Press Statement by Mary Olson, NIRS Southeast on Duke Energy's decision to permanently close Crystal River nuclear power reactor. February 5, 2013
Evidentiary Hearing filing, June 26, 2012:
Intervenors' Statement of Position (supported by following expert testimony).
Expert Testimony of Geologist Gareth Davies in Support of Intervenors Contention 4, Levy County COL.
Expert testimony of Hydrologist / Water Modeling Analyst Tim Hazlett in support of Intervenors Contention 4 Levy County COL.
Expert Testimony of Hydro Ecologist Dr. Sydney Bacchus in support of Intervenors' Contention 4 in Levy County COL.
Expert Testimony of David Still, formerly a Water Management Administrator for State of Florida in support of Intervenors' Contention 4, Levy County COL.
Rebuttal to Intervenors' Filing by NRC Staff and Progress Energy Florida. July 31, 2012
Rebuttal to Intervenors' Contention 4 by NRC staff Statement of Position.
NRC Staff rebuttal to Experts in Support of Intervenor C4 in Levy COL.
Rebuttal Statement from Progress Energy Florida.
Intervenors Response, July 31, 2012
Statement of Position Contention 4, Levy COL.
Rebuttal Testimony Gareth Davies
Rebuttal Testimony Tim Hazlett
Rebuttal Testimony Sydney Bacchus + 2 exhibits
Exhibit INT 802
Exhibit INT 803
Rebuttal Testimony David Still
* The complete filings by all parties in the Levy County case includes dozens of documents submitted as exhibits. Some of these are quite short, others are documents hundreds of pages long. All are in the Nuclear Regulatory Commission's Electronic Hearing Dockets 52-029 and 52-030. You may also request the intervenors' exhibits from Mary Olson. There may be a small handling fee.
February 15, 2012: Atomic Safety Judges issue Memo to Parties asserting authority to rule on allegation that laws would be broken, instructing Parties to respond to allegations in Answer briefs.
February 13, 2012: Motion and Proposed Contention 14 -- Federal and State laws would be broken if Levy COL approved.
Attachments 1- 4 for Levy Contention 14 including federal and state laws and 1991 resolution by governor Chiles protecting waters of the Levy County area.
August 11, 2011:
Motion to Admit New Contention (13) and Reconsider Contention 5 Regarding the Safety and Environmental Implications of the Nuclear Regulatory Commission Task Force Report on the Fukushima Dai-ichi Accident.
- Contention 13 Regarding NEPA Requirement to Address Safety and Environmental Implications of the Fukushima Task Force Report.
- Rulemaking Petition to Rescind Prohibition Against Consideration of Environmental Impacts of Severe Reactor and Spent Fuel Pool Accidents and Request to Suspend Licensing Decision
- Contention 5 on Severe Accident Impact on Multiple Sites - Submitted for Reconsideration by the Ecology Party of Florida, Nuclear Information and Resource Service, and the Green Party of Florida
- Declaration of Dr. Arjun Makhijani Regarding Safety and Environmental Significance of NRC Task Force Report Regarding Lessons Learned from Fukushima Daiichi Nuclear Power Station Accident.
February 2, 2011: The ASLB handed down three rulings in favor of the Interveners on the hydro ecological contention #4:
- Order Denying Progress Energy Motion to Dismiss Parts of C4 as Moot
- Order Denying Progress Energy Motion for Summary Disposition on C4
- Order Admitting Intervener’s Amended Contention C4A
LNP DEIS supplemental comment letter. November 27, 2010
Bacchus Exhibit A. LNP DEIS Critical Deficiencies.
Bacchus Exhibit A1. LNP Bacchus DEIS preliminary comment letter. October 26, 2010
Bacchus Exhibit A2. LNP Bacchus Affidavit. November 12, 2010
Bacchus Exhibit A3. LNP Interveners Motion to Compel Model files. September 27, 2010
Bacchus Exhibit A4. LNP Oral Argument Notice for Motion to Compel. October 15, 2010
Bacchus Exhibit A6. LNP Amended Contention 4. November 15, 2010
Bacchus Exhibit A7. Economic Impacts of Mining on Levy County. February 22, 2010
Bacchus Exhibit A8. LNP Deficient cultural resource surveys.
Bacchus Exhibit A9. Impacts of inadequate archeological assessments. November 25, 2010
Bacchus Exhibit B. LNP DEIS Federal Agency Comments.
Bacchus Exhibit B1. EPA comments Levy DEIS. October 26, 2010
Bacchus Exhibit B2. NOAA comments on Levy DEIS. October 26, 2010
Bacchus Exhibit C. LNP Affected Area.
Bacchus Exhibit C1. LNP vicinity Casey Declaration photos.
Bacchus Exhibit C1ai. Casey LNP vicinity karst conduits video. February 14, 2010
Bacchus Exhibit C1aii. Casey LNP vicinity karst conduits video. March 27, 2010
Bacchus Exhibit C2. Bacchus and Barile.
Bacchus Exhibit C3. Conceptual drawing of proposed LNP DEIS Fig 3-2.
Bacchus Exhibit C4. Floodplains map LNP ER Fig 4.1-4.
Bacchus Exhibit C5. USGS Topographic map 5 mile PEF Environmental Report Fig 2.7-23. December 9, 2009
Bacchus Exhibit C6. Wetland Classification map 6-mile Levy DEIS Fig 2-4.
Bacchus Exhibit C7. Waters of the US and ctastrophic destructive wildfires 2007.
Bacchus Exhibit C8. Levy County sinkholes and faults PEF ER Fig 2.6-2.
Bacchus Exhibit C9. Groundwater drawdown contours LNP DEIS Fig 5-1.
Bacchus Exhibit C10. Model Grid LNP DEIS Fig 2-12.
Bacchus Exhibit C11. Potentiometric high in LNP affected area12208
Bacchus Exhibit C12. FSAR geologic conditions excerpts.
Bacchus Exhibit D. LNP Adverse Environmental Water Impacts.
Bacchus Exhibit D1a. Multibasin watersheds LNP DEIS Fig 2-7
Bacchus Exhibit D1b. Sub-basin coastal discharges LNP DEIS Fig 2-8
Bacchus Exhibit D1e. SRWMD Water Supply Assessment Report 2010
Bacchus Exhibit D1f. FDEP Withlacoochee impaired verified-c2. January 12, 2010
Bacchus Exhibit D1g. FDEP Waccasassa impaired waters. January 15, 2010
Bacchus Exhibit D2. Giant Holes in flood plain MIT Technology Review. November 12, 2010
Bacchus Exhibit D3. Critical Wildlife Habitat Levy County
Bacchus Exhibit D4. Baseline Conditions GWRC S1-95
Bacchus Exhibit D5. Passive dewatering 2006
Bacchus Exhibit E. LNP Adverse Salt Drift Impacts
Bacchus Exhibit E1. LNP salt drift FLDEPCOC appendices.
Bacchus Exhibit E2. LNP Bruner email Tampa climate data.
Bacchus Exhibit E3. LNP Citrus Levy SWFWMD cover classification map.
Bacchus Exhibit E4. LNP NOAA Tampa rainfall data.
Bacchus Exhibit E5. LNP NOAA Chiefland rainfall October 2010 Rain.
Bacchus Exhibit E6. NUREG 1555 on Salt Drift.
Bacchus Exhibit E7. BDA Crystal River Aerial Salt Study'94-pics.
Bacchus Exhibit F. Unpermitted Taking of Listed Species.
Bacchus Exhibit F1. WAR comments A-NRC Draft EIS Hearing-Final. September 23, 2010
Bacchus Exhibit F2. Bacchus coastal impacts to listed species 2001.
Bacchus Exhibit F3. DOAH Save the Manatee mine case 96001723
Bacchus Exhibit G. LNP Alternatives Not Considered Invalid Mitigation.
Bacchus Exhibit G1. Affected Regional transmission corridors substations Levy DEIS Fig 2-5
Bacchus Exhibit G2. FL rooftop solar PV-OS-20-2000.
Bacchus Exhibit G3. CA rooftop solar. January 21, 2008
Bacchus Exhibit G4. LOE smarter utilities decoupling alternative. January 30, 2009
Bacchus Exhibit H. LNP Comprehensive Cumulative Effects Analysis.
Bacchus Exhibit H1. 1997 Cumulative Effects
Bacchus Exhibit I. List of Bacchus Exhibits and References.
Bacchus Exhibit I1. List of Exhibits. November 27, 2010
January 7, 2010: Ruling by Nuclear Regulatory Commission upholding NIRS, Green Party, Ecology Party as interveners and confirming admission of three contentions in Levy County nuclear license challenge, striking down the Progress Energy appeal.
July 8, 2009: NRC licensing board admits three contentions in NIRS, Green Party, Ecology Party challenge to Progress Energy’s proposed Levy County (FL) reactors.
NIRS, Ecology Party, Green Party file legal challenge before NRC to proposed new reactors on greenfields site in Levy County, Florida. Feburary 6, 2009