ML15321A477

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FPL Unopposed Motion for Extension of Time to File Motions for Summary Disposition
ML15321A477
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 11/17/2015
From: Hamrick S
Florida Power & Light Co
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-250-LA, 50-251-LA, ASLBP 15-935-02-LA-BD01, RAS 28564
Download: ML15321A477 (3)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

) Docket No. 50-250-LA Florida Power & Light Company ) 50-251-LA

)

(Turkey Point Units 3 and 4) ) ASLBP No. 15-935-02-LA-BD01 FLORIDA POWER & LIGHT COMPANYS UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTIONS FOR

SUMMARY

DISPOSITION Pursuant to 10 C.F.R. § 2.323, Florida Power & Light Company (FPL) moves the Atomic Safety and Licensing Board to extend the regulatory deadline for motions for summary disposition. Currently, the hearing in this proceeding is scheduled for the week of January 11, 2016. Under 10 C.F.R. § 2.1205, motions for summary disposition may not be filed later than 45 days prior to the start of the hearing. Depending on the ultimate hearing date, this deadline would fall between November 30 and December 2. Currently, CASEs deadline for filing rebuttal testimony is December 1, 2015. FPL believes that it would be most efficient for such motions, if appropriate, to be filed following the submission of all testimony. For this reason, FPL requests a modest extension of this deadline to December 4, 2015.

CERTIFICATION I certify that I have made a sincere effort to contact the other parties in this proceeding, to explain to them the factual and legal issues raised in this motion, and to resolve those issues.

Neither the NRC Staff nor CASE oppose the motion.

Respectfully Submitted, Signed (electronically) by Steven Hamrick Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 William S. Blair Erin Walkowiak Florida Power & Light Company 700 Universe Blvd.

Juno Beach, Florida 33408 william.blair@fpl.com erin.walkowiak@fpl.com 561-304-5238 November 17, 2015 COUNSEL FOR FLORIDA POWER & LIGHT COMPANY 2

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

) Docket No. 50-250-LA Florida Power & Light Company ) 50-251-LA

)

(Turkey Point Units 3 and 4) ) ASLBP No. 15-935-02-LA-BD01 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Unopposed Motion for Extension of Time to File Motions for Summary Disposition were provided to the E-Filing system for service to those individuals on the service list in this proceeding.

Signed (electronically) by, Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 Dated at Washington, DC this 17th day of November, 2015

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

) Docket No. 50-250-LA Florida Power & Light Company ) 50-251-LA

)

(Turkey Point Units 3 and 4) ) ASLBP No. 15-935-02-LA-BD01 FLORIDA POWER & LIGHT COMPANYS UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTIONS FOR

SUMMARY

DISPOSITION Pursuant to 10 C.F.R. § 2.323, Florida Power & Light Company (FPL) moves the Atomic Safety and Licensing Board to extend the regulatory deadline for motions for summary disposition. Currently, the hearing in this proceeding is scheduled for the week of January 11, 2016. Under 10 C.F.R. § 2.1205, motions for summary disposition may not be filed later than 45 days prior to the start of the hearing. Depending on the ultimate hearing date, this deadline would fall between November 30 and December 2. Currently, CASEs deadline for filing rebuttal testimony is December 1, 2015. FPL believes that it would be most efficient for such motions, if appropriate, to be filed following the submission of all testimony. For this reason, FPL requests a modest extension of this deadline to December 4, 2015.

CERTIFICATION I certify that I have made a sincere effort to contact the other parties in this proceeding, to explain to them the factual and legal issues raised in this motion, and to resolve those issues.

Neither the NRC Staff nor CASE oppose the motion.

Respectfully Submitted, Signed (electronically) by Steven Hamrick Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 William S. Blair Erin Walkowiak Florida Power & Light Company 700 Universe Blvd.

Juno Beach, Florida 33408 william.blair@fpl.com erin.walkowiak@fpl.com 561-304-5238 November 17, 2015 COUNSEL FOR FLORIDA POWER & LIGHT COMPANY 2

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

) Docket No. 50-250-LA Florida Power & Light Company ) 50-251-LA

)

(Turkey Point Units 3 and 4) ) ASLBP No. 15-935-02-LA-BD01 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Unopposed Motion for Extension of Time to File Motions for Summary Disposition were provided to the E-Filing system for service to those individuals on the service list in this proceeding.

Signed (electronically) by, Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 Dated at Washington, DC this 17th day of November, 2015