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| {{#Wiki_filter:}} | | {{#Wiki_filter:April 28, 2021 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION |
| | ) |
| | In the Matter of ) |
| | Virginia Electric Power Co. ) Docket Nos. 50-338/339 SLR North Anna Power Station, Units 1 and 2 ) |
| | ___________________________________ ) |
| | ERRATA TO BRIEF ON APPEAL OF LBP-21-04 BY BEYOND NUCLEAR, SIERRA CLUB, AND ALLIANCE FOR A PROGRESSIVE VIRGINIA Appellants in this proceeding (Beyond Nuclear, Inc., Sierra Club, Inc., and Alliance for a Progressive Virginia, Inc.) hereby correct their Brief on Appeal of LBP 04 (Apr. 21, 2021) as follows. A corrected copy of the brief is also attached. |
| | Page Line Correction Title 8 Add a after Alliance for 1 3 Insert a between for and Progressive 1 11 delete duplicate regulations 5 fn 10 1 delete v. NRC 5 13 Change together to together, 5 fn 12 6-7 Delete sentence starting with Taken together 8 12 Change earthquake to Earthquake 14 8 Change withut to without 14 17 change Again to Again, |
| | |
| | 23 15 insert the NRC after reactors, 25 fn 47 1 change Forida to Florida 26 9 delete t after event 26 22 change Earthquake, to Earthquake 27 16 change VECO to VEPCO 28 2 change Section IV to Section IV.B 29 8 insert (emphasis in original) after Id. at 34. |
| | 29 8-9 move fn 54 from line 9 to line 8 after the North Anna design 30 2 change Petitioners to Appellants 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 April 28, 2021 2}} |
Latest revision as of 15:10, 19 January 2022
Errata to Brief on Appeal of LBP-21-04 by Beyond Nuclear, Sierra Club and Alliance for a Progressive VirginiaML21118A990 |
Person / Time |
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Site: |
North Anna |
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Issue date: |
04/28/2021 |
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From: |
Curran D Alliance for Progressive Values, Beyond Nuclear, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Sierra Club |
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To: |
NRC/OCM |
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SECY RAS |
Shared Package |
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ML21118A989 |
List: |
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References |
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50-338-SLR, 50-339-SLR, ASLBP 21-970-01-SLR-01, LBP-21-04, RAS 56077 |
Download: ML21118A990 (2) |
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Category:Legal-Pleading
MONTHYEARML24243A1352024-08-30030 August 2024 NRC Staff Brief in Response to the Appeal Filed by Beyond Nuclear, Inc and Sierra Club Inc from the Atomic Safety and Licensing Board Decision in LBP 24 07 ML24243A1632024-08-30030 August 2024 Applicants Answer and Brief in Opposition to the Appeal of LBP-24-07 Filed by Beyond Nuclear and the Sierra Club ML24218A2872024-08-0505 August 2024 Brief by Beyond Nuclear and the Sierra Club on Appeal of LBP-24-07 ML24218A2862024-08-0505 August 2024 Notice of Appeal of LBP-24-07 by Beyond Nuclear and the Sierra Club ML24150A3282024-05-29029 May 2024 Applicants Tables of Legal and Factual Authorities in Response to the Boards May 21, 2024 Memorandum and Order ML24150A1902024-05-29029 May 2024 Beyond Nuclears and the Sierra Clubs Table of Authorities in Response to Board Order of May 21, 2024 ML24150A3842024-05-29029 May 2024 NRC Staff Response to the Atomic Safety and Licensing Boards Memorandum and Order of May 21, 2024 ML24141A2872024-05-20020 May 2024 Reply by Beyond Nuclear and Sierra Club to Oppositions to Their Hearing Request and Petition to Intervene ML24134A1942024-05-13013 May 2024 Unopposed Emergency Motion by Beyond Nuclear and the Sierra Club for Extension of Time to Reply to Oppositions to Their Hearing Request and Petition to Intervene and Request for Postponement of Oral Argument ML24130A2062024-05-0909 May 2024 Site Visit (Resident for a Day Program) ML24127A2342024-05-0606 May 2024 Attachment 1 to NRC Staff Answer in Opposition to Petition for Leave to Intervene Filed by Beyond Nuclear Inc., and Sierra Club, Inc ML24127A2202024-05-0606 May 2024 Applicants Answer to the Hearing Request and Petition to Intervene and Motion for Leave to Amend Contention 3 Filed by Beyond Nuclear and Sierra Club ML24127A2332024-05-0606 May 2024 NRC Staff Answer in Opposition to Petition for Leave to Intervene Filed by Beyond Nuclear Inc., and Sierra Club, Inc ML24047A3002024-02-16016 February 2024 NRC Staff Answer to Beyond Nuclear and Sierra Clubs Notification of Relevance of LBP 24 01 to This Proceeding and Request to Immediately Suspend Hearing Request Deadline Pending Resolution of Certified Question Raised in LBP-24-01 ML24043A0362024-02-12012 February 2024 Notification of Relevance of LBP 24-01 to This Proceeding and Request to Immediately Suspend Hearing Request Deadline Pending Resolution of Certified Question Raised in LBP 24-01 ML24043A0162024-02-12012 February 2024 Notification of Relevance of LBP 24-01 to This Proceeding and Request to Immediately Hearing Request Pending Resolution of Resolution of Certified Question Raised in LBP-24-01 ML24032A0042024-02-0101 February 2024 Conditional Motion by Beyond Nuclear and Sierra Club for Extension of Time to Submit Hearing Request ML24029A2552024-01-29029 January 2024 Notice of Appearance for Sherwin E Turk ML24029A2592024-01-29029 January 2024 NRC Staff Answer to Beyond Nuclear and Sierra Club Motion for Withdrawal of Premature Hearing Notice ML24022A0662024-01-22022 January 2024 Errata to Motion by Beyond Nuclear and Sierra Club for Withdrawal of Premature Hearing Notice ML24018A1502024-01-18018 January 2024 Motion by Beyond Nuclear and Sierra Club for Withdrawal of Premature Hearing Notice ML21305B8612021-11-0101 November 2021 Reply by Beyond Nuclear, Inc., Sierra Club, Inc., and Alliance for a Progressive Virginia, Inc. to Oppositions to Their Motion to Amend Contention Out of Time ML21298A1542021-10-25025 October 2021 Applicants Answer Opposing Motion to Amend Contention Out of Time and Motion to Reopen the Record by Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia ML21298A2312021-10-25025 October 2021 NRC Staffs Response to Petitioners Motion to Amend Contention Out of Time and Motion to Re-Open the Record ML21292A1692021-10-19019 October 2021 Notice of Appearance for Diane Curran on Behalf of Beyond Nuclear, the Sierra Club, and Alliance for a Progressive Virginia ML21272A3862021-09-29029 September 2021 Motion to Amend Contention Out of Time and Motion to Re-Open the Record by Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia ML21152A2992021-06-0101 June 2021 Applicants' Answer Opposing Petitioners' Motion for Leave to Reply ML21145A3762021-05-25025 May 2021 Motion for Leave to Reply to Opposition Briefs by Beyond Nuclear, Sierra Club, and Alliance for a Progressive Virginia ML21145A3772021-05-25025 May 2021 Reply to Opposition Briefs by Beyond Nuclear, Sierra Club, and Alliance for a Progressive Virginia ML21138A8942021-05-18018 May 2021 Applicants' Brief in Opposition to Appeal of LBP-21-4 by Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia ML21138A9422021-05-18018 May 2021 NRC Staff'S Brief in Response to Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia'S Appeal of LBP-21-4 ML21118A9912021-04-28028 April 2021 Corrected Brief on Appeal of LBP-21-04 by Beyond Nuclear, Sierra Club and Alliance for Progressive Virginia ML21118A9902021-04-28028 April 2021 Errata to Brief on Appeal of LBP-21-04 by Beyond Nuclear, Sierra Club and Alliance for a Progressive Virginia ML21113A3172021-04-23023 April 2021 Brief on Appeal of LBP-21-04 by Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia ML21113A3162021-04-23023 April 2021 Notice of Appeal of LBP-21-04 by Beyond Nuclear Sierra Club and Alliance for Progressive Virginia ML21015A6052021-01-15015 January 2021 Reply by Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia to Oppositions to Hearing Request and Waiver Petition ML21008A5312021-01-0808 January 2021 Applicant'S Answer Opposing Request for Hearing, Petition to Intervene, and Petition for Waiver Submitted by Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia ML21008A5932021-01-0808 January 2021 NRC Staff Answer to Hearing Request, Petition to Intervene, and Petition for Waiver Filed by Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia ML21007A3832021-01-0707 January 2021 Notices of Appearance for Anita Ghosh Naber, Sherwin E. Turk, Joseph D. Mcmanus, and Travis C. Jones on Behalf of NRC Staff ML20349D9522020-12-14014 December 2020 Hearing Request and Petition to Intervene by Beyond Nuclear, Sierra Club, and Alliance for Progressive Virginia and Petition for Waiver of 10 C.F.R. 51.53(c)(3)(i), 51.71(d), and 51.95(C)(1) to Allow Consideration of Category 1 NEPA Issues ML20335A4332020-11-30030 November 2020 Applicants' Answer Opposing Petitioners' Motion for Extension of Deadline for Filing Hearing Requests ML20328A2782020-11-23023 November 2020 Partially Unopposed Motion by Beyond Nuclear, Sierra Club, and Alliance for a Progressive Virginia for Extension of Deadline for Filing Hearing Requests ML20344A2912020-11-23023 November 2020 Corrected Partially Unopposed Motion by Beyond Nuclear, Sierra Club, and Alliance for a Progressive Virginia for Extension of Deadline for Filing Hearing Requests ML12118A4742012-04-27027 April 2012 Notice of Appearance of Stephen L. Markus ML12118A4712012-04-27027 April 2012 Dominion'S Answer Opposing Requests for Heariing 2024-08-05
[Table view] |
Text
April 28, 2021 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of )
Virginia Electric Power Co. ) Docket Nos. 50-338/339 SLR North Anna Power Station, Units 1 and 2 )
___________________________________ )
ERRATA TO BRIEF ON APPEAL OF LBP-21-04 BY BEYOND NUCLEAR, SIERRA CLUB, AND ALLIANCE FOR A PROGRESSIVE VIRGINIA Appellants in this proceeding (Beyond Nuclear, Inc., Sierra Club, Inc., and Alliance for a Progressive Virginia, Inc.) hereby correct their Brief on Appeal of LBP 04 (Apr. 21, 2021) as follows. A corrected copy of the brief is also attached.
Page Line Correction Title 8 Add a after Alliance for 1 3 Insert a between for and Progressive 1 11 delete duplicate regulations 5 fn 10 1 delete v. NRC 5 13 Change together to together, 5 fn 12 6-7 Delete sentence starting with Taken together 8 12 Change earthquake to Earthquake 14 8 Change withut to without 14 17 change Again to Again,
23 15 insert the NRC after reactors, 25 fn 47 1 change Forida to Florida 26 9 delete t after event 26 22 change Earthquake, to Earthquake 27 16 change VECO to VEPCO 28 2 change Section IV to Section IV.B 29 8 insert (emphasis in original) after Id. at 34.
29 8-9 move fn 54 from line 9 to line 8 after the North Anna design 30 2 change Petitioners to Appellants 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 April 28, 2021 2