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Category:Legal-Pleading
MONTHYEARML20177A6212020-06-25025 June 2020 Applicants Status Report ML20156A0502020-06-0404 June 2020 Joint Motion of Applicants and the Commonwealth of Massachusetts for a Stay of Issuance of a Decision on the Pending Petitions for Intervention and a Hearing ML20014E7632020-01-14014 January 2020 Commonwealth of Massachusetts' Reply in Support of Motion to Amend Its Petition with New Information ML20007E9182020-01-0707 January 2020 Applicants' Answer Opposing the Commonwealth of Massachusetts' Second Motion to Supplement Its Petition with New Information ML19343C6922019-12-0909 December 2019 Applicants' Answer Opposing Pilgrim Watch'S Third Motion to Supplement Its Motion to Intervene and Request for Hearing ML19329B3242019-11-25025 November 2019 Watch Motion to Supplement Its February 20, 2019 Motion to Intervene and Request for Hearing, Its April 1, 2019 Reply to Petitioners, and Its May 3, 2019 Motion to Supplement ML19284E8962019-10-11011 October 2019 Notice of Appearance and Substitution of Counsel ML19256B9952019-09-13013 September 2019 Applicant'S Answer Opposing Pilgrim Watch'S Stay Motions ML19256B9602019-09-13013 September 2019 Applicants' Answer Opposing the Application of the Commonwealth of Massachusetts for a Stay ML19255K4112019-09-12012 September 2019 Reply of the Commonwealth of Massachusetts in Support of Its Motion for a Twenty-Two Minute Enlargement of Time to File Its Stay Application and Supporting Appendix ML19252A3332019-09-0909 September 2019 Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts for a Twenty-Two Minute Enlargement of Time to File Its Stay Application ML19246B1762019-09-0303 September 2019 Applicants Unopposed Motion for Clarification of Time to Respond to Pilgrim Watch Motion for Stay of Exemption ML19234A3582019-08-22022 August 2019 Notice of Appearance - Anita Ghosh Naber ML19231A1542019-08-19019 August 2019 Watch Reply to Applicants' Answer Opposing Pilgrim Watch'S Motion to File a New Contention ML19228A0902019-08-16016 August 2019 Pilgrm Watch Memorandum in Support of Emergency Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application to Stay a NRC Staff Order Approving the License Transfer Application ML19228A1672019-08-16016 August 2019 Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application for Stay ML19228A1622019-08-16016 August 2019 Notice of Appearance and Substitution of Counsel ML19227A2902019-08-15015 August 2019 Watch Memorandum in Support of Emergency Motion of the Commonwealth of Massachusetts for Clarification of the Commission'S August 14, 2019 Memorandum and Order ML19224C4242019-08-12012 August 2019 Applicants' Answer Opposing Pilgrim Watch'S Motion to File a New Contention ML19217A3682019-08-0505 August 2019 Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts to Stay Proceedings to Complete Settlement Negotiations ML19197A3302019-07-16016 July 2019 Watch Motion to File a New Contention ML19137A0732019-05-17017 May 2019 Applicants' Answer Opposing Pilgrim Watch'S Motion to Supplement Its Motion to Intervene and Request for Hearing ML19126A0502019-05-0606 May 2019 Watch Reply to Applicants Answer Opposing Pilgrim Watch Motion to Supplement Its Motion to Intervene and Request for Hearing May 6, 2019 Its Motion to Intervene and Request for Hearing (May 6, 2019) ML19122A1262019-05-0202 May 2019 Applicant'S Answer Opposing Pilgrim Watch Motion to Supplement Its Motion to Intervene and Request for Hearing ML19122A1222019-05-0202 May 2019 Applicant'S Answer Opposing the Commonwealth of Massachusetts Motion to Supplement Its Petition with New Information ML19116A1622019-04-26026 April 2019 Watch Motion to Supplement Its Motion to Intervene and Request for Hearing. New Information ML19091A2972019-04-0101 April 2019 Commonwealth of Massachusetts' Reply in Support of Petition for Leave to Intervene and Hearing Request ML19077A1902019-03-18018 March 2019 Notice of Appearances for Mary E. Lampert and James B. Lampert ML19077A2352019-03-18018 March 2019 Applicants' Answer Opposing Pilgrim Watch Petition for Leave to Intervene and Hearing Request ML19077A2322019-03-18018 March 2019 Applicants' Answer Opposing the Commonwealth of Massachusetts' Petition for Leave to Intervene and Hearing Request ML19052A1872019-02-21021 February 2019 Exhibit 4 to Pilgrim Watch Petition to Intervene and Hearing Request ML19052A1902019-02-21021 February 2019 Exhibit 5 to Pilgrim Watch Petition to Intervene and Hearing Request ML19051A0192019-02-20020 February 2019 Watch Petition to Intervene and Hearing Request ML19052A1822017-07-31031 July 2017 Exhibit 2 to Pilgrim Watch Petition to Intervene and Hearing Request ML17095A3642017-04-0505 April 2017 Status of Decision on Petitioners Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109 ML17048A5712017-02-17017 February 2017 Status of Decision on Petitioners Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109 ML16285A3782016-10-11011 October 2016 Petitioners' Response to NRC Staff'S and Entergy'S Opposition to Peitioners' Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109 ML16277A5482016-10-0303 October 2016 Entergy Answer Opposing Request for Hearing Regarding Pilgrim and EA-13-109 ML16277A5612016-10-0303 October 2016 NRC Staff Response to Pilgrim Watch and Co-Petitioners Request for Hearing ML16277A4652016-10-0303 October 2016 Notice of Appearance for Marcia Simon ML16277A2102016-10-0303 October 2016 Notice of Appearance for Robert Carpenter ML16277A4712016-10-0303 October 2016 Notice of Appearance for Matthew Ring ML12195A0912012-07-13013 July 2012 NRC Staff'S Answer to Jones River Watershed Association and Pilgrim Watch'S Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention ML12195A1692012-07-13013 July 2012 Entergy'S Answer Opposing Jones River Watershed Association and Pilgrim Watch'S Petition for Review of LBP-12-11 ML12185A1392012-07-0303 July 2012 Certificate of Service for Jones River Watershed Association and Pilgrim Watch Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention) ML12185A1382012-07-0303 July 2012 Jones River Watershed Association and Pilgrim Watch Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention) LBP 12-11, June 18, 2012 ML12160A4392012-06-0808 June 2012 Entergy'S Answer Opposing Jones River Watershed Association'S and Pilgrim Watch'S Motion to Reopen and Hearing Request on Contention Regarding Water-Related Approvals ML12159A5762012-06-0707 June 2012 NRC Staff'S Answer to Jones River Watershed Association and Pilgrim Watch'S Requests to Reopen the Record and File a New Contention on Water Quality ML12159A5772012-06-0707 June 2012 Notice of Appearance for Maxwell C. Smith ML12157A5742012-06-0505 June 2012 Notice of Appearance for Susan L. Uttal on Entergy Nuclear Operations, Inc., (Pilgrim) 2020-06-04
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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 June 23, 2011 Pilgrim Watch Memorandum -Submerged Cables The Region I Administrator, William Dean, was quoted today in the press saying that, submerged cables at nuclear plants (are) something that needs to be addressed. The news article reads, with pertinent paragraphs highlighted for the boards convenience, NRC says VY has operated safely By JOSH STILTS / Reformer Staff Posted: 06/23/2011 03:00:00 AM EDT http://www.reformer.com/localnews/ci_18334719 Thursday June 23, 2011 BRATTLEBORO - Just hours before the federal court was set to hear Entergy's lawsuit against the State of Vermont, members of Nuclear Regulatory Commission presented their yearly findings of the Vermont Yankee nuclear power plant.
Regional Administrator for the NRC, Bill Dean, met with members of the press before Wednesday's annual assessment meeting and said that from a safety stand point, Vermont Yankee is doing well.
"Particularly with all of the distractions, all of the doubts as to whether they're going to continue to operate, the plant has safely operated," Dean said.
Dean said that he hasn't seen any attrition and that staffing levels at the plant are good, that personnel are making good decisions and taking appropriate steps to complete corrective action.
There were eight green low-safety significant findings at the plant during 2010, according to the presentation.
Members of the audience were polarized on the issue how safely the Vermont Yankee plant is operated.
More than 200 people attended the meeting as members of the NRC and employees from Vermont Yankee tried to explain what measures have been taken at the plant to ensure that the disaster that happened in Japan isn't duplicated.
"Nuclear power plants in this country are safe to operate in light of what happened at Fukushima," Dean said.
"We're probably not going to get all the information for some time," he said.
Whatever happens to plant whether it continues to operates, is decommissioned or is held in stasis, the NRC is going to ensure that the plant either operates safely or is decommissioned safely, Dean said.
Technical consultant for the New England Coalition, Ray Shadis, urged members of the NRC staff to reexamine the mitigation of submerged electrical cables at the plant.
"NRC's job is safety, it's not about whether I like the color of the plant," he said. "NRC seems to comfort itself in public documents that we're not going to have an earthquake and a tsunami here."
Dean agreed that submerged cables at nuclear plants something that needs to be addressed.
Earlier this week, Shadis expressed his desire for civility during the hearing and trial which begins today. Dean said he appreciated what Shadis was saying.
Last week Sen. Bernie Sanders I-Vt., said that he was informed that members of the NRC had met with the United States Department of Justice about intervening in Entergy's lawsuit against Vermont and Jared Cobb called for the NRC to stay out of the lawsuit the crowd applauded.
Dean told the media before the meeting that he had no knowledge of a NRC vote on whether it should side with Entergy in its lawsuit against Vermont.
"I'm not aware of anything that has been done relative to the NRC to inject itself into the court hearing," he said. "Our Chairman (Gregory Jaczko) has repeatedly stated that the NRC will not intervene."
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There are certain rules and responsibilities, such as environmental and economic concerns that fall within the state's ability to regulate a plant, he said.
He also said that nuclear plants can operate in a "post-down mode" lowering the power output levels.
"They could shut down now and re-fuel next year," Dean said. "There are plenty of experiences in the past, Crystal River nuclear power plant in Florida, for example, they've been shut down for several years and were able to restart safely."
He added that if Entergy decided to purchase refueling materials to possibly be installed this fall and the court decided to not allow the plant to operate past March 2012, the fuel could be sold to another plant. (Emphasis added)
Conclusion We respectfully ask that this be included in the record as it serves to support Pilgrim Watchs Requests for Hearings filed on December 10, 2010 and January 20, 2011.
Respectfully signed, Mary lampert (Signed Electronically)
Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 Tel. 781-934-0389 Email: mary.lampert@comcast.net 3