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Category:Legal-Motion
MONTHYEARML20261H6042020-09-17017 September 2020 C-10 Research and Education Foundation'S Motion for Leave to File Reply to Oppositions to Motion for Partial Reconsideration of LBP-20-09 ML19310E6572019-11-0606 November 2019 NRC Staff'S Answer Opposing C-10'S Motion to Admit Additional Exhibit and Testimony ML19123A2092019-05-0303 May 2019 NRC Staff'S Answer to Nextera'S Motion in Limine ML17156A2782017-06-0505 June 2017 NRC Staff'S Motion for Leave to File a Sur-Reply to Nextera'S Reply to NRC Staff'S Answer to C-10's Petition for Leave to Intervene ML17142A2812017-05-22022 May 2017 NRC Staff Motion to Strike Portions of C-10's Reply ML17142A2822017-05-22022 May 2017 Motion to Strike - Attachment a ML15209A7432015-07-28028 July 2015 Motion to Withhold or Withdraw Final Environmental Impact Statement Pending Renewed Opportunity for Comment ML14063A5332014-03-0101 March 2014 Certificate of Service for Petition to Suspend Reactor Licensing Decisions ML14063A5322014-03-0101 March 2014 Certificate of Timely Submission of Petition to Suspend Reactor Licensing Decisions ML14063A5312014-02-27027 February 2014 Petition to Suspend Reactor Licensing Decisions and Reactor Re-Licensing Decisions Pending Completion of Rulemaking Proceeding Regarding Environmental Impacts of High-Density Pool Storage of Spent Fuel and Mitigation Measures ML13140A1392013-05-20020 May 2013 NRC Staff Motion for Extension of Time of File Answers to Nextera Motions for Summary Disposition of Contentions 4B & 4D ML13130A2152013-05-10010 May 2013 Nextera'S Motion for Summary Disposition of Friends of the Coast/New England Coalition Contention 4D (SAMA Analysis Atmospheric Modeling) ML13130A2142013-05-10010 May 2013 Nextera'S Motion for Summary Disposition of Friends of the Coast/New England Coalition Contention 4B (SAMA Analysis Source Terms) ML13122A4632013-05-0202 May 2013 Joint Motion on Timing of Summary Disposition Motions ML12270A0602012-09-26026 September 2012 Corrected Friends/Nec Exhibit 2, Seabrook Alkali-Silica Reaction Issue Technical Team Charter ML12270A0612012-09-26026 September 2012 Correction to Supplement to Friends of the Coast and New England Coalition Petition for Leave to File a New Contention Regarding NextEra Energy Seabrook License Renewal Application Structures Monitoring Program Supplement-Alkali-Silica Reac ML12265A4102012-09-21021 September 2012 Friends of the Coast and New England Coalition'S Motion (with September 19, 2012) Corrections for Leave to File a New Contention Concerning Nextera Energy Seabrook'S Amendment of Its Aging Management Program for Safety-Related Concrete Stru ML12265A3942012-09-21021 September 2012 Supplement to Friends of the Coast & New England Coalition'S Motion for Leave to File New Contention Re NextEra Energy Seabrook'S Amendment of Its Aging Management Program for Safety-Related Concrete Structures ML12265A3862012-09-21021 September 2012 Joint Motion to Modify Initial Scheduling Order ML12265A3962012-09-21021 September 2012 Friends/Nec Exhibit Two: Request for Additional Information for the Review of the Seabrook Station, License Renewal Application - Set 19 ML12265A3972012-09-21021 September 2012 Corrections & Supplement to Friends of the Coast & New England Coalition Petition for Leave to File a New Contention ML12265A3932012-09-14014 September 2012 Friends/Nec Exhibit Three: Request for Additional Information for the Review of the Seabrook Station, License Renewal Application - Set 19 ML12265A3982012-09-13013 September 2012 Friends/Nec Exhibit 4: Union of Concerned Scientists Requests That NextEra Begin a Systematic Conditional Assessment During Seabrook'S Refueling ML12265A3952012-09-0505 September 2012 Friend/Nec Exhibit One: Request for Deviation from Reactor Oversight Process Action Matrix to Provide Increased Oversight of Alkali-Silica Reaction Issue at Seabrook ML12191A4192012-07-0909 July 2012 Certificate of Services for Intervenors' Motion for Leave to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at Seabrook Station, Unit 1 ML12191A4182012-07-0909 July 2012 Transmittal of Intervenors' Motion for Leave to File a New Contention Temporary Storage and Ultimate Disposal of Nuclear Waste at Seabrook Station, Unit 1 ML12191A4202012-07-0909 July 2012 Intervenors' Motion for Leave to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at Seabrook Station, Unit 1 ML12158A2802012-06-0505 June 2012 Beyond Nuclear, Motion for Intervention ML11312A0382011-11-0707 November 2011 Petitioners' Withdrawl of Motion of October 28, 2011 for Leave to Supplement Basis of Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report ML11301A2412011-10-28028 October 2011 Motion for Leave to Supplement Basis of Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report ML11301A2422011-10-28028 October 2011 Certificate of Service for Motion for Leave to Supplement Basis of Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report ML11301A2292011-10-28028 October 2011 Joint Motion Regarding Mandatory Disclosures ML11273A1752011-09-30030 September 2011 Joint Motion to Amend the Initial Scheduling Order ML11223A3752011-08-11011 August 2011 (Beyond Nuclear, Seacoast Antipollution League, Sierra Club of Nh) Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-ichi Accident ML11223A3762011-08-11011 August 2011 (Beyond Nuclear, Seacoast Antipollution League, Sierra Club of Nh) Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report ML11223A4432011-08-11011 August 2011 (Friends of the Coast, New England Coalition) Motion to Admit New Contention Regarding Safety & Environmental Implications of Nuclear Regulatory Commission Task Force Report on Fukushima Dai-ichi Accident ML11221A1012011-08-0909 August 2011 NextEra Energy Seabrook, LLCs Motion to Amend the Initial Scheduling Order ML1113602232011-05-16016 May 2011 Answer of NextEra Energy Seabrook, LLC Opposing Motion to Permit Unauthorized Reply ML1113603952011-05-16016 May 2011 NRC Staff'S Answer to Petitioners' Motion for Modification of the Commission'S April 19, 2011, Order to Permit a Consolidated Reply ML1113603962011-05-16016 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 ML1112604732011-05-0606 May 2011 Petitioners' Motion for Modification of the Commission'S April 19, 2011, Order to Permit a Consolidated Reply ML1112608092011-05-0606 May 2011 Certificate of Service for Petitioners' Motion for Modification of Commission'S April 19, 2011, Order to Permit Consolidated Reply, and Reply to Responses to Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related. ML1112608102011-05-0606 May 2011 Certificate Regarding Consultation ML1112608112011-05-0606 May 2011 Petitioners' Reply to Responses to 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 ML1112608122011-05-0606 May 2011 Petitioner'S Motion for Modification of the Commission'S April 19, 2011, Order to Permit a Consolidated Reply ML1112604762011-05-0606 May 2011 Petitioners' Reply to Responses to 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 ML1112604752011-05-0606 May 2011 Certificate Regarding Consultation ML1112604742011-05-0606 May 2011 Certificate of Service for Motion for Modification of Order to Allow Reply and Certificate of Consultation ML1106805342011-03-0909 March 2011 Commonwealth of Massachusetts' Request to Participate as an Interested State ML1106801332011-03-0808 March 2011 Friends of the Coast and New England Coalition, Inc. Request for Extension of Time 2020-09-17
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September 21, 2012 Administrative Judge Administrative Judge Paul S. Ryerson, Chair Dr. Michael F. Kennedy Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop: T-3F23 Mail Stop: T-3F23 Washington, DC 20555-0001 Washington, DC 20555-0001 Administrative Judge Dr. Richard E. Wardwell Atomic Safety and Licensing Board Mail Stop: T-3F23 Washington, DC 20555-0001 In the Matter of NEXTERA ENERGY SEABROOK, LLC (Seabrook Station, Unit 1)
Docket No. 50-443-LR RE: Corrections and Supplement to Friends of the Coast and New England Coalition Petition for leave to File a New Contention Regarding NextEra Energy Seabrook License Renewal Application Structures Monitoring Program Supplement-Alkali-Silica Reaction (ASR) Monitoring
Dear Administrative Judges:
Friends of the Coast and New England Coalition (Friends/NEC), intervenors in the above captioned matter hereby provide a Supplement and Corrections to our August 27, 2012 petition seeking leave to file a new contention regarding the NextEra Energy Seabrook License Renewal Application Structures Monitoring Program Supplement-Alkali-Silica Reaction (ASR) Monitoring.
On September 14, 2012, the NRC published plans for a deviation in the Reactor Oversight Process (ROP) to seek assurance that NextEra has adequately assessed the extent and progress of ASR-related concrete degradation of safety-related structures at Seabrook Station and that NextEra will develop a concrete structures inspection and monitoring program that will retain operability of affected concrete structures through the term of Seabrooks current license to 2032 [ never mind the proposed period of extend operation; through 2052].
On September 17, 2012, NRC published Requests for Additional Information, Set 19, which concerns inadequacies in the NextEras responses to the NRCs May 16, 2012, Confirmatory Action Letter, Seabrook Station, Unit 1 -Information Related to Concrete Degradation Issues, dealing with management of ASR in affected Seabrook Station structures.
And, on September 13, 2012, C-10 Research Foundation and Union of Concerned Scientists (UCS) Advised NRC by letter of their profound concerns with inadequacies in the approach to ASR at Seabrook Station.
Friends/NEC believes that the C-10/UCS Letter and following documents:
- ML12242A370, Request for Deviation from the Reactor Oversight Process Action Matrix to Provide Increased Oversight of the Alkali-Silica Reaction Issue at Seabrook (Added To ADAMS September 14, 2012) and
- ML121250588 Seabrook Alkali-Silica Reaction Issue Technical Team Charter (Added To ADAMS September 14, 2012) and ;
- Ml12250A707, Requests for Additional Information for the Review of the Seabrook Station, License Renewal Application -Set 19 (Added to ADAMS September 17, 2012, constitute new information, material to a decision on admittance of the proposed new contention; thus information which the parties have an obligation to provide to the Atomic Safety and Licensing Board (Board) in a prompt and timely fashion. Also, Friends/NEC offers that these documents, not available when the petition was filed, support and provide additional basis for the proposed contention:
The NextEra Energy Seabrook License Renewal Application, as amended by the Structures Monitoring Program Supplement-Alkali-Silica Reaction (ASR) Monitoring, (dated May 16, 2012 and provided to Friends/NEC in NRC Staff Disclosures, July 6, 2012) fails to demonstrate as required by Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, Section 21(a)(3), of Title 10 of the Code of Federal Regulations (10 CFR 54.21(a)(3)), that the effects of aging on structures and components subject to an aging management review (AMR) are adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation.
Therefore, Friends/NEC is providing the documents as a supplement containing language that simply draws a nexus between the petition and NRCs expressed misgivings regarding NextEras plans for managing determination and preservation of operability of ASR-affected structures.
In preparing this supplemental filing, Friends/NEC reviewed the Petition itself and perceived a number of typographical and scriveners errors, which for the sake of the record and the convenience of readers have now been corrected and are now being forwarded in a corrected version , together with an errata and corrections index so that readers need not hunt for changes.
Friends/NEC regrets any inconvenience or concern for the Board and the parties resulting from either the supplement or the corrected petition. The deadline for filing answers to the petition looms within a few days so parties preparing answers may feel burdened by the timing of this filing. Friends/NEC respectfully offers that if the parties need extra time to fold an answer to this filing into their answer to the petition, or to answer this filing separately, it should be accorded; and the Boards consideration and decision regarding the proposed new Friends/NEC contention delayed as appropriate.
Sincerely, Signed (electronically) by Raymond Shadis Friends of the Coast/
New England Coalition Post Office Box 98 Edgecomb, Maine 04556 Date of signature: September 21, 2012