ML092260794

Certificate of Counsel in Support of Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energy'S Petition to Intervene and Admit Them as Interveners

ML092260794
Person / Time
Site:	Watts Bar
Issue date:	08/14/2009
From:	Curran D Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-391-OL, ASLBP No. 09-893-01-OL-BD01, RAS 16204
Download: ML092260794 (2)

Text

August 14, 2009 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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Tennessee Valley Authority ) Docket No. 50-391

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(Watts Bar Unit 2) )

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CERTIFICATE OF COUNSEL IN SUPPORT OF MOTION TO PERMIT LATE ADDITION OF CO-PETITIONERS TO SOUTHERN ALLIANCE FOR CLEAN ENERGYS PETITION TO INTERVENE AND ADMIT THEM AS INTERVENORS Pursuant to 10 C.F.R. § 3.232(b), I certify that on August 13, 2009, I contacted counsel for the Tennessee Valley Authority and the Nuclear Regulatory Commission Staff in a sincere effort to resolve the issues raised by Petitioners Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energys Petition to Intervene and Admit them as Intervenors. However, I was unsuccessful.

Electronically signed by Diane Curran HARMON, CURRAN, SPIELBERG & EISENBERG, L.L.P.

1726 M St. NW, Suite 600 Washington, D.C. 20036 Tel: (202) 328-3500 Fax: (202) 328-6918 dcurran@harmoncurran.com mfraser@harmoncurran.com August 14, 2009

CERTIFICATE OF SERVICE I certify that on August 14, 2009, I posted on the NRCs Electronic Information Exchange System copies of the foregoing Certificate of Counsel in Support of Petitioners Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energys Petition to Intervene and Admit them as Intervenors. It is my understanding that as a result, the following parties were served:

Edward J. Vigluicci, Esq.

Office of the General Counsel Tennessee Valley Authority 400 West Summit Hill Drive, WT 6A-K Knoxville, TN 37902 ejvigluicci@tva.gov David E. Roth, Esq.

Office of General Counsel U.S. Nuclear Regulatory Commission Mail Stop - O-15D21 Washington, D.C. 20555 David.roth@nrc.gov Kathryn M. Sutton, Esq.

Paul M. Bessette, Esq.

Morgan, Lewis & Bockius, L.L.P.

1111 Pennsylvania Avenue N.W.

Washington, D.C. 20004 ksutton@morganlewis.com pbessette@morganlewis.com NRC Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hearing.docket@nrc.gov NRC Office of Appellate Commission Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ocaamail.resource@nrc.gov Electronically signed by Diane Curran 2