ML11265A078: Difference between revisions
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
| (3 intermediate revisions by the same user not shown) | |||
| Line 2: | Line 2: | ||
| number = ML11265A078 | | number = ML11265A078 | ||
| issue date = 09/21/2011 | | issue date = 09/21/2011 | ||
| title = | | title = Petitioners Memorandum in Reply to Oppositions to Admission of Contention | ||
| author name = Bell N | | author name = Bell N | ||
| author affiliation = Northwest Environmental Advocates | | author affiliation = Northwest Environmental Advocates | ||
| Line 17: | Line 17: | ||
=Text= | =Text= | ||
{{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD | {{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD | ||
) | |||
In the Matter of | |||
) | |||
) | |||
ENERGY NORTHWEST ) | |||
Docket No. 50-397-LR | |||
) | |||
(Columbia Generating Station) ) | |||
September 21, 2011 | |||
__________________________________________) | __________________________________________) | ||
PETITIONERS MEMORANDUM IN REPLY TO OPPOSITIONS TO ADMISSION OF CONTENTION Pursuant to 10 C.F.R. § 2.309(h)(2), the Petitioner hereby replies to the oppositions submitted by the applicant, Energy Northwest, and the U.S. Nuclear Regulatory Commission (NRC) Staff to Petitioners contention seeking consideration of the environmental implications of the Fukushima Task Force Report. Petitioner respectfully submits that the arguments by applicant and the NRC Staff regarding the timeliness and admissibility of the contention are without merit and the contention should be admitted. | |||
The arguments raised by the applicant and the NRC Staff in response to | The arguments raised by the applicant and the NRC Staff in response to Petitioners contention are similar or identical to arguments made by the applicant and staff in response to Fukushima Task Force Report-related contentions that were filed in other reactor licensing proceedings a few days before the one in the instant proceeding. | ||
Petitioner attaches and incorporates by reference the attached Reply Memorandum, which addresses the most common arguments that are made in the responses and was | Petitioner attaches and incorporates by reference the attached Reply Memorandum, which addresses the most common arguments that are made in the responses and was | ||
petitioners in April 2011. | prepared by counsel for intervenors in several of the cases.1 The Reply Memorandum also discusses the effect of the NRC Commissioners recent decision regarding the Emergency Petition that was submitted by Petitioner and many other intervenors and petitioners in April 2011. Union Electric Co., d/b/a/ Ameren Missouri (Callaway Plant, Unit 2) et al., CLI-11-05, __ NRC __ (Sept. 9, 2011) (CLI-11-05).2 Respectfully submitted, this 21st day of September, 2011. | ||
Union Electric Co., d/b/a/ Ameren Missouri (Callaway Plant, Unit 2) et al., CLI-11-05, __ | (signed electronically by) | ||
2 | Nina Bell, Executive Director Northwest Environmental Advocates P.O. Box 12187 Portland, OR 97212-0187 503-295-0490 E-mail: nbell@advocates-nwea.org 1 | ||
The Reply Memorandum was prepared by Diane Curran (counsel for the intervenor in the Diablo Canyon license renewal proceeding and Watts Bar operating license proceeding), Mindy Goldstein (counsel for some of the intervenors in the Vogtle and Turkey Point COL proceedings), and Jason Totoui (counsel for some of the intervenors in the Turkey Point COL proceeding). | |||
2 Because the applicant and the NRC Staff have not had an opportunity to address the effect of CLI-11-05 on the timeliness and admissibility of Petitioners contention, Petitioner would not object to a response by the applicant and the Staff to their arguments regarding the relevance of CLI-11-05 to their contention.}} | |||
P.O. Box 12187 Portland, OR | |||
503-295-0490 E-mail: | |||
2 | |||
Latest revision as of 01:55, 13 January 2025
| ML11265A078 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/21/2011 |
| From: | Bell N Northwest Environmental Advocates |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML11265A076 | List: |
| References | |
| RAS 21099, 50-397-LR, ASLBP 11-912-03-LR-BD01 | |
| Download: ML11265A078 (2) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
ENERGY NORTHWEST )
Docket No. 50-397-LR
)
(Columbia Generating Station) )
September 21, 2011
__________________________________________)
PETITIONERS MEMORANDUM IN REPLY TO OPPOSITIONS TO ADMISSION OF CONTENTION Pursuant to 10 C.F.R. § 2.309(h)(2), the Petitioner hereby replies to the oppositions submitted by the applicant, Energy Northwest, and the U.S. Nuclear Regulatory Commission (NRC) Staff to Petitioners contention seeking consideration of the environmental implications of the Fukushima Task Force Report. Petitioner respectfully submits that the arguments by applicant and the NRC Staff regarding the timeliness and admissibility of the contention are without merit and the contention should be admitted.
The arguments raised by the applicant and the NRC Staff in response to Petitioners contention are similar or identical to arguments made by the applicant and staff in response to Fukushima Task Force Report-related contentions that were filed in other reactor licensing proceedings a few days before the one in the instant proceeding.
Petitioner attaches and incorporates by reference the attached Reply Memorandum, which addresses the most common arguments that are made in the responses and was
prepared by counsel for intervenors in several of the cases.1 The Reply Memorandum also discusses the effect of the NRC Commissioners recent decision regarding the Emergency Petition that was submitted by Petitioner and many other intervenors and petitioners in April 2011. Union Electric Co., d/b/a/ Ameren Missouri (Callaway Plant, Unit 2) et al., CLI-11-05, __ NRC __ (Sept. 9, 2011) (CLI-11-05).2 Respectfully submitted, this 21st day of September, 2011.
(signed electronically by)
Nina Bell, Executive Director Northwest Environmental Advocates P.O. Box 12187 Portland, OR 97212-0187 503-295-0490 E-mail: nbell@advocates-nwea.org 1
The Reply Memorandum was prepared by Diane Curran (counsel for the intervenor in the Diablo Canyon license renewal proceeding and Watts Bar operating license proceeding), Mindy Goldstein (counsel for some of the intervenors in the Vogtle and Turkey Point COL proceedings), and Jason Totoui (counsel for some of the intervenors in the Turkey Point COL proceeding).
2 Because the applicant and the NRC Staff have not had an opportunity to address the effect of CLI-11-05 on the timeliness and admissibility of Petitioners contention, Petitioner would not object to a response by the applicant and the Staff to their arguments regarding the relevance of CLI-11-05 to their contention.