ML20205D725
| ML20205D725 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/20/1988 |
| From: | Demastry J FLORIDA POWER & LIGHT CO. |
| To: | RICH, C. |
| References | |
| CON-#488-7332 88-560-01-LA, 88-560-1-LA, OLA, NUDOCS 8810270193 | |
| Download: ML20205D725 (5) | |
Text
v EnAIED CORRE.sPONDENgg i
1,-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION o
NLKETED BEFORE.THE ATOMIC SAFETY AND LICENSING BOARD,
'88 DCT 24 NO S6
)
In the Matter of
)
Docket No. 50?335. 0LA
)
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FLORIDA POWER AND LIGHT COMPANY
)
)
(St. Lucie Plant, Unit No. 1)
)
(ASLBP No. 88-560-01-LA)
)
LICENSEE'S RESPONSE TO INTERVENOR'S PIRST SET OF INTERROGATORIES TO LICENSEE Florida Power & Light Company ("Licensee") hereby responds to Intervenor's First Set of Interrogatories to Li-censee ("Intervenor's Interrogatories") in the above-captioned proceeding.
Licensee's Response to Intervenor's General Interrogatories General Interrogatory I.A State whether Licensee intends to call any person or persons as witnesses, in-cluding expert witnesses, in this proceed-ing in opposition to each contention and, if so, identify any and all such persons giving the name, address and professional qualifications of eech.
Licensee has not yet selected any witnesses.
Licen-see recognizes its duty under 10 C.F.R. 5 2.740(e) seasonably to supplement this answer and will do so when witnesses are chosen.
General Interrogatory I.B Provide summaries of the views, positions, or proposed testimony in opposition to each contention of all persons identified in response to interrogatory I.A.
that Licensee intends to present during this proceeding.
8810270393 001020 gDR ADOCK 05000335 jpp PDC
1,-.
It uill not be possible to provide a summary of the "views, positions, or proposed testimony" to be presented by Licensee until witnesses have been selected.
- However, Licensee recognizes its duty under 10 C.F.R. $ 2.740(e) season-ably to supplement this answer and will do so.
General Intirrogatory I.C Identifv all documents, books, reports, papers, studies, analyses and calculations that Licensee intends to employ or rely upon in presenting his direct case in opposition to each contention.
I It is not possible to determine the "documents, j
a books, reports, papers, studies, analyses and calculations that Licensee intends to employ or rely upon" until witnesses j
have been selected, and testimony pr5 pared.
In general, how-i ever, Licensee expects that the documentation supporting its testimony will be similar in nature to the material docketed l
in connection with the s, t fuel pool reracking amendment, and that referenced in Licensee's motion for for summary judge-1 ment and accompanying affidavits.
This would include:
1.
Florida Power & Light Co., St. Lucie Plant - Unit i
Ne, 1, Spent Fuel Storage Facility Modification Safety Analysis Report, Docket Ho. 50-335 (Rev.
1, January 29, 1988):
I 2.
Safety Evaluation by the office of Nuclear Reactor l
Regulation relating to the Reracking of the Spent Fuel Pool at the St. Lucie Plant, Unit No. 1 as related to Amendment No. 91 to Unit 1 Facility Oper-j ating License No. DPR-67 Florida Power and Light Co. Docket No. 50-335 (March 11, 1988): and 3.
NRC Standard Review Plan, NUREG-0800.
I l
f.
I
3-This response is without prejudice as to the choice of documentation upon which Licensee may ultimately rely following the selection of witnesses and preparation of testimony.
STATE OF FLORIDA
-)) ss.
COUllTY OF PALM BEACli )
J. A.
DeMastry being first duly sworn, deposes and sayst That he is Manager luclear Licensing, of Florida Power and Light Company, the Licensco herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licesisee.
. d htA
/ J. A.
DeMast ryC/
Subscribed and sworn to before me this E b ay of 9
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-!' j liOTARY PURLIC, in and for the County of Palm Beach, State of Florida My Commission expires I
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- c. 1 UNITED $TATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION BEFORE THE A,TOMIC SAFETY AND LICENSING BOARS 3 00124 N0 57
.(
{nNky. l I' f ne In the Matter of
)
Docket No. 50-335 OLA
)
FLORIDA POWER AND LIGHT COMPANY
)
)
(St. Lucie Plant, Unit No. 1)
)
ASLBP No. 88-560-01-LA
)
l CERTIFICATE OF SERVICE l
I hereby certify that copies of Licensee's Response to Intervencr's First Set of Interrogatories to
- Licensee, dated October 20, 1988, were s6rved on the following by deposit in the United States mail, first class, postage prepaid and properly addrested.
- 7. the date shown below:
B.
Paul Cotter, Jr., Chairman
- Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Glenn O.
Bright Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatoly Commission Washington, D.C.
20555 Dr. Richard F. Cole
- Atomic Safety end Licensing Board Panel U.S. Nuclear Regulatory Comnission Washington, D.C.
20555 Also served by overnight delivery service.
_ i Adjudicatory File Atomic Safety and Licensing Board Panel U.'.
Nuclear Regulatory Cormission Washington, D.C.
20555
(*wo copies) becretary U.S.
Nuclear Regulatory Cormission Washington, D.C.
20555 Attenticn:
Chief, Docketing and Service Section (Ori71nal plus two copies)
Benjamin H.
Vogle'c, Esq.
Office of Genera *, Counsel U.S.
Nuclear Regulatory Cor.missien 4
Washington, P.C.
20555 Carpbell Rich
- 4626 S.E.
Pilot Avenue Stuart, Florida 34997 i
Dated this 20th day of October, 1988.
J 4u'_
- l
_ Michael A.g Bauser Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, D.C.
20036 i
Telephone:
(202) 955 6669 Counsel for Florida Power & Light Corpany Also served by overnight delivery service.