ML20196K520

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Joint Motion for Extension of Time to Respond to Summary Disposition Motions on Contentions F & P.* Staff Has No Objection to Motion as Long as Time for Response Similarly Extended,As Requested.With Certificate of Svc
ML20196K520
Person / Time
Site: 07200022
Issue date: 07/01/1999
From: Gaukler P
AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
References
CON-#399-20622 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9907090047
Download: ML20196K520 (4)


Text

fr ti DOCKETED USNRP July 1,1999

'99 Jul. -6 P 4 :22 UNITED STATES OF AMERICA OF s Ab NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

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PRIVATE FUEL STORAGE L.L.C.

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Docket No. 72-22

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(Private Fuel Storage Facility)

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ASLBP No. 97-732-02-ISFSI JOINT MOTION FOR AN EXTENSION OF TIME TO RESPOND TO

SUMMARY

DISPOSITION MOTIONS ON CONTENTIONS F & P i

Private Fuel Stotage L.L.C. (" Applicant" or "PFS") and the State of Utah hereby request that the time for the State and the NRC Staff to file their responses to the j

Applicant's Motion for Summary Disposition of Contentions F & P -- Training and Certification (dated June 11,1999) be extended from July 6,1999 to July 13,1999. The extension is needed because the State and the Applicant have entered into settlement negotiations and have agreed in principle on the terms of a settlement. However, the parties need additional time to prepare and review the documentation associated with the settlement. It will not be possible to do so by the close of business tomorrow and the following week counsel for the State will be out of the office on vacation. Therefore, the Applicant and the State request that the time for both the State and the NRC Staff to file their responses to the summary disposition motion for Utah F & P be extended to July 13, I

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9907090047 990701 PDR ADOCK 07200022 C

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-4 1999. - The Staff has no objection to this motion as long as the time for its response is l

l sin,ilarly extended, as has been requested.

The Applicant and the State are aware that the Board has instructed that extension l

r.oti ins should be filed at least three days prior to deadlines, but they were unable to do so in this case. The Applicant and the State submit that an extension is appropriate nevertheless, because (1) it amounts to only five business days; (2) the Applicant, Staff, and the State all agree to the extension; and (3) the extersion is likely to result in the resolution of the contention.

Respectfully submitted, M

Jay E. Silberg Emest L. Blake, Jr.

Paul A.Gaukler SHAW PITfMAN 2300 N Street, N.W.

Washington,DC 20037 (202) 663-8000 Dated: July 1,1999 Counsel for Private Fuel Storage L.L.C.

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00CKETED USHRC i

UNITED STATES OF AMERICA

.o9 JUL -6 P4 :22 NUCLEAR REGULATORY COMMISSION OR Before the Atomic Safety and Licensing Board g '.

j In the Matter of

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PRIVATE FUEL STORAGE L.L.C.

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Docket No. 72-22

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(Private Fuel Storage Facility)

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CERTIFICATE OF SERVICE I hereby certify that copies of the " Joint Motion for an Extension of Time to Respond to Summary Disposition Motions on Contentions F & P," dated July 1,1999 were served on the persons listed below (unless otherwise noted) by e-mail with conforming copies by U.S. Mail, first class, postage prepaid, this 1st day of July,1999.

j G. Paul Bollwerk III, Esq., Chairman Dr. Jerry R. Kline Administrative Judge Administrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 e-mail: GPB@nrc. gov e-mail: JRK2@nrc. gov and kjerry@erols.com Dr. Peter S. Lam

  • Susan F. Shankman Administrative Judge Deputy Director, Licensing & Inspection Atomic Safety and Licensing Board Panel Directorate, Spent Fuel Project Office U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety &

Washington, D.C. 20555-0001 Safeguards e-mail: PSL@nrc. gov U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

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1 Oflice of the Secreta.y

  • Adjudicatory File U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission
Attention: Rulemakings and Adjudications Washington, D.C. 20555-0001 Staff e-mail: hearingdocket@nrc. gov (Original and two copies)

Catherine L. Marco, Esq.

Denise Chancellor, Esq.

Sherwin E. Turk, Esq.

Assistant Attorney General Office of the General Counsel Utah Attorney General's Office Mail Stop O-15 B18 160 East 300 South,5th Floor U.S. Nuclear Regulatory Commission P.O. Box 140873 Washington, D.C. 20555 Salt Lake City, Utah 84114-08;?,

e-mail: pfscase@nrc. gov

e. mail: dchancel@ state.UT.US John Paul Kennedy, Sr., Esq.

Joro Walker, Esq.

Confederated Tribes of the Goshute Land and Water Fund of the Rockies Reservation and David Pete 2056 East 3300 South, Suite 1 1385 Yale Avenue Salt Lake City, UT 84109 Salt Lake City, Utah 84105 e-mail: ioro61@inconnect.com e-mail: jolm@kennedys.org Diane Curran, Esq.

Danny Quintana, Esq.

Harmon, Curran, Spielberg &

Skull Valley Band of Goshute Indians Eisenberg, L.L.P.

Danny Quintana & Associates, P.C.

1726 M Street, N.W., Suite 600 50 West Broadway, Fourth Floor Washington, D.C. 20036 Salt Lake City, Utah 84101

,.e-mail: deurran@harmoncurran.com e-mail: quintana @xmission.com

  • By Hand Delivery only

'd.40 Paul A.Gaukler Document #: 782%8 v.1 2

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