ML23331A982

Exhibit 2, Request for Hearing and Petition to Intervene Submitted by Miami Waterkeeper

ML23331A982
Person / Time
Site:	Turkey Point
Issue date:	11/03/2023
From:	Stoddard P Miami Waterkeeper
To:	NRC/SECY/RAS
SECY RAS
References
RAS 56848, 50-250-SLR-2, 50-251-SLR-2
Download: ML23331A982 (0)

Text

EXHIBIT 2

1 DECLARATION OF PHILIP K. STODDARD, PH.D.

I, Phillip Stoddard, declare as follows:

1.

I make this declaration of my own personal knowledge. If called to testify as a witness, I could and would testify competently regarding its contents.

2.

I am a current member of the Miami Waterkeeper. I joined Miami Waterkeeper because I care about the environment and believe that it is not being adequately protected. I am particularly worried about climate change and sea level rise, contamination of water, and the consequent potential impacts on human health and on the natural world. One of the reasons I have contributed to the Miami Waterkeeper was because of my concerns about the Turkey Point Nuclear Generating Station and the special risks that the commercial operation of nuclear plants in a hurricane zone, subject to storm surge, poses to the surrounding environment and communities.

3.

I live at 6820 SW 64th Court, South Miami, Florida. I have lived at this address for about twenty years.

4.

My home is approximately 18 miles from the Florida Power & Light (FPL),

Turkey Point Generating Station (TPGS), Units 3 and 4 in Homestead, Florida. I am aware that TPGS nuclear facility is seeking to have its operating license renewed for another 20 years by the Nuclear Regulatory Commission (NRC).

5.

I used to be a fan of nuclear power because of its relatively low carbon footprint. Then I began looking into the safety record and environmental conditions at Turkey Point. As I studied the plant and its safety plan, I came to recognize greater hazards and environmental costs than had been made public. I was elected Mayor of the City of South Miami, Florida, in part because of my familiarity with these issues. My participation in public

2 discussion of these issues has spanned nearly a decade. In the course of this participation, I physically toured the TPGS facility with FPL staff following the Fukushima accident, as part of FPLs program to assure elected officials that their own nuclear operation was safe. During the proposed licensing of planned Units 6 and 7, I reviewed licensing documents and other material related to safety issues and severe accident risks posed by the TPGS facility, and I consulted with experts in nuclear safety and risk assessment concerning the risks of operation of the reactors.

6.

I do not believe that the NRC has adequately assessed the full-scale, long-term consequences of continued operations of the cooling canals, a poorly conceived cooling system design that is unique to this site of porous geology. Saline leakage, overheating, evaporative concentration of salt, and storm washout are harmful to the southern reaches of the Biscayne Aquifer, Biscayne Bay, and the Southeast Coastal Everglades. Aquifer pollution, such as the hypersaline and tritium-laced waters leaching from the TPGS cooling canal system, threatens our sole source aquifer, which is also habitat for the Miami Cave Crayfish (Procamberus milleri), which U.S. Fish and Wildlife Service recently proposed to list as a threatened species under the Endangered Species Act. Of greater concern, leaching of cooling canal water eastward to Biscayne Bay, particularly during episodic flushing events following heavy rains, threatens the remaining seagrasses.

7.

I am also concerned about the environmental problems surrounding the TPGS facilitys extended use of cooling canals and NRCs failure to consider environmental and safety concerns posed by rising sea levels in its environmental reviews of FPLs subsequent license extension request.

8.

I remain unconvinced that the TPGS facility is as safe as it needs to be to operate adjacent to an urban area, as the facility is vulnerable to accelerating sea level rise and

2 hurricane-driven storm surge. I am particularly concerned about the lack of careful analysis of storm surge vulnerability on cooling systems and stored fuel. The disaster at the Fukushima-Daichi Nuclear Power Plant in Japan caused me increased concern about the unique vulnerabilities of nuclear power reactors to rare external events. I sincerely question whether TPGS, in its current configuration, has fully considered a reasonable range of alternatives available for reducing or avoiding adverse environmental effects.

9.

I believe that FPLs Turkey Point operation is misusing our limited supply of freshwater. Southeast Florida requires a freshwater head to hold out the saltwater that would otherwise infiltrate our groundwater and exacerbate hypersalinity. The need to conserve these local freshwater sources is urgent. Climate change is already causing local sea levels to rise, increasing saltwater pressure on the aquifer. The local population continues to grow, increasing freshwater demand. By using cooling canals instead of cooling towers as the ultimate heat sink for the nuclear plants at Turkey Point, FPL increases evaporative loss beyond what is necessary.

FPL is currently using freshwater for to mitigate the western half of the hypersaline plume generated by canal evaporation. This effort leaves the eastern half of the plume unmitigated, while misusing the limited freshwater supply to attempt to address a problem of FPLs own making. While my drinking water is not supplied directly from the well fields most at risk, water is pumpable and therefore fungible. As the regional supply is depleted, the County must make up the shortfall, at considerable expense to the consumer, through desalination of the deeper Floridan Aquifer. In the height of irony, desalination requires vastly more electricity; FPL is raising demand for electricity by wasting water, and wasting water by meeting this demand. We have to maintain our regional freshwater head as long as we can, and FPLs plan to keep Turkey Point cool and its failing attempt to mitigate the hypersaline plume is raising the cost of domestic drinking water and shortening the period before seawater infiltrates our

3 aquifer.

10.

Moreover, because my home is well within the 50-mile emergency planning zone for the ingestion pathway, I am concerned that an accident at the TPGS may result in dangerous airborne levels of radioiodines, with subsequent elevations of radiation-induced thyroid cancers as reported near Chernobyl and Three Mile Island. Prevailing winds at TPGS are often in the direction of inhabited areas. No realistic plan exists to distribute potassium iodide prophylaxis to the vulnerable population before airborne exposure to radioiodines. As development has increased in southern Miami-Dade County, the roads are now inadequate for evacuation in the event of a nuclear emergency. The proscribed alternative to evacuation, shelter-in-place, is not a survivable action in the absence of electricity needed to keep houses habitable in the summer heat of hurricane season.

11.

I know that the NRC must undertake an environmental review when it grants relicensing permits to nuclear power plants such as the TPGS. However, I am aware that there are a number of issues that, as part of this relicensing, have not been adequately or accurately analyzed. Examples include, but are not limited to: (i) sea level rise, (ii) microcystins produced by cyanobacterial blooms in the cooling canals, (iii) and groundwater contamination. Nor has FPL provided sufficient analysis of the potential ways to mitigate the consequences of the continued operations.

12.

The failure to require updated studies and plans concerns me. Sea level rise was not even on the radar when the plants were initially licensed. I want to know that if the reactors are allowed to operate for 80 years (an additional 20 years beyond the already once-extended timeframe of 40 to 60 years) that the extended operating life is supported by reliable and accurate prospective analyses and realistic mitigation strategies, sufficient to effectively eliminate environmental and safety risks or impacts.

4

13.

I would certainly pay close attention if the NRC were to carefully analyze the significant issues of sea level rise, environmental impacts of cooling systems, and effective mitigation measures. A clear analysis would help me feel safer and better informed of the risks my family and neighbors face as nearby residents. But, because no adequate analysis has been conducted on these issues for decades, or ever for some of the issues, I remain deeply concerned.

13.

The NRC has a duty to keep communities living near nuclear plants informed about the risks of further extending the operation of a nuclear plant proposed to operate for double its design life, including any risk related to aging plants, aging materials, or emerging risks from changes in climate and sea level.

14.

I support Miami Waterkeepers intervention in this case and authorize them to act on my behalf. I believe that with their participation the Nuclear Regulatory Commission will be better positioned to fully review the possible impacts of the applicants proposed relicensing for an additional 20 years and adequately analyze how to minimize environmental and human health impacts in the event of continued operation of the TPGS.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information, and belief and that this declaration was executed on November 3, 2023 in South Miami, Florida.

Philip K. Stoddard, Ph.D.