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Category:Legal-Motion
MONTHYEARML0831905302008-11-0606 November 2008
Connecticut Coalition Against Millstone and Nancy Burton, (Attorney) Notice of Appeal
ML0822506942008-08-11011 August 2008
NRC Staff'S Answer Opposing Petitioner'S Motion Dated July 31, 2008 for Nunc Pro Tunc Relief and Continuing Waiver of Electronic Filing
ML0822506912008-08-11011 August 2008
NRC Staff Answer Opposing Petitioner'S Motion Dated July 31, 2008 for Nunc Pro Tunc Relief and Continuing Waiver of Electronic Filing
ML0822700412008-08-0707 August 2008
Connecticut Coalition Against Millstone and Nancy Burton Revised Motion for Leave to File Their New And/Or Amended Contentions Based on Receipt of New Information and for Continuing Waiver of Electronic Filing
ML0822003562008-07-31031 July 2008
Connecticut Coalition Against Millstone and Nancy Burton Motion for Leave to File Their Motion for Leave to File New And/Or Amended Contentions Based on Receipt of New Information Dated July 18, 2008, Nunc Pro Tunc, and for Continuing.
ML0812207412008-05-0101 May 2008
Dominion Nuclear Connecticut'S Motion to Strike Portions of Connecticut Coalition Against Millstone and Nancy Burton'S Reply to Responses to Petition to Intervene
ML0811305222008-04-16016 April 2008
Connecticut Coalition Against Millstone and Nancy Burton'S Motion to Consolidate Reply to NRC Staff and Dominion Responses to Petition to Intervene and for Extension of Time to File Consolidated Reply on or Before April 22, 2008
ML0604105372006-01-30030 January 2006
Motion Information Statement - Motion for Leave to Intervene, Dated 1/30/2006
ML0601704802006-01-0404 January 2006
Unopposed Motion of Dominion Nuclear Connecticut for Leave to Intervene & Corporate Disclosure Statement, Dated 1/4/06
ML0603101972005-11-25025 November 2005
2005/11/25-Motion to Reopen Millstone License Renewal Proceeding Filed by the Connecticut Coalition Against Millstone
ML0523702062005-08-18018 August 2005
Motion of the Nuclear Energy Institute for Leave to File Brief as Amicus Curiae in Opposition to Suffolk County'S Request for an Exemption from or Waiver of 10 C.F.R. 50.47(a)(1)
ML0523702092005-08-18018 August 2005
Brief of Dominion Nuclear Connecticut in Response to CLI-05-18 Concerning Suffolk County'S Late Petition and Waiver Request
ML0510401902005-03-18018 March 2005
NRC Staff Motion to Strike County of Suffolk'S Reply and Response to 10 CFR 2.335 Request for Waiver
ML0512602312004-10-0606 October 2004
Mandated Motion to Dismiss for Lack of Jurisdiction, the Petitioner'S Petition for Review of Two Decisions of the Nuclear Regulatory Commission, Dated 4/8/05
ML0426103042004-09-10010 September 2004
Federal Respondent'S Reply to Petitioner'S Objection to Motion to Dismiss, Dated 9/10/04
ML0426103012004-09-0303 September 2004
Petitioner'S Objection to Motion to Dismiss, Dated 9/3/04
ML0426103002004-09-0202 September 2004
Petitioner'S Motion for Extension of Time to Reply to Motion to Dismiss, Dated 9/2/04
ML0426102962004-08-26026 August 2004
Response by Dominion Nuclear in Support of Motion to Dismiss, Dated 8/26/04
ML0423900322004-08-18018 August 2004
Dominion'S Answer to Ccam'S Motion for Reconsideration and Request for Leave to Amend Petition
ML0425701172004-08-16016 August 2004
Federal Respondents Motion to Dismiss, Dated 8/16/04
ML0809803502004-08-16016 August 2004
Connecticut Coalition Against Millstone V. USNRC and Dominion Nuclear Connecticut, No. 07-3577-ag; Federal Respondents' Motion to Dismiss
ML0423205482004-08-0909 August 2004
Connecticut Coalition Against Millstone Motion for Reconsideration and Request for Leave to Amend Petition
ML0425701112004-07-30030 July 2004
Order Granting Motion to Intervene, Dated 7/30/04
ML0425701092004-07-19019 July 2004
Unopposed Motion to Intervene, Dated 7/19/2004
ML0414201772004-05-14014 May 2004
Motion for Reconsideration of CLI-04-12
ML0412501942004-04-13013 April 2004
Appeal Scheduling Order #2
ML0411300352004-04-12012 April 2004
Connecticut Coalition Against Millstone Reply to NRC Staff and Dominion Response to Motion to Vacate
ML0409901582004-04-0202 April 2004
Dominion'S Answer to Ccam'S Motion to Vacate Secretary Determination
ML0409705222004-04-0202 April 2004
Millstone Units 2 & 3 - NRC Staff'S Response to Connecticut Coalition Against Millstone'S Motion to Vacate and to Accept Petition to Intervene and Request for Hearing
ML0409300792004-04-0101 April 2004
Millstone Units 2 & 3 - NRC Staff'S Unopposed Motion for an Extension of Time to Respond to Connecticut Coalition Against Millstone'S Petition to Intervene and Request for Hearing
ML0410403392004-03-22022 March 2004
Motion to Vacate NRC Secretary Determination of Petition Prematurity and to Accept Petiton to Intervene and Request for Hearing as of Date of Filing and to Apply 'Old' CFR Hearing Rules to Said Petition
ML0405602262004-01-23023 January 2004
Motion for Leave to Intervene for Dominion Nuclear Connecticut, Inc. Dated 01/23/2004
ML0332202232003-11-17017 November 2003
NRC Staff'S Response in Opposition to Petitioner'S Motion for Reconsideration
ML0331701272003-11-0404 November 2003
Answer of Dominion Nuclear Connecticut, Inc. to Motion of Connecticut Coalition Against Millstone for Reconsideration of CLI-03-14
ML0331701232003-11-0303 November 2003
Motion for Reconsideration
ML0321806782003-06-11011 June 2003
Respondent'S Motion to Dismiss Petition for Review Granted Connecticut Coalition Against Millstone, No. 03-4372) Dated 06/11/03
ML0310506282003-04-14014 April 2003
Federal Respondents' Motion to Dismiss, Dated April 14, 2003
ML0307904422003-03-11011 March 2003
Motion Information Statement Re Leave to Intervene
ML0307904362003-03-11011 March 2003
Motion of Dominion Nuclear Connecticut, Inc. for Leave to Intervene
ML0307304392003-03-0707 March 2003
Motion of Petitioner, Connecticut Coalition Against Millstone, for One-Day Extension of Time to File Supplemented Petition and Contentions
ML0208703162002-03-18018 March 2002
Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone Response to NRC Staff Motion to Strike
ML0207900102002-03-15015 March 2002
NRC Staff'S Motion to Strike Reply Brief Filed by Ccam/Cam
ML0207100652002-03-0808 March 2002
NRC Staff'S Response to the Motion of the Nuclear Energy Institute for Leave to File an Amicus Brief
ML0207301032002-02-27027 February 2002
Motion by the Nuclear Energy Institute for Leave to File an Amicus Brief in Response to the Commission'S Memorandum and Orders Dated February 6, 2002, Regarding the Commission'S Consideration of Potential Intentional Malevolent Acts
ML0205802412002-02-26026 February 2002
NRC Staff'S Response Opposing Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone'S Motion to Extend Scheduling Orders and Date of Oral Argument
ML0205805842002-02-25025 February 2002
NRC Staff'S Motion to Compel Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone to Respond to NRC Staff'S First Set of Descovery Requests Directed to Intervenors in the Reopened Proceeding
ML0216901222002-02-22022 February 2002
Connecticut, Inc.'S Response to Motion to Extend Scheduling Orders and Date of Oral Argument
ML0206505902002-02-21021 February 2002
Connecticut, Inc.'S Emergency Motion to Compel Answers to Interrogatories and Production of Documents
ML0206506052002-02-19019 February 2002
Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone Motion to Extend Scheduling Orders and Date of Oral Argument
ML0202501972002-01-0303 January 2002
Connecticut'S Response to Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone Reply to Oppositions to Motion to Reopen the Record and Request for Admission of Late-Filed Envrionmental Contention
2008-08-07
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Text
RAS 4049 March 8, 2002 DOCKETED 03/11/02 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
)
DOMINION NUCLEAR CONNECTICUT, INC. ) Docket No. 50-423-LA-3 (Millstone Nuclear Power Station, Unit No. 3 )
)
NRC STAFFS RESPONSE TO THE MOTION OF THE NUCLEAR ENERGY INSTITUTE FOR LEAVE TO FILE AN AMICUS BRIEF On February 27, 2002, the Nuclear Energy Institute (NEI) filed a motion for leave to file a brief amicus curiae,1 along with its proposed brief,2 in response to the Commissions Orders of February 6, 2002, requesting briefs from the parties in four separate adjudicatory proceedings.3 NEIs Motion seeks leave to file a brief concerning an issue that is now under review by the Commission -- i.e., whether the Commissions responsibility under the National Environmental Policy Act of 1969 (NEPA) requires consideration of intentional malevolent acts, such as those directed against the United States on September 11, 2001. The NRC Staff (Staff) herewith responds to NEIs Motion.
1 See Motion By the Nuclear Energy Institute for Leave to File an Amicus Brief in Response to the Commissions Memorandum and Orders Dated February 6, 2002, Regarding the Commissions Consideration of Potential Intentional Malevolent Acts (Motion), dated February 27, 2002.
2 See Amicus Brief of Nuclear Energy Institute in Response to the Commissions Memorandum and Orders Dated February 6, 2002, Regarding the Commissions Consideration of Potential Intentional Malevolent Acts (Brief), dated February 27, 2002.
3 See (1) Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation),
CLI-02-03, 55 NRC ___ (Feb. 6, 2002); (2) Duke Cogema Stone & Webster (Savannah River Mixed Oxide Fuel Fabrication Facility), CLI-02-04, 55 NRC ___ (Feb. 6, 2002); (3) Dominion Nuclear Connecticut, Inc. (Millstone Nuclear power Station, Unit No. 3), 55 NRC ___ (Feb. 6, 2002); and (4) Duke Energy Corp. (McGuire Nuclear Station, Units 1 & 2, and Catawba Nuclear Station, Units 1 & 2), CLI-02-06, 55 NRC ___ (Feb. 6, 2002).
In the Staffs view, NEIs Motion establishes that the issue under review by the Commission is of concern to NEIs members and to the nuclear energy industry, in general. In addition, it is apparent that the Commissions resolution of this issue may affect NEIs members interests, in that the issue appears to have generic applicability to NRC licensees and license applicants other than those involved in the instant proceeding, and the resolution of this issue could affect other licensing proceedings in the future. Accordingly, the Staff does not object to NEIs filing of its amicus brief relating to this issue in the instant proceeding.
Respectfully submitted,
/RA/
Ann P. Hodgdon Counsel for NRC Staff Dated at Rockville, Maryland this 8th day of March, 2002
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
)
DOMINION NUCLEAR CONNECTICUT, INC ) Docket No. 50-423-LA-3
)
Millstone Nuclear Power Station, Unit No. 3 )
CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFFS RESPONSE TO THE MOTION OF THE NUCLEAR ENERGY INSTITUTE FOR LEAVE TO FILE AN AMICUS BRIEF, in the above captioned proceeding have been served on the following through deposit in the NRCs internal mail system, with copies by electronic mail, as indicated by an asterisk, or by deposit in the U.S.
Postal Service, as indicated by double asterisk, with copies by electronic mail this 8th day of March, 2002:
Charles Bechhoefer, Chairman* Dr. Charles N. Kelber*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 (E-mail copy to cxb2@nrc.gov) (E-mail copy to cnk@nrc.gov)
Dr. Richard F. Cole* Office of the Secretary*
Administrative Judge ATTN: Rulemakings and Adjudications Atomic Safety and Licensing Board Staff U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 (E-mail copy to rfc1@nrc.gov) (E-mail copies to SECY@nrc.gov and HEARINGDOCKET@nrc.gov)
Michelle McKown, Esq.*
Atomic Safety and Licensing Board Panel Office of the Commission Appellate U.S. Nuclear Regulatory Commission Adjudication Mail Stop: T-3F23 Mail Stop: 16-C-1 OWFN Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission (E-mail copy to mrm@nrc.gov) Washington, DC 20555-0001 Atomic Safety and Licensing Board Panel Lillian M Cuoco, Esq.**
U.S. Nuclear Regulatory Commission Dominion Nuclear Connecticut, Inc.
Washington, DC 20555-0001 Millstone Power Station Building 475/5 Rope Ferry Road (Route 156)
Waterford, Connecticut 06385 (E-mail copy to Lillian_Cuoco@dom.com)
David A. Repka, Esq** Diane Curran, Esq.**
Donald P. Ferraro, Esq. Harmon, Curran, Spielberg & Eisenberg Winston & Strawn 1726 M Street, N.W., Suite 600 1400 l Street, N.W Washington, D.C. 20036 Washington, DC 20005-3502 (E-mail copy to (E-mail copy to drepka@winston.com) dcurran@harmoncurran.com)
Nancy Burton, Esq.**
147 Cross Highway Redding Ridge,CT 06876 (E-mail copy to nancyburtonesq@hotmail.com)
/RA/
Ann P. Hodgdon Counsel for NRC Staff
