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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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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of: ) Docket No. 50-346-L FirstEnergy Nuclear Operating Company ) November 11, 2014 Davis-Besse Nuclear Power Station, Unit 1
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NOTICE OF FILING OF RILEY EMAIL (EXHIBIT A TO CONTENTION NO. 7)
Now come Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario (CEA), Dont Waste Michigan, and the Green Party of Ohio (collectively, Intervenors), by and through counsel, and give notice of their filing hereby of the May 8, 2012 email from Timothy Riley of NRCs office of OCA to Ohios two U.S. Senators (Exh. A to Intervenors September 8 Amended Motion filing on Contention 7). Exhibit A was erroneously not attached to the Amended Motion but is alleged to have been attached at p. 8 of the Amended Motion.
In the email, Mr. Riley noted that FENOC concluded in its Shield Building Root Cause Report dated February 27, 2012, that the SB [Shield Building], with the laminar cracking in its walls, was operable but non-conforming to the current design and licensing bases with regard to the design stress analysis methodology, and the tornado allowable stress values.
/s/ Terry J. Lodge Terry J. Lodge (Ohio Bar #0029271) 316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 Phone/fax (419) 255-7552 tjlodge50@yahoo.com Counsel for Intervenors UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of: ) Docket No. 50-346-L FirstEnergy Nuclear Operating Company ) November 11, 2014 Davis-Besse Nuclear Power Station, Unit 1
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CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Notice of Filing of Riley Email (Exhibit A to Contention No. 7) was deposited in the NRCs Electronic Information Exchange this 11th day of November, 2014 and was served upon all parties of record.
Executed in Accord with 10 C.F.R. § 2.304(d)
/s/ Terry J. Lodge Terry J. Lodge (Ohio Bar #0029271) 316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 Phone/fax (419) 255-7552 tjlodge50@yahoo.com Counsel for Intervenors