ML18227D547

Motion of the City of Quincy to Withdraw as an Individually Named Party

ML18227D547
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	07/18/1977
From:	Jablon R City of Quincy, FL, Spiegel & McDiarmid
To:	Atomic Safety and Licensing Board Panel
References
50-250A, 50-251A, 50-335A
Download: ML18227D547 (3)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD Florida Power 6 Light Company )

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

)

Florida Power & Light Company )

(Turkey Point Plant, Unit Nos. ) Docket Nos. 50-250A 3 and 4) ) F0=2YZA-MOTION OF THE CITY OF QUINCY TO WITHDRAW FROM THESE DOCKETS 'AS AN INDIVIDUALLY NAMED PARTY The City of Quincy,, Florida, respectfully requests permission to withdraw its participation in the above-captioned dockets as an individually. named party... Quincy wishes to continue to participate indirectly as a member of the Florida Municipal Utilities Association ("FMUA"), an organization of some 34 municipally owned and operated electric utilities in Florida, which has requested intervention in order. to protect generally the rights of each of its members.

In support. thereof Quincy states as follows:

Florida Cities seek to intervene in this docket in order to have their rights to nondiscriminatory access to competitive power supply confirmed. These rights should not require protects.'on through protracted and expensive litigation.

The Cities that have sought. intervention'individually did so because of the overriding importance of establishing these rights. and their belief that they can contribute significantly in the decisional process through individual and active

participation. At the same time, FMUA seeks intervention in the belief that, the entitlements, sought should be generally available, and it is FMUA' position that license conditions ordered should be made generally applicable.

Nhile Quincy recognizes that Florida Power & Light Company ("FP&L") may assert, or the Board may rule, that if it withdraws as a named intervenor,. entitlements that it.

might. otherwise have may be'reduced or- negated, this City and others like it ought to be able to assert a general I

'public interest in license conditions through a membership association without having to bear the costs and burdens

(

associated with individual and, active participation in lengthy, complex large-scale litigation.

Respectfully submitted, Robert A. Jablon July 18, 1977 Law Offices of:

Spiegel & McDiarmid

,2600 Virginia Avenue, N.N'..

Nashington, D.C.. 20037 202-333-4500 k

CERTIFICATE OF SERVICE I hereby certify that I have this day caused the foregoing document to be served,. upon the following persons:

William C. Wise, Esp'. Linda L. Hodge, Escr.

Robert Weinberg, Escr. 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, Esct. Lee Scott Dewey, Esa.

Chandler, O'Neal, Avera, Gray, Office of Executive Legal Lang & Stripling Director P.O. Drawer 0 Nuclear Regulatory Commission, Gainesville, Florida, 32601 Washington, D.C.. 20555 David A. Leckie, Esa Chief,- Docketing and. Service Antitrust Division Section Department o f Jus tice Office of the Secretary 1101 Pennsylvania Avenue, N. W., Nuclear 'Regulatory Co~<< ssion Washington, D. C. 205 30 Washington, D.C. 20555 I

Robert H. Culp, Esp. Ivan W. Smith, Esa.

Lowenstein, Newman, Reis Atomic Safety & Licensing

& Axelrad Board Panel 1025 Connecticut. Avenue, N.W., Nuclear Regulatory Commission Washington,--D.C. 20036 Washington,. D ..C., 20555 Tracy Danese, Escr. John M Frysiak, Esa.

Vice President, Public Affairs Atomic Safety & Licensing.

Florida Power & Light Company Board Panel P.O. Box 013100 Nuclear Regulatory Commission".

Miami, Florida 33101 Washington, D.C.. 20555 John E. Mathews, Jr., Esp.. Robert M Lazo, Esq.

Mathews, Osborne, Ehrlich, . Atomic Safety' Licensing McNatt, Gobelman. & Cobb Board Panel 1500 American Heritage Life Bldg. Nuclear Regulatory Commission

'Jacksonville,. Florida. 32202 Washingtan, D.C. 20555 J. A. Bouknight,, Jr , Esp.

Lowenstein, Newman,. Reis

& Axelrad 1025 Connecticut Avenue, N.W.

Washington, D.C.. 20036 Dated. at Washington, D.C. this 18th day of. July, 1977.

Robert A. ion