ML20006C510
| ML20006C510 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/16/1990 |
| From: | Patricia Jehle NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20006C496 | List: |
| References | |
| OLA-5, NUDOCS 9002080150 | |
| Download: ML20006C510 (19) | |
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DOChl1ED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS$10N gggg BEFORE.TWE COMMISSION croct0; ncat34py 00CKCimG A 5!i<uci In the Matter of UhANC" Docket No. 50-250 FLORIDA POWER AND LIGHT 50-251 COMPANY (Turkey Point Plant, Units 3 and 4)
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i NRC STAFF RESPONSE TO REQUEST FOR HEARING AND PETITION FOR LEAVE TO INTERVENE OF NUCLEAR ENERGY ACCOUNTABILITY PROJECT AND THOMAS J. SAPORITO, JR.
Patricia Jehle Counsel for NRC Staff January 16, 1990 Ok20[3ffCKbo 900;pp onoogpgg G
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS$1DN j
BEFORI.TNE CONNIS$10N l
1 In the Matter of Docket No. 50-250 l
FLORIDA POWER AND LIGHT 50-251 l
COMPANY t
(Turkey Point Plant, Units 3 and 4) 1 l
i NRC STAFF RESPONSE TO REQUEST FOR HEARING AND i
PETITION FOR LEAVE TO INTERVENE OF NUCLEAR ENERGY ACCOUNTABILITY PROJECT AND THOMAS J. SAPORIT0, JR.
3 4
i Patricia Jehle Counsel for NRC Staff 4
January 16, 1990
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TABLE OF CONTENTS i
1 I.121 1
TABLE OF AUTHORITIES 11
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l I.
INTRODUCTION 1
II. BACKGROUND 2
III. ARGUMENT 3
)
A.
Standards for Intervention 3
B.
Mr. Saporito and NEAP have not met the interest and injury-in-fact requirements i
of 10 C.F.R. I 2.714 of the Commission's i
rules and regulations 6
C.
Petitioners have not satisfied the aspect.
I requirement of 10 C.F.R. I 2.714 of the Commission's rules and regulations 9
11 I
IV. CONCLUSION j
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TABLE.0F AUTHORITIES l
?.191 COURT. CASES:
Dellumsv.NRC,863F.2d968(D.C.Cir.1988) 4 ADMINISTRATIVE. DECISIONS:
)
BostonEdisonCo.(PilgrimNuclearPowerStation)3
)
LBP-55-z4,zzNRC97(1985) 4, 5 BostonEdisonCo.(PilgrimNuclearPowerStation),
ALAB-Ble, 22 NRC 461 (1985) 5 I
Consolidated Edison.Co ofNew. York (IndianPoint, Unit z) and Power Au".nority of the. State of.New l
York (Indian Point Unit 3), L5P-5z-25 U RC 715 (1982),......................................
6 Detroit. Edison Co. (Enrico Fermi Atomic Power Plant, Unitz),L5P-78-11,7NRC381(1978)
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l Detroit. Edison Co. (Enrico Fermi Atomic Power Plant, Unit z), ALA5-470, 7 NRC 473 (1978) 5 Ducuesne Light Co. (Beaver Valley (1984)
Power Station, Lnit z),1.5P-84-6, 19 NRC 393 6, 9 Florida. Power and. Light Co. (St. Lucie Nuclear Power Plant, Un1t z), L5P-57-z, 25 NRC 32 (1987) 3 Houston Lightinro and Power.co.- (South Texas Project, UnitsIancz,,L5P-79-IU,9NRC439(1979) 4,5,8 Long Island Lighting Co. (Shoreham Nuclear Power
' statton, Unit 1), L5P-77-11, 5 NRC 481 (1977) 6 Niagra. Mohawk Power.cor). (NineMilePointNuclear station,Unitz,L5P-33-45,18NRC213(1983) 4, 7 Nuclear Ent'ineering.Co...Inc. (Sheffield, Illinois
~i.ow-Leve Rac1oactivewasteDisposalSite),
ALAB-473,7NRC737(1978) 4, 8 Philadelphia Electric Co. (Limerick Generating station, Units I and z), LBP-82-43A, 15 NRC 1423 (1982) 4
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1 ADMINISTRATIVE DECISIONS.(CONTINVED):
1 M
j Portland General Electric Co.-(Pebble Springs Nuclear Plant, Units 1 and 2), CLI-76-27, 4 NRC 610 (1976) 3.-4, 7 Pucet Sound Power and. Light.Co. (Skagit/Hanford Puclesr Project ) Units I and 2), LBP-82-74, 16 NRC 981 (1982 6
Vermont Yankee Nuclear Power. corp. (Vermont Yankee J
Nuclear Power Station), LUP-87-7, 25 NRC 116 (1987) 5, 6 1
Virginia-Electric.and Power.Co. (North Anna Nuclear Power Station, Units I and 2J. ALAB-522, 9NRC54(1979) 5 REGULATIONS:
i 10 C.F.R. 9 2.713(b) 5, 6 1
10 C.F.R. l 2.714 2,3,8 1
10 C.F.R. 6 2.714(a)(2) l 3,-9,-10, 11 10C.F.R.52.714(b)(1) 3.
10 C.F.R. 5 2.714(b)(2) 9.
10 C.F.R. 5 50.57 9
10C.F.R.650.58(b)(6) 10 10 C.F.R. I 50.59
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10, 111 5
10 C.F.R. 9 50.91 10 L
10 C.F.R. i 50.92 10 10C.F.R.650.92(c) 9 MISCELLANEOUS:
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" Florida Power and Light Co., Consideration of Issuance of Amendments to Facility Operating Licenses and Opportunity for Hearing}"
54 Fed. Ry. 50295 (December 5, 1989 1, 2 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION I
In the Matter of Docket No. 50-250 FLORIDA POWER AND LIGHT 50-251
-COMPANY (Turkey Point Plant, Units 3 and 4)-
1 NRC STAFF RESPONSE TO REQUEST FOR HEARING AND-PETITION FOR LEAVE TO INTERVENE OF' NUCLEAR ENERGY ACCOUNTABILITY PROJECT--AND. THOMAS.J.;SAPORITO.,JR.
1.
INTRODUCTION i
On December 27. 1989, Mr. Thomas J. Saporito, Jr. filed a request for a hearing and petition for leave to intervene on his own behalf and on behalf of the Nuclear Energy Accountability Project (NEAP).
" Request for Hearing and Petition for Leave to Intervene,"'(December 27, 1989)
(hereinafterPetition). The Petition is in response:to a notice published in the Federal Register on December 5,1989, announcing the proposed issuance of amendments to the Technical Specifications for Turkey Point, Units 3 and 4.
" Florida Power and Light Co., Consideration of Issuance of Amendments to Facility Operating Licenses and Opportunity for Hearing,"
54 Qd. g. 50295 (December 5,1989). The proposed amendments to Turkey:
Point Units 3 and 4 would replace the current Technical Specifications I
L with a set of Technical Specifications based on the Westinghouse Standard i
Technical Specifications. M.
For the reasons set forth below, the Petitioa filed on behalf of NEAP and Mr. Saporito-(hereinafter Petitioners) 4
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does not meet the interest and aspect requirements of 10 C.F.R. I 2.714 of the Counission's regulations. Accordingly, the request of these Petitioners for a hearing and their petition for-leave to intervene should be denied.
II. BACKGROUND On December 5,1989, tr.e Comission published a Notice of Proposed t
i Issuance of Amendments for the Turkey Point Units 3 and 4 licenses in the L
Federal Register. 54 Fed. Reg.50295(December 5,1989). The proposed j.
amendments would replace the Technical Specifications for both units with changes based on the Westinghouse Standard Technical Specifications.
These amendments are being considered as'part of the NRC and-industry 1
program to standardize and improve technical specifications. M.
i The proposed changes to the Turkey Point Technical Specifications can be grouped into four categories. M. The largest group includes non-technical changes, which involve editorial and typographical changes which are intended to make the Technical Specifications easier to use for plant operations personnel. The second category consists of chances involving more stringent Technical Specifications which provide enhanced safety. Other changes involve the removal of selected requirements from the Technical Specifications and the relocation of the requirements into other controlled documents. The final group of changes provides for the j
relaxation of existing requirements which, based upon operating experience, have been shown to provide little or no safety benefit and r
which place a burden on.the licensee.
On December 27, 1989, Thomas J. Saporito filed a timely request for a hearing and petition for leave to intervene on-his behalf as an
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3 individual and on behalf of NEAP as an organization. Petition at 1 and 3 III. ARGUMENT 4
A.
Standards for Intervention A person seeking ~ to intervene in a Commission proceeding must satisfy the requirements of 10 C.F.R. I 2.714 A petition for leave to intervene must set forth with particularity the petitioner's interest in the proceeding and how the interest will be affec'ted by the results of the proceeding.
10 C.F.R. 5 2.714(a)(2). A petition must state the' reasons petitioner should be allowed to intervene and the specific aspects of the subject-matter of the proceeding as to which petitioner wants to inter-I
- 3. The burden of meeting these requirements is on the petitioner.
vene.
Florida Power and. Light Co.-(St. Lucie Nuclear Power Plant, Unit 2),.
LBP-87-2,25NRC32,34-35(1987). A petitioner must address the criteria j
of 10 C.F.R. 9 2.714(d)(1). These criteria are:
(1) The nature of_the petitioner's right under the Act to be made'a.
party to-the proceeding.
(2) The nature and extent of the petitioner _'s property, financial, or other interest in the proceeding.
(3) The possible effect of any order which may be entered in the proceeding on the petitioner's interest.
1 The petition also must set forth at least one valid contention and its i
supporting bases, although this requirement need not be met when the i
I petition is first filed.
j,ee,10C.F.R.i2.714(b)(1).
e Judicial concepts of standing are used to determine whether a petitioner has sufficient interest to intervene in a proceeding.
Portland General Electric Co. (Pebble Springs Nuclear Plant, Units 1 and 2), CLI-76-27, 4 NRC 610 (1976). To establish standing to intervene
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the petitioner must show that the action. sought in the proceeding will cause an injury in fact, and that the injury-is within the zone of interest protected by the Atomic Energy Act of 1954, as amended or the i
National Environmental Policy Act. M. at 613-614; Niagra Mohawk Power Corp. (Nine Mile Point Nuclear Station, Unit 2), LBP-83-45,18 NRC 213, 215(1983). Inaddition,thepetitionermustestablish(a)thathe personally has suffered or will suffer a distinct and palpable harm that constitutes an injury in fact (b) that the injury can be traced to the
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challenged action, and (c) that the injury is likely to be remedied by a favorable decision. Dellums v..NRC, 863 F.2d 968, 971 (D.C. Cir.1988);.
jee Nuclear. Engineering Co., Inc. (Sheffield, Illinois Low-Level Radioactive.
Waste Disposal Site), ALAB-473, 7 NRC 737, 743 (1978). A petitioner also must have a "real stake" in the outcome of the proceeding to establish injury in fact for standing. HoustonLighting.and.PowerCo.-(SouthTexas Project, Units 1 and 2), LBP-79-10, 9 NRC 439, 447-448 (1979). A petitioner's-stake need not be a substantial one, but merely direct or genuine. g. at 448.
An alleged injury to the health and safety of a petitioner residing I
near a reactor has been found to be sufficient to establish standing to l
intervene. Philadelphia Electric Co. (Limerick Generating Station, Units 1 and2),LBP-82-43A,15NRC1423,1434-1435(1982). A petitioner may base standing upon a showing that his.or her residence is within the-geographical zone which could be affected by a nuclear. accident. South
_ Texas, supra, 9 NRC at 443-444. Residence within 6 50-mile radius of a
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nuclear power plant, however, is not always sufficient.to establish standing to intervene. Boston. Edison.Co.
(PilgrimNuclearPower
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t Station), t.BP-85-24, 22 NRC 97, 98-99, aff'd.on.other grounds, ALAB-816,
.j 22NRC461(1985). The nature of the proceeding will be considered by a-Board in a determination of standing to intervene'and a Board will apply a different standard in proceedings which involve construction permits and I
operating licenses than in license amendment proceedings. J,dj d
A petitioner residing nea~r a reactor is not required to establish a causal relationship, well-founded in fact, between an immediate or threatened injury and the action at issue in the proceeding; although the petitioner'.should-link the harm to the proposed action. Virginia Electric and Power Co.--(North Anna NuclearPowerStation, Units 1and2),'ALAB-522,9NRC54,;57n.5(1979).
I A petitioner may not assert the rights of third parties as a basis for.
i intervention. Detroit Edison Co.-(Enrico Fermi Atomic Power Plant.
Unit 2), LBP-78-11, 7 NRC 381, 387, aff'd,ALA8-470,7NRC'473-(1978);
$ 10 C.F.R. 5 2.713(b).
p An organization may establish standing through the interest of its j
members or on its own. VermontYankee.NuclearPowerCorp.'(VermontYankee i
NuclearPowerStation),LBP-87-7,25NRC.116,.118(1987). An organization must have a "real stake" in the outcome of the proceeding, and show an injury in fact within the protected zone of interest. South Texas, supra, 9 NRC at 447. An organization may meet the injury in fact-test in two it may (1) show an injury to its' organizational interest, or (2) ways:
allege its members are suffering an immediate or threatened injury duelto the challenged action. Vermont Yankee, supra, 25 NRC.at 118. An i
organization cannot establish independent standing to intervene in a licensing proceeding merely by asserting it has an interest in a i
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proceeding. Puget Sound. Power and. Light Co. (Skagit/Hanford Nuclear Power Project, Units 1 and 2), LBP-82-74, 16 NRC 981, 983 (1982).
When an organization establishes standing.through the interest of its members, the name and address of at least one affected member, who wishes to be represented by the organization, must be provided.. Vermont. Yankee, supra, 25 NRC at 118-113. An affidavit should be submitted which indicates that the menber wants the organization to serve his or her interests-in a representative capacity. Duquesne. Light Co. (Beaver Valley Power Station, Unit 2), LBP-84-6, 19 NRC 393, 411 (1984). An organization-has standing to intervene when its petition is' signed by an officer of the j
organization who has the' required personal interest for intervention.
l Consolidated Edison Co. of New York (Indian' Point, Unit No. 2) and I
Power Authority of the. State of New York (IndianPoint,UnitNo'.3),
LBP-82-25,15 NRC 715, 728-729, 734-736 (1982). The Commission's regulations do not permit the organization to represent the interests of persons who are not members. Long Island Lightire) Co.(ShorehamNuclear PowerStation, Unit 1),LBP-77-11,5NRC481,483(1977);jee 10C.F.R.52.713(b).
B.
Mr. Saporito and NEAP have not met the interest.and-l-
injury in fact requirements of 10 C.F.R. 5 2.714 of L
the Commission!s regulations.
Mr. Saporito has requested intervention as an individual in this proceeding. ' As discussed in Section A above, in order for an individual
'l to demonstrate that he or she has an interest which may be affected by the outcome of the proceeding;in question, that individual must show an injury l
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in fact, and that 1njury must fall within.the. zone of interest protected by the Atomic Energy Act cr the National Environmental Policy Act.
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Pebble Springs, supra, 4 NRC at 612 613; Nine Mile Point, supra, 18 NRC at 215. The Petitioner has not established the requisite interest or injury in fact to gain standing to intervene in this license amendment proceeding.
It is not clear from the Petition whether Mr. Saporito's contact with the Miami area is sufficient to establish the requisite interest to support standing. Mr. Saporito's. statements in the Petition regarding his regular place of employment are inconsistent with other statements made in the Petition. Mr. Saporito states that he acts as the executive director:
of NEAP, which is headquartered in Jupiter, Florida, approximately 100 miles from the Turkey Point plant. Petition at 1.
The Petitioner also.
alleges that he works "in and about the City of Miami" five or six days a j
week in his capacities as an instructor:and as a researcher for NEAP.
Petition at 3. - Mr. Saporito has not established thAt his nonna1, everyday work activities are conducted at specific locations in the Miami area or-i in the vicinity of the Turkey Point plant.
He resides in Jupiter, Florida. Without more, the visits to the Miami area alleged by:the Petitioner would not be sufficient to demonstrate that his health and safety could be affected by the amendments at issue.
Mr. Saporito has not stated an interest which will be affected by the outcome of the proceeding, nor has he alleged an injury which would fall within the zone of interest protected by the Atomic Energy Act. Mr.
Saporito has failed to provide sufficient information to show that he has regular contacts within a 50-mile radius of the Turkey Point plant. -The evidence of his contacts with the Miami area provided by Mr. Saporito is.
not sufficient to establish standing to-intervene.
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s In addition, Mr. Saporito has failed to allege an injury in fact that would result from the proposed licensing action. He has failed to set j
forth an injury which is in any way connected to the action at issue. The Petitioner has failed to meet the requirements of 10 C.F.R. f 2.714 to
. gain individual standing to intervene in this license amendment proceeding.
The Petition also' requests intervention on behalf of NEAP, Petition at 1-3.
As discussed in Section A above, an organization may establish standing on its own or it may derive its standing from a member who l
possesses individual standing to intervene. South Texas, supra, 9 NRC at l
646. NEAP is an organization with its principal place of business in Jupiter, Florida,-which is approximately 100 miles from the Turkey Point plant. Thus, NEAP has not established an interest which could be affected-l by the outcome of the proceeding.
Furthermore, NEAP's general claim that is has'an interest in environmental issues does not serve as a basis for i
establishing standing to intervene in this proceeding, because mere interest in a problem is not enough to establish an injury in' fact. See j
Nuclear. Engineering.Co., supra, 7 NRC at 742. Mr. Saporito.is executive -
director of NEAP.
Petition at 1.
Since Mr. Saporito's standing has not j
been established, NEAP does not derive standing through him.
The names of four persons are listed in the Petition.
Petition at 2.
L However, the Petitioners have not.provided an executed affidavit which a
establishes the standing to intervene of at least one NEAP member.- A J
Statement for Permission to Represent signed by Ms. Astrid Weinkle has been submitted by the Petitioners. Ms. Weinkle's statement, in the form of a letter, does not cure NEAP's failure to establish the requisite l
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protected interests and injury in fact for standing. Although it appears Ms. Weinkle lives within 50 miles of the facility and would have the requisite interest she has not stated-her. relationship.to NEAP. An affidavit executed by a NEAP member with the requisite standing which
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authorizes NEAP to serve his or her interests in a representational capacity is required.
See Beaver Valley, supra, 19-NRC at-411.
e C..
Petitioners have not satisfied the aspect requirements of 10 C.F.R.
s i 2.714 of the-Connission!s regulations-.
The Petitioners have not set forth an issue or aspect in the Petition -
which satisfies the requirements of 10 C.F.R. I 2.714(a)(2). As is discussed below, the issues raised lack the requisite specificity or are outside the scope of the license amendments. The Staff considers the issues raised by the Petitioners to be aspects rather than contentions.
The issues set forth in the Petition also fail to meet the: requirements of~
10C.F.R.I2.714(b)(2)forvalidandlitigablecontentions.
Paragraphs 5(a), (b). and (c) of the Petition. recite ~ 1anguage from 10 C.F.R. 6 50.57 of the Commission's regulations concerning the issuance of operating licenses and make the claim that the proposed amendments will not meet the regulatory requirements. Herely quoting regulatory' language and asserting non-compliance does'not provide sufficient information to apprise the Staff as to the aspect the Petitioners wish to pursue. These issues do not raise specific aspects'related to the proposed license amendments. Therefore, paragraphs 5(a)', (b) and (c) do not meet-the aspect requirements of 10 C.F.R. 5 2.714(a)(2).
Paragraphs 5(d), (e) and (f) paraphase the criteria for a no significanthazardsconsiderationsetforthin10C.F.R.6.50.92(c)ofthe Commission's regulations dealing with the issuance of license amendments.-
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1 Paragraph 6(a) asserts that the proposed license amendments involve a significant hazards consideration. The Staff has not yet taken a position l
on whether or not the proposed amendments involve a no significant hazards consideration.
If the Staff makes a no significant hazards i
consideration finding, detemination will not be subject.to challenge and will not be an-issue for the Atomic Safety and Licensing Board to decide.
10C.F.R.il50.92,50.91and50.58(b)(6).
Paragraph 6(b) alleges that the' proposed technical specifications changes would increase the probability and consequences of a major accident because of shared safety systems and the age of the units at the Turkey Point plant. Petition at 4-5.
The allegation does not establish how the proposed amendments relate to the fact that there are shared l
safety systems at the Turkey Point plant.
This situation,' as the Petition acknowledges, existed prior to the proposed amendments. Furthermore,.the j
issue of the age of the. plant is outside the scope of the proposed amendments..
The allegations establish no connection with the issues at hand in the l
proposed. licensing action and'it does not meet the aspect requirements of 10C.F.R.92.714(a)(2).
Paragraph 6(c) states that the amendments willl remove selected.
requirements which are currently in the Technical Specifications and relocate the in other controlled documents.
The Petitioners complain.
j that the relocation will permit the Licensee to make changes in the I
relocated requirements pursuant to 10 C.F.R. 9 50.59.
Petitioners also
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l complain that the approval of the Staff to make changes is not required under 10 C.F.R. ' 9 50.59. The Petitioners have failed to' raise a litigable' issue as the question of whether the Licensee should'be allowed'to utilize.
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l 10 C.F.R. I 50.59 is not within the--scope of the amendments.
In paragraph
.6(c)Petitionersalsoassertthattheproposedamendmentswouldincrease the probability and consequences of a major nuclear accident because the l
L Turkey Point plant is of an "out-dated design." This assertion is outside the scope of the proposed amendments. Paragraph _6(c) of the Petition does L
notidentifyaspecificaspectwhichsatisfies10C.F.R.I2.714(a)(2).
The Petitioners make several other allegations which are outside the i
scope of the proposed licensing action. Paragraph 6(d)concernsthe operator training program at the Turkey Point plant, 6(e) concerns the-operating history of the Turkey Point plant, and paragraph 7 concerns the l'
operation of the plant outside its Technical Specifications and design basis. The license amendments at issue are unrelated to any of these issues and, therefore, the Petitioners do not satisfy the aspect requirements of 10 C.F.R. 5 2.714(a)(2) of _ the Comission's regulations.
I The Petitioners have not raised issues which satisfy the aspect d
.i requirementsof10C.F.R.2.714(a)(2)oftheCommission'sregulations..
f IV. CONCLUSION i
1 For the reasons set forth'abote, the Petition of Thomas J. Saporito, j
Jr. and the Nuclear Energy Accountability Project should be' denied.
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Respectfully. submitted.
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$4, /
- l Counsel for NRC Staff Dated at Rockville, Maryland this 16th, day of January, 1990.
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UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION BEFORE -THE C0fP!ISSION
- 1 In the Matter of Docket lio. 50-250-FLORIDA POWER AND LIGHT 50-251 COMPANY (Turkey Point Plant, Units 3 and 4)
NOTICE OF APPEARANCE Notice'is hereby given that the undersigned attorney enters an-appearanceintheabove-captionedmatter..Inaccordancewith52.713(b),
10 C.F.R., Part 2, the following information is provided:
Name:
Patricit A. Jehle i
Address:
U.S. Nuclear Regulatory Comission.
Office of the General Counsel l
Washington, D.C.
20555 Telephone humber:
(301)492-1535 l-M missions:
Supreme Court of. Pennsylvania-Name of Party:.
NRC Staff-Respectfully submitted, -
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Patricia A. ilehle Counsel for NRC Staff.
Dated at Rockville, Maryland this 16th day of January,1990.
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'1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION' BEFORE THE COMMISSION In the Matter of-Docket No. 50-250~
FLORIDA POWER AND LIGHT 50-251 COMPANY (Turkey Point Plant,-Units 3 and 4)
-NOTICE OF APPEARANCE Notice is hereby given that.the undersigned attorney enters an appearance in the above-captioned matter.
Inaccordancewith6~2.713(b),
10 C.F.R., Part 2, the following information is provided:
Name:
Janice E. Moore-Address:
U.S. Nuclear RegulatoryLCommission Office of the General Counsel Washington, D.C.-
20555 Telephone Number:
(301)492-1580 Admissions:
District of Columbia Court of Appeals
[
Name of Party:
NRC Staff 3
Respectfully. submitted,.
Janice E. Moore
' Counsel for.NRC Staff Dated at Rock,'ille, Maryland this 16th day of January,1990.
4 s
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION Y
In the Matter of Docket No. 50-250 FLORIDA POWER AND LIGHT 50-251 COMPANY (TurkeyPointPlant, Units 3and4) e CERTIFICATE OF. SERVICE 1
I hereby certify. that copies of "NRC STAFF RESPONSE TO REQUEST FOR-HEARING AND PETITION FOR LEAVE TO INTERVENE OF THOMAS J. SAPORITO, JR..AND' THE NUCLEAR ENERGY ACCOUNTABILITY PROJECT" and " NOTICE OF APPEARANCES" for-Patricia A. Jehle and for Janice E. Moore 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 Comission's internal mail system, this 16th day -
p of January, 1990.
Steven P. Frantz, Esq.
Atomic Safety and Licensing Board Harold F. ; sis, Esq.
Panel (1) i l
Newman'& Holtzinger U.S. Nuclear Regulatory Commission '
1615 L. Street, N.W., Suite 1000
- Washington, D.C.
20555 Washington, D.C.
20555-Atomic Safety and Licensing Appeal John T. Butler, Esq.
' Panel (5) t Steel, Hector & Davis U.S. Nuclear Regulatory Commission 4000 Southeast Financial Center
. Washington, D.C.
20555:
Miami, FL '33131-2398 1
Office of the Secretary (2)*
Thomas J. Saporito, Jr.
U.S. Nuclear Regulatory Commission Executive Director, NEAP Washington, D.C.
20555 1202 Sioux Street Attn: Docketing and Service Section Jupiter, FL. 33458 Richard J. Goddard, Esq.*
Adjudicatory File (2)*
i Regional Counsel Atomic Safety and Licensing Board USNRC, Region II U.S. Nuclear Regulatory Commission L
101 Marietta St., N.W., Suite 2900 Washington,-D.C.
20555-
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Aylanta,GA 30303 i
L,- Ca L
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Patricta denle
-Counsel for NRC Staff 4
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