|
---|
Category:Legal-Pleading
MONTHYEARML20177A6212020-06-25025 June 2020 Applicants Status Report ML20156A0502020-06-0404 June 2020 Joint Motion of Applicants and the Commonwealth of Massachusetts for a Stay of Issuance of a Decision on the Pending Petitions for Intervention and a Hearing ML20014E7632020-01-14014 January 2020 Commonwealth of Massachusetts' Reply in Support of Motion to Amend Its Petition with New Information ML20007E9182020-01-0707 January 2020 Applicants' Answer Opposing the Commonwealth of Massachusetts' Second Motion to Supplement Its Petition with New Information ML19343C6922019-12-0909 December 2019 Applicants' Answer Opposing Pilgrim Watch'S Third Motion to Supplement Its Motion to Intervene and Request for Hearing ML19329B3242019-11-25025 November 2019 Watch Motion to Supplement Its February 20, 2019 Motion to Intervene and Request for Hearing, Its April 1, 2019 Reply to Petitioners, and Its May 3, 2019 Motion to Supplement ML19284E8962019-10-11011 October 2019 Notice of Appearance and Substitution of Counsel ML19256B9952019-09-13013 September 2019 Applicant'S Answer Opposing Pilgrim Watch'S Stay Motions ML19256B9602019-09-13013 September 2019 Applicants' Answer Opposing the Application of the Commonwealth of Massachusetts for a Stay ML19255K4112019-09-12012 September 2019 Reply of the Commonwealth of Massachusetts in Support of Its Motion for a Twenty-Two Minute Enlargement of Time to File Its Stay Application and Supporting Appendix ML19252A3332019-09-0909 September 2019 Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts for a Twenty-Two Minute Enlargement of Time to File Its Stay Application ML19246B1762019-09-0303 September 2019 Applicants Unopposed Motion for Clarification of Time to Respond to Pilgrim Watch Motion for Stay of Exemption ML19234A3582019-08-22022 August 2019 Notice of Appearance - Anita Ghosh Naber ML19231A1542019-08-19019 August 2019 Watch Reply to Applicants' Answer Opposing Pilgrim Watch'S Motion to File a New Contention ML19228A0902019-08-16016 August 2019 Pilgrm Watch Memorandum in Support of Emergency Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application to Stay a NRC Staff Order Approving the License Transfer Application ML19228A1672019-08-16016 August 2019 Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application for Stay ML19228A1622019-08-16016 August 2019 Notice of Appearance and Substitution of Counsel ML19227A2902019-08-15015 August 2019 Watch Memorandum in Support of Emergency Motion of the Commonwealth of Massachusetts for Clarification of the Commission'S August 14, 2019 Memorandum and Order ML19224C4242019-08-12012 August 2019 Applicants' Answer Opposing Pilgrim Watch'S Motion to File a New Contention ML19217A3682019-08-0505 August 2019 Applicants' Answer Opposing the Motion of the Commonwealth of Massachusetts to Stay Proceedings to Complete Settlement Negotiations ML19197A3302019-07-16016 July 2019 Watch Motion to File a New Contention ML19137A0732019-05-17017 May 2019 Applicants' Answer Opposing Pilgrim Watch'S Motion to Supplement Its Motion to Intervene and Request for Hearing ML19126A0502019-05-0606 May 2019 Watch Reply to Applicants Answer Opposing Pilgrim Watch Motion to Supplement Its Motion to Intervene and Request for Hearing May 6, 2019 Its Motion to Intervene and Request for Hearing (May 6, 2019) ML19122A1262019-05-0202 May 2019 Applicant'S Answer Opposing Pilgrim Watch Motion to Supplement Its Motion to Intervene and Request for Hearing ML19122A1222019-05-0202 May 2019 Applicant'S Answer Opposing the Commonwealth of Massachusetts Motion to Supplement Its Petition with New Information ML19116A1622019-04-26026 April 2019 Watch Motion to Supplement Its Motion to Intervene and Request for Hearing. New Information ML19091A2972019-04-0101 April 2019 Commonwealth of Massachusetts' Reply in Support of Petition for Leave to Intervene and Hearing Request ML19077A1902019-03-18018 March 2019 Notice of Appearances for Mary E. Lampert and James B. Lampert ML19077A2352019-03-18018 March 2019 Applicants' Answer Opposing Pilgrim Watch Petition for Leave to Intervene and Hearing Request ML19077A2322019-03-18018 March 2019 Applicants' Answer Opposing the Commonwealth of Massachusetts' Petition for Leave to Intervene and Hearing Request ML19052A1872019-02-21021 February 2019 Exhibit 4 to Pilgrim Watch Petition to Intervene and Hearing Request ML19052A1902019-02-21021 February 2019 Exhibit 5 to Pilgrim Watch Petition to Intervene and Hearing Request ML19051A0192019-02-20020 February 2019 Watch Petition to Intervene and Hearing Request ML19052A1822017-07-31031 July 2017 Exhibit 2 to Pilgrim Watch Petition to Intervene and Hearing Request ML17095A3642017-04-0505 April 2017 Status of Decision on Petitioners Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109 ML17048A5712017-02-17017 February 2017 Status of Decision on Petitioners Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109 ML16285A3782016-10-11011 October 2016 Petitioners' Response to NRC Staff'S and Entergy'S Opposition to Peitioners' Request for Hearing Regarding Entergy'S Request for Extension to Comply with NRC Order EA-13-109 ML16277A5482016-10-0303 October 2016 Entergy Answer Opposing Request for Hearing Regarding Pilgrim and EA-13-109 ML16277A5612016-10-0303 October 2016 NRC Staff Response to Pilgrim Watch and Co-Petitioners Request for Hearing ML16277A4652016-10-0303 October 2016 Notice of Appearance for Marcia Simon ML16277A2102016-10-0303 October 2016 Notice of Appearance for Robert Carpenter ML16277A4712016-10-0303 October 2016 Notice of Appearance for Matthew Ring ML12195A0912012-07-13013 July 2012 NRC Staff'S Answer to Jones River Watershed Association and Pilgrim Watch'S Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention ML12195A1692012-07-13013 July 2012 Entergy'S Answer Opposing Jones River Watershed Association and Pilgrim Watch'S Petition for Review of LBP-12-11 ML12185A1392012-07-0303 July 2012 Certificate of Service for Jones River Watershed Association and Pilgrim Watch Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention) ML12185A1382012-07-0303 July 2012 Jones River Watershed Association and Pilgrim Watch Petition for Review of Memorandum and Order (Denying Petition for Intervention and Request to Reopen Proceeding and Admit New Contention) LBP 12-11, June 18, 2012 ML12160A4392012-06-0808 June 2012 Entergy'S Answer Opposing Jones River Watershed Association'S and Pilgrim Watch'S Motion to Reopen and Hearing Request on Contention Regarding Water-Related Approvals ML12159A5762012-06-0707 June 2012 NRC Staff'S Answer to Jones River Watershed Association and Pilgrim Watch'S Requests to Reopen the Record and File a New Contention on Water Quality ML12159A5772012-06-0707 June 2012 Notice of Appearance for Maxwell C. Smith ML12157A5742012-06-0505 June 2012 Notice of Appearance for Susan L. Uttal on Entergy Nuclear Operations, Inc., (Pilgrim) 2020-06-04
[Table view] |
Text
December 22, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
) ) ENTERGY NUCLEAR GENERATION
) Docket No. 50
-293-LR COMPANY AND ENTERGY NUCLEAR
) OPERATIONS, INC.
) ) (Pilgrim Nuclear Generating Station)
) NRC STAFF'S ANSWER TO PILGRIM WATCH'S REQUEST TO SUPPLEMENT PETITION FOR REVIEW OF LBP-11-20 and LBP 23 On December 12, 2011, Pilgrim Watch sought to supplement its petitions for review to includ e a December 9, 2011 report by Congressman Edward Markey ("Report").
1 The Staff of the NRC objects to the supplementation of the petition for review on the grounds that it is not relevant or material to the issue s raised by Pilgrim Watch in its petitions for review of the Board decisions in this license renewal proceeding
.2 T he Report discusses the Chairman's exercise of emergency authority, the individual
1Pilgrim Watch's Request to Supplement Petition for Review of Memorandum and Order (Denying Pilgrim Watch's Requests for Hearing on Certain New Contentions ASLBP No. 06
-848-02-LR, August 11, 2011 (Filed August 26, 2011) and Pilgrim Watch's Petition for Review of Memorandum and Order (Denying Pilgrim Watch's Request for Hearing on New Contentions Relating to Fukushima Accident) Sept. 8, 2011 (Filed September 23, 2011), (December 12, 2011) (Agencywide Documents and Access Management System Accession No. ML11346A570).
2 USEC Inc. (American Centrifuge Plant), CLI 10, 63 NRC 451, 470 (2006) (reminding parties of their obligation to inform the board, the Commission, and other parties of relevant new developments in a proceeding);
cf. Duke Power Co. (William B. McGuire Nuclear Station, Units 1 & 2), ALAB
-143, 6 AEC 623, 625 (1973) (parties are required to inform the board and other parties of new information that is relevant and material to the matters being adjudicated
). Commissioners' views and voting record s regarding the creation of the NRC Near-Term Task Force (TF) on the Fukushima accident, and the process by which the TF's recommendations will be addressed. The Report does not discuss the Pilgrim Nuclear Generating Statio n in particular or the Board's Orders that are the subject of Pilgrim Watch's petition s for review. It provides no new information or data that are relevant to any factual issue raised by Pilgrim Watch before the Board. It addresses none of the legal issues involved in the appeal of the Board's decisions. It thus provides no legal or factual basis for overturning the Board's decision s. Accordingly, the Request to Supplement the Petitions for Review should be denied.
Respectfully submitted, Susan Uttal
/Electronically signed/
Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop: O15
-D21 Washington, DC 20555 Telephone: (301) 415
-1582 E-mail: Susan.Uttal@nrc.gov Dated at Rockville, Maryland This 22 nd day of December, 2011
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION 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 Answer to Pilgrim Watch's Request to Supplement Petition for Review of LBP 20 and LBP-11-23" has been served upon the following by the Electronic Information Exchange, this 22nd day of December, 2011: Administrative Judge Richard F. Cole Atomic Safety and Licensing Board Panel Mail Stop: T
-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555
-0001 E-mail: Richard.Cole@nrc.gov Administrative Judge Paul B. Abramson Atomic Safety and Licensing Board Panel Mail Stop: T
-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555
-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 thWashington, DC 20004 St., NW, Suite 1000 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.
Paul A. Gaukler, Esq.
Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, NW Washington, DC 20037
-1137 E-mail: david.lewis@pillsburylaw.com paul.gaukler@pillsburylaw.com Chief Kevin M. Nord Fire Chief & 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.
Plymouth, MA 02360 E-mail: marrighi@townhall.plymouth.ma.us Richard R. MacDonald Town Manager 878 Tremont Street Duxbury, MA 02332 E-mail: macdonald@town.duxbury.ma.us Matthew Brock Assistant Attorney General Commonwealth of Massachusetts One Ashburton Place Boston, MA 02108 Martha.Coakley@state.ma.us Matthew.Brock@state.ma.us
/Signed (electronically) by/
____________________
Susan L. Uttal Counsel for NRC Staff U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop
- O-15D21 Washington, DC 20555 Telephone: (301) 415
-5236 E-mail: Susan.Uttal@nrc.gov Date of signature: December 22, 2011