ML18323A304
| ML18323A304 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 11/19/2018 |
| From: | Connolly E, Leidich A, Silberg J, Walsh T Holtec, Pillsbury, Winthrop, Shaw, Pittman, LLP |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| ASLBP 18-958-01-ISFSI-BD01, HI-STORE Fuel Storage, Holtec International, RAS 54638 | |
| Download: ML18323A304 (4) | |
Text
4825-7904-9338.v2 November 19, 2018 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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Docket No. 72-1051 Holtec International
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ASLBP No. 18-958-01-ISFSI-BD01
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HI-STORE Consolidated Interim Storage
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Facility
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HOLTEC INTERNATIONALS RESPONSE TO BOARD ORDER REGARDING LOCATION AND METHOD OF ORAL ARGUMENT In accordance with the Atomic Safety and Licensing Boards (the Boards) November 7, 2018 Order,1 Holtec International (Holtec) hereby submits a brief statement of its position concerning the preferable location for the prehearing conference and how to conduct oral argument most efficiently on standing and contention admissibility. Order at 2.
Location of Oral Argument. Holtecs preference for the location of the prehearing conference is either Hobbs or Carlsbad, New Mexico, or the NRC headquarters in Rockville, Maryland. Holtec believes that the Hobbs/Carlsbad location would be most convenient for Lea and Eddy Counties, the City of Hobbs, and the Eddy-Lea Energy Alliance, as well as those individuals and entities who are proximate to the proposed site. The NRC headquarters location would be most convenient for Holtec (based in Camden, New Jersey), as well as for the Board, the NRC Staff, and counsel for Holtec, and presumably counsel for Beyond Nuclear and NAC International (all located in Washington, DC). We would note that, while counsel for Alliance for Environmental Strategies is located in Albuquerque, New Mexico, counsel for Dont Waste 1 Order (Regarding Location and Method of Oral Argument) (Nov. 7, 2018).
2 4825-7904-9338.v2 Michigan, Fasken Land and Minerals, and Sierra Club are located neither in New Mexico nor Washington/Maryland, but in Toledo, Ohio; Lawrence, Kansas; and Cedar Rapids, Iowa, respectively.
Should the Board decide to hold the prehearing conference in Hobbs or Carlsbad, Holtec has identified the following possible locations for the Boards consideration:
Lea County Events Center, Hobbs, New Mexico (www.leacounty.net/p/departments/eventcenter), which has a banquet hall with three adjacent rooms accommodating up to 120 people per room.
The Center of Recreational Excellence (CORE), also in Hobbs (www.corehobbs.com), which has two banquet rooms that can accommodate up to a total of 196 persons.
The Pecos River Village Conference Center in Carlsbad, New Mexico (http://www.carlsbadchamber.com/pecos-river-village-conference-center), which has an exhibit hall that can accommodate up to 200 persons in a classroom arrangement.
The Walter Gerrells Performing Arts Center in Carlsbad, New Mexico (http://www.cityofcarlsbadnm.com/CommDevWalterGerrellsPA.cfm), which has an exhibit and banquet hall that can accommodate nearly 700 persons.
Timing of Oral Argument. The week of January 22, 2019 (following the Martin Luther King Jr. birthday holiday) would be appropriate, but Holtec recognizes that it may be inconvenient for Federal participants to travel to New Mexico prior to January 22.
Scope of Oral Argument. To assist the parties in focusing their preparation efforts for oral argument, Holtec respectfully suggests that the Board (1) identify any issues or contentions
3 4825-7904-9338.v2 for which the Board has determined that it does not need the assistance of oral argument; and (2) identify specific information or argument that would assist the Board in making its decision.
Respectfully submitted,
/Signed electronically by Timothy J. V. Walsh/
Erin E. Connolly Corporate Counsel Holtec International Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104 Telephone: (856) 797-0900 x 3712 e-mail: e.connolly@holtec.com Jay E. Silberg Timothy J. V. Walsh Anne R. Leidich PILLSBURY WINTHROP SHAW PITTMAN LLP 1200 Seventeenth Street, NW Washington, DC 20036 Telephone: 202-663-8063 Facsimile: 202-663-8007 jay.silberg@pillsburylaw.com timothy.walsh@pillsburylaw.com anne.leidich@pillsburylaw.com November 19, 2018 Counsel for HOLTEC INTERNATIONAL
4825-7904-9338.v2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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Docket No. 72-1051 Holtec International
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ASLBP No. 18-958-01-ISFSI-BD01
)
HI-STORE Consolidated Interim Storage
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Facility
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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Holtec Internationals Response to Board Order Regarding Location and Method of Oral Argument has been served through the EFiling system on the participants in the above-captioned proceeding this 19th day of November 2018.
/signed electronically by Timothy J. V. Walsh/
Timothy J. V. Walsh