ML18088B142

Motion for Extension of Time

ML18088B142
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	06/20/1977
From:	Jablon R Florida Cities, Spiegel & McDiarmid
To:	Atomic Safety and Licensing Board Panel
References
50-250A, 50-251A, 50-335A
Download: ML18088B142 (3)

Text

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOA D Florida Power 8 Light Company )

(St. Lucie Plant, Unit, No. 1 ) Docket. No. 50 335

)

Florida Power 6 Light Company )

(Turkey Point Plant, Unit Nos. ) Docket Nos. 50-250A 3 and 4) ) 50-251A MOTION FOR EXTENSION OF TIME Florida Cities respectfully request a change in the dates to file the pleadings referred to in the Appeal Board's June 16, 1977 Order. They request that Florida Cities'rief be due on or before June 29, 1977, and that other parties'riefs be due on or before July 13, 1977. 1/ Counsel for Florida Cities is authorized to state that neither Florida Power 6 Light Company nor Staff object to Florida Cities'equest for an extension of time.

Florida Cities realize that, the Appeal Board's Order set forth a short time period for response. They do not desire to delay resolution of these matters. However, counsel for Florida Cities had meetings outside of Washington one Thursday, June 16, 1977, the date the Order was issued, and Friday, June 17, 1977. In addition, counsel had a 1/ Staff has agreed that under this proposed schedule would not. have additional time after Florida Po~er a Light it Company's brief.

conference yesterday. Tomorrow, June 21, and Wednesday, June 22, counsel has a long-standing commitment involving settlement discussions of a Federal Power Commission rate case, which commitment cannot be changed because of certain Federal Power Commission rate case filing rules. On Thursday, June 23, 1977, he has a pre-hearing confernece scheduled in another Federal Power Commission rate case, although he anticipates that this will be short and may be cancelled.

Under the circumstances, in order to allow them to give appropriate consideration of the Commission's decision in Houston Li htin 6 Power Com an (South Texas Project, Units 1 and 2), Docket Nos. 50-498A and 50-499A, Florida Cities respectfully request that the dates above be approved.

Respectfully submitted, e'4,.~7/(y Robert A. Jablon Attorney for Florida Cities June 20, 1977 Law Offices of:

Spiegel 6 McDiarmid 2600 Virginia Avenue, N.W.

Washington, D.C. 20037 202-333-4500

0 CERTIFICATE OF SERVICE I hereby certify that I have this day caused the foregoing Motion for Extension of Time to be, served upon the following persons:

William C. Wise, Esq. Linda L. Hodge, Esq.

Robert Weinberg, Esq. Lowenstein, Newman, Reis Suite 200 Axelrad 1019 19th Street, N.W. 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Washington, D.C. 20036 William H. Chandler, Esq. Lee Scott Dewey, Esq.

Chandler, 0 'eal, Avera, Gray, Office of Executive Legal Land 6 Stripling Director P.O. Drawer 0 Nuclear Regulatory Commission Gainesville, Florida 32601 Washington, D.C. 20555 David A. Leckie, Esq. Chief, Docketing 6 Service Antitrust Division, Department, Section of Justice Office of the Secretary 1101 Pennsylvania Avenue, N.W. Nuclear Regulatory Commission Washington, D.C. 20530 Washington, D.C. 20555 Robert H. Culp, Esq. ~

Ivan W. Smith, Esq.

Lowenstein, Newman, Reis Atomic Safety E Licensing Axelrad Board Panel 1025 Connecticut Avenue, N.W. Nuclear Regulatory Commission Suite 1214 Washington, D.C. 20555 Washington, D.C. 20036 John M. Frysiak, Esq.

Tracy Danese, Esq. Atomic Safety 6 Licensing Vice President, Public Affairs Board Panel Florida Power 6 Light Company Nuclear Regulatory Commission P.O. Box 013100 Washington, D.C. 20555 Miami, Florida 33101 Richard M. Lazo, Esq.

John E. Mathews, Jr., Esq. Atomic Safety 6 Licensing Mathews, Osborne, Ehrlich, Board Panel McNatt, Gobelman 6 Cobb Nuclear Regulatory Commission 1500 American Heritage Life Washington, D.C. 20555 Building Jacksonville, Florida 32202 J. A. Bouknight, Jr., Esq.

Lowenstein, Newman, Reis &

Axelrad 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Dated at Washington, D.C. this 20th day of June, 1977.

Robert A. J~pl'on