ML110591142

Friends of the Coast and New England Coalition, Inc., Request for Extension of Time - Addenda Certificate of Counsel

ML110591142
Person / Time
Site:	Seabrook
Issue date:	02/28/2011
From:	Shadis R Friends of the Coast, New England Coalition
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 19713, 50-443-LR, ASLBP 10-906-02-LR-BD01
Download: ML110591142 (4)

Text

1 February 26, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

In the Matter of

NextEra Energy Seabrook, LLC Seabrook Station (Operating License Renewal)

FRIENDS OF THE COAST AND NEW ENGLAND COALITION, INC.

REQUEST FOR EXTENSION OF TIME ADDENDA CERTIFICATE OF COUNSEL INTRODUCTION On February 26, 2011, Friends/NEC filed a request for Extension of Time in which to present its Motion for Reconsideration, due no later than February 25, 2011, but also filed on February 26, 2011.

In its Request for Extension of Time, Friends/NEC explained that it had not consulted with the parties as required by 10 C.F.R.§2.323 in as much as February 26 th was a Saturday, but that Friends/NEC would consult with the parties and file a §2.323 Certificate on the next business day, February 28, 2011.

Friends/NEC has now consulted with the parties and reports that the Request for Extension of Time is unopposed.

CERTIFICATE OF COUNSEL Pro Se Representative for Friends/NEC hereby certifies that in conformance with 10 C.F.R. §2.323, Friends/NEC made a sincere attempt to obtain the consent of the parties to the filing of ASLBP No. 10

-906-02-LR Docket No. 50

-443-LR February 28 , 2011 2 the Friends/NEC Request for Extension of time in which to file a Motion for Reconsideration of the Board's February 15, 2011 Order.

The parties have represented as follows: Beyond Nuclear "supports," NRC Staff "does not oppose," and NextEra "does not take a position

" on the retroactive motion for extension of time to file the reconsideration motion

. Respectfully submitted, Electronically signed

[Raymond Shadis

] ___________________

Raymond Shadis Pro se representative Friends of the Coast New England Coalition Post Office Box 98

Edgecomb, Maine 04556

207-882-7801 Shadis@prexar.com

3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

NEXTERA ENERGY SEABROOK, LLC (Seabrook Station, Unit 1)

(License Renewal)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Friends of the Coast and New England Coalition, Inc.

Request for Extension of Time Addenda - Certificate Of Counsel

, dated February 28, 2011, have been served upon the following persons by Electronic Information Exchange.

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop: T

-3F23 Washington, DC 20555

-0001 Administrative Judge

Paul S. Ryerson, Chair psr1@nrc.gov Administrative Judge Michael F. Kennedy michael.kennedy@nrc.g ov Administrative Judge Richard E. Wardwell richard.wardwell@nrc.gov Anthony C. Eitreim, Esq.

Chief Counsel ace1@nrc.gov Hillary Cain, Law Clerk hillary.cain@nrc.gov

U.S. Nuclear Regulatory Commission Office of the Secretary of the Commission Mail Stop: O-16C1 Washington, DC 20555

-0001 hearingdocket@nrc.gov U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop: O

-15D21 Washington, DC 20555

-0001 Emily Monteith, Esq.

emily.monteith@nrc.gov Brian Newell, Paralegal brian.newell@nrc.go v David Roth, Esq.

david.roth@nrc.gov Maxwell Smith, Esq.

maxwell.smith@nrc.gov Mary Spencer, Esq.

mary.spencer@nrc.gov Edward Williamson, Esq.

edward.williamson@nrc.gov Megan Wright, Esq.

megan.wright@nrc.gov OGC Mail Center OGCMailCenter@nrc.gov

U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Mail Stop: O

-16C1 Washington, DC 20555

-0001 ocaamail@nrc.gov ASLBP No. 10

-906-02-LR Docket No. 50

-443-LR February 28, 2011

4 Counsel for the Applicant NextEra Energy Seabrook, LLC 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 Steven C. Hamrick, Esq.

steven.hamrick@fpl.com Kim Bartels, Paralegal kim.bartels@fpl.com Beyond Nuclear 6930 Carroll Avenue, Suite 400 Takoma Park, MD 20912 Paul Gunter, Director Reactor Oversight Project paul@beyondnuclear.org

Kurt Ehrenberg, Field Organizer kurt.ehrenberg@sierraclub.org New Hampshire Sierra Club 40 N. Main Street Concord, NH 03870 Seacoast Anti

-Pollution League P.O. Box 1136 Portsmouth, NH 03802 Doug Bogen, Executive Director dbogen@metrocast.net Counsel for the Applicant NextEra Energy Seabrook, LLC 700 Universe Boulevard Juno Beach, FL 33408

William Blair, Esq.

william.blair@fpl.com Antonio Fernandez, Esq.

antonio.fernandez@fpl.com

Mitchell S. Ross, Esq.

mitch.ross@fpl.com

[Original signed by Raymond Shadis]

Friends of the Coast/New England Coalition Post Office Box 98 Edgecomb, ME 04556 Raymond Shadis, Pro Se Representative shadis@prexar.com Dated at Edgecomb, Maine this 28th day of February 2011