ML16005A623
| ML16005A623 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 01/05/2016 |
| From: | Roth P, Schofield S, Snook R State of CT, Office of the Attorney General, State of MA, Office of the Attorney General, State of NH, Office of the Attorney General |
| To: | NRC/OCM |
| SECY RAS | |
| References | |
| 50-271-LA-3, ASLBP 15-940-03-LA-BD01, RAS 50833 | |
| Download: ML16005A623 (5) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the matter of: )
)
ENTERGY NUCLEAR VERMONT YANKEE, LLC ) Docket No. 50-271 AND ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Vermont Yankee Nuclear Power Station) )
)
UN-OPPOSED MOTION BY THE STATES FOR AN ENLARGEMENT OF TIME TO FILE AN ANSWER TO ENTERGYS MOTION TO STRIKE THE STATES REPLY Pursuant to 10 C.F.R. § 2.307(a) and § 2.323(a), and un-opposed by Entergy,1 the Nuclear Regulatory Commission Staff (NRC Staff), and the Petitioners,2 the Commonwealth of Massachusetts and the States of Connecticut and New Hampshire (the States) respectfully request a brief enlargement of time in which the States must file an Answer to Entergys Motion to Strike Impermissible December 17, 2015 Reply Filed by the States (Motion to Strike the States Reply) from January 7, 2016 to January 15, 2016. In support of this Motion, the States note as follows:
- 1. On December 28, 2015, Entergy filed, pursuant to 10 C.F.R. § 2.323, a Motion to Strike the States Reply, which was filed on December 17, 2015. Under 10 C.F.R. § 2.323(c),
the States Answer to that Motion, if any, is currently due on January 7, 2016.
1 Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (collectively Entergy).
2 State of Vermont, the Vermont Yankee Nuclear Power Corporation, and the Green Mountain Power Corporation (collectively, Petitioners).
- 2. The States need a brief period of additional time to prepare and file their anticipated Answer to Entergys Motion to Strike their Reply due to the vacation schedule and existing commitments of undersigned counsel for the Commonwealth of Massachusetts, who is the lead counsel for the States, and to ensure the completion of necessary coordination and approval among the States regarding the anticipated Answer before it is filed. In particular, undersigned counsel for the States was on vacation during the weeks of December 21 and December 28 and just returned to work on January 4, 2016. In addition, undersigned counsel for the States has a number of pre-existing commitments, including a significant filing in another matter that is due on January 11, 2016 and will require a significant commitment of time and resources this week.
- 3. Counsel for each of the parties referenced above has stated that they do not oppose the requested enlargement of time.
For the foregoing reasons, and for good cause shown, the States respectfully request that the Commission grant this Motion and extend the deadline by which the States must file their Answer to Entergys Motion to Strike their Reply from January 7, 2016 to January 15, 2016.
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Dated: January 5, 2016 Respectfully submitted, Executed in Accord with 10 C.F.R. § 2.304(d)
THE COMMONWEALTH OF MASSACHUSETTS MAURA HEALEY ATTORNEY GENERAL By: /s/ Seth Schofield SETH SCHOFIELD Assistant Attorney General Environmental Protection Division Senior Appellate Counsel Energy and Environment Bureau Office of the Attorney General One Ashburton Place, 18th Floor Boston, MA 02108 Tel: (617) 963-2436 Fax: (617) 727-9665 seth.schofield@state.ma.us THE STATE OF CONNECTICUT THE STATE OF NEW HAMPSHIRE GEORGE JEPSEN JOSEPH A. FOSTER ATTORNEY GENERAL ATTORNEY GENERAL By: /s/ Robert Snook By: /s/ Peter C.L. Roth ROBERT SNOOK PETER C.L. ROTH Assistant Attorney General Senior Assistant Attorney General Office of the Attorney General Environmental Protection Bureau 55 Elm Street, P.O. Box 120 33 Capitol Street Hartford, Conn. 06106 Concord, NH 3301 Tel: (860) 808-5107 Tel: (603) 271-3679 robert.snook@ct.gov peter.roth@doj.nh.gov UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the matter of: )
)
ENTERGY NUCLEAR VERMONT YANKEE, LLC ) Docket No. 50-271 AND ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Vermont Yankee Nuclear Power Station) )
)
CONSULTATION Pursuant to 10 C.F.R. § 2.323(b), undersigned Counsel for the States conferred with counsel for Entergy, NRC Staff, and Petitioners, and they have all stated that they do not oppose the States request for an enlargement of time to file an Answer to Entergys Motion to Strike the States Reply.
/ Signed (electronically) by/
Seth Schofield Assistant Attorney General Environmental Protection Division Senior Appellate Counsel Energy and Environment Bureau Office of the Massachusetts Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 (617) 963-2436 Dated: January 5, 2016 seth.schofield@state.ma.us UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the matter of: )
)
ENTERGY NUCLEAR VERMONT YANKEE, LLC ) Docket No. 50-271 AND ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Vermont Yankee Nuclear Power Station) )
)
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, a copy of the foregoing Motion was served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above captioned docket.
/ Signed (electronically) by/
Seth Schofield Assistant Attorney General Environmental Protection Division Senior Appellate Counsel Energy and Environment Bureau Office of the Massachusetts Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 (617) 963-2436 Dated: January 5, 2016 seth.schofield@state.ma.us 16-01.05 [3] - States Mot. for an Enlargment of Time to File Resp (NRC Vt. Pet) [fnl].docx UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the matter of: )
)
ENTERGY NUCLEAR VERMONT YANKEE, LLC ) Docket No. 50-271 AND ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Vermont Yankee Nuclear Power Station) )
)
UN-OPPOSED MOTION BY THE STATES FOR AN ENLARGEMENT OF TIME TO FILE AN ANSWER TO ENTERGYS MOTION TO STRIKE THE STATES REPLY Pursuant to 10 C.F.R. § 2.307(a) and § 2.323(a), and un-opposed by Entergy,1 the Nuclear Regulatory Commission Staff (NRC Staff), and the Petitioners,2 the Commonwealth of Massachusetts and the States of Connecticut and New Hampshire (the States) respectfully request a brief enlargement of time in which the States must file an Answer to Entergys Motion to Strike Impermissible December 17, 2015 Reply Filed by the States (Motion to Strike the States Reply) from January 7, 2016 to January 15, 2016. In support of this Motion, the States note as follows:
- 1. On December 28, 2015, Entergy filed, pursuant to 10 C.F.R. § 2.323, a Motion to Strike the States Reply, which was filed on December 17, 2015. Under 10 C.F.R. § 2.323(c),
the States Answer to that Motion, if any, is currently due on January 7, 2016.
1 Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (collectively Entergy).
2 State of Vermont, the Vermont Yankee Nuclear Power Corporation, and the Green Mountain Power Corporation (collectively, Petitioners).
- 2. The States need a brief period of additional time to prepare and file their anticipated Answer to Entergys Motion to Strike their Reply due to the vacation schedule and existing commitments of undersigned counsel for the Commonwealth of Massachusetts, who is the lead counsel for the States, and to ensure the completion of necessary coordination and approval among the States regarding the anticipated Answer before it is filed. In particular, undersigned counsel for the States was on vacation during the weeks of December 21 and December 28 and just returned to work on January 4, 2016. In addition, undersigned counsel for the States has a number of pre-existing commitments, including a significant filing in another matter that is due on January 11, 2016 and will require a significant commitment of time and resources this week.
- 3. Counsel for each of the parties referenced above has stated that they do not oppose the requested enlargement of time.
For the foregoing reasons, and for good cause shown, the States respectfully request that the Commission grant this Motion and extend the deadline by which the States must file their Answer to Entergys Motion to Strike their Reply from January 7, 2016 to January 15, 2016.
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Dated: January 5, 2016 Respectfully submitted, Executed in Accord with 10 C.F.R. § 2.304(d)
THE COMMONWEALTH OF MASSACHUSETTS MAURA HEALEY ATTORNEY GENERAL By: /s/ Seth Schofield SETH SCHOFIELD Assistant Attorney General Environmental Protection Division Senior Appellate Counsel Energy and Environment Bureau Office of the Attorney General One Ashburton Place, 18th Floor Boston, MA 02108 Tel: (617) 963-2436 Fax: (617) 727-9665 seth.schofield@state.ma.us THE STATE OF CONNECTICUT THE STATE OF NEW HAMPSHIRE GEORGE JEPSEN JOSEPH A. FOSTER ATTORNEY GENERAL ATTORNEY GENERAL By: /s/ Robert Snook By: /s/ Peter C.L. Roth ROBERT SNOOK PETER C.L. ROTH Assistant Attorney General Senior Assistant Attorney General Office of the Attorney General Environmental Protection Bureau 55 Elm Street, P.O. Box 120 33 Capitol Street Hartford, Conn. 06106 Concord, NH 3301 Tel: (860) 808-5107 Tel: (603) 271-3679 robert.snook@ct.gov peter.roth@doj.nh.gov UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the matter of: )
)
ENTERGY NUCLEAR VERMONT YANKEE, LLC ) Docket No. 50-271 AND ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Vermont Yankee Nuclear Power Station) )
)
CONSULTATION Pursuant to 10 C.F.R. § 2.323(b), undersigned Counsel for the States conferred with counsel for Entergy, NRC Staff, and Petitioners, and they have all stated that they do not oppose the States request for an enlargement of time to file an Answer to Entergys Motion to Strike the States Reply.
/ Signed (electronically) by/
Seth Schofield Assistant Attorney General Environmental Protection Division Senior Appellate Counsel Energy and Environment Bureau Office of the Massachusetts Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 (617) 963-2436 Dated: January 5, 2016 seth.schofield@state.ma.us UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the matter of: )
)
ENTERGY NUCLEAR VERMONT YANKEE, LLC ) Docket No. 50-271 AND ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Vermont Yankee Nuclear Power Station) )
)
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, a copy of the foregoing Motion was served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above captioned docket.
/ Signed (electronically) by/
Seth Schofield Assistant Attorney General Environmental Protection Division Senior Appellate Counsel Energy and Environment Bureau Office of the Massachusetts Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 (617) 963-2436 Dated: January 5, 2016 seth.schofield@state.ma.us 16-01.05 [3] - States Mot. for an Enlargment of Time to File Resp (NRC Vt. Pet) [fnl].docx