ML17339A453

Motion for Extension Until 790114 to Reply to Intervenor 791217 Responses Treated as Motion to Compel.Withdrawal of Certain Objections to Intervenor Discovery Depends on Available Technical Personnel.Certificate of Svc Encl

ML17339A453
Person / Time
Site:	Turkey Point
Issue date:	12/21/1979
From:	Reis H FLORIDA POWER & LIGHT CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8001150188
Download: ML17339A453 (8)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD gl ~"

I Zn the Matter of )

)

FLORIDA PONER & LIGHT COMPANY ) Docket Nos. 50-250-SP

) 50-251-SP (Turkey Point Nuclear Generating )

Unit Nos.. 3 and 4) )

)

) ~

MOTION FOR EXTENTION OF TIME

'ICENSEE' On December 17, 1979, the Intervenor served on the Licensee a document entitled "Intervenor's Responses to Licensee's Objections to Intervenor's Interrogatories to and Request for the Production of Documents from Licensee, Florida Power &

Light Company." The Intervenor requested that the Licensing Board order the Licensee to answer specific discovery requests.

Consequently, the Licensee assumes that the Intervenor intends that the docu-ent be treated as a motion to compel, aind tiNe Licensee hereby declares its intention to file an'nswer to motion as permitted by 10 CFR .52.730 (c) .

r'he.

As part of its answer to the motion to compel, the Licensee i.'s considering whether to withdraw some of ~ts objections to specific interrogatories. The determination of which objections 80011go /Kp

(

~ i.

wil'1 be withdrawn depends, to a large extent, upon the recom-mendations, of the Licensee's technical personnel. However, due to the upcoming:holiday season, many of these individuals will. be unavailable for consultation. Therefore, to -enable the Licensee to confer with its technical staff,, the Licensee requests an extension to January 14, 1979 in which to.file its answer to the Xntervenor's motion.

The Intervenor's counsel has stated that 'ne has no'bjec-tion to the granting of this extension.

Respectfully 'submitted, Haro F. Ress Lowenstein; Newman, Reis, Axelrad & Toll Co-counsel for Licensee 1025 Connecticut Ave., N.W.

Washington,. D;. C ..200 36 (202) 862-8400 Dated this 21st day of December, 1979..

.iO UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-250-SP

)

50-25l-SP FLORIDA -POWER & LIGHT COMPANY )

) (Proposed Amendments to (Turkey Point Nuclear Generating ) Facility Operating Licenses Unit Nos. 3 and 4) ) to Permit Steam Generator

) Repair)

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of the attached Licensee's Motion for Extension of Time captioned in the above matter was served on the following by deposit in the United States mail, first class,, properly stamped and addressed, on the date shown below.

Elizabeth S. Bowers, Esquire Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr, Oscar H. Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board Panel U. S. 'Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555

, ~

Atomic Safety and Li'censing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr.,Mark P. Oncavage 12200,S.W. 110 Avenue Miami, FL 33176 Docketing and Service Section, Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Steven C. Goldberg,. Esquire Office of the Executive Legal. Director U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Bruce S. Rogow, Esquire Joel V. Lumer, Esquire Richard .A. Marshall, Jr., Esquire Counsel for .Intervenor 3301 College Avenue Fort Lauderdale, FL'3314 Norman A. Coll, Esquire Steel, Hector 'a Davis 14th Floor Southeast First National Bank Building Miami, FL 33131 Dated this 21st day of December, 1979.

Harold'. Reis Lowenstein, Newman, Reis, Axelrad & Toll Co-counsel for L'icensee 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036, (202) 862-8400

Ci Q>.