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Category:Legal-Motion
MONTHYEARML18348A9852018-12-14014 December 2018
New England Coalition'S Withdrawal of Its Request for a Hearing and Petition for Leave to Intervene
ML18071A4142018-03-12012 March 2018
Amended Motion to Hold in Abeyance Action on New England Coalition'S Petition for Leave to Intervene and Hearing Request in Consideration of Anticipated Withdrawal
ML17164A2682017-06-13013 June 2017
Attachment Two - Five E-mails Tracing Efforts on June 9, 2017 to File a Request for an Extension of Time
ML17164A2382017-06-13013 June 2017
Resubmitted Request for Extension of Time to File Request for Hearing and Petition for Leave to Intervene
ML17164A2392017-06-13013 June 2017
Request for Leave to Reply and Reply to Applicants' Response to New England Coalition'S Request for Extension
ML16005A6232016-01-0505 January 2016
Unopposed Motion by the States for an Enlargement of Time to File an Answer to Entergy Motion to Strike the States Reply
ML15362A5192015-12-28028 December 2015
Entergy Motion to Strike Impermissible December 17, 2015 Reply Filed by the Commonwealth of Massachusetts and the States of Connecticut and New Hampshire
ML15362A4902015-12-28028 December 2015
Motion to Strike Portions of December 17, 2015, Reply Filed by the State of Vermont, Vermont Yankee Nuclear Power Corporation, and Green Mountain Power Corporation
ML15299A2602015-10-26026 October 2015
NRC Staff Motion to Vacate LBP-15-24
ML15286A4422015-10-13013 October 2015
Entergy Motion for Leave to File Reply and Reply Re Motion to Withdraw LAR
ML15275A3222015-10-0202 October 2015
Staff Answer to Motion to Withdraw
ML15271A3112015-09-23023 September 2015
Federal Respondents' Motion for Extension of Time to File Dispositive Motions and Certified Index 9-23-15
ML15265A5832015-09-22022 September 2015
Entergy'S Motion to Withdraw Its September 4, 2014 License Amendment Request
ML15265A5862015-09-22022 September 2015
Entergy'S Unopposed Motion to Extend the Time to Appeal LBP-15-24
ML15260B2782015-09-17017 September 2015
Joint Motion on Mandatory Disclosures and Schedule
ML15201A1752015-07-20020 July 2015
Joint Proposed Corrections to Oral Argument Transcript Held on July 7, 2015
ML15072A4622015-03-13013 March 2015
Entergy Answer Opposing State of Vermont'S Motion to Stay the License Amendment Proceeding Pending Commission Reconsideration
ML14352A2082014-12-18018 December 2014
NRC Staff Answer to State of Vermont'S Submission of Additional Information and Request to File Supplemental Briefing Addressing New Information and Argument Raised at Oral Argument
ML12088A0852012-03-15015 March 2012
Fed Respondents Opposition to Motion to Strike No.11-1168 and 11-1177 (Consolidated)
ML12067A0892012-03-0707 March 2012
State of Vermont Motion to Strike, Petitioners' Motion to Strike Four Extra-Record References Contained in Respondents' Recently Filed Amended Certified Index of the Record and in Respondents' and Interveners Briefs
ML12066A1772012-03-0606 March 2012
Petitioners Motion to Strike Amended Cert 11-1168
ML1107703932011-03-10010 March 2011
Motion to Stay Any and All Final Commission Decisions in the Matter of 50-271 Lr and Request for Hearing on Entergy License Renewal Application Amendments
Information Notice 2010-26, New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review2010-12-30030 December 2010
New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-19
Information Notice 2010-26, New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-2010-12-30030 December 2010
New England Coalition'S Motion for Leave to Reply to NRC Staff'S Objection to Nec'S Notification of Information Notice 2010-26 and Entergy'S Response to the Supplement to Nec'S Petition for Commission Review of LBP-10-19
ML1027204012010-09-23023 September 2010
Entergy'S Motion to Strike the Declaration of Paul Blanch
ML1025800092010-09-14014 September 2010
NRC Staff'S Opposition to New England Coalition'S Motion to Reopen the Hearing and Answer to Proposed New Contention and Affidavit of Roy K. Mathew
ML1024200422010-08-20020 August 2010
New England Coalition'S Motion to Reopen the Hearing and for the Admission of New Contentions
ML1006304252010-03-0202 March 2010
New England Coalition'S Petition for Review of Licensing Board'S Full Initial Decision
ML0921509462009-08-0303 August 2009
NRC Staff'S Answer to Nec'S Petition for Review of the Licensing Board'S Full Initial Decision, LBP-09-09
ML0917405782009-06-15015 June 2009
New England Coalition'S Request for Leave to Reply to Entergy'S Answer to Nec'S Request for Extension of Time to Reply to Entergy NRC Staff Oppositions to New England Coalition'S Motion for Leave to File a Timely New Contention
ML0916702672009-06-10010 June 2009
Entergy'S Oppositions to Nec'S Request for an Ex-Post-Facto Extension of Time to File a Reply to the NRC Staff and Entergy'S Oppositions to Nec'S Motion to File a Timely New Contention
ML0916000212009-06-0808 June 2009
Vermont Yankee - NRC Staff'S Answer to Entergy'S Motion to Strike New England Coalition'S Reply to NRC Staff Entergy Oppositions to Nec'S Motion to File a Timely New Contention
ML0916101422009-06-0202 June 2009
Entergy'S Motion to Strike New England Coalition'S Reply to NRC Staff and Entergy Oppositions to Nec'S Motion to File a Timely New Contention
ML0913907852009-05-19019 May 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to Nec'S Motion for Leave to File a New Contention
ML0912100122009-04-30030 April 2009
NRC Staff'S Answer in Opposition to NEC Motion to Hold in Abeyance Action on Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report
ML0912005142009-04-24024 April 2009
New England Coalition, Inc.'S Motion for Leave to File a Timely New Contention and Motion to Hold in Abeyance Action on This Proposed Contention Until Issuance of NRC Staff Supplemental Safety Evaluation Report
ML0906800032009-03-0606 March 2009
Oyster Creek - Notice of Appearance of Maxwell Smith and Notice of Withdrawal of Mary Baty
ML0906800082009-03-0606 March 2009
Vermont Yankee - Notice of Appearance of Maxwell Smith and Notice of Withdrawal of Mary Baty
ML0907711412009-03-0606 March 2009
New England Coalition'S Motion to Alter or Amend the Schedule in the Above Captioned Proceeding
ML0902601102009-01-26026 January 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to Nec'S Motion for Leave to Reply
ML0903501142009-01-25025 January 2009
Vermont Department of Public Service Unopposed Motion for Extension of Time to Respond to Energy'S Confirmatory Cufen Analyses
ML0903606582009-01-23023 January 2009
Entergy'S Opposition to New England Coalition'S Motion for Leave to Reply
ML0903001122009-01-14014 January 2009
New England Coalition'S Motion for Leave to Reply to NRC Staff and Entergy Nuclear Vermont Yankee, L.L.C., and Entergy Nuclear Operations, Inc.'S Answers to New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial
ML0900800242009-01-0707 January 2009
Vermont Yankee - NRC Staff'S Answer in Opposition to New England Coalition'S Motion for Reconsideration and Notice of Withdrawal of Jessica Bielecki
ML0835900532008-12-23023 December 2008
Vermont Yankee - NRC Staff'S Reply to Nec'S Answer to NRC Staff'S Petition for Review of LBP-08-25
ML0835900722008-12-23023 December 2008
Vermont Yankee - NRC Staff'S Reply to Motion to Submit Brief Amicus Curiae
ML0900202572008-12-19019 December 2008
Motion for Leave by the States of New York and Connecticut, Et. Al., to Submit Brief Amici Curiae in Opposition to Staff'S Petition for Review and in Support of Intervenors State of Vermont and the New England Coalition
ML0901603582008-12-17017 December 2008
New England Coalition'S Motion for Reconsideration of the Licensing Board'S Partial Initial Decision
ML0836593462008-12-15015 December 2008
New England Coalition, Inc.'S Motion for a Second Extension of Time in Which to File a Motion for Reconsideration
ML0835304522008-12-12012 December 2008
the State of New York, V USNRC and Entergy Nuclear Operations Inc; 08-3903-ag(L)/08-4833-ag(CON) - Motion Out of Time
2018-03-12
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P-&-S t4_ 5ý DOCKETED USNRC December 15, 2008 (10:53am)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF New England Coalition VT NH ME MA RI CT -NY __:1 POST OFFICE BOX 545, BRATTLEBORO, VERMONT o5302 December 15, 2008 Office of the Secretary Attn: Rulemaking and Adjudications Staff Mail Stop: O-16C1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket No. 50-271-LR, ASLBP No. 06-849-03-LR, Vermont Yankee Nuclear Power Station
Dear Rulemaking and Adjudications Staff,
Please find enclosed for filing before the Atomic Safety and Licensing Board in the above captioned proceeding:
NEW ENGLAND COALITION, INC.'S MOTION FOR A SECOND EXTENSION OF TIME IN WHICH TO FILE A MOTION FOR RECONSIDERATION Thank you for your kind attention,
/RS /x* /
for New England Coalition, Inc.
Raymond Shadis Pro Se Representative Post Office Box 98 Edgecomb, Maine 04556 04/ý
UNITED STATES NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of December 15, 2008 Entergy Nuclear Vermont Yankee, LLC Docket No. 50-271 -LR and Entergy Nuclear Operations, Inc. ASLB No. 06-894-03-LR (Vermont Yankee Nuclear Power Station)
NEW ENGLAND COALITION, INC.'S MOTION FOR A SECOND EXTENSION OF TIME IN WHICH TO FILE A MOTION FOR RECONSIDERATION New England Coalition, Inc. (NEC) respectfully requests a second extension of the deadline for a motion for reconsideration of the Atomic Safety and Licensing Board's
("ASLB") ("Board") Partial Initial Decision (Ruling on Contentions 2A, 2B, 3, and 4) in the above captioned matter.
The current deadline for NEC's Motion for Reconsideration, per the ASLB Order issued on December 4, 2008; granting a ten day extension of time, is December 15, 2008.
NEC requests that the Board extend the deadline by two days or until Wednesday, December 17, 2008.
NEC recognizes the extraordinary nature of a second extension of time however, as discussed below; NEC has experienced extraordinary, unforeseen, and unavoidable obstruction and delay in preparing its Motion for Reconsideration filing.
Discussion A Second Extension of Time (until Wednesday, December 17'h) in which to file NEC's Motion for Reconsideration is necessary to restore working time lost due to the New England-wide ice storm of December 1 Ith and 12th. This very severe storm knocked
out power to over 300,000 Central Maine Power customers: among them, NEC's Pro Se Representative. As a result of time lost due to the storm NEC now lacks adequate time in which to finalize its Motion for Reconsideration.
The ice storm knocked out power and phone (including internet connection) to the office and home of NEC's Pro Se Representative from Thursday evening (the 1 1 t) until Saturday afternoon (the 1 3P). Roads in the vicinity were impassable due to ice and downed power lines until mid-day Friday at which point NEC relocated preparation of its Motion for Reconsideration into borrowed office space in a nearby town. However, work in the borrowed space was greatly hampered as NEC's Pro Se Representative had only intermittent phone service and internet access; and did not have access to files in the main office computer or the office library. As it is, NEC is working diligently to complete the Motion for Reconsideration but it is very doubtful that it can be ready by the end of the day, December 15, 2008.
No party will be unduly burdened by a small extension of time of two days at this juncture. The proposed extension will however restore to New England Coalition time lost due to the ice storm; time much needed to finalize the Coalition's filing.
Agreement of the Parties On the morning of December 15, 2008, NEC requested (via E-mail) agreement of the Parties to its motion.
As of the time of this (electronic) filing Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy), and the States of New Hampshire and Massachusetts have not responded.
The State of Vermont Department of Public Service has indicated that it will support the motion.
2
NRC Staff has indicated that it will not oppose the motion provided that two additional days in which to respond are also granted.
Motion For all of the good reasons stated above, NEC respectfully moves the Board to extend the deadline for filing NEC's Motion to Reconsider by two days, until December 17, 2008.
Raymond Shadis Pro se Representative New England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801 Shadis @prexar.com -
AFFIDAVIT I, Raymond Shadis, swear under penalty of perjury that description of circumstances in the forgoing Motion for a Second Extension of Time in Which to File a Motion for Reconsideration is accurate and true.
Raymond Shadis Pro se Representative New England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801 Shadis @prexar.com 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Vermont Yankee, LLC ) Docket No. 50-271 -LR and Entergy Nuclear Operations, Inc. ) ASLBP No. 06-849-03-LR
)
(Vermont Yankee Nuclear Power Station) )
CERTIFICATE OF SERVICE I, Raymond Shadis, hereby certify that copies of New England Coalition, Inc.'s Motion for a Second Extension of Time in Which to File a Motion For Reconsideration in the above-captioned proceeding were served on the persons listed below, by U.S. Mail, first class, postage prepaid; and, where indicated by an e-mail address below, by electronic mail, on the 15th of December, 2008.
Administrative Judge Office of the Secretary Alex S. Karlin, Esq., Chair Attn: Rulemaking and Adjudications Staff Atomic Safety and Licensing Board Mail Stop: O-16C1 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: hearingdocket@nrc.gov E-mail: ask2@nrc.gov Sarah Hofmann, Esq.
Administrative Judge Director of Public Advocacy William H. Reed Department of Public Service 1819 Edgewood Lane 112 State Street, Drawer 20 Charlottesville, VA 22902 Montpelier, VT 05620-2601 E-mail: whrcville(aembar mail.com E-mail: sarah.hofmannristate.vt.us Office of Commission Appellate Adjudication Lloyd B. Subin, Esq.
Mail Stop: O-16C1 Mary C. Baty, Esq.
U.S. Nuclear Regulatory Commission Susan L. Uttal, Esq.
Washington, DC 20555-0001 Jessica A. Bielecki, Esq.
E-mail: OCAAmail(nrc.gov Office of the General Counsel Mail Stop 0-15 D21 Administrative Judge U.S. Nuclear Regulatory Commission Dr. Richard E. Wardwell Washington, DC 20555-0001 Atomic Safety and Licensing Board Panel E-mail: lbs3gnrc.gov; mebi (aanrc.ogov Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission susan.uttaibnrc.gov_; jessica.bielecki(&inrc.gov Washington, DC 20555-0001 E-mail: rewp@nrc.gov Anthony Z. Roisman, Esq.
National Legal Scholars Law Firm 84 East Thetford Road Lyme, NH 03768 E-mail: aroisman(dnationallegalscholars.com
Zachary Kahn David R. Lewis, Esq.
Atomic Safety and Licensing Board Panel Matias F. Travieso-Diaz Mail Stop T-3 F23 Pillsbury Winthrop Shaw Pittman LLP U.S. Nuclear Regulatory Commission 2300 N Street NW Washington, DC 20555-0001 Washington, DC 20037-1128 E-mail: zacharv.kati11 (rnrc.aov E-mail: david.lewis@pillsburylaw.com matias t avieso-diaz(Wn i Isburviaw.con i Peter C. L. Roth, Esq.
Office of the Attorney General Matthew Brock 33 Capitol Street Assistant Attorney General Concord, NH 03301 Environmental Protection Division E-mail: Peter.roth@doj.nh.gov Office of the Attorney General One Ashburton Place, 1 8 th Floor Boston, MA 02108 E-mail: Matthew.Brock hstate.nmaiis by:
Raymond Shadis Pro se Representative New England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801 shadisi,Drexar.corn
