ML24134A194
| ML24134A194 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/13/2024 |
| From: | Curran D Beyond Nuclear, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Sierra Club |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57019, 50-338-SLR-2, 50-339-SLR-2 | |
| Download: ML24134A194 (0) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Virginia Electric Power Co.
)
Docket Nos. 50-338/339 SLR-2 North Anna Power Station Units 1 & 2
)
May 13, 2024
____________________________________)
UNOPPOSED EMERGENCY MOTION BY BEYOND NUCLEAR AND THE SIERRA CLUB FOR EXTENSION OF TIME TO REPLY TO OPPOSITIONS TO THEIR HEARING REQUEST AND PETITION TO INTERVENE AND REQUEST FOR POSTPONEMENT OF ORAL ARGUMENT Pursuant to 10 C.F.R. §§ 2.307(a) and 2.323, Petitioners Beyond Nuclear, Inc. and the Sierra Club, Inc. hereby request the Atomic Safety and Licensing Board (ASLB) to grant a one-week extension of time to reply to oppositions to their Hearing Request and Petition to Intervene, which they submitted on March 28, 2024. Pursuant to 10 C.F.R. § 2.309(i)(2), that Reply is due today, May 13, 2024.1 In addition, Petitioners ask the ASLB to reschedule the initial prehearing conference now planned for May 20, 2024 until sometime during the first two weeks of June.
This motion is unopposed.
The sole grounds for this motion are that Petitioners undersigned counsel is recovering from emergency surgery in early May, has not been able to resume her full workload as quickly as she had foreseen, and today was advised by her surgeon to reduce her workload lest she 1 Petitioners recognize that this motion is not in compliance with the requirement of the ASLBs Initial Prehearing Order (amended) of April 15, 2024, because it is being submitted within less than three days of todays deadline. Petitioners respectfully ask for an emergency exception to that requirement because it did not become clear until this morning that compliance would not be possible for health-related reasons.
2 jeopardize her recovery.2 The requested extensions are needed and should be sufficient to allow counsel to better balance her caseload with the amount of rest required for a full recovery.
Counsel for Virginia Electric Power Co. (VEPCO) and the U.S. Nuclear Regulatory Commission Staff have stated that VEPCO and the Staff do not oppose this motion. They do request the ASLB to consult them regarding their availability on any future dates for the initial prehearing conference that the ASLB proposes.
Respectfully submitted,
__/signed electronically by/___
Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com May 13, 2024 2 Undersigned counsels surgeon is willing to provide a letter to this effect if requested.
3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Virginia Electric Power Co.
)
Docket Nos. 50-338/339 SLR-2 North Anna Power Station, Units 1 and 2
)
___________________________________ )
CERTIFICATE OF SERVICE I certify that on May 13, 2024, I posted UNOPPOSED EMERGENCY MOTION BY BEYOND NUCLEAR AND THE SIERRA CLUB FOR EXTENSION OF TIME TO REPLY TO OPPOSITIONS TO THEIR HEARING REQUEST AND PETITION TO INTERVENE AND REQUEST FOR POSTPONEMENT OF ORAL ARGUMENT on the NRCs Electronic Information Exchange.
___/signed electronically by/__
Paul Gunter