ML17209B176

Forwards New App Iv,Containing Original Photographs,To 810601 Brief in Opposition to Util Application for Subpoenas.W/O Encl Photographs

ML17209B176
Person / Time
Site:	Saint Lucie
Issue date:	06/02/1981
From:	Kucik G ARENT, FOX, KINTNER, PLOTKIN & KAHN
To:	Smith I Atomic Safety and Licensing Board Panel
References
ISSUANCES-A, NUDOCS 8106090329
Download: ML17209B176 (4)

Text

,,4r'ent, I ox., Kintner, Plotkin Federal Bar Building, 1815 H Street. Y.N'.

4'ashington. D.C. 20006 8c Kahn

'Q'f JUN 08 tt Tekphone: (202) 85 r.6000 Cable: ARFOX Tdtx: AU 692672 ITT 440266

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1p George R. Kucik (202) 857-6084 Oe June 2, 1981 The Honorable Ivan W. Smith tt t'11 ~g 8 Chairman Atomic Safety 6 Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 I

Re: In the Matter of Florida Company Docket No.

(St. Luc 5

'ant, 89~A Power Unit

& Light No. 2)

Dear Judge. Smith:

Yesterday we filed a brief in opposition to Florida Power & Light Company's aoplication for subpoenas in this proceeding. Appendix IV to that brief was intended to consist of two photographs. By mistake, however, the original photographs were not included with any of the filed copies; instead, appended to all twenty copies were photocopied impressions of the photographs. For the record, I have enclosed a new Appendix IV containing the original photographs.

Also, in the cover page to that Appendix we have corrected a typographical error. The word "from" in the third sentence has been changed to "fou ". A copy of this letter and of the corrected cover page to Appendix 1V are being mailed to everyone identified on the certificate of service attached to the brief.

I apologize for any inconvenience that this oversight may have caused.

Sincerely,

~+ One R.P ~

of Counsel for Petitioners

"nclosures

a7 k

I

Appendix lV Page l Ae'-'al view of RRD's resource recovery plant showing six cooling towers (mid-foreground), two stacks and four electro-static precipitators (left). .our boilers and two turbogenerators are in the central structures, with the step-up transformers and switchyard to "heir right. The 240 kv in ertie line runs from the switchyard, west (leftwards) between the cooling towers and stacks, then north to the street, then east (rightwards) to FPGL's north-south Turkey Point line (off picture, to right). Across the street (background) is the non-conforming 58th Street landfill due to be replaced by the resource recovery plant.

Page 2 The resource recovery plant's 240 kv inter-tie line (left) stands ready to interconnect with FPSL's 240 kv Turkey Point line (right).

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