Letter Sequence Request |
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EPID:L-2020-LLE-0050, Township of Lacey'S Petition for Leave to Intervene and Hearing Request (Open) |
Initiation
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- Acceptance...
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MONTHYEARML18312A2512018-11-0808 November 2018 Township of Lacey'S Petition for Leave to Intervene and Hearing Request Project stage: Request ML18324A6382018-11-16016 November 2018 Comments from the Concerned Citizens for Lacey Coalition Regarding the Oyster Creek Nuclear Generating Station Application for Direct Transfer of License Project stage: Request ML18337A4192018-12-0303 December 2018 Applicants' Joint Answer to Township of Lacey Project stage: Request ML19009A3262019-01-0707 January 2019 Comments from the Concerned Citizens of Lacey Coalition on Oyster Creek Nuclear Plant License Transfer Project stage: Request ML19008A4942019-01-15015 January 2019 Post-Shutdown Decommissioning Activities Report - NRC Presentation at Public Meeting on January 15, 2019 Project stage: Request ML19009A1712019-01-15015 January 2019 Post-Shutdown Decommissioning Activities Report, NRC Public Meeting January 15, 2019 Project stage: Request ML19009A3432019-01-15015 January 2019 Holtec Slides PSDAR Meeting 1-15-19 Project stage: Request ML19032A0732019-01-31031 January 2019 Comment (1) from Anonymous on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19046A0172019-02-13013 February 2019 Comment (2) from Anonymous on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19051A0192019-02-20020 February 2019 Watch Petition to Intervene and Hearing Request Project stage: Request ML19051A1142019-02-20020 February 2019 Commonwealth of Massachusetts' Petition for Leave to Intervene and Hearing Request Project stage: Request ML19057A1882019-02-24024 February 2019 Comment (3) of Anonymous Individual on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19057A1902019-02-24024 February 2019 Comment (4) from Anonymous Regarding Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19057A5692019-02-25025 February 2019 Comment from Jim R. Garb on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19060A2282019-02-26026 February 2019 Comment from Henrietta Cosentino on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19059A0232019-02-27027 February 2019 Comment (5) of Rebecca Chin on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19065A1802019-03-0101 March 2019 Comment (6) of David Noyes Supporting Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19070A1762019-03-0101 March 2019 Comments from Carolyn Barthel on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1612019-03-0101 March 2019 Comments from Chris Riger on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19065A1872019-03-0101 March 2019 Comment (7) of Henrietta Cosentino on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19060A2272019-03-0101 March 2019 Comment from the Associated Industries of Massachusetts on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1672019-03-0202 March 2019 Comments from Irene Paine on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1662019-03-0202 March 2019 Comments from Gertrude Carter on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1622019-03-0202 March 2019 Comments from David Agnew on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19065A2582019-03-0202 March 2019 Comment from James Sinclair on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19065A2572019-03-0202 March 2019 Comments from William Stewart on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1682019-03-0303 March 2019 Comments from Joan Holt on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1752019-03-0303 March 2019 Comments from Betsy Smith on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1742019-03-0303 March 2019 Comments from Barbara Clark on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1722019-03-0303 March 2019 Comments from Alex Bally on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1712019-03-0303 March 2019 Comments from Nicola Blake on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1702019-03-0303 March 2019 Comments from Lillia Frantin on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1692019-03-0303 March 2019 Comments from Lesley Phillips on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19064B3302019-03-0303 March 2019 Comment from James B. Lampert on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19065A1922019-03-0303 March 2019 Comment (9) of James B. Lampert on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19065A1882019-03-0303 March 2019 Comment (8) of Mary Gatslick on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19070A1642019-03-0303 March 2019 Comments from Diana Maher on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19065A1932019-03-0404 March 2019 Comment (10) of J. B. Lampert on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19065A1962019-03-0404 March 2019 Comment (11) of Guy Page on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19072A3122019-03-0404 March 2019 Comments from Guy Page on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19072A3142019-03-0404 March 2019 Comments from Commonwealth of Massachusetts on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1772019-03-0404 March 2019 Comments from Catherine Berkey on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19064B3312019-03-0404 March 2019 Comments from the Cape Downwinders and Boston Downwinders on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19064B3322019-03-0404 March 2019 Comment from Pilgrim Watch on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19064B3452019-03-0404 March 2019 Comment from Pine Dubois on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19070A1652019-03-0404 March 2019 Comments Received from Concerned Citizens of Massachusetts on the Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment (NRC-2018-0279) Project stage: Request ML19065A1982019-03-0404 March 2019 Comment (12) of Brad Ferland on Pilgrim Nuclear Power Station; Consideration of Approval of Transfer of License and Conforming Amendment Project stage: Request ML19109A1772019-04-17017 April 2019 Response to NRC Request for Additional Information Project stage: Response to RAI ML19114A5192019-04-24024 April 2019 Motion of the Commonwealth of Massachusetts to Supplement Its Petition with New Information Project stage: Request ML19129A4732019-05-0909 May 2019 Watch Motion to Supplement Its Motion to Intervene and Request for Hearing, Biodiversity (05.09.19) Project stage: Request 2019-02-25
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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 COMMISSION 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) )
MOTION OF THE COMMONWEALTH OF MASSACHUSETTS TO STAY PROCEEDING TO COMPLETE SETTLEMENT NEGOTIATIONS Petitioner, the Commonwealth of Massachusetts (Commonwealth or Massachusetts),
respectfully requests that the Nuclear Regulatory Commission (NRC or Commission) stay all activities in the above captioned proceeding for 90 days to permit the Commonwealth, Entergy Corporation (Entergy), and Holtec International (Holtec) (collectively, Negotiating Parties) to complete settlement negotiations. The Negotiating Parties have been engaged in settlement discussions regarding the Commonwealths Petition for Leave to Intervene and Hearing Request, Docket Nos. 50-293 & 72-1044, filed on February 20, 2019 (Petition). See Letter from Pamela Cowan to Attorney General Maura Healey, copying Margaret Doane, Executive Director of Operations, NRC (Jul. 17, 2019), attached hereto as Exhibit 1. The resolution of the settlement negotiations could resolve the Commonwealths Petition and prove valuable to the NRCs own decision-making process. To preserve the current positions of the parties and in light of the benefits to the NRC if the Negotiating Parties are able to reach an agreement, we ask that the NRC take no action on any of the pending requests for 90 days, or until the Negotiating Parties
jointly inform the NRC either that they have reached a settlement and the Commonwealth is withdrawing its Petition or that an agreement cannot be reached and the Commission should proceed to rule on the Commonwealths Petition, whichever occurs sooner.
The NRCs longstanding policy favors settlement rather than litigating adjudicatory proceedings. Sequoyah Fuels Corporation and General Atomics (Gore, Oklahoma Site Decontamination and Decommissioning Funding), ASLBP No. 94-684-01-EA, Dkt. No. 40-8027-EA, at 7 (Nov. 13, 1995) (ADAMS Accession No. ML13109A473). Consistent with Holtecs July 17 representation to the Commonwealth and the NRC, the Negotiating Parties are undertaking good faith discussions to finalize a resolution. Exhibit 1. Preliminary discussions between the Negotiating Parties began in late 2018, and a larger in-person meeting was held in late February 2019. Numerous phone calls and email exchanges transpired in the following months, culminating in an initial draft settlement provided by the Commonwealth to Entergy and Holtec, covering a broad range of issues, in mid-June 2019. As Holtec stated in its July 17 letter, it is still working on its response to the initial draft settlement, and is prepared to undertake good faith discussions to finalize a comprehensive agreement that will provide assurances to the citizens of the Commonwealth and associated stakeholders. Exhibit 1. A stay of the proceeding to complete settlement negotiations is consistent with this commitment. While settlement negotiation is not a magic phrase the invocation of which must bring the proceeding to a complete halt[,] Sequoyah Falls, at 7, it is the Commonwealths hope that upon receipt of Holtecs response, an agreement can be reached in the near term.
A stay of the proceeding will not prejudice the current decommissioning effort at Pilgrim.
Entergy is the current license holder and operator and will remain as such during the pendency of the stay. Further, Entergy recently received an exemption from the NRC to use the Pilgrim Decommissioning Trust Fund for certain non-decommissioning activities. Pilgrim Nuclear Power Station - Request for Exemption from 10 C.F.R. 50.82(a)(8)(i)(A), Dkt. No. 50-293 (Jul.
22, 2019) (ADAMS Accession No. ML19162A334). Thus, Entergy is responsible for, and capable of, maintaining decommissioning efforts during the pendency of the proceeding, and a temporary, time-limited stay will not affect that. Indeed, allowing a stay may provide a quicker resolution to the proceeding and be more administratively efficient. Should one or more of the Commonwealths Contentions set forth in its Petition be granted, then a fully adjudicated proceeding will result with full discovery opportunities and evidentiary hearings, requiring valuable time and attention from both the parties and the NRC. However, if the Negotiating Parties are permitted to finalize a settlement agreement, then this would resolve the Commonwealths issues in a timelier fashion and prevent the expending of the parties and NRCs resources. Thus, any minor prejudice caused by a stay is far outweighed by the benefit of reaching a comprehensive settlement.
The Commonwealth conferred with Entergy and Holtec regarding this Motion on August 1, 2019. Counsel for Entergy and Holtec indicated that they oppose this Motion. The Commonwealth also conferred with Petitioner Pilgrim Watch regarding this Motion on July 31, 2019. A representative of Pilgrim Watch indicated that Pilgrim Watch does not object to this Motion.
For the foregoing reasons, and for good cause shown, the Commonwealth requests that the Commission grant this Motion and take no action on any of the pending requests for 90 days, or until a settlement is reached and the Commonwealth withdraws its Petition or the parties notify the NRC that an agreement cannot be reached, whichever occurs sooner.
Respectfully submitted this 1st day of August, 2019, 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 joseph.dorfler@mass.gov UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION 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 Motion to Stay Proceeding to Complete Settlement Negotiations have been served upon the Electronic Information Exchange, the NRCs e-filing system, in the above-captioned proceeding this 1st day of August 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: August 1, 2019 EXHIBIT 1 KPS Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 - Fax (856) 797-0900 www.holtecinternational.com July 17, 2019 The Honorable Maura Healey Attorney General 20th Floor One Ashburton Place Boston, MA 02108-1598 Re: Decommissioning the Pilgrim Nuclear Power Station - Settlement Agreement
Dear Ms. Healey:
We received your proposed draft Settlement Agreement related to decommissioning Pilgrim.
This letter is to confirm that we are working diligently to respond to each of the wide-ranging requests therein and will provide a detailed response once fully vetted. Following your receipt of our response, we are prepared to undertake good faith discussions to finalize a comprehensive agreement that will provide assurances to the citizens of the Commonwealth and associated stakeholders.
Please know that we are committed to completing the decommissioning with the utmost protection for public health and safety and the environment. We look forward to continuing to work with the Commonwealth of Massachusetts and local officials throughout the project and continued amicable dialogue with your office to ensure the interests of the community are well served. Ultimately, Holtecs acquisition and cleanup of Pilgrim, in lieu of guardianship of a defunct plant, will create opportunities for reuse and is in the best interest of the Commonwealth and its local communities.
Sincerely, HOLTEC DECOMMISSIONING INTERNATIONAL, LLC Pamela B. Cowan Senior Vice President & Chief Operating Officer 1lPage
KPS Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 - Fax (856) 797-0900 www.holtecinternational.com Cc: Margaret Doane Executive Director of Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Seth Schofield Susan H. Raimo Andrew Ryan Senior Appellate Counsel Assistant General Counsel General Counsel Assistant Attorney General Entergy Services, LLC Holtec International Energy and Environment 101 Constitution Ave., NW, Suite 1 Holtec Blvd.
Bureau 200 East Camden, NJ 08104 Office of the Attorney Washington, DC 20001 A.Ryan@holtec.com General sraimo@entergy.com One Ashburton Place Boston, MA 02108-1598 seth.schofield@state.ma.us 2lPage