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| ML19179A313 |
| Person / Time |
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| Site: |
Turkey Point  |
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| Issue date: |
06/28/2019 |
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| From: |
Ayres R, Cox K, Fettus G, Reiser C, Rumelt K
Ayres Law Group, Environmental & Natural Resources Law Clinic, Friends of the Earth, Miami Waterkeeper, Natural Resources Defense Council, Vermont Law School |
|---|
| To: |
Atomic Safety and Licensing Board Panel |
|---|
| SECY RAS |
| Shared Package |
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| ML19179A312 |
List: |
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| References |
|---|
| 50-250-SLR, 50-251-SLR, ASLBP 18-957-01-SLR-BD01, RAS 55066 |
| Download: ML19179A313 (5) |
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[Table view] |
Text
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
) Docket No. 50-251 (Turkey Point Nuclear Generating Station, Unit Nos. 3 )
and 4) ) June 28, 2019
)
ERRATA TO 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 On June 24, 2019, Natural Resources Defense Council, Friends of the Earth, and Miami Waterkeeper (together Intervenors) submitted their Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement. Along with this Motion, Intervenors submitted three expert reports. On June 26, 2019, Intervenors were notified that the Declaration of E.J. Wexler contained links to three proprietary documents even though the declaration was filed as public.1 To address this discrepancy, Intervenors today file a revised version of the Declaration of E.J. Wexler with the pages containing the links to the proprietary documents removed.
It has also come to Intervenors attention that a document referenced in the Expert Report of Dr. William Nuttle as Exhibit B in error failed to be included. To correct the error, Intervenors today file a revised version of the Expert Report of Dr. William Nuttle with Exhibit 1
The three documents are: Final Report, Simulation of Groundwater Flow and Saltwater Movement in the Vicinity of the Atlantic Civil Property South Miami-Dade County, FL, Prepared for: US Army Corps of Engineers in Support of Application Number SAJ-1995-6797 (mining) (Jan. 30, 2012); Technical Appendix A, Additional Groundwater Flow and Saltwater/Freshwater Interface Modeling for the Atlantic Civil Property South Miami-Dade County, FL, Prepared for EAS Engineering, Inc. (Mar. 25, 2014); and Review of the FPL Three-Dimensional Groundwater Flow and Saltwater Transport Model, Prepared for: Lewis, Longman, and Walker, P.A. & EAS Engineering, Inc. (June 5, 2016).
B included. The newly included Exhibit B contains Dr. Nuttles resume to support his qualifications as an expert in this matter.
Finally, Joint Intervenors also submit the following errata for the text of the Motion.
These corrections have been made to a corrected version of the Motion, which was also filed today.
Page Line Correction Passim Passim Replace SMALL with small and MODERATE with moderate (unless within a quotation) 9 3 Replace Per with Under 10 5 Replace cooling water system with cooling tower 11 6 Replace to rigorously explore with to explore vigorously 11 10 Replace water system with tower 11 11 Replace water system with tower 11 12 Replace plays with pays 12 1 Replace water system with tower 12 8 Insert a hyphen between special and status 13 16 Replace a range threatened with range-threatened 13 18 Replace them with it 13 22 Replace adequately consider with consider adequately 14 4 Replace regards with regard 14 12 Replace to rigorously and objectively evaluate with to evaluate rigorously and objectively 14 13 Replace to adequately analyze with to analyze adequately 15 5 Replace Units with units
16 1 Replace claims with claimed 16 5 Replace addressed with eliminated 16 14 Replace on with of 16 15 Replace should cooling towers be built with if cooling towers were built 16 16-17 Replace to adequately analyze with to analyze adequately 21 17 Replace Per with Under 25 18 Insert request after waiver 26-36 passim Replace MDC with Miami-Dade County 29-30 passim Replace P with phosphorus 29-30 passim Replace N with nitrogen 36 11 Insert a quotation mark after Startup Report 38 13 Replace no with not 40 19 Replace they have with it has 44 3 Replace are not and will not reach with are not reaching, and will not reach Respectfully submitted,
/s/ Ken Rumelt /s/ Geoffrey Fettus Kenneth J. Rumelt Geoffrey Fettus Environmental & Natural Resources /s/ Caroline Reiser Law Clinic Caroline Reiser Vermont Law School Natural Resources Defense Council 164 Chelsea Street, PO Box 96 1152 15th Street, NW, Suite 300 South Royalton, VT 05068 Washington, DC 20005 802-831-1031 202-289-2371 krumelt@vermontlaw.edu gfettus@nrdc.org Counsel for Friends of the Earth creiser@nrdc.org Counsel for Natural Resources Defense Council
/s/ Richard Ayres /s/ Kelly Cox Richard E. Ayres Kelly Cox Ayres Law Group Miami Waterkeeper 2923 Foxhall Road, N.W. 2103 Coral Way 2nd Floor Washington, D.C. 20016 Miami, FL 33145 202-722-6930 305-905-0856 ayresr@ayreslawgroup.com kelly@miamiwaterkeeper.org Counsel for Friends of the Earth Counsel for Miami Waterkeeper June 28, 2019
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
) Docket No. 50-251 (Turkey Point Nuclear Generating Station, Unit Nos. 3 )
and 4) ) June 26, 2019
)
(Subsequent License Renewal Application)
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, a copy of the foregoing Errata to Natural Resources Defense Councils, Friends of the Earths, and Miami Waterkeerpers Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement was served upon the Electronic Information Exchange (EIE, the NRCs E-Filing System), in the above-captioned docket, which to the best of my knowledge resulted in transmittal of same to those on the EIE Service List for the captioned proceeding.
/Signed (electronically) by/
Caroline Reiser Natural Resources Defense Council 1152 15th Street, N.W., Suite 300 Washington, D.C. 20005 (202) 717-2341 creiser@nrdc.org Counsel for NRDC June 26, 2019