ML15212A756

San Luis Obispo Mothers for Peace'S Unopposed Motion for Extension of Time

ML15212A756
Person / Time
Site:	Diablo Canyon
Issue date:	07/31/2015
From:	Curran D Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-275-LR, 50-323-LR, ASLBP 10-900-01-LR-BD01, RAS 28100
Download: ML15212A756 (2)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR Diablo Canyon Nuclear Power Plant 50-323-LR Units 1 and 2 SAN LUIS OBISPO MOTHERS FOR PEACES UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to 10 C.F.R. §§ 2.323, San Luis Obispo Mothers for Peace (SLOMFP) seeks an extension of time to respond to Pacific Gas & Electric Companys (PG&Es) Motion for Summary Disposition of Contention EC-1, filed today (July 31, 2015). Under 10 C.F.R. § 2.1205(b), SLOMFP will have twenty days, or until August 20, to respond to PG&Es Motion.

During much of the response period (August 7 through August 21), counsel for SLOMFP will be on a long-planned family vacation, away from telephones and the internet. And SLOMFP has no other counsel that can respond to the motion. Therefore SLOMFP respectfully requests the Atomic Safety and Licensing Board to extend the time period for responding to PG&Es motion from August 20 to September 14, by starting the clock for SLOMFPs response at August 24.

Counsel for SLOMFP has been authorized to state that PG&E supports this motion and the NRC Staff has no objection.

Respectfully submitted,

[Electronically signed by]

Diane Curran Harmon, Curran, Spielberg & Eisenberg, L.L.P.

1726 M Street N.W. Suite 600 Washington, D.C. 20036 202-328-3500 E-mail: dcurran@harmoncurran.com July 31, 2015

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR Diablo Canyon Nuclear Power Plant 50-323-LR Units 1 and 2 SAN LUIS OBISPO MOTHERS FOR PEACE CERTIFICATE OF SERVICE I certify that on July 31, 2015, I posted on the NRCs Electronic Information Exchange SAN LUIS OBISPO MOTHERS FOR PEACES UNOPPOSED MOTION FOR EXTENSION OF TIME. It is my understanding that as a result, the NRC Commissioners, Atomic Safety and Licensing Board, and parties to this proceeding were served.

Respectfully submitted, Electronically signed by Diane Curran Harmon, Curran, Spielberg & Eisenberg, L.L.P.

1726 M Street N.W. Suite 600 Washington, D.C. 20036 202-328-3500 Fax: 202-328-6918 E-mail: dcurran@harmoncurran.com 1