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Category:Legal-Pleading
MONTHYEARML20279A4812020-10-0505 October 2020 C-10 Research and Education Foundation'S Reply to Oppositions to Motion for Partial Reconsideration and Motion to Re-Open the Record for Consideration of Supplemental Testimony Regarding License Conditions in LBP-20-09 ML20272A2742020-09-28028 September 2020 Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply and Motion for Leave to File INT053 ML20254A2342020-09-10010 September 2020 Nextera'S Answer Opposing C-10 Motion for Leave and Motion for Partial Reconsideration of LBP-20-9 ML20254A2352020-09-10010 September 2020 Nextera'S Answer Opposing C-10 Motion to Reopen the Record for Consideration of Supplemental Testimony ML20244A3212020-08-31031 August 2020 C-10 Research and Education Foundation'S Motion for Partial Reconsideration and Motion to Re-Open the Record for Consideration of Supplemental Testimony Regarding License Conditions in LBP-20-09 ML20244A3202020-08-31031 August 2020 C-10 Research and Education Foundation'S Motion for Leave to File Motion for Partial Reconsideration of LBP-20-09 ML20043E2542020-01-31031 January 2020 Redacted C-10 Research and Education'S Supplemental Proposed Findings of Fact and Conclusions of Law ML20031D6992020-01-31031 January 2020 NRC Staff Supplemental Proposed Findings of Fact and Conclusions of Law ML20031E7222020-01-31031 January 2020 NextEra Energy Seabrook Llc'S Supplemental Proposed Findings of Fact and Conclusions of Law ML19354C4482019-12-20020 December 2019 C-10 Research and Education Foundation'S Response to Nextera'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law ML19353D4192019-12-19019 December 2019 C-10 Research and Education Foundation'S Response to Nextera'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law ML19347D0672019-12-13013 December 2019 NextEra Energy Seabrook Llc'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law ML19347D0702019-12-13013 December 2019 NextEra Energy Seabrook Llc'S Responsive Proposed Findings of Fact and Conclusions of Law ML19333B9702019-11-29029 November 2019 Unopposed Motion for Extension of Time to Seek Leave to File Responsive Proposed Findings of Fact and Conclusions of Law ML20043E2522019-11-27027 November 2019 Redacted Corrected C-10 Research and Education Foundation'S Proposed Findings of Fact and Conclusions of Law ML19325D9092019-11-21021 November 2019 NRC Staff Proposed Findings of Fact and Conclusions of the Law for the Admitted Contention ML19325F3902019-11-21021 November 2019 NextEra Energy Seabrook Llc'S Proposed Findings of Fact and Conclusions of Law ML19310E2592019-11-0606 November 2019 Nextera'S Answer Opposing C-10's Third Motion for Leave to File Supplemental Testimony ML19304B3522019-10-31031 October 2019 C-10 Research and Education Foundation'S Response to ASLB Memorandum and Motion to Submit Additional Exhibits Regarding Petrographic Observations and Analyses of ASR at Seabrook ML19283A0362019-10-0909 October 2019 Nextera'S Answer Opposing C-10's Motions to Compel Production of Mineralogical Data and to Submit Additional Post-Hearing Testimony ML19272B3252019-09-30030 September 2019 C-10 Research and Education Foundation'S Motion to Compel Production of Mineralogy Data and Request for Opportunity to Submit Supplemental Written Testimony Regarding the Data ML19262K7512019-09-19019 September 2019 C-10 Research and Education Foundation'S Opposition to Nextera'S Second Motion in Limine ML19261B8802019-09-18018 September 2019 NRC Staff'S Answer to Nextera'S Motion in Limine ML19254F1582019-09-11011 September 2019 Appendix a Revised Exhibit List for September 2019 Evidentiary Hearing Exhibits ML19253D6782019-09-10010 September 2019 NRC Staff'S Answer to C-10's Motion to Supplement Rebuttal Testimony ML19252B3072019-09-0909 September 2019 NextEra Answer Opposing C-10 Motion for Leave to File Supplemental Rebuttal ML19252B2322019-09-0909 September 2019 Nextera'S Motion in Limine to Strike or Exclude Portions of C-10's Testimony and Exhibits ML19247D5932019-09-0404 September 2019 C-10 Research and Education Foundation'S Motion for Leave to File Supplemental Rebuttal Testimony ML19235A3172019-08-23023 August 2019 C-10 Research and Education Foundation, Inc. Rebuttal Statement of Position on C-10's Contentions Regarding Nextera'S Program for Managing ASR at Seabrook Station Nuclear Power Plant ML19235A3182019-08-23023 August 2019 Appendix a Revised Exhibit List ML19205A3412019-07-24024 July 2019 NRC Staff Initial Written Statement of Position ML19205A4882019-07-24024 July 2019 NextEra Energy Seabrook LLC Statement of Position and Certificate of Service ML19171A4012019-06-20020 June 2019 C-10 Research and Education Foundation'S Errata to Exhibit INT-001, Testimony of Dr. Victor E. Saouma ML19161A3722019-06-10010 June 2019 Appendix a Exhibit List ML19161A3712019-06-10010 June 2019 C-10 Research and Education Foundation, Inc. Initial Statement of Position on Contentions Re Nextera'S Program for Managing ASR at Seabrook Station ML19123A1912019-05-0303 May 2019 C-10 Research and Education Foundation'S Opposition to Nextera'S Motion in Limine ML19114A0762019-04-23023 April 2019 Nextera'S Motion in Limine to Exclude Testimony and Exhibits Regarding Structure Deformation Monitoring ML19105B2822019-04-15015 April 2019 Nextera'S Answer Opposing C-10's Motion Regarding Seabrook Station Site Tour ML19101A4082019-04-11011 April 2019 C-10 Research and Education Foundation'S Motion Regarding Seabrook Station Site Tour ML19064B4022019-03-0505 March 2019 Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply to Answers to C-10's Emergency Petition ML19064A6322019-03-0505 March 2019 Notice of Appearance for Jennifer E. Scro ML19060A3042019-03-0101 March 2019 C-10 Research and Education Foundation'S Reply to Oppositions by NextEra and NRC Staff to Emergency Petition for Exercise of Commission'S Supervisory Authority to Reverse No Significant Hazards Determination and Immediately Suspend License ML19060A3032019-03-0101 March 2019 C-10 Research and Education Foundation'S Motion for Leave to File Reply to Oppositions by NextEra and NRC Staff to Emergency Petition ML19056A5882019-02-25025 February 2019 NRC Staff Answer to C-10's Emergency Petition ML19056A5862019-02-25025 February 2019 Nextera'S Answer Opposing C-10 Emergency Petition ML19044A7702019-02-13013 February 2019 Exhibit 1 to Saouma Declaration: Curriculum Vitae for Dr. Victor E. Saouma ML19044A7682019-02-13013 February 2019 Emergency Petition by C-10 Research and Education Foundation for Exercise of Commission'S Supervisory Authority to Reverse No Significant Hazards Determination and Immediately Suspend License Amendment and License Renewal Decisions ML19044A7692019-02-13013 February 2019 Declaration of Victor E. Saouma, Ph.D ML19044A7722019-02-13013 February 2019 Exhibit 3 to Saouma Declaration: Sauoma, Experimental and Numerical Investigation of Alkali Silica Reaction in Nuclear Reactors, Final Summary Report ML19044A7732019-02-12012 February 2019 Exhibit 4a to Saouma Declaration: Introduction and Executive Summary 2020-09-28
[Table view] Category:Legal-Intervention Petition
MONTHYEARML12181A1732012-06-20020 June 2012 Letter to Ms. Vietti-Cook Withdrawal of Appearance of Eric J. Epstein from the Bell Bend Nuclear Power Plant Docket No. 52-039-COL Proceeding and TMI-Alert Inc.'S Support for the Petition to Suspend Final Decisions in All Pending Licensing ML12172A3962012-06-18018 June 2012 Petition to Suspend Final Decisions in All Pending Reactor Licensing Proceedings from Friends of the Earth ML11257A0042011-09-13013 September 2011 Certificate of Service for Intervenors' Memorandum in Reply to Nextera and NRC Staff Oppositions to Admission of Friends of the Coast and New England Coalition'S Contention Re NEPA Requirement to Address Safety & Environmental Implications ML11257A0022011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A0032011-09-13013 September 2011 Intervenors' Reply and Memorandum in Reply to Nextera and NRC Staff Oppositions to Admission of Friends of the Coast and New England Coalition'S Contention Re NEPA Requirements to Address Safety and Environmental Implications of the Fukushi ML11256A3562011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11256A3572011-09-13013 September 2011 Petitioners' Memorandum in Reply to Oppositions to Admission of New Contention in the Seabrook Relicensing Proceeding ML11249A1392011-09-0606 September 2011 Answer of NextEra Energy Seabrook, LLC, Opposing Motions to Admit New Contention ML1110900102011-04-18018 April 2011 Amendment and Errata to Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Daiichi Nuclear Power Station Accident ML1035601642010-12-22022 December 2010 NextEra Energy Seabrook, Llc'S Answer to Nec/Friends of the Coast'S Motion for Leave to File a Reply ML1035602852010-12-22022 December 2010 NRC Staff'S Response in Opposition to Friends of the Coast and New England Coalition'S Motion for Leave to Reply ML1035500572010-12-20020 December 2010 Motion by Friends of the Coast and New England Coalition for Leave to Rely to NRC Staff Objections: Nextera Energy Seabook, LLC, Response in Opposition to the Friends of the Coast and New England Coalition Supplement to Its Petition ML1035500582010-12-20020 December 2010 Friends of the Coast and New England Coalition'S Reply to NRC Staff Objections; and Nextera Energy Seabrook, Llc., Response in Opposition to the First of the Coast and New England Coalition'S Supplement to Its Petition ML1034707042010-12-13013 December 2010 NextEra Energy Seabrook, Llc'S Response Opposing Nec/Friends of the Coast'S Supplement to Its Petition ML1034705912010-12-13013 December 2010 NRC Staff'S Objections to the Friends of the Coast and New England Coalition'S Supplement ML1032703242010-11-23023 November 2010 Certificate of Service (for Friends of the Coast/New England Coalition Reply and Request for Extension of Time) ML1032606572010-11-22022 November 2010 Combined Reply of Joint Petitioners (Beyond Nuclear, Seacoast Anti-Pollution League and New Hampshire Sierra Club) to Answers of NextEra Energy Seabrook, LLC and the United States Nuclear Regulatory Commission ML1032703272010-11-22022 November 2010 Friends of the Coast and New England Coalition Reply to Nextera and NRC Staff Answers to Friends of the Coast and New England Coalition Petition for Leave to Intervene, Request for Hearing, and Admission of Contentions ML1032703222010-11-22022 November 2010 Friends of the Coast/New England Coalition'S Request for Extension of Time ML1032700012010-11-22022 November 2010 Friends of the Coast and New England Coalition Reply to Nextera and NRC Staff Answers to Friends of the Coast and New England Coalition Petition for Leave to Intervene, Request for Hearing, and Admission of Contentions ML1032606692010-11-22022 November 2010 Errata of Joint Petitioners (Beyond Nuclear, Seacoast Anti-pollution League and New Hampshire Sierra Club) ML1031905292010-11-15015 November 2010 NextEra Energy Seabrook, LLCs Answer Opposing the Petition to Intervene and Request for Hearing of Beyond Nuclear, Seacoast Anti-Pollution League, and New Hampshire Sierra Club ML1031907642010-11-15015 November 2010 NRC Staff'S Answer to Petitions to Intervene and Requests for Hearing Filed by (1) Friends of the Coast and New England Coalition and (2) Beyond Nuclear, Seacoast Anti-Pollution League, and New Hampshire Sierra Club ML1030504922010-11-0101 November 2010 Attachment C (resubmitted)-Economic Consequences of a Rad/Nuc Attack: Cleanup Standards Significantly Affect Cost ML1032703262010-10-18018 October 2010 Declaration of Deborah Grinnell ML1032703232010-10-18018 October 2010 Declaration of Deborah Breen ML1032703192010-10-18018 October 2010 Declaration of Sandra Gavutis ML1032703252010-10-12012 October 2010 Declaration of Diane M. Teed ML1032703212010-09-30030 September 2010 Declaration of Peter Kellman ML1032703182010-09-29029 September 2010 Declaration of Karen Stewart ML1032703202010-09-20020 September 2010 Declaration of Mary Lampert ML0617800572006-06-16016 June 2006 Constellation'S Answer to Petition to Intervene by International Brotherhood of Electrical Workers, Local 97 2012-06-20
[Table view] Category:Responses and Contentions
MONTHYEARML12181A1732012-06-20020 June 2012 Letter to Ms. Vietti-Cook Withdrawal of Appearance of Eric J. Epstein from the Bell Bend Nuclear Power Plant Docket No. 52-039-COL Proceeding and TMI-Alert Inc.'S Support for the Petition to Suspend Final Decisions in All Pending Licensing ML12172A3962012-06-18018 June 2012 Petition to Suspend Final Decisions in All Pending Reactor Licensing Proceedings from Friends of the Earth ML11257A0042011-09-13013 September 2011 Certificate of Service for Intervenors' Memorandum in Reply to Nextera and NRC Staff Oppositions to Admission of Friends of the Coast and New England Coalition'S Contention Re NEPA Requirement to Address Safety & Environmental Implications ML11257A0022011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A0032011-09-13013 September 2011 Intervenors' Reply and Memorandum in Reply to Nextera and NRC Staff Oppositions to Admission of Friends of the Coast and New England Coalition'S Contention Re NEPA Requirements to Address Safety and Environmental Implications of the Fukushi ML11256A3562011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11256A3572011-09-13013 September 2011 Petitioners' Memorandum in Reply to Oppositions to Admission of New Contention in the Seabrook Relicensing Proceeding ML11249A1392011-09-0606 September 2011 Answer of NextEra Energy Seabrook, LLC, Opposing Motions to Admit New Contention ML1110900102011-04-18018 April 2011 Amendment and Errata to Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Daiichi Nuclear Power Station Accident ML1035601642010-12-22022 December 2010 NextEra Energy Seabrook, Llc'S Answer to Nec/Friends of the Coast'S Motion for Leave to File a Reply ML1035602852010-12-22022 December 2010 NRC Staff'S Response in Opposition to Friends of the Coast and New England Coalition'S Motion for Leave to Reply ML1035500572010-12-20020 December 2010 Motion by Friends of the Coast and New England Coalition for Leave to Rely to NRC Staff Objections: Nextera Energy Seabook, LLC, Response in Opposition to the Friends of the Coast and New England Coalition Supplement to Its Petition ML1035500582010-12-20020 December 2010 Friends of the Coast and New England Coalition'S Reply to NRC Staff Objections; and Nextera Energy Seabrook, Llc., Response in Opposition to the First of the Coast and New England Coalition'S Supplement to Its Petition ML1034707042010-12-13013 December 2010 NextEra Energy Seabrook, Llc'S Response Opposing Nec/Friends of the Coast'S Supplement to Its Petition ML1034705912010-12-13013 December 2010 NRC Staff'S Objections to the Friends of the Coast and New England Coalition'S Supplement ML1032703242010-11-23023 November 2010 Certificate of Service (for Friends of the Coast/New England Coalition Reply and Request for Extension of Time) ML1032606572010-11-22022 November 2010 Combined Reply of Joint Petitioners (Beyond Nuclear, Seacoast Anti-Pollution League and New Hampshire Sierra Club) to Answers of NextEra Energy Seabrook, LLC and the United States Nuclear Regulatory Commission ML1032703272010-11-22022 November 2010 Friends of the Coast and New England Coalition Reply to Nextera and NRC Staff Answers to Friends of the Coast and New England Coalition Petition for Leave to Intervene, Request for Hearing, and Admission of Contentions ML1032703222010-11-22022 November 2010 Friends of the Coast/New England Coalition'S Request for Extension of Time ML1032700012010-11-22022 November 2010 Friends of the Coast and New England Coalition Reply to Nextera and NRC Staff Answers to Friends of the Coast and New England Coalition Petition for Leave to Intervene, Request for Hearing, and Admission of Contentions ML1032606692010-11-22022 November 2010 Errata of Joint Petitioners (Beyond Nuclear, Seacoast Anti-pollution League and New Hampshire Sierra Club) ML1031905292010-11-15015 November 2010 NextEra Energy Seabrook, LLCs Answer Opposing the Petition to Intervene and Request for Hearing of Beyond Nuclear, Seacoast Anti-Pollution League, and New Hampshire Sierra Club ML1031907642010-11-15015 November 2010 NRC Staff'S Answer to Petitions to Intervene and Requests for Hearing Filed by (1) Friends of the Coast and New England Coalition and (2) Beyond Nuclear, Seacoast Anti-Pollution League, and New Hampshire Sierra Club ML1030504922010-11-0101 November 2010 Attachment C (resubmitted)-Economic Consequences of a Rad/Nuc Attack: Cleanup Standards Significantly Affect Cost ML1032703262010-10-18018 October 2010 Declaration of Deborah Grinnell ML1032703232010-10-18018 October 2010 Declaration of Deborah Breen ML1032703192010-10-18018 October 2010 Declaration of Sandra Gavutis ML1032703252010-10-12012 October 2010 Declaration of Diane M. Teed ML1032703212010-09-30030 September 2010 Declaration of Peter Kellman ML1032703182010-09-29029 September 2010 Declaration of Karen Stewart ML1032703202010-09-20020 September 2010 Declaration of Mary Lampert ML0617800572006-06-16016 June 2006 Constellation'S Answer to Petition to Intervene by International Brotherhood of Electrical Workers, Local 97 2012-06-20
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
NEXTERA ENERGY SEABROOK, LLC ) DOCKET NO. 50-443-LR (Seabrook Station, Unit 1) )
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(License Renewal) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Friends of the Coast/New England Coalition Reply and Request For Extension of Time dated November 22, 2010 and November 23, 2010, respectively, have been served upon the following persons by Electronic Information Exchange.
U.S. Nuclear Regulatory Commission Atomic U.S. Nuclear Regulatory Commission Safety and Licensing Board Panel Mail Stop: Office of the General Counsel T-3F23 Mail Stop: O-15D21 Washington, DC 20555-0001 Washington, DC 20555-0001 Catherine Kanatas Administrative Judge catherine.kanatas@nrc.gov Paul S. Ryerson, Chair Emily Monteith, Esq.
psr1@nrc.gov emily.monteith@nrc.gov Brian Newell, Paralegal Administrative Judge brian.newell@nrc.gov Michael F. Kennedy David Roth, Esq.
michael.kennedy@nrc.gov der@nrc.gov Maxwell Smith, Esq.
Administrative Judge maxwell.smith@nrc.gov Richard E. Wardwell Mary Spencer, Esq.
richard.wardwell@nrc.gov mary.spencer@nrc.gov Edward Williamson, Esq.
Anthony C. Eitreim, Esq. edward.williamson@nrc.gov Chief Counsel Megan Wright, Esq.
ace1@nrc.gov megan.wright@nrc.gov Hillary Cain, Law Clerk OGC Mail Center hillary.cain@nrc.gov OGCMailCenter@nrc.gov U.S. Nuclear Regulatory Commission Office U.S. Nuclear Regulatory Commission of the Secretary of the Commission Mail Stop: Office of Commission Appellate Adjudication O-16C1 Mail Stop: O-16C1 Washington, DC 20555-0001 Washington, DC 20555-0001 Hearing Docket ocaamail@nrc.gov hearingdocket@nrc.gov
NEXTERA ENERGY SEABROOK, LLC (Seabrook Station Unit 1) - Docket No. 50-443-LR Friends/NEC Reply and Request for extension of Time Counsel for the Applicant NextEra Counsel for the Applicant NextEra Energy Seabrook, LLC 801 Energy Seabrook, LLC 700 Pennsylvania Avenue, N.W. Suite Universe Boulevard 220 Juno Beach, FL 33408 Washington, DC 20004 William Blair, Esq.
Steven C. Hamrick, Esq. william.blair@fpl.com steven.hamrick@fpl.com Antonio Fernandez, Esq.
Kim Bartels, Paralegal antonio.fernandez@fpl.com kim.bartels@fpl.com Mitchell S. Ross, Esq.
mitch.ross@fpl.com Beyond Nuclear Friends of the Coast/New England Coalition 6930 Carroll Avenue, Suite 400 Post Office Box 98 Takoma Park, MD 20912 Edgecomb, ME 04556 Paul Gunter, Director Raymond Shadis, Pro Se Representative Reactor Oversight Project shadis@prexar.com paul@beyondnuclear.org New Hampshire Sierra Club 40 N. Main Street Concord, NH 03870 Kurt Ehrenberg, Field Organizer kurt.ehrenberg@sierraclub.org Seacoast Anti-Pollution League P.O.
Box 1136 Portsmouth, NH 03802 Doug Bogen, Executive Director dbogen@metrocast. net Original signed (electronically) by Raymond Shadis Pro Se Representative , Friends/NEC Dated at Edgecomb, Maine this 23rd day of November 2010 2