ML17340B022

Request for Summary Disposition of Contentions 3 & 6 Re Cumulative Offsite Radiation Doses & Discharge of Coolant or Laundry Waste Water.No Genuine Issue of Matl Facts Exists

ML17340B022
Person / Time
Site:	Turkey Point
Issue date:	04/08/1981
From:	Coll N FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML17340B023	List: ML17340B022 ML17340B024 ML17340B026 ML17340B027 ML17340B030 ML17340B032
References
ISSUANCES-SP, NUDOCS 8104220619
Download: ML17340B022 (4)

Text

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4'OC!<~Pg g UNITED STA'TES OF AMERICA lC NUCLEAR REGULATORY COMMIS S ION APR13198t ~

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~~>i,wig BEFORE THE ATOMIC SAFETY AND LICENSING BO <wl e ~ C3 LswiCij C5

) Docket Nos. 50-250-SP

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

)

(Turkey Point Nuclear Generating ) (Proposed Amendments to Units 3 and, 4) ) Facility Operating License

) to Permit Steam Generator Repairs) 8 8(

LICENSEE'S MOTION .FOR

SUMMARY

DISPOSITION OF CONTENTIONS 3 AND 6 Pursuant to 10 CFR 52.749, Florida Power & Light Company

("FPL" or "Licensee" ) moves for summary disposition,, in its favor, of Contentions 3 and 6 which provide:

Contention 3 During the course of the repairs proposed by the Licensee, (a) the handling, processing, storing or dischargin of primary coolant or (b) the discharging o laundry waste water is- likely to result in the release of radioactive material to unrestricted areas in quantities which will not be as, low as is reasonably achievable within the meaning of 10 CFR Parts 20 and 50.

Contention 6 - The cumulative offsite 2'he radiate.on releases as a result of all activity at Turkey Point, during the proposed repairs, do not comply with 10 CFR Parts 20 and 50.

grounds for this motion are that, as to the matters raised in these contentions, there exists no genuine issue of 810422'(n!3:4

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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 6 DAVXS Co-Counsel for Licensee, Flori:da Power 6 Light Company 1400 Southeast First National Bank Bui'1 ing Miami, Flo 'da 33131 (305) 577- 863 By:;

Norman A.. Coll Date:. Apr3.1 8, 1981 cc: See attached Certificate of Service.

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