ML19319D620
| ML19319D620 | |
| Person / Time | |
|---|---|
| Site: | Crystal River |
| Issue date: | 11/13/1972 |
| From: | Spiegel G SPIEGEL & MCDIARMID |
| To: | Oleary J US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8003180659 | |
| Download: ML19319D620 (3) | |
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CONTROL NUMBER FILE LOC ATION Z
Geerse Epiegel 5084 0-Washington, D. C.
DATE or DOCUMENT A CilON COMPLETION DE AOLINE 11/13/72 12/4/72
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10 ACliON FROCESS NG DATES PREPARE FC4 SiON ATURE OF:
Acknow led g e d Chairman O
N Interim Report.
Director o' f Regulation F anol D ES C RipilO r4 I*tr
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"* "'S Requests that the City of Cainesville's Cceditional Raquest fcr UearinE and Petitiest to latervene in proceedings for Crystal ILiver (3 be granted f
f REFERRED TO DATE iS NOi1FICATION TO THE JCAE skapar f/actica 11/20/72 RECOMMENDED 7 c i:
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.s 00 NOT DETACH THIS C'OPY DIRECTOR CF REGULATION Form HQ 32 (6 70)
COMMuidlCAfiONS CONTROL USA EC D
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law OFFICES oF GEORGE SPIEGEL 2600 VIRGINIA AVENUE, N. W.
WASHINGTON, 0. C. 2OO37 November 13, 1972 GEORGE $PtEGEL TELEPHONE 3338860 i
JAMES F FAIRM AN. JR, AREA CODE 202 KCBERT C MCDIARMIO SANCRA J STREBEL Mr. John F. O' Leary, Director Directorate of Licensing United States Atcaic Energy Commission Washington, D. C.
20545 Re:
Crystal River No. 3 Nuclear Generating Unit, Docket Nos. 50-302 and 50-302A
Dear Mr. O' Leary:
I has recently come to our attention that Florida Power Corporation requested that the Commission g
deny the City of Gainesville's Conditional Request for f
a Hearing and Petition to Intervene.
In its letter of September 1, 1072, Florida Power states that Gainesville's cont
.<a; limited to Commitment No. 3 which dealt with t'.
abligation by Florida Power to exchange bulk power by transmission over its systems between or among ot.'er entities with which it is connected.
This is an oversimplification of Gainesville's concern.
Commitment No. 3 and the explanatory notes thereto and the other 4 Ccmmitments have been of concern to Gainesville since April 12, 1972 when it petitioned to intervene in this case.
Gainesville has an equal interest in all of the commitments and the explanatory notes contained in the letter to Florida Power from Mr. Abraham Braitman dated May 18, 1972.
These commitments and their explanatory notes were produced as a result of agree-ments between counsel and were, we believed, the conditions to be made a part of any license granted abo Florida Power.
They are interrelated.
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- y Mr. John F. O' Leary, Director Page Two.
We view with deep concern any attempt on the part of Florida Power to substantively change these commitments, which we now are informed has been attempted as recently as October 4, 1972.
For these reasons we request the Commission to change its position with respect to our petition to intervene.which it filed on Jt 26, 1972 In that petition the Staff stated: " explanatory notes have been discussed and a mutual understanding with counsel as to all has not been attained; however, only a few points remain unresolved."
It is now clear that much more than a " few points" are being discussed and con-sidered without our knowledge or participation.
Gainesville's participation as a full party to these proceedings appears imperative if its concerns are to be protected.
We therefore respectfully request that Gainesville's Conditional Request for Hearing and Petition to Intervene be granted.
Sincerely,
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George Spiegel i
GS:jdf Attorney for City of Gainccville, cc: Wallace E. Brand, Esquire Florida Joseph Rutberg, Esquire Stanley A. Brandimore, Esquire 4
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