ML17340A936
| ML17340A936 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/30/1981 |
| From: | Chonin N CHONIN, N., ONCAVAGE, M. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8104080494 | |
| Download: ML17340A936 (8) | |
Text
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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 8
THE ATOMIC SAFETY AND LICENSING:BOARD In'he Matter of
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Docket Nos.
50=2~50 FLORIDA POWER AND LIGHT COMPANY
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50-251
)
Proposed Amendments to Facility
)
Operating Licenses to Permit
)
Steam Generator Repair)
MOTION PURSUANT TO RULE 2.749 (c)
COMES NOW the Intervenor.
Mark P.
- Oncavage, by and through his undersigned attorney and moves the Board to refuse the application for Summary Disposition filed by the NRC Staff on or about March 23,
- 1981, or in the alternative for an Order continuing the time within which the Intervenor must respond and as grounds therefor would state:
1.
That on December
- 9th, 1980, the Intervenor served a document entitled Motion to Permit Entry Upon Turkey Point Site on the NRC Staff and the Licensee.
2.
That the Licensee refused the Intervenor's request to permit entry upon the Turkey Point Site and a hearing was duly held r
before the Board on March 24th, 1981.
3.
That said hearing was set on the Board"s initiative and at said hearing the Board ruled that the Intervenor would have per-mission to enter upon the Turkey. Point Site to conduct certain tests and samplings.
That the conditions and limitations to be set upon said ggo$
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inspection have not yet been determined and the Intervenor should have the right to complete the entry onto the site and to complete the tests and monitoring which are set forth in the Motion befo're the -Intervenor should be forced to respond to the pending Motion for Summary Disposition.
5.
That the Intervenor at the hearing indicated'hat said inspection was relevant to contentions two and,six and the Interveno'r should be 'entitled to complete his discovery prior to having to respond to the Summary Disposition filed by the NRC Staff.
6.
That based on the present schedule the Intervenor would have to respond to the Motion for Summary Disposition before his discovery was completed.
WHEREFORE, the Intervenor respectfully moves this Board pursuant to Rule 2.749 (c) to'refuse the application for Summary Disposition or in the alternative to continue the time within which the Intervenor must respond to twenty-five (25) days after the date the site inspection is completed.
Respectfully.submitted, Law Offices of Neil Chonin, P.A.
Attorneys for Intervenor Suite 1400 Amerifirst Bldg.
One S.
E. 3rd Avenue Miami,.Florida 33131 Telephone:
377-3023 By New C onion
4
Certificate of Service I HEREBY CERTEFY that copies of Motion Pursuant to Rule 2.749(c) in the above captioned proceeding have been served on the following by deposit in the United States Mail, this +Q day of MARCH, 1981.
Marshall E. Miller, Esq.,
Chairman 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 Dr. Oscar H. Paris Atomic Safety arid Licensing Board Panel U.S. Nuclear'egulatory Commission Washington, D.C.
20555 Mr. Mark P.
Oncavage 12200 S.W.
110th Avenue Miami, Florida 33176 Harold F. Reis, Esquire Lowenstein,
- Newman, Reis, Axelrad 8 Toll 1025 Connecticut
- Avenue, N.W.
Washington, D.C.
20036 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Norman A. Coll Esquire
- Steel, Hector 8 Davis Southeast First National Bank Building Miami, Florida 33131
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Burt Saunders, Esquire Assistant Dade County Attorney 1626 Dade County Courthouse Miami, Florida 33130 Henry H. Harnage, Esquire Peninsula Federal Bldg., 10th Floor 200 S.E. First Street Miami, Florida 33131 Steven C. Goldberg, Esquire U.S.'uclear Regulatory Commission Washington, D.C.
20555 LAW OFFICES OF NEIL CHONIN, P.A.
1400 Amerifirst Building One Southeast Third Avenue Miami, Florida 33131 Tele:'305) 377-3023 BY:
NEIL CHONIN
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