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Category:Legal-Pleading
MONTHYEARML20177A6212020-06-25025 June 2020
Applicants Status Report
ML20156A0502020-06-0404 June 2020
Joint Motion of Applicants and the Commonwealth of Massachusetts for a Stay of Issuance of a Decision on the Pending Petitions for Intervention and a Hearing
ML20014E7632020-01-14014 January 2020
Commonwealth of Massachusetts' Reply in Support of Motion to Amend Its Petition with New Information
ML20007E9182020-01-0707 January 2020
Applicants' Answer Opposing the Commonwealth of Massachusetts' Second Motion to Supplement Its Petition with New Information
ML19343C6922019-12-0909 December 2019
Applicants' Answer Opposing Pilgrim Watch'S Third Motion to Supplement Its Motion to Intervene and Request for Hearing
ML19329B3242019-11-25025 November 2019
Watch Motion to Supplement Its February 20, 2019 Motion to Intervene and Request for Hearing, Its April 1, 2019 Reply to Petitioners, and Its May 3, 2019 Motion to Supplement
ML19284E8962019-10-11011 October 2019
Notice of Appearance and Substitution of Counsel
ML19256B9952019-09-13013 September 2019
Applicant'S Answer Opposing Pilgrim Watch'S Stay Motions
ML19256B9602019-09-13013 September 2019
Applicants' Answer Opposing the Application of the Commonwealth of Massachusetts for a Stay
ML19255K4112019-09-12012 September 2019
Reply of the Commonwealth of Massachusetts in Support of Its Motion for a Twenty-Two Minute Enlargement of Time to File Its Stay Application and Supporting Appendix
ML19252A3332019-09-0909 September 2019
Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts for a Twenty-Two Minute Enlargement of Time to File Its Stay Application
ML19246B1762019-09-0303 September 2019
Applicants Unopposed Motion for Clarification of Time to Respond to Pilgrim Watch Motion for Stay of Exemption
ML19234A3582019-08-22022 August 2019
Notice of Appearance - Anita Ghosh Naber
ML19231A1542019-08-19019 August 2019
Watch Reply to Applicants' Answer Opposing Pilgrim Watch'S Motion to File a New Contention
ML19228A0902019-08-16016 August 2019
Pilgrm Watch Memorandum in Support of Emergency Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application to Stay a NRC Staff Order Approving the License Transfer Application
ML19228A1672019-08-16016 August 2019
Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application for Stay
ML19228A1622019-08-16016 August 2019
Notice of Appearance and Substitution of Counsel
ML19227A2902019-08-15015 August 2019
Watch Memorandum in Support of Emergency Motion of the Commonwealth of Massachusetts for Clarification of the Commission'S August 14, 2019 Memorandum and Order
ML19224C4242019-08-12012 August 2019
Applicants' Answer Opposing Pilgrim Watch'S Motion to File a New Contention
ML19217A3682019-08-0505 August 2019
Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts to Stay Proceedings to Complete Settlement Negotiations
ML19197A3302019-07-16016 July 2019
Watch Motion to File a New Contention
ML19137A0732019-05-17017 May 2019
Applicants' Answer Opposing Pilgrim Watch'S Motion to Supplement Its Motion to Intervene and Request for Hearing
ML19126A0502019-05-0606 May 2019
Watch Reply to Applicants Answer Opposing Pilgrim Watch Motion to Supplement Its Motion to Intervene and Request for Hearing May 6, 2019 Its Motion to Intervene and Request for Hearing (May 6, 2019)
ML19122A1262019-05-0202 May 2019
Applicant'S Answer Opposing Pilgrim Watch Motion to Supplement Its Motion to Intervene and Request for Hearing
ML19122A1222019-05-0202 May 2019
Applicant'S Answer Opposing the Commonwealth of Massachusetts Motion to Supplement Its Petition with New Information
ML19116A1622019-04-26026 April 2019
Watch Motion to Supplement Its Motion to Intervene and Request for Hearing. New Information
ML19091A2972019-04-0101 April 2019
Commonwealth of Massachusetts' Reply in Support of Petition for Leave to Intervene and Hearing Request
ML19077A1902019-03-18018 March 2019
Notice of Appearances for Mary E. Lampert and James B. Lampert
ML19077A2352019-03-18018 March 2019
Applicants' Answer Opposing Pilgrim Watch Petition for Leave to Intervene and Hearing Request
ML19077A2322019-03-18018 March 2019
Applicants' Answer Opposing the Commonwealth of Massachusetts' Petition for Leave to Intervene and Hearing Request
ML19052A1872019-02-21021 February 2019
Exhibit 4 to Pilgrim Watch Petition to Intervene and Hearing Request
ML19052A1902019-02-21021 February 2019
Exhibit 5 to Pilgrim Watch Petition to Intervene and Hearing Request
ML19051A0192019-02-20020 February 2019
Watch Petition to Intervene and Hearing Request
ML19052A1822017-07-31031 July 2017
Exhibit 2 to Pilgrim Watch Petition to Intervene and Hearing Request
ML17095A3642017-04-0505 April 2017
Status of Decision on Petitioners Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109
ML17048A5712017-02-17017 February 2017
Status of Decision on Petitioners Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109
ML16285A3782016-10-11011 October 2016
Petitioners' Response to NRC Staff'S and Entergy'S Opposition to Peitioners' Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109
ML16277A5482016-10-0303 October 2016
Entergy Answer Opposing Request for Hearing Regarding Pilgrim and EA-13-109
ML16277A5612016-10-0303 October 2016
NRC Staff Response to Pilgrim Watch and Co-Petitioners Request for Hearing
ML16277A4652016-10-0303 October 2016
Notice of Appearance for Marcia Simon
ML16277A2102016-10-0303 October 2016
Notice of Appearance for Robert Carpenter
ML16277A4712016-10-0303 October 2016
Notice of Appearance for Matthew Ring
ML12195A0912012-07-13013 July 2012
NRC Staff'S Answer to Jones River Watershed Association and Pilgrim Watch'S Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention
ML12195A1692012-07-13013 July 2012
Entergy'S Answer Opposing Jones River Watershed Association and Pilgrim Watch'S Petition for Review of LBP-12-11
ML12185A1392012-07-0303 July 2012
Certificate of Service for Jones River Watershed Association and Pilgrim Watch Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention)
ML12185A1382012-07-0303 July 2012
Jones River Watershed Association and Pilgrim Watch Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention) LBP 12-11, June 18, 2012
ML12160A4392012-06-0808 June 2012
Entergy'S Answer Opposing Jones River Watershed Association'S and Pilgrim Watch'S Motion to Reopen and Hearing Request on Contention Regarding Water-Related Approvals
ML12159A5762012-06-0707 June 2012
NRC Staff'S Answer to Jones River Watershed Association and Pilgrim Watch'S Requests to Reopen the Record and File a New Contention on Water Quality
ML12159A5772012-06-0707 June 2012
Notice of Appearance for Maxwell C. Smith
ML12157A5742012-06-0505 June 2012
Notice of Appearance for Susan L. Uttal on Entergy Nuclear Operations, Inc., (Pilgrim)
2020-06-04
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Text
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) )
PILGRM WATCH MEMORANDUM IN SUPPORT OF EMERGENCY MOTION OF THE COMMONWEALTH OF MASSACHUSETTS FOR AN ENLARGEMENT OF TIME TO FILE AN APPLICATION TO STAY A NRC STAFF ORDER APPROVING THE LICENCE TRANSFER APPLICATION Late yesterday, August 15, 2019, the Commonwealth of Massachusetts (Commonwealth or Massachusetts asked, on an emergency basis, that the Commission enlarge the time to file a stay application under 10 C.F.R. § 2.1327(a) to ten (10) days from the date the Nuclear Regulatory Commission (NRC) Staff issues an order, if any, approving the pending License Transfer Application.
The Commonwealths Motion also stated that Pilgrim joins the motion, and specifically asks that any enlargement of time granted to the Commonwealth for filing its stay application also apply to Pilgrim Watch.
Unless the Commission does not today act on the Commonwealths other pending emergency motion to clarify 10 C.F.R. § 2.1327(a), or if the Commission should decide that 10 C.F.R. § 2.1327(a) requires a motion to stay the effectiveness of an order granting a license transfer application must be filed within 5 days of notification of an intent to grant the license
application rather than 5 days after any such order might actually be issued, Pilgrim Watch will be in an essentially impossible position. Without even seeing whatever order the Staff might issue, Pilgrim Watch (and also the Commonwealth) will have to file to prepare and file any motion under 10 C.F.R. § 2.1327 that addresses in detail each of the required four required showings, and to do so by Monday, August 19, the same day on which it must also file its reply to Applicants Answer opposing the pending Pilgrim Watch Motion to add a new contention.
The Commonwealths Motion sets forth reason the Commonwealth need enough time to prepare an application for a stay that satisfies the standards set forth in 10 C.F.R. § 2.1327; Pilgrim Watch, that has no staff, needs enough time for it to do so, also.
Extending the time to file only for the Commonwealth, would result in motions to stay to be filed on different dates. And unless the Applicants should request time to extend their times for response, will result in their responses to file on different dates. That makes no sense and benefits only the Applicants.
The Commonwealth and Pilgrim Watch should be allowed to file any such motions to stay at the same time, ten (10) days from the date the Nuclear Regulatory Commission (NRC)
Staff issues an order, if any, approving the pending License Transfer Application. To decide whether to stay the effectiveness of a Staff order, the NRC will need to consider all motions filed, and all responses that Applicants make to such motions; it makes no sense for the NRC to consider them piecemeal.
The NRC seems to agree that such simultaneous filings make sense. In an Order in this proceeding dated March 20, 2019, it recognized Pilgrim Watchs request that it be granted any enlargement of time granted to the Commonwealth, and extended the deadline for the Commonwealth and Pilgrim Watch to file their respective replies to the same date.
Respectfully submitted this 16th of August 2019, (Electronically signed)
Mary Lampert 148 Washington Street, Duxbury MA 02332 Tel. 781.934.0389 Email:
mary.lampert@comcast.net James B. Lampert 148 Washington Street, Duxbury MA 02332 Tel. 781.934.0389 Email:
james.lampert@comcast.net 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 Pilgrim Watch Memorandum in Support of Emergency Motion of the Commonwealth of Massachusetts to File an Application to Stay a NRC Staff Order Approving the License Transfer Application have been served upon the Electronic Information Exchange, the NRCs e-filing system, in the above-captioned proceeding this 16th day of August 2019.
Signed (electronically) by Mary Lampert Pilgrim Watch, director 148 Washington Street Duxbury, MA 02332 Tel. 781.934.0389 Email: mary.lampert@comcast.net Dated: August 16, 2019