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Category:Legal-Pleading
MONTHYEARML24127A0462024-05-0606 May 2024 Notice of Withdrawal of Motion and Petition to Intervene of the City of San Antonio, Texas, Acting by and Through the City Public Service Board of San Antonio ML24099A2182024-04-0808 April 2024 Parties Joint Status Report ML24068A0952024-03-0808 March 2024 Parties Joint Status Report ML23237B4492023-08-25025 August 2023 Exhibit a to Nrg Answer Opposing the City of San Antonio and City of Austins Petition to Intervene and Supplemental Contention ML23237B4252023-08-25025 August 2023 Exhibit a to NRCs Answer Opposing the City of San Antonios and City of Austins Petition to Intervene and Supplemental Contention ML23237B4242023-08-25025 August 2023 Nrgs Answer Opposing the City of San Antonios and City of Austins Petition to Intervene and Supplemental Contention ML23237B4152023-08-25025 August 2023 Constellations Answer Opposing CPS Energys and Austins Petition for Leave to Intervene and Hearing Request ML23227A1032023-08-15015 August 2023 Certificate of Service of Declarations of C. Zoino and M Goldis ML23227A1022023-08-15015 August 2023 Non-Disclosure Declaration of Christine Zoino ML23227A1012023-08-15015 August 2023 Non-Disclosure Declaration of Michelle Goldis ML23227A0252023-08-14014 August 2023 Non-Disclosure Declaration of Thomas Farrell ML23227A0192023-08-14014 August 2023 Non-Disclosure Declaration of Mitchell C Lancaster ML23227A0202023-08-14014 August 2023 Non-Disclosure Declaration of Christina Dillard ML23227A0182023-08-14014 August 2023 Non-Disclosure Declaration of Edmund Daniels ML23226A2722023-08-14014 August 2023 Non Disclosure Declaration of James Barkley ML23227A0172023-08-14014 August 2023 Non-Disclosure Declaration of David Lewis ML23226A2732023-08-14014 August 2023 Certificate of Service for Non Disclosure Declaration of James Barkley ML23227A0232023-08-14014 August 2023 Resubmission of Exhibits a and B ML23227A0222023-08-14014 August 2023 Certificate of Service for Nrg Non-Disclosure Declarations ML23227A0212023-08-14014 August 2023 Non-Disclosure Declaration of D Zahn ML23227A0262023-08-14014 August 2023 Certificate of Service of Non-Disclosure Declaration of Thomas Farrell ML23223A2072023-08-11011 August 2023 CPS Energy Non-Disclosure Declarations ML23220A2142023-08-0808 August 2023 Errata to NRCs Answer Opposing the Motion by the City of San Antonio and the City of Austin to Dismiss or Suspend License Transfer Proceeding ML23219A2162023-08-0707 August 2023 STPNOC Answer Opposing Motions to Dismiss and Stay by CPS Energy and Austin ML23216A1952023-08-0404 August 2023 Revised Signature Page for Constellations Response ML23216A1822023-08-0404 August 2023 Nrg’S Answer Opposing the Motion by the City of San Antonio and the City of Austin to Dismiss or Suspend License Transfer Proceeding ML23216A1422023-08-0404 August 2023 Constellations Response in Opposition to Motion to Dismiss License Transfer Application and Motion for Stay ML23215A0242023-08-0303 August 2023 Notice of Appearance of David R Lewis ML23212B2442023-07-31031 July 2023 Notice of Appearance of M. Stanford Blanton for CPS Energy Counsel ML15127A2532015-05-0707 May 2015 Reply by Beyond Nuclear, Blue Ridge Environmental Defense League, Nuclear Information and Resource Service, Seed Coalition and Southern Alliance for Clean Energy to Oppositions by Applicants and NRC Staff to Motions to Admit New Contentions ML15127A2512015-05-0707 May 2015 Reply by Beyond Nuclear, Blue Ridge Environmental Defense League, Nuclear Information and Resource Service, Seed Coalition and Southern Alliance for Clean Energy to Oppositions by Applicants and NRC Staff to Motions to Admit New Contentions ML15126A4782015-05-0606 May 2015 Reply by Beyond Nuclear, Blue Ridge Environmental Defense League, Nuclear Information and Resource Service, Seed Coalition and Southern Alliance for Clean Energy to Oppositions by Applicants and NRC Staff to Motions to Admit New Contentions ML15124A7832015-05-0404 May 2015 STP Nuclear Operating Company Response Opposing Motion to Reopen and Placeholder Contention Regarding Continued Storage Rule ML15121A7502015-05-0101 May 2015 NRC Staff Answer to Seed Coalitions Hearing Request and Petition to Intervene and Motion to Reopen the Record in the License Renewal Proceeding for South Texas Units 1 and 2 ML15114A4562015-04-24024 April 2015 Declaration of Susan Dancer ML15049A6472015-02-18018 February 2015 Petitioners' Reply to Oppositions to Petition to Supplement Reactor-Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage ML15043A4672015-02-12012 February 2015 STP Nuclear Operating Company Response Opposing Petition to Supplement Environmental Impact Statements ML15043A7882015-02-12012 February 2015 NRC Staff Opposition to the Petition to Supplement Reactor-Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage. ML15033A4872015-01-29029 January 2015 Petition to Supplement Reactor Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage ML14311A9832014-11-0707 November 2014 Petitioners' and Intervenors' Consolidated Reply to Answer to Petitions to Suspend Final Reactor Licensing Decisions, Motions to Admit a New Contention, Motions to Reopen the Record ML14304A6652014-10-31031 October 2014 NEI Motion and Amicus Brief in the Matter of STP Nuclear Operating Co. (South Texas Project, Units 1 and 2) ML14304A7152014-10-31031 October 2014 NRC Staff Consolidated Answer to Petitions to Suspend Final Reactor Licensing Decisions, Motions to Admit a New Contention, and Motions to Reopen the Record ML14304A7192014-10-31031 October 2014 STP Nuclear Operating Company Combined Response to Proposed Contention and Petition to Suspend Related to Alleged Need for Issuance of Waste Confidence Safety Findings ML14302A7832014-10-29029 October 2014 Notice of Appearance of Mitzi A. Young ML14301A4292014-10-28028 October 2014 Notice of Appearance of Anita Ghosh ML13130A3782013-05-10010 May 2013 Notice of Withdrawal of Appearance from Maxwell C. Smith ML12216A1402012-08-0303 August 2012 STP Nuclear Operating Company'S Answer Opposing Petition for Intervention to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at STP, Units 1 & 2 ML12215A3322012-08-0202 August 2012 NRC Staff Answer to Intervenor'S Petition for Intervention to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at STP, Units 1 & 2 ML12191A3922012-07-0909 July 2012 Petition for Intervention to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at STP Units 1 & 2 ML12191A3912012-07-0909 July 2012 Standing Declaration in Support of Motion to Suspend Licensing Decisions 2024-05-06
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DECLARATION Under penalty of perjury, I, Karen Hadden, do hereby declare as follows:
- 1. I am the executive director of the SEED Coalition.
- 2. SEED Coalition advocates for safe energy alternatives and opposes the use of nuclear power to generate electricity including the relicensing of South Texas Project (STP) Units 1 & 2.
- 3. SEED Coalition has members who reside within 50 miles of the STP 1 & 2 including Susan Dancer who lives in Blessing, Texas, approximately 8 miles from STP 1 & 2. Ms.
Dancer wishes to be represented by SEED Coalition in this matter. (See Declaration of Susan Dancer)
- 4. Due to SEED Coalitions advocacy in favor of safe energy alternatives and opposition to nuclear power as an energy source, and because one of SEEDs members, Susan Dancer, has standing based on proximity to STP Units 1 & 2, SEED has representational standing in the relicensing proceeding for STP Units 1 & 2.
_______________________________ Date: March 14, 2011 Signature