ML101730182
| ML101730182 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/16/2010 |
| From: | Lampert M Pilgrim Watch |
| To: | NRC/OCM |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, RAS J-245 | |
| Download: ML101730182 (4) | |
Text
'?AS DOCKETED USNRC June 16, 2010 (3:22p.m.)
OFFICE OF SECRETARY RULEMAKINGS AND UNITED STATES OF AMERICA ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION BEFORE THE.U.S. NUCLEAR REGULATORY COMMISSION In the Matter of
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Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc.
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Docket No. 50-293-LR
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ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station)
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June 16, 2010 MOTION REQUESTING LEAVE TO FILE RESPONSE TO JUDGE PAUL B.
ABRAMSON DECISION ON RECUSAL MOTION (JUNE 10, 2010)
Pilgrim Watch respectfully.files this Motion with the Commission for leave to file Pilgrim Watch Response To Judge Paul B. Abramson Decision On Recusal Motion (June 10, 2010) necessary in order for fairness to be accorded the Petitioner. It is a fourteen page response with attachments provided for the convenience of the Commission.
Pilgrim Watch could not have anticipated that Judge Abramson would have spent 20 pages adding new reasoning to defend his Decision. We believe his Decision requires a response in order for Pilgrim Watch to explain precisely why, despite his argument, we believe that the Commission should recuse Judge Abramson on the grounds that (1) he had extrajudicial knowledge of disputed evidentiary facts pertinent to this proceeding (28 U.S.C. §455(b)(2), and
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(2) his impartiality might reasonably be questioned (28 U.S.C. §455(a). Pilgrim Watch has consulted both the Applicant and NRC Staff.
Respectfully Submitted, Electronically signed by, Mary Lampert Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 June 16, 2010 CERTIFICATION BY PILGRIM WATCH'S REPRESENTATIVE PURSUANT TO 10C.F.R. § 2.323(b)
Pursuant to 10 C.F.R. 2.323(b), I certify that on June 16, 2010, I contacted counsel for Entergy and NRC Staff and they would oppose the Motion.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application June 16, 2010 CERTIFICATE OF SERVICE I hereby certify that Pilgrim Watch's Motion Requesting Leave To File Response To Judge Paul B. Abramson Decision On Recusal Motion (June 10, 2010) was served June 16, 2010 in the above captioned proceeding to the following persons by electronic mail this date, followed by deposit of paper copies in the U.S. mail, first class.
Secretary of the Commission Attn: Rulemakings and Adjudications Staff Mail Stop 0-16 C I United States Nuclear Regulatory Commission [2 copies]
Ch. Gregory B. Jaczko Chairman
.U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Hon. Kristine L. Svinicki Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Hon. George Apostolakis Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Hon. William D. Magwood, IV Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Hon. William C. Ostendorff Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Administrative Judge Ann Marshall Young, Chair Atomic Safety and Licensing Board Mail Stop - T-3 F23 US NRC Washington, DC 20555-0001 Administrative Judge Paul B. Abramson Atomic Safety and Licensing Board Mail Stop T-3 F23 US NRC Washington, DC 20555-0001 Administrative Judge Richard F; Cole Atomic Safety and Licensing Board Mail Stop -T-3-F23 US NRC Washington, DC 20555-0001
Office of Commission Appellate Adjudication Mail Stop 0-16 C I United States Nuclear Regulatory Commission Washington, DC 20555-0001 Atomic Safety and Licensing Board Mail Stop T-3 F23 United States Nuclear Regulatory Commission Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Mail Stop: 0-16C1 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Office of General Counsel Mail Stop: 0-15 D21 Washington DC 20555-0001 Susan L. Uttal, Esq.
Marcia Simon, Esq.
Andrea Jones, Esq.
David Roth, Esq.
Brian Harris, Esq.
Brian Newell, Paralegal U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop: 011-FI Washington, DC 20555-0001 Lisa Regner, Project Mgr. Plant Lic.
Branch 1-1, Operator Reactor Licensing Washington, DC 20555-0001 Paul A. Gaukler, Esq.
David R. Lewis, Esq.
Jason B. Parker, Esq.
Pillsbury, Winthrop, Shaw, Pittman, LLP -
2300 N Street, N.W.
Washington, DC 20037-1128 Martha Coakley, Attorney General Matthew Brock, Assistant Attorney General Commonwealth of Massachusetts Office of Attorney General One Ashburton Place Boston, MA 02108 Mark Stankiewicz Town Manager, Town of Plymouth 11 Lincoln Street Plymouth MA 02360 Sheila Slocum Hollis, Esq.
Town of Plymouth MA Duane Morris, LLP 505 9th Street, N.W. 1000 Washington D.C. 20004-2166 Richard R. MacDonald Town Manager, Town of Duxbury 878 Tremont Street Duxbury, MA 02332 Fire Chief & Director DEMA, Town of Duxbury 688 Tremont Street P.O. Box 2824 Duxbury, MA 02331 Terence A. Burke, Esq.
Entergy Nuclear Mail Stop M-ECH-62 Jackson, MS 39213 Mary Lampert Pilgrim Watch, pro se 148 Washington St.
Duxbury, MA 023332 2