ML17338B216
| ML17338B216 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/12/1979 |
| From: | Rasmussen G AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 7911020107 | |
| Download: ML17338B216 (28) | |
Text
eicy'"Q~~
QUn49L LLszgUtS, P" ~4, XS I Si CITIZENS ACAINST ~DIOA~ POLLUTION MISS GERALD&KDe IIASMUSSEN'rONDGL DIRECTOR EDITOR GvtMUS September 12, 1979 JQ
~ u e Sec. etary o t'e CoI".mission, Nuclear ?egulatory Commission Has hingt on,, D. C. 20555 Sirs:
ATTENTION: DOCKT'Z% AND SERVICE Though I will. not be able to personally appear at the hearing on Che Turkey Point Nuclear Generating Station and Che proposed amend->
ment t'o Units 3 and g, l submit the following for the record:
Due Co Che extreme dangers and likelihood of explosions of nuclear storage sites, and the dangers of the entire nuclear fuel cycle,
> urge that nuc2e ar energy be banned from the state of Florida, and other regions also.
vlith the explosion of Che nuclear w aste storage site in the Khystym region of the Soviet during 1IL57-1958, Z arrge you Co recommend that Florida ?prer and Light work towards reestablishing safe forms of'nergy for generating electricity witlxn our state
~
- Radon, which is disbursed into the atmosphere by the nuclear industry (enclosed on nuclear industry pract;ices from the international Agency for Atomic Energy at Vienna, Austria) turns into alpha, beta and gamma rays according to.L~Iarie Curie (Treasury cf World Science, Dagobert Itunes, Editor, ?hilisophical Library, N.Y. ); galena rays are extremely penetrating, and I can personally testify that for at least eight to ten years T. have been able to detect the oddr of radiation in the atmosphere at least once every two or three weeks, though lately less frequently (though the odor persisted today briefly), and e nclose a
photograph showing radiation burns suffered by me from two after-noonsI outdoor work on September 30 and October 1, 1977.
Photogryah was taken about four days later:
The top burns show where the penetrating rays entered and exited my skin on the leg,'nd t;he lower burns are a large blotch from combined radfation.
Z realise Che problems faced by utility companies, and know that there is not enough coal. (itself with certain drawbacks) for us-ing Chat form of energyp, other forms of alternatives could be developed
- however, and Z urge the Nuclear Regulatory Commission to work towards this goal.
7 conserve, and know Chat many cculd conserve more also,.
but thev think that nuclear power is endless-that uranium will last forever and think it safe.
- Hreeders, the only way that nuclear fuel could last long enough to be a solution to the energy pro'olem, are Coo undafe to use even though foreign counhries such as England and rance have several.
You witness Chei massive demonstrations
~here ever o.fic-ials in public office march with the opposition to nuclear power.
in Sweden
>rime '.Linister Thorbjorn 7'alldin resigned over the nuclear dispute; he knew that Sweden was sending spent nuclear fuel up the coast of =lorida after entering the Niami port, yet their pane>>s majority wanted to c ontinue with nuclear power..
z hope Chat ou>> of-ficials have more comprehension as Co uture,.';dan ers.
Thank you,
~+j'</(~
Sincerelv 3 ral ei cDn. eRasmussen,
~irectcr-"meritus 030 ] g 7 g
79>~030
I
p+P+
AW h
1 g J
4k O~
~f+f' I
~ >+a<<+ ~
IAA of'ct oor work cn
=
".."~.-..'. r 1
30 ard'"c te'o'er
- ort Lauderda'.e,
.-."ov ~a.
Hepcrtei f'rst to Lr. ="-ed-er~~cx !?o/e of UVULA a: rv'ne,
".alifornia;- h~s r pr cn s"n-
'-"".-.er;o
~
a
~...... '...
4
'I
~
~
g @~P
~
entered sxin anc ex'.
. er lar ze are a barn a
=" o-'"rec sec
~on.
~ c e ~ l ne~ pcs and s pev t:ea 1
'f
Management Practices in the Nuciear Industry Radioactive Waste Stream Contaminants Typical Waste Management Practice i
Uranium Miningsnd Milling Air from mines Process/ventilation sir fram mills Mine snd runoff waters Process waste solutions Solid waste tailings Radon Radon, ore dust Radium, uranium, heavy metals Radium, uranium, acid, inorganic salts, heavy metals, sulphate, etc.
Radium, uranium, radon, thorium Diluted and discharged to atmosphere Filteredhcrubbed, discharged to atmosphere Can be used in mill, excess diluted and discharged Neutralised with lime: precipitated solids stared in tailings retention system, dear liquor recycled to gant, excess lost by natural evaporation
" Neutralised with lime: stored permanently in tailings retention system, eventually vegetated snd stsbillsed Uranium Hexafluoride Production Process gases/ventilation sir Process waste solutions.
Low level solid waste Uranium, lluorides, nitrogen oxides Uranium, acid, inorganic salts, lluorides, nitrates, etc.
Filteredhcrubbed, discharged to sunosphere Neutrslised with lime; precipitated solids retained in dams or buried, dear liquor held in dams or discharged and diluted Packsgsd for ground burial Isotope Enrichment Process gases/ventilation air Low level liquid elf luents Low level solid waste Uranium, fluorides, fluorine Traces of uranium, fluarides, nltrstesi ~tc, Oischarged to atmosphere Neutralised with lime; precipitated solids retained in dsms or buried, dear liquor held in dsms or discharged snd diluted Ground burial Fuel Fabrication Process gases/ventilation air Low level liquid effluents Low level solkl waste Uranium, nitrogen oxides, ammonia Uranium, nitrates, ammonia Filteredhcrubbed, discharged to atmosphere Neutralised with lime; predoitated solids retained in dame or buried, clear liquor held in dams or discharged snd diluted Ground burial Reactor 0peratlon.
Offgases Slowdown water, coolant leakage General chemical liquid waste Medium level solid waste Low level solid waste Fission product nobl ~ gases (e.g.
krypton, xenon), iodine isotopes,
~tivsted nitrogen, etc.
Fission products, corrosion snd activation products, tritium Fission products, activation products, inorganic salts Spent ion exchange resins, sludges from waste treatment Filtered (absolute), adsorbed on charcoal beds, diluted and discharged to atmosphere Filtered, purified by ion exchange, recycied/
diluted and discharged Evaporated, treated by flocculstion~recipitstion or ion exchange Incorporated in bitumen/cement prior to storage/
ground burial Ground burial Reprocessing of Irradiated Fuel
- Qffgssss, High level liquid waste Medium level liquid waste Low level liquid waste High level solid waste (e.g.
solidified high level liquid waste, chopped fuel daddlng)
Medium level solid waste Law level solid waste Fission product noble gases
(~.g.
krypton, xenon) radioiodine, tritium Fission products, uranium, plutonium, other actinides,nitrstas Fission products, sctinides, nitrstes,
<<arbonstes, orgsnics Fission products, inorganic saf ts, of gall les Fission products, actinides, activated dadding materials Similar to reactor operations Treated to remove iodine isotopes, filtered (absolute), diluted and discharged Evaporated stored In tanks on interim basis, solidified Evaporated, concentrate to high level liquid waste treatment, condensate to low level fiquid waste treatment Treated by ion exchange or f)occulatian<re-cipitstion; sludges, resins, etc. to solid waste treatment, purified water recyded/discharged.
Interim storage in engineered facilities, ultimate storage/disposaf to be determined Incorporated in cement/bitumen for ground burfsl Ground burial
~/~~ -iiiri~~ f~Aciiyz.
g mr lrwrvcrp g~a~P A+Wre',
~+waif'r~
ITIZENS AOAINST'ADIOACTIVEPOI I,UTION C
MISS GERALDINE D. RASMUSSEN FOUNDErC~DLRECTOft EDITOR EhtERITVS
41 41
Who is Doing What with High-level Waste and Where?
Current pr<<tice.
Future plans USA Honforct, Washington Liquid wastes are mode alkaline and stored in mild steel tanks.
Coeslum 137. and strontium 90 are chemically separated from high heat wastes, encapsulated and stored in water~ed basins.
Uquid wastes are gradually being solidified by evs.
poratian to a salt cake that is stored in existing tanks.
Savannah River. South CcroRno Liquid wastes ace made alkaline snd stored In mild steel tanks. Programme under wsy to evaporate and cool liquid wastes to form a salt cake. Saturated salt solutions sre stored in existing tanks.
iyoctonol Re<<car 7esring Scscion, IChho Acidic waste solutions stored in stainless steel tanks prior to calcination in Waste Calcining Facility and Intarim storage in stainless steel bins.
ment Operations Allhigh activity wastes are to be solidified as soon as practicable.
Long term options being evaluated'ndude storage in existing tanks or vaults, storage on-site in underground caverns, or shipment to oft.site federal repository.
No commercial plants are currendy operational.
The Nuclear Fuel Senrices Plant in New York State operated 1966-1972 but is naw shut down. Most high activity wastes fram this plant were mode alkaline snd sre stored in s mild steel tank but smell quantities af special wastes sre stoced in s stainless steel tank.
Wastes from Commercial Reprocesslng The Bsmwell Nudesr,Plant in South Carolina is expected to commence operation in 1978. After co processing, sll high activity liquid waste is to be converted into sn immobile lorm within five years snd must bo transferred to s national repository within ten years. Pilot plant demonstration ot waste solidification processes tram 1966-72 at Henford established the necessary technology.
Currently, assesscnents ot alternatives for both interim snd ultimate storage ore in progress.
USSR UK France Belgium Canada FR Gercnon India Italy Japan Liquid wastes stored in stainless steel tanks. Sdiditic-ation processes to produce phosphate glasses have been investigated an a laboratory scale with radio-active wastes and on o pilot plant scale with inactive simulated wastes.
Uquid wastes are stored as acidic soiutians st Winchcale and Oounreoy reprocessing plants in stainless steel tanks.
Liquid wastes sre stored as acid solutions st the Msrcoule and La Hague reprocessing plants in stainless steel tanks. ThMIVERpilotplant to solidify wastes into borosilicate glass has been operating since 1969.
Liquid wastes from Eurochemic ceprocsssing plant are stored in stainless steel tanks.
~ Engineered storage of irradiated tuel sssembfles.
Uqu<d wastes from WAKreprocessing priat plant are stored in stainless steel tanks.
Studies of solidifying wastes into borosilicate and phosphate glass are in
'rogress Uquid wastes stored as acidic solutions ln stainiess steel tanks.
EUROX pilot repracessing plant began operation in 1970. Small quantities of liquid wastes ws stored in stainless steel tanks.
No slgniflcant quantities ot high level wastes have been produced.
industrial seal ~ plant to glassity wastes is expected to begin operation in the 1980's.
Uquid Infection into deep geologicsl tormati ons is also being considered.
Storage of wastes ss liquids is considered safe in the near term. The FINGALpracess to solidify wastes into borasilicste glass wss investigated trom 1958-68.
An improved glass making pro.
cess IHARVESTI is being developed snd there sre plans to begin soliditying wastes In the mid 1980s.
Storage methods that allow solidified wastes to be retrieved are favoured.
A new solidification plant capable ot vitrifying, wastes from essentially an 800 ton reprocessing facility has been constructed at Marcoule.
Calcination and gisssi tication processes are being considered tor waste solidification.
Storage of fuel without reprocsssing in water or sir~ed vaults is considered satisfactory tor at least 75 years. Ifeconomically attractive, tuel willbe reprocessed at s later date.
First radioactive glasses willbe produced in the VERA pilot plant ln 1978/79.
Hlghdevel liquid wastes will be canveaed into glasses after s three to five year cooling period. Salt formations similar to Asse are being studied tor ultimate dis.
possl.
A waste in cnobilisation plant using a batch glass-cnaking process is expected to be operating in 1977i78. Safldifled wastes willbe stored In slr-cool ed vaults..
Batch solidification to form borosilicate or phosphate glasses under consideration.
Oisposal of salid wastes in day formations of low perme" ability is being investigated.
A reprocsssing plant is presently under construe.
tion. Acidicwastes willbe stoced in stainless steel tanks tor periods of up to five years. It is Pro-posed to construct s pilot sdidification plant by 1981.
CI22ZENS AGAINST RADIOACTIVE'OII VTION MISS GERALDINE D RAS i&VSSEN FOUNDER DQLECTOR EDITO1'c EAIERlTVS
0
. ~
y
~
f f
f
\\
'i,
~
~
~
0-QCT1XKNS'~fN5T'DIOA~'OLLUTION'1$
8'EltALDlNE;D. RA<MUSSEN POUND ER+DlRECTOR+KDLTOR i.rERALDII>>Z Do QUASI'GJSSEI>>
> DIRECTOR EDITOR POUTER SR'VER p 1979 INTERNATIQIrA'L".O'Y DAY DEDICATION D
A N
O R
0 U
S L
E, H
A L
DEDICATZO TO HAZEL C.. HASMJSSEN, 1895-1979,, I!onorary Yember.,
- CARP, Hazel C ~ Rasmussen
!memorial rund establ5.shed by Edwin Oliver KAREN SILKlOGD, Kerr-'AcQee plutonium lab technician k5.lied in. a mysterious auto accident on November 13, 197$
wh5.le she was en route to ~ive facts on falsified company records to a, New York =5.mes reporter; parents suing Kerr-I!cGEE NILLZAN'A'QTER, Alabama Anti-Nuclear Attorney ='eneral who aied on January 17, 1979,, will be;-.-reatly missed DAVID CO.KY, Nicely known environmental leader who cied in an automobi1e accident on J'anuary 5,
979.
A NUCLEAR REACTOR STOHA.~E SITE Efi.PLODED contaminatin",
a thousand quare N LES in the southern Jral region of. the SOVIET UIIIOi>>,. a DTSASTOR which nZXP.R.,Sn sa5d could
~IV" ha~pen~
curin.r 195(19gg Reports were suppressed and location not.=iven unt'1 revealed in EVl".rLAND by Zhores
- Hedvedev, former Soviet scientist, who -.ives deta5.1s in his book, S'OVIET SCIENCE,
('rl.':l. Norton, 1978}, pages 9Q-98 and Appendix II', pages 232-2Ur~..')
The nuclear cisastor oc-curred in a region whe~re nuclear reactor NASTES had been stored in shallow trench-like sites in the Jral region near Chiliaoinsk.
and Sverdlovsk, where thousands died immediately, many more lat-er, as hospitals were not prepared ana evacuation was delayed because of lack of any plan.
he zone is heavily, contaminated be5ng a thousand times more so than test laboratories for test-ing radiation..
The two above cities are approximately 200 miles apart,,
and winds carried and spread the s evere c ontaminat ion a thousand aware miles in a circular area; the public is not per-mitted there even today though test stations are on the outskirts.
.The DIRECTOR of the PORT CF
!CZAPI has banned radioact've materials from he port following the I'motorcade up Florida's east coast.
It is sad that local Florida newspapers criticized the group, as they and we are preparing for a safer nation ana world,.
hese shipments trav-elled up the coast of Plorida by truck,and train to South Carolina for reprocessing.
(Any wishing past CAPP 5.ssues on His issue may obtain the-.
by sendin= 02.00) Last month personal frienas driving south tIwough Tennessee passed through. an area near Nonteagle north of Chattanooga where
- a. truck containing radioactive materials overturned; all traffic was rerouted, and the Tennessee State Highway Patrol wrote me that there was no leakage.
The truck was drivhg from Chicago.
lt is. such a small, amount of the total need for ener:~
and electric'ty which nuclear energy fills, that there is no need to RISK future life on our EARTH for this dangerous form of energy; alternative, safe forms
- exist, and are waiting for a subsidized 5ndustry to turn some attention and funds to d evelopment of solar,. wind, hydro-and hydrogen energy.
Though DR.
NOF2U.N RASIIUSSZNls 197$ Feport greatly minimized the dangers (aublished by EFZ)A, condensed in the Readerls Di-est), Dr.. Basmussen a year later:
"Nuclear, power plants have Rot performed with the
0 0
Ah
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY 6 LICENSING BOARD In the Matter of
)
)
FLORIDA POWER 6 LIGHT COMPANY
)
)
(Turkey Point Nuclear Generating Units Nos.
3 and 4)
)
Docket -Nos.
50-250-SP 50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repair)
MOTION TQ ADOPT PRE-HEARING SCHEDULE AND TQ SCHEDULE FINAL HEARING Pursuant to the provisions of 10 CFR Sections 2.703(a) (1),
2.730, and the "Notice of Hearing" issued by the Atomic Safety and Licensing Board August 9, 1979 (44 FR 47821), Licensee respectfully requests that the Board issue an Order adopting the proposed Pre-Hearing Schedule attached to this Motion and schedule the commencement.
of a Final Hearing for December 4, 1979, in Miami, Florida.
Both Licensee and. Intervenor have agreed to the proposed December 4,
1979 hearing date, but the NRC Staff, has indicated that it is premature to project dates to file testimony or for the commencement of a hearing.
(See letter dated August 31, 1979 from the undersigned co-counsel for Licensee reporting to the Board on the meeting between all parties held August 30, 1979 in Miami, Florida, pursuant to the Board's Order of August 3, 1979.)
.However, the NRC Staff Safety Evaluation for the proposed repairs was issued May 14, 1979, and. copies served on the Board
4>
gi f,
and parties May 15, 1979.
Similarly, the NRC Environmental Impact Appraisal was issued and served on the Board and all parties, June 29, 1979.
Adoption of the proposed Schedule and scheduling the Final Hearing, as requested, will assist the parties in pre-hearing. preparation, including the conduct of
.discovery and the filing of prepared written testimony.
Respectf lly submitted',
NO STEEL HE Co-Couns 1400',Sou AN A. COLL TOR 6 DAVIS 1 for Licensee heast,First National Bank Building Miami, Florida 33131 Telephone;:.
(305) 355-2863'ated:
September 4,
1979
0 4~
Il
p PROPOSED SCHEDULE - TURKEY POINT STEAM GENERATOR REPAIRS LICENSING HEARING Thursday Friday Friday
- /
Tuesday-August. 30, 1979 August 31, 1979 September 14, 1979 October 30, 1979 Parties meet in Miami to discuss contentions, possible stipulations, and set a schedule for discovery.
Parties report, to Board (ASLB) on meeting of August. 30.
All parties commence discovery on contentions ruled admissible by Board in Order of August 3, 1979 (Contentions 2, 5,, 6, 7, 12 and 18).
Part:ies simultaneously file and serve statements concerning admis-sibility of 'Intervenor's conten-tions filed with Board. with report of August: 31, l979
\\
Cut<<off for discovery requests on contentions ruled admissible by the Board in Order of August 3, 1979.
Friday November 16, 1979
- 4'/'uesday.
December 4,
1979 Pile prepared testimony.
Commence hearing.
All parties agree that discovery on any other contentions ruled admissible by the Board may commence upon issuance of the Board's order so ruling.
- / Assuming it is consistent with the Board's schedule, both Licensee and Intervenor agree to the proposed December 4 hearing date.
The NRC Staff believes it is premature to project dates to file testimony or comm'ence a hearing.
ATTACHMENT
UNITED,STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY
& LICENSING BOARD In the Matter of
)
)
,FLORXDA POWER
& LIGHT COMPANY
)
)
(Turkey Point Nuclear Generating
)
Units Nos.
3 and 4)-
)
Docket Nos.
50-250-SP 50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repair)
CERTIFICATE OF SERVICE I HEREBY CERTIFY'hat copies of the attached captioned.in the above matter, together with attachment thexeta.,
were served on the following by deposit in the United States mail, first class, properly stamped and addressed.,
on the date shown below.
Elizabeth, S.
Bowers, Esquire Chairman Atomic Safety
& Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Oscar H. Paris Atomic Safety
& Licensing Board Panel U.S. Nuclear 'Regulatory Commission Washington, DC 20555 Dr. David B. Hall 400 Circle Drive Santa Fe, NM, 8750l Atomic Safety
& Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555
4~
Atomic Safety 6 -Licensing Appeal Board Panel, U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Mark P.
Oncavage 12200 S.W.
110 Avenue Miami, FL 33176 Docketing and Service Section
'ffice of the Secretary
'U. S. Nuclear Regulatory Commission Washington, DC 20555 Steven C. Goldberg, Esquire U.S. Nuclear:Regulatory Commission Office of the Executive Legal Director Washington, DC
.20555 Bruce S.. Rogow, E'squire Dean.
NOVA Law School 3301 College Avenue Fort Lauderdale, FL 33314 Harold. F. Reis, Esquire Lowenstein, Newman,, Reis, Axelrad 6 To 1 1025 Connecticut Avenue, NW Washington, DC 20036 ORMAN A. COLL STEEL HE T 1400 Sou OR 6 DAVIS east First National ank Building Miami, Florida 33131 Telephone:
(305) 577-2863 Dated:
September 4.,
1979
J 1
t 0~I CI nUcnbA II,~. SU~g Vg g~~fd>SI S' AW OFFICES R ICHARO N. FR I EDMAN lOO OISOAYNC OOVt CVAROq NORTH MIAMI,FLORIDA ODIST TCLCPHON C (305) O'F'7 OQ88 September l4, 1979 IIOgIt.'nt>
IIgNLC gEP1 9 )S78 + 9 OIP ~ ~I IQy $+tftwf I>*~ 5 I~I+~
$ec&s Secretarv of the Commission Nuclear RegulatorV Commission Washington, D.C.
20555 ATTN:
DOCKETING AND SERVXCE BRANCH
Dear Sir:
As a member of the public, X should like the opportunity to make an oral presentation for five (5) minutes before the Nuclear Regulatory Commission in connection with a hearing to be held on the petition of Mark P.
Oncavage regarding the proposal to repair the steam generators at, the Turkey Point Plant in Florida.
Thank you. for your earliest advice as to the date, time and place when the public hearing will be held and your confirmation that I will be a speaker.
Thank you for your cooperation.
Uery t ly yours, R CARD N.
RNF/d
UNITED STATES. OF AMERICA NUCLEAR REGULATORY COMMISS ION In the Matter of
)
)
FLORIDA POWER AND LIGHT COMPANY
)
)
(Turkey Point, Units 3 and 4)
)
)
)
)
)
Docket No. (s) SO-250SP..
S0-253.SP CERTIFICATE OF SERVICE I hereby certify that iI have this day.served the foregaa.ng document(s) upon each person designated on the official service liw>> compiled by the Office of the Secretary of the Commission in this pz-ocaeding in accordance with the requirements of Section 2.712 of 7$
CFR Part 2-Rules of Practice, of the Nuclear Regulatory Commissioni*s Rules and Regulations.
Dated at Washington, D.C. this day of A+7 /
197+.
ul~iNi Office o the Secretary a~ tha Commission
il
UNITED STATES OF A?~~RICA NUCLEAR REGULATORY COHIXSSION Xn the Matter of SERVICE LIST
)
)
FLORIDA POWER AND LIGHT COMPANY
)
)
(Turkey Point, Units 3 and 4)
)
)'
Docket No. (s) 50 250SP 50-251SP Elizabeth S. Bowers, Esq.,
Chairman Atomic Safety and Licensing Board.
U.S. Nuclear Regulatory Commission
$iashington, D.C.
20555 Dr. David B; Hall 400 Circle Drive Santa Fe, New Mexico 87501 Dr. Oscar H. Paris Atomic.Safety and Licensing Board U.S. Nuclear Regulatory Commission washington, D.C.
20555 Michael A. Bauser, Esq.'
.Lowens,tein, Neman, Rais, Axelrad and Toll 1025 Connecticut
- Avenue, N.V,.
h'ashington, D.C.
20036 Mr.-,Mark P.
Oncavage 12200 S.l~. 110th Avenue Miami, Florida 33176 Norman A. Coll, Esq.
Steel Hector
& Davis 1400 S.E. First National Bank E~M.ng Miami, Florida 33131 Counsel for NRC Staff 0ffice of the'Executive U.S. Nuclear Regulatory
'.washington, D.C.
20555 Florida Power and Light Company
.;T':
Dr. Rooert E. Uhrig Vic'e'resident P. 0. Box 529100
".w~'ani, Florida 33152 Joel V., Lumer, Fsq.
245 Catalonia Avenue Coral Gables, Florida 33134 Richard A. Etarshall, Jr.,
Esq.
18450 S.V. 212th Street Miami, Florida 33187 Legal Director Bruce S.
- Rogow, Esq.
Commission
~ Nova University Center for the Study of Law 3301 College Avenue
]Fort Lauderda'le, Florida 33314
il