ML20155J116

NRC Staff Motion for Extension of Page Limit for Response to Ohngo Gaudadeh Devia Contentions Re Low Rail Transportation License Amend.* Staff States Listed Info in Support of Request.With Certificate of Svc

ML20155J116
Person / Time
Site:	07200022
Issue date:	11/09/1998
From:	Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#498-19702 ISFSI, NUDOCS 9811120033
Download: ML20155J116 (4)

Text

_

4

' l 00CKrIED November 90$C l

UNITED STATES OF AMERICA

-9 P4 :20 NUCLEAR REGULATORY COMMISSION GQ'

/

BEFORE THE ATOMIC SAFETY AND LICENSING BOARDOjy,

'In the Matter of

)

)

4 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 OHNGO GAUDADEH DEVIA'S CONTENTIONS

~ RELATING TO THE LOW RAIL TRANSPORTATION 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 four-page extension of the 10-page limit for filing its response to "Ohngo Gaudadeh Devia's (OGD) Contentions Relating to the Low Rail Transportation License i

Amendment" ("OGD Rail Contentions"), filed November 2,1998. In support of this request, the Staff states as follows:

l I.

In their Rail Contentions, OGD set forth ten contentions challenging the Applicant's revisions to its license application concerning the construction and operation of a new rail spur.

In accordance with the Licensing Board's Order of November 2,1998, the Staff's response to those contentions is due to be filed on or before November 12,1998.

2.

In order to prepare a thorough response to OGD's Rail Contentions, the Staff has determined that approximately 14 pages, or four additional pages beyond the limit established by 9811120033 981109 fA DR

e.

4 t

2-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 OGD's Rail Contentions and the number of subissues raised therein.

3.

Counsel for the Staff has contacted Counsel for OGD 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 OGD's Rail Contentions and do not appear to be affected by this request.

Respectfully submitted, WL Sherwin E. Turk Counsel for NRC Staff Dated at Rockville, Maryland this 9th day of November 1998 1

l

('

4 e

i UNITED STATES OF AMERICA 00CXETED NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

% NGV -9 P4 :34 In the Matter of

)

OR

)

t U.

PRIVATE FUEL STORAGE L.L.C.

),

Docket No. 72-22-IbJ' -

)

(Independent Spent

)

Fuel Storage Installation)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S MOTION FOR EXTENSION OF THE PAGE LIMIT FOR ITS RESPONSE TO OHNGO GAUDADEH DEVIA'S CONTENTIONS RELATING TO THE LOW RAIL TRANSPORTATION LICENSE 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 the United States mail, first class, as indicated by an asterisk, with copies by electronic mail as indicated, this 9th day of November,1998:

G. Paul Bollwerk, III, Chairman Atomic Safety and Licensing Board Panel Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Secretary (E-mail copy to GPB@NRC. GOV)-

ATrN: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission

. Dr. Jerry R. Kline Washington, DC 20555 Administrative Judge (E-mail copy to:

Atomic Safety atxi Licensing Board HEARINGDOCKET@NRC. GOV)

U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Commission Appellate (E-mail copy to JRK2@NRC. GOV)

Adjudication.

Mail Stop: 16-G-15 OWFN Dr. Peter S. Lam U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission James M. Cutchin, V

- Washington, DC 20555 Atomic Safety and Licensing Board (E-mail copy to PSL@NRC. GOV)

U.S. Nuclear Regulatory Commission Washington, DC 20555 (by E-mail to JMC3@NRC. GOV)

a I.

Danny Quintana, Esq.*

John Paul Kennedy, Sr., Esq.*

Danny Quintana & Associates, P.C.

1385 Yale Ave.

50 West Broadway, Fourth Floor Salt Lake City, UT 84105 Salt Lake City, UT 84101 (E-mail copy to john @kennedys.org)

(E-mail copy to quintana @Xmission.com)

Joro Walker, Esq.*

Land and Water Fund of the Rockies Jay E. Silberg, Esq.*

165 South Main St., Suite 1 Ernest Blake, Esq.*

Salt Lake City, UT 84111 1

Paul A. Gaukler, Esq.*

(E-mail copy to joro61@inconnect.com)

SHAW, PITTMAN, POTTS &

TROWBRIDGE Richard E. Condit, Esq.

2300 N Street, N.W.

Land and Water Fund of the Rockies J

Washington, DC 20037-8007 2260 Baseline Road, Suite 200 (E-mail copies to jay _silberg, Boulder, CO 80302 paul _gaukler, and ernest _blake (E-mail copy to rcondit@lawfund.org)

@shawpittman.com)

Clayton J. Parr, Esq.*

Denise Chancellor, Esq.*

PARR, WADDOUPS, BROWN, GEE Fred G. Nelson, Esq.

& LOVELESS Utah Attorney General's Office-185 S. State St., Suite 1300 160 East 300 South,5th Floor P.O. Box 11019 P.O. Box 140873 Salt Lake City, UT 84147-0019 Salt Lake City, UT 84114-0873 (E-mail copy to karenj@pwlaw.com)

(E-mail copy to dchancel@ State.UT.US)

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 enakahar@ 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 i

DCurran.HCSE@zzapp.org) h g

Sherwin E. Turk Counsel for NRC Staff