2010/04/07-Entergy's Opposition to Town of Plymouth'S Motion to Reschedule Telephone ConferenceML101040821 |
Person / Time |
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Site: |
Pilgrim |
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Issue date: |
04/07/2010 |
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From: |
Gaukler P, Doris Lewis Entergy Nuclear Generation Co, Entergy Nuclear Operations, Pillsbury, Winthrop, Shaw, Pittman, LLP |
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To: |
Atomic Safety and Licensing Board Panel |
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SECY RAS |
References |
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50-293-LR, ASLBP 06-848-02-LR, CLI-10-11, RAS J-213 |
Download: ML101040821 (3) |
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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
DOCKETED
- - USNRC ~ ~ ~ 2/
April 7, 2010 '(9:33am)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF April 7, 2010 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR
)
(Pilgrim Nuclear Power Station) )
ENTERGY'S OPPOSITION TO TOWN OF PLYMOUTH'S MOTION TO RESCHEDULE TELEPHONE CONFERENCE Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc. (collectively "Entergy") oppose the Town of Plymouth, Massachusetts Motion to Reschedule Telephone Conference to Address Future Course of Proceeding (April 6, 2010). For the reasons discussed in Entergy's Opposition to Pilgrim Watch's Motion to Reschedule Telephone Conference (April 7, 2010), delaying the conference call and the scheduling of the remanded proceeding by a month is both inconsistent with Commission policy and injurious to Entergy. Further, the Town of Plymouth merely states that it would like to stay informed of the future course of this proceeding. While Ms. Hollis may be unavailable on April 8, Entergy assumes that there are other colleagues at her firm who could monitor the call to stay informed.
f3secfull bj t t ed, David R. Lewis Paul A. Gaukler PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037-1128 Tel. (202) 663-8000 Counsel for Entergy Dated: April 7, 2010
i' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR
)
(Pilgrim Nuclear Power Station) )
CERTIFICATE OF SERVICE I hereby certify that copies of "Entergy's Opposition to Town of Plymouth's Motion to Reschedule Telephone Conference" were served on the persons listed below by deposit in the U.S. Mail, first class, postage prepaid, and where indicated by an asterisk, by electronic mail, this 7th day of April, 2010.
- Secretary *Office of Commission Appellate Adjudication Att'n: Rulemakings and Adjudications Staff Mail Stop 0-16 C1 Mail Stop 0-16 C1 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 ocaamail@nrc.gov secy@nrc.gov; hearingdocket@nrc.gov
- Administrative Judge *Administrative Judge Ann Marshall Young, Esq., Chair Dr. Richard F. Cole Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 amy@nrc.gov rfcl @nrc.gov
- Administrative Judge Atomic Safety and Licensing Board Paul B. Abramson Mail Stop T-3 F23 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop T-3 F23 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 pba@nrc.gov
'I
148 Washington Street *Andrea Z. Jones, Esq.
Duxbury, MA 02332 *Brian Harris, Esq.
mary.lampert@comcast.net Office of the General Counsel Mail Stop 0-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Susan.Uttal@nrc.gov; andrea.jones@nrc.gov; brian.harris@nrc.gov
- Matthew Brock, Assistant Attorney General *Sheila Slocum Hollis, Esq.
Commonwealth of Massachusetts Duane Morris LLP Office of the Attorney General 505 9th Street, NW One Ashburton Place Suite 1000 Boston, MA 02108 Washington, DC 20006 Martha. Coakley@state.ma.us sshollis@duanemorris.com Matthew.Brock/astate.ma.us
- Mr. Mark D. Sylvia *Chief Kevin M. Nord Town Manager Fire Chief and Director, Duxbury Emergency Town of Plymouth Management Agency 11 Lincoln St. 688 Tremont Street Plymouth, MA 02360 P.O. Box 2824 msylvia@townhall.plymouth.ma.us Duxbury, MA 02331 nord@town.duxbury.ma.us
- Richard R. MacDonald Town Manager 878 Tremont Street Duxbury, MA 02332 macdonald@town.duxbury.maus David R. Lewis