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Category:Legal-Motion
MONTHYEARML23347A2102023-12-13013 December 2023
Petitioners’ Memorandum in Opposition to Holtec Motion for Secretary Order Denying Petition for a Hearing on Exemption
ML23345A1372023-12-11011 December 2023
Motion for Secretary Order Denying Beyond Nuclear Et Al.S Petition for Hearing on Exemption Request
ML23058A2032023-02-27027 February 2023
Joint Motion for the Correction of Hearing Transcript
ML23053A1682023-02-22022 February 2023
Joint Motion to Close the Hearing Record
ML22361A9542022-12-27027 December 2022
Joint Motion to Extend Deadline for Motion to Strike
ML22354A1622022-12-20020 December 2022
Joint Motion Regarding Amended Protective Order
ML22238A3302022-08-26026 August 2022
Joint Motion Regarding Mandatory Disclosures and Proposed Protective Order
ML22203A1362022-07-22022 July 2022
Joint Motion for Extension of Time to Provide Initial Disclosures
NRC-2021-0036, Memorandum of Beyond Nuclear, Michigan Safe Energy Future and Don'T Waste Michigan in Opposition to Applicant'S Motion to Strike Late Responses2021-04-16016 April 2021
Memorandum of Beyond Nuclear, Michigan Safe Energy Future and Don'T Waste Michigan in Opposition to Applicant'S Motion to Strike Late Responses
ML21104A4272021-04-14014 April 2021
Reply of Beyond Nuclear, Michigan Safe Energy Future and Don'T Waste Michigan in Opposition to Applicants' Motion to Strike Portions of Beyond Nuclear Et Al.'S Reply and Second Declaration of Robert Alvarez
ML21055A4112021-02-24024 February 2021
Reply in Support of Motion to Extend Deadlines for Filing of Intervention Petitions and Public Comments in Palisades License Transfer Proceeding
ML21054A2122021-02-23023 February 2021
Motion to Extend Deadlines for Filing of Intervention Petitions and Public Comments in Palisades License Transfer Proceeding
ML18347B0662018-12-13013 December 2018
Intervenors' Motion for Production by the Regulatory Staff of Post Operational Inspection Reports
ML15219A4272015-08-0707 August 2015
Motion for Permission to File Amicus Brief
ML15180A4092015-06-29029 June 2015
Entergy'S Motion to Defer Initial Disclosures
ML15020A7402015-01-20020 January 2015
Petitioners' Combined Reply in Support of Amended Petition to Intervene and for a Public Adjudication Hearing of Entergy License Amendment Request for Authorization to Implement 10 CFR Section 50.61a, 'Alternate Fracture Toughness Requireme
ML14351A5272014-12-17017 December 2014
Applicant'S Unopposed Motion for Extension of Time to File Answer to Petition to Intervene and Request for Hearing
ML12132A4682012-05-11011 May 2012
Motion to Strike
ML0805706922008-02-26026 February 2008
Consent Motion of Entergy Nuclear Operations, Inc. for Expedited Commission Approval of Revised Filing Schedule and Applicant'S Conforming Request for Extension of Time to File Answer to Uwua Locals Petition to Intervene
ML0618405432006-07-0303 July 2006
NRC Staff Opposition to Request for Redraft of EIS, Additional Comment Period, and for New Period for Receipt of Contentions on Terrorism
ML0618001592006-06-22022 June 2006
Notice of Pertinent New Case Law Affecting Proceeding; Request for Redraft of EIS, Additional Comment Period, and for New Period for Receipt of Contentions on Terrorism
ML0604101472006-02-0303 February 2006
Nuclear Management Company'S Answer to Petitioners' Motion to Strike, Stay Proceeding and Take Deposition
ML0619804722005-10-0606 October 2005
Petitioners' Combined Response in Opposition to NRC Staff and Nuclear Management Company Motions to Strike
ML0527705282005-09-26026 September 2005
Nuclear Management Company'S Motion to Strike Petitioners' September 16, 2005 Combined Reply to NRC Staff and Nuclear Management Company Answers
ML0525602522005-09-0606 September 2005
Nuclear Management Company'S Response Opposing Petitioners' Motion for Rescheduling
ML18347B2811980-05-14014 May 1980
Motion to Compel
2023-02-27
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UNITED STATES OF AMERICA NULCEAR REGULATORY COMMISION BEFORE THE COMMISSION In the Matter of: )
) Docket No. 50-255-LA-2 ENTERGY NUCLEAR OPERATIONS, INC.,)
) August 7, 2015 (Palisades Nuclear Plant) )
MOTION BY SIERRA CLUB FOR PERMISSION TO FILE AMICUS BRIEF Comes now the Sierra Club, pursuant to 10 C.F.R. § 2.315, and in support of this Motion for Permission to File Amicus Curiae Brief, states to the Commission as follows:
- 1. The Sierra Club supports the decision of the ASLB in this case granting the Intervenors a hearing on their contention regarding Entergys license amendment request.
- 2. The Sierra Club is the nations largest grassroots environmental organization, with over 600,000 members. Its Michigan Chapter has approximately 16,000 members. The Sierra Club supports sustainable energy alternatives that do not harm the environment. The Sierra Club opposes nuclear power because its fuel cycle from uranium mining to spent radioactive fuel poses grave dangers to the environment. In addition, reliance on nuclear power unjustifiably delays the beneficial transition to clean and renewable energy sources.
- 3. With specific reference to the Palisades Nuclear Plant and the embrittlement of the reactor vessel at the
plant, members of the Michigan Chapter are at risk if the embrittled reactor vessel shatters and disperses radioactive material into the environment. This can affect the air, water and soil upon which Michigan residents depend. Therefore, the attempt by Entergy to shortcut assurances that the reactor pressure vessel is safe poses grave risks to the Sierra Club and its members in the Michigan Chapter.
- 4. The Sierra Clubs amicus curiae brief is desirable in this case because it will present the perspective of the many Sierra Club members who are residents of Michigan and are affected by the outcome of this case. The brief will also emphasize the far-reaching impacts of a decision in this case. A decision allowing Entergy to avoid testing the material in the pressure vessel would be a bad precedent for actions involving embrittlement at other aging reactors.
- 5. Pursuant to 10 C.F.R. § 2.323(b), undersigned counsel certifies that he has contacted the other parties to this proceeding about the filing of the Sierra Clubs amicus curiae brief. The Intervenors have no objection to the filing of the brief. Entergy Nuclear Operations and the NRC staff have no objection to the filing of the amicus curiae brief but reserve the right to respond to it.
- 6. The amicus curiae brief is hereto attached.
WHEREFORE, the Sierra Club requests permission to file an amicus curiae brief in support of the ASLB decision.
/s/ Wallace L. Taylor WALLACE L. TAYLOR Law Offices of Wallace L. Taylor 118 3rd Ave. S.E., Suite 326 Cedar Rapids, Iowa 52401 319-366-2428;(Fax)319-366-3886 e-mail: wtaylorlaw@aol.com ATTORNEY FOR SIERRA CLUB CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on August 7, 2015, copies of Sierra Clubs Motion for Permission to File Amicus Brief were served upon the Electronic Information Exchange (the NRCs E-Filing System) in the above-captioned proceeding.
/s/ Wallace L. Taylor WALLACE L. TAYLOR
