ML19011A158
| ML19011A158 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 01/11/2019 |
| From: | Lodge T Citizens for Alternatives to Chemical Contamination, Citizens' Environmental Coalition, Don't Waste Michigan, Nuclear Energy Information Service, Nuclear Issues Study Group, Public Citizen, San Luis Obispo Mothers for Peace, Terry Jonathan Lodge |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| ASLBP 18-958-01-ISFSI-BD01, RAS 54748, Holtec International | |
| Download: ML19011A158 (3) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of Holtec International (HI-STORE Consolidated Interim Storage Facility)
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Docket No. 72-1051
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January 11, 2019
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MOTION OF DONT WASTE MICHIGAN, CITIZENS ENVIRONMENTAL COALITION, CITIZENS FOR ALTERNATIVES TO CHEMICAL CONTAMINATION, NUCLEAR ENERGY INFORMATION SERVICE, PUBLIC CITIZEN, INC., SAN LUIS OBISPO MOTHERS FOR PEACE AND NUCLEAR ISSUES STUDY GROUP TO ADOPT AND LITIGATE SIERRA CLUB CONTENTIONS Now come Petitioners Dont Waste Michigan, Citizens for Alternatives to Chemical Contamination, Public Citizen, Inc., San Luis Obispo Mothers for Peace, Nuclear Energy Information Service, Citizens Environmental Coalition, and Nuclear Issues Study Group (Joint Petitioners), by and through counsel, and pursuant to 10 C.F.R. § 2.309(f)(3), move to adopt all contentions filed by the Sierra Club and admitted into this proceeding, and to re-allege and litigate them as their own.
Joint Petitioners and the Sierra Club share many of the same issues and concerns regarding the proposed Holtec CISF at issue in this proceeding. It would serve the interests of judicial economy and merits litigation of the issues raised in this proceeding for Joint Petitioners to adopt the Sierra Clubs contentions.
Joint Petitioners agree that the Sierra Club shall act as the primary party with respect to its contentions, and they designate the Sierra Clubs counsel, Wallace L. Taylor, as their representative, delegating to him the authority to act for the Joint Petitioners as to those contentions.
Where two petitioners have independently met the requirements to participate in a licensing proceeding, the Atomic Safety and Licensing Board may provisionally allow them to adopt each others issues early in the proceeding. Consol. Edison Co. (Indian Point, Units 1 and 2), CLI-01-19, 54 NRC 109, 132 (2001).
Certification of Consultation With Opposing Counsel As required by 10 C.F.R. § 2.323(b), counsel for Joint Petitioners solicited the agreement of opposing parties counsel to this motion via communication on January 8, 2019. Counsel for Holtec International opposed the motion. The NRC Staff stated that it had no opposition to the motion. The Sierra Club consents to the granting of the motion. The other parties did not respond.
WHEREFORE, Joint Petitioners pray the Atomic Safety and Licensing Board grant them leave to adopt all of the contentions of the Sierra Club admitted for hearing in this proceeding and to designate Wallace L. Taylor as their representative with respect to those contentions.
/s/ Terry J. Lodge Terry J. Lodge, Esq.
316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 205-7084 tjlodge50@yahoo.com Counsel for Dont Waste Michigan, Citizens Environmental Coalition, Citizens for Alternatives to Chemical Contamination, Nuclear Energy Information Service, Public Citizen, Inc., San Luis Obispo Mothers for Peace and Nuclear Issues Study Group, Petitioners UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of Holtec International (HI-STORE Consolidated Interim Storage Facility)
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Docket No. 72-1051
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January 11, 2019
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CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on this 11 day of January, 2019, th copies of the Motion of Dont Waste Michigan, Citizens Environmental Coalition, Citizens for Alternatives to Chemical Contamination, Nuclear Energy Information Service, Public Citizen, Inc., San Luis Obispo Mothers for Peace and Nuclear Issues Study Group Motion to Adopt and Litigate All Sierra Club Contentions was filed in the Electronic Information Exchange (the NRCs E-Filing System) in the above captioned proceeding for service via automated distribution to all registered counsel and parties.
/s/ Terry J. Lodge Terry J. Lodge, Esq.
Counsel for Joint Petitioners DWM et al.