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Category:Legal-Pleading
MONTHYEARML22090A2712022-03-31031 March 2022 Constellation Response to Beyond Nuclear and Staff Views in Response to CLI-22-04 ML22090A2492022-03-31031 March 2022 Staff Response to Views on Practical Effects ML22090A2692022-03-31031 March 2022 Beyond Nuclear'S Response to Constellation Energy Generation, Llc'S and NRC Staff'S Views on CLI-22-04 ML22080A2752022-03-21021 March 2022 Renewed License - Attachment to NRC Staff Views ML22080A2762022-03-21021 March 2022 Renewed License - Attachment to NRC Staff Views ML22080A2742022-03-21021 March 2022 NRC Staff Views on the Practical Effects of (1) the Subsequent Renewed Licenses Continuing in Place and (2) the Previous Licenses Being Reinstated ML22080A2502022-03-21021 March 2022 Constellation Energy'S Response to Commission Request for Views in CLI-22-04 ML22076A0892022-03-17017 March 2022 Beyond Nuclear'S Response to Constellation Energy'S Petition for Partial Reconsideration of CLI-22-04 and Beyond Nuclear'S Views in Response to CLI-22-04 ML22066B3352022-03-0707 March 2022 Constellation Energy Generation'S Petition for Partial Reconsideration of CLI-22-04 ML22001A0032022-01-0101 January 2022 Notice of Withdrawal of Mitzi Young on Behalf of NRC Staff ML21328A2492021-11-24024 November 2021 Notice of Withdrawal of the People of the State of Illinois'S Hearing Request and Petition for Leave to Intervene ML21225A7632021-08-13013 August 2021 People of the State of Illinois'S Reply to Exelon'S Answer to Their Request for a Hearing Regarding Exelon Generation Company, Llc'S Facility Operating License Transfer Application ML21218A1702021-08-0606 August 2021 the Environmental Law and Policy Center'S Reply to Applicants Answer ML21218A1712021-08-0606 August 2021 Certificate of Service ML21218A1982021-08-0606 August 2021 Exelon'S Answer Opposing Petition of the State of Illinois for Leave to Intervene and Request for a Hearing ML21211A5932021-07-30030 July 2021 Exelon'S 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 Exelon'S Answer Opposing Petition of Edf Inc. for Leave to Intervene and Request a Hearing ML21193A3282021-07-12012 July 2021 Notice of Appearance of Susan L. Satter ML21193A3292021-07-12012 July 2021 Certificate of Service ML21193A3642021-07-12012 July 2021 Exelon'S 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 Exelon'S Answer Opposing Petition of Edf Inc. for Leave to Intervene and Request for a Hearing 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 Exelon'S Answer Opposing the State of Illinois'S 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 Center'S Motion to Extend Hearing Request Deadline ML21130A6782021-05-10010 May 2021 Joint Motion for Entry of a Protective Order ML20064H0952020-03-0404 March 2020 Notification of NRC Staff Communication with the Commission Regarding EPA ML20042F8342020-02-11011 February 2020 Notice of Availability of FSEIS ML19310G5512019-11-0606 November 2019 Notice of Withdrawal for Rebecca Susko ML19304A2062019-10-31031 October 2019 Exelon'S Answer Opposing Beyond Nuclear'S Motion for Leave to File Reply to Oppositions to Motion to Reopen the Record ML19304C5952019-10-31031 October 2019 NRC Staff Answer to Beyond Nuclear, Inc.'S Motion for Leave to Reply ML19294C3032019-10-21021 October 2019 Beyond Nuclear, Inc.'S Reply to Oppositions to Motion to Reopen the Record of Proceeding for Subsequent License Renewal of Peach Bottom Operating License ML19294C3052019-10-21021 October 2019 Beyond Nuclear, Inc.'S Motion for Leave to File Reply to Oppositions to Motion to Reopen the Record of Proceeding for Subsequent License Renewal of Peach Bottom Operating License ML19294C3082019-10-21021 October 2019 Beyond Nuclear, Inc.'S Reply to Oppositions to Motion for Leave to File a New Contention Based on Draft Supplement 10 to Generic Environmental Impact Statement for Subsequent License Renewal of Peach Bottom Operating License ML19276J7462019-10-0303 October 2019 NRC Staff Answer to Beyond Nuclear Inc.'S: Motion for Leave to File New Contention Based on Draft Supplement to Generic Environmental Impact Statement; and Motion to Reopen the Record and for Consideration of Arguments Out of Time ML19276F6132019-10-0303 October 2019 Exelon'S Answer Opposing Beyond Nuclear'S Motion for Leave to File a New Contention and Motion to Reopen the Record ML19265A0062019-09-22022 September 2019 Beyond Nuclear, Inc.'S Motion to Reopen the Record for Purposes of Considering and Admitting a New Contention Based on Draft Supplement 10 to Generic Environmental Impact Statement for Subsequent License Renewal of Peach Bottom ML19265A0072019-09-22022 September 2019 Beyond Nuclear, Inc.'S Unopposed Motion for Extension of Time to Reply to Exelon'S and NRC Staff'S Responses to Beyond Nuclear'S Motion for Leave to File New Contention ML19248D0922019-09-0505 September 2019 Errata to Beyond Nuclear, Inc.'S Motion for Leave to File New Contention Based on Draft Supplement 10 to Generic Environmental Impact Statement for Subsequent License Renewal of Peach Bottom Operating License ML19248D0952019-09-0505 September 2019 Beyond Nuclear, Inc.'S Motion for Leave to File New Contention Based on Draft Supplement 10 to Generic Environmental Impact Statement for Subsequent License Renewal of Peach Bottom Operating License (Corrected) ML19246C3012019-09-0303 September 2019 Beyond Nuclear, Inc.'S Motion for Leave to File New Contention Based on Draft Supplement 10 to Generic Environmental Impact Statement for Subsequent License Renewal of Peach Bottom Operating License ML19241B3712019-08-29029 August 2019 NRC Staff Answer to Beyond Nuclear Motion for Leave to Reply ML19241A3772019-08-29029 August 2019 Answer Opposing Beyond Nuclear'S Motion to File a Reply Brief ML19231A4722019-08-19019 August 2019 Beyond Nuclear Motion for Leave to Reply in Part to Oppositions to Beyond Nuclear'S Brief on Appeal of LBP-19-05 ML19231A4772019-08-19019 August 2019 Beyond Nuclear Reply Brief on Appeal of LBP-19-05 (Refiled) ML19231A4732019-08-19019 August 2019 Beyond Nuclear Reply Brief on Appeal of LBP-19-05 ML19221B5352019-08-0909 August 2019 Exelon'S Brief in Opposition to Beyond Nuclear'S Appeal of LBP-19-05 ML19221B7382019-08-0909 August 2019 NRC Staff Brief in Opposition to Beyond Nuclear Appeal of LBP-19-05 ML19196A3712019-07-15015 July 2019 Beyond Nuclear'S Notice of Appeal of LBP-19-05 2022-03-07
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY
)
In the Matter of )
Exelon Generation Company, LLC ) Docket Nos. 50-277/278 SLR Peach Bottom Atomic Power Station, )
Units 2 & 3 )
___________________________________ )
BEYOND NUCLEARS MOTION FOR EXTENSION OF DEADLINE FOR FILING HEARING REQUESTS Pursuant to 10 C.F.R. §§ 2.307 and 2.323, Beyond Nuclear hereby requests a two-week extension of the November 5, 2018 deadline for hearing requests and petitions to intervene in the above-captioned proceeding. See 83 Fed. Reg. 45,285 (Sept. 6, 2018). Beyond Nuclear respectfully submits that it has good cause to request an extension, as required by 10 C.F.R. § 2.307, due to the following circumstances:
This is only the second U.S. Nuclear Regulatory Commission (NRC) proceeding in which a licensee has sought approval of a subsequent license renewal (SLR) term.1 Due to the general lack of experience operating a nuclear plant for so many additional years beyond the initial term and first twenty-year renewal, theses cases raises unprecedented safety and environmental concerns that warrant careful and time-consuming review.
Beyond Nuclears legal-expert team (undersigned counsel and technical consultant David Lochbaum) is now reviewing Exelons Aging Management Plan for Peach Bottom Units 2 and 3 in light of NRC regulations, guidance for SLR applications, and current research on reactor aging issues. The process requires the time-consuming review of a large 1
The first is Turkey Point, now pending. See 83 Fed. Reg. 19,304 (May 2, 2018).
number of documents, regarding issues that are legally and technically complex, against guidance that is sometimes new and untested.
Beyond Nuclears legal/expert team must also balance this time-consuming work on the Peach Bottom SLR proceeding with other professional obligations. Since publication of the Peach Bottom hearing notice on September 6, for example, undersigned counsel has had significant briefing obligations in three other cases (Turkey Point SLR, Docket No.
50-250/251; Holtec Centralized Interim Storage Facility (CISF), Docket No. 72-1051; and Interim Storage Partners CISF, Docket No. 72-1050).
Under these circumstances, Beyond Nuclear has found that the 60-day period provided by the hearing notice is inadequate to prepare a hearing request. Therefore, Beyond Nuclear has good cause to request a modest extension of two weeks, until November 19, 2018.
Respectfully submitted,
___/signed electronically by/__
Diane Curran Harmon, Curran, Spielberg & Eisenberg, LLP 1725 DeSales St. N.W., Suite 500 Washington, D.C. 20036 October 18, 2018 CERTIFICATE OF COUNSEL PURSUANT TO 10 C.F.R. § 2.323(b)
I certify that on October 15, 2018, I contacted counsel for Exelon and the NRC Staff in an attempt to resolve the issue raised by this motion. Counsel for Exelon stated that Exelon intends to oppose the motion. Counsel for the NRC Staff stated that the Staff would not oppose the motion.
___/signed electronically by/__
Diane Curran 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY
)
In the Matter of )
Exelon Generation Company, LLC ) Docket Nos. 50-277/278 SLR Peach Bottom Atomic Power Station, )
Units 2 & 3 )
___________________________________ )
CERTIFICATE OF SERVICE I certify that on October 18, 2018, I posted the foregoing Beyond Nuclears Motion for Extension of Deadline for Filing Hearing Request on the NRCs Electronic Information Exchange.
___/signed electronically by/__
Diane Curran 3