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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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July 5, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board Panel In the Matter of )
)
Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR
)
(Pilgrim Nuclear Power Station) )
ENTERGY RESPONSE AND OBJECTION TO PILGRIM WATCH MEMORANDUM - SUBMERGED CABLES Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc. (collectively Entergy) hereby respond and object to Pilgrim Watch Memorandum - Submerged Cables (June 23, 2011) (PW Memorandum). Pilgrim Watchs Memorandum is yet another unauthorized post-hearing filing by Pilgrim Watch.1 For the reasons set forth in Entergys April 22, 2011 Objection and the NRC Staffs Response to Pilgrim Watch Memorandum -
Submerged Cables (June 30, 2011), the Atomic and Safety Licensing Board should disregard Pilgrim Watchs latest attempt to supplement the record and argue the merits of its contention.
Respectfully submitted
/Signed Electronically by Paul A. Gaukler/
David R. Lewis Paul A. Gaukler PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037-1128 Tel. (202) 663-8000 E-mail: paul.gaukler@pillsburylaw.com Dated: July 5, 2011 Counsel for Entergy 1
See Entergys Objection to Pilgrim Watchs Post-Hearing Memoranda and Other Unauthorized Filings (April 22, 2011) (Entergys April 22, 2011 Objection).
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR
)
(Pilgrim Nuclear Power Station) )
CERTIFICATE OF SERVICE I hereby certify that copies of Entergy Response and Objection to Pilgrim Watch Memorandum - Submerged Cables, were provided to the Electronic Information Exchange for service on the individuals below, this 5th day of July, 2011.
Secretary Office of Commission Appellate Adjudication Attn: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Mail Stop O-16 C1 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission E-mail: OCAAMAIL@nrc.gov Washington, DC 20555-0001 hearingdocket@nrc.gov Administrative Judge Administrative Judge Ann Marshall Young, Esq., Chair Dr. Paul B. Abramson 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 Ann.Young@nrc.gov Paul.Abramson@nrc.gov Administrative Judge Atomic Safety and Licensing Board Dr. Richard F. Cole Mail Stop T-3 F23 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop T-3 F23 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Richard.Cole@nrc.gov
Susan L. Uttal, Esq. Matthew Brock, Assistant Attorney General Andrea Z. Jones, Esq. Commonwealth of Massachusetts Brian Harris, Esq. Office of the Attorney General Beth Mizuno, Esq. One Ashburton Place Office of the General Counsel Boston, MA 02108 Mail Stop O-15 D21 Martha.Coakley@state.ma.us U.S. Nuclear Regulatory Commission Matthew.Brock@state.ma.us Washington, DC 20555-0001 Susan.Uttal@nrc.gov; andrea.jones@nrc.gov; brian.harris@nrc.gov; beth.mizuno@nrc.gov Ms. Mary Lampert Sheila Slocum Hollis, Esq.
148 Washington Street Duane Morris LLP Duxbury, MA 02332 505 9th Street, NW mary.lampert@comcast.net Suite 1000 Washington, DC 20006 sshollis@duanemorris.com Mr. Mark D. Sylvia Richard R. MacDonald Town Manager Town Manager Town of Plymouth 878 Tremont Street 11 Lincoln St. Duxbury, MA 02332 Plymouth, MA 02360 macdonald@town.duxbury.ma.us msylvia@townhall.plymouth.ma.us Chief Kevin M. Nord Katherine Tucker, Esq.
Fire Chief and Director, Duxbury Emergency Law Clerk, Management Agency Atomic Safety and Licensing Board Panel 688 Tremont Street Mail Stop T3-E2a P.O. Box 2824 U.S. Nuclear Regulatory Commission Duxbury, MA 02331 Washington, DC 20555-0001 nord@town.duxbury.ma.us Katie.Tucker@nrc.gov
/Signed Electronically by Paul A. Gaukler/
Paul A. Gaukler 2
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