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Category:Legal-Pleading
MONTHYEARML12118A4642012-04-27027 April 2012
Energy Northwest'S Answer to Request for Hearing
ML11318A2742011-11-14014 November 2011
NRC Staff'S Answer to Petition for Review of LBP-11-27
ML11318A2032011-11-14014 November 2011
Energy Northwest'S Answer in Opposition to Petition for Review of LBP-11-27
ML11311A3032011-11-0707 November 2011
NRC Staff'S Response to Northwest Environmental Advocates' Motion to Reinstate and Supplement the Basis for Fukushima Task Force Report Contention
ML11311A2992011-11-0707 November 2011
Energy Northwest'S Answer in Opposition to Motion to Reinstate and Supplement the Basis for Fukushima Task Force Report Contention
ML11265A0782011-09-21021 September 2011
Petitioner'S Memorandum in Reply to Oppositions to Admission of Contention
ML11265A0772011-09-21021 September 2011
Certificate of Service for Petitioner'S Memorandum in Reply to Oppositions to Admission of Contention, and Reply Memorandum Regarding Timeliness and Admissibility of New Contentions . . .
ML11259A2392011-09-16016 September 2011
Energy Northwest'S Answer in Opposition to Petition for Hearing and Leave to Intervene
ML11259A2412011-09-16016 September 2011
Certificate of Service for Energy Northwests Answer in Opposition to Petition for Hearing and Leave to Intervene, and the Notices of Appearance of Angel D. Rains and Steven P. Frantz and the Notice of Withdrawal of Pamela R. Bradley
ML11258A3202011-09-15015 September 2011
NRC Staff'S Answer to Petition for Hearing and Leave to Intervene
ML11265A0792011-09-13013 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
ML1113610522011-05-16016 May 2011
Energy Northwest'S Answer in Opposition to Petitioners' Motion to Permit a Consolidated Reply
ML1113603832011-05-16016 May 2011
NRC Staff'S Answer to Petitioners' Motion for Modification of the Commission'S April 19, 2011, Order to Permit a Consolidated Reply
ML1113603822011-05-16016 May 2011
Certificate of Service for NRC Staff'S Answer to Petitioners' Motion for Modification of the Commission'S April 19, 2011, Order to Permit a Consolidated Reply
ML1112205502011-05-0202 May 2011
Notices of Appearance of Pamela R. Bradley, Kathryn M. Sutton, and Raphael P. Kuyler on Behalf of Energy Northwest
ML1112205492011-05-0202 May 2011
Energy Northwests Answer in Opposition to Emergency Petition to Suspend Licensing Proceedings
ML1112205482011-05-0202 May 2011
Certificate of Service for Energy Northwest'S Answer in Opposition to Emergency Petition to Suspend Licensing Proceedings, and Notices of Appearance of Pamela Bradley, Kathryn Sutton, and Raphael Kuyler on Behalf of Energy Northwest
ML1112205452011-05-0202 May 2011
Certificate of Service for NRC Staff'S Answer to Emergency Petition to Suspend All Pending Reactor Licensing Decisions & Related Rulemakings Decisions Pending Investigation of Lessons Learned from Fukushima Daiichi Nuclear Power Station Acc
ML1112205442011-05-0202 May 2011
Notice of Appearance of Maxwell C. Smith on Behalf of the U.S. Nuclear Regulatory Commission in the Matter of the Columbia Generating Station
ML1112205432011-05-0202 May 2011
NRC Staff Answer to Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemakings Decisions Pending Investigation of Lessons Learned from Fukushima Daiichi Nuclear Power Station Accident
ML1110808692011-04-18018 April 2011
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
2012-04-27
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of )
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ENERGY NORTHWEST ) Docket No. 50-397-LR
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(Columbia Generating Station) ) September 21, 2011
__________________________________________)
PETITIONERS MEMORANDUM IN REPLY TO OPPOSITIONS TO ADMISSION OF CONTENTION Pursuant to 10 C.F.R. § 2.309(h)(2), the Petitioner hereby replies to the oppositions submitted by the applicant, Energy Northwest, and the U.S. Nuclear Regulatory Commission (NRC) Staff to Petitioners contention seeking consideration of the environmental implications of the Fukushima Task Force Report. Petitioner respectfully submits that the arguments by applicant and the NRC Staff regarding the timeliness and admissibility of the contention are without merit and the contention should be admitted.
The arguments raised by the applicant and the NRC Staff in response to Petitioners contention are similar or identical to arguments made by the applicant and staff in response to Fukushima Task Force Report-related contentions that were filed in other reactor licensing proceedings a few days before the one in the instant proceeding.
Petitioner attaches and incorporates by reference the attached Reply Memorandum, which addresses the most common arguments that are made in the responses and was
prepared by counsel for intervenors in several of the cases.1 The Reply Memorandum also discusses the effect of the NRC Commissioners recent decision regarding the Emergency Petition that was submitted by Petitioner and many other intervenors and petitioners in April 2011. Union Electric Co., d/b/a/ Ameren Missouri (Callaway Plant, Unit 2) et al., CLI-11-05, __ NRC __ (Sept. 9, 2011) (CLI-11-05).2 Respectfully submitted, this 21st day of September, 2011.
(signed electronically by)
Nina Bell, Executive Director Northwest Environmental Advocates P.O. Box 12187 Portland, OR 97212-0187 503-295-0490 E-mail: nbell@advocates-nwea.org 1
The Reply Memorandum was prepared by Diane Curran (counsel for the intervenor in the Diablo Canyon license renewal proceeding and Watts Bar operating license proceeding), Mindy Goldstein (counsel for some of the intervenors in the Vogtle and Turkey Point COL proceedings), and Jason Totoui (counsel for some of the intervenors in the Turkey Point COL proceeding).
2 Because the applicant and the NRC Staff have not had an opportunity to address the effect of CLI-11-05 on the timeliness and admissibility of Petitioners contention, Petitioner would not object to a response by the applicant and the Staff to their arguments regarding the relevance of CLI-11-05 to their contention.
