ML060540082
| ML060540082 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/06/2006 |
| From: | Shadis R New England Coalition |
| To: | Atomic Safety and Licensing Board Panel |
| Byrdsong A T | |
| References | |
| 50-271-OLA, ASLBP 04-832-02-OLA, RAS 11196 | |
| Download: ML060540082 (5) | |
Text
.1?845 IiqI DOCKETED USNRC February 22, 2006 (11:38am)
UNITED STATES OF AMERICA OFFICE OF SECRETARY RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF Before the Atomic Safety and Licensing Board In the Matter of Entergy Nuclear Vermont Yankee, LLC, and Docket No. 50-271 Entergy Nuclear Operations, Inc.
ASLBP No. 04-832-02-OLA (Operating License Amendment)
(Vermont Yankee Nuclear Power Station)
February 6, 2006 NEW ENGLAND COALITION'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE A BRIEF Pursuant to 10 C.F.R. § 2.323, New England Coalition ("NEC") hereby files this unopposed motion seeking that the Atomic Safety and Licensing Board ("Board") enlarge by one week the time allowed for NEC to file its brief on the question of which regulations underlie NEC's Contention 4 in the above-captioned matter, so that NEC's brief is due on February 14,2006.
The basis for NEC's motion is as follows.
During the telephonic scheduling conference on January 24, 2006, the Board set a date of February 7, 2006 for the submission of NEC's brief. NEC is unable to comply with this requirement as its staff of one is fully occupied with the ongoing technical hearings before Vermont's Public Service Board on the issue of dry cask storage at Vermont Yankee. The number of witnesses questioned and the length of time necessary to prepare for each witness have been far greater than expected.
These hearings, scheduled in September of 2005, began on January 30, 2006 and will be completed by February 10d.
This motion seeks that NEC be granted 7 additional days in order to prepare its brief Te n p I Cae= recut- 0 4/6q c I/ ;
-A CERIFICATION Pursuant to 10 C.F.R. § 2.323(b), NEC certifies that it has consulted with counsel for Entergy, the NRC staff, and counsel for the Vermont Department of Public Service
("DPS'). NEC has been advised that Entergy and the NRC have taken no position on NEC being granted the enlargement of time sought herein. The DPS has stated that it does not object to NEC being granted the relief sought herein.
CONCLUSION For the reasons stated above, NEC requests that the Board grant it until February 14, 2006 to file its brief in this matter.
Respectfully submitted.
New England Coalition P.O. Box 98 Edgecomb, ME 04556 shadisgprexar.com cc: Service List 2
.1, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ENTERGY NUCLEAR VERMONT YANKEE)
LLC and ENTERGY NUCLEAR OPERATIONS, INC.
(Vermont Yankee Nuclear Power Station)
)
Docket No. 50-271-OLA
)
ASLBP No. 04-832-02-OLA CERTIFICATE OF SERVICE I hereby certify that copies of New England Coalition's "Unopposed Motion for Enlargement of Time to File a Brief in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class this 14t day of February 2006 and by e-mail as indicated by a double asterisk (**), the 6tday of February, 2006'.
Alex S. Karlin, Chair**
Administrative Judge Atomic Safety and Licensing Board Panel Mail Stop T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: ask2@nrc.gov Dr. Anthony J. Baratta' Administrative Judge Atomic Safety and Licensing Board Panel Mail Stop T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: ajb5@nrc.gov Lester S. Rubenstein**
Administrative Judge Atomic Safety and Licensing Board Panel 4760 East Country Villa Drive Tucson, AZ 85718 E-mail: lesrrrecomcast.net Office of the Secretary" ATTN: Rulemaking and Adjudications Staff Mail Stop: O-16C1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: HEARINGDOCKET@nrc.gov Office of Commission Appellate John M. Fulton, Esq.
Adjudication Assistant General Counsel Mail Stop: 0-16C1 Entergy Nuclear Operations, Inc.
U.S. Nuclear Regulatory Commission 440 Hamilton Avenue Washington, DC 20555-0001 White Plains, NY 10601
' Through an inadvertent omission in New England Coalition's outgoing mail list, conforming hardcopy this Motion was not deposited in the US Mail on February 6w", as represented in New England Coalition's electronic filing of February 6, 2006. Conforming hardcopy is provided today, February 14, 2006. New England Coalition deeply regrets an inconvenience, concern, or confusion that may have resulted.
Jay E. Silberg, Esq.**
Sarah Hofmann, Esq.*
Matias Travieso-Diaz, Esq.**
Special Counsel Pillsbury Winthrop Shaw Pittman, LLP Department of Public Service 2300 N St., NW 112 State Street - Drawer 20 Washington, DC 20037-1128 Montpelier, VT 05620-2601 E-mail: jay.silberg@pillsburylaw.com E-mail: sarah.hofmannestate.vt.us matias.travieso-diaz@pillsburylaw.com douglas.rosinski~pillsburylaw.com Anthony Z. Roisman, Esq.**
National Legal Scholars Law Firm 84 East Thetford Rd.
Lyme, NH 03768 E-mail: aroismanenationallegalscholars.com Jonathan M. Rund, Esq.'
Sherwin E. Turk, Esq.*
Law Clerk Jason C. Zom, Esq.*
Atomic Safety and Licensing Board Panel Office of the General Counsel Mail Stop: T-31F23 Mi tp01 2
U.S. Nuclear Regulatory Commission Mail Stop 0-15 D21 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission (E-mail: imr3@nrc.ov)
Washington, DC 20555-0001 set(nrc.pov, iczQnrc.gov Raymond Shadis Pro Se Representative New England Coalition Post Office Box 98, Edgecomb, Maine 04556 207-882-7801 shadis~prexar~com
6 UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of February 14, 2006 ENTERGY NUCLEAR VERMONT YANKEE, LLC Docket No. 50-271 and ENTERGY NUCLEAR OPERATIONS, INC.
(Vermont Yankee Nuclear Power Station)
ASLBP No. 04-832-02-OLA Office of the Secretary ATTN: Rulemaking and Adjudications Staff Mail Stop: 0-16C1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Rulemaking and Adjudications Staff,
Please find for filing in the above captioned matter one original and two copies of NEW ENGLAND COALITION'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE A BRIEF.
Thank you for your kind assistance in making this filing, Raymond Shadis Pro se Representative New England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801 shadis i prexar.com