ML15300A177
| ML15300A177 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/27/2015 |
| From: | Hamrick S Florida Power & Light Co |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-250-LA, 50-251-LA, ASLBP 15-935-02-LA-BD01, RAS 28437 | |
| Download: ML15300A177 (9) | |
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-LA
) 50-251-LA (Turkey Point Units 3 and 4) )
) ASLBP No. 15-935-02-LA-BD01 FLORIDA POWER & LIGHT COMPANYS REVISION TO TABLES IN ITS OCTOBER 19, 2015 MOTION TO STRIKE On October 19, Florida Power & Light Company (FPL) filed a Motion to Strike Portions of CASEs Initial Statement of Position, Testimony, Affidavits and Exhibits or, in the Alternative, Motion in Limine to Exclude it and its Cited Documents From Evidence (Motion to Strike). Subsequently, on October 22 and 26, 2015 CASE refiled certain exhibits via the NRCs EIE system. The version of CASE Exhibit INT-001 submitted on October 22 differs from the version it originally submitted via email as Attachment 1. Most of the differences are relatively minor and reflect changes of font and justification, as well as the removal of certain embedded figures. However, CASE did move the two paragraphs that now come at the end of INT-001 from elsewhere within Attachment 1 and corrected the descriptions of other exhibits and its initial statement in those paragraphs.1 The version filed on October 26 included still further changes, chiefly consolidating references to documents together with the excerpts from those documents and other organizational improvements. For example, CASE deleted the 1
Compare INT-001 (October 22 version) at 24 (Slide 10 in the exhibit INT-002) with Attachment 1 at 12 (Slide 10 in the exhibit xxxx); compare INT-001 (October 22 version) at 24 (October 22 version)
(Illustration 3, Initial Statement, at 12,) with Attachment 1 at 13 (Attachment x).
1
heading usgs summary and conclusions from page 11.2 FPL notes that CASEs revisions to this document in the October 26 version are inconsistent with the Boards direction that CASE may not submit any new exhibits.3 Further, while neither the original Attachment 1 nor the first version of CASE Exhibit INT-001 included page numbers, the most recent version does include page numbers. The pagination in this version is significantly altered from that reflected in FPLs Motion due to the changes among the three versions of Exhibit INT-001. As a result, FPL is providing a modified version of Tables 1 and 2 from its Motion to Strike, reflecting the new identification number for Exhibit INT-001 and updating the page numbers accordingly based on the October 26 version.
The revisions to Tables 1 and 2 are identified in boldface and strikethrough below.
Table 1 Documents Improperly Referenced or Reproduced in the CASEs Submission Page # Document Identified in Mandatory Disclosures?
CASE Email from Dr. Christopher Kelble No Statement (CS) at 8-9 CS at 12-14 Origins and Delineation of Saltwater Intrusion in the Yes Biscayne Aquifer and Changes in the Distribution of Saltwater in Miami-Dade County, Florida CS at 15, Water, Water, Everywhere: Sea Level Rise in No INT-001 at MiamiUniversity of Miami Rosenstiel School Of Marine 6-7 and Atmospheric Science, Miami, http://www.rsmas.miami.edu/blog/2014/10/03/sea-level-rise-in-miami/
CS at 17-18, USGS Ground Water Atlas Of The United States Alabama, No 51, 77; INT- Florida, Georgia, South Carolina 001 at 17 2
Compare INT-001 (October 22 version) at 11 (usgs summary and conclusions.) with INT-001 (October 26 version) at 11.
3 Order (Requiring Proper Numbering of CASEs Exhibits), October 21, 2015 at 2.
2
Page # Document Identified in Mandatory Disclosures?
CS at 28-30 Letter from C. Espinosa to M. Harris, Application to No Renew Turkey Point Industrial Wastewater Facility Permit number Fzl0001582 CS at 32, 33 Florida Power and Light Company Docket No. 50-251 ADAMS Facility Operating License, License No. DPR-41 April; 10.
1973 ML013400438 CS at 33; Knowledge Of Ground Water Responses - Critical Factor in No INT-001 at Saving Florida's Threatened and Endangered Species Part I:
23-25 Marine Ecological Disturbances Sydney T. Bacchus Applied Environmental Services, P. O. Box 174, Athens, GA 30603; appliedenvirserv@mindspring.com https://www.nirs.org/nukerelapse/levy/exhf2bacchus.pd CS at 37 Email from G. Burzycki, Subject RE: FPL Cooling Canals No CS at 38 Email from E. Alvear, Subject Cormorant colony closest to No FPL cooling canals undergoing severe decline CS at 38-40 Email from L. Otero, Subject Uprate monitoring issues Yes CS at 41 Email from L. Otero, Subject CCS Surface Water TKN Yes CS at 41 Email from C. Grossenbacher, Subject FW:FPL Annual Yes Crocodile Report CS at 42 Email from L. Otero, Subject RE: Turkey Point Units 3&4 Yes Uprate Addendum - Tritium Attachments: 2014 Post Uprate Report MDC Draft Comments CS at 42 Memorandum from L. Hefty L. to P. Coram Yes CS at 47 Message from F. Mazzoti to J. Wrublik Yes CS at 47 Ecology and Conservation of the American Crocodile No (Crocodylus acutus) in Florida CS at 47-48 Message from M. Pearce to S. Scroggs Yes CS at 48 Statement of P. Stoddard No CS at 48-50 Comments of Miami-Dade County on Draft Environmental ADAMS Impact Statement for Turkey Point Units 6&7 CS at 56-57 Meeting Minutes of the South Florida Water Management No District CS at 63 July 25, 2014 NRC letter to the FWS the NRC requested ADAMS consultation on the subject EA (ADAMS Accession No. ML14206A800) 3
Page # Document Identified in Mandatory Disclosures?
CS at 67-68 Email from A. Gunderson No CS at 68-69 Email to T. Hoeg; Email from T. Hoeg No CS at 75 Environmental Review Guidance for Licensing Actions ADAMS Associated with NMSS Programs Division of Waste Management Office of Nuclear Material Safety and Safeguards (ML032450279)
CS at 79-80; Statement from National Park Service website No INT-001 at 22 INT-001 at What Is Saltwater Intrusion? Saltwater Intrusion of Coastal Yes 1-6 Aquifers in the U.S. James Spatafo Johnson State College Senior Seminar May 6, 2008T http://kanat.jsc.vsc.edu/student/spatafora/setup.htm INT-001 at http://www.rsmas.miami.edu/blog/2014/10/03/sea-level- No 6-7 rise-in-miami/ 4 INT-001 at Emergency Order No. 2015-034-DAOWU [PDF] - Yes 7 South www.sfwmd.gov/...sfwmd.../f INT-001 at Dolan Study No 7
INT-001 at Borehole geophysical logging for the Florida Power & Light No 8-9 Turkey Point Plant groundwater, surface water, and ecological monitoring plan INT-001 at Origins and Delineation of Saltwater Intrusion in the Yes 9-16 Biscayne Aquifer and Changes in the Distribution of Saltwater in Miami-Dade County, Florida5 AT1 at 14- usgs summary and conclusions No 18 INT-001 at McNeill, Donald F., 2000. A Review of Upward Migration No 17 of Effluent Related to Subsurface Injection at Miami-Dade Water and Sewer South District Plant.
INT-001 at Biological Assessment on the American Crocodile ADAMS 18-21 (Crocodylus acutus) Turkey Point Nuclear Generating Unit Nos. 3 and 4 Proposed License Amendment to Increase the 4
It is now apparent that the passage beginning An Attack from Below on page 6 of the October 26 version of INT-001 is a part of this blog post.
5 It is now apparent that the header usgs summary and conclusions in the previous versions did not refer to a separate document, but instead referred to parts of the Origins and Delineation of Saltwater Intrusion paper.
This heading was removed in the October 26 version of INT-001.
4
Page # Document Identified in Mandatory Disclosures?
Ultimate Heat Sink Temperature Limit July 2014 INT-001 at Hughes, J.D., Langevin, C.D., and Brakefield-Goswami, No 21 Linzy, 2010, Effect of hypersaline cooling canals on aquifer salinization: Hydrogeology Journal, v. 18, p. 25-38.
INT-001 at Turkey Point Unit 1 Eco System By Russ Finley On Mar 3, Yes 21-22 2015 with 14 Responses Table 2 CASE Arguments and Exhibits Addressing Matters Beyond the Scope of Contention 1 Beginning Location Ending Location Description of Beyond-Scope Argument CASE Statement Top of page 8 Top of Page 9 Email regarding fish habitat in Biscayne Bay (In one email) (...temperature of 35C)
Bottom of page 33 Middle of Page 35 Bacchus Report on impact on endangered (Perhaps the (Industrial Waste species due to groundwater alterations with strongest) Facility (IWF).) respect to pathogens, underground injection, endocrine disruptors, and microbes.
Bottom of Page 35 Middle of Page 37 Discussion of need for NRC to require (Monitoring) (could be additional monitoring monitored.)
Beginning of Page 38 Middle of Page 38 Alvear email regarding cormorants (regularly monitored)
Beginning of Page 41 End of Page 41 Otero email regarding TKN (Total Kjeldahl Nitrogen);
Grossenbacher email regarding crocodiles Bottom of Page 42 Top of page 43 Hefty memorandum to Coram regarding (November 26, (emphasis added) sampling for trace metals and nutrients 2014)
Top of page 43 Bottom of page 43 Allegation that the NRC fails to discuss (As the citations (specifically that it impacts of copper sulfate on crocodiles does.)
Top of Page 46 Middle of Page 50 Discussion of crocodiles and wildlife, (Crocodiles and (as a regulatory including emails wildlife in the CCS) action?)
Bottom of Page 61 Middle of Page 64 Discussion of NRC consultation with other (NEPA: Consultation (FPL statements agencies, including US Fish and Wildlife with Other Agencies) accepted as fact.) Service Bottom of Page 64 Middle of Page 65 Discussion of whether the EA addressed 5
Beginning Location Ending Location Description of Beyond-Scope Argument NEPA: Health and ( did not consider health and welfare Welfare of Man) these concerns.)
Middle of Page 65 End of Page 69; Discussion of alternatives and grid (NEPA: Consider continuing at beginning reliability/shutting down reactors, including Alterative Actions) of Page 71 to the Gunderson and Hoeg emails.
middle of Page 72 (be asked.)
Bottom of Page 73 Middle of Page 75 Discussion of conflicts over resources (NEPA: Unresolved (resource like Conflicts Over freshwater.)
Resources)
Middle of Page 75 End of page 76 Argument that the administration of the (NEPA: Major Cooling Canals is a major federal action Federal Actions)
Beginning of page 81 Middle of page 81 Discussion of impact on Biscayne Bay
(.2014 EA.)
Bottom of Page 81 Middle of page 82 Discussion of the speed of the NRC Staffs (Speed of the 2014 (18 day EA) review EA)
INT-001 Top of Page 17 Middle of Page 17 McNeil Report on underground injection of (McNeil, Donald (lateral travel.) effluents into the Boulder Zone of the Lower F.) Floridan Aquifer Middle of Page 21 Middle of Page 22 Blog post discussing impact on crocodiles (Turkey Point Unit 1 ( level playing Eco System) field.)
Middle of Page 22 End of Page 22 Discussion of Biscayne Bay estuary (The National Park website states Beginning of Page 23 End of Page 25 Bacchus Report on impacts to marine species from underground effluent injection, aquifer storage and recovery, and mining Bottom of Page 7 End of Page 7 Thesis addressing impacts to mangroves and (Tara Dolan study) habitats 6
Respectfully Submitted, Signed (electronically) by Steven Hamrick Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 William S. Blair Erin Walkowiak Florida Power & Light Company 700 Universe Blvd.
Juno Beach, Florida 33408 william.blair@fpl.com erin.walkowiak@fpl.com 561-304-5238 October 27, 2015 COUNSEL FOR FLORIDA POWER & LIGHT COMPANY 7
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-LA
) 50-251-LA (Turkey Point Units 3 and 4) )
) ASLBP No. 15-935-02-LA-BD01 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Florida Power & Light Companys Revision to Tables in its October 19, 2015 Motion to Strike, were provided to the Electronic Information Exchange for service to those individuals listed below and others on the service list in this proceeding, and via e-mail to those marked with an asterisk.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Mail Stop: T-3F23 Mail Stop: O-15D21 Washington, DC 20555-0001 Washington, DC 20555-0001 Michael M. Gibson, Chair Brian Harris, Esq.
Dr. William W. Sager David Roth, Esq.
Dr. Michael F. Kennedy Catherine Kanatas, Esq.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Office of the Secretary of the Commission Mail Stop: O-16C1 Mail Stop: O-16C1 Washington, DC 20555-0001 Washington, DC 20555-0001 OCAA Mail Center Hearing Docket Barry White*
Citizens Allied for Safe Energy, Inc.
1001 SW 129 Terrace Miami, FL 33176
Signed (electronically) by, Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 Dated at Washington, DC this 27th day of October, 2015 2
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-LA
) 50-251-LA (Turkey Point Units 3 and 4) )
) ASLBP No. 15-935-02-LA-BD01 FLORIDA POWER & LIGHT COMPANYS REVISION TO TABLES IN ITS OCTOBER 19, 2015 MOTION TO STRIKE On October 19, Florida Power & Light Company (FPL) filed a Motion to Strike Portions of CASEs Initial Statement of Position, Testimony, Affidavits and Exhibits or, in the Alternative, Motion in Limine to Exclude it and its Cited Documents From Evidence (Motion to Strike). Subsequently, on October 22 and 26, 2015 CASE refiled certain exhibits via the NRCs EIE system. The version of CASE Exhibit INT-001 submitted on October 22 differs from the version it originally submitted via email as Attachment 1. Most of the differences are relatively minor and reflect changes of font and justification, as well as the removal of certain embedded figures. However, CASE did move the two paragraphs that now come at the end of INT-001 from elsewhere within Attachment 1 and corrected the descriptions of other exhibits and its initial statement in those paragraphs.1 The version filed on October 26 included still further changes, chiefly consolidating references to documents together with the excerpts from those documents and other organizational improvements. For example, CASE deleted the 1
Compare INT-001 (October 22 version) at 24 (Slide 10 in the exhibit INT-002) with Attachment 1 at 12 (Slide 10 in the exhibit xxxx); compare INT-001 (October 22 version) at 24 (October 22 version)
(Illustration 3, Initial Statement, at 12,) with Attachment 1 at 13 (Attachment x).
1
heading usgs summary and conclusions from page 11.2 FPL notes that CASEs revisions to this document in the October 26 version are inconsistent with the Boards direction that CASE may not submit any new exhibits.3 Further, while neither the original Attachment 1 nor the first version of CASE Exhibit INT-001 included page numbers, the most recent version does include page numbers. The pagination in this version is significantly altered from that reflected in FPLs Motion due to the changes among the three versions of Exhibit INT-001. As a result, FPL is providing a modified version of Tables 1 and 2 from its Motion to Strike, reflecting the new identification number for Exhibit INT-001 and updating the page numbers accordingly based on the October 26 version.
The revisions to Tables 1 and 2 are identified in boldface and strikethrough below.
Table 1 Documents Improperly Referenced or Reproduced in the CASEs Submission Page # Document Identified in Mandatory Disclosures?
CASE Email from Dr. Christopher Kelble No Statement (CS) at 8-9 CS at 12-14 Origins and Delineation of Saltwater Intrusion in the Yes Biscayne Aquifer and Changes in the Distribution of Saltwater in Miami-Dade County, Florida CS at 15, Water, Water, Everywhere: Sea Level Rise in No INT-001 at MiamiUniversity of Miami Rosenstiel School Of Marine 6-7 and Atmospheric Science, Miami, http://www.rsmas.miami.edu/blog/2014/10/03/sea-level-rise-in-miami/
CS at 17-18, USGS Ground Water Atlas Of The United States Alabama, No 51, 77; INT- Florida, Georgia, South Carolina 001 at 17 2
Compare INT-001 (October 22 version) at 11 (usgs summary and conclusions.) with INT-001 (October 26 version) at 11.
3 Order (Requiring Proper Numbering of CASEs Exhibits), October 21, 2015 at 2.
2
Page # Document Identified in Mandatory Disclosures?
CS at 28-30 Letter from C. Espinosa to M. Harris, Application to No Renew Turkey Point Industrial Wastewater Facility Permit number Fzl0001582 CS at 32, 33 Florida Power and Light Company Docket No. 50-251 ADAMS Facility Operating License, License No. DPR-41 April; 10.
1973 ML013400438 CS at 33; Knowledge Of Ground Water Responses - Critical Factor in No INT-001 at Saving Florida's Threatened and Endangered Species Part I:
23-25 Marine Ecological Disturbances Sydney T. Bacchus Applied Environmental Services, P. O. Box 174, Athens, GA 30603; appliedenvirserv@mindspring.com https://www.nirs.org/nukerelapse/levy/exhf2bacchus.pd CS at 37 Email from G. Burzycki, Subject RE: FPL Cooling Canals No CS at 38 Email from E. Alvear, Subject Cormorant colony closest to No FPL cooling canals undergoing severe decline CS at 38-40 Email from L. Otero, Subject Uprate monitoring issues Yes CS at 41 Email from L. Otero, Subject CCS Surface Water TKN Yes CS at 41 Email from C. Grossenbacher, Subject FW:FPL Annual Yes Crocodile Report CS at 42 Email from L. Otero, Subject RE: Turkey Point Units 3&4 Yes Uprate Addendum - Tritium Attachments: 2014 Post Uprate Report MDC Draft Comments CS at 42 Memorandum from L. Hefty L. to P. Coram Yes CS at 47 Message from F. Mazzoti to J. Wrublik Yes CS at 47 Ecology and Conservation of the American Crocodile No (Crocodylus acutus) in Florida CS at 47-48 Message from M. Pearce to S. Scroggs Yes CS at 48 Statement of P. Stoddard No CS at 48-50 Comments of Miami-Dade County on Draft Environmental ADAMS Impact Statement for Turkey Point Units 6&7 CS at 56-57 Meeting Minutes of the South Florida Water Management No District CS at 63 July 25, 2014 NRC letter to the FWS the NRC requested ADAMS consultation on the subject EA (ADAMS Accession No. ML14206A800) 3
Page # Document Identified in Mandatory Disclosures?
CS at 67-68 Email from A. Gunderson No CS at 68-69 Email to T. Hoeg; Email from T. Hoeg No CS at 75 Environmental Review Guidance for Licensing Actions ADAMS Associated with NMSS Programs Division of Waste Management Office of Nuclear Material Safety and Safeguards (ML032450279)
CS at 79-80; Statement from National Park Service website No INT-001 at 22 INT-001 at What Is Saltwater Intrusion? Saltwater Intrusion of Coastal Yes 1-6 Aquifers in the U.S. James Spatafo Johnson State College Senior Seminar May 6, 2008T http://kanat.jsc.vsc.edu/student/spatafora/setup.htm INT-001 at http://www.rsmas.miami.edu/blog/2014/10/03/sea-level- No 6-7 rise-in-miami/ 4 INT-001 at Emergency Order No. 2015-034-DAOWU [PDF] - Yes 7 South www.sfwmd.gov/...sfwmd.../f INT-001 at Dolan Study No 7
INT-001 at Borehole geophysical logging for the Florida Power & Light No 8-9 Turkey Point Plant groundwater, surface water, and ecological monitoring plan INT-001 at Origins and Delineation of Saltwater Intrusion in the Yes 9-16 Biscayne Aquifer and Changes in the Distribution of Saltwater in Miami-Dade County, Florida5 AT1 at 14- usgs summary and conclusions No 18 INT-001 at McNeill, Donald F., 2000. A Review of Upward Migration No 17 of Effluent Related to Subsurface Injection at Miami-Dade Water and Sewer South District Plant.
INT-001 at Biological Assessment on the American Crocodile ADAMS 18-21 (Crocodylus acutus) Turkey Point Nuclear Generating Unit Nos. 3 and 4 Proposed License Amendment to Increase the 4
It is now apparent that the passage beginning An Attack from Below on page 6 of the October 26 version of INT-001 is a part of this blog post.
5 It is now apparent that the header usgs summary and conclusions in the previous versions did not refer to a separate document, but instead referred to parts of the Origins and Delineation of Saltwater Intrusion paper.
This heading was removed in the October 26 version of INT-001.
4
Page # Document Identified in Mandatory Disclosures?
Ultimate Heat Sink Temperature Limit July 2014 INT-001 at Hughes, J.D., Langevin, C.D., and Brakefield-Goswami, No 21 Linzy, 2010, Effect of hypersaline cooling canals on aquifer salinization: Hydrogeology Journal, v. 18, p. 25-38.
INT-001 at Turkey Point Unit 1 Eco System By Russ Finley On Mar 3, Yes 21-22 2015 with 14 Responses Table 2 CASE Arguments and Exhibits Addressing Matters Beyond the Scope of Contention 1 Beginning Location Ending Location Description of Beyond-Scope Argument CASE Statement Top of page 8 Top of Page 9 Email regarding fish habitat in Biscayne Bay (In one email) (...temperature of 35C)
Bottom of page 33 Middle of Page 35 Bacchus Report on impact on endangered (Perhaps the (Industrial Waste species due to groundwater alterations with strongest) Facility (IWF).) respect to pathogens, underground injection, endocrine disruptors, and microbes.
Bottom of Page 35 Middle of Page 37 Discussion of need for NRC to require (Monitoring) (could be additional monitoring monitored.)
Beginning of Page 38 Middle of Page 38 Alvear email regarding cormorants (regularly monitored)
Beginning of Page 41 End of Page 41 Otero email regarding TKN (Total Kjeldahl Nitrogen);
Grossenbacher email regarding crocodiles Bottom of Page 42 Top of page 43 Hefty memorandum to Coram regarding (November 26, (emphasis added) sampling for trace metals and nutrients 2014)
Top of page 43 Bottom of page 43 Allegation that the NRC fails to discuss (As the citations (specifically that it impacts of copper sulfate on crocodiles does.)
Top of Page 46 Middle of Page 50 Discussion of crocodiles and wildlife, (Crocodiles and (as a regulatory including emails wildlife in the CCS) action?)
Bottom of Page 61 Middle of Page 64 Discussion of NRC consultation with other (NEPA: Consultation (FPL statements agencies, including US Fish and Wildlife with Other Agencies) accepted as fact.) Service Bottom of Page 64 Middle of Page 65 Discussion of whether the EA addressed 5
Beginning Location Ending Location Description of Beyond-Scope Argument NEPA: Health and ( did not consider health and welfare Welfare of Man) these concerns.)
Middle of Page 65 End of Page 69; Discussion of alternatives and grid (NEPA: Consider continuing at beginning reliability/shutting down reactors, including Alterative Actions) of Page 71 to the Gunderson and Hoeg emails.
middle of Page 72 (be asked.)
Bottom of Page 73 Middle of Page 75 Discussion of conflicts over resources (NEPA: Unresolved (resource like Conflicts Over freshwater.)
Resources)
Middle of Page 75 End of page 76 Argument that the administration of the (NEPA: Major Cooling Canals is a major federal action Federal Actions)
Beginning of page 81 Middle of page 81 Discussion of impact on Biscayne Bay
(.2014 EA.)
Bottom of Page 81 Middle of page 82 Discussion of the speed of the NRC Staffs (Speed of the 2014 (18 day EA) review EA)
INT-001 Top of Page 17 Middle of Page 17 McNeil Report on underground injection of (McNeil, Donald (lateral travel.) effluents into the Boulder Zone of the Lower F.) Floridan Aquifer Middle of Page 21 Middle of Page 22 Blog post discussing impact on crocodiles (Turkey Point Unit 1 ( level playing Eco System) field.)
Middle of Page 22 End of Page 22 Discussion of Biscayne Bay estuary (The National Park website states Beginning of Page 23 End of Page 25 Bacchus Report on impacts to marine species from underground effluent injection, aquifer storage and recovery, and mining Bottom of Page 7 End of Page 7 Thesis addressing impacts to mangroves and (Tara Dolan study) habitats 6
Respectfully Submitted, Signed (electronically) by Steven Hamrick Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 William S. Blair Erin Walkowiak Florida Power & Light Company 700 Universe Blvd.
Juno Beach, Florida 33408 william.blair@fpl.com erin.walkowiak@fpl.com 561-304-5238 October 27, 2015 COUNSEL FOR FLORIDA POWER & LIGHT COMPANY 7
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-LA
) 50-251-LA (Turkey Point Units 3 and 4) )
) ASLBP No. 15-935-02-LA-BD01 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Florida Power & Light Companys Revision to Tables in its October 19, 2015 Motion to Strike, were provided to the Electronic Information Exchange for service to those individuals listed below and others on the service list in this proceeding, and via e-mail to those marked with an asterisk.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Mail Stop: T-3F23 Mail Stop: O-15D21 Washington, DC 20555-0001 Washington, DC 20555-0001 Michael M. Gibson, Chair Brian Harris, Esq.
Dr. William W. Sager David Roth, Esq.
Dr. Michael F. Kennedy Catherine Kanatas, Esq.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Office of the Secretary of the Commission Mail Stop: O-16C1 Mail Stop: O-16C1 Washington, DC 20555-0001 Washington, DC 20555-0001 OCAA Mail Center Hearing Docket Barry White*
Citizens Allied for Safe Energy, Inc.
1001 SW 129 Terrace Miami, FL 33176
Signed (electronically) by, Steven C. Hamrick Florida Power & Light Company 801 Pennsylvania Avenue, N.W. Suite 220 Washington, DC 20004 steven.hamrick@fpl.com 202-349-3496 Dated at Washington, DC this 27th day of October, 2015 2