ML17340A517

Request That Intervenor & Designated Experts Be Allowed to Enter Site to Measure,Survey,Test & Photograph Based on Recent & Continuing Steam Generator Problems.Certificate of Svc Encl

ML17340A517
Person / Time
Site:	Turkey Point
Issue date:	11/09/1980
From:	Chonin N CHONIN, N., ONCAVAGE, M.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8012290400
Download: ML17340A517 (9)

Text

REGULA . Y INFORMATION OISTRIBUTIO YSTEM (RIOS)

ACCESSION NSR'8012290400 DOC ~ DATE j 80/11/09 NOTARIZED'O DOCKET FACIL:50"250 Turkey Point Planti Unit 3p Florida Power and Light C 50 251 Turkey Point Planti Unit QP Florida Power and Lignt BYNAME C 050 0251 AUTH AUTHOR AFFILIATION CHONINP N ~ DncavageiMark CHONINE N ~ ChoninEN ~

REC IP ~ NAME RECIPIENT AFFILIATION Atomic Safety and Licensing Board Panel SUBJECT> Request that intervenor 8 designated experts be allowed to enter site to measureisurveyitest 8 photograph based on

-recent E continuing steam gener ator problems,Cer tificate of Svc encl, DISTRIBUTION CODE: DROSS TITLE: Filings (Not Orig COPIES RECEIVED:LTR by I9RC}

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NOTESR RECIPIENT COPIES RECIPIENT COPIES IO CODE/NAME ~Tl'R ENCL ID CODE/NAME LTTR ENCL ACTION: PARRISHP C ~ GROTENHUISE M INTERNAL: ASLAP ASLB I8,E VRC PDR TON PUBLIC AFFAIRS REG FIL EXTERNAL: LPDR NSIC d

TOTAL NURBER OF COPIES REQUIRED: LTTR 'NCL 16

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Atomic Safet and Licensin Board Elizabeth S. Bowers, Chairman Dr. Emmeth A. Luebke, Member Dr. Oscar H. Paris, Member

• 'P *

• In the Matter of:

FLORIDA POWER Bc LIGHT COMPANY Docket Nos. 50-250-SP 50-251-SP (Turkey Point Nuclear Generating Unit Nos. 3 and 4) 7 MOTION TO PERMIT ENTRY UPON TURKEY POINT SITE COMES NOW the Intervenor, Mark Oncavage, and moves this Board for an Order allowing the Intervenor and any experts designated by the Intervenor to enter. upon the Turkey Point Site for the purpose of inspection, measuring, surveying, photographing, testing, or sampling the property or any designated object or operation there-on pursuant to 10 CFR 2.741 and as grounds therefor states:

1. That the Turkey. Point Plant has had recent and continuing problems with the steam generators which are the subject matter of this action.

2. That Unit Number Three (3) recently began to leak up to two-hundred and forty (240) gallons of radioactive water per day.

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3. That about twenty (20) percent of Unit Number Three's tubes, nearly ten thousand (10,000) tubes have been plugged since 1976 and said plugs have recently begun to develop radioactive leaks.

4. That Florida Power and Light Company is unaware and is uncertain as to what is causing the lastest leaks and whether or not the leaks are related to previous problems that have occurred in November of this year.

5. That the very recent tube leaks were first noticed on No-vember 19, 1980 at which time the tubes were leaking a half gallon per hour. That the leakage has gradually increased and stabilized at ten (10) gallons per hour and on November 22, 1980 continued at that level until a voluntary shut-down was instituted by Florida Power and Light Company.

6. That recently a rumbling probably caused by surging water shook Unit Number Three and broke a two inch pipe that spewed out thousands of gallons, of cooling water.

7. That Mark Oncavage as the Intervenor has the right to make an independent=inspection to determine what damage if any these latest problems have caused to the steam generators and whether or not there has been radioactive leakage into the various cooling canals and surroundings areas of the Turkey Point Site.

8. That the Intervenor wishes to examine the Plant Survey Reports starting January 1, 1978, the environmental radiological monitoring data starting January 1, 1978, and the workers dosimetry records starting January 1, 1978, and in addition wishes to do a physical radiological survey of Turkey Point and Environs, to obtain samples of the air, water, soil, sediment, and various biota

forms. That the above inspections are relevent and could lead to admissible evidence concerning contentions number 2, 3, 7, 9, and 13.

MHEREFORE the Intervenor respectfully petitions this Board to immediately allow the Intervenor to conduct inspections as described above pursuant to 10 CFR subpart G, Section 2.741.

LAN OFFICES OF NEIL CHONIN, P .A Counsel for Intervenor Suite 1400 Amerifirst Bldg.

One S. E. 3rd Avenue Miami, Florida 33131 By New onion

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC. SAFETY AND LICENSING BOARD IN THE MATTER OF: ) Docket Nos. 50-250-SP

) 50-251-SP FLORIDA POWER 6c LIGHT COMPANY ) (Proposed Amendments to

) Facility Operating (Turkey Point Nuclear Generating -) Licenses to Permit Steam Units Nos. 3 and 4) ) Generator Repair)

CERTIFICATE OF SERVICE I HERBY CERTIFY that a copy of the attached Motion to Permit Entry Upon Turkey Point Site in the above captioned matter, were served on the following by deposit in the Untied States Mail, first class, properly stamped and addressed, on the date shown below:

Elizabeth S. Bowers, Esq. ho~~

Chairman 8 0~sgRo Atomic Safety and Licensing Board Panel Qlp U.S. Nuclear Regulatory Commission e( ~>e~

Washington, D.C. 20555 ~Ofg A p Dr. Oscar H. Paris a

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Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission <<e Washington, D.C. 20555 Dr. Emmeth A. Luebke 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 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Mark P, Oncavage 12200 S. W. 110th Avenue Miami, Florida 33176

Docketing and Service Section Office of Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Steven C. Goldberg, Esq.

Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Henry H. Harnage, Esq.

Counsel for Intervenor Peninsula Fed. Bldg., 10th Flr.

200 S. E. 1st Street Miami, Florida 33131 Robert A. Ginsburg Dade County Attorney 1626 Dade County Courthouse Miami, Florida 33130 Harold F. Reis, Esq.

Steven P. Frantz, Esq.

Lowenstein, Newman, Reis, Axelrad 6 Toll Co-Counsel for Licensee 1025 Connecticut Avenue, N.W.

Washington, D,C. 20036 DATED: November 9, 1980.

LAW OFFICES OF NEIL CHONIN, P.A.

Counsel for Intervenor Suite 1400 Amerifirst Bldg.

One S. E. 3rd Avenue Miami, Florida 33131 By ez C onion