ML11269A134
| ML11269A134 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/26/2011 |
| From: | Polonsky A, Sutton K Exelon Generation Co, Morgan, Morgan, Lewis & Bockius, LLP |
| To: | NRC/OCM |
| SECY RAS | |
| References | |
| License Renewal, RAS 21125, 50-352-LR, 50-353-LR | |
| Download: ML11269A134 (4) | |
Text
DB1/68197729.1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of
)
Docket Nos. 50-352-LR
)
50-353-LR EXELON GENERATION COMPANY, LLC
)
)
(Limerick Generating Station, Units 1 and 2)
)
September 26, 2011
)
EXELONS ANSWER TO NRDCS REQUEST FOR EXTENSION OF TIME On September 22, 2011, NRDC submitted a request to the Office of the Secretary to extend the deadline to file a Request for Hearing and Petition for Leave to Intervene (Request/Petition) to challenge the license renewal application for the Limerick Generating Station.1 Although submitted in letter format, the content requests relief from the Secretary, and should have been submitted as a Motion. See 10 C.F.R. § 2.323(a). Exelon Generation Company, LLC (Exelon) treats the letter as a motion for extension of time, and hereby submits this Answer in response, pursuant to 10 C.F.R. § 2.323(c).
Under the NRCs Federal Register2 announcing the opportunity to file a Request/Petition, the deadline for filing a Request/Petition is October 24, 2011. NRDC seeks a 30-day extension.
Exelon does not oppose NRDCs requested extension. However, a 30-day extension would move the due date for any Request/Petition to November 22, 2011, which is the Tuesday before 1
See Letter from G. Fettus to NRC, Office of the Secretary, Re: Extension of Time for Opportunity to Request a Hearing and Petition for Leave to Intervene in the NRCs Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Nos. NPF-39 and NPF-85 for an Additional 20-Year Period, Exelon Generation Company, LLC, Limerick, Generating Station, Docket ID NRC-2011-0166, Docket Numbers 50-352 and 50-353 (September 22, 2011) (Extension Request).
DB1/68197729.1 2
Thanksgiving. Exelon would request an additional five (5) calendar days to account for the interruption caused by the Thanksgiving holiday. Accordingly, if the Commission grants NRDCs request, and NRDC files a Request/Petition, then Exelon respectfully requests that the Commission extend Exelons time to answer from twenty-five (25) days, pursuant to 10 C.F.R.
§ 2.309(h)(1), to thirty (30) days. Counsel for Exelon contacted counsel for NRDC, and counsel for NRDC stated that he did not object to Exelons contingent request for an additional five days.
Respectfully submitted, Signed (electronically) by Alex S. Polonsky Alex S. Polonsky Kathryn M. Sutton Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Phone: 202-739-5830 Fax: 202-739-3001 E-mail: apolonsky@morganlewis.com Counsel for Exelon Generation Company, LLC 2
Notice of Acceptance for Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Nos. NPF-39 and NPF-85 for an Additional 20-Year Period (August 24, 2011).
DB1/68197729.1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of
)
Docket Nos. 50-352-LR
)
50-353-LR EXELON GENERATION COMPANY, LLC
)
)
(Limerick Generating Station, Units 1 and 2)
)
September 26, 2011
)
CERTIFICATE OF SERVICE I hereby certify that on September 26, 2011 a copy of the foregoing Exelons Answer to NRDCs Request for Extension of Time was filed electronically with the Electronic Information Exchange.
Office of the Secretary U.S. Nuclear Regulatory Commission Rulemakings and Adjudications Staff Washington, DC 20555-0001 E-mail: hearingdocket@nrc.gov Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Mail Stop: O-16C1 Washington, DC 20555-0001 E-mail: ocaamail@nrc.gov Geoffrey H. Fettus Senior Project Attorney Natural Resources Defense Counsel 1152 15th St., N.W.
Washington, D.C. 20005 E-mail: gfettus@nrdc.org Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop O-15D21 Washington, DC 20555-0001 ogcmailcenter@nrc.gov Catherine Kanatas catherine.kanatas@nrc.gov Brian Newell brian.newell@nrc.gov Maxwell Smith maxwell.smith@nrc.gov Mary Spencer mary.spencer@nrc.gov Ed Williamson edward.williamson@nrc.gov ASLBP Chief Judge Roy Hawkens roy.hawkens@nrc.gov
DB1/68197729.1 2
Signed (electronically) by Alex S. Polonsky Alex S. Polonsky Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Phone: 202-739-5830 Fax: 202-739-3001 E-mail: apolonsky@morganlewis.com COUNSEL FOR EXELON GENERATION COMPANY, LLC