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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
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Steven Hamrick (202) 349-3496 steven.hamrick@fpl.com March 30, 2011 Paul S. Ryerson, Esq., Chair Dr. Michael Kennedy Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Dr. Richard E. Wardwell Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 In the Matter of NextEra Energy Seabrook, LLC (Seabrook Station)
Docket No. 50-443-LR; ASLBP No. 10-906-02-LR
Dear Administrative Judges:
By order dated March 23, 2011, the Licensing Board circulated a draft Scheduling Order for the above-captioned proceeding and requested that any comments be filed on or before March 30, 2011. NextEra Energy Seabrook, LLC (NextEra) hereby offers comments on a single matter -
the schedule for evidentiary submittals by the Commonwealth of Massachusetts acting as an interested state under 10 C.F.R. § 2.315(c).
While an interested state need not proffer its own contentions, once it is in the proceeding, it must observe the procedural requirements applicable to the parties appearing before the Board.
See Gulf States Utilities Co. (River Bend Station, Units 1 & 2), ALAB-444, 6 NRC 760, 768 (1977). Paragraph II.F.3 of the draft Scheduling Order sets forth a staggered filing schedule whereby each party to the proceeding is afforded an opportunity to respond to the initial evidentiary submission of any opposing party. But the draft Scheduling Order treats the Commonwealth differently in this respect, offering it an opportunity to file an evidentiary submission 15 days after the last party filing. NextEra is concerned that the proposed schedule would preclude any party from offering a pre-filed written rebuttal to the Commonwealths submission.
March 30, 2011 Page 2 Instead, NextEra suggests a requirement that the Commonwealth notify the parties within 30 days after the Trigger Date whether it intends to submit testimony in support of or opposition to the contentions for which it has already indicated its desire to participate. See Louisiana Energy Services, L.P. (National Enrichment Facility), 60 NRC 619, 627 (2004) (The representative [of an interested state) shall identify in advance of a hearing those contentions on which he or she wishes to participate). Under this proposal, any such testimony would then be filed at the same time as the party or parties whose position the Commonwealth supports. That way, regardless of the position asserted by the Commonwealth, the opposing party would have an opportunity to address its testimony in writing. In addition, if the Commonwealth elects to participate by submission of testimony on any contention, it should complete disclosure on each such contention 30 days after the Trigger Date, including the identity of experts under 10 C.F.R.
§ 2.336(a)(1).
In accordance with the Boards Order, NextEra made a good-faith effort to resolve this concern with the other participants in order to submit a joint proposal. Counsel for the NRC Staff supported NextEras proposal, but counsel for the Commonwealth did not. Counsel for the Commonwealth did indicate, however, that it would be amenable to a proposal allowing NextEra to respond to its evidentiary submission with leave of the Board. NextEra appreciates this accommodation, but maintains that the ability to respond to an evidentiary submission should be a matter of right built into the schedule as reflected in NextEras proposal. The representatives for Beyond Nuclear and Friends of the Coast/ New England Coalition did not respond to NextEras proposal.
Sincerely,
/Signed electronically by Steven Hamrick/
Steven Hamrick Counsel for NextEra Energy Seabrook, LLC
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) )
) ASLBP No. 10-906-02-LR (Operating License Renewal) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing letter, dated March 30, 2011, were provided to the Electronic Information Exchange for service to those individuals listed below and others on the service list in this proceeding, this 30th day of March, 2011.
Administrative Judge Administrative Judge Paul S. Ryerson, Esq., Chair Dr. Michael Kennedy Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Email: psr1@nrc.gov Email: michael.kennedy@nrc.gov Administrative Judge Secretary Dr. Richard E. Wardwell Attn: Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Mail Stop O-16 C1 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 hearingdocket@nrc.gov Email: richard.wardwell@nrc.gov
Office of Commission Appellate Adjudication Mary Spencer, Esq.
Mail Stop O-16 C1 Maxwell C. Smith, Esq.
U.S. Nuclear Regulatory Commission Emily L. Monteith, Esq.
Washington, DC 20555-0001 Megan Wright, Esq.
E-mail: OCAAMAIL@nrc.gov Office of the General Counsel Mail Stop O-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: mary.baty@nrc.gov Raymond Shadis Kurt Ehrenberg New England Coalition New Hampshire Sierra Club Post Office Box 98 40 N. Main Street Edgecomb, Maine 04556 Concord, NH 03301 E-mail: shadis@prexar.com E-mail: Kurt.Ehrenberg@sierraclub.org Paul Gunter, Reactor Oversight Project Doug Bogen Beyond Nuclear Executive Director 6930 Carroll Avenue, Suite 400 Seacoast Anti-Pollution League Takoma Park, MD 20912 PO Box 1136 E-mail: paul@beyondnuclear.org Portsmouth, NH 03802 E-mail: bogen@metrocast.net Matthew Brock Assistant Attorney General Environmental Protection Division Office of the Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 matthew.brock@state.ma.us
/Signed electronically by Steven Hamrick/
Steven Hamrick
