ML110591142

Friends of the Coast and New England Coalition, Inc., Request for Extension of Time - Addenda Certificate of Counsel

ML110591142
Person / Time
Site:	Seabrook
Issue date:	02/28/2011
From:	Shadis R Friends of the Coast, New England Coalition
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 19713, 50-443-LR, ASLBP 10-906-02-LR-BD01
Download: ML110591142 (4)

Text

February 26, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ASLBP No. 10-906-02-LR NextEra Energy Seabrook, LLC Docket No. 50-443-LR Seabrook Station (Operating License Renewal) February 28, 2011 FRIENDS OF THE COAST AND NEW ENGLAND COALITION, INC.

REQUEST FOR EXTENSION OF TIME ADDENDA CERTIFICATE OF COUNSEL INTRODUCTION On February 26, 2011, Friends/NEC filed a request for Extension of Time in which to present its Motion for Reconsideration, due no later than February 25, 2011, but also filed on February 26, 2011.

In its Request for Extension of Time, Friends/NEC explained that it had not consulted with the parties as required by 10 C.F.R.§2.323 in as much as February 26th was a Saturday, but that Friends/NEC would consult with the parties and file a §2.323 Certificate on the next business day, February 28, 2011. Friends/NEC has now consulted with the parties and reports that the Request for Extension of Time is unopposed.

CERTIFICATE OF COUNSEL Pro Se Representative for Friends/NEC hereby certifies that in conformance with 10 C.F.R.

§2.323, Friends/NEC made a sincere attempt to obtain the consent of the parties to the filing of 1

the Friends/NEC Request for Extension of time in which to file a Motion for Reconsideration of the Boards February 15, 2011 Order.

The parties have represented as follows: Beyond Nuclear supports, NRC Staff does not oppose, and NextEra does not take a position on the retroactive motion for extension of time to file the reconsideration motion.

Respectfully submitted, Electronically signed

[Raymond Shadis]

Raymond Shadis Pro se representative Friends of the Coast New England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801 Shadis@prexar.com 2

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ASLBP No. 10-906-02-LR NEXTERA ENERGY SEABROOK, LLC Docket No. 50-443-LR (Seabrook Station, Unit 1)

February 28, 2011 (License Renewal)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Friends of the Coast and New England Coalition, Inc.

Request for Extension of Time Addenda - Certificate Of Counsel, dated February 28, 2011, have been served upon the following persons by Electronic Information Exchange.

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop: T-3F23 Office of the General Counsel Washington, DC 20555-0001 Mail Stop: O-15D21 Washington, DC 20555-0001 Administrative Judge Emily Monteith, Esq.

Paul S. Ryerson, Chair emily.monteith@nrc.gov psr1@nrc.gov Brian Newell, Paralegal brian.newell@nrc.gov Administrative Judge David Roth, Esq.

Michael F. Kennedy david.roth@nrc.gov michael.kennedy@nrc.gov Maxwell Smith, Esq.

maxwell.smith@nrc.gov Administrative Judge Mary Spencer, Esq.

Richard E. Wardwell mary.spencer@nrc.gov richard.wardwell@nrc.gov Edward Williamson, Esq.

edward.williamson@nrc.gov Anthony C. Eitreim, Esq. Megan Wright, Esq.

Chief Counsel megan.wright@nrc.gov ace1@nrc.gov OGC Mail Center OGCMailCenter@nrc.gov Hillary Cain, Law Clerk hillary.cain@nrc.gov U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Office of the Secretary of the Commission Mail Stop: O-16C1 Mail Stop: O-16C1 Washington, DC 20555-0001 Washington, DC 20555-0001 ocaamail@nrc.gov hearingdocket@nrc.gov 3

Counsel for the Applicant Kurt Ehrenberg, Field Organizer NextEra Energy Seabrook, LLC kurt.ehrenberg@sierraclub.org 801 Pennsylvania Avenue, N.W. New Hampshire Sierra Club Suite 220 40 N. Main Street Washington, DC 20004 Concord, NH 03870 Steven C. Hamrick, Esq. Seacoast Anti-Pollution League steven.hamrick@fpl.com P.O. Box 1136 Kim Bartels, Paralegal Portsmouth, NH 03802 kim.bartels@fpl.com Doug Bogen, Executive Director dbogen@metrocast.net Beyond Nuclear 6930 Carroll Avenue, Suite 400 Counsel for the Applicant Takoma Park, MD 20912 NextEra Energy Seabrook, LLC Paul Gunter, Director 700 Universe Boulevard Reactor Oversight Project Juno Beach, FL 33408 paul@beyondnuclear.org William Blair, Esq.

william.blair@fpl.com Antonio Fernandez, Esq.

antonio.fernandez@fpl.com Mitchell S. Ross, Esq.

mitch.ross@fpl.com

[Original signed by Raymond Shadis]

Friends of the Coast/New England Coalition Post Office Box 98 Edgecomb, ME 04556 Raymond Shadis, Pro Se Representative shadis@prexar.com Dated at Edgecomb, Maine this 28th day of February 2011 4