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Category:Legal-Pleading
MONTHYEARML21287A6592021-10-14014 October 2021
Notice of Withdrawal of Samuel Reeves Lehman on Behalf of Tennessee Valley Authority
ML21070A3612021-03-11011 March 2021
NRC Staff Answer to the Tennessee Valley Authority'S Motion Regarding Disclosures
ML15173A0332015-06-22022 June 2015
Southern Alliance for Clean Energy'S Reply to Oppositions to Petition for Review of LBP-15-14 Denying Admission of a New Contention Concerning Tva'S Failure to Comply with 10 C.F.R. Section 5.34(b)(4)
ML15163A2142015-06-12012 June 2015
Tennessee Valley Authority'S Answer Opposing Southern Alliance for Clean Energy'S Petition for Review of LBP-15-14
ML15163A1452015-06-12012 June 2015
NRC Staff Answer Opposing the Southern Alliance for Clean Energy Petition for Review of Board Decision LBP-15-14
ML15138A4522015-05-18018 May 2015
Sace Petition for Review of LBP-15-14
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
ML15126A3832015-05-0606 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
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
ML15121A4532015-05-0101 May 2015
NRC Staff Answer to Southern Alliance for Clean Energy'S Hearing Request and Petition to Intervene and Motion to Reopen the Record in the Operating License Proceeding for Watts Bar Unit 2
ML15121A7902015-05-0101 May 2015
TVA Answer to Sace Motions to Reopen and Admit a New Contention
ML15111A3562015-04-21021 April 2015
Southern Alliance for Clean Energy'S Hearing Request and Petition to Intervene in Operating License Proceeding for Watts Bar Unit 2 Nuclear Power Plant
ML15069A4922015-03-10010 March 2015
Southern Alliance for Clean Energy Reply to Oppositions to Motion for Leave to File a New Contention Concerning Tva'S Failure to Comply with 10 C.F.R. Section 50.34(b)(4)
ML15062A3782015-03-0303 March 2015
Tennessee Valley Authority'S Answer Opposing Southern Alliance for Clean Energy'S Motion for Leave to File a New Contention
ML15062A1142015-03-0303 March 2015
NRC Staff'S Answer to Southern Alliance for Clean Energy'S Motion for Leave to File a New Contention
ML15049A6182015-02-18018 February 2015
Petitioners' Reply to Oppositions to Petition to Supplement Reactor-Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage
ML15049A3652015-02-18018 February 2015
NRC Staff'S Answer to Southern Alliance for Clean Energy'S Motion to Reopen the Record
ML15048A0612015-02-17017 February 2015
Tennessee Valley Authority'S Answer Opposing Southern Alliance for Clean Energy'S Motion to Reopen the Record
ML15043A7792015-02-12012 February 2015
NRC Staff Opposition to Petition to Supplement Reactor-Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage
ML15043A5572015-02-12012 February 2015
Tennessee Valley Authority'S Answer Opposing Petition to Supplement Reactor-Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage
ML15037A5492015-02-0606 February 2015
Southern Alliance for Clean Energy'S Unopposed Motion to Permit Corrected Filing
ML15037A3182015-02-0505 February 2015
Refiled Motion for New Contention and Motion to Reopen
ML15028A1132015-01-28028 January 2015
Petition to Supplement Reactor-Specific Environmental Impact Statement Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage
ML14311A9752014-11-0707 November 2014
Petitioners' and Intervenors' Consolidated Reply to Answer to Petitions to Suspend Final Reactor Licensing Decisions, Motions, to Admit a New Contention, and Motions to Reopen the Record
ML14304A7652014-10-31031 October 2014
Tennessee Valley Authority'S Answer to Opposing Petition to Suspend Final Decisions in All Pending Reactor Licensing Proceeding Pending Issuance of Waste Confidence Safety Findings and Motions for Leave to File New Contention
ML14304A7162014-10-31031 October 2014
Tennessee Valley Authority'S Answer Opposing Southern Alliance for Clean Energy'S Motion to Reopen the Record
ML14304A6742014-10-31031 October 2014
Inc.'S Motion for Leave to File Amicus Curiae Brief
ML14304A6682014-10-31031 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
ML14080A4582014-03-21021 March 2014
Tennessee Valley Authority'S Answer Opposing Petition to Suspend Reactor Licensing Decisions & Reactor Re-Licensing Decisions Pending Completion of Rulemaking Proceeding Regarding Environmental Impacts of High-Density Pool Storage of Spent
ML14080A4602014-03-21021 March 2014
Tennessee Valley Authority'S Answer Opposing 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 Spen
ML14080A2542014-03-21021 March 2014
NRC Staff Answer to Opposing Suspension Petition
ML14058A6802014-02-27027 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
ML13196A3552013-07-15015 July 2013
Southern Alliance for Clean Energy'S Unopposed Motion to Withdraw Contention 7
ML13127A3492013-05-0707 May 2013
Notice of Appearance for Anita Ghosh on Behalf of NRC Staff, in the Matter of Tennessee Valley Authority (Watts Bar Nuclear Plant, Unit 2)
ML12362A3162012-12-27027 December 2012
Joint Response to Board Order Notifying Parties of Amendments to Rules of Practice
ML12216A1592012-08-0303 August 2012
Tennessee Valley Authority'S Answer Opposing New Contention Concerning Temporary Storage and Ultimate Disposal of Spent Reactor Fuel at Watts Bar, Unit 2
ML12215A4652012-08-0202 August 2012
NRC Staff'S Answer to Southern Alliance for Clear Energy'S Motion for Leave to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Spent Reactor Fuel at Watts Bar, Units 2
ML12198A3942012-07-16016 July 2012
Certificate of Service for a Letter from Diane Curran to Counsel for TVA and the NRC Staff Regarding Saces Thirtieth Supplement to Its Mandatory Disclosures
ML12191A3832012-07-0909 July 2012
Southern Alliance for Clean Energy'S Motion for Leave to File a New Contention Concerning Temporary Storage and Ultimate Disposal of Spent Reactor Fuel at Watts Bar Unit 2
ML12177A1582012-06-25025 June 2012
Tennessee Valley Authority'S Answer Opposing Petition to Suspend Final Licensing Decisions Pending Completion of Remanded Waste Confidence Proceedings
ML12177A0852012-06-25025 June 2012
NRC Staff'S Answer to Petition to Suspend Final Decisions in All Pending Reactor Licensing Proceedings Pending Completion of Remanded Waste Confidence Proceedings
ML12170B0412012-06-18018 June 2012
Petition to Suspend Final Decisions in All Pending Reactor Licensing Proceedings 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
ML11354A4732011-12-20020 December 2011
Certificate of Service of Copies of the Southern Alliance for Clean Energy'S Opposition to Tva'S Motion for Summary Disposition of Contention 7, Statement of Disputed Material Facts, and Declaration of Shawn Paul Young, Ph.D
ML11354A4722011-12-20020 December 2011
Declaration of Shawn Paul Young, Ph.D. on Behalf of Southern Alliance for Clean Energy
ML11354A4702011-12-20020 December 2011
Southern Alliance for Clean Energy'S Opposition to Tennessee Valley Authority'S Motion for Summary Disposition of Contention 7 Regarding Aquatic Impacts of Watts Bar Unit 2
ML11354A4712011-12-20020 December 2011
Southern Alliance for Clean Energy'S Statement of Disputed Material Facts
ML11354A4032011-12-20020 December 2011
NRC Staff'S Answer to Tva'S Motion for Summary Disposition of Contention 7 Regarding Aquatic Impacts
ML11311A3352011-11-0707 November 2011
Tennessee Valley Authority'S Opposition to Sace'S Motion for Leave to Supplement Its Fukushima-Related New Contention
2021-03-11
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Text
February 6, 2015 United States of America Nuclear Regulatory Commission Before the Commission In the Matter of )
TENNESSEE VALLEY AUTHORITY ) Docket No. 50-391-OL (Watts Bar Nuclear Plant, Unit 2) )
)
SOUTHERN ALLIANCE FOR CLEAN ENERGYS UNOPPOSED MOTION TO PERMIT CORRECTION OF FILING Pursuant to 10 C.F.R. § 2.323(b), Southern Alliance for Clean Energy (SACE) hereby requests the U.S. Nuclear Regulatory Commission (NRC) to permit SACE to correct its filing of February 5, 2015, by adding SACEs Motion for Leave to File a New Contention Concerning TVAs Failure to Comply with 10 C.F.R. § 50.34(b)(4) (Motion for Leave to File a New Contention). SACE intended to file the Motion for Leave to File a New Contention along with the Motion to Reopen the Record and attachments that were filed on February 5, but inadvertently omitted it from the filing. The error was pointed out to SACEs counsel by the Secretarys office the following morning, whereupon SACEs counsel immediately re-filed the entire package of pleadings.
SACE respectfully requests the Commission to excuse the clerical error of its counsel by deeming SACEs Motion for Leave to File a New Contention to have been filed on February 5, 2015. In making this request, SACE wishes to clarify that it does not seek to address the timeliness of its Motion for Leave to File a New Contention in any respect other than the date of its filing.
Counsel for the Tennessee Valley Authority and the NRC Staff have stated that they do not object to this motion, on condition that the 25-day period for their response provided by 10
C.F.R. § 2.309(h)(1) be measured from February 6, i.e., the date when they received the Motion for Leave to File a New Contention.
Respectfully submitted,
[Electronically signed by]
Diane Curran Harmon, Curran, Spielberg & Eisenberg, L.L.P.
1726 M Street N.W. Suite 600 Washington, D.C. 20036 202-328-3500 E-mail: dcurran@harmoncurran.com February 6, 2015 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
TENNESSEE VALLEY AUTHORITY ) Docket No. 50-391-OL (Watts Bar Nuclear Plant, Unit 2) )
)
CERTIFICATE OF SERVICE I certify that on February 6, 2015, on behalf of Southern Alliance for Clean Energy, I posted on the NRCs Electronic Information Exchange SOUTHERN ALLIANCE FOR CLEAN ENERGYS UNOPPOSED MOTION TO PERMIT CORRECTION OF FILING. It is my understanding that as a result, the NRC Commissioners, Atomic Safety and Licensing Board, and parties to this proceeding were served.
Respectfully submitted, Electronically signed by Diane Curran Harmon, Curran, Spielberg & Eisenberg, L.L.P.
1726 M Street N.W. Suite 600 Washington, D.C. 20036 202-328-3500 Fax: 202-328-6918 E-mail: dcurran@harmoncurran.com
