ML17341A288
| ML17341A288 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point  |
| Issue date: | 05/05/1981 |
| From: | Reis H FLORIDA POWER & LIGHT CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML17341A290 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8107060170 | |
| Download: ML17341A288 (4) | |
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5 In the Matter of FLORIDA POWER 6 LIGHT COMPANY Docket Nos.
50-250-SP 50-251-SP (Proposed Amendments to Facility Operating Licenses to Permit Steam Generator Repair)
(Turkey Point Nuclear Generating Unit Nos.
3 and 4)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD LICENSEE'S MSPONSE IN SUPPORT OF NRC STAFF MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 4B On April 27, 1981, the NRC Staff filed a document entitled "NRC Staff Objections to Proposed Amended Contention 1 and Third Motion for Summary Disposition," urging the summary disposition of Contentions 1 and 4B.
On April 30, 1981, Florida Power
& Light Company (FPL or Licensee) filed a response supporting the dismissal of Contention 1.
FPL now files its response in support of the motion for summary disposition of Contention 4B.
I FPL has examined the motion, filed.hy the NRC Staff and the supporting affidavit of Robert F. Abbey, Jr.
FPL herewith submits an additional affidavit of Frederick G. Flugger< Habib H. Jabali and Ping K.
Wan which provides further support for the summary dispo-sition of Contention 4B.
The affidavit attached hereto is consistent, with the Abbey affidavit and provides further support for paragraphs numbered 7 through 12 of the Staff's "Statement of Material Facts as to Which There Are No Genuine Issues to be pQo5 r
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Consequently, FPL agrees that there is no genuine issue as to the material facts concerning Contention 4B and submits that the contention should be dismissed.
FPL notes that the Staff Statement of Material Facts states, among other things, that:
7.
The proposed repair schedule does not substantially coincide with the historical hurricane season in southeastern Florida and the chance of a tornado occurrence is remote.
The affidavit attached hereto supports that statement.
- However, consistent with paragraphs numbered 8 through 12 of the Staff's Statement of Material Facts, the attached affidavit, also emphasizes that the repair schedule should not be based on the timing of the hurricane season or the low probability of the occurrence of tornadoes since "ft]hese severe meteorological events in no wav alter the acceptability of the proposed repair activity."
(p. 10)-
Respectfully submitted, Date:
May 5, 1981 Harold F. Reis Steven P. Frantz LOWENSTEINg NEWMAN'EIS 6 AXELRAD 1025 Connecticut Ave., N.W.
Washington, D.C.
20036 Telephone:
(202) 862-8400
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The affidavit attached hereto refers to two studies Copies of the studies are also attached.
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