ML17340B034
| ML17340B034 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/14/1981 |
| From: | Chonin N CHONIN, N., ONCAVAGE, M. |
| To: | FLORIDA POWER & LIGHT CO. |
| References | |
| ISSUANCES-SP, NUDOCS 8104230208 | |
| Download: ML17340B034 (8) | |
Text
bOCKBTPb gpss g 6 1987 i Glg LQI gpss BELATED COPiPJ.
iDZNCB THE ATOMIC SAFETY AND LICENSING BOARD C
g UNITED STATES 'OF A~RICA P+ ~~g4+
t NUCLEAR REGULATORY COMMISSION g.S C+
C
. In the Matter of FLORIDA POWER AND LIGHT COMPANY Docket Nos.
50-250-SP 50-(51-SP (Proposed Amendments to Facility (Turkey Point Nuclear Generating Operating License to Permit Units Nos.
3 and 4);
Steam Generator Repairs)
INTERVENOR MARK, P.
ONCAVAGE'S REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM LICENSEE, FLORIDA POWER AND LIGHT COMPANY Intervenor, by his undersigned attorney, in accordance with the applicable rules of 10 CER 2.740 and 2.741.,
requests the Licensee to
- produce within thirty (30) days, at the office of the attorney for
'the Intervenor:
1; All documents in possession,
- custody, or control of Licensee that outline Licensee's time schedule for the projected. repairs on the, steam generators.
Such schedule would contain the dates of each step of the repairs and list the c~ticaltime fr'arne for each task from
'start to completion.
2.
Westinghouse Report g ST Res FJF 30/30, containing material on corrosion product activity which the Licensee used to calculate offsite airborne doses to the public.
P 3.
Document mentioned at Homestead NCR Hearing on September 17,
- 1980, concerning grit blasting.
4.
Document mentioned at Homestead NCR Hearing on September 17, 1980; "Proceedings of AMerican Power Conference 1971, Decontamination of Sena in Brussels," which Licensee used to calculate offsite dose from decontamination processes.
5.
The examination results of all personnel who will be involved in the repair and who have obtained unescorted access badges and/or waivers referred to in pages 8 and 9 of the Affidavit of Harvey F.
Story.
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Xhe Intervenor has a substantial need for the requested documents and cannot obtain them elsewhere with'out undue hardship.
Request No.
1 (work. schedule) is relevant to contention 4A and 4B and is needed to demonstrate the exposure of radioactive material to a hurricane prone environment during the various stages of the steam generator repair.
Documents Nos.
2, 3, 4, and 5 are relevant to contentions 1,2, and 6.
They are needed to identify the constituents of the grit blasting
.process which has been recently proposed by the Licensee.
The airborne radioactivity impacts on public exposure (contentions 1), worker ingested exposure
('ontention.2),
and offsite releases (contention 6).
Dated this 14th day of April, 1981.
LAW OFFICES'F NEIL CHONIN, P,.A.
Attorney for Intervenor 1400 AmeriFirst Building 1 S.E.
3rd Avenue Miami, FL 33131 Phone:
377-3023 BY:
.LC N
41
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RELATED CO SPOXDE'VCB UNITED STA'ZES OF AMERICA NUCLEAR REGULATORY COESiISSION In the Matter of FLORIDA POWER -AND LIGHT COMPANY
(
I1~( gp BEFORE'HE 'ATOMIC SAFETY AND LICENSING 'BOAR) 8 g 8 1g81, Docket Nos.
50-250
-< I f l~>
50g251 (Turkey Point Nuclear Generating Unit Nos.
3 and 4).
- (Proposed Amendments to Facility Operating Licenses to Permit Steam Generatore Repair)
CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of INZERVENOR'SREQUEST FOR PRODUCTION in the above-.captioned proceeding have, been served on.the following by deposit in the United States mail, first. class or, as indicated by an asterisk,
~
through deposit in the Nuclear Regulatory'ommission's internal mail system, this 14th day of April, 1981.
Marshall E. Miller, Esq. Administrative Judge
-;,:,: Chairman, Atomic Safety and Licensing Board Panel
". U:S. Nuclear Regulatory'ommission
' Washington,'.
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, Adminstrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.
C, 20555 Mr. Mark P.
Oncavage 12200 S.
W. 110th Avenue Miami, Florida 33176 Harold F. Reis, Esq.
Steven P. Frantz, Esq.
Lowenstein,
- Newman, Reis.6 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
%If S
Atomic Safety and Licensing Board Panel U.-S. Nuclear Regulatory Commission
'ashington, 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 1'626 Dade County Courthouse Miami, FLorida 33130 Henry H; Harnage, Esq.
Peninsula Federal Bui;lding 10th Floor 200 S.
E. 1st Street Miami, Florida 33131 Norman A. Coll, Esq.
,STEEL, HECTOR 6c DAVIS Co-Counsel for Licensee 1400 S.. E. 1st National Bank Bldg.
~ 'Miami,.Florida.
33131 IL CHONIN Counsel for.Intervenor
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