ML071520175

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Pilgrim - Request by Pilgrim Watch for Extension of Time to Reply to Entergy'S Motion for Summary Disposition
ML071520175
Person / Time
Site: Pilgrim
Issue date: 05/22/2007
From: Lampert M
Pilgrim Watch
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-293-LR, ASLBP 06-848-02-LR, RAS 13713
Download: ML071520175 (3)


Text

Vfa- 5 13 7/13 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Docket # 50-293 Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application May 22, 2007 REQUEST BY PILGRIM WATCH FOR EXTENSION OF TIME TO REPLY TO ENTERGY'S MOTION FOR

SUMMARY

DISPOSITION Pilgrim Watch hereby requests an extension of time to reply to Entergy's Motion for Summary Disposition of Pilgrim Watch' Contention 3, dated May 17, 2007. Pilgrim Watch has recently had its counsel, Molly Bartlett, withdraw from the proceedings because of unforeseen circumstances. Mary Lampert, Director of Pilgrim Watch will now be representing Pilgrim Watch pro se going forward. As a result of this change, Pilgrim Watch requests that the Licensing Board grant an extension of time until June 29, 2007, to reply to the current motion by Entergy. The Hearing Schedule for this proceeding stated that June 11, 2007 was the deadline for filing any motions for summary disposition and June 29, 2007 the deadline for responses to any motions for summary disposition; therefore the ASLB may consider it not overly cumbersome for its review schedule to grant Pilgrim Watch additional time to adjust to unavoidable circumstances.

Signed:

Aý- A- ý:tl Mary Lampert Date

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293 Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application May 22, 2007 CERTIFICATE OF SERVICE I hereby certify that the foregoing Pilgrim Watch Notice of Withdrawal of Molly H.

Bartlett; Notice of Appearance of Mary Elizabeth Lampert; Request by Pilgrim Watch for Extension of Time to Reply to Entergy's Motion of Summary Disposition, dated May 22, 2007 was sent by electronic mail and by U.S. Mail, first class to each of the following:

Administrative Judge Administrative Judge Ann Marshall Young, Chair Richard F. Cole Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop - T-3 F23 Mail Stop -T-3-F23 US NRC US NRC Washington, DC 20555-0001 Washington, DC 20555-0001 amy@nrc.gov rfc@nrc.gov Administrative Judge Secretary of the Commission Paul B. Abramson Attn: Rulemakings and Adjudications Atomic Safety and Licensing Board Staff Mail Stop T-3 F23 Mail Stop 0-16 Cl US NRC United States Nuclear Regulatory Washington, DC 20555-0001 Commission pba@nrc.gov Washington, DC 20555-0001 rfc1@nrc.gov

Office of Commission Appellate Mr. Mark Sylvia Adjudication Town Manager, Town of Plymouth Mail Stop 0-16 C 1 11 Lincoln Street United States Nuclear Regulatory Plymouth MA 02360 Commission msylvia@townhall.plymouth.ma.us Washington, DC 20555-0001 Sheila Slocum Hollis, Esq.

Atomic Safety and Licensing Board Town of Plymouth MA Mail Stop T-3 F23 Duane Morris, LLP United States Nuclear Regulatory 1667 K. Street, N.W.

Commission Suite 700 Washington, DC 20555-0001 Washington, DC 20006 Susan L. Uttal, Esq. Richard R. MacDonald Marian L. Zobler, Esq, Town Manager, Town of Duxbury Office of General Counsel 878 Tremont Street Mail Stop 15 D21 Duxbury, MA 02332 United States Nuclear Regulatory macdonald@town.duxbury.ma.us Commission Washington, DC 20555-0001 Kevin Nord Fire Chief & Director DEMA, Paul A. Gaukler, Esq. Town of Duxbury David R. Lewis, Esq. 688 Tremont Street Pillsbury, Winthrop, Shaw, Pittman, P.O. Box 2824 LLP Duxbury, MA 02331 2300 N Street, N.W. nord(t)town .d u.xburv.m-a. us Washington, DC 20037-1138 MA Mary Elizabeth Lampert Date