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Category:Legal-Pleading
MONTHYEARML20279A4812020-10-0505 October 2020 C-10 Research and Education Foundation'S Reply to Oppositions to Motion for Partial Reconsideration and Motion to Re-Open the Record for Consideration of Supplemental Testimony Regarding License Conditions in LBP-20-09 ML20272A2742020-09-28028 September 2020 Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply and Motion for Leave to File INT053 ML20254A2342020-09-10010 September 2020 Nextera'S Answer Opposing C-10 Motion for Leave and Motion for Partial Reconsideration of LBP-20-9 ML20254A2352020-09-10010 September 2020 Nextera'S Answer Opposing C-10 Motion to Reopen the Record for Consideration of Supplemental Testimony ML20244A3212020-08-31031 August 2020 C-10 Research and Education Foundation'S Motion for Partial Reconsideration and Motion to Re-Open the Record for Consideration of Supplemental Testimony Regarding License Conditions in LBP-20-09 ML20244A3202020-08-31031 August 2020 C-10 Research and Education Foundation'S Motion for Leave to File Motion for Partial Reconsideration of LBP-20-09 ML20043E2542020-01-31031 January 2020 Redacted C-10 Research and Education'S Supplemental Proposed Findings of Fact and Conclusions of Law ML20031D6992020-01-31031 January 2020 NRC Staff Supplemental Proposed Findings of Fact and Conclusions of Law ML20031E7222020-01-31031 January 2020 NextEra Energy Seabrook Llc'S Supplemental Proposed Findings of Fact and Conclusions of Law ML19354C4482019-12-20020 December 2019 C-10 Research and Education Foundation'S Response to Nextera'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law ML19353D4192019-12-19019 December 2019 C-10 Research and Education Foundation'S Response to Nextera'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law ML19347D0672019-12-13013 December 2019 NextEra Energy Seabrook Llc'S Motion for Leave to File Responsive Proposed Findings of Fact and Conclusions of Law ML19347D0702019-12-13013 December 2019 NextEra Energy Seabrook Llc'S Responsive Proposed Findings of Fact and Conclusions of Law ML19333B9702019-11-29029 November 2019 Unopposed Motion for Extension of Time to Seek Leave to File Responsive Proposed Findings of Fact and Conclusions of Law ML20043E2522019-11-27027 November 2019 Redacted Corrected C-10 Research and Education Foundation'S Proposed Findings of Fact and Conclusions of Law ML19325D9092019-11-21021 November 2019 NRC Staff Proposed Findings of Fact and Conclusions of the Law for the Admitted Contention ML19325F3902019-11-21021 November 2019 NextEra Energy Seabrook Llc'S Proposed Findings of Fact and Conclusions of Law ML19310E2592019-11-0606 November 2019 Nextera'S Answer Opposing C-10's Third Motion for Leave to File Supplemental Testimony ML19304B3522019-10-31031 October 2019 C-10 Research and Education Foundation'S Response to ASLB Memorandum and Motion to Submit Additional Exhibits Regarding Petrographic Observations and Analyses of ASR at Seabrook ML19283A0362019-10-0909 October 2019 Nextera'S Answer Opposing C-10's Motions to Compel Production of Mineralogical Data and to Submit Additional Post-Hearing Testimony ML19272B3252019-09-30030 September 2019 C-10 Research and Education Foundation'S Motion to Compel Production of Mineralogy Data and Request for Opportunity to Submit Supplemental Written Testimony Regarding the Data ML19262K7512019-09-19019 September 2019 C-10 Research and Education Foundation'S Opposition to Nextera'S Second Motion in Limine ML19261B8802019-09-18018 September 2019 NRC Staff'S Answer to Nextera'S Motion in Limine ML19254F1582019-09-11011 September 2019 Appendix a Revised Exhibit List for September 2019 Evidentiary Hearing Exhibits ML19253D6782019-09-10010 September 2019 NRC Staff'S Answer to C-10's Motion to Supplement Rebuttal Testimony ML19252B3072019-09-0909 September 2019 NextEra Answer Opposing C-10 Motion for Leave to File Supplemental Rebuttal ML19252B2322019-09-0909 September 2019 Nextera'S Motion in Limine to Strike or Exclude Portions of C-10's Testimony and Exhibits ML19247D5932019-09-0404 September 2019 C-10 Research and Education Foundation'S Motion for Leave to File Supplemental Rebuttal Testimony ML19235A3172019-08-23023 August 2019 C-10 Research and Education Foundation, Inc. Rebuttal Statement of Position on C-10's Contentions Regarding Nextera'S Program for Managing ASR at Seabrook Station Nuclear Power Plant ML19235A3182019-08-23023 August 2019 Appendix a Revised Exhibit List ML19205A3412019-07-24024 July 2019 NRC Staff Initial Written Statement of Position ML19205A4882019-07-24024 July 2019 NextEra Energy Seabrook LLC Statement of Position and Certificate of Service ML19171A4012019-06-20020 June 2019 C-10 Research and Education Foundation'S Errata to Exhibit INT-001, Testimony of Dr. Victor E. Saouma ML19161A3722019-06-10010 June 2019 Appendix a Exhibit List ML19161A3712019-06-10010 June 2019 C-10 Research and Education Foundation, Inc. Initial Statement of Position on Contentions Re Nextera'S Program for Managing ASR at Seabrook Station ML19123A1912019-05-0303 May 2019 C-10 Research and Education Foundation'S Opposition to Nextera'S Motion in Limine ML19114A0762019-04-23023 April 2019 Nextera'S Motion in Limine to Exclude Testimony and Exhibits Regarding Structure Deformation Monitoring ML19105B2822019-04-15015 April 2019 Nextera'S Answer Opposing C-10's Motion Regarding Seabrook Station Site Tour ML19101A4082019-04-11011 April 2019 C-10 Research and Education Foundation'S Motion Regarding Seabrook Station Site Tour ML19064B4022019-03-0505 March 2019 Nextera'S Answer Opposing C-10's Motion for Leave to File a Reply to Answers to C-10's Emergency Petition ML19064A6322019-03-0505 March 2019 Notice of Appearance for Jennifer E. Scro ML19060A3042019-03-0101 March 2019 C-10 Research and Education Foundation'S Reply to Oppositions by NextEra and NRC Staff to Emergency Petition for Exercise of Commission'S Supervisory Authority to Reverse No Significant Hazards Determination and Immediately Suspend License ML19060A3032019-03-0101 March 2019 C-10 Research and Education Foundation'S Motion for Leave to File Reply to Oppositions by NextEra and NRC Staff to Emergency Petition ML19056A5882019-02-25025 February 2019 NRC Staff Answer to C-10's Emergency Petition ML19056A5862019-02-25025 February 2019 Nextera'S Answer Opposing C-10 Emergency Petition ML19044A7702019-02-13013 February 2019 Exhibit 1 to Saouma Declaration: Curriculum Vitae for Dr. Victor E. Saouma ML19044A7682019-02-13013 February 2019 Emergency Petition by C-10 Research and Education Foundation for Exercise of Commission'S Supervisory Authority to Reverse No Significant Hazards Determination and Immediately Suspend License Amendment and License Renewal Decisions ML19044A7692019-02-13013 February 2019 Declaration of Victor E. Saouma, Ph.D ML19044A7722019-02-13013 February 2019 Exhibit 3 to Saouma Declaration: Sauoma, Experimental and Numerical Investigation of Alkali Silica Reaction in Nuclear Reactors, Final Summary Report ML19044A7732019-02-12012 February 2019 Exhibit 4a to Saouma Declaration: Introduction and Executive Summary 2020-09-28
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of: )
) Docket No. 50-443-LA-2 NEXTERA ENERGY SEABROOK, LLC )
) November 29, 2019 (Seabrook Station Unit 1) )
)
UNOPPOSED MOTION FOR EXTENSION OF TIME TO SEEK LEAVE TO FILE RESPONSIVE PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW On November 21, 2019, NextEra Energy Seabrook, LLC (NextEra), C-10 Research and Education Foundation (C-10), and the U.S. Nuclear Regulatory Commission (NRC)
Staff filed their respective Proposed Findings of Fact and Conclusions of Law (Proposed Findings), under 10 C.F.R. § 2.1209.1 At the evidentiary hearing, the Atomic Safety and Licensing Board instructed that the parties would need to seek leave to submit any Responsive Proposed Findings.2 The current deadline for such motions is December 2, 2019the Monday after Thanksgiving.3 Pursuant to 10 C.F.R. §§ 2.323 and 2.307, NextEra requests a brief extension of that deadline.
NextEra is currently evaluating the parties Proposed Findings and has not yet decided whether to seek leave to file Responsive Proposed Findings. Given the Thanksgiving holiday and corresponding availability limitations for relevant subject matter experts, NextEra requests a brief four-day extension of the deadline (i.e., until December 6, 2019) for submitting a motion 1
NextEra Energy Seabrook, LLCs Proposed Findings of Fact and Conclusions of Law (Nov. 21, 2019); NRC Staff Proposed Findings of Fact and Conclusions of Law for the Admitted Contention (Nov. 21, 2019); C-10 Research and Education Foundations Proposed Findings of Fact and Conclusions of Law (Nov. 21, 2019) 2 Tr. at 1181.
3 See 10 C.F.R. § 2.323(a)(2).
for leave to submit Responsive Proposed Findings (along with the Responsive Proposed Findings themselves). As required by 10 C.F.R. § 2.323(b), NextEra consulted the other parties in this proceeding regarding this Motion. C-10 joins the Motion, but requests that the deadline be extended an additional week (i.e., until December 13, 2019).4 The NRC Staff does not object to the Motion.
Respectfully submitted, Executed in Accord with 10 C.F.R. § 2.304(d) Executed in Accord with 10 C.F.R. § 2.304(d)
Steven Hamrick, Esq. Paul M. Bessette, Esq.
NextEra Energy Seabrook, LLC Morgan, Lewis & Bockius LLP 801 Pennsylvania Ave., NW Suite 220 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Washington, D.C. 20004 Phone: (202) 349-3496 Phone: (202) 739-5796 Fax: (202) 347-7076 Fax: (202) 739-3001 E-mail: steven.hamrick@fpl.com E-mail: paul.bessette@morganlewis.com Signed (electronically) by Ryan K. Lighty Ryan K. Lighty, Esq.
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Phone: (202) 739-5274 Fax: (202) 739-3001 E-mail: ryan.lighty@morganlewis.com Counsel for NextEra Energy Seabrook, LLC Dated in Washington, DC this 29th day of November 2019 4
Counsel for C-10 stated that C-10 requests an extension until December 13, 2019 due to an important and unavoidable family obligation by C-10s counsel during the entire week of December 2-6, 2019.
2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of: )
) Docket No. 50-443-LA-2 NEXTERA ENERGY SEABROOK, LLC )
) November 29, 2019 (Seabrook Station Unit 1) )
)
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, the foregoing Unopposed Motion for Extension of Time to Seek Leave to File Responsive Proposed Findings of Fact and Conclusions of Law was served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned proceeding.
Signed (electronically) by Ryan K. Lighty Ryan K. Lighty, Esq.
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Phone: (202) 739-5274 Fax: (202) 739-3001 E-mail: ryan.lighty@morganlewis.com Counsel for NextEra Energy Seabrook, LLC DB1/ 110188092.1