ML020660181

Tennessee Valley Authority'S Motion for Leave to File Reply in Support of Motion for Summary Decision

ML020660181
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah
Issue date:	03/01/2002
From:	Slater J Tennessee Valley Authority
To:	Atomic Safety and Licensing Board Panel
Byrdsong A
References
+adjud/rulemjr200506, 50-259-CIVP, 50-260-CIVP, 50-296-CIVP, 50-327-CIVP, 50-328-CIVP, 50-390-CIVP, ASLBP 01-791-01-CIVP, EA-99-234, RAS 4010
Download: ML020660181 (3)

Text

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1q45 IolD DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2002 MAR -5 AM II: 17 ATOMIC SAFETY AND LICENSING BOARD 3JFICE;f iiE ;YtIM<ETARY RULEDN "KINGS ANO ADJUDICATIONS STAFF IN THE MATTER OF ) Docket Nos. 50-390-CivP;

) 50-327-CivP; 50-328-CivP; TENNESSEE VALLEY AUTHORITY ) 50-259-CivP; 50-260-CivP;

) 50-296-CivP

)

(Watts Bar Nuclear Plant, Unit 1; ) ASLBP No. 01-791-01-CivP Sequoyah Nuclear Plant, Units 1 & 2; )

Browns Ferry Nuclear Plant, ) EA 99-234 Units 1, 2, & 3) )

TENNESSEE VALLEY AUTHORITY'S MOTION FOR LEAVE TO FILE REPLY IN SUPPORT OF MOTION FOR

SUMMARY

DECISION Pursuant to 10 C.F.R. §§ 2.730 and 2.749, the Tennessee Valley Authority (TVA) moves for leave to file a reply in support of its motion for summary decision which is filed contemporaneously herewith. The NRC Staff's response to TVA's motion for summary decision was 48 pages in length, focused on many issues and facts not pertinent to the pending motion, and overstated other facts and/or the inferences it wishes the Board to draw from such facts. We believe a short reply would be helpful to the Board in that it addresses those overstated facts and inferences that the NRC Staff raised in its response in opposition to TVA's motion for summary decision.

Te7p/5 UVes v-OV/

Respectfully submitted, March 1, 2002 Maureen H. Dunn General Counsel Office of the General Counsel Tennessee Valley Authority Thomas F. Fine 400 West Summit Hill Drive Assistant General Counsel Knoxville, Tennessee 37902-1401 Facsimile 865-632-6718 Brent R. Marquand Senior Litigation Attorney Barbara S. Maxwell, Attorney Of Counsel: Jo E. Sla (SC Bar No. 005149)

David A. Repka, Esq. Senior Litigation Attorney Winston & Strawn Telephone 865-632-7878 1400 L Street, NW Washington, D.C. 20005 Attorneys for Tennessee Valley Authority 003692664 2

CERTIFICATE OF SERVICE I hereby certify that the foregoing motion for leave to file reply in support of TVA's motion for summary decision, together with the reply, has been served by regular mail on the persons listed below. Copies of the motion and reply, less the attachments which are being sent by regular mail, have also been sent by e-mail to those persons listed below with e-mail addresses.

Administrative Judge Administrative Judge Charles Bechhoefer, Chairman Richard F. Cole U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Two White Flint North Two White Flint North 11545 Rockville Pike 11545 Rockville Pike Rockville, Maryland 20852-2738 Rockville, Maryland 20852-2738 e-mail address: cxb2@nrc.gov e-mail address: rfclCnrc.gov Administrative Judge Dennis C. Dambly, Esq.

Ann Marshall Young Jennifer M. Euchner, Esq.

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Two White Flint North One White Flint North 11545 Rockville Pike 11555 Rockville Pike Rockville, Maryland 20852-2738 Rockville, Maryland 20852-2738 e-mail address: amyCnrc.gov e-mail address: dcd~nrc.gov e-mail address: jme~nrc.gov Office of Commission Appellate Adjudication Mr. William D. Travers U.S. Nuclear Regulatory Commission Executive Director of Operations One White Flint North U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint North Rockville, Maryland 20852-2738 11555 Rockville Pike Rockville, Maryland 20852-2738 This 1st day of March, 2002.

Attokney for Xnnessee Valley Authority 3