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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
UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT CONNECTICUT COALITION )
AGAINST MILLSTONE )
Petitioner, )
) No. 04-3577-ag
- v. )
U.S. NUCLEAR REGULATORY COMMISSION,)
Respondent. )
UNOPPOSED MOTION OF DOMINION NUCLEAR CONNECTICUT, INC FOR LEAVE TO INTERVENE Dominion Nuclear Connecticut, Inc. ("DNC") respectfully moves, pursuant to 28 U.S.C § 2348 and F.R.A.P 15(d), for leave to intervene in the above-entitled action. In support of this motion, DNC states the following:
- 1. Petitioner Coalition Against Millstone ("CCAM") is seeking review of a Memorandum and Order of the Nuclear Regulatory Commission ("NRC") relating to a request by CCAM for a hearing on DNC's application to renew the operating licenses for the Millstone Power Station, Units 2 and 3.
- 2. DNC is the NRC-licensed operator of the Millstone Power Station, the sole owner of Unit 2, and the majority owner of Unit 3. CCAM's challenge to the NRC's Memorandum and Order directly effects the renewal of the operating licenses for these units. Thus, DNC has a substantial, direct and tangible interest in the ultimate resolution of this proceeding. Although the NRC is a Respondent with respect to CCAM's petition for review, DNC has a separate
interest apart for the regulatory interests of the NRC. It is therefore submitted that DNC is entitled to intervene in this proceeding.
- 4. Counsel for the NRC and Counsel for CCAM have authorized DNC to state that their clients do not oppose DNC's intervention in this matter.
Wherefore, DNC requests that it be granted leave to intervene as a party respondent in the above captioned proceeding, Respectfully submitted, Lillian M. Cuoco David R. Lewis.
Dominion Resources Services, Inc. Matias Travieso-Diaz.
Millstone Power Station Rope Ferry Road SHAW PI=IMAN, LLP Waterford, CT 06835 2300 N. Street, N.W.
Washington, D.C. 20037 (202) 663-8000 Counsel for Dominion Nuclear Connecticut, Inc.
Dated: July 19,2004 2
UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT CONNECTICUT COALITION )
AGAINST MILLSTONE )
Petitioner, )
) No. 04-3577-ag V. )
U.S. NUCLEAR REGULATORY COMMISSION,)
Respondent. )
CORPORATE DISCLOSURE STATEMENT OF DOMINION NUCLEAR CONNECTICUT. INC.
Pursuant to Fed. R. App. P. 26. 1, Dominion Nuclear Connecticut, Inc. ("DNC") hereby files this Disclosure Statement.
DNC is a corporation organized under the laws of the State of Delaware, with its principal place of business in Connecticut. DNC is the licensed owner and operator of Millstone Power Station, Units 1, 2 and 3, and is principally engaged in the business of generating electricity.
DNC is an indirect wholly-owned subsidiary of Dominion Resources, Inc. ("DRI").
DNC is owned directly by Dominion Energy Marketing, Inc. and Dominion Nuclear Marketing III, L.L.C., which collectively own 100 percent of DNC's stock. Other intermediate subsidiaries in the organization between DRI and one or more of the two direct owners of DNC are:
Dominion Energy, Inc.; Dominion Nuclear Holdings, Inc.; Dominion Retail, Inc.; and
Consolidated Natural Gas Company. There are no other publicly held corporations owning ten percent or more of DNC's stock.
Respectfully submitted, By:A 'JL David R. Lewis Matias Travieso-Diaz SHAW PITTMAN, LLP 2300 N. Street, N.W.
Washington, D.C. 20037 (202) 663-8474 Counsel for Dominion Nuclear Connecticut Inc.
Dated: July 19, 2004 2
UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Thurgood Marshall U.S. Courthouse at Foley Square 40 Centre Street, New York, NY 10007 Telephone: 212-857-8500 MOTION INFORMATION STATEMENT Caption [use short titlel Docket Number(s): 04-3577-ag Connecticut Coalition Against Millstone v.
U.S. Nuclear Regulatory Commission Motion for: Leave to Intervene Set forth below precise, complete statement of relief sought:
Dominion Niirlpnr rnnnPt-tiriit Tn -- th . majority owner and operator of the Millstone Power Station, and the applicant in the administrative proceeding to which the Petition for review relates, seeks to intervene as a party-respondent.
MOVING PARTY: Dominion Nunlenr onnnPrtieiit- TIQP.POSING PARTY: Connect-icut Cnonlii-inn Agninqt O Plaintiff 0 Defendant Millstone o Appellant/Petitioner 3 Appellee/Respondent MOVINGATTORNEY: navid R. TP 1.Pic OPPOSING ATTORNEY [Name]: Nancy Burton
[name of attorney, with firm, address, phone number and e-mail] [name of attorney, with firm, address, phone number and e-mail]
Shaw Pittman. LTP 147 Cross Highwav 21nO N 9trPot- NWL Redding Ridge, Cux 0b5/6 Wl aciQitgtnit 1' C 9'0037 (ZU3)938-3952 (202d eis-A47m aincvBurtonEsq@aol.com david lewis~shawsittman.com Court-Judge/Agency appealed from: U.S. Nuclear Regulatory Commission Please check appropriate boxes: FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS AND INJUNCTIONS PENDING APPEAL:
Has consent of opposiuig counsel: Has request for relief been made below? 3 Yes D No A. been sought? 0l Yes 3 No B. been obtained? X Yes 0 No Has this relief been previously sought in this Court? D Yes O No Is oral argument requested? 0 Yes 13 No (requests for oral argument will not necessarily be granted) Requested return date and explanation of emergency:
Has argument date of appeal been set? 0 Yes X No If yes, enter date tur torAttorney:
Date: 7/19c / a Has service been effected? X Yes 0 No
[Attach proof of service]
ORDER IT IS HEREBY ORDERED THAT the motion is GRANTED DENIED.
FOR THE COURT:
ROSEANN B. MacKECHNIE, Clerk of Court Date: By:
Form T-1080 (Revised 10/31/02).
CERTIFICATE OF SERVICE I hereby certify that true copies of the foregoing pleadings were served upon the following by deposit in the United States mail, first class, postage prepaid, on this 19th day of July, 2004.
John F. Cordes, Esq.
Solicitor U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Annette Vietti-Cook Secretary to the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Environmental Division, Appellate Section U.S. Department of Justice Washington, D.C. 20530 Nancy Burton, Esq.
147 Cross Highway Redding Ridge, CT 06876 David R. Lewis Counsel for Dominion Nuclear Connecticut, Inc.
