ML19080A039
| ML19080A039 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 03/21/2019 |
| 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 54876, Holtec International | |
| Download: ML19080A039 (3) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF:
)
) Docket No. 72-1051 HOLTEC INTERNATIONAL
)
) March 21, 2019 (Consolidated Interim Storage Facility
)
Project)
)
SIERRA CLUBS REPLY TO NRC STAFFS RESPONSE TO SIERRA CLUBS MOTION TO AMEND CONTENTION 16 Comes now Sierra Club and for its Reply to NRC Staffs Response to Sierra Clubs Motion to Amend Contention 16, states as follows:
INTRODUCTION Sierra Club Contention 16, as originally presented, alleged that Holtecs ER does not contain any information as to whether brine continues to flow in the subsurface under the Holtec site. The contention was based on the information available at the time Sierra Clubs Petition to Intervene was filed.
The Requests for Information (RAIs) submitted to Holtec and Holtecs Responses thereto presented new information that was not available when the original Contention16 was drafted. The information contained in Holtecs Responses to the RAIs was not even set forth in Holtecs Answer to the original Contention 16.
SIERRA CLUBS MOTION TO AMEND CONTENTION 16 WAS TIMELY FILED Sierra Club has set forth in its Motion to Amend Contention 16 and in its Reply to Holtecs Opposition to Sierra Clubs Motion to Amend 16 why the Motion to Amend Contention 16 was timely filed. The NRC Staff has not presented any new arguments or 1
facts in support of its allegation that the Motion to Amend Contention 16 was not timely filed that were not raised by Holtec. Therefore, Sierra Club incorporates and restates herein the statements and arguments made in its Reply to Holtecs Opposition to Sierra Clubs Motion to Amend Contention 16.
AMENDED CONTENTION 16 IS ADMISSIBLE Sierra Club has set forth in its Motion to Amend Contention 16 and in its Reply to Holtecs Opposition to Sierra Clubs Motion to Amend 16 why the Motion to Amend Contention 16 is admissible. The NRC Staff has not presented any new arguments or facts in support of its allegation that the Motion to Amend Contention 16 is not admissible that were not raised by Holtec. Therefore, Sierra Club incorporates and restates herein the statements and arguments made in its Reply to Holtecs Opposition to Sierra Clubs Motion to Amend Contention 16.
/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 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF: )
) Docket No. 72-1051 HOLTEC INTERNATIONAL )
)
(Consolidated Interim Storage Facility ) March 21, 2019 Project) )
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, copies of Sierra Clubs Reply to NRC Staffs Response to Sierra Clubs Amended Contention 16 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 3