ML17340A975

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
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: ML17340A975 ML17340A978 ML17340A979 ML17340A980
References
ISSUANCES-SP, NUDOCS 8104140495
Download: ML17340A975 (4)

Text

~f

+0~~g DOCK+ Eg UNtar.

UNITED STATES: OF AMERICA APR 61SSt >

NUCLEAR REGULATORY COMMISSION Oliice of the $

ecretarii Docketing & $ @yice BEFORE THE ATOMICSAFETY. AND. LICENSING BO Branch g-g i In the Matter of ) 'Docket Nos. 0- 0-

) 50'-251-SP FLORIDA POWER & LIGHT COMPANY )

)

(Turkey Point Nuclear Generating ) ,(Proposed Amendments to Units 3 and 4). ) 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.

g$ .Ir) xD 810 4 1.40't'f5'

p ii .

T 4

• ~

1

(

1

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.

1 pS s(