979-02-16016 February 1979
Resolution Opposing Storage of High Level Radioactive Wastes in Lower Alloways Creek Township
2009-11-05
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1112/09 223 Park Avenue Marlton, NJ 08053 To: Hon Chairman Gregory B. Jaczko. Chairman United States Nuclear Regulatory Commission Washington D.C. 20555-0001
Dear Chairman Jaczko:
The NJ EnvironmentlI Federation, N]'s chapter of Qean Water Action, respectfully requests a 60-day extension in which to file its Request foe a Hearing/Petition for Leave to Intervene in response to the relicensing application ftied by PSEG for the Salem and Hope Creek nuclear power plants (Salem 1 and 2, Hope Creek) located in Lower Alloways Township, New Jersey. (Docket No. 50-354; NRC-2009-0391] Docket Nos. 50-272 and 50-311; NRC-2009-0390)
The NJ Environmental Federation, as part of the UNPLUG SALEM campaign, has been working diligently to prepare its responses even before the NRC published a notice in the Federal Register on October 23rd, 2009, that PSEG's relicensing application for SalernlHope Creek was accepted for review, thereby commencing the NRC's 60-day time period within which to file these papers.
The UNPLUG Salem Campaign is a network of organizations that watchdog PSEG's three nuclear plants. UNPLUG has taken the lead to coordinate with other organizations to submit contentions as required by the NRC's regulations. This coordination requires many meetings and a great deal of consultation and cooperation, all of which takes a significant amount of time.
Additional time is also needed because of the structural differences between Salem Units I and 2, which are PWR's and Hope Creek, which is a BWR, Also, as citizen groups, we do not have the staff and resources needed to review the extensive and complex application for relicensing in only 60 days. The sheer size of PSEG's relicensing application requires more than 60 days to evaluate.
In addition, the process to retain consultants and experts to provide necessary support and expertise is very difficult to accomplish within 60 days. We began the process early for some of these individuals, but as we have developed our contentions over the last few weeks, we have seen the need to retain additional experts and consultants. This process will not likely be concluded by the December 22nd, 2009 deadline established by the NRC.
A 60-day extension would enable the NJ Environmental Federation to participate more fully and to more meaningfully contribute to the relicensing proceeding. For all of these reasons, we respectfully request that the NRC grant a 60-day extension until February 22nd, 2010.
Respectfully submitted, Jane Nogaki Vice Chair NJ Environmental Federation
