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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) ML19347D4152019-12-13013 December 2019 Motion of the Commonwealth of Massachusetts to Amend Its Petition with New Information ML19303B4252019-10-28028 October 2019 Transport Room (Motion for Stay Pending Appellate Review)(Dc Cir.)(Case No. 19-1198) 10-28-19 ML19295E6852019-10-16016 October 2019 Entergy Motion to Intervene (DC Cir.)(Case No. 19-1198) 10-16-19 ML19247E5092019-09-0404 September 2019 Motion of the Commonwealth of Massachusetts for a Twenty-Two Minute Enlargement of Time to File Its Stay Application and Supporting Appendix ML19247B4312019-09-0303 September 2019 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 ML19246A0322019-09-0303 September 2019 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 ML19230A0212019-08-18018 August 2019 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 Watch Motion to Supplement Its Motion to Intervene and Request for Hearing, Biodiversity (05.09.19) 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 ML11290A1812011-10-17017 October 2011 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 ML11256A3042011-09-13013 September 2011 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 ML11223A2842011-08-11011 August 2011 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 ML1113905702011-05-19019 May 2011 Commonwealth of Massachusetts Motion to Reply to the Answers of the NRC Staff and Entergy in Opposition to the Commonwealth of Massachusetts Motion to Hold Licensing Decision in Abeyance Pending Commission Decision Weather to Suspend the Pi ML1112203262011-05-0202 May 2011 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 ML1102407012011-01-24024 January 2011 Entergy'S Motion to Strike Portions of Pilgrim Watch'S Reply to Entergy'S and the NRC Staff'S Answers Opposing Pilgrim Watch'S Request for Hearing on a New Contention ML1101306682011-01-13013 January 2011 Entergy'S Motion in Limine to Exclude from Evidence Pilgrim Watch'S Sama Remand Pre-Filed Testimony and Exhibits ML1100503302010-12-30030 December 2010 Entergy Request for Change in Hearing Date ML1035004002010-12-13013 December 2010 Pilgrim Watch Request for Hearing on a New Contention: Inadequacy of Entergy'S Aging Management of Non-Environmentally Qualified (EQ) Inaccessible Cables (Splices) at Pilgrim Station ML1032103122010-11-0404 November 2010 Pilgrim Watch Request Extension Submit Affidavits ML1027800452010-10-0404 October 2010 NRC Staff'S Answer to Pilgrim Watch Motion Regarding ASLB Refusal to Respond to Pilgrim Watch'S Motion for Clarification ML1027300422010-09-22022 September 2010 Pilgrim Watch Motion Regarding ASLB Refusal to Respond to Pilgrim Watch'S Motion for Clarification ASLB Order (Sept 2, 2010) ML1025803182010-09-0909 September 2010 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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DOCKETED April 6, 2010 (4:26pm)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD April 6, 2010 In the Matter of )
Entergy Nuclear Generation Co. ) Docket No. 50-293-LR and Entergy Nuclear Operations, Inc. )
) ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station) )
TOWN OF PLYMOUTH, MASSACHUSETTS MOTION TO RESCHEDULE TELEPHONE CONFERENCE TO ADDRESS FUTURE COURSE OF PROCEEDING
'Pursuant to 10 C.F.R. § 2.323(a) (2009), The Town of Plymouth, Massachusetts
("Plymouth") respectfully submits the instant motion to reschedule the conference call currently scheduled for April 8, 2010. On April 1, 2010, an order was issued stating that that Atomic Safety and Licensing Board ("ASLB") will hold a telephone conference to address the future course of this proceeding in light of the Nuclear Regulatory Commission's recent decision in Docket No. CLI- 10-11. The order further stated that at the conference, the parties shall be prepared to discuss the issues remaining for adjudication, the need for discovery on these issues, the time needed to prepare for a hearing, and any other matters relevant to the Commission's remand of the proceeding. In addition, the order noted that if any party will be unavailable on the date established, the conference may be rescheduled.
Counsel for Plymouth will be out of the country on April 8, 2010 and therefore unavailable to participate in the call that day. Counsel for Plymouth will be available any day
during the first or third week in May, except for Friday, May 21, 2010. Accordingly, in light of the other parties' availability, discussed below, Plymouth respectfully requests that the conference call be moved to either May 3, May 4 or May 5. Plymouth contacted the other parties in this proceeding to determine whether they would be willing to reschedule the conference call. Pilgrim Watch has indicated that it also plans to file a motion requesting to reschedule. Pilgrim Watch stated that the third week in May will work best, but it is also available during the first week in May except for May 6 and May 7.1 Entergy opposes delaying the conference call until May, but has indicated that it is available during the first week in May or May 21. Staff also opposes moving the call into the month of May and proposes a date of either April 20 or 21.
Although Plymouth is participating in this proceeding as an interested party, it would like to stay informed on the future course of this proceeding which will be the topic of discussion on the conference call. The Pilgrim Nuclear Power Station is located in Plymouth and for that reason, Plymouth has a substantial interest in the outcome of this proceeding. Accordingly, notwithstanding Staff's and Entergy's reluctance to reschedule the conference call to a date within the month of May, Plymouth respectfully requests that the call be moved to the first week in May on either May 3, May4 or May 5 which will not result in a substantial delay in the timing of the proceeding.
Plymouth notes that it does not object to rescheduling the call to the third week in May (except May 21) which appears to be the best time for Pilgrim Watch.
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Based on the foregoing, Plymouth respectfully requests that this motion to reschedule be granted.
Respectfully submitted, Sheila Slocum Hollis Duane Morris LLP 505 9th Street, N.W., Suite 1000 Washington DC 20004 202.776.7810 202.379.9837 (fax) sshollis@duanemorris.com Counsel for Plymouth, Massachusetts Dated: April 6, 2010 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
Entergy Nuclear Generation Co. ) Docket No. 50-293-LR and Entergy Nuclear Operations, Inc. )
) ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station) )
CERTIFICATE OF SERVICE I hereby certify that copies of Motion to Reschedule Telephone Conference to Address Future Course of Proceeding of the Town of Plymouth, Massachusetts in the above-captioned proceeding have been served on the following by electronic and First Class mail this 6 th day of April, 2010.
Administrative Judge Richard F, Cole Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Richard.Cole@nrc.gov Administrative Judge Paul B. Abramson Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Paul.Abramson@nrc.gov 4
Administrative Judge Ann Marshall Young, Chair Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Ann.Young@nrc.gov Susan L. Uttal, Esq.
David Roth, Esq.
Andrea Z. Jones, Esq.
Brian G. Harris Brian Newell U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop 0- 15 D21 Washington, DC 20555-0001 Susan.Uttal@nrc.gov David.Roth@nrc.gov Andrea.Jones@nrc.gov Brian.Harris@nrc.gov Brian.Newell@nrc.gov U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Mail Stop O-16C1 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Office of the Secretary of the Commission Mail Stop O-16C1 Washington, DC 20555-0001 hearingdocket@nrc. gov Perry Buckberg, Project Manager Plant Licensing Branch I-I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O1 -Fl Washington, DC 20555-0001 Perry.Buckberg@nrc.gov 5
Johanna Thibault Law Clerk Nuclear Regulatory Commission Mail Stop: T-3F23 Washington, DC 20555-0001 Johanna.Thibault@nrc.gov Mary Lampert, Director Pilgrim Watch 148 Washington Street Duxbury, MA 02332 mary.lampert@comcast.net Chief Kevin M. Nord Fire Chief & Director Duxbury Emergency Management Agency 668 Tremont Street Duxbury, MA 02332 nord@town.duxbury.ma.us Richard R. MacDonald Town Manager 878 Tremont Street Duxbury, MA 02332 macdonald@town.duxbury.ma.us Terence A. Burke, Esq.
Entergy Nuclear 1340 Echelon Parkway Mail Stop: M-ECH-62 Jackson, MS 39213 tburke@entergy. corn David R. Lewis, Esq Paul A. Gaukler, Esq.
Jason B. Parker Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, NW Washington, DC 20037-1 137 david.lewis@pillsburylaw.com paul.gaukler@pillsburylaw.com jason.parker@ pillsburylaw.com 6
Melissa Arrighi Acting Town Manager Town of Plymouth 11 Lincoln St.
Plymouth, MA 02360 marrighi@townhall.plymouth.ma.us Matthew Brock, Esq.
Assistant Attorney General Office of the Attorney General Environmental Protection Division One Ashburton Place, 18th Floor Boston, MA 02108 matthew. brock@ago. state. ma. us Sheila Slocum Hollis 7