ML17340B016

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Response in Support of NRC 810323 Motion for Summary Disposition of Contention 2 Re Util Proposed Program for Controlling Occupational Exposures
ML17340B016
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 04/13/1981
From: COLL N A
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)


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)

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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