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Category:Legal-Pleading
MONTHYEARML19221B7252019-08-0909 August 2019
Applicants' Answer Opposing the Environmental Law & Policy Center'S Petition to Intervene and Hearing Request
ML15138A1542015-05-18018 May 2015
FENOC Answer Opposing Motion to Amend Placeholder Contention
ML15138A0662015-05-18018 May 2015
NRC Staff Answer to Motion to Amend
ML15127A2512015-05-0707 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
ML15126A4782015-05-0606 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
ML15124A7652015-05-0404 May 2015
Firstenergy Nuclear Operating Company Response Opposing Motion to Reopen and Placeholder Contention Regarding Continued Storage Rule
ML15121A4992015-05-0101 May 2015
NRC Staff Answer to Beyond Nuclear'S Hearing Request and Petition to Intervene and Motion to Reopen the Record in the License Renewal Proceeding for Davis-Besse Nuclear Power Plant
ML14304A7202014-10-31031 October 2014
Firstenergy Nuclear Operating Co., Combined Response to Proposed Contention and Petition to Suspend Related to Alleged Need for Issuance of Waste Confidence Safety Findings
ML14304A6872014-10-31031 October 2014
NRC Staff Consolidated Answer to Petitions to Suspend Final Reactor Licensing Decisions, Motions to Admit a New Contention, and Motions to Reopen the Record
ML14304A6452014-10-31031 October 2014
Inc.'S Motion for Leave to File Amicus Curiae Brief
ML14136A4862014-05-16016 May 2014
Fenoc'S Answer Opposing Intervenors'S Motion for Admission of Contention No. 6
ML14136A3272014-05-16016 May 2014
NRC Staff'S Answer to Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems
ML14087A0252014-03-28028 March 2014
March 2014 Status Update Letter
ML14080A2352014-03-21021 March 2014
NRC Staff Answer Opposing Suspension Petition
ML14080A5932014-03-21021 March 2014
Firstenergy Nuclear Operating Company Response to Petition to Suspend Licensing Decisions Pending Completion of Rulemaking
ML13189A3272013-07-0808 July 2013
NRC Staff Answer to Firstenergy Nuclear Operating Company Motion to Strike
ML13165A3512013-06-14014 June 2013
NRC Staff Answer to the Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Don'T Waste Michigan, and Ohio Sierra Club Joint Request for a Hearing and Petition to Intervene
ML13165A3022013-06-14014 June 2013
Firstenergy Nuclear Operating Company'S Answer Opposing Petition to Intervene and Request for Hearing Regarding Technical Specification License Amendment Request
ML13155A2852013-06-0404 June 2013
Notice of Appearance of Mitzi A. Young on Behalf of the U.S. Nuclear Regulatory Commission in the Matter of Davis-Besse Nuclear Power Station, Unit 1
ML13141A2502013-05-20020 May 2013
Petition to Intervene and for an Adjudicatory Public Hearing of FENOC License Amendment Request
ML12306A2732012-11-0101 November 2012
Fenocs Answer Opposing Intervenors' Motion for Reconsideration of Order Striking Intervenors' Answer to Fenocs Motion for Summary Disposition of Contention 4
ML12305A2782012-10-31031 October 2012
NRC Staff'S Answer to 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)
ML12258A3112012-09-14014 September 2012
Attachment E - NRC Staff Answer to Motion for Summary Disposition of Contention 4
ML12258A3072012-09-14014 September 2012
Attachment D - NRC Staff Answer to Motion for Summary Disposition of Contention 4
ML12258A3082012-09-14014 September 2012
the Staff'S Response to Firstenergy'S Statement of Materials Facts
ML12258A3092012-09-14014 September 2012
Attachment a - NRC Staff Answer to Motion for Summary Disposition of Contention 4
ML12258A3062012-09-14014 September 2012
Attachment B - NRC Staff Answer to Motion for Summary Disposition of Contention 4
ML12258A3122012-09-14014 September 2012
K. Ross Statement of Professional Qualifications
ML12258A3142012-09-14014 September 2012
NRC Staff'S Answer to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis Source Terms)
ML12258A3132012-09-14014 September 2012
Affidavit of Kyle W. Ross Concerning the Motion for Summary Disposition of Contention 4
ML12254B0862012-09-10010 September 2012
Fenoc'S Answer Opposing Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking)
ML12254A1382012-09-10010 September 2012
NRC Staff'S Answer to Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking)
ML12230A3182012-08-17017 August 2012
Fenoc'S Answer Opposing Intervenors' Third and Fourth Motions to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking)
ML12230A2122012-08-17017 August 2012
NRC Staff'S Answer to Intervenors' Third and Fourth Motions to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking)
ML12216A1452012-08-0303 August 2012
Fenoc'S Answer Opposing New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at Davis-Besse Nuclear Power Station
ML12215A5072012-08-0202 August 2012
NRC Staff'S Answer to Intervenor'S Motion for Leave to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Nuclear Waste at Davis-Besse Nuclear Power Station
ML12215A2952012-08-0202 August 2012
NRC Staff'S Unopposed Motion for Extension of Time to File an Answer to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis Source Terms)
ML12208A4292012-07-26026 July 2012
Attachment 1, Firstenergy Statement of Material Facts on Which There Is No Genuine Issue to Be Heard (July 26, 2012)
ML12208A4302012-07-26026 July 2012
List of Attachments to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis Source Terms)
ML12181A3032012-06-29029 June 2012
Fenoc'S Answer Opposing Intervenors' Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking)
ML12181A0132012-06-29029 June 2012
NRC Staff'S Answer to Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking)
ML12177A0282012-06-25025 June 2012
NRC Staff'S Answer to Petition to Suspend Final Decisions in All Pending Reactor Licensing Proceeding Pending Completion of Remanded Waste Confidence Proceedings
ML12177A2002012-06-25025 June 2012
Fenoc'S Answer Opposing Petition to Suspend Final Licensing Decisions Pending Completion of Remanded Waste Confidence Proceedings
ML12118A5402012-04-27027 April 2012
Notices of Appearance of Paul M. Bessette and Stephen J. Burdick
ML12118A5412012-04-27027 April 2012
Joint Answer Opposing Hearing Requests Regarding Sufficiency of Order EA-12-051 Modifying Licenses with Regard to Spent Fuel Pool Instrumentation
ML12110A4702012-04-19019 April 2012
Notice of Appearance Withdrawal of Alex Polonsky
ML12110A4662012-04-19019 April 2012
Notice of Appearance Withdrawal of Brooke Leach
ML12068A0952012-03-0808 March 2012
NRC Staff'S Answer to Intervenor'S Motion to Amend 'Motion for Admission of Contention No. 5.'
ML12068A4292012-03-0808 March 2012
Fenoc'S Answer Opposing Intervenors' Motion to Amend Proposed Contention 5 on Shield Building Cracking
ML12068A0942012-03-0808 March 2012
Attachment C - NRC Staff Affidavit of Abdul H. Sheikh Concerning Intervenors' Motion to Amend Motion for Admission of Contention No. 5
2019-08-09
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Text
Attachment B Harris, Brian From: Harris, Brian Sent: Monday, February 27, 2012 11:11 AM To: 'Terry Lodge'; Timothy P.Matthews Cc: Kanatas, Catherine; Subin, Lloyd
Subject:
RE: Davis-Besse Contention 5 (proposed motion to amend/consultation)
- Terry, Based on the timing of your request for consultation and its short deadline for response, the NRC Staff reserves the right to oppose the motion to amend the proposed Contention 5 once it is filed.
Best regards, Brian G. Harris Office of the General Counsel Nuclear Regulatory Commission 301.415.1392 brian.harris@nrc.gov Official Use Only -- Attorney Client Privilege/Work Product Doctrine
Original Message-----
From: Terry Lodge [1]
Sent: Sunday, February 26, 2012 11:53 AM To: Timothy P.Matthews Cc: Kanatas, Catherine; Harris, Brian; Subin, Lloyd
Subject:
Davis-Besse Contention 5 (proposed motion to amend/consultation)
Counsel, by this email I'm requesting FENOC's and the NRC Staff's nonopposition to a motion to amend our proposed Contention 5 by alleging the following additional facts:
- 1) That the Davis-Besse shield building cracking was deemed in December 2011 by the NRC staff to be so extensive that the NRC required FirstEnergy to assume, in its calculations of the strength of the wall, that the vertical outer rebar mat did not even exist and that FENOC knew in October 2011 that the cracking was in the area of the main outer rebar and not solely, or primarily, in the architectural regions of the structure.
- 2) The NRC staff's January 31, 2012 inspection report shows that FENOC discovered on October 31, 2011 that the areas of cracking included cracking towards the top of the SB wall, approximately between the 780 ft and 800 ft elevations.
We intend to file a motion on February 27, 2012. Kindly indicate your consent or opposition by noon tomorrow, February 27.
Thank you.
Terry Lodge 1
