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Anti-pollution League to submit a request for · Seacoast Anti-Pollution League Request for an...
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Docket, Hearing
From: Doug Bogen [[email protected]] Sent: Friday, September 17, 2010 6:25 PM To: Spencer, Mary; malthew,brock@state,ma,us; [email protected]: [email protected]: [email protected]; Docket, Hearing; Kanalas, Catherine: Newell,
Brian; OCAAMAIL Resource; OGCMailCenler Resource; [email protected]: [email protected],gov: jennifer.venezla@slale,ma.us; Williamson, Edward: Monteith, Emily; [email protected]; [email protected]: [email protected] gOY
Subject: Re: Seabrook - Request for 30-day Extension to File Re: 50-443-LR Attachments: Request for 30day Extension to File Re 50-443-LR.doc; An00002.txt
All,
Please ignore the previous attachment - I neglected to save/sent the final version of our request.
Doug Bogen
Good Afternoon I
Please find attached a request for a 30-day extension for Seacoat Anti-pollution League to submit a request for interverntion and a hearing. I wi!. request an NRC Approval Code in order to obtain an electronic Digital ID Certificate within the 30 day period.
Doug Bogen Executive Director Seacoast Anti-Pollution League PO Box 1136 .Portsmouth, NH 03802
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From: Doug Bogen <[email protected]> Subject: Re: Seabrook - Hequest for 30-day Extension to File Re:
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September 17,2010
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Before the Secretary
In the Matter of ) )
NextEra Energy Seabrook, LLC ) [Seabrook Station] )
) [Operating License Renewal] ) Docket No. 50-443-LR
Seacoast Anti-Pollution League Request for an Extension in the Filing of the Request for Public
Hearing and Petition to Intervene
Per 10 C.F.R. §§ 2.307 and 2.323 Seacoast Anti-Pollution League submits its request for an
extension in the above captioned matter in response to the "Request of the State of New Hampshire for an
Extension ofTime to Respond to the Notice of Opportunity for Hearing Regarding the Renewal of
Seabrook's Operating License" dated September 9,2010 regarding the filing of a Request for Public
Hearing and Petition to Intervene in the same above captioned matter and the "Order" by the Secretary
granting the State of New Hampshire, Beyond Nuclear, Friends of the Coast, and New England
Coalition an extension of 30 days in which to file a Petition to Intervene and Request for a Hearing,
dated September 17, 2010.
Seacoast Anti-Pollution League requests that the Ordered extension be uniformly applied to this
request.
The Staff of the Nuclear Regulatory Commission (NRC) states in its Answer that it does not object
to a partial extension of the til ing deadline for a "Request of a Public Hearing and Petition to Intervene" for
the State of New Hampshire to October 13, 2010. The Staff further states that any extension granted by the
Office of Secretary should only apply to the State of New Hampshire. The Staff offers no argument or
reason as to why such an extension only be granted to the State.
For the following reasons Seacoast Anti-Pollution League fonnally requests that an extension of the
filing deadline in the above captioned matter be unifonnly granted to Seacoast Anti-Pollution League as
may be granted to the State of New Hampshire and other pm1ies.
Seacoast Anti-Pollution League submits that since the NRC granted an extension to the State of
New Hampshire the same extension period should be equally afforded to all pm1ies wishing to petition in
this matter for many of the same reasons and hardships as raised by the State. The State of New Hampshire
has significantly more resources than most public interest organizations equally concerned about
representing their own constituent issues, yet the complex nature and extensive volume of the material is the
same for both State and public interest. The arduous task of conferring, interviewing and selecting potential
expe11s to fonnulate, present and defend contentions is the same for both State and public interest
organizations, alike. Seacoast Anti-Pollution League has many of the same interests of its members, most
of whom are at the same time citizens of the State of New Hampshire, as well, but whose unique interests
and concerns may not be served or protected by any particular contention(s) submitted by the State.
There is additionally the fact that the NRC Staff's proposal to separately and differently grant the
State of New Hampshire an extension for filing a request for hearing and petition to intervene while holding
all other parties to the September 20, 20 lOis ill advised for the reason of the judicial economy of the
Atomic Safety and Licensing Board (ASLB) by potentially having to referee over two different timetables
for petition filings, answers and replies to answers and other motions. Thus, simply for the sake of the
considerations ofjudicial economy, conserving the ASLB's time and board attention, Seacoast Anti
Pollution League contends tha'~ the filing deadline should unifonnly be moved back for all potential parties.
Furthennore, economic litigation of the potential issues might be enhanced by a single, unified deadline
which would allow potential communications between parties and the State of New Hampshire and the
coordination of petitions as belween the parties and the State of New Hampshire.
Sincerely,
Doug Bogen Executive Director Seacoast Anti-Pollution League
PO Box 1136 Portsmouth, NH 03802 (603)431-5089
September 17, 2010
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Before the Secretary
In the Matter of
NextEra Energy Seabrook, LLC Seabrook Station
))))) )
Operating License Renewal ))
Docket 50-443 LR
CERTIFICATE OF SERVICE
I hereby certify that copies of the foregoing Seacoast Anti-Pollution League Request for Extension, dated
September 17,2010, have been served upon the following persons by email.
Secretary Attention: Rulemakings and Adjudications Staff Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 [email protected]
Office of Commission Appellate Adjudication Mail Stop 0-16 CI U.S. Nuclear Regulatory Comrrission Washington, DC 20555-0001 E-mail: [email protected]
U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop: 0-15D21 Washington, DC 20555-0001
Edward Williamson, Esq. [email protected]
Brian Newell, Esq. bpn [email protected]
Mary Spencer, Esq. [email protected]
Catherine Kanatas [email protected]
Emily Monteith, Esq. emi Iy. montei [email protected]
OGC Mail Center [email protected]
Counsel for the Applicant NextEra Energy Seabrook, LLC 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 Steven C. Hamrick, Esq. [email protected] Antonio Fernandez, Esq. [email protected] Mitchell S. Ross, Esq. [email protected]
Beyond Nuclear 6930 Can-oil Avenue Suite 400 Takoma Park, MD 20912 Paul Gunter, Director Reactor Oversight Project [email protected]
Friends of the Coast / New Eng.and Coalition Post Office Box 98 Edgecomb, ME 04556 Raymond Shadis, Pro Se Repre:;entative [email protected]
Office of the Attorney General State of New Hampshire 33 Capitol Street Concord, NH 03301 K. Allen Brooks, Assistant Attomey General [email protected] Michael A. Delaney, Attorney General [email protected] Peter Roth, Assistant Attorney General [email protected] Office of the Attorney General
State of Massachusetts One Ashburton Place Boston, MA 021 08 Matthew Brock, Assistant Attomey General [email protected] Jennifer Venezie, Paralegal [email protected]
-----signed by Doug Bogen------
Doug Bogen Executive Director Seacoast Anti-Pollution League PO Box 1136 Portsmouth, NH 03802 (603)431-5089 [email protected]