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Category:Legal-Motion
MONTHYEARML20079J1802020-03-19019 March 2020
Unopposed Motion of the Commonwealth of Massachusetts to Correct a Previously Filed Declaration
ML20035C7562020-01-30030 January 2020
1-30-20 Entergy Motion to Intervene (DC Cir.)(Case No. 20-1019)
ML20031D4332020-01-29029 January 2020
1-29-20 Reply to Response to Motion to Dismiss (DC Cir.)(Case No. 19-1198)
ML19347D4152019-12-13013 December 2019
Motion of the Commonwealth of Massachusetts to Amend Its Petition with New Information
ML19303B4252019-10-28028 October 2019
Transport Room (Motion for Stay Pending Appellate Review)(Dc Cir.)(Case No. 19-1198) 10-28-19
ML19295E6852019-10-16016 October 2019
Entergy Motion to Intervene (DC Cir.)(Case No. 19-1198) 10-16-19
ML19247E5092019-09-0404 September 2019
Motion of the Commonwealth of Massachusetts for a Twenty-Two Minute Enlargement of Time to File Its Stay Application and Supporting Appendix
ML19247B4312019-09-0303 September 2019
Application of the Commonwealth of Massachusetts for a Stay of the Effectiveness of the NRC Staff Actions Approving the License Transfer Application and Request for an Exemption to Use the Decommissioning Trust Fund for Non-Decommissioning
ML19246A0322019-09-0303 September 2019
Watch Motion to Stay Staff Order of August 22, 2019 Granting Exemption
ML19246A0332019-09-0303 September 2019
Watch Motion Under 10 C.F.R 2.1327 to Stay Staff Order of August 22, 2019
ML19230A0212019-08-18018 August 2019
Reply of the Commonwealth of Massachusetts in Support of Its Motion for an Enlargement of Time to File an Application to Stay a Nuclear Regulatory Commission Staff Order Approving the License Transfer Application
ML19227A0682019-08-15015 August 2019
Emergency Motion of the Commonwealth of Massachusetts for Clarification of the Commission'S August 14, 2019 Memorandum and Order
ML19227A3982019-08-15015 August 2019
Emergency Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application to Stay a Nuclear Regulatory Commission Staff Order Approving the License Transfer Application
ML19213A3132019-08-0101 August 2019
Motion of the Commonwealth of Massachusetts to Stay Proceeding to Complete Settlement Negotiations
ML19129A3732019-05-0909 May 2019
Commonwealth of Massachusetts' Reply in Support of Motion to Supplement Its Petition with New Information
ML19129A4732019-05-0909 May 2019
Watch Motion to Supplement Its Motion to Intervene and Request for Hearing, Biodiversity (05.09.19)
ML19114A5192019-04-24024 April 2019
Motion of the Commonwealth of Massachusetts to Supplement Its Petition with New Information
ML19091A1892019-04-0101 April 2019
Watch Reply to Applicant'S Answer Opposing Pilgrim Watch Petition for Leave to Intervene and Hearing Request
ML19077A2092019-03-18018 March 2019
Notices of Appearance of David R. Lewis, Anne R. Leidich, and Susan H. Raimo
ML19077A2762019-03-18018 March 2019
Unopposed Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File Its Reply
ML12257A3392012-09-13013 September 2012
Filed Copy - Joint Motion to Amend Briefing Schedule - Massachusetts V NRC - 1st Cir 12-1404 and 12-1772
ML12195A0802012-07-13013 July 2012
Notice of Appearance for Joseph A. Lindell for ESA Roseate Term
ML12157A1872012-06-0505 June 2012
Notice of Appearance from Joseph A. Lindell on Entergy Nuclear Operations, Inc., (Pilgrim)
ML12137A2582012-05-16016 May 2012
Notice of Appearance for Joseph A. Lindell
ML12136A5172012-05-15015 May 2012
NRC Staff'S Unopposed Motion for an Extension of Time to Respond to Jones River Watershed Association and Pilgrim Watch'S May 14, 2012, Request to Reopen, for a Hearing and to File New Contentions
ML12132A4682012-05-11011 May 2012
Motion to Strike
ML12097A2222012-04-0505 April 2012
Entergy Motion to Strike Petitioners' Affidavit and Portions of Petitioners' Reply
ML11357A2092011-12-23023 December 2011
Commonwealth of Massachusetts' Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Appeal of LBP-11-35
ML11290A1812011-10-17017 October 2011
Commonwealth of Massachusetts Motion to Reply to NRC Staff Answer to Massachusetts Request to Stay Commission Decision on Pilgrim Watch Appeal or in the Alternative to Strike Reference to Massachusetts Expert
ML11258A0262011-09-15015 September 2011
Commonwealth of Massachusetts Amended Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Motion to Supplement Bases to Its Contention
ML11256A3042011-09-13013 September 2011
Commonwealth of Massachusetts Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Motion to Supplement Bases to Its Contention
ML11235B0962011-08-23023 August 2011
Applicant'S Motion for Issuance of Renewed License
ML11223A2842011-08-11011 August 2011
Commonwealth of Massachusetts Motion to Supplement Bases to Commonwealth Contention to Address NRC Task Force Report on Lessons Learned from the Radiological Accident at Fukushima
ML1115303402011-06-0202 June 2011
Commonwealth of Massachusetts' Motion to Admit Contention and, If Necessary, to Re-Open Record Regarding New and Significant Information Revealed by Fukushima Accident
ML1115303442011-06-0202 June 2011
Commonwealth of Massachusetts' Conditional Motion to Suspend Pilgrim Nuclear Power Plant License Renewal Proceeding Pending Resolution of Petition for Rulemaking to Rescind Spent Fuel Pool Exclusion Regulations
ML1113905722011-05-19019 May 2011
Commonwealth of Massachusetts Motion to Reply to Entergy'S Answer Opposing Commonwealth'S Joinder in Petition to Suspend the License Renewal Proceeding for the Pilgrim Nuclear Power Plant and Request for Additional Relief
ML1113905702011-05-19019 May 2011
Commonwealth of Massachusetts Motion to Reply to the Answers of the NRC Staff and Entergy in Opposition to the Commonwealth of Massachusetts Motion to Hold Licensing Decision in Abeyance Pending Commission Decision Weather to Suspend the Pi
ML1112203262011-05-0202 May 2011
Commonwealth of Massachusetts Motion to Hold Licensing Decision in Abeyance Pending Commission Decision Whether to Suspend the Pilgrim Proceeding to Review the Lessons of the Fukushima Accident
ML1102407012011-01-24024 January 2011
Entergy'S Motion to Strike Portions of Pilgrim Watch'S Reply to Entergy'S and the NRC Staff'S Answers Opposing Pilgrim Watch'S Request for Hearing on a New Contention
ML1101306682011-01-13013 January 2011
Entergy'S Motion in Limine to Exclude from Evidence Pilgrim Watch'S Sama Remand Pre-Filed Testimony and Exhibits
ML1100503302010-12-30030 December 2010
Entergy Request for Change in Hearing Date
ML1035004002010-12-13013 December 2010
Pilgrim Watch Request for Hearing on a New Contention: Inadequacy of Entergy'S Aging Management of Non-Environmentally Qualified (EQ) Inaccessible Cables (Splices) at Pilgrim Station
ML1032103122010-11-0404 November 2010
Pilgrim Watch Request Extension Submit Affidavits
ML1027800452010-10-0404 October 2010
NRC Staff'S Answer to Pilgrim Watch Motion Regarding ASLB Refusal to Respond to Pilgrim Watch'S Motion for Clarification
ML1027300422010-09-22022 September 2010
Pilgrim Watch Motion Regarding ASLB Refusal to Respond to Pilgrim Watch'S Motion for Clarification ASLB Order (Sept 2, 2010)
ML1025803182010-09-0909 September 2010
Pilgrim Watch Motion for Clarification ASLB Order (Sept. 02, 2010)
ML1017301822010-06-16016 June 2010
Motion Requesting Leave to File Response to Judge Paul B. Abramson Decision on Recusal Motion (June 10, 2010)
ML1015404252010-05-26026 May 2010
Pilgrim Watch Request for Permission, and Reply to NRC Staff'S Response to Pilgrim Watch Motion to Disqualify Judge Abramson
ML1014500892010-05-24024 May 2010
NRC Response to Pilgrim Watch Motion to Disqualify Judge Paul B. Abramson
ML1015404242010-05-24024 May 2010
Pilgrim Watch Request for Permission, and Reply to Entergy'S Opposition to Pilgrim Watch Motion to Disqualify Judge Abramson
2020-03-19
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May 15, 2012 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
ENTERGY NUCLEAR GENERATION ) Docket No. 50-293-LR COMPANY AND ENTERGY NUCLEAR )
OPERATIONS, INC. )
)
(Pilgrim Nuclear Generating Station) )
NRC STAFFS UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO RESPOND TO JONES RIVER WATERSHED ASSOCIATION AND PILGRIM WATCHS MAY 14, 2012, REQUEST TO REOPEN, FOR A HEARING AND TO FILE NEW CONTENTIONS Under 10 C.F.R. §§ 2.323(a) the NRC Staff (Staff) hereby requests an extension of time to respond to Jones River Watershed Association (JRWA) and Pilgrim Watch (PW)
Request to Reopen, for a Hearing, and to File New Contentions (Request).1 JRWA and PW (collectively Petitioners) filed the Request on May 14, 2012. This Atomic Safety and Licensing Boards (Board) Initial Scheduling Order provides for a fourteen day period to respond to any new or amended contentions in this proceeding.2 Thus, the deadline for a response to the Request would be May 29, 2012.3 For the following reasons, the Staff asks the Board to extend 1
Jones River Watershed Association (JRWA) and Pilgrim Watch (PW) Request to Reopen, for a Hearing, and to File New Contentions and JRWA Motion to Intervene On Issues Of: (1) Violations of State and Federal Clean Water Laws; (2) Lack of Valid State § 401 Water Quality Certification; (3) Violation of State Coastal Zone Management Policy; and (4) Violation o NEPA (May 14, 2012).
2 Order (Establishing Schedule for Proceeding and Addressing Related Matters), at 7 (Dec. 20, 2006) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML063540494) (Initial Scheduling Order).
3 May 28, 2012, is a government holiday, Memorial Day.
the fourteen day period for filing responses to new or amended contentions to twenty-five days.
- 1. The Boards Initial Scheduling Order provides for a fourteen day period to respond to new or amended contentions.4 NRC regulations normally provide for a twenty-five day response period for answers to new or amended contentions.5 In other proceedings, Boards have adopted a twenty-five day response period.6
- 2. Two of the Staffs Attorneys assigned to this proceeding have vacations scheduled during the fourteen-day response period provided for by the Boards order.
- 3. In accordance with 10 C.F.R. § 2.323(b), Staff counsel contacted counsel for Entergy and JRWA and the representative of PW regarding this motion. Entergy did not oppose the extension. JRWA and PW provided the following reply:
JRWA and PW will not oppose the request, subject to the caveat that its assent shall not be construed in any way to mean that JRWA and PW support the NRC staff and EDO position that Pilgrim can be issued a new 20 operating license before all of the outstanding contentions and legal appeals are fully litigated to their conclusion. JRWA states this position due to the fact that the staff NRC supported the EDO request to the NRC Commission to relicense Pilgrim by May 8, 2012, despite outstanding contentions and legal appeals. By agreeing to the extension for replying to our May 14, 2012 petition, to a date that will extend the time for JRWA's & PWs reply brief to after the June 8, 2012 licensing deadline, we are not agreeing in any way that Pilgrim can be issued a new operating license on June 8, 2012 while contentions are pending.
Therefore, neither the applicant nor PW and JRWA oppose the extension request.
4 Initial Scheduling Order at 7.
5 10 C.F.R. § 2.309(h)(1).
6 Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3),
Memorandum and Order (Summarizing Pre-hearing Conference), at 5 (Feb. 4, 2009) (ADAMS Accession No. ML090350569); Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.
(Vermont Yankee Nuclear Power Station), Initial Scheduling Order, at 6 (Nov. 17, 2006) (ADAMS Accession No. ML063210212).
Wherefore, the Staff respectfully requests that the Board extend the period of time for responding to the Request from fourteen to twenty-five days.
Respectfully submitted,
/Signed (electronically) by/
Maxwell C. Smith Counsel for NRC Staff U.S. Nuclear Regulatory Commission Mail Stop O-15D21 Washington, DC 20555-0001 (301) 415-1246 Maxwell.Smith@nrc.gov Dated at Rockville, Maryland this 15th day of May 2012
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
ENTERGY NUCLEAR GENERATION )
COMPANY AND ENTERGY NUCLEAR ) Docket No. 50-293-LR OPERATIONS, INC. )
)
(Pilgrim Nuclear Generating Station) )
CERTIFICATE OF SERVICE I hereby certify that copies of the NRC STAFFS UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO RESPOND TO JONES RIVER WATERSHED ASSOCIATION AND PILGRIM WATCHS MAY 14, 2012 REQUEST TO REOPEN, FOR A HEARING AND TO FILE NEW CONTENTIONS have been served upon the following by the Electronic Information Exchange this 15th day of May, 2012:
Administrative Judge Administrative Judge Richard F. Cole Paul B. Abramson Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop: T-3F23 Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: Richard.Cole@nrc.gov E-mail: Paul.Abramson@nrc.gov Administrative Judge Office of Commission Appellate Ann Marshall Young, Chair Adjudication Atomic Safety and Licensing Board Mail Stop: O-16G4 Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail:
E-mail: Ann.Young@nrc.gov Atomic Safety and Licensing Board Office of the Secretary Mail Stop: T-3F23 Attn: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Mail Stop: O-16G4 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission (VIA INTERNAL MAIL ONLY) Washington, DC 20555-0001 E-mail: Hearing.Docket@nrc.gov Sheila Slocum Hollis Terence A. Burke, Esq.
Duane Morris LLP Entergy Nuclear 505 9th St., NW, Suite 1000 1340 Echelon Parkway Washington, DC 20004 Mail Stop: M-ECH-62 E-mail: sshollis@duanemorris.com Jackson, MS 39213 E-mail: tburke@entergy.com
Mary Lampert David R. Lewis, Esq.
148 Washington Street Paul A. Gaukler, Esq.
Duxbury, MA 02332 Pillsbury, Winthrop, Shaw, Pittman, LLP E- mail: mary.lampert@comcast.net 2300 N Street, NW Washington, DC 20037-1137 E-mail: david.lewis@pillsburylaw.com paul.gaukler@pillsburylaw.com Chief Kevin M. Nord Town Manager Fire Chief & Director Duxbury Emergency Town of Plymouth Management Agency 11 Lincoln St.
668 Tremont Street Plymouth, MA 02360 Duxbury, MA 02332 E-mail: marrighi@townhall.plymouth.ma.us E-mail: nord@town.duxbury.ma.us Richard R. MacDonald Matthew Brock Town Manager Assistant Attorney General 878 Tremont Street Commonwealth of Massachusetts Duxbury, MA 02332 One Ashburton Place E-mail: macdonald@town.duxbury.ma.us Boston, MA 02108 Martha.Coakley@state.ma.us Margaret Sheehan Matthew.Brock@state.ma.us 61 Grozier Road Cambridge, MA 02138 Anne Bingham E-mail : meg@ecolaw.biz 78A Cedar St.
Sharon, MA 02067 Email:annebinghamlaw@comcast.net
/Signed (electronically) by/
Maxwell C. Smith Counsel for NRC Staff Dated at Rockville, Maryland this 15th Day of May 2012