ML103270322
| ML103270322 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/22/2010 |
| From: | Shadis R New England Coalition, Friends of the Coast |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML103270317 | List: |
| References | |
| RAS 19163, 50-443-LR, ASLBP 10-906-02-LR-BD01 | |
| Download: ML103270322 (4) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of FPL Energy Seabrook, LLC (NextEra, Inc)
(Seabrook Station, Unit 1 - License Renewal Application)
FRIENDS OF THE COAST/NEW ENGLAND COALITIONS REQUEST FOR EXTENSION OF TIME INTRODUCTION Friends of the Coast/New England Coalition, (Friends of the Coast/NEC) through its pro se representative, Raymond Shadis, respectfully requests a one-day extension of time in which to file its Petition for Leave to Intervene and Request for a Hearing in the above captioned matter.
This extension, if granted, would allow for filing of Friends of the Coast/NECs Petition and Request on November 23, 2010, one day past the due date of November 22, 2010.
DISCUSSION Friends of the Coast/NECs need for the requested extension arises from a computer/ internet service-provider connection failure which occurred on the evening of November 22, 2010 and prevented timely filing of Friends of the Coast/New England Coalitions Reply to NRC Staff and NextEra Answers to the Friends of the Coast/New England Coalition Petition for Leave to Intervene and Request for a Hearing in the above captioned Matter.
November 22, 2010 Docket No. 50-443
2 As it happened, and for reasons unknown to Friends/NEC, the connection was restored shortly after midnight and the Friends/NEC filing was made. However, due to the consternation and the confusion of the moment, Friends/NEC inadvertently attached the incorrect file at the EIE site, thus filing a draft version of its pleading, which lacked (1) sequential numbering of its pages, (2) a Certificate of service; and (3) attachments providing pdf image files of member declarations.
These is no substantial harm to the parties with respect to timeliness, inasmuch as service of a substantially identical pleading was provided via electronic submission to the docket within minutes of the November 22, 2010 11:59 electronic filing deadline and service of the complete and intended filing is completed in the forenoon of the today, November 23, 2010.
Friends/NEC avers that consideration of its Reply is important to addressing its members interests and will aid in building a good record in this proceeding.
Friends/NEC is filing, contemporary with this request, the correct, intended Friends/NEC Reply in anticipation of the Boards favorable response to this request for extension of time. Friends/NEC will make every effort to see to it that all future filings are made well in advance of the deadline.
For the good reasons set forth above, Friends of the Coast/NEC now respectfully requests that the Board now grant the requested extension of time for Friends /NEC to file its Reply to NRC Staff and NextEra Answers to Friends of the Coast/New England Coalitions Motion for Leave to Intervene in the above captioned matter of one day.
3 Certificate Pro se representative for Friends of the Coast/NEC certifies that he has consulted with the other parties regard this Request for Extension of Time as required by 10 C.F.R. § 2.323(b). FPL/NextEra opposes the motion. NRC Staff does not oppose this motion provided that there are no substantive changes to the filing.
Signed (electronically) by Raymond Shadis Friends of the Coast New England Coalition Post Office Box 98 Edgecomb, Maine 04556 shadis@prexar.com 207-882-7801 AFFIDAVIT I, Raymond Shadis, do hereby declare under penalty of perjury that all of the information contained in the foregoing Friends of the Coast/New England Coalition Request for Extension of Time is true and correct.
Signed (electronically) this day, November 23, 2010 at Edgecomb, Maine Signed (electronically) by Raymond Shadis Friends of the Coast New England Coalition
4 Post Office Box 98 Edgecomb, Maine 04556 shadis@prexar.com 207-882-7801