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| | number = ML100470494 | | | number = ML100470494 |
| | issue date = 02/16/2010 | | | issue date = 02/16/2010 |
| | title = 2010/02/16-Certificate of Counsel in Support of Motion | | | title = Certificate of Counsel in Support of Motion |
| | author name = Dougherty J | | | author name = Dougherty J |
| | author affiliation = Bellefonte Efficiency & Sustainability Team (BEST), Blue Ridge Environmental Defense League, Southern Alliance for Clean Energy | | | author affiliation = Bellefonte Efficiency & Sustainability Team (BEST), Blue Ridge Environmental Defense League, Southern Alliance for Clean Energy |
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Category:Legal-Pleading
MONTHYEARNRC-2019-0228, Notice of Withdrawal of Martin J. O'Neill2020-02-12012 February 2020 Notice of Withdrawal of Martin J. O'Neill ML19358A0122019-12-24024 December 2019 Applicant'S Answer Opposing Petition to Intervene and Request for Hearing by the Blue Ridge Environmental Defense League and Its Chapter Bellefonte Efficiency and Sustainability Team ML14304A7182014-10-31031 October 2014 Tennessee Valley Authority'S Answer to Motion to Reopen the Record for Sequoyah Nuclear Power Plant and Motion to Reopen the Record for Bellefonte Nuclear Power Plant 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 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 ML12118A5402012-04-27027 April 2012 Notices of Appearance of Paul M. Bessette and Stephen J. Burdick ML1012006512010-04-30030 April 2010 Tennessee Valley Authority Opposing Petitioners' Motion for Additional Time to Appeal LBP-10-07 ML1011904762010-04-29029 April 2010 NRC Staff'S Response to Petitioners' Motion for Additional Time in Which to File Appeal of LBP-10-07 and Brief in Opposition to Appeal ML1011002962010-04-20020 April 2010 Brief on Appeal of LBP-10-07 by Blue Ridge Environmental Defense League, Its Chapter Bellefonte Efficiency and Sustainability Team and the Southern Alliance for Clean Energy ML1008103532010-03-22022 March 2010 Notice of Actions Taken by Morgan Lewis & Bockius Pursuant to DC Rules of Professional Conduct 1.11 to Screen Karen D. Cyr from Bellefonte Units 1 and 2 ML1007803942010-03-19019 March 2010 NRC Staff'S Response to Board Order and Memorandum of March 16, 2010 ML1007705842010-03-18018 March 2010 Petitioners' Corrected Response to Licensing Board Memorandum and Order Regarding Prehearing Conference Transcript Corrections ML1007407122010-03-15015 March 2010 Petitioners' Response to Licensing Board Memorandum and Order Regarding Prehearing Conference Transcript Corrections ML1007405582010-03-15015 March 2010 NRC Staff'S Unopposed Motion to Correct the Record and Proposed Corrections to the Transcript of the Initial Pre-Hearing Conference Held on March 1, 2010 ML1004802302010-02-17017 February 2010 Tennessee Valley Authority'S Answer Opposing Petitioner'S Motion for Additional Time to File Reply ML1004802202010-02-17017 February 2010 NRC Staff Response to Petitioners' Motion for Additional Time in Which to (1) File a Notice of Appearance of Counsel and (2) Reply to Tennessee Valley Authority and NRC Staff Answers to Petition for Intervention ML1004704942010-02-16016 February 2010 Certificate of Counsel in Support of Motion ML1004704902010-02-16016 February 2010 Petitioners' Reply to NRC Staff'S and Tva'S Answers in Oposition to Petition for Intervention and Request for Hearing ML1002910402010-01-29029 January 2010 NRC Staff'S Answer to Petition for Intervention and Request for Hearing, and Response to Joint Intervenors' Supplemental Basis to Contention 5 - Lack of Good Cause, and Joint Petitioners' Supplemental Basis for Previously Submitted Contenti ML1002908592010-01-29029 January 2010 Answer of Tennessee Valley Authority Opposing the Petition for Intervention and Request for Hearing by the Blue Ridge Environmental Defense League Et Al ML1002109052010-01-21021 January 2010 Updated Notice of Appearance of Martin J. O'Neill ML0916106942009-06-10010 June 2009 Tennessee Valley Authority'S Response to Petitioners' Brief Opposing the Nrc'S Authority to Reinstate the Construction Permits for Bellefonte Nuclear Power Plant, Units 1 and 2 ML0916106312009-06-10010 June 2009 NRC Staff'S Response to Petitioners' Brief Regarding Nrc'S Statutory Authority to Reinstate Construction Permits at Bellefonte ML0916107262009-06-10010 June 2009 Reply Brief of the Petitioners in Response to the Commission'S May 20, 2009 Order Concerning the Nrc'S Statutory Authority to Reinstate the Bellefonte Construction Permits ML0915412762009-06-0303 June 2009 Brief of the Blue Ridge Environmental Defense League, Its Chapter Bellefonte Efficiency and Sustainability Team and the Southern Alliance for Clean Energy Regarding Nrc'S Statutory Authority to Reinstate Construction Permits at Bellefonte ML0915412672009-06-0303 June 2009 NRC Staff'S Brief in Support of NRC Authority to Reinstate Construction Permit Numbers CPPR-122 and CPPR-123 ML0915412412009-06-0303 June 2009 Tennessee Valley Authority'S Brief in Response to the Commission'S May 20, 2009 Order Concerning the Nrc'S Statutory Authority to Reinstate the Bellefonte Construction Permits ML0915412402009-06-0303 June 2009 Notice of Appearance for Lawrence J. Chandler on Behalf of Tennessee Valley Authority ML0915412392009-06-0303 June 2009 Notice of Appearance of Martin J. O'Neill on Behalf of Tennessee Valley Authority ML0913206482009-05-12012 May 2009 Notice of Appearance of Jeremy Suttenberg on Behalf of the U.S. Nuclear Regulatory Commission Regarding Bellefonte, Units 1 and 2 ML0913206462009-05-12012 May 2009 Notice of Appearance of Andrea Z. Jones on Behalf of the U.S. Nuclear Regulatory Commission Regarding Bellefonte, Units 1 and 2 ML0913106712009-05-11011 May 2009 Notice of Appearance of David E. Roth 2020-02-12
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
___________________________________
In the Matter of Tennessee Valley Authority Docket Nos. 50-438 and 50-439 Bellefonte Nuclear Power Plant Units 1 and 2 February 16, 2010
___________________________________
CERTIFICATE OF COUNSEL IN SUPPORT OF MOTION Pursuant to 10 C.F.R. § 3.232(b), I certify that today I telephonically contacted counsel for the Tennessee Valley Authority (K. Sutton, Esq.) and the Nuclear Regulatory Commission Staff (A. Jones, Esq.) in a sincere effort to resolve the issues raised by Petitioners Motion For Additional Time In Which to Reply to TVA and NRC Staff Answers To Petition for Intervention. Ms. Sutton indicated that TVA would oppose the motion. Ms. Jones took no position on the matter.
Respectfully submitted, Signed (electronically) this 16th day of February, 2009, in Washington, D.C.
James B. Dougherty, Esq.
709 3rd St. S.W.
Washington, D.C. 20024 (202) 488-1140 (v)
(202) 488-1140 (f)
(E-mail: jimdougherty@aol.com)
Counsel for Petitioners Blue Ridge Environmental Defense League, et al.
1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
___________________________________
In the Matter of Tennessee Valley Authority Docket Nos. 50-438 and 50-439 Bellefonte Nuclear Power Plant Units 1 and 2
___________________________________
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Certificate of Counsel were served this day on the following persons via Electronic Information Exchange.
Office of the Secretary Kathryn M. Sutton, Esq.
ATTN: Docketing and Service Lawrence J. Chandler, Esq.
Mail Stop 0-16C1 Morgan, Lewis & Bockius LLP US Nuclear Regulatory Commission 1111 Pennsylvania Ave., NW Washington, DC 20555-0001 Washington, DC 20004 (E-mail: hearingdocket@nrc.gov) (E-mail: ksutton@morganlewis.com, lchandler@morganlewis.com)
Office of Commission Appellate Adjudication Martin J. ONeill, Esq.
US Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP Washington, DC 20555-0001 1000 Louisiana St., Suite 4000 (E-mail: ocaamail@nrc.gov) Houston, TX 77002 E-mail: martin.oneill@morganlewis.com Patrick A. Moulding, Esq.
Ann P. Hodgdon, Esq. Edward J. Vigluicci, Esq.
US Nuclear Regulatory Commission Scott A. Vance, Esq.
Mail Stop O-15 D21 Tennessee Valley Authority Washington, DC 20555-0001 400 West Summit Hill Dr., WT 6A-K (E-mail: patrick.moulding@nrc.gov, Knoxville, TN 37902 ann.hodgdon@nrc.gov) (E-mail: ejvigluicci@tva.gov, savance@tva.gov)
Louise Gorenflo Andrea Z. Jones, Esq.
Bellefonte Efficiency & Sustainability Counsel for NRC Staff Team US Nuclear Regulatory Commission 185 Hood Drive Office of the General Counsel Crossville, TN 28555 Mail Stop: O-15 D21 (E-mail: lgorenflo@gmail.com) Washington, DC 20555-0001 2
Signed (electronically) this 16th day of February, Sara Barczak 2009, in Washington, D.C.
Southern Alliance for Clean Energy 428 Bull Street James B. Dougherty, Esq.
Savannah, GA 31401 709 3rd St. S.W.
sara@cleanenergy.org Washington, D.C. 20024 (202) 488-1140(v)
(202) 488-1140(f)
(E-mail: jimdougherty@aol.com) 3