ML18177A194

Comment (25) of Matthew Schwartz of South Florida Wildlands Association on Florida Power & Light Company; Turkey Point Nuclear Plant Units 3 and 4

ML18177A194
Person / Time
Site:	Turkey Point
Issue date:	06/21/2018
From:	Schwartz M South Florida Wildlands Association
To:	May Ma Office of Administration
References
83FR23726 00025, NRC-2018-0101
Download: ML18177A194 (4)

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-0025 Comment on FR Doc# 2018-10806 Submitter Information Name: Matthew Schwartz Submitter's Representative: Matthew Schwartz Organization: South Florida Wildlands Association General Comment Please see attached comments.

Attachments South Florida Wildlands Comments on Turkey Point license renewal As of: 6/22/18 2:25 PM Received: June 21, 2018 Status: Pending_Post Tracking No. lk2-93ur-wfge Comments Due: June 21, 2018 Submission Type: Web SUNSI Review Complete Template= ADM-013 E-RIDS=ADM-03 COMMENT (25)

PUBLICATION DATE: 5/22/2018 CITATION# 83 FR 23726 ADD= Yvonne Edmonds, Eric Oesterie, LaShawnna Lewis, Benjamin Beasley

~SOUTH FLORIDA

.WILDLANDS ASSOCIATION P.O. Box 30211 Fort Lauderdale, FL 33303 June 21, 2018 May Ma Director, Program Management Annountements and Editing Branch Office of Administration Mailstop: TWFN-7A60M U.S. Nuclear Regulatory Commission Washington, D.C.20555-0001 Greetings:

South Florida Wild lands Association appreciates the opportunity to provide these brief scoping comments on the renewal application for the Turkey Point Nuclear Plant, Units 3 and 4. These comments will mainly outline remarks we made during the public hearing on May 31st in Homestead, Florida.

First, the Turkey Point cooling canals have become an environmental hazard for South Florida. The hot, highly saline water in the canals and its other constituents (e.g. ammonia) have been found to have created a plume of non-potable water beneath the canals and the underlying Biscayne Aquifer, a sole source aquifer for all of Miami-Dade, Broward, and the Florida Keys. Water from the canals has also been found to be leaking into Biscayne Bay as evidenced by levels of radioactive*

tritium in the bay many times the ordinary background radiation.

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The canals are also poised to merge with the bay at some point in the coming decades - but very likely within the time frame of the extended operating license.

The land the canals were dug into sits only 6 inches above sea level. And there l

are no scientific predictions for sea level rise in the coming decades which envision a rise in sea levels under that amount. And berms will not help -the limestone beneath the canals is highly porous and will quickly allow in rising levels of saltwater no matter how high the berm is made.

In our comments from May 3l5\\ we also focused on the threat from hurricanes.

Scientists are not necessarily predicting more storms, but they are predicting larger, wetter, and more powerful storms. It is possible that the 2017 hurricane season was an anomaly-but few scientists hold to that opinion.

In 1992, Turkey Point took a direct hit from Hurricane Andrew. The NRCreport deemed the damage "extensive." And, as we learned from Fukushima, an event doesn't need to damage the reactor itself to become catastrophic. Loss of all outside power, as happened during Andrew, combined with loss of generators or backup batteries (which did not occur at Turkey Point-fortunately) is enough to stop the flow of cooling water through the radioactive material on site. And that can lead to an unfolding of events that, although unthinkable, did in fact happen in Fukushima.

In the fall of 2017, Hurricane Irma had a direct bead on Turkey Point. Fortunately, it did not make the northward turn as predicted, but instead veered south into Cuba (which lessened its intensity from Category 5) and then stayed on a westward cou_rse, not turning north until it was well past Turkey Point. One of reactors had already been shut down - but the second was shut down after wind and rain from outer bands from Hurricane Irma damaged an outside valve.

Similarly, a room at the St. Lucie nuclear plant was flooded by heavy rains alone -

and that was after the NRC had required a full safety review of nuclear plants for possible water damage due to weak or faulty seals. Both the NRC and the plant owner, FPL, signed off on the plant-and yet the damage occurred.

For the above reasons, we strongly believe that the Turkey Point nuclear reactors should not receive a second extension for yet an additional 20 years of operation.

There are no plants operating for that length of time, storms are getting stronger, sea levels of rising, and the risk to already threatened South Florida is eno-rmous.

We would rather see the NRC use the time before the current operating license expires to work with FRL in devising the complex plan for decommissioning both reactors at Turkey Point.

Best regards, Matthew Schwartz Executive Director South Florida Wildlands Association