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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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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY In the Matter of )
)
ENTERGY NUCLEAR OPERATIONS, INC., )
ENTERGY NUCLEAR GENERATION )
COMPANY, AND HOLTEC ) Docket Nos. 50-293 & 72-1044 DECOMMISSIONING INTERNATIONAL, )
LLC; CONSIDERATION OF APPROVAL OF )
TRANSFER OF LICENSE AND )
CONFORMING AMENDMENT )
)
(Pilgrim Nuclear Power Station) )
UNOPPOSED MOTION OF THE COMMONWEALTH OF MASSACHUSETTS FOR AN ENLARGEMENT OF TIME TO FILE ITS REPLY Pursuant to 10 C.F.R. § 2.307, Petitioner, the Commonwealth of Massachusetts (Commonwealth or Massachusetts), respectfully requests a brief enlargement of time to file its reply to the Applicants Answer Opposing the Commonwealths Petition for Leave to Intervene and Hearing Request, which spans sixty-four pages, from March 25, 2019 up to and including April 1, 2019. The Applicants, Entergy Nuclear Operations, Inc. (Entergy), Holtec International, and Holtec Decommissioning International, LLC, 1 do not object to this request. In support of this motion, the Commonwealth states as follows:
- 1. This matter concerns the Commonwealths petition for leave to intervene and hearing request under 10 C.F.R. § 2.309 on the Applicants License Transfer Application (Application or LTA), Holtecs unconditioned Exemption Request to use Pilgrims Decommissioning Trust Fund for site restoration and spent fuel management costs (incorporated into the LTA by LTA 1
In this Petition, Entergy refers to Entergy Nuclear Operations, Inc. and Entergy Nuclear Generation Company, and Holtec refers to Holtec International and Holtec Decommissioning International, LLC.
), and Holtecs Revised Post-Shutdown Decommissioning Activities Report (PSDAR) and Site-Specific Cost Estimate (incorporated into the LTA by LTA Attachment D).
On February 20, 2019, the Commonwealth filed its petition for leave to intervene and hearing request. On March 18, 2019, the Applicants filed their response to the petition. The Commonwealths reply is currently due on or before March 25, 2019.
- 2. This matter raises issues that are of critical importance to the Commonwealth, its agencies, and its residents. Undersigned counsel for the Commonwealth are in the midst of very busy schedules and need the requested additional time to ensure that they have enough time to review and research the issues raised by the Applicants in their lengthy answer and to draft a reply that is appropriate given the significant nature of the matter. For example, undersigned counsel Schofield is lead counsel on a multi-state brief for a case pending before the U.S. Court of Appeals for the First Circuit, which raises complicated constitutional issues and that is due on April 12, 2019. Given the nature of that case and the level of review, the preparation time for that brief will coincide with preparation of the Commonwealths reply in this matter. Similarly, undersigned counsel Dorfler has a rate case hearing before the Massachusetts Department of Public Utilities currently scheduled for April 8, 2019 through April 12, 2019, which will also require preparation that will coincide with preparation of the Commonwealths reply in this matter.
- 3. The Commonwealths reply is also subject to review by management in the Attorney Generals Office and in executive agencies of the Commonwealth, including the Executive Office on Energy and Environmental Affairs. Undersigned counsel thus also needs the requested additional time to ensure that there is sufficient time to complete that process prior to the filing date.
- 4. The Commonwealth consulted with the Applicants regarding this motion pursuant to 10 C.F.R. § 2.323, on March 15, 2019. Counsel for the Applicants has courteously indicated that the Applicants do not object to this requested enlargement of time. The Commonwealth also conferred with Petitioner Pilgrim Watch regarding this motion. A representative of Pilgrim Watch indicated that Pilgrim Watch does not oppose the requested enlargement of time, but specifically asked that any enlargement of time granted to the Commonwealth for filing its reply also apply to Pilgrim Watch.
For the foregoing reasons, and for good cause shown, the Commonwealth requests that the Secretary grant this motion and modify the current deadline by which the Commonwealth must serve its reply to the Applicants answer to the petition for leave to intervene and hearing request from March 25, 2019 up to an including April 1, 2019.
Respectfully submitted this 18th day of March, 2019, Respectfully submitted, COMMONWEALTH OF MASSACHUSETTS By their attorneys, MAURA HEALEY ATTORNEY GENERAL Signed (electronically) by SETH SCHOFIELD Senior Appellate Counsel JOSEPH DORFLER Assistant Attorney General Energy and Environment Bureau One Ashburton Place, 18th Floor Boston, Massachusetts 02108 617-963-2000 seth.schofield@mass.gov Dated: March 18, 2019 joseph.dorfler@mass.gov UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY In the Matter of )
)
ENTERGY NUCLEAR OPERATIONS, INC., )
ENTERGY NUCLEAR GENERATION )
COMPANY, AND HOLTEC ) Docket Nos. 50-293 & 72-1044 DECOMMISSIONING INTERNATIONAL, )
LLC; CONSIDERATION OF APPROVAL OF )
TRANSFER OF LICENSE AND )
CONFORMING AMENDMENT )
)
(Pilgrim Nuclear Power Station) )
CERTIFICATION OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that copies of the Commonwealth of Massachusettss Petition for Leave to Intervene and Hearing Request and the Five attached Declarations have been served upon the Electronic Information Exchange, the NRCs e-filing system, in the above-captioned proceeding this 18th day of March 2019.
Signed (electronically) by Joseph Dorfler Assistant Attorney General Energy & Telecommunications Division One Ashburton Place, 18th Floor Boston, Massachusetts 02108 617-963-2086 Joseph.Dorfler@mass.gov Dated: March 18, 2019