ML12223A358
| ML12223A358 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/10/2012 |
| From: | Snook R State of CT, Office of the Attorney General |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 23284, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML12223A358 (2) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the matter of Docket Nos. 50-247-LR and 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC.
(Indian Point Nuclear Generating Units 2 and 3) August 10, 2012 STATE OF CONNECTICUTS MOTION FOR LEAVE TO FILE REPLY TO RESPONSES OF NRC STAFF AND ENTERGY TO CONNECTICUTS STATEMENT OF POSITION In accordance with 10 C.F.R. § 2.323(a), the State of Connecticut hereby moves the Atomic Safety and Licensing Board (Board) for leave to file the attached reply to the Response of NRC Staff and Applicants Response to Connecticuts Statement of Position. This reply does not purport to change anything in Connecticuts Statement of Position filed on June 28, but is needed to clarify an evident misperception. In support of this Motion, State of Connecticut further states as follow:
- 1.
In accordance with the Boards previous scheduling Orders in this proceeding, Connecticut filed its Statement of Position (SOP) on June 28, 2012.
- 2.
Both NRC Staff and Entergy have filed responses to the Statement of Position stating, among other things, that the SOP should be vacated because it does not list the specific contentions it is designed to support.
- 3.
State of Connecticut recognizes that this proceeding began more than four years ago and respects the Boards desire to avoid unnecessary delay. However, this reply would not add any new factual material but is designed only to rectify a misperception.
- 4.
In accordance with 10 C.F.R. § 2.323(b), counsel for Connecticut certifies that he made a sincere effort to contact Entergy and the NRC Staff on August 8, 2012, to explain to them the factual and legal issues raised in this Motion, and to resolve those issues, and he certifies that his efforts have been unsuccessful.
- 4.
The Applicant and NRC Staff both oppose the proposed Motion and reserve the right to file a response.
WHEREFORE, State of Connecticut respectfully requests that the Board grant it leave to file the attached reply.
Respectfully submitted, By: /s/ Robert Snook_____________
Robert Snook Assistant Attorney General 55 Elm Street Hartford, CT 06141-0120 Phone: (860) 808-5020 Fax: (860) 808-5347 E-mail: Robert.Snook@ct.gov