ML17340B016: Difference between revisions
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| issue date = 04/13/1981 | | issue date = 04/13/1981 | ||
| title = Response in Support of NRC 810323 Motion for Summary Disposition of Contention 2 Re Util Proposed Program for Controlling Occupational Exposures | | title = Response in Support of NRC 810323 Motion for Summary Disposition of Contention 2 Re Util Proposed Program for Controlling Occupational Exposures | ||
| author name = | | author name = Coll N | ||
| author affiliation = FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS | | author affiliation = FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS | ||
| addressee name = | | addressee name = | ||
Revision as of 12:14, 18 June 2019
| ML17340B016 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/13/1981 |
| From: | Coll N FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML17340B017 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8104220548 | |
| Download: ML17340B016 (4) | |
Similar Documents at Turkey Point | |
|---|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEAR3F0999-05, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines1999-09-14014 September 1999
[Table view]Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines L-99-201, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments1999-09-0707 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments ML20206H4441999-05-0303 May 1999 Comment Opposing Proposed Rules 10CFR170 & 10CFR171 Re Rev of Fy 1999 Fee Schedules ML20205J0461999-04-0101 April 1999 Comment Supporting Proposed Draft Std Review Plan on Foreign Ownership,Control & Domination.Util Supports Approach Set Forth in SRP Toward Reviewing Whether Applicant for NRC License Owned by Foreign Corp.Endorses NEI Comments ML20205B3771999-03-16016 March 1999 Comment Opposing PRM 50-64 Re Liability of Joint Owners of Npps.Util Endorses Comments of NEI & Urges Commission to Deny Petition for Rulemaking ML17355A2511999-03-0909 March 1999 Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs L-98-306, Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP1998-12-10010 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP L-98-272, Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses1998-10-28028 October 1998 Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses L-98-252, Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule1998-10-0606 October 1998 Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule L-98-248, Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement1998-10-0505 October 1998 Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement ML17354A8741998-03-27027 March 1998 Comment Opposing Proposed Generic Communication,Lab Testing of nuclear-grade Activated Charcoal (M97978) ML17354B1061998-02-26026 February 1998 Submits Listed Requests for NRC EA Per 10CFR2.206 to Modify OLs for All FPL NPPs Until Licensee Can Demonstrate Open Communication Channels Exist Between NRC & Licensee.Also Requests EA to Address Alleged Discriminatory Practices ML20217M0751997-08-13013 August 1997 Licensee Response to Supplemental 10CFR2.206 Petitions Filed by Tj Saporito & National Litigation Consultants.Petition Provides No Basis for Extraordinary Relief Requested. Petition Should Be Denied.W/Certificate of Svc ML20217J4321997-08-0707 August 1997 Memorandum & Order.* Grants Staff Petition for Review & Reverses Presiding Officer Decision Requiring Staff to Issue Tetrick SRO License.Order Disapproved by Commissioner Diaz. W/Certificate of Svc.Served on 970807 ML20148P8461997-06-25025 June 1997 Memorandum & Order (Determination of Remand Question).* Concludes That Presiding Officer Reaffirms Determination That Response of Rl Tetrick to Question 63 of Exam to Be SRO Was Incorrect.W/Certificate of Svc.Served on 970626 ML17354A5521997-06-18018 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems. ML20141F5441997-06-13013 June 1997 NRC Staff Response to Presiding Officer Memorandum & Order (Questions Relevant to Remand).* Staff Submits That Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam Should Be Denied ML20141F5711997-06-13013 June 1997 Supplemental Affidavit of B Hughes & Ta Peebles.* Affidavit Re Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam.W/Certificate of Svc ML17354A5181997-05-27027 May 1997 Licensee Response to 10CFR2.206 Petition Filed by Tj Saporito & National Litigation Consultants.Petition Should Be Denied,Based on Listed Info.W/Certificate of Svc ML20148G6531997-05-27027 May 1997 Notice.* Forwards Documents Received & Read by Author from Rl Tetrick on 970317 W/O Being Served as Required Under Procedural Rules.W/Certificate of Svc.Served on 970527 ML20148G7071997-05-27027 May 1997 Memorandum & Order (Questions Relevant to Remand).* Rl Tetrick May Respond to Questions W/Filing Served Pursuant to Procedural Regulations W/Notarized Statement to Be Received by 970617.Certificate of Svc Encl.Served on 970527 ML20148G7501997-05-20020 May 1997 Memorandum & Order CLI-97-05.* Staff May Withhold Issuance of SRO License to Rl Tetrick Pending Further Order of Commission.W/Certificate of Svc.Served on 970520 ML17354A5631997-05-17017 May 1997 Second Suppl to 970423 Petition Requesting Enforcement Against Listed Util Employees by Imposing Civil Penalties, Restricting Employees from Licensed Activities & Revoking Unescorted Access ML20141C7331997-05-16016 May 1997 Order Extending Until 970616,time within Which Commission May Rule on NRC Staff 970416 Petition for Review of Presiding Officer Initial Decision.W/Certificate of Svc. Served on 970516 ML17354A5611997-05-11011 May 1997 Suppl to 970423 Petition Requesting Enforcement Action Against Util Former Executive Vice President,Site Vice President & Maint Superintendent by Imposing Civil Monetary Penalty ML20138J2331997-05-0202 May 1997 Affidavit.* Affidavit of B Hughes Re Denial of Application for SRO License for Rl Tetrick.W/Certificate of Svc ML20138J2271997-05-0202 May 1997 NRC Staff Response to Questions Posed in Commission Order of 970425.* Staff Respectfully Submits That Commission Should Undertake Review of Presiding Officer Decisions in Proceedings LBP-97-2 & LBP-97-6 ML20138J2241997-05-0202 May 1997 Line (Providing Omitted Citation).* Informs That Submitted Citation Inadvertently Omitted from Response to Questions Posed in Commission Order of 970425.W/Certificate of Svc ML20138J2401997-04-25025 April 1997 Scheduling Order.* Staff Instructed to File W/Commission,By COB 970502,response to Tetrick Argument Re Question 63 & Discussion of Legal Significance of Consistent Staff Practices.W/Certificate of Svc.Served on 970425 ML17354A5651997-04-23023 April 1997 Requests That NRC Take EA to Modify,Suspend or Revoke FPL Operating Licenses for All Four Nuclear Reactors Until Licensee Can Sufficiently Demonstrate to NRC & Public That Employees Encouraged to Freely Raise Safety Concerns ML20137X5921997-04-16016 April 1997 NRC Staff Petition for Commission Review of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Undertake Review of Presiding Officer Decisions in Proceeding.W/Certificate of Svc ML20137X5511997-04-11011 April 1997 NRC Request for Issuance of Order Staying Effectiveness of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Stay Effectiveness of Decision in Subj Proceeding.W/Certificate of Svc ML20137R3531997-03-27027 March 1997 Correct Copy of Memorandum & Order (Denial of Reconsideration,Stay).* Denies NRC Staff Motion for Reconsideration.W/Certificate of Svc.Served on 970327 ML20137F5551997-03-25025 March 1997 NRC Staff Response to Memorandum & Order of 970321.* Presiding Officer Should Grant Staff 970310 Motion for Reconsideration.W/Certificate of Svc ML20137F8251997-03-21021 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Orders That Effect of Initial Decision Postponed Until Close of Business on 970326.W/Certificate of Svc.Served on 970321 ML20137F5081997-03-17017 March 1997 NRC Staff Motion for Issuance of Stay.* Requests That Presiding Officer Deny NRC Staff Request for Issuance of Stay in Matter of Issuance of SRO License ML20137F5371997-03-17017 March 1997 NRC Staff Motion for Reconsideration in Matter of Rl Tetrick.* Requests That Presiding Officer Deny NRC Staff Request for Reconsideration ML20136F2981997-03-12012 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Informs That Initial Decision Issued by Presiding Officer on 970228 Postponed Until 970321 & Rl Tetrick May File Response by 970318.W/Certificate of Svc.Served on 970312 ML20136F2351997-03-10010 March 1997 NRC Staff Motion for Reconsideration Introduction.* Requests That Presiding Officer Reconsider Determination That Tetrick Passed Written Exam & Find,Instead,That Tetrick Failed Written Exam ML20136F3411997-03-10010 March 1997 NRC Staff Request for Issuance of Order Staying Effectiveness of Presiding Officers Initial Decision LBP-97-2.* Staff Submits That Presiding Officer Should Stay Effectiveness of Initial Decision.W/Certificate of Svc ML20136F2721997-03-0606 March 1997 Supplemental Affidavit of B Hughes.* Supports Staff Motion for Reconsideration of Presiding Officer Initial Decision of 970228.W/Certificate of Svc ML20138Q0191997-02-28028 February 1997 Initial Decision.* Concludes That Rl Tetrick Had Passing Score of 80% & Should Be Granted License as Sro. W/Certificate of Svc.Served on 970228 ML20134A6551997-01-23023 January 1997 Written Presentation of NRC Staff.* Staff Concludes That SE Turk Failed Written Exam & Did Not Establish Sufficient Cause to Change Grading of Answers to Listed Questions. Denial of Application for SRO License Should Be Sustained ML20134A6661997-01-23023 January 1997 Affidavit of B Hughes & Ta Peebles Re Denial of Application for SRO License.W/Certificate of Svc.Served on 970124 ML20129J5681996-10-23023 October 1996 Memorandum & Order (Error).* Informs of Incorrect Caption Identified in Order .W/Certificate of Svc.Served on 961023 ML20129D4981996-10-21021 October 1996 Memorandum & Order (Grant of Request for Hearing Scheduling).* Requests for Hearing Hereby Granted. W/Certificate of Svc.Served on 961021 ML20129D6681996-10-18018 October 1996 NRC Staff Answer to Rl Tetrick Request for Hearing.* Staff Does Not Oppose Request & Will Be Prepared to Submit Hearing File.W/Certificate of Svc & Notice of Appearance ML20129D4401996-10-0909 October 1996 Designating of Presiding Officer.* Pb Bloch Designated to Serve as Presiding Officer to Conduct Informal Adjudicatory Hearing in Proceeding of Rl Tetrick Re Denial of SRO License.W/Certificate of Svc.Served on 961010 ML17353A6311996-01-19019 January 1996 Decision & Remand Order Re FPL Discrimination Against RR Diaz-Robainas.FPL Ordered to Offer Reinstatement to RR Diaz-Robainas W/Comparable Pay & Benefits,To Pay Him Back Pay W/Interest & to Pay His Costs & Expenses Re Complaint ML17353A2471995-06-27027 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style. 1999-09-07 Category:PLEADINGS MONTHYEARML17354B1061998-02-26026 February 1998
[Table view]Submits Listed Requests for NRC EA Per 10CFR2.206 to Modify OLs for All FPL NPPs Until Licensee Can Demonstrate Open Communication Channels Exist Between NRC & Licensee.Also Requests EA to Address Alleged Discriminatory Practices ML20217M0751997-08-13013 August 1997 Licensee Response to Supplemental 10CFR2.206 Petitions Filed by Tj Saporito & National Litigation Consultants.Petition Provides No Basis for Extraordinary Relief Requested. Petition Should Be Denied.W/Certificate of Svc ML20141F5441997-06-13013 June 1997 NRC Staff Response to Presiding Officer Memorandum & Order (Questions Relevant to Remand).* Staff Submits That Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam Should Be Denied ML17354A5181997-05-27027 May 1997 Licensee Response to 10CFR2.206 Petition Filed by Tj Saporito & National Litigation Consultants.Petition Should Be Denied,Based on Listed Info.W/Certificate of Svc ML17354A5631997-05-17017 May 1997 Second Suppl to 970423 Petition Requesting Enforcement Against Listed Util Employees by Imposing Civil Penalties, Restricting Employees from Licensed Activities & Revoking Unescorted Access ML17354A5611997-05-11011 May 1997 Suppl to 970423 Petition Requesting Enforcement Action Against Util Former Executive Vice President,Site Vice President & Maint Superintendent by Imposing Civil Monetary Penalty ML20138J2271997-05-0202 May 1997 NRC Staff Response to Questions Posed in Commission Order of 970425.* Staff Respectfully Submits That Commission Should Undertake Review of Presiding Officer Decisions in Proceedings LBP-97-2 & LBP-97-6 ML17354A5651997-04-23023 April 1997 Requests That NRC Take EA to Modify,Suspend or Revoke FPL Operating Licenses for All Four Nuclear Reactors Until Licensee Can Sufficiently Demonstrate to NRC & Public That Employees Encouraged to Freely Raise Safety Concerns ML20137X5921997-04-16016 April 1997 NRC Staff Petition for Commission Review of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Undertake Review of Presiding Officer Decisions in Proceeding.W/Certificate of Svc ML20137X5511997-04-11011 April 1997 NRC Request for Issuance of Order Staying Effectiveness of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Stay Effectiveness of Decision in Subj Proceeding.W/Certificate of Svc ML20137F5551997-03-25025 March 1997 NRC Staff Response to Memorandum & Order of 970321.* Presiding Officer Should Grant Staff 970310 Motion for Reconsideration.W/Certificate of Svc ML20137F5081997-03-17017 March 1997 NRC Staff Motion for Issuance of Stay.* Requests That Presiding Officer Deny NRC Staff Request for Issuance of Stay in Matter of Issuance of SRO License ML20137F5371997-03-17017 March 1997 NRC Staff Motion for Reconsideration in Matter of Rl Tetrick.* Requests That Presiding Officer Deny NRC Staff Request for Reconsideration ML20136F2351997-03-10010 March 1997 NRC Staff Motion for Reconsideration Introduction.* Requests That Presiding Officer Reconsider Determination That Tetrick Passed Written Exam & Find,Instead,That Tetrick Failed Written Exam ML20136F3411997-03-10010 March 1997 NRC Staff Request for Issuance of Order Staying Effectiveness of Presiding Officers Initial Decision LBP-97-2.* Staff Submits That Presiding Officer Should Stay Effectiveness of Initial Decision.W/Certificate of Svc ML20129D6681996-10-18018 October 1996 NRC Staff Answer to Rl Tetrick Request for Hearing.* Staff Does Not Oppose Request & Will Be Prepared to Submit Hearing File.W/Certificate of Svc & Notice of Appearance ML20070E7721991-02-25025 February 1991 NRC Staff Response to Licensee Motion to Reject or Strike Appellant Reply.* Sarcastic Language in Reply Should Be Stricken & Applellant Should Be Required to Provide Supplementary Info.W/Certificate of Svc ML20070C1971991-02-19019 February 1991 Licensee Reply to Appeal Request of Tj Saporito.* Licensee Adopts Position & Argument of NRC as Stated in Appeal. W/Certificate of Svc ML20066G9711991-02-0808 February 1991 Licensees Motion to Reject or Strike Petitioners Reply to Motion to Dismiss.* Moves Aslab to Reject or Strike Nuclear Energy Accountability Project 910128 Reply Due to Discourteous & Insulting Tone of Reply.W/Certificate of Svc ML20073E0511991-01-28028 January 1991 Reply.* Board of Directors of Nuclear Energy Accountability Project (Neap) Have Not Decided to Dissolve Neap.Tj Saporito Notification That Neap Will Dissolve by 901231 Was Outside Authority.Aslb 910110 Order Is Moot.Appeal Should Be Valid ML20070A0371991-01-0909 January 1991 Licensee Answer to Petitioner Motion for Reconsideration.* Request for Hearing & Intervention Should Be Denied Due to Petitioner Lack of Standing & Timing of Contentions Is Moot. W/Certificate of Svc ML20066D5981990-12-26026 December 1990 Reply to Answers to Petition & Amended Petition.* Intervenor Finds ASLB 901206 Order Premature & Requests That Hearing on Record Be Granted ML20066A2531990-12-21021 December 1990 Motion for Order to Show Cause Why Nuclear Energy Accountability Project (Neap) Should Not Be Dismissed from Proceeding.* Unless Aslab Denies Appeal Prior to 901231,NEAP Should Show Cause for Dismissal.W/Certificate of Svc ML20066A1081990-12-19019 December 1990 Motion for Order to Show Cause Why Proceeding Should Not Be Terminated.* Nuclear Energy Accountability Project Should Be Directed to Show Why Proceeding Should Not Be Terminated, Unless Appeal Denied Prior to 901231.W/Certificate of Svc ML20065T8771990-12-13013 December 1990 Motion to Withdraw.* Withdraws from Proceeding Due to Dissolution of Organization,Effective 901231.W/Certificate of Svc.Served on 901213.Granted for Licensing Board on 901212 ML20065T7851990-12-13013 December 1990 Licensee Response to Motion to Withdraw.* Licensee Lack of Objection to Withdrawal of Nuclear Energy Accountability Project from Proceeding Noted.W/Certificate of Svc ML20065T7921990-12-0808 December 1990 Motion to Withdraw.* Nuclear Energy Accountability Project Will Be Dissolved Effective 901231.W/Certificate of Svc ML20065T8461990-12-0505 December 1990 Licensee Response to Notices of Change of Address.* Inconsistencies Re Issue of Standing Have Been Injected Into Proceeding by Notices.W/Certificate of Svc ML20062B9861990-10-11011 October 1990 Licensee Opposition to Nuclear Energy Accountability Project (Neap) Request to Change Location of Oral Argument.* Neap Request to Transfer Location of Oral Argument Should Be Denied.W/Certificate of Svc ML20059L8401990-09-14014 September 1990 Applicant Response to Memorandum & Order (Motion to Dismiss).* Board Should Not Undertake Sua Sponte Review Due to Board Lacking Jurisdiction.W/Certificate of Svc ML20059C5021990-08-31031 August 1990 NRC Staff Response to Licensing Board Order of 900717.* Requests That Licensing Board Refrain from Raising Sua Sponte Issues ML20059A8941990-08-16016 August 1990 Opposition to Motion for Extension of Time to Appeal.* Requests That Nuclear Energy Accountability Project 900813 Motion for Extension of Time to File Brief in Support of Appeal Be Denied.W/Certificate of Svc ML20059B0161990-08-13013 August 1990 Motion for Extension of Time to Appeal.* Board Should Grant Extension of Time to Insure Intervenor Has Opportunity to Fully & Completely Address Issues on Appeal.W/Certificate of Svc ML20059A8791990-08-13013 August 1990 Motion for Extension of Time to Appeal.* Requests Extension of 15 Days to File Brief in Support of Appeal.W/Certificate of Svc.Served on 900817.Granted for Appeal Board on 900817 ML20056B2181990-08-10010 August 1990 NRC Staff Motion for Extension of Time.* Requests Extension of Time Until 900831 to File Response to Licensing Board 900717 Order,Per 10CFR2.711.W/Certificate of Svc ML20056B2011990-08-0303 August 1990 Licensee Motion for Leave to Submit Citation to Supplemental Authority.* Licensee Moves for Leave to Call Recent Supreme Court Authority to Attention of Appeal Board.W/Certificate of Svc.Served on 900803.Granted for Appeal Board on 900803 ML20056A3751990-07-31031 July 1990 NRC Staff Response to Licensee Motion to Submit Citation to Supplemental Authority.* NRC Has No Objection to Granting of Licensee 900716 Motion.W/Certificate of Svc ML20056A3821990-07-25025 July 1990 Notice of Appeal.* Requests Oral Argument on Issue of Standing & That Argument Be Held in Miami,Fl to Permit Fair & Equitable Opportunity to Address Issue in Proceeding. W/Certificate of Svc ML20055G6491990-07-16016 July 1990 Licensee Motion for Leave to Submit Citation to Supplemental Authority.* Licensee Moves for Leave to Call Recent Supreme Court Authority to Attention of Appeal Board & Parties. Certificate of Svc Encl ML20055G7851990-07-12012 July 1990 NRC Staff Response to Applicant Motion for Reconsideration.* Advises That Nuclear Energy Accountability Project Has Not Established Standing to Intervene in Proceeding,Therefore, Petition Should Be Denied.W/Certificate of Svc ML20055F5891990-07-0606 July 1990 NRC Staff Response to Motions for Change of Location of Oral Argument.* NRC Does Not See Necessity for Aslab to Depart from Practice of Holding Oral Arguments in Bethesda,Md. Motion Should Be Denied.W/Certificate of Svc ML20058K7551990-06-24024 June 1990 Intervenor Motion for Reconsideration of Appeal Board Order Setting Oral Argument.* Requests That Appeal Board Move Oral Argument Scheduled for 900710 in Bethesda,Md to Miami,Fl. Certificate of Svc Encl ML20055D9241990-06-20020 June 1990 Appellant Motion to Move Place of Oral Argument.* Appellant Motion Should Be Granted.W/Certificate of Svc ML20043H1801990-06-19019 June 1990 Unopposed Request for 1-day Extension.* Extension Requested in Order to Seek Legal Advise Re Board 900615 Order on Intervention Status.Granted for ASLB on 900619. Served on 900620.W/Certificate of Svc ML20043A6761990-05-17017 May 1990 Applicant Reply to Nuclear Energy Accountability Project (Neap) Response to ASLB Memorandum & Order.* Neap Petition to Intervene Should Be Denied & Proceeding Dismissed.W/ Certificate of Svc ML20042E6011990-04-20020 April 1990 Intervenors Answer to Applicant 900413 Response & Intervenors Motion for Sanctions Against Applicant & Intervenors Motion for Leave to Amend Contentions.* Certificate of Svc Encl ML20012F7051990-04-13013 April 1990 Applicant Response to Notice of Withdrawal from Proceeding.* Advises That Nuclear Energy Accountability Project (Neap) No Longer Has Standing Since Saporito Withdrew from Proceeding & Neap Has Not Established Standing.W/Certificate of Svc ML20011F1081990-02-23023 February 1990 Intervenors Motion for Extension of Time to File Appeal Brief.* Extension Requested to File Brief Due to Intervenor J Lorion Involved W/Family Health Matters.W/Certificate of Svc.Served on 900226.Granted for Aslab on 900223 ML20011F1151990-02-23023 February 1990 Intervenors Motion for Extension of Time to File Appeal Brief.* Requests 5-day Extension Until 900305 to File Appeal Brief Due to Author Family Health Matters Interfering W/ Ability to Meet Commitments.W/Certificate of Svc ML20006G1171990-02-21021 February 1990 Motion for Reconsideration of Time Extension.* Petitioners Ask That Board Reconsider 900208 Request for Extension of Time Until 900305 to File Amended Petition & Contentions Based on Parties Agreement.Certificate of Svc Encl 1998-02-26 |
Text
c+P UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION FORE THE.ATOMIC'AFETY AND LICENSING Docjg~<>P~aI~~APR]G]98), Ojjjjcp pf<<>><Bppfp jjp+a<~pl>pf B BOARD In the Matter of))FLORIDA POWER AND LIGHT COMPANY.))(Turkey Point Nuclear Generating
)Units Nos.3 and 4))Docket Nos.50-250-S 50-2 1-SP (Proposed Amendments to Facility Operating, Licenses to Permit.Steam Generator Repairs)413 ag LICENSEE'ANSWER, SUPPORTING
'NRC STAFF MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 2 On March 23, 1981, the NRC Staff filed-"NRC Staff Second Motion for.-,Summary Disposition
.(Motion)" which seeks summary disposition, inter alia, of Contention 2.Pursuant to 10 CFR 5 2.749(a), Florida Power 6 Light Company (FPL)files its answer in support of the Motion with respect to Contention 2.FPL has examined the Motion and the supporting affidavits filed by the NRC Staff.FPL agrees that there is no genuine issue as to the material facts concerning Contention 2, and submits that, summary disposition should be.granted dismissing Contention 2 from this proceeding.
l C In support of its Answer supporting the Motion, FPL herewith submits additional affidavits from Harvey F.Story and George R.Gram on Contention 2.These individuals have detailed 8 z o,a a 2osltb'4 iI)
-lk 1t*1 U 1\
knowledge about FPL's current health physics practices and its planning with.regard to the work force to be utilized for the steam generator repair program.Respectfully submitted, STEEL HECTOR 6 DAVIS Co-Counsel for Licensee l400 Southeast First National Bank Bldg.Miami, lorida 33l'31 Teleph e (305)577 28 April/$1981 N rman A.oil cc: See Attached Certificate of Service 45 I[4
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