ML17338A666

Responds to Requesting Consideration of MP Oncavage 790319 Revision to Petition to Intervene.Prehearing Conference Is Scheduled for 790502 in Miami,Fl

ML17338A666
Person / Time
Site:	Turkey Point
Issue date:	04/19/1979
From:	Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Rebecca Stone SENATE
Shared Package
ML17338A667	List: ML17338A666 ML17338A669 ML17338A671
References
NUDOCS 7904270118
Download: ML17338A666 (59)

Text

NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos. 50-250 50-251~

The Honorable Richard Stone United States Senator Post Office Box 4081 Tallahassee, Florida 32303

Dear Senator Stone:

I am writing in response to your letter of March 27, 1979 reque'sting consideration of Mark P. Oncavage's March 19, 1979 revision to his petition for leave to intervene in the NRC license amendment proceeding involving repair of the steam generators at the Turkey Point Nuclear Generating Station.

On April 6, 1979, the NRC Staff filed a response to the revised petition, a copy of which is enclosed.

The presiding NRC Atomic Safety and Licensing Board has s'cheduled a prehearing con-ference for May 2; 1979 at the Howard Johnson Downtowner, 200 South-east Avenue, Miami, Florida to consider the petition. At or shortly following this prehearing'conference, the Board willrule on whether to grant or deny the petition. Ifthe Licensing Board denies the petition, Mr. Oncavage may immediately appeal to the Atomic Safety and Licensing Appeal Board. Ifthe Licensing Board grants the petition, other. parties have the same rights of appeal.

4 Pursuant to your request a duplicate copy of this letter is enclosed.

We are also returning your letter to us and its enclosure, as you have requested.

Ifyou have any further questions regarding this matter, please let me know.

Fnclosure:

Incoming ltr w/encls.,

dtd. 3/27/79 Sincerely,

)eo g. GOSSiCk p>;<.'" ",,

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JEHoore, OELD APR 19 1979 I

Docket.Nos.

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50-251 h

4 The, Honorable Richard Stone United'States Senator Post OfB'ce Box 4081 Tallahassee, Florida 32303

Dear Senator Stone:

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I am writingi response to your letter of March 27', 1979 requesting consideration o5 Mark P. Oncavage's March 19,, 1979 revision to his petition for 'leave to intervene in the NRC'license amendment-proceeding, involving repair of the steam generators at the'Turkey Point Nuclear Generating Station.

On Aprii 6, 1979, the NRC Staff filed a response to the revised petition, a copy of which is enclosed'.

The presiding NRC Atomic Safety and Licensing Board has scheduled a prehearing con-ference for May 2,'1979 at "the Howard Johnson Downtowner, 200 South-east Avenue,, Miami, Florida to consider the-petition.

At or shortly following this prehearing conference, the Board willrule on whether to grant or deny the petition. Ifthe Licensing, Board denies the petition, Mr. Oncavage may immediately appeal,to the Atomic Safety and Licensing Appea133oard'.

Ifthe Licensing Board grants the petition, other parties have the. same rights of appeal.

r Pursuant to your request a duplicate copy of this letter is enclosed.

We are also returning your letter to us and its enclosure, as you have requested.

Ifyou have any further questions regarding this matter., please let me know.

I Sincerely, Lee.V. Gossick Executive Director for Operations

Enclosure:

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JCook The Honorable Richard Stone

~ United'-Slates-Senate'-

.'oyt Office.Box 4081 Tallahassee,~Florida 32303

Dear Senator Sto e:

I am writing in resp nse to your letter of March 27, 1979 requesting consideration of Mark

. Oncavage's March 19, 1979 revision to his petition for leave to int vene in the NRC license amendment proceeding involving repair of the s am generators at the Turkey Point Nuclear Generating Station.

On Ap il 6, 1979, the NRC Staff filed a response to the revised petition, a copy fwhich is enclosed.

The presiding NRC Atomic Safety and Licensing B ard has scheduled a prehearing con-ference for May 2, 1979 at the Ho ard Johnson Downtowner, 200 South-east Avenue, Miami, Florida to con ider the petition. At or shortly following this prehearing conferenc the Board willrule on whether to grantor deny thepetition. Ifthe Lice ing Board denies the petition, Mr. Oncavage m'ay immediately appeal to he Atomic Safety and Licensing Appeal Board. Ifthe Licensing Board gra the petition,other parties have the same rights of appeal.

Pursuant to your request a duplicate copy of this etter is enclosed.

We are also returning your letter to us and its enclosu e, as you have requested.

Ifyou have any further questions regarding this matter, lease let me know.

Sincerely,

Enclosures:

1. Courtes co See previous yellow for concurrences OFFICC~

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Doc et Nos. 50-250 50-251 The Honora le Richard Stone PostOffice B x 4081 Tallahassee, orida 32303 Dear Se'nator Sto I am writingin resp nse to your letter of March 27, 1979 requesting consideration of Mar

. Oncavage's March 19, 1979 revision to his petition for leave to int rvene in the'NRC 1icense amendment proceeding involving repair of the s am generators at the Turkey Point Nuclear Generating Station.

On'A ril 6, 1979, the NRC Staff filed a response to the revised petition, a cop of which is enclosed.

The presidi'ng NRC Atomic Safety and L'i'censing oard'as schedul'ed a prehearing con-ference for May 2, '1979 at the.

oward Johnson Downtowner, 200'South-east Avenue, Miami, Florida to onsider the petition. At or shortly following this prehearing confer ce, the Board willrule on whether to grant or deny the petition.

A den 1 of the petition may be appealed to the Atomic Safety and Licensing, Ap eal Board.

Ifyou have any further questions reg ding this matter-, please let me know.

I Sine

ely,

Enclosure:

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~NRC'SECRETARIAT TO:

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Cl Cong.,Liaisons O Public Affairs Logging Date~~C n ln a~el Date

. ',O Gen. Counsel Q Solicitor O Secretary

. fncoming:

. from:

To;

Subject:

Peti tion " or

. eave to ntervene 1n.

u

. e Proceedin 0

Prepare reply for signature of:

0 'Chairman CI commissioner.'B EDO;GC,,CL,,SOL, PA, SECY D. Signature.block omitted

~ 0 Return original of incoming with.response XCQ( For.direct reply

'l For appropriate action CI For information, 0;For.recommendation sLjspense:

April 16 Remarks:

For the Commission:

~ 'Send tbree (3j copies of reply to Secy Mail Faolity NRC42 ACTION SL'IP

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RICMARD'(DICK)STONE PODRIDA COWkI1TCCS s AGRICVLTVRE NUTRITIONe ANO FORESTRY FOREIGN RELATIONS VETERANS'FFAIRS WASHINGT6No O C 205IO March 27, 1979 Our File:

9058170010 Congressional Liaison Nucl'ear Regulatory Commission 17~7 H Street, NM Washington, D. C.

20555

Dear Director:

Because of the desire of this office to 'be responsive to all inquiries and communications, your consideration of the attached is requested.,Your findings and views, in duplicate form, along with return of the enclosure, would be greatly appreciated.

It would also oe helpful to me if your response is mailed to my office at the address below and INCLUDES THE FILE NUMBER SHQNN ON THE COMMUNICATION I HAVE SENT TO YOU.'ordially, (u,~

Richard (Dick)

S one RDS/vms Enclos ur e PLEASE REP LY TO POST OF FIG E BOX 4 08 1 TALL'AHASSEE, FL ORI DA 3230 3

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Oncavage 12200 S.>7.

110 t,h gve.

miami, Florida Bar c1 19, 1979

"tom c Safety V..S.

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",<'eshi-@ton, D.

and Licensin= Board

..egulatory Commission, C.

2C555 Dear Pe@hers of the Board:

Please accept the revision to the petition for'leave to intervene, dated February 9, 1979 Very truly yours, j.

/

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r 1Zar3c P-Oncavage

UNIT"'D STATZS OF A%MICA

. NUCLrAR R'"GULATORY COhRISSION B~FOR" TH"'TG".IC SAFZTY 2 LIC'"NSING BOARD In the matter of:

FLORIDA POYIZR 8: LIGET CO.

)

(Turkey Point Nuclear.

)

Generating Units Nos.

3 and 4)

,Docket Nos,, 50-250 50-25l (Proposed Amendments to Facility Operating License to= Permit Steam Generator Repairs)

P-"TIT ON FOR L AVE TO INTZRVZN'"

Revision.

BY KABX P.

ONCAVAGZ h;ark P.

Oncavage, petition for leave to intervene in the matter of proposed amendments to the facility operating license to permit steam generator repairs at the Turkey Point facility licensed to Florida Power and Light Company.

STRING TO INTZRV"HZ The petitioner has grave concerns on the contemplated repairs to the steam generators at. 'Dxrkey Point Units Nos.

3 and 4.

There are three areas of concern and the petitioner's standing to intervene will be dern'onstrated to each area.

The first.concern is about the release of radioactive airborne particulates occurring during the steam generator repair operation.

The petitioner considers an-radiation

.exposur abov the natural background radiation

.to be an increased hazard in the formation of degenerative diseases.

The pet't oner s wife, two year old son, and the petitioner

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live in Dade County,:lorida.

Xpproximate1y 15 miles from the home in which the petitioner and his family r sides and owns 're the Turkey Poi."t reactors.

Turkey Point lies in a south-southeast direction from the petitioners residence.

The climatological tables as found in the U.S. Coast Pilot, Ho. 4, 1972)

Mere compiled from U S. ',feather Bureau data.

The tables for miami, Florida, state that during the months

bruary, L~arch, April, T'ay; June, July, august, and Sept mber the mean prevailing wind dir ction is either ast-southeast or southeast.

The r lease of radioactive airborne particulates coupled with the mean prevailing wind presents a'hazardous situation for the petitioner and his fam1ly e The waters of South Biscayne Bay are among the finest of recreational areas in the United States Zn close proximity of Turkey point, the. Dade County Metro Government has established two recreational

areas, Homestead Bayfront Park and Zlliot Key Park.

The. Federal Government has established the. Biscayne National Monument encompassing much of the bay bottom and benthic biota of South Biscayne Bay. rrom South Biscayhe Bay, through the pas sages of'nge lfish Creek Broad Creek, and Caesar's Creek lies the only living coral reef in tho waters of the continental United States. lt is the. John Pennekamp Underwater Beef'tat~ Park.

Th s, sensa<

ie ~~turaZ. communit'ies must be protected

0

fro all forms of po'lution. if t?iey are to survive.

The pe i ioner ov~

a ailboat, =I 1684 M, end of en cruises t¹se;vates with his family. The recreational, aspects of cruis ng: include cfishing, crabbing, swimming, skin diving, end underwater photography-To be denied the privilege of utilizing the recreational environment of South Biscayne Bay, would diminish the quality of'he petitioner s life.

Th land surrounding Turkey Point is a low lying mang ave coastal zone.. h U.S. Department of interior in the p'blication Resource and Land nonfor ation for South Dade County, desc ibes th mangrove zone as having an eleva ion. of "0 to 5 feet above mean sea level." There is littl land to trap radioactive liquids if a spill occurs.

Also, the f'low of groundwater in the Biscayne Aquifer starts in the Everglades, vest of'urkey Point and f'1'ows eastward to South Biscayne zey. Large portions of a liquid radioactive rele.ese mould migrate to South Biscayne may.

As a user of South '3iscayne My, as a recreational

area, and as a student of'nvironmental affairs, the petitioner has standing and a 'substantial interest on the matter of radioactive liquid rel eses.

The third area of'oncern is the economic f'easibility of'lter atives to repairing the steam generators.

The petition r is a resiaent of South Florida, a consumer of'he electricity that is p oduced by l'lorida Power ana Light (.'o.,

and a =ember of the South >'lorida economic corn~unity.

=. asonabl ener~~

costs can hav a ben ficial effect on tre economic health of the petitioner's community and nreasonaole or inflated energy costs can place an undue burden on individuals and the entire economic structure.

The petitioner ouestions the wisdom of proceeding towards expensive repairs without examining the alternatives horoughly.

he petitioner se ks'a reanalysis of the total cost's of Turkey Point's nuclear electricity, within the

=ra eworz o= cost benefits as outlined by the Hational

=nvirozmental rrotection Act, of 1969.

1C

(.'FR Part 2 ~ 714 i GOOD CAUS~

Th

":fotic of proposed issuance of am ndments to Facility Op rating'ic nses" as published in the Federal R mister on December 13,

1977, Docket Nos.

50-250 and 50-251, contained incorrect information-The statement is:

"For further details pertinent to tnese

matters, see the licensee's letter dated September 20,

1977, along with other material that may be submitted by the licensee in.

support of this action,'ll of'hich are or

.will be avail ble or public inspection at the J~~C '

Public Document

Room, 17 17 H Stre et N',Y.

/ashington, D.C.,

and the nvironmental and Urban M airs Library, Florida Int rnational University, Miami, Fla 33199."

The Nuclear Regulatory Commission, staff response. of Zarch 1; 1979, states:

"We are informed by the librarian, Ms Rene Daily, that the documents have, in fact,. been in the local PDR since October 4., 1977, though probably misfiled for part of the time."

This statement directly conflicts with the enclosed, sworn affidavit of March 16, 1979 by Ms. Hence'aily.

Ms. Daily states:

"The September 20, 1977 letter from Florida Power and Light comparer to the. Nuclear Regulatory Commission was.not found in the applicant correspondence file f'r 1977 letters."

The petitioner's contention is not to assign.

blame for this flaw of procedure.

The petitioner's contention is to state that the public's right to domestic information that

conc ns the health and w lf'are of'h

public, mus not be Qen3. ec ~

If the importance of having crucial documents missing from the local Public Document Boom can be dismissed, then it follows that the importance of having crucial documents missing from any Public Document, Room can be dismissed. If the burden of full and accurate information can be lifted from. the'ublic Document

Rooms, then i;t must fall on the ederal Re ister.

As the petitioner has shorn, the Federal "he circular reasoning used oy the>>uclear i:.egulatory commission's staff response of "arch 1, 1979, f'ails to do the Commission service.

>ach organ of public information;

.the local Public Document Boom, the Huclear Regulatory CRtl'D tli,'d t I

R~R' must stand on the merits of'.full and accurate information, otherwise, these organs of information will become functionless.

The contention of the Huclear Regulatory Commission staf'f'esponse of'farch 1, 1979,, that the letter of'eptember 20, 1977 was available from the Huclear Regulatory commission's Public Document

Room, assumes that knowl dge of the existence of'he letter should hav exist d even though the letter was missing.

The petitioner submits that the discovery, by 2s. Daily, that a crucial docu= nt;vas missing, took thirteen months to be realized.

Il 0

. av;g c ucial docu ents missin~ frou.a =ublic. Document

.=.oom -=.or thirteen months justi ies good cause for extending

."e t~ li-i,for +iling a petition for leave to'ntervene, by thirteen months.

Other factors that can meat the qualifications'f good cause for a time extension are present, also.

l.

The cost projections of the steam generator repairs publis?e'd in r vision 1, arrived at the rlorida international University Pab lie Document 'oom on January 3,.1978, only

. n ceys be="or he il ng deadline.

2.

Sine January 13,

1978, new evidence has appeared directly related to the concerns expressed in the petition of'eoruary 9,

1979-It is Nuclear Power Costs by the

~ Committee on Government Operations, House Report Ho.

95-1090, april 26, 1978.

3.

Cther sources of information that have been released, s-zce

.he filing deadline, are the responses to the sixty two cuestions asked of <<lorida Pov.er and Light by the Nuclear Regulatory Commission.

The ansv.ers were published in revisions nos.

2, 3, 4, 5, and 6, which arrived at the florida. International University, Public Document Room from Inarch 20, 1978 to i'ebruary 12, 1979.

Many of these cuestions and responses deal with public safety in relation to radiation release.

4.

also r leased after the filing deadline o+'anuary 13,

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l 78, is

=: vision G. This informatiO-is 1 ela proprietary and i as been excluded from th iublic document

Room, but

,content ana project d costs of this'ocument figure pro~mnently into the areas of public safety economic f asibility.

The process of ouestion and answer between the Nuclear Regulatory Commission and r'lorida Fower and Light company which fo ces the licensee to examine their situation mor closely, is valuole.

The appropriate ti=e for initiating h ar'ngs on public saf ty and economic f asibility is after all revisions have been made and after the Nuclear Regulatory Commission has completed the staff review of the proposed chart r amendments.

Rather than the petition being considered delaying or untimely, the -time f'r conv ning hearings is ripe and the petition should be considered appropriate.

Full justification exists for the granting of the petition due to the stated problems in the information organs and the belated nature

'by which full information has been made public. members of the 'public should be allowed to t&e part. in the decision menacing process whenever possxblei

0

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=R Par 2.714 i'The petitioner's concerns can be oest addressed in the hear=ngs t'at ~want or deny the chart r amendments to the lice see. All appeals are remedies that would be appropriate only if the Atomic Safety and Licensing Board were to deny the petition

>nother.regulatory body which may represent.

means to

.p o ect 'the petitioner's interest is the PIorida Public Service Commission.

The licensee has not brought the Publ c Service commission into the decision making process, thereby not allowing the petitioner an alternate administrative remedy. In a letter to the petitioner, of E'ebruary 27,

1979, concerning the proposed steam generator repairs, Commission Chairman Robert T. Bann states:

"It was the first time that this matter had been brought to my at,tention."

The granting of the petition for leave to intervene remains to date the only apparent

.procedure whereby the peti ioner's interests may be adequately protected.

4l

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.CF-.-. Par-2.714 iii D"-V'"LOP A SQUND R-COBE As a resident o

ioutn Florida ana a.consumer of elec =icity proauced by the licensee, the petitioner's participation in the hearing will be.directea towards the safet-and economic well being of'he petitioner,.his family, and tne South Florida community.

T?ese issues are extremely important, to the residents of'outh Floriaa.

This importance is reflected in the correspondence that the petitioner has received from the elected officials r presenting t'lorida, concerning the proposed steam generator repairs.

In th letter of >'ebruary 22,

1979, aadressed to the petitioner, the Honorable Dante Fascell states:

"1 can appreciate your concern about the proposed repairs at turkey Point. I too, have written to the chairman of the Nuclear Regulatory Commission requesting action in this case."

In the letter of March 1,

1979, addressed to the petitioner, Senator richard stone states:

".I can certainly understand your concerns in this.

matter and your efforts to obtain public hearings on this issue. I am theref'ore taking the liberty of'ontacting the appropriate authorities within the Nuclear Regulatory Commission for their thorough review of this matter."

Senator I,awton Chiles,, in the letter of'arch 5,

1979, states:

"In an effort to be of some ¹lp to zou I will contact the t.-ommission on your behaM.

2 will ask them to look into this matter and to fullv review your recuest in the light of the comments you have made concerning the safety aspect involv d with these repairs."

is e rident that the aonorablo.-dante

>'ascell from the

= (.'ongressionel Dist ict, whic? includes urkey.Point,

"-enato richer

>tone, and Senator Lawton t;hiles have inc. cated t at th petitioner's concerns warrant action, h a-ings anc r view he petitioner will make every effort to assist in developi g a souno record.

Legal counsel will be available to the pe-itioner for the hearing.

-"xpert witnesses are an icipeted to estif-" in behalf of the petitioner.

he petitioner brings to the hearing a position not rep sen ed by the licensee in philosophy or intensity.

The licensee as a profit making company may not have the health and wel are of the residents of South ~Florida foremost in heir philosophy, if the health and welfare issues conflict with company interests.

The Nuclear Pegulatory.Commis-ion as a judicial body may find t more difficult to render a just decision if the health and welfare concerns of the public 'are not represented at the hearing, but only licensee's interests are represented.

4i

mhe petit oner has examined Docket Hos.

G-2SO and C-col searching for existing parties:and other pet for leave to intervene.

i~one were found-It is apparent t at if this petition is denied, the licensee's ao l at for charter amendments

>vill be uncontested.

he position o

the Nuclear Regulatory commission staff recommendation is unknovn to the petitioner as of this d'ate.

C=R c-art 2.714 BROADEN ZSSU'S OR,.DELLA,'ROC~~DIKGS

. e pet" ioner contends that the concerns of public saf ty from radiation

xposure, protection of the environment from. radioactive licuid contaminants, and economic feasibility of t?.e steam generator repairs, represent the crux of the proposed hearings. All other matters such as man-rem usage, cons ruction acciden s,

storage of radioactive steam gen

,ator units, radwaste

disposal, and security measures a nexus in the three concerns.

"-=oacening the issues can only serve to dilute the main core

. s.

she petitioner

.s intervention vrill be directed towa ds the satisfactory resolution of the three main issues The purpose of the petition is not to delay proceedings but o assist in reaching a,just decision.

The petitioner

'finds no merit in prolonging the op ration of the acknowledged defective steam generators.

En an effort to reduce any delay that may occur, the petitioner is pref ling a motion with the Huclear Regulatory Commission, to g ant Discovery Rights immediately.

Zf a delay becomes unavoidabl'e, the loss of flexibility

.by the licensee is more than offset by the value of having public hearings where a.just decision can be rendered.

7"e petitioner seeks proof or demonstration that all re~ eases of radioactive a'" rborne particulates

.and radioactive 'licuid contaminants,rele'ased rom. the Turkey Point si e, during the steam generator repairs, v.ill be fully and accurately determined by planned.monitoring procedures.

he pe.itioner seeks

-a determination of the total a ount of radioactivi y that may be released from the Turkey Point site, during the steam generator repairs, that would not be hazardous to the petitioner's health nor the public's health nor present any hazard to the 'environment surrounding the Turkey Point sit'e, including South Biscayne Hay.

The petiti'oner seeks proof or determination that

adeouate, containment and decontamination procedures are immeciately available to protect the petitioner's health, the public's health, and protect, the environment in the event of any postulated or possible release of hazardous radioactivity, from the Turkey Point site, during the steam generator repairs.

The petitioner seeks to examine the total costs pertaining to the fission generated electricity from Turkey Point and compare the costs: to the licensee's pro'ected cost(s} of coal generated electricity. This

0

da a would be 'ns ru ental in determining the cost benefits a

the steam 'generator reoairs within the framework oz the

>,a ional environmental Policy Act of 1969.

Cost benefit anal.sis must include the projected'operating life of Turkey Point reactors nos.

8 and 4, and the, projected operating life of a coal burning facility.

COZC EUS 101'he licensee cannot demonstrate, to the satisfaction of t-.e.;uclear regulatory Commission, that th petitioner's co cerns are un easonable or unfounded, then the.'nuclear Beau atory Commission is fully justified to deny the charter amendments reouired by the licensee to repair the steam generators at the Turkey Point nuclear facility..

STATZ Or rmoaZDA.

COUNTY OP

DADZ, Nark P.

Oncavage Before me personally appeared Mark P. Oncavage, to me well known and known to me to be the person described in and who executed the foregoing. instrument for the.purposes therein expressed, MITN&S my hand and official seal, this 18 th day of Parch A.D. 1979'gpIgg'"( ~t;t Of,:.rH~ zt ',a-.".a 1

~

f<~y ggzrm,gicn E~..<res >ca Ionls4 Ly ~(ical 4e a C-~Jr Coayase

I

Kii ~'-

2 R=GJL+ O.('O ~".I~~IGZ 3 '= GR.=

i'."-.F~

LIC:. '~i <G BG~.G the matter of:

P -"TITIGN F(rR L 'AV-TO

)

Docket Nos.

50-250 5 3-251 I;iT'V=N~

AFF DAVIT GF R" H" " DAiLY

~ T.aT=

GF FLG.RICA CQ7:

Y C =

DAD'".

3:-FOR-". "'= personally a+peared RZN" =. DAILY, <ho being first duly sworn, deposes a-..d says:

I.am employed by Florida International University and am a library technical assistant at the Environm ntal and Urban affairs Library, Hiami, Florida.

The 8eotember 20, 1977 letter from Florida Power and Light Company,to the Nuclear Regulatory Commission was not found in the applicant correspondence file for the 1977 letters.

'fe requested a xeroxed copy of it and received'he duplicate letter January 22, 1'979.

DAILY 3.FOXED TO and SUB~CRIB=D before.

me this day of 1larch; 1979'otarv Public, State of Florida

II

FUCL'R B.GULATOR" COJ.~ ISATION

~iO.3 Ti~ A 0:.'.IC SAFEST Z LIC~HSIhG BOARO In t?=e matter of:

Petition for leave to Doc+et Nos.,50-25C 50-251 intervene

'...'.O I

>I.or +he "rocuc.ion of docu ents and thin@a and entr-upon lard for ins"ec-ion and other. purposes.

u suant to regulation of 10 CFR Part 2.741 (a) the petitioner motions he be permitted to inspect all

.documents and things pertaining to proposed charter amendments specificall-described as steam generator repa1rs

~

Vark P.. Oncavage 122CG S.W.

110 th Avenue Kiami, florida 33176 L'arch 19 1979

0

GifI'D SL'iT"'3 0" ~RIC~

2HJCL. AR P 'GiP~TORY CCTPUZSSIOi'I "GB '- A~O"~C In the'matter of Peti ion for 1 ave to intervene Turkey Point Ifuclear Generating Units ITos.

3 and 4

SLZ TY 8: LIC i~lSIifG BOARD Docket Hos.

50-250 50-251

)

)

C. RTIFICAT" OF SZRVICZ I, "ark P-Onc vage, hereby certify that copies of the Revision to, Petition:or Leave To Intervene, have been served on. the following by 'deposit in the United States mail, first class, properly stamped and addressed, this day of Karch, 1979:

. elizabeth S. Bowers, 'cuire, Chairman atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission

,washington, D.

C.

205 5

Dr David B. Eall 400 Circle Drive Santa Fe, Hew Mexico 87501 Dr Oscar E

Paris Atomic Sa ety and Lic nsing Board Panel'..S.

sluclear Regulatory Commission

<'ashington, D.

CD 20555

~,

Harold:. Reis,

-'souire Lo ers ein,

Uevmm, Reis, Axelr d ~ Toll lC2 Corwecti cut "venue, I;.;V.

washington, D.

- C.

2GGS6 Atomic Safety wd Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Atom' Sa-ty and Licensing Appeal Board Panel U. S. ifuclear Regulatory Commission 7asr=ngt on, D.

C.

2C 55 5 Docketing and Service Section Of ice of the Secretary U;. S. iIuclear Regulatory Commission geehington, D. C.

20555 Guy 2.

Cunningham,

-'scuire Steven C. Goldberg, Zsguire U. S. Nuclear Regulatory Commission Office of the "-xecutive Legal Director

)washington, D. C.

20555 Mark P. Oncavage

4i f

h w I il I

f I'4 IU 0