ML100470492
| 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
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 INTERVENTION Petitioners 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.
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Respectfully submitted, Signed (electronically) this 16th day of February, 2009, in Washington, D.C.
James B. Dougherty 709 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.
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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 SERVICE I hereby certify that copies of the foregoing Petitioners Motion for Additional Time were served this day on the following persons via Electronic Information Exchange:
Office of the Secretary Bellefonte Efficiency & Sustainability ATTN: Docketing and Service Team Mail Stop 0-16C1 185 Hood Drive US Nuclear Regulatory Commission Crossville, TN 28555 Washington, DC 20555-0001 (E-mail: lgorenflo@gmail.com)
(E-mail: hearingdocket@nrc.gov)
Kathryn M. Sutton, Esq.
Office of Commission Appellate Lawrence J. Chandler, Esq.
Adjudication Morgan, Lewis & Bockius LLP US Nuclear Regulatory Commission 1111 Pennsylvania Ave., NW Washington, DC 20555-0001 Washington, DC 20004 (E-mail: ocaamail@nrc.gov) (E-mail: ksutton@morganlewis.com, lchandler@morganlewis.com)
Patrick A. Moulding, Esq.
Ann P. Hodgdon, Esq. Martin J. ONeill, Esq.
US Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP Mail Stop O-15 D21 1000 Louisiana St., Suite 4000 Washington, DC 20555-0001 Houston, TX 77002 (E-mail: patrick.moulding@nrc.gov, E-mail:
ann.hodgdon@nrc.gov) martin.oneill@morganlewis.com Edward J. Vigluicci, Esq.
Scott A. Vance, Esq.
Louise Gorenflo Tennessee Valley Authority 3
400 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 20555-0001 Signed (electronically) this 16th day of February, 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) 4