STATE OF VERMONT
PUBLIC SERVICE BOARD
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into the environment;
(2) whether good cause exists to
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modify or revoke the 30 V.S.A. ยง 231 Certificate of Public )
Good issued to Entergy VY; and (3) whether any penalties)
should be imposed on Entergy VY for any identified
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violations of Vermont statutes or Board orders related to
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Investigation into (1) whether Entergy Nuclear Vermont
Yankee, LLC, and Entergy Nuclear Operations, Inc.,
(collectively, "Entergy VY"), should be required to cease
operations at the Vennont Yankee Nuclear Power Station,
or take other ameliorative actions, pending completion of
repairs to stop releases of radionuclides,
radioactive
materials, and, potentially, other non-radioactive materials
Docket No. 7600
MOTION TO MODIFY THE PREHEARING CONFERENCE MEMORANDUM
AND TO ENLARGE THE TIME FOR ENTERGY VY TO RESPOND TO
PENDING DISCOVERY REQUESTS
Under Rules 6(b) and 16.2 of the Vermont Rules of Civil Procedure, as made applicable
to proceedings before the Vermont Public Service Board (referenced herein as "The Board") by
its Rule 2.103, Entergy Nuclear Vermont Yankee, LLC, and Entergy Nuclear Operations, Inc.
(collectively referenced herein as "Entergy VY"), file this Motion to Modify the Prehearing
Conference Memorandum and to Enlarge the Time for Entergy VY to Respond to Pending
Discovery Requests.
Good cause exists for the entry of an order enlarging time because Entergy VY has been
served with discovery vastly exceeding what was contemplated in the Prehearing Conference
Memorandum dated March 18,2010 (hereinafter "March 18 Order"), not only in terms of
volume-over
three hundred requests and sub-requests served near the end of the rolling
discovery period set forth in the March 18 Order-but also in terms of substance.
In particular,
the Board has acknowledged the significant role that matters of jurisdiction,
including Federal preemption, will play in this docket, and consequently it limited discovery
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during the initial phase of the docket to certain enumerated categories of