ML100470492: Difference between revisions
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
||
| Line 3: | Line 3: | ||
| issue date = 02/16/2010 | | issue date = 02/16/2010 | ||
| title = 2010/02/16-Petitioner's Motion for Additional Time in Which to (1) File a Notice of Appearance of Counsel and (2) Reply to TVA and NRC Staff Answers to Petition for Intervention | | title = 2010/02/16-Petitioner's Motion for Additional Time in Which to (1) File a Notice of Appearance of Counsel and (2) Reply to TVA and NRC Staff Answers to Petition for Intervention | ||
| author name = Dougherty J | | author name = Dougherty J | ||
| author affiliation = Bellefonte Efficiency & Sustainability Team (BEST), Blue Ridge Environmental Defense League, Southern Alliance for Clean Energy | | author affiliation = Bellefonte Efficiency & Sustainability Team (BEST), Blue Ridge Environmental Defense League, Southern Alliance for Clean Energy | ||
| addressee name = | | addressee name = | ||
Revision as of 13:34, 11 July 2019
| ML100470492 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 02/16/2010 |
| From: | Jay Dougherty Bellefonte Efficiency & Sustainability Team (BEST), Blue Ridge Environmental Defense League, Southern Alliance for Clean Energy |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML100470488 | List: |
| References | |
| 50-438-CP, 50-439-CP, ASLBP 10-896-01-CP-BD01, RAS 17218 | |
| Download: ML100470492 (4) | |
Text
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
___________________________________In the Matter of Tennessee Valley Authority Docket Nos. 50-438 and 50-439 Bellefonte Nuclear Power Plant Units 1 and 2
___________________________________PETITIONERS' MOTION FOR ADDITIONAL TIME IN WHICH TO (1) FILE A NOTICE OF APPEARANCE OF COUNSEL AND (2) REPLY TO TVA AND NRC STAFF ANSWERS TO PETITION FOR INTERVENTIONPetitioners hereby request leave of the Atomic Safety and Licensing Board
("Board") to file the attached PETITIONERS' REPLY TO TVA AND NRC STAFF ANSWERS TO PETITION FOR INTERVENTION and NOTICE OF APPEARANCE of undersigned attorney James B. Dougherty out of time. The reason that Petitioners were late in filing said documents is that they were diligently attempting to secure the services of counsel to represent them henceforth in this proceeding. As they are all non-profit organizations, even in good times it is difficult to secure sufficient funds to have legal representation in administrative proceedings. Due to the current downturn in the economy, however, Petitioners and most non-profits have faced unusually trying financial circumstances. Petitioners attempted to secure representation from pro bono counsel, but without success.
It was only last week that the undersigned attorney agreed to represent Petitioners in this proceeding. The undersigned represents that future Board-established deadlines will be met.
2Respectfully submitted, Signed (electronically) this 16 th day ofFebruary, 2009, in Washington, D.C.James B. Dougherty709 3rd St. S.W.
Washington, D.C. 20024
202-488-1140 (v)
202-484-1789 (f) jimdougherty@aol.com Counsel for Petitioners
Blue Ridge Defense League, et al.
3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
___________________________________In the Matter of Tennessee Valley Authority Docket Nos. 50-438 and 50-439 Bellefonte Nuclear Power Plant February 16, 2010 Units 1 and 2
___________________________________
CERTIFICATE OF SERVICEI hereby certify that copies of the foregoing Petitioners' Motion for Additional Timewereserved this day on the following persons via Electronic Information Exchange:
Office of the Secretary ATTN: Docketing and Service
Mail Stop 0-16C1 US Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: hearingdocket@nrc.gov
)Office of Commission Appellate Adjudication US Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: ocaamail@nrc.gov
)Patrick A. Moulding, Esq.
Ann P. Hodgdon, Esq.
US Nuclear Regulatory Commission
Mail Stop O-15 D21 Washington, DC 20555-0001 (E-mail: patrick.moulding@nrc.gov, ann.hodgdon@nrc.gov
)Louise Gorenflo Bellefonte Efficiency & Sustainability Team 185 Hood Drive
Crossville, TN 28555 (E-mail: lgorenflo@gmail.com
)Kathryn M. Sutton, Esq.
Lawrence J. Chandler, Esq.
1111 Pennsylvania Ave., NW Washington, DC 20004 (E-mail: ksutton@morganlewis.com, lchandler@morganlewis.com
)Martin J. O'Neill, Esq.
1000 Louisiana St., Suite 4000
Houston, TX 77002 E-mail:
martin.oneill@morganlewis.com Edward J. Vigluicci, Esq.
Scott A. Vance, Esq.
Tennessee Valley Authority 4400 West Summit Hill Dr., WT 6A-K Knoxville, TN 37902 (E-mail: ejvigluicci@tva.gov, savance@tva.gov
)Andrea Z. Jones, Esq.
Counsel for NRC Staff US Nuclear Regulatory Commission
Office of the General Counsel
Mail Stop: O-15 D21 Washington, DC 20555-0001Signed (electronically) this 16 th day ofFebruary, 2010 in Washington, D.C.James B. Dougherty, Esq.709 3rd St. S.W.
Washington, D.C. 20024
(202) 488-1140(v)
(E-mail: jimdougherty@aol.com)