Text

FPL Motion to Strike Portions of Case'S Initial Statement
	ML15292A564
Person / Time
Site:	Turkey Point
Issue date:	10/19/2015
From:	Hamrick S; Florida Power & Light Co
To:	; Atomic Safety and Licensing Board Panel
	SECY RAS
References
	50-250-LA, 50-251-LA, ASLBP 15-935-02-LA-BD01, RAS 28401
	Download: ML15292A564 (15)
	v • d • e

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

Florida Power & Light Company ) Docket No. 50-250-LA

) 50-251-LA (Turkey Point Units 3 and 4) )

) ASLBP No. 15-935-02-LA-BD01 FLORIDA POWER & LIGHT COMPANYS MOTION TO STRIKE PORTIONS OF CASES INITIAL STATEMENT OF POSITION, TESTIMONY, AFFIDAVITS AND EXHIBITS OR, IN THE ALTERNATIVE, MOTION IN LIMINE TO EXCLUDE IT AND ITS CITED DOCUMENTS FROM EVIDENCE Pursuant to 10 C.F.R. §§ 2.319, 2.323, and 2.337, and in accordance with the Licensing Boards (Board) Scheduling Order of May 8, 2015, Florida Power & Light Company (FPL) files this motion to strike portions of the Citizens Allied For Safe Energy [CASE] Initial Statement of Position, Testimony, Affidavits and Exhibits (the CASE Statement) and attached documents because they raise issues beyond the scope of Contention 1, include opinions and exhibits not properly sponsored by an expert, and include exhibits not properly disclosed or introduced into the record. In the alternative, FPL also files this motion in limine to exclude these materials from evidence.

Although captioned as including testimony [and] affidavits, the CASE filing is simply a statement of position and does not contain any sworn expert testimony. The CASE Statement and the documents referenced in and attached thereto are technical in nature and are not supported by a qualified witness and thus, should not be considered evidence. In addition, significant portions of the CASE Statement and its cited documents raise issues beyond the limited scope of Contention 1 as admitted by the Board in this proceeding. Because the 1

Commissions rules makes clear that arguments and exhibits that address matters beyond the scope of an admitted Contention or are unsupported by a qualified witness are inadmissible, or in the alternative should be excluded from the record, the Board should grant FPLs motion.

I. NRC EVIDENCE ADMISSIBILITY STANDARDS A. The Boards Authority to Regulate Arguments and Evidence Commission rules allow [o]nly relevant, material, and reliable evidence to be admitted into evidence.1 Thus, the Board may strike any portion of a written presentation or a response to a written question that is irrelevant, immaterial, unreliable, duplicative or cumulative.2 And, in the alternative, the Board may restrict evidence or arguments for the same reasons.3 B. Rules Governing Arguments and Evidence Technical opinion testimony must be sponsored by a qualified expert with the knowledge, skill, experience, training, or education to testify.4 Non-expert testimony on a technical issue is accorded no weight.5 Further, a non-expert cannot sponsor technical analyses for admission as evidence.6 Finally, exhibits submitted to support testimony should be either an original or a copy, not cut and pasted into another document.7 These procedural standards are fully applicable to CASE, despite the fact the organization has chosen to proceed without an attorney. The Commission has previously held in another proceeding involving a pro se intervenor that parties in NRC proceedings must include as exhibits all documents that a party 1

10 C.F.R. § 2.337(a).

2 10 C.F.R. § 2.319(d).

3 10 C.F.R. § 2.319(e).

4 Duke Energy Corporation (Catawba Nuclear Station, Units 1 and 2), CLI-04-21, 60 NRC 21, 27 (2004)

(citations omitted), citing Duke Power Co. (William B. McGuire Nuclear Station, Units 1 and 2), ALAB-669, 15 NRC 453, 475 (1982).

5 Texas Utilities Electric Co. (Comanche Peak Steam Electric Station, Units 1 and 2), LBP-84-55, 20 NRC 1646, 1651 (1984).

6 Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), ALAB-717, 17 NRC 346, 367 (1983).

7 See 10 C.F.R. § 2.337(d).

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relies upon.8 There, the Commission specifically provided guidance [f]or future proceedings, such as the one currently before the Board, to make clear that documents or other evidence referenced in parties briefs must be available in the case record [because] Boards and the Commission should not be expected to consider items never provided on the record.9 C. Rules Governing the Scope of Issues Addressed in Arguments and Evidence There are also significant limitations on the scope of the subject matter that a party may address at hearing. Intervenors cannot expand the scope of an admitted contention beyond the specific bases proffered and accepted by the Board.10 As the Commission has explained, [t]he scope of a contention is limited to issues of law and fact pled with particularity in the intervention petition, including its stated bases, unless the contention is satisfactorily amended in accordance with [its] rules. Otherwise, NRC adjudications quickly would lose order.11 This standard allows both the parties and the Board to be on notice of the issues being litigated and ensures focused and fair proceedings.12 In Pilgrim, the Commission reiterated that longstanding precedent requires a Board to examine a contentions bases to determine the scope of a contention because the reach of a contention necessarily hinges upon its terms coupled with its stated bases.13 Intervenors may not freely change the focus of an admitted contention at will to add a host of new issues and objections that could have been raised at the outset. . . . [The Commission does] not allow distinctly new complaints to be added at will as litigation progresses.14 8

Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc. (Pilgrim Nuclear Power Station), CLI-10-11, 71 NRC 287 (slip op. at 25 n.97) (2010).

9 Id.

10 Southern Nuclear Operating Co. (Early Site Permit for Vogtle ESP Site), CLI-10-5, 71 NRC 90, 100-01 (2010).

11 Id (emphasis added).

12 Id.

13 Pilgrim, CLI-10-11 (slip op. at 28) (emphasis added).

14 Id.

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II. PORTIONS OF THE CASE STATEMENT AND ACCOMPANYING DOCUMENTS SHOULD BE STRICKEN The CASE Statement, despite being labeled by CASE as containing the Statement of Position, testimony, and exhibits, should not be considered pre-filed testimony or evidence of any kind because it consists entirely of unsupported argument and technical references not appropriately sponsored by a qualified expert with the knowledge, skill, experience, training, or education to testify.15 CASE has provided no evidence that Mr. White is an expert in the technical areas that form the bases of the arguments advanced in the CASE Statement. Indeed, CASE readily admitted that it had provided absolutely no expert testimony whatsoever in support of its proffered opinions.16 Accordingly, the entirety of the CASE Statement is merely CASEs summation of its position and, because it does not meet established Commission standards, FPL objects to the admission of the CASE Statement or any of the documents excerpted therein as evidence in this proceeding.17 For similar reasons, the Board should strike CASE Attachment 1 (ostensibly Exhibit INT-001), which appears to be a report prepared by Mr.

White, as evidence in this proceeding, because it was not sponsored into evidence by an expert.

CASE Attachments 2 and 3 (Exhibits INT-002 and INT-003) suffer from this same defect.18 Many of the documents CASE includes in its Statement were also not properly introduced as exhibits into the record.19 Both the CASE Statement and its Attachment 1 reference numerous documents not contained in the record nor provided by CASE in its mandatory disclosures. Instead, the CASE Statement impermissibly cites by reference to multiple external, non-record documents, cutting and pasting from them liberally, often with no 15 See Catawba, CLI-04-21, 60 NRC at 27.

16 CASE Statement at 5.

17 See 10 C.F.R. § 2.319(d).

18 FPL does not object to CASE Attachments 4 (Florida Department of Environmental Protection Administrative Order), 5 (Miami-Dade County Notice of Violation), and 6 (Consent Agreement Between Miami-Dade County and FPL), which are public records.

19 See Pilgrim, CLI-10-11 (slip op. at 25 n.97).

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clear indication where one excerpted passage ends and another begins. Similarly, the CASE Statement includes cut and pasted information from various emails and memoranda without providing the whole document to provide context for the parties and Board to determine their veracity and relevance. Admissible exhibits should either be an original or a copy, and cannot be simple cut and paste portions of other documents.20 In its Scheduling Order, the Board provided specific, detailed instruction regarding the presentation of exhibits at hearing, and CASE has ignored both the Boards instructions and the Commissions rules. Further, as shown in more detail Table 1 below, CASE also failed to identify all of these external, non-record documents in its mandatory disclosures, forcing FPL to seek complete, original versions of some of the documents from alternative sources.

Any document CASE referenced or excerpted without properly offering into the record as an exhibit should be stricken from the record in this matter. Table 1 contains a listing of CASEs improperly submitted documents.

Table 1 Documents Improperly Referenced or Reproduced in the CASEs Submission Page # Document Identified in Mandatory Disclosures?

CASE Email from Dr. Christopher Kelble No Statement (CS) at 8-9 CS at 12-14 Origins and Delineation of Saltwater Intrusion in the Yes Biscayne Aquifer and Changes in the Distribution of Saltwater in Miami-Dade County, Florida CS at 15 Water, Water, Everywhere: Sea Level Rise in No MiamiUniversity of Miami Rosenstiel School Of Marine and Atmospheric Science, Miami, http://www.rsmas.miami.edu/blog/2014/10/03/sea-level-rise-in-miami/

20 See 10 C.F.R. § 2.337.

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Page # Document Identified in Mandatory Disclosures?

CS at 17-18, USGS Ground Water Atlas Of The United States Alabama, No 51, 77; Florida, Georgia, South Carolina Attachment 1 (AT1) at 21 CS at 28-30 Letter from C. Espinosa to M. Harris, Application to No Renew Turkey Point Industrial Wastewater Facility Permit number Fzl0001582 CS at 32, 33 Florida Power and Light Company Docket No. 50-251 ADAMS Facility Operating License, License No. DPR-41 April; 10.

1973 ML013400438 CS at 33; Knowledge Of Ground Water Responses - Critical Factor in No AT1 at 20, Saving Florida's Threatened and Endangered Species Part I:

26-28 Marine Ecological Disturbances Sydney T. Bacchus Applied Environmental Services, P. O. Box 174, Athens, GA 30603; appliedenvirserv@mindspring.com https://www.nirs.org/nukerelapse/levy/exhf2bacchus.pd CS at 37 Email from G. Burzycki, Subject RE: FPL Cooling Canals No CS at 38 Email from E. Alvear, Subject Cormorant colony closest to No FPL cooling canals undergoing severe decline CS at 38-40 Email from L. Otero, Subject Uprate monitoring issues Yes CS at 41 Email from L. Otero, Subject CCS Surface Water TKN Yes CS at 41 Email from C. Grossenbacher, Subject FW:FPL Annual Yes Crocodile Report CS at 42 Email from L. Otero, Subject RE: Turkey Point Units 3&4 Yes Uprate Addendum - Tritium Attachments: 2014 Post Uprate Report MDC Draft Comments CS at 42 Memorandum from L. Hefty L. to P. Coram Yes CS at 47 Message from F. Mazzoti to J. Wrublik Yes CS at 47 Ecology and Conservation of the American Crocodile No (Crocodylus acutus) in Florida CS at 47-48 Message from M. Pearce to S. Scroggs Yes CS at 48 Statement of P. Stoddard No CS at 48-50 Comments of Miami-Dade County on Draft Environmental ADAMS Impact Statement for Turkey Point Units 6&7 6

Page # Document Identified in Mandatory Disclosures?

CS at 56-57 Meeting Minutes of the South Florida Water Management No District CS at 63 July 25, 2014 NRC letter to the FWS the NRC requested ADAMS consultation on the subject EA (ADAMS Accession No. ML14206A800)

CS at 67-68 Email from A. Gunderson No CS at 68-69 Email to T. Hoeg; Email from T. Hoeg No CS at 75 Environmental Review Guidance for Licensing Actions ADAMS Associated with NMSS Programs Division of Waste Management Office of Nuclear Material Safety and Safeguards (ML032450279)

CS at 79-80; Statement from National Park Service website No AT1 at 25 AT1 at 1-8 What Is Saltwater Intrusion? Saltwater Intrusion of Coastal Yes Aquifers in the U.S. James Spatafo Johnson State College Senior Seminar May 6, 2008T http://kanat.jsc.vsc.edu/student/spatafora/setup.htm AT1 at 8 http://www.rsmas.miami.edu/blog/2014/10/03/sea-level- No rise-in-miami/

AT1 at 8 Emergency Order No. 2015-034-DAOWU [PDF] - Yes South www.sfwmd.gov/...sfwmd.../f AT1 at 9, 28 Dolan Study No AT1 at 9-10 Borehole geophysical logging for the Florida Power & Light No Turkey Point Plant groundwater, surface water, and ecological monitoring plan AT1 at 10- Origins and Delineation of Saltwater Intrusion in the Yes 12 Biscayne Aquifer and Changes in the Distribution of Saltwater in Miami-Dade County, Florida AT1 at 14- usgs summary and conclusions No 18 AT1 at 18- McNeill, Donald F., 2000. A Review of Upward Migration No 20 of Effluent Related to Subsurface Injection at Miami-Dade Water and Sewer South District Plant.

AT1 at 21- Biological Assessment on the American Crocodile ADAMS 24 (Crocodylus acutus) Turkey Point Nuclear Generating Unit Nos. 3 and 4 Proposed License Amendment to Increase the 7

Page # Document Identified in Mandatory Disclosures?

Ultimate Heat Sink Temperature Limit July 2014 AT1 at 24 Hughes, J.D., Langevin, C.D., and Brakefield-Goswami, No Linzy, 2010, Effect of hypersaline cooling canals on aquifer salinization: Hydrogeology Journal, v. 18, p. 25-38.

AT1 at 24 Turkey Point Unit 1 Eco System By Russ Finley On Mar 3, Yes 2015 with 14 Responses III. SIGNIFICANT PORTIONS OF THE CASE STATEMENT AND ITS EXHIBITS ARE BEYOND THE SCOPE OF CONTENTION 1 AND SHOULD BE STRICKEN Because the Board is empowered to [r]estrict irrelevant, immaterial, unreliable, duplicative or cumulative evidence and/or arguments,21 those portions of the CASE Statement and attachments that go beyond the limited scope of Contention 1, as admitted, should also, in addition to the reasons set forth above, be stricken as irrelevant and immaterial arguments.

CASE Contention 1, as reformulated and subsequently admitted by the Board, alleges that the NRCs Environmental Assesment (EA) does not adequately address the impact of increased temperature and salinity in the [cooling canal system (CCS)] on saltwater intrusion arising from: (1) migration out of the CCS; and (2) the withdrawal of fresh water from surrounding aquifers to mitigate conditions within the CCS.22 Essentially, the contention alleges that the increase in ultimate heat sink temperature allowed by the license amendment will lead to an increase in average temperature in the CCS and a resultant increase in CCS salinity.

According to the contention, this heightened CCS salinity, in turn, will exacerbate saltwater intrusion both by direct migration out of the CCS and by operation of FPLs CCS mitigation measures.

21 10 C.F.R. § 2.319(e).

22 LBP-15-13 (slip op. at 24) (emphasis added).

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A. Biscayne Bay The CASE Statement argues, for the first time, that CCS water may impact the water of Biscayne Bay, as opposed to the Biscayne Aquifer, which underlies both Biscayne Bay and the Turkey Point site.23 Neither CASEs Petition nor its Reply ever asserted that hypersaline water from the CCS would intrude into Biscayne Bay.24 In its Petition, CASE cited a document discussing the high salinity groundwater plume from the cooling canals as it moves to the east under the Bay.25 CASE certainly never argued that CCS water would affect Biscayne Bay.

Thus, the scope of the CASE contention should exclude impacts to Biscayne Bay.

B. Need for Monitoring The CASE Statement also devotes a considerable amount of attention to the alleged failure of the EA to properly address monitoring, including several pages of emails from Miami-Dade County representatives.26 The CASE Petition and the admitted contention do not include consideration of this issue.

C. Impact of Algae Remediation on Crocodiles The CASE Statement alleges that the EA failed to properly consider the impacts of copper sulfate on crocodiles.27 Although this claim was raised in CASEs original petition, the Board expressly rejected this allegation because the EA does, in fact, discuss this issue.28 23 See, e.g., CASE Statement at 8-9, 81.

24 At the prehearing conference, Mr. White engaged in a lengthy discussion with Judge Kennedy regarding the results of FPL monitoring wells at location TPGW-10, shown in slide 8 to CASE Petition Exhibit 1. See Tr. at 109-115, discussing CASE Pet. Ex. 1 at 8. As demonstrated in that slide and in Mr. Whites discussion, the slide represents three wells at various depths in the ground near the Biscayne Bay shoreline, with the higher values of the dense hypersaline water in the deepest part of the aquifer as would be expected. None of these groundwater readings involved measurements in the Bay itself. See also Pet. Ex. 1 at 7 and 9 (providing contours based on deep well tritium results) (emphasis added).

25 CASE Petition at 13 (emphasis added).

26 CASE Statement at 35-43.

27 Id. at 43.

28 See Pet. at 15; LBP-15-13 (slip op. at 26-27).

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D. Bacchus Paper CASE excerpts the Abstract from a paper by Dr. Sydney Bacchus, entitled Knowledge of Ground Water Responses - Critical Factor in Saving Florida's Threatened and Endangered Species Part I: Marine Ecological Disturbances.29 This paper discusses impacts to marine resources from activities such as the underground injection of wastewater, aquifer storage and recovery, and mining and impacts related to disease, pathogens, antagonistic evolution and endocrine disruptors. CASE raised none of these issues in its Petition and none was admitted by the Board as part of Contention 1.

E. General NEPA Considerations Finally, CASE devotes a large section of its Statement to a discussion of general NEPA principles not presented in its Petition.30 Among other out-of-scope issues, CASE discusses the NRCs considerations of alternatives, evaluation of unresolved conflicts, consultation with other agencies, and the speed with which the NRC completed its review. None of these issues were raised by CASE or admitted by the Board.

F. Identification of Beyond-Scope Arguments Table 2 provides a page-by-page identification of these beyond-scope arguments.

Because these arguments were not included in Contention 1 as admitted, the Board should strike them as irrelevant.

29 CASE Statement at 33-35; Attachment 1 at 26-28.

30 CASE Statement at 58-82.

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Table 2 CASE Arguments and Exhibits Addressing Matters Beyond the Scope of Contention 1 Beginning Location Ending Location Description of Beyond-Scope Argument CASE Statement Top of page 8 Top of Page 9 Email regarding fish habitat in Biscayne Bay (In one email) (...temperature of 35C)

Bottom of page 33 Middle of Page 35 Bacchus Report on impact on endangered (Perhaps the (Industrial Waste species due to groundwater alterations with strongest) Facility (IWF).) respect to pathogens, underground injection, endocrine disruptors, and microbes.

Bottom of Page 35 Middle of Page 37 Discussion of need for NRC to require (Monitoring) (could be additional monitoring monitored.)

Beginning of Page Middle of Page 38 Alvear email regarding cormorants 38 (regularly monitored)

Beginning of Page End of Page 41 Otero email regarding TKN (Total Kjeldahl 41 Nitrogen);

Grossenbacher email regarding crocodiles Bottom of Page 42 Top of page 43 Hefty memorandum to Coram regarding (November 26, (emphasis added) sampling for trace metals and nutrients 2014)

Top of page 43 Bottom of page 43 Allegation that the NRC fails to discuss (As the citations (specifically that it impacts of copper sulfate on crocodiles does.)

Top of Page 46 Middle of Page 50 Discussion of crocodiles and wildlife, (Crocodiles and (as a regulatory including emails wildlife in the CCS) action?)

Bottom of Page 61 Middle of Page 64 Discussion of NRC consultation with other (NEPA: (FPL statements agencies, including US Fish and Wildlife Consultation with accepted as fact.) Service Other Agencies)

Bottom of Page 64 Middle of Page 65 Discussion of whether the EA addressed NEPA: Health and ( did not consider health and welfare Welfare of Man) these concerns.)

Middle of Page 65 End of Page 69; Discussion of alternatives and grid (NEPA: Consider continuing at beginning reliability/shutting down reactors, including Alterative Actions) of Page 71 to the Gunderson and Hoeg emails.

middle of Page 72 (be asked.)

Bottom of Page 73 Middle of Page 75 Discussion of conflicts over resources (NEPA: Unresolved (resource like Conflicts Over freshwater.)

Resources) 11

Beginning Location Ending Location Description of Beyond-Scope Argument Middle of Page 75 End of page 76 Argument that the administration of the (NEPA: Major Cooling Canals is a major federal action Federal Actions)

Beginning of page Middle of page 81 Discussion of impact on Biscayne Bay 81 (.2014 EA.)

Bottom of Page 81 Middle of page 82 Discussion of the speed of the NRC Staffs (Speed of the 2014 (18 day EA) review EA)

Bottom of Page 18 Top of Page 20 McNeil Report on underground injection of (Dr. Donald (Sierra Club - effluents into the Boulder Zone of the Lower McNeil) Miami Group. 30 p.) Floridan Aquifer Bottom of Page 24 Middle of Page 25 Blog post discussing impact on crocodiles (Turkey Point Unit (see the real n) 1 Eco System)

Bottom of page 25 End of page 25 Discussion of Biscayne Bay estuary (The National Park website states Beginning of page Bottom of page 28 Bacchus Report on impacts to marine species 26 (Endeditableow_ from underground effluent injection, aquifer ThesespageEndedita storage and recovery, and mining bleow_ThesespageGrid Reliability)

Bottom of Page 28 End of Page 28 Thesis addressing impacts to mangroves and (Tara Dolan study) habitats IV. CONCLUSION For the foregoing reasons, significant portions of the cited references in the CASE Statement and Attachment 1 should be stricken because they were not properly included in the record as exhibits. Further, no portion of the CASE Statement or any of its technical attachments should be considered as evidence because they were not sponsored by an expert.31 Finally, any argument or exhibit that addresses issues beyond the scope of CASE Contention 1 as pled and admitted, should be stricken. In the alternative, FPL moves the Board to limit these materials by excluding them from evidence.

31 With the exception of CASE Attachments 4, 5, and 6, as noted above.

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V. CERTIFICATION I certify that I have made a sincere effort to contact the other parties in this proceeding, to explain to them the factual and legal issues raised in this motion, and to resolve those issues, and I certify that my efforts have been unsuccessful. Counsel for the NRC Staff does not oppose the motion.

Respectfully Submitted, Signed (electronically) by Steven Hamrick Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 William S. Blair Erin Walkowiak Florida Power & Light Company 700 Universe Blvd.

Juno Beach, Florida 33408 william.blair@fpl.com erin.walkowiak@fpl.com 561-304-5238 October 19, 2015 COUNSEL FOR FLORIDA POWER & LIGHT COMPANY 13

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

Florida Power & Light Company ) Docket No. 50-250-LA

) 50-251-LA (Turkey Point Units 3 and 4) )

) ASLBP No. 15-935-02-LA-BD01 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Florida Power & Light Companys Motion to Strike Portions of CASEs Initial Statement of Position, Testimony, Affidavits and Exhibits or, in the Alternative, Motion in Limine to Exclude it and its Cited Documents from Evidence, were provided to the Electronic Information Exchange for service to those individuals listed below and others on the service list in this proceeding, and via e-mail to those marked with an asterisk.

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Mail Stop: T-3F23 Mail Stop: O-15D21 Washington, DC 20555-0001 Washington, DC 20555-0001 Michael M. Gibson, Chair Brian Harris, Esq.

Dr. William W. Sager David Roth, Esq.

Dr. Michael F. Kennedy Catherine Kanatas, Esq.

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Office of the Secretary of the Commission Mail Stop: O-16C1 Mail Stop: O-16C1 Washington, DC 20555-0001 Washington, DC 20555-0001 OCAA Mail Center Hearing Docket Barry White*

Citizens Allied for Safe Energy, Inc.

1001 SW 129 Terrace Miami, FL 33176

Signed (electronically) by, Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 Dated at Washington, DC this 19th day of October, 2015 2