Errata to Petitioners' Response to Applicant'S Surreply| ML18277A317 |
| Person / Time |
|---|
| Site: |
Turkey Point  |
|---|
| Issue date: |
10/04/2018 |
|---|
| From: |
Ayres R, Curran D, Fettus G, Rotenberg E, Rumelt K
Friends of the Earth, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Miami Waterkeeper, Natural Resources Defense Council, Super Law Group, Vermont Law School |
|---|
| To: |
Atomic Safety and Licensing Board Panel |
|---|
| SECY RAS |
| References |
|---|
| 50-250-SLR, 50-251-SLR, License Renewal, RAS 54537 |
| Download: ML18277A317 (4) |
|
|
|---|
Category:Legal-Pleading
MONTHYEARML24023A2072024-01-23023 January 2024
Miami Waterkeepers Response in Opposition to Florida Power & Light Companys Motion to Strike Portions of Miami Waterkeepers Reply
ML24008A2932024-01-0808 January 2024
Reply in Support of Request for Hearing and Petition to Intervene Submitted by Miami Waterkeeper
ML23356A1622023-12-22022 December 2023
NRC Staff Answer Opposing Miami Waterkeeper Hearing Request
ML23356A1562023-12-22022 December 2023
Florida Power and Light Company'S Answer Opposing Miami Waterkeeper'S Hearing Request and Petition for Leave to Intervene
ML23352A3282023-12-18018 December 2023
Florida Power and Light Company'S Answer Opposing Miami Waterkeeper'S Second Extension Request
ML23306A2862023-11-0202 November 2023
Answer in Opposition to Miami Waterkeeper Extension Request
ML22090A2482022-03-31031 March 2022
NRC Staff'S Response to Views on Practical Effects
ML22090A2102022-03-31031 March 2022
Florida Power and Light Company'S Response to Other Parties' Views on License Status as Requested in Commission Order CLI-22-02
ML22080A2722022-03-21021 March 2022
Superseded License
ML22080A2332022-03-21021 March 2022
Views on License Status as Requested in Commission Order CLI-22-02
ML22080A2702022-03-21021 March 2022
NRC Staff Views on the Practical Effects of (1) the Subsequent Renewed Licenses Continuing in Place and (2) the Previous Licenses Being Reinstated
ML22080A2712022-03-21021 March 2022
Turkey Pont, Unit 3, Superseded License
ML20043F4402020-02-12012 February 2020
Notice of Withdrawal of Martin J. O'Neill
ML19347D4582019-12-13013 December 2019
NRC Staff'S Brief in Response to Intervenors' Petition for Review of LBP-19-8
ML19347D0342019-12-13013 December 2019
Florida Power & Light Company'S Answer Opposing Friends of the Earth'S, Natural Resources Defense Council'S, and Miami Waterkeeper'S Petition for Review of LBP-19-8
ML19344D1332019-12-10010 December 2019
Notice of Appearance for Mary Frances Woods
ML19322D6232019-11-18018 November 2019
Friends of the Earth'S, Natural Resources Defense Council'S, and Miami Waterkeeper'S Petition for Review of the Atomic Safety and Licensing Board'S Ruling in LBP-19-08
ML19263D9092019-09-20020 September 2019
Reply of Friends of the Earth, Natural Resources Defense Council and Miami Waterkeeper in Support of Petition for Review of the Aslb'S Rulings in LBP-19-3 and LBP-19-06
ML19253E1182019-09-10010 September 2019
Florida Power and Light Company'S Answer Opposing Intervenors' Petition for Review of LBP-19-3 and LBP-19-6
ML19253E0512019-09-10010 September 2019
NRC Staff Answer to Petition for Review of LBP-19-3 and LBP-19-6
ML19226A3842019-08-14014 August 2019
Corrected Intervenors' Opposition to Florida Power & Light Co., Motion to Strike Intervenors' Reply to Fpl'S and NRC Staff'S Answer to Intervenors' Waiver Petition
ML19221B6772019-08-0909 August 2019
Friends of the Earth'S, Natural Resources Defense Council'S, and Miami Waterkeeper'S Petition for Review of the Atomic Safety and Licensing Board'S Rulings in LBP-19-3 and LBP-19-06
ML19221B6732019-08-0909 August 2019
Intervenors' Opposition to Florida Power & Light Company'S Motion to Strike Intervenors' Reply to Fpl'S and NRC Staff'S Answer to Intervenors' Waiver Petition
ML19214A0872019-08-0202 August 2019
Florida Power & Light Company'S Motion to Strike Intervenors' Reply to Fpl'S and NRC Staff'S Answers to Their Waiver Petition
ML19203A3502019-07-22022 July 2019
Errata to NRC Staff'S Answer to Joint Intervenors' (1) Amended Motion to Migrate or Amend Contentions 1E and 5E and to Admit Four New Contentions, and (2) Petition for Waiver.
ML19200A2972019-07-19019 July 2019
Florida Power & Light Company'S Answer Opposing Intervenors' Motion to Migrate or Amend Contentions 1-E and 5-E and to Admit New Contentions 6-E, 7-E, 8-E, and 9-E
ML19200A3002019-07-19019 July 2019
NRC Staff'S Answer to Joint Intervenors' (1) Amended Motion to Migrate or Amend Contentions 1-E and 5-E and to Admit Four New Contentions, and (2) Petition for Waiver
ML19200A2982019-07-19019 July 2019
Florida Power & Light Company'S Answer to Intervenors' Petition for Waiver of Certain 10 C.F.R. Part 51 Regulations
ML19179A3132019-06-28028 June 2019
Errata to Natural Resources Defense Council'S, Friends of the Earth'S, and Miami Waterkeeper'S Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staff'S Supplemental Draft Environmental Impact Statement
ML19175A3112019-06-24024 June 2019
Natural Resources Defense Council'S, Friends of the Earth'S, and Miami Waterkeeper'S Petition for Waiver of 10 CFR 51.53(C)(3) and 51.71(D) and 10 CFR Part 51, Subpart a, Appendix B
ML19175A3122019-06-24024 June 2019
Declaration of Kenneth Rumelt in Support of Waiver Petition
ML19161A3602019-06-10010 June 2019
Joint Petitioners' Answer Opposing Fpl'S Motion to Dismiss Joint Petitioners' Contention 1-E as Moot
ML19161A2522019-06-10010 June 2019
NRC Staff'S Answer to Fpl'S Motions to Dismiss
ML19161A3612019-06-10010 June 2019
Joint Petitioners' Answer Opposing Fpl'S Motion to Dismiss Joint Petitioners' Contention 5-E as Moot
ML19140A3562019-05-20020 May 2019
Fpl'S Motion to Dismiss Joint Petitioners' Contention 5-E as Moot
ML19140A3552019-05-20020 May 2019
Fpl'S Motion to Dismiss Joint Petitioners' Contention 1-E as Moot
ML19130A1632019-05-10010 May 2019
Intervenors' Initial Mandatory Disclosure Report Under 10 C.F.R. 2.336
ML19116A2722019-04-26026 April 2019
NRC Staff'S Brief in Response to Florida Power and Light Company Appeal
ML19099A3142019-04-0909 April 2019
Sace Notice of Withdrawal
ML19091A3022019-04-0101 April 2019
FPL Notice of Appeal and Brief in Support of Appeal of LBP-19-3
ML19087A3072019-03-28028 March 2019
FPL Answer Opposing Intervenors' Joint Motion for Partial Reconsideration of Initial Scheduling Order
ML19085A3312019-03-26026 March 2019
Intervenors' Joint Motion for Partial Reconsideration of Initial Scheduling Order
ML19078A3022019-03-19019 March 2019
Joint Motion Regarding Hearing Schedule, Mandatory Disclosures, and Hearing File Obligations
ML19025A2732019-01-25025 January 2019
NRC Staff'S Answer to Petitioners' Motion for Leave to Respond to Applicant'S Response to the NRC Staff'S Clarification
ML19022A0262019-01-22022 January 2019
Applicant'S Answer to Petitioners' Joint Motion for Leave to Respond to Applicant'S Response to the NRC Staff'S Clarification
ML19007A3112019-01-0707 January 2019
Applicant'S Response to NRC Staff'S Clarification Regarding the Admissibility of Proposed Cooling Tower Contentions
ML19007A2662019-01-0707 January 2019
Petitioners' Response to NRC Staff Clarification
ML18354B1462018-12-20020 December 2018
Joint Motion for Correction of the Transcript of the Oral Argument Held on December 4, 2018
ML18352B2102018-12-18018 December 2018
NRC Staff'S Clarification of Its Views Regarding the Admissibility of Joint Petitioners' Contention 1-E and Sace Contention 2 (Alternative Cooling Systems)
ML18306A9552018-11-0202 November 2018
NRC Staff'S Response to the Applicant'S Surreply and the Petitioners' Response, Regarding the Applicability of 10 C.F.R. 51.53(c)(3) to Subsequent License Renewal Applications
2024-01-08
[Table view] |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
_____________________________________
)
In the Matter of )
Florida Power and Light Company ) Docket Nos. 50-250/251-SLR Turkey Point Units 3 and 4 )
_____________________________________)
ERRATA TO PETITIONERS RESPONSE TO APPLICANTS SURREPLY Petitioners, Southern Alliance for Clean Energy, Friends of the Earth, Natural Resources Defense Council, and Miami Waterkeeper, hereby submit the following list of errata to Petitioners Response to Applicants Surreply (Oct. 1, 2018):
Page Line Change Cover Insert Filed before October 1, 2018 Cover Insert CORRECTED October 4, 2018) after October 1, 2018 Tables of Contents and Authorities Insert page numbers 3 6 Delete do not after applicants that Respectfully submitted,
___/signed electronically by/__
Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com Counsel to SACE
___/signed electronically by/__
Richard Ayres 2923 Foxhall Road, N.W.
Washington, D.C. 20016 202-744-6930 ayresr@ayreslawgroup.com Counsel to Friends of the Earth
___/signed electronically by/__
Geoffrey H. Fettus NATURAL RESOURCES DEFENSE COUNCIL 1152 I Street, N.W., Suite 300 Washington, D.C. 20005 202-289-2371 gfettus@nrdc.org Counsel to Natural Resources Defense Council
___/signed electronically by/__
Professor Ken Rumelt Vermont Law School 164 Chelsea Street, PO Box 96 South Royalton, VT 05068 802-831-1000 krumelt@vermontlaw.edu Counsel to Friends of the Earth
___/signed electronically by/__
Edan Rotenberg SUPER LAW GROUP, LLC 180 Maiden Lane, Suite 603 New York, N.Y. 10038 212-242-2355, Ext. 2 edan@superlawgroup.com Counsel to Miami Waterkeeper October 4, 2018 CERTIFICATE OF COUNSEL 2
Pursuant to 10 C.F.R. § 2.323(b), I certify that on August 28, 2018, I consulted counsel for FPL and the NRC Staff in a sincere effort to resolve the issues raised by this motion. Counsel for FPL stated that FPL takes no position on the motion. Counsel for the NRC Staff stated that the Staff does not oppose the motion.
___/signed electronically by/__
Diane Curran 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
_____________________________________
)
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 August 28, 2018, I posted copies of the foregoing UNOPPOSED MOTION BY SOUTHERN ALLIANCE FOR CLEAN ENERGY, FRIENDS OF THE EARTH, NATURAL RESOURCES DEFENSE COUNCIL, AND MIAMI WATERKEEPER FOR EXTENSION OF REPLY DEADLINE on the NRCs Electronic Information Exchange System.
___/signed electronically by/__
Diane Curran 4