ML18177A181
| ML18177A181 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/21/2018 |
| From: | Rice D, Tennyson L Monroe County, FL, Board of County Commissioners |
| To: | May Ma Office of Administration |
| References | |
| 83FR23726 00017, NRC-2018-0101 | |
| Download: ML18177A181 (8) | |
Text
PUBLIC SUBMISSION Docket: NRC-2018-0101 Turkey Point Nuclear Plant Units 3 and 4 Comment On: NRC-2018-0101-0001 Florida Power & Light Company; Turkey Point Nuclear Plant Units 3 and 4 Document:
NRC-2018-0101-DRAFT-0017 Comment on FR Doc # 2018-10806 Name: Lisa Tennyson Address: Submitter Information As of: 6/22/18 1 :25 PM Received:
June 21, 2018 Status: Pending_Post Tracking No. lk2-93ud-lipw Comments Due: June 21, 2018 Submission Type: Web Monroe County Board of County Commissioners, 1100 Simonton Street, Key West, Florida 33040 Key West, FL, 33040 Email: tennyson-lisa@monroecounty-fl.gov Submitter's Representative:
Lisa Tennyson, Director oflntergovernmental Affairs Government Agency Type: Local Government Agency: Monroe County Board of County Commissioners General Comment Monroe County Board of County Commissioners requests that the granting of FPL's requested Subsequent License Renewal for Units 3 and 4 be conditioned upon the demonstrated remediation of the existing hypersaline plume and the decommissioning the cooling canal system and replacement with new cooling towers, to safeguard our water supply and surrounding natural resources.
Attachments FPL Turkey Point Units 3 and 4 Docket ID NRC-2018-0101 Monroe County, Fl Comments SUNS! Review Complete Template=
ADM-013 E-RIDS=ADM-03 ADD=Yvonne Edmonds, Eric Oesterie, LaShawnna Lewis, Benjamin Beasley CO MM ENT ( 17) PUBLICATION DATE: 5/22/2018 CITATION#
'County of Monroe The Florida Keys Mayor David Rice Monroe County Board of County Commissioners*
Historic Gato Building.
1100 Simonton Street, Key West, Florida 33040 June 21, 2018 Ms. May Ma. Director Program Management Announcements and Editing Branch Office of Administration Mailstop:
TWFN-7 A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
.. BOARD OF COUNTY COMMISSIONERS Mayor David Rice, District 4 Mayor Pro Tem Sylvia Murphy, District 5 Danny L. Kolhage, District 1 Heather Canulhers, District 3 George Neugent, District 2 Re: Subseguent License Renewal Application Turkey Point Units 3 and 4
Dear Ms. May Ma:
Florida Power and Light (FPL) has filed an application with the Nuclear Regulatory Commission seeking approval of a Subsequent License Renewal for Units 3 and 4 at the Turkey Point site in Miami-Dade County. The requested renewal would extend the operational life of the units and the existing cooling canal system (CCS) to 2053. Monroe County, which comprises the Florida Keys and operates under the Area of Critical State Concern statutory designation, borders Miami-Dade County to the south. Monroe County is following closely the developments at the Turkey Point facility.
Representatives of the County attended the Scoping Meeting on May 31, 2018 in Homestead, Florida. I write to briefly state Monroe County's serious concerns about Turkey Point facility and its license renewal application.
' FPL is experiencing difficulties in the current operation of Units 3 and 4 at Turkey Point, specifically with regard to the CCS for these units. One byproduct of FPL 's current operation of the CCS for Units 3 and 4, and our primary concern, is an underground hypersaline plume emanating from the cooling canal system ~estward toward the FKAA Biscayne Aquifer wellfield, placing the drinking water supply for all of Monroe County in jeopardy.
Of secondary concern, is the eastward movement of the underground plume from the CCS into the environmentally sensitive Biscayne Bay. These developments are of grave concern to Monroe County as set forth in Resolutions 87-2016 and 43-2017. Copies of the resolutions are attached hereto as Exhibits A and B, respectively.
Monroe County requests that any granting of FPL's requested subsequent license renewal for Units 3 & 4 at Turkey Point be conditioned upon the following:
- Demonstrated remediation of the existing hypersa1ine plume within a reasonable timeframe and with an identified completion date.
- Decommissioning of the CCS and replacement with new cooling towers to safeguard our water supply and surrounding natural resources.
Respectfully submitted, Enclosures (2)
" \~ 1 . ,.,~ .: ... i ** *' . .. . ... Mayor Carruthers RESOLUTION NO. J!!!: 2016 A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA EXPRESSING ITS CONCERN OVER THE THREAT FLORIDA POWER & LIGHT COMPANY'S TURKEY POINT FACILITY'S COOLING CANAL SYSTEM POSES TO MONROE COUNTY'S SOURCE OF POTABLE WATER AND BISCVANE BAY; EXPRESSING A DESIRE TO WORK COOPERATIVELY WITH MIAMI-DADE COUNTY AND OTHER AGENCIES WITH JURISDICTION TO PROTECT THE FLORIDA KEYS POTABLE WATER SUPPLY; ENCOURATING THE FLORIDA KEVS AQUEDCUT AUTHORITY TO TAKE ALL STEPS NECESSARY TO PROTECT ITS WELLFIELDS IN FLORIDA CITY; DIRECTING THE CLERK TO DISTRIBUTE THE RESOLUTION, AND PROVIDING FOR AN EFFECTIVE DA TE. WHEREAS, Monroe County is the southernmost county in the State of Florida and home to the world renown Florida Keys; and WHEREAS, Mon.roe C~unty shares a common boundary*
with Miami-Dade County which is approximately 152 miles' long; and WHEREAS, the Florida Keys is home to approximately 75,000 full time residents plus several thousand part time residents many of whom reside full time in Miami-Dade County, and WHERE~. the Florida Keys Aqueduct Authority (FKAA} is the public entity created by the Legislature" which has been vested with the responsibility for providing potable water to residents and businesses in the Florida Keys; and WHEREAS, the FKAA draws potah'-~ water primarily from the Biscayne Aquifer through a welUield located west of Florida City"' within Miami-Dade County; and WHEREAS, Florida Power & Light Company (f PL) is the ~int-largest electric utility in the United States and provides powers to over 4.8 million customers 111 in the state; and WHEREAS. f PL owns and operates it*s Turkey Point facility in southeast Miami-Dade County comprised of multiple power generating units; and WHEREAS. the Turkey Point facility includes an approximately 5,900-acre network of unlined canals and an interceptor ditch on the western side of the network. or collectively the cooling canal system** (CCS), which dissipates heat from the water used in the operation of FPL's nuclear Units 3 and 4, as well as Unit t when in operation; and WHEREAS, FPL*s CCS is located at its closest point less than two miles from the Miami-Dade/Monroe County line and approximately
9.5 miles
from the FKAA's weUfield in Florida City. and Pagel of 4 -... --------~--'--------------*---.--~ .. --------~-------------
*-------*---___ .,.._ __ .,_ --------*-** ----~ *-** ---.----,. -. -------------------*-
*--**--------~----
- --... --*--*---~--~j
..... , I" .... Mayor Carruthers WHEREAS, that while the CCS has no direct surface waler discharges, data shows that water from the CCS has moved beyond its boundaries; and WHEREAS 1 the hypersaline plume extends two or three miles west of the CCS and continues to move westward and the plume is pushing the saline water i~terface, which is now four or five miles west of the CCS, at the rate of 400 to 600 feet per year. vi; and WHEREAS 9 Monroe County supports Miami-Dade County's Division of Environmental Resourecs Management (DERM) for issuing a Notice of Violation and Orders for Corrective Action (October 2, 2015) against FPL to redress alleged violations of the Miami-Dade County Code involving the CCS and entering into a Consent Agreement with FPL on October 6, 2015 to resolve those violations; and WHEREAS, Miami-Dade County recently issued a Reportvii on March 7, 2016 indicating that: ... a. the long tenn water quality in the CCS is degrading;"'
11 b. water from the CCS is migrating outside its boundaries away from the "f urkcy Point facility property with impacts measured in both surface and groundwatcr; 1 1: c. monitoring data indicate that a hyper-saline groundwater plume originating from the CCS has migrated landward and is impacting water quality;" d. results for recent tritium sampling (an isotope of hydrogen that is frequently associated with the operation of nuclear power plants) provide the most compelling evidence that water origin~ing from the CCS is reaching tidal surface waters connected to Biscayne Bay;111 and e. rainfall.
pumping additional water into the CCS and operations of the CCS Interceptor Ditch lead lo record high water stage in the CCS which would be expected to result in increased scepag~ of water from the CCS into surrounding ground waters and perhaps surface waters. " 11 WHEREAS, Monroe County is concerned that the westward migrating hypersaline plume in the Biscayne Aquifer places the Florida Keys' source of potable water in jeopardy; and WHEREAS~ Monroe County is also concerned that the eastern migration of the hypcrsaline plume into the tidal surface waters connected to Biscayne Bay (and potentially the Biscayne Bay Aquatic Preserve) places these water resources in jeopardy where Monroe County citizens fish and recreate; and WHEREAS, Monroe County is working to gain a full understanding of all the solutions being proposed by DERM and the other agencies with jurisdiction over Turkey Point and the CCS including.
but not limited to. the Florida Department of Environmental Protection (DEP), the South Florida Water Management District (SFWMD) and the Nuclear Regulatory Commission (NRC); and WHEREAS, Monroe County desires to work cooperatively with Miami-Dade County leadership and other agencies with jurisdiction over Turkey Point and the CCS to ensure that the FKAA's well fields are protected to the maximum extent possible now and in the future; and Page2of4
. /". ,* ,-. "-::;,*,.
.. . **-' Mayor Carruthers WHEREAS, a comprehensive approach is needed to 1) stop the western movement of the hypersaline plume immediately.
- 2) remove the CCS discharges into the Biscayne Aquifer in an expedited manner and 3) address any impacts to Biscayne Bay; and WHEREAS, Monroe County calls upon its partners at the FKAA to take all steps necessary to protect the Florida Kcy*s supply of potable water, including potential partnering on the development of new technical data to better undcrstan.d the extent of the hypersaline plume and potential threat to the FKAA's wcllfields; and WHEREAS, Monroe County reserves its right to i~_~tiate the conflict resolution provisions of the Florida Governmental C~nftict Resolution Actwa and to bring an action under the Florida Environmental Protection Act 111 or any other available Federal or State legal remedy at a later date should the Board deem such action appropriate; NOW THEREFORE, BE IT RESOLVED BV THE BOARD OF COUNT\' COMMISSIONERS OF MONROE COUNTY. FLORIDA THAT: 1. The above recitals are hereby incorporated into this resolution as restated herein constitute the legislative findings and intent of the Board of County Commissioners of Monroe County, Florida. 2. The Miami-Dade County leadership, the SFWMD and DEP are invited to open a dialog with Monroe County in support of finding comprehensive solutions to combat the western migration of the hypersalinc plume stemming from FPL's Turkey Point CCS; remove the CCS discharges into the Biscayne Aquifer in an expedited manner. and address any impacts to Biscayne Bay. 3. Monroe County cnc.ourages the FKAA to talce all steps necessary to protect the potable waler supply for the Florida Keys including its wellfields in Florida City. 4. Monroe County is willing to provide material support to the FKAA to enhance its current efforts to protect the Florida City well fields. 5. TI1e Clede. for this Board shall furnish copies of this resolution to:
- U.S. Senator Bill Nelson
- U.S. Senator Marco Rubio
- U.S. Representative Carlos Curbelo, District 26
- Florida Governor Rick Scott
- Florida Senate President Andy Gardiner
- Florida House Speaker Steve Crisafulli
- State Senator Dwight Bullard, District 39
- State Senator Anitcrc Flores, District 3 7
- State Representative HoJty Raschein, District 120
- Chairman of the Nuclear Regulatory Commission Stephen G. Bums
- Chair, South Florida Water Management District Governing Board, Daniel o*Keere
- Executive Director, South Florida Water Management District Peter Antonacci
- Secretary, Florida Department of Environmental Protection, Jon Steverson Page3of4
.,. ... * ... ,,.. Mayor Carruthers
- Miami Dade County Mayor Carlos Gimenez
- Chair, Florida Keys Aqueduct Authority Robert Dean
- Executive Director, Florida Keys Aqueduct Authority Kirk Zuclch 6. This resolution shall take effect immediately upon adoption.
PASSED AND ADOPTED by the Board of County Commissioners of Monroe County Florida. at a regular meeting of said Board held on the zcf'-day of April, 2016. Mayor Hesther Carrutben Mayor pro tem George Neugeut Commkdontt Daooy L. Kolmge Commissioner David Rice Comm!moou Sylvia Murphy 1 Per Brian Davisson.
Monroe Coonty GIS Planner. "See, ch.76-441. uws of Florida. "' hup:llwww.Ocaa.romlour
_wa1er_sowce.h1m
,. https:/ I www.fpl.com/aboul/comp:my-profitc.html Yes Rot Present: ....!g_
- Consent Agreement i.n Aliami-Dadc Coun1y ,~ Florida Pok'er & light Co., dated October 7, 2015 * ., Tropical A.uduh<Jn Society , .. FP&.L and SFWAID. Case I S-J84S. 'Jl 46 (DOAH Rtt'd Omer Dec. 31, 20151; https:flwww.dooh.state.fl.us/ROS/2015/ISOOJ84S.pdf.
'" Report on Recent Biscayne Ony Water Quality Ob£cnraaiotH Amx:iakd with Florida Power and Light Turkey Point Cooti.ng Canal systems Opcmliow;-
Directive 152Bli4, d&cd Mnn:h 7. 2016 (Mia.m.i-D.adc Report) . ... Miami-Dade Rc:port pg. t. 11 Miami-Dade Report. pg. S.
- Miami-Dade Rc:port pg. 3. Miami-Dade Report pg. 4. '"" Mwni Dade Report pg. 4 -F.S. 164.101 et seq . .,,. F .S. 403.412. Page4 of 4 'I:
' .. RESOLUTION NO. -2017 A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF MQNROE COUNTY, FLORIDA SUPPORTING EFFORTS TO SEEK A COMMITMENT FROM FLORIDA POWER AND LIGHT TO DISCONTINUE USE OF THE COOLING CANAL SYSTEM AT THE TURKEY POINT NUCLEAR POWER PLANT AS SOON AS POSSfflLE; PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, The Florida Power and Light Turkey Point Nuclear Power Plant, located in south Miami-Dade County, utilizes a cooling canal system which consists of a network of approximately 5,900 acres of unlined canals; and WHEREAS, The Florida Power and Light Turkey Point Nuclear Power Plant is the only facility in the world that uses a cooling canal system instead of mechanical draft cooling towers; and WHEREAS, water from this cooling canal system communicates with the surrounding groundwater, and long-tenn monitoring data has shown that a hypersaline plume of water from the cooling canals has been migrating into and contaminating the groundwater, beyond the boundaries of the cooling canals; and WHEREAS, Miami-Dade County took action to address this issu~ including, but not limited to issuing a Notice of Violation in 2015 to Florida Power and Light for certain water quality violations in the groundwater, and requiring, through an administrative consent agreement, the Florida Power and Light take certain remedial actions to retract and contain the hypersaline ground water plume; and WHEREAS, at that time, the issues were focused on the westward migration of the hypersaline ground water plume from the cooling canals, more recent water quality sampling has detected exceedances of water quality standards in certain surface water locations in or connected to Biscayne Bay, adjacent to and east of the cooling canal system; and WHEREAS, this Board, the residents of Monroe County and members of the general public are concerned about these recent discoveries and potential impacts on Card Sound, Biscayne Bay, and the Florida Keys' drinking water supply, and such discoveries serve to highlight the challenges posed by the continued operation of the cooling canal system; and WHEREAS, Florida Power and Light has a license from the federal government to operate the Turkey Point Power Plant units that use the cooling canal system until 2033; and WHEREAS, this Board is seeking a conunibnent from Florida Power and Light lo discontinue the use of the cooling canal system in favor of a more modem mechanical draft cooling tower system that would remove all future interactions with ground water and make.use Dade County's reuse water; Page 1 of2
.... ) -NOW THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA that: 1. The Monroe County Board of County Commissioners seeks a commihnent from Florida Power and Light to discontinue the use of the cooling canal system at its Turkey Point Nuclear Power Plant, as soon as possible, in favor of mechanical draft cooling towers. 2. This resolution shall take effect upon adoption.
PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a regular meeting of said Board held on the 15th day of February, 2017. MayorGeorge Neugent Mayor Pro Tem David Rke Commissioner Danny Kolhage Commissioner Heather Carruthers Commissioner Sylvia Murphy Yes Yes Yes Xe Yes MADOK, Clerk BOARD OF COUNTY COMMISSIONERS OF 70E COUNTY, FU>;rr By: ~~L* ¥).,_.. ;, "ri Pagel of2 Mayor C"'. ..,, i,, ::lr rr, CJ n;,i; CD -,* N -,, .~£! N §5 *5:--~*, . .-~r ...... . . ., * ,_ C:!1 -~ ...-0 (A) __ ) ., . ' \ '*