|
|---|
Category:Legal-Motion
MONTHYEARML12132A4682012-05-11011 May 2012
Motion to Strike
ML0513902052005-05-13013 May 2005
Duke Energy Corporation'S Opposition to Blue Ridge Environmental Defense League'S Motion to Exceed Page Limitation
ML0505502862005-02-15015 February 2005
Duke Energy Corporation'S Response to the Blue Ridge Environmental Defense League'S Motion to Re-open the Record on Security Contention 5
ML0504901822005-02-15015 February 2005
Catawba - NRC Staff Response in Opposition to Blue Ridge Environmental Defense League'S Motion to Re-Open the Record on Security Contention 5
ML0504700292005-02-15015 February 2005
Catawba - NRC Staff'S Response to Bredl'S February 3rd Letter
ML0504503372005-01-31031 January 2005
Duke Energy Corporation'S Motion to Amend Protective Order to Add an Additional Individual to Receive Protected Information
ML0502502522005-01-24024 January 2005
Catawba - Corrected Certificate of Service to the NRC Staff'S Motion to Amend December 15, 2003 Protective Order
ML0502502492005-01-21021 January 2005
Catawba - NRC Staff'S Motion to Amend December 15, 2003 Protective Order
ML0500602012004-12-22022 December 2004
Blue Ridge Environmental Defense League'S Opposition to NRC Staff'S Motion for Interlocutory Review of ASLB Ruling Amending Protective Order
ML0436402832004-12-22022 December 2004
Response of Duke Energy Corporation to NRC Staff'S Motion for Expedited Interlocutory Review
ML0436400962004-12-21021 December 2004
Catawba MOX - NRC Staff'S Motion for Interlocutory Review of the Licensing Board'S December 17, 2004 Order Amending the Protective Order and Request for Expedited Review
ML0500501202004-12-20020 December 2004
Catawba - NRC Staff'S Motion for Stay Pending Interlocutory Review of the Licensing Board'S December 17, 2004 Order Amending Protective Order
ML0435503702004-12-20020 December 2004
Letter from Diane Curran to Emile Julian Enclosing Blue Ridge Environmental Defense League'S Motion for Leave to File Prefiled Written Testimony Out of Time
CY-03-215, Blue Ridge Environmental Defense League'S Motion for Leave to Reply to NRC Staff'S Response to Need-to-Know Appeal with Accompanying Reply2004-12-15015 December 2004
Blue Ridge Environmental Defense League'S Motion for Leave to Reply to NRC Staff'S Response to Need-to-Know Appeal with Accompanying Reply
ML0500404622004-12-15015 December 2004
Catawba MOX - NRC Staff'S Response to Bredl'S Appeal of Staff'S Adverse Need-to-Know Determination Regarding SECY-03-215
ML0435700192004-12-15015 December 2004
Blue Ridge Environmental Defense League'S Motion to Amend Protective Order
ML0432803532004-11-22022 November 2004
Catawba - NRC Staff Response to Bredl Motion for Imposition of Interim Discovery Measures to Compensate for Unavailability of ADAMS
ML0433501362004-11-15015 November 2004
Duke Energy Corporation'S Response to Bredl Motion for Imposition of Interim Discovery Measures and Delay in the Hearing Schedule
ML0431703692004-11-0505 November 2004
Motion for Approval of Consent Order Regarding Document Discovery; Consent Order Regarding Document Discovery; Blue Ridge Environmental Defense League'S Motion for Imposition of Interim Discovery Measures to Compensate.
ML0430904602004-10-28028 October 2004
Duke Energy Corporation'S Response to Motion for Reconsideration of CLI-04-29
ML0430104462004-10-18018 October 2004
Blue Ridge Environmental Defense League'S Motion for Reconsideration of CLI-04-29
ML0426703602004-09-22022 September 2004
Catawba - NRC Staff'S Motion to Amend December 15, 2003 Protective Order
ML0426800692004-09-17017 September 2004
Duke Energy Corporation'S Opposition to Blue Ridge Environmental Defense League'S Motion to Compel Production of the Proposed Security Plan for Catawba Nuclear Station
ML0426401042004-09-0707 September 2004
Blue Ridge Environmental Defense League'S Motion to Compel Production of Revision 17 of Security Plan for Catawba Nuclear Power Plant
ML0425702412004-09-0707 September 2004
Catawba - NRC Staff Response to Intervenor'S Motion Requesting Access to Certain Classified Documents
ML0425303862004-08-31031 August 2004
Duke Energy Corporation'S Response to Blue Ridge Environmental Defense League'S Request for Need-to-Know Determination on Classified Regulatory Guidance for NRC Category I Facilities
ML0424701652004-08-27027 August 2004
Duke Energy Corporation'S Request for Action Under Subpart I of 10 C.F.R. Part 2
ML0424402492004-08-26026 August 2004
Blue Ridge Environmental Defense League'S Request for Need-to-Know Determination
ML0421605462004-07-27027 July 2004
Duke Energy Corporation'S Motion to Modify December 15. 2003 Protective Order
ML0421003572004-07-20020 July 2004
Blue Ridge Environmental Defense League'S Opposition to NRC Staff'S Motion for Leave to Reply to Bredl'S Opposition
ML0420301732004-07-19019 July 2004
Catawba - NRC Staff'S Motion for Leave to Reply to Bredl'S Opposition to NRC Staff'S Petition for Review Regarding Bredl'S Security Expert and NRC Staff'S Reply to Bredl'S Response to Staff'S Petition for Review
ML0419803032004-07-0808 July 2004
Duke Energy Corporation Motion to Compel Discovery Responses from Blue Ridge Environmental Defense League Relating to Security Contention 5
ML0419802952004-07-0808 July 2004
Letter from Diane Curran to Administrative Judges Enclosing Blue Ridge Environmental Defense League'S Motion to Compel Security-Related Discovery Responses by NRC Staff
ML0419003282004-07-0707 July 2004
Catawba - NRC Staff'S Motion to Compel Bredl to Respond to NRC Staff'S First Set of Discovery Requests on Security Contention 5
ML0418400042004-06-30030 June 2004
Catawba - NRC Staff'S Petition for Review of the Licensing Board'S Ruling Related to Bredl'S Proffered Security Expert
ML0418400022004-06-30030 June 2004
Catawba - NRC Staff'S Motions for Temporary Stay to Preserve the Status Quo and for Stay Pending Interlocutory Review of the Licensing Board'S June 25, 2004 Finding Regarding Dr. Edwin Lyman'S Expertise
ML0417503272004-05-21021 May 2004
Blue Ridge Environmental Defense League'S Motion for Leave to Withdraw Contention II and Request to Change Hearing Schedule for Contention I
ML0414004642004-05-11011 May 2004
Duke Energy Corporation'S Motion to Modify Protective Order
ML0411900812004-04-19019 April 2004
Blue Ridge Environmental Defense League'S Proposed Hearing Schedule and Request for Reconsideration of Aslb'S Internal Deadline of August 2004 for Issuing a Decision in This Proceeding
ML0411900752004-04-19019 April 2004
Blue Ridge Environmental Defense League'S Motion for Clarification or Reconsideration April 8, 2004, Order
ML0411107922004-04-16016 April 2004
NRC Staff'S Motion to Compel Blue Ridge Environmental Defense League to Respond to NRC Staff'S First Set of Interrogatories and Request for Production of Documents
ML0410001092004-04-0202 April 2004
Duke Energy Corporation'S Motion for Protective Order
ML0409202502004-03-30030 March 2004
Nuclear Regulatory Commission Staff'S Response to Duke Energy Corporation'S Motion to Dismiss Contention III
ML0409203312004-03-25025 March 2004
Blue Ridge Environmental Defense League'S Opposition to Duke Energy Corporation'S Motion to Dismiss Contention III
ML0408306822004-03-15015 March 2004
Duke Energy Corporation'S Motion to Dismiss Contention III
ML0405004752004-02-11011 February 2004
Certificate of Service for NRC Staff'S Petition for Review of the Licensing Board'S February 4, 2004 Order Relating to Bredl'S Request to Attend a Closed Meeting.
ML0405004672004-02-11011 February 2004
Affidavit of John A. Nakoski in Support of NRC Staff Request for Interlocutory Review
ML0404202532004-02-0303 February 2004
Blue Ridge Environmental Defense League'S Emergency Motion for Access to NRC Staff Meeting on February 6, 2004
ML0403604932004-02-0202 February 2004
Catawba -- NRC Staff'S Motion for Interlocutory Review of the Licensing Board'S January 29, 2004 Order Finding a Need-To-Know and Ordering NRC Staff to Provide Petitoner with Acess to Documents Containing Safeguards Information (Superceded)
ML0403604702004-01-30030 January 2004
Catawba MOX - NRC Staff'S Motions for Temporary Stay to Preserve the Status Quo and for Stay Pending Interlocutory Review of the Licensing Board'S January 29, 2004 Order Regarding Access to NRC Documents Containing Safeguards Information
2012-05-11
[Table view] |
Text
V-HARMON, CURRAN, SPIELBERG Q-;..--- EISENBERG, LLP 1726 M Street, NWSuite 600 W-ashington, DC 20036 .- (202)328-3500 (202)328-6918fix December 20, 2004 DOCKETED BY HAND DELIVERY USNRC December 20, 2004 (10:29am)
Emile Julian Assistant for Rulemakings and Adjudications OFFICE OF SECRETARY RULEMAKINGS AND Office of the Secretary ADJUDICATIONS STAFF U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Safeguarls Filing in Duke LTA Proceedling, ANos.
50-413, 50414
Dear Mr. Julian,
Enclosed please find two copies of the Prefiled Written Testimony of Dr. Edwin S.
Lyman Regarding Blue Ridge Environmental Defense League's Security Contention 5, along wvith a set of exhibits.
Please note that Dr. Lyman's testimony and Exhibit 2 contain safeguards information.
Exhibit 2 is clipped separately from the other exhibits, in order to ensure that its safeguards status is not overlooked.
I am also enclosing the original and three copies of a motion for leave to file Dr. Lyman's testimony out of time.
As indicated on the service list that is attached to the motion, these pleadings have been served on the Atomic Safety and Licensing Board ("ASLB") and the parties by hand and by Federal Express courier service, in accordance with the requirements of the ASLB's December 15, 2003, Protective Order in this proceeding.
Sincerely, aneCirran cc w/o enclosures: service list i( /a&ecs~c Y-o4( 5
December 20, 2004 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No's. 50-413-OLA, DUKE ENERGY CORPORATION 50-414-OLA (Catawba Nuclear Station, Units 1 and 2)
BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE'S MOTION FOR LEAVE TO FILE PREFILED WRITTEN TESTIMONY OUT OF TIME Blue Ridge Environmental Defense League ("BREDL") hereby moves for leave to file the Prefiled Written Testimony of Dr. Edwin S. Lyman Regarding Blue Ridge Environmental Defense League's Security Contention 5 out of time. The testimony, which was due by close of business on Friday December 17, 2004, is being filed today.
BREDL respectfully submits that its counsel and expert have diligently attempted to meet their obligations throughout this proceeding, including complying with the December 17, 2004, deadline for the filing of prefiled testimony. However, because of a family emergency late in the afternoon of December 17, BREDL's counsel had to leave her office around 4:15 p.m., before she had finished proof-reading Dr. Lyman's testimony or assembled all of the exhibits. In addition, BREDL's counsel was somewhat delayed in completing these tasks by Friday's two telephone conferences with the Atomic Safety and Licensing Board, which together took about two hours.
BREDL has tried to minimize any prejudice to the other parties that may be caused by this delay, by ensuring that the testimony and exhibits are ready for service before 9 a.m. on Monday morning, December 20. BREDL has also arranged for same-
day courier service on Duke Energy Corporation's in-house counsel in Charlotte, North Carolina. The package is expected to arrive in Charlotte before noon on Monday, December 20.
Therefore, BREDL respectfully submits that the requested extension should be granted because it is justified and will not unduly prejudice the other parties.
Counsel for Duke Energy Corporation, whom BREDL contacted on Friday afternoon, has stated that Duke intends to oppose this motion. Counsel for BREDL was unable to reach counsel for the NRC Staff before filing this motion.
Respectfully submitted, Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1726 M Street N.W., Suite 600 W'ashington, D.C. 20036 202/328-3500 e-mail: Dcurraneharmoncurran.com December 20, 2004 2
CERTIFICATE OF SERVICE I hereby certify that on December 20, 2004, copies of Prefiled Written Testimony of Dr. Edwin S.
Lyman Regarding Blue Ridge Environmental Defense League's Security Contention 5 and Blue Ridge Environmental Defense League's Motion for Leave to File Prefiled Written Testimony Out of Time were served by hand or by Federal Express courier on all of the parties listed below, under the requirements of the Atomic Safety and Licensing Board's Protective Order of December 15, 2003:
Ann Marshall Young, Chair Antonio FemrAndez, Esq.
Atomic Safety and Licensing Board Office of the General Counsel 11545 Rockville Pike Mail Stop 15 D21 Rockville, MD 20852 U.S. Nuclear Regulatory Commission (by hand) 11555 Rockville Pike 301/415-7463 Rockville, MD 20852 (by hand)
Anthony J. Baratta 301/415-7463 Administrative Judge Atomic Safety and Licensing Board Lisa F. Vaughn, Esq.
11545 Rockville Pike Timika Shafeek-Horton, Esq.
Rockville, MD 20852 Legal Dept. (EC-07H)
(by hand) Duke Energy Corporation 301/415-7463 526 South Church Street (ECI IX)
Charlotte, NC 28201-1006 Thomas S. Elleman (by Federal Express courier)
Administrative Judge 704/382-8134 Atomic Safety and Licensing Board 11545 Rockville Pike Rockville, MD 20852 Mark J. Wetterhan, Esq.
(by hand) Anne W. Cottingham, Esq.
301/415-7463 David A. Repka, Esq.
Winston & Strawn, LLP Emile Julian 1400 L Street, N.W.
Assistant for Rulemakings and Adjudications Washington, D.C. 20005-3502 Office of the Secretary (by hand)
U.S. Nuclear Regulatory Commission 202/371-5726 11555 Rockville Pike Rockville, MD 20852 (by hand) 301/415-1966 iane Curran
