Similar Documents at Salem |
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Category:Legal-Correspondence
MONTHYEARML0931001372009-11-0505 November 2009
E-mail from Ray P. Kuyler, Counsel for PSEG Nuclear in Response to Petitioner'S Request for Extension of Time to File a Request for Hearing and Petition to Intervene
ML0931001452009-11-0404 November 2009
Letter from Alex Polonsky, Counsel for PSEG Nuclear in Response to Nov. 2, 2009 Request for Extension of Time to File by Delaware Riverkeeper and the New Jersey Environmental Federation
ML0931001552009-11-0404 November 2009
2009/11/04- Notice of Appearances of Vincent C. Zabielski, Kathryn M. Sutton, Alex S. Polonsky, and Raphael P. Kuyler, Counsel for PSEG Nuclear in the Salem 1 and 2 License Renewal Proceeding
ML0931001532009-11-0404 November 2009
2009/11/04- Notice of Appearances by Vincent C. Zabielski, Kathryn M. Sutton, Alex S. Polonsky, and Raphael P. Kuyler, Morgan, Counsel for PSEG Nuclear in the Hope Creek License Renewal Proceeding
ML0931001522009-11-0404 November 2009
2009/11/04- Letter from Alex Polonsky, Counsel for PSEG Nuclear Petitioner'S Request for Extension of Time to File a Request for a Hearing in the Hope Creek License Renewal Proceeding
ML0931006172009-11-0202 November 2009
2009/11/02- Letter to Chairman Jaczko from Jane Nogaki, Nj Environmental Federation Requesting a 60 Day Extension to File a Hearing Request in the Hope Creek and Salem 1 and 2 License Renewal Proceedings
ML0931006042009-11-0202 November 2009
2009/11/02 - Email from Fred Stein, Maya K. Van Rossum, Delaware Riverkeeper Requesting a 60 Day Extension to File a Request for Hearing in the Hope Creek and the Salem 1 and 2 License Renewal Proceeding
ML0309700872003-03-25025 March 2003
Rothschild Inc.'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period February 1, 2003 - February 28, 2003
ML0234003322002-12-0606 December 2002
Memorandum from Emile L. Julian to Recipients of Letter Dated 12/04/02 from Annette L. Vietti-Cook to Norm Cohen Regarding DD-02-03
ML19029A8491981-02-17017 February 1981
02/17/1981 Certificate of Service on Copies of Licensee'S Response to Briefs in Support of Exceptions of Lower Alloways Creek Township and Mr. and Mrs. Alfred C. Coleman, Jr
ML19029A8531980-11-30030 November 1980
11/30/1980 Legal Correspondence Intervenors' Exception to Initial Decision of October 27, 1980
ML19029A8851980-05-13013 May 1980
Certificate of Service of Copies of Licensee'S Request for Extension of Time & Response to NRC Staff Motion for Extension of Time & Licensee'S Proposed Transcript Corrections for the Evidentiary Hearings of 3/28-29/1980.
ML19029A8861980-05-0202 May 1980
05/02/1980 Legal Correspondence Delaware'S Corrections of Transcript
ML19029A8781980-04-10010 April 1980
04/10/1980 Legal Correspondence Licensee'S Response to Licensing Board Question 5 on 'Gross Loss of Water' from the Salem Spent Fuel Pool
ML19029A8811980-04-0909 April 1980
04/09/1980 Legal Correspondence Submittal of Technical Report of Dr. Richard E. Webb in Response to ASLB Order of February 22, 1980
ML19029A8791980-04-0909 April 1980
04/09/1980 Legal Correspondence Written Testimony and Qualifications of Dr. David B. Fankhauser, in Response to ASLB Order of February 22, 1980
ML19029A8821980-04-0707 April 1980
04/07/1980 Legal Correspondence Intervenors' Inability to Prepare Written Testimony in Requisite Time to Most Recent Question Posed by Board
ML19029A7781979-12-13013 December 1979
Informing Licensee'S Installation Procedure for Increased Capacity Spent Fuel Racks Has Been Submitted
ML19029A7651979-08-31031 August 1979
Certify Copies of Licensee'S Response to Motion for Reconsideration of Coleman'S Contention No. 13 & Licensee'S Response to Motion to Re-open Coleman'S Contention 2 & 6 for Receipt of Newly Discovered Evidence.
ML19029A7641979-08-31031 August 1979
Licensee'S Response to Motion for Reconsideration of Colemans' Contention No. Thirteen
ML19029A7551979-08-22022 August 1979
Unit #1 - Intervenors', Coleman, Response to Boards Question Number Four: Was TMI a Class Nine Accident?
ML19029A7601979-08-10010 August 1979
Applicant'S Request for an Extension of Time to Respond to Intervenors' Motion to Reopen Coleman'S Contentions Two & Six for Receipt of Newly Discovered Evidence & Motion for Reconsideration of Dismissal of Coleman'S Contention No. 13.
ML19029A8181979-06-26026 June 1979
06/26/1979 Licensee'S Answer to Motion by Intervensors, Coleman, to Compel Supplementation of Answers to Interrogatories by Licensee
ML19029A8211979-06-25025 June 1979
Intervenor Township of Lower Alloways Creek Response to NRC Staff Objection to Board Question
ML19029A8231979-06-18018 June 1979
Licensee'S Response to NRC Staff Objection to Board Question and Motion for Extension of Time to File Response to Board Question Relating to Class 9 Accidents
ML19029A8251979-06-14014 June 1979
Enclosed Brief on Behalf of Interveners in Opposition to Staff'S Objection to Board'S Consideration of Impacts of Class Nine Accident on Salem Spent Fuel Pool
ML19029A8281979-06-12012 June 1979
06/12/1979 Legal Correspondence Response to the Atomic Safety and Licensing Board Order Dated April 18, 1979
ML19029A8301979-06-11011 June 1979
06/11/1979 Legal Correspondence Intervenor Township of Lower Alloways Creek Motion for Extension of Time to Respond to NRC Staff Objection to Board Question
ML19029A8541979-04-26026 April 1979
04/26/1979 Legal Correspondence Professional Qualifications of Warren S. Nechodom
ML19029A8631979-04-25025 April 1979
04/25/1979 State of New Jersey'S Outline of Cross-Examination
ML19029A8611979-04-25025 April 1979
04/25/1979 Licensee'S Outline of Cross-Examination
ML19029A8601979-04-25025 April 1979
04/25/1979 Legal Correspondence Outline of Cross-Examination of Evidence Submitted by the Nuclear Regulatory Commission
ML19029A8581979-04-25025 April 1979
04/25/1979 Legal Correspondence Outline of Areas of Cross-Examination
ML19029A8571979-04-25025 April 1979
04/25/1979 Intervenors' Response to ASLBP Order Dated April 18, 1979
ML19029A8561979-04-25025 April 1979
04/25/1979 Outline of Intervenors, Colemans, Cross-Examination; Contentions Two and Six
ML19029A8641979-04-24024 April 1979
04/24/1979 Legal Correspondence Non-Proprietary Version of Exxon Nuclear Company'S Report on Fuel Storage Racks Corrosion Program
ML19029A8671979-04-23023 April 1979
04/23/1979 Licensee'S Objections to Intervenors' Profferred Testimony
ML19029A8731979-04-12012 April 1979
04/12/1979 Legal Correspondence Application for Stay by the Township of Lower Alloways Creek
ML19029A8741979-04-11011 April 1979
04/11/1979 Legal Correspondence Intervenors Submit Their Proposed Direct Testimony to Be Elicited from Robert M. Crockett, Vice President for Fuel Supply, Public Service Electric and Gas Company
ML19029A8771979-04-0707 April 1979
04/07/1979 Legal Correspondence Township of Lower Alloways Creek Objections to Prehearing Order and Requests for Revision of Order or Recertification
ML19029A4421979-04-0202 April 1979
Letter Re Prehearing Conference to Fulfill the Requirements by the ASLBP for the Identification of Written Testimony and the Proposed Order or Proof
ML19029A8471979-04-0202 April 1979
04/02/1979 Legal Correspondence Identification of Written Testimony to Be Filed
ML19029A4541979-03-26026 March 1979
Interveners, Colemans' Memorandum in Opposition to the Licensee'S Motion for Summary Disposition, Interveners' Statement of Material Facts in Dispute Pertaining to Contention Two
ML19029A4571979-03-20020 March 1979
Interested State of Delaware'S Answer to Licensee'S Motion for Summary Judgment
ML19029A4591979-03-12012 March 1979
Intervenor Township of Lower Alloways Creek'S Answer to Motion for Summary Disposition
ML19029A4601979-03-12012 March 1979
Request for Report & Correspondence for Constituent'S Inquiry
ML19029A4641979-03-0707 March 1979
Intervenors, Colemans, Motion to Consolidate Prehearing Conference with Special Prehearing Conference for Purposes of Prehearing Order
ML19029A4651979-03-0606 March 1979
Letter Re Resolution Which Was Approved & Adopted by Township Committee of Township of Pennsville
ML19029A4691979-02-27027 February 1979
Public Service Electric & Gas Co. - Licensee'S Memorandum in Support of Its Motion for Summary Disposition
ML19029A4731979-02-16016 February 1979
Resolution Opposing Storage of High Level Radioactive Wastes in Lower Alloways Creek Township
2009-11-05
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Text
UNITED STATES OF AMERIO{\** -
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In The Matter of )
) Docket No.~
PUBLIC SERVICE ELECTRIC & ) Proposed Is~
GAS COMPANY ) of Amendment to
) Facility Operating (Salem Nuclear Generating ) License No. DPR-70.
Station, Unit No. 1) )
- ANSWER BY THE TOWNSHIP OF LOWER--.ALLOWAYS CREEK TO NOTICE OF HEARING ON AMENDMENT OF FACILITY OPERATING LICEN:m Pursuant to the provisions of 10CFR 2.705 and pursuant to the Notice of Hearing on Amendment of Facility Operating License docketed in this proceeding on April 27, 1978 the Township of Lower Alloways Creek, a party to this proceeding by virtue of its admission as an i*ntervenor, hereby states by way of Answer to said Notice of Hearing as follows:
- 1. The nature of its position is that it continues to seek the admission of each of the eleven (11) cnntentions
that it set forth in its Petition for Intervention as specific issues to be 6onsidered in the hearings on the application by Public Service Electric & Gas Company
- for its requested amendmen.t to its facility operating license No. DPR-70 which is the subject of this proceeding.
- 2. Since the Licensing Board has not yet determined the specific issues to be considered at the hearing and since these specific issues are not set forth in the Notice of Hearing the Township of Lower Alloways Creek at this time cannot state the items of the specification of issues it controverts and those it does not controvert .
- 3. The Township of Lower Alloways Creek intends to appear at the hearing and present evidence.
- 4. Since the issues have not yet been specified there are no facts alleged which .cctn be admitted or denied in this Answer nor affirmative defenses or positions to
'be stated other than the eleven (11) contention~ ~et forth in the Petition to Int.ervene by the Township of Lower ..
Alloways Creek, which eleven (11) contentions are hereby incorporated by reference as its position.
- 5. The Township of Lower Alloways Creek does not oppose the holding of a pre-hearing conference followed by a hearing on the proposed amendment of the facility operating license.
" 6. The Township of Lower Alloways Creek does oppose the views of the Atomic Safety and Licensing Board designated to rule over Petitions for Leave to Intervene pertaining to its contentions 2, 4, 5, 6, 7, 8, 9, 10 and 11 as expressed in said Board's Memorandum and Order dated April 26, 1978 and plans to address those views and to defend and further develop and clarify its contentions and to urge thei~ acceptance, in modified form where necessary, as contentions and specific issues to be considered at the hearing.
Respectfully submitted, Dated: LOWER ALLOWAYS CREEK TOWNSHIP By: l-t ::LL-- [ (/k-v_,,
1 William C. Horner Its Attorney 67 Market Street Salem, NJ 08079
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before The Atomic Safety And Licensing Board
)
In The Matter Of )
) Docket No. 50-272 PUBLIC SF.RVICE ELECTRIC & ) Proposed Issuance GAS COMPANY ) of Amendment to
) Facility Operating (Salem Nuclear Generating ) License No. DPR-70.
Station, Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of the attached "Answer By The Township Of Lower Alloways Creek To Notice Of Hearing On Amendment Of Facility Operating License" were served upon the persons listed on the attachment to this Certificate of Service by deposit in the United States mail (first class),
postage prepaid, this 16th day of May, 1978.
Attorney for Lower Alloways Creek Township 67 Market Street Salem, NJ 08079
SERVICE LIST Gary L. Milkollin, Esquire Chairman .
Atomic Safety & Lice~sing Board 1815 Jefferson Street Madison, Wisconsin 53711 Mr. Glenn 0. Bright Member Atomic Safety & Licensing Board Panel U.S. Nuclea.r Regulatory Cornmis sion Washington, D.C. 20555 Dr. James C. Lamb, III Member Atomic SafE!ty & Licensing Board Panel 313 Woo.dhaven Road Chapel Hill, N.C. 27514 I. Chairman, Atomic Safety & Licensing Board tJ *. S. Nuclear Regulatory Commission Washington, D.C. 20555 Troy B. Conner, Jr., Esquire
Washington;* D. C. 20006 Barry Smith, Esquire Office of th Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Rex William Potter, Esquire
- Assistant Deputy Public Advocate Sandra T. Ayres Assistant Deputy Public Advocate 520 East State Street Trenton, NJ 08625 Richard Fryling, Jr., Esquire Assistant General Solicitor Puhlic Service Electric & Gas Company 80 Park Place Newark, NJ 07101 Office of the Secretary Docketing & Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mark L. First, Esquire Deputy Attorney General Department of Law & Public Safety
- 36 West State Street Trenton, NJ 08625
