ML17340A610

Confirms 810107 Telcon Re Preliminary Informal Conference to Discuss Facility Repairs & Schedule for Proceedings on Proposed Amends to Ols.Proposed Schedule & Certificate of Svc Encl

ML17340A610
Person / Time
Site:	Turkey Point
Issue date:	01/08/1981
From:	Coll N FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS
To:	Chonin N CHONIN, N.
References
NUDOCS 8101140886
Download: ML17340A610 (12)

Text

par REGULATI, INFORMATION DISTRIBUTION STEM" (RIDS)

ACCESSION. NBR:8101 irI0886 DOC ~ DATE: 81/01/08 NOTARIZED: NO DOCKE'7 FACIL:50-250 Turkey Point Plantr Unit 3i Florida Power, and Light C 05000250 50 2S1 Turkey Point Planti Unft 4r Flor ida Power and Light BYNAME C 05000251 AUTH AUTHOR AFFILI'ATION COLLINS A' Florida Power 8 Light Co, COLLgN ~ AD Stee,l r Hector 8 Davis RECIP ~ NAME, RECIPIENT. AFFILIATION CHONIN e N' ChonfnrN ~

1 SUBJECT Conf ir ms 8101.07 tel con re prel iminar y informal .conferehce to discuss facf lfty repairs 8 schedule for,proceedfngs on proposed. amends OLs.Proposed schedule L Certificate of Svc encl' DISTRIBUTION CODE.: DS03S -COPIES RECEIVED.I TR ENCL 'SIZE:

TITLE4 Filings (Not Or ig by NRC)

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE'/NAME LTTR'NCL ACTION ~ PARR ISH'g C'e 1 1 GROTENHUI 8 i 1 1 INTERNAI: ASLAP 5 5 M'SLB'RC 1 1 I8E 2 2 PDR 1 1 TON 1 1 PUBL'IC AFFAIRS 1 1 EG FILE 1 1 EXTERNAL: LPDR NSIC 4@3 tl ]ggt TOTiAL NUMBER'F COPIES REQUIRED'TTR 16 ENCL 16

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ST E E I H EGTQ 8'.. DAY s I SOUTHEAST FIRST NATIONAL BANK BUILOINO MIAMI)FLORIDA 33I3I TCLCX 5I 5758

~~ o PALM BEACH NORMAN A. COLI (305) 577 2883 January 8, 1981 2OS WORTH AVENUE PALM BEACH, FLORIOA 33480

/p Neil Chonin, Esquire New World Tower Building L

~CA 30th Floor Q+ Q 100 North Biscayne Boulevard n

~CD y) CA C

Miami, Florida 33132' Re: -In the Matter of Florida Power &

Light. Company (Turkey Point Nuclear Generating Unit Nos. 3 and 4) Docket Nos. 50-250, 50-251 (Proposed. Amend-ments to Facility Operating Licenses to Permit Steam 'Generator Re air)

Dear Neil:

This will confirm"our telephone conversation Wednesday., January 7,, 1981.

As you know, on Friday, December 19, 1980, the NRC issued the Draft Environmental Statement,(DES), and the updated Safety Evaluation Report (SER), for the Turkey Point Steam Generator repairs. As I mentioned to you, FPL wishes to make every effort to have the license amendments issued in August so that a, work force can be mobilized and the repairs commenced in October of 1981. After making allowances for filing proposed findings of fact and conclusions of law and for the Board to prepare a decision after the hearing, is concluded, the hearing itself would have to be completed sometime in April or May. Consequently, we have attempted to draft a proposed schedule for a hearing in that time frame.

The purpose of my telephone ca13. was to discuss the proposed schedule with you.

In our conversation, you suggested that a preliminary informal conference be set up in Miami, to be attended by all parties and their counsel, atlike which time your client, intervenor Mark Oncavage, would to make certain suggestions with respect to how the repairs might occur, and certain requests that FPL take into consideration certain matters which he felt had not previously been g $ 09

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STE EL H ECTO R & DAVIS Neil Chonin, Esquire January 8, 1981 Page Two considered. You indicated that you had asked Mr. Oncavage to prepare a preparation for such a meeting.

list of such matters in have discussed your proposal with our client, and We it We has agreed that we should attend such a meeting.

hope that the conference may result in resolution of some or all of the issues to be litigated in the proceeding.

In preparation for the conference, we ask that you provide us with Mr.. Oncavage's list as soon as available. This will help us prepare for the conference, it is as well as assist us in determining whether technical representatives will be necessary to participate in the discussions.

We believe that it is essential that a schedule for the proceeding be discussed at the conference.

Enclosed is a copy of a proposed schedule which my co-counsel Harold, F.. Reis has drafted and discussed with Steven C. Goldberg of the NRC Staff. I also discussed it with Burt Saunders by telephone today. We would like to discuss it further at the proposed conference, and to the extent that we can agree on, these dates,. we suggest that the schedule be presented to the Board, promptly for its consideration.

It is my understanding will be back in touch with that. you and/or your secretary me, and the other counsel within the next couple of days to set up a mutually agreeable time during the week of January 19 for the conference. Prom my client's standpoint January 19 and January 23 are the most preferable dates. I look forward to hearing from you and to receiving Mr. Oncavage's list as soon as it is available.

(

Very uly yours, NAC/m Norm n A. Coll cc: See Attached Service List.

ig IO LO~ENSTEINp NEWM~J RE I s & AxE n PROPOSED SCHEDULE

1. February 13, 1981 Last day for filing discovery requests

2. March 1, 1981 Last day for filing responses to discovery

3. March 6, 1981 Motions for summary disposition

4. March 17, 1981 Prehearing. conference:.(10CFR g2.752)

5. April 7, 1981 Prefiled testimony 6.. April 22, 1981 Hearing begins. covering all issues not previously summarily dismissed

ii 0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSON BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docket Nos. 50-250-SP 50-251-SP IN'HE MATTER OF )

FLORIDA POWER G. LIGHT COMPANY ) (Proposed'mendments to (Turkey Point Nuclear Generating ) Facility Operating Units Nos'. 3. and' ) License to Permit Steam Generator Repairs)

CERTIFICATE'F'ERVICE I HEREBY CERTIFY that copies of the foregoing letter of January 8, 1981 was 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, Esq.< Administrative Judge Chairman, A'tomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washi:ng ton, D..C'. 20555 Dr. Emmeth A. Luebke, Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Oscar H- Paris, Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Pr. Mark P. Oncavage 12200 S.W. 110th Avenue Miami, Florida 33176 Harold F. Reis, Esq.

Steven P. Frantz Lowenstein, Newman, Reis 6 Axelrad 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036

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Steven C. Goldberg,, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C'.

20555'urt Saunders, Esq.

Assistant Dade County Attorney 1626 Dade County Courthouse.

Miami, Florida 33130 Neil Chonin:, Esq.

New World Tower Building,, 30th Floor 100 N. Biscayne Boulevard Miami, Flor ida 33132 Henry H.:Harnage, Fsq.

Peninsula:Federal Building.

lOth Floor

,200 S.E'. First Street Miami, Florida 331'31 STEEL HECTOR 6 DAVIS Co-counsel for Licensee 1400 Southeast First Natio 1 Bank Building Miami, lorida 331 1 Telep e (305) 57 28 3 By Nor an A. Coll January 8, 1981

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