Notice of Supplemental Standing DeclarationML24149A315 |
Person / Time |
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Site: |
Diablo Canyon |
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Issue date: |
05/28/2024 |
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From: |
Curran D, Leary C, Leah Parks Environmental Working Group, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP |
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To: |
Atomic Safety and Licensing Board Panel |
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SECY RAS |
References |
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RAS 57031, 50-275-LR-2, 50-323-LR-2 |
Download: ML24149A315 (0) |
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Category:Legal-Pleading
MONTHYEARML24263A2122024-09-19019 September 2024 Notice of Substitution of Counsel for the California Energy Commission ML24236A7752024-08-23023 August 2024 NRC Staff Brief in Opposition to the San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group Appeal of LBP-24-6 ML24236A7902024-08-23023 August 2024 Pacific Gas and Electric Company Answer Opposing the Appeal of LBP-24-6 Filed by San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group ML24211A2872024-07-29029 July 2024 Notice of Appeal of LBP-24-06 by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group ML24211A2882024-07-29029 July 2024 Brief by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group on Appeal of LBP-24-06 ML24149A3152024-05-28028 May 2024 Notice of Supplemental Standing Declaration ML24116A1732024-04-25025 April 2024 Response by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group to Pacific Gas and Electric Companys Motion to Strike Portions of Their Reply ML24106A2992024-04-15015 April 2024 Pacific Gas and Electric Companys Motion to Strike Portions of the Reply Filed by San Luis Obispo Mothers for Peace Friends of the Earth and Environmental Working Group ML24096B7842024-04-0505 April 2024 Reply by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group to Oppositions to Request for Hearing on Pacific Gas and Electric Companys License Renewal Application for the Diablo Canyon Nuclear Plant ML24089A1102024-03-29029 March 2024 NRC Staff Answer Opposing the San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group Hearing Request ML24089A2412024-03-29029 March 2024 Pacific Gas and Electric Companys Answer Opposing the Hearing Request Filed by San Luis Obispo Mothers for Peace Friends of the Earth and Environmental Working Group ML24080A5032024-03-20020 March 2024 Notice of Appearance for Devin Black ML24067A0662024-03-0707 March 2024 Petition by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group for Shutdown of Diablo Canyon Nuclear Power Plant Due to Unacceptable Risk of Seismic Core Damage Accident ML24064A1322024-03-0404 March 2024 Request of the California Energy Commission to Participate as Non-Party Pursuant to 10 C.F.R. 2.315(c) ML23272A1952023-09-29029 September 2023 Motion by San Luis Obispo Mothers for Peace and Friends of the Earth for Leave to Reply to Oppositions to Request for Emergency Order Requiring Immediate Shutdown of Unit 1 Pending Completion of Tests and Inspections of Pressure Vessel, Pub ML23272A1962023-09-29029 September 2023 Reply by San Luis Obispo Mothers for Peace and Friends of the Earth to Oppositions to Request for Emergency Order Requiring Immediate Shutdown of Unit 1 Pending Completion of Tests and Inspections of Pressure Vessel, Public Disclosure of Re ML23268A4352023-09-25025 September 2023 Pacific Gas and Electric Company Response to the Request of San Luis Obispo Mothers for Peace and Friends of the Earth for an Emergency Order Requiring Immediate Shutdown of Diablo Canyon Nuclear Power Plant, Unit 1 ML23268A0552023-09-25025 September 2023 NRC Staff Answer to San Luis Obispo Mothers for Peace and Friends of the Earth Request for Emergency Order Requiring Immediate Shutdown ML23257A3012023-09-14014 September 2023 San Luis Obispo Mothers for Peace and Friends of the Earth Request for Hearing on NRC Staff Decision Effectively Amending Diablo Canyon 1 License, Request for Emergency Order Requiring Shutdown, and Errata ML23257A3022023-09-14014 September 2023 San Luis Obispo Mothers for Peace and Friends of the Earth Corrected Request for Hearing on NRC Staff Decision Effectively Amending Diablo Canyon 1 License, Request for Emergency Order Requiring Shutdown, and Errata ML23254A3872023-09-11011 September 2023 San Luis Obispo Mothers for Peaces Notice of Withdrawal of Contention a ML23248A2222023-09-0505 September 2023 NRC Staff Answer to Pacific Gas and Electric Companys Motion to Dismiss or for Summary Disposition of Contention a as Moot ML23236A4952023-08-24024 August 2023 Pacific Gas and Electric Company Motion to Dismiss or for Summary Disposition of Contention a as Moot ML23227A0152023-08-14014 August 2023 Pacific Gas and Electric Company Notice of Appeal and Brief in Support of Appeal of LBP-23-7 ML23212A9662023-07-31031 July 2023 Joint Unopposed Motion to Modify Timing of Mandatory Disclosures and Hearing File Obligations ML23103A3942023-04-13013 April 2023 Slomfp Reply Re DC ISFSI ML23097A1292023-04-0707 April 2023 Pacific Gas and Electric Company Answer Opposing San Luis Obispo Mothers for Peace Hearing Request and Petition to Intervene ML23097A0632023-04-0707 April 2023 NRC Staff Answer to San Luis Obispo Mothers for Peace Hearing Request and Petition to Intervene ML23094A1342023-04-0303 April 2023 Notice of Appearance for Diane Curran ML23073A3822023-03-14014 March 2023 Re-filed San Luis Obispo Mothers for Peaces Hearing Request and Petition to Intervene in License Renewal Proceeding for Diablo Canyon Spent Fuel Storage Installation ML23074A1102023-03-13013 March 2023 Email Filing of Hearing Request from San Luis Obispo Mothers for Peace Regarding Diablo Canyon ISFSI License Renewal Application ML23074A2042023-03-13013 March 2023 San Luis Obispo Mothers for Peaces Hearing Request and Petition to Intervene in License Renewal Proceeding for Diablo Canyon Spent Fuel Storage Installation ML23073A3072023-03-13013 March 2023 San Luis Obispo Mothers for Peaces Hearing Request and Petition to Intervene in License Renewal Proceeding for Diablo Canyon Spent Fuel Storage Installation ML23052A2032023-01-20020 January 2023 Notices of Appearance for Ryan Lighty, Paul Bessette, and Timothy Matthews on Behalf of Pacific Gas and Electric ML23052A2022023-01-20020 January 2023 Pacific Gas and Electric Response to the January 10, 2023 Extraprocedural Filing by San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group Regarding Diablo Canyon Units 1 and 2 ML23052A1932023-01-10010 January 2023 Notice of Appearance for Hallie Templeton on Behalf of Friends of the Earth ML23052A2042023-01-10010 January 2023 E-mail from Paul Bessette Dated 01/10/2023 Regarding Diablo Canyon ML23052A1942023-01-10010 January 2023 Notice of Appearance for Caroline Leary on Behalf of Environmental Working Group ML23052A1952023-01-10010 January 2023 Notice of Appearance for Diane Curran on Behalf of San Luis Obispo Mothers for Peace ML23052A1922023-01-10010 January 2023 San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group Petition to Review Undocketed License Renewal Application for Diablo Canyon Unit 1 and Unit 2 Reactors and to Deny Request to Extend License Terms ML15345A4632015-12-11011 December 2015 Applicant Response Opposing Slomfp Appeal of LBP-15-29 ML15345A2212015-12-11011 December 2015 NRC Staff Answer to Slomfp Petition for Review of LBP-15-29 ML15321A4862015-11-17017 November 2015 NRC Staff Brief in Opposition to Foe'S Appeal of LBP-15-27 ML15321A4632015-11-17017 November 2015 Pacific Gas and Electric Response to Foe Appeal of LBP-15-27 ML15320A5652015-11-16016 November 2015 San Luis Obispo Mothers for Peace'S Petition for Review of LBP-15-29 ML15296A5502015-10-23023 October 2015 Friends of the Earth'S Notice of Appeal and Brief in Support of Appeal of LBP-15-27 ML15282A0492015-10-0909 October 2015 NRC Staff Answer to Slomfp Petition for Review of August 6, 2015 Board Order ML15282A4592015-10-0909 October 2015 Applicant Response Opposing Slomfp Petition for Review ML15257A5722015-09-14014 September 2015 San Luis Obispo Mothers for Peace'S Response to Pacific Gas & Electric Company'S Motion for Summary Disposition of Contention EC-1 ML15257A5702015-09-14014 September 2015 Petition for Review - San Luis Obispo Mothers for Peace'S Petition for Review of Memorandum and Order (Denying Motions to File New Contentions) 2024-09-19
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR, 50-373-LR-2 Diablo Canyon Nuclear Power Plant Units 1 and 2
NOTICE OF FILING OF SUPPLEMENTAL DECLARATION OF LINDA PARKS As permitted by the Atomic Safety and Licensing Board during the Initial Prehearing
Conference on May 22, 2024, Petitioners San Luis Obispo Mothers for Peace and Environmental
Working Group hereby submit the attached Supplemental Declaration of Linda Parks in support
of Environmental Working Groups representational standing to participate in this proceeding.
Respectfully submitted,
__/signed electronically by/___
Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com
__/signed electronically by/___
Caroline Leary Environmental Working Group 1250 I St N.W.
Washington, DC 20005 202-667-6982 cleary@ewg.org Counsel to Environmental Working Group
May 28, 2024
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR, 50-373-LR-2 Diablo Canyon Nuclear Power Plant Units 1 and 2
SUPPLEMENTAL DECLARATION OF LINDA PARKS Under penalty of perjury, Linda Parks declares as follows:
- 1. My name is Linda Parks. I am a supporter of Environmental Working Group (EWG). On March 1, 2024, I prepared a declaration in support of a hearing request and petition to intervene in this proceeding by EWG. The statements in my March 1 declaration continue to be true and correct. A copy of that declaration is attached.
- 2. The purpose of this Supplemental Declaration is to clarify that in addition to being a subscriber to EWGs newsletter and generally endorsing EWGs advocacy efforts, I provide financial support to EWG. In 2024, I donated $41.50 to the organization.
Executed in Accordance with 10 C.F.R. § 2.304(d) by Linda Parks May 28, 2024
TINITED STATES OF AMERICA NUCLEAR REGULATORY COMMI S SION BEFORETHE SECRETARY
In the matter of Pacific Gas and Electric Company Docket Nos. 5A-275-L& 5A-373-LR Diablo Canyon Nuclear Power Plant Units I and?
DECLARATION OF LINI}A PARKS
Under penalty of perjury, Linda Parks declares as follows:
- t. My name is Linda Parks. I am a supporter of Environmental Working Group (EWG). As an EWG supporter, I receive monthly EWG emails that provides me with public education information about health risks posed by toxic and radiological contamination of consumer products and the environment. In these emails, EWG regularly asks about supporters' concerns and opinions in order to guide it in establishing organizational goals. I am pleased with EWG'S work and believe EWG generally represents my interests and concerns.
- 2. I live at 242Butte Drive, Los Osos. My home is located within the SO-mile ingestion pathway zone of Diablo Canyon Unit I and Unit 2 nuclear reactors (DCPP).
- 3. I am aware that the licensee, Pacific Gas and Electric Company (PG&E), has requested the U.S. Nuclear Regulatory Commission (NRC) to renew the DCPP operating licenses for 20 years.
- 4. Based on my knowledge that the Diablo Canyon nuclear reactors are operating with aging equipment, including an embrittled reactor pressure vessel that has not been inspected for over 20 years; and based on the location of the Diablo Canyon reactors on or neax a web of significant earthquake faults, I believe that the continued operation of the Diablo Canyon reactors for a renewed license term poses an unacceptable radiological accident risk that jeopardizes my health and safety and the environment.
- 5. Therefore,I have authorized EWG to represent my interests by submitting ahearing request in this license renewal proceeding.
Evec.uted in Acc"wdance with lQ Q.f,fi,, {2.30.4.(d,\\ -b}t
Date: March 1,2024 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR, 50-373-LR-2 Diablo Canyon Nuclear Power Plant Units 1 and 2
CERTIFICATE OF SERVICE I certify that on May 28, 2024, I posted Notice of Filing of Supplemental Declaration of Linda Parks and attached Supplemental Declaration of Linda Parks on the NRCs Electronic Information Exchange.
__/signed electronically by/___
Diane Curran