ML20196K522

Applicant Request to Exceed Page Limitation for Response to State of UT Request for Admission of late-filed Amended UT Contention C.Applicant Requests to Be Allowed to File Up to 20 Page Response to Contention C.With Certificate of Svc

ML20196K522
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-#299-20612, CON-#399-20612 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9907090048
Download: ML20196K522 (4)

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DOCKETED U3'RC July 1,1999 UNITED STATES OF AMERICA M JUL -6 P4 :22 NUCLEAR REGULATORY COMMISSION Oli e w

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 APPLICANT'S REQUEST TO EXCEED PAGE LIMITATION FOR ITS RESPONSE TO STATE OF UTAH'S REQUEST FOR ADMISSION OF LATE-FILED AMENDED UTAH CONTENTION C In accordance with the Atomic Safety and Licensing Board's (" Board") Memo-randum and Order of February 2,1998 (Memorializing Initial Prehearing Conference Di-rectives), the Applicant requests the Board's approval to exceed the ten page limitation with respect to Applicant's response to the " State of Utah's Request for Admission of Late-Filed Amended Utah Contention C," due to be filed Wednesday, July 7,1999. The Applicant will be responding to the State's request to late-file the amended contention as well as addressing whether the amended contention meets the Commission's require-ments for the admission of contentions wholly apart from the timing ofits filing. Al-though Applicant does not now know how long its response addressing these two matters will be, it requests that it be allowed to file a response of up to 20 pages, which is equal to the 20 pages, combined, that the State filed for its motion and the amended contention Applicant believes that this request is reasonable in that it will be addressing both the late filing of the amended contention and its admissibility apart from the late filing.

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'g Counsel for Applicant has contacted counsel for the State and the NRC Staff, neither of whom objects to this request for a page extension.

Accordingly, the Applicant requests the Board that it be allowed to file a response to the " State of Utah's Request for Admission of Late-Filed Amended Utah Contention C" of up to 20'pages.

Respectfully submitted, Tay E. Silberg Ernest L. Blake, Jr.

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

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DOCKElED

,1 U S F r' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

?) Jul. -6 P4 :22 Before the Atomic Safety and Licensing Board gg

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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 " Applicant's Request to Exceed Page Limitation For Its Response to State of Utah's request for Admission of Late-Filed Amended Utah Conten.

tion C," dated July 1,1999 were served on the persons listed below (unless otherwise noted) by 1

e-mail with conforming copies by U.S. Mail, first class, postage prepaid, this 1st day c f July,.,

1999.

G. Paul Bollwerk III, Esq., Chairman Ad-Dr. Jerry R. Kline

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ministrative 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 Oflice U.S. Nuclear Regulatory Conunission Office ofNuclear Material Safety &

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

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1-L Office of the Secretary

• Adjudicatory File U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D.C. 20555-0001.

U.S. Nuclear Regulatory Comuission Attention: Rulemakings and Adjudications Wash:ngton, 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 84114-0873 e-mail: pfscase@nrc. gov

e. mail: dchancel@ state.UT.US

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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 l

1385 Yale Avenue Salt Lake City, UT 84109 Salt Lake City, Utah 84105 e-mail: ioro61@inconnect.com e-mail: john @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 l

Washington, D.C. 20036 Salt Lake City, Utah 84101 e-mail: dcurran@harmoncurran.com e-mail: quintana @xmission.com

• By Hand Delivery only claluYh Paul A.Gaukfer Document #: 783009 v.I l

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