ML061780634

Pilgrim - Unopposed Motion for Extension of Time to Reply to NRC Staff Response to Hearing Request, Filed by D. Curran, Counsel for Massachusetts Attorney General

ML061780634
Person / Time
Site:	Pilgrim
Issue date:	06/16/2006
From:	Curran D Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP
To:	Atomic Safety and Licensing Board Panel
Giitter R
References
50-293-LR, ASLBP 06-848-02-LR, RAS 11845
Download: ML061780634 (4)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD USNRC June 16, 2006 (3:4l pm)

In the Matter of OFFICE OF SECRETARY Entergy Nuclear Operations, Inc. 1 Docket No. 50-293-LR RULEMAKINGS AND ADJUDICATIONS STAFF 1

(Pilgrim Nuclear Power Station) 1 UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLY TO NRC STAFF RESPONSE TO HEARING REQUEST Pursuant to the Atomic Safety and Licensing Board's ("ASLB's") Order of June 14, 2006, and 10 C.F.R. 5 2.323(b), the Massachusetts Attorney General hereby moves for a two-day extension of time to reply to the U.S. Nuclear Regulatory Commission

("NRC") Staffs response to the Attorney General's hearing request and contention.' The NRC Staff has agreed to this motion on the condition that the Staff should be allowed a corresponding extension of two days, or until June 22,2006, to file its response. The Attorney General does not oppose the Staffs request.

DISCUSSION On May 26,2006, the Attorney General served its Hearing Request and Contention on the NRC Staff by hand, and on Entergy Nuclear Operations, Inc.

("Entergy") by overnight mail. Under the NRC's procedural rules, the Staffs response is due on June 20, and Entergy's response is due on June 22. Therefore the Attorney General's reply to the Staff is due on June 27, while his reply to Entergy's response is due on June 29.

Massachusetts Attorney General's Request for a Hearing and Petition to Intervene With Respect to Entergy Nuclear Operations Inc.'s Application for Renewal of

In anticipation that some of the arguments by Entergy and the Staff may overlap, the Attorney General wishes to be able to address them in a single reply pleading.

Therefore, the Attorney General seeks to adjust the briefing schedule slightly so that the due date for its reply to the Staff and Entergy will fall on the same date, June 29.

Undersigned counsel Diane Curran consulted Susan Uttal, counsel for the Staff, and David Lewis, counsel for Entergy, who had no objection to this motion. As discussed above, however, the Staff seeks an extension of time until June 22 for its response. The Attorney General has no objection to giving the NRC Staff an additional two days for its response.

Respectfully submitted, Harmon, Curran, Spielberg, & Eisenberg, L.L.P.

1726 M Street N.W., Suite 600 Washington, D.C. 20036 2021328-3500 FAX 2021328-69 18 dcusra~~~~~liasr~~on~~~rrm.cc~~n hatthew Brock, Assistant Attorney General Environmental Protection Division Office of the Attorney General One Ashburton Place Boston, MA 02108 61 7172712200 x 2425 FAX 61 71727-9665 m a t t h c ~.bsock rr aqo.st;ite.nla.i~s June 16,2006 the Pilgrim Nuclear Plant Operating License, etc. (May 26, 2006) ("Hearing Request and Contention").

CERTIFICATE OF SERVICE I certify that on June 16, 2006, copies of the foregoing letter from Diane Curran to Administrative Judges and Massachusetts Attorney General's Motion for Extension of Time to File Reply were served on the following by first-class mail and/or electronic mail, as indicated below:

Ann Marshall Young, Chair Matthew Brock, Esq.

Atomic Safety and Licensing Board Panel Assistant Attorney General Mail Stop: T-3F23 Office of the Mass. Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Division Washington, DC 20555-0001 One Ashburton Place, Room 1813 Also by E-mail: =yQi,nsc.crov Boston, MA 02 108- 1598 Also by E-mail:

matthciz . I ~ r o c I \ - ~ ~ i r ~ a e o . ~ L a t c . ~ n ~ ~ . i ~ s Richard F. Cole Susan L. Uttal, Esq.

Atomic Safcty and Licensing Board Panel Harry E. Wedewer, Esq.

Mail Stop: T-3F23 Mail Stop 0- l5D2 1 U.S. Nuclear Regulatory Commission Office of General Counsel Washington, DC 20555-000 1 U S . Nuclear Regulatory Commission Also by E-mail: 1fc1!dnsc.gov Washington, D.C. 20555 Also by E-mail: 5 l u 2 nrc.go\ ;

Iicit~itnrc.rlov Nicholas G. Trikouros Molly H. Bartlett, Esq.

Atomic Safety and Licensing Board Panel 52 Crooked Lane Mail Stop: T-3F23 Duxbury, MA 02332 U.S. Nuclear Regulatory Commission Also by E-mail:

Washington, DC 20555-0001 moll\ libal-t\ctYri\hot~nail.coiii Also by E-mail: n.trikouros~iiatt.ner Office of Cornmission Appellate Terence A. Burke, Esq.

Adjudication Entergy Nuclear Mail Stop: 0-1 6C 1 1340 Echelon Parkway U.S. Nuclear Regulatory Commission Mail Stop: M-ECH-62 Washington, DC 20555-0001 Jackson, MS 392 13 Also by E-mail: g('AJ4bln~l rt nsc.xoi

Office of the Secretary David R. Lewis, Esq.

Attn: Rulemaking and Adjudications Staff Paul A. Gaukler, Esq.

Mail Stop: 0-1 6C 1 Pillsbury, Winthrop, Shaw, Pittman, LLP U.S. Nuclear Regulatory Conimission 2300 N Street, NW Washington, DC 20555-000 1 Washington, DC 20037-1 137 Also by E-mail: I i c a r i n ~ ~ t i o c k c t i u ~ n r c . ~Also

~ ~ by E-mail:

david.lcu is:i?pillsbuq law.com p a d ~aukler/ii,pill~hur~

law.con~

Atomic Safety and Licensing Board Panel Mary Lambert Mail Stop: T-3 F23 148 Washington Street U.S. Nuclear Regulatory Commission Duxbury, MA 02332 Washington. DC 20555-0001 Also by E-mail: lam bert~t~)adell~hia.nct Sheila Slocum Hollis, Esq.

Duane Morris L.L.P.

1667 K Street N.W., Suite 700 Washington. D.C. 20006 G

Diane Curran