ML11334A039: Difference between revisions
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| issue date = 11/30/2011 | | issue date = 11/30/2011 | ||
| title = Natural Resources Defense Council Unopposed Motion for Extension of Time | | title = Natural Resources Defense Council Unopposed Motion for Extension of Time | ||
| author name = Fettus G | | author name = Fettus G, Roisman A | ||
| author affiliation = National Legal Scholars Law Firm, PC, Natural Resources Defense Council (NRDC) | | author affiliation = National Legal Scholars Law Firm, PC, Natural Resources Defense Council (NRDC) | ||
| addressee name = | | addressee name = | ||
| Line 13: | Line 13: | ||
| document type = Legal-Motion | | document type = Legal-Motion | ||
| page count = 3 | | page count = 3 | ||
| project = | |||
| stage = Other | |||
}} | }} | ||
=Text= | |||
{{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) | |||
) | |||
EXELON GENERATION COMPANY, LLC ) Docket No. 50-352-LR | |||
) Docket No. 50-353-LR (Limerick Generating Station, Units 1 and 2) ) | |||
) November 30, 2011 (License Renewal Application) ) | |||
NATURAL RESOURCES DEFENSE COUNCIL UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to the current briefing schedule (October 17, 2011 Order) and 10 C.F.R. § 2.309(h)(2) responses to the Natural Resources Defense Council Petition to Intervene and Notice of Intention to Participate (November 22, 2011) are due December 22, 2011 and the reply by NRDC is due on December 29, 2011. Due to the intervening holiday and pre-existing vacation plans by several NRDC Staff scientists and attorneys, it will be extremely difficult for NRDC to prepare and file an appropriate reply by the current due date. Thus, we request an extension of time for the filing of NRDCs reply to, and including, January 6, 2012. | |||
Undersigned counsel has consulted with counsel for Exelon and NRC Staff who have advised that they do not oppose this request. | |||
Therefore, NRDC requests that it be granted an extension of time to file its reply to responses to its Petition to Intervene from December 29, 2011 to, and including, January 6, 2012. | |||
1 | |||
Respectfully Submitted, s/ (electronically signed) s/(electronically signed) | |||
Anthony Z. Roisman Geoffrey H. Fettus National Legal Scholars Law Firm, P.C. Natural Resources Defense Council 241 Poverty Lane, Unit 1 1152 15th Street, NW, Suite 300 Lebanon, NH 03766 Washington, D.C. 20005 603-443-4162 202-289-2371 aroisman@nationallegalscholars.com gfettus@nrdc.org 2 | |||
CERTIFICATE OF SERVICE I hereby certify that copies of the Natural Resources Defense Council Unopposed Motion for Extension of Time in the captioned proceeding was served via the Electronic Information Exchange (EIE) on the 30th day of November 2011, which to the best of my knowledge resulted in transmittal of the same to those on the EIE Service List for the captioned proceeding. | |||
Chief Judge Roy Hawkens Office of the General Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop: T-3F23 Mail Stop O-15D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 ogcmailcenter@nrc.gov Roy.Hawkens@nrc.gov Catherine Kanatas catherine.kanatas@nrc.gov U.S. Nuclear Regulatory Commission Brian Newell Office of the Secretary of the Commission brian.newell@nrc.gov Mail Stop: O-16C1 Maxwell Smith Washington, DC 20555-0001 maxwell.smith@nrc.gov hearingdocket@nrc.gov Mary Spencer mary.spencer@nrc.gov U.S. Nuclear Regulatory Commission Ed Williamson Office of Commission Appellate Adjudication edward.williamson@nrc.go Mail Stop: O-16C1 Washington, DC 20555-0001 ocaamail@nrc.gov Exelon Generation Company, LLC 4300 Warrenville Road Warrenville, IL 60555 J. Bradley Fewell, Deputy General Counsel Bradley.Fewell@exeloncorp.com Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W. | |||
Washington, DC 20004 Alex S. Polonsky, Esq. | |||
apolonsky@morganlewis.com Kathryn M. Sutton, Esq. | |||
ksutton@morganlewis.com Brooke E. Leach bleach@morganlewis.com s/(electronically signed) | |||
Anthony Z. Roisman 3}} | |||
Latest revision as of 12:18, 12 November 2019
| ML11334A039 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/30/2011 |
| From: | Fettus G, Roisman A National Legal Scholars Law Firm, PC, Natural Resources Defense Council |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| License Renewal, RAS 21474, 50-352-LR, 50-353-LR | |
| Download: ML11334A039 (3) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
)
EXELON GENERATION COMPANY, LLC ) Docket No. 50-352-LR
) Docket No. 50-353-LR (Limerick Generating Station, Units 1 and 2) )
) November 30, 2011 (License Renewal Application) )
NATURAL RESOURCES DEFENSE COUNCIL UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to the current briefing schedule (October 17, 2011 Order) and 10 C.F.R. § 2.309(h)(2) responses to the Natural Resources Defense Council Petition to Intervene and Notice of Intention to Participate (November 22, 2011) are due December 22, 2011 and the reply by NRDC is due on December 29, 2011. Due to the intervening holiday and pre-existing vacation plans by several NRDC Staff scientists and attorneys, it will be extremely difficult for NRDC to prepare and file an appropriate reply by the current due date. Thus, we request an extension of time for the filing of NRDCs reply to, and including, January 6, 2012.
Undersigned counsel has consulted with counsel for Exelon and NRC Staff who have advised that they do not oppose this request.
Therefore, NRDC requests that it be granted an extension of time to file its reply to responses to its Petition to Intervene from December 29, 2011 to, and including, January 6, 2012.
1
Respectfully Submitted, s/ (electronically signed) s/(electronically signed)
Anthony Z. Roisman Geoffrey H. Fettus National Legal Scholars Law Firm, P.C. Natural Resources Defense Council 241 Poverty Lane, Unit 1 1152 15th Street, NW, Suite 300 Lebanon, NH 03766 Washington, D.C. 20005 603-443-4162 202-289-2371 aroisman@nationallegalscholars.com gfettus@nrdc.org 2
CERTIFICATE OF SERVICE I hereby certify that copies of the Natural Resources Defense Council Unopposed Motion for Extension of Time in the captioned proceeding was served via the Electronic Information Exchange (EIE) on the 30th day of November 2011, which to the best of my knowledge resulted in transmittal of the same to those on the EIE Service List for the captioned proceeding.
Chief Judge Roy Hawkens Office of the General Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop: T-3F23 Mail Stop O-15D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 ogcmailcenter@nrc.gov Roy.Hawkens@nrc.gov Catherine Kanatas catherine.kanatas@nrc.gov U.S. Nuclear Regulatory Commission Brian Newell Office of the Secretary of the Commission brian.newell@nrc.gov Mail Stop: O-16C1 Maxwell Smith Washington, DC 20555-0001 maxwell.smith@nrc.gov hearingdocket@nrc.gov Mary Spencer mary.spencer@nrc.gov U.S. Nuclear Regulatory Commission Ed Williamson Office of Commission Appellate Adjudication edward.williamson@nrc.go Mail Stop: O-16C1 Washington, DC 20555-0001 ocaamail@nrc.gov Exelon Generation Company, LLC 4300 Warrenville Road Warrenville, IL 60555 J. Bradley Fewell, Deputy General Counsel Bradley.Fewell@exeloncorp.com Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.
Washington, DC 20004 Alex S. Polonsky, Esq.
apolonsky@morganlewis.com Kathryn M. Sutton, Esq.
ksutton@morganlewis.com Brooke E. Leach bleach@morganlewis.com s/(electronically signed)
Anthony Z. Roisman 3