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{{#Wiki_filter:UNITED STAT ES O F AMERICA NUCLEAR REG ULATORY COMMISSION Before the At om ic Saf ety and Licensin g Board I n the Matter of
{{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of:                                     )       Docket No. 50-255-LA2 Entergy Nuclear Operations, Inc.                      )
: Enterg y Nuclea r Ope rations, I nc.(Palisades Nuc lear Plant)Oper ating L icense Amendment Reque st)   Docke t No. 50-255-L A2 ))           Jul y 8, 2015)     *****PETITIONERS' POSITION STA TEMENT ON MANDATORY DISCLOSURE S AND SC HEDULE Now come Be y ond Nuclea r ("BN"), D on't Waste Michig an ("DWM"), Michig an Safe Energ y Future - Shoreline Chapte r ("MSEF"), and the Nuc lear Energ y I nformation Servic e ("N EI S") (he rea fter c ollectively called "Petitioners"), by counsel, a nd explain their positi ons on two aspec ts of the "Joint Proposal on Mandatory Disclosures a nd Schedule."
(Palisades Nuclear Plant)
: 1. Com m encem ent Date of Disclosu res Enterg y has propose d that initial dis closures be defe rre d to 30 day s after Commi ssion action on Enter g y's planned a ppeal of the B oard's J une 18, 2015 Memora ndum and Orde r (Gra nting Petition to I nterve ne and Re quest for H ear ing), L BP-15-20, or three months from the date of the B oard's ruling in L BP-15-20, whicheve r come s first. The NRC Staff doe s not object to this proposal.
                                                      )       July 8, 2015 Operating License Amendment Request
The interve nors object be cause the re actor pressure vessel at Palisade s, which is widely believed to be the most-embrittled in Western Hemispher e, ca nnot wait for a ppeals. The RPV is becoming ever more e mbrittled daily. Dialog ue betwe en the Staff and Enter g y respe cting RPV monitoring a nd oversig ht continues apa ce dur ing this extremely critica l period. Petitioners repr esent sig nificant number s of the g ener al public who ar e ver y conce rned a bout the persistent neg ative dire ction of the RPV's condition. The a ppeal may take ha lf a y ear for r esolution. The public deser ves to have RPV-relate d information broug ht to its specific attention during that period. I t will also enhance eff iciency of sche duling the pr ocee dings onc e re mand has oc curr ed (bec ause the likelihood of the Commis sion rever sing the ASL B, in Petitioners' opinion, is small).
                                                      )
: 2. Deadline f or F ilin g New or Am ended Contentions Enterg y and the NRC Staff pr opose that the de adline for filing ne w or a mended contentions based on the Safety Evaluation be 30 da y s after its availability. The Petitioners propose that the de adline for filing ne w or a mended c ontentions based on the Saf ety Evaluation be 60 day s after its availability. Six ty (60) da y s was the mea sure a dopted by the ASL B in the pending Davis-B esse lice nse re newa l proce eding. Given the likely complexit y of the SE on this novel issue, and the potential nee d for Petitioners to identify one or more appropr iate experts in the narrow are a of me tallugic al scienc e, 60 day s is not unreasonable. Respectf ully ,          
PETITIONERS POSITION STATEMENT ON MANDATORY DISCLOSURES AND SCHEDULE Now come Beyond Nuclear (BN), Dont Waste Michigan (DWM), Michigan Safe Energy Future - Shoreline Chapter (MSEF), and the Nuclear Energy Information Service (NEIS) (hereafter collectively called Petitioners), by counsel, and explain their positions on two aspects of the Joint Proposal on Mandatory Disclosures and Schedule.
  /s/ Terry J. L odg e Terr y J. L odg e (O H #0029271) 316 N. Michig an St., Ste. 520 Toledo, OH 43604-5627 (419) 255-7552 Fa x (419) 255-7552 Tjlodge 50@y ahoo.com Counsel for Petitioners UNITED STAT ES O F AMERICA NUCLEAR REG ULATORY COMMISSION Before the At om ic Saf ety and Licensin g Board I n the Matter of
: 1. Commencement Date of Disclosures Entergy has proposed that initial disclosures be deferred to 30 days after Commission action on Entergys planned appeal of the Boards June 18, 2015 Memorandum and Order (Granting Petition to Intervene and Request for Hearing), LBP-15-20, or three months from the date of the Boards ruling in LBP-15-20, whichever comes first. The NRC Staff does not object to this proposal.
: Enterg y Nuclea r Ope rations, I nc.(Palisades Nuc lear Plant)Oper ating L icense Amendment Reque st)   Docke t No. 50-255-L A2 ))           Jul y 8, 2015)     *****CERTIFIC ATE OF SERVICE I here by cer tify that copies of the fore g oing "PETI TI ONERS' POSI TI ON STATEMENT ON MAND ATORY DI SCL OSURES AND SCHEDUL E" wa s serve d by me upon the par ties to this procee ding via the NRC's Electronic I nformation Exchang e sy stem this 18th day of Jul y , 2015.   /s/ Terry J. L odg e Terr y J. L odg e (O H #0029271) 316 N. Michig an St., Ste. 520 Toledo, OH 43604-5627 (419) 255-7552 Fa x (419) 255-7552 Tjlodge 50@y ahoo.com Counsel for Petitioners }}
The intervenors object because the reactor pressure vessel at Palisades, which is widely believed to be the most-embrittled in Western Hemisphere, cannot wait for appeals. The RPV is becoming ever more embrittled daily. Dialogue between the Staff and Entergy respecting RPV monitoring and oversight continues apace during this extremely critical period. Petitioners represent significant numbers of the general public who are very concerned about the persistent negative direction of the RPVs condition. The appeal may take half a year for resolution. The public deserves to have RPV-related information brought to its specific attention during that period. It will also enhance efficiency of scheduling the proceedings once remand has occurred (because the likelihood of the Commission reversing the ASLB, in Petitioners opinion, is small).
: 2. Deadline for Filing New or Amended Contentions Entergy and the NRC Staff propose that the deadline for filing new or amended contentions based on the Safety Evaluation be 30 days after its availability. The Petitioners propose that the deadline for filing new or amended contentions based on the Safety Evaluation be 60 days after its availability. Sixty (60) days was the measure adopted by the ASLB in the pending Davis-Besse license renewal proceeding. Given the likely complexity of the SE on this novel issue, and the potential need for Petitioners to identify one or more appropriate experts in the narrow area of metallugical science, 60 days is not unreasonable.
Respectfully,
                                                  /s/ Terry J. Lodge Terry J. Lodge (OH #0029271) 316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 255-7552 Fax (419) 255-7552 Tjlodge50@yahoo.com Counsel for Petitioners UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of:                                       )       Docket No. 50-255-LA2 Entergy Nuclear Operations, Inc.                        )
(Palisades Nuclear Plant)
                                                        )       July 8, 2015 Operating License Amendment Request
                                                        )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing PETITIONERS POSITION STATEMENT ON MANDATORY DISCLOSURES AND SCHEDULE was served by me upon the parties to this proceeding via the NRCs Electronic Information Exchange system this 18th day of July, 2015.
                                                  /s/ Terry J. Lodge Terry J. Lodge (OH #0029271) 316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 255-7552 Fax (419) 255-7552 Tjlodge50@yahoo.com Counsel for Petitioners
                                                  }}

Latest revision as of 10:37, 5 February 2020

Petitioners' Position Statement on Mandatory Disclosures and Schedule
ML15189A190
Person / Time
Site: Palisades Entergy icon.png
Issue date: 07/08/2015
From: Lodge T
Beyond Nuclear, Don't Waste Michigan, Michigan Safe Energy Future - Shoreline Chapter (MSEF), Nuclear Energy Information Service
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-255-LA-2, ASLBP 15-939-04-LA-BD01, RAS 28036
Download: ML15189A190 (3)
v • d • e


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of: ) Docket No. 50-255-LA2 Entergy Nuclear Operations, Inc. )

(Palisades Nuclear Plant)

) July 8, 2015 Operating License Amendment Request

)

PETITIONERS POSITION STATEMENT ON MANDATORY DISCLOSURES AND SCHEDULE Now come Beyond Nuclear (BN), Dont Waste Michigan (DWM), Michigan Safe Energy Future - Shoreline Chapter (MSEF), and the Nuclear Energy Information Service (NEIS) (hereafter collectively called Petitioners), by counsel, and explain their positions on two aspects of the Joint Proposal on Mandatory Disclosures and Schedule.

1. Commencement Date of Disclosures Entergy has proposed that initial disclosures be deferred to 30 days after Commission action on Entergys planned appeal of the Boards June 18, 2015 Memorandum and Order (Granting Petition to Intervene and Request for Hearing), LBP-15-20, or three months from the date of the Boards ruling in LBP-15-20, whichever comes first. The NRC Staff does not object to this proposal.

The intervenors object because the reactor pressure vessel at Palisades, which is widely believed to be the most-embrittled in Western Hemisphere, cannot wait for appeals. The RPV is becoming ever more embrittled daily. Dialogue between the Staff and Entergy respecting RPV monitoring and oversight continues apace during this extremely critical period. Petitioners represent significant numbers of the general public who are very concerned about the persistent negative direction of the RPVs condition. The appeal may take half a year for resolution. The public deserves to have RPV-related information brought to its specific attention during that period. It will also enhance efficiency of scheduling the proceedings once remand has occurred (because the likelihood of the Commission reversing the ASLB, in Petitioners opinion, is small).

2. Deadline for Filing New or Amended Contentions Entergy and the NRC Staff propose that the deadline for filing new or amended contentions based on the Safety Evaluation be 30 days after its availability. The Petitioners propose that the deadline for filing new or amended contentions based on the Safety Evaluation be 60 days after its availability. Sixty (60) days was the measure adopted by the ASLB in the pending Davis-Besse license renewal proceeding. Given the likely complexity of the SE on this novel issue, and the potential need for Petitioners to identify one or more appropriate experts in the narrow area of metallugical science, 60 days is not unreasonable.

Respectfully,

/s/ Terry J. Lodge Terry J. Lodge (OH #0029271) 316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 255-7552 Fax (419) 255-7552 Tjlodge50@yahoo.com Counsel for Petitioners UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of: ) Docket No. 50-255-LA2 Entergy Nuclear Operations, Inc. )

(Palisades Nuclear Plant)

) July 8, 2015 Operating License Amendment Request

)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing PETITIONERS POSITION STATEMENT ON MANDATORY DISCLOSURES AND SCHEDULE was served by me upon the parties to this proceeding via the NRCs Electronic Information Exchange system this 18th day of July, 2015.

/s/ Terry J. Lodge Terry J. Lodge (OH #0029271) 316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 255-7552 Fax (419) 255-7552 Tjlodge50@yahoo.com Counsel for Petitioners

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