ML17340B141

Affidavit That Intervenor Site Insp Will Be Conducted on 810418 & Response Due on 810428.Certificate of Svc Encl. Related Correspondence

ML17340B141
Person / Time
Site:	Turkey Point
Issue date:	04/15/1981
From:	Chonin N CHONIN, N., ONCAVAGE, M.
To:
Shared Package
ML17340B137	List: ML17340B136 ML17340B138 ML17340B140 ML17340B141
References
ISSUANCES-SP, NUDOCS 8105040474
Download: ML17340B141 (8)

Text

UNITED STATES OF AtKRICA NUCLEAR REGULATORY COMMISSION 6- APR g p

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BEFORE THE ATOMIC 'SAFETY AND LICENSING BOARD >@ncft Xn the Hatter of Docket Nos.: 50-250-SP 50-251-SP FLORIDA POWER AND LIGHT COMPANY (Proposed Amendments to Facility Operating License to Permit (Turkey Point Nuclear Generating Steam Generator Repairs)

Units Nos.: 3 and 4)

AFFIDAVIT OF NEIL CHONIN I, Neil Chonin, being duly sworn, state as'ollows:

1. That on April..::10, 1981, Licensee served Notions for Summary Disposition o f Contentions 3, 6, and 8 on Intervenor .

2. That attached to these Motions were the following Affidavits:

1 ~ Contention 8 A. Affidavit of Harvey Story

2. Contention 3 and 6 A. Affidavit of Walter A. Roger

3. That the Staff on March 26, 1981, served a Motion for Summary Disposition of Contentions 2 and 6 on the Intervenor. The Board by an Order dated April 7, 1981, gave the Intervenor. until 10 days from the Site Xnspection to respond.

4. That the Intervenor will be conducting his site inspection on April 18, 1981, making a response due on April 28, 1981, (unless samples exceed the limits of 10 CFR Part 30 and the technical specification of FPL OL. And than the time to respond will be 10 days after receipt of the laboratory results).

5. That on April 14, 1981, the Intervenor served a Request for Production on the Licensee a copy of- which is .attached.

6. That on April 15, 3.981, the Intervenor served a Request'or Production on the Staff'and the licensee, copies of,which are attached.

7. That the Intervenors time to respond,.to the Motions fox Summary Disposition prevents the Xntervenor from, completing its discovery and it would be manifestly unjust to provide a cut off date of discovery,=-of

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April 15th and a Summary Disposition response cut- off prior to the time discovery is completed.

DATED THIS 15th day of April, 1981.

NEIL HONIN SHOR'.0 TO AND SUBSCRIBED before me,this 15th day of April, 1981.

4 l 0; NOTA~. PUBLIC, State o F orida at Large I'fy commission expires:

NOl Af.> PU5UC STATE OF 'Fl.Ot.lOA AT l.~f M O'lM ON EXPi M MAT . 33 l V 63

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSXNG BOARD Xn the Matter of Docket Nos 50-250-SP 50-251-SP FLORIDA POWER AND LIGHT COMPANY (Proposed Amendments to Facility Opexating License to Permit (Turkey Point Nuclear Generating Steam Generator Repairs)

Units Nos.: 3 and 4)

CERTIFXCATE'F SERVICE I HEREBY CERTXFY that copies of the Intervenor s 'Motion to Continue or Deny Summary Disposition; Requests to." Produce to both the Staff and the Licenssee 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 Regulatoxy Commission's internal mail system, this 15th day of April, 1981.

Maxshall E. Miller, Esq. Administrative Judge Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Emmeth A. Luebke, Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555

.Dx. 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. Fxantz, 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

Oi Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DE C. 20555 Docketing and Service Section Office of the Secretary V. S. Nuclear Regulatory Commission Washington, D. C. 20555 Burt Saunders,, Esq.

Assistant Dade County Attorney 1626 Dade County Courthouse Hiami, FLorida 33130 Henry H. Harnage, Esq.

Peninsula Federal Building 10th Floor 200 S. E. 1st Street Miami, Florida 33131 Norman A. Coll, Esq.

STEEL, HECTOR & DAVIS Co-Counsel for Licensee 1400 S. E. 1st National Bank Bldg.

Miami, Florida 33131 NEj:L CHONXN Counsel fox intervenor

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