ML20071D839

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Unopposed Motion of the State of New York for an Enlargement of Time to File Its Reply
ML20071D839
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/11/2020
From: Lois James, Tallent J
State of NY, Office of the Attorney General
To:
NRC/OCM
SECY RAS
References
50-003, 50-247, 50-286-LT-3, 72-51-LT-2, License Transfer, RAS 55600
Download: ML20071D839 (4)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.;

ENTERGY NUCLEAR INDIAN POINT 2, LLC; ENTERGY NUCLEAR INDIAN POINT 3, LLC; HOLTEC INTERNATIONAL; and HOLTEC Docket Nos.:

DECOMMISSIONING INTERNATIONAL, 50-3 LLC; APPLICATION FOR ORDER 50-247 CONSENTING TO TRANSFERS OF 50-286 CONTROL OF LICENSES AND 72-051 APPROVING CONFORMING LICENSE AMENDMENTS (Indian Point Nuclear Generating Station)

UNOPPOSED MOTION OF THE STATE OF NEW YORK FOR AN ENLARGEMENT OF TIME TO FILE ITS REPLY Pursuant to 10 C.F.R. § 2.307, petitioner State of New York moves the Com-mission for a brief enlargement of time to reply to the answer filed in the above-cap-tioned proceeding, from March 16, 2020 to and including March 23, 2020. Entergy Nuclear Operations, Inc.; Entergy Nuclear Indian Point 2, LLC; Entergy Nuclear In-dian Point 3, LLC; Holtec International; and Holtec Decommissioning International, LLC (collectively, the Applicants) do not oppose the States request. In support of this motion, the State offers the following:

1. This matter concerns an application to the Nuclear Regulatory Commis-sion by the Applicants for permission to transfer the licenses for the Indian Point

Nuclear Generating Station (Indian Point) and the Indian Point independent spent fuel storage installation. On February 12, 2020, the State submitted a petition to intervene in the license transfer proceedings under 10 C.F.R. § 2.309 and requested a hearing. On March 9, 2020, the Applicants filed a 106-page answer responding to the States petition. The States reply is currently due to be filed on March 16, 2020.

2. The prompt, safe, and successful decommissioning of Indian Pointand, thus, the proposed transfer of the Indian Point licensesis a matter of great concern to the State, its agencies, and its residents. While the State has devoted and will continue to devote significant resources to the prosecution of its petition to intervene in this proceeding, undersigned counsels other professional obligationsincluding a pending state-court appellate matter for which briefing coincides with briefing in the instant license transfer proceedinglimit the time available to research and respond to the issues raised in the Applicants extensive answer.
3. Further, undersigned counsels briefing in this matter is subject to re-view by senior staff in the Office of the Attorney General, as well as by the Office of the Governor and senior staff in two executive branch agencies. Additional time is therefore necessary to ensure adequate time for internal review and comment.
4. As required under 10 C.F.R. § 2.323(b), the State consulted with counsel for the Applicants Paul Bessette on March 11, 2020. Mr. Bessette courteously indi-cated that the Applicants do not oppose the States request for an enlargement of time to file its reply.

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For the foregoing reasons, and upon good cause shown, the State requests that the Commission grant this motion for an enlargement of time and modify the deadline by which the State must file its reply in this proceeding from March 16, 2020 to and including March 23, 2020.

March 11, 2020 Albany, New York Respectfully submitted, LETITIA JAMES Attorney General State of New York Signed (electronically) by Joshua M. Tallent Assistant Attorney General Environmental Protection Bureau The Capitol Albany, NY 12224 (518) 776-2456 Joshua.Tallent@ag.ny.gov 3

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.;

ENTERGY NUCLEAR INDIAN POINT 2, LLC; ENTERGY NUCLEAR INDIAN POINT 3, LLC; HOLTEC INTERNATIONAL; and HOLTEC Docket Nos.:

DECOMMISSIONING INTERNATIONAL, 50-3 LLC; APPLICATION FOR ORDER 50-247 CONSENTING TO TRANSFERS OF 50-286 CONTROL OF LICENSES AND 72-051 APPROVING CONFORMING LICENSE AMENDMENTS (Indian Point Nuclear Generating Station)

CERTIFICATION OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that I served the States Motion for an Enlargement of Time to File Reply in the above-captioned proceeding via the NRCs Electronic Information Exchange on this 11th day of March, 2020.

Signed (electronically) by Joshua M. Tallent Assistant Attorney General Environmental Protection Bureau The Capitol Albany, NY 12224 (518) 776-2456 Joshua.Tallent@ag.ny.gov 4