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| {{#Wiki_filter:August 14, 2009 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD | | {{#Wiki_filter:August 14, 2009 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD |
| ____________________________________ | | ____________________________________ |
| )
| | ) |
| In the Matter of ) | | In the Matter of ) |
| )
| | ) |
| Tennessee Valley Authority ) Docket No. 50-391 | | Tennessee Valley Authority ) Docket No. 50-391 |
| )
| | ) |
| (Watts Bar Unit 2) ) | | (Watts Bar Unit 2) ) |
| | | ____________________________________) |
| ____________________________________) | | CERTIFICATE OF COUNSEL IN SUPPORT OF MOTION TO PERMIT LATE ADDITION OF CO-PETITIONERS TO SOUTHERN ALLIANCE FOR CLEAN ENERGYS PETITION TO INTERVENE AND ADMIT THEM AS INTERVENORS Pursuant to 10 C.F.R. § 3.232(b), I certify that on August 13, 2009, I contacted counsel for the Tennessee Valley Authority and the Nuclear Regulatory Commission Staff in a sincere effort to resolve the issues raised by Petitioners Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energys Petition to Intervene and Admit them as Intervenors. However, I was unsuccessful. |
| | | Electronically signed by Diane Curran HARMON, CURRAN, SPIELBERG & EISENBERG, L.L.P. |
| CERTIFICATE OF COUNSEL IN SUPPORT OF MOTION TO PERMIT LATE ADDITION OF CO-PETITIONERS TO SOUTHERN ALLIANCE FOR CLEAN ENERGY'S PETITION TO INTERVENE AND ADMIT THEM AS INTERVENORS Pursuant to 10 C.F.R. § 3.232(b), I certify that on August 13, 2009, I contacted counsel for the Tennessee Valley Authority and the Nuclear Regulatory Commissi on Staff in a sincere effort to resolve the issues raised by Petitioners' Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energy's Petition to Intervene and Admit them as Intervenors. However, I was unsuccessful. Electronically signed by Diane Curran HARMON, CURRAN, SPIELBERG & EISENBERG, L.L.P. | | 1726 M St. NW, Suite 600 Washington, D.C. 20036 Tel: (202) 328-3500 Fax: (202) 328-6918 dcurran@harmoncurran.com mfraser@harmoncurran.com August 14, 2009 |
| 1726 M St. NW, Suite 600 | |
| | |
| Washington, D.C. 20036 | |
| | |
| Tel: (202) 328-3500 | |
| | |
| Fax: (202) 328-6918 dcurran@harmoncurran.com mfraser@harmoncurran.com | |
| | |
| August 14, 2009 | |
| | |
| 2CERTIFICATE OF SERVICE I certify that on August 14, 2009, I posted on the NRC's Electronic Information Exchange System copies of the foregoing Certificate of Counsel in Support of Petitioners' Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energy's Petition to Intervene and Admit them as Inte rvenors. It is my understandi ng that as a result, the following parties were served:
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| Edward J. Vigluicci, Esq.
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| Office of the General Counsel
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| Tennessee Valley Authority 400 West Summit Hill Drive, WT 6A-K Knoxville, TN 37902
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| ejvigluicci@tva.gov
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| David E. Roth, Esq.
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| Office of General Counsel
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| U.S. Nuclear Regulatory Commission Mail Stop - O-15D21
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| Washington, D.C. 20555
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| David.roth@nrc.gov
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| Kathryn M. Sutton, Esq.
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| Paul M. Bessette, Esq.
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|
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|
| | CERTIFICATE OF SERVICE I certify that on August 14, 2009, I posted on the NRCs Electronic Information Exchange System copies of the foregoing Certificate of Counsel in Support of Petitioners Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energys Petition to Intervene and Admit them as Intervenors. It is my understanding that as a result, the following parties were served: |
| | Edward J. Vigluicci, Esq. |
| | Office of the General Counsel Tennessee Valley Authority 400 West Summit Hill Drive, WT 6A-K Knoxville, TN 37902 ejvigluicci@tva.gov David E. Roth, Esq. |
| | Office of General Counsel U.S. Nuclear Regulatory Commission Mail Stop - O-15D21 Washington, D.C. 20555 David.roth@nrc.gov Kathryn M. Sutton, Esq. |
| | Paul M. Bessette, Esq. |
| Morgan, Lewis & Bockius, L.L.P. | | Morgan, Lewis & Bockius, L.L.P. |
| 1111 Pennsylvania Avenue N.W. | | 1111 Pennsylvania Avenue N.W. |
| Washington, D.C. 20004 ksutton@morganlewis.com pbessette@morganlewis.com | | Washington, D.C. 20004 ksutton@morganlewis.com pbessette@morganlewis.com NRC Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hearing.docket@nrc.gov NRC Office of Appellate Commission Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ocaamail.resource@nrc.gov Electronically signed by Diane Curran 2}} |
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| NRC Office of the Secretary | |
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| U.S. Nuclear Regulatory Commission Washington, D.C. 20555 | |
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| Hearing.docket@nrc.gov | |
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| NRC Office of Appellate Commission Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ocaamail.resource@nrc.gov | |
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| Electronically signed by Diane Curran}} | |
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Category:Legal-Motion
MONTHYEARML15043A7752015-02-12012 February 2015 NEI Motion and Amicus Brief 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 ML11332A1472011-11-28028 November 2011 Southern Alliance for Clean Energy'S Unopposed Motion for Extension of Time to Respond to Tva'S Motion for Summary Disposition of Contention 7 and for Opportunity to Respond to NRC Staff If Needed ML11325A4112011-11-21021 November 2011 Attachments 1 Through 16 for Tennessee Valley Authority'S Motion for Summary Disposition of Contention 7 ML11325A4102011-11-21021 November 2011 Tennessee Valley Authority'S Motion for Summary Disposition of Contention 7 ML11325A4122011-11-21021 November 2011 Attachments 17 Through 28 for Tennessee Valley Authority'S Motion for Summary Disposition of Contention 7 ML11311A2912011-11-0707 November 2011 NRC Staff'S Answer to Southern Alliance for Clean Energy'S Motion for Leave to Supplement Basis of Contention Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report ML1113604632011-05-16016 May 2011 NRC Staff'S Answer to Petitioners' Motion for Modification of the Commission'S April 19, 2011, Order to Permit a Consolidated Reply ML1011101822010-04-21021 April 2010 Southern Alliance for Clear Energy'S Unopposed Motion for Extension of Time to Respond to TVA Motion to Dismiss Contention 1 ML1010905292010-04-19019 April 2010 Tennessee Valley Authority'S Motion to Dismiss Southern Alliance for Clean Energy'S Contention 1 as Moot ML1007703572010-03-18018 March 2010 Joint Motion for Entry of a Protective Order ML1007606402010-03-17017 March 2010 NRC Staff'S Answer to Sace Reply Motion and Motion to Amend ML1004307912010-02-12012 February 2010 Tennessee Valley Authority'S Unopposed Motion for Order Establishing Deadline to File Responses to Waive Petition ML0924608032009-09-0303 September 2009 Certificate of Service for Petitioners' Motion for Leave to Amend Contention 7 Regarding TVA Aquatic Study ML0924608022009-09-0303 September 2009 Petitioners' Motion for Leave to Amend Ontention 7 Regarding TVA Aquatic Study ML0922607942009-08-14014 August 2009 Certificate of Counsel in Support of Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energy'S Petition to Intervene and Admit Them as Interveners ML0430900952004-11-0202 November 2004 Tennessee Valley Authority - Joint Motion to Approve Settlement Agreement and Terminate Proceeding ML0427405262004-09-23023 September 2004 Tennessee Valley Authority - Joint Motion for Extension ML0425801082004-09-0909 September 2004 Tennessee Valley Authority'S Motion for a Status Conference ML0402205952003-12-31031 December 2003 Tennessee Valley Authority (TVA) - NRC Staff Response to Tennessee Valley Authority'S Motion for Leave to File Supplemental Authorities ML0335603622003-12-17017 December 2003 Tennessee Valley Authority'S Motion for Leave to File Supplemental Authorities ML0334501322003-12-10010 December 2003 Tennessee Valley Authority (TVA) - NRC Staff Response to Tennessee Valley Authority'S Motion to Strike ML0334210822003-12-0404 December 2003 Tennessee Valley Authority'S Motion to Strike ML0322502622003-08-12012 August 2003 Tennessee Valley Authority - NRC Staff'S Response to Nuclear Energy Institute'S Motion for Leave to File an Answer in Support of Commission Review of Initial Decision in LBP-03-10 ML0321100142003-07-28028 July 2003 Letter from Ellen C. Ginsberg Enclosing a Request of the Nuclear Energy Institute for Leave to File an Answer in Support of Commission Review of Initial Decision in LBP-03-10 and Its Answer ML0306508772003-02-20020 February 2003 Tennessee Valley Authority'S Unopposed Motion for an Extension of Time ML0228105792002-10-0707 October 2002 NRC Staff Objection to Submission of TVA Exhibit 75 ML0225604522002-09-0606 September 2002 Tennessee Valley Authority (TVA) - NRC Staff Responses to Tennessee Valley Authority'S Motion to Compel ML0224100362002-08-22022 August 2002 Tennessee Valley Authority'S Motion to Compel ML0210105112002-04-0808 April 2002 Tennessee Valley Authority'S Response in Opposition to NRC Staff Motion in Limine to Exclude the Testimony and Summary of Analyses of Carey L. Peters ML0209901192002-04-0808 April 2002 Tennessee Valley Authority (TVA) - April 8, 2002; NRC Staff Response to Tva'S Motion in Limine ML0210103852002-04-0808 April 2002 Tennessee Valley Authority'S Response in Opposition to Motion in Limine to Exclude Documents Related to Ronald Grover ML0210001262002-04-0505 April 2002 Tennessee Valley Authority'S Motion in Limine ML0212203692002-04-0404 April 2002 Tennessee Valley Authority - NRC Staff Motion in Limine to Exclude Certain Documents Related to Ronald Grover ML0212203862002-04-0404 April 2002 Tennessee Valley Authority (TVA) - NRC Staff Motion in Limine to Exclude the Testimony and Summary of Analyses of Carey Peters and Request for Permission to File Further Motions in Limine ML0208007632002-03-21021 March 2002 Sequoyah/Watts Bar - NRC Staff'S Answer to We the People, Inc. Tennessee'S Motion to Dismiss License Amendment Applications and Proceeding ML0208805382002-03-18018 March 2002 Response of Tennessee Valley Authority to We the People Motion to Dismiss ML0207301692002-03-0808 March 2002 Response to the NRC Staff'S Objection to Tennessee Valley Authority'S Motion for Leave to File Reply in Support of Motion for Summary Decision ML0206602262002-03-0404 March 2002 Tennessee Valley Authority (TVA) - NRC Staff Objection to Tennessee Valley Authority'S Motion for Leave to Reply in Support of Motion for Summary Decision ML0206601812002-03-0101 March 2002 Tennessee Valley Authority'S Motion for Leave to File Reply in Support of Motion for Summary Decision ML0206601732002-03-0101 March 2002 Reply in Support of Tennessee Valley Authority'S Motion for Summary Decision ML0207202692002-02-20020 February 2002 Tennessee Valley Authority (TVA) - NRC Staff Response to Tennessee Valley Authority'S Motion for Summary Decision 2015-02-12
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Text
August 14, 2009 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
____________________________________
)
In the Matter of )
)
Tennessee Valley Authority ) Docket No. 50-391
)
(Watts Bar Unit 2) )
____________________________________)
CERTIFICATE OF COUNSEL IN SUPPORT OF MOTION TO PERMIT LATE ADDITION OF CO-PETITIONERS TO SOUTHERN ALLIANCE FOR CLEAN ENERGYS PETITION TO INTERVENE AND ADMIT THEM AS INTERVENORS Pursuant to 10 C.F.R. § 3.232(b), I certify that on August 13, 2009, I contacted counsel for the Tennessee Valley Authority and the Nuclear Regulatory Commission Staff in a sincere effort to resolve the issues raised by Petitioners Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energys Petition to Intervene and Admit them as Intervenors. However, I was unsuccessful.
Electronically signed by Diane Curran HARMON, CURRAN, SPIELBERG & EISENBERG, L.L.P.
1726 M St. NW, Suite 600 Washington, D.C. 20036 Tel: (202) 328-3500 Fax: (202) 328-6918 dcurran@harmoncurran.com mfraser@harmoncurran.com August 14, 2009
CERTIFICATE OF SERVICE I certify that on August 14, 2009, I posted on the NRCs Electronic Information Exchange System copies of the foregoing Certificate of Counsel in Support of Petitioners Motion to Permit Late Addition of Co-Petitioners to Southern Alliance for Clean Energys Petition to Intervene and Admit them as Intervenors. It is my understanding that as a result, the following parties were served:
Edward J. Vigluicci, Esq.
Office of the General Counsel Tennessee Valley Authority 400 West Summit Hill Drive, WT 6A-K Knoxville, TN 37902 ejvigluicci@tva.gov David E. Roth, Esq.
Office of General Counsel U.S. Nuclear Regulatory Commission Mail Stop - O-15D21 Washington, D.C. 20555 David.roth@nrc.gov Kathryn M. Sutton, Esq.
Paul M. Bessette, Esq.
Morgan, Lewis & Bockius, L.L.P.
1111 Pennsylvania Avenue N.W.
Washington, D.C. 20004 ksutton@morganlewis.com pbessette@morganlewis.com NRC Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hearing.docket@nrc.gov NRC Office of Appellate Commission Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ocaamail.resource@nrc.gov Electronically signed by Diane Curran 2