ML020650605

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Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone Motion to Extend Scheduling Orders and Date of Oral Argument
ML020650605
Person / Time
Site: Millstone Dominion icon.png
Issue date: 02/19/2002
From: Burton N
Connecticut Coalition Against Millstone, Long Island Coalition Against Millstone
To: Bechhoefer C, Cole R, Kelber C
Atomic Safety and Licensing Board Panel
Byrdsong A
References
+adjud/rulemjr200506, 50-423-LA-3, ASLBP 00-771-01-LA-R, RAS 3999
Download: ML020650605 (4)


Text

DocKETED UNITED STATES OF AMERICA DOC NUCLEAR REGULATORY COMMISSION 2002MAR-4 AM11`08 ATOMIC SAFETY AND LICENSING BOARD .

JLt--AI'\NGS AND Before Administrative Judges: ADJUDICPATIONS STAFF Charles Bechhoefer, Chairman Dr. Richard F. Cole Dr. Charles N. Kelber In the Matter of Docket No. 50-423-LA-3 DOMINION NUCLEAR  : ASLBP No. 00-771-01-LA-R CONNECTICUT, INC.

(Millstone Nuclear Power Station, Unit No. 3:

Facility Operating License NPF-49  : February 19, 2002 CONNECTICUT COALITION AGAINST MILLSTONE AND LONG ISLAND COALITION AGAINST MILLSTONE MOTION TO EXTEND SCHEDULING ORDERS AND DATE OF ORAL ARGUMENT The Intervenors, Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone, respectfully move for an extension of the scheduling orders and date of oral argument in this matter, as per the Licensing Board's "Notice of Filing Schedules and Oral Argument" issued on February 4, 2002.

The Intervenors request a sixty-day extension of time of the deadlines set forth in said order.

In support of this motion, the Intervenors represent as follows:

1. In these reopened proceedings, the Intervenors are represented by the undersigned, a solo practitioner acting pro bono in this matter.
2. The undersigned has just completed a civil jury trial which commenced on January 3, 2002 in the Superior Court of the State of Connecticut and which culminated in a jury verdict rendered on February 11, 2002, followed by post-verdict proceedings p/e;-iP~

Ile eey- c o4.se Y 0 ýP_

which are ongoing, in the case entitled William V. Raymond, Jr. et al. v. Rock Acquisition Limited Partnership et al., CV 96 0323527.

3. The demands and pressures of such proceedings substantially interfered with the ability of the undersigned to adequately address the copious filings submitted by the licensee and staff in this matter, consisting of some eight (8) 16" X 13" X 10" crates of materials and other issues pertinent hereto.
4. It is respectfully submitted that the issues under consideration in these reopened proceedings involve issues of substantial public interest which are not likely to be addressed by local, state or federal authorities other than in these proceedings, and that the public interest in these proceedings argues in favor of the granting of this motion.

THE INTERVENORS By:

. Won,23 3 -.

NancyT 14.7 0/os Highway Red/cin Ridge CT 06876 Tel. q203-938-3952

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Richard F. Cole Dr. Charles N. Kelber In the Matter of Docket No. 50-423-LA-3 DOMINION NUCLEAR ASLBP No. 00-771-01-LA-R CONNECTICUT, INC.

(Millstone Nuclear Power Station, Unit No. 3:

Facility Operating License NPF-49 February 19, 2002 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing "Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone Motion to Extend Scheduling Orders and Date of Oral Argument" was mailed on February 19, 2002 to the following via U.S. Mail, postage pre-paid, and emailed as indicated hereinbelow:

Charles Bechhoefer, Chairman Dr. Richard F. Cole Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S.Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Washington DC 20555-0001 (email: cxb2@nrc.gov) (email: rfc1'@nrc.gov)

Dr. Charles N. Kelber Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington DC 20555 U.S. Nuclear Regulatory Commission Attn: Rulemakings and Adjudication Staff Washington DC 20555-0001 (original + two copies)

(email: cnk',nrc.gov) (email: HEARINGDOCKETdJrc.gov)

Office of Commission Appellate Adjudicatory File Adjudication Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington DC 20555 Washington DC 20555

David A. Repka, Esq. Ann P. Hodgdon, Esq.

Winston & Strawn Office of the General Counsel 1400 L Street NW U.S. Nuclear Regulatory Commission Washington DC 20005-3502 Washington DC 20555 (email: drcpkaLdwinston.com) (email: aphgdnrc. ov)