ML17340B129

Response to Intervenor MP Oncavage 810414 & 15 Requests for Production of Documents.Licensee Will Provide Documents Except in Response to Requests 3 & 5.Certificate of Svc Encl

ML17340B129
Person / Time
Site:	Turkey Point
Issue date:	04/22/1981
From:	Reis H FLORIDA POWER & LIGHT CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Oncavage M ONCAVAGE, M.
References
ISSUANCES-SP, NUDOCS 8104300487
Download: ML17340B129 (14)

Text

@SERG UNITED STATES OF AMERICA 'APR P 51981e NUCLEAR REGULATORY COMMISSION.

Off1ce ORE THE ATOMIC SAFETY AND LICENSING BOARD pygmy In the Matter of ) Docket Nos. 50-250-SP

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

) (Proposed Amendments to (Turkey Point Nuclear ) Facility Operating Licenses Generating Units Nos. 3 ) to Permit Steam Generator and 4) )

wz-LICENSEE'S RESPONSE TO INTERVENOR'S DISCOVERY REQUESTS On April 14, 1981, Idark P. Oncavage (Intervenor) served "Intervenor Mark P. Oncavage's Request for the Production of t

Documents from Licensee,, Florida Power and Light Company" (April 14th Request). On April 15, 1981, the Intervenor served "Intervenor Mark Oncavage's Request to Produce Docu-ments from Licensee, Florida Power and Light Company" (April 15th Request). 1/ Florida Power and Light Company hereby submits its response to these requests.

I. A ril 14th Re uest Re uest No. 1 The Licensee vill produce a schedule for the repairs which contains the projected initiation and completion dates of the various tasks.

1/ On April 15, 1981, the Intervenor also served "Intervenor Mark P. Oncavage's Request to Produce Documents From the Staff of Florida Power .and Light Company (sic) ." Inter-venor's attorney has informed us that this request is directed to the Staff of the Nuclear Regulatory Commission.

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Re uest No. 2 The Licensee will produce Westinghouse Report ST-RES-FJF-3030.

Re uest No. 3 The reference to a document "concerning grit blasting" mentioned at the September 17, 1980, meeting at 'Homestead is vague and the Licensee is unclear as to the document which is requested. Due to the lack of specificity, the Licensee is unable to comply with this request. Moreover, on the basis of the description provided by the Intervenor, the Licensee doubts whether the requested document is in its possession.

Re uest No. 4 The Licensee will produce "Decontamination of a PWR Primary System, SENA Plant," Volume 33, Proceedings of the American Power Conference, 1981. Contrary to the assertion in the request, the Licensee did not use this document "to calculate of fsite dose from decontamination processes. "

The Licensee objects to the production of the "examination results of all persons who will be involved in the repair."

it Initially, should be noted that the identities of the vast majority of personnel who will be involved in the repairs are not presently known. Moreover, .the request for the exami-nation results of individual workers is not, relevant to any contention admitted in this proceeding, nor is it designed to

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lead to the discovery of admissible evidence. The results of a particular worker would not be relevant to establishing whether or not the repairs will comply with the ALA1Q. principle.

II. A ril 15th Re uest The Licensee will produce the manual used in the FPL's course in radiological protection. A training film used in connection with this course will also be made available for viewing at FPL's General Offices at 9250 W. Flagler St.,

Miami, Florida,'upon reasonable notice, during normal business hours.

FPL administers five different versions of the same comprehensive examination given in connection with FPL's

. course in radiological protection. In order to prevent the possibility of disclosure. of all five versions to individuals who might take the examination, the Licensee will produce of

~'3 a copy a version of the examination.

The Licensee will permit the Intervenor to view the 1/2" = 1'0" scale models of the Turkey Point containment and steam generator internals. Due to the size of the models, it is impracticable to transport them to the offices of the Intervenor's attorney. Consequently, the Licensee will permit the Intervenor to view these models, upon reasonable notice, during normal business hours, at the current location of the models at the Turkey Point site.

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III. Location of Production

.A's requested by the Intervenor, the Licensee will produce the above identified documents at the office of the Inter-venor's attorney, with the exceptions noted above.

Respectfully submitted, Harold F. Reis Steven P. Frantz LOWENSTEIN, NEWSMAN, REIS & AXELRAD 1025 Connecticut Ave., N.W.

Washington, D.C. 20036 Telephone: (202) 862-8400 Dated: April 22, 1981

Ik M UNITED STATES OF M'KRICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter o f ) Docket Nos. 50-250

) 50-251 FLORIDA POWER AND LIGHT 'COMPANY )

) (Proposed Amendments,to (Turkey Point Nuclear ) Facility Operating Licenses Generating Unit Nos. 3 and 4) ) to Permit Steam Generator

) Repair)

CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT copies of the foregoing "Licensee's Response to Intervenor's Discovery Requests" was served on the individuals whose names appear on the attached service list by deposit in the United States mail, first class, properly stamped and addressed, 'on the date shown below.

Additional service. by hand or courier was made upon the individuals next, to whose name an asterisk (*) appears.

Ha o d F,. Reis Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Telephone: (202) 862-8410 April 22, 1981 Attachment

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-250

) 50-251 FLORIDA POWER AND LIGHT COMPANY )

) {Proposed Amendments to (Turkey Point Nuclear ) Facility Operating Licenses Generating Unit Nos. 3 and 4) ) to Permit Steam Generator

) Repair)

SERVICE LIST

• Marshall E. Miller, Esq., Administrative Judge Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Dr. Emmeth A. Luebke,. Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Dr. Oscar H. Paris, Administrative Judge Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Mark P. Oncavage 12200 S.W. 110th Avenue Miami, Florida 33176 Norman A. Coll, Esq.

Steel, Hector 6 Davis Co-counsel for Licensee 1400 Southeast First National Bank Building Miami, Florida 33131

• Steven C. Goldberg, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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Service List Pa e Two Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Burt Saunders, Esq.

Assistant Dade County Attorney 1626 Dade County Courthouse Miami, Florida 33130

• Neil Chonin, Esp.

1400 AmeriFirst Building

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One Southeast Third Avenue Miami, Florida 33131

• Henry H. Harnage, Esq.

Peninsula Federal Building 10th Floor 200 S.E. First Street Miami, Florida 33131 April 22, 1981

• Additional Service by Hand or Courier

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