ML102730788

Pilgrim Watch'S Reply to Entergy'S Response to Pilgrim Watch'S Memo Regarding Proposed Schedule

ML102730788
Person / Time
Site:	Pilgrim
Issue date:	09/21/2010
From:	Lampert M Pilgrim Watch
To:	NRC/SECY/RAS, Atomic Safety and Licensing Board Panel
References
RAS J-271
Download: ML102730788 (3)

Text

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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