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| issue date = 09/30/2011 | | issue date = 09/30/2011 | ||
| title = Joint Motion to Amend the Initial Scheduling Order | | title = Joint Motion to Amend the Initial Scheduling Order | ||
| author name = Hamrick S, Ross M | | author name = Hamrick S, Ross M | ||
| author affiliation = NextEra Energy Seabrook, LLC | | author affiliation = NextEra Energy Seabrook, LLC | ||
| addressee name = | | addressee name = | ||
| Line 16: | Line 16: | ||
=Text= | =Text= | ||
{{#Wiki_filter:September 30, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board | {{#Wiki_filter:September 30, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of | ||
) | |||
) | |||
NextEra Energy Seabrook, LLC | |||
) | |||
Docket No. | |||
50-443-LR | |||
) | |||
(Seabrook Station) | |||
) | |||
) | |||
ASLBP No. 10-906-02-LR (Operating License Renewal) | |||
) | |||
Joint Motion to Amend the Initial Scheduling Order NextEra Energy Seabrook, LLC (hereinafter NextEra), on behalf of itself and the NRC Staff, Intervenors Beyond Nuclear, Sierra Club of New Hampshire, and Seacoast Anti-Pollution League, and Intervenors Friends of the Coast and the New England Coalition, hereby moves the Atomic Safety and Licensing Board (Board) to further amend its April 4, 2011 Initial Scheduling Order to modify its deadline for submitting a proposed protective order and nondisclosure agreement. | |||
The Board recently granted NextEras motion to modify the Initial Scheduling Order, moving the deadline for production of mandatory disclosures from October 3, 2011 to April 2, 2012. Order (Granting Motion to Modify Deadline for Initial Disclosures) (Aug. 23, 2011). At that time, no change was made to Paragraph B of the Initial Scheduling Order, which requires the parties to submit a proposed protective order, also by October 3, 2011. | |||
In accordance with the Boards Initial Scheduling Order, the parties have conferred for the purpose of developing a proposed protective order and nondisclosure | |||
2 agreement concerning the handling of documents that are proprietary or otherwise sensitive, but have not yet reached an agreement to submit to the Board. The parties have also engaged in discussions regarding other aspects of discovery management. The parties would prefer to reach agreement among themselves and believe that they can resolve these issues by November 10, if not sooner. In light of these ongoing discussions and of the Boards earlier amendment of the Initial Scheduling Order to no longer require mandatory disclosures on October 3, the parties jointly request the Board to amend Paragraph B of its Initial Scheduling Order to require the submittal of a proposed protective order by November 10, 2011. | |||
Respectfully Submitted, | Respectfully Submitted, | ||
/Signed electronically by Steven Hamrick/ | |||
Mitchell S. Ross NextEra Energy Seabrook, LLC 700 Universe Blvd. | |||
Juno Beach, Florida 33408 Telephone: 561-691-7126 Facsimile: 561-691-7135 E-mail: mitch.ross@fpl.com Steven Hamrick NextEra Energy Seabrook, LLC 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 Telephone: 202-349-3496 Facsimile: 202-347-7076 E-mail: steven.hamrick@fpl.com Counsel for NextEra Energy Seabrook, LLC | |||
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of | |||
) | |||
) | |||
NextEra Energy Seabrook, LLC | NextEra Energy Seabrook, LLC | ||
) | |||
Docket No. | |||
50-443-LR | |||
) | |||
(Seabrook Station) | |||
) | |||
) | |||
ASLBP No. 10-906-02-LR (Operating License Renewal) | |||
) | |||
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Joint Motion to Amend the Initial Scheduling Order, were provided to the Electronic Information Exchange for service to those individuals listed below and others on the service list in this proceeding, this 30th day of September, 2011. | |||
Administrative Judge Paul S. Ryerson, Esq., Chair Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Email: psr1@nrc.gov Administrative Judge Dr. Michael Kennedy Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Email: michael.kennedy@nrc.gov Administrative Judge Dr. Richard E. Wardwell Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Email: richard.wardwell@nrc.gov Secretary Attn: Rulemakings and Adjudications Staff Mail Stop O-16 C1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 hearingdocket@nrc.gov | |||
2 Office of Commission Appellate Adjudication Mail Stop O-16 C1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: OCAAMAIL@nrc.gov Mary Spencer, Esq. | |||
Maxwell C. Smith, Esq. | |||
Richard Harper, Esq. | |||
Office of the General Counsel Mail Stop O-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: mary.spencer@nrc.gov Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, Maine 04556 E-mail: shadis@prexar.com Kurt Ehrenberg New Hampshire Sierra Club 40 N. Main Street Concord, NH 03301 E-mail: Kurt.Ehrenberg@sierraclub.org Paul Gunter, Reactor Oversight Project Beyond Nuclear 6930 Carroll Avenue, Suite 400 Takoma Park, MD 20912 E-mail: paul@beyondnuclear.org Doug Bogen Executive Director Seacoast Anti-Pollution League PO Box 1136 Portsmouth, NH 03802 E-mail: bogen@metrocast.net Matthew Brock Assistant Attorney General Environmental Protection Division Office of the Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 matthew.brock@state.ma.us | |||
/Signed electronically by Steven Hamrick/ | |||
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: OCAAMAIL@nrc.gov | |||
Mary Spencer, Esq. Maxwell C. Smith, Esq. | |||
Richard Harper, Esq. | |||
Office of the General Counsel | |||
Mail Stop O-15 D21 | |||
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: | |||
Raymond Shadis | |||
New England Coalition | |||
Post Office Box 98 Edgecomb, Maine 04556 E-mail: | |||
Kurt Ehrenberg New Hampshire Sierra Club | |||
40 N. Main Street | |||
Concord, NH 03301 E-mail: | |||
Paul Gunter, Reactor Oversight Project | |||
Beyond Nuclear | |||
6930 Carroll Avenue, Suite 400 Takoma Park, MD 20912 E-mail: | |||
Doug Bogen Executive Director Seacoast Anti-Pollution League | |||
PO Box 1136 Portsmouth, NH 03802 E-mail: | |||
Steven Hamrick}} | Steven Hamrick}} | ||
Latest revision as of 01:47, 13 January 2025
| ML11273A175 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/30/2011 |
| From: | Hamrick S, Ross M NextEra Energy Seabrook |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 21161, 50-443-LR, ASLBP 10-906-02-LR-BD01 | |
| Download: ML11273A175 (4) | |
Text
September 30, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
NextEra Energy Seabrook, LLC
)
Docket No.
50-443-LR
)
(Seabrook Station)
)
)
ASLBP No. 10-906-02-LR (Operating License Renewal)
)
Joint Motion to Amend the Initial Scheduling Order NextEra Energy Seabrook, LLC (hereinafter NextEra), on behalf of itself and the NRC Staff, Intervenors Beyond Nuclear, Sierra Club of New Hampshire, and Seacoast Anti-Pollution League, and Intervenors Friends of the Coast and the New England Coalition, hereby moves the Atomic Safety and Licensing Board (Board) to further amend its April 4, 2011 Initial Scheduling Order to modify its deadline for submitting a proposed protective order and nondisclosure agreement.
The Board recently granted NextEras motion to modify the Initial Scheduling Order, moving the deadline for production of mandatory disclosures from October 3, 2011 to April 2, 2012. Order (Granting Motion to Modify Deadline for Initial Disclosures) (Aug. 23, 2011). At that time, no change was made to Paragraph B of the Initial Scheduling Order, which requires the parties to submit a proposed protective order, also by October 3, 2011.
In accordance with the Boards Initial Scheduling Order, the parties have conferred for the purpose of developing a proposed protective order and nondisclosure
2 agreement concerning the handling of documents that are proprietary or otherwise sensitive, but have not yet reached an agreement to submit to the Board. The parties have also engaged in discussions regarding other aspects of discovery management. The parties would prefer to reach agreement among themselves and believe that they can resolve these issues by November 10, if not sooner. In light of these ongoing discussions and of the Boards earlier amendment of the Initial Scheduling Order to no longer require mandatory disclosures on October 3, the parties jointly request the Board to amend Paragraph B of its Initial Scheduling Order to require the submittal of a proposed protective order by November 10, 2011.
Respectfully Submitted,
/Signed electronically by Steven Hamrick/
Mitchell S. Ross NextEra Energy Seabrook, LLC 700 Universe Blvd.
Juno Beach, Florida 33408 Telephone: 561-691-7126 Facsimile: 561-691-7135 E-mail: mitch.ross@fpl.com Steven Hamrick NextEra Energy Seabrook, LLC 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 Telephone: 202-349-3496 Facsimile: 202-347-7076 E-mail: steven.hamrick@fpl.com Counsel for NextEra Energy Seabrook, LLC
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
NextEra Energy Seabrook, LLC
)
Docket No.
50-443-LR
)
(Seabrook Station)
)
)
ASLBP No. 10-906-02-LR (Operating License Renewal)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Joint Motion to Amend the Initial Scheduling Order, were provided to the Electronic Information Exchange for service to those individuals listed below and others on the service list in this proceeding, this 30th day of September, 2011.
Administrative Judge Paul S. Ryerson, Esq., Chair Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Email: psr1@nrc.gov Administrative Judge Dr. Michael Kennedy Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Email: michael.kennedy@nrc.gov Administrative Judge Dr. Richard E. Wardwell Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Email: richard.wardwell@nrc.gov Secretary Attn: Rulemakings and Adjudications Staff Mail Stop O-16 C1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 hearingdocket@nrc.gov
2 Office of Commission Appellate Adjudication Mail Stop O-16 C1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: OCAAMAIL@nrc.gov Mary Spencer, Esq.
Maxwell C. Smith, Esq.
Richard Harper, Esq.
Office of the General Counsel Mail Stop O-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: mary.spencer@nrc.gov Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, Maine 04556 E-mail: shadis@prexar.com Kurt Ehrenberg New Hampshire Sierra Club 40 N. Main Street Concord, NH 03301 E-mail: Kurt.Ehrenberg@sierraclub.org Paul Gunter, Reactor Oversight Project Beyond Nuclear 6930 Carroll Avenue, Suite 400 Takoma Park, MD 20912 E-mail: paul@beyondnuclear.org Doug Bogen Executive Director Seacoast Anti-Pollution League PO Box 1136 Portsmouth, NH 03802 E-mail: bogen@metrocast.net Matthew Brock Assistant Attorney General Environmental Protection Division Office of the Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 matthew.brock@state.ma.us
/Signed electronically by Steven Hamrick/
Steven Hamrick