ML17340B127

Forwards Util 810417 Answer Supporting NRC 810323 Motion for Summary Disposition of Contention 4A & Fg Flugger & Hh Jabali Joint Affidavit.Svc Copies May Not Have Contained Certificate of Svc.Certificate of Svc Encl

ML17340B127
Person / Time
Site:	Turkey Point
Issue date:	04/20/1981
From:	Coll N STEEL, HECTOR & DAVIS
To:	Luebke E, Mark Miller, Paris O Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8104300451
Download: ML17340B127 (8)

Text

STEEL HECTOR & DAVtS 8 gpR SOUTHEAST FIR5T NATIONAL BANK BUII OING yS t98t a teCISAR MIAMIIFLORIDA 33I3I RE

.CO~ ISS Q IIA TOST TELEX 5l 5758 PLM+KAC~OFf/CE NORMAN A.COLL (305) 577 2863 April 20, 1981 PALM C5 )R PAVKNUK BEACH'LORIDA 33+80 Marshall E. Miller, Esq.

Administrative Judge t Chairman, Atomic Safety & Licensjng Board Panel U.S. Nuclear Regulatory Commission qO~~~O Washington, D.C. 20555 @8~AD' Dr. Emmeth A. Luebke @9~

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Administrative Judge C gC Atomic Safety & Licensing Board Panel

'U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Oscar H. Paris Administrative Judge Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Xn the Matter of Florida Power & Light Company (Turkey Point Nuclear Generating Units Nos. 3 and 4) Docket Nos. 50-250-SP, 50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Re airs)

Dear Members of the Board:

On Friday, April 17, 1981, Licensee filed and served "Licensee's Answer Supporting NRC Staff Motion for Summary Disposition of Contention 4A" with attached affidavit of Frederick G. F3.ugger and H. H. Jabali. Service was made by mail, and additional service was made by delivery .to a courier for the members of the Board and Mr. Goldberg, and by hand-delivery for Mr. Saunders, Mr. Harnage, and Mr. Chonin.

service However, it has come to my attention copies may not have a copy of the that some certificate of of the service attached. gO 7 c

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~Q STEEL HECTOR & DAVIS Marshall E. Miller, Esq.

Dr. Emmeth A. Luebke Dr. Oscar H. Paris April 20, 1981 Page Two Consequently, I am re-serving the entire package herewith, together with the certificate of service indicating when same was originally served on April 17, 1 81.

Resp tfully submit.tt N 0 NAC/jm Enc.

cc.: See Attached, Certificate of Service

I 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 Permit Steam Generator Repairs)

CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of of the foregoing letter of April 20, 1981 to the Board, re-service of Licensee's Answer supporting NRC staff Motion for Summary Disposition of. Contention 4a, Affidavit of Frederick G.

Flugger and H. H. Jabali on Contention 4a, and Certificate of Service for same dated April 17, 1981 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, Esp., Administrative Judge Chairman, Atomic Safety and Licensing. Board Panel <<<<t<<D U.S. Nuclear Regulatory Commission uggPG Washington, D.C. 20555 t g

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• Dr. Emmeth A. Luebke, Administrative Judge ghcao>+

Atomic Safety and Licensing Board Panel q, Q~'gg,rgb U.S. Nuclear Regulatory Commission

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Washington, D.C. 20555

• Dr. Oscar H. Paris, Administrative 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'

II L Harold F. Reis, Esq.

Steven P. Frantz, Esq.

Lowenstein, Newman, Reis & Axelrad 1025 Connecti'cut 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 6 DAVIS Co-counsel for Licensee 1400 Sout east First Nationa Bank Building Miami, F orida 33131 Telepho (305) 577- 6 By orm n A. Coll April 20, 1981

• Additional Service By Hand or Courier

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