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Category:Legal-Motion
MONTHYEARML15251A6782015-09-0404 September 2015
Motion for Leave to Intervene by First Energy Nuclear Operating Company
ML15132A5152015-05-12012 May 2015
Certificate of Service of Beyond Nuclear Reply to Oppositions to Motion to Admit New Contention
ML15128A2912015-05-0808 May 2015
Beyond Nuclear'S Motion to Amend Nepa Placeholder Contention in License Renewal Proceeding for Davis-Besse Nuclear Power Plant
ML15132A1972015-05-0808 May 2015
Certificate of Service for Beyond Nuclear'S Motion to Amend NEPA Placeholder Contention, Filed May 8, 2015
ML15128A2982015-05-0808 May 2015
Reply by Beyond Nuclear, Blue Ridge Environmental Defense League, Nuclear Information and Resource Service, Seed Coalition and Southern Alliance for Clean Energy to Oppositions by Applicants and NRC Staff to Motions to Admit New Contentions
ML15112B2012015-04-22022 April 2015
Beyond Nuclear'S Hearing Request and Motion to Intervene
ML15112B1992015-04-22022 April 2015
Beyond Nuclear Motion to Reopen Record of License Renewal Proceeding
ML15112B2022015-04-22022 April 2015
Standing Declaration of Victoria Clemons
ML15065A2222015-03-0606 March 2015
FENOC Motion for Clarification Regarding Termination of Proceeding
ML14364A4052014-12-30030 December 2014
Intervenors' Second Motion to Supplement Contention No. 7 on Worsening Shield Building Cracking and Inadequate Amps in Shield Building Monitoring Program
ML14335A7802014-12-0101 December 2014
Joint Proposed Corrections to the Transcript of the Oral Argument Held on November 12, 2014
ML14315A0492014-11-11011 November 2014
Notice of Filing of Riley Email (Exhibit a to Contention No. 7)
ML14311A9892014-11-0707 November 2014
Petitioners and Intervenors Consolidated Reply to Answers to Petitions to Suspend Final Reactor Licensing Decisions, Motions to Admit a New Contention, and Motions to Reopen the Record
ML14255A0302014-09-12012 September 2014
Erratum to Intervenors' Motion to Amend and Supplement Contention No. 7 on Worsening Shield Building Cracking and Inadequate AMPs in Shield Monitoring Program
ML14252A8982014-09-0909 September 2014
Unopposed Motion to Establish Consolidated Briefing Schedule for Proposed Contention 7 Admissibility Filings
ML14251A6092014-09-0808 September 2014
Intervenors Motion to Amend and Supplement Contention No. 7 on Worsening Shield Building Cracking and Inadequate AMPs in Shield Building Monitoring Program
ML14245A6562014-09-0202 September 2014
Intervenors' Motion for Admission of Contention No. 7 on Worsening Shield Building Cracking and Inadequate Amps in Shield Building Monitoring Program
ML14144A0002014-05-23023 May 2014
Intervenors' Reply in Support of Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems
ML14112A0072014-04-21021 April 2014
Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems
ML14112A0082014-04-15015 April 2014
Exhibit 7 - Request for Additional Information (Rai), April 15, 2014
ML14113A0012014-04-14014 April 2014
Exhibit 3 - Declaration of Victoria Clemons
ML14058A6822014-02-27027 February 2014
Certificate of Service of Petition to Suspend
ML14058A6832014-02-27027 February 2014
Petition to Suspend Reactor Licensing Decisions and Reactor Re-Licensing Decisions Pending Completion of Rulemaking Proceeding Regarding Environmental Impacts of High-Density Pool Storage of Spent Fuel and Mitigation Measures
ML14112A0092014-02-19019 February 2014
Exhibit 1 - Preliminary Notice of Event or Occurrence, February 19, 2014
ML14112A0032014-02-15015 February 2014
Exhibit 2 - Toledo Blade Article, Davis-Besse Had Air Gap in Shield Building, February 15, 2014
ML13277A7252013-10-0303 October 2013
Intervenors' Memorandum in Opposition to 'Fenoc'S Petition for Certification of Waste Confidence-Related Question to the Commission Pursuant to 10CFR2.323(f)(2).'
ML13266A4322013-09-23023 September 2013
Fenoc'S Petition for Certification of Waste Confidence-Related Question to the Commission Pursuant to 10 C.F.R. Section 2.32.(f)(2)
ML14112A0042013-09-20020 September 2013
Exhibit 6 - Preliminary Notice of Event or Occurrence, September 20, 2013
ML13192A2842013-07-11011 July 2013
Firstenergy Nuclear Operating Company'S Answer Supporting the NRC Staff'S Motion to Strike Portions of Petitioners Reply
ML13192A5052013-07-11011 July 2013
Petitioners' Reply in Opposition to NRC Staff Motion to Strike
ML13190A2162013-07-0808 July 2013
Petitioners' Reply in Opposition to FENOC 'Motion to Strike'
ML13182A4792013-07-0101 July 2013
NRC Staff Motion to Strike Portions of Joint Petitioners Reply or, in the Alternative, for Leave to Reply
ML13179A4032013-06-28028 June 2013
Firstenergy Nuclear Operating Company'S Motion to Strike Portions of Petitioners' Reply
ML13173A0012013-06-21021 June 2013
Petitioners' Reply in Support of Petition to Intervene and for an Adjudicatory Public Hearing of FENOC License Amendment Request
ML14112A0062013-05-20020 May 2013
Exhibit 8 - Expert Witness Report of Arnold Gundersen, 50-246-LA
ML12334A2602012-11-29029 November 2012
Joint Proposed Corrections to the Transcript of the Oral Argument Held on November 5-6, 2012
ML12304A0652012-10-30030 October 2012
Motion to File Intervenors' Motion for Reconsideration of ASLB Order Granting Fenoc'S Motion to Strike Nunc Pro Tunc
ML12297A3532012-10-22022 October 2012
Intervenors' Motion for Reconsideration of ASLB Order Granting Fenoc'S Motion to Strike Intervenors' Reply in Opposition to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis-Source Terms)
ML12278A0402012-10-0404 October 2012
Intervenors' Response in Opposition to Fenoc'S Motion to Strike 'Intervenors' Reply in Opposition to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis - Source Terms).'
ML12268A3762012-09-24024 September 2012
Fenoc'S Motion to Strike Intervenors' Reply in Opposition to Firstenergy'S Motion for Summary Disposition of Contention 4 (SAMA Analysis - Source Terms).
ML12258A7772012-09-14014 September 2012
Intervenors' Reply in Opposition to 'Firstenergy'S Motion for Summary Disposition of Contention 4 (Sama Analysis - Source Terms).'
ML12237B1972012-08-24024 August 2012
Intervenors' Combined Reply to NRC and FENOC Answers to Inervenors' Third and Fourth Motions to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking)
Information Notice 2010-12, Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Contain2012-08-17017 August 2012
Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Containment Liner Cor
Information Notice 2010-12, Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notic2012-08-17017 August 2012
Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Containment Liner Cor
Information Notice 2010-12, Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Con2012-08-17017 August 2012
Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-51 Through B-53); Turkey Point Event Report; NRC Information Notice 2010-12: Containment Liner Cor
ML12230A0032012-08-17017 August 2012
Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-49 Through B-50)
ML12230A0022012-08-17017 August 2012
Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-44 Through B-48)
ML12230A0012012-08-17017 August 2012
Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Responses (B-39 Through B-43)
ML12230A0002012-08-17017 August 2012
Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix VI: NRC FOIA Response (B-33 Through B-38)
ML12229A5872012-08-16016 August 2012
Intervenors' Fifth Motion to Amend And/Or Supplement Proposed Contention No. 5 (Shield Building Cracking). Appendix III: NRC FOIA Responses (B-24 Through B-26)
2015-09-04
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November 12, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the Matter of )
)
DAVID GEISEN ) Docket No. IA-05-052
)
) ASLBP No. 06-845-01-EA
)
UNOPPOSED NRC STAFF MOTION FOR A PAGE LIMIT EXTENSION On October 23, 2008, the three judge panel of the Atomic Safety and Licensing Board
("Board") convened a conference call with counsel for Mr. Geisen and the U.S. Nuclear
Regulatory Commission Staff ("Staff") to determine the schedule for the path forward in this
proceeding. During the call, the Board set a schedule for the Staff to file a 10 page collateral
estoppel motion by November 17, 2008, with a response from Mr. Geisen by November 26, 2008.1 The Board set the week of December 1, 2008 for issuance of its ruling.
2 Pursuant to a March 27, 2006 Board Order, 3 the NRC Staff requests that it be allowed to file its motion for collateral estoppel in 25 pages or less. The NRC Staff believes that it will 1 Memorandum and Order (Summarizing Conf erence Call) at 3-4 (Nov. 3, 2008).
2 Transcript of Pre-Hearing Conference ITMO David Geisen at 731 (Oct. 23, 2008).
3 On March 27, 2006, the Board issued the Memorandum and Order Summarizing Conference Call (Granting All Hearing Requests, Setting Oral Argument on Staff's Abeyance Motion, and Addressing Related Matters). Appended to that Order was the "Standard Practice Manual," which set forth the administrative directives that are to apply to this proceeding. Section D.1 states that "Any motion filed after the date of the Board issuance to which this Manual is appended, and any related responsive pleadings to such a motion, shall not exceed t en pages in length (including signature page) absent preapproval of the Licensing Board. A request for B oard preapproval to exceed this page limitation shall be sought in writing no less than three business days pr ior to the time the motion or responsive pleading is filed or due to be filed. A reques t to exceed this page limitation must (1) indicate whether the request is opposed or supported by the other participants to the pr oceeding; (2) provide a good faith estimate of the number of additional pages that will be filed; and (3) demonstrate good cause for being permitted to exceed the page limitation." Memorandum and Order Summarizing Conference Call (Granting All Hearing Requests, Setting Oral Argument on Staff's Abeyance Motion, and Addressing Related Matters) at 13 (Mar. 27, 2006).
need additional pages in order to fully address the legal issues and to explain the jury's verdict in light of the evidence in the criminal trial. In accordance with 10 C.F.R. § 2.323(b), the NRC
Staff has contacted counsel for Mr. Geisen, who expressed no objection to this request.
Respectfully submitted, /RA/
Kimberly A. Sexton Counsel for the NRC Staff
Dated at Rockville, Maryland
this 12 th day of November, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the Matter of )
)
DAVID GEISEN ) Docket No. IA-05-052
) ) ASLBP No. 06-845-01-EA )
CERTIFICATE OF SERVICE I hereby certify that copies of a letter regarding a supplemental hearing file update and an "UNOPPOSED NRC STAFF MOTION FOR A PAGE LIMIT EXTENISON" in the above captioned proceeding have been served on the following persons by deposit in the United States Mail; through deposit in the Nuclear Regulatory Commission internal mail system as indicated by an asterisk (*); and by electronic mail as indicated by a double asterisk (**) on this 12th day of November, 2008.
Michael C. Farrar * **
Administrative Judge
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington, D.C. 20555
E-mail: Mike.Farrar@nrc.gov
Nicholas G. Trikouros * **
Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
Mail Stop: T-3 F23 Washington, D.C. 20555
E-mail: Nicholas.Trikouros@nrc.gov Adjudicatory File
- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
Mail Stop: T-3 F23 Washington, D.C. 20555
Office of the Secretary * **
Attn: Rulemaking and Adjudications Staff U.S. Nuclear Regulatory Commission
Mail Stop: O-16 G4 Washington, D.C. 20555 E-mail: Hearing.Docket@nrc.gov
E. Roy Hawkens * **
Chief Administrative Judge
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington, D.C. 20555
E-mail: Roy.Hawkens@nrc.gov Office of Commission Appellate Adjudication * ** U.S. Nuclear Regulatory Commission
Mail Stop: O-16 G4 Washington, D.C. 20555
Email: OCAAMAIL.Resource@nrc.gov Richard A. Hibey, Esq. **
Charles F.B. McAleer, Jr., Esq.
Andrew T. Wise, Esq.
Mathew T. Reinhard, Esq.
Miller & Chevalier 655 Fifteenth Street, N.W., Suite 900 Washington, D.C. 20005-5701
E-mail: rhibey@milchev.com awise@milchev.com mreinhard@milchev.com
Johanna Thibault * **
Board Law Clerk Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington, D.C. 20555
E-mail: Johanna.Thibault@nrc.gov Libby Perch * **
Board Staff Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 Washington, D.C. 20555
E-mail: Libby.Perch@nrc.gov
/RA/ ___________________________
Kimberly A. Sexton Counsel for the NRC Staff
