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Category:Legal-Motion
MONTHYEARML23136B1622023-05-15015 May 2023 – Town of North Salem, County of Westchester, New York Board Resolution Letter Regarding Treated Water Release from Indian Point Site ML21153A0072021-05-28028 May 2021 5-28-21 Motion for Voluntary Dismissal (DC Cir.)(Case No. 21-1084) ML21050A4322021-02-18018 February 2021 2-18-21 Motion to Intervene (DC Cir.)(Case No. 21-1037) ML20311A6602020-11-0606 November 2020 Motion of Riverkeeper, Inc. for Full Adjudication of Its Pending Contention Prior to Any Decision by NRC on the License Transfer ML20311A6612020-11-0606 November 2020 Declaration of David Lochbaum in Support of Riverkeepers Motion for Full Adjudication of Its Pending Contention Prior to Any Decision by NRC on the License Transfer ML20296A2832020-10-20020 October 2020 Resubmission of Motion of Riverkeeper, Inc. to Supplement the Basis for Its Contention with New Evidence Not Previously Available (Technical Correction) ML20084Q1912020-03-24024 March 2020 New York State Motion for Leave to Amend Contentions NY-2 and NY-3 ML20072K2862020-03-12012 March 2020 Unopposed Motion of Riverkeeper, Inc. for an Enlargement of Time to File Its Reply ML20071J9722020-03-11011 March 2020 Unopposed Motion of the Town of Cortlandt, Village of Buchanan and Hendrick Hudson School District for an Enlargement of Time to File Its Reply ML20071D8392020-03-11011 March 2020 Unopposed Motion of the State of New York for an Enlargement of Time to File Its Reply ML18347B0662018-12-13013 December 2018 Intervenors' Motion for Production by the Regulatory Staff of Post Operational Inspection Reports ML17039B0912017-02-0808 February 2017 Kwong Declaration of Lisa Kwong ML17039B0922017-02-0808 February 2017 Declaration of Diane Curran ML17039B0902017-02-0808 February 2017 NYS and Riverkeeper Notice of Withdrawal and Unopposed Motion to Dismiss Contentions and Proceeding ML16300A3882016-10-26026 October 2016 Unopposed Joint Motion to Extend Track 2 Hearing Schedule Deadlines ML16207A7132016-07-25025 July 2016 Joint Motion for Reconsideration or, in the Alternative, Clarification of the July 13, 2016 Licensing Board Order Scheduling Further Filings on the Track 2 Contentions ML16182A5112016-06-30030 June 2016 State of New York Motion to Establish Schedule ML16189A3182016-06-16016 June 2016 Entergy Motion to Intervene (D C Cir 6-16-16 ML16085A2122016-03-25025 March 2016 NYS Certificate of Service ML16085A2112016-03-25025 March 2016 NYS Reply in Support of Contention NYS-40 ML16069A2922016-03-0909 March 2016 NYS Cover Letter Regarding February 19, 2016, Order (Requesting Expert Testimony on New York'S Proposed Exhibits and Suspending Deadline for Filing Proposed Findings of Fact and Law) ML16069A2932016-03-0909 March 2016 NYS Unopposed Motion for Extension of Time to File Reply Expert Testimony ML16069A2942016-03-0909 March 2016 NYS Cos Regarding Unopposed Motion for Extension of Time to File Reply Expert Testimony ML16068A4412016-03-0808 March 2016 Riverkeeper Motion to Admit New Contention in Indian Point Case ML16060A5872016-02-29029 February 2016 NYS Supplement to February 22, 2016 Motion for Leave ML16060A5882016-02-29029 February 2016 NYS Certificate of Service ML16057A5322016-02-26026 February 2016 NYS Motion for Stay or to Vacate ML16057A5542016-02-26026 February 2016 NYS Certificate of Service ML16057A5332016-02-26026 February 2016 NYS Declaration in Support of Motion ML16057A5532016-02-24024 February 2016 NYS Exhibit 14 on Notification of Issuance of License Amendment ML16057A5522016-02-23023 February 2016 NYS Exhibit 13 on NRC Issuance of Amendment Re Extension of Containment Integrated Leak Rate Test to 15 Years ML16054A6712016-02-22022 February 2016 NYS Motion for Leave Re Contention NYS-40 ML16057A5492016-02-22022 February 2016 NYS Exhibit 12 on Commission Notification of Significant Licensing Action ML16047A4252016-02-16016 February 2016 NRC Staff Answer to New York Motion for Leave to File Six Documents as Additional Exhibits ML16036A3512016-02-0505 February 2016 NYS Cover Letter - Submitting Motion for Leave to File Additional Exhibits ML16036A3552016-02-0505 February 2016 Attachment 2 - to State of New York Kwong Declaration Dated February 5, 2016 ML16036A3622016-02-0505 February 2016 NYS000589 - Revised Track 2 New York State Exhibits List ML16036A3612016-02-0505 February 2016 NYS000588 - NRC Inspection Report, Indian Point Unit 3, 05000286/2015011 (November 19, 2015) (ML15323A026) ML16036A3632016-02-0505 February 2016 Declaration for Lisa S. Kwong ML16036A3722016-02-0505 February 2016 NYS Motion for Leave Cos Public EIE ML16036A3732016-02-0505 February 2016 NYS Motion for Leave Coa Non Public EIE ML16036A3542016-02-0505 February 2016 Attachment 1- New York State List of Attachments and Proposed Exhibits Table ML16036A3532016-02-0505 February 2016 NYS Motion for Leave to File Six Documents as Additional Exhibits ML15357A5562015-12-23023 December 2015 Entergy'S Answer to Opposing State of New York Motion for Public Disclosure of Six Revised Westinghouse Documents ML15348A4382015-12-14014 December 2015 Attachment 4 - Cover Page of ENTR00681 WCAP-17199-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted ML15348A4392015-12-14014 December 2015 Attachment 5 - Cover Page of ENTR00682 WCAP-17200-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted ML15348A4402015-12-14014 December 2015 Attachment 6 - Cover Page of ENTR00683 CN-PAFM-13-32, Revision 4, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted ML15348A4412015-12-14014 December 2015 Attachment 7 - Cover Page of ENTR00689 WCAP-12191, Revision 5, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted ML15348A4422015-12-14014 December 2015 Attachment 8 - Cover Page of ENTR00690 WCAP-16898-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement, Full Text Copyrighted ML15348A4432015-12-14014 December 2015 Attachment 9 - Cover Page of ENTR00727 CN-PAFM-09-21, Revision 4, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted 2023-05-15
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.;
ENTERGY NUCLEAR INDIAN POINT 2, LLC; ENTERGY NUCLEAR INDIAN POINT 3, LLC; HOLTEC INTERNATIONAL; and HOLTEC DECOMMISSIONING INTERNATIONAL, LLC; APPLICATION FOR ORDER CONSENTING TO TRANSFERS OF CONTROL OF LICENSES AND APPROVING CONFORMING LICENSE AMENDMENTS (Indian Point Nuclear Generating Station)
Docket Nos.:
50-3 50-247 50-348 72-051 UNOPPOSED MOTION OF RIVERKEEPER, INC.
FOR AN ENLARGEMENT OF TIME TO FILE ITS REPLY Pursuant to 10 C.F.R. § 2.307, Petitioner Riverkeeper, Inc. (Petitioner) moves the Commission for a short enlargement of time to reply to the answer filed in the above-captioned proceeding, from March 16, 2020 to and including March 23, 2020. Entergy Nuclear Operations, Inc.; Entergy Nuclear Indian Point 2, LLC; Entergy Nuclear Indian Point 3, LLC; Holtec International; and Holtec Decommissioning International, LLC (collectively, the Applicants) do not oppose the Petitioners request. In support of this motion, the Petitioner offers the following:
- 1.
This matter concerns an application to the Nuclear Regulatory Commission by the Applicants for permission to transfer the licenses for the Indian Point Nuclear Generating Station (Indian Point) and the Indian Point Independent Spent Fuel Storage Installation. On February 12, 2020, Petitioner submitted a petition to intervene in the license transfer proceedings under 10 C.F.R.
§ 2.309 and requested a hearing thereon (the Petition). On March 9, 2020, the Applicants filed an answer responding to the Petition. Petitioners reply is currently due to be filed on March 16, 2020.
- 2.
As described in the Petition and accompanying standing affidavits, the complete, thorough and safe decontamination and restoration of Indian Point is of great concern to the Petitioner and its members. Petitioner has devoted and will continue to devote significant resources to this matter, but other factors have intervened to complicate the preparation of a reply brief. In addition to the length and complexity of the Petition and Answer, Pace University has closed all campuses to students, including the Law School and the undersigned clinic. Undersigned counsel can and will continue to work on the reply but these events have complicated our completion of the reply brief. Additional time is therefore necessary to complete the reply brief, and Petitioner respectfully requests a one-week extension to coincide with the extensions sought by other Petitioners in this matter.
- 3.
As required by 10 C.F.R. § 2.323(b), counsel for Petitioner consulted with counsel for the Applicants, Paul Bessette, on March 12, 2020. Mr. Bessette courteously indicated that the Applicants do not oppose Petitioners request for an enlargement of time to file its reply.
For the foregoing reasons, and upon good cause shown, Petitioner respectfully request that the Commission grant this motion for an enlargement of time and modify the deadline by which the Petitioner must file its reply in this proceeding from March 16, 2020 to and including March 23, 2020.
Respectfully submitted on March 12, 2020 Signed electronically by:
Todd Ommen Managing Attorney Pace Environmental Law Clinic, Inc.
78 N. Broadway White Plains NY 10603
Tel.914-422-4343 Email: tommen@law.pace.edu
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.;
ENTERGY NUCLEAR INDIAN POINT 2, LLC; ENTERGY NUCLEAR INDIAN POINT 3, LLC; HOLTEC INTERNATIONAL; and HOLTEC DECOMMISSIONING INTERNATIONAL, LLC; APPLICATION FOR ORDER CONSENTING TO TRANSFERS OF CONTROL OF LICENSES AND APPROVING CONFORMING LICENSE AMENDMENTS (Indian Point Nuclear Generating Station)
Docket Nos.:
50-3 50-247 50-348 72-051 CERTIFICATE OF SERVICE Pursuant to 10 CFR § 2.305, I certify that copies of The Unopposed Motion of Riverkeeper, Inc. for an Enlargement of Time to File a Reply have been served upon the Electronic Information Exchange, the NRCs e-filing system, in the above captioned proceeding, on March 12, 2020.
Signed electronically by:
Todd Ommen Managing Attorney Pace Environmental Law Clinic, Inc.
78 N. Broadway White Plains NY 10603 Tel.914-422-4343 Email: tommen@law.pace.edu