ML19179A318

Intervenors' Mandatory Disclosure Report

ML19179A318
Person / Time
Site:	Turkey Point
Issue date:	06/28/2019
From:	Ayres R, Cox K, Fettus G, Reiser C 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
ML19179A317	List: ML19179A318 ML19179A320 ML19179A322
References
50-250-SLR, 50-251-SLR, ASLBP 18-957-01-SLR-BD01, RAS 55067
Download: ML19179A318 (4)

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

)

INTERVENORS MANDATORY DISCLOSURE REPORT UNDER 10 C.F.R. § 2.336 Pursuant to 10 C.F.R. § 2.336, and the Licensing Boards 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 identified the following persons whom they propose to have testify as witnesses with respect to the admitted contentions:

a. E.J. Wexler, P.Eng (Ontario)

Earthfx Incorporated 3363 Yonge Street Toronto, Ontario Canada M4N 2M6 Tel: (416) 410-4260 Fax: (416) 481-6026

b. William Nuttle, PH.D, Peng (Ontario) 11 Craig Street Ottawa, Ontario Canada K1S 4B6 wknuttle@gmail.com

c. James Fourqurean, Ph.D.

Florida International University Modesto A. Maidique Campus 11200 SW 8th Street, CASE 450 Miami, FL 33199 OE 219; Labs VH 310 and 321 Tel: (305) 348-4084

The majority of analysis and authorities upon which these persons base their opinions have been submitted with [Intervenors] Motion to Migrate Contentions &

Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement (June 24, 2019). Under the Licensing Boards Initial Scheduling Order dated March 21, 2019, The parties are not required to identify or produce any document that has been served on all other parties to this proceeding. Intervenors attach four documents which these potential witnesses have reviewed but were not identified or included in the submitted motion.

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/ 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-SLR

) Docket No. 50-251-SLR (Turkey Point Nuclear Generating Station, Unit Nos. 3 )

and 4) ) June 28, 2019

)

CERTIFICATE OF SERVICE I certify that on June 28, 2019, I posted copies of the foregoing INTERVENORS MANDATORY DISCLOSURE REPORT UNDER 10 C.F.R. § 2.336 on NRCs Electronic Information Exchange System.

/signed electronically by/ Caroline Reiser