ML18163A440
| ML18163A440 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 06/12/2018 |
| From: | Curran D Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Southern Alliance for Clean Energy, Tennessee Environmental Council |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 52-047-ESP, ASLBP 17-954-01-ESP-BD01, RAS 54329 | |
| Download: ML18163A440 (3) | |
Text
June 12, 2018 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
) Docket No. 52-047-ESP Tennessee Valley Authority )
)
(Clinch River Nuclear Site) )
)
INTERVENORS UNOPPOSED MOTION TO ESTABLISH JUNE 22, 2018 AS A FIXED DEADLINE FOR FILING A SINGLE REPLY TO RESPONSES TO INTERVENORS MOTION TO ADMIT NEW CONTENTIONS 4 AND 5 I. INTRODUCTION Pursuant to 10 C.F.R. §§ 2.323, Intervenors Southern Alliance for Clean Energy and Tennessee Environmental Council hereby request the Atomic Safety and Licensing Board (ASLB) to establish June 22, 2018 as a fixed deadline for filing a single reply to responses by Tennessee Valley Authority (TVA) and the U.S. Nuclear Regulatory Commission (NRC)
Staff to Intervenors Motion for Leave to File Contention 4 (Inadequate Discussion of Environmental Impacts of Spent Fuel Pool Fires) and Contention 5 (Impermissible Discussion of Energy Alternatives and Need for the Proposed SMR) (May 21, 2018) (Intervenors Motion for Leave to File New Contentions). Neither TVA nor the Staff opposes this motion.
Yesterday, June 11, 2018, the NRC Staff filed a Motion to Dismiss Contention 2 as Moot and Answer to Intervenors Motion for Leave to File Contentions 4 and 5. TVA also filed a Motion to Dismiss Contention 2 as Moot the same day, but unlike the Staff it did not file an answer to Intervenors Motion for Leave to File New Contentions. Under NRC regulation 10
C.F.R. 2.309(i), TVAs response to Intervenors Motion for Leave to File New Contentions is not due until June 15.
Intervenors were not expecting the NRC Staff to file a response to Contentions 4 and 5 early, and instead anticipated that both the Staff and TVA would file their responses on June 15.
Therefore, Intervenors counsel made a plan with Intervenors experts to review both the Staffs and TVAs responses the week of June 18 and file a single reply by June 22. By this motion, Intervenors seek to establish a predictable schedule for preparing and filing a single consolidated reply to TVAs and the Staffs responses to Intervenors new contentions. This modest schedule adjustment would conserve the resources of Intervenors, the other parties, and the ASLB.
Accordingly, Intervenors request the Board to establish June 22 as the due date for Intervenors reply to TVAs and the Staffs responses to Intervenors Motion for Leave to File New Contentions.
Respectfully submitted,
___/signed electronically by/__
Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com June 12, 2018 2
CERTIFICATE OF SERVICE I certify that on June 12, 2018, I posted copies of the foregoing INTERVENORS UNOPPOSED MOTION TO ESTABLISH JUNE 22, 2018 AS A FIXED DEADLINE FOR FILING A SINGLE REPLY TO RESPONSES TO INTERVENORS MOTION TO ADMIT NEW CONTENTIONS 4 AND 5 on the NRCs Electronic Information Exchange System.
___/signed electronically by/__
Diane Curran 3