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| issue date = 08/16/2011
| issue date = 08/16/2011
| title = NRC Staff'S Unopposed Motion for an Extension to September 6, 2011, to File a Response to the Commonwealth of Massachusetts' Motion
| title = NRC Staff'S Unopposed Motion for an Extension to September 6, 2011, to File a Response to the Commonwealth of Massachusetts' Motion
| author name = Harris B G
| author name = Harris B
| author affiliation = NRC/OGC
| author affiliation = NRC/OGC
| addressee name =  
| addressee name =  
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=Text=
=Text=
{{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
{{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of                                 )
    )      ) Entergy Nuclear Generation Co. and
                                                )
  ) Entergy Nuclear Operations, Inc.
Entergy Nuclear Generation Co. and               )
  ) Docket No. 50
Entergy Nuclear Operations, Inc.                 )       Docket No. 50-239-LR
-239-LR       )       ) (Pilgrim Nuclear Power Station)
                                                )
  )  NRC STAFF'S UNOPPOSED MOTION FOR A N EXTENSION TO SEPTEMBER 6, 2011, TO FILE A RESPONSE TO THE COMMONWEALTH OF MASSACHUSETTS' MOTION Pursuant to 10 C.F.R. § 2.323(c), the NRC staff ("Staff") hereby requests an extension to September 6, 2011, for all parties to file their Answer to the "Commonwealth of Massachusetts' Motion to Supplement Bases to Commonwealth Contention t o Address NRC Task Force Report on Lessons Learned from the Radiological Accident at Fukushima" ("Commonwealth's Motion") on August 11, 2011. In support of this request, the Staff respectfully states as follows:
                                                )
: 1. The Commonwealth's Motion seeks to supplement the bases to its June 2, 2011 contention
(Pilgrim Nuclear Power Station)                  )
: s. The supplement al bases relate to the NRC's July 12, 2011 Near-Term Task Force Report ("Task Force Report") regarding the events at Fukushima Daiichi.
NRC STAFFS UNOPPOSED MOTION FOR AN EXTENSION TO SEPTEMBER 6, 2011, TO FILE A RESPONSE TO THE COMMONWEALTH OF MASSACHUSETTS MOTION Pursuant to 10 C.F.R. § 2.323(c), the NRC staff (Staff) hereby requests an extension to September 6, 2011, for all parties to file their Answer to the 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 (Commonwealths Motion) on August 11, 2011. In support of this request, the Staff respectfully states as follows:
The Staff has also been served with new contentions in 1 7 license renewal and combined operating license ("COL") proceedings.
: 1.       The Commonwealths Motion seeks to supplement the bases to its June 2, 2011 contentions. The supplemental bases relate to the NRCs July 12, 2011 Near-Term Task Force Report (Task Force Report) regarding the events at Fukushima Daiichi. The Staff has also been served with new contentions in 17 license renewal and combined operating license (COL) proceedings. 1 The stated basis for these new contentions is the release of the Task 1
1 1 For license renewal proceedings, the Staff has been served with a new contention in Seabrook, Indian Point, Davis
For license renewal proceedings, the Staff has been served with a new contention in Seabrook, Indian Point, Davis-Besse, and Diablo Canyon. Beyond Nuclear Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report (Aug. 11, 2011) (ADAMS Accession No. ML11223A376); Riverkeeper, Inc. And Hudson River Sloop Clearwater, Inc. New Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The NRC Fukushima Task Force Report (Aug. 11, 2011)(Unpublished); Beyond Nuclears Contention in Support of Motion to Admit New Contention Regarding the Safety and (continued. . .)
-Besse, and Diablo Canyon. "Beyond Nuclear Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report" (Aug. 11, 2011) (ADAMS Accession No. ML11223A376); "Riverkeeper, Inc. And Hudson River Sloop Clearwater, Inc. New Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The NRC Fukushima Task Force Report" (Aug. 11, 2011)(Unpublished); "Beyond Nuclear's Contention in Support of Motion to Admit New Contention Regarding the Safety and The stated bas is for these new contentions is the release of the Task (continued. . .)   Force Report on July 12, 2011. The majority of the new contentions in the se other proceedings were served on the Staff on August 12, 2011. As a result, pursuant to 10 C.F.R.
§ 2.309(h)(1), the Staff's responses to the new contention s in those proceedings is due September 6, 2011.


(. . .continued)
Force Report on July 12, 2011. The majority of the new contentions in these other proceedings were served on the Staff on August 12, 2011. As a result, pursuant to 10 C.F.R. § 2.309(h)(1),
Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident" (Aug. 11, 2011) (ADAMS Accession No. ML11224A000)
the Staffs responses to the new contentions in those proceedings is due September 6, 2011.
; "SLOMFP Motion To Admit New Contention Regarding The Safety And Environmental Implications Of The Nuclear Regulatory Commission Task Force Report On The Fukushima Dai
(. . .continued)
-Ichi Accident" (Aug. 11, 2011)(Unpublished)
Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident (Aug. 11, 2011) (ADAMS Accession No. ML11224A000); SLOMFP Motion To Admit New Contention Regarding The Safety And Environmental Implications Of The Nuclear Regulatory Commission Task Force Report On The Fukushima Dai-Ichi Accident (Aug. 11, 2011)(Unpublished) .
. For operating licensing proceedings, the Staff was served with a new contention in Watts Bar Unit 2. "SACE Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai
For operating licensing proceedings, the Staff was served with a new contention in Watts Bar Unit 2.
-ichi Accident" (Aug. 11, 2011) (ADAMS Accession No. ML11223A291). For COL proceedings, the Staff has been served 3 supplements to party's previous petition seeking a emergency suspension of licensing decisions (Harris, V.C. Summer, and North Anna) and a new contention in 10 proceedings (Bell Bend, Calvert Cliffs, Turkey Point, Vogtle, Lee, Commanche. South Texas, Bellefonte). "Supplemental Comments by NC WARN in Support of Emergency Petition Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report" (Aug. 11, 2011) (ADAMS Accession No. ML11222A243)
SACE Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-ichi Accident (Aug. 11, 2011)
; "Supplemental Comments by Friends of the Earth and the South Carolina Chapter of the Sierra Club in Support of Emergency Petition Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report" (Aug. 10, 2011) (ADAMS Accession No. ML11222A294)
(ADAMS Accession No. ML11223A291). For COL proceedings, the Staff has been served 3 supplements to partys previous petition seeking a emergency suspension of licensing decisions (Harris, V.C. Summer, and North Anna) and a new contention in 10 proceedings (Bell Bend, Calvert Cliffs, Turkey Point, Vogtle, Lee, Commanche. South Texas, Bellefonte). Supplemental Comments by NC WARN in Support of Emergency Petition Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report (Aug. 11, 2011) (ADAMS Accession No. ML11222A243); Supplemental Comments by Friends of the Earth and the South Carolina Chapter of the Sierra Club in Support of Emergency Petition Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report (Aug. 10, 2011) (ADAMS Accession No. ML11222A294); Supplemental Comments By The Blue Ridge Environmental Defense League In Support Of Emergency Petition Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report (Aug. 11, 2011) (Unpublished); Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report (Aug. 11, 2011) (Unpublished); "New Contention Regarding NEPA Requirement to Address Safety &
; "Supplemental Comments By The Blue Ridge Environmental Defense League In Support Of Emergency Petition Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report" (Aug. 11, 2011) (Unpublished)
Environmental Implications of the Fukushima Task Force Report" (Aug. 11, 2011) (ADAMS Accession No. ML11223A346); Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report (Aug. 11, 2011) (Unpublished); Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report (Aug. 11, 2011) (Unpublished); Motion to Reopen and Admit Contention to Address the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident (Aug. 11, 2011) (ADAMS Accession No. ML11223A043); Motion to Reopen the Record and Admit Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident (Aug. 11, 2011)
; "Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report" (Aug. 11, 2011) (Unpublished)
(ADAMS Accession No. ML11223A481); Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident (Aug. 11, 2011) (ADAMS Accession No. ML11223A486); Contention re NEPA Requirement to Address Safety & Environmental Implications of Fukushima Task Force Report (Aug. 11, 2011) (ADAMS Accession No. ML11223A475); Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report (Aug. 11, 2011) (ADAMS Accession No. ML11223A469); BREDL/SACE Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report On the Fukushima Dai-Ichi Accident (Aug. 11, 2011) (ADAMS Accession No. ML11223A485).
; "New Contention Regarding NEPA Requirement to Address Safety & Environmental Implications of the Fukushima Task Force Report" (Aug. 11, 2011) (ADAMS Accession No. ML11223A346)
: 2.       The Commonwealths Motion is substantially similar to the new contention filed in these other proceedings. 10 C.F.R. 2.323(c) requires the Staff and other parties to file answers to the Commonwealths Motion within 10 days or no later than August 22, 2011. Due to the overlap of issues between the Commonwealths Motion and the other new contentions, the need to coordinate the Staffs responses, and the breadth of the issues raised, the Staff needs additional time to reply to the Commonwealths Motion. The normal ten day response time is insufficient for the Staff to complete its review, analysis, and coordinate the contention responses to ensure a consistent response by the Staff in each of these substantially similar filings. The Staff proposes that the time for filing the Staffs answer to the Commonwealths Motion be extended to September 6, 2011, which is consistent with the answers to be filed in the other proceedings, would not result in any undue delay to the proceeding and would greatly aid the Atomic Safety and Licensing Board in this proceeding and other Board proceedings.
; "Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report" (Aug. 11, 2011) (Unpublished)
: 3.       In accordance with 10 C.F.R. § 2.323(b), Staff counsel contacted counsel for the Commonwealth of Massachusetts and Entergy, and the representative of Pilgrim Watch regarding this motion. No one had an objection to the Staffs requested extension of time. In addition, counsel for Entergy requested that Entergy be afforded the same extension of time for the filing of its answer to Commonwealths Motion. The Staff does not oppose that request, and understands that the Commonwealth of Massachusetts and Pilgrim Watch does not oppose Entergys request.
; "Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report" (Aug. 11, 2011) (Unpublished)
; "Motion to Reopen and Admit Contention to Address the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report o n the Fukushima Dai
-Ichi Accident" (Aug. 11, 2011) (ADAMS Accession No. ML11223A043)
; "Motion to Reopen the Record and Admit Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident" (Aug. 11, 2011) (ADAMS Accession No. ML11223A481)
; "Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident" (Aug. 11, 2011) (ADAMS Accession No. ML11223A486)
; "Contention re NEPA Requirement to Address Safety & Environmental Implications of Fukushima Task Force Report" (Aug. 11, 2011) (ADAMS Accession No. ML11223A475)
; "Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report" (Aug. 11, 2011) (ADAMS Accession No. ML11223A469); "BREDL/SACE Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report On the Fukushima Dai
-Ichi Accident" (Aug. 11, 2011) (ADAMS Accession No. ML11223A485).
: 2. The Commonwealth's Motion is substantially similar to the new contention filed in the se other proceedings. 10 C.F.R. 2.323(c) requires the Staff and other parties to file answer s to the Commonwealth's Motion within 10 days or no later than August 22, 2011. Due to the overlap of issues between the Commonwealth's Motion and the other new contentions , the need to coordinate the Staff's response s , and the breadth of the issues raised, the Staff needs additional time to reply to the Commonwealth's Motion. The normal ten day response time is insufficient for the Staff to complete its review, analysis , and coordinate the contention responses to ensure a consistent response by the Staff in each of these substantially similar filings. The Staff proposes that the time for filing the Staff's answer to the Commonwealth's Motion be extended to September 6, 2011, which is consistent with the answers to be filed in the other proceedings, would not result in any undue delay to the proceeding and would greatly aid the Atomic Safety and Licensing Board in this proceeding and other Board proceedings
. 3. In accordance with 10 C.F.R.  
§ 2.323(b), Staff counsel contacted counsel for the Commonwealth of Massachusetts and Entergy, and the representative of Pilgrim Watch regarding this motion. No one had an objection to the Staff's request ed extension of time.
In addition, counsel for Entergy requested that Entergy be afforded the same extension of time for the filing of its answer to Commonwealth's Motion. The Staff does not oppose that request, and understands that the Commonwealth of Massachusetts and Pilgrim Watch does not oppose Entergy's request.
Therefore, the Staff respectfully requests that this motion to extend the time for the parties to respond to the Commonwealth's Motion until September 6, 2011, be granted.
Respectfully Submitted,              Brian G. Harris
/Signed Electronically By/
Counsel for the NRC Staff Dated at Rockville, Maryland this 16th day of August, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )  ) ENTERGY NUCLEAR OPERATIONS, INC.
) Docket No. 50
-293-LR  ) (Pilgrim Nuclear Power Station)
)  )    CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "NRC STAFF'S UNOPPOSED MOTION FOR A N EXTENSION TO SEPTEMBER 6, 2011, TO FILE A RESPONSE TO THE COMMONWEALTH OF MASSACHUSETTS' MOTION" have been served upon the following by the Electronic Information Exchange, with courtesy copies sent by electronic mail, this 16th day of August, 2011:  Administrative Judge Richard F. Cole


Atomic Safety and Licensing Board Panel Mail Stop: T
Therefore, the Staff respectfully requests that this motion to extend the time for the parties to respond to the Commonwealths Motion until September 6, 2011, be granted.
-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555
Respectfully Submitted,
-0001 E-mail: Richard.Cole@nrc.gov Administrative Judge Paul B. Abramson Atomic Safety and Licensing Board Panel Mail Stop: T
                                                      /Signed Electronically By/
-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555
Brian G. Harris Counsel for the NRC Staff Dated at Rockville, Maryland this 16th day of August, 2011
-0001  E-mail: Paul.Abramson@nrc.gov Administrative Judge Ann Marshall Young, Chair Atomic Safety and Licensing Board Panel Mail Stop: T
-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555
-0001 E-mail: Ann.Young@nrc.gov Office of Commission Appellate    Adjudication Mail Stop: O
-16G4 U.S. Nuclear Regulatory Commission Washington, DC 20555
-0001 E-mail: OCAAMAIL.Resource@nrc.gov Atomic Safety and Licensing Board Mail Stop: T
-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555
-0001 (VIA INTERNAL MAIL ONLY)
Office of the Secretary Attn: Rulemakings and Adjudications Staff Mail Stop: O
-16G4 U.S. Nuclear Regulatory Commission Washington, DC 20555
-0001 E-mail: Hearing.Docket@nrc.gov Sheila Slocum Hollis*
Duane Morris LLP 505 9 th St., NW, Suite 1000 Washington, DC 20004 E-mail: sshollis@duanemorris.com Terence A. Burke, Esq.*
Entergy Nuclear 1340 Echelon Parkway Mail Stop: M
-ECH-62 Jackson, MS 39213 E-mail:  tburke@entergy.com Mary Lampert*
148 Washington Street Duxbury, MA 02332


E- mail: mary.lampert@comcast.net David R. Lewis, Esq*.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of                                    )
Paul A. Gaukler, Esq.
                                                    )
Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, NW Washington, DC 20037
ENTERGY NUCLEAR OPERATIONS, INC.                    )      Docket No. 50-293-LR
-1137 E-mail: david.lewis@pillsburylaw.com paul.gaukler@pillsburylaw.com Chief Kevin M. Nord*
                                                    )
Fire Chief &
(Pilgrim Nuclear Power Station)                    )
Director Duxbury Emergency Management Agency 668 Tremont Street Duxbury, MA 02332 E-mail: nord@town.duxbury.ma.us Town Manager*
                                                    )
Town of Plymouth 11 Lincoln St.
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing NRC STAFFS UNOPPOSED MOTION FOR AN EXTENSION TO SEPTEMBER 6, 2011, TO FILE A RESPONSE TO THE COMMONWEALTH OF MASSACHUSETTS MOTION have been served upon the following by the Electronic Information Exchange, with courtesy copies sent by electronic mail, this 16th day of August, 2011:
Plymouth, MA 02360 E-mail: marrighi@townhall.plymouth.ma.us Richard R. MacDonald*
Administrative Judge                                Administrative Judge Richard F. Cole                                      Paul B. Abramson Atomic Safety and Licensing Board Panel              Atomic Safety and Licensing Board Panel Mail Stop: T-3F23                                    Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission                  U.S. Nuclear Regulatory Commission Washington, DC 20555-0001                            Washington, DC 20555-0001 E-mail: Richard.Cole@nrc.gov                        E-mail: Paul.Abramson@nrc.gov Administrative Judge                                Office of Commission Appellate Ann Marshall Young, Chair                            Adjudication Atomic Safety and Licensing Board Panel              Mail Stop: O-16G4 Mail Stop: T-3F23                                    U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission                  Washington, DC 20555-0001 Washington, DC 20555-0001                            E-mail: OCAAMAIL.Resource@nrc.gov E-mail: Ann.Young@nrc.gov Atomic Safety and Licensing Board                    Office of the Secretary Mail Stop: T-3F23                                    Attn: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission                  Mail Stop: O-16G4 Washington, DC 20555-0001                            U.S. Nuclear Regulatory Commission (VIA INTERNAL MAIL ONLY)                            Washington, DC 20555-0001 E-mail: Hearing.Docket@nrc.gov
Town Manager 878 Tremont Street Duxbury, MA  02332 E-mail:   macdonald@town.duxbury.ma.us


Brian G. Harris /Signed Electronically By/
Sheila Slocum Hollis*                          Terence A. Burke, Esq.*
Counsel for the NRC Staff}}
Duane Morris LLP                              Entergy Nuclear 505 9th St., NW, Suite 1000                    1340 Echelon Parkway Washington, DC 20004                          Mail Stop: M-ECH-62 E-mail: sshollis@duanemorris.com              Jackson, MS 39213 E-mail: tburke@entergy.com Mary Lampert*                                  David R. Lewis, Esq*.
148 Washington Street                          Paul A. Gaukler, Esq.
Duxbury, MA 02332                              Pillsbury, Winthrop, Shaw, Pittman, LLP E- mail: mary.lampert@comcast.net              2300 N Street, NW Washington, DC 20037-1137 E-mail: david.lewis@pillsburylaw.com paul.gaukler@pillsburylaw.com Chief Kevin M. Nord*                          Town Manager*
Fire Chief & Director Duxbury Emergency        Town of Plymouth Management Agency                            11 Lincoln St.
668 Tremont Street                            Plymouth, MA 02360 Duxbury, MA 02332                              E-mail: marrighi@townhall.plymouth.ma.us E-mail: nord@town.duxbury.ma.us Richard R. MacDonald*
Town Manager 878 Tremont Street Duxbury, MA 02332 E-mail: macdonald@town.duxbury.ma.us
                                            /Signed Electronically By/
Brian G. Harris Counsel for the NRC Staff}}

Latest revision as of 17:05, 10 March 2020

NRC Staff'S Unopposed Motion for an Extension to September 6, 2011, to File a Response to the Commonwealth of Massachusetts' Motion
ML11228A277
Person / Time
Site: Pilgrim
Issue date: 08/16/2011
From: Harris B
NRC/OGC
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 20775, 50-293-LR, ASLBP 06-848-02-LR
Download: ML11228A277 (6)
v • d • e


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

Entergy Nuclear Generation Co. and )

Entergy Nuclear Operations, Inc. ) Docket No. 50-239-LR

)

)

(Pilgrim Nuclear Power Station) )

NRC STAFFS UNOPPOSED MOTION FOR AN EXTENSION TO SEPTEMBER 6, 2011, TO FILE A RESPONSE TO THE COMMONWEALTH OF MASSACHUSETTS MOTION Pursuant to 10 C.F.R. § 2.323(c), the NRC staff (Staff) hereby requests an extension to September 6, 2011, for all parties to file their Answer to the 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 (Commonwealths Motion) on August 11, 2011. In support of this request, the Staff respectfully states as follows:

1. The Commonwealths Motion seeks to supplement the bases to its June 2, 2011 contentions. The supplemental bases relate to the NRCs July 12, 2011 Near-Term Task Force Report (Task Force Report) regarding the events at Fukushima Daiichi. The Staff has also been served with new contentions in 17 license renewal and combined operating license (COL) proceedings. 1 The stated basis for these new contentions is the release of the Task 1

For license renewal proceedings, the Staff has been served with a new contention in Seabrook, Indian Point, Davis-Besse, and Diablo Canyon. Beyond Nuclear Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report (Aug. 11, 2011) (ADAMS Accession No. ML11223A376); Riverkeeper, Inc. And Hudson River Sloop Clearwater, Inc. New Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The NRC Fukushima Task Force Report (Aug. 11, 2011)(Unpublished); Beyond Nuclears Contention in Support of Motion to Admit New Contention Regarding the Safety and (continued. . .)

Force Report on July 12, 2011. The majority of the new contentions in these other proceedings were served on the Staff on August 12, 2011. As a result, pursuant to 10 C.F.R. § 2.309(h)(1),

the Staffs responses to the new contentions in those proceedings is due September 6, 2011.

(. . .continued)

Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident (Aug. 11, 2011) (ADAMS Accession No. ML11224A000); SLOMFP Motion To Admit New Contention Regarding The Safety And Environmental Implications Of The Nuclear Regulatory Commission Task Force Report On The Fukushima Dai-Ichi Accident (Aug. 11, 2011)(Unpublished) .

For operating licensing proceedings, the Staff was served with a new contention in Watts Bar Unit 2.

SACE Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-ichi Accident (Aug. 11, 2011)

(ADAMS Accession No. ML11223A291). For COL proceedings, the Staff has been served 3 supplements to partys previous petition seeking a emergency suspension of licensing decisions (Harris, V.C. Summer, and North Anna) and a new contention in 10 proceedings (Bell Bend, Calvert Cliffs, Turkey Point, Vogtle, Lee, Commanche. South Texas, Bellefonte). Supplemental Comments by NC WARN in Support of Emergency Petition Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report (Aug. 11, 2011) (ADAMS Accession No. ML11222A243); Supplemental Comments by Friends of the Earth and the South Carolina Chapter of the Sierra Club in Support of Emergency Petition Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report (Aug. 10, 2011) (ADAMS Accession No. ML11222A294); Supplemental Comments By The Blue Ridge Environmental Defense League In Support Of Emergency Petition Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report (Aug. 11, 2011) (Unpublished); Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report (Aug. 11, 2011) (Unpublished); "New Contention Regarding NEPA Requirement to Address Safety &

Environmental Implications of the Fukushima Task Force Report" (Aug. 11, 2011) (ADAMS Accession No. ML11223A346); Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report (Aug. 11, 2011) (Unpublished); Contention Regarding NEPA Requirement To Address Safety And Environmental Implications Of The Fukushima Task Force Report (Aug. 11, 2011) (Unpublished); Motion to Reopen and Admit Contention to Address the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident (Aug. 11, 2011) (ADAMS Accession No. ML11223A043); Motion to Reopen the Record and Admit Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident (Aug. 11, 2011)

(ADAMS Accession No. ML11223A481); Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-Ichi Accident (Aug. 11, 2011) (ADAMS Accession No. ML11223A486); Contention re NEPA Requirement to Address Safety & Environmental Implications of Fukushima Task Force Report (Aug. 11, 2011) (ADAMS Accession No. ML11223A475); Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report (Aug. 11, 2011) (ADAMS Accession No. ML11223A469); BREDL/SACE Motion to Admit New Contention Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report On the Fukushima Dai-Ichi Accident (Aug. 11, 2011) (ADAMS Accession No. ML11223A485).

2. The Commonwealths Motion is substantially similar to the new contention filed in these other proceedings. 10 C.F.R. 2.323(c) requires the Staff and other parties to file answers to the Commonwealths Motion within 10 days or no later than August 22, 2011. Due to the overlap of issues between the Commonwealths Motion and the other new contentions, the need to coordinate the Staffs responses, and the breadth of the issues raised, the Staff needs additional time to reply to the Commonwealths Motion. The normal ten day response time is insufficient for the Staff to complete its review, analysis, and coordinate the contention responses to ensure a consistent response by the Staff in each of these substantially similar filings. The Staff proposes that the time for filing the Staffs answer to the Commonwealths Motion be extended to September 6, 2011, which is consistent with the answers to be filed in the other proceedings, would not result in any undue delay to the proceeding and would greatly aid the Atomic Safety and Licensing Board in this proceeding and other Board proceedings.
3. In accordance with 10 C.F.R. § 2.323(b), Staff counsel contacted counsel for the Commonwealth of Massachusetts and Entergy, and the representative of Pilgrim Watch regarding this motion. No one had an objection to the Staffs requested extension of time. In addition, counsel for Entergy requested that Entergy be afforded the same extension of time for the filing of its answer to Commonwealths Motion. The Staff does not oppose that request, and understands that the Commonwealth of Massachusetts and Pilgrim Watch does not oppose Entergys request.

Therefore, the Staff respectfully requests that this motion to extend the time for the parties to respond to the Commonwealths Motion until September 6, 2011, be granted.

Respectfully Submitted,

/Signed Electronically By/

Brian G. Harris Counsel for the NRC Staff Dated at Rockville, Maryland this 16th day of August, 2011

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

ENTERGY NUCLEAR OPERATIONS, INC. ) Docket No. 50-293-LR

)

(Pilgrim Nuclear Power Station) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing NRC STAFFS UNOPPOSED MOTION FOR AN EXTENSION TO SEPTEMBER 6, 2011, TO FILE A RESPONSE TO THE COMMONWEALTH OF MASSACHUSETTS MOTION have been served upon the following by the Electronic Information Exchange, with courtesy copies sent by electronic mail, this 16th day of August, 2011:

Administrative Judge Administrative Judge Richard F. Cole Paul B. Abramson Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: Richard.Cole@nrc.gov E-mail: Paul.Abramson@nrc.gov Administrative Judge Office of Commission Appellate Ann Marshall Young, Chair Adjudication Atomic Safety and Licensing Board Panel Mail Stop: O-16G4 Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: OCAAMAIL.Resource@nrc.gov E-mail: Ann.Young@nrc.gov Atomic Safety and Licensing Board Office of the Secretary Mail Stop: T-3F23 Attn: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Mail Stop: O-16G4 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission (VIA INTERNAL MAIL ONLY) Washington, DC 20555-0001 E-mail: Hearing.Docket@nrc.gov

Sheila Slocum Hollis* Terence A. Burke, Esq.*

Duane Morris LLP Entergy Nuclear 505 9th St., NW, Suite 1000 1340 Echelon Parkway Washington, DC 20004 Mail Stop: M-ECH-62 E-mail: sshollis@duanemorris.com Jackson, MS 39213 E-mail: tburke@entergy.com Mary Lampert* David R. Lewis, Esq*.

148 Washington Street Paul A. Gaukler, Esq.

Duxbury, MA 02332 Pillsbury, Winthrop, Shaw, Pittman, LLP E- mail: mary.lampert@comcast.net 2300 N Street, NW Washington, DC 20037-1137 E-mail: david.lewis@pillsburylaw.com paul.gaukler@pillsburylaw.com Chief Kevin M. Nord* Town Manager*

Fire Chief & Director Duxbury Emergency Town of Plymouth Management Agency 11 Lincoln St.

668 Tremont Street Plymouth, MA 02360 Duxbury, MA 02332 E-mail: marrighi@townhall.plymouth.ma.us E-mail: nord@town.duxbury.ma.us Richard R. MacDonald*

Town Manager 878 Tremont Street Duxbury, MA 02332 E-mail: macdonald@town.duxbury.ma.us

/Signed Electronically By/

Brian G. Harris Counsel for the NRC Staff

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