ML15215A590: Difference between revisions

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| issue date = 08/03/2015
| issue date = 08/03/2015
| title = Applicant'S Supplemental Disclosures
| title = Applicant'S Supplemental Disclosures
| author name = Christinidis J P, Reddick D M, Smith T R
| author name = Christinidis J, Reddick D, Smith T
| author affiliation = DTE Electric Company, Winston & Strawn, LLP
| author affiliation = DTE Electric Company, Winston & Strawn, LLP
| addressee name =  
| addressee name =  
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=Text=
=Text=
{{#Wiki_filter:August 3, 2015 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: DTE ELECTRIC COMPANY (Fermi Nuclear Power Plant, Unit 2) ) )  
{{#Wiki_filter:August 3, 2015 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:                               )
)
                                                )
)
DTE ELECTRIC COMPANY                             )            Docket No. 50-341-LR
) Docket No. 50-341-LR  APPLICANT'S SUPPLEMENTAL DISCLOSURES Pursuant to 10 C.F.R. § 2.336, the Joint Motion on Mandatory Disclosures dated February 23, 2015, and the Licensing Board's Order, dated February 27, 2015, DTE Electric Company ("DTE" or "Applicant"), hereby supplements its disclosures with respect to the admitted contentions.  
                                                )
: 1. Testifying Witnesses   DTE has not yet identified the persons upon whom it will rely as witnesses with respect to the admitted contentions. In accordance with 10 C.F.R. § 2.336(b), DTE will supplement this disclosure after testifying witnesses are identified. 2. Documents and Data Collections   No documents or data compilations in the possession, custody, or control of DTE that are relevant to the admitted contentions and subject to disclosure under the parties' disclosure agreement were identified.  
(Fermi Nuclear Power Plant, Unit 2)             )
: 3. Tangible Things   No relevant tangible things have been identified.
APPLICANTS SUPPLEMENTAL DISCLOSURES Pursuant to 10 C.F.R. § 2.336, the Joint Motion on Mandatory Disclosures dated February 23, 2015, and the Licensing Boards Order, dated February 27, 2015, DTE Electric Company (DTE or Applicant), hereby supplements its disclosures with respect to the admitted contentions.
2 Respectfully submitted, 
: 1.     Testifying Witnesses DTE has not yet identified the persons upon whom it will rely as witnesses with respect to the admitted contentions.     In accordance with 10 C.F.R. § 2.336(b), DTE will supplement this disclosure after testifying witnesses are identified.
: 2.     Documents and Data Collections No documents or data compilations in the possession, custody, or control of DTE that are relevant to the admitted contentions and subject to disclosure under the parties disclosure agreement were identified.
: 3.     Tangible Things No relevant tangible things have been identified.


    /s/ signed electronically by                 Tyson R. Smith Darani M. Reddick Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006 Jon P. Christinidis DTE Electric Company One Energy Plaza Detroit, Michigan 48226 COUNSEL FOR DTE ELECTRIC COMPANY Dated at Washington, District of Columbia this 3rd day of August 2015  
Respectfully submitted,
                                              /s/ signed electronically by Tyson R. Smith Darani M. Reddick Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006 Jon P. Christinidis DTE Electric Company One Energy Plaza Detroit, Michigan 48226 COUNSEL FOR DTE ELECTRIC COMPANY Dated at Washington, District of Columbia this 3rd day of August 2015 2
DC:777056.1


DC:777056.1 August 3, 2015 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: DTE ELECTRIC COMPANY (Fermi Nuclear Power Plant, Unit 2) ) )
August 3, 2015 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:                                 )
)
                                                  )
)  
DTE ELECTRIC COMPANY                             )            Docket No. 50-341-LR
) Docket No. 50-341-LR  CERTIFICATION OF SUPPLEMENTAL DISCLOSURES   I, Jon P. Christinidis do hereby state as follows:  
                                                  )
: 1. I am employed as Expert Attorney - Regulatory and Nuclear for DTE Electric Company. Working with other attorneys for the Applicant, I have been responsible for managing the searches, collection, and compilation of documents, data compilations, and tangible things to comply with the mandatory disclosure requirements in 10 C.F.R. § 2.336.  
(Fermi Nuclear Power Plant, Unit 2)               )
: 2. A search was conducted of documents, data compilations, and tangible things under the custody and control of the Applicant for the types of information specified in 10 C.F.R. § 2.336(a). The search was based on information and documents reasonably available to the Applicant. The searches encompassed both electronic and paper documents. 3. I hereby certify that to the best of my knowledge, information, and belief all relevant materials required to be disclosed pursuant to 10 C.F.R. § 2.336(a) in the captioned proceeding have been disclosed, and that the disclosures are accurate and complete as of June 30, 2015.
CERTIFICATION OF SUPPLEMENTAL DISCLOSURES I, Jon P. Christinidis do hereby state as follows:
: 4. I hereby certify under penalty of perjury that the foregoing is true and complete to the best of my knowledge, information, and belief.
: 1.     I am employed as Expert Attorney - Regulatory and Nuclear for DTE Electric Company. Working with other attorneys for the Applicant, I have been responsible for managing the searches, collection, and compilation of documents, data compilations, and tangible things to comply with the mandatory disclosure requirements in 10 C.F.R. § 2.336.
2      Executed in accord with 10 C.F.R. § 2.304(d),    /s/ signed electronically by        Jon P. Christinidis DTE Electric Company One Energy Plaza Detroit, Michigan 48226  Dated at Detroit, Michigan this 3rd day of August 2015 
: 2.     A search was conducted of documents, data compilations, and tangible things under the custody and control of the Applicant for the types of information specified in 10 C.F.R. § 2.336(a). The search was based on information and documents reasonably available to the Applicant. The searches encompassed both electronic and paper documents.
: 3.     I hereby certify that to the best of my knowledge, information, and belief all relevant materials required to be disclosed pursuant to 10 C.F.R. § 2.336(a) in the captioned proceeding have been disclosed, and that the disclosures are accurate and complete as of June 30, 2015.
: 4.     I hereby certify under penalty of perjury that the foregoing is true and complete to the best of my knowledge, information, and belief.


DC:777058.1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: DTE ELECTRIC COMPANY (Fermi Nuclear Power Plant, Unit 2) ) )
Executed in accord with 10 C.F.R. § 2.304(d),
)
                              /s/ signed electronically by Jon P. Christinidis DTE Electric Company One Energy Plaza Detroit, Michigan 48226 Dated at Detroit, Michigan this 3rd day of August 2015 2
)  
DC:777058.1
) Docket No. 50-341-LR  CERTIFICATE OF SERVICE   I hereby certify that copies of the foregoing "APPLICANT'S SUPPLEMENTAL DISCLOSURES" and "CERTIFICATION OF SUPPLEMENTAL DISCLOSURES" have been served via the Electronic Information Exchange ("EIE") this 3rd day of August 2015, which to the best of my knowledge resulted in transmittal of the foregoing to those on the EIE Service List for the captioned proceeding. Respectfully submitted,  
 
    /s/ signed electronically by                 Darani M. Reddick Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006 COUNSEL FOR DTE ELECTRIC COMPANY Dated at Washington, District of Columbia this 3rd day of August 2015}}
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:                                 )
                                                  )
DTE ELECTRIC COMPANY                             )            Docket No. 50-341-LR
                                                  )
(Fermi Nuclear Power Plant, Unit 2)               )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing APPLICANTS SUPPLEMENTAL DISCLOSURES and CERTIFICATION OF SUPPLEMENTAL DISCLOSURES have been served via the Electronic Information Exchange (EIE) this 3rd day of August 2015, which to the best of my knowledge resulted in transmittal of the foregoing to those on the EIE Service List for the captioned proceeding.
Respectfully submitted,
                                                        /s/ signed electronically by Darani M. Reddick Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006 COUNSEL FOR DTE ELECTRIC COMPANY Dated at Washington, District of Columbia this 3rd day of August 2015}}

Latest revision as of 09:33, 31 October 2019

Applicant'S Supplemental Disclosures
ML15215A590
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 08/03/2015
From: Christinidis J, Reddick D, Tanya Smith
DTE Electric Company, Winston & Strawn, LLP
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-341-LR, ASLBP 14-933-01-LR-BD01, RAS 28109
Download: ML15215A590 (5)


Text

August 3, 2015 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

)

DTE ELECTRIC COMPANY ) Docket No. 50-341-LR

)

(Fermi Nuclear Power Plant, Unit 2) )

APPLICANTS SUPPLEMENTAL DISCLOSURES Pursuant to 10 C.F.R. § 2.336, the Joint Motion on Mandatory Disclosures dated February 23, 2015, and the Licensing Boards Order, dated February 27, 2015, DTE Electric Company (DTE or Applicant), hereby supplements its disclosures with respect to the admitted contentions.

1. Testifying Witnesses DTE has not yet identified the persons upon whom it will rely as witnesses with respect to the admitted contentions. In accordance with 10 C.F.R. § 2.336(b), DTE will supplement this disclosure after testifying witnesses are identified.
2. Documents and Data Collections No documents or data compilations in the possession, custody, or control of DTE that are relevant to the admitted contentions and subject to disclosure under the parties disclosure agreement were identified.
3. Tangible Things No relevant tangible things have been identified.

Respectfully submitted,

/s/ signed electronically by Tyson R. Smith Darani M. Reddick Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006 Jon P. Christinidis DTE Electric Company One Energy Plaza Detroit, Michigan 48226 COUNSEL FOR DTE ELECTRIC COMPANY Dated at Washington, District of Columbia this 3rd day of August 2015 2

DC:777056.1

August 3, 2015 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

)

DTE ELECTRIC COMPANY ) Docket No. 50-341-LR

)

(Fermi Nuclear Power Plant, Unit 2) )

CERTIFICATION OF SUPPLEMENTAL DISCLOSURES I, Jon P. Christinidis do hereby state as follows:

1. I am employed as Expert Attorney - Regulatory and Nuclear for DTE Electric Company. Working with other attorneys for the Applicant, I have been responsible for managing the searches, collection, and compilation of documents, data compilations, and tangible things to comply with the mandatory disclosure requirements in 10 C.F.R. § 2.336.
2. A search was conducted of documents, data compilations, and tangible things under the custody and control of the Applicant for the types of information specified in 10 C.F.R. § 2.336(a). The search was based on information and documents reasonably available to the Applicant. The searches encompassed both electronic and paper documents.
3. I hereby certify that to the best of my knowledge, information, and belief all relevant materials required to be disclosed pursuant to 10 C.F.R. § 2.336(a) in the captioned proceeding have been disclosed, and that the disclosures are accurate and complete as of June 30, 2015.
4. I hereby certify under penalty of perjury that the foregoing is true and complete to the best of my knowledge, information, and belief.

Executed in accord with 10 C.F.R. § 2.304(d),

/s/ signed electronically by Jon P. Christinidis DTE Electric Company One Energy Plaza Detroit, Michigan 48226 Dated at Detroit, Michigan this 3rd day of August 2015 2

DC:777058.1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

)

DTE ELECTRIC COMPANY ) Docket No. 50-341-LR

)

(Fermi Nuclear Power Plant, Unit 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing APPLICANTS SUPPLEMENTAL DISCLOSURES and CERTIFICATION OF SUPPLEMENTAL DISCLOSURES have been served via the Electronic Information Exchange (EIE) this 3rd day of August 2015, which to the best of my knowledge resulted in transmittal of the foregoing to those on the EIE Service List for the captioned proceeding.

Respectfully submitted,

/s/ signed electronically by Darani M. Reddick Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006 COUNSEL FOR DTE ELECTRIC COMPANY Dated at Washington, District of Columbia this 3rd day of August 2015