ML17340A235
| ML17340A235 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/01/1980 |
| From: | Saunders B DADE COUNTY, FL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8010080637 | |
| Download: ML17340A235 (12) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Atomic Safety and Licensin Board Elizabeth S. Bowers, Chairman Dr. Emmeth A. Luebke, Member Dr. Oscar H. Paris, Member usNRc p
Offlwgfg DocksQg g g NICC In the Matter of FLORIDA POWER 8c LIGHT COMPANY (Turkey Point Nuclear Generating Unit Nos.
3 and 4)
Docket Nos.. 50-250-SP 50-251-SP MOTION FOR LEAVE TO PARTICIPATE PURSUANT TO RULE 2.715 c OF THE UNITED STATES NUCLEAR REGULATORY COMMISSION RULES AND REGULATIONS, RULES OF PRACTICE FOR DOMESTIC LICENSING PROCEEDINGS Petitioner, METROPOLITAN DADE
- COUNTY, a
political subdivision of the State of Florida, by and through its -undersigned
- counsel, hereby files this Motion for Leave to Participate Pursuant to Rule 2.715(c) before this Honorable Board, and alleges as grounds therefor, the following:
1.
On September 2,
- 1980, the Board of County Commissioners of Dade County unanimously adopted a
resolution directing the County Attorney's Office to petition the Atomic&afety and Licensing 4'oard for leave to participate pursuant to Pule
- 2. 715(c),
said resolution being attached hereto and made a part hereof.
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2.
Rule 2.715(c) provides in pertinent part that an agency such 'as Dade County shall have a "a reasonable opportunity to participate and to introduce evidence, interrogate witnesses, and advise the commission without requiring the representative.
to take a-position with respect to the issue.,
Such participants may also file proposed, findings and exceptions pursuant to Sections 2.754 and 2.762 and petitions for review by the commission pursuant to Section 2.786"..
3.
Review of the Environmental Impact Appraisal by the Office of Nuclear Reactor Regulation and the Safety Evaluation by the Office of Nuclear Reactor Regulation, and amendments.
- thereto, and review of the Environmental Impact Statement.is likely to reveal areas of unique concern to petitioner.
Petitioner would reserve its right to raise issues upon review of said documents.
THEREFOR=-, your Petitioner, IKTROPOLITAN DADE COUNTY, respectfully reques"s
.that this Board permit petitioner
-to participate in all hearings in reference to the repairs at the Turkey Point Nuclear Generating Unit Nos.
3 and 4, as provided in Rules of Practice for Domes ic Licensing Proceedings, 2.715(c).
ROBERT A. GINSBURG Dade County Attorney 1626 Dade County Courthouse Miami, Florida 33130 QgCg~Wr=r Bur L. Saunders Assistant County Attorney
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF
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FLORIDA 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 Licenses to Permit Steam Generator Repair)
'CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of the attached Motion for Leave to Participate Pursuant to Rule 2.715(c) of the United'tates Nuclear Regulatory Commission Rules and Regulations, Rules or Practice for Domestic Licensing Proceedings, captioned in the above matter, were served on the following by deposit in the United States maii, first class, properly stamped and addressed, on,the date shown below:
Elizabeth S. Bowers, Esp.
Chairman Atomic Safety and Licensing B oard Panel U.S. Nuclear 'Regulatory Commission Washington, D.C.
20555 Dr. Oscar H. Paris.
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr.
Emmeth A. Luebke Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 DUOiW UBNRD
"". -Qadi Office af Se pecr&ty D."NeinE 6 SenEce BfBllc7J~
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Atomic Safety and Licensing Board, Panel U. S. Nuclear Regulatory Commission Washington,,D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Mark P..
Oncavage 12200 S.N. 110th Avenue Miami, Florida 33176 Docketing and Service Section Office of the.Secretary U.S. Nuclear Regulatory Commission Nashington, D.C.
20555 Steven C. Goldberg, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington@
D'C 20555 Neil Chonin, Esq.
Law Offices of Neil Chonin, P.A.
Counsel for Intervenor New tforld Tower Building, 30th Floor 100 N. Biscayne Boulevard, Miami, Florida 33132 Henry H. Harnage,,
Esq.
Counsel for Intervenor Peninsula Federal Building, 10th Floor 200,S.E. First Street Miami, Florida 33131 Harold F.. Rei;s, Esq.
Steven P. Frantz, Esq.
Lovrenstein, Newman, Reis, Axelrad
& Toll Co-counsel for Licensee 1025 Connecticut Avenue,NW Nashington, D.C.
20036 ROBERT A.
GXNSBURG Dade County Attorney 1626 Dade County Courthouse Miami, Florida 33130 z)
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Burt L. Saunders Assistant County Attorney October 1,
1980
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'ESOLUTION NO.
R-1022-80 QDMa'Z<< ~
A<<<<~ J Amendec uNRe Agenda Item No.
(cg('6 tuo y 9-2-80 0'flCeO'~'~8 Pg~gtllhSeWC" 97etlC RESOLUTXON DIRECTING
- THE, DADE COUNTY ATK)RNEY'S OFFICE TO INTERVENE PURSUANT TO NUCLEAR REGULATORY COMMISSXON RULE 2.715(c)
IN THE MATTER OF FLORIDA POWER AND LIGHT COMPANY (TURKEY POINT NUCLEAR GENERATXNG UNITS NOS.
,3 AND '4)i DOCKET NOS.
50-250 AND 251
'(PROPOSED AMENDMENTS TO OPERATING LICENSES TO PERMXT STEAM GENERATOR REPAIR)
WHEREAS, Florida Power
& Light Company has petitioned the Nuclear Regulatory Commiss'ion of the 'United States for a
license to repair Turkey Point Units.Nos.
3 and 4;
and WHEREAS,.
Florida Power Light Company has contracted with Westinghouse Electric Corporat'ion to make these repairs; and WHEREAS, several issues of interest to the citizens of Metropolitan Dade County, such as the possible environmental effects on Biscayne Bay, the Biscayne Aquifer and the County drinking water
- supply, and the storage of radioactive waste in Dade County, must be considered. by the Nuclear Regulatory Commission in its review of the proposed plans and licensing thereof;
.and
- WHEREAS, no other governmental entity can adequately represent and protect the interest of Metropolitan Dade County whose interest is most directly affected by these repairs due to the location of the Turkey Point Nuclear facility; and WHEREAS, it is the desire of this Board to ensure that all matters of interest to the County and the citizens-thereof, are fully addressed and considered prior to the commencement of maintenance and repair work above-described at Turkey Point,
- NOW, THEREFORE BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF DADE COUNTY, FLORIDA:
Section l.
The County Attorney is hereby authorized and directed to petition the Nuclear Regulatory, Commission of the United States for permission to intervene --in proceedings concerning Florida Power
& Light Company's application for license to repair Turkey Point Units Nos.
3 and 4,
which intervention is provided for by Nuclear
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Q~W Amende Agenda tern No.
2 (c)
Page No. 2-
,Regulatory Commission Rule 2.715(c),
which rule is specifically designed to permit intervention by a County government without that government taking a
position: with respect to the adversary issues before the Nuclear Regulatory Commission.'Section 2.
The County Attorney is directed to submit a bi-monthly report to the Board of County Commissioners on the petition to the Nuclear Regulatory Commission and to obtain pri'or approval from this Board for expenditures in excess of
$ 2,500.00.
-Section 3.
The County Manager is hereby authorized and directed I
to review the forthcoming Environmental Impact Statement incident to the proposed repairs at Turkey Poi'nt Units Nos.
3 and 4,
and to prepare comments and testimony concerning the statement, if necessary and appropriate in the determination of this Board.
.The foregoing resolution was offered by Commissioner Harvey Ruvin who moved its adoption.
The motion was seconded by Commissioner Ruth Shack put to a vote, the vote was as follows:
,,and upon, being Barbara M. Carey Clara Oesterle William G. Oliver Beverly B. Phillips James F. Redford, Jr.
Harvey Ruvin Barry D. Schreiber Ruth Shack C
Stephen P. Clark Aye Aye Aye Aye Aye Aye Aye Aye Aye The Mayor thereupon declared the resolution duly passed and adopted this 2nd day of September, 1980.
DADE COUNTY, FLORIDA'Y ITS BOARD OF COUNTY COMMISSIONERS RICHARD P.
- BRZNKER, CLERK Aoproved by Coun.ty Attorney as ~
to form and legal su fficiency. -~>
By:
Deputy Clerk.
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