ML110680133

Friends of the Coast and New England Coalition, Inc. Request for Extension of Time

ML110680133
Person / Time
Site:	Seabrook
Issue date:	03/08/2011
From:	Shadis R Friends of the Coast, New England Coalition
To:	NRC/SECY
SECY RAS
References
50-443-LR, ASLBP 10-906-02-LR-BD01, RAS 19765
Download: ML110680133 (6)

Text

March 8, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Secretary In the Matter of ASLBP No. 10-906-02-LR NextEra Energy Seabrook, LLC Docket No. 50-443-LR Seabrook Station (Operating License Renewal) March 8, 2011 FRIENDS OF THE COAST AND NEW ENGLAND COALITION, INC.

REQUEST FOR EXTENSION OF TIME Pursuant to 10 C.F.R. § 2.307, Friends of the Coast and New England Coalition, Inc.

(Friends/NEC") respectfully and for good cause requests of the Secretary of the Commission, an extension of time of three-days, from Monday, March 7, 2011 to Thursday, March 10, 2011 in which to file its Opposition to NextEras Appeal to the Commission of LBP 11 02, February 25, 2011, in the above captioned matter.

DISCUSSION In accordance with 10 C.F.R. 2.311(b), Friends/NECs answer or opposition was due Monday, March 7, 2011. Friends /NEC undertook diligently to file its Answer and Opposition to NextEras appeal within the ten days allowed.

However a heavy rain on frozen earth beginning late Sunday, the 6th and continuing through Monday, the 7th resulted in a basement flood knocking out furnace, water-pump, and electrical circuitry in the Friends/NEC Edgecomb, Maine office; thus disabling completely Friends/NECs ability to complete its pleading and filing. Further, a resulting unanticipated

computer shutdown caused the loss of essential files: references and pleading material, which Friends/NEC is now undertaking to retrieve from other sources. Office utilities were not fully restored until mid-day, March 8, 2011, whereupon Friends/NEC sought concurrence from the parties for this request for extension of time.

For all of the forgoing good reasons, Friends/NEC now respectfully requests that the deadline be extended until Thursday, March 10, 2003 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 the Friends/NEC Request for Extension of time in which to file its Answer and Opposition to NextEras Appeal .

The parties have represented as follows: Beyond Nuclear supports, NRC Staff cannot support, (but might have had NEC filed this request on Monday) and NextEra opposes the 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

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY In the Matter of )

)

NEXTERA ENERGY SEABROOK, LLC ) DOCKET NO. 50-443-LR (Seabrook Station, Unit 1) )

)

(License Renewal) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Friends of the Coast/ New England Coalition Request for Extension of Time, dated March 8, 2011, have been served upon the following persons by Electronic Information Exchange.

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Mail Stop: T-3F23 Mail Stop: O-15D21 Washington, DC 20555-0001 Washington, DC 20555-0001 Catherine Kanatas Administrative Judge catherine.kanatas@nrc.gov Paul S. Ryerson, Chair Emily Monteith, Esq.

psr1@nrc.gov emily.monteith@nrc.gov Brian Newell, Paralegal Administrative Judge brian.newell@nrc.gov Michael F. Kennedy David Roth, Esq.

michael.kennedy@nrc.gov der@nrc.gov Maxwell Smith, Esq.

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

richard.wardwell@nrc.gov mary.baty@nrc.gov Edward Williamson, Esq.

Anthony C. Eitreim, Esq. elw2@nrc.gov Chief Counsel Megan Wright, Esq.

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

Counsel for the Applicant Counsel for the Applicant NextEra Energy Seabrook, LLC NextEra Energy Seabrook, LLC 801 Pennsylvania Avenue, N.W. 700 Universe Boulevard Suite 220 Juno Beach, FL 33408 Washington, DC 20004 William Blair, Esq.

Steven C. Hamrick, Esq. william.blair@fpl.com steven.hamrick@fpl.com Antonio Fernandez, Esq.

Kim Bartels, Paralegal antonio.fernandez@fpl.com kim.bartels@fpl.com Mitchell S. Ross, Esq.

mitch.ross@fpl.com Beyond Nuclear Friends of the Coast/New England Coalition 6930 Carroll Avenue, Suite 400 Post Office Box 98 Takoma Park, MD 20912 Edgecomb, ME 04556 Paul Gunter, Director Raymond Shadis, Pro Se Representative Reactor Oversight Project shadis@prexar.com paul@beyondnuclear.org New Hampshire Sierra Club 40 N. Main Street Concord, NH 03870 Kurt Ehrenberg, Field Organizer kurt.ehrenberg@sierraclub.org Seacoast Anti-Pollution League P.O. Box 1136 Portsmouth, NH 03802 Doug Bogen, Executive Director dbogen@metrocast. net

[Signed Electronically]

Raymond Shadis Friends/NEC PO Box 98 Edgecomb. ME 04556 207-882-780 Dated at Edgecomb, Maine this 8th day of March 2011.

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