ML20207C693

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Motion for Extension Until 861215 to Respond to Licensee 861120 Motion to Relinquish Jurisdiction & Terminate Proceeding.Certificate of Svc Encl
ML20207C693
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 12/15/1986
From: Hodder M
CENTER FOR NUCLEAR RESPONSIBILITY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20207C631 List:
References
84-496-03-LA, 84-496-3-LA, OLA, OLA-2, NUDOCS 8612300211
Download: ML20207C693 (3)


Text

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00LfE M unt4RL UNITED STATES OF AMERICA

'86 00: 29 P6 :44 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Nos(.c$b6bi!

In the Matter of

)

250'-OLA-1 Docket

)

50-251-OLA-2 FLORIDA POWER AND LIGHT COMPANY

)

Turkey Point Units 3 and 4 ASLBP No. 84-496-03-LA (Vessel Flux Reduction)

)

INTERVENORS' MOTION FOR EXTENSION OF TIME TO RESPOND 10 LICENSEE'S MOTION FOR TERMINATION OF PROCEEDING Pursuant to Rule

2. 711 ( a ), Intervenors, the Center for Nuclear Responsibility and Joette Lorion, motion that this Board grant a 12 day extension of time within which to file Intervenor's Response to " Licensee's Motion to Relinquish Jurisdiction and Terminate Proceeding" dated November 20, 1986.

In support of this motion for extension of time, Intervenors would list the following factors for their late filing, as required by the good cause requirements of Rule 2.711 (a).

Intervenors' Counsel is a sole practioner, and the press of other business interfered with his ability to adequately 1

address the issues presented by Licensee's termination motion before this date.

Intervenors also point out that the filing of this motion out of time will not delay the proceedings in the above captioned matter since the hearing has already been held and the license amendments issued.

f 8612300211 B61215 l

PDR ADOCK 05000250 O

PDR

4 (2).

Intervenors believe that their. continued participation

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on this issue vill both develop a sound record and protect the public interest, since the other parties in the proceeding have a vested interest in the outcome and would not protect the public interest adequately.

In addition, their is no other forum for the Intervenors to raise their safety concerns.

Thus, -the Intervenors have demonstrated that they have met the good cause requirements of Rule 2. 711 (a), and request that this Board extend the filing date for their Response to Licensee's Motion to Terminate this Proceeding to December 15, 1986.

1 Respectfully submitted, 4

McLM.q N-k(

Martin H. Hodder 1131 NF 86 Street Miani, F1. 33138 (305) 751-8706

  • signed in his absence by l

Joette Lorion Dated:, December 15, 1986 i

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UNITED STATES OF AMERICA NUCLEARREGULATORYCOMMISSfgNgat 29 P6 :43 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IiOCCggf In the Matter of DOCKET NOS. 50-250-OLA-1 50-251-OLA-1 FLORIDA POWER & LIGHT COMPANY (Turkey Point Nuclear Operating ASLBP No.

84-496-03-LA Units 3 and 4)

CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenors' Response to Licensee's Motion to Relinquish ' Jurisdiction" and"Intervenors' Motion for Extension of Time" in the above captioned proceeding have been served on the following individuals by deposit in the U.S. Mail, postage prepaid, on this 15th day of December,1986:

Dr. Robert M. Lazo, Chairman Harold F. Reis, Esquire Atomic Safety and Licensing Board Newman & Holtzinger U.S. Nuclear Regulatory Commission 1615 L. Street NW Washington, D.C. 20555 Washington, D.C. 20036 Dr. Emmeth A. Luebke Norman A. Coll, Esquire Atomic Safety and Licensing Board Steel, Hector & Davis U.S. Nuclear Regulatory Commission 4000 SE Financial Center Washington, D.C. 20555 Miami, F1. 33131-2398 Dr. Richard F. Cole Atomic Safety and Licensing Board Docketing & Service U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory sio y,((1lgton,D.C.20555 Washington, D.C. 20555 ff ce of Exe ut Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Ap ea Washington, D.C. 20555 Nuc ar Regulatory Commission Washington, D.C. 20555 0\\CLt%n Y' N 0 0AA-

  • Martin H. Hodder J

1131 NE 86 Street Miami, F1.33138 Counsel for Intervenors

  • signed in his absence by Joette Lorion i

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