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| | issue date = 07/09/2012 | | | issue date = 07/09/2012 |
| | title = NRDC Errata Notice | | | title = NRDC Errata Notice |
| | author name = Fettus G H, Roisman A Z | | | author name = Fettus G, Roisman A |
| | author affiliation = Natural Resources Defense Council (NRDC), National Legal Scholars Law Firm, PC | | | author affiliation = Natural Resources Defense Council (NRDC), National Legal Scholars Law Firm, PC |
| | addressee name = | | | addressee name = |
Revision as of 16:53, 28 June 2019
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Category:Legal-Pleading
MONTHYEARML21328A2492021-11-24024 November 2021
Notice of Withdrawal of the People of the State of Illinois'S Hearing Request and Petition for Leave to Intervene
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People of the State of Illinois'S Reply to Exelon'S Answer to Their Request for a Hearing Regarding Exelon Generation Company, Llc'S Facility Operating License Transfer Application
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Exelon'S Answer Opposing Petition of the State of Illinois for Leave to Intervene and Request for a Hearing
ML21218A1712021-08-0606 August 2021
Certificate of Service
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the Environmental Law and Policy Center'S Reply to Applicants Answer
ML21211A5932021-07-30030 July 2021
Exelon'S Answer Opposing the Petition of the Environmental Law and Policy Center for Leave to Intervene and for a Hearing
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Reply to Exelon'S Answer Opposing Petition of Edf Inc. for Leave to Intervene and Request a Hearing
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Exelon'S Answer Opposing the Petition of Eric Joseph Epstein and Three Mile Island Alert, Inc for Leave to Intervene and for a Hearing
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Exelon'S Answer Opposing Petition of Edf Inc. for Leave to Intervene and Request for a Hearing
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Certificate of Service
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Notice of Appearance of Susan L. Satter
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Combined Motion of Exelon to File Its Answers to the Edf and Epstein-TMIA Hearing Requests on Illinois New Hearing Request Deadline and Motion of Elpc to Move Exelon Deadline to Answer Elpc Hearing Request to July 30 2021
ML21171A0092021-06-20020 June 2021
Exelon'S Answer Opposing the State of Illinois'S Motion to Yet Again Amend the Protective Order
ML21155A1212021-06-0404 June 2021
Joint Motion to Amend Protective Order
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Proposed Order Granting Joint Motion to Amend Protective Order
ML21141A3482021-05-21021 May 2021
Applicants' Answer Opposing Environmental Law and Policy Center'S Motion to Extend Hearing Request Deadline
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Joint Motion for Entry of a Protective Order
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NRDC V. NRC - DC Cir 13-1311 Joint Appendix
ML13316C4212013-11-12012 November 2013
Exelon'S Petition for Certification of Waste Confidence-Related Question to the Commission Pursuant to 10CFR2.323(f)(2)
ML13212A3832013-07-31031 July 2013
Natural Resources Defense Council'S Opposition to Exelon'S Motion for Clarification, or in the Alternative for Leave to Request Partial Reconsideration of the Board July 12 Order
ML13203A1622013-07-22022 July 2013
Exelon'S Motion for Clarification or, in the Alternative, for Leave to Request Partial Reconsideration of the Board'S July 12 Order
ML13189A3052013-07-0808 July 2013
Natural Resources Defense Council'S Reply in Support of Resubmission of Contentions
ML13175A2502013-06-24024 June 2013
Exelon'S Answer Opposing Natural Resources Defense Council'S Resubmission of Contentions in Response to Staff'S Supplemental Draft Environmental Impact Statement
ML13175A2142013-06-24024 June 2013
NRC Staff Answer to the Natural Resources Defense Council'S Resubmission of Contentions in Response to Staff'S Supplemental Draft Environmental Impact Statement
ML13130A3692013-05-10010 May 2013
Notice of Withdrawal for Maxwell C. Smith
ML13079A6622013-03-20020 March 2013
Exelon'S Reply Brief in Response to the Referral of LBP-13-1 to the Commission
ML13079A5512013-03-20020 March 2013
Natural Resources Defense Council'S Response Brief in Support of Waiver of 10 C.F.R. Section 51.53(c)(3)(ii)(L) as Applied to Application for Renewal of Licenses for Limerick Units 1 and 2
ML13079A5012013-03-20020 March 2013
NRC Staff Reply on the Boards' Referred Ruling in LBP-13-1
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Exelon'S Initial Brief in Response to the Referral of LBP-13-1 to the Commission
ML13072B0362013-03-13013 March 2013
Exhibit B for Natural Resources Defense Council'S Brief in Support of Waiver of 10 C.F.R. 52.53(c)(3)(ii)(L) as Applied to Application for Renewal of Licenses for Limerick Units 1 and 2
ML13072B0392013-03-13013 March 2013
Exhibit a for Natural Resources Defense Council'S Brief in Support of Waiver of 10 C.F.R. 52.53(c)(3)(ii)(L) as Applied to Application for Renewal of Licenses for Limerick Units 1 and 2
ML13072B0382013-03-13013 March 2013
Natural Resources Defense Council'S Brief in Support of Waiver of 10 C.F.R. 51.53(c)(3)(ii)(L) as Applied to Application for Renewal of License for Limerick, Units 1 & 2
ML13072A5162013-03-13013 March 2013
Amended Notice of Appearance of Brooke F. Mcglinn
ML13072A8042013-03-13013 March 2013
NRC Staff'S Brief on the Board'S Referred Ruling in LBP-13-1
ML12356A4932012-12-21021 December 2012
Reply of Natural Resources Defense Council in Support of Petition, by Way of Motion, for Waiver of 10CFR51.53(c)(3)(ii)(L) as Applied to Application for Renewal of Licenses for Limerick Units 1 & 2
ML12349A3842012-12-14014 December 2012
NRC Staff Answer to Natural Resources Defense Council Petition for Waiver of 10 C.F.R. 51.53(c)(3)(ii)(L)
ML12349A3292012-12-14014 December 2012
Exhibit a, Declaration of Christopher J. Weaver, Ph.D., on Behalf of the Natural Resources Defense Council in Support of Motion for Waiver
ML12349A3282012-12-14014 December 2012
Exelon'S Counter Affidavit Supporting Exelon'S Response Opposing Nrdcs Petition for Waiver of 10 C.F.R. Section 51.53(C)(3)(ii)(L)
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Exelons Response Opposing Nrdcs Petition for Waiver of 10 C.F.R. Section 51.53(C)(3)(ii)(L)
ML12215A5712012-08-0202 August 2012
Exelon'S Answer Opposing Nrdc'S New Waste Confidence Contention
ML12215A4572012-08-0202 August 2012
NRC Staff'S Response to Nrdc'S Motion for Leave to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at Limerick and Nrdc'S Waste Confidence Contention
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NRDC Errata Notice
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Nrdc'S Waste Confidence Contention - 1st Corrected
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2nd Errata Notice Waste Confidence Contention
ML12192A3702012-07-0909 July 2012
2nd Corrected NRDC Waste Confidence Contention
ML12188A0212012-07-0505 July 2012
NRDC Initial Disclosures Attachment C Corrected
ML12184A2412012-07-0202 July 2012
Attachment B to Nrdc'S Initial Disclosures - Documents Relevant to Contention E-1
ML12184A2422012-07-0202 July 2012
Attachment a to Nrdc'S Initial Disclosures - Potential Expert Witnesses Contention E-1
ML12184A2402012-07-0202 July 2012
Initial Disclosures NRDC Filed Pursuant to 10 C.F.R 2.336(a)
ML12128A3972012-05-0707 May 2012
Notice of Withdrawal of Lauren Woodall on Behalf of the U.S. Nuclear Regulatory Commission in the Matter of Limerick Generating Station, Units 1 and 2
2021-08-06
[Table view] |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) ) EXELON GENERATION COMPANY, LLC ) Docket No. 50-352-LR ) Docket No. 50-353-LR (Limerick Generating Station, Units 1 and 2) ) (License Renewal Application) ) July 9, 2012 ERRATA NOTICE Yesterday, July 9, 2012, counsel for NRDC inadvertently inserted an earlier and inaccurate version of the Waste Confidence Contention that omitted two regulatory references. The correct version is included in this errata sheet that delineates the omitted regulatory references and in a new version of the Contention today that does not. No text in the Motion for Leave or in the Bases or Supporting Evidence have been changed or altered in any way. SUPPLEMENTAL CONTENTION 1 (with omission underlined) THE ENVIRONMENTAL REPORT FOR LIMERICK RELICENSING FAILS TO COMPLY WITH THE REQUIREMENTS OF THE NATIONAL ENVIRONMENTAL POLICY ACT AND ALL RELEVANT IMPLEMENTING REGULATIONS INCLUDING BUT NOT LIMITED TO 10 C.F.R. §§ 51.20(b)(2), 51.45, 51.53(c)(1)(2), 51.71(d), 51.90, 51.91(c), 51.95(c)(1), 51.95(c)(2), AND 51.101(a) BECAUSE IT FAILS TO INCLUDE OR INCORPORATE A LEGALLY SUFFICIENT ANALYSIS OF THE ENVIRONMENTAL IMPACTS OF ON-SITE STORAGE OF NUCLEAR WASTE AFTER THE CONCLUSION OF THE EXTENDED OPERATING PERIOD, INCLUDING THE IMPACTS IN THE EVENT THAT NO PERMANENT REPOSITORY IS EVER ESTABLISHED, AND FAILS TO CONSIDER ALTERNATIVES TO MITIGATE THOSE IMPACTS; BECAUSE THERE IS NO VALID ANALYSIS OF THESE ISSUES, NRC MAY NOT REACH A FINAL DECISION ON WHETHER TO RENEW LIMERHAS BEEN COMPLETED IN COMPLIANCE WITH APPLICABLE FEDERAL LAW AND REGULATIONS. Signed (electronically) by Signed (electronically) by Geoffrey H. Fettus Senior Attorney Natural Resources Defense Council 1152 15th St. NW, Suite 300 Washington, D.C. 20005 (202) 289-2371 gfettus@nrdc.org Anthony Roisman National Legal Scholars Law Firm, P.C.241 Poverty Lane, Unit 1 Lebanon, NH 03766 (603)443-4162 aroisman@nationallegalscholars.com July 10th, 2012 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Errata Notice Regarding Contention in the captioned proceeding were served via the Electronic Information Exchange (EIE) on the 10th day of July 2012, which to the best of my knowledge resulted in transmittal of same to those on the EIE Service List for the captioned proceeding. Administrative Judge William J. Froehlich, Chair Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: William.Froehlich@nrc.gov U.S. Nuclear Regulatory Commission Office of the Secretary of the Commission Mail Stop: O-16C1 Washington, DC 20555-0001 hearingdocket@nrc.gov Administrative Judge Dr. William E. Kastenberg Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: William.Kastenberg@nrc.gov Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Mail Stop: O-16C1 Washington, DC 20555-0001 E-mail: OCAAMail@nrc.gov Administrative Judge Michael F. Kennedy Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: Michael.Kennedy@nrc.gov Matthew Flyntz Law Clerk Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: Matthew.Flyntz@nrc.gov Alex S. Polonsky Kathryn M. Sutton Anna V. Jones Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 E-mail: apolonsky@morganlewis.com J. Bradley Fewell Vice President and Deputy General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 E-mail: Bradley.Fewell@exeloncorp.com Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop O-15D21 Washington, DC 20555-0001 OGCMailCenter@nrc.gov Catherine Kanatas Catherine.Kanatas@nrc.gov Brian Newell Brian.Newell@nrc.gov Maxwell Smith Maxwell.Smith@nrc.gov Mary Spencer Mary.Spencer@nrc.gov Ed Williamson Edward.Williamson@nrc.gov Lauren Woodall Lauren.Woodall@nrc.gov /Signed (electronically) by/ Geoffrey H. Fettus July 10, 2012
