ML17207A856
| ML17207A856 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/13/1980 |
| From: | Coll N FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8002290033 | |
| Download: ML17207A856 (6) | |
Text
fO UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE, ATOMIC SAFETY AND LICENSING APPEAL BOARD Xn the Matter of FLORIDA POWER 6 LIGHT COMPANY I
(St. Lucie Nuclear Power Plant, Unit No.
2)
Docket No. 50-389 MOTXON FOR EXTENSION OF TIME TO SUBMIT. DIESEL'. GENERATOR DATA Florida Power 6 Light Company moves for an order extending the time within which to submit the data requested by the Board on the St. Lucie. 1 diesel generators on the following grounds:
(1)
The information is contained, in the daily plant log entries made since. 1976 which are. handwritten, in abbreviated language,.
and are not, capable of readily being reviewed and interpreted.
(2)
After initial efforts were made, to compile the information from review of each of the daily plant log
- entries, the data compiled was.randomly re-checked and. it was discover'ed that all of the. available information had not been retrieved.
(3)
Xn order to accurately compile the information which does-exist, additional time will be required.
(4)
In, order to analyze the data and present it in a form.which is understandable,,
additional time is also 8 OOSSQ6
necessary so that persons gathering. the. data, can. communicate with those persons who recorded it, perform the analysis, and prepare the. requisite affidavit(s) to accompany the data.
Florida, Power 6 Light Company requests an extension of time from February 15, 1980 to March 14, 1980 within which to submit the information to the Board and'he parties.
Counsel for the NRC Staff, William.Olmstead,- Esq.,
has authorized us to represent to the Board that the NRC Staff has no objection, to the grant of this motion.
Counsel for Intervenors, Martin H. Hodder, Esq.,
has authorized us to represent to the Board that the Intervenors have no objection.
to the grant of this motion if the Intervenors are afforded two (2) weeks 'from the date the data is submitted. within which to submit. their proposed Findings of Fact and Conclusions of Law.
We suggest that the present schedule for submission of Findings, of Fact and Conclusions of Law not be modified, but that. the Board:,permit any party to file a supplement, if it desires, within two (2). weeks from the date the data is submitted.
Respectfully submitted, L. 33131 e:
(305) 577-2863 Telepho STEEL,'ECTOR 6 DAVIS Co-'counsel for Applicant Florida-Power
- a. Light. Company 1400.-Southeast,.First, National Bk. Bldg.
Miam3. (
By NORMAN A.
COLL
UNITED-.STATES OF AMERICA NUCLEAR. REGUL'ATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING.APPEAL BOARD In the Matter of FLGRIDA POWER
& LIGHT COMPANY (St. Lucie Nuclear. Power Plant, Unit No.. 2)
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Docket No. 50-389
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CERTIFICATE. OF SERVICE WE HEREBY CERTIFY that. true and correct copies of FPL's "Motion for Extension of Time to Submit Diesel Generator Data," captioned in the above matter, were. served on the following by deposit in the United States. mail, first class, properly stamped and addressed,,
on the date shown below:
Mr. C.
R. Stephens, Supervisor Docketing and Service Section Office of the Secretary'f the Commission Nuclear Regulatory Commission Washington, DC 20555
- Michael C. Farrar,'Esq..
Chairman Atomic Safety
& Licensing Appeal Board Nuclear Regulatory Commission Washington, DC 20555
- Dr. W.. Reed Johnson Atomic Safety
& Licensing Appeal Board Nuclear Regulatory Commission Washington, DC 20555-
- Richard S.
- Salzman, Esq.
Atomic Safety
& Licensing
'ppeal Board Nuclear. Regulatory Commission Washington, DC 20555
.Alan S. Rosenthal, Esq.
'hairman Atomic Safety
& Licensing Appeal Panel Nuclear Regulatory Commission Washington, DC 20555 Edward Luton, Esq.
Chai:rman Atomic Safety
& Licensing Board Panel Nuclear Regulatory Commission Washington, DC 20555
Michael Glaser, Esq.
Alternate Chairman Atomic. Safety &,Licensing"Board 1150 17th Street,.
NW Washington, DC 20036 Dr. Marvin M. Mann",
Technical Advisor Atomic Safety,& L'icensing Board Nucl'ear Regulatory Commission Washington,-DC
- 20555, Dr. David L. Hetrick Professor of Nuclear Engineering University of Arizona
- Tuscon, AZ 85721 Terence J. Anderson, Esq.
University of Miami School of Law Coral Gables, FL. 33134 William D. Paton, Esq.
Counsel, for NRC Regulatory Staff Nuclear Regulatory Commission Washington, DC 20555 William J.
- Olmstead, Esq.
Nuclear Regulatory Commission Washington, DC 20555 Dr. Frank F. Hooper Chairman Resource Ecology Program School of Natural Resouxces University of Michigan Ann, Arbor,'I 48104 Local Public Document Room Indian'iver'Junior College
'ibrary 3209 Virginia Avenue Ft. Pierce, FL.
33450 Martin Harold Hodder, Esq.
1130 NE 86 Street Miami, FL. '33138 Harold F. Reis, Esq.
Lowenstein, Newman, Reis, Axelrad
& Toll 1025 Connecticut Avenue, NW Washington, DC 20036 DATED this 13th day of
- February, 1980.
- STEEL, HECTOR
& DAVIS Co-Counsel'for Applicant Flo'rida Power
& Light, Company 1400 Southeast First National Bk. Bldg.
- Miami, FQ Telephong 33131 (305) 577-2863 NORMAN A. COLL
- delivexed by courier service to Messrs.
- Farrar, Johnson and Salzman
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before 'the Atomic Licensing And Licensing Appeal Board Michael C. Farrar, Chairman and presiding officer In the Matter of
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FLORIDA POWER
& LIGHT COMPANY
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(St; Lucie Nuclear Power Plant, )
Unit No.
2)
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Docket No. 50-389 Motion for Leave to File Intervenors move that the Appeal Board grant leave to file the enclosed Intervenors'eply and in support of this motion intervenors state:
1.
On December 14, 1979, the Appeal Board granted FPL and the staff leave to respond to intervenors motion requesting consideration of class 9 accidents by January 18,
- 1980, and granted intervenors leave to file a reply within two weeks thereafter (Tr. pp. 877-79).
2.
The undersigned counsel received a copy of FPL's response on or about January 18, 1980, but did not receive a
copy of the staff's response until January 29 and co-counsel, Mr. Hodder, received it in the mail on January 24, 1980.
f4 3.
Because 'of the delay in the mail. and the confusion-over whether'.
a copy had bee'n sent to the undersigned, Inter-venors'eply was not completed and mailed until February 5, 19 80.
4.
Under Commission rules, because the responses were served by mail, intervenors would have two weeks plus five days or until February 6,
1980, to file their reply.
10 CFR 5 2.710.
Because 'confusion has arisen over whether the Appeal J
Board intended this rule to apply when it granted intervenors leave to reply,.intezvenors have submitted this motion.
Respectfully submitted,
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Terence J. Anderson University of Miami School
~.of Law Coral Gables, Florida 33134 (305) 284-2253 or 2971