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Category:Legal-Motion
MONTHYEARML20079J1802020-03-19019 March 2020 Unopposed Motion of the Commonwealth of Massachusetts to Correct a Previously Filed Declaration ML20035C7562020-01-30030 January 2020 1-30-20 Entergy Motion to Intervene (DC Cir.)(Case No. 20-1019) ML20031D4332020-01-29029 January 2020 1-29-20 Reply to Response to Motion to Dismiss (DC Cir.)(Case No. 19-1198) ML19347D4152019-12-13013 December 2019 Motion of the Commonwealth of Massachusetts to Amend Its Petition with New Information ML19303B4252019-10-28028 October 2019 Transport Room (Motion for Stay Pending Appellate Review)(Dc Cir.)(Case No. 19-1198) 10-28-19 ML19295E6852019-10-16016 October 2019 Entergy Motion to Intervene (DC Cir.)(Case No. 19-1198) 10-16-19 ML19247E5092019-09-0404 September 2019 Motion of the Commonwealth of Massachusetts for a Twenty-Two Minute Enlargement of Time to File Its Stay Application and Supporting Appendix ML19247B4312019-09-0303 September 2019 Application of the Commonwealth of Massachusetts for a Stay of the Effectiveness of the NRC Staff Actions Approving the License Transfer Application and Request for an Exemption to Use the Decommissioning Trust Fund for Non-Decommissioning ML19246A0322019-09-0303 September 2019 Watch Motion to Stay Staff Order of August 22, 2019 Granting Exemption ML19246A0332019-09-0303 September 2019 Watch Motion Under 10 C.F.R 2.1327 to Stay Staff Order of August 22, 2019 ML19230A0212019-08-18018 August 2019 Reply of the Commonwealth of Massachusetts in Support of Its Motion for an Enlargement of Time to File an Application to Stay a Nuclear Regulatory Commission Staff Order Approving the License Transfer Application ML19227A0682019-08-15015 August 2019 Emergency Motion of the Commonwealth of Massachusetts for Clarification of the Commission'S August 14, 2019 Memorandum and Order ML19227A3982019-08-15015 August 2019 Emergency Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File an Application to Stay a Nuclear Regulatory Commission Staff Order Approving the License Transfer Application ML19213A3132019-08-0101 August 2019 Motion of the Commonwealth of Massachusetts to Stay Proceeding to Complete Settlement Negotiations ML19129A3732019-05-0909 May 2019 Commonwealth of Massachusetts' Reply in Support of Motion to Supplement Its Petition with New Information ML19129A4732019-05-0909 May 2019 Watch Motion to Supplement Its Motion to Intervene and Request for Hearing, Biodiversity (05.09.19) ML19114A5192019-04-24024 April 2019 Motion of the Commonwealth of Massachusetts to Supplement Its Petition with New Information ML19091A1892019-04-0101 April 2019 Watch Reply to Applicant'S Answer Opposing Pilgrim Watch Petition for Leave to Intervene and Hearing Request ML19077A2092019-03-18018 March 2019 Notices of Appearance of David R. Lewis, Anne R. Leidich, and Susan H. Raimo ML19077A2762019-03-18018 March 2019 Unopposed Motion of the Commonwealth of Massachusetts for an Enlargement of Time to File Its Reply ML12257A3392012-09-13013 September 2012 Filed Copy - Joint Motion to Amend Briefing Schedule - Massachusetts V NRC - 1st Cir 12-1404 and 12-1772 ML12195A0802012-07-13013 July 2012 Notice of Appearance for Joseph A. Lindell for ESA Roseate Term ML12157A1872012-06-0505 June 2012 Notice of Appearance from Joseph A. Lindell on Entergy Nuclear Operations, Inc., (Pilgrim) ML12137A2582012-05-16016 May 2012 Notice of Appearance for Joseph A. Lindell ML12136A5172012-05-15015 May 2012 NRC Staff'S Unopposed Motion for an Extension of Time to Respond to Jones River Watershed Association and Pilgrim Watch'S May 14, 2012, Request to Reopen, for a Hearing and to File New Contentions ML12132A4682012-05-11011 May 2012 Motion to Strike ML12097A2222012-04-0505 April 2012 Entergy Motion to Strike Petitioners' Affidavit and Portions of Petitioners' Reply ML11357A2092011-12-23023 December 2011 Commonwealth of Massachusetts' Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Appeal of LBP-11-35 ML11290A1812011-10-17017 October 2011 Commonwealth of Massachusetts Motion to Reply to NRC Staff Answer to Massachusetts Request to Stay Commission Decision on Pilgrim Watch Appeal or in the Alternative to Strike Reference to Massachusetts Expert ML11258A0262011-09-15015 September 2011 Commonwealth of Massachusetts Amended Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Motion to Supplement Bases to Its Contention ML11256A3042011-09-13013 September 2011 Commonwealth of Massachusetts Motion to Reply to NRC Staff and Entergy Oppositions to Commonwealth Motion to Supplement Bases to Its Contention ML11235B0962011-08-23023 August 2011 Applicant'S Motion for Issuance of Renewed License ML11223A2842011-08-11011 August 2011 Commonwealth of Massachusetts Motion to Supplement Bases to Commonwealth Contention to Address NRC Task Force Report on Lessons Learned from the Radiological Accident at Fukushima ML1115303402011-06-0202 June 2011 Commonwealth of Massachusetts' Motion to Admit Contention and, If Necessary, to Re-Open Record Regarding New and Significant Information Revealed by Fukushima Accident ML1115303442011-06-0202 June 2011 Commonwealth of Massachusetts' Conditional Motion to Suspend Pilgrim Nuclear Power Plant License Renewal Proceeding Pending Resolution of Petition for Rulemaking to Rescind Spent Fuel Pool Exclusion Regulations ML1113905722011-05-19019 May 2011 Commonwealth of Massachusetts Motion to Reply to Entergy'S Answer Opposing Commonwealth'S Joinder in Petition to Suspend the License Renewal Proceeding for the Pilgrim Nuclear Power Plant and Request for Additional Relief ML1113905702011-05-19019 May 2011 Commonwealth of Massachusetts Motion to Reply to the Answers of the NRC Staff and Entergy in Opposition to the Commonwealth of Massachusetts Motion to Hold Licensing Decision in Abeyance Pending Commission Decision Weather to Suspend the Pi ML1112203262011-05-0202 May 2011 Commonwealth of Massachusetts Motion to Hold Licensing Decision in Abeyance Pending Commission Decision Whether to Suspend the Pilgrim Proceeding to Review the Lessons of the Fukushima Accident ML1102407012011-01-24024 January 2011 Entergy'S Motion to Strike Portions of Pilgrim Watch'S Reply to Entergy'S and the NRC Staff'S Answers Opposing Pilgrim Watch'S Request for Hearing on a New Contention ML1101306682011-01-13013 January 2011 Entergy'S Motion in Limine to Exclude from Evidence Pilgrim Watch'S Sama Remand Pre-Filed Testimony and Exhibits ML1100503302010-12-30030 December 2010 Entergy Request for Change in Hearing Date ML1035004002010-12-13013 December 2010 Pilgrim Watch Request for Hearing on a New Contention: Inadequacy of Entergy'S Aging Management of Non-Environmentally Qualified (EQ) Inaccessible Cables (Splices) at Pilgrim Station ML1032103122010-11-0404 November 2010 Pilgrim Watch Request Extension Submit Affidavits ML1027800452010-10-0404 October 2010 NRC Staff'S Answer to Pilgrim Watch Motion Regarding ASLB Refusal to Respond to Pilgrim Watch'S Motion for Clarification ML1027300422010-09-22022 September 2010 Pilgrim Watch Motion Regarding ASLB Refusal to Respond to Pilgrim Watch'S Motion for Clarification ASLB Order (Sept 2, 2010) ML1025803182010-09-0909 September 2010 Pilgrim Watch Motion for Clarification ASLB Order (Sept. 02, 2010) ML1017301822010-06-16016 June 2010 Motion Requesting Leave to File Response to Judge Paul B. Abramson Decision on Recusal Motion (June 10, 2010) ML1015404252010-05-26026 May 2010 Pilgrim Watch Request for Permission, and Reply to NRC Staff'S Response to Pilgrim Watch Motion to Disqualify Judge Abramson ML1014500892010-05-24024 May 2010 NRC Response to Pilgrim Watch Motion to Disqualify Judge Paul B. Abramson ML1015404242010-05-24024 May 2010 Pilgrim Watch Request for Permission, and Reply to Entergy'S Opposition to Pilgrim Watch Motion to Disqualify Judge Abramson 2020-03-19
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DOCKETED
- 3-USNRC April 6, 2009 (4:26pm)
OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION In the Matter of )
Entergy Nuclear Generation Co. and )
Entergy Nuclear Operations, Inc. ) Docket No. 50-293-LR
)
) ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station) )
PILGRIM WATCH'S REQUEST FOR ALL CORRESPONDENCE AND NOTES OF CONVERSATION BETWEEN THE NUCLEAR REGULATORY COMMISSION AND DR. VINOD MUBAYAI THAT PERTAINS TO INFORMATION NOT ALREADY IN THE RECORD April 6, 2009 April 1, 2009 a Notice of Appointment of Adjudicatory Employee (Docket Number 50-293-LR) was served. It said that pursuant to 10 C.F.R. 2.4 notice was given that Dr. Vinod Mubayai, Staff Scientist at Brookhaven National Laboratory, has been appointed as a Commission adjudicat6ry employee to advise the Commission. regarding issues relating to intervenor Pilgrim. Watch's pending petition for review filed in this case.
The record in this proceeding has long since been closed. Pilgrim Watch questions the extent to which Dr. Mubayi properly may provide expert"advicd'to the Commission regarding that closed record. However, what seems clear is that the Commission could not properly seek new facts and opinions from Dr. Mubayi, and add this new material to the already closed record or base its decision upon them.
For that reason, Pilgrim Watch requests all correspondence and records of conversation between Dr. Mubayai and the Commission regarding any fact or opinion that might be viewed as not already in the record. Consistent with President Obamads call for transparency in government decision making, the Commission should take every step to ensure that all of the evidence on 0&/54
N which the Commission's decision eventually will be based is part of the public record. The public wishes to be assured of a fair hearing; and we know that you, in turn, wish to maintain public confidence.
Respectfully submitted, Mary Lampert Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE IuS. NUCLEAR REGULATORY COMMISSION In the Matter of )
)
Entergy Nuclear Generation Co. and )
Entergy Nuclear Operations, Inc. ) Docket No. 50-293-LR
)
) ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station) )
CERTIFICATE OF SERVICE I hereby certify that I have sent copies of the foregoing in the above captioned proceeding to the following persons by electronic mail this date, April 6, 2009, followed by paper copies by U.S.
mail, first class.
Administrative Judge Administrative Judge Ann Marshall Young, Chair Richard F. Cole Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop - T-3 F23 Mail Stop -T-3-F23 US NRC US NRC Washington, DC 20555-0001 Washington, DC 20555-0001 amy@nrc.gov rfc@nrc.gov Administrative Judge Secretary of the Commission Paul B. Abramson Attn: Rulemakings and Adjudications Atomic Safety and Licensing Board Staff Mail Stop T-3 F23 Mail Stop 0-16 C I US NRC United States Nuclear Regulatory Washington, DC 20555-0001 Commission pba@nrc.gov Washington, DC 20555-0001 rfcl @nrc.gov
Office of Commission Appellate Terence Burke, Esq.
Adjudication Entergy Nuclear Mail Stop 0-16 C I 1340 Echelon parkway United States Nuclear Regulatory Mail Stop M-ECH-62 Commission Jackson, MS 39213 Washington, DC 20555-0001 Ms. Melissa Arrighi Atomic Safety and Licensing Board Acting Town Manager, Mail Stop T-3 F23 Town of Plymouth United States Nuclear Regulatory 11 Lincoln Street Commission Plymouth MA 02360 Washington, DC 20555-0001 marrighi@townhall.plymouth.ma.us Susan L. Uttal, Esq. Sheila Slocum Hollis, Esq.
Andrea Jones, Esq. Town of Plymouth MA David Roth, Esq. Duane Morris, LLP Brian Newell, Paralegal 1667 K. Street, N.W.
Office of General Counsel Suite 700 Mail Stop 15 D21 Washington, DC 20006 United States Nuclear Regulatory Commission Richard R. MacDonald Washington, DC 20555-0001 Town Manager, Town of Duxbury 878 Tremont Street Paul A. Gaukler, Esq. Duxbury, MA 02332 David R. Lewis, Esq. macdonald@town.duxbury.ma.us Jason Parker, Esq.
Pillsbury, Winthrop, Shaw, Pittman, Fire Chief & Director DEMA, LLP Town of Duxbury 2300 N Street, N.W. 688 Tremont Street Washington, DC 20037-1138 P.O. Box 2824 Duxbury, MA 02331 Perry Buckberg nordgtown.duxbury.ma.us Project Manager, Plant Lic.
Branch 1-1, Operating Reactor Licensing US Nuclear regulatory Commission Mail Stop:011 -F1 Washington, DC 20555-0001 I c~
Mary Lampert