ML17340A974
| ML17340A974 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/06/1981 |
| From: | Coll N FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8104140456 | |
| Download: ML17340A974 (4) | |
Text
à UNITED STATES OF AMERICA NUCLEAR)'EGULATORY COMMISSION'@Q Q~~<
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docket Nos.
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COMPANY
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Generating
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In the Matter of FLORIDA POWER 6 LIGHT (Turkey Point Nuclear and 4)
APR'1 8 198'1'~
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~g5)2j (Proposed Amendments to Facility Operating License to Permit Steam Generator Repairs) 4 &8'/
LICENSEE'S MOTION FOR
SUMMARY
DISPOSITION.OF CONTENTION 7'ursuant to 10 CFR 52.749, Florida Power 6 Light Company
("FPL" or "Licensee" ) moves for summary disposition, in its favor, of Contention 7 which provides:
The SGRR is inadequate because:
- a. it has used the inaccurate figure of
$ 300,000 per day per unit for replacement power costs for reactor outage;
- b. it has failed to provide an analysis for an additional commitment of land resources for the storage of the defective steam gen-
,erators; c.. it has.,failed
.to consider the costs of
,addition of a full-flow condensate demin-eralizer and. of condenser retubing;
- d. it has failed to update costs from December 1977 due to inflation.
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The grounds for this motion are that, as to the matters raised in this contention, there exists no genuine issue of material fact and that Licensee is entitled to a favorable decision as a matter of law,.
.An affidavit, a statement of the material f'acts as to which there is no genuine
- issue,
.and a memorandum of law in.
support of this motion are attached.
Respectfully submitted, STEEL HECTOR 6 'DAVIS Co-Counsel for Licensee, Florida Power 6 Light Company 1400 Southeast First National Bank Bu'lding Miami, Fl rida 33131
(.305) 57, 28'63'y:
Norman A.
o 1
Date:
Apzj 1 6, 1981 cc:
See attached Certi'ficate of Service.,
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