ML19011A124
| ML19011A124 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 01/11/2019 |
| From: | Taylor W Law Offices of Wallace L. Taylor, Sierra Club |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| ASLBP 18-958-01-ISFSI-BD01, RAS 54747, Holtec International | |
| Download: ML19011A124 (3) | |
Text
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )
) Docket No. 72-1051 HOLTEC INTERNATIONAL )
)
(Consolidated Interim Storage ) January 11, 2019 Facility Project) )
SIERRA CLUBS MOTION TO ADOPT THE CONTENTIONS OF DONT WASTE MICHIGAN, CITIZENS ENVIRONMENTAL COALITION, CITIZENS FOR ALTERNATIVES TO CHEMICAL CONTAMINATION, NUCLEAR ENERGY INFORMATION SERVICE, NUCLEAR ISSUES STUDY GROUP, SAN LUIS OBISPO MOTHERS FOR PEACE, AND PUBLIC CITIZEN Comes now Sierra Club and in support of this Motion to Adopt the Contentions of Dont Waste Michigan, et al.,
states as follows:
- 1. Sierra Club and the above-named parties have many of the same issues and concerns regarding the proposed Holtec CIS facility at issue in this proceeding. It would be in the interests of efficiency and fully litigating the issues in this proceeding to allow the parties to adopt each others contentions.
- 2. Pursuant to 10 C.F.R. § 2.309(f)(3), Sierra Club moves to adopt all contentions filed by the above-named parties, Dont Waste Michigan, et al.
- 3. Sierra Club designates Terry J. Lodge as its representative regarding the Dont Waste Michigan et al.
contentions adopted by Sierra Club with the authority to act for Sierra Club as to those contentions.
- 4. Pursuant to 10 C.F.R. § 2.323(b), counsel for the Movants certifies that a sincere effort has been made to confer with other parties to resolve the issues raised in this Motion. Holtec opposes the Motion, NRC Staff have no objection to the Motion, and other parties have taken no position on the Motion.
WHEREFORE, Sierra Club requests that it be allowed to adopt all of the contentions of Dont Waste Michigan, et al., and to designate Terry J. Lodge as Sierra Clubs representative with respect to those contentions.
/s/ Wallace L. Taylor WALLACE L. TAYLOR Law Offices of Wallace L. Taylor 4403 1st Ave. S.E., Suite 402 Cedar Rapids, Iowa 52402 319-366-2428:(Fax)319-366-3886 e-mail: wtaylorlaw@aol.com ATTORNEY FOR SIERRA CLUB
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )
) Docket No. 72-1051 HOLTEC INTERNATIONAL )
)
(Consolidated Interim Storage ) January 11, 2019 Facility Project) )
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, copies of Motion to Adopt Contentions of Dont Waste Michigan et al. were served upon the Electronic Information Exchange (the NRCs E-Filing System) in the above captioned proceeding.
/s/ Wallace L. Taylor WALLACE L. TAYLOR Law Offices of Wallace L. Taylor 4403 1st Ave. S.E., Suite 402 Cedar Rapids, Iowa 52402 319-366-2428;(Fax)319-366-3886 e-mail: wtaylorlaw@aol.com ATTORNEY FOR SIERRA CLUB