ML20272A275

Attachment 1 to Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply and Motion for Leave to File INT053 (Curran E-mail)

ML20272A275
Person / Time
Site:	Seabrook
Issue date:	09/28/2020
From:	Curran D C-10 Research & Education Foundation, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP
To:	Bessette P, Amitava Ghosh Morgan, Morgan, Lewis & Bockius, LLP, NRC/OGC
SECY RAS
References
50-443-LA-2, ASLBP 17-953-02-LA-BD01, RAS 55803
Download: ML20272A275 (1)

Text

ATTACHMENT 1 To NextEras Answer Opposing C-10s Motion for Leave to File a Reply and Motion for Leave to File INT053 (Sept. 28, 2020)

From: Diane Curran <dcurran@harmoncurran.com>

Sent: Wednesday, September 16, 2020 3:36 PM To: Bessette, Paul M. <paul.bessette@morganlewis.com>; Ghosh Naber, Anita

<anita.ghoshnaber@nrc.gov>; Jeremy.Wachutka@nrc.gov; Campbell, Tison <Tison.Campbell@nrc.gov>;

Lighty, Ryan K. <ryan.lighty@morganlewis.com>; Steven Hamrick (STEVEN.HAMRICK@fpl.com)

<STEVEN.HAMRICK@fpl.com>

Cc: Natalie Hildt Treat <natalie@c10.org>

Subject:

Consultation pursuant to 10 CFR 2.323

Dear Counsel for NextEra and the NRC Staff,

Please let me know at your earliest convenience whether you would agree to the filing by C10 Research and Education Foundation of a reply to your oppositions to C10s Motion for Reconsideration and to ReOpen the Record (supported by the Declaration of Dr. Victor E. Saouma), C10s Motion for Leave to file the Motion for Reconsideration, and the Supplemental Testimony of Dr. Victor E. Saouma. Our primary purpose in replying to your oppositions will be to reply to technical arguments by the NRC Staffs hearing witnesses in response to Dr. Saoumas proposed changes to the new license conditions proposed by the Board. We also plan to respond to your arguments that we have failed to meet the standard for reconsideration or reopening the record, which mischaracterize Dr. Saoumas testimony and the appropriate standards. Finally, we plan to respond to NextEras unsupported criticisms of Dr.

Saoumas expertise to make his supplemental testimony. We could not have anticipated these arguments because they are inconsistent with the record and the law. We also think it is important for the ASLB to have a full record of the law and the issues in order to make a meaningful determination on our motions.

Thanks, Diane Diane Curran Harmon Curran Spielberg & Eisenberg LLP 1725 DeSales Street NW, Suite 500 Washington, DC 20036 (240)393-9285