|
---|
Category:Legal-Motion
MONTHYEARML24129A2202024-05-0808 May 2024 Miami Waterkeepers Motion to Admit Amended and New Contentions in Response to NRC Staffs Final Site-Specific Environmental Impact Statement ML24116A2602024-04-25025 April 2024 Florida Power and Light Companys Answer Opposing Miami Waterkeepers Third Extension Request ML24115A1932024-04-24024 April 2024 Motion for Extension of Time to File New Contention Based on GAO-24-106326 Submitted by Miami Waterkeeper ML24095A3142024-04-0404 April 2024 Joint Unopposed Motion to Dismiss Reformulated Contention 1 as Moot and Position of the NRC Staff and Miami Waterkeeper Regarding Opportunity to File New or Amended Contentions ML24082A0842024-03-22022 March 2024 Joint Motion Regarding Hearing Schedule, Mandatory Disclosures, and Hearing File Obligations ML24032A2192024-02-0101 February 2024 Unopposed Motion for Leave to File Amended Response in Opposition to FPLs Motion to Strike Portions of Miami Waterkeepers Reply ML24018A2242024-01-18018 January 2024 Florida Power and Light Companys Motion to Strike Portions of the Reply Filed by Miami Waterkeeper ML23349A2012023-12-15015 December 2023 Motion for Extension of Time to File Reply Submitted by Miami Waterkeeper ML20318A0242020-11-11011 November 2020 11-11-20 Petitioners Motion to Supplement Joint Appendix (DC Cir.)(Case No. 20-1026) ML20280A5542020-10-0505 October 2020 10-5-20 Petitioners Unopposed Motion for Extension (DC Cir.)(Case No. 20-1026) ML20224A0202020-08-0606 August 2020 8-6-20 Respondents Unopposed Motion for Extension of Time to File Brief (DC Cir.)(Case No. 20-1026) ML20086H0252020-03-25025 March 2020 Respondents Unopposed Motion to Dispense with Paper Copies (DC Cir.)(Case No. 20-1026) ML20084K0622020-03-23023 March 2020 3-23-20 Respondents Motion to Dismiss (Including Addendum and Exhibits) (D.C. Cir. )(Case No. 20-1026) ML20043D1402020-02-11011 February 2020 2-11-20 Florida Power and Light Company Unopposed Motion for Intervention (DC Cir.)(Case No. 20-1026) ML19357A2632019-12-23023 December 2019 Reply of Friends of the Earth, Natural Resources Defense Council, and Miami Waterkeeper in Support of Petition for Review of the Atomic Safety and Licensing Boards Rulings in LBP-19-08 ML19207C0922019-07-26026 July 2019 Reply in Support of Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement ML19207C0952019-07-26026 July 2019 Reply of Natural Resources Defense Council, Friends of the Earth, & Miami Waterkeeper in Support of Petition for Waiver of 10 C.F.R. 51.53(C)(3) & 51.71(D) & 10 C.F.R. Part 51, Subpart a, Appendix B as Applied to Application . ML19200A2292019-07-19019 July 2019 Intervenors Motion to Extend Time to Appeal Dismissal of Contentions ML19179A3162019-06-28028 June 2019 Natural Resources Defense Councils, Friends of the Earths, and Miami Waterkeepers Amended Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement ML19175A3072019-06-24024 June 2019 Natural Resources Defense Councils, Friends of the Earths, and Miami Waterkeepers Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement ML19175A3092019-06-24024 June 2019 Expert Report of James Fourqurean ML19175A3102019-06-24024 June 2019 Expert Report of William Nuttle ML19015A3172019-01-15015 January 2019 Petitioners Response to Applicants New Arguments on the Admissibility of Petitioners Cooling Tower Contentions ML19015A3162019-01-15015 January 2019 Petitioners Motion for Leave to Respond to Applicants Response to the NRC Staffs Clarification Regarding the Admissibility of Proposed Cooling Tower Contentions ML18263A2052018-09-20020 September 2018 Monroe County, Floridas Request to Participate as Interested Governmental Participant ML18172A2432018-06-21021 June 2018 Certificate of Service ML18172A2422018-06-21021 June 2018 Notices of Appearance for Sherwin E. Turk and Jeremy L. Wachutka ML18172A2412018-06-21021 June 2018 NRC Staffs Answer to Southern Alliance for Clean Energys Motion for Extension of Time to File Petitions to Intervene and Requests for Hearing ML18023B5822018-01-23023 January 2018 NRC Staff Motion to Reopen the Record to File Corrected Exhibit NRC-005-R ML18019A1472018-01-19019 January 2018 Notice of Withdrawal of William Blair ML18019A1432018-01-19019 January 2018 Notice of Withdrawal of William Blair ML16273A5672016-09-29029 September 2016 Joint Motion to Govern Proceedings (DC Cir. No. 16-1108) 9-29-16 ML16273A0842016-09-29029 September 2016 Case Inquiry Regarding Final Decision ML16179A4092016-06-27027 June 2016 Citizens Allied for Safe Energy Petition for Review ML16067A2712016-03-0707 March 2016 NRC Staff'S Motion in Response to the Board'S Order (Taking Official Notice and Ordering Briefing) ML16067A3702016-03-0707 March 2016 Florida Power & Lights Motion to Controvert Officially Noticed Recommended Order ML16040A3462016-02-0909 February 2016 Case Statement on Transcript Corrections ML15343A3542015-12-0909 December 2015 Case Second Motion Requesting Subpoenas for Expert Witnesses for January 2016 ML15337A4222015-12-0303 December 2015 FPL Motion to Dismiss Case Contention 1 and for Summary Disposition ML15337A4232015-12-0303 December 2015 FPL Statement of Material Facts on Which No Genuine Dispute Exists ML15307A4702015-11-0303 November 2015 Case Motion Requesting Subpoenas for Expert Witnesses for January 2016 Evidentiary Hearing ML15292A5642015-10-19019 October 2015 FPL Motion to Strike Portions of Cases Initial Statement ML15100A1792015-04-10010 April 2015 Corrected Notice of Appearance for Daniel Davis Straus ML15100A1302015-04-10010 April 2015 Notice of Appearance for Daniel Straus ML15085A5552015-03-26026 March 2015 Joint Motion Regarding Mandatory Disclosures ML0827008772008-09-26026 September 2008 FPLs Motion to Strike Saporitos Reply and for Sanctions ML18088A5371979-03-28028 March 1979 Motion for Antitrust Hearing ML18088A5491978-08-28028 August 1978 Answer of the Department of Justice to Florida Power & Light Companys Motion for Recall of Order in Light of Changed Circumstances ML18088A5551978-08-18018 August 1978 Motion for Recall of Order in Light of Changed Circumstances ML18305A6891977-12-22022 December 1977 Transmittal of Documents Referred to in Florida Cities Motion to Lodge Documents 2024-05-08
[Table view] |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY
)
In the Matter of
)
Florida Power and Light Company
) Docket Nos. 50-250/251 - SLR Turkey Point Units 3 and 4
)
_____________________________________)
MONROE COUNTY, FLORIDAS REQUEST TO PARTICIPATE AS INTERESTED GOVERNMENTAL PARTICIPANT Pursuant to 10 C.F.R. § 2.315(c) and the hearing notice published by the U.S. Nuclear Regulatory Commission (NRC or Commission) at 83 Fed. Reg. 19,304 (May 2, 2018),
Monroe County, Florida hereby requests leave to participate in this proceeding as an Interested Governmental Participant (IGP).
Interests of Monroe County The Turkey Point nuclear power plant operated by Florida Power and Light (FPL) is located in southeast Miami-Dade County, adjacent to Biscayne Bay. Monroe County borders Miami-Dade County to the South. It comprises the fabulous but fragile Florida Keys, an island chain that stretches from the Florida Everglades to the Dry Tortugas and encompasses the Florida Keys National Marine Sanctuary, three national parks (Biscayne National Park, Everglades National Park, Dry Tortugas National Park), four National Wildlife Refuges, and three State Aquatic Preserves. Monroe County has also been designated as an Area of Critical State Concern by the Florida Legislature.
The primary concern of Monroe County relates to FPLs operation of the cooling canal system (CCS) to cool the reactors for Units 3 and 4, and the hypersaline plume that has developed in the Biscayne Aquifer and is migrating westward. Monroe County depends on the Biscayne
Aquifer as the source of its drinking water, which is supplied by the Florida Keys Aqueduct Authority (FKAA). Contaminants in the plume and the groundwater generated by the Turkey Point plant include phosphorous, ammonia, TKN, total nitrogen, radioactive tritium, and chlorophyll a. The plume has migrated more than two miles beyond FPLs property and contaminated a larger portion of the Biscayne Aquifer. The plume has also forced the freshwater-saltwater interface within the Biscayne Aquifer as much as four miles westward, which is farther than would otherwise naturally occur. As reported by the FKAA in the agencys June 7, 2018, letter to the NRC, [i]f the FKAA drinking water wellfield, which is located approximately ten miles from the Turkey Point Facility, becomes contaminated by the hypersaline plume created by FPL, the primary drinking water supply to Monroe County is lost.
Monroe County is also concerned about the impacts of the Turkey Point plant on the environmentally sensitive Biscayne Bay, a portion of which falls within the jurisdictional limits of the County. As reported by the National Park Service (NPS) in its June 22, 2018, letter to the NRC, groundwater tritium data and subsurface conductivity confirms that the CCS... is not a closed system and has: 1) connectivity with the Biscayne Bay and nearby wetlands, and 2) a subterranean hyper-saline plume that underlies both the Turkey Point facility and Biscayne NP.
The environmental impacts to Biscayne Bay, which shares ecological connections with other waters and resources of the Florida Keys, threaten the tourism and fishing industries on which Monroe Countys identity and economy are based.
Designation of Single Representative The Countys representative for purposes of this proceeding is the Monroe County Board of County Commissioners.
Identification of Contentions on Which the County Will Participate Monroe County seeks to participate on the two contentions raised by the Southern Alliance for Clean Energy in its Request for Hearing and Petition to Intervene, which include (1) that the FPL Environmental Report fails to adequately discuss the environmental impacts of using the CCS in violation of the National Environmental Policy Act (NEPA) and NRC implementing regulation 10 C.F.R. § 51.53(c); and, (2) that FPL has failed to consider the reasonable alternative of cooling the Turkey Point Units 3 and 4 reactors with mechanical draft cooling towers in violation of NEPA and 10 C.F.R. § 51.53(c)(2).
Respectfully submitted, Monroe County Attorneys Office 1111 12th Street, Suite 408 Key West, FL 33040 Telephone: (305) 292-3470 By:
/s/ Derek V. Howard Derek V. Howard Assistant Monroe County Attorney Florida Bar No.: 667641 Howard-Derek@monroecounty-fl.gov
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY
)
In the Matter of
)
Florida Power and Light Company
) Docket Nos. 50-250/251 - SLR Turkey Point Units 3 and 4
)
_____________________________________)
CERTIFICATE OF SERVICE I certify that on September 20, 2018, I posted copies of the foregoing Monroe County, Floridas Request to Participate as Interested Governmental Participant on the NRCs Electronic Information Exchange System.
/s/ Derek V. Howard Derek V. Howard Assistant Monroe County Attorney