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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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.. Rks 3-J-4v DOCKETED November 4, 2010 (2:05pm)
OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMIS*SION BEFORE THE ATOMIC SAFETY AND LICENSSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application November 4, 2010 PILGRIM WATCH REQUEST EXTENSION SUBMIT AFFIDAVITS The Board's October 26, 2010 Order (Questions from the Board Majority Regarding the Mechanics of Computing "mean Consequences" in SAMA Analyses) requested expert affidavits to respond to the disagreement among parties as to the definition of "mean consequence values" by explaining "at what point in the process of SAMA computations performed using the MACCS2 code the "mean consequences" are done."
Parties were directed to deliver the expert affidavits by noon November 12, 2010; and if that were not possible, to state why they cannot do so, provide a date by which they can submit the affidavits, and advise the Board "no later than three business days after the issuance of this Order" - or by October 29th.
Our expert emailed this morning that he was in Vienna on business returning on November 11th and would need at least the following week to prepare his response. Dr. Lyman indicated that he could respond at the earliest by the end of the business day November 19; but
he would prefer November 23 to allow time to attend to other urgent business matters that may have arrived on his desk in his absence.
We regret that our expert did not respond indicating his whereabouts and schedule prior to October 2 9 th so that we could comply with the three - day response deadline provided. It was not possible to advise the Board by which date we could submit our affidavit until making contact with the expert. We hope that you will favorably grant an extension and thank-you for your consideration in this matter.
Sincerely, Mary Lampert Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application November 4, 2010 CERTIFICATE OF SERVICE I hereby certify that Pilgrim Watch's Request Extension Submit Affidavits was served November 4, 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 Administrative Judge Attn: Rulemakings and Adjudications Richard F. Cole Staff Atomic Safety and Licensing Board Mail Stop 0-16 C I Mail Stop -T-3-F23 United States Nuclear Regulatory US NRC Commission [2 copies] Washington, DC 20555-0001 Administrative Judge Office of Commission Appellate Ann Marshall Young, Chair Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 C 1 Mail Stop - T-3 F23 United States Nuclear Regulatory US NRC Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Administrative Judge Atomic Safety and Licensing Board Paul B. Abramson Mail Stop T-3 F23 Atomic Safety and Licensing Board United States Nuclear Regulatory Mail Stop T-3 F23 Commission US NRC Washington, DC 20555-0001 Washington, DC 20555-000-1
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U.S. Nuclear Regulatory Commission Martha Coakley, Attorney General Office of Commission Appellate Matthew Brock, Assistant Attorney Adjudication General Commonwealth of Mail Stop: 0-16C1 Massachusetts Washington, DC 20555-0001 Office of Attorney General One Ashburton Place U.S. Nuclear Regulatory Commission Boston, MA 02108 Office of General Counsel Mail Stop: 0-15 D21 Mark Stankiewicz Washington DC 20555-0001 Town Manager, Town of Plymouth Susan L. Uttal, Esq. 11 Lincoln Street Marcia Simon, Esq. Plymouth MA 02360 Andrea Jones, Esq.
Brian Harris, Esq. Sheila Slocum Hollis, Esq.
Michael Dreher, Esq. Town of Plymouth MA Brian Newell, Paralegal Duane Morris, LLP 505 9 th Street, N.W. 1000 U.S. Nuclear Regulatory Commission Washington D.C. 20004-2166 Office -ofNuclear Reactor Regulation Mail Stop: 011-Fi Richard R. MacDonald Washington, DC 20555-0001 Town Manager, Town of Duxbury 878 Tremont Street Lisa Regner, Project Mgr. Plant Lic. Duxbury, MA 02332 Branch 1-1, Operator Reactor Licensing Washington, DC 20555-0001 Fire Chief & Director DEMA, Town of Duxbury Paul A. Gaukler, Esq. 688 Tremont Street David R. Lewis, Esq. P.O. Box 2824 Jason B. Parker, Esq. Duxbury, MA 02331 Pillsbury, Winthrop, Shaw, Pittman, LLP - 2300 N Street, N.W. Terence A. Burke, Esq.
Washington, DC 20037-1128 Entergy Nuclear Mail Stop M-ECH-62 Katherine Tucker Jackson, MS 39213 ASLB, Law Clerk U.S. Nuclear Regulatory Commission Mail Stop T-3-E2a Washington, DC 20555-0001 Mary Lampert Pilgrim Watch, pro se 148 Washington St.
Duxbury, MA 023332 November 4, 2010 2