ML17340A975

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Request for Summary Disposition of Contention 5 Re full-flow Condensate Polishing Demineralizing Sys.No Genuine Issue of Matl Fact Exists.Request Should Be Granted as Matter of Law. Related Correspondence
ML17340A975
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 04/06/1981
From: Coll N
FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML17340A977 List:
References
ISSUANCES-SP, NUDOCS 8104140495
Download: ML17340A975 (4)


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+0~~g UNITED STATES: OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMICSAFETY. AND. LICENSING BO g-g i DOCK+Eg UNtar.

APR 61SSt Oliice of the $ecretarii Docketing & $@yice Branch In the Matter of

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FLORIDA POWER

& LIGHT COMPANY

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(Turkey Point Nuclear Generating

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Units 3 and 4).

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'Docket Nos.

0-0-

50'-251-SP

,(Proposed Amendments to Facili'ty Operating License to Permit Steam Generator Repairs)

LICENSEE'S MOTION FOR

SUMMARY

DISPOSITION OF CONTENTION 5 Pursuant to 10 CFR 52.749, Florida Power.& Light Company

("FPL"'r "Licensee" ) moves for summary.dispos'ition, in its favor, of Contention 5, which provi:des:

In evaluating the steam generator

repair, the followi'ng has not been considered:.

a.

the cost of a full-flow condensate polishing demineralizing system; b.

the effluent release from,a full-flow condensate polish':ng demineralizing system; or c.

.the environmental'egradation caused by a full-flow condensate polishing demi'neraliz-ing system.

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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 facts as to which there is no genuine issue,.

and a memorandum of law in support of this motion are attached.

Respectfully submitted, STEEL HECTOR' DAVIS Co-Counsel for Licensee, Florida Power

& Light Company 1400 Southeast First National Bank Bu'lding Miami, F rida 33131 (305) 57 2863 By o Norman A. Coll Date:

April 2, 1981 cc:

See attached Certificate of Service.

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