ML24365A266
| ML24365A266 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/30/2024 |
| From: | Blind A - No Known Affiliation, Holtec Decommissioning International, Holtec Palisades |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57247, 50-255-LA-3, ASLBP 24-986-01-LA-BD01 | |
| Download: ML24365A266 (0) | |
Text
Submitted: 12/30/2024 50-255-LA-3 of 1
5 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, AND HOLTEC PALISADES, LLC Docket No. 50-255-LA-3 JOINT PETITIONERS MOTION FOR EXTENSION OF TIME (Request to Extend Ten-Day Filing Deadline for Newly Provided Information)
I. INTRODUCTION Pursuant to 10 C.F.R. § 2.323(a)(2) and the Boards Initial Prehearing Order, the Joint Petitioners respectfully request an extension of time to file a motion concerning newly provided information pertinent to this proceeding. Two sets of information became available through NRCs ADAMS system on December 23 and December 30, respectively. Because the second set clarifies or supplements
Submitted: 12/30/2024 50-255-LA-3 of 2
5 the first, and the holiday period from late December into early January and considering adequate time for the parties to consult during the holidays, the Joint Petitioners submit that December 30 should serve as the operative date for any applicable filing deadline, and further seek a brief extension to ensure meaningful compliance with 10 C.F.R. § 2.323(b).
II. BACKGROUND 1.
Proceeding Context
This proceeding involves Holtec Palisades, LLC, and Holtec Decommissioning International, LLC, who have sought certain license amendment requests under Docket No. 50-255-LA-3.
On or about December 23, the Joint Petitioners became aware of certain new information related to these requests, made publicly available via the NRCs ADAMS system.
On or about December 30, a second document, related to the first and, also pertinent to the pending license amendment proceeding, was posted on ADAMS.
2.
Holiday Period Constraints
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5
The time between December 23 and January 3 encompasses multiple holidays and reduced business operations, limiting the practical ability to consult with counsel for Holtec and the NRC Staff.
The Joint Petitioners and the other participants, made good-faith efforts to engage in consultations promptly; however, consideration was given for holiday non-business day considerations for all.
III. LEGAL BASIS FOR EXTENSION Under 10 C.F.R. § 2.323(a)(2), the Board may extend filing deadlines upon a showing of appropriate cause. The Boards Initial Prehearing Order normally requires a motion to be filed within ten days of new circumstances giving rise to that motion. However, the Joint Petitioners respectfully assert that:
1.
Two Interrelated Releases: The December 23 and December 30 releases are closely tied, with the second clarifying or supplementing the first.
2.
Holiday Scheduling Constraints: The overlapping holiday period significantly curtailed the opportunity for consultation and preparation, which 10 C.F.R. § 2.323(b) requires.
Submitted: 12/30/2024 50-255-LA-3 of 4
5 3.
No Undue Prejudice: A modest extension will not delay the proceeding and proposed no new arguments or contentions, but rather ensures a complete and accurate motion addressing both pieces of newly provided information.
IV. REQUEST FOR RELIEF Accordingly, the Joint Petitioners respectfully request that the Board:
1.
Acknowledge December 30 as the operative trigger date for applying the ten-day requirement referenced in the Initial Prehearing Order.
2.
Grant a short extension of that deadlinee.g., an additional five business daysto accommodate the holiday closures and achieve meaningful consultation under 10 C.F.R. § 2.323(b).
3.
Provide any additional relief the Board deems necessary or appropriate to ensure a fair and efficient process.
V. CERTIFICATION OF CONSULTATION There was no direct consultation on this motion, however, we have exchanged emails to bring the ten day deadline to the attention of all, and asking for assistance in moving up the consultations.
Submitted: 12/30/2024 50-255-LA-3 of 5
5 CONCLUSION For the foregoing reasons, the Joint Petitioners respectfully move the Board to extend the ten-day filing deadline to begin on December 30or to grant such other relief as the Board finds just and reasonableso that the Joint Petitioners can prepare a consolidated motion addressing the newly provided information in a manner consistent with NRC regulations and the Boards Orders.
Respectfully submitted, Signe by NRC Electronic Submission Alan Blind Representative for Joint Petitioners