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Category:Legal-Pleading
MONTHYEARML20279A4812020-10-0505 October 2020
C-10 Research and Education Foundation'S Reply to Oppositions to Motion for Partial Reconsideration and Motion to Re-Open the Record for Consideration of Supplemental Testimony Regarding License Conditions in LBP-20-09
ML20272A2742020-09-28028 September 2020
Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply and Motion for Leave to File INT053
ML20254A2342020-09-10010 September 2020
Nextera'S Answer Opposing C-10 Motion for Leave and Motion for Partial Reconsideration of LBP-20-9
ML20254A2352020-09-10010 September 2020
Nextera'S Answer Opposing C-10 Motion to Reopen the Record for Consideration of Supplemental Testimony
ML20244A3212020-08-31031 August 2020
C-10 Research and Education Foundation'S Motion for Partial Reconsideration and Motion to Re-Open the Record for Consideration of Supplemental Testimony Regarding License Conditions in LBP-20-09
ML20244A3202020-08-31031 August 2020
C-10 Research and Education Foundation'S Motion for Leave to File Motion for Partial Reconsideration of LBP-20-09
ML20043E2542020-01-31031 January 2020
Redacted C-10 Research and Education'S Supplemental Proposed Findings of Fact and Conclusions of Law
ML20031D6992020-01-31031 January 2020
NRC Staff Supplemental Proposed Findings of Fact and Conclusions of Law
ML20031E7222020-01-31031 January 2020
NextEra Energy Seabrook Llc'S Supplemental Proposed Findings of Fact and Conclusions of Law
ML19354C4482019-12-20020 December 2019
C-10 Research and Education Foundation'S Response to Nextera'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law
ML19353D4192019-12-19019 December 2019
C-10 Research and Education Foundation'S Response to Nextera'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law
ML19347D0672019-12-13013 December 2019
NextEra Energy Seabrook Llc'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law
ML19347D0702019-12-13013 December 2019
NextEra Energy Seabrook Llc'S Responsive Proposed Findings of Fact and Conclusions of Law
ML19333B9702019-11-29029 November 2019
Unopposed Motion for Extension of Time to Seek Leave to File Responsive Proposed Findings of Fact and Conclusions of Law
ML20043E2522019-11-27027 November 2019
Redacted Corrected C-10 Research and Education Foundation'S Proposed Findings of Fact and Conclusions of Law
ML19325D9092019-11-21021 November 2019
NRC Staff Proposed Findings of Fact and Conclusions of the Law for the Admitted Contention
ML19325F3902019-11-21021 November 2019
NextEra Energy Seabrook Llc'S Proposed Findings of Fact and Conclusions of Law
ML19310E2592019-11-0606 November 2019
Nextera'S Answer Opposing C-10's Third Motion for Leave to File Supplemental Testimony
ML19304B3522019-10-31031 October 2019
C-10 Research and Education Foundation'S Response to ASLB Memorandum and Motion to Submit Additional Exhibits Regarding Petrographic Observations and Analyses of ASR at Seabrook
ML19283A0362019-10-0909 October 2019
Nextera'S Answer Opposing C-10's Motions to Compel Production of Mineralogical Data and to Submit Additional Post-Hearing Testimony
ML19272B3252019-09-30030 September 2019
C-10 Research and Education Foundation'S Motion to Compel Production of Mineralogy Data and Request for Opportunity to Submit Supplemental Written Testimony Regarding the Data
ML19262K7512019-09-19019 September 2019
C-10 Research and Education Foundation'S Opposition to Nextera'S Second Motion in Limine
ML19261B8802019-09-18018 September 2019
NRC Staff'S Answer to Nextera'S Motion in Limine
ML19254F1582019-09-11011 September 2019
Appendix a Revised Exhibit List for September 2019 Evidentiary Hearing Exhibits
ML19253D6782019-09-10010 September 2019
NRC Staff'S Answer to C-10's Motion to Supplement Rebuttal Testimony
ML19252B3072019-09-0909 September 2019
NextEra Answer Opposing C-10 Motion for Leave to File Supplemental Rebuttal
ML19252B2322019-09-0909 September 2019
Nextera'S Motion in Limine to Strike or Exclude Portions of C-10's Testimony and Exhibits
ML19247D5932019-09-0404 September 2019
C-10 Research and Education Foundation'S Motion for Leave to File Supplemental Rebuttal Testimony
ML19235A3172019-08-23023 August 2019
C-10 Research and Education Foundation, Inc. Rebuttal Statement of Position on C-10's Contentions Regarding Nextera'S Program for Managing ASR at Seabrook Station Nuclear Power Plant
ML19235A3182019-08-23023 August 2019
Appendix a Revised Exhibit List
ML19205A3412019-07-24024 July 2019
NRC Staff Initial Written Statement of Position
ML19205A4882019-07-24024 July 2019
NextEra Energy Seabrook LLC Statement of Position and Certificate of Service
ML19171A4012019-06-20020 June 2019
C-10 Research and Education Foundation'S Errata to Exhibit INT-001, Testimony of Dr. Victor E. Saouma
ML19161A3722019-06-10010 June 2019
Appendix a Exhibit List
ML19161A3712019-06-10010 June 2019
C-10 Research and Education Foundation, Inc. Initial Statement of Position on Contentions Re Nextera'S Program for Managing ASR at Seabrook Station
ML19123A1912019-05-0303 May 2019
C-10 Research and Education Foundation'S Opposition to Nextera'S Motion in Limine
ML19114A0762019-04-23023 April 2019
Nextera'S Motion in Limine to Exclude Testimony and Exhibits Regarding Structure Deformation Monitoring
ML19105B2822019-04-15015 April 2019
Nextera'S Answer Opposing C-10's Motion Regarding Seabrook Station Site Tour
ML19101A4082019-04-11011 April 2019
C-10 Research and Education Foundation'S Motion Regarding Seabrook Station Site Tour
ML19064B4022019-03-0505 March 2019
Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply to Answers to C-10's Emergency Petition
ML19064A6322019-03-0505 March 2019
Notice of Appearance for Jennifer E. Scro
ML19060A3042019-03-0101 March 2019
C-10 Research and Education Foundation'S Reply to Oppositions by NextEra and NRC Staff to Emergency Petition for Exercise of Commission'S Supervisory Authority to Reverse No Significant Hazards Determination and Immediately Suspend License
ML19060A3032019-03-0101 March 2019
C-10 Research and Education Foundation'S Motion for Leave to File Reply to Oppositions by NextEra and NRC Staff to Emergency Petition
ML19056A5882019-02-25025 February 2019
NRC Staff Answer to C-10's Emergency Petition
ML19056A5862019-02-25025 February 2019
Nextera'S Answer Opposing C-10 Emergency Petition
ML19044A7702019-02-13013 February 2019
Exhibit 1 to Saouma Declaration: Curriculum Vitae for Dr. Victor E. Saouma
ML19044A7682019-02-13013 February 2019
Emergency Petition by C-10 Research and Education Foundation for Exercise of Commission'S Supervisory Authority to Reverse No Significant Hazards Determination and Immediately Suspend License Amendment and License Renewal Decisions
ML19044A7692019-02-13013 February 2019
Declaration of Victor E. Saouma, Ph.D
ML19044A7722019-02-13013 February 2019
Exhibit 3 to Saouma Declaration: Sauoma, Experimental and Numerical Investigation of Alkali Silica Reaction in Nuclear Reactors, Final Summary Report
ML19044A7732019-02-12012 February 2019
Exhibit 4a to Saouma Declaration: Introduction and Executive Summary
2020-09-28
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August 22, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
NextEra Energy Seabrook, LLC ) Docket No. 50-443-LR
) ASLBP No. 10-906-02-LR (Seabrook Station, Unit 1) )
NextEra Energy Seabrook LLCs Objection to Filing of Rulemaking Petition and Suspension Request Before the Atomic Safety and Licensing Board On August 11, 2011, Friends of the Coast and the New England Coalition (Friends/NEC) filed before both the Secretary and the Atomic Safety and Licensing Board (Board) a Rulemaking Petition to Rescind Prohibition Against Consideration of Environmental Impacts of Severe Accidents and Spent Fuel Pool Accidents and Request to Suspend Licensing Decisions (Petition).1 The Petition requests that the NRC rescind regulations in 10 C.F.R. Part 51 that make generic conclusions about the environmental impacts of severe reactor and spent fuel pool accidents, and also requests that the NRC suspend the Seabrook license renewal proceeding while the NRC considers this petition and the environmental issues raised in a proposed new contention alleging a requirement to address the implications of the Fukushima Task Force Report. Petition at 1.
To the extent that this Petition seeks any action by the Board, NextEra Energy Seabrook, LLC (NextEra) objects to Friends/NECs placing the Petition before the Board, because the Board has no authority to grant it. 10 C.F.R. § 2.802(a) provides that a rulemaking petition should be addressed to the Secretary, and the Board has been
delegated no authority to rescind the NRCs rules. Further, 10 C.F.R. § 2.802(a) provides that a petitioner for rulemaking may request the Commission (not the presiding officer) to suspend a proceeding to which the petitioner is a party pending disposition of the rulemaking petition. In addition, Friends/NEC and other entities have already submitted a request to the Commission to suspend all licensing proceedings proceeding pending consideration of the environmental implications of the Fukushima Daiichi accident,2 so any attempt to put a duplicative request before the Board is inappropriate. For all these reasons, Friends/NECs Petition is not properly before the Board,3 and NextEra will address its opposition to the Commission.
Respectfully Submitted,
/Signed electronically by Steven Hamrick/
Mitchell S. Ross Steven Hamrick James M. Petro, Jr. NextEra Energy Seabrook, LLC NextEra Energy Seabrook, LLC 801 Pennsylvania Avenue, N.W. Suite 220 700 Universe Blvd. Washington, DC 20004 Juno Beach, Florida 33408 Telephone: 202-349-3496 Telephone: 561-691-7126 Facsimile: 202-347-7076 Facsimile: 561-691-7135 E-mail: steven.hamrick@fpl.com E-mail: mitch.ross@fpl.com james.petro@fpl.com Counsel for NextEra Energy Seabrook, LLC Dated: August 22, 2011 1
Beyond Nuclear filed a similar petition on the same date, but addressed it only to the Secretary.
2 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned From Fukushima Daiichi Nuclear Power Station Accident (April 18, 2011).
3 NextEra does not object to the suspension request being submitted on the docket of this license renewal proceeding. NextEra only objects to its being filed as a request before the Board.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
NextEra Energy Seabrook, LLC ) Docket No. 50-443-LR
) ASLBP No. 10-906-02-LR (Seabrook Station, Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that NextEra Energy Seabrook LLCs Objection to Filing of Rulemaking Petition and Suspension Request Before the Atomic Safety and Licensing Board, dated August 22, 2011, was provided to the Electronic Information Exchange for service on the individuals listed below, this 22nd day of August, 2011.
Secretary Office of Commission Appellate Attn: Rulemakings and Adjudications Staff Adjudication U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 hearingdocket@nrc.gov E-mail: OCAAMAIL@nrc.gov Administrative Judge Administrative Judge Paul S. Ryerson, Esq., Chair Dr. Richard E. Wardwell Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Email: psr1@nrc.gov Email: richard.wardwell@nrc.gov Administrative Judge Mary Spencer, Esq.
Dr. Michael Kennedy Maxwell C. Smith, Esq.
Atomic Safety and Licensing Board Richard S. Harper, Esq.
U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Email: michael.kennedy@nrc.gov Washington, DC 20555-0001 E-mail: mary.spencer@nrc.gov; maxwell.smith@nrc.gov; Richard.Harper@nrc.gov Raymond Shadis Kurt Ehrenberg New England Coalition New Hampshire Sierra Club Post Office Box 98 40 N. Main Street Edgecomb, Maine 04556 Concord, NH 03301 E-mail: shadis@prexar.com E-mail: Kurt.Ehrenberg@sierraclub.org
Paul Gunter Doug Bogen Beyond Nuclear Executive Director 6930 Carroll Avenue, Suite 400 Seacoast Anti-Pollution League Takoma Park, MD 20912 PO Box 1136 E-mail: paul@beyondnuclear.com Portsmouth, NH 03802 E-mail: dbogen@metrocast.net Matthew Brock, Esq.
Assistant Attorney General Environmental Protection Division Office of the Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 matthew.brock@state.ma.us
/Signed electronically by Steven Hamrick /
Steven Hamrick 2
