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| | number = ML102730788 | | | number = ML102730788 |
| | issue date = 09/21/2010 | | | issue date = 09/21/2010 |
| | title = 2010/09/21-Pilgrim Watch'S Reply to Entergy'S Response to Pilgrim Watch'S Memo Regarding Proposed Schedule | | | title = Pilgrim Watch'S Reply to Entergy'S Response to Pilgrim Watch'S Memo Regarding Proposed Schedule |
| | author name = Lampert M | | | author name = Lampert M |
| | author affiliation = Pilgrim Watch | | | author affiliation = Pilgrim Watch |
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| {{#Wiki_filter:kks j -.;k- -) /DOCKETED USNRC September 22, 2010 (8:00a.m.) | | {{#Wiki_filter:kks j -. ;k- -) / |
| OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application Docket # 50-293 September 21, 2010 Pilgrim Watch's Reply to Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule The statement in Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule saying that "Pilgrim Watch was previously able to prepare its testimony in six weeks,[and] there is no good reason why is now needs more than three months" is misleading and totally disingenuous. | | DOCKETED USNRC September 22, 2010 (8:00a.m.) |
| The Board's May 5, 2010 Order provided for a five (5) month preparatory period prior to submitting pre-trial filings. The time period prior to filing is not simply for what experts are required to do, but also what Pilgrim Watch is required to do, absent a plethora of other supports-lawyers, paralegals, secretaries, copy room staff, and mail clerks.Thanking you for your consideration, I am sirely, Mary Lampert \........Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application September 21, 2010 CERTIFICATE OF SERVICE I hereby certify that Pilgrim Watch's Reply to Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule was served September 21, 2010 in the above captioned proceeding to the following persons by electronic mail this date, followed by deposit of paper copies in the U.S. mail, first class.Secretary of the Commission Attn: Rulemakings and Adjudications Staff Mail Stop 0-16 C I United States Nuclear Regulatory Commission | | OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293 Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application September 21, 2010 Pilgrim Watch's Reply to Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule The statement in Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule saying that "Pilgrim Watch was previously able to prepare its testimony in six weeks, |
| [2 copies]Administrative Judge Ann Marshall Young, Chair Atomic Safety and Licensing Board Mail Stop -T-3 F23 US NRC Washington, DC 20555-0001 Administrative Judge Paul B. Abramson Atomic Safety and Licensing Board Mail Stop T-3 F23 US NRC Washington, DC 20555-0001 Administrative Judge Richard F. Cole Atomic Safety and Licensing Board Mail Stop -T-3-F23 US NRC Washington, DC 20555-0001 Office of Commission Appellate Adjudication Mail Stop 0-16 C1 United States Nuclear Regulatory Commission Washington, DC 20555-0001 Atomic Safety and Licensing Board Mail Stop T-3 F23 United States Nuclear Regulatory Commission Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Mail Stop: 0-16C1 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Office of General Counsel Mail Stop: 0-15 D21 Washington DC 20555-0001 Susan L. Uttal, Esq.Andrea Jones, Esq.Brian Harris, Esq.Michael Dreher, Esq.Brian Newell, Paralegal U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop: 01 -Fl Washington, DC 20555-0001 Lisa Regner, Project Mgr. Plant Lic.Branch 1-1, Operator Reactor Licensing Washington, DC 20555-0001 Paul A. Gaukler, Esq.David R. Lewis, Esq.Jason B. Parker, Esq.Pillsbury, Winthrop, Shaw, Pittman, LLP -2300 N Street, N.W.Washington, DC 20037-1128 Katherine Tucker ASLB, Law Clerk U.S. Nuclear Regulatory Commission Mail Stop T-3-E2a Washington, DC 20555-0001 Martha Coakley, Attorney General Matthew Brock, Assistant Attorney General Commonwealth of Massachusetts Office of Attorney General One Ashburton Place Boston, MA 02108 Mark Stankiewicz Town Manager, Town of Plymouth 11 Lincoln Street Plymouth MA 02360 Sheila Slocum Hollis, Esq.Town of Plymouth MA Duane Morris, LLP 505 9th Street, N.W. 1000 Washington D.C. 20004-2166 Richard R. MacDonald Town Manager, Town of Duxbury 878 Tremont Street Duxbury, MA 02332 Fire Chief & Director DEMA, Town of Duxbury 688 Tremont Street P.O. Box 2824 Duxbury, MA 02331 Terence A. Burke, Esq.Entergy Nuclear Mail Stop M-ECH-62 Jackson, MS 39213 Mary Lampert Pilgrim Watch, pro se 148 Washington St.Duxbury, MA 023332 September 21, 2010 2}} | | [and] there is no good reason why is now needs more than three months" is misleading and totally disingenuous. |
| | The Board's May 5, 2010 Order provided for a five (5) month preparatory period prior to submitting pre-trial filings. The time period prior to filing is not simply for what experts are required to do, but also what Pilgrim Watch is required to do, absent a plethora of other supports |
| | - lawyers, paralegals, secretaries, copy room staff, and mail clerks. |
| | Thanking you for your consideration, I am sirely, Mary Lampert \........ |
| | Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 |
| | |
| | UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application September 21, 2010 CERTIFICATE OF SERVICE I hereby certify that Pilgrim Watch's Reply to Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule was served September 21, 2010 in the above captioned proceeding to the following persons by electronic mail this date, followed by deposit of paper copies in the U.S. mail, first class. |
| | Secretary of the Commission Administrative Judge Attn: Rulemakings and Adjudications Richard F. Cole Staff Atomic Safety and Licensing Board Mail Stop 0-16 C I Mail Stop -T-3-F23 United States Nuclear Regulatory US NRC Commission [2 copies] Washington, DC 20555-0001 Administrative Judge Office of Commission Appellate Ann Marshall Young, Chair Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 C1 Mail Stop - T-3 F23 United States Nuclear Regulatory US NRC Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Administrative Judge Atomic Safety and Licensing Board Paul B. Abramson Mail Stop T-3 F23 Atomic Safety and Licensing Board United States Nuclear Regulatory Mail Stop T-3 F23 Commission US NRC Washington, DC 20555-0001 Washington, DC 20555-0001 |
| | |
| | U.S. Nuclear Regulatory Commission Martha Coakley, Attorney General Office of Commission Appellate Matthew Brock, Assistant Attorney Adjudication General Commonwealth of Mail Stop: 0-16C1 Massachusetts Washington, DC 20555-0001 Office of Attorney General One Ashburton Place U.S. Nuclear Regulatory Commission Boston, MA 02108 Office of General Counsel Mail Stop: 0-15 D21 Mark Stankiewicz Washington DC 20555-0001 Town Manager, Town of Plymouth Susan L. Uttal, Esq. 11 Lincoln Street Andrea Jones, Esq. Plymouth MA 02360 Brian Harris, Esq. |
| | Michael Dreher, Esq. Sheila Slocum Hollis, Esq. |
| | Brian Newell, Paralegal Town of Plymouth MA Duane Morris, LLP U.S. Nuclear Regulatory Commission 505 9th Street, N.W. 1000 Office of Nuclear Reactor Regulation Washington D.C. 20004-2166 Mail Stop: 01 -Fl Washington, DC 20555-0001 Richard R. MacDonald Town Manager, Town of Duxbury Lisa Regner, Project Mgr. Plant Lic. 878 Tremont Street Branch 1-1, Operator Reactor Licensing Duxbury, MA 02332 Washington, DC 20555-0001 Fire Chief & Director DEMA, Paul A. Gaukler, Esq. Town of Duxbury David R. Lewis, Esq. 688 Tremont Street Jason B. Parker, Esq. P.O. Box 2824 Pillsbury, Winthrop, Shaw, Pittman, Duxbury, MA 02331 LLP - 2300 N Street, N.W. |
| | Washington, DC 20037-1128 Terence A. Burke, Esq. |
| | Entergy Nuclear Katherine Tucker Mail Stop M-ECH-62 ASLB, Law Clerk Jackson, MS 39213 U.S. Nuclear Regulatory Commission Mail Stop T-3-E2a Washington, DC 20555-0001 Mary Lampert Pilgrim Watch, pro se 148 Washington St. |
| | Duxbury, MA 023332 September 21, 2010 2}} |
|
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Category:Legal-Intervention Petition
MONTHYEARML11346A3012011-06-27027 June 2011 Declaration of Joseph R. Lynch, Lori Ann Potts, and Dr. Kevin R. O'Kula in Support of Entergy'S Answer Opposing Pilgrim Watch Request for Hearing on a New Contention Regarding Inadequacy of Environmental Report, Post-Fukushima ML1102503532011-01-0101 January 2011 Pilgrim Watch Reply to Entergy'S Request to Change the Hearing Date ML1100401252010-12-27027 December 2010 Entergy Answer Opposing Pilgrim Watch Request for Hearing on a New Contention ML1033403262010-11-22022 November 2010 Pilgrim Watch Reply to Order (October 26, 2010) - Questions from Board Majority Regarding the Mechanics of Computing Mean Consequences ML1030810622010-11-0303 November 2010 Response to Pilgrim Watch October 27 Letter Regarding Pilgrim Watch 6th and 7th Supplemental Disclosures ML1028711332010-10-0808 October 2010 Pilgrim Watch Reply to Entergy'S & NRC Staff'S Briefs Regarding Timeliness of Pilgrim Watch'S Raising Averaging Practice Concerns ML1027203992010-09-21021 September 2010 Entergy'S Response to Pilgrim Watch'S Memo Re Proposed Schedule ML1027307882010-09-21021 September 2010 Pilgrim Watch'S Reply to Entergy'S Response to Pilgrim Watch'S Memo Regarding Proposed Schedule ML1027307892010-09-21021 September 2010 Memo Regarding Proposed Schedule ML1021104482010-07-25025 July 2010 Pilgrim Watch Notice to Commission Regarding New and Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848 ML1020900242010-07-19019 July 2010 Pilgrim Watch 2.206 Petition Regarding Inadequacy of Entergy'S Management of Non-Environmentally Qualified Inaccessible Cables & Wiring at Pilgrim Station ML1018000932010-06-28028 June 2010 NRC Staff'S Opposition to Pilgrim Watch'S Motion Requesting Leave to File Response to Judge Paul B. Abramson Decision on Recusal Motion (June 10, 2010) ML1018004862010-06-23023 June 2010 Entergy'S Opposition to Pilgrim Watch'S Motion Requesting Leave to File Response to Judge Abramson'S Decision on Recusal Motion ML1017301832010-06-16016 June 2010 Pilgrim Watch Response to Judge Paul B. Abramson Decision on Recusal Motion ML1014605742010-05-21021 May 2010 Entergy'S Opposition to Pilgrim Watch Motion to Disqualify Judge Abramson ML1014402032010-05-17017 May 2010 Entergy'S Reply to Pilgrim Watch'S Response to Aslb'S May 5, 2010 Order ML1015404212010-05-17017 May 2010 Pilgrim Watch'S Reply to Entergy'S Submission on Scope and Schedule for Remanded Hearing ML1014503232010-05-17017 May 2010 Pilgrim Watch'S Reply to NRC Staff'S Initial Brief to the Board'S Order (Regarding Deadlines for Submission of Parties) ML1014107452010-05-12012 May 2010 Pilgrim Watch Response to Aslb'S May 5, 2010 Order ML1014107432010-05-12012 May 2010 Entergy'S Submission on Scope and Schedule for Remanded Hearing ML1010504322010-04-15015 April 2010 NRC Staff'S Response in Opposition to Pilgrim Watch'S Motion for Reconsideration of CLI-10-11 ML1010408202010-04-0808 April 2010 Entergy'S Opposition to Pilgrim Watch'S Motion for Reconsideration of CLI-10-11 ML1010408192010-04-0707 April 2010 Entergy'S Opposition to Pilgrim Watch'S Motion to Reschedule Telephone Conference ML1010408212010-04-0707 April 2010 Entergy'S Opposition to Town of Plymouth'S Motion to Reschedule Telephone Conference ML1004808082010-02-0202 February 2010 Pilgrim Watch'S Reply to NRC Staff'S Response to Pilgrim Watch Notice to Commission Regarding New & Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848 ML0823700122008-08-19019 August 2008 Pilgrim - Notice of Withdrawal of Appearance for James E. Adler ML0816402452008-05-15015 May 2008 2008/05/15-Supplemental Petition by Listed Companies for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews, for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0814906102008-05-15015 May 2008 2008/05/15-Supplemental Petition by Collective Petitioners for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0814306512008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.: Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club: New Jersey.. ML0808600962008-03-17017 March 2008 Pilgrim Watch Reply to NRC Staff'S Motion in Limine to Strike Exhibits and Testimony Filed by Pilgrim Watch, March 10, 2008 ML0808600952008-03-17017 March 2008 Pilgrim Watch Reply to Entergy'S Motion in Limine to Strike Exhibits and Testimony Filed by Pilgrim Watch, March 10, 2008 ML0807402022008-03-0707 March 2008 Entergy'S Eleventh Supplemental Disclosure ML0802904142008-01-18018 January 2008 2008/01/18-Answer of Entergy Nuclear Operation, Inc. Opposing Petition to Suspend License Renewal Reviews and Proceedings ML0802803052008-01-18018 January 2008 2008/01/18-NRC Staff Answer to Petition for Suspension of License Renewal Reviews Pending Investigation of NRC Staff License Renewal Process ML0735403732007-12-14014 December 2007 Entergy'S Eighth Supplemental Disclosure ML0726901592007-09-20020 September 2007 Entergy Nuclear Operations Inc. Answer Opposing Intervention Petition of Local 369, Utility Workers Union of America, AFL-CIO ML0726205402007-09-18018 September 2007 Motion to Intervene of Local 369, Utility Workers Union of America, AFL-CIO ML0721901912007-07-30030 July 2007 Pilgrim Watch'S Answer Opposing NRC Staff'S Motion Requesting That Pilgrim Watch'S Answer Opposing NRC Staff Support of Entergy'S Motion to Strike Pilgrim Watch'S Answer to Entergy'S Summary Disposition Motion Not Be Considered by the Board ML0721302252007-07-26026 July 2007 Pilgrim - Pilgrim Watch'S Answer Opposing NRC Staff'S Support of Entergy'S Motion to Strike Portions of Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Contention 3 ML0720501452007-07-17017 July 2007 Pilgrim - Pilgrim Watch'S Answer Opposing Entergy'S Motion to Strike Portions of Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3 ML0718405682007-06-29029 June 2007 Pilgrim - Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3 ML0718000592007-06-28028 June 2007 Pilgrim - NRC Staff Response to Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 1 ML0716303952007-06-0505 June 2007 Pilgrim - Entergy'S Sixth Supplemental Disclosure ML0715002992007-05-24024 May 2007 Pilgrim - Entergy'S Opposition to Pilgrim Watch Request to Extend Time to Respond to Summary Disposition of Pilgrim Watch Contention 3 ML0715201682007-05-22022 May 2007 Pilgrim - Notice of Appearance of Mary Elizabeth Lampert ML0711702672007-04-18018 April 2007 Pilgrim - Second Disclosure Statement by Pilgrim Watch ML0711702602007-04-16016 April 2007 Pilgrim - Entergy'S Fourth Supplemental Disclosure ML0708002172007-03-15015 March 2007 Pilgrim - Entergy'S Third Supplemental Disclosure ML0707301912007-03-0606 March 2007 Pilgrim - Letter to Judge Cole from S. Uttal, OGC Providing (Cd) Version of Safety Evaluation Report with Open Items ML0634803752006-12-0808 December 2006 Pilgrim- Entergy'S Comments on Proposed Schedule 2011-06-27
[Table view] Category:Responses and Contentions
MONTHYEARML11346A3012011-06-27027 June 2011 Declaration of Joseph R. Lynch, Lori Ann Potts, and Dr. Kevin R. O'Kula in Support of Entergy'S Answer Opposing Pilgrim Watch Request for Hearing on a New Contention Regarding Inadequacy of Environmental Report, Post-Fukushima ML1102503532011-01-0101 January 2011 Pilgrim Watch Reply to Entergy'S Request to Change the Hearing Date ML1100401252010-12-27027 December 2010 Entergy Answer Opposing Pilgrim Watch Request for Hearing on a New Contention ML1033403262010-11-22022 November 2010 Pilgrim Watch Reply to Order (October 26, 2010) - Questions from Board Majority Regarding the Mechanics of Computing Mean Consequences ML1030810622010-11-0303 November 2010 Response to Pilgrim Watch October 27 Letter Regarding Pilgrim Watch 6th and 7th Supplemental Disclosures ML1028711332010-10-0808 October 2010 Pilgrim Watch Reply to Entergy'S & NRC Staff'S Briefs Regarding Timeliness of Pilgrim Watch'S Raising Averaging Practice Concerns ML1027203992010-09-21021 September 2010 Entergy'S Response to Pilgrim Watch'S Memo Re Proposed Schedule ML1027307882010-09-21021 September 2010 Pilgrim Watch'S Reply to Entergy'S Response to Pilgrim Watch'S Memo Regarding Proposed Schedule ML1027307892010-09-21021 September 2010 Memo Regarding Proposed Schedule ML1021104482010-07-25025 July 2010 Pilgrim Watch Notice to Commission Regarding New and Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848 ML1020900242010-07-19019 July 2010 Pilgrim Watch 2.206 Petition Regarding Inadequacy of Entergy'S Management of Non-Environmentally Qualified Inaccessible Cables & Wiring at Pilgrim Station ML1018000932010-06-28028 June 2010 NRC Staff'S Opposition to Pilgrim Watch'S Motion Requesting Leave to File Response to Judge Paul B. Abramson Decision on Recusal Motion (June 10, 2010) ML1018004862010-06-23023 June 2010 Entergy'S Opposition to Pilgrim Watch'S Motion Requesting Leave to File Response to Judge Abramson'S Decision on Recusal Motion ML1017301832010-06-16016 June 2010 Pilgrim Watch Response to Judge Paul B. Abramson Decision on Recusal Motion ML1014605742010-05-21021 May 2010 Entergy'S Opposition to Pilgrim Watch Motion to Disqualify Judge Abramson ML1014402032010-05-17017 May 2010 Entergy'S Reply to Pilgrim Watch'S Response to Aslb'S May 5, 2010 Order ML1015404212010-05-17017 May 2010 Pilgrim Watch'S Reply to Entergy'S Submission on Scope and Schedule for Remanded Hearing ML1014503232010-05-17017 May 2010 Pilgrim Watch'S Reply to NRC Staff'S Initial Brief to the Board'S Order (Regarding Deadlines for Submission of Parties) ML1014107452010-05-12012 May 2010 Pilgrim Watch Response to Aslb'S May 5, 2010 Order ML1014107432010-05-12012 May 2010 Entergy'S Submission on Scope and Schedule for Remanded Hearing ML1010504322010-04-15015 April 2010 NRC Staff'S Response in Opposition to Pilgrim Watch'S Motion for Reconsideration of CLI-10-11 ML1010408202010-04-0808 April 2010 Entergy'S Opposition to Pilgrim Watch'S Motion for Reconsideration of CLI-10-11 ML1010408192010-04-0707 April 2010 Entergy'S Opposition to Pilgrim Watch'S Motion to Reschedule Telephone Conference ML1010408212010-04-0707 April 2010 Entergy'S Opposition to Town of Plymouth'S Motion to Reschedule Telephone Conference ML1004808082010-02-0202 February 2010 Pilgrim Watch'S Reply to NRC Staff'S Response to Pilgrim Watch Notice to Commission Regarding New & Significant Information Pertaining to Pilgrim Watch'S Petition for Review of LBP-06-848 ML0823700122008-08-19019 August 2008 Pilgrim - Notice of Withdrawal of Appearance for James E. Adler ML0816402452008-05-15015 May 2008 2008/05/15-Supplemental Petition by Listed Companies for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews, for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0814906102008-05-15015 May 2008 2008/05/15-Supplemental Petition by Collective Petitioners for Additional Investigation and Correction of Deficiencies Regarding License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, and Vermont Yankee Nuclear Power Plants ML0814306512008-05-15015 May 2008 Supplemental Petition by Nuclear Information and Resource Service: Jersey Shore Nuclear Watch, Inc.: Grandmothers, Mothers and More for Energy Safety: New Jersey Public Interest Research Group: New Jersey Sierra Club: New Jersey.. ML0808600962008-03-17017 March 2008 Pilgrim Watch Reply to NRC Staff'S Motion in Limine to Strike Exhibits and Testimony Filed by Pilgrim Watch, March 10, 2008 ML0808600952008-03-17017 March 2008 Pilgrim Watch Reply to Entergy'S Motion in Limine to Strike Exhibits and Testimony Filed by Pilgrim Watch, March 10, 2008 ML0807402022008-03-0707 March 2008 Entergy'S Eleventh Supplemental Disclosure ML0802904142008-01-18018 January 2008 2008/01/18-Answer of Entergy Nuclear Operation, Inc. Opposing Petition to Suspend License Renewal Reviews and Proceedings ML0802803052008-01-18018 January 2008 2008/01/18-NRC Staff Answer to Petition for Suspension of License Renewal Reviews Pending Investigation of NRC Staff License Renewal Process ML0735403732007-12-14014 December 2007 Entergy'S Eighth Supplemental Disclosure ML0726901592007-09-20020 September 2007 Entergy Nuclear Operations Inc. Answer Opposing Intervention Petition of Local 369, Utility Workers Union of America, AFL-CIO ML0726205402007-09-18018 September 2007 Motion to Intervene of Local 369, Utility Workers Union of America, AFL-CIO ML0721901912007-07-30030 July 2007 Pilgrim Watch'S Answer Opposing NRC Staff'S Motion Requesting That Pilgrim Watch'S Answer Opposing NRC Staff Support of Entergy'S Motion to Strike Pilgrim Watch'S Answer to Entergy'S Summary Disposition Motion Not Be Considered by the Board ML0721302252007-07-26026 July 2007 Pilgrim - Pilgrim Watch'S Answer Opposing NRC Staff'S Support of Entergy'S Motion to Strike Portions of Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Contention 3 ML0720501452007-07-17017 July 2007 Pilgrim - Pilgrim Watch'S Answer Opposing Entergy'S Motion to Strike Portions of Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3 ML0718405682007-06-29029 June 2007 Pilgrim - Pilgrim Watch'S Answer Opposing Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3 ML0718000592007-06-28028 June 2007 Pilgrim - NRC Staff Response to Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 1 ML0716303952007-06-0505 June 2007 Pilgrim - Entergy'S Sixth Supplemental Disclosure ML0715002992007-05-24024 May 2007 Pilgrim - Entergy'S Opposition to Pilgrim Watch Request to Extend Time to Respond to Summary Disposition of Pilgrim Watch Contention 3 ML0715201682007-05-22022 May 2007 Pilgrim - Notice of Appearance of Mary Elizabeth Lampert ML0711702672007-04-18018 April 2007 Pilgrim - Second Disclosure Statement by Pilgrim Watch ML0711702602007-04-16016 April 2007 Pilgrim - Entergy'S Fourth Supplemental Disclosure ML0708002172007-03-15015 March 2007 Pilgrim - Entergy'S Third Supplemental Disclosure ML0707301912007-03-0606 March 2007 Pilgrim - Letter to Judge Cole from S. Uttal, OGC Providing (Cd) Version of Safety Evaluation Report with Open Items ML0634803752006-12-0808 December 2006 Pilgrim- Entergy'S Comments on Proposed Schedule 2011-06-27
[Table view] |
Text
kks j -. ;k- -) /
DOCKETED USNRC September 22, 2010 (8:00a.m.)
OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293 Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application September 21, 2010 Pilgrim Watch's Reply to Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule The statement in Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule saying that "Pilgrim Watch was previously able to prepare its testimony in six weeks,
[and] there is no good reason why is now needs more than three months" is misleading and totally disingenuous.
The Board's May 5, 2010 Order provided for a five (5) month preparatory period prior to submitting pre-trial filings. The time period prior to filing is not simply for what experts are required to do, but also what Pilgrim Watch is required to do, absent a plethora of other supports
- lawyers, paralegals, secretaries, copy room staff, and mail clerks.
Thanking you for your consideration, I am sirely, Mary Lampert \........
Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application September 21, 2010 CERTIFICATE OF SERVICE I hereby certify that Pilgrim Watch's Reply to Entergy's Response to Pilgrim Watch's Memo Regarding Proposed Schedule was served September 21, 2010 in the above captioned proceeding to the following persons by electronic mail this date, followed by deposit of paper copies in the U.S. mail, first class.
Secretary of the Commission Administrative Judge Attn: Rulemakings and Adjudications Richard F. Cole Staff Atomic Safety and Licensing Board Mail Stop 0-16 C I Mail Stop -T-3-F23 United States Nuclear Regulatory US NRC Commission [2 copies] Washington, DC 20555-0001 Administrative Judge Office of Commission Appellate Ann Marshall Young, Chair Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 C1 Mail Stop - T-3 F23 United States Nuclear Regulatory US NRC Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Administrative Judge Atomic Safety and Licensing Board Paul B. Abramson Mail Stop T-3 F23 Atomic Safety and Licensing Board United States Nuclear Regulatory Mail Stop T-3 F23 Commission US NRC Washington, DC 20555-0001 Washington, DC 20555-0001
U.S. Nuclear Regulatory Commission Martha Coakley, Attorney General Office of Commission Appellate Matthew Brock, Assistant Attorney Adjudication General Commonwealth of Mail Stop: 0-16C1 Massachusetts Washington, DC 20555-0001 Office of Attorney General One Ashburton Place U.S. Nuclear Regulatory Commission Boston, MA 02108 Office of General Counsel Mail Stop: 0-15 D21 Mark Stankiewicz Washington DC 20555-0001 Town Manager, Town of Plymouth Susan L. Uttal, Esq. 11 Lincoln Street Andrea Jones, Esq. Plymouth MA 02360 Brian Harris, Esq.
Michael Dreher, Esq. Sheila Slocum Hollis, Esq.
Brian Newell, Paralegal Town of Plymouth MA Duane Morris, LLP U.S. Nuclear Regulatory Commission 505 9th Street, N.W. 1000 Office of Nuclear Reactor Regulation Washington D.C. 20004-2166 Mail Stop: 01 -Fl Washington, DC 20555-0001 Richard R. MacDonald Town Manager, Town of Duxbury Lisa Regner, Project Mgr. Plant Lic. 878 Tremont Street Branch 1-1, Operator Reactor Licensing Duxbury, MA 02332 Washington, DC 20555-0001 Fire Chief & Director DEMA, Paul A. Gaukler, Esq. Town of Duxbury David R. Lewis, Esq. 688 Tremont Street Jason B. Parker, Esq. P.O. Box 2824 Pillsbury, Winthrop, Shaw, Pittman, Duxbury, MA 02331 LLP - 2300 N Street, N.W.
Washington, DC 20037-1128 Terence A. Burke, Esq.
Entergy Nuclear Katherine Tucker Mail Stop M-ECH-62 ASLB, Law Clerk Jackson, MS 39213 U.S. Nuclear Regulatory Commission Mail Stop T-3-E2a Washington, DC 20555-0001 Mary Lampert Pilgrim Watch, pro se 148 Washington St.
Duxbury, MA 023332 September 21, 2010 2