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Category:Legal-Motion
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Attachment 4 - Cover Page of ENTR00681 WCAP-17199-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted
ML15348A4392015-12-14014 December 2015
Attachment 5 - Cover Page of ENTR00682 WCAP-17200-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted
ML15348A4402015-12-14014 December 2015
Attachment 6 - Cover Page of ENTR00683 CN-PAFM-13-32, Revision 4, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted
ML15348A4412015-12-14014 December 2015
Attachment 7 - Cover Page of ENTR00689 WCAP-12191, Revision 5, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted
ML15348A4422015-12-14014 December 2015
Attachment 8 - Cover Page of ENTR00690 WCAP-16898-P, Revision 2, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement, Full Text Copyrighted
ML15348A4432015-12-14014 December 2015
Attachment 9 - Cover Page of ENTR00727 CN-PAFM-09-21, Revision 4, Contains Westinghouse Designated Proprietary Information Subject to Nondisclosure Agreement Full Text Copyrighted
2023-05-15
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Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Docket Nos. 50-247-LR and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 1 and 3) ) March 26, 2014
__________________________________________)
HUDSON RIVER SLOOP CLEARWATER INC.S UNOPPOSED MOTION FOR 3 MINUTE EXTENSION OF TIME TO FILE COMBINED ANSWER BRIEF Pursuant to 10 C.F.R. § 2.333 and § 2.307(a), Hudson River Sloop Clearwater, Inc.
(Clearwater) hereby requests that the Commission grant an extension of time of 3 minutes in which to file its Combined Answer in opposition to the Applicants Petition for Review and the NRC Staffs Petition for Review regarding Contention CW-EC-3A (Answer Brief). The request is unopposed.
Clearwaters counsel apologizes to the Commission and the parties for having to submit this motion for a de minimus 3-minute extension, but does so to come into technical compliance the deadline for submitting Clearwaters Answer Brief.
Pursuant to the Commission Order of February 28, 2014, Clearwater was to file its Answer Brief by March 25, 2014. The Answer Brief was timely completed on March 25, 2014 but was technically filed 3 minutes after midnight Eastern Standard Time. Clearwaters counsel logged onto the NRCs filing website prior to midnight but was delayed a few minutes while online in completing the filing due to entry issues and having to reformat the Brief from Word to pdf format for filing, and was essentially standing in line to file when the midnight deadline ran, and the filing was entered by NRC computer processing as 3 minutes after midnight.
Clearwaters counsel diligently worked to complete the Answer Brief for several weeks and was delayed shortly before filing when the final draft was inadvertently saved without the final revisions and they had to be re-entered. At the time the Answer Brief was filed, it was 10:03 pm MST on March 25, 2014, in Denver, Colorado, from where the Answer Brief was filed.
The Answer Brief has been filed with the Commission and served on all parties. The 3 minute delay is de minimus, unintentional, and does not prejudice any party nor the Commission in any manner. In contrast, Clearwater would suffer great prejudice if the Answer Brief were not accepted.
Clearwaters counsel contacted counsel for all parties in this proceeding and all parties expressed that they were unopposed to the request for a 3-minute extension of time.
Accordingly, for good cause shown, Clearwater requests that the Commission grant it 3 additional minutes in which to submit its Answer Brief.
Respectfully Submitted, Signed (electronically) by Andrew B. Reid Andrew B. Reid, Esq.
Springer & Steinberg, P.C.
1600 Broadway, Suite 1200 Denver, CO 80202 Tel: 303.861.2800 / Fax: 303.832.7116 Email: areid@springer-and-steinberg.com Dated: March 26, 2014, Denver, Colorado.
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305 (as revised), I certify that, on this date, copies of the HUDSON RIVER SLOOP CLEARWATER, INC.S UNOPPOSED MOTION FOR 3-MINUTE EXTENSION OF TIME TO FILE COMBINED ANSWER BRIEF were served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned proceeding.
Dated: March 26, 2014.
Signed (electronically) by Andrew B. Reid Andrew B. Reid, Esq.
Springer & Steinberg, P.C.
1600 Broadway, Suite 1200 Denver, CO 80202 Tel: 303.861.2800 / Fax: 303.832.7116 Email: areid@springer-and-steinberg.com
