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Category:Legal-Motion
MONTHYEARML15251A6782015-09-0404 September 2015 Motion for Leave to Intervene by First Energy Nuclear Operating Company ML15132A5152015-05-12012 May 2015 Certificate of Service of Beyond Nuclear Reply to Oppositions to Motion to Admit New Contention ML15128A2912015-05-0808 May 2015 Beyond Nuclear'S Motion to Amend Nepa Placeholder Contention in License Renewal Proceeding for Davis-Besse Nuclear Power Plant ML15132A1972015-05-0808 May 2015 Certificate of Service for Beyond Nuclear'S Motion to Amend NEPA Placeholder Contention, Filed May 8, 2015 ML15128A2982015-05-0808 May 2015 Reply by Beyond Nuclear, Blue Ridge Environmental Defense League, Nuclear Information and Resource Service, Seed Coalition and Southern Alliance for Clean Energy to Oppositions by Applicants and NRC Staff to Motions to Admit New Contentions ML15112B2012015-04-22022 April 2015 Beyond Nuclear'S Hearing Request and Motion to Intervene ML15112B1992015-04-22022 April 2015 Beyond Nuclear Motion to Reopen Record of License Renewal Proceeding ML15112B2022015-04-22022 April 2015 Standing Declaration of Victoria Clemons ML15065A2222015-03-0606 March 2015 FENOC Motion for Clarification Regarding Termination of Proceeding ML14364A4052014-12-30030 December 2014 Intervenors' Second Motion to Supplement Contention No. 7 on Worsening Shield Building Cracking and Inadequate Amps in Shield Building Monitoring Program ML14335A7802014-12-0101 December 2014 Joint Proposed Corrections to the Transcript of the Oral Argument Held on November 12, 2014 ML14315A0492014-11-11011 November 2014 Notice of Filing of Riley Email (Exhibit a to Contention No. 7) ML14311A9892014-11-0707 November 2014 Petitioners and Intervenors Consolidated Reply to Answers to Petitions to Suspend Final Reactor Licensing Decisions, Motions to Admit a New Contention, and Motions to Reopen the Record ML14255A0302014-09-12012 September 2014 Erratum to Intervenors' Motion to Amend and Supplement Contention No. 7 on Worsening Shield Building Cracking and Inadequate AMPs in Shield Monitoring Program ML14252A8982014-09-0909 September 2014 Unopposed Motion to Establish Consolidated Briefing Schedule for Proposed Contention 7 Admissibility Filings ML14251A6092014-09-0808 September 2014 Intervenors Motion to Amend and Supplement Contention No. 7 on Worsening Shield Building Cracking and Inadequate AMPs in Shield Building Monitoring Program ML14245A6562014-09-0202 September 2014 Intervenors' Motion for Admission of Contention No. 7 on Worsening Shield Building Cracking and Inadequate Amps in Shield Building Monitoring Program ML14144A0002014-05-23023 May 2014 Intervenors' Reply in Support of Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems ML14112A0072014-04-21021 April 2014 Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems ML14112A0082014-04-15015 April 2014 Exhibit 7 - Request for Additional Information (Rai), April 15, 2014 ML14113A0012014-04-14014 April 2014 Exhibit 3 - Declaration of Victoria Clemons ML14058A6822014-02-27027 February 2014 Certificate of Service of Petition to Suspend ML14058A6832014-02-27027 February 2014 Petition to Suspend Reactor Licensing Decisions and Reactor Re-Licensing Decisions Pending Completion of Rulemaking Proceeding Regarding Environmental Impacts of High-Density Pool Storage of Spent Fuel and Mitigation Measures ML14112A0092014-02-19019 February 2014 Exhibit 1 - Preliminary Notice of Event or Occurrence, February 19, 2014 ML14112A0032014-02-15015 February 2014 Exhibit 2 - Toledo Blade Article, Davis-Besse Had Air Gap in Shield Building, February 15, 2014 ML13277A7252013-10-0303 October 2013 Intervenors' Memorandum in Opposition to 'Fenoc'S Petition for Certification of Waste Confidence-Related Question to the Commission Pursuant to 10CFR2.323(f)(2).' ML13266A4322013-09-23023 September 2013 Fenoc'S Petition for Certification of Waste Confidence-Related Question to the Commission Pursuant to 10 C.F.R. Section 2.32.(f)(2) ML14112A0042013-09-20020 September 2013 Exhibit 6 - Preliminary Notice of Event or Occurrence, September 20, 2013 ML13192A2842013-07-11011 July 2013 Firstenergy Nuclear Operating Company'S Answer Supporting the NRC Staff'S Motion to Strike Portions of Petitioners Reply ML13192A5052013-07-11011 July 2013 Petitioners' Reply in Opposition to NRC Staff Motion to Strike ML13190A2162013-07-0808 July 2013 Petitioners' Reply in Opposition to FENOC 'Motion to Strike' ML13182A4792013-07-0101 July 2013 NRC Staff Motion to Strike Portions of Joint Petitioners Reply or, in the Alternative, for Leave to Reply ML13179A4032013-06-28028 June 2013 Firstenergy Nuclear Operating Company'S Motion to Strike Portions of Petitioners' Reply ML13173A0012013-06-21021 June 2013 Petitioners' Reply in Support of Petition to Intervene and for an Adjudicatory Public Hearing of FENOC License Amendment Request ML14112A0062013-05-20020 May 2013 Exhibit 8 - Expert Witness Report of Arnold Gundersen, 50-246-LA ML12334A2602012-11-29029 November 2012 Joint Proposed Corrections to the Transcript of the Oral Argument Held on November 5-6, 2012 ML12304A0652012-10-30030 October 2012 Motion to File Intervenors' Motion for Reconsideration of ASLB Order Granting Fenoc'S Motion to Strike Nunc Pro Tunc ML12297A3532012-10-22022 October 2012 Intervenors' Motion for Reconsideration of ASLB Order Granting Fenoc'S Motion to Strike Intervenors' Reply in Opposition to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis-Source Terms) ML12278A0402012-10-0404 October 2012 Intervenors' Response in Opposition to Fenoc'S Motion to Strike 'Intervenors' Reply in Opposition to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis - Source Terms).' ML12268A3762012-09-24024 September 2012 Fenoc'S Motion to Strike Intervenors' Reply in Opposition to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis - Source Terms). ML12258A7772012-09-14014 September 2012 Intervenors' Reply in Opposition to 'Firstenergy'S Motion for Summary Disposition of Contention 4 (Sama Analysis - Source Terms).' ML12237B1972012-08-24024 August 2012 Intervenors' Combined Reply to NRC and FENOC Answers to Inervenors' Third and Fourth Motions to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking) Information Notice 2010-12, Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Contain2012-08-17017 August 2012 Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Containment Liner Cor Information Notice 2010-12, Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notic2012-08-17017 August 2012 Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Containment Liner Cor Information Notice 2010-12, Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Con2012-08-17017 August 2012 Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Containment Liner Cor ML12230A0032012-08-17017 August 2012 Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-49 Through B-50) ML12230A0022012-08-17017 August 2012 Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-44 Through B-48) ML12230A0012012-08-17017 August 2012 Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-39 Through B-43) ML12230A0002012-08-17017 August 2012 Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Response (B-33 Through B-38) ML12229A5872012-08-16016 August 2012 Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix III: NRC FOIA Responses (B-24 Through B-26) 2015-09-04
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KRAS 78 62 DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION April 29, 2004 (4:37PM)
ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETARY Before Administrative Judges: RULEMAKINGS AND G. Paul Bollwerk, III, Chairman ADJUDICATIONS STAFF Dr. Charles N. Kelber Dr. Peter S. Lam In the Matter of ) Docket No. 50-346-CO FirstEnergy Nuclear Operating Co. ) ASLB No. 04-825-01-CO Davis-Besse Nuclear Power Station, Unit 1 ) April 29, 2004 PETITIONERS' MOTION FOR EXTENSION OF TIME TO REPLY TO FENOC AND STAFF RESPONSES TO OBJECTIONS Now come Michael Keegan, Donna Lueke, Joanne DiRando, and Nuclear Information and Resource Service (by Paul Gunter), Petitioners herein, and move the Board for leave to file on or before May 13, 2004 their replies to the responses filed by FirstEnergy Corp. and the NRC staff to the March 29, 2004 "Objections to Confirmatory Order Modifying License."
Presently, Petitioners' reply is due May 3, 2004.
FENOC and the NRC have, between them, filed approximately 30 total pages of factual and legal argument in opposition to the "Objections." A ruling favorable to them would be potentially dispositive of the issues raised by Petitioners. Each respondent took some 24 days to prepare and file its response. Fairness suggests that Petitioners ought to have at least 20 days to prepare theirs.
Counsel for both FENOC and the NRC have signified via electronic message that neither respondent has an objection to the grant of this request.
While counsel for Petitioners acknowledges that he has not tendered this Motion within the three business days prior to the Tezrplate= SEc y- -Il sEc -6_
current May 3, 2004 deadline as contemplated by the Board,' it is being submitted two (2) days in advance, and hopefully the Board will agree that this noncontroversial request should be granted in the interests of justice.
WHEREFORE, Petitioners pray the Board grant them until May 13, 2004 to file their replies. AV411 /
Terry J. Lo ge Counsel for Individual Petitioners See April 15, 2004 "Memorandum and Order" in this proceeding, p. 5.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
G. Paul Bollwerk, III, Chairman Dr. Charles N. Kelber Dr. Peter S. Lam In the Matter of )
FirstEnergy Nuclear Operating Co. ) Docket No. 50-346-CO Davis-Besse Nuclear Power Station, Unit 1 ) April 29, 2004 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing PETITIONERS' MOTION FOR EXTENSION OF TIME TO REPLY TO FENOC AND STAFF RESPONSES TO OBJECTIONS have been served upon the following persons via deposit of paper copies in the U.S. first-class mail as indicated by an asterisk
(*), and via electronic mail as indicated by a double asterisk (**):
Office of Commission Appellate Adjudication* **
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Administrative Judge G. Paul Bollwerk, III, Chair* **
Atomic Safety and Licensing Board Panel Mail Stoip - T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 E-mail: gpb@nrc.gov Administrative Judge Charles N.. Kelber* **
Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: cnk@nrc.gov Administrative Judge Peter S. Lam* **
Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Washington; DC 20555-0001 E-mail: psl@nrc.gov
Lew W. Myers*
Chief Operating Officer FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State Route 2 Oak Harbor, OH 43449-9760 E-mail: lwmyers@firstenergycorp.com Steven P. Frantz, Esq.**
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Ave., N.W.
Washington, DC 20004 E-mail: sfrantz@morganlewis.com Lisa Clark, Esq.**
Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop 0 15-D21 Washington, D.C. 20555 lbc@nrc.gov 7.110T Counsel for Individual Petitioners