ML16019A357

Limited Appearance Statement of Larry Fink Regarding Turkey Point, Units 3 and 4, License Amendment Request

ML16019A357
Person / Time
Site:	Turkey Point
Issue date:	01/14/2016
From:	Fink L Waterwise Consulting
To:	Atomic Safety and Licensing Board Panel, NRC/SECY
SECY/RAS
References
50-250-LA, 50-251-LA, ASLBP 15-935-02-LA-BD01, VVV-28
Download: ML16019A357 (3)

Text

From:Buckberg, PerryTo:Docket, Hearing; Pepperl, Nicole; Scro, Jennifer

Subject:

RE: FPL"s Turkey Point Permit Comment PeriodDate:Friday, January 15, 2016 8:37:28 AMGood morning, I am acting as the NRR/DORL Turkey Point Project Manager while the Lead PM (Audrey Klett) is out of the office.

The comments below look to be intended for the official hearing record for this week's Turkey Point cooling canals hearing (Jan. 11, 2016 in Homestead, FL) but were submitted via an OPA feedback form. I am forwarding the comments to you-but I can provide

'Notice of Hearing' submittal requirements with this member of the public if needed. Please let me know.

Thanks,Perry BuckbergSenior Project ManagerOffice of Nuclear Reactor Regulation415-1383 O-08E03 From: Buckberg, Perry Sent: Friday, January 15, 2016 7:54 AMTo: Hannah, Roger; Klett, Audrey; Williamson, AliciaCc: Ledford, Joey

Subject:

RE: FPL's Turkey Point Permit Comment Period Thanks Roger.

I will ensure these comments are included 'in the official hearings record on these issues' as requested and as appropriate. Thanks,Perry BuckbergSenior Project ManagerOffice of Nuclear Reactor Regulation415-1383 O-08E03 -----Original Message-----

From: Hannah, Roger Sent: Friday, January 15, 2016 7:40 AM To: Klett, Audrey; Buckberg, Perry; Williamson, Alicia Cc: Ledford, Joey

Subject:

FW: FPL's Turkey Point Permit Comment Period

This came in through our public web page and I'm not sure who should get it or if this individual has provided these comments in some other manner, but I'm sending it to all of you so that it hopefully gets to the right place.

Thanks, Roger Hannah, APR Senior Public Affairs Officer Region II -- Atlanta, Ga.

Office - 404-997-4417 Mobile - 404-317-3879 roger.hannah@nrc.gov

---

Original Message-----

From: Larry E. Fink, M.S. [1]Sent: Thursday, January 14, 2016 5:04 PM To: OPA2 Resource <OPA2.Resource@nrc.gov>

Subject:

FPL's Turkey Point Permit Comment Period

Below is the result of your feedback form. It was submitted by

Larry E. Fink, M.S. (larryfink@waterwiseconsulting.com) on Thursday, January 14, 2016 at 17:04:27

through the IP 216.246.75.15

using the form at http://www.nrc.gov/about-nrc/public-affairs/contact-opa.html and resulted in this email to opa2.resource@nrc.gov

---

comments: The old Turkey Point units are operating outside of permit limits regarding fresh cooling water flow, water temperature, salinity and radionuclides and the combined facility-contaminated groundwater and surface water loads to Biscayne Bay are causing or contributing to a violation of Water Quality Standards, and the routine operation of new Units 6 and 7 will just exacerbate these problems when the old units consume more fresh surface and ground water than they were originally allocated and more pollution assimilation capacities in the groundwater and surface water to which its regulated and unregulated discharges are effluent. In addition, FPL misrepresented the source of tritium in the groundwater underlying the facility and confluence with Biscayne Bay as primarily natural rather than unnatural in origin, a misrepresentation for which it was held to account by scientists working for the South Florida Water Management District under the aegis of its Executive Director, Carol Wehle. Please include these comments in the official hearings record on these issues. Operation of the old units should be scaled back until the more restrictive of the fresh water flow, temperature, or salinity on the source side or pollution load limits are met on the receiving waters side based on a USGS-approved, calibrated, and validated combined surface water-groundwater water quantity and quality model. This temporary emergency operating condition should continue until such time as the EIS for the combined operation of the old and new units are revised to reflect these new circumstances and the ability for FPL to provide the required reasonable assurances reconsidered.

Thank you.

Larry E Fink, M.S Owner and Principal Waterwise Consulting, LLC

organization: Waterwise Consulting, LLC

address1: 1601 S. Ocean Drive

address2: Suite 406

city: Hollywood

state: FL

zip: 33019

country: USA

phone: 954-923-7374

---

From:Buckberg, PerryTo:Docket, Hearing; Pepperl, Nicole; Scro, Jennifer

Subject:

RE: FPL"s Turkey Point Permit Comment PeriodDate:Friday, January 15, 2016 8:37:28 AMGood morning, I am acting as the NRR/DORL Turkey Point Project Manager while the Lead PM (Audrey Klett) is out of the office.

The comments below look to be intended for the official hearing record for this week's Turkey Point cooling canals hearing (Jan. 11, 2016 in Homestead, FL) but were submitted via an OPA feedback form. I am forwarding the comments to you-but I can provide

'Notice of Hearing' submittal requirements with this member of the public if needed. Please let me know.

Thanks,Perry BuckbergSenior Project ManagerOffice of Nuclear Reactor Regulation415-1383 O-08E03 From: Buckberg, Perry Sent: Friday, January 15, 2016 7:54 AMTo: Hannah, Roger; Klett, Audrey; Williamson, AliciaCc: Ledford, Joey

Subject:

RE: FPL's Turkey Point Permit Comment Period Thanks Roger.

I will ensure these comments are included 'in the official hearings record on these issues' as requested and as appropriate. Thanks,Perry BuckbergSenior Project ManagerOffice of Nuclear Reactor Regulation415-1383 O-08E03 -----Original Message-----

From: Hannah, Roger Sent: Friday, January 15, 2016 7:40 AM To: Klett, Audrey; Buckberg, Perry; Williamson, Alicia Cc: Ledford, Joey

Subject:

FW: FPL's Turkey Point Permit Comment Period

This came in through our public web page and I'm not sure who should get it or if this individual has provided these comments in some other manner, but I'm sending it to all of you so that it hopefully gets to the right place.

Thanks, Roger Hannah, APR Senior Public Affairs Officer Region II -- Atlanta, Ga.

Office - 404-997-4417 Mobile - 404-317-3879 roger.hannah@nrc.gov

---

Original Message-----

From: Larry E. Fink, M.S. [2]Sent: Thursday, January 14, 2016 5:04 PM To: OPA2 Resource <OPA2.Resource@nrc.gov>

Subject:

FPL's Turkey Point Permit Comment Period

Below is the result of your feedback form. It was submitted by

Larry E. Fink, M.S. (larryfink@waterwiseconsulting.com) on Thursday, January 14, 2016 at 17:04:27

through the IP 216.246.75.15

using the form at http://www.nrc.gov/about-nrc/public-affairs/contact-opa.html and resulted in this email to opa2.resource@nrc.gov

---

comments: The old Turkey Point units are operating outside of permit limits regarding fresh cooling water flow, water temperature, salinity and radionuclides and the combined facility-contaminated groundwater and surface water loads to Biscayne Bay are causing or contributing to a violation of Water Quality Standards, and the routine operation of new Units 6 and 7 will just exacerbate these problems when the old units consume more fresh surface and ground water than they were originally allocated and more pollution assimilation capacities in the groundwater and surface water to which its regulated and unregulated discharges are effluent. In addition, FPL misrepresented the source of tritium in the groundwater underlying the facility and confluence with Biscayne Bay as primarily natural rather than unnatural in origin, a misrepresentation for which it was held to account by scientists working for the South Florida Water Management District under the aegis of its Executive Director, Carol Wehle. Please include these comments in the official hearings record on these issues. Operation of the old units should be scaled back until the more restrictive of the fresh water flow, temperature, or salinity on the source side or pollution load limits are met on the receiving waters side based on a USGS-approved, calibrated, and validated combined surface water-groundwater water quantity and quality model. This temporary emergency operating condition should continue until such time as the EIS for the combined operation of the old and new units are revised to reflect these new circumstances and the ability for FPL to provide the required reasonable assurances reconsidered.

Thank you.

Larry E Fink, M.S Owner and Principal Waterwise Consulting, LLC

organization: Waterwise Consulting, LLC

address1: 1601 S. Ocean Drive

address2: Suite 406

city: Hollywood

state: FL

zip: 33019

country: USA

phone: 954-923-7374

---