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Category:Legal-Pleading
MONTHYEARML20279A4812020-10-0505 October 2020
C-10 Research and Education Foundation'S Reply to Oppositions to Motion for Partial Reconsideration and Motion to Re-Open the Record for Consideration of Supplemental Testimony Regarding License Conditions in LBP-20-09
ML20272A2742020-09-28028 September 2020
Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply and Motion for Leave to File INT053
ML20254A2342020-09-10010 September 2020
Nextera'S Answer Opposing C-10 Motion for Leave and Motion for Partial Reconsideration of LBP-20-9
ML20254A2352020-09-10010 September 2020
Nextera'S Answer Opposing C-10 Motion to Reopen the Record for Consideration of Supplemental Testimony
ML20244A3212020-08-31031 August 2020
C-10 Research and Education Foundation'S Motion for Partial Reconsideration and Motion to Re-Open the Record for Consideration of Supplemental Testimony Regarding License Conditions in LBP-20-09
ML20244A3202020-08-31031 August 2020
C-10 Research and Education Foundation'S Motion for Leave to File Motion for Partial Reconsideration of LBP-20-09
ML20043E2542020-01-31031 January 2020
Redacted C-10 Research and Education'S Supplemental Proposed Findings of Fact and Conclusions of Law
ML20031D6992020-01-31031 January 2020
NRC Staff Supplemental Proposed Findings of Fact and Conclusions of Law
ML20031E7222020-01-31031 January 2020
NextEra Energy Seabrook Llc'S Supplemental Proposed Findings of Fact and Conclusions of Law
ML19354C4482019-12-20020 December 2019
C-10 Research and Education Foundation'S Response to Nextera'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law
ML19353D4192019-12-19019 December 2019
C-10 Research and Education Foundation'S Response to Nextera'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law
ML19347D0672019-12-13013 December 2019
NextEra Energy Seabrook Llc'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law
ML19347D0702019-12-13013 December 2019
NextEra Energy Seabrook Llc'S Responsive Proposed Findings of Fact and Conclusions of Law
ML19333B9702019-11-29029 November 2019
Unopposed Motion for Extension of Time to Seek Leave to File Responsive Proposed Findings of Fact and Conclusions of Law
ML20043E2522019-11-27027 November 2019
Redacted Corrected C-10 Research and Education Foundation'S Proposed Findings of Fact and Conclusions of Law
ML19325D9092019-11-21021 November 2019
NRC Staff Proposed Findings of Fact and Conclusions of the Law for the Admitted Contention
ML19325F3902019-11-21021 November 2019
NextEra Energy Seabrook Llc'S Proposed Findings of Fact and Conclusions of Law
ML19310E2592019-11-0606 November 2019
Nextera'S Answer Opposing C-10's Third Motion for Leave to File Supplemental Testimony
ML19304B3522019-10-31031 October 2019
C-10 Research and Education Foundation'S Response to ASLB Memorandum and Motion to Submit Additional Exhibits Regarding Petrographic Observations and Analyses of ASR at Seabrook
ML19283A0362019-10-0909 October 2019
Nextera'S Answer Opposing C-10's Motions to Compel Production of Mineralogical Data and to Submit Additional Post-Hearing Testimony
ML19272B3252019-09-30030 September 2019
C-10 Research and Education Foundation'S Motion to Compel Production of Mineralogy Data and Request for Opportunity to Submit Supplemental Written Testimony Regarding the Data
ML19262K7512019-09-19019 September 2019
C-10 Research and Education Foundation'S Opposition to Nextera'S Second Motion in Limine
ML19261B8802019-09-18018 September 2019
NRC Staff'S Answer to Nextera'S Motion in Limine
ML19254F1582019-09-11011 September 2019
Appendix a Revised Exhibit List for September 2019 Evidentiary Hearing Exhibits
ML19253D6782019-09-10010 September 2019
NRC Staff'S Answer to C-10's Motion to Supplement Rebuttal Testimony
ML19252B3072019-09-0909 September 2019
NextEra Answer Opposing C-10 Motion for Leave to File Supplemental Rebuttal
ML19252B2322019-09-0909 September 2019
Nextera'S Motion in Limine to Strike or Exclude Portions of C-10's Testimony and Exhibits
ML19247D5932019-09-0404 September 2019
C-10 Research and Education Foundation'S Motion for Leave to File Supplemental Rebuttal Testimony
ML19235A3172019-08-23023 August 2019
C-10 Research and Education Foundation, Inc. Rebuttal Statement of Position on C-10's Contentions Regarding Nextera'S Program for Managing ASR at Seabrook Station Nuclear Power Plant
ML19235A3182019-08-23023 August 2019
Appendix a Revised Exhibit List
ML19205A3412019-07-24024 July 2019
NRC Staff Initial Written Statement of Position
ML19205A4882019-07-24024 July 2019
NextEra Energy Seabrook LLC Statement of Position and Certificate of Service
ML19171A4012019-06-20020 June 2019
C-10 Research and Education Foundation'S Errata to Exhibit INT-001, Testimony of Dr. Victor E. Saouma
ML19161A3722019-06-10010 June 2019
Appendix a Exhibit List
ML19161A3712019-06-10010 June 2019
C-10 Research and Education Foundation, Inc. Initial Statement of Position on Contentions Re Nextera'S Program for Managing ASR at Seabrook Station
ML19123A1912019-05-0303 May 2019
C-10 Research and Education Foundation'S Opposition to Nextera'S Motion in Limine
ML19114A0762019-04-23023 April 2019
Nextera'S Motion in Limine to Exclude Testimony and Exhibits Regarding Structure Deformation Monitoring
ML19105B2822019-04-15015 April 2019
Nextera'S Answer Opposing C-10's Motion Regarding Seabrook Station Site Tour
ML19101A4082019-04-11011 April 2019
C-10 Research and Education Foundation'S Motion Regarding Seabrook Station Site Tour
ML19064B4022019-03-0505 March 2019
Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply to Answers to C-10's Emergency Petition
ML19064A6322019-03-0505 March 2019
Notice of Appearance for Jennifer E. Scro
ML19060A3042019-03-0101 March 2019
C-10 Research and Education Foundation'S Reply to Oppositions by NextEra and NRC Staff to Emergency Petition for Exercise of Commission'S Supervisory Authority to Reverse No Significant Hazards Determination and Immediately Suspend License
ML19060A3032019-03-0101 March 2019
C-10 Research and Education Foundation'S Motion for Leave to File Reply to Oppositions by NextEra and NRC Staff to Emergency Petition
ML19056A5882019-02-25025 February 2019
NRC Staff Answer to C-10's Emergency Petition
ML19056A5862019-02-25025 February 2019
Nextera'S Answer Opposing C-10 Emergency Petition
ML19044A7702019-02-13013 February 2019
Exhibit 1 to Saouma Declaration: Curriculum Vitae for Dr. Victor E. Saouma
ML19044A7682019-02-13013 February 2019
Emergency Petition by C-10 Research and Education Foundation for Exercise of Commission'S Supervisory Authority to Reverse No Significant Hazards Determination and Immediately Suspend License Amendment and License Renewal Decisions
ML19044A7692019-02-13013 February 2019
Declaration of Victor E. Saouma, Ph.D
ML19044A7722019-02-13013 February 2019
Exhibit 3 to Saouma Declaration: Sauoma, Experimental and Numerical Investigation of Alkali Silica Reaction in Nuclear Reactors, Final Summary Report
ML19044A7732019-02-12012 February 2019
Exhibit 4a to Saouma Declaration: Introduction and Executive Summary
2020-09-28
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Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of )
NextEra Energy Seabrook, LLC ) Docket No. 50-443 (Seabrook Station, Unit 1) )
_____________________________________)
NOTICE OF APPEARANCE FOR DIANE CURRAN AND REQUEST FOR ACCESS TO ELECTRONIC HEARING DOCKET FOR ADJUDICATORY SUBMISSIONS CONTAINING PROPRIETARY INFORMATION Pursuant to 10 C.F.R. § 2.314(b), Diane Curran hereby enters an appearance in this proceeding as duly authorized legal counsel for C-10 Research and Education Fund. Undersigned counsel is a member in good standing of the bars of the District of Columbia; the State of Maryland; the U.S. District Court for the District of Columbia; the U.S. Supreme Court; and the U.S. Courts of Appeals for the D.C., First, Third, Ninth, and Tenth Circuits.
Undersigned counsel also has signed a Nondisclosure Declaration in this proceeding, giving her permission to receive and submit documents containing proprietary information. See attached Nondisclosure Declaration and cover letter. Therefore, counsel requests access to the NRCs Adjudicatory Submissions portal for submitting and receiving proprietary documents.
Respectfully submitted,
__/signed electronically by/___
Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com February 11, 2019
Via electronic submission TO: Paul M. Bessette - Morgan Lewis Anita Ghosh Naber - U.S. Nuclear Regulatory Commission, Office of the General Counsel CC: Jeremy Wachutka and Sabrina Allen - NRC; Scott Clausen & Grant Eskelsen - Morgan Lewis; Chris Nord and Diane Teed - C-10 Board of Directors FROM: Natalie H. Treat, Executive Director, C-10 Research & Education Foundation DATE: January 8, 2019 RE: Signed Non-Disclosure Affidavit of Diane Curran, Consulting Attorney to C-10 in the matter of:
NEXTERA ENERGY SEABROOK, LLC (Seabrook Station Unit 1) Docket No. 50-443-LA-2 Pursuant to 10 C.F.R. § 2.336, the C-10 Research and Education Foundation, Inc. (C-10) hereby submits the following non-disclosure affidavit for Diane Curran, attorney with Harmon, Curran, Spielberg &
Eisberg, LLP, 1725 DeSales Street NW, Suite 500 Washington, DC 20036.
Ms. Curran has entered into a limited agreement with C-10 as a consulting attorney. As such, she has completed the non-disclosure affidavit covering protected documents under NRC Docket No.
50-443-LA-2, regarding the license amendment request (LAR) 16-03 from NextEra Energy Seabrook, 1
LLC (NextEra) to adopt a methodology to monitor the impacts of alkali-silica reaction (ASR) on concrete structures at Seabrook Station, Unit No. 1 (Seabrook).
Ms. Curran has read and signed the Protective Order (Governing Non-Disclosure of Protected Information) issued by the Atomic Safety and Licensing Board on January 19, 2018. Her signed affidavit have been scanned and are attached as a pdf.
Respectfully Submitted on behalf of C-10, Natalie Hildt Treat Executive Director C-10 Research & Education Foundation Ph: (978) 465-6646 Email: natalie@c-10.org 1
License Amendment Request 16-03, Revise Current Licensing Basis to Adopt a Methodology for the Analysis of Seismic Category I Structures with Concrete Affected by Alkali-Silica Reaction, (Aug. 1, 2016) (ADAMS Accession No. ML16216A240)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of )
NextEra Energy Seabrook, LLC ) Docket No. 50-443 (Seabrook Station, Unit 1) )
_____________________________________)
CERTIFICATE OF SERVICE I certify that on February 11, 2019, NOTICE OF APPEARANCE FOR DIANE CURRAN AND REQUEST FOR ACCESS TO ELECTRONIC HEARING DOCKET FOR ADJUDICATORY SUBMISSIONS CONTAINING PROPRIETARY INFORMATION and ATTACHED NONDISCLOSURE DECLARATION AND CORRESPONDENCE were posted on the NRCs electronic hearing docket.
__/signed electronically by/___
Diane Curran
