ML17340B022: Difference between revisions

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| issue date = 04/08/1981
| issue date = 04/08/1981
| title = Request for Summary Disposition of Contentions 3 & 6 Re Cumulative Offsite Radiation Doses & Discharge of Coolant or Laundry Waste Water.No Genuine Issue of Matl Facts Exists
| title = Request for Summary Disposition of Contentions 3 & 6 Re Cumulative Offsite Radiation Doses & Discharge of Coolant or Laundry Waste Water.No Genuine Issue of Matl Facts Exists
| author name = COLL N A
| 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 =  
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=Text=
=Text=
{{#Wiki_filter:UNITED STA'TES OF AMERICA lC NUCLEAR REGULATORY COMMI S S ION BEFORE THE ATOMIC SAFETY AND LICENSING BO cv.4'OC!<~Pg g APR13198t~5 1"-INt~~>i,wig<wl e~C3 LswiCij))FLORIDA POWER&LIGHT COMPANY))(Turkey Point Nuclear Generating
{{#Wiki_filter:cv.
)Units 3 and, 4)))C5 Docket Nos.50-250-SP 50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repairs)8 8(LICENSEE'S MOTION.FOR  
4'OC!<~Pg                g UNITED STA'TES OF AMERICA         lC NUCLEAR REGULATORY COMMIS S ION           APR13198t           ~
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                                                                              ~~>i,wig BEFORE THE ATOMIC SAFETY AND LICENSING      BO                <wl e ~ C3 LswiCij C5
                                        )     Docket Nos. 50-250-SP
                                        )                 50-251-SP FLORIDA POWER   & LIGHT COMPANY     )
                                        )
(Turkey Point Nuclear Generating     )     (Proposed Amendments to Units 3 and, 4)                       )     Facility Operating   License
                                        )    to Permit Steam Generator Repairs) 8 8(
LICENSEE'S MOTION .FOR  


==SUMMARY==
==SUMMARY==
DISPOSITION OF CONTENTIONS 3 AND 6 Pursuant to 10 CFR 52.749, Florida Power&Light Company ("FPL" or"Licensee")moves for summary disposition,, in its favor, of Contentions 3 and 6 which provide: Contention 3-During the course of the repairs proposed by the Licensee, (a)the handling, processing, storing or dischargin of primary coolant or (b)the discharging o laundry waste water is-likely to result in the release of radioactive material to unrestricted areas in quantities which will not be as, low as is reasonably achievable within the meaning of 10 CFR Parts 20 and 50.Contention 6-The cumulative offsite radiate.on releases as a result of all activity at Turkey Point, during the proposed repairs, do not comply with 10 CFR Parts 20 and 50.2'he grounds for this motion are that, as to the matters raised in these contentions, there exists no genuine issue of 810422'(n!3:4 4l r r P l I~~~II c 4 ,)4'9 4 1~W p'Ci material fact and that Licensee is entitled to a favorable decision-as a matter of.law.An affidavit, a statement of.the material facts as to which there is no genuine issue, and a memorandum of law in support of this motion are attached.Respectfully submitted, STEEL HECTOR 6 DAVXS Co-Counsel for Licensee, Flori:da Power 6 Light Company 1400 Southeast First National Bank Bui'1 ing Miami, Flo'da 33131 (305)577-863 By:;Norman A..Coll Date:.Apr3.1 8, 1981 cc: See attached Certificate of Service.
 
DISPOSITION OF CONTENTIONS 3 AND   6 Pursuant to 10 CFR 52.749, Florida Power & Light Company
("FPL" or "Licensee" ) moves for summary disposition,, in its favor, of Contentions     3 and 6 which provide:
Contention     3 During the course of the repairs proposed by the Licensee, (a) the handling, processing, storing or dischargin of primary coolant or (b) the discharging o laundry waste water is- likely to result in the release of radioactive material to unrestricted areas in quantities which will not be as, low as is reasonably achievable within the meaning of 10 CFR Parts 20 and 50.
Contention 6 - The cumulative offsite                                           2'he radiate.on releases as a result of all activity at Turkey Point, during the proposed repairs, do not comply with 10 CFR Parts   20 and 50.
grounds   for this motion are that, as to the matters raised in these contentions, there exists no genuine issue of 810422'(n!3:4
 
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material fact and that Licensee is entitled to a favorable decision -as a matter of. law.
An affidavit, a statement of .the material facts as to which there is no genuine issue, and a memorandum of law in support of this motion are attached.
Respectfully submitted, STEEL HECTOR 6 DAVXS Co-Counsel for Licensee, Flori:da Power 6 Light Company 1400 Southeast First National Bank Bui'1 ing Miami, Flo 'da 33131 (305) 577- 863 By:;
Norman A.. Coll Date:. Apr3.1 8, 1981 cc:   See attached Certificate of Service.
 
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Latest revision as of 10:55, 22 October 2019

Request for Summary Disposition of Contentions 3 & 6 Re Cumulative Offsite Radiation Doses & Discharge of Coolant or Laundry Waste Water.No Genuine Issue of Matl Facts Exists
ML17340B022
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 04/08/1981
From: Coll N
FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML17340B023 List:
References
ISSUANCES-SP, NUDOCS 8104220619
Download: ML17340B022 (4)
v • d • e


Text

cv.

4'OC!<~Pg g UNITED STA'TES OF AMERICA lC NUCLEAR REGULATORY COMMIS S ION APR13198t ~

1"- INt 5

~~>i,wig BEFORE THE ATOMIC SAFETY AND LICENSING BO <wl e ~ C3 LswiCij C5

) Docket Nos. 50-250-SP

) 50-251-SP FLORIDA POWER & LIGHT COMPANY )

)

(Turkey Point Nuclear Generating ) (Proposed Amendments to Units 3 and, 4) ) Facility Operating License

) to Permit Steam Generator Repairs) 8 8(

LICENSEE'S MOTION .FOR

SUMMARY

DISPOSITION OF CONTENTIONS 3 AND 6 Pursuant to 10 CFR 52.749, Florida Power & Light Company

("FPL" or "Licensee" ) moves for summary disposition,, in its favor, of Contentions 3 and 6 which provide:

Contention 3 During the course of the repairs proposed by the Licensee, (a) the handling, processing, storing or dischargin of primary coolant or (b) the discharging o laundry waste water is- likely to result in the release of radioactive material to unrestricted areas in quantities which will not be as, low as is reasonably achievable within the meaning of 10 CFR Parts 20 and 50.

Contention 6 - The cumulative offsite 2'he radiate.on releases as a result of all activity at Turkey Point, during the proposed repairs, do not comply with 10 CFR Parts 20 and 50.

grounds for this motion are that, as to the matters raised in these contentions, there exists no genuine issue of 810422'(n!3:4

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material fact and that Licensee is entitled to a favorable decision -as a matter of. law.

An affidavit, a statement of .the material facts as to which there is no genuine issue, and a memorandum of law in support of this motion are attached.

Respectfully submitted, STEEL HECTOR 6 DAVXS Co-Counsel for Licensee, Flori:da Power 6 Light Company 1400 Southeast First National Bank Bui'1 ing Miami, Flo 'da 33131 (305) 577- 863 By:;

Norman A.. Coll Date:. Apr3.1 8, 1981 cc: See attached Certificate of Service.

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