ML12313A296

Clearwater'S Unopposed Motion for an Extension of Time to File a Motion Regarding Relevant New Information That Became Apparent After Hurricane Sandy

ML12313A296
Person / Time
Site:	Indian Point
Issue date:	11/08/2012
From:	Webster R Public Justice P C
To:	Lathrop K, Lawrence Mcdade, Richard Wardwell Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23717, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12313A296 (2)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Lawrence G. McDade, Chairman Dr. Kaye D. Lathrop Dr. Richard E. Wardwell 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) )

) Date: November 8, 2012 CLEARWATERS UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO FILE A MOTION REGRARDING RELEVANT NEW INFORMATION THAT BECAME APPARENT AFTER HURRICANE SANDY Hudson River Sloop Clearwater, Inc. (Clearwater) hereby moves for an extension of time to file a motion requesting the Atomic Safety and Licensing Board (the Board) to allow Clearwater to present evidence of how Hurricane Sandy had a disparate impact on Environmental Justice populations, including those in prisons, hospitals, and nursing homes.1 Clearwater respectfully requests that the filing date of that motion be moved from November 9, 2012, to November 14, 2012. After considerable discussion, neither Entergy nor the NRC Staff oppose the relief sought in this motion, nor does New York State.2 1

This cursory description of the motion is not exhaustive, Clearwater reserves the right to file its Motion regarding any new information arising out of Hurricane Sandy that is relevant.

2 Entergys acquiescence in Clearwaters motion for extension of time should not be taken as agreement that the motion Clearwater intends to file is in any way relevant to issues within the scope of license renewal or this proceeding.

1

The primary reason for this motion is that Clearwaters counsel, Richard Webster Esq., returned from Florida to New Jersey on November 1 to a dwelling without heat, power, and high-speed internet access. Northern New Jersey also experienced severe shortages of gasoline. Mr. Webster therefore elected not to drive to conserve his ability to leave the area, if necessary. Only very limited public transport was available. Ms. Raimundi, Clearwaters in-house representative also experienced similar difficulties. Clearwaters ability to work on gathering and collating relevant information was therefore severely impaired. The time extension requested will provide Clearwater with 10 days in which its representatives have functional offices, as envisaged by the Part 2 regulations.

Respectfully Submitted,

_________/s/__________

Richard Webster, Esq.

Public Justice, P.C.

1825 K Street, N.W. Suite 200 Washington, D.C. 20006 rwebster@publicjustice.net 202-797-8600 Dated: November 8, 2012 2