ML20072K286

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Unopposed Motion of Riverkeeper, Inc. for an Enlargement of Time to File Its Reply
ML20072K286
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/12/2020
From: Ommen T
Pace Environmental Law Clinic
To:
NRC/SECY
SECY RAS
References
50-003-LT-3, 50-247-LT-3, 50-286-LT-3, 72-51-LT-2, License Transfer, RAS 55605
Download: ML20072K286 (4)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.;

ENTERGY NUCLEAR INDIAN POINT 2, LLC; ENTERGY NUCLEAR INDIAN POINT 3, LLC; Docket Nos.:

HOLTEC INTERNATIONAL; and HOLTEC 50-3 DECOMMISSIONING INTERNATIONAL, LLC; 50-247 APPLICATION FOR ORDER CONSENTING TO 50-348 TRANSFERS OF CONTROL OF LICENSES72-051 AND APPROVING CONFORMING LICENSE AMENDMENTS (Indian Point Nuclear Generating Station)

UNOPPOSED MOTION OF RIVERKEEPER, INC.

FOR AN ENLARGEMENT OF TIME TO FILE ITS REPLY Pursuant to 10 C.F.R. § 2.307, Petitioner Riverkeeper, Inc. (Petitioner) moves the Commission for a short enlargement of time to reply to the answer filed in the above-captioned proceeding, from March 16, 2020 to and including March 23, 2020. Entergy Nuclear Operations, Inc.; Entergy Nuclear Indian Point 2, LLC; Entergy Nuclear Indian Point 3, LLC; Holtec International; and Holtec Decommissioning International, LLC (collectively, the Applicants) do not oppose the Petitioners request. In support of this motion, the Petitioner offers the following:

1. This matter concerns an application to the Nuclear Regulatory Commission by the Applicants for permission to transfer the licenses for the Indian Point Nuclear Generating Station (Indian Point) and the Indian Point Independent Spent Fuel Storage Installation. On February 12, 2020, Petitioner submitted a petition to intervene in the license transfer proceedings under 10 C.F.R. 1

§ 2.309 and requested a hearing thereon (the Petition). On March 9, 2020, the Applicants filed an answer responding to the Petition. Petitioners reply is currently due to be filed on March 16, 2020.

2. As described in the Petition and accompanying standing affidavits, the complete, thorough and safe decontamination and restoration of Indian Point is of great concern to the Petitioner and its members. Petitioner has devoted and will continue to devote significant resources to this matter, but other factors have intervened to complicate the preparation of a reply brief. In addition to the length and complexity of the Petition and Answer, Pace University has closed all campuses to students, including the Law School and the undersigned clinic. Undersigned counsel can and will continue to work on the reply but these events have complicated our completion of the reply brief. Additional time is therefore necessary to complete the reply brief, and Petitioner respectfully requests a one-week extension to coincide with the extensions sought by other Petitioners in this matter.
3. As required by 10 C.F.R. § 2.323(b), counsel for Petitioner consulted with counsel for the Applicants, Paul Bessette, on March 12, 2020. Mr. Bessette courteously indicated that the Applicants do not oppose Petitioners request for an enlargement of time to file its reply.

For the foregoing reasons, and upon good cause shown, Petitioner respectfully request that the Commission grant this motion for an enlargement of time and modify the deadline by which the Petitioner must file its reply in this proceeding from March 16, 2020 to and including March 23, 2020.

Respectfully submitted on March 12, 2020 Signed electronically by:

Todd Ommen Managing Attorney Pace Environmental Law Clinic, Inc.

78 N. Broadway White Plains NY 10603

Tel.914-422-4343 Email: tommen@law.pace.edu

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.;

ENTERGY NUCLEAR INDIAN POINT 2, LLC; ENTERGY NUCLEAR INDIAN POINT 3, LLC; Docket Nos.:

HOLTEC INTERNATIONAL; and HOLTEC 50-3 DECOMMISSIONING INTERNATIONAL, LLC; 50-247 APPLICATION FOR ORDER CONSENTING TO 50-348 TRANSFERS OF CONTROL OF LICENSES72-051 AND APPROVING CONFORMING LICENSE AMENDMENTS (Indian Point Nuclear Generating Station)

CERTIFICATE OF SERVICE Pursuant to 10 CFR § 2.305, I certify that copies of The Unopposed Motion of Riverkeeper, Inc. for an Enlargement of Time to File a Reply have been served upon the Electronic Information Exchange, the NRCs e-filing system, in the above captioned proceeding, on March 12, 2020.

Signed electronically by:

Todd Ommen Managing Attorney Pace Environmental Law Clinic, Inc.

78 N. Broadway White Plains NY 10603 Tel.914-422-4343 Email: tommen@law.pace.edu