ML18186A125

[External_Sender] Docket NRC-2018-0101 - Scoping Comments on Florida Power & Light'S Subsequent License Renewal Application for Turkey Point Nuclear Generating Station'S Reactor Units 3 & 4

ML18186A125
Person / Time
Site:	Turkey Point
Issue date:	06/21/2018
From:	Schoedinger S R North Key Largo Utility District
To:	William Burton, May Ma Rules, Announcements, and Directives Branch, Division of Materials and License Renewal
NRC/NRR/DMLR
References
83FR23726, NRC-2018-0101
Download: ML18186A125 (22)

Text

From: To: Cc: Steven Schoedinger TurkeyPoint34SLREIS Resource Burton. William

Subject:

[External_Sender]

Docket NRC-2018-0101-Scoping Comments on Florida Power & Ught"s Subsequent License Renewal Application for Turkey Point Nuclear Generating Station"s Reactor Units 3 & 4 Date: Thursday, June 21, 2018 9:49:36 PM Attachments:

NPS TPP WO Concerns Ltr May 2016.pdf Mia Beach Reso re -FPL Discontinue use of CCS 2017 F.A. 3.16.2017.pdf Monroe Co FPL CCS Resolution 022217.pdf Mia Dade TPP 3 & 4 resolution 07-16.pdf ORCA Ltr to County. TPP 3 &4 CCS Resolution.pdf FPL TPP City of Key West Resolution

& FKAA Ltr to NRC.pdf FKAA TPPP ltr to BOCC 01-2017 .pdf

Dear Ms. Ma and Mr. Burton:

Attached for U.S. Nuclear Regulatory Commission staff review and consideration are 6 PDFs comprising resolutions passed and correspondence sent in the past 3 years by City of Key West, FL Monroe County,FL Florida Keys Aqueduct Authority, Miami-Dade County, FL U.S. National Park Service, Ocean Reef Club,Key Largo, FL Ocean Reef Community Association, Key Largo,FL.

These publicly-recorded documents (1) condemn the water pollution emanating from the FPL TPPP 46 year old open canal reactor cooling water system, (2) support the decommissioning of same open cooling canal system before 2032, and (3) support constructing new mechanical draft cooling towers as soon as possible before the 2032 operating license renewal for the existing nuclear reactors #3 and #4.

• The action taken by these organizations is significant and pertinent to Docket# NRC-2018-0101 Scoping Comments Phase of the Florida Power & Light's Subsequent License Renewal Application for Turkey Point Nuclear Generating Station's Reactor Units 3 & 4. Sincerely, Steven R Schoedinger, P.E. Chair, Water Resources Committee North Key Largo Utility District 58 Anchor Drive, Unit B Key Largo, FL 33037 Florida Keys Aqueduct Authority 1100 Kennedy Drive Key West, Florida 33040 Telephone (305) 296°2454 \WIW. fkaa.com Board of County Commissioners Monroe County 1100 Simontoh Street Key West, FL 33040 Re: Florida Power and Light

Dear Commissioners:

... January 26, 2017 J .. Robert Dean Chairman iJi~trict 3 Richard J. Toppino Vice-Chairman District 2 David C. Ritz Secretaryrf reaslirer Dis.trict5 Antoinette M. Appell District 4 Cara Higgins District 1

• Kirk C. Zuelch Executive Director The Florida Keys Aqueduct Authority Board of Directors requests yoµr support in opposition to Florida Power and Light's (FPL) application to construct and operate two new nuclear plants at their Turkey Point facility.

I have a_ttached the letter from our Board to the U.S. Nuclear Regulatory Commission (NRC) .and a Resolution from the City of Key West in opposition to the FPL application.

The Authority's letter to the NRC goes into detail explaining the reasons for our opposition; however, the :following is a brief summary: 1. FPL has been out of compliance with the operating requirements of the cooling canal system for years and has on!y now addressed the problem after enforcement was initiated by Florida Depat1ment of Ehvitonmental Protection and Miami-Dade County. Our Board's position is clear: fix the problem created before expanding the facility.

2. The closed cooling canal system in a subtropical environment is unique among nuclear plants. Most plants use cooling towers or direct sea water pass-through systems. The cooling canal system at Turkey Pofr1t hasn't worked properly and agency, university and private sector experts are concerned that FPL will not be able to restore the aquifer to pre-existing conditions and eliminate the existing high salinity plume that threatens our fresh water supply. Our Board, therefore, h~s suggested to the NRC that cooling towers, which do work, be built to replace the failed cooling canal system. We appreciate your support of the At1thority's position which we b¢lieye best protects the .. water supply for ~he Florida Keys. Sincerely, cc: Roman Gastesi Bob Shillinger Annette L. Viclli-Cook.

Sccrctm*y US Nuclear Regulatory Commissioti Washinglrin.

l).C. 20555-000 I RE: IX>CK.E'i'S52-040 AND 52-()41 0 Deccmbcr 29, 2016 Issuance of Combined Licenses for FPL's Turkey Point Units 6 and 7 Dear Se1;n;tary Vietti-Cook:

J .. Robert Dean Chairman Dislrict 3 Antoinette M Appell Vice-Chairman Dislricl 4 OavidC Ritz Secretary/Treasurer Oislrict 5 Cara Higgins District 1 Richard J. Toppino Dlstrict 2 Kirk. C. Zuelch Executive Director This leller is to present issues fol' consideration at yom Evidcntiary I !caring on February 9, 2017 regnrding the application to cQnstmct and operate two new nuclear plants in southeast Miami-Dade County. The Florida Keys Aqueduct Authority is an Independent Special District or the State of Florida with the responsibility of supplying the entire group of islands known as the Florida Keys with drinking water ihrn1 the Class I Biscayne Aquifer located in southeast Miami-Dade County. Our Board of LJirectors is appointed by the (iovemor of the State of Fl<)rida and has directed staff lo prepare this letter in accordance with your correspondence, dated December S. 2016. For mt1rc than a decade; Florida Power & Light Company (FPL) has been out of compliance with operating.

requirements of' its cooling canal system (CCS). The salinity v.ilucs in the CCS have rir-cn to conccntrati(111s higher thm1 fi.mnd in seawater.

Thcsc high concentrations wci"e not contained lo acceptable lcvchi as required by fPL's interceptor canal. and as a result. hypenmlinc conditions lmvc migrated more than two miles beyond FPL"s property and ~l plume of hypcrsnlinc has contaminated a large p(>rti(11i of the. Biscayne Aquifor. This hypcrsalinc plume and its inllueticc on the movement of saline water as much as four miles ,~*est ward tow,ird 1.:ritict-11 drinking water ~upplies has been an issue that FPL has ignored for years. In 2014. the C( *s tcmpcratw:c increased above the permitted range and emergcncy provisions

\\'ere grunted to alkm higher (lpcrating tcn'lpcraturcs and to tap into unpcrmittcd surface water supplies to reduce temperatures.

The ('CS experienced increased salinity, regulated nutrients.

~md other constituents during. this emergency.

It was later determined . .that the ('('S had not hccn properly 1irnintainccl fbr many ycnrs resulting in sediment acclnmdation that limited the voh.unc qf cooling water ,md _rcstrietccl the Witter tlow rcgimi; between th~ canals und the groundwater below and adjacent to the CCS. The prinmry impuet to the Floridu Keys from the foilurc *or FPL to conduct the operation of its plant apprqpriatcly is to have put at risk the source of nl I the pntnhle wntcr ,vc provide lo our customers.

If' our wells. which are l~>cuted upproximalely ten miles from thl! FPL plant. arc cqntaminatcd h)' the FPI. created high salinity plume. the entire water supply to the Fkirida Keys is gQllC.

Aller these FPL failures were discovered.

both the State of Florida and Miami-Dade County found FPL in violation of their opcnlling conditions.

Both the State and Miami-Dade County tile<,I regulatory and permit violations against FPL. FPL entered into Consent Orders with both entities rather than contest the violations in court. The primary clement of both orders is to reduce the salinities in the groundwater aquifer which have been contaminated by FPI.. Secondary impacts include nutrient loading from the CCS int(1 Biscayne Bay. Because of the magnitude of these probler11s and the sensiti,*ity of adjacent.

environmentally-sensitive areas. the improvements will take many years to achieve even under favorable .conditions.

There arc sei"ious concerns expressed by agency. university, and private sector experts that th<; plan proposed by FPL to fix the hypcrsaline problem i~ based on assumptions and analyses that arc incorrect and/or inadequate and therefore will not provide the needed scope, capacities.

and cost commitments to bring the aquifer back to pre-existing conditions.

Past and current operational issues caused hy PPL have led to the environmental degradation of a source aquifer and Biscayne Bay. FPL had shown little interest in dealing with these unpcrmittcd consequences of its operation until enforcement action was taken. Even with consent urders in place; there is no clear evidence that FPI. can resolve the issues they have caused by using the C'CS over n1any years nor can they prove that the CCS is still a viable option to handle thermal loads from the existing nuclear reactors.

FKAA believes that the existing damage to the local environment must he fully reversed before FPL is granted any additional increase to thermal load capacity at its Turkey Point po,,*cr plant. It makes no sense to allow this expansion when FPL has such a poor track record operating the existing system. FKAA also requests the lJSNRC require cooling towers be built for use ,vith the existing operation and the closure of the existing (.'C'S. Once built the lowers would alleviate the thermal loads being imposed by the CCS, leading to recovery llf the Biscayne Aquifer and Bay with proven technology.

We appreciate the opportunity to provide these comments to your Commission.

If there arc any questions regarding our comments.

please let me know at your earliest convenience.

Sincerely.

,1~*, ,,

• J .... /--\.,~ .* ,.. . Kirk C. .uc *h Fxccuth e Director cc: .I. Robert Dean. FKAA Board of Directors Antoinette M. Appell. FKAA Board of Directors David C'. Ritz. FKAA Board or Directors Cam Higgins, FKAA Board t\f Dircctors Richard .I. Toppino. FKAA Bon.rd of Dircclms George Neugent, Monrnc C'ounty Commissioner David Rice. Monroe County C\m1111issioner I >mmy Kol hage, Momoc County Commissioner I leather Carruthers.

Monroe County Commissioner Sylviu Murphy. Monroe County Commissioner Roman Ciastcsi, Monroe County Administrator RESOLUTION NO.17-033 A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF KEY WEST, FLORIDA, OPPOSING THE APPROVAL OF ADDITIONAL REACTORS FOR FLORIDA POWER AND LIGHT (FPL) AT TURKEY POINT NUCLEAR POWER PLANT; PROVIDING FOR AN EFFECTIVE DATE WHEREAS, FPL has requested to be granted the right to construct two new nuclear reactors at*their Turkey Point facility; and WHEREAS, the past operations of said nuclear facility by FPL has resulted in the creation of a large saltwater plume which threatens the Florida Keys and Key West with loss of its fresh water supply drawn from wells in the Biscayne Aquifer; and WHEREAS, the Florida Keys Aqueduct Authority (FKAA), the Florida Keys sole supplier of fresh water, has gone on record opposing the granting of the required permit to erect two new reactors at the Turkey Point Nuclear facility, because FKAA' s wells are located within 10 miles of the high salinity plume which exists as a direct result of said facility operations having taken inadequate environmental measure.s to guard against the possible degradation, past and current of the Keys water s.upply; and WHEREAS, the Florida Department of Environmental Protection (FDEl?) has found that the past and present operation of said nuclear facility to be in violation of State rules and requirements of the permits for operati.on granted them; and Pagel of 3 WHEREAS, the FDEP and FPL have worked out a settlement over these violations, which calls upon the utility to reverse and eradicate the flow of this plume; and WHEREAS, there is serious concern that the required eradication could be accomplished within the next 10 years, if at all; and WHEREAS, there is concern that the addition of more reactors will only acerbate the efforts to eradicate the dangerous plume and further jeopardize efforts to eradicate the plume, leading to the eventual loss of a fresh water supply for over 87,000 residents of the Florida Keys, and the important military installations located there. NOW, THEREFORE, BE IT RESOLVED BY THE CITY ~OMMISSION OF THE CITY OF KEY WEST, FLORIDA AS FOLLOWS.:

Section 1: That the United States Nuclear Regulatory Commission is hereby requested to deny the application of Florida Power & Light Company to construct additional nuclear reactors at its Turkey Point Nuclear. Power Plant, until the saltwater plume is completely eradicated and no longer poses a danger to the fresh water supply provided by the Biscayne Aquifer, from which the Florida Keys and its 87,000 residents and military in$tallation~

reqeive their supply of fresh water. Section 2: That the City Commission additionally reque~ts that the United States Nuclear Regulatory Commission not permit the addition of any more reactors, unless and until the elec:t.ric util.~ty Page 2 of 3 can demonstrate scientifically that its canal cooling system is a viable method to handle .thermal loads from its existing reactors . .Section 3: That this Resolution shall go into effect immediately upon its passage and adoption and authentication by the signature of the Presiding Officer and the Clerk of the Commission.

Passed and adopted by the City Commission at a meeting held this day of January ------------

2017. Authenticated by the Presiding Officer and Clerk of the Commission on __ l_B~~~h ___ day of January , 2017. Filed with the Clerk on January 19 -------------

Mayor Craig Cates Vice Mayor Clayton Lopez Commissioner Sam Kaufman Commissioner Richard Payne Commissioner Margaret Romero Commissioner Billy Wardlow Commissioner Jim.my Weekley Yes Absent Yes Yes Yes Yes Yes , 2017. i RESOLUTION NO.17-033 A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF KEY WEST, FLORIDA, OPPOSING THE APPROVAL OF ADDITIONAL REACTORS FOR FLORIDA POWER AND LIGHT (FPL) AT TURKEY POINT NUCLEAR POWER PLANT; PROVIDING FOR AN EFFECTIVE DATE WHEREAS, FPL has requested to be granted the right to construct two new nuclear reactors at their Turkey Point facility; and WHEREAS, .the past operations of said nuclear facility by FPL has resulted in the creation of a large saltwater plume which threatens the Florida Keys and Key West with loss of its fresh water supply drawn from wells in the Biscayne Aquifer; and WHEREAS, the Florida Keys Aqueduct Authority (FKAA), the Florida Keys sole supplier of fresh water, has gone on record opposing the granting of the required permit to erect two new reactors at the Turkey Point Nuclear facility, because FKAA' s wells are located within 10 miles of the high salinity plume which exists as a direct result of said facility operations having taken inadequate environmental meas~res to guard against the possible degradation, past and current of the Keys water supply; and WHEREAS, the Florida Department of Environmental Protection (FDEP) has found that the past and present operation of said nuclear facility to be in violation of State rules and requirements of the permits for operation granted them; and l?a.ge 1 of 3 WHEREAS, the FDEP and FPL have worked dut a settlement over these violations, which calls upon the utility to reverse and eradicate the flow of this plume; and WHEREAS, there is serious concern that the required eradication could be accomplished within the next 10 years, if at all; and WHERE.Ap, there is concern that the addition of more reactors will only acerbate the efforts to eradicate the dangerous plume and further jeopardize efforts to eradicate the plume, leading to the eve:r;1tual loss of a fresh water supply for over 87,000 residents of the Florida Keys, anci the important military installations located there. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF KEY WEST, FLORIDA AS FOLLOWS: Section 1: That the United Stat.es Nuclear Regulatory Commission is hereby requested to deny the application of Florida Power & Light Company to construct additional nuclear reactors at its Turkey Point Nuclear Power Plant, until the saltwater plume is completely eradicated and no longer poses a danger to the fresh water supply provided by the Biscayne Aquifer, from which the Florida Keys and its 87, ooo residents and military installations receive their supply of fresh water. Sec.ti.on 2: That the City Commission additionally requests that the United States Nuclear Regulatory Commission not permit *the addition of any more reactors, unless and until the electric utility Page 2 of 3 can demonstrate scientifically that its canal cooling i;;ystem is a viable method to handle thermal loads from its existing reactors.

Section 3: That this Resolution.shall go into effect immediately upon its passage and adoption and authentication by the .signature of the Presiding Officer and the Clerk of the Commission.

Passed and adopted by the City Commission at a meeting held this 18th day of January , 2017. on ----"------

Authenticated by the Presiding Officer and Clerk of the Commission

~~18_t_h~~-d~y of January , 2017. Filed with the Clerk on January 19 ------------

Mayor Craig Cates Vice Mayor Clayton Lopez Commissioner Sam Kaufman Commissioner Richard Payne Commissioner Margaret Romero Commissioner Billy Wardlow Commissioner Jimmy Weekley Page 3 of 3 Yes Absent Yes Yes Yes Yes Yes , 2017.

Florida Keys P ~~e~!!~!!ct Authority

l<Eiy West, Flonda '.33040 d{?' Telephone (305) 296-2454 ,<< * * ~Jl!ru1!;Q!!J l . . *C,, s,-.~\l&\~

.,, ... o::rL/~ Annette L. Vietti-Cook, Secretary US Nuclear Regulatory Commission Washington, D.C. 205SS-OOOI RE: DOCKETS 52.;040 AND 52-041 December 29, 2016 Issuance of Co111bined Uce11$es for FPL 's Turkey Point Units. 611,nd 7 Dear Secretary*

Vietti-Cook:

J. Robert Dean Chairman Distric;t3 Antoinette M. Appell Vice-Chairman District4 David C. RltZ. SecretaryTTreasurer Disirict 5. . . Cara tiigg~ District 1 Richard J. Toppino District 2 . Kirk C. Zuelch Executive Director This letter is to present issues for consideration at your Evidentiary Hearing on February 9; 2017 regarding the applicatio~

to construct and operate two ~ew nuclear plants in s<>utheast Miami-Dade County. The Florida Keys Aqueduct Authority is an independent Special District of the State of Florida with the responsibility of supplying the entire group of islan.ds known as the Florida Keys with drinking water from the Class I Biscayne Aquifer located in southeast Miami-Dade County. Our Board of Directors is appointed by the Governor of the State of Florida and has directed staff to prepare this leU~r in accordance with your corr~pondence, dated December 8, 20 l 6. For more than~ decade, Florida Power & Light Com~ny (FPL) has been out of compliance with operating requirements of its cooling canal system (CCS). The saJinity values in the CCS have risen to concentrations higher than fouod in seawater.

These high concentrations were not .contain~

to acceptable levels as required by FPL's interceptor canal, and as a result, hypersaline conditions,have migrated more than two miles beyond FPL's property and a plume ofhypersaline has contaminaJed a large portion of the Biscayne Aquifer. This hypersali11e plume and its influence on the movement of saline water as much as four miles westward toward critical drinking water supplies has been an issue that FPL has ignored for years. In 2014, the CCS temperature increased above the pennitted rang~ and emergency provisions were granted to allow higher operating temperatures and to tap into unpermitted surface water supplies to r~duce t~mperatures.

The CCS .experienced increased salinity, regulated nutrients, arid other cpns*Uuents during this ~m~rgency.

It w~ later .detennined, that the CCS 1)-.<I not been properly maintained for many years resulting in sediment accumulation that limited the volume of cooling. water end re$tricted the water flow regime between the canals* and the groqndwater below and adjacent to the CCS. The primary impact to the Florida Keys from the failure of FPL .to conduct the. operation of its plant appropriately is to have put at risk the source of all the potable water we provide to our customers.

If our welis, which are* tocated approxiQ'lately ten miles. frc;,m lh.e FPL plarit, are contaminated by the FPL created high salinity plume, the entire water supply to the Florida Keys is gone.

After these FPL failures were discovered, both the State of Florida and Miami-Dade County found FPL in violation of their operating conditions 1 Both the State and Miamj-Dade County fil~d regulatory

• and pennit violations

• against FPL. FPL entered into Consent Orders with both entities rather than contest the violations in coui:t. The primary element of bot~ orders is (Q i:educe Jhe salinities i11 the groundwater aquifer which have been contaminated by FPL. Secondary impacts include nutrient loading from the CCS into Biscayne Bay. Because of the magnitude of these probJenis an~ the sensitivity of adjacent, environmeritally-se11sitive areas, the improvement~

will take many years to achieve even under favorable conditions.

• There are serious concerns expressed by agency; university, and private sector experts that the plan proppsed by FPL to fix the hyj:,ersaline problem is based 01.1 assumptions and analyses that *~ incorrect and/or inadequate and therefore will not provide the needed scope, capacities; and cost commitme~ts to bring the aquifer back to pre-existing conditions.

• Past and current operational issues caused by FPL have led to the environmental degradation ofa source aquifer and Biscayne 13ay. f'.PL had shown little interest.

in _dealing witll these unpennittcd consequences of its operation until enforcement action was taken. Even with consent orders in place, *there is no clear evidence.

t'1at FPL can resolve the issues they have caused by using the CCS over . many years nor can they prove that the CCS is still a viable option to handle thermal loads from the existing nuclear reactors.

FKAA believes that the existing damage to the local environment must be fully reversed before FPL is granted any additional increase to thermal load capacity at its Turkey Point power plant. It makes no sense to allow this expansion when FPL has such a poor track record operating the existing system. FKAA also requests the USNRC require cooling towers be built for use with the existing operation .and the closure of the existing CCS. Once buili, the towers would alleviate the thermal loads being impo~d by the CCS, leading to recovery of the Biscayne Aquifer and Bay with proven technology.

We apprecia(e the opportunity to proviqe these comments to your Comµiission.

If ihere are any questions regarding our comments, please let me know at your earliest convenience.

Sincerely, 14,~_QQ Kiri< C. ue h

• Executi ~tor cc: J. Robert Dean, FKAA Board of Directors

• Antoinette M. Appell, FKAA Board of Di~ctors David C. Ritz, FKAA Board ofDirectors cara Higgins. FKAA Board of Di.rectors Richard i. Toppino, FKAA Board of Directors George Neugent, Monroe County :Commissioner David Rice, Monroe County Commissioner Danny Kolhage, Monroe County Commissioner Heather Carruthers, Monroe County Commissioner Sylvia Murphy, Monroe County Commissioner Roman Gastesi, Monroe County Administrator RESOLUTION NO.-----A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA 1 SUPPORTING EFFORTS TO SEEK A COMMITMENT FROM FLORIDA POWER & LIGHT TO DISCONTINUE THE USE OF THE COOLING CANAL SYSTEM AT THE TURKEY POINT NUCLEAR POWER PLANT AS SOON AS POSSIBLE.

WHEREAS, the Florida Power & Light (FPL) 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, FPL's 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 1 water from this cooling canal system communicates with the surrounding groundwater 1 and long-term 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, FPL 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, Miami-Dade County took action to address this issue, including, but not limited to, issuing a Notice of Violation in 2015 to FPL for certain water quality violations in the groundwater and requiring, through an administrative consent agreement, that FPL take certain remedial actions to retract and contain the hypersaline ground water plume; and WHEREAS 1 at that time, the issµes were focused on the westward migration of the hypersaline groundwater plume from the cooling canals; however, more recent water quality sampling has detected levels in excess 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, on May 11, 2016, the Mayor and City Commission of the City of Miami Beach passed and adopted Resolution No. 2016-29405 regarding FPL's violation of State water quality stc1ndards in the operation of its cooling canal system and urged the Florida Department of Environmental Protection to take action to protect the residents of southeast Florida from the hazards of saltwater intrusion into the Biscayne Aquifer and Biscayne National Park; and WHEREAS, the Biscayne Aquifer is an important natural resource which supplies fresh drinking water to millions of South Florida residents and is vital to irrigation and to Florida's marsh and wetland communities; and

• • .. * . ., . WHEREAS, the Mayor and City Commission of the City of Miami Beach join Monroe County in seeking a commitment from FPL to discontinue the use of the cooling canal system in favor of a more modern mechanical draft cooling tower system that would remove all future interactions with groundwater and make use of Miami-Dade County's reuse water. NOW, THEREFORE, BE IT DULY RESOLVED BY THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, that the Mayor and City Commission hereby support efforts that seek a commitment from FPL to discontinue the use of the cooling canal system at the Turkey Point Nuclear Power Plant as soon as possible.

PASSED AND ADOPTED this 22"dday of March, 2017.

• ATTEST: Philip Levine, Mayor Rafael E. Granado, City Clerk F:IA1TO\TURN\RESOS\Reso re: FPL Discontinue use of Cooling Canal System 2017.doc RESOLUTION NO. 043 -2017 A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF MONROE 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 POSSIBLE; . 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 use$ 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-term monitoring data has shown that a hypersaline plume of water from the cooling carials 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 issue, 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 commitment from Florida Power .and . Light to 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 of 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 commitment 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 15 1 h day of February, 2017. Mayor George Neugent Yes Mayor Pro Tern David Rice . Yes Commissioner Danny Kolhage Yes Commissioner Heathe!" Carruthers Yes Commissioner Sylvia Murphy Tu, BOARD OF COUNTY COMMISSIONERS

,];;:.n::? Mayor ?-:: "'Tl Page 2 of2 ::, ("" f"T1 :::>r co r,::.,:: ,* N -., .-::,r, N 0 ,**--;:o _., (""' ;*,_ ,-**q United States Department of the Interior National Park S~rvice l.A.2 Mr. James D. Gianina, Director Water Protection Division US EPA Region 4 61 Forsyth Street Atlanta, GA 30303 Biscayne National Park 9700 s. w. 328th .Street Homestead, J.1orida 33033-5634 May 13,,2016 Mr. Jonathan P. Steverson.

Secretary Florida Department of'Environmcntnl Protection 3900 Commonwealth Bivd Tallahassee, FL 32339 Mr. J;iclc Ostcrholdt, Director Department of Regulatory and Economic Resources Stephen P. Clark Center 111 NW i.i Street, Ii t!i Floor Miami,FL33i28 I>car Sirs: Biscayne National Park (BNP) has ongoing conccms with the operation of Units 3 & 4 of Florida Power and Light's (FPL) Turkey Point facility.

A primary concern is the potential for salt, nutrients and other J polfotants in the facility's Cooling Canal System (CCS) to flow and disperse via ground or surface water connections into Biscayne Bay and BNP .. Recent monitoring 4ata qas confirmed tlJat water from the CCS is hydrologically connected to the Bay, with CCS water moving through or underCCS benns. These data have also confmned that nutric;nts (phosphorus arid nitrogen) have been added to the Bay system in concentrations that exceed the Numeric Nutrient Criteria (NNC) (62-302:532 F.A.C.} adopted by the State offlorida Department of Environmental Protection (fDEP) and approved by the U.S. Environmental Protection Agency (EPA) for Biscayne Bay~ These nutrients can stimulate algal growth and increase chlorophyll a contentrations above the NNC criterion.

We are aware that discussions arc occurring among the regulatmy agencies regarding how to best address this situation.

BNP respectfully requests tllatyou include the National Park Service (NPS) in yo~ deliberations.

The NPS is required by law to "conserve the scenery, natural and historic objects, and wild life ... in such manner and by such means as will leave them unimpait-cd for the cnjoymc."llt of future generations." (54 USC I 00 l O 1( 1 )) Because of our special expertise.

regarding BNP and Biscayne Bay, we are well suited to provide assistance.

The original scope and extent of sampling identified in the Units 3 and 4 Uprate Monitoring Plan, approved in tJ1e Fifth Supplemental Agreement with the' South Jllorida Water Management District (SFWMD), J.'DEP, and Miami-Dade County Regulatory and Economic Resources I>ivision.ofEnvironmental Resources Management (RER-DERM), needs to be reestablished as a requirement in order to assess the impacts of the CCS. In addition, we request the following new requirements be added. r-';_,,------------------------------*-*--**-*--*--*-----

FPL Turkey Point S/13/2016 Page2of2 First, we call for establishing a more extensive nearshore water quality monitoring network that is maintained by FPL and provides data on potential loading of nutrients and other contaminants to the Bay, as well as identifying the ecological impacts that FPL operations have on the Bay. BNP would like to participate in developing this monitoring plan and would like the data to be made available to BNP and regulatory agencies on the same schedule and under the same Quality Assurance Plan that initially was adopted for implementation of the Uprate Monitoring Plan. This monitoring effort would serve as an early warning system to alert all affected parties of any increases in nutrients and other contaminants to the Bay from CCS operations.

Moreover, this monitoring could be linked to other monitoring efforts so that managers and decision makers have a broader view ofw-dtcr quality and any potential impacts in the Bay. .]//' .L n r~f P]... n~l-ec(~c!,'.

Second, we call for FPL to be required to develop a strategy for maJ!aging CCS salinity, nutrients, and J -/: J +!, :S other potential pollutants to prevent impacts to the Bay. This strategy should be developed in concert with J ;_ "i 1 ,. 5 BNP and the regulatory agencies.

Every feasible a:;pect of controlling nutrient and salinity loadings to the , 0 r *.J . ~' Bay should be considered, while not affecting freshwater flows to BNP or the Comprehensive Everglades

-+ r.:>""' l 'l 7 ?...-Zo /0 Restoration Plan (C'ERP). Perfonnanec criteria for the CCS should be established for nutrients (particularly phosphorous, ammonia, total nitrogen and total suspended solids) and salinity.

We suggest havin.g this J JI<. F strategy as a requirement ofFPL's NPDES (National Pollutant Discharge Elimination System) permit for . f L .J.-f the CCS. C\l fr.'( i.J I '/ J ( {c_~"'i , .... J Third, BNP is concerned with the relatively shallow ( 4S ') injection well used for wastewater discharge at ., / ( u f IM. f / hi the plant. We suggest there is the potential for nutrient-laden wastewater to migrate via the gro1mdwater r { 1.,v* c connection to the Bay, and also contribute to cooling system biofouling which requires chemicals to C:&\41~ .!! {( control. We suggest that the regulatory agencies work with FPL to facilitate wastewater transfer to the -f o ~.Jr I "-:* t' regional sewage treatment system or implement anotl1er treatment and disposal route that is protective of ~II 'if;, 5 < .., f adjacent waters. v: ,../,. f <<'ld ,; Finally, we suggest the establishment of an interagency adaptive management working group that would biannually review monitoring data and performance crit('.ria, and recommend any adjustments necessary to ensure the ,fater resources of the Bay are protected.

The performance criteria established would provide the basis for management actions, should the data indicate the potential for wa~cr quality issues and impacts associated with algal blooms, changes 1n biotic communities, scagrass die-offs, or other ecological concerns.

This group would also be valuable in monitofuig the effects of construction activities for the proposed Units 6 & 7, should those reactors be built. We rec<immcnci that this group be comprised of members of the regulatory community (DERM, FDEP, SFWMD, EPA), as well as the NPS and FPL. We appreciate your consideration of these matteis, irrespective of any enforcement actions the regulatory agencies may take. We believe this level of vigilance is warranted 10 protect BNP now and in the future. Questions can be addressed to BISC _ Supcrintendcnt@nps.gov, or you can contact me at 786.335-3~6.

Sincerely, William L. Cox Interim Superintl.-n~ent

• ' .J._ I fQfW,t\ < ,4~Jt lkar Co:.inty Commi:;:;ionr:rs, 1hc Florida Powe: & U.rht c,:n:i.l :;ystcm 1.1t Turkey !'(lint Nudc:u-Powi.'r Plant h:i~ been. ond co:i.tir.ucs.

to be. a co.nc:cm to the resident::

of the Occ:m Rc1..{ Comm1.:.."lity.

lhis wolbg c:i.P...il

,~*~tcm intcrncts with the r.urround:n~:

grnundwntcr;

!o:i,g-tcrm mm:ito:ing d:itu hn" :.h,l\\n th:ll a hypcrs1.1linc plume in the watn hz bcci mir,rating ttw,rud the: drinking w:itCT bcyorui the bound:!."lcs of the n>olin~ r=al .!ml ::; now cnt1:ring tile surface wu!crs (lf Biscayne N::uional P::rk. We O.K" very co:ircrr.t'.c

ibout m:rn: di:;covcr;c; relating to the im~l"ts (\:l ifo.i;*ay:1, !by und oclic,.*c-it i:; time to <lisrnr.:inuc the use of :he ,:nol:ng c::mal :;y:;tcm in farnr o!* 1.-nolinr; towns. Coinciclrnt!y, Miami-D.:a!i:

County hus a r:ccd lu *utiliz.:

their reuse water in order to dimi:u!c w:itcr qt::i.li:y pmhlc:n::;

c.:u::.cd by tl1.:ir scwa5c sy::tc:n.

Now i~ Ille time to solve thc:;c :wo w..::j,1:

cnvirorimrnml i'.iSul'$

by b.iit<l,ng coo!inz tow..:rs and utili:,ini; misc \,-.itc:r.

We cm:our.agc tile Mun."\ll.~

County !fo:::rtl of Coumy Commissiom:rs t<> odop, the :illu.riicd p::op.,5rd n.-solctiun supporti.'lg thc~.c dfon~ .. \\'c f'.r~!ly :ip;m:d:!tc you~ :i:!c:1:ion to thir. tr.:l:tc.

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• n:.7 .;'t~:l TITL~~ RESOLUTION SUPPORTING EFFORTS TO SEEK A COMMITMENT FROM FLORIDA POWER & LIGIIT COMPANY TO DI8CONTINUE USE OF TIIi~ COOLING CANAL SYSTI~M AT THE TURKEY POINT POWER PLANT BODY WHEREAS, the Florida Power & l,ight*s (FPL) Turkey Point 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 no other system of its kind operating anywhere in the world; and

• WlmREAS, water from this cooling canal system interacts with the surrounding groundwater, and long-tenn monitoring data has shcn.vn that a hypersalinc plume of cooling canal water has been migrating in the f,'TOundwater, beyond the boundaries of the cooling canals, contaminating drinking water to the west and entering the surface waters of BNP to the ea<;t; and WI mREAS, Miami-Dade County Department of Environmental Resources Management (DERM) and the Florida Department of Environmental*

Protection (DEP) have taken some action in response to violations of water quality standards including, hut not limited to. issuing a Notice ofViolaticm In 2015 to FPL for certain water quality violations in the groundwater, and requiring, through an administrative consent agreement, that FPL take certain actions to retract and contain the hypcrsaline groundwater plume; and WHEREAS, at that time, the issues were focused on the hypcrsaline groundwater plume migrating west of the cooling canal system; and WHEREAS, more recent water quality sampling detected excee.dances of State and Miami-Dade Cmmty water quality standards in surf ace water locations in and connected to Biscayne Bay, adjacent to and east of the cooling canal system; and WHEREAS, this Board, as well as residents of this County and members of the general public, are concerned about these recent dis,:overies and the impacts on Biscayne Bay, and such discoveries further highlight the challenges posed by the continued operation of the cooling canal system; and WHEREAS, FPL hac; a license from the federal goverwncnt to operate the Turkey Point power plant units that use the cooling cmial system until 2033; and WHEREAS, the County is seeking a commitment from FPL to discontinue the use of the cooling canal system in favor of efficient, commonly-(..,'IDployed technology such as cooling towers; and WHEREAS, information and analysis recently made available to the County suggests that the use of mechanical draft closed-cycle cooling towers combined with the elimination of cooling tower wastewater discharges (through the Zero Liquid Discharge (ZLD) system), represents the best available technology for eliminating the water quality problems being caused by the Turkey Point cooling canal system and \vould remove all interactions with the aquifer and make use of Miami Dade County re1L<;e water; and WHEREAS, FPL with spend a minimum of 50 Million Dollars a year for over at least a ten-year period for remediation alone and it is unclear if the extrnction wells proposed *will have a negative impact on the surrounding environment, while this technology could he completed in a more timely and affordable manner; and WHEREAS, this technology can he used beyond 2033 if needed for a variety of energy generation technologies that FPL might pursue and can reduce *bann to the surrounding environment and water supply in comparison to the failing cooling canal system; and WHEREAS, current plans for remediation that DEP and DERM have proposed and FPL is operat1ng under will not address the interactions v.~th the Aquifer and Biscayne Bay alone; and WHEREAS, this Board wishes to express its support for the Miami Dade County Mayor's efforts to obtain such a commitment from FPL, NOW, THEREFORE.

BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA, that this Board supports the efforts by Miami Dade County and the Environmental community to seek a commitment from Florida Power & Light to discontinue the use of the cooling canal system at the Turkey Point Power Plant as soon as possible, in favor of cooling towers.

Mia Dade TPP 3 & 4 resolution 07-16.pdfwas submitted as a password protected document and could not be opened and added to this Adobe file. 7/5/2018