ML20154P641

NRC Staff Motion for Extension of Page Limit for Response to Contentions of Confederated Tribes of Goshute Reservation Re Low Rail License Amend.* Staff Response to Contentions Due to Be Filed on 981026.With Certificate of Svc

ML20154P641
Person / Time
Site:	07200022
Issue date:	10/21/1998
From:	Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#498-19660 ISFSI, NUDOCS 9810230033
Download: ML20154P641 (4)

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, lW U t r 21,1998 UNITED STATES OF AMERICA 38 OCT 22 Pl2:16 NUCLEAR REGULATORY COMMISSION OFD '

BEFORE THE ATOMIC SAFETY AND LICENSINU BOARD

. ' .r r. .

In the Matter of )

)

PRIVATE FUEL STORAGE, LLC ) Docket No. 72-22-ISFSI

)

(Independent Spent )

Fuel Storage Installation) )

NRC STAFF'S MOTION FOR EXTENSION OF THE PAGE LIMIT FOR ITS RESPONSE TO THE CONTENTIONS OF THE CONFEDERATED TRIBES OF THE GOSHUTE RESERVATION RFI.ATING TO THE LOW RAIL LICENSE AMENDMENT Pursuant to the Atomic Safety and Licensing Board's " Memorandum and Order (Memorializing Initial Prehearing Conference Directives)," dated February 2,1998, the NRC Staff (" Staff") hereby requests a three-page extension of the 10-page limit for filing its response to the " Contentions of the Confederated Tribes of the Goshute Reservation Relating to the Low Rail License Amendment" (" Low Rail Contentions"), filed October 14,1998. In support of this request, the Staff states as follows:

1. In their Low Rail Contentions, the Confederated Tribes set forth six contentions challenging the Applicant's revisions ta its license application concerning the construction and operation of a new rail spur and a new location for the Rowley Junction Intermodal Transfer Point (ITP). The Staff's response to those contentions is due to be filed on October 26,1998.

2. In order to prepare a thorough response to the Confederated Tribes' Low Rail Contentions, the Staff has determined that a total of 13 pages, or three additional pages beyond 9810230033 981021 PDR ADOCK 07200022 C PDR 2

. the limit established by the Licensing Board, will likely be required for its response. The Staff believes that the instant request is reasonable, in view of the breadth of the Confederated Tribes' Low Fail Contentions and the number of subissues raised therein.

3. Counsel for the Staff has contacted Counsel for the Confederated Tribes and Counsel for the Applicant, neither of whom objects to the instant request for a page extension.

Counsel for the Staff has not contacted other parties, inasmuch as those parties did not join in the Confederated Tribes' contentions and do not appear to be affected by this request.

Respectfully submitted, s

t.,)

Sherwin E. Turk Counsel for NRC Staff Dated at Rockville, Maryland this 21st day of October 1998 E

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!s UNITED STATES OF AMERICA p

, NUCLEAR REGULATORY COMMISSION 1

i BEFORE THE ATOMIC SAFETY AND LICENSING BOAMD OCT 22 Pl2 :16 In the Matter of ) OFK .a

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PRIVATE FUEL STORAGE L.L.C. Docket No. blSFs! ' WA F

)

i. )

(Independent Spent )

Fuel Storage Installation) )

CERTIFICATE OF SERVICE l I hereby certify that copies of "NRC STAFF'S MOTION FOR EXTENSION OF THE PAGE LIMIT FOR ITS RESPONSE TO THE CONTENTIONS OF THE CONFEDERATED TRIBES OF THE GOSHUTE RESERVATION RELATING TO THE LOW RAIL LICENSE F' AMENDMENT" in the above captioned proceeding have been served on the following

! through deposit in the Nuclear Regulatory Commission's internal mail system, or by deposit in i

the United States mail, first class, as indicated by an asterisk, with copies by electronic mail as indicated, this 21st day of October,1998:

G. Paul Bo::werk, III, Chairman Atomic Safety and Licensing Board Panel )

! Adininistrative Judge U.S. Nuclear Regulatory Corrission .I

. Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission j Washington, DC 20555 Office of the Secretary (E-mail copy to GPB@NRC. GOV) ATTN: Rulemakings end Adjudications Staff

U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline Washington, DC 20555 Administrative Judge (E-mail copy to:

Atomic Safety and Licensing Board HEARINGDOCKET@NRC. GOV) 1 U.S. lyuclear Regulatory Commission 3

Washirigton, DC 20555 . Office of the Commission Appellate (E-mail copy to JRK2@NRC. GOV) Adjudication Mail Stop: 16-G-15 OWFN j ie Peter S. Lam . U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555 l Atomic Safety and Licensing Board  !

U.S. Nuclear Regulatory Commission James M. Cutchin, V l Washington, DC 20555 Atomic Safety and Licensing Board (E-mail copy to PSL@NRC. GOV) U.S. Nuclear Regulatory Commission Washington, DC 20555 i (by E-mail to JMC3@NRC. GOV)

d John Paul Kennedy, Sr., Esq.*

Danny Quintana, Esq.* 1385 Yale Ave.

Danny Quintana & Associates, P.C. Salt Lake City, UT 84105 50 West Broadway, Fourth Floor (E-mail copy to john @kennedys.org)

Salt Lake City, UT 84101 (E-mail copy to Joro Walker, Esq.*

quintana @Xmission.com) Land and Water Fund of the Rockies 165 South Main St., Suite 1 Jay E. Silberg, Esq.* Sa' e City, UT 84111 Ernest Blake, Esq.* (E-n..at copy tojoro61@inconnect.com)

Paul A. Gaukler, Esq.*

SHAW, PITTMAN, POTTS & Richard E. Condit, Esq.

TROWBRIDGE Land and Water Fund of the Rockies 2300 N Street, N.W. 2260 Base.line Road, Suite 200 Washington, DC 20037-8007 .,

Boulder, CO 80302 .

(E-mail copies to jay silberg, . (E-mail copy to rcondit@lawfund.org) paul _gaukler, and ernest _blake "

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@shawpittman.com) Clayton J. Parr, Esq.* 'c w

'PARR, WADDOUPS, BROWN, GEE Denise Chancellor, Esq.* & LOVELESS Fred G. Nelson, Esq. 185 S. State St., Suite 1300 Utah Attorney General's Office P.O. Box 11019 160 East 300 South,5th Floor Salt 12ke City, UT 84147-0019 P.O. Box 140873 (E-mail copy to karenj@pwlaw.com)

Salt Lake City, UT 84114-0873 (E-mail copy to dchancel@ State.UT.US) i Connie Nakahara, Esq.*

Utah Dep't of Environmental Quality 168 North 1950 West P. O. Box 144810 Salt Lake City, UT 84114-4810 (E-mail copy to cnakahar@ state.UT.US) ,

Diane Curran, Esq.*

Harmon, Curran, Spielberg & Eisenberg 2001 S Street, N.W., Suite 430 Washington, D.C. 20009 #

(E-mail copy to y b/

DCurran.HCSE@zzapp.org)

Sherwin E. Turk Counsel for NRC Staff

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