ML19151A607
| ML19151A607 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/31/2019 |
| From: | Ayres R, Cox K, Fettus G, Reiser C, Rumelt K Friends of the Earth, Miami Waterkeeper, Natural Resources Defense Council |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-250-SLR, 50-251-SLR, ASLBP 18-957-01-SLR-BD01, RAS 55013 | |
| Download: ML19151A607 (3) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) ) Docket Nos. 50-250-SLR & 50-251-SLR FLORIDA POWER & LIGHT COMPANY ) (Turkey Point Units 3 and 4) ) May 31, 2019 )
INTERVENORS' MANDATORY DISCLOSURE REPORT UNDER 10 C.F.R. § 2.336 Pursuant to 10 C.F.R. § 2.336, and the Licensing Board's Initial Scheduling Order dated March 21, 2019 and Order dated April 2, 2019, Intervenors Friends of the Earth, Inc., Natural Resources Defense Council, Inc., and Miami Waterkeeper, Inc. (collectively, Intervenors), by and through counsel, make the following disclosures with respect to the admitted contentions:
1.Testifying Witnesses. Intervenors have not yet identified the persons whom they propose to have testify as witnesses with respect to the admitted contentions. As required by 10 C.F.R. § 2.336, Intervenors will supplement this disclosure once testifying witnesses are identified.
2.Documents and Data Collections. Petitioners currently do not have additional documents or data collections to disclose.
3.Tangible Things. Intervenors do not have any tangible things to disclose.
4.Privileged Documents. At this time, Intervenors are not aware of any documents in their possession, relevant to the contentions, that would otherwise be required to be disclosed for which a claim of privilege or protected status is being made.
5.Certification under 2.336(c). Pursuant to Section 2.336(c), the foregoing disclosures constitute all relevant materials required by such section to have been disclosed, and the disclosures are accurate and complete as of this date.
Respectfully submitted, /s/ Richard Ayres Richard E. Ayres Ayres Law Group 2923 Foxhall Road, N.W. Washington, D.C. 20016 202-722-6930 ayresr@ayreslawgroup.com Counsel for Friends of the Earth /s/ Geoffrey H. Fettus Geoffrey Fettus /s/ Caroline Reiser Caroline Reiser Natural Resources Defense Council 1152 15 th Street, NW, Suite 300 Washington, DC 20005 202-289-2371 gfettus@nrdc.org creiser@nrdc.org Counsel for Natural Resources Defense Council
/s/ Ken Rumelt Kenneth J. Rumelt Environmental & Natural Resources Law Clinic Vermont Law School 164 Chelsea Street, PO Box 96 South Royalton, VT 05068 802-831-1031 krumelt@vermontlaw.edu Counsel for Friends of the Earth
/s/ Kelly Cox Kelly Cox Miami Waterkeeper 2103 Coral Way 2nd Floor Miami, FL 33145 305-905-0856 kelly@miamiwaterkeeper.org Counsel for Miami Waterkeeper May 31, 2019 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Intervenors' Mandatory Disclosure Report in the above-captioned proceeding were served via the Electronic Information Exchange (EIE) on the 31st day of May 2019, which to the best of my knowledge resulted in transmittal of same to those on the EIE Service List for the captioned proceeding.
/s/ Ken Rumelt
May 31, 2019