ML17340B027

Request for Summary Disposition of Contentions 3 & 6 Re Cumulative Offsite Dose & Discharge of Laundry Waste & Coolant Water.Wa Rodger Affidavit Proves There Is No Genuine Issue of Matl Fact.Certificate of Svc Encl

ML17340B027
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 8104220637
Download: ML17340B027 (10)

Text

UNITED STATES OF AMERICA NUCL'EAR REGULATORY COYNISS ION BFFORE THE ATONIC'AFETY AND L'ICENSING BOARD In the .Matter of ) Docket Nos.. 50-250-SP

) 50-251-SP FL'ORIDA POF'E'ER 6 LIGHT'OMPANY )

)

(Turkey Point Nuclear Generating ) (Proposed'mendments to Uni.ts 3 and: 4) ) Facili;ty Operati.'ng License

) to Permit Steam Generator Repairs)

LICENSEE'S MEMORANDUM 'OF LAÃ IN SUPPORT OF'OTION'OR

SUMMARY

DISPOSITION OF CONTENTIONS 3 AND 6 INTRODUCTION Contentions 3 and 6 provide:

Contentions 3 During the course of the repairs proposed by the Licensee, (a) the handling, processing, .storing or discharging of primary coolant or (b) the discharging of laundry waste water is likely to result in the release of radioactive material to unrestrictive 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 radiation releases as a result of all activity at Turkey Point, during with the

.proposed repairs, do not comply 10 CFR Parts 20 and 50.

P Licensee respectfully submits that the Board should grant summary disposition of Contentions 3 and 6 and dismiss them from these proceedings.

The applicable law related to Summary Disposition is set forth in the "Licensee's Memorandum of Law in Support of Motion for Summary Disposition of Contention 5 "April 2, 1981, which is incorporated herein by reference.,

The affidavit of Dr. Walton A. Rodger addresses the matters raised by these contentions.. With respect to Contention 3,. Dr. Rodger's affidavit demonstrates that the estimated dose from the liquid releases (including primary reactor coolant and laundry, waste water) attributable to the steam generator repairs meets the requirements of Section II,, Paragraphs A and D, of Appendix I to 10 CFR Part 50, and that these releases are as low as is reasonably achievable within the meaning of 10 CFR Parts 20 and 50. With respect to Contention 6, Dr. Rodger's affidavit demonstrates that the maximum individual dose from combined liquid and gaseous releases from both the operation of one steam generator unit and the repair of the other meets the requirements of Section II, Paragraphs A, B, C and D of Appendix I to 10 CFR Part 50, and that cumulative offsite radiation releases as a result of all activity at Turkey Point during the repairs comply with 10 CFR Parts 20 and 50.

Therefore, there is no genuine issue as to any material fact with respect to Contentions 3 and 6, and it is respectfully

4>

submitted that summary disposition of these contentions. should be granted in Licensee's favor..

Respectfully submitted, STEEL HECTOR & DAVXS Co-Counsel for Licensee, Florida Power & Light Company 1400 S'outheast First National Bank B u 'lding Miami, F r ida 33'131 (305) 57 -2863 By:

Norman A. Coll Date: April 8, 1981

4i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSON BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docket Nos. 50-250-SP 50-251-SP IN 'THE. MATTER OF' FLORIDA POWER &: LIGHT COMPANY ) (Proposed Amendments to (Turkey Point Nuclear Generating ') Facility Operating Units Nos. 3 and 4 ) License to Permi,t Steam Generator Repairs),

CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of Licensee's Motion f'r .Summary Disposition of Contentions 3 and 6, Affidavi't of Walton A. Rodger on Contentions 3: and 6, Licensee's Statement of Material Facts as to Which There is no Genuine Issue to be Heard (Contentions 3. and 6), and'icensee's Memorandum of Law In; Support of Motion for Summary I

,Disposition of Contentions 3 and 6 were served on the following by deposit in the United States mail, first class,,

properly stamped and addressed', on the date shown below:

• Marshall E. Miller, Esq., Administrative Judge Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washing 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, Admi'nistrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear .Regulatory Commission Washington, D.C. 20555

4> 4~

Mr. Mark P.. Oncavage 12200 S.W. 110th Avenue Miami, Florida 33176 Harold F. Reis, Esq.

Steven P. Frantz, Esq.

Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W.

Washington, D.C., 20036

• 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

• Burt Saunders, Esq.

Assistant Dade County Attorney 1626 Dade County Courthouse Miami, Florida 33130

• Henry,H. Harnage,. Esq.

Peninsula Federal Building 10th Floor 200 S.E'. First Street Miami, Florida 33131.

• Neil Chonin, Esq.

1400 AmeriFirst Building One Southeast Third Avenue Miami, Florida 33131 STEEL HECTOR & DAVIS Co-counsel for Licensee 1400 Southeast First Nation 1 Bank Building Miami, orida 33131 Telepho e (305) 577-2 3 By or a n A. Coll April 8, 1981

• Additional Service By Hand or Courier

4~ Qi