ML20236D303
| ML20236D303 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/13/1989 |
| From: | Frantz S FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#189-8290 OLA-4, NUDOCS 8903230046 | |
| Download: ML20236D303 (4) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD C P !L1 i t.
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In the Matter of
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l FLORIDA POWER & LIGHT
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Docket Nos. 50-250 OLA - 4 COMPANY
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50-251 OLA - 4
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(Turkey Point Plant,
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(P/T Limits)
Units 3 and 4)
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LICENSEE'S RESPONSE TO PETITION FOR LEAVE TO MAKE STATEMENT BY THOMAS SAPORITO. JR.
On March 7, 1989, Thomas J.
Saporito, Jr. submitted to the Licensing Board a " Petition for Leave to Make Statement."
In this petition, Mr. Saporito requested leave under 10 C.F.R.
S 2.715(a) to make a limited appearance statement "at any session of the hearing."
In its " Notice of Oral Argument" dated February 17, 1989, the Licensing Board stated that it will not take limited appearance statements at the oral argument scheduled for March 21, 1989, presumably intending to take such statements at a later stage of the proceeding.
If the reference in Mr. Saporito's petition to "any session of the hearing" is intended to request that his limited appearance statement be made at whatever future i
session the Licensing Board determines to take such statements, the request is consistent with the Board's notice and is unobjectionable.
If, however, the reference to "any session of the hearing" is read as covering any session that Mr. Saporito chooses, including the March 21, 1989 oral argument, Licensee respectfully requests the Board to adhere to the position 8903230046 890313 PDR ADOCK 05000250 g
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The oral argument is not a hearing, is scheduled for'only one day,.and will be concerned primarily with the re'latively narrow legal issue of whether the Petitioners' proposed contentions satisfy the Commission's standard for admissible contentions.
Taking limited appearance statements does not appear to be appropriate during a relatively brief session conducted for such a limited purpose.
Respectfully submitted, M1 Harold F.
Reis Steven P.
Frantz-Kenneth C. Manne Newman & Holtzinger, P.C.
1615 L Street, N.W.
Suite 1000 3
Washington, D.C.
20036 (202) 955-6600 Co-Counsel for Florida Power &
Light Company Co-Counsel John T.
Butler Steel, Hector & Davis l
4000 Southeast Financial Center Miami, Florida 33131
'4 (305) 577-2800 March 1, 1989 1
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Ntu r we UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 19 MM 15 P4 :07 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD yo-ar.
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00Cr i lhG A 'b d-iiR UR,4 In the Matter of
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FLORIDA POWER & LIGHT
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Docket Nos. 50-250 OLA - 4 COMPANY
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50-251 OLA - 4
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(Turkey Point Plant,
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(P/T Limits)
Units 3 and 4)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response To Petition For Leave To Make Statement By Thomas Saporito, Jr." were served on the following by deposit in the United States mail,
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first class, properly stamped and addressed, on the date shown below.
B.
Paul cotter, Chairman Atomic Safety and Licensing Board Panel l
I U.S. Nuclear Regulatory Commission y
Washington, D.C.
20555 j
Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Jerry Harbour Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
Atomic Safety and Licensing Appeal Board Panel
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U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Office of Secretary U.S. Nuclear Regulatory Ccamission i
Washington, D.C.
20555 Attention:
Chief, Docketing and Service Section (Original plus two copies) m_
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', o' L4 3-Joette Lorion, Director Center.for Nuclear Responsibility 7210 Red Road'#217 Miami, Florida 33143 Janice Moore Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John T.' Butler Steel, Hector & Davis 4000 Southeast Financial Center Miami, Florida 33131 Thomas J. Saporito, Jr.
1202 Sioux Street J6piter, Florida 33458 Dated this 13th day of March 1989.
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'Kenneth C. Mannd
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Newman & Holtzinger, P.C.
1615 L Street, N.W.
Suite 1000 Washington, D.C.
20036 i
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