ML020660181
| ML020660181 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 03/01/2002 |
| From: | Slater J Tennessee Valley Authority |
| To: | Atomic Safety and Licensing Board Panel |
| Byrdsong A | |
| References | |
| +adjud/rulemjr200506, 50-259-CIVP, 50-260-CIVP, 50-296-CIVP, 50-327-CIVP, 50-328-CIVP, 50-390-CIVP, ASLBP 01-791-01-CIVP, EA-99-234, RAS 4010 | |
| Download: ML020660181 (3) | |
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1q45 IolD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD DOCKETED USNRC 2002 MAR -5 AM II: 17 3JFICE;f iiE ;YtIM<ETARY RULEDN "KINGS ANO ADJUDICATIONS STAFF IN THE MATTER OF TENNESSEE VALLEY AUTHORITY (Watts Bar Nuclear Plant, Unit 1; Sequoyah Nuclear Plant, Units 1 & 2; Browns Ferry Nuclear Plant, Units 1, 2, & 3)
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Docket Nos. 50-390-CivP;
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50-327-CivP; 50-328-CivP;
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50-259-CivP; 50-260-CivP;
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50-296-CivP
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ASLBP No. 01-791-01-CivP
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EA 99-234
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TENNESSEE VALLEY AUTHORITY'S MOTION FOR LEAVE TO FILE REPLY IN SUPPORT OF MOTION FOR
SUMMARY
DECISION Pursuant to 10 C.F.R. §§ 2.730 and 2.749, the Tennessee Valley Authority (TVA) moves for leave to file a reply in support of its motion for summary decision which is filed contemporaneously herewith. The NRC Staff's response to TVA's motion for summary decision was 48 pages in length, focused on many issues and facts not pertinent to the pending motion, and overstated other facts and/or the inferences it wishes the Board to draw from such facts. We believe a short reply would be helpful to the Board in that it addresses those overstated facts and inferences that the NRC Staff raised in its response in opposition to TVA's motion for summary decision.
Te7p/5 UVes v-OV/
Respectfully submitted, March 1, 2002 Office of the General Counsel Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, Tennessee 37902-1401 Facsimile 865-632-6718 Maureen H. Dunn General Counsel Thomas F. Fine Assistant General Counsel Brent R. Marquand Senior Litigation Attorney Barbara S. Maxwell, Attorney Of Counsel:
David A. Repka, Esq.
Winston & Strawn 1400 L Street, NW Washington, D.C. 20005 Jo E. Sla (SC Bar No. 005149)
Senior Litigation Attorney Telephone 865-632-7878 Attorneys for Tennessee Valley Authority 003692664 2
CERTIFICATE OF SERVICE I hereby certify that the foregoing motion for leave to file reply in support of TVA's motion for summary decision, together with the reply, has been served by regular mail on the persons listed below. Copies of the motion and reply, less the attachments which are being sent by regular mail, have also been sent by e-mail to those persons listed below with e-mail addresses.
Administrative Judge Charles Bechhoefer, Chairman U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Two White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 e-mail address: cxb2@nrc.gov Administrative Judge Ann Marshall Young U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Two White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 e-mail address: amyCnrc.gov Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Administrative Judge Richard F. Cole U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Two White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 e-mail address: rfclCnrc.gov Dennis C. Dambly, Esq.
Jennifer M. Euchner, Esq.
U.S. Nuclear Regulatory Commission Office of the General Counsel One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 e-mail address: dcd~nrc.gov e-mail address: jme~nrc.gov Mr. William D. Travers Executive Director of Operations U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 This 1st day of March, 2002.
Attokney for Xnnessee Valley Authority 3