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Category:Legal-Pleading
MONTHYEARML24302A3212024-10-28028 October 2024
Miami Waterkeepers Reply in Support of Petition for Review of LBP-24-08
ML24292A1992024-10-18018 October 2024
NRC Staff Answer Opposing Petition for Commission Review of LBP-24-8
ML24292A1982024-10-18018 October 2024
Florida Power and Light Companys Answer Opposing Miami Waterkeepers Petition for Discretionary Review of LBP-24-08
ML24267A2982024-09-23023 September 2024
Miami Waterkeepers Petition for Review of the Atomic Safety and Licensing Boards Ruling in LBP-24-08
ML24264A1332024-09-20020 September 2024
Notice of Appearance for Jaclyn Lopez
ML24264A1322024-09-20020 September 2024
Notice of Appearance for Rachael Curran
ML24185A2542024-07-0303 July 2024
Miami Waterkeepers Answer to FPLs Motion to Strike Portions of Its Reply
ML24176A2712024-06-24024 June 2024
Applicants Motion to Strike Portions of the Reply Filed by Miami Waterkeeper Regarding the Motion to Admit New and Amended Contentions
ML24164A3182024-06-12012 June 2024
Miami Waterkeepers Reply in Support of Motion to Admit Amended and New Contentions
ML24155A1102024-06-0303 June 2024
NRC Staff Answer to Amended and New Contentions and Petition for Waiver
ML24155A2672024-06-0303 June 2024
Applicants Answer to Petitioners Motion to Admit New and Amended Contentions on the Final Site-Specific Environmental Impact Statement
ML24129A2212024-05-0808 May 2024
Miami Waterkeepers Petition for Waiver of 10 C.F.R. 51.53(C)(3) and 51.71(D) and 10 C.F.R. Part 51, Subpart a, Appendix B
ML24074A3022024-03-14014 March 2024
Notice of Withdrawal of Blake Vaisey on Behalf of NRC Staff
ML24023A2072024-01-23023 January 2024
Miami Waterkeeper’S Response in Opposition to Florida Power & Light Company’S Motion to Strike Portions of Miami Waterkeeper’S Reply
ML24008A2932024-01-0808 January 2024
Reply in Support of Request for Hearing and Petition to Intervene Submitted by Miami Waterkeeper
ML23356A1622023-12-22022 December 2023
NRC Staff Answer Opposing Miami Waterkeeper Hearing Request
ML23356A1562023-12-22022 December 2023
Florida Power and Light Companys Answer Opposing Miami Waterkeepers Hearing Request and Petition for Leave to Intervene
ML23352A3282023-12-18018 December 2023
Florida Power and Light Companys Answer Opposing Miami Waterkeepers Second Extension Request
ML23306A2862023-11-0202 November 2023
Answer in Opposition to Miami Waterkeeper Extension Request
ML22090A2102022-03-31031 March 2022
Florida Power and Light Companys Response to Other Parties Views on License Status as Requested in Commission Order CLI-22-02
ML22090A2482022-03-31031 March 2022
NRC Staffs Response to Views on Practical Effects
ML22080A2722022-03-21021 March 2022
Superseded License
ML22080A2332022-03-21021 March 2022
Views on License Status as Requested in Commission Order CLI-22-02
ML22080A2712022-03-21021 March 2022
Turkey Pont, Unit 3, Superseded License
ML22080A2702022-03-21021 March 2022
NRC Staff Views on the Practical Effects of (1) the Subsequent Renewed Licenses Continuing in Place and (2) the Previous Licenses Being Reinstated
ML20043F4402020-02-12012 February 2020
Notice of Withdrawal of Martin J. Oneill
ML19347D4582019-12-13013 December 2019
NRC Staff'S Brief in Response to Intervenors' Petition for Review of LBP-19-8
ML19347D0342019-12-13013 December 2019
Florida Power & Light Companys Answer Opposing Friends of the Earths, Natural Resources Defense Councils, and Miami Waterkeepers Petition for Review of LBP-19-8
ML19344D1332019-12-10010 December 2019
Notice of Appearance for Mary Frances Woods
ML19322D6232019-11-18018 November 2019
Friends of the Earth'S, Natural Resources Defense Council'S, and Miami Waterkeeper'S Petition for Review of the Atomic Safety and Licensing Board'S Ruling in LBP-19-08
ML19263D9092019-09-20020 September 2019
Reply of Friends of the Earth, Natural Resources Defense Council and Miami Waterkeeper in Support of Petition for Review of the Aslb'S Rulings in LBP-19-3 and LBP-19-06
ML19253E0512019-09-10010 September 2019
NRC Staff Answer to Petition for Review of LBP-19-3 and LBP-19-6
ML19253E1182019-09-10010 September 2019
Florida Power and Light Company'S Answer Opposing Intervenors' Petition for Review of LBP-19-3 and LBP-19-6
ML19226A3842019-08-14014 August 2019
Corrected Intervenors' Opposition to Florida Power & Light Co., Motion to Strike Intervenors' Reply to Fpl'S and NRC Staff'S Answer to Intervenors' Waiver Petition
ML19221B6772019-08-0909 August 2019
Friends of the Earth'S, Natural Resources Defense Council'S, and Miami Waterkeeper'S Petition for Review of the Atomic Safety and Licensing Board'S Rulings in LBP-19-3 and LBP-19-06
ML19221B6732019-08-0909 August 2019
Intervenors' Opposition to Florida Power & Light Company'S Motion to Strike Intervenors' Reply to Fpl'S and NRC Staff'S Answer to Intervenors' Waiver Petition
ML19214A0872019-08-0202 August 2019
Florida Power & Light Company'S Motion to Strike Intervenors' Reply to Fpl'S and NRC Staff'S Answers to Their Waiver Petition
ML19203A3502019-07-22022 July 2019
Errata to NRC Staff'S Answer to Joint Intervenors' (1) Amended Motion to Migrate or Amend Contentions 1E and 5E and to Admit Four New Contentions, and (2) Petition for Waiver.
ML19200A2982019-07-19019 July 2019
Florida Power & Light Company'S Answer to Intervenors' Petition for Waiver of Certain 10 C.F.R. Part 51 Regulations
ML19200A3002019-07-19019 July 2019
NRC Staff'S Answer to Joint Intervenors' (1) Amended Motion to Migrate or Amend Contentions 1-E and 5-E and to Admit Four New Contentions, and (2) Petition for Waiver
ML19200A2972019-07-19019 July 2019
Florida Power & Light Company'S Answer Opposing Intervenors' Motion to Migrate or Amend Contentions 1-E and 5-E and to Admit New Contentions 6-E, 7-E, 8-E, and 9-E
ML19179A3132019-06-28028 June 2019
Errata to Natural Resources Defense Council'S, Friends of the Earth'S, and Miami Waterkeeper'S Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staff'S Supplemental Draft Environmental Impact Statement
ML19175A3122019-06-24024 June 2019
Declaration of Kenneth Rumelt in Support of Waiver Petition
ML19175A3112019-06-24024 June 2019
Natural Resources Defense Council'S, Friends of the Earth'S, and Miami Waterkeeper'S Petition for Waiver of 10 CFR 51.53(C)(3) and 51.71(D) and 10 CFR Part 51, Subpart a, Appendix B
ML19161A3602019-06-10010 June 2019
Joint Petitioners' Answer Opposing Fpl'S Motion to Dismiss Joint Petitioners' Contention 1-E as Moot
ML19161A3612019-06-10010 June 2019
Joint Petitioners' Answer Opposing Fpl'S Motion to Dismiss Joint Petitioners' Contention 5-E as Moot
ML19161A2522019-06-10010 June 2019
NRC Staff'S Answer to Fpl'S Motions to Dismiss
ML19140A3552019-05-20020 May 2019
Fpl'S Motion to Dismiss Joint Petitioners' Contention 1-E as Moot
ML19140A3562019-05-20020 May 2019
Fpl'S Motion to Dismiss Joint Petitioners' Contention 5-E as Moot
ML19130A1632019-05-10010 May 2019
Intervenors' Initial Mandatory Disclosure Report Under 10 C.F.R. 2.336
2024-09-23
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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 ANSWER SUPPORTING THE NRC STAFFS MOTION IN LIMINE Florida Power & Light Company hereby answers the NRC Staffs Motion in Limine to Exclude Portions of the Prefiled Rebuttal Testimony or in the Alternative Strike Portions of the Prefiled Rebuttal Testimony and Rebuttal statement of Position, dated December 14, 2015.
FPL supports the motion. CASEs Rebuttal includes arguments and testimony on matters that should have been raised in CASEs case-in-chief, discussion of issues that are beyond the scope of the contention, testimony offered without proper foundation regarding the expertise of the witness, non-sworn statements attributed to a witness, and citation to documents that were not properly disclosed. As explained in the NRC Staffs motion, these portions of CASEs rebuttal should all be excluded.
CERTIFICATION I certify that I have made a sincere effort to be available to consult with the moving party, and to attempt in good faith to resolve the factual and legal issues raised in the motion, and that my efforts to resolve the issues have been unsuccessful. While FPL and the NRC Staff were able to reach agreement, efforts to resolve the issues with CASE were unsuccessful.
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 December 15, 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 Florida Power & Light Companys Answer Supporting the NRC Staffs Motion in Limine 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 15th day of December, 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 ANSWER SUPPORTING THE NRC STAFFS MOTION IN LIMINE Florida Power & Light Company hereby answers the NRC Staffs Motion in Limine to Exclude Portions of the Prefiled Rebuttal Testimony or in the Alternative Strike Portions of the Prefiled Rebuttal Testimony and Rebuttal statement of Position, dated December 14, 2015.
FPL supports the motion. CASEs Rebuttal includes arguments and testimony on matters that should have been raised in CASEs case-in-chief, discussion of issues that are beyond the scope of the contention, testimony offered without proper foundation regarding the expertise of the witness, non-sworn statements attributed to a witness, and citation to documents that were not properly disclosed. As explained in the NRC Staffs motion, these portions of CASEs rebuttal should all be excluded.
CERTIFICATION I certify that I have made a sincere effort to be available to consult with the moving party, and to attempt in good faith to resolve the factual and legal issues raised in the motion, and that my efforts to resolve the issues have been unsuccessful. While FPL and the NRC Staff were able to reach agreement, efforts to resolve the issues with CASE were unsuccessful.
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 December 15, 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 Florida Power & Light Companys Answer Supporting the NRC Staffs Motion in Limine 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 15th day of December, 2015
