ML23312A068
| ML23312A068 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/07/2023 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 88FR62110 | |
| Download: ML23312A068 (8) | |
Text
From: Kajumba, Ntale <Kajumba.Ntale@epa.gov>
Sent: Tuesday, November 7, 2023 9:56 PM To: Lance Rakovan Cc: Long, Larry; Buskey, Traci P.
Subject:
[External_Sender] EPA Comments on Turkey Point Unit No 3 and 4 SDEIS Attachments: Turkey Point Unit No 3 and 4 SDEIS- 20230112.pdf Greetings Lance, Attached is EPAs comment letter for Site-Specific EIS for License Renewal for Turkey Point No 3 and 4 (SDEIS). Let us know if you have questions regarding these comments and we can follow up.
Ntale Ntale Kajumba NEPA Manager Strategic Programs Office U.S. EPA Region 4 61 Forsyth Street, S.W.
Atlanta, Georgia 30303 Tel: (404) 562-9620 Email: Kajumba.ntale@epa.gov
Federal Register Notice: 88FR62110 Comment Number: 7 Mail Envelope Properties (SA0PR09MB7322C06521104AC984A8FE1AF9A8A)
Subject:
[External_Sender] EPA Comments on Turkey Point Unit No 3 and 4 SDEIS Sent Date: 11/7/2023 9:56:24 PM Received Date: 11/7/2023 9:56:45 PM From: Kajumba, Ntale Created By: Kajumba.Ntale@epa.gov Recipients:
"Long, Larry" <Long.Larry@epa.gov>
Tracking Status: None "Buskey, Traci P." <Buskey.Traci@epa.gov>
Tracking Status: None "Lance Rakovan" <Lance.Rakovan@nrc.gov>
Tracking Status: None Post Office: SA0PR09MB7322.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 414 11/7/2023 9:56:45 PM Turkey Point Unit No 3 and 4 SDEIS- 20230112.pdf 353563 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW ATLANTA, GEORGIA 30303-8960 November 11, 2023 Lance Rakovan U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Mail Stop T-4B72 11555 Rockville Pike Rockville, Maryland 20852 RE: EPA Comments on the Site-Specific EIS for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, NUREG1437, Supplement 5a, Second Renewal Docket NRC-2022- 0172, CEQ 20230112
Dear Lance Rakovan:
The U.S. Environmental Protection Agency (EPA) has reviewed the Nuclear Regulatory Commissions (NRC) Supplemental Draft Environmental Impact Statement (SDEIS) in accordance with Section 309 of the Clean Air Act and Section 102(2)(C) of the National Environmental Policy Act (NEPA). The CAA Section 309 role is unique to the EPA. Among other things, CAA Section 309 requires the EPA to review and comment on the environmental impact of any proposed federal action subject to NEPAs environmental impact statement requirements and to make its comments public.
The current licenses for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point) expire on July 19, 2032, and April 10, 2033, respectively. The purpose of the SDEIS is to address the environmental effects associated with obtaining relicense renewals for Florida Power & Light Companys (FPL) Turkey Point facility. Subsequent renewed operating licenses evaluated in this SDEIS would authorize FPL to operate Turkey Point for 20 years beyond the period in each of the current licenses.
The SDEIS evaluated three feasible alternatives, along with the no-action alternative, that were evaluated in the 2019 Final Supplemental Environmental Impact Statement (FSEIS). These alternatives include:
- 1. An alternative for new nuclear power.
- 2. An alternative for new natural gas combined-cycle power.
- 3. An alternative with a combination of new natural gas combined-cycle power and new solar photovoltaic power.
The no-action alternative would result in the NRC not authorizing the operation of FPLs Turkey Point facility for an additional twenty years. The SDEIS does not include the NRCs recommended alternative. According to the SDEIS, NRCs recommended alternative will be presented in the Supplemental Final Environmental Impact Statement (SFEIS) and the NRC will make a final decision on the subsequent license renewal (SLR) in the Record of Decision.
Summary:
The EPAs environmental concerns are associated with surface and groundwater resources, radionucleotides, climate change, and environmental justice, along with the cumulative impacts associated with discharges from these sources. We reiterate some of our primary comments in our agencys FEIS comment letter dated December 12, 2019, and our Notice of Intent response letter dated November 7, 2022. We have attached detailed comments for your review. We request that our comments be addressed in the SFEIS and included in an analysis for any severe accident mitigation alternatives (SAMAs) conducted for this license renewal.
The EPA appreciates the opportunity to review the SDEIS. If you have any questions regarding our comments, please contact Larry Long of the NEPA Section at (404) 562-9460, or by e-mail at long.larry@epa.gov.
Sincerely, Kajumb Digitally signed by Kajumba, Ntale a, Ntale 21:51:03 -05'00' Date: 2023.11.07 Ntale Kajumba NEPA Manager Strategic Programs Office
Enclosure:
Detailed Comments
EPA Detailed Comments on Site-Specific EIS for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, NUREG1437, Supplement 5a, Second Renewal Docket NRC-2022- 0172 CEQ 20230112 Water Resource The SDEIS states that the Florida Power and Light (FPL) operates five groundwater withdrawal systems at Turkey Point to support plant operation, including:
- 1. Closed-Cycle Cooling System (CCS) freshening wells that withdraw brackish water from the Upper Floridan Aquifer (UFA).
- 2. Biscayne Aquifer marine wells that withdraw salt water to supplement CCS freshening.
- 3. Several Unit 5 production wells withdraw brackish water from the UFA to support operations of Turkey Point Unit 5.
- 4. Recovery Well System (RWS) wells that withdraw saltwater from the Biscayne Aquifer for control of the CCS hypersaline groundwater plume.
- 5. Use of Underground Injection Control (UIC) wells for the disposal of hypersaline plume fluids collected from extraction.
The EPA notes that the NRC concluded that the probability-weighted consequences of severe accidents are SMALL for all plants (NRC 1996). Nonetheless, the NRC has required that an analysis of severe accident mitigation alternatives (SAMAs) be conducted for license renewal if such an analysis has not been conducted previously (NRC 1996). The EPAs concerns that need to be evaluated in depth for any SAMA with these systems are as follows:
Surface Water The FPL institutes stormwater and Industrial Wastewater (IWW) programs to prevent or minimize the generation and potential for releases of pollutants from nuclear power plant operations via stormwater and the CCS. FPL assesses facility components and systems under the IWW Best Management Practices (BMPs) program for possible waste minimization and implements measures to reduce waste loadings and chemical losses to wastewater and stormwater streams.
Section 2.7 discusses the Turkey Point effluents discharges. The EPA is concerned about the potential adverse impact of seepages from the facilitys CCS, except for treated wastewater on waters of the United States. The seepage is routed to the CCS, which is a permitted IWW facility (National Pollutant Discharge Elimination System (NPDES) Permit No. FL0001562) and does not discharge through a point source to surface waters of the state, although it appears that some CCS waters has infiltrated to the underlying Biscayne Aquifer at the facility.
Although the Industrial Wastewater Facility (IWF) is a CCS, it appears not to be a closed hydrologic system and as such, the SFEIS for permit renewal of the NRC license needs to include a water balance calculation for the site that shows all the potential sources of water supplying the site and discharges and other releases from the site under normal operating conditions. This water balance should include seepages from the canal system and changes in evaporative losses. The SFEIS should discuss the potential impacts of increases in nutrient loading and other pollutants on the underlying Biscayne Aquifer via seepages. Additionally, the SFEIS needs to address the integrity of the IWF to retain releases of IWF wastewaters to waters of the United States. The EPA also recommends the NRC address the structural integrity of the CCS. While the current NPDES permit requires monitoring of the berms for structural issues to ensure that there are no point source discharges from the cooling ponds to
the adjacent surface waters, the facility needs to use relevant techniques to verify that all CCS barriers are intact and able to retain nutrient-rich wastewater. This issue should be considered as part of the Aging Management Program or other relevant mechanism and include the potential discharges of increased peak storm events such as tropical storms and hurricanes.
Water Quality Standards The SDEIS states that impacts on aquatic resources would be small. However, the impacts of thermal pollution on dissolved oxygen (DO) and primary productivity (i.e., eutrophication) are discussed in generalities. Other parameters, such as metals, are also only discussed generally.
The SDEIS acknowledges past impacts to Biscayne Bay and Card Sound including Biscayne National Park (Outstanding Florida Water). Even though there are no wetland nutrient standards (salt marsh canal system), the existing and high-quality characteristics of Biscayne Bay and Card Sound including Biscayne National Park, should be protected from impacts of cooling canal system discharge(s).
Recommendation - Citations from the state of Floridas water quality standards need to be included with a related discussion for how those standards will be met to keep the impact on aquatic resources small.
Floridas water quality standards are located at 62-302, Florida Administrative Code (F.A.C.). There are standards for dissolved oxygen (62-302.533) and a narrative standard, which would apply to thermal discharges (62-302.500(1)(b) , F.A.C.). Metals criteria are in 62-302.530, F.A.C. and nutrients are at 62-302.531, F.A.C. These should all be discussed in the relevant subsections of the EIS under 2.10.
A discussion of the baseline water quality associated with the Biscayne National Park Outstanding Florida Water and the protections provided by this project should be included in the SFEIS. Outstanding Florida Waters are in 62-302.700, F.A.C.
Indirect and Cumulative Impacts Several potential cumulative and indirect project impacts are of concern at Turkey Point, including radionuclides in surface water and groundwater, along with hypersalinity (i.e., other issues are highlighted in enclosure). The existing unlined IWF/CCS for Turkey Point has issues regarding radionuclides and hypersalinity releases to the adjacent Biscayne Bay and the surrounding terrestrial environment that could potentially contribute to existing issues, thereby increasing cumulative impacts.
The hypersaline plume in the aquifer related to the CCS is the EPA's primary concern. The EPA notes that the Florida Department of Environmental Protection (FDEP) and the Miami-Dade County Department of Environmental Resources Management (DERM) have historically entered into consent agreements with FPL to address issues related to the CCS. The EPA supports the FDEP and DERM's efforts to work with FPL to remediate impacts of the hypersaline plume in the aquifer and the ammonia releases to surface waters. Past consent agreements have outlined corrective actions to address issues related to the CCS.
Recommendations - The EPA recommends that the NRC and FPL provide a detailed discussion in the SDEIS that reassesses alternative corrective measures outlined in the Consent Order 16-0241, and the 2009 monitoring plan; and FPL provide a detailed plan regarding mitigation procedures and processes to address the corrective measures. The EPA also recommends that NRC consider incorporating language in future license that states that FPL has developed and submitted an alternative mitigation plan to address water quality if FPL's future monitoring results demonstrate that the corrective measures identified in the consent agreements were not effective.
Groundwater Impacts Specifically, the SDEIS needs to address the condition of the Biscayne aquifer, an EPA-designated sole source aquifer serving as a drinking water resource in South Florida. The Biscayne aquifer has a history of hypersalinity impacts, and the EPA is concerned that the proposed project may result in further migration of a hypersaline lens towards a public water supply well. We are concerned about the potential for additional and cumulative impacts to the sole source aquifer, in addition to the risk to this public drinking water supply.
Section 2.8.2.2 discusses the Upper Floridian Aquifer, and new information that was considered in this SDEIS. Recommendation - Please clarify where information regarding cumulative impacts associated with the Floridian Aquifer is located.
Radionuclides - Section 2.61 on page 2-10 and Section 2.14 on page 2-68 discusses existing and historic operations at Turkey Point that have resulted in radionuclides (tritium, strontium, cesium) migrating into Biscayne Bay and local groundwater. Existing and historic operations at Turkey Point have resulted in radionuclides (tritium, strontium, cesium) migrating into Biscayne Bay and local groundwater. We have concerns regarding potential cumulative impacts and environmental stressors related to additional discharges.
Recommendation - The SFEIS should provide updated information regarding the progress in defining the extent of the contamination and its sources. Updated sampling data should be included or referenced in the SFEIS, with modeling information included regarding potential cumulative impacts. The updated data needs to be evaluated in depth for SAMAs conducted for the facility. A discussion that focuses on potential cumulative impacts to the Floridian Aquifer should be included.
The EPA recommends that hypersalinity, underground injection of effluent impacts to the Biscayne Aquifer system, and radionuclides be included in any analysis of SAMAs conducted for license renewal and that the SAMAs be provided for public comment, if feasible.
SAMA Lines 46-48, page XIX references Appendix F (2019 FSEIS), and those lines indicate that new and significant information was evaluated that could alter the conclusions of the severe accident mitigation alternatives and that a SAMA analysis was performed. The EPA notes that Appendix F was not available in the 2019 SFEIS. Based on a recent conversation with NRC, on 10/27/23, NRC indicated that the citation was incorrect and that the correct appendix is Appendix E Recommendations - The EPA recommends that the SFEIS provide the correct reference to any new significant information since the 2019 FSEIS. The EPA notes that information from the 2019 document may have changed and that the SAMA information should reflect those changes. The FSEIS should discuss how Consent Order 16-0241, June 20th, 2016, along with the 2009 monitoring plan and statistics, were considered in the SAMA analysis.
Climate and Greenhouse Gas Climate change may impact the proposed project, posing threats to aging infrastructure, worker health and safety, and the environment. The EPA notes that NRC concluded that greenhouse gas impacts on climate change from Turkey Point SLR is small. In addition, the SDEIS referenced Section 4.15.3.1 of the 2019 FSEIS which discussed observed changes in climate and the potential future climate change across the Southeast during the Turkey Point SLR period, based on climate modeling.
The EPA acknowledges climate studies cited in the 2019 SFEIS and referenced in the SDEIS, including those by the U.S. Global Change Research Program, the IPCC, the EPA, and the National Oceanic and Atmospheric Administration (NOAA 2013, USGCRP 2018). While a more recent sixth assessment synthesis report by the Intergovernmental Panel on Climate Change (IPCC), was identified and assessed as part of the SDEIS, NRC continues to conclude that climate change impacts on environmental resources, have been addressed (2019 FSEIS and SDEIS).
Recommendations - The EPA recommends that the SFEIS provide a more detailed description of climate models used for determining storm surge and flooding, including the rationale for utilizing another model over the Sea, Lake, and Overland Surges from Hurricanes (SLOSH) model, which is used by the National Weather Service when determining storm surge predictions. If no updated modeling was performed for this SDEIS, the SFEIS needs to state why modeling would not be of value as part of the SAMA evaluation.
We recommend that the SFEIS include further evaluation or more updated site-specific climate-related impacts, including discussions of the frequency and severity of major storm events, wildfires, or droughts that could lead to power disruptions or increased cooling demands in summer months. Efforts that FPL is taking to address and adapt to potential climate impacts should also be discussed in the SFEIS.
Environmental Justice In Section 4.16 of the 2019 FSEIS, the NRC evaluated the overlapping impacts of climate change on environmental resources (air quality, water resources, aquatic resources, socioeconomics, historical and cultural resources, and environmental justice (EJ)) for which the NRC found there are incremental impacts due to Turkey Point SLR. In 2019, data from 2010 was used for the NRCs EJ analysis, which is currently outdated.
Recommendations - The EPA recommends including an updated detailed EJ analysis in the FSEIS, which should include 2020 census block data. The SFEIS also needs to discuss any cumulative impacts associated with Consent Order 16-0241, June 20th, 2016, and the FPL 2009 monitoring plan that may have potential implications for surrounding communities including communities with EJ concerns.
The FSEIS should include an analysis consistent with the EJ Executive Order (EO) 12898. The analysis should indicate whether minority, low-income, or other overburdened populations reside within the vicinity of the proposed project area based on current census data. The EJ analysis should also be completed in accordance with the new EO 14096, Revitalizing Our Nation's Commitment to Environmental Justice for All, published April 21, 2023.
It would also be helpful to include a current map depicting the population demographics near the FPL facility. The EPAs EJSCREEN tool can be used for preliminary screening to help identify potential issues.