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Category:Legal-Pleading
MONTHYEARML21328A2492021-11-24024 November 2021
Notice of Withdrawal of the People of the State of Illinoiss Hearing Request and Petition for Leave to Intervene
ML21225A7632021-08-13013 August 2021
People of the State of Illinoiss Reply to Exelons Answer to Their Request for a Hearing Regarding Exelon Generation Company, LLCs Facility Operating License Transfer Application
ML21218A1982021-08-0606 August 2021
Exelons Answer Opposing Petition of the State of Illinois for Leave to Intervene and Request for a Hearing
ML21218A1712021-08-0606 August 2021
Certificate of Service
ML21218A1702021-08-0606 August 2021
The Environmental Law and Policy Centers Reply to Applicants Answer
ML21211A5932021-07-30030 July 2021
Exelons Answer Opposing the Petition of the Environmental Law and Policy Center for Leave to Intervene and for a Hearing
ML21200A2292021-07-19019 July 2021
Reply to Exelons Answer Opposing Petition of Edf Inc. for Leave to Intervene and Request a Hearing
ML21193A3642021-07-12012 July 2021
Exelons Answer Opposing the Petition of Eric Joseph Epstein and Three Mile Island Alert, Inc for Leave to Intervene and for a Hearing
ML21193A3652021-07-12012 July 2021
Exelons Answer Opposing Petition of Edf Inc. for Leave to Intervene and Request for a Hearing
ML21193A3292021-07-12012 July 2021
Certificate of Service
ML21193A3282021-07-12012 July 2021
Notice of Appearance of Susan L. Satter
ML21181A3762021-06-30030 June 2021
Combined Motion of Exelon to File Its Answers to the Edf and Epstein-TMIA Hearing Requests on Illinois New Hearing Request Deadline and Motion of Elpc to Move Exelon Deadline to Answer Elpc Hearing Request to July 30 2021
ML21171A0092021-06-20020 June 2021
Exelons Answer Opposing the State of Illinoiss Motion to Yet Again Amend the Protective Order
ML21155A1212021-06-0404 June 2021
Joint Motion to Amend Protective Order
ML21155A1222021-06-0404 June 2021
Proposed Order Granting Joint Motion to Amend Protective Order
ML21141A3482021-05-21021 May 2021
Applicants Answer Opposing Environmental Law and Policy Centers Motion to Extend Hearing Request Deadline
ML21130A6782021-05-10010 May 2021
Joint Motion for Entry of a Protective Order
ML14273A5102014-09-24024 September 2014
NRDC V. NRC - DC Cir 13-1311 Joint Appendix
ML13316C4212013-11-12012 November 2013
Exelon'S Petition for Certification of Waste Confidence-Related Question to the Commission Pursuant to 10CFR2.323(f)(2)
ML13212A3832013-07-31031 July 2013
Natural Resources Defense Council'S Opposition to Exelon'S Motion for Clarification, or in the Alternative for Leave to Request Partial Reconsideration of the Board July 12 Order
ML13203A1622013-07-22022 July 2013
Exelon'S Motion for Clarification or, in the Alternative, for Leave to Request Partial Reconsideration of the Board'S July 12 Order
ML13189A3052013-07-0808 July 2013
Natural Resources Defense Council'S Reply in Support of Resubmission of Contentions
ML13175A2502013-06-24024 June 2013
Exelon'S Answer Opposing Natural Resources Defense Council'S Resubmission of Contentions in Response to Staff'S Supplemental Draft Environmental Impact Statement
ML13175A2142013-06-24024 June 2013
NRC Staff Answer to the Natural Resources Defense Council'S Resubmission of Contentions in Response to Staff'S Supplemental Draft Environmental Impact Statement
ML13130A3692013-05-10010 May 2013
Notice of Withdrawal for Maxwell C. Smith
ML13079A6622013-03-20020 March 2013
Exelon'S Reply Brief in Response to the Referral of LBP-13-1 to the Commission
ML13079A5512013-03-20020 March 2013
Natural Resources Defense Council'S Response Brief in Support of Waiver of 10 C.F.R. Section 51.53(c)(3)(ii)(L) as Applied to Application for Renewal of Licenses for Limerick Units 1 and 2
ML13079A5012013-03-20020 March 2013
NRC Staff Reply on the Boards' Referred Ruling in LBP-13-1
ML13072B4332013-03-13013 March 2013
Exelon'S Initial Brief in Response to the Referral of LBP-13-1 to the Commission
ML13072B0362013-03-13013 March 2013
Exhibit B for Natural Resources Defense Council'S Brief in Support of Waiver of 10 C.F.R. 52.53(c)(3)(ii)(L) as Applied to Application for Renewal of Licenses for Limerick Units 1 and 2
ML13072B0392013-03-13013 March 2013
Exhibit a for Natural Resources Defense Council'S Brief in Support of Waiver of 10 C.F.R. 52.53(c)(3)(ii)(L) as Applied to Application for Renewal of Licenses for Limerick Units 1 and 2
ML13072B0382013-03-13013 March 2013
Natural Resources Defense Council'S Brief in Support of Waiver of 10 C.F.R. 51.53(c)(3)(ii)(L) as Applied to Application for Renewal of License for Limerick, Units 1 & 2
ML13072A5162013-03-13013 March 2013
Amended Notice of Appearance of Brooke F. Mcglinn
ML13072A8042013-03-13013 March 2013
NRC Staff'S Brief on the Board'S Referred Ruling in LBP-13-1
ML12356A4932012-12-21021 December 2012
Reply of Natural Resources Defense Council in Support of Petition, by Way of Motion, for Waiver of 10CFR51.53(c)(3)(ii)(L) as Applied to Application for Renewal of Licenses for Limerick Units 1 & 2
ML12349A3842012-12-14014 December 2012
NRC Staff Answer to Natural Resources Defense Council Petition for Waiver of 10 C.F.R. 51.53(c)(3)(ii)(L)
ML12349A3292012-12-14014 December 2012
Exhibit a, Declaration of Christopher J. Weaver, Ph.D., on Behalf of the Natural Resources Defense Council in Support of Motion for Waiver
ML12349A3282012-12-14014 December 2012
Exelon'S Counter Affidavit Supporting Exelon'S Response Opposing Nrdcs Petition for Waiver of 10 C.F.R. Section 51.53(C)(3)(ii)(L)
ML12349A3272012-12-14014 December 2012
Exelons Response Opposing Nrdcs Petition for Waiver of 10 C.F.R. Section 51.53(C)(3)(ii)(L)
ML12215A5712012-08-0202 August 2012
Exelon'S Answer Opposing Nrdc'S New Waste Confidence Contention
ML12215A4572012-08-0202 August 2012
NRC Staff'S Response to Nrdc'S Motion for Leave to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at Limerick and Nrdc'S Waste Confidence Contention
ML12192A2422012-07-0909 July 2012
NRDC Errata Notice
ML12192A2412012-07-0909 July 2012
Nrdc'S Waste Confidence Contention - 1st Corrected
ML12192A3712012-07-0909 July 2012
2nd Errata Notice Waste Confidence Contention
ML12192A3702012-07-0909 July 2012
2nd Corrected NRDC Waste Confidence Contention
ML12188A0212012-07-0505 July 2012
NRDC Initial Disclosures Attachment C Corrected
ML12184A2412012-07-0202 July 2012
Attachment B to Nrdc'S Initial Disclosures - Documents Relevant to Contention E-1
ML12184A2422012-07-0202 July 2012
Attachment a to Nrdc'S Initial Disclosures - Potential Expert Witnesses Contention E-1
ML12184A2402012-07-0202 July 2012
Initial Disclosures NRDC Filed Pursuant to 10 C.F.R 2.336(a)
ML12128A3972012-05-0707 May 2012
Notice of Withdrawal of Lauren Woodall on Behalf of the U.S. Nuclear Regulatory Commission in the Matter of Limerick Generating Station, Units 1 and 2
2021-08-06
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of ) Docket Nos. 50-352-LR
) 50-353-LR EXELON GENERATION COMPANY, LLC )
)
(Limerick Generating Station, Units 1 and 2) ) September 26, 2011
)
EXELONS ANSWER TO NRDCS REQUEST FOR EXTENSION OF TIME On September 22, 2011, NRDC submitted a request to the Office of the Secretary to extend the deadline to file a Request for Hearing and Petition for Leave to Intervene (Request/Petition) to challenge the license renewal application for the Limerick Generating Station.1 Although submitted in letter format, the content requests relief from the Secretary, and should have been submitted as a Motion. See 10 C.F.R. § 2.323(a). Exelon Generation Company, LLC (Exelon) treats the letter as a motion for extension of time, and hereby submits this Answer in response, pursuant to 10 C.F.R. § 2.323(c).
Under the NRCs Federal Register2 announcing the opportunity to file a Request/Petition, the deadline for filing a Request/Petition is October 24, 2011. NRDC seeks a 30-day extension.
Exelon does not oppose NRDCs requested extension. However, a 30-day extension would move the due date for any Request/Petition to November 22, 2011, which is the Tuesday before 1
See Letter from G. Fettus to NRC, Office of the Secretary, Re: Extension of Time for Opportunity to Request a Hearing and Petition for Leave to Intervene in the NRCs Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Nos. NPF-39 and NPF-85 for an Additional 20-Year Period, Exelon Generation Company, LLC, Limerick, Generating Station, Docket ID NRC-2011-0166, Docket Numbers 50-352 and 50-353 (September 22, 2011) (Extension Request).
DB1/68197729.1
Thanksgiving. Exelon would request an additional five (5) calendar days to account for the interruption caused by the Thanksgiving holiday. Accordingly, if the Commission grants NRDCs request, and NRDC files a Request/Petition, then Exelon respectfully requests that the Commission extend Exelons time to answer from twenty-five (25) days, pursuant to 10 C.F.R.
§ 2.309(h)(1), to thirty (30) days. Counsel for Exelon contacted counsel for NRDC, and counsel for NRDC stated that he did not object to Exelons contingent request for an additional five days.
Respectfully submitted, Signed (electronically) by Alex S. Polonsky Alex S. Polonsky Kathryn M. Sutton Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Phone: 202-739-5830 Fax: 202-739-3001 E-mail: apolonsky@morganlewis.com Counsel for Exelon Generation Company, LLC 2
Notice of Acceptance for Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Nos. NPF-39 and NPF-85 for an Additional 20-Year Period (August 24, 2011).
DB1/68197729.1 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of ) Docket Nos. 50-352-LR
) 50-353-LR EXELON GENERATION COMPANY, LLC )
)
(Limerick Generating Station, Units 1 and 2) ) September 26, 2011
)
CERTIFICATE OF SERVICE I hereby certify that on September 26, 2011 a copy of the foregoing Exelons Answer to NRDCs Request for Extension of Time was filed electronically with the Electronic Information Exchange.
Office of the Secretary Office of the General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Rulemakings and Adjudications Staff Mail Stop O-15D21 Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: hearingdocket@nrc.gov ogcmailcenter@nrc.gov Catherine Kanatas catherine.kanatas@nrc.gov Office of Commission Appellate Adjudication Brian Newell U.S. Nuclear Regulatory Commission brian.newell@nrc.gov Mail Stop: O-16C1 Maxwell Smith Washington, DC 20555-0001 maxwell.smith@nrc.gov E-mail: ocaamail@nrc.gov Mary Spencer mary.spencer@nrc.gov Ed Williamson Geoffrey H. Fettus edward.williamson@nrc.gov Senior Project Attorney Natural Resources Defense Counsel 1152 15th St., N.W. ASLBP Washington, D.C. 20005 Chief Judge Roy Hawkens E-mail: gfettus@nrdc.org roy.hawkens@nrc.gov DB1/68197729.1
Signed (electronically) by Alex S. Polonsky Alex S. Polonsky Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Phone: 202-739-5830 Fax: 202-739-3001 E-mail: apolonsky@morganlewis.com COUNSEL FOR EXELON GENERATION COMPANY, LLC DB1/68197729.1 2
