NUREG-1437, Dfc, Supplement 5a, Second Renewal, Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 5a, Second Renewal Regarding Subsequent License Renewal: Difference between revisions

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#REDIRECT [[NUREG-1437, Dfc, Supplement 60, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 60, Regarding License Renewal of Comanche Peak Nuclear Power Plant]]
| number = ML23242A216
| issue date = 08/31/2023
| title = NUREG-1437 Dfc, Supplement 5a, Second Renewal, Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 5a, Second Renewal Regarding Subsequent License Renewal
| author name = Rakovan L
| author affiliation = NRC/NMSS
| addressee name =
| addressee affiliation =
| docket =
| license number =
| contact person =
| document report number = NUREG-1437, Suppl 5a
| document type = NUREG, Draft
| page count = 1
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:NUREG-1437 Supplement 5a Second Renewal Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 5a, Second Renewal Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 Draft Report for Comment Office of Nuclear Material Safety and Safeguards
 
AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference Material                                      Non-NRC Reference Material As of November 1999, you may electronically access          Documents available from public and special technical NUREG-series publications and other NRC records at the      libraries include all open literature items, such as books, NRCs Library at www.nrc.gov/reading-rm.html. Publicly      journal articles, transactions, Federal Register notices, released records include, to name a few, NUREG-series        Federal and State legislation, and congressional reports.
publications; Federal Register notices; applicant, licensee, Such documents as theses, dissertations, foreign reports and vendor documents and correspondence; NRC                and translations, and non-NRC conference proceedings correspondence and internal memoranda; bulletins and        may be purchased from their sponsoring organization.
information notices; inspection and investigative reports; licensee event reports; and Commission papers and their      Copies of industry codes and standards used in a attachments.                                                substantive manner in the NRC regulatory process are maintained at NRC publications in the NUREG series, NRC regulations,              The NRC Technical Library and Title 10, Energy, in the Code of Federal Regulations          Two White Flint North may also be purchased from one of these two sources:                11545 Rockville Pike Rockville, MD 20852-2738
: 1. The Superintendent of Documents U.S. Government Publishing Office                    These standards are available in the library for reference Washington, DC 20402-0001                            use by the public. Codes and standards are usually Internet: https://bookstore.gpo.gov/                  copyrighted and may be purchased from the originating Telephone: (202) 512-1800                            organization or, if they are American National Standards, Fax: (202) 512-2104                                  from American National Standards Institute
: 2. The National Technical Information Service                  11 West 42nd Street 5301 Shawnee Road                                            New York, NY 10036-8002 Alexandria, VA 22312-0002                                    Internet: www.ansi.org Internet: https://www.ntis.gov/                              (212) 642-4900 1-800-553-6847 or, locally, (703) 605-6000 Legally binding regulatory requirements are stated only in laws; NRC regulations; licenses, including technical A single copy of each NRC draft report for comment is          specifications; or orders, not in NUREG-series publications.
available free, to the extent of supply, upon written          The views expressed in contractor prepared publications in request as follows:                                            this series are not necessarily those of the NRC.
The NUREG series comprises (1) technical and Address: U.S. Nuclear Regulatory Commission                  administrative reports and books prepared by the staff Office of Administration                            (NUREG-XXXX) or agency contractors (NUREG/CR-XXXX),
Digital Communications and Administrative          (2) proceedings of conferences (NUREG/CP-XXXX),
Services Branch                                  (3) reports resulting from international agreements Washington, DC 20555-0001                          (NUREG/IA-XXXX),(4) brochures (NUREG/BR-XXXX), and (5) compilations of legal decisions and orders of the E-mail: Reproduction.Resource@nrc.gov Commission and the Atomic and Safety Licensing Boards and Facsimile: (301) 415-2289 of Directors decisions under Section 2.206 of the NRCs regulations (NUREG-0750), (6) Knowledge Management Some publications in the NUREG series that are posted        prepared by NRC staff or agency contractors (NUREG/KM-at the NRCs Web site address www.nrc.gov/reading-rm/        XXXX).
doc-collections/nuregs are updated periodically and may      DISCLAIMER: This report was prepared as an account of work differ from the last printed version. Although references to  sponsored by an agency of the U.S. Government. Neither the material found on a Web site bear the date the material      U.S. Government nor any agency thereof, nor any employee, makes any warranty, expressed or implied, or assumes any was accessed, the material available on the date cited legal liability or responsibility for any third partys use, or the may subsequently be removed from the site.                    results of such use, of any information, apparatus, product, or process disclosed in this publication, or represents that its use by such third party would not infringe privately owned rights.
 
NUREG-1437 Supplement 5a Second Renewal Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 5a, Second Renewal Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 Draft Report for Comment Manuscript Completed: August 2023 Date Published: August 2023 Office of Nuclear Material Safety and Safeguards
 
1                                          COVER SHEET 2 Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Material Safety 3 and Safeguards.
4
 
==Title:==
Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants 5 Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 6 4, NUREG-1437, Supplement 5a, Second Renewal, Draft Report for Comment (NUREG-1437).
7 For additional information or copies of this document contact:
8                                U.S. Nuclear Regulatory Commission 9                          Office of Nuclear Material Safety and Safeguards 10                                            Mail Stop T-4B72 11                                        11555 Rockville Pike 12                                          Rockville, MD 20852 13                                    Email: lance.rakovan@nrc.gov 14 15                                            ABSTRACT 16 The U.S. Nuclear Regulatory Commission (NRC, the Commission) staff prepared this site-17 specific environmental impact statement (EIS) to supplement the Generic Environmental 18 Impact Statement for License Renewal of Nuclear Plants, Supplement 5, Second Renewal, 19 Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 20 4, Final Report (NUREG-1437, Supplement 5, Second Renewal) (FSEIS), issued in October 21 2019. This EIS includes the NRC staffs site-specific evaluation of the environmental impacts of 22 subsequent license renewal (SLR) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 23 (Turkey Point) for each of the environmental issues that the FSEIS dispositioned as Category 1 24 issues (generic to all or a distinct subset of nuclear power plants) consistent with Table B-1 in 25 Appendix B to Subpart A of Title 10 of the Code of Federal Regulations (10 CFR) Part 51 and 26 NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear 27 Plants, Revision 1, Final Report (LR GEIS).
28 This EIS considers information contained in the Florida Power & Light Company (FPL) June 9, 29 2022, submittal (FPL 2022a), which supplements its 2018 SLR application that was considered 30 in the FSEIS. The EIS also considers whether there is significant new information that would 31 change the NRC staffs conclusions concerning Category 2 issues (specific to individual nuclear 32 power plants) in the FSEIS. The NRC staff prepared the EIS in accordance with the 33 Commissions decisions in Commission Legal Issuance (CLI)-22-02 and CLI-22-03, both dated 34 February 24, 2022. These decisions, confirmed in CLI-22-06 issued on June 3, 2022, directed 35 the NRC staff to modify the expiration dates of the Turkey Point subsequent renewed licenses, 36 which were issued on December 4, 2019, to reflect the end dates of the previous renewed 37 licenses (i.e., July 19, 2032, for Turkey Point Unit 3 and April 10, 2033, for Turkey Point Unit 4).
38 Together, this EIS and the previous FSEIS evaluate, on a site-specific basis, all of the 39 environmental impacts of continued operation during the SLR term for Turkey Point Unit 3 40 from July 19, 2032, to July 19, 2052, and for Turkey Point Unit 4 from April 10, 2033, to 41 April 10, 2053.
42 Based on the October 2019 FSEIS and the NRC staffs evaluation in this EIS, the staffs 43 preliminary recommendation is that the adverse environmental impacts of SLR for Turkey Point iii
 
1 (i.e., the continued operation of Turkey Point for a period of 20 years beyond the expiration 2 dates of the initial renewed licenses) are not so great that preserving the option of SLR for 3 energy-planning decision-makers would be unreasonable. The NRC staff based its 4 recommendation on the following:
5
* FPLs environmental report, as supplemented 6
* the NRC staffs consultations with Federal, State, Tribal, and local government agencies 7
* the NRC staffs independent environmental review, which is documented in the FSEIS and 8      this EIS 9
* the NRC staffs consideration of public comments.
iv
 
1                                      TABLE OF CONTENTS 2 ABSTRACT ................................................................................................................... iii 3 TABLE OF CONTENTS.................................................................................................. v 4 LIST OF FIGURES......................................................................................................... ix 5 LIST OF TABLES .......................................................................................................... xi 6 EXECUTIVE
 
==SUMMARY==
............................................................................................. xiii 7 ABBREVIATIONS AND ACRONYMS ........................................................................ xxi 8 1    INTRODUCTION ................................................................................................. 1-1 9      1.1  Proposed Federal Action ....................................................................................... 1-2 10      1.2  Purpose and Need for the Proposed Federal Action............................................. 1-3 11      1.3  Major Environmental Review Milestones .............................................................. 1-3 12      1.4  Environmental Impacts of the Proposed Federal Action ....................................... 1-4 13      1.5  Site-Specific Environmental Impact Statement ..................................................... 1-5 14      1.6  Decisions to Be Supported by the EIS .................................................................. 1-6 15      1.7  Cooperating Agencies ........................................................................................... 1-6 16      1.8  Consultations ........................................................................................................ 1-6 17      1.9  Correspondence .................................................................................................... 1-7 18      1.10 Status of Compliance ............................................................................................ 1-7 19      1.11 Related State and Federal Activities ..................................................................... 1-7 20 2    ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS .............. 2-1 21      2.1  Introduction ........................................................................................................... 2-1 22      2.2  Land Use ............................................................................................................... 2-5 23          2.2.1      Onsite Land Use ..................................................................................... 2-6 24          2.2.2      Offsite Land Use ..................................................................................... 2-6 25          2.2.3      Offsite Land Use in Transmission Line Rights-of-Way ........................... 2-7 26      2.3  Visual Resources .................................................................................................. 2-7 27          2.3.1      Aesthetic Impacts ................................................................................... 2-7 28      2.4  Air Quality .............................................................................................................. 2-7 29          2.4.1      Air Quality Impacts ................................................................................. 2-7 30          2.4.2      Air Quality Effects of Transmission Lines ............................................... 2-9 31      2.5  Noise ..................................................................................................................... 2-9 32          2.5.1      Noise Impacts ......................................................................................... 2-9 33      2.6  Geologic Environment ......................................................................................... 2-10 34          2.6.1      Geology and Soils ................................................................................ 2-10 35      2.7  Surface Water Resources ................................................................................... 2-11 36          2.7.1      Surface Water Use and Quality ............................................................ 2-11 v
 
1      2.7.2    Discharge of Metals in Cooling System Effluent................................... 2-12 2      2.7.3    Discharge of Biocides, Sanitary Wastes, and Minor Chemical Spills ... 2-13 3      2.7.4    Effects of Dredging on Surface Water Quality ...................................... 2-14 4 2.8  Groundwater Resources ..................................................................................... 2-15 5      2.8.1    Groundwater Contamination and Use .................................................. 2-15 6      2.8.2    Groundwater Use Conflicts and Groundwater Quality Degradation 7                Resulting from Water Withdrawals ....................................................... 2-16 8      2.8.3    Groundwater Quality Degradation ........................................................ 2-22 9 2.9  Terrestrial Resources .......................................................................................... 2-31 10      2.9.1    Exposure of Terrestrial Organisms to Radionuclides ........................... 2-31 11      2.9.2    Cooling System Impacts on Terrestrial Resources .............................. 2-34 12      2.9.3    Bird Collisions with Plant Structures and Transmission Lines .............. 2-36 13      2.9.4    Transmission Line Right-of-Way Management Impacts on Terrestrial 14                Resources ............................................................................................ 2-37 15      2.9.5    Effects of Electromagnetic Fields on Flora and Fauna ......................... 2-38 16 2.10 Aquatic Resources .............................................................................................. 2-39 17      2.10.1 Entrainment of Phytoplankton and Zooplankton................................... 2-39 18      2.10.2 Infrequently Reported Thermal Impacts ............................................... 2-41 19      2.10.3 Effects of Cooling Water Discharge on Dissolved Oxygen, Gas 20                Supersaturation, and Eutrophication .................................................... 2-43 21      2.10.4 Effects of Nonradiological Contaminants on Aquatic Organisms ......... 2-46 22      2.10.5 Exposure of Aquatic Organisms to Radionuclides ............................... 2-48 23      2.10.6 Effects of Dredging on Aquatic Organisms .......................................... 2-49 24      2.10.7 Effects on Aquatic Resources .............................................................. 2-50 25      2.10.8 Impacts of Transmission Line Right-of-Way Management on Aquatic 26                Resources ............................................................................................ 2-51 27      2.10.9 Losses from Predation, Parasitism, and Disease Among Organisms 28                Exposed to Sublethal Stresses ............................................................ 2-52 29 2.11 Socioeconomics .................................................................................................. 2-54 30      2.11.1 Employment and Income, Recreation and Tourism ............................. 2-54 31      2.11.2 Tax Revenues ...................................................................................... 2-55 32      2.11.3 Community Services and Education..................................................... 2-57 33      2.11.4 Population and Housing ....................................................................... 2-59 34      2.11.5 Transportation ...................................................................................... 2-60 35 2.12 Human Health ..................................................................................................... 2-62 36      2.12.1 Radiation Exposures to the Public ....................................................... 2-62 37      2.12.2 Radiation Exposures to Plant Workers ................................................. 2-63 38      2.12.3 Human Health Impact from Chemicals ................................................. 2-64 39      2.12.4 Microbiological Hazards to Plant Workers ............................................ 2-64 40      2.12.5 Physical Occupational Hazards ............................................................ 2-64 41 2.13 Postulated Accidents ........................................................................................... 2-65 42      2.13.1 Design Basis Accidents ........................................................................ 2-65 vi
 
1          2.13.2 Severe Accidents ................................................................................. 2-67 2    2.14  Waste Management ............................................................................................ 2-68 3          2.14.1 Low-Level Waste Storage and Disposal............................................... 2-68 4          2.14.2 Onsite Storage of Spent Nuclear Fuel .................................................. 2-69 5          2.14.3 Offsite Radiological Impacts of Spent Nuclear Fuel and High-Level 6                    Waste Disposal .................................................................................... 2-69 7          2.14.4 Mixed-Waste Storage and Disposal ..................................................... 2-70 8          2.14.5 Nonradioactive Waste Storage and Disposal ....................................... 2-70 9    2.15  Uranium Fuel Cycle ............................................................................................. 2-70 10          2.15.1 Offsite Radiological Impacts - Individual Impacts from Other than the 11                    Disposal of Spent Fuel and High-Level Waste ..................................... 2-71 12          2.15.2 Offsite Radiological Impacts - Collective Impacts from Other than the 13                    Disposal of Spent Fuel and High-Level Waste ..................................... 2-72 14          2.15.3 Nonradiological Impacts of the Uranium Fuel Cycle............................. 2-72 15          2.15.4 Transportation ...................................................................................... 2-73 16    2.16  Termination of Nuclear Power Plant Operations and Decommissioning ............. 2-73 17          2.16.1 Termination of Plant Operations and Decommissioning ...................... 2-73 18 3  CONCLUSION .................................................................................................... 3-1 19    3.1  Environmental Impacts of the Proposed Federal Action ....................................... 3-1 20    3.2  Comparison of Alternatives ................................................................................... 3-1 21    3.3  Preliminary Recommendation ............................................................................... 3-2 22 4  REFERENCES .................................................................................................... 4-1 23 5  LIST OF PREPARERS........................................................................................ 5-1 24 6  LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM 25    COPIES OF THIS ENVIRONMENTAL IMPACT STATEMENT ARE SENT ....... 6-1 26 APPENDIX A    COMMENTS RECEIVED ON THE TURKEY POINT NUCLEAR 27                GENERATING UNITS 3 AND 4 ENVIRONMENTAL REVIEW ......... A-1 28 APPENDIX B    CONSULTATION CORRESPONDENCE .......................................... B-1 29 APPENDIX C    CHRONOLOGY OF ENVIRONMENTAL REVIEW 30                CORRESPONDENCE ....................................................................... C-1 31 APPENDIX D    SEVERE ACCIDENTS ...................................................................... D-1 32 APPENDIX E    ENVIRONMENTAL ISSUES AND IMPACT FINDINGS 33                CONTAINED IN THE PROPOSED RULE, 10 CFR PART 51, 34                ENVIRONMENTAL PROTECTION REGULATIONS FOR 35                DOMESTIC LICENSING AND RELATED REGULATORY 36                FUNCTIONS .....................................................................................E-1 37 vii
 
1                                        LIST OF FIGURES 2 Figure 1-1 Environmental Review Process .......................................................................... 1-4 3 Figure 2-1 Compliance Area, RWS and Monitoring Wells West and North of the CCS .... 2-19 4 Figure 2-2 FPL Freshening Well Locations ....................................................................... 2-21 5 Figure 2-3 CCS Salinity Time Series ................................................................................. 2-24 6 Figure 2-4 Comparison of the 2018 and 2022 Inland Extent of Hypersaline 7            Groundwater in the Shallow Horizon ................................................................ 2-25 8 Figure 2-5 Comparison of the 2018 and 2022 Inland Extent of Hypersaline 9            Groundwater in the Middle Horizon .................................................................. 2-26 10 Figure 2-6 Comparison of the 2018 and 2022 Inland Extent of Hypersaline 11            Groundwater in the Deep Horizon .................................................................... 2-27 12 Figure 2-7 Location of the Initial, Year 5, and Year 10 Hypersaline Interface in Model 13            Layer 4 ............................................................................................................. 2-28 14 Figure 2-8 Location of the Initial, Year 5, and Year 10 Hypersaline Interface in Model 15            Layer 9 ............................................................................................................. 2-29 16 Figure 2-9 Location of the Initial, Year 5, and Year 10 Hypersaline Interface in Model 17            Layer 16 ........................................................................................................... 2-30 ix
 
1                                          LIST OF TABLES 2 Table ES-1 Summary of the Site-Specific Conclusions Regarding Turkey Point SLR 3            Made in this EIS ..................................................................................................xvi 4 Table ES-2 Summary of the Site-Specific Conclusions Regarding Turkey Point SLR 5            Made in the FSEIS ............................................................................................ xviii 6 Table 2-1  Site-Specific Conclusions Regarding Turkey Point SLR Made in this EIS ......... 2-2 7 Table 2-2  Site-Specific Conclusions Regarding Turkey Point SLR Made in the 8            FSEIS ................................................................................................................. 2-4 9 Table 2-3  Estimated Air Pollutant Emissions from Turkey Point Units 3 and 4 .................. 2-8 10 Table 2-4  Turkey Point Groundwater Withdrawal Wells ................................................... 2-17 11 Table 2-5  Miami-Dade County Total Operating Revenues, Miami-Dade County 12            School Board Revenues, and Turkey Point Units 3 and 4 Total Property 13            Tax Paid ........................................................................................................... 2-56 14 Table 2-6  Miami-Dade County Public School District Class Limits and Average 15            Class Size ........................................................................................................ 2-58 16 Table 2-7  Population and Percent Growth in Miami-Dade County, 1990-2070 ............... 2-59 17 Table 2-8  Housing in Miami-Dade County, 2021 Estimates ............................................. 2-60 18 Table 2-9  Peak Hour Traffic, Reserve Capacity, and Level of Service at Roads in 19            the Vicinity of the Turkey Point Site .................................................................. 2-61 20 Table 5-1  List of Preparers ................................................................................................. 5-1 21 Table 6-1  List of Agencies, Organizations, and Persons to Whom Copies of this 22            Environmental Impact Statement Are Sent ........................................................ 6-1 23 Table B-1  Endangered Species Act Section 7 Consultation Correspondence with the 24            U.S. Fish and Wildlife Service ........................................................................... B-1 25 Table B-2  National Historic Preservation Act Correspondence ......................................... B-2 26 Table C-1  Environmental Review Correspondence ........................................................... C-1 27 Table E-1  New and Revised 10 CFR Part 51 License Renewal Environmental 28            Issues ................................................................................................................ E-3 29 Table E-2  Estimated Greenhouse Gas Emissions from Operation at Turkey Point, 30            Units 3 and 4 ..................................................................................................... E-8 31 xi
 
1                                  EXECUTIVE
 
==SUMMARY==
 
2 By {{letter dated|date=January 30, 2018|text=letter dated January 30, 2018}}, Florida Power & Light Company (FPL, the licensee) submitted 3 to the U.S. Nuclear Regulatory Commission (NRC, the Commission) an application requesting 4 subsequent license renewal (SLR) of the Turkey Point Nuclear Generating Unit Nos. 3 and 4 5 (Turkey Point, Turkey Point Units 3 and 4) renewed facility operating licenses (FPL 2018a). FPL 6 subsequently supplemented its SLR application by letters dated February 9, 2018 (FPL 2018b),
7 February 16, 2018 (FPL 2018c), March 1, 2018 (FPL 2018d), and April 10, 2018 (FPL 2018e).
8 The Turkey Point Unit 3 initial renewed facility operating license (DPR-31) was set to expire at 9 midnight on July 19, 2032, and the Turkey Point Unit 4 initial renewed facility operating license 10 (DPR-41) was set to expire at midnight on April 10, 2033. In its SLR application, FPL requested 11 subsequent renewed facility operating licenses for a period of 20 years beyond these expiration 12 datesi.e., July 19, 2052, for Turkey Point Unit 3 and April 10, 2053, for Turkey Point Unit 4.
13 The NRCs environmental protection regulations in Title 10 of the Code of Federal Regulations 14 (10 CFR) Part 51, Environmental Protection Regulations for Domestic Licensing and Related 15 Regulatory Functions, implement the National Environmental Policy Act of 1969, as amended 16 (NEPA; 42 U.S.C. 4321 et seq.), and require, in part, that the NRC prepare an environmental 17 impact statement (EIS) before the issuance or renewal of a license to operate a nuclear power 18 plant. Pursuant to these regulations, the NRC staff performed an environmental review of FPLs 19 SLR application as a supplement to NUREG-1437, Generic Environmental Impact Statement 20 for License Renewal of Nuclear Plants, Revision 1, Final Report (LR GEIS) (NRC 2013a).
21 Specifically, in March 2019, the NRC staff issued a draft supplement to the LR GEIS, titled 22 Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 23 5, Second Renewal, Regarding Subsequent License Renewal for Turkey Point Nuclear 24 Generating Unit Nos. 3 and 4, Draft Report for Comment (NRC 2019a). In October 2019, after 25 considering public comments on the draft supplement, the NRC staff issued a final supplement 26 to the LR GEIS, titled Generic Environmental Impact Statement for License Renewal of Nuclear 27 Plants, Supplement 5, Second Renewal, Regarding Subsequent License Renewal for Turkey 28 Point Nuclear Generating Unit Nos. 3 and 4, Final Report (FSEIS) (NRC 2019b). The FSEIS 29 concluded, in part, that the adverse environmental impacts of SLR for Turkey Point are not so 30 great that preserving the option of SLR for energy-planning decision-makers would be 31 unreasonable. Based, in part, on that environmental review, on December 4, 2019, the NRC 32 issued subsequent renewed licenses for Turkey Point (NRC 2019b), with expiration dates of 33 July 19, 2052, for Turkey Point Unit 3 and April 10, 2053, for Turkey Point Unit 4.
34 On February 24, 2022, the Commission issued three memoranda and orders that addressed the 35 NRC staffs environmental reviews in SLR proceedings for five nuclear power plants. Two of 36 these orders, Commission Legal Issuance (CLI)-22-02 (NRC 2022a) and CLI-22-03 (NRC 37 2022b), addressed Turkey Point. In the orders, the Commission concluded that the LR GEIS, on 38 which the NRC staff had relied, in part, to meet its obligations under 10 CFR Part 51 and NEPA 39 for its environmental reviews of the SLR applications for the affected nuclear power plants, did 40 not consider SLR. Therefore, the Commission determined that the staffs SLR environmental 41 reviews, including the environmental review for the Turkey Point SLR application, were 42 inadequate. Accordingly, the Commission directed the NRC staff to modify the expiration dates 43 of the Turkey Point subsequent renewed licenses to reflect the end dates of the previous 44 renewed licenses (i.e., July 19, 2032, for Turkey Point Unit 3 and April 10, 2033, for Turkey 45 Point Unit 4). The Commission affirmed this direction in CLI-22-06 (NRC 2022c).
xiii
 
1 In CLI-22-03, the Commission directed the NRC staff to update the LR GEIS so that it covers 2 nuclear power plant operation during the SLR period. The Commission stated that it believed 3 the most efficient way to proceed would be for the NRC staff to update the LR GEIS and then 4 take appropriate action with respect to pending SLR applications to ensure that the 5 environmental impacts for the period of SLR are considered. Alternatively, the Commission 6 allowed SLR applicants to submit a revised environmental report (ER) providing additional 7 information about environmental impacts during the SLR period, in which they evaluate, on a 8 site-specific basis, the environmental impacts that were dispositioned in Table B-1 in Appendix 9 B to Subpart A of 10 CFR Part 51 and the LR GEIS as Category 1 issues (generic to all or a 10 distinct subset of nuclear power plants). For SLR applicants that provide such information, the 11 NRC staff was directed to address the environmental impacts of these issues in site-specific 12 EISs.
13 Consistent with CLI-22-03, on June 9, 2022, FPL submitted ER Supplement 2, providing a site-14 specific analysis of the environmental impacts of the continued operation of Turkey Point during 15 the SLR period (FPL 2022a). That analysis supplemented the ER (including ER Supplement 1) 16 that was included as part of FPLs SLR application and addressed, on a site-specific basis, each 17 environmental issue that was previously dispositioned as a Category 1 issue in the ER.
18 The NRC staff has prepared this EIS to evaluate, on a site-specific basis, the environmental 19 impacts of the operation of Turkey Point during the SLR period for each of the environmental 20 issues that were dispositioned as Category 1 issues in the FSEIS, in accordance with CLI-22-02 21 and CLI-22-03. The EIS considers information contained in the ER Supplement 2; the NRC 22 staffs consultation with Federal, State, Tribal, and local government agencies; and other 23 information, as appropriate. The EIS also considers whether there is significant new information 24 that would change the NRC staffs conclusions concerning Category 2 issues (specific to 25 individual nuclear power plants) evaluated in the FSEIS. Thus, the EIS supplements the FSEIS 26 evaluation of Category 1 impacts and updates the FSEIS evaluation of Category 2 impacts, as 27 set forth herein. Together, the EIS and the FSEIS evaluate, on a site-specific basis, all of the 28 environmental impacts of continued operation during the SLR term for Turkey Point Unit 3 from 29 July 19, 2032, to July 19, 2052, and for Turkey Point Unit 4 from April 10, 2033, to April 10, 30 2053.
31 Proposed Federal Action 32 FPL initiated the proposed Federal action of determining whether to issue subsequent renewed 33 licenses for Turkey Point by submitting an SLR application to the NRC. The Turkey Point Unit 3 34 initial renewed license was set to expire at midnight on July 19, 2032, and the Turkey Point Unit 35 4 initial renewed license was set to expire at midnight on April 10, 2033. On December 4, 2019, 36 the NRC issued subsequent renewed licenses for Turkey Point authorizing operation for a 37 period of 20 years beyond the expiration datesi.e., July 19, 2052, for Turkey Point Unit 3 and 38 April 10, 2053, for Turkey Point Unit 4. On March 25, 2022 (NRC 2022e), in accordance with the 39 Commissions direction in CLI-22-02, dated February 24, 2022, the NRC staff modified the 40 expiration dates of these subsequent renewed licenses to reflect the end dates of the previous 41 renewed licenses. Therefore, the subsequent renewed licenses for Turkey Point now expire on 42 July 19, 2032 (Unit 3) and April 10, 2033 (Unit 4).
43 The proposed Federal action as stated in the FSEIS (p. 1-1) is determining whether to issue 44 subsequent renewed licenses for Turkey Point for an additional 20 years of operation. After 45 issuing the FSEIS, the NRC issued (and later modified) subsequent renewed licenses for 46 Turkey Point. Based on the above discussion, the proposed Federal action at this time is to xiv
 
1 determine whether the site-specific evaluation presented in the EIS warrants any modification to 2 the NRC staffs previous determination that the adverse environmental impacts of SLR for 3 Turkey Point are not so great that preserving the option of SLR for energy-planning decision-4 makers would be unreasonable.
5 Purpose and Need for the Proposed Federal Action 6 The purpose and need for the proposed Federal action, as stated in the FSEIS (p. 1-1), is to 7 provide an option that allows for power generation capability beyond the term of the current 8 nuclear power plant licenses to meet future system generating needs. Such needs may be 9 determined by energy-planning decision-makers, such as State regulators, utility owners, and 10 Federal agencies other than the NRC. This definition of purpose and need reflects the NRCs 11 recognition that, unless there are findings in the NRCs safety review (required by the Atomic 12 Energy Act of 1954, as amended; 42 U.S.C. § 2011 et seq.) or findings in the NRCs 13 environmental analysis (required by NEPA) that would lead the NRC to reject an SLR 14 application, the NRC does not have a role in energy-planning decisions about whether a 15 particular nuclear power plant should continue to operate.
16 Environmental Impacts of the Proposed Federal Action 17 This EIS supplements the FSEIS in order to evaluate the potential environmental impacts of the 18 proposed Federal action. The NRC designates these environmental impacts as SMALL, 19 MODERATE, or LARGE.
20        SMALL: Environmental effects are not detectable or are so minor that they will 21        neither destabilize nor noticeably alter any important attribute of the resource.
22        MODERATE: Environmental effects are sufficient to alter noticeably, but not to 23        destabilize, important attributes of the resource.
24        LARGE: Environmental effects are clearly noticeable and are sufficient to 25        destabilize important attributes of the resource.
26 In this EIS, the NRC staff evaluates the environmental issues that were dispositioned as 27 Category 1 issues in the FSEIS by reference to Table B-1 in Appendix B to Subpart A of 10 28 CFR Part 51 and the LR GEIS. In the FSEIS, the NRC staff relied upon the analyses and 29 conclusions in the LR GEIS for each of these issues, and considered any new and significant 30 information that might change those conclusions. The NRC staff determined that there would be 31 no impacts related to these issues beyond those already discussed in the LR GEIS; therefore, 32 for each of these issues, the staff adopted the LR GEISs conclusions of SMALL environmental 33 impacts. However, as explained herein, the Commission later determined that the NRC staff 34 cannot rely on the LR GEIS for the environmental reviews of SLR applications. Therefore, in this 35 EIS, the NRC staff addresses each of these environmental issues on a site-specific basis.
36 Table ES-1 lists these environmental issues and the NRC staffs site-specific conclusions 37 related to the issues.
38 In the FSEIS, the NRC staff also evaluated additional environmental issues for the Turkey Point 39 SLR application on a site-specific basis. Table B-1 in Appendix B to Subpart A of 10 CFR Part 40 51 and the LR GEIS disposition these issues as site-specific or Category 2 issues. In this EIS, 41 the NRC staff has identified no significant new information that would change the conclusions 42 for these issues reached in the FSEIS. Therefore, the analyses and conclusions in the FSEIS xv
 
1 remain valid for these issues. Table ES-2 lists these environmental issues and the FSEISs 2 conclusions related to these issues.
3 In sum, this EIS supplements the FSEIS evaluation of Category 1 impacts and updates the 4 FSEIS evaluation of Category 2 impacts and, together, the EIS and the FSEIS evaluate, on a 5 site-specific basis, all of the potential environmental impacts of the proposed Federal action.
6 Table ES-1      Summary of the Site-Specific Conclusions Regarding Turkey Point SLR 7                Made in this EIS Resource Area                              Environmental Issue                      Impacts Land Use                    Onsite land use                                                SMALL Land Use                    Offsite land use                                              SMALL Land Use                    Offsite land use in transmission line rights-of-way (ROWs)    SMALL Visual Resources            Aesthetic impacts                                              SMALL Air Quality                  Air quality impacts                                            SMALL Air Quality                  Air quality effects of transmission lines                      SMALL Noise                        Noise impacts                                                  SMALL Geologic Environment        Geology and soils                                              SMALL Surface Water Resources      Surface water use and quality (non-cooling system              SMALL impacts)
Surface Water Resources      Discharge of metals in cooling system effluent                SMALL Surface Water Resources      Discharge of biocides, sanitary wastes, and minor              SMALL chemical spills Surface Water Resources      Effects of dredging on surface water quality                  SMALL Groundwater Resources        Groundwater contamination and use (non-cooling system          SMALL impacts)
Groundwater Resources        Groundwater quality degradation resulting from water          SMALL withdrawals Groundwater Resources        Groundwater quality degradation (plants with cooling          SMALL to ponds in salt marshes)                                      MODERATE Groundwater Resources        Groundwater use conflicts (plants that withdraw more than    SMALL to 100 gallons per minute)                                      MODERATE Terrestrial Resources        Exposure of terrestrial organisms to radionuclides            SMALL Terrestrial Resources        Cooling system impacts on terrestrial resources (plants        SMALL with once-through cooling systems or cooling ponds)
Terrestrial Resources        Bird collisions with plant structures and transmission lines  SMALL Terrestrial Resources        Transmission line right-of-way management impacts on          SMALL terrestrial resources(c)
Terrestrial Resources        Electromagnetic fields on flora and fauna (plants,            SMALL agricultural crops, honeybees, wildlife, livestock)
Aquatic Resources            Entrainment of phytoplankton and zooplankton                  SMALL Aquatic Resources            Infrequently reported thermal impacts                          SMALL Aquatic Resources            Effects of cooling water discharge on dissolved oxygen,        SMALL gas supersaturation, and eutrophication Aquatic Resources            Effects of nonradiological contaminants on aquatic            SMALL organisms Aquatic Resources            Exposure of aquatic organisms to radionuclides                SMALL xvi
 
1  Table ES-1      Summary of the Site-Specific Conclusions Regarding Turkey Point SLR Made 2                  in this EIS (Continued)
Resource Area                                  Environmental Issue                                  Impacts Aquatic Resources                Effects of dredging on aquatic organisms                                  SMALL Aquatic Resources                Effects on aquatic resources (non-cooling system impacts)                  SMALL Aquatic Resources                Impacts of transmission line right-of-way management on                    SMALL aquatic resources(c)
Aquatic Resources                Losses from predation, parasitism, and disease among                      SMALL organisms exposed to sublethal stresses Socioeconomics                  Employment and income, recreation and tourism                              SMALL Socioeconomics                  Tax revenues                                                              SMALL Socioeconomics                  Community services and education                                          SMALL Socioeconomics                  Population and housing                                                    SMALL Socioeconomics                  Transportation                                                            SMALL Human Health                    Radiation exposures to the public                                          SMALL Human Health                    Radiation exposures to plant workers                                      SMALL Human Health                    Human health impact from chemicals                                        SMALL Human Health                    Microbiological hazards to plant workers                                  SMALL Human Health                    Physical occupational hazards                                              SMALL Postulated Accidents            Design basis accidents                                                    SMALL Postulated Accidents            Severe accidents                                                        Probability-weighted consequences of severe accidents are SMALL Waste Management                Low-level waste storage and disposal                                      SMALL Waste Management                Onsite storage of spent nuclear fuel                                      SMALL Waste Management                Offsite radiological impacts of spent nuclear fuel and high-                  (a) level waste disposal Waste Management                Mixed-waste storage and disposal                                          SMALL Waste Management                Nonradioactive waste storage and disposal                                  SMALL Uranium Fuel Cycle              Offsite radiological impactsindividual impacts from                      SMALL sources other than the disposal of spent fuel and high-level waste Uranium Fuel Cycle              Offsite radiological impactscollective impacts from other                    (b) than the disposal of spent fuel and high-level waste Uranium Fuel Cycle              Nonradiological impacts of the uranium fuel cycle                          SMALL Uranium Fuel Cycle              Transportation                                                            SMALL Termination of Nuclear          Termination of plant operations and decommissioning                        SMALL Power Plant Operations and Decommissioning 3 (a) The ultimate disposal of spent nuclear fuel and high-level waste in a potential future geologic repository is a 4    separate and independent licensing action that is outside the regulatory scope of this site-specific review. The 5    environmental impact of this issue for the time frame beyond the licensed life for reactor operations is contained 6    in NUREG-2157, the NRCs Generic Environmental Impact Statement for Continued Storage of Spent Nuclear 7    Fuel. Per 10 CFR Part 51 Subpart A, the Commission determined that the impacts presented in NUREG-2157 8    would not be sufficiently large to require the conclusion, for any plant, that the option of extended operation 9    under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level xvii
 
Table ES-1        Summary of the Site-Specific Conclusions Regarding Turkey Point SLR Made in this EIS (Continued)
Resource Area                                  Environmental Issue                                  Impacts 1    of significance for the impacts of spent nuclear fuel and high-level waste disposal, this issue is considered 2    generic to all nuclear power plants and does not warrant a site-specific analysis.
3 (b) There are no regulatory limits applicable to collective doses to the general public from fuel-cycle facilities. The 4    practice of estimating health effects on the basis of collective doses may not be meaningful. All fuel-cycle 5    facilities are designed and operated to meet the applicable regulatory limits and standards. The Commission 6    determined that the collective impacts are acceptable. The Commission also determined that the impacts would 7    not be sufficiently large to require the conclusion, for any plant, that the option of extended operation under 10 8    CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of 9    significance for the collective impacts of the uranium fuel cycle, this issue is considered generic to all nuclear 10    power plants and does not warrant a site-specific analysis.
11 (c) This issue applies only to the in-scope portion of electric power transmission lines, which are defined as 12    transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional 13    power distribution system and transmission lines that supply power to the nuclear power plant from the grid.
14 Table ES-2        Summary of the Site-Specific Conclusions Regarding Turkey Point SLR 15                    Made in the FSEIS Resource Area                          Environmental Issue                                  Impacts(a)
Groundwater Resources            Groundwater use conflicts (plants that                  SMALL to MODERATE withdraw more than 100 gallons per minute [gpm])
Groundwater Resources            Radionuclides released to groundwater                            SMALL Terrestrial Resources            Effects on terrestrial resources (non-                          SMALL cooling system impacts)
Aquatic Resources                Impingement and entrainment of aquatic                  SMALL to MODERATE(b) organisms (plants with once-through cooling systems or cooling ponds)
Aquatic Resources                Thermal impacts on aquatic organisms                    SMALL to MODERATE(b)
(plants with once-through cooling systems or cooling ponds)
Special Status Species            Threatened, endangered, and protected                Impact determinations vary by and Habitats                      species and essential fish habitat                        species and habitat(c)
Historic and Cultural            Historic and cultural resources                    Would not adversely affect known Resources                                                                            historic properties or historic and cultural resources(d)
Human Health                      Chronic effects of electromagnetic fields                  Uncertain Impact Human Health                      Electric shock hazards(e)                                        SMALL Environmental Justice            Minority and low-income populations                  No disproportionately high and adverse human health and environmental effects Cumulative Impacts                Cumulative impacts                                      See FSEIS Section 4.16 16 (a) In reciting the FSEIS conclusions here, the NRC staff notes that the impact determinations for these issues were 17    described in Chapter 4 of the FSEIS.
18 (b) The NRC staff notes that the FSEIS conclusion of SMALL to MODERATE applied to aquatic resources in the 19    cooling canal system. Aquatic organisms inhabiting Biscayne Bay and connected water bodies (e.g., Card 20    Sound, the Atlantic Ocean) are not subject to impingement and entrainment because they do not interact with the 21    Turkey Point intake structure, and there are no thermal effects outside the cooling canal system because there 22    are no surface water connections that allow flow between the waters of Biscayne Bay and the cooling canal 23    system.
xviii
 
1 Table ES-2        Summary of the Site-Specific Conclusions Regarding Turkey Point SLR 2                    Made in the FSEIS (Continued)
Resource Area                        Environmental Issue                                    Impacts(a) 3 (c) In the FSEIS, the NRC staff concluded that Turkey Point SLR is likely to adversely affect the American crocodile 4    and the eastern indigo snake and may result in adverse modification of the designated critical habitat of the 5    American crocodile. The FSEIS also concluded that the proposed action may affect but is not likely to adversely 6    affect the Florida panther, West Indian manatee, red knot, wood stork, loggerhead sea turtle, green sea turtle, 7    leatherback sea turtle, hawksbill sea turtle, Kemps ridley sea turtle, and smalltooth sawfish. The FSEIS further 8    concluded that the proposed action would result in no adverse modification of designated critical habitat of the 9    West Indian manatee. The NRC staffs evaluation of impacts on federally listed species and critical habitats 10    under the U.S. Fish and Wildlife Services (FWS) jurisdiction appears in the NRCs Biological Assessment (NRC 11    2018). The FWSs separate evaluation and conclusions appear in a July 25, 2019, biological opinion (FWS 12    2019), which is described in Section 4.8.1.1 of the FSEIS. The FWS later amended its biological opinion on 13    March 21, 2022 (FWS 2022). The NRC staffs evaluation of impacts on federally listed species and critical 14    habitats under the National Marine Fisheries Services jurisdiction appears in Section 4.8.1.1 of the FSEIS. The 15    FSEIS concluded that the proposed action would have no adverse effects on essential fish habitat. The NRC 16    staffs evaluation of impacts on essential fish habitat appears in Section 4.8.1.2 of the FSEIS. The NRC staff also 17    concluded in the FSEIS that the proposed action would not affect the sanctuary resources of the Florida Keys 18    National Marine Sanctuary. The NRC staffs evaluation of sanctuary resources appears in Section 4.8.1.3 of the 19    FSEIS.
20 (d) The NRC staff notes that, based on (1) the location of National Register of Historic Places-eligible historic 21    properties within the area of potential effect, (2) Tribal input, (3) FPLs cultural resource protection plans, (4) the 22    fact that no license renewal-related physical changes or ground-disturbing activities would occur, (5) Florida 23    State Historic Preservation Office input, and (6) cultural resource assessment, the FSEIS concluded that Turkey 24    Point SLR would not adversely affect any known historic properties. See FSEIS Table 2-2.
25 (e) The NRC staff notes that this issue applies only to the in-scope portion of electric power transmission lines, 26    which are defined as transmission lines that connect the nuclear power plant to the substation where electricity is 27    fed into the regional power distribution system and transmission lines that supply power to the nuclear power 28    plant from the grid.
29 Alternatives 30 As part of its environmental review, the NRC is required to consider reasonable alternatives to 31 SLR and to evaluate the environmental impacts associated with each alternative. These 32 alternatives can include other methods of power generation (replacement power alternatives),
33 as well as not authorizing the operation of Turkey Point for an additional 20 years (the no-action 34 alternative).
35 In the FSEIS, the NRC staff initially considered 16 replacement power alternatives but later 36 dismissed 13 of them because of technical, resource availability, or commercial limitations that 37 existed at that time, and that the NRC staff believed are likely to still exist when the Turkey Point 38 licenses expire. This left the following three feasible and commercially viable replacement power 39 alternatives:
40
* new nuclear power 41
* new natural gas combined-cycle power 42
* a combination of new natural gas combined-cycle power and new solar photovoltaic power.
43 The NRC staff evaluated these alternatives, along with the no-action alternative, in depth in 44 Chapter 4 of the FSEIS. Additionally, the staff evaluated an alternative cooling water system to 45 mitigate potential impacts associated with the continued use of the existing cooling canal 46 system. Finally, Appendix F of the FSEIS evaluated any new and significant information that 47 could alter the conclusions of the severe accident mitigation alternatives (SAMA) analysis that 48 was performed previously in connection with the initial license renewal for Turkey Point. In xix
 
1 developing this EIS, the NRC staff has identified no significant new information that would 2 change these discussions in the FSEIS.
3 Recommendation 4 The NRC staffs recommendation in the FSEIS was that the adverse environmental impacts of 5 Turkey Point SLR are not so great that preserving the option of SLR for energy-planning 6 decision-makers would be unreasonable. The NRC staff based this recommendation on the LR 7 GEIS, as well as the following:
8
* FPLs ER 9
* the NRC staffs consultation with Federal, State, Tribal, and local government agencies 10
* the NRC staffs independent environmental review documented in the FSEIS 11
* the NRC staffs consideration of public comments.
12 The NRC staffs preliminary recommendation in this EIS is that the adverse environmental 13 impacts of SLR for Turkey Point (i.e., the continued operation of Turkey Point for a period of 14 20 years beyond the expiration dates of the initial renewed licenses) are not so great that 15 preserving the option of SLR for energy-planning decision-makers would be unreasonable. In 16 this EIS, the NRC staff considers each of the sources listed above that were considered in the 17 FSEIS, other than the LR GEIS. In addition, the NRC staff considers additional information 18 provided by those sources following the issuance of the FSEIS, including information 19 concerning the site-specific impacts of issues that were previously treated as Category 1 20 impacts and any significant new information that would change the conclusions reached in the 21 FSEIS regarding Category 2 impacts.
xx
 
1          ABBREVIATIONS AND ACRONYMS 2 §      Section 3 ac      acre(s) 4 ADAMS  Agencywide Documents Access and Management System 5 AEA    Atomic Energy Act of 1954, as amended 6 ALARA  as low as is reasonably achievable 7 ANS    Aquatic Nuisance Species 8 APLIC  Avian Power Line Interaction Committee 9 APP    Avian Protection Plan 10 BMP    best management practice 11 CCS    cooling canal system 12 CFR    Code of Federal Regulations 13 CLB    current licensing basis 14 CLI    Commission Legal Issuance 15 CO      carbon monoxide 16 CSEM    continuous surface electromagnetic mapping 17 CWA    Clean Water Act 18 CZMA    Coastal Zone Management Act 19 dBA    A-weighted decibel(s) 20 DOE    U.S. Department of Energy 21 ECFASV2 East Coast Floridan Aquifer System version 2 22 EIS    environmental impact statement 23 ELU    existing legal users 24 EMF    electromagnetic field 25 EPA    U.S. Environmental Protection Agency 26 ER      environmental report 27 FDEP    Florida Department of Environmental Protection 28 FDOH    Florida Department of Health 29 FPL    Florida Power & Light Company 30 FR      Federal Register 31 FRN    Federal Register notice 32 FSEIS  final supplemental environmental impact statement or Generic 33        Environmental Impact Statement for License Renewal of Nuclear Plants, 34        Supplement 5, Second Renewal, Regarding Subsequent License 35        Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 36        (NUREG-1437) 37 fps    feet per second xxi
 
1 ft      foot (feet) 2 FWS    U.S. Fish and Wildlife Service 3 GEIS    generic environmental impact statement 4 gpm    gallon(s) per minute 5 ha      hectare(s) 6 IAEA    International Atomic Energy Agency 7 ICRP    International Commission on Radiation Protection 8 in. inch(es) 9 ISFSI  Independent spent fuel storage installation 10 IWW    industrial wastewater 11 kV      kilovolt(s) 12 L      liter(s) 13 LLD    lower limit of detection 14 LR GEIS license renewal generic environmental impact statement or Generic 15        Environmental Impact Statement for License Renewal of Nuclear Plants, 16        Revision 1, Final Report (NUREG-1437) 17 LOS    level of service 18 LWR    light-water reactor 19 m      meter(s) 20 MDC    Miami-Dade County 21 MDWSD  Miami-Dade Water and Sewer Department 22 MEI    maximally exposed individual 23 mg      milligram(s) 24 MG      million gallons 25 MGD    million gallons per day 26 MGY    million gallons per year 27 mm      millimeter(s) 28 m/s    meters per second 29 m3/s    cubic meters per second 30 NCRP    National Council on Radiation Protection and Measurements 31 NEPA    National Environmental Policy Act of 1969, as amended 32 NMFS    National Marine Fisheries Service 33 NMSS    Nuclear Material Safety and Safeguards 34 NO2    nitrogen dioxide 35 NPDES  National Pollutant Discharge Elimination System 36 NRC    U.S. Nuclear Regulatory Commission 37 ODCM    Offsite Dose Calculation Manual 38 OSHA    Occupational Safety and Health Administration xxii
 
1 PILOT        payments in lieu of tax 2 PM          particulate matter 3 PRA          Probabilistic Risk Assessment 4 psu          practical salinity unit 5 PW          permitted well 6 RAI          Request for Additional Information 7 RCI          Request for Confirmatory Information 8 RCRA        Resource Conservation and Recovery Act of 1976, as amended 9 REMP        Radiological Environmental Monitoring Program 10 Rn          radon 11 ROW          right-of-way 12 RW          recovery well 13 RWS          Recovery Well System 14 SAMA        severe accident mitigation alternative 15 SEIS        supplemental environmental impact statement 16 SFWMD        South Florida Water Management District 17 SLR          subsequent license renewal 18 SO2          sulfur dioxide 19 SPCC        spill prevention, control, and countermeasure 20 SWPPP        stormwater pollution prevention plan 21 Tc          technetium 22 TDS          total dissolved solids 23 TEDE        total effective dose equivalent 24 Turkey Point Turkey Point Nuclear Generating Unit Nos. 3 and 4 25 UFA          Upper Floridan Aquifer 26 UIC          Underground Injection Control 27 UNSCEAR      United Nations Scientific Committee on the Effects of Atomic Radiation 28 U.S.        United States 29 USACE        U.S. Army Corps of Engineers 30 U.S.C.      United States Code 31 USCB        U.S. Census Bureau 32 VOC          volatile organic compound 33 xxiii
 
1                                    1      INTRODUCTION 2 The U.S. Nuclear Regulatory Commissions (NRCs, the Commissions) environmental 3 protection regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 51, 4 Environmental Protection Regulations for Domestic Licensing and Related Regulatory 5 Functions, implement the National Environmental Policy Act of 1969, as amended (NEPA; 6 42 U.S.C. 4321 et seq.), and require, in part, that the NRC prepare an environmental impact 7 statement (EIS) before the issuance or renewal of a license to operate a nuclear power plant.
8 The Atomic Energy Act of 1954, as amended (AEA; 42 U.S.C. 2011 et seq.), specifies that 9 licenses for commercial nuclear power plants can be granted for up to 40 years. The initial 40-10 year licensing period was based on economic and antitrust considerations rather than on 11 technical limitations of the nuclear facility. NRC regulations permit these licenses to be renewed 12 beyond the initial 40-year term for an additional period, limited to 20-year increments per 13 renewal. Renewal is based on the results of (1) the NRC staffs environmental review and 14 (2) the NRC staffs safety review (10 CFR 54.29, Standards for issuance of a renewed 15 license). Neither the AEA nor the NRCs regulations restrict the number of times a license may 16 be renewed. The decision to seek renewal rests entirely with nuclear power plant owners and 17 typically is based on the plants economic viability and the investment necessary to continue to 18 meet all safety and environmental requirements. The NRC makes the decision to grant or deny 19 license renewal based on whether the applicant has demonstrated reasonable assurance that it 20 can meet the environmental and safety requirements in the agencys regulations during the 21 period of extended operation.
22 Pursuant to 10 CFR Part 51, the NRC staff performed an environmental review of the Florida 23 Power & Light Company (FPL, the licensee) January 30, 2018, subsequent license renewal 24 (SLR) application, as supplemented by letters dated February 9, 2018 (FPL 2018b), February 25 16, 2018 (FPL 2018c), March 1, 2018 (FPL 2018d), and April 10, 2018 (FPL 2018fe. In its SLR 26 application, FPL requested subsequent renewed facility operating licenses for Turkey Point 27 Nuclear Generating Unit Nos. 3 and 4 (Turkey Point, Turkey Point Units 3 and 4) for a period of 28 20 years beyond the dates when the initial renewed facility operating licenses would expire 29 i.e., July 19, 2052, for Turkey Point Unit 3 and April 10, 2053, for Turkey Point Unit 4. As part of 30 its SLR application, FPL submitted an environmental report (ER) (FPL 2018f), which it 31 supplemented by {{letter dated|date=April 10, 2018|text=letter dated April 10, 2018}} (ER Supplement 1) (FPL 2018e).
32 The NRC staff documented its environmental review of FPLs SLR application as a supplement 33 to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear 34 Plants, Revision 1, Final Report (LR GEIS; NRC 2013a). Specifically, in March 2019, the NRC 35 staff issued a draft supplement to the LR GEIS, titled Generic Environmental Impact Statement 36 for License Renewal of Nuclear Plants, Supplement 5, Second Renewal, Regarding 37 Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, Draft 38 Report for Comment (NRC 2019). In October 2019, after considering public comments on the 39 draft supplement, the NRC staff issued a final supplement to the LR GEIS, titled Generic 40 Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 5, Second 41 Renewal, Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit 42 Nos. 3 and 4, Final Report (FSEIS) (NRC 2019a). The FSEIS concluded, in part, that the 43 adverse environmental impacts of SLR for Turkey Point are not so great that preserving the 44 option of SLR for energy-planning decision-makers would be unreasonable. Based, in part, on 45 that environmental review, on December 4, 2019, the NRC issued subsequent renewed 46 licenses for Turkey Point (NRC 2019b), which included the expiration dates of July 19, 2052, for 1-1
 
1 Turkey Point Unit 3 and April 10, 2053, for Turkey Point Unit 4. In accordance with 10 CFR Part 2 51, the NRC also issued a record of decision in support of this action (NRC 2019c).
3 On February 24, 2022, the Commission issued three memoranda and orders that addressed the 4 NRC staffs environmental reviews in SLR proceedings for five nuclear power plants (NRC 5 2022a, 2022b, 2022d). Two of these orders, Commission Legal Issuance (CLI)-22-02 (NRC 6 2022a) and CLI-22-03 (NRC 2022b), addressed Turkey Point. In the orders, the Commission 7 concluded that the LR GEIS, on which the NRC staff had relied, in part, to meet its obligations 8 under 10 CFR Part 51 and NEPA for its environmental reviews of the SLR applications for the 9 affected nuclear power plants, did not consider SLR. Therefore, the Commission determined 10 that the staffs SLR environmental reviews, including the environmental review for the Turkey 11 Point SLR application, were inadequate. Accordingly, the Commission directed the NRC staff to 12 leave the Turkey Point subsequent renewed licenses in place but to modify their expiration 13 dates to reflect the end dates of the previous renewed licenses (i.e., July 19, 2032, for Turkey 14 Point Unit 3 and April 10, 2033, for Turkey Point Unit 4), which the staff did on March 25, 2022 15 (NRC 2022e). The Commission affirmed this direction in CLI-22-06 (NRC 2022c).
16 In CLI-22-03, the Commission directed the NRC staff to update the LR GEIS so that it covers 17 nuclear power plant operation during the SLR period (NRC 2022b). The Commission stated that 18 it believed the most efficient way to proceed would be for the NRC staff to update the LR GEIS 19 and then take appropriate action with respect to pending SLR applications to ensure that the 20 environmental impacts for the period of SLR are considered. Alternatively, the Commission 21 allowed SLR applicants to submit a revised ER providing additional information about 22 environmental impacts during the SLR period, in which they evaluate, on a site-specific basis, 23 the environmental impacts that were dispositioned in Table B-1 in Appendix B to Subpart A of 24 10 CFR Part 51 and the LR GEIS as Category 1 issues (generic to all or a distinct subset of 25 nuclear power plants). For SLR applicants that provide such information, the NRC staff was 26 directed to address the environmental impacts of these issues in site-specific EISs.
27 Consistent with CLI-22-03, on June 9, 2022, FPL submitted ER Supplement 2, providing a site-28 specific analysis of the environmental impacts of the continued operation of Turkey Point during 29 the SLR period (FPL 2022a). That analysis supplemented the ER and ER Supplement 1 that 30 were included as part of FPLs SLR application (FPL 2018f, 2018e) and addressed, on a site-31 specific basis, each environmental issue that was previously dispositioned as a Category 1 32 issue in the ER and ER Supplement 1.
33 1.1      Proposed Federal Action 34 FPL initiated the proposed Federal action of determining whether to issue subsequent renewed 35 licenses for Turkey Point by submitting an SLR application to the NRC. The Turkey Point Unit 3 36 initial renewed license was set to expire at midnight on July 19, 2032, and the Turkey Point Unit 37 4 initial renewed license was set to expire at midnight on April 10, 2033. On December 4, 2019, 38 the NRC issued subsequent renewed licenses for Turkey Point authorizing operation for a 39 period of 20 years beyond the expiration datesi.e., July 19, 2052, for Turkey Point Unit 3 and 40 April 10, 2053, for Turkey Point Unit 4. On March 25, 2022 (NRC 2022e), in accordance with the 41 Commissions direction in CLI-22-02, dated February 24, 2022, the NRC staff modified the 42 expiration dates of these subsequent renewed licenses to reflect the end dates of the previous 43 renewed licenses. Therefore, the subsequent renewed licenses for Turkey Point now expire on 44 July 19, 2032 (Unit 3) and April 10, 2033 (Unit 4).
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1 The proposed Federal action as stated in the FSEIS (p. 1-1) is to determine whether to issue 2 subsequent renewed licenses for Turkey Point for an additional 20 years of operation. After 3 issuing the FSEIS, the NRC issued (and later modified) subsequent renewed licenses for 4 Turkey Point. Based on the above discussion, the proposed Federal action at this time is to 5 determine whether the site-specific evaluation presented in the EIS warrants any modification to 6 the NRC staffs previous determination that the adverse environmental impacts of SLR for 7 Turkey Point are not so great that preserving the option of SLR for energy-planning decision-8 makers would be unreasonable.
9 1.2    Purpose and Need for the Proposed Federal Action 10 The purpose and need for the proposed Federal action, as stated in the FSEIS (p. 1-1), is to 11 provide an option that allows for power generation capability beyond the term of the current 12 nuclear power plant licenses to meet future system generating needs. Such needs may be 13 determined by energy-planning decision-makers, such as State regulators, utility owners, and 14 Federal agencies other than the NRC. This definition of purpose and need reflects the NRCs 15 recognition that, unless there are findings in the NRCs safety review (required by the Atomic 16 Energy Act of 1954, as amended) or findings in the NRCs environmental analysis (required by 17 NEPA) that would lead the NRC to reject an SLR application, the NRC does not have a role in 18 making energy-planning decisions about whether a particular nuclear power plant should 19 continue to operate.
20 1.3    Major Environmental Review Milestones 21 By {{letter dated|date=June 9, 2022|text=letter dated June 9, 2022}}, FPL submitted to the NRC its ER Supplement 2 (FPL 2022a).
22 On July 26, 2022, the NRC issued a notice of its receipt of ER Supplement 2 (Volume 87 of the 23 Federal Register (FR), page 44430 [87 FR 44430]). On October 7, 2022, the NRC issued a 24 notice of its intent to prepare an EIS supplement and to conduct EIS scoping (87 FR 61104).
25 To independently verify the information that FPL provided in ER Supplement 2, the NRC staff 26 conducted a virtual audit in December 2022 and January 2023. In a {{letter dated|date=February 1, 27|text=letter dated February 1, 27}} 2023, the staff summarized the audit and listed the attendees (NRC 2023). During the audit, the 28 staff held meetings with Turkey Point plant personnel and reviewed site-specific documentation.
29 The NRC has established a license renewal process that includes clear requirements to assure 30 safe plant operation for up to an additional 20 years of plant life. This process consists of 31 separate environmental and safety reviews, which the NRC staff conducts simultaneously and 32 documents in two reports: (1) the EIS documents the environmental review and (2) the safety 33 evaluation report (SER) documents the safety review. The staffs findings in the EIS and the 34 SER are both factors in the NRCs decision to grant or deny the issuance of a renewed license.
35 The environmental review process specific to this EIS is illustrated below in Figure 1-1.
1-3
 
1 2                          Figure 1-1    Environmental Review Process 3 1.4    Environmental Impacts of the Proposed Federal Action 4 This EIS supplements the FSEIS in order to evaluate the potential environmental impacts of the 5 proposed Federal action. The NRC designates these environmental impacts as SMALL, 6 MODERATE, or LARGE.
7        SMALL: Environmental effects are not detectable or are so minor that they will 8        neither destabilize nor noticeably alter any important attribute of the resource.
9        MODERATE: Environmental effects are sufficient to alter noticeably, but not to 10        destabilize, important attributes of the resource.
11        LARGE: Environmental effects are clearly noticeable and are sufficient to 12        destabilize important attributes of the resource.
13 The NRC staff has prepared this EIS to evaluate, on a site-specific basis, the environmental 14 impacts of the operation of Turkey Point during the SLR period for each of the environmental 15 issues that were dispositioned as Category 1 issues in the FSEIS, in accordance with CLI-22-02 16 and CLI-22-03. The EIS considers information contained in ER Supplement 2; the NRC staffs 17 consultation with Federal, State, Tribal, and local government agencies; and other information, 18 as appropriate. The EIS also considers whether there is significant new information that would 19 change the NRC staffs conclusions concerning Category 2 issues (specific to individual nuclear 20 power plants) in the FSEIS. Thus, the EIS supplements the FSEIS evaluation of Category 1 21 impacts and updates the FSEIS evaluation of Category 2 impacts, as set forth herein. Together, 22 the EIS and the FSEIS evaluate, on a site-specific basis, all of the environmental impacts of 1-4
 
1 continued operation during the SLR term for Turkey Point Unit 3 from July 19, 2032, to July 19, 2 2052, and for Turkey Point Unit 4 from April 10, 2033, to April 10, 2053.
3 In the FSEIS, the NRC staff relied upon the analyses and conclusions in the LR GEIS for each 4 of the environmental issues that were dispositioned as Category 1 issues in the LR GEIS and 5 Table B-1 in Appendix B to Subpart A of 10 CFR Part 51. In the FSEIS, the NRC staff also 6 considered any new and significant information that might change those conclusions. The NRC 7 staff determined in the FSEIS that there would be no impacts related to these issues beyond 8 those already discussed in the LR GEIS; therefore, for each of these issues, the FSEIS adopted 9 the LR GEISs conclusions of SMALL environmental impacts. However, as explained herein, the 10 Commission later determined that the NRC staff cannot rely on the LR GEIS for the 11 environmental reviews of SLR applications (NRC 2022a, NRC 2022b). Therefore, in this EIS, 12 the NRC staff addresses each of these environmental issues on a site-specific basis.
13 In the FSEIS, the NRC staff also evaluated an additional set of environmental issues for the 14 Turkey Point SLR application on a site-specific basis. Table B-1 in Appendix B to Subpart A of 15 10 CFR Part 51 and the LR GEIS disposition these issues as Category 2 issues that are specific 16 to individual nuclear power plants. The FSEISs analyses of these issues are unaffected by the 17 Commission orders because the NRC staff already performed site-specific analyses of these 18 issues for Turkey Point SLR. This EIS incorporates by reference the FSEIS conclusions for 19 these issues, as appropriate, and considers whether there is any significant new information 20 that would change the NRC staffs FSEIS conclusions concerning the issues.
21 In sum, this EIS supplements the FSEIS evaluation of Category 1 impacts and updates the 22 FSEIS evaluation of Category 2 impacts and, together, the EIS and the FSEIS evaluate, on a 23 site-specific basis, all of the potential environmental impacts of the proposed Federal action.
24 1.5    Site-Specific Environmental Impact Statement 25 This site-specific EIS presents the NRC staffs supplemental analysis of the environmental 26 effects of the continued operation of Turkey Point during the SLR term, reasonable alternatives 27 to SLR, and mitigation measures for minimizing adverse environmental impacts. Chapter 2, 28 Environmental Consequences and Mitigating Actions, contains an analysis and comparison of 29 the potential environmental impacts from SLR and alternatives to SLR. Chapter 3, Conclusion, 30 presents the NRC staffs recommendation about whether the environmental impacts of SLR for 31 Turkey Point are so great that preserving the option of SLR for energy-planning decision-32 makers would be unreasonable. In issuing this site-specific EIS, the NRC staff considered the 33 comments it received during the public scoping comment period. The NRC staff will consider the 34 public comments that it receives on this draft site-specific EIS and will then issue its final site-35 specific EIS. The NRC staff will make its final determination on SLR for Turkey Point Units 3 and 36 4 in a record of decision to be issued following issuance of the final site-specific EIS.
37 In the preparation of this site-specific EIS, the NRC staff carried out the following activities:
38
* reviewed the information provided in FPLs ER Supplement 2 39
* consulted with Federal, State, Tribal, and local government agencies 40
* conducted an independent environmental review, including the environmental and severe 41      accident mitigation alternatives analysis site audits 42
* considered public comments received during the scoping process.
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1 New information can come from many sources, including the applicant, the NRC, other 2 agencies, or public comments. If the information revealed a new issue, the staff analyzed the 3 issue to determine whether it was within the scope of the license renewal environmental 4 evaluation. If the staff determined that the new issue was relevant to the proposed action, the 5 staff then determined the significance of the issue for the plant and analyzed the issue in the 6 EIS, as appropriate.
7 1.6    Decisions to Be Supported by the EIS 8 This site-specific EIS provides information and analyses to support an NRC decision about 9 whether the environmental impacts of SLR for Turkey Point are so great that preserving the 10 option of SLR for energy-planning decision-makers would be unreasonable.
11 The NRC takes many factors into consideration when making a final decision about SLR for a 12 nuclear power plant. The analyses of environmental impacts in this site-specific EIS will provide 13 the NRC with important environmental information for use in the overall decision-making 14 process related to SLR for Turkey Point. Other decisions are made outside the regulatory scope 15 of SLR, by the NRC or other decision-makers, as appropriate. These include decisions related 16 to (1) changes in plant cooling systems, (2) disposition of spent nuclear fuel, (3) emergency 17 preparedness, (4) safeguards and security, (5) need for power, and (6) seismicity and flooding 18 (NRC 2013a).
19 1.7    Cooperating Agencies 20 The U.S. National Park Service, Southeast Region (NPS), is participating in this environmental 21 review as a cooperating agency. The NPS does not have any specific regulatory actions related 22 to Turkey Point SLR at this time; however, the NPS is providing special expertise for 23 environmental issues pertaining to the areas in and around Biscayne National Park, which is 24 located next to the Turkey Point site. The NPS also cooperated in the NRC staffs preparation of 25 the site-specific EIS. The NRC and NPS staff met several times to discuss the proposed action 26 and its effects, and the NPS reviewed and provided comments on preliminary sections of the 27 draft EIS discussing surface water and groundwater resources.
28 1.8    Consultations 29 Certain Federal environmental statutes require Federal agencies to consult with other agencies, 30 Tribes, and organizations before taking an action that may affect protected environmental 31 resources, such as endangered species, habitat of managed fisheries, and historical and 32 cultural resources. These include the Endangered Species Act of 1973, as amended (ESA; 33 16 U.S.C. 1531 et seq.); the Magnuson-Stevens Fishery Conservation and Management Act of 34 1996, as amended (16 U.S.C. 1801 et seq.); and the National Historic Preservation Act of 1966, 35 as amended (54 U.S.C. 300101 et seq.), among others.
36 In preparing the FSEIS, the NRC consulted with numerous agencies and Tribes. These 37 consultations are summarized in Section 1.8 and Appendix C of the FSEIS. In preparing this 38 site-specific EIS, the NRC staff consulted with the following agencies, organizations, and Tribes:
39
* Miami-Dade County Office of Historic Preservation 40
* Miccosukee Tribe of Indians of Florida 41
* Muscogee (Creek) Nation 1-6
 
1
* Poarch Band of Creek Indians 2
* The Seminole Nation of Oklahoma 3
* Seminole Tribe of Florida 4
* Florida Department of State, Division of Historical Resources 5
* Federal Advisory Council on Historic Preservation.
6 Appendix B, Consultation Correspondence, of this EIS discusses the consultations that the 7 NRC staff conducted, or considered to be unwarranted, in support of this EIS.
8 1.9    Correspondence 9 During the environmental review, the NRC staff contacted the Federal, State, regional, local, 10 and Tribal government agencies listed in Section 1.8 above. Appendix B, Consultation 11 Correspondence, describes correspondence between the NRC staff, other Federal agencies, 12 and Tribes. Appendix C, Chronology of Environmental Review Correspondence, 13 chronologically lists all other correspondence.
14 1.10 Status of Compliance 15 When developing this site-specific EIS, the NRC staff identified no significant new information 16 that would change this discussion in the FSEIS and, therefore, the staff incorporates that 17 discussion herein by reference.
18 1.11 Related State and Federal Activities 19 When developing this site-specific EIS, the NRC staff identified no significant new information 20 that would change this discussion in the FSEIS and, therefore, the staff incorporates that 21 discussion herein by reference.
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1  2      ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS 2 2.1    Introduction 3 In this chapter, the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff 4 evaluates the environmental consequences of the Florida Power & Light Companys (FPL, the 5 licensee) continued operation of Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey 6 Point, Turkey Point Units 3 and 4) for an additional 20 years under the terms of subsequent 7 renewed licenses.
8 In 2019, the NRC staff prepared the Generic Environmental Impact Statement for License 9 Renewal of Nuclear Plants, Supplement 5, Second Renewal, Regarding Subsequent License 10 Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, Final Report (NUREG-1437, 11 Supplement 5, Second Renewal) (FSEIS) for the Turkey Point subsequent license renewal 12 (SLR) application (NRC 2019a) in accordance with the NRCs environmental protection 13 regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental 14 Protection Regulations for Domestic Licensing and Related Regulatory Functions, which 15 implement the National Environmental Policy Act of 1969, as amended (NEPA; 42 U.S.C. 4321 16 et seq.).
17 In the FSEIS, the NRC staff evaluated the environmental issues that are applicable to Turkey 18 Point SLR. For some of these issues (site-specific or Category 2 issues), the NRC staff 19 performed site-specific analyses and reached conclusions specific to the Turkey Point site. For 20 the remaining environmental issues (generic or Category 1 issues), the NRC staff relied upon 21 the analyses and conclusions in NUREG-1437, Generic Environmental Impact Statement for 22 License Renewal of Nuclear Plants, Revision 1, Final Report (LR GEIS) (NRC 2013a), and 23 considered any new and significant information that might change those conclusions. The staff 24 concluded that the impacts of these issues would be SMALL for Turkey Point SLR. However, as 25 explained in Chapter 1 of this environmental impact statement (EIS), the Commission later 26 determined that the LR GEIS did not consider SLR and, therefore, the NRC staffs 27 environmental review for Turkey Point SLR was inadequate in its evaluation of the Category 1 28 issues (NRC 2022a, 2022b). This EIS addresses the Commissions determination by providing 29 the NRC staffs site-specific analysis of the environmental issues that were previously 30 addressed as generic Category 1 issues. Table 2-1 lists these issues and the NRC staffs 31 findings related to the issues specific to Turkey Point SLR.
32 Additionally, in this EIS the NRC staff considers whether there is significant new information that 33 would change the staffs conclusions concerning the Category 2 environmental issues for which 34 the staff performed site-specific analyses and made site-specific conclusions in the FSEIS. In 35 2021, the NRC reinitiated consultation with the U.S. Fish and Wildlife Service (FWS) because 36 FPL exceeded the allowable take of American crocodile (Crocodylus acutus). As a result of the 37 reinitiated consultation, the FWS revised the amount of allowable take of the American 38 crocodile. Appendix B, Section B.1 describes this consultation. Although this information is new 39 because it has transpired since the issuance of the FSEIS, the staff determined that it does not 40 affect the conclusions made in the FSEIS concerning federally protected ecological resources.
41 For all other Category 2 issues, the NRC staff has identified no significant new information that 42 would change the conclusions reached in the FSEIS. Therefore, the analyses and conclusions 43 in the FSEIS remain valid for these issues, and that information is incorporated herein by 44 reference. Table 2-2 lists these issues, the relevant sections of the FSEIS in which a discussion 45 of the issues can be found, and the FSEISs conclusions.
2-1
 
1 Finally, the NRC staff considered whether any additional environmental issues exist for Turkey 2 Point SLR that were not addressed previously. The NRC staff identified no such issues.
3 Together, this EIS and the FSEIS evaluate, on a site-specific basis, all of the environmental 4 impacts of continued operation during the SLR term for Turkey Point Unit 3 from July 19, 2032, 5 to July 19, 2052, and for Turkey Point Unit 4 from April 10, 2033, to April 10, 2053.
6 Table 2-1      Site-Specific Conclusions Regarding Turkey Point SLR Made in this EIS Resource Area                            Environmental Issue                      Impacts Land Use                    Onsite land use                                                SMALL Land Use                    Offsite land use                                              SMALL Land Use                    Offsite land use in transmission line rights-of-way            SMALL (ROWs)
Visual Resources            Aesthetic impacts                                              SMALL Air Quality                Air quality impacts                                            SMALL Air Quality                Air quality effects of transmission lines                      SMALL Noise                      Noise impacts                                                  SMALL Geologic Environment        Geology and soils                                              SMALL Surface Water Resources    Surface water use and quality (non-cooling system              SMALL impacts)
Surface Water Resources    Discharge of metals in cooling system effluent                SMALL Surface Water Resources    Discharge of biocides, sanitary wastes, and minor              SMALL chemical spills Surface Water Resources    Effects of dredging on surface water quality                  SMALL Groundwater Resources      Groundwater contamination and use (non-cooling system          SMALL impacts)
Groundwater Resources      Groundwater quality degradation resulting from water          SMALL withdrawals Groundwater Resources      Groundwater quality degradation (plants with cooling          SMALL to ponds in salt marshes)                                      MODERATE Groundwater Resources      Groundwater use conflicts (plants that withdraw more          SMALL to than 100 gallons per minute)                                MODERATE Terrestrial Resources      Exposure of terrestrial organisms to radionuclides            SMALL Terrestrial Resources      Cooling system impacts on terrestrial resources (plants        SMALL with once-through cooling systems or cooling ponds)
Terrestrial Resources      Bird collisions with plant structures and transmission lines  SMALL Terrestrial Resources      Transmission line right-of-way management impacts on          SMALL terrestrial resources(c)
Terrestrial Resources      Electromagnetic fields on flora and fauna (plants,            SMALL agricultural crops, honeybees, wildlife, livestock)
Aquatic Resources          Entrainment of phytoplankton and zooplankton                  SMALL Aquatic Resources          Infrequently reported thermal impacts                          SMALL Aquatic Resources          Effects of cooling water discharge on dissolved oxygen,        SMALL gas supersaturation, and eutrophication Aquatic Resources          Effects of nonradiological contaminants on aquatic            SMALL organisms Aquatic Resources          Exposure of aquatic organisms to radionuclides                SMALL 7
2-2
 
Table 2-1      Site-Specific Conclusions Regarding Turkey Point SLR Made in this EIS (Continued)
Resource Area                              Environmental Issue                                Impacts Aquatic Resources              Effects of dredging on aquatic organisms                              SMALL Aquatic Resources              Effects on aquatic resources (non-cooling system                      SMALL impacts)
Aquatic Resources              Impacts of transmission line right-of-way                              SMALL management on aquatic resources(c)
Aquatic Resources              Losses from predation, parasitism, and disease                        SMALL among organisms exposed to sublethal stresses Socioeconomics                  Employment and income, recreation and tourism                          SMALL Socioeconomics                  Tax revenues                                                          SMALL Socioeconomics                  Community services and education                                      SMALL Socioeconomics                  Population and housing                                                SMALL Socioeconomics                  Transportation                                                        SMALL Human Health                    Radiation exposures to the public                                      SMALL Human Health                    Radiation exposures to plant workers                                  SMALL Human Health                    Human health impact from chemicals                                    SMALL Human Health                    Microbiological hazards to plant workers                              SMALL Human Health                    Physical occupational hazards                                          SMALL Postulated Accidents            Design basis accidents                                                SMALL Postulated Accidents            Severe accidents                                              Probability-weighted consequences of severe accidents are SMALL Waste Management                Low-level waste storage and disposal                                  SMALL Waste Management                Onsite storage of spent nuclear fuel                                  SMALL Waste Management                Offsite radiological impacts of spent nuclear fuel and                    (a) high-level waste disposal Waste Management                Mixed-waste storage and disposal                                      SMALL Waste Management                Nonradioactive waste storage and disposal                              SMALL Uranium Fuel Cycle              Offsite radiological impactsindividual impacts from                  SMALL other than the disposal of spent fuel and high-level waste Uranium Fuel Cycle              Offsite radiological impactscollective impacts from                      (b) other than the disposal of spent fuel and high-level waste Uranium Fuel Cycle              Nonradiological impacts of the uranium fuel cycle                      SMALL Uranium Fuel Cycle              Transportation                                                        SMALL Termination of Nuclear          Termination of plant operations and                                    SMALL Power Plant Operations          decommissioning and Decommissioning 1 (a) The ultimate disposal of spent nuclear fuel and high-level waste in a potential future geologic repository is a 2    separate and independent licensing action that is outside the regulatory scope of this site-specific review. The 3    environmental impact of this issue for the time frame beyond the licensed life for reactor operations is contained 4    in NUREG-2157, the NRCs Generic Environmental Impact Statement for Continued Storage of Spent Nuclear 5    Fuel. Per 10 CFR Part 51 Subpart A, the Commission determined that the impacts presented in NUREG-2157 6
2-3
 
Table 2-1        Site-Specific Conclusions Regarding Turkey Point SLR Made in this EIS (Continued)
Resource Area                                Environmental Issue                                  Impacts 1    would not be sufficiently large to require the conclusion, for any plant, that the option of extended operation 2    under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level 3    of significance for the impacts of spent nuclear fuel and high-level waste disposal, this issue is considered 4    generic to all nuclear power plants and does not warrant a site-specific analysis.
5 (b) There are no regulatory limits applicable to collective doses to the general public from fuel-cycle facilities. The 6    practice of estimating health effects on the basis of collective doses may not be meaningful. All fuel-cycle 7    facilities are designed and operated to meet the applicable regulatory limits and standards. The Commission 8    determined that the collective impacts are acceptable. The Commission also determined that the impacts would 9    not be sufficiently large to require the conclusion, for any plant, that the option of extended operation under 10    10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of 11    significance for the collective impacts of the uranium fuel cycle, this issue is considered generic to all nuclear 12    power plants and does not warrant a site-specific analysis.
13 (c) This issue applies only to the in-scope portion of electric power transmission lines, which are defined as 14    transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional 15    power distribution system and transmission lines that supply power to the nuclear power plant from the grid.
16 Table 2-2          Site-Specific Conclusions Regarding Turkey Point SLR Made in the FSEIS FSEIS Resource Area                        Environmental Issue                      Section            Impacts(a)
Groundwater Resources Groundwater use conflicts (plants that                          4.5.1            SMALL to withdraw more than 100 gallons per                                    MODERATE minute [gpm])
Groundwater Resources Radionuclides released to groundwater                          4.5.1              SMALL Terrestrial Resources          Effects on terrestrial resources (non-                4.6.1              SMALL cooling system impacts)
Aquatic Resources              Impingement and entrainment of                        4.7.1            SMALL to aquatic organisms (plants with once-                                  MODERATE(b) through cooling systems or cooling ponds)
Aquatic Resources              Thermal impacts on aquatic organisms                                    SMALL to (plants with once-through cooling                                    MODERATE(b) systems or cooling ponds)
Special Status Species        Threatened, endangered, and protected                  4.8.1              Impact and Habitats                  species and essential fish habitat                                determinations vary by species and habitat(c)
Historic and Cultural          Historic and cultural resources                        4.9.1      Would not adversely Resources                                                                                        affect known historic properties or historic and cultural resources(d)
Human Health                  Chronic effects of electromagnetic fields            4.11.1        Uncertain Impact Human Health                  Electric shock hazards    (e) 4.11.1              SMALL 17 2-4
 
1 Table 2-2        Site-Specific Conclusions Regarding Turkey Point SLR Made in the FSEIS 2                  (Continued)
FSEIS Resource Area                      Environmental Issue                        Section              Impacts(a)
Environmental Justice        Minority and low-income populations                    4.12.1                  No disproportionately high and adverse human health and environmental effects Cumulative Impacts            Cumulative impacts                                      4.16        See FSEIS Section 4.16 3 (a) In reciting the FSEIS conclusions here, the NRC staff notes that the impact determinations for these issues were 4    described in Chapter 4 of the FSEIS. These impact findings are incorporated herein by reference.
5 (b) The NRC staff notes that the FSEIS conclusion of SMALL to MODERATE applies to aquatic resources in the 6    cooling canal system. Aquatic organisms inhabiting Biscayne Bay and connected water bodies (e.g., Card 7    Sound, the Atlantic Ocean) are not subject to impingement and entrainment because they do not interact with the 8    Turkey Point intake structure, and there are no thermal effects outside the cooling canal system because there 9    are no surface water connections that allow flow between the waters of Biscayne Bay and the cooling canal 10    system.
11 (c) In the FSEIS, the NRC staff concluded that Turkey Point SLR is likely to adversely affect the American crocodile 12    and the eastern indigo snake and may result in adverse modification of the designated critical habitat of the 13    American crocodile. The FSEIS also concluded that the proposed action may affect but is not likely to adversely 14    affect the Florida panther, West Indian manatee, red knot, wood stork, loggerhead sea turtle, green sea turtle, 15    leatherback sea turtle, hawksbill sea turtle, Kemps ridley sea turtle, and smalltooth sawfish. The FSEIS further 16    concluded that the proposed action would result in no adverse modification of designated critical habitat of the 17    West Indian manatee. The NRC staffs evaluation of impacts on federally listed species and critical habitats 18    under the U.S. Fish and Wildlife Services (FWS) jurisdiction appears in the NRCs Biological Assessment (NRC 19    2018). The FWSs separate evaluation and conclusions appear in a July 25, 2019, biological opinion (FWS 20    2019), which is described in Section 4.8.1.1 of the FSEIS. The FWS later amended its biological opinion on 21    March 21, 2022 (FWS 2022). The NRC staffs evaluation of impacts on federally listed species and critical 22    habitats under the National Marine Fisheries Services jurisdiction appears in Section 4.8.1.1 of the FSEIS. The 23    FSEIS concluded that the proposed action would have no adverse effects on essential fish habitat. The NRC 24    staffs evaluation of impacts on essential fish habitat appears in Section 4.8.1.2 of the FSEIS. The NRC staff also 25    concluded in the FSEIS that the proposed action would not affect the sanctuary resources of the Florida Keys 26    National Marine Sanctuary. The NRC staffs evaluation of sanctuary resources appears in Section 4.8.1.3 of the 27    FSEIS.
28 (d) The NRC staff notes that based on (1) the location of National Register of Historic Places-eligible historic 29    properties within the area of potential effect, (2) Tribal input, (3) FPLs cultural resource protection plans, (4) the 30    fact that no license renewal-related physical changes or ground-disturbing activities would occur, (5) Florida 31    State Historic Preservation Office input, and (6) cultural resource assessment, the FSEIS concluded that Turkey 32    Point SLR would not adversely affect any known historic properties. See FSEIS Table 2-2.
33 (e) The NRC staff notes that this issue applies only to the in-scope portion of electric power transmission lines, 34    which are defined as transmission lines that connect the nuclear power plant to the substation where electricity is 35    fed into the regional power distribution system and transmission lines that supply power to the nuclear power 36    plant from the grid.
37 2.2    Land Use 38 License renewal has had little or no effect on land use on or near the nuclear power plant site.
39 Industrial land use activities at Turkey Point are not expected to change appreciably until 40 sometime after decommissioning. Similarly, land use activity within transmission line rights-of-41 way (ROWs) would continue with no change in land use restrictions, and easements are 42 expected to remain unchanged during the SLR term. The following sections address the site-43 specific environmental impacts of Turkey Point SLR on three environmental issues related to 44 land use.
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1 2.2.1      Onsite Land Use 2 Operational activities during the SLR term would be similar to those already occurring at Turkey 3 Point. The industrial nature of onsite land use would continue unchanged. However, additional 4 space within the site could be needed for new or expanded onsite storage of the spent nuclear 5 fuel and low-level radioactive waste generated during the SLR term. The exact size and location 6 of any such additional storage cannot be known at this time. However, the applicant indicates 7 that the amount of additional space needed for these activities would be relatively small2.5 to 8 10 acres (ac) (1 to 4 ha) (FPL 2018a). This would be addressed in separate licensing actions 9 and environmental reviews of any future application to expand onsite spent fuel and/or low-level 10 waste storage capacity, as appropriate.
11 Based on these considerations, the NRC staff concludes that the impact of continued nuclear 12 power plant operations on onsite land use during the Turkey Point SLR term would be SMALL.
13 In addition, the NRC staff did not identify any new information that would alter this conclusion.
14 2.2.2      Offsite Land Use 15 License renewal activities have had little to no effect on population or tax revenue in 16 communities near nuclear power plants. Employment levels at Turkey Point have remained the 17 same or have slightly decreased with no increased demand for housing, infrastructure 18 improvements, or services. Operational activities during the SLR term would be similar to those 19 already occurring at Turkey Point and would not affect offsite land use beyond what has already 20 been affected.
21 Section 307(c)(3)(A) of the Coastal Zone Management Act of 1972, as amended (CZMA; 22 16 U.S.C. 1456), requires that applicants for Federal licenses who conduct activities in a 23 coastal zone provide a certification that the proposed activity complies with the enforceable 24 policies of the States coastal zone program. Turkey Point Units 3 and 4 are within the Florida 25 coastal zone. The Florida Department of Environmental Protection (FDEP) issued a license that 26 constitutes concurrence that FPLs activities at Turkey Point are consistent with those 27 addressed in the State of Floridas approved coastal zone management program. The most 28 recent certification for Turkey Point Units 3 through 5 (FDEP 2012) shows Turkey Point Units 3 29 and 4 as being consistent with Floridas coastal zone program in 2008, with several 30 modifications since then, the most recent having been issued on January 24, 2022 (FDEP 31 2022a).
32 Land to the south and west of the Turkey Point site is in the Everglades Mitigation Bank where 33 wetlands are created, restored, or enhanced to provide compensatory mitigation of wetland 34 losses elsewhere. Under the joint federally and State-operated mitigation bank program, both 35 public and private entities can own lands managed under the program. FPL owns the 36 Everglades Mitigation Bank land, which comprises approximately 13,000 ac (5,300 ha) of 37 relatively undisturbed freshwater and estuarine wetlands. The U.S. Army Corps of Engineers 38 (USACE), the U.S. Environmental Protection Agency (EPA), the Natural Resources 39 Conservation Service, the FWS, and the National Marine Fisheries Service (NMFS) review and 40 comment on mitigation bank permit applications and subsequent Mitigation Banking Instruments 41 issued by the USACE to ensure consistency with specific laws and provisions, including the 42 Section 404 of the Federal Water Pollution Control Act of 1972, as amended (33 U.S.C. 1251 et 43 seq.) (also known as the Clean Water Act [CWA]) (FWPCA 1972), permit program, the wetland 44 conservation provisions of the Food Security Act of 1985, NEPA, and several other statutory 45 provisions. The FDEP permits mitigation banks for utility companies within Florida pursuant to 2-6
 
1 the Florida Mitigation Banking Rule and other State authorities. FPL must comply with those 2 requirements, assuring that SLR operations at Turkey Point will be consistent with mitigation 3 bank requirements.
4 Based on these considerations, the NRC staff concludes that the impact of continued nuclear 5 power plant operations offsite land use during the Turkey Point SLR term would be SMALL. In 6 addition, the NRC staff did not identify any new information that would alter this conclusion.
7 2.2.3      Offsite Land Use in Transmission Line Rights-of-Way 8 Maintenance activities in transmission line ROWs during the license renewal term, would be the 9 same as or similar to those already occurring and would not affect offsite land use beyond what 10 has already been affected. Transmission line ROWs do not preclude the use of the land for 11 other purposes, such as agriculture and recreation. However, land use is limited to activities that 12 do not endanger power line operation.
13 Based on these considerations, the NRC staff concludes that the impact of continued nuclear 14 power plant operations during the Turkey Point SLR term on offsite land use in transmission line 15 ROWs would be SMALL. In addition, the NRC staff did not identify any new information that 16 would alter this conclusion.
17 2.3    Visual Resources 18 The visual appearance of Turkey Point and associated transmission lines have become well 19 established during the current licensing term and are not likely to change appreciably over time.
20 The following section addresses the site-specific environmental impacts of Turkey Point SLR on 21 one environmental issue related to visual resources.
22 2.3.1      Aesthetic Impacts 23 The visual impact of continued nuclear power plant operations at Turkey Point during the SLR 24 term would be SMALL, because the visual appearance of the nuclear power plant and 25 transmission lines would not change. In addition, the NRC staff did not identify any new 26 information that would alter this conclusion.
27 2.4    Air Quality 28 Ambient air quality conditions at Turkey Point and associated transmission lines have been well 29 established during the current licensing term. These conditions are expected to remain 30 unchanged during the SLR term. The following sections address the site-specific environmental 31 impacts of Turkey Point SLR on two environmental issues related to air quality.
32 2.4.1      Air Quality Impacts 33 The Clean Air Act of 1970, as amended (42 U.S.C. 7401 et seq.), Title V, Permits, requires 34 States to develop and implement an air pollution permit program (CAA 1970). The FDEP 35 regulates air emissions at Turkey Point under Title V air operation permits (FDEP 2020a, 2020b, 36 2023; FPL 2023a).
37 Combined Turkey Point Units 3, 4, and 5 are considered one facility for purposes of the 38 Prevention of Significant Deterioration permitting program and Title V operating permits.
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1 However, FPL operates these units under two separate Title V permits: one for fossil fuel Unit 5 2 (Permit 0250003-032-AV) (Unit 1, which has been retired, was deleted from the permit upon its 3 renewal in November 2018), and another for nuclear Units 3 and 4 (Permit 0250003-036-AV) 4 (FDEP 2020a, FDEP 2023).
5 The FDEP issued the previous permit, Title V Air Operation Permit 0250003-033-AV, for Turkey 6 Point Units 3 and 4 in May 2020; it was set to expire in 2023 (FDEP 2020b). In September 7 2022, FPL submitted an application to renew this air operation permit for 5 years. In March 8 2023, FDEP issued Air Operation Permit 0250003-036-AV for Units 3 and 4 (FDEP 2023).
9 A similar process is being used for fossil fuel Unit 5 (FDEP 2023; FPL 2023a).
10 The ambient air quality in the vicinity of Turkey Point is described in Section 3.3.2 of the FSEIS 11 (NRC 2019a). Table 2-3 presents updated annual emissions from permitted sources at Turkey 12 Point Units 3 and 4. Turkey Point employs five emergency diesel generators for use as a 13 backup power source to the nuclear power plant. These generators provide a standby source of 14 electric power for essential equipment required during an emergency. They also allow for safe 15 reactor shutdown and for the maintenance of safe conditions. Each generator is tested on a 16 staggered test schedule (e.g., once every refueling outage). Turkey Point also employs 17 emergency diesel generators supporting meteorological tower and fire pump operation. FPL 18 operates these diesel generators/engines at Turkey Point Units 3 and 4 only intermittently 19 (usually during testing or during outages).
20 Table 2-3 Estimated Air Pollutant Emissions (tons/year) from Turkey Point Units 3 and 4 Year            SOx              NOx              CO              PM10            VOCs 2017            1.39            14.2              1.82            1.64            0.71 2018            0.03            10.6              2.83            0.18              0.31 2019            0.03            11.1              2.97            0.18              0.33 2020            0.01            13.1              3.92            0.22              0.36 2021            0.04            10.0              2.70            0.17              0.32 21          CO = carbon monoxide; NOx = nitrogen oxides; SOx = sulfur dioxides; PM10 = particulate matter 22          less than 10 micrometers; VOC = volatile organic compounds.
23          To convert tons per year to metric tons per year, multiply by 0.90718.
24          Note: In 2018, FPL standardized the emissions calculations for its fleet. For Turkey Point, the 25          calculations were changed from being performance factor-based to being derived from standard 26          emission factors defined by the U.S. Environmental Protection Agency in Compilation of Air 27          Pollutant Emission Factors (AP-42).
28          Source: FPL 2023a.
29 According to the 2017 National Emissions Inventory, estimated annual emissions in tons per 30 year for Miami-Dade County are approximately 1,210 (sulfur dioxide), 33,800 (nitrogen dioxide),
31 256,000 (carbon monoxide), 28,200 (particulate matter less than 10 microns), and 83,400 32 (volatile organic compounds) (EPA 2023). Turkey Point Units 3 and 4 air emissions from 33 permitted sources make up 0.1 percent or less of Miami-Dade Countys total annual emissions.
34 SLR for Turkey Point Units 3 and 4 would continue current operating conditions and 35 environmental stressors rather than introducing wholly new impacts. Therefore, the impacts of 36 current operations and operations under SLR would be similar. Given Turkey Point Units 3 and 37 4s limited air emissions as presented in Table 2-3, there is little likelihood that a continuation of 38 ongoing activities at Turkey Point Units 3 and 4 during the SLR term would adversely affect air 39 quality and air quality-related values. Based on these considerations, the NRC staff concludes 2-8
 
1 that the air quality impacts of continued nuclear power plant operations at Turkey Point during 2 the SLR term would be SMALL. In addition, the NRC staff did not identify any new information 3 that would alter this conclusion.
4 2.4.2      Air Quality Effects of Transmission Lines 5 Small amounts of ozone and substantially smaller amounts of oxides of nitrogen are produced 6 during corona, a phenomenon that occurs when air ionizes near isolated irregularities on the 7 conductor surface of transmission lines. FPL has not conducted field tests of ozone and 8 nitrogen oxide emissions generated by Turkey Point transmission lines (FPL 2023a). However, 9 because transmission line emissions associated with corona discharge are typically so small 10 compared to those from other sources of air pollution (e.g., ozone precursors from automobiles, 11 power plants, and large industrial boilers), corona-related transmission line emissions are not a 12 regulated source of air pollution in the United States.
13 SLR would continue current operating conditions and environmental stressors rather than 14 introduce wholly new impacts. Therefore, the impacts of current operations and operations 15 during SLR would be similar. For these reasons, the effects of transmission lines on air quality 16 would be minor and would neither destabilize nor noticeably alter any important air quality 17 attribute during the SLR term. Based on these considerations, the NRC staff concludes that the 18 impacts of transmission lines on air quality during the Turkey Point SLR term would be SMALL.
19 In addition, the NRC staff did not identify any new information that would alter this conclusion.
20 2.5    Noise 21 Noise from nuclear power plant operations can often be detected offsite near the site boundary.
22 Major sources of noise include cooling towers, turbines, transformers, large pumps, firing range, 23 steam safety relief valves, and cooling water system motors. Ambient noise conditions near 24 Turkey Point have become well established during the current licensing term. These conditions 25 are expected to remain unchanged during the SLR term. The following section addresses the 26 site-specific environmental impacts of Turkey Point SLR on one environmental issue related to 27 noise.
28 2.5.1      Noise Impacts 29 The ambient noise conditions in the vicinity of Turkey Point are described in Section 3.3.3 of the 30 FSEIS (NRC 2019a). Nuclear power plant operations have not changed appreciably over time, 31 and no change in noise levels or noise-related impacts are expected during the SLR term.
32 Given the industrial nature of the nuclear power plant and the number of years of plant 33 operation, noise from a nuclear power plant is generally nothing more than a continuous minor 34 nuisance.
35 In the 1996 LR GEIS, the NRC noted that there have been few complaints about noise at 36 nuclear power plants, and that noise impacts have been found to be small (NRC 1996).
37 Because noise sources at nuclear power plants do not change appreciably during the aging 38 process, the 1996 LR GEIS concluded that noise was not expected to be a problem at any 39 nuclear power plant during the license renewal term and, given the few noise complaints 40 received, that no additional mitigation measures are warranted. The magnitude of noise impacts 41 was therefore determined to be SMALL for all nuclear power plants.
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1 In 2008, an ambient noise-monitoring survey was performed in areas adjacent to the Turkey 2 Point site (NRC 2014a). Measurements (equivalent sound intensity level) at monitoring locations 3 offsite and beyond the site boundary (including nearest residence, day-care facility, and a park) 4 ranged from 46 dBA to 67 dBA during the daytime and from 41 dBA to 56 dBA during the 5 nighttime. Audible noise sources contributing to noise levels included traffic, insects, and wind, 6 indicating that audible sound from the Turkey Point site does not reach these noise-sensitive 7 receptors.
8 Plant operations at Turkey Point during the SLR term would continue current operating 9 conditions and environmental stressors rather than introduce wholly new impacts. Therefore, 10 the impacts of current operations and SLR operations would be similar. Based on these 11 considerations, the NRC staff concludes that the noise impacts of continued nuclear power plant 12 operations at Turkey Point during the SLR term would be SMALL. In addition, the NRC staff did 13 not identify any new information that would alter this conclusion.
14 2.6    Geologic Environment 15 The following section addresses the site-specific environmental impacts of Turkey Point SLR on 16 one environmental issue related to the geologic environment.
17 2.6.1      Geology and Soils 18 The 2013 LR GEIS (NRC 2013a) indicated that the impact of continued plant operations and 19 any refurbishment associated with license renewal on geologic and soil resources would involve 20 soil and subsurface disturbance, such as sediment and/or any associated bedrock, related to 21 replacing or adding buildings, roads, parking lots, and below-grade and above-grade utility 22 structures, and subsequent soil erosion and impacts on surface water quality. The impacts of 23 natural phenomena, such as geologic hazards, on nuclear power plant systems, structures, and 24 components are outside the scope of the NRCs license renewal environmental review; they are 25 addressed in the reactor oversight process and in the staffs plant-specific severe accident 26 evaluation and safety review during license renewal.
27 FPL has not planned any refurbishment activities or construction of new facilities related to SLR 28 at Turkey Point (FPL 2018f). Land disturbance activities for continued nuclear power plant 29 operations at Turkey Point during the SLR term would be associated with routine infrastructure 30 maintenance, upgrade, renovation, or replacement as needed to support Turkey Point 31 operation.
32 FPL has internal procedures and plans (e.g., Administrative Procedure No. 0-ENV-0601, 33 stormwater pollution prevention plans [SWPPP], best management practices [BMPs], etc.) in 34 place to ensure compliance with existing comprehensive environmental regulations and permits.
35 These procedures and plans would minimize or prevent potential impacts (e.g., stormwater 36 induced erosion and sediment transport) from ground-disturbing activities during the SLR term 37 (FPL 2018b; FDEP 2022b).
38 In addition, conditions in the industrial wastewater (IWW)/National Pollutant Discharge 39 Elimination System (NPDES) permit for Turkey Point contain specific requirements for 40 implementing a BMP plan covering both industrial wastewater and stormwater. FPL is required 41 to inspect components of the Turkey Point cooling canal system (CCS) for changes that may 42 indicate a potential compromise of the impoundment integrity (FDEP 2022b). Soil disturbance 43 for CCS maintenance and sediment removal is conducted in accordance with FPL internal 2-10
 
1 procedures, the sediment removal maintenance support package, and a terrestrial vegetation 2 plan. These guidance documents minimize or prevent impacts on soils and near subsurface 3 geology in and around the CCS.
4 Based on these considerations, the NRC staff concludes that the impacts on soils and the 5 geologic environment due to continued nuclear power plant operations at Turkey Point during 6 the SLR term would be SMALL.
7 2.7      Surface Water Resources 8 The following sections address the site-specific environmental impacts of Turkey Point SLR on 9 four environmental issues related to surface water resources.
10 2.7.1      Surface Water Use and Quality (Non-Cooling System Impacts) 11 This section concerns surface water use and its potential degradation in quality due to 12 continued nuclear power plant operations at Turkey Point during the SLR term that are 13 unrelated to the operation of the Turkey Point cooling system. Activities associated with such 14 plant operations and refurbishment can result in a variety of pollutants (e.g., suspended 15 sediments, petroleum products including oil and other chemicals, paints, heavy metals, and 16 road salts) entering surface water bodies by way of, for instance, stormwater runoffs. These 17 pollutants could potentially degrade water quality, impair its designated uses, and cause harm to 18 aquatic terrestrial species (NRC 2013a). Water uses related to such plant operation and 19 refurbishment activities can include concrete production, dust control, washing stations, and 20 facility and equipment cleaning.
21 FPL does not use or have plans to access surface water for non-cooling purposes at Turkey 22 Point. The water source at Turkey Point for its systems other than the cooling water system is a 23 municipal supply (i.e., domestic water) (FPL 2018f, Section 2.2.3.1) and treated groundwater, 24 which is used for process water.
25 FPL does not anticipate any refurbishment activities or construction of new facilities at Turkey 26 Point during the SLR term. Land-disturbing activities for continued nuclear power plant 27 operations at Turkey Point during the SLR term would be limited to the routine maintenance, 28 upgrade, or replacement of infrastructure as needed. FPL has internal procedures and plans for 29 such construction activities, including stormwater permitting requirements and State-required 30 BMPs (e.g., SWPPPs), to minimize or prevent soil erosion and sediment transport (FPL 2018g, 31 RAI T-6).
32 Turkey Point effluents, except for treated wastewater, are routed to the closed-loop CCS. The 33 CCS is a permitted IWW facility (Permit No. FL0001562) and does not discharge through a point 34 source to surface waters of the state, although some CCS waters have infiltrated to the 35 underlying Biscayne Aquifer at the facility (FDEP 2016b). As required by permit conditions, FPL 36 institutes stormwater and IWW programs to prevent or minimize the generation and potential for 37 releases of pollutants from nuclear power plant operations via stormwater and the CCS.
38 Stormwater runoff collects in drainage channels and typically flows through a series of 39 stormwater catch basins before discharging to the CCS, while equipment and containment area 40 drains are routed to oil/water separators prior to being routed to the CCS (FPL 2018f, 41 Sections 2.2.3 and 3.6.1.4.2; 2022a). FPL assesses facility components and systems under the 42 IWW BMPs program for possible waste minimization and implements measures to reduce 2-11
 
1 waste loadings and chemical losses to wastewater and stormwater streams. FPL further 2 incorporates its findings of potential vulnerabilities in the components and systems into the 3 BMPs to effectively conduct inspection and maintenance of stormwater management devices.
4 FPL also implements a spill prevention, control, and countermeasure (SPCC) plan that 5 addresses storage, secondary containment, and inspections. No reportable spills occurred at 6 Turkey Point from 2012 to March 2022 (FPL 2022a).
7 FPL has not planned any refurbishment activities or construction of new facilities related to SLR 8 at Turkey Point. Land disturbance activities for continued nuclear power plant operations at 9 Turkey Point during the SLR term would be limited to the routine maintenance, upgrade, or 10 replacement of infrastructure as needed to support Turkey Point operation. FPL would follow its 11 internal procedures and plans related to construction activities, including stormwater permitting 12 requirements and the State-required BMPs (i.e., SWPPPs) to minimize or prevent soil erosion 13 and sediment transport (FPL 2018g, RAI T-6).
14 In 2010, FPL implemented surface water quality and environmental monitoring in the CCS and 15 area surrounding the nuclear power plant based on the monitoring network designed with State 16 and local input (i.e., FDEP, Miami-Dade County Department of Environmental Resources 17 Management, and the South Florida Water Management District). There have been no reported 18 violations related to surface water quality as a result of Turkey Point nuclear power plant 19 operation (FPL 2022a). In the 2019 FSEIS, the NRC staff identified a new issue: a nuclear 20 power plant with a cooling pond in a salt marsh may indirectly affect the water quality of 21 adjacent surface water bodies via a groundwater pathway (NRC 2019a). Because the CCS is 22 unlined, the water in it can and has interacted with the underlying shallow groundwater system.
23 The operation of the CCS has contributed to the degradation of groundwater quality beyond the 24 Turkey Point site boundaries, as discussed in the groundwater resources section of this EIS 25 (Section 2.8). However, based on a site-specific analysis of this issue, the NRC staff did not 26 identify any new information that would change the staffs FSEIS conclusion that the impacts on 27 adjacent surface water bodies via the groundwater pathway from the CCS during the Turkey 28 Point SLR term would be SMALL.
29 Based on its review of available information, the NRC staff understands that FPL does not use 30 or plan to use surface water for nuclear power plant operations at Turkey Point and would 31 obtain all necessary permits if such a need for surface water occurs during the SLR term. FPL 32 would continue to comply with the current IWW/NPDES and stormwater regulatory requirements 33 and permit conditions and implement the SWPPP, BMPs, and SPCC plan to minimize or 34 prevent impacts on surface water quality during the SLR term. FPL would also continue surface 35 water quality and environmental monitoring programs at the site. The NRC staff concludes that 36 the impacts on surface water use and quality would be SMALL for continued nuclear power 37 plant operations at Turkey Point during the SLR term.
38 2.7.2      Discharge of Metals in Cooling System Effluent 39 This section addresses potential leaching of heavy metals, such as copper, zinc, and chromium, 40 from condenser tubing and other components of the nuclear power plant heat exchange system 41 by circulating cooling water (NRC 2013a). Parts of the water distribution system infrastructure 42 and appurtenances, piping, linings, fixtures, and solders can react with water and potentially 43 release heavy metals to the distributed water. Permeation of plastic pipes and leaching from 44 linings and metal appurtenance are documented pathways for water quality degradation (EPA 45 2002). These dissolved metals are normally the subject of an NPDES permit because elevated 46 metal concentrations can become toxic to aquatic organisms. During normal nuclear power 2-12
 
1 plant operations, heavy metal concentrations are generally below laboratory detection levels.
2 However, elevated metal concentrations may occur after plants occasionally undergo planned 3 outages for refueling or unplanned maintenance, with stagnant water remaining in the heat 4 exchange system.
5 At Turkey Point, circulating cooling water is supplied from and discharged to a closed-loop CCS 6 that is a permitted IWW facility (Permit No. FL0001562). The CCS waters, with permitted 7 chemical additives used in the nuclear power plant system, are not allowed to discharge to non-8 CCS surface waters through a point source, although some CCS waters have infiltrated to the 9 underlying Biscayne Aquifer at the site (FPL 2000, FDEP 2016b). Corrosion inhibitors, which 10 are used to minimize system degradation, and release of metals to the CCS are among the 11 chemicals authorized by the Turkey Point IWW/NPDES permit (FPL 2022a). FPL is prohibited 12 from discharging waste resulting from the combustion of toxic, hazardous, or metal-cleaning 13 wastes to any waste stream that ultimately reaches the CCS.
14 Water pH can strongly affect metal mobility. The mean measured pH of the CCS was 8.24 from 15 June 2010 to December 2017, with a range from 7.78 to 8.72 based on the 10th and 90th 16 percentiles, respectively (FPL 2018h). The mean pH of the CCS has essentially remained 17 constant at 8.22 from June 2020 to March 2021 (FPL 2022a). These above-neutral pHs will limit 18 metal dissolution in the CCS waters at the site (Hoffland 2019) and in the circulating cooling 19 water system.
20 Based on its site-specific review, the NRC staff has determined that Turkey Point discharges 21 only to the closed CCS, a permitted IWW facility. The permit to operate that facility requires 22 CCS monitoring for copper, zinc, and other constituents. In addition, the use of corrosion 23 inhibitors as permitted, the maintenance of an above-neutral pH, and other BMPs to control 24 pollutants to the maximum extent practicable during continued operations of the nuclear power 25 plant will limit the dissolution and release of metals from the plants water distribution system 26 infrastructure and appurtenances and from other activities or events at the plant. The NRC staff 27 concludes that the impacts from the discharges of heavy metals in cooling system effluent due 28 to continued nuclear power plant operations at Turkey Point during the SLR term would be 29 SMALL.
30 2.7.3      Discharge of Biocides, Sanitary Wastes, and Minor Chemical Spills 31 This issue addresses concerns about biocides, sanitary wastes, and minor chemical spills 32 discharging to surface water bodies (NRC 2013a). The application of biocides and other water 33 treatment chemicals is common and necessary to control biofouling and nuisance organisms in 34 nuclear power plant cooling systems. The types of chemicals, concentrations, and frequency of 35 their use, however, are specific to each plant. Treated sanitary waste may be released via 36 onsite wastewater treatment facilities, a septic field, or through a connection to a municipal 37 sewage system. Minor chemical spills may be collected in floor drains. Each of these activities 38 or events has the potential to affect surface water quality.
39 FPL stated in ER Supplement 2 (FPL 2022a) that the Turkey Point cooling water and non-40 cooling water discharges are directed to the closed CCS under an IWW/NPDES permit (Permit 41 No. FL0001562), and treated domestic wastewater is permitted to be injected into an 42 underground geologic formation. The CCS is not directly connected to any surface water bodies 43 (FPL 2018f). The IWW/NPDES permit authorizes FPL to use specific biocides or, with FDEP 44 prior approval, other non-permitted biocides or chemical additives in the CCS or any other 45 portion of the IWW system (FDEP 2022b. The discharge of any waste resulting from the 2-13
 
1 combustion of toxic, hazardous, or metal-cleaning wastes directly or indirectly to the CCS is 2 prohibited under the IWW/NPDES permit. FPL discharges its sanitary wastewater to a septic 3 system under Florida Department of Health (FDOH) Permit No. AP998256 (FDOH 2022) and to 4 a subsurface injection well (Permit No. 0355186-001-UO/5W) after treatment (FDEP 2018b; 5 FPL 2018f [Section 2.2.3.1 in both permits]).
6 Effluents for all other systems, including stormwater runoff and equipment and containment area 7 drains, are routed to the closed-loop, unlined CCS under the conditions specified in the 8 IWW/NPDES permit. Stormwater runoff flows through a series of catch basins, while equipment 9 and containment area drain effluents are routed to oil/water separators prior to being discharged 10 to the CCS (FDEP 2022b, FPL 2018f [Sections 2.2.3 and 3.6.1.4.2, respectively]). Under 40 11 CFR Part 112, Oil Pollution Prevention, FPL implements an SPCC plan, including measures 12 such as containments, automatic spill and overfill detection systems, and an inspection 13 program, along with BMPs for storage and handling to prevent and control accidental spills.
14 There were no reported spills at Turkey Point during the period from 2012 to March 2022 (FPL 15 2022a).
16 In summary, Turkey Point discharges to the closed-loop CCS with no direct connection to any 17 surface water bodies under an IWW/NPDES permit. Certain specific biocides and chemicals 18 allowed to be used with approval by the FDEP are monitored and reported to ensure 19 compliance with the permit. Turkey Point discharges sanitary wastewater to a septic system and 20 to a permitted deep injection well after treatment.
21 Based on its site-specific review, the NRC staff concludes that the impacts from the discharge of 22 biocides, sanitary wastes, and minor chemical spills due to continued nuclear power plant 23 operations at Turkey Point during the SLR term would be SMALL 24 2.7.4      Effects of Dredging on Surface Water Quality 25 This issue concerns the effects on surface water quality of dredging deposited sediments in the 26 vicinity of surface intakes, canals, and discharge structures primarily to maintain the function of 27 the nuclear power plant cooling system. Dredging by mechanical, suction, or other methods 28 disturbs sediments, temporarily increases the turbidity of the water column, and may mobilize 29 heavy metals and other contaminants in the sediments, if present.
30 The 2013 LR GEIS (NRC 2013a) concluded that the effects of dredging on surface water quality 31 would be SMALL during the initial license renewal term. Below, the NRC staff analyzes this 32 issue on a site-specific basis for the Turkey Point SLR term.
33 FPL anticipates no dredging within the scope of this issue during the Turkey Point SLR term 34 (FPL 2022a). Therefore, there would be no related impacts on surface water quality. Because 35 the closed-loop CCS is not considered to be a water of the United States, but an IWW facility, 36 maintenance dredging activities within the CCS are outside the scope of this issue. However, if 37 FPL were to determine at a future date that dredging was necessary to, for instance, provide 38 adequate clearance for barge deliveries, such dredging would require FPL to obtain permits 39 from the USACE under CWA Section 404. BMPs and conditions associated with those permits 40 would minimize impacts on the environment. The process of granting such permits would also 41 require the USACE to conduct environmental reviews prior to FPL undertaking such dredging.
42 The NRC staff expects that the effects of dredging on surface water quality would be minor and 43 would neither destabilize nor noticeably alter any important attribute of surface water quality 2-14
 
1 during the SLR term. The NRC staff expects that FPL would continue to implement site 2 environmental procedures and would obtain any necessary permits for dredging activities, if 3 determined necessary. Implementation of such controls would further reduce or mitigate 4 potential effects on the environment. The NRC staff concludes that the effects of dredging on 5 surface water quality due to continued nuclear power plant operations at Turkey Point during the 6 SLR term would be SMALL.
7 2.8      Groundwater Resources 8 The following sections address the site-specific environmental impacts of Turkey Point SLR on 9 environmental issues related to groundwater resources.
10 2.8.1      Groundwater Contamination and Use (Non-Cooling System Impacts) 11 This section concerns the potential impacts on groundwater availability resulting from aquifer 12 dewatering during nuclear power plant operations and refurbishment. In addition, this section 13 concerns impacts on groundwater quality that may occur due to the contamination of soil and 14 groundwater during general industrial activities at the nuclear power plant, including the storage 15 and use of solvents, hydrocarbon fuels (diesel and gasoline), heavy metals, or other chemicals, 16 and operation of wastewater treatment/disposal ponds or lagoons. Materials that are released 17 from these activities all have the potential to affect soils, sediments, and groundwater. Such 18 contaminants that migrate into the subsurface environment can cause a long-term impact on 19 underlying groundwater resources depending on the type of contaminant, the quantity of the 20 release, and site hydrogeological conditions. Potential impacts due to groundwater withdrawals 21 to remediate the hypersaline groundwater plume in the Biscayne Aquifer are presented in 22 Section 2.8.2.
23 As stated above, FPL has not planned any refurbishment activities or construction of new 24 facilities related to SLR at Turkey Point (FPL 2018a) and, therefore, no dewatering activities 25 would be needed with respect to refurbishment or construction during the SLR term.
26 Additionally, apart from groundwater withdrawals to remediate the hypersaline groundwater 27 plume in the Biscayne Aquifer, discussed in 2.8.2, there are no dewatering activities associated 28 with nuclear power plant operations and none are anticipated during the SLR term. In 29 accordance with the Conditions of Certification and Florida Administrative Code Rule 62-30 621.300(2), FPL is required to submit a detailed plan for any future dewatering activities at 31 Turkey Point for review and approval by other authorities.
32 FPL operates five groundwater withdrawal systems at Turkey Point to support plant operation, 33 including (1) CCS freshening wells that withdraw brackish water from the Upper Floridan Aquifer 34 (UFA), (2) Biscayne Aquifer marine wells that withdraw salt water to supplement CCS 35 freshening, (3) several Unit 5 production wells that withdraw brackish water from the UFA to 36 support operations of Turkey Point Unit 5, (4) Recovery Well System (RWS) wells that withdraw 37 saltwater from the Biscayne Aquifer for control of the CCS hypersaline groundwater plume, and 38 (5) Underground Injection Control (UIC) test extraction wells that are also used for hypersaline 39 plume withdrawals. FPL operates all groundwater withdrawal systems in accordance with 40 required permits issued by the State and the water management district. The impacts of 41 withdrawals on water use and groundwater quality were evaluated by FPL to comport with State 42 and district water use rules and criteria prior to water permit issuance (FPL 2018f; SFWMD 43 2017).
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1 Groundwater use conflicts arising from Biscayne Aquifer and UFA withdrawals were evaluated 2 in Section 4.5.1.2 of the FSEIS under the Category 2 issue, Groundwater use conflicts (plants 3 that withdraw more than 100 gallons per minute). New information regarding groundwater use 4 conflicts is evaluated in Section 2.8.2 of this EIS.
5 The potential effects of groundwater withdrawals on groundwater quality were evaluated 6 generically in the FSEIS under the Category 1 issue, Groundwater quality degradation resulting 7 from water withdrawals; those impacts are evaluated on a site-specific basis in Section 2.8.2 of 8 this EIS.
9 FPL operates one onsite Class V, Group 3 gravity injection well, and one Class I injection well 10 system located approximately 1.1 miles southwest of the nuclear power plant. The onsite gravity 11 injection well is used to dispose of up to 35,000 gpd of treated domestic sanitary wastewater 12 into the Biscayne Aquifer. The Class I injection well system is used to dispose of hypersaline 13 groundwater extracted by the RWS into a deep, confined formation in the aquifer (referred to as 14 the Boulder Zone). As required, FPL monitors discharge volume and permit-specified water 15 quality parameters in both injection systems and is in compliance with permit conditions (FDEP 16 2018a, FDEP 2018b; 2019, 2019a).
17 Turkey Point industrial activities involving the use of chemicals include painting, cleaning parts 18 and equipment, storage and refueling onsite vehicles/generators (with fuel oil and gasoline), and 19 storage and use of water treatment additives. Site-specific programs are in place to address 20 accidental spills or releases of chemicals to the environment, including FPLs chemical control 21 procedure and SPCC plan, which addresses storage, secondary containment, and inspections.
22 As described in the Turkey Point SPCC plan, all aboveground storage tanks at the site are 23 equipped with secondary containment and, as appropriate, automatic spill and overfill detection 24 systems. In addition, FPL implements BMPs for storage and handling of containers containing 25 less than 55 gallons of petroleum products. FPL also implements waste management programs 26 to oversee its storage and handling of waste streams (FPL 2018f Section 4.11). There were no 27 reportable spills or releases at the plant during the period from 2012 to December 2022 (FPL 28 2018e, FPL 2018g, FPL 2023a).
29 Based on its site-specific analyses, the NRC staff concludes that there are no groundwater 30 dewatering activities in use for the operation of the nuclear power plant and none are 31 anticipated during the SLR term, beyond those associated with groundwater withdrawals to 32 remediate the hypersaline groundwater plume in the Biscayne Aquifer, discussed in 33 Section 2.8.2 of this EIS. The current environmental programs, including water withdrawal and 34 injection permits, IWW/NPDES permits, and stormwater management, are in compliance with 35 regulatory requirements and programs at Turkey Point and are expected to continue to be in 36 compliance during the SLR term. The NRC staff concludes that the environmental impacts on 37 groundwater use and quality from non-cooling systems due to continued nuclear power plant 38 operations at Turkey Point during the SLR term would be SMALL.
39 2.8.2      Groundwater Use Conflicts and Groundwater Quality Degradation Resulting 40            from Water Withdrawals 41 This section addresses the potential for groundwater use conflicts and any related groundwater 42 quality degradation as a result of inducing water of potentially lower quality to flow into an 43 aquifer during groundwater withdrawals. In a coastal setting (e.g., ocean shore or estuary),
44 saltwater intrusion into an aquifer is an additional consideration. The magnitude of groundwater 45 use conflicts and the degree of water quality degradation or saltwater intrusion depends on well 2-16
 
1 locations, screen depths, pumping rates, and other site-specific hydrogeologic conditions (NRC 2 2013a). Additionally, this section addresses new information regarding groundwater use.
3 The aquifers underlying the Turkey Point site are the Biscayne Aquifer and the Upper and 4 Lower Floridan Aquifers. The Biscayne and Lower Floridan Aquifers in the area of the Turkey 5 Point site are classified as G-III nonpotable water use and contain hypersaline water and 6 saltwater, respectively. Saltwater intrusion in the Biscayne Aquifer underneath and west of the 7 Turkey Point site has been documented over 4 mi (6.4 km) inland prior to the construction of the 8 CCS (FPL 2022a). The UFA contains brackish water and is classified as G-II potable water use.
9 Turkey Point nuclear power plant operations use five sets of groundwater withdrawal wells as 10 summarized in Table 2-4.
11 Table 2-4      Turkey Point Groundwater Withdrawal Wells Number of                                                          Withdrawal Well Type        Permit #        Wells          Identifiers      Aquifer        Purpose            Limit Freshening    PA03-45                7        F1 through F7 Upper              F1/Flex Well:    10,950 MGY wells                                                            Floridan        Primary:        with a (brackish)      Provide          maximum makeup          monthly water to the    withdrawal of Condensate      1,033.6 MG Storage Tank    (permit limit)
F1 alternate and F2-F7 primary: CCS freshening Recovery well 13-06251-W              10        RW-1            Biscayne        Hypersaline      5,475 MG system                                          through RW-    (hyper-          groundwater      Annually, 10              saline)          removal          15 MGD 465 MG monthly (permit limit)
Unit 5        PA03-45                3        PW-1,          Upper            Turkey Point    14.06 MGD production                                      PW-3, and      Floridan        process          (permit limit) wells                                            PW-4            (brackish)      water and Unit 5 cooling with blowdown to the CCS UIC test      No                      4        UICPW-1,        Biscayne        Extraction for 3.5 MGD extraction    consumptive    (2 active, 2      UICPW-2,        (hyper-          groundwater (based on wells          use permit      capped and        UICPW-3,        saline)          remediation      the UIC rated required        on standby)      and                                              capacity of UICPW-4                                          18.64 MGD) 12 CCS = cooling canal system; MG = million gallons; MGD = million gallons per day; MGY = million gallons per year; 13 PW = permitted well; RW = recovery well; UIC = Underground Injection Control.
14 Source: FPL 2022a 15 2.8.2.1    Biscayne Aquifer 16 The marine wells, the RWS, and UIC test extractions wells all withdraw water from the Biscayne 17 Aquifer. The marine wells, located on the Turkey Point peninsula, withdraw water that has 2-17
 
1 chloride concentrations greater than 19,000 mg/L (i.e., saline or saltwater and, therefore, do not 2 require a consumptive use permit from the South Florida Water Management District (SFWMD; 3 FPL 2022a). FPL stated that the marine wells are used only under extraordinary 4 circumstances or upset recovery conditions to manage salinity in the CCS. No withdrawals 5 were made from the marine wells during the years 2019 to 2021 (FPL 2022a). As discussed in 6 the FSEIS, the periodic use of the marine wells is not expected to have a substantial impact on 7 groundwater quality.
8 The RWS is required as part of both the 2015 Miami-Dade County Consent Agreement (MDC 9 2015) and the 2016 FDEP Consent Order (FDEP 2016b). It includes 10 groundwater recovery 10 wells to remediate the hypersaline groundwater plume in the Biscayne Aquifer. The RWS has 11 operated since May 2018 under a consumptive use permit (13-06251-W) issued by the SFWMD 12 (SFWMD 2017). In the FSEIS, the NRC staff reviewed the groundwater modeling that was used 13 to support the 13-06251-W permit application, as part of the staffs evaluation of the Category 1 14 issue, Groundwater Quality Degradation (Plants with Cooling Ponds in Salt Marshes), and the 15 Category 2 issue, Groundwater Use Conflicts (Plants That Withdraw More Than 100 Gallons 16 per Minute) (NRC 2019a, Section 4.5.1.2). The NRC staff incorporates herein by reference the 17 information and analyses presented in Section 4.5.1.2 of the FSEIS for these two issues.
18 In the FSEIS, the NRC staff concluded that operation of the RWS would not result in any 19 interference with existing permitted uses of groundwater and would not affect natural resources, 20 based on the continued regulatory oversight by other authorities and enforcement of the terms 21 of the 2015 Miami-Dade County Consent Agreement and the 2016 FDEP Consent Order.
22 Accordingly, the staff concluded that groundwater use conflicts from RWS and marine well 23 operations would be SMALL for the Biscayne Aquifer and that the impacts on groundwater 24 quality would also be SMALL. In this EIS, the NRC staff considered additional information that 25 was not available when the FSEIS was published, concerning two extraction wells that became 26 operational following the staffs issuance of the FSEIS.
27 Specifically, in early 2020, two existing UIC test extraction wells (UICPW-1 and UICPW-2) were 28 activated with a combined rate of up to 3.5 MGD, to remove hypersaline groundwater from 29 beneath the CCS. The UIC test extraction wells were drilled to the base of the Biscayne Aquifer 30 (a surficial aquifer extending from land surface to approximately 140 ft deep at the Turkey Point 31 site) and were constructed in a similar manner as the recovery wells. The UIC test extraction 32 wells are colocated with the deep injection well used for disposal of extracted hypersaline water 33 (Permit No. 0293962-004-UO/MM). The deep injection well discharges to the Boulder Zone 34 aquifer (about 3,000 ft below land surface). The rated capacity of the deep injection well was 35 increased to 18.6 MGD to account for UIC test extraction withdrawals. As discussed in Section 36 4.5.3 of the FSEIS, the NRC staff concluded in the final EIS for the Turkey Point Units 6 and 7 37 combined licenses (NUREG-2176) (NRC 2016) that groundwater quality impacts from deep well 38 injection into the Boulder Zone would be SMALL. The NRC staff incorporates those findings into 39 this EIS by reference.
40 Like the marine wells, the UIC test extraction wells withdraw water that has chloride 41 concentrations greater than 19,000 mg/L (i.e., saline or saltwater) and, therefore, do not require 42 a consumptive use permit (FPL 2022a). Because the UIC test extraction wells remove 43 hypersaline groundwater as part of an approved groundwater remediation program, the NRC 44 staff concludes that their use would not degrade groundwater quality.
45 The FSEIS also concluded that the potential for groundwater use conflicts in the Biscayne 46 Aquifer from FPLs groundwater withdrawals would be SMALL. This conclusion accounted for 2-18
 
1 the use of the permitted RWS wells, as well as the emergency use of the marine wells, but did 2 not consider the UIC test extraction wells that were activated following the issuance of the 3 FSEIS. In this EIS, the NRC staff considers new information concerning the environmental 4 impacts of the UIC test extraction wells. The UIC test extraction wells are located approximately 5 1 mile east of the RWS-4 well (see Figure 2-1) and their withdrawals (3.5 MGD) represent an 6 increase in extraction of approximately 25 percent above the existing 15 MGD allocation 7 approved for the RWS. There are no registered water wells within a 2-mile band around the FPL 8 site boundary (FPL 2018f); therefore, the NRC staff does not expect any substantial 9 groundwater use conflict to result from the additional UIC test extraction well withdrawals.
10 11 Figure 2-1    Compliance Area, RWS and Monitoring Wells West and North of the CCS 12                (Source: FPL 2022d) 2-19
 
1 This determination is consistent with the updated groundwater modeling predictions (which 2 include RWS and UIC test extraction well pumping rates of 15 and 3 MGD, respectively) 3 presented in Appendix I of ER Supplement 2 (FPL 2022a). This modeling predicts that the 0.1 ft 4 drawdown contour within the Biscayne Aquifer extends approximately 1.5 miles west of the CCS 5 in year 5 of the remediation period, and this contour does not intersect with any offsite water 6 supply wells completed in the Biscayne Aquifer.
7 Based on the above evaluation, the NRC staff concludes that both the potential for groundwater 8 use conflicts and the potential for groundwater quality degradation from FPLs groundwater 9 withdrawals during the SLR term, would be SMALL for the Biscayne Aquifer.
10 2.8.2.2    Upper Floridan Aquifer 11 The existing Turkey Point Unit 5 production well system and the freshening well system 12 withdraw water from the UFA. The 14 MGD (daily average) withdrawals from the UFA for CCS 13 freshening were initially authorized in 2016 by Turkey Point Site Certification PA03-45E (FDEP 14 2016a). Although FPL initially believed that the freshening actions that it had taken were 15 effective in moderating CCS salinity, it later determined that additional freshening was needed 16 to replace evaporative losses during drought periods and to achieve and maintain an average 17 annual salinity at or below 34 practical salinity units (psu), as required by the 2016 FDEP 18 Consent Order. Therefore, FPL filed an application to modify Turkey Point Site Certification 19 PA03-45E in October 2020 to add an additional freshening well (F-7) (see Figure 2-2) and to 20 increase the daily average UFA withdrawal for CCS freshening by an additional 16 MGD (FPL 21 2020a). This additional allocation was not evaluated by the NRC staff in the FSEIS and 22 represents new information that is considered in this section of the site-specific EIS. FPL did not 23 request any changes to the Turkey Point Site Certification for the Unit 5 production well system.
24 In support of its request to modify Turkey Point Site Certification PA03-45E, FPL used the East 25 Coast Floridan Aquifer System Model - Phase 2 (ECFAS2) to evaluate potential aquifer 26 drawdown and impacts on other groundwater users from the proposed groundwater use. This 27 same modeling approach was used by FPL to evaluate drawdown in the UFA in support of 28 withdrawals for CCS freshening, as described in the FSEIS. The model, which was originally 29 developed for SFWMD water use permitting, was revised by FPLs contractor for site-specific 30 conditions and recalibrated using two site-specific aquifer performance tests (FPL 2020a). The 31 resulting calibrated groundwater model was used to assess the impact and cumulative impact 32 from the proposed 16 MGD freshening withdrawal combined with all other existing authorized 33 UFA allocations. The NRC staff reviewed the related modeling report included in FPLs Turkey 34 Point Clean Energy Center Power Plant Site Certification No. PA 03-45 Petition for Modification 35 F (FPL 2020a). The report indicates that the extent of drawdown resulting from the additional 16 36 MGD of average daily use, as defined by the 1 ft drawdown contour, encompasses six non-FPL 37 existing legal UFA users.
38 The maximum predicted additional drawdown for non-FPL offsite wells is 2.94 ft for the 39 proposed withdrawal. This prediction is for the North Largo Utilities wellfield, which is located 40 approximately 9.2 miles southeast of recovery well F-3. The modeling report also predicts 41 approximately 19 feet of additional drawdown to occur on the Turkey Point site at CCS salinity 42 reduction well F-3. Given that there are hundreds of feet of developable head in the UFA, the 43 NRC staff concludes that the proposed allocation of 16 MGD freshening withdrawal combined 44 with all other existing authorized UFA allocations will not interfere with existing legal users 45 ability to pump water at their permitted rates.
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1 2                Figure 2-2    FPL Freshening Well Locations (Source: FPL 2020a) 3 Further, the modeling results indicate that operation of the FPL freshening well system is 4 unlikely to result in changes to vertical and lateral flows sufficient to change regional water 5 quality. Local changes in water quality, however, may occur over time due to upconing of 6 deeper saline water due to individual and cumulative UFA withdrawals, as documented by 7 SFWMD modeling (SFWMD 2018). However, such changes are expected to be minor and are 8 not expected to be exacerbated by the proposed increase in UFA freshening withdrawals (FPL 9 2020a). Moreover, although the UFA is designated as an underground source of drinking water, 10 it is too saline to be used for drinking water without treatment (NRC 2019a).
11 Turkey Point Site Certification PA03-45F was issued by the FDEP on October 19, 2021, 12 increasing the UFA annual allocation for freshening to 10,950 million gallons (average rate of 13 30 MGD) with a maximum monthly allocation of 1,033.6 million gallons (FDEP 2021).
14 In accordance with the modified site certification and associated Conditions of Certification for 15 the Turkey Point site (FDEP 2021), FPL is required to mitigate harm to offsite groundwater 2-21
 
1 users (either related to water quantity or quality) as well as to offsite water bodies, land uses, 2 and other beneficial uses. As necessary, the SFWMD can order FPL to reduce withdrawals or 3 undertake other mitigative actions (FDEP 2021).
4 FPL performs ongoing monitoring and reporting on multiple aspects of its water use. This 5 includes reporting water use via a SFWMD-approved accounting system to ensure that FPLs 6 use is within its permitted allocation. Additionally, monitoring is required to ensure that water 7 quality is appropriate for its intended use (e.g., freshening), that water use is having the 8 anticipated impact (e.g., reducing and moderating salinity within the CCS), and that water use is 9 not harming existing legal uses, natural resources, and offsite land uses (FDEP 2022b; SFWMD 10 2017).
11 Based on the above evaluation of FPLs groundwater withdrawals during the SLR term, the 12 NRC staff concludes that the potential for groundwater use conflicts would be MODERATE and 13 the potential for groundwater quality degradation would be SMALL for the UFA.
14 2.8.3      Groundwater Quality Degradation (Plants with Cooling Ponds in Salt Marshes) 15 The issue of groundwater quality degradation (for plants with cooling ponds in salt marshes) 16 was evaluated as a generic Category 1 issue in Section 4.5.1.2 of the FSEIS. In addition, in 17 Section 4.5.1.2 of the FSEIS (NRC 2019a), the NRC staff considered any new and potentially 18 significant information that might have warranted reconsideration of the LR GEIS generic 19 finding. In this section of the current EIS, the staff evaluates this issue on a site-specific basis.
20 This issue considers the situation in which groundwater quality and potential beneficial use may 21 become degraded as a result of the migration of contaminants discharged to cooling ponds or 22 similar impoundments from the plants cooling water system. The concentration of dissolved 23 chemicals, including those naturally occurring in the effluent, increases relative to that of the 24 concentration of chemicals in the makeup water as water passes through the plants cooling 25 system. These increases include total dissolved solids (TDS) primarily due to water losses to 26 evaporation, heavy metals released from the cooling system components, and chemical 27 additives introduced to prevent biofouling.
28 Because cooling ponds or impoundments are generally unlined, the water in them can 29 hydraulically interact with underlying shallow groundwater systems and may create a 30 groundwater mound with water originating from the cooling ponds or impoundments. In coastal 31 regions, including salt marshes, the groundwater is already limited in its use because it is 32 naturally brackish (e.g., it has a TDS level of above 1,000 milligrams per liter [mg/L]).
33 The FSEIS discusses this issue in detail. As described in the FSEIS (NRC 2019a), the plants 34 CCS has no direct intake or discharge to any surface water, including that of Biscayne Bay. The 35 CCS is sustained by precipitation falling directly on the CCS, groundwater inflow from the 36 Biscayne Aquifer, and inputs from the freshening wells. As the FSEIS further explains, the 37 Biscayne Aquifer is classified as both Class G-III (nonpotable use, with TDS levels of 38 10,000 mg/L or greater) beneath the Turkey Point site and CCS, and Class-II (potable) to the 39 west of the CCS. Seawater intrusion in the Biscayne Aquifer had progressed inland westward 40 beyond the Turkey Point site prior to construction of the CCS in the 1970s. West of the saltwater 41 interface inland is a major well field where the Biscayne Aquifer serves as the major public 42 water supply source for the region, including Miami-Dade County and the Florida Keys.
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1 As discussed in the FSEIS, CCS salinity increased gradually over time from approximately 2 34 psu in the early 1970s (about equal to that of the nearby Biscayne Bay) to a maximum salinity 3 of about 90 psu in portions of 2014 and 2015 (NRC 2019a). A hypersaline plume developed in 4 the Biscayne Aquifer beneath the CCS and moved vertically downward in the aquifer and then 5 migrated laterally beyond the CCS boundaries. The operation of the CCS contributed to the 6 degradation of groundwater quality beyond the CCS structure and Turkey Point site boundaries, 7 and the affected water migrates to the west toward areas where groundwater within the Biscayne 8 Aquifer is of sufficient quality to serve as a potable water supply (NRC 2019a).
9 In the FSEIS, the NRC staff also discussed various regulatory and enforcement initiatives 10 pursued by local and State governmental authorities, including the 2015 Miami-Dade County 11 Consent Agreement, the 2016 FDEP Consent Order, and the SFWMD Supplemental 12 Agreement. In its ER Supplement 2, FPL indicates that in accordance with these requirements 13 and the consolidated conditions documented in the updated Conditions of Certification report 14 (FDEP 2022a), it continues to adhere to applicable State and local governmental requirements.
15 These include maintaining the CCS salinity and nutrient management program, recovering 16 hypersaline groundwater from the Biscayne Aquifer, and conducting specified monitoring 17 programs (FPL 2022a). The CCS salinity and nutrient management programs include adding 18 lower salinity groundwater pumped from the UFA to the CCS, improving CCS thermal efficiency, 19 and vegetation management.
20 2.8.3.1    Salinity and Nutrient Management Program 21 A critical part of the CCS salinity reduction measures involves the use of water from the UFA.
22 An increase of the UFA allocation from 5,110 to 10,950 million gallons per year (average rate of 23 30 million gallons per day) with a maximum monthly allocation of 1,033.6 million gallons was 24 granted for Turkey Point in October 2021.
25 FPL conducts extensive vegetation management on CCS berms to reduce nutrient inputs to the 26 CCS and uses berm sediment BMPs to prevent nutrients in berm sediment from entering the 27 cooling canals. Additionally, nutrients are removed from the CCS by implementing a nutrient-28 rich foam capture and effluent disposal system. Nutrients are sequestered naturally by 29 approximately 7 ac of planted seagrass. Nutrients, including ammonia and phosphorus, are 30 monitored in the groundwater around the CCS. Concentrations of ammonia tend to fluctuate 31 relative to other parameters; the highest levels were observed in proximity to the RWS wells in 32 March 2022. Total phosphorous levels that were found recently were in a range that is similar to 33 that observed in the shallow Biscayne Aquifer (FPL 2022b).
34 The annual average salinity of the CCS has decreased from the high of 82.5 psu observed from 35 June 2014 through May 2015 to 39.2 psu during June 2020 through May 2021 (EEI 2016 a; FPL 36 2021a). Figure 2-3 presents a time series of the salinity (average of all stations) in the CCS over 37 the past 7 years (2015-2022) and illustrates a declining trend during that period. The first full 38 year of freshening activities began in 2017. The annual average salinity for the June 1, 2021, to 39 May 31, 2022, reporting period was 36.1 psu, which is the lowest annual average value since 40 1977 (FPL 2022c). This annual average of salinity in the CCS is near the daily average salinity 41 observed in Biscayne Bay east and south of Turkey Point, which has fluctuated from a low of 42 12.3 psu to a high of 47.5 psu since bay monitoring adjacent to Turkey Point began in 2010 43 (FPL 2022a). FPL attributes the reduced salinity to freshening activities via water additions from 44 UFA pumping as well as above-average rainfall (approximately 20 percent higher) for the 45 reporting period (FPL 2022b, FPL 2022d). The amount of freshening water added to the CCS 46 during the 2021-2022 reporting period was less than half of the authorized UFA allocation (FPL 47 2022d).
2-23
 
1 2                  Figure 2-3    CCS Salinity Time Series (Source: FPL 2022b) 3 As discussed in the FSEIS, the 2016 FDEP Confirmatory Order requires FPL to achieve an 4 average annual CCS salinity of 34 psu or less. The CCS salinity data indicate that significant 5 progress has been made toward achieving the 34 psu objective. Based on the available data, 6 the NRC staff concludes that CCS operation during the SLR term is unlikely to result in 7 substantial contributions to the hypersaline groundwater plume, if freshening activities and CCS 8 salinity are maintained at their current levels.
9 2.8.3.2    Recovery of Hypersaline Groundwater from the Biscayne Aquifer and Monitoring 10 The RWS, including 10 groundwater recovery wells, has operated since May 2018 (FPL 2022d).
11 In February 2020, FPL initiated operation of two UIC test extraction wells to remove hypersaline 12 groundwater from the Biscayne Aquifer beneath the CCS (FPL 2022a). A total of approximately 13 23 billion gallons of hypersaline groundwater and more than 9 billion pounds of salt have been 14 extracted from the Biscayne Aquifer since RWS operations began (FPL 2022d).
15 The results of FPLs 2022 continuous surface electromagnetic mapping (CSEM) survey indicate 16 that the volume of hypersaline water in the 2016 FDEP Consent Order compliance area (see 17 Figure 2-1) has been reduced by 67 percent since remediation began in 2018 (FPL 2022d).
18 The 2015 Miami-Dade County Consent Agreement and the 2016 FDEP Consent Order define 19 hypersaline groundwater as groundwater with a chloride concentration greater than 20 19,000 milligrams per liter (mg/L). Figure 2-4 through Figure 2-6 show comparative positions of 21 the 19,000 mg/L chloride contour for the 2018 baseline conditions and 2022 conditions, for the 22 shallow, middle, and deep monitoring well horizons. Chloride contour maps were generated, 23 using monitoring well analytical data augmented with CSEM data (FPL 2022d). These figures 24 indicate that the hypersaline interface is being retracted closer to the CCS boundary for all three 25 depth horizons. FPL states (FPL 2022d) that there is some uncertainty in these chloride 26 concentration estimates in some areas due to spatial distances between the monitoring wells, 27 differing depths of well screens, discrepancies between the CSEM and laboratory analytical 28 results, and the hydraulic continuity of the aquifer, among other factors.
29 As discussed above, FPL continues to implement various programs to address the salinity and 30 nutrients in the CCS and hypersaline groundwater in the Biscayne Aquifer. The recent 31 monitoring data show that progress has been made in resolving these issues, including a 32 substantial decrease in CCS salinity, recovery of hypersaline groundwater, and halting the 33 westward advance of the saltwater interface in the Biscayne Aquifer.
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1 The goal of the RWS is to retract the hypersaline groundwater to within the FPL site boundary.
2 Initial modeling of the RWS, discussed in Section 4.5.1.2 of the FSEIS (NRC 2019a), had 3 indicated that the hypersaline groundwater plume would be retracted to within the CCS 4 boundary prior to the start of the SLR term (i.e., by about 2028). However, new information 5 about the performance of the RWS obtained since the FSEIS was prepared indicates that while 6 the RWS has been successful in retracting the hypersaline plume, it has not been as successful 7 as originally forecasted.
8 9 Figure 2-4      Comparison of the 2018 and 2022 Inland Extent of Hypersaline Groundwater 10                (19,000 mg/L Chloride Isochlor) in the Shallow Horizon (Source: FPL 2022d) 11 2-25
 
1 2 Figure 2-5 Comparison of the 2018 and 2022 Inland Extent of Hypersaline Groundwater 3            (19,000 mg/L Chloride Isochlor) in the Middle Horizon (Source: FPL 2022d) 4 2-26
 
1 2 Figure 2-6    Comparison of the 2018 and 2022 Inland Extent of Hypersaline Groundwater 3                (19,000 mg/L Chloride Isochlor) in the Deep Horizon (Source: FPL 2022d) 4 Specifically, FPL updated its variable density flow and salt transport model, which now includes 5 17 layers (FPL 2022d). This update was informed by data collected during operation of the 6 RWS. The updated modeling indicates that within 10 years of commencing operation of the 7 RWS (i.e., by year 2028) the RWS will fully retract the hypersaline plume interface in the upper 8 two-thirds of the Biscayne Aquifer to within the FPL site boundary (see Figure 2-7 and 9 Figure 2-8). However, as presented in Figure 2-9, the modeling predicts that in the lower 10 portions of the aquifer, some retraction of the hypersaline plume interface will occur in the 11 northern areas, but the westward expansion will only slow or halt after 10 years of RWS 12 operation (FPL 2022d). This updated modeling, along with recent data (see Figure 2-6),
13 suggests that the hypersaline plume will persist, to some extent, in the lower portions of the 14 Biscayne Aquifer outside the FPL site boundary prior to the SLR period.
2-27
 
1 2 Figure 2-7 Location of the Initial, Year 5, and Year 10 Hypersaline Interface in Model 3            Layer 4 (Source: FPL 2022d) 2-28
 
1 2 Figure 2-8 Location of the Initial, Year 5, and Year 10 Hypersaline Interface in Model 3            Layer 9 (Source: FPL 2022d) 4 2-29
 
1 2 Figure 2-9    Location of the Initial, Year 5, and Year 10 Hypersaline Interface in Model 3                Layer 16 (Source: FPL 2022d) 4 As shown in Figure 2-4, based on 2022 CSEM and groundwater monitoring well data, the 5 hypersaline groundwater plume in the shallow zone has almost been fully retracted to within the 6 FPL site boundary, while Figure 2-6 indicates that hypersaline groundwater plume in the deep 7 zone extends approximately 0.5 to 1.5 miles west of the L-31E canal. The NRC staff notes, 8 however, that the updated modeling tends to underestimate the extent of the hypersaline 9 interface in the shallow layers and overestimate its extent in deeper layers, relative to the CSEM 10 and groundwater monitoring well data (FPL 2022d).
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1 As discussed in the FSEIS, there are no registered groundwater supply wells within a 2-mile 2 band of the FPL site boundary (FPL 2018f). Relative to the Turkey Point site, the nearest 3 mapped water supply wells are located about 5 miles west of the western boundary of the CCS 4 and are used to support mining operations (FDOH 2023). The nearest public water supply wells 5 are located about 6 miles from the northwest corner of the CCS and approximately 7 miles from 6 the center of the Turkey Point plant complex (FDOH 2023, MDC 2006, NRC 2016).
7 Based on the results obtained to date, it is likely that, with continued freshening of the CCS and 8 continued operation of the RWS to halt and retract the westward migration of that plume, the 9 operation of Turkey Point Units 3 and 4 during the SLR term would not worsen the hypersaline 10 groundwater plume outside the plant boundary, would not destabilize the groundwater resource, 11 and would not adversely affect the beneficial uses of groundwater offsite by existing users. The 12 NRC staff notes, however, that FPL has not presented predictive modeling results that extend to 13 either the start or the expiration of the SLR term, which precludes the staff from reaching a 14 definitive conclusion about the likely extent of hypersaline plume retraction during the SLR term.
15 At the same time, the NRC staff notes that the SLR term would not commence until 2032 and 16 2033 for Turkey Point Units 3 and 4, respectively; therefore, a substantial period of time exists 17 to allow the ongoing (or potentially revised) groundwater remediation activities to improve 18 groundwater quality prior to the start of the SLR term.
19 In sum, if FPL can retract and maintain the hypersaline plume to within the FPL site boundary 20 prior to the SLR term, the impacts on groundwater quality from the CCS operations during the 21 SLR term would be SMALL. However, because some uncertainty exists about whether FPL will 22 be able to retract the hypersaline groundwater plume to within the FPL site boundary prior to the 23 SLR term, the impact could be MODERATE. Accordingly, the staff concludes that, depending 24 on FPLs success in retracting the hypersaline plume, the impacts on groundwater quality from 25 the CCS operations during the SLR term would be SMALL to MODERATE.
26 2.9    Terrestrial Resources 27 The following sections address the site-specific environmental impacts of Turkey Point SLR on 28 five environmental issues related to terrestrial resources.
29 2.9.1      Exposure of Terrestrial Organisms to Radionuclides 30 This issue concerns the potential impacts on terrestrial organisms caused by exposure to 31 radionuclides related to routine radiological effluent releases. In the following discussion, the 32 NRC staff summarizes the manner in which this issue has been addressed historically, and then 33 presents a site-specific evaluation of the issue for Turkey Point SLR.
34 Radionuclides may be released from nuclear power plants into the environment through several 35 pathways. During normal operations, nuclear power plants can release gaseous emissions that 36 deposit small amounts of radioactive particulates in the surrounding environment. Gaseous 37 emissions typically include krypton, xenon, and argon (which may or may not be radioactive),
38 tritium, isotopes of iodine, and cesium. Emissions may also include strontium, cobalt, and 39 chromium. Radionuclides may also be released into water as liquid effluent. Terrestrial plants 40 can absorb through their roots radionuclides that enter shallow groundwater or surface waters.
41 Animals may experience exposure to ionizing radiation through direct contact with air, water, or 42 other media; inhalation; or ingestion of contaminated food, water, or soil.
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1 The 1996 LR GEIS (NRC 1996) did not address this issue. In 2007, the International 2 Commission on Radiation Protection (ICRP) issued revised recommendations for a system of 3 protection to control exposure from radiation sources (ICRP 2007). The recommendations 4 included a section about the protection of the environment in which the ICRP found that a 5 clearer framework for assessing non-human organisms was warranted. The ICRP indicated that 6 it would develop a set of reference animals and plants as the basis for relating exposure to 7 dose, and dose to radiation effects, for different types of organisms. This information would then 8 provide a basis from which agencies and responsible organizations could make policy and 9 management decisions. Subsequently, the ICRP developed and published a set of 12 reference 10 animals and plants (ICRP 2008, 2009). They include a large and small terrestrial mammal, an 11 aquatic bird, and a large and small terrestrial plant, among others. The ICRP also issues 12 publications and information related to radiological effects and radiosensitivity in non-human 13 biota (Adam-Guillermin et al. 2018).
14 In 2009, after the staff conducted a review of the ICRPs 2007 recommendations, the 15 Commission found that there is no evidence that the NRCs current set of radiation protection 16 controls is not protective of the environment (NRC 2009a). For this reason, the Commission 17 determined that the NRC staff should not develop separate radiation protection regulations for 18 plant and animal species (NRC 2009a). The Commission charged the NRC staff with continuing 19 to monitor international developments on this issue and to keep the Commission informed of 20 any such developments. Nonetheless, the NRC addressed the radiological exposure of non-21 human organisms in the 2013 LR GEIS (NRC 2013a) due to public concern about these 22 impacts at some nuclear power plants.
23 In the 2013 LR GEIS, the NRC staff adopted the U.S. Department of Energy (DOE) standard for 24 a graded approach for evaluating radiation doses to terrestrial and aquatic biota (DOE 2019).
25 This DOE standard provides methods, models, and guidance that can be used to characterize 26 radiation doses to terrestrial and aquatic biota exposed to radioactive material (DOE 2019). The 27 following DOE guidance dose rates are the levels below which no adverse effects to resident 28 populations are expected:
29
* riparian animal (0.1 radiation-absorbed dose per day [rad/d]; 0.001 gray per day [Gy/d])
30
* terrestrial animal (0.1 rad/d) (0.001 Gy/d) 31
* terrestrial plant (1 rad/d) (0.01 Gy/d) 32
* aquatic animal (1 rad/d) (0.01 Gy/d).
33 The NRC staff notes that in 1992, the International Atomic Energy Agency (IAEA 1992) had 34 concluded that chronic dose rates of 0.1 rad/d (0.001 Gy/d) or less do not appear to cause 35 observable changes in terrestrial animal populations. The United Nations Scientific Committee 36 on the Effects of Atomic Radiation (UNSCEAR) concluded in 1996 and reaffirmed in 2008 that 37 chronic dose rates of less than 0.1 mGy/hr (0.24 rad/d or 0.0024 Gy/d) to the most highly 38 exposed individuals would be unlikely to have significant effects on most terrestrial communities 39 (UNSCEAR 2010).
40 In the 2013 LR GEIS, the NRC estimated the total radiological dose that the four non-human 41 receptors listed above (i.e., riparian animal, terrestrial animal, terrestrial plant, and aquatic 42 animal) would be expected to receive during normal nuclear power plant operations based on 43 plant-specific radionuclide concentrations in water, sediment, and soils at 15 operating nuclear 44 power plants using the Argonne National Laboratory RESRAD-BIOTA dose evaluation model.
45 The NRC found that total calculated dose rates for all terrestrial receptors at all 15 plants were 46 significantly less than the DOE guideline values. As a result, the NRC anticipated in the 2013 2-32
 
1 LR GEIS that normal operations of these facilities would not result in negative effects on 2 terrestrial biota. The 2013 LR GEIS concluded that the impact of radionuclides on terrestrial 3 biota from past operations would be SMALL for all nuclear power plants and would not be 4 expected to change appreciably during the initial license renewal period.
5 The NRC staff did not specifically address the exposure of terrestrial organisms to radionuclides 6 as part of its environmental review of the FPL application for initial license renewal for Turkey 7 Point (NRC 2002a), because that issue was not addressed in the 1996 LR GEIS upon which the 8 environmental review relied. Later, however, the 2013 LR GEIS did address the issue 9 generically for initial license renewal of all nuclear power plants and concluded that impacts 10 would be SMALL; the staff adopted that conclusion in the 2013 FSEIS for Turkey Point SLR.
11 In the following discussion, the NRC staff analyzes this issue on a site-specific basis for the 12 Turkey Point SLR term.
13 The NRC requires nuclear power plants to maintain a radiological environmental monitoring 14 program (REMP) in accordance with the regulations in (1) 10 CFR Part 50, Domestic Licensing 15 of Production and Utilization Facilities, Appendix I, Numerical Guides for Design Objectives 16 and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably 17 Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; 18 (2) 10 CFR Part 20, Standards for Protection Against Radiation; and (3) 10 CFR Part 72, 19 Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level 20 Radioactive Waste, and Reactor-Related Greater Than Class C Waste. In addition, radiological 21 monitoring is required in accordance with plant-specific technical specifications. These 22 provisions collectively require that licensees establish and implement a REMP to obtain data 23 about measurable levels of radiation and radioactive material. The NRC provides guidance to 24 licensees on acceptance methods for establishing and conducting REMPs in Regulatory Guide 25 4.1, Radiological Environmental Monitoring for Nuclear Power Plants (NRC 2009b).
26 FPL established an REMP before Turkey Point began commercial operations to gather data 27 about background radiation and radioactivity that is normally present in the area. FPL has 28 continued to monitor direct radiation and to sample air, water, sediment, crustaceans, fish, and 29 broadleaf vegetation annually for radionuclides. FPL also samples milk if animals that are used 30 to produce milk products for human consumption are present within 5 mi (8 km) of the site.
31 FDOH personnel collect and analyze REMP samples on behalf of FPL, and the results are 32 reported to the NRC. REMP sampling includes indicator and control locations within a 20 mi 33 (32 km) radius of the plant. The indicator locations are designed to detect any increases or 34 buildup of radioactivity that might occur due to Turkey Point operation. Control locations are 35 farther away to monitor naturally occurring radioactivity. FPL compares monitoring results at 36 indicator and control locations to assess any radiological impacts that Turkey Point operations 37 might be having on the surrounding environment.
38 Since Turkey Point began operating, REMP results have not indicated any significant 39 radiological impacts on the surrounding environment attributable to Turkey Point operations.
40 As part of its environmental review, the NRC staff reviewed the past 5 years of REMP reports 41 (FPL 2022e, 2021b, 2020b, 2019a, 2018h). During this period, the radionuclide concentrations 42 in air, shoreline, crustaceans, and fish samples was below the lower limit of detection (LLD).
43 Surface water samples yielded detectable tritium in 8 to 16 percent of indicator sample locations 44 each year at levels ranging from 93 to 128 picocuries per liter (pCi/L). Tritium concentrations 45 were consistent with those detected during previous operational years and were all well below 46 the reportable level of 30,000 pCi/L. Broadleaf vegetation samples yielded detectable cesium-2-33
 
1 137 at both indicator and control sites at levels ranging from 89 to 102 picocuries per kilogram 2 (pCi/kg). Concentrations were consistent with those detected during previous operational years 3 and were all well below the reportable level of 2,000 pCi/kg. This activity is attributable to a 4 combination of weapons fallout testing 30 to 40 years ago and the 1986 Chernobyl Nuclear 5 Power Plant accident in Chernobyl, Ukraine. Therefore, the detected cesium-137 is background 6 radiation present in the area and is unrelated to Turkey Point operations.
7 In summary, NRC regulations require nuclear power plants to monitor radiation in the 8 environment and to report the results of such monitoring to the NRC through a REMP. The 9 conduct of REMP monitoring ensures that levels of radiation are below regulatory limits and that 10 any changes in radionuclide concentrations are detected and addressed. To date, FPL has not 11 detected levels of radioactivity attributable to Turkey Point operations that would result in 12 measurable radiological impacts on terrestrial organisms. Turkey Point operations during the 13 SLR term would continue current operating conditions and environmental stressors rather than 14 introduce wholly new impacts. For these reasons, radiological impacts would be minor and 15 would neither destabilize nor noticeably alter any important attribute of the terrestrial 16 environment during the SLR term. Accordingly, the NRC staff concludes that the exposure of 17 terrestrial organisms to radionuclides due to continued nuclear power plant operations at Turkey 18 Point during the SLR term would be SMALL.
19 2.9.2      Cooling System Impacts on Terrestrial Resources (Plants with Once-Through 20            Cooling Systems or Cooling Ponds) 21 This issue concerns the potential impacts of once-through cooling systems and cooling ponds at 22 nuclear power plants on terrestrial resources. Cooling system operation can alter the ecological 23 environment in a manner that affects terrestrial resources. Such alterations may include thermal 24 effluent additions to receiving water bodies, chemical effluent additions to surface water or 25 groundwater, impingement of waterfowl, disturbance of terrestrial plants and wetlands 26 associated with maintenance dredging, disposal of dredged material, and erosion of shoreline 27 habitat. In the following discussion, the NRC staff summarizes the manner in which this issue 28 has been addressed historically, and then presents a site-specific evaluation of the issue for 29 Turkey Point SLR.
30 The 2013 LR GEIS (NRC 2013a) summarizes the available information about these effects.
31 Many of these effects have only been identified at a small number of nuclear power plants, and 32 these plants have modified plant operation to reduce or eliminate the effects. For instance, 33 heavy metals used in condenser tubing was found to be an issue at two plants and elevated 34 concentrations of these contaminants are toxic to terrestrial organisms. Copper alloy condenser 35 tubes in the cooling systems of these plants resulted in the discharge of copper in these plants 36 liquid effluent. At one plant, these metals resulted in adverse effects on the morphology and 37 reproduction of resident bluegill (Lepomis macrochirus) populations (Harrison 1985). At the 38 other plant, abalone (Haliotis species) deaths were attributed to exposure to copper in plant 39 effluents (NRC 1996). Terrestrial wildlife that feed on these aquatic organisms could have also 40 been exposed to elevated copper levels and could have experienced adverse effects. However, 41 these nuclear power plants subsequently replaced their copper alloy condenser tubes with 42 tubes made of different materials (e.g., titanium), which has eliminated these impacts. Similar 43 issues have not been reported at any other nuclear power plants.
44 The 1996 LR GEIS (NRC 1996) and the 2013 LR GEIS (NRC 2013a) concluded that cooling 45 system impacts on terrestrial resources during initial license renewal would be SMALL. The 46 1996 LR GEIS considered this issue for nuclear power plants with cooling ponds; the 2013 LR 2-34
 
1 GEIS expanded this issue to include plants with once-through cooling systems. In its 2 environmental review of the FPL application for initial license renewal for Turkey Point (NRC 3 2002a), the NRC staff found no new and significant information concerning this issue and 4 adopted the 1996 LR GEISs conclusion of SMALL impacts for Turkey Point initial license 5 renewal. Also, the FSEIS for the SLR of Turkey Point adopted the 2013 LR GEISs conclusion 6 of SMALL impacts for SLR. Below, the NRC staff analyzes this issue on a site-specific basis for 7 the Turkey Point SLR term.
8 The potential cooling system impacts on terrestrial resources relevant to the Turkey Point CCS 9 include those associated with thermal and chemical effluents. All liquid effluents from Turkey 10 Point operations are discharged into the CCS, which does not directly connect to any surface 11 water bodies. Section 3.5.1.3 of the Turkey Point FSEIS for SLR describes surface water 12 discharges in detail. The temperature of the CCS varies in response to factors such as heated 13 water discharged from Turkey Point into the CCS, air temperature, wind, precipitation, Biscayne 14 Aquifer groundwater flowing into and out of the CCS, and water that FPL adds to the CCS from 15 wells to reduce salinity. To a lesser extent, discharges of water into the CCS from the 16 interceptor ditch and the Turkey Point Unit 5 cooling tower blowdown can also affect the 17 temperature of water within the CCS. The CCS serves as the ultimate heat sink to cool Turkey 18 Point Units 3 and 4. In 2014, the NRC established an ultimate heat sink temperature limit for the 19 intake from the CCS of 104 °F (40 °C) (NRC 2014b).
20 Since 2010, FPL has commissioned Ecology and Environment, Inc. to perform ongoing, 21 semiannual ecological monitoring of the Turkey Point site and surrounding environment as a 22 requirement of the FDEP Conditions of Certification in connection with the Turkey Point 23 extended power uprate and the SFWMD Fifth Supplemental Agreement. With respect to the 24 terrestrial environment, Ecology and Environment, Inc. monitors marsh, mangrove, and tree 25 islands to characterize and observe changes in the ecological characteristics over time. FPL 26 samples freshwater marsh sawgrass within the study area for sawgrass percent cover, 27 sawgrass average height, sawgrass live biomass, annual net primary productivity, sclerophylly 28 (a measure of leaf hardness or toughness), and leaf nutrient and stable isotopic composition.
29 FPL also samples marsh porewater for conductance, temperature, and nutrients (nitrogen, 30 ammonia, and phosphorus). FPLs reports show data that have remained generally consistent 31 since monitoring began and have shown no clear upward or downward trend or differences 32 among transects that can be attributed to the proximity of the transects to the CCS. FPLs 33 ecological monitoring data suggest that the observed changes and fluctuations near Turkey 34 Point are attributable to landscape-scale environmental factors, such as hydroperiod length, 35 overall water depth, and storm surges, and that proximity to the CCS does not noticeably 36 influence marsh ecology. Section 3.6.2 of the FSEIS describes the methods and results of these 37 monitoring efforts in detail. To date, ecological monitoring has not detected evidence of any 38 impacts from the CCS on marshes, mangroves, or tree islands via the groundwater pathway 39 (FPL 2022a).
40 FPL has also undertaken efforts to improve CCS water quality and thermal conditions. These 41 efforts have further reduced the potential for the CCS to affect the surrounding terrestrial 42 environment. Since 2014, FPL has worked to reduce algae concentrations, improve canal 43 circulation, and increase the inflow of groundwater from the Biscayne Aquifer into the CCS by 44 removing sediment from CCS channels. For a short period of time, to help lower CCS 45 temperatures, freshwater from Canal L-31E, brackish water from the UFA, and saltwater from 46 the Biscayne Aquifer were added to the CCS (NRC 2019a). In 2017, FPL began implementing a 47 Nutrient Management Plan for the CCS. This plan was a requirement of the June 20, 2016, 48 Consent Order between FPL and the State of Florida. Actions under this plan have included 2-35
 
1 sediment removal from many of the CCS canals, flow management within the CCS, water stage 2 management, and vegetation management (NRC 2019a). As part of this plan, since late 2018, 3 FPL has planted widgeongrass (Ruppia maritima) in the CCS to restore previous losses of 4 seagrass due to high salinity levels and unsuitable thermal conditions. FPL has planted more 5 than 100,000 individual plants over a total of 7 ac (2.8 ha) to date (FPL 2022a). Section 3.5.1.4 6 of the FSEIS further describes the components and requirements of the Nutrient Management 7 Plan.
8 Turkey Point operations during the SLR term would continue current operating conditions and 9 environmental stressors rather than introduce wholly new impacts. Therefore, cooling system 10 impacts on terrestrial resources from current operations and SLR would be similar. Further, 11 requirements under the 2016 Consent Order and SFWMD Fifth Supplemental Agreement will 12 ensure that potential impacts of the CCS on the surrounding environment are minimized and 13 that conditions in the CCS continue to improve. For these reasons, cooling system impacts 14 would be minor and would neither destabilize nor noticeably alter any important attribute of the 15 terrestrial environment during the SLR term. Accordingly, the NRC staff concludes that the 16 cooling system impacts on terrestrial resources due to continued nuclear power plant operations 17 at Turkey Point during the SLR term would be SMALL.
18 2.9.3      Bird Collisions with Plant Structures and Transmission Lines 19 Tall structures on nuclear power plant sites, such as cooling towers, meteorological towers, and 20 transmission lines, create collision hazards for birds that can result in their injury or death.
21 Throughout the United States, millions of birds are killed each year when they collide with 22 human-made objects, including buildings, windows, vehicles, transmission lines, communication 23 towers, wind turbines, cooling towers, and numerous other objects (Erickson et al. 2001).
24 Associated bird mortality is of concern if the stability of the population of a species is threatened 25 or if the reduction in numbers within any bird population significantly impairs its function within 26 the ecosystem.
27 The 2013 LR GEIS (NRC 2013a) summarizes the results of bird mortality surveys at several 28 nuclear power plants. In the LR GEIS, the NRC staff found that the available data about bird 29 collision mortality associated with nuclear power plant cooling towers and other structures 30 suggest that nuclear power plants cause a small number of bird mortalities. A large percentage 31 of these mortalities occur during the spring and fall migratory periods and primarily involve 32 songbirds migrating at night. Natural draft cooling towers appear to be the structures that pose 33 the largest collision risk at nuclear power plant sites. Operating cooling towers appear to detract 34 birds; the vapor plume, noise, or lighting may mitigate the risk of bird collision. Data about bird 35 injuries are not available, but the NRC staff assumes that some birds that collide with nuclear 36 power plant structures are injured and either die later or suffer reduced fitness until they 37 recover. The relatively few nuclear power plants in the United States that have natural draft 38 towers, combined with the relatively low bird mortality at studied sites, indicate that bird 39 populations are unlikely to be measurably affected by collisions with nuclear power plant 40 structures and that the contribution of nuclear power plant sites to the cumulative effects of bird 41 collision mortalities in the United States is very small. Both the 1996 LR GEIS (NRC 1996) and 42 the 2013 LR GEIS concluded that the impacts of bird collisions during initial license renewal 43 would be SMALL. The 1996 LR GEIS evaluated this issue as two separate issues; the 2013 LR 44 GEIS consolidated them into one issue. In its environmental review of the FPL application for 45 initial license renewal for Turkey Point (NRC 2002a), the NRC staff found no new and significant 46 information concerning this issue and adopted the 1996 LR GEISs conclusion of SMALL 47 impacts for Turkey Point initial license renewal. Also, the FSEIS for the SLR of Turkey Point 2-36
 
1 adopted the 2013 LR GEISs conclusion of SMALL impacts for SLR. Below, the NRC staff 2 analyzes this issue on a site-specific basis for the Turkey Point SLR term.
3 Turkey Point does not have cooling towers. The tallest structures on the Turkey Point site are 4 the containment structures for Turkey Point Units 3 and 4, which are approximately 210 ft 5 (64 m) tall. Transmission lines run 590 ft (180 m) from the turbine building west to the 240 kV 6 switchyard. The site also contains a 197 ft (60 m) meteorological tower. These structures and 7 transmission lines lie within the industrial portion of the site.
8 FPL maintains a voluntary corporate Avian Protection Plan. This plan adheres to Avian Power 9 Line Interaction Committee and FWS guidelines regarding birds and electrical energy 10 production (APLIC and FWS 2005). It includes guidance on reporting bird mortalities, dealing 11 with bird injuries, nest management, permitting, construction design standards to minimize 12 collision and electrocution, staff training, and mortality risk assessment (FPL 2018f).
13 In the NRCs Biological Assessment for Turkey Point SLR (NRC 2018), the NRC staff evaluated 14 the risk of federally listed birds colliding with in-scope transmission lines. The NRC staff found 15 that the likelihood of collisions of piping plover (Charadrius melodus), Everglades snail kite 16 (Rostrhamus sociabilis), and Kirtlands warbler (Setophaga kirtlandi) at Turkey Point is 17 extremely small because suitable habitat for the listed birds does not occur near major plant 18 structures or in-scope transmission lines, because the staff is not aware of any known reports or 19 incidents of such collisions, and because FPL maintains an Avian Protection Plan.
20 Between 2012 and 2021, FPL reported eight bird deaths on the Turkey Point site: one brown 21 pelican (Pelecanus occidentalis) (2016), three white pelicans (P. erythrorhynchos) (2017 and 22 2021), one anhinga (Anhinga anhinga) (2020), two grackles (Quiscalus quiscula) (2020 and 23 2021), and one green heron (Butorides virescens) (2021) (FPL 2022a). FPL only reports birds 24 that are handled, removed, or disposed of by site personnel. Nonetheless, this information 25 indicates that the occurrence of avian collisions with site structures and in-scope transmission 26 lines is very low. None of these mortalities is expected to impair the function of or to affect the 27 stability of these populations within the local ecosystem.
28 Turkey Point operations during the SLR term would continue current operating conditions and 29 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 30 current operations and SLR on birds would be similar. For these reasons, the effects of bird 31 collisions with plant structures and transmission lines would be minor and would neither 32 destabilize nor noticeably alter any important attribute of bird populations during the SLR term.
33 Accordingly, the NRC staff concludes that the impacts of bird collisions with plant structures or 34 transmission lines due to continued nuclear power plant operations at Turkey Point during the 35 SLR term would be SMALL.
36 2.9.4      Transmission Line Right-of-Way Management Impacts on Terrestrial Resources 37 This issue concerns the effects of transmission line ROW management on terrestrial plants and 38 animals. Utilities maintain transmission line ROWs so that the ground cover is composed of low-39 growing herbaceous or shrubby vegetation and grasses. Generally, ROWs are initially 40 established by clear-cutting during transmission line construction and are subsequently 41 maintained by physical (e.g., mowing and cutting) and chemical (e.g., herbicides or pesticides) 42 means. These activities alter the composition and diversity of plant communities and generally 43 result in lower-quality habitat for wildlife. Heavy equipment used for ROW maintenance can 44 crush vegetation and compact soils, which can affect soil quality and reduce infiltration to 2-37
 
1 shallow groundwater. This is especially of concern in sensitive habitats, such as wetlands.
2 Chemical herbicides can be transported to neighboring undisturbed habitats through 3 precipitation and runoff. Disturbed habitats often favor non-native or nuisance species and can 4 lead to their proliferation. Noise and general human disturbance during ROW management can 5 temporarily disturb wildlife and affect their behaviors, and the presence of ROWs can favor 6 wildlife species that prefer edge or early successional habitats.
7 Both the 1996 LR GEIS (NRC 1996) and the 2013 LR GEIS (NRC 2013a) concluded that the 8 impacts of transmission line ROW management on terrestrial resources would be SMALL during 9 the initial license renewal term. In its environmental review of the FPL application for initial 10 license renewal for Turkey Point (NRC 2002a), the NRC staff found no new and significant 11 information concerning this issue and adopted the 1996 LR GEISs conclusion of SMALL 12 impacts for Turkey Point initial license renewal. Also, the FSEIS for the SLR of Turkey Point 13 adopted the 2013 LR GEISs conclusion of SMALL impacts for SLR. Below, the NRC staff 14 analyzes this issue on a site-specific basis for the Turkey Point SLR term.
15 The transmission lines within the scope of the Turkey Point SLR review are two lines that 16 extend 590 ft (180 m) from the turbine building west to the 240 kV switchyard that connect the 17 Turkey Point reactor buildings to the switchyard. Figure 3-6 in the FSEIS (NRC 2019a) depicts 18 these lines. Both lines are contained within the industrial use portion of the site. They do not 19 cross any natural areas and vegetation management is not required. Therefore, maintenance of 20 these lines has no discernible effect on ecological resources.
21 Turkey Point operations during the SLR term would continue current operating conditions and 22 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 23 current operations and SLR would be similar. For these reasons, the effects of transmission line 24 ROW management on terrestrial resources would be minor and would neither destabilize nor 25 noticeably alter any important attribute of plant or animal populations during the SLR term.
26 Accordingly, the NRC staff concludes that the impacts of transmission line ROW management 27 on terrestrial resources due to continued nuclear power plant operations at Turkey Point during 28 the SLR term would be SMALL.
29 2.9.5      Effects of Electromagnetic Fields on Flora and Fauna (Plants, Agricultural 30            Crops, Honeybees, Wildlife, Livestock) 31 This issue concerns the effects of electromagnetic fields (EMFs) on terrestrial plants and 32 animals, including agricultural crops, honeybees, wildlife, and livestock. Operating transmission 33 lines produce electric and magnetic fields, collectively referred to as EMFs. EMF strength at the 34 ground level varies greatly but is generally stronger for higher-voltage lines. Corona is the 35 electrical discharge occurring in air from EMFs; it can be detected adjacent to phase 36 conductors. Corona is generally not an issue for transmission lines of 345 kV or less. Corona 37 results in audible noise, radio and television interference, energy losses, and ozone and 38 nitrogen oxide production. Studies investigating the effects of EMFs produced by operating 39 transmission lines up to 1,100 kV have generally not detected any ecologically significant impact 40 on terrestrial plants and animals.
41 The 2013 LR GEIS (NRC 2013a) summarizes relevant scientific studies and literature about this 42 topic. In the LR GEIS, the NRC staff found that study results reported in the literature about the 43 effects of EMF on plants and wildlife are somewhat mixed. One study found reduced upward 44 growth of trees. Studies of agricultural crops, including corn, bluegrass, alfalfa, and sunflower, 45 have detected no effects or minor effects that did not ultimately affect germination or crop yield.
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1 One study found that densities of breeding birds under transmission lines were greater than 2 those in adjacent forests, grasslands, or agricultural fields. Other studies have found no 3 measurable effects on birds or other wildlife or have concluded that observed population 4 densities were more highly correlated with habitat type than with proximity to transmission lines.
5 Other studies have observed impacts of EMFs on animals, such as an influence on the 6 development, reproduction, and physiology of certain insects and mammals. Honeybees in 7 hives under transmission lines can suffer increased propolis (a resin-like material produced to 8 build hives) production, reduced growth, greater irritability, and increased mortality resulting 9 from voltage buildup and electric currents within the hives. These effects can be mitigated by 10 keeping bees in moisture-free nonconductive conditions, by shielding hives with a grounded 11 metal screen, or by moving them away from transmission lines. The 2013 LR GEIS (p. 4-80 12 through 4-84) contains more details about and full citations for these studies. Both the 1996 LR 13 GEIS (NRC 1996) and the 2013 LR GEIS concluded that the impacts of EMFs on flora and 14 fauna during initial license renewal would be SMALL. In its environmental review of the FPL 15 application for initial license renewal for Turkey Point (NRC 2002a), the NRC staff found no new 16 and significant information concerning this issue and adopted the 1996 LR GEISs conclusion of 17 SMALL impacts for Turkey Point initial license renewal. Also, the FSEIS for the SLR of Turkey 18 Point adopted the 2013 LR GEISs conclusion of SMALL impacts for SLR. Below, the NRC staff 19 analyzes this issue on a site-specific basis for the Turkey Point SLR term.
20 The transmission lines within the scope of the Turkey Point SLR review are two lines that 21 extend 590 ft (180 m) from the turbine building west to the 240 kV switchyard that connect the 22 Turkey Point reactor buildings to the switchyard. Figure 3-6 in the FSEIS (NRC 2019a) depicts 23 these lines. Both lines are contained within the industrial use portion of the site and do not cross 24 any wildlife habitat, agricultural fields, or other natural areas. Because of this, exposure of plants 25 and animals to EMFs created by these lines is minimal.
26 Turkey Point operations during the SLR term would continue current operating conditions and 27 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 28 current operations and SLR would be similar. For these reasons, the effects of EMFs on flora 29 and fauna would be minor and would neither destabilize nor noticeably alter any important 30 attribute of plant or animal populations during the SLR term. Accordingly, the NRC staff 31 concludes that the impacts of EMFs on flora and fauna due to continued nuclear power plant 32 operations at Turkey Point during the SLR term would be SMALL.
33 2.10 Aquatic Resources 34 The following sections address the site-specific environmental impacts of Turkey Point SLR on 35 nine environmental issues related to aquatic resources.
36 2.10.1    Entrainment of Phytoplankton and Zooplankton 37 Entrainment occurs when organisms pass through the cooling systems screening device and 38 travel through the entire system, including the pumps, condenser or heat exchanger tubes, and 39 discharge pipes (79 FR 48300). Organisms susceptible to entrainment are of smaller size, such 40 as ichthyoplankton, meriplankton, zooplankton, and phytoplankton. During travel through the 41 cooling system, entrained organisms experience physical trauma and stress, pressure changes, 42 excess heat, and exposure to chemicals (Mayhew et al. 2000). Because entrainable organisms 43 generally consist of fragile life stages (e.g., eggs, which exhibit poor survival after interacting 44 with a cooling water intake structure, and early larvae, which lack a skeletal structure and 45 swimming ability), the EPA has concluded that, for purposes of assessing the impacts of a 2-39
 
1 cooling water intake system on the aquatic environment, all entrained organisms die (79 FR 2 48300). The NRC staff assessed the site-specific impacts of entrainment of fish and shellfish 3 during the Turkey Point SLR term in Section 4.7.1.1 of the FSEIS (NRC 2019a), with respect to 4 the entrainment of phytoplankton and zooplankton.
5 Most nuclear power plants were required to monitor for entrainment effects during their initial 6 years of operation. In the 2013 LR GEIS (NRC 2013a), the effects of entrainment on 7 phytoplankton and zooplankton were determined to be of SMALL significance if monitoring 8 indicated no evidence that nuclear power plant operation had reduced or otherwise affected 9 populations of these organisms in the source water body. The 2013 LR GEIS summarizes the 10 results of entrainment monitoring at several nuclear power plants. Based on its review, the NRC 11 staff found in the 1996 LR GEIS (NRC 1996) and the 2013 LR GEIS that nuclear power plants 12 had not noticeably altered phytoplankton or zooplankton abundance near these and other plants 13 and that the impacts of initial license renewal would be similar and SMALL. In its environmental 14 review of the FPL application for initial license renewal for Turkey Point (NRC 2002a), the NRC 15 staff found no new and significant information concerning this issue and adopted the 1996 LR 16 GEISs conclusion of SMALL impacts for Turkey Point initial license renewal. Also, the FSEIS 17 for the SLR of Turkey Point adopted the 2013 LR GEISs conclusion of SMALL impacts for SLR.
18 Below, the NRC staff analyzes this issue on a site-specific basis for the Turkey Point SLR term.
19 The NRC staff analysis first considers impacts that would be experienced by the aquatic biota in 20 the CCS and then impacts that would be experienced by the aquatic biota in adjacent natural 21 aquatic environments, including Biscayne Bay and Card Sound.
22 2.10.1.1    Phytoplankton and Zooplankton of the CCS 23 Aquatic organisms inhabiting the CCS may be entrained when water is drawn from the CCS into 24 the Turkey Point intake structure. Water from the CCS flows from the canal system into eight 25 intake channels and through (0.37 in.) 9.5 mm mesh intake screens at a rate of 4.48 feet per 26 second (fps) (1.4 meters per second [m/s]). The maximum flow per intake channel is 27 225,375 gpm (14.2 m3/s) (FPL 2018f; NRC 2019a).
28 In the early 1970s, researchers conducted field and laboratory studies to determine the effects 29 of entrainment of zooplankton at Turkey Point. These studies contemplated the use of Biscayne 30 Bay as an interim cooling water source until the construction of the CCS was completed, 31 followed by Card Sound as a source of CCS makeup water (AEC 1972). After these studies, the 32 Turkey Point cooling system design was modified so that it did not require withdrawal from or 33 discharge to any natural surface water bodies. Therefore, the results of these studies are not 34 relevant to the Turkey Point cooling system, as it was ultimately constructed. FPL has not 35 conducted any entrainment studies within the CCS since its construction. The CWA does not 36 impose ecological study requirements because the State classifies the CCS as an IWW facility 37 and because the CCS does not directly withdraw from or discharge to any natural surface water 38 bodies.
39 Due to a lack of studies, the characteristics of the phytoplankton and zooplankton community 40 within the CCS are unknown. Species present within the CCS may include those that were 41 common in the 1970s in Biscayne Bay, from which the CCS was initially filled. These include 42 Acartia tonsa, Paracalanus parvus, Tamora turbinate, Labidocera scotti, Oithona nana, and 43 Metis jousseaumei (AEC 1972). Most of these organisms in the CCS are not at risk of 44 entrainment due to the layout of the system and the large size of the CCS relative to the small 45 area influenced by the Turkey Point intake structures withdrawal of water. Only those 2-40
 
1 individuals in the CCS intake canal, specifically, would be at risk of entrainment and only those 2 individuals within the smaller area influenced by the intake velocity are likely to be entrained.
3 Many phytoplankton and zooplankton in the CCS likely spend their lives in the main canals and 4 are never exposed to entrainment risk. In contrast, for a nuclear power plant whose intake 5 draws from a river, migration or movement of organisms past the plant would likely necessitate 6 passage through the zone of the plant intakes influence. For the reasons discussed above, the 7 NRC staff concludes that while entrainment at Turkey Point is likely to affect CCS populations of 8 phytoplankton and zooplankton, only a small portion of those organisms would be susceptible to 9 entrainment at any given time.
10 Turkey Point operations during the SLR term would continue current operating conditions and 11 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 12 current operations and SLR on phytoplankton and zooplankton would be similar. For these 13 reasons, the effects of entrainment of phytoplankton and zooplankton in the CCS would be 14 minor and would neither destabilize nor noticeably alter any important attribute of these 15 populations during the SLR term. Accordingly, the NRC staff concludes that the impacts of 16 entrainment of phytoplankton and zooplankton in the CCS due to continued nuclear power plant 17 operations at Turkey Point during the SLR term would be SMALL.
18 2.10.1.2    Phytoplankton and Zooplankton of the Biscayne Bay 19 Aquatic organisms inhabiting Biscayne Bay are not subject to entrainment because there are no 20 surface water connections that allow flow between the waters of Biscayne Bay and the CCS.
21 Thus, phytoplankton and zooplankton in Biscayne Bay and connected water bodies (e.g., Card 22 Sound, the Atlantic Ocean, etc.) never interact with the Turkey Point intake structure.
23 Accordingly, the NRC staff concludes that the issue of entrainment of phytoplankton and 24 zooplankton at Turkey Point during the SLR term does not apply to aquatic organisms in 25 Biscayne Bay.
26 2.10.2    Infrequently Reported Thermal Impacts 27 This issue concerns the infrequently reported effects of thermal effluents. These effects include 28 cold shock, thermal migration barriers, accelerated maturation of freshwater aquatic insects, 29 and proliferated growth of aquatic nuisance species.
30 Cold shock occurs when an organism has been acclimated to a specific water temperature or 31 range of temperatures and is subsequently exposed to a rapid decrease in temperature. This 32 can result in a cascade of physiological and behavioral responses and, in some cases, death 33 (Donaldson et al. 2008). Rapid temperature decreases may be caused by natural sources 34 (e.g., thermocline temperature variation and storm events) and anthropogenic sources 35 (e.g., thermal effluent discharges). The magnitude, duration, and frequency of the temperature 36 change, as well as the initial acclimation temperatures of individuals, can influence the extent of 37 the consequences of cold shock on fish and other aquatic organisms (Donaldson et al. 2008).
38 At nuclear power plants, cold shock could occur during refueling outages, reductions in power 39 generation level, or other situations that would quickly reduce the amount of cooling capacity 40 required at the plant. Cold shock is most likely to be observable during the winter. The 1996 LR 41 GEIS reports that cold shock events have only rarely occurred at nuclear power plants. Fish 42 mortalities usually involved only a few fish and did not result in population-level effects. Gradual 43 depowering or shutdown of plant operations, especially in winter months, can mitigate the 44 effects of cold shock.
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1 Thermal effluents have the potential to create migration barriers if the thermal plume covers an 2 extensive cross-sectional area of a river and temperatures within the plume exceed a species 3 physiological tolerance limit. This impact has been examined at several nuclear power plants, 4 but it has not been determined to result in observable effects (NRC 1996, 2013a).
5 The 1996 LR GEIS and the 2013 LR GEIS considered that the heated effluents of nuclear 6 power plants could accelerate the maturation of aquatic insects in freshwater systems and 7 cause premature emergence. The maturation and emergence of aquatic insects are often 8 closely associated with water temperature regimes. If insects develop or emerge early in the 9 season, they may be unable to feed or reproduce or they may die because the local climate is 10 not warm enough to support them.
11 The 1996 LR GEIS and the 2013 LR GEIS also considered that the heated effluents of nuclear 12 power plants could proliferate the growth of aquatic nuisance species. Aquatic nuisance species 13 are organisms that disrupt the ecological stability of infested inland (e.g., rivers and lakes),
14 estuarine, or marine waters (EPA 2022). The 1996 LR GEIS and the 2013 LR GEIS discuss the 15 zebra mussel (Dreissena polymorpha) and Asiatic clam (Corbicula fluminea), two bivalves that 16 are of particular concern in many freshwater systems because they can cause significant 17 biofouling of industrial intake pipes at power and water facilities. These species are also of 18 ecological concern because they outcompete and lead to the decline of native freshwater 19 mussels. Nuclear power plants that withdraw water from water bodies in which these species 20 are known to occur often periodically chlorinate intake pipes or have other procedures in place 21 to mitigate the spread of these bivalves. There is no evidence, however, that thermal effluent 22 leads to these species proliferation.
23 Langford (1983) reported several instances in which wood-boring crustaceans and mollusks, 24 notably shipworms, have caused concern in British waters. Although increased abundance of 25 shipworms in the area influenced by heated power plant effluents caused substantial damage to 26 wooden structures, the replacement of old wood with concrete or metal structures eliminated the 27 problem. Langford concluded that increased temperatures could enhance the activity and 28 reproduction of wood-boring organisms in enclosed or limited areas, but that elevated 29 temperature patterns were not sufficiently stable to cause widespread effects.
30 The 1996 LR GEIS and the 2013 LR GEIS concluded that these infrequently reported thermal 31 impacts would be SMALL during the initial license renewal term. The 1996 LR GEIS evaluated 32 these concerns as five issues; the 2013 LR GEIS consolidated them into one issue. In its 33 environmental review of the FPL application for initial license renewal for Turkey Point (NRC 34 2002a), the NRC staff found no new and significant information concerning these issues and 35 adopted the 1996 LR GEISs conclusion of SMALL impacts for Turkey Point initial license 36 renewal. Also, the Turkey Point FSEIS adopted the 2013 LR GEISs conclusion of SMALL 37 impacts for SLR. Below, the NRC staff analyzes this issue on a site-specific basis for the Turkey 38 Point SLR term.
39 With respect to cold shock, no such events have been reported or are expected at Turkey Point.
40 Therefore, cold shock is not expected to be of concern for Turkey Point SLR.
41 With respect to thermal migration barriers, there are no surface water connections that allow 42 flow between the CCS and any natural water bodies. Therefore, Turkey Points thermal effluent 43 does not create barriers to migration or otherwise contribute to changes in the natural 44 distribution of aquatic organisms in the region and this issue is not relevant to Turkey Point SLR.
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1 The potential concerns of accelerated maturation of freshwater aquatic insects and proliferated 2 growth of aquatic nuisance species are not relevant to Turkey Point because the CCS is not a 3 freshwater system. Additionally, shipworms are not of concern at Turkey Point because it does 4 not discharge to coastal waters.
5 Turkey Point operations during the SLR term would continue current operating conditions and 6 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 7 current operations and SLR would be similar. For these reasons, infrequently reported thermal 8 impacts would be minor and would neither destabilize nor noticeably alter any important 9 attribute of the aquatic environment during the SLR term. Accordingly, the NRC staff concludes 10 that infrequently reported thermal impacts on aquatic resources due to continued nuclear power 11 plant operations at Turkey Point during the SLR term would be SMALL.
12 2.10.3    Effects of Cooling Water Discharge on Dissolved Oxygen, Gas Supersaturation, 13            and Eutrophication 14 This issue concerns the effects of thermal effluents on dissolved oxygen, gas supersaturation, 15 and eutrophication. Because nuclear power plant effluents are heated, discharged water can 16 change certain biological conditions in the receiving water body in a manner that affects the 17 characteristics of that habitat and the potential suitability of that habitat for local fish, shellfish, 18 and other aquatic organisms.
19 Aerobic organisms, such as fish, require oxygen, and the concentration of dissolved oxygen in a 20 water body is one of the most important ecological water quality parameters. Dissolved oxygen 21 also influences several inorganic chemical reactions. In general, dissolved oxygen 22 concentrations of less than 3 parts per million (ppm) in warmwater habitats or less than 5 ppm in 23 coldwater habitats can adversely affect fish (Morrow and Fischenich 2000). Oxygen dissolves 24 into water via diffusion, aeration, and as a product of photosynthesis. The amount of oxygen 25 water can absorb depends on temperature; the amount of oxygen that can dissolve in a volume 26 of water (i.e., the saturation point) is inversely proportional to the temperature of the water.
27 Thus, when other chemical and physical conditions are equal, the warmer the water is, the less 28 dissolved oxygen it can hold. Increased water temperatures also affect the amount of oxygen 29 that aquatic organisms need by increasing metabolic rates and chemical reaction rates. The 30 rates of many chemical reactions in water approximately doubles for every 18 °F (10 °C) 31 increase in temperature.
32 The thermal effluent discharges of nuclear power plants have the potential to stress aquatic 33 organisms by simultaneously increasing these organisms need for oxygen and decreasing 34 oxygen availability. Aquatic organisms are more likely to experience adverse effects from 35 thermal effluents in ecosystems where dissolved oxygen levels are already approaching 36 suboptimal levels caused by other factors in the environment. This is most likely to occur in 37 ecosystems where increased levels of detritus and nutrients (e.g., eutrophication), low flow, and 38 high ambient temperatures already exist. These conditions can occur during drought conditions 39 or in hot weather, especially in lakes, reservoirs, or other dammed freshwater.
40 Although the thermal effluents of nuclear power plants may contribute to reduced dissolved 41 oxygen in the immediate vicinity of the discharge point, as the effluent disperses, diffusion and 42 aeration from turbulent movement introduce additional oxygen into the water. As the water 43 cools, the saturation point increases, and the water can absorb additional oxygen as it is 44 released by aquatic plants and algae through photosynthesis, which is a continuously ongoing 45 process during daylight hours. Therefore, lower dissolved oxygen is generally only a concern 2-43
 
1 within the thermal mixing zone, which is typically a small area of the receiving water body. Many 2 States address thermal mixing zones in State water quality criteria to ensure that mixing zones 3 provide a continuous zone of passage for aquatic organisms. Additionally, the EPA, or 4 authorized States and Tribes, often imposes conditions specifically addressing dissolved 5 oxygen through NPDES permits to ensure that receiving water bodies maintain adequate levels 6 of oxygen to support aquatic life. These conditions are established pursuant to CWA 7 Section 316(a), which requires that regulated facilities operate under effluent limitations that 8 assure the protection and propagation of a balanced, indigenous population of shellfish, fish, 9 and wildlife in and on the receiving water body.
10 Rapid heating of cooling water can also affect the solubility and saturation point of other 11 dissolved gases, including nitrogen. As water passes through the condenser cooling system of a 12 nuclear power plant, it can become supersaturated with gases. Once the supersaturated water 13 is discharged in the receiving water body, dissolved gas levels equilibrate as the effluent cools 14 and mixes with ambient water. This process is of concern if aquatic organisms remain in the 15 supersaturated effluent for a long enough period to become equilibrated to the increased 16 pressure associated with the effluent. If these organisms then move into water of lower pressure 17 too quickly when, for example, swimming out of the thermal effluent or diving to depths, the 18 dissolved gases within the affected tissues may come out of solution and form embolisms 19 (bubbles). The resulting condition is known as gas bubble disease. In fish, it is most noticeable 20 in the eyes and fins. Affected tissues can swell or hemorrhage and result in behavioral 21 abnormalities, increased susceptibility to predation, or death. Mortality in fish generally occurs at 22 gas supersaturation levels above 110 or 115 percent (EPA 1986). Aquatic insects and 23 crustaceans appear to be more tolerant of supersaturated water (Nebeker et al. 1981).
24 The ability to detect and avoid supersaturated waters varies among species. A fish can avoid 25 supersaturated waters by either not entering the affected area or by diving to avoid the onset of 26 supersaturated conditions near the surface. Some species, however, may not avoid 27 supersaturated waters until symptoms of gas bubble disease occur; at that point, some fish may 28 already be lethally exposed. Other species may be attracted to supersaturated waters because 29 it is often warmer (Gray et al. 1983).
30 The 1996 LR GEIS and the 2013 LR GEIS report cases of fish mortality from gas bubble 31 disease at hydroelectric dams and coal-fired power plants. Typically, gas bubble disease is of 32 concern at facilities where the configuration of the discharge allows organisms to reside in the 33 supersaturated effluent for extended periods of time (e.g., discharge canals that fish can freely 34 enter). However, fish mortality from gas bubble disease has been observed in only one instance 35 in the mid-1970s at a nuclear power plant that is no longer operating.
36 An early concern about nuclear power plant discharges was that thermal effluents would cause 37 or speed eutrophication by stimulating biological productivity in receiving water bodies (NRC 38 1996). Eutrophication is the gradual increase in the concentration of phosphorus, nitrogen, and 39 other nutrients in a slow-flowing or stagnant aquatic ecosystem, such as a lake. These nutrients 40 enter the ecosystem primarily through runoff from agricultural land and impervious surfaces.
41 The increase in nutrient content allows algae to proliferate on the waters surface, which 42 reduces light penetration and oxygen absorption necessary for underwater life. The 1996 LR 43 GEIS reports that several nuclear power plants conducted long-term monitoring to investigate 44 this potential effect. No evidence of eutrophication was detected.
45 The 1996 LR GEIS (NRC 1996) and the 2013 LR GEIS (NRC 2013a) concluded that the effects 46 of nuclear power plant cooling water discharge on dissolved oxygen, gas supersaturation, and 2-44
 
1 eutrophication would be SMALL during the initial license renewal term. The 1996 LR GEIS 2 evaluated these concerns as three issues; the 2013 LR GEIS consolidated them into one issue.
3 In its environmental review of the FPL application for initial license renewal for Turkey Point 4 (NRC 2002a), the NRC staff found no new and significant information concerning these issues 5 and adopted the 1996 LR GEISs conclusion of SMALL impacts for Turkey Point initial license 6 renewal. Also, the Turkey Point FSEIS adopted the 2013 LR GEISs conclusion of SMALL 7 impacts for SLR. Below, the NRC staff analyzes this issue on a site-specific basis for the Turkey 8 Point SLR term.
9 Section 3.7.3 of the FSEIS describes the aquatic community of the CCS. Specifically, it 10 describes a CCS characterization study that Ecological Associates, Inc. performed in 2016.
11 Aquatic sampling identified only four taxa of fish and shellfish within the CCS: sheepshead 12 minnow (Cyprinodon variegatus), sailfin molly (Poecilia latipinna), eastern mosquitofish 13 (Gambusia holbrooki), and mudflat fiddler crabs (Uca rapax) (EAI 2017). Sampling yielded three 14 taxa of benthic macroinvertebrates. The polychaete Capitella capitate was the most common 15 taxon collected followed by marine oligochaetes (Class Oligochaeta) and midge larvae (Family 16 Chironomidae) (EAI 2017). Because there are no surface water connections that allow flow 17 between the CCS and any natural water bodies, no additional aquatic species can be expected 18 to colonize the CCS.
19 In the FSEIS, the NRC staff described the current CCS aquatic community as being of low 20 diversity and including only those species that can withstand hot, hypersaline waters with low 21 dissolved oxygen and poor water clarity. Therefore, lowered dissolved oxygen resulting from 22 Turkey Points thermal effluent is unlikely to noticeably affect the aquatic species present in the 23 CCS. Further, these conditions would only be experienced in the immediate vicinity of the 24 discharge, and fish and other aquatic organisms could swim or move away from this area to 25 escape these conditions. For these reasons and because Turkey Point operations during the 26 SLR term would continue current operating conditions, the NRC staff does not expect reduced 27 dissolved oxygen resulting from Turkey Points thermal effluent to be of concern during the SLR 28 period.
29 With respect to gas supersaturation, FPL has not reported any instances of fish kills at Turkey 30 Point or any other information indicating that fish in the CCS may have experienced symptoms 31 of gas bubble disease. Because Turkey Point operations during the SLR term would continue 32 current operating conditions, gas supersaturation resulting from Turkey Points thermal effluent 33 is not expected to be of concern during the SLR period.
34 With respect to eutrophication, in 2010, the CCS began experiencing a pronounced ecosystem 35 shift. The average salinity of the CCS increased, water quality and clarity began to degrade, and 36 average surface water temperatures increased. Seagrass colonies began to die off due to 37 salinity- and high temperature-related stress. By 2012, very few seagrass beds remained in the 38 CCS. The subsequent decomposition of the seagrasses released a significant volume of 39 nutrients into the CCS, and the increased nutrient levels facilitated algae blooms, which resulted 40 in high turbidity and degraded water quality. Algae blooms remained local and isolated in 2011 41 and 2012. In 2013 and 2014, continuously elevated concentrations of algae were observed 42 throughout the CCS. By 2016, no seagrasses remained in the CCS. In 2019 when the NRC 43 issued the FSEIS (NRC 2019a), the CCS was operating as an algal-based, phosphorus-limited 44 system such that the algae life cycle primarily dictated the movement of nutrients in and out of 45 the water column.
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1 In 2017, FPL began implementing a Nutrient Management Plan for the CCS as a requirement of 2 the 2016 Consent Order between FPL and the State of Florida. One component of this plan is 3 for FPL to take the necessary actions to ensure acceptable nutrient levels in the CCS.
4 Section 3.5.1.4 of the FSEIS (NRC 2019a) describes the components and requirements of this 5 plan in detail. FPLs recent monitoring results under this plan indicate that the CCS is no longer 6 in a state of eutrophication. Total nitrogen and total phosphorus collected at CCS monitoring 7 stations from April 2019 through September 2022 show low total phosphorus concentrations 8 (ranging from between 0.01 to 0.05 mg/L) and a significant decline in total nitrogen. Dissolved 9 oxygen concentrations averaged 5.0 mg/L from October 2020 through June 2022. Since 10 September 2021, FPL has documented a clear decreasing trend in chlorophyll-a concentrations, 11 decreased turbidity, and increased water clarity, all of which parallel a decline in algae 12 concentrations. Seagrass plantings have also facilitated these improved conditions. (FPL 13 2023a) 14 These changes, along with salinity decreases, appear to be driving the CCS ecosystem toward 15 a new equilibrium characterized by lower algal densities, lower particulate nutrient loads, and 16 improved water clarity. Because FPL is required to continue implementing the Nutrient 17 Management Plan, CCS water quality is expected to continue to improve, and eutrophication is 18 not expected to be of concern during the SLR period.
19 Turkey Point operations during the SLR term would continue current operating conditions and 20 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 21 current operations and SLR would be similar. For these reasons, the effects of dissolved 22 oxygen, gas supersaturation, and eutrophication would be minor and would neither destabilize 23 nor noticeably alter any important attribute of the aquatic environment during the SLR term.
24 Accordingly, the NRC staff concludes that the effects of dissolved oxygen, gas supersaturation, 25 and eutrophication on aquatic resources due to continued nuclear power plant operations at 26 Turkey Point during the SLR term would be SMALL.
27 2.10.4      Effects of Nonradiological Contaminants on Aquatic Organisms 28 This issue concerns the potential effects of nonradiological contaminants on aquatic organisms 29 that could occur as a result of nuclear power plant operations. This issue was originally of 30 concern because some nuclear power plants used heavy metals in condenser tubing that could 31 leach from the tubing and expose aquatic organisms to these contaminants. Because aquatic 32 organisms can bioaccumulate heavy metals, even when exposed at low levels, this can cause 33 toxicity in fish and other animals that consume contaminated organisms. Section 3.9.2 of the 34 2013 LR GEIS (NRC 2013a) describes instances in which copper contamination was an issue 35 at operating nuclear power plants. Heavy metals have not been found to be of concern other 36 than in these few instances. In all cases, the nuclear power plants eliminated leaching by 37 replacing the affected piping, and these changes were implemented during the initial operating 38 license terms. The NRC staff has not identified this issue to be of concern during any license 39 renewal reviews to date.
40 The 1996 LR GEIS (NRC 1996) and the 2013 LR GEIS (NRC 2013a) concluded that the effects 41 of nonradiological contaminants on aquatic organisms would be SMALL during the initial license 42 renewal term. In its environmental review of the FPL application for initial license renewal for 43 Turkey Point (NRC 2002a), the NRC staff found no new and significant information concerning 44 these issues and adopted the 1996 LR GEISs conclusion of SMALL impacts for Turkey Point 45 initial license renewal. Also, the FSEIS for the SLR of Turkey Point adopted the 2013 LR GEISs 2-46
 
1 conclusion of SMALL impacts for SLR. Below, the NRC staff analyzes this issue on a site-2 specific basis for the Turkey Point SLR term.
3 Section 2.7.2 of the FSEIS addresses the discharge of metals in cooling system effluent. As 4 explained in that section, Turkey Points NPDES permit establishes allowable levels of zinc, 5 copper, and iron in wastewater discharges, including stormwater, through two internal outfalls 6 into the CCS. The permit requires FPL to sample and report levels of these metals to the FDEP 7 to demonstrate compliance. Additionally, in 2022, the FDEP instituted a new condition in the 8 NPDES permit that requires FPL to implement a Best Management Practices Plan to prevent or 9 minimize the generation and the potential for the release of pollutants, including mercury, 10 copper, iron, zinc, and nutrients, from plant operations (including spillage, leaks, and material 11 and waste handling and storage activities) to wastewater and stormwater in the CCS. The NRC 12 staff reviewed FPLs NPDES monitoring reports for the past 5 years, and FPL has reported no 13 violations related to the discharge of metals in wastewater or stormwater discharges.
14 Additionally, as described in Section 3.7.4 of the FSEIS, since 2010, FPL has commissioned 15 Ecology and Environment, Inc. to perform ongoing, semiannual ecological monitoring of the 16 Turkey Point site and surrounding environment as a requirement of FDEPs Conditions of 17 Certification in connection with the Turkey Point extended power uprate and the SFWMDs Fifth 18 Supplemental Agreement. With respect to the aquatic environment, Ecology and Environment, 19 Inc. monitors the CCS within the Turkey Point site, as well as three locations adjacent to the 20 CCS within Biscayne Bay and Card Sound and one reference site in Barnes Sound that lies 21 directly south of Card Sound. Ecological monitoring encompasses a total of 16 sampling points 22 per study area and a total of 64 sampling points across all study areas. At each sampling 23 location, researchers collect general physical parameters and quantitative and qualitative data 24 about the submerged aquatic vegetation to characterize and observe changes in the ecological 25 characteristics over time. FPL samples Biscayne Bay and Card Sound seagrasses biannually to 26 monitor changes in cover and faunal composition over time and with distance from the CCS.
27 Researchers qualitatively assess each sampling location for overall condition; presence or 28 absence of seagrass, green algae (Bataphora spp.), and drift algae; amount of calcerous algae, 29 sponges, and hard and soft corals; and substrate type and depth. Researchers also collect turtle 30 grass (Thalassia testudinum) blades and process them in a laboratory for nutrient analysis.
31 FPLs reports have consistently demonstrated that the marsh and mangrove areas are 32 representative of the hydrologically modified or nutrient-limited communities found along the 33 coastal fringe of south Florida. Data indicate that the CCS does not have an ecological impact 34 on the surrounding areas, and there is no clear evidence of CCS water in the surrounding 35 marsh or mangrove areas from a groundwater pathway. Rather, ecological changes observed 36 during the reporting period are more seasonally and meteorologically driven. Section 3.7.4 of 37 the FSEIS describes the methods and results of these monitoring efforts in detail. To date, 38 ecological monitoring has not detected evidence of any impacts from the CCS on the 39 surrounding area, including Biscayne Bay and Card Sound (FPL 2022a).
40 Turkey Point operations during the SLR term would continue current operating conditions and 41 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 42 current operations and SLR would be similar. For these reasons, the effects of nonradiological 43 contaminants on aquatic organisms would be minor and would neither destabilize nor noticeably 44 alter any important attribute of the aquatic environment during the SLR term. Accordingly, the 45 NRC staff concludes that the effects of nonradiological contaminants on aquatic organisms due 46 to continued nuclear power plant operations at Turkey Point during the SLR term would be 47 SMALL.
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1 2.10.5    Exposure of Aquatic Organisms to Radionuclides 2 This issue concerns the potential impacts on aquatic organisms of exposure to radionuclides 3 from routine radiological effluent releases. As explained in Section 2.9.1 of this EIS, 4 radionuclides may be released from nuclear power plants into the environment through several 5 pathways, including via gaseous and liquid emissions. Aquatic plants can absorb through their 6 roots radionuclides that enter shallow groundwater or surface waters. Aquatic animals can be 7 exposed externally to ionizing radiation from radionuclides in water, sediment, and other biota, 8 and can be exposed internally through ingested food, water, and sediment and absorption 9 through the integument and respiratory organs.
10 As discussed in Section 2.9.1 of this EIS, the DOE has produced a standard for a graded 11 approach to evaluating radiation doses to aquatic and terrestrial biota (DOE 2019). The DOE 12 standard provides methods, models, and guidance that can be used to characterize radiation 13 doses to terrestrial and aquatic biota exposed to radioactive material (DOE 2019). For aquatic 14 animals, the DOE guidance dose rate is 1 rad/d (0.1 Gy/d), which represents the level below 15 which no adverse effects on resident populations are expected. The DOE also recommends that 16 the screening-level concentrations of most radionuclides in aquatic environments be based on 17 internal exposure as well as external exposure to contaminated sediments, rather than external 18 exposure to contaminated water (DOE 2019).
19 Previously, in the early 1990s, the IAEA (1992) and the National Council on Radiation 20 Protection and Measurements (NCRP 1991) had also concluded that a chronic dose rate of no 21 greater than 1 rad/d (0.01 Gy/d) to the maximally exposed individual in a population of aquatic 22 organisms would ensure protection of the population. The UNSCEAR concluded in 1996 and 23 reaffirmed in 2008 that chronic dose rates of less than 0.4 mGy/hr (1.0 rad/day or 0.01 Gy/day) 24 to the most highly exposed individuals would be unlikely to have significant effects on most 25 aquatic communities (UNSCEAR 2010).
26 In the 2013 LR GEIS (NRC 2013a), the NRC estimated the total radiological dose that aquatic 27 biota would be expected to receive during normal nuclear power plant operations using plant-28 specific radionuclide concentrations in water and sediments at 15 nuclear power plants using 29 the Argonne National Laboratorys RESRAD-BIOTA dose evaluation model. The NRC found 30 that total calculated dose rates for aquatic animals at all 15 plants were all less than 0.2 rad/d 31 (0.002 Gy/d), which is less than the guideline value of 1 rad/d (0.01 Gy/d). As a result, the NRC 32 anticipated in the 2013 LR GEIS that normal operations of these plants would not result in 33 negative effects on aquatic biota. The 2013 LR GEIS concluded that the impact of radionuclides 34 on aquatic biota from past operations would be SMALL for all nuclear power plants and would 35 not be expected to change appreciably during the initial license renewal period.
36 The NRC staff did not specifically address the exposure of aquatic organisms to radionuclides 37 as part of its environmental review of the FPL application for initial license renewal for Turkey 38 Point (NRC 2002a) because that issue was not addressed in the 1996 LR GEIS, upon which the 39 environmental review relied. The 2013 LR GEIS, however, did later address the issue 40 generically for initial license renewal of all nuclear power plants and concluded that impacts 41 would be SMALL and, accordingly, the FSEIS for the SLR of Turkey Point adopted that 42 conclusion. Below, the NRC staff analyzes this issue on a site-specific basis for the Turkey 43 Point SLR term.
44 As discussed in Section 2.9.1 of this EIS, the NRC requires nuclear power plants to maintain a 45 REMP and to obtain data about measurable levels of radiation and radioactive material in the 2-48
 
1 environment. FPL established its REMP before Turkey Point began commercial operations, and 2 it continues to monitor direct radiation and sample air, water, sediment, crustaceans, fish, and 3 broadleaf vegetation annually for radionuclides. FPL reports the results of its monitoring to the 4 NRC. Since Turkey Point began operating, REMP results have not indicated any significant 5 radiological impacts on the surrounding environment attributable to Turkey Point operations.
6 As part of its environmental review, the NRC staff reviewed the past 5 years of REMP reports 7 (FPL 2018i, 2019a, 2020b, 2021b, 2022e). During this period, the concentrations of 8 radionuclides detected in air, shoreline, crustaceans, and fish samples were below the LLD.
9 Surface water samples yielded detectable tritium in 8 to 16 percent of indicator sample locations 10 each year at levels ranging from 93 to 128 pCi/L. Tritium concentrations were consistent with 11 those detected in previous operational years and were all well below the reportable level of 12 30,000 pCi/L.
13 In summary, NRC regulations require nuclear power plants to monitor radiation in the 14 environment and to report the results of such monitoring to the NRC through a REMP. The 15 conduct of REMP monitoring ensures that levels of radiation are below regulatory limits and that 16 any changes in radionuclide concentrations are detected and addressed. To date, FPL has not 17 detected levels of radioactivity attributable to Turkey Point operations that would result in 18 measurable radiological impacts on aquatic organisms. Turkey Point operations during the SLR 19 term would continue current operating conditions and environmental stressors rather than 20 introduce wholly new impacts. For these reasons, radiological impacts would be minor and 21 would neither destabilize nor noticeably alter any important attribute of the aquatic environment 22 during the SLR term. Accordingly, the NRC staff concludes that the exposure of aquatic 23 organisms to radionuclides due to continued nuclear power plant operations at Turkey Point 24 during the SLR term would be SMALL.
25 2.10.6    Effects of Dredging on Aquatic Organisms 26 This issue concerns the effects of dredging at nuclear power plants on aquatic resources.
27 Small-particle sediment, such as sand and silt, that enters water bodies through erosion can 28 subsequently deposit and accumulate along shorelines and in shallow water areas. If sediment 29 deposition affects cooling system function or reliability, a nuclear power plant may need to 30 periodically dredge to improve intake flow and keep the area clear of sediment. Nuclear power 31 plants where dredging may be necessary are typically located along fast-flowing waters that 32 feature sandy or silty bottoms, such as large rivers or the ocean. In some instances, dredging 33 may be performed to maintain barge slips for transport of materials and waste to and from the 34 site. Dredging entails excavating a layer of sediment from the affected areas and transporting 35 that sediment to onshore or offshore areas for disposal. The three main types of dredges are 36 mechanical dredges, hydraulic dredges, and airlift dredges. The selection of dredge type 37 generally is related to the sediment type, the size of the area to be dredged, and the aquatic 38 resources present. At operating nuclear power plants, dredging is performed infrequently, if at 39 all.
40 In its environmental review of the FPL application for initial license renewal for Turkey Point 41 (NRC 2002a), the NRC staff did not consider dredging because FPL did not anticipate that 42 dredging would be required during the Turkey Point initial license renewal period. The 2013 LR 43 GEIS (NRC 2013a) analyzed the effects of dredging on aquatic organisms as a new issue and 44 concluded that the effects of this issue would be SMALL during the initial license renewal term 45 for all nuclear power plants. The FSEIS for the SLR of Turkey Point adopted the 2013 LR 2-49
 
1 GEISs conclusion of SMALL impacts for SLR. Below, the NRC staff analyzes this issue on a 2 site-specific basis for the Turkey Point SLR term.
3 FPL anticipates no dredging during the SLR term (FPL 2022a). Therefore, there would be no 4 impacts on aquatic resources. However, if FPL were to determine at a future date that dredging 5 was necessary to, for instance, provide adequate clearance for barge deliveries, such dredging 6 would require FPL to obtain permits from the USACE under CWA Section 404. BMPs and 7 conditions associated with those permits would minimize impacts on the environment. The 8 process of granting such permits would also require the USACE to conduct environmental 9 reviews prior to FPL undertaking dredging.
10 The NRC staff expects that the effects of dredging on aquatic resources would be minor and 11 would neither destabilize nor noticeably alter any important attribute of the aquatic environment 12 during the SLR term. The NRC staff expects that FPL would continue to implement site 13 environmental procedures and would obtain any necessary permits for dredging activities, if 14 determined necessary. Implementation of such controls would further reduce or mitigate 15 potential effects on the environment. Accordingly, the NRC staff concludes that the effects of 16 dredging on aquatic resources due to continued nuclear power plant operations at Turkey Point 17 during the SLR term would be SMALL.
18 2.10.7      Effects on Aquatic Resources (Non-Cooling System Impacts) 19 This issue concerns the effects of nuclear power plant operations on aquatic resources that are 20 unrelated to operation of the cooling system. Such activities include landscape and grounds 21 maintenance, stormwater management, and ground-disturbing activities that could directly 22 disturb aquatic habitat or cause runoff or sedimentation. These impacts are expected to be like 23 past and ongoing impacts that aquatic resources are already experiencing at the nuclear power 24 plant site.
25 The 1996 LR GEIS (NRC 1996) and the 2013 LR GEIS (NRC 2013a) concluded that the non-26 cooling system impacts on aquatic resources would be SMALL during the initial license renewal 27 term. In the 1996 LR GEIS, the NRC evaluated the impacts of refurbishment on aquatic 28 resources. In the 2013 LR GEIS, the NRC expanded this issue to include impacts of other site 29 activities, unrelated to cooling system operation, that may affect aquatic resources. In its 30 environmental review of the FPL application for initial license renewal for Turkey Point (NRC 31 2002a), the NRC staff found no new and significant information concerning this issue and 32 adopted the 1996 LR GEISs conclusion of SMALL impacts for Turkey Point initial license 33 renewal. Also, the FSEIS for the SLR of Turkey Point adopted the 2013 LR GEISs conclusion 34 of SMALL impacts for SLR. Below, the NRC staff analyzes this issue on a site-specific basis for 35 the Turkey Point SLR term.
36 Within the Turkey Point site, aquatic features include hypersaline mudflats, remnant canals, 37 channels, dwarf mangrove wetlands, and areas of open water. These features are part of, or 38 located adjacent to, the CCS, mangrove swamp, and tidal flats located outside of the developed 39 area of the site, and a barge basin adjacent to Biscayne Bay. As explained in Section 4.6.1.1 of 40 the FSEIS, environmental impacts from landscape maintenance, ground-disturbing activities, 41 and other operational activities would be minimized because FPL maintains environmental 42 control procedures for any activities that result in the clearing of land, excavation, or other 43 activity that would alter the physical environment or ecology of the site (FPL 2018b). FPLs 44 procedures direct personnel to obtain appropriate local, State, or Federal permits (or some 45 combination of the three) before beginning work; implement best practices to protect wetlands, 2-50
 
1 natural heritage areas, and sensitive ecosystems; and consult the appropriate agencies 2 wherever federally or State-listed species may be affected. The Turkey Point Environmental 3 Protection Plan contained in Appendix B of the subsequent renewed operating licenses requires 4 FPL to prepare an environmental evaluation for any construction or operational activities that 5 may significantly affect the environment (NRC 2019d). If such an evaluation indicates that an 6 activity involves an unreviewed environmental question, the Turkey Point Environmental 7 Protection Plan requires that FPL obtain approval from the NRC before performing the activity 8 (NRC 2019d).
9 With respect to stormwater management, stormwater runoff from impervious surfaces can 10 change the frequency or duration of inundation and soil infiltration within wetlands, mangroves, 11 and neighboring terrestrial habitats. The effects of stormwater runoff may include erosion, 12 altered hydrology, sedimentation, and other changes in plant community characteristics. Runoff 13 may contain sediments, contaminants and oils from road or parking surfaces, or herbicides. At 14 Turkey Point, stormwater collected in drainage channels and floor drains is discharged directly 15 to the CCS. Turkey Point does not discharge stormwater directly into Biscayne Bay or any other 16 surface waters other than the CCS. Use of the stormwater conveyance system, which collects 17 stormwater, minimizes the amount of excess runoff that terrestrial habitats would receive and 18 the associated effects. FDEP regulations require a stormwater permit and SWPPP for any 19 construction activities or activities that would result in the clearing of land, excavation, or other 20 action that would alter the physical environment or ecology of the site. FPLs SWPPP identifies 21 potential sources of pollutants that could affect stormwater discharges and identifies BMPs that 22 FPL uses to reduce pollutants in stormwater discharges to ensure compliance with applicable 23 conditions of the permit (FPL 2023b). The BMPs include soil stabilization, such as seeding and 24 structural controls (e.g., silt fences). FPL has also developed an SPCC plan that identifies and 25 describes the procedures, materials, equipment, and facilities that are used to minimize the 26 frequency and severity of oil spills (FPL 2018a). Collectively, these measures ensure that the 27 effects on aquatic resources from pollutants carried by stormwater would be minimized during 28 the SLR term.
29 Turkey Point operations during the SLR term would continue current operating conditions and 30 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 31 current operations and SLR would be similar. For these reasons, non-cooling system impacts 32 on aquatic resources would be minor and would neither destabilize nor noticeably alter any 33 important attribute of the environment during the SLR term. Accordingly, the NRC staff 34 concludes that non-cooling system impacts on aquatic resources due to continued nuclear 35 power plant operations at Turkey Point during the SLR term would be SMALL.
36 2.10.8      Impacts of Transmission Line Right-of-Way Management on Aquatic Resources 37 This issue concerns the effects of transmission line ROW management on aquatic plants and 38 animals. Transmission line management can directly disturb aquatic habitats if ROWs traverse 39 aquatic features and heavy machinery is used in these areas. Heavy equipment can also 40 compact soils, which can affect soil quality and reduce infiltration to shallow groundwater, 41 resulting in runoff and erosion in nearby aquatic habitats. Chemical herbicides applied in ROWs 42 can be transported to nearby aquatic habitats through precipitation and runoff. For small 43 streams, trees may grow sufficiently between cutting cycles to provide shading and support 44 microhabitats. Tree removal to maintain appropriate transmission line clearance could alter the 45 suitability of habitats for fish and other aquatic organisms and locally increase water 46 temperatures.
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1 The 1996 LR GEIS (NRC 1996) and the 2013 LR GEIS (NRC 2013a) concluded that the 2 impacts of transmission line ROW management on aquatic resources would be SMALL during 3 the initial license renewal term. In its environmental review of the FPL application for initial 4 license renewal for Turkey Point (NRC 2002a), the NRC staff found no new and significant 5 information concerning this issue and adopted the 1996 LR GEISs conclusion of SMALL 6 impacts for Turkey Point initial license renewal. Also, the FSEIS for the SLR of Turkey Point 7 adopted the 2013 LR GEISs conclusion of SMALL impacts for SLR. Below, the NRC staff 8 analyzes this issue on a site-specific basis for the Turkey Point SLR term.
9 As explained in Section 2.9.4 of this EIS, which discusses the impacts of transmission line ROW 10 management on terrestrial resources, the transmission lines within the scope of the Turkey 11 Point SLR review are contained within the industrial use portion of the site. They do not cross 12 any natural areas and vegetation management is not required. Therefore, maintenance of these 13 lines has no discernible effect on ecological resources.
14 Turkey Point operations during the SLR term would continue current operating conditions and 15 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 16 current operations and SLR would be similar. For these reasons, the effects of transmission line 17 ROW management on aquatic resources would be minor and would neither destabilize nor 18 noticeably alter any important attribute of plant or animal populations during the SLR term.
19 Accordingly, the NRC staff concludes that the impacts of transmission line ROW management 20 on aquatic resources due to continued nuclear power plant operations at Turkey Point during 21 the SLR term would be SMALL.
22 2.10.9      Losses from Predation, Parasitism, and Disease Among Organisms Exposed to 23            Sublethal Stresses 24 This issue concerns the effects of nuclear power plant operation that can increase the 25 susceptibility of aquatic organisms to predation, parasitism, and disease. Such sublethal effects 26 can result from impingement, if an organism is subsequently returned to the source water body, 27 as well as from exposure to thermal effluents. This issue does not apply to entrainment.
28 Because entrainable organisms generally consist of fragile life stages, all entrained organisms 29 are assumed to die (79 FR 48300) and would, therefore, not survive entrainment to 30 subsequently experience sublethal effects.
31 The 1996 LR GEIS (NRC 1996) and the 2013 LR GEIS (NRC 2013a) concluded that the losses 32 from predation, parasitism, and disease among organisms exposed to sublethal stresses would 33 be SMALL during the initial license renewal term. In its environmental review of the FPL 34 application for initial license renewal for Turkey Point (NRC 2002a), the NRC staff found no new 35 and significant information concerning this issue and adopted the 1996 LR GEISs conclusion of 36 SMALL impacts for Turkey Point initial license renewal. Also, the FSEIS for the SLR of Turkey 37 Point adopted the 2013 LR GEISs conclusion of SMALL impacts for SLR. Below, the NRC staff 38 analyzes this issue on a site-specific basis for the Turkey Point SLR term.
39 As established in Section 2.10 of this EIS, aquatic organisms inhabiting Biscayne Bay are not 40 subject to impingement or the effects associated with exposure to thermal effluents because 41 there are no surface water connections that allow flow between the waters of Biscayne Bay and 42 the CCS. Therefore, the discussion below pertains to aquatic organisms in the CCS.
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1 2.10.9.1    Sublethal Effects of Impingement 2 The EPAs 2014 CWA Section 316(b) regulations establish best technology available standards 3 for impingement mortality. Impingement mortality considers the survival rate of impinged 4 organisms, rather than simply the total number of organisms impinged. Survival studies typically 5 consider latent mortality associated with stunning, disorientation, or injury. Such effects can 6 result from the injury itself or from increased susceptibility to predation, parasitism, or disease 7 that results from the sublethal effects of impingement. As explained in Section 4.7.1.1 of the 8 FSEIS (NRC 2019a), the Turkey Point intake system does not include a fish return system, and 9 FPL has no plans to alter the design or function of the cooling system during the SLR term.
10 Therefore, all impingements would result in mortality, and the issue of sublethal effects from 11 impingement does not apply to Turkey Point SLR.
12 2.10.9.2    Sublethal Effects of Thermal Effluents 13 Fish and shellfish that are exposed to the thermal effluent of a nuclear power plant may 14 experience stunning, disorientation, or injury. These sublethal effects can subsequently affect 15 an organisms susceptibility to predation, parasitism, or disease.
16 With respect to susceptibility to predation, laboratory studies of the secondary mortality of fish 17 following exposure to heat or cold shock demonstrate the increased susceptibility of these fish 18 to predation; however, field evidence of such effects is often limited to anecdotal information, 19 such as observations of the increased feeding activity of seagulls and predatory fish near 20 effluent outfalls (e.g., Cada et al. 1981). For example, Barkley and Perrin (1971) and Romberg 21 et al. (1974) reported increased concentrations of predators feeding on forage fish attracted to 22 thermal plumes. However, these studies did not quantify whether the observed behaviors 23 resulted in population-level effects on prey species.
24 With respect to susceptibility to parasitism and disease, Langford (1983) found that the 25 tendency for fish to congregate in heated effluent plumes, the increased physiological stress 26 that higher water temperatures exert on fish, and the ability of some diseases and parasites to 27 proliferate at higher temperatures were all factors that could contribute to increased rates of 28 disease or parasitism in exposed fish. Some studies have suggested that crowding of fish within 29 the thermal plume, rather than the thermal plume itself, may lead to an increased risk of 30 exposure to infectious diseases (Coutant 1987).
31 The 1996 LR GEIS and the 2013 LR GEIS reported that neither scientific literature reviews nor 32 consultations with agencies or utilities yielded clear evidence of nuclear power plant operation 33 causing sublethal effects that result in noticeable increases in the susceptibility of exposed 34 organisms to predation, parasitism, or disease. FPL reported no evidence of such effects, and 35 FPLs continued implementation of its thermal efficiency plan would continue to improve CCS 36 conditions and mitigate any potential effects (FPL 2022a).
37 Turkey Point operations during the SLR term would continue current operating conditions and 38 environmental stressors rather than introduce wholly new impacts. Therefore, the impacts of 39 current operations and SLR would be similar. For these reasons, losses from predation, 40 parasitism, and disease among organisms exposed to sublethal stresses would be minor and 41 would neither destabilize nor noticeably alter any important attribute of aquatic populations 42 during the SLR term. Accordingly, the NRC staff concludes that the impacts of losses from 43 predation, parasitism, and disease among organisms exposed to sublethal stresses due to 44 continued nuclear power plant operations at Turkey Point during the SLR term would be 45 SMALL.
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1 2.11 Socioeconomics 2 Turkey Point and the communities that support it can be described as a dynamic socioeconomic 3 system. The communities supply the people, goods, and services required to operate the 4 nuclear power plant. Power plant operations, in turn, supply wages and benefits for people and 5 dollar expenditures for goods and services. The measure of a communitys ability to support 6 Turkey Point operations depends on the communitys ability to respond to changing 7 environmental, social, economic, and demographic conditions. The following sections address 8 the site-specific environmental impacts of Turkey Point SLR on five environmental issues 9 related to socioeconomics. The majority of Turkey Point permanent workers (85 percent) and 10 contract workers (80 percent) reside in Miami-Dade County, and the most significant 11 socioeconomic effects of plant operations are likely to occur in that county. The focus of the 12 impact analysis and region of influence, therefore, is on the socioeconomic impacts of continued 13 Turkey Point operations during the SLR term on Miami-Dade County.
14 2.11.1    Employment and Income, Recreation and Tourism 15 Nuclear power plants generate employment and income in the local economy. Therefore, 16 continued operations and refurbishment associated with license renewal can affect employment, 17 income, recreation, and tourism. Nuclear power plant operation provides employment and 18 income and pays for goods and services. Wages, salaries, and expenditures generated by 19 nuclear power plant operation create demand for goods and services in the local economy, 20 while wage and salary spending by workers creates additional demand for services and 21 housing. Additional employment and expenditures occur during refueling and maintenance 22 outages and any refurbishment activities at nuclear power plants. Payments for these goods 23 and services create additional employment and income opportunities in the community.
24 Communities located near nuclear power plants in coastal regions experience summer, 25 weekend, and retirement population increases due to the recreational and tourism activities that 26 attract visitors. Some communities attract visitors interested in outdoor recreational activities.
27 The aesthetic impacts of nuclear power plant operations and refurbishment activities could 28 potentially affect tourism and recreational businesses.
29 FPL indicated that there are no planned SLR-related refurbishment activities, and that it has no 30 plans to add additional employees to support plant operations during the Turkey Point SLR term 31 (FPL 2022a). Therefore, SLR would not constitute new employment and new indirect jobs would 32 not be created. FPL employs a permanent workforce of approximately 680 workers, and 33 approximately 85 percent of this workforce resides in Miami-Dade County (FPL 2018a and FPL 34 2022a). In addition to permanent Turkey Point plant employees, FPL hires contract workers to 35 support plant operations. FPL employs approximately 370 onsite contract workers and 80 36 percent of the contract workers reside in Miami-Dade County. Temporary employment is 37 generated during routine outages. During refueling outages, onsite employment typically 38 increases by an additional 1,200 workers for 25-30 days.
39 In 2021, the Miami-Dade County civilian labor force was 1,380,903 individuals, and 1,297,349 40 individuals were employed (USCB 2022c). Turkey Points permanent workforce residing in 41 Miami-Dade County represents a small fraction of Miami-Dade Countys employed civilian labor 42 force. In 2015, the average FPL nuclear power plant employee wage was $97,500 (NEI 2015a).
43 Applying this average wage to the Turkey Point permanent workforce that resides in Miami-44 Dade County results in $56.34 million (97,500 x 680 x 0.85) going into the Miami-Dade County 45 economy. In 2015, total wage earnings in Miami-Dade County were $54,557,797,108 (BLS 46 2015). In 2021, total wage earnings in Miami-Dade County were $65,149,278,279 (BLS 2022).
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1 Annual wage earnings as a result of Turkey Point operations represent 0.1 percent of total wage 2 earnings in Miami-Dade County. Any new employment and wages generated by regularly 3 scheduled plant refueling and maintenance outages would be short-term and temporary.
4 The tourism industry is one of the largest sectors in the local economy in Miami-Dade County.
5 Biscayne National Park and Everglades National Park attract approximately 7,500,000 and 6 1,000,000 visitors a year, respectively (NPS 2020 and NPF Undated). Biscayne National Park 7 and Everglades National Park offer various recreational activities including sightseeing, 8 snorkeling, boating, and fishing. In Section 2.3.1 of this EIS, the NRC staff considered the 9 aesthetic impacts of Turkey Point continued operations during the SLR term and concluded that 10 the impacts would be SMALL.
11 The effects of Turkey Point operations on employment, income, recreation, and tourism are 12 ongoing and have become well established. As discussed above, the number of nuclear power 13 plant operations workers is not expected to change during the SLR term. In addition, tourism 14 and recreational activities in the vicinity of nuclear power plants are not expected to change as a 15 result of SLR. The impacts from operations during the SLR term on employment and income in 16 communities near nuclear power plants are not expected to noticeably change from those 17 currently being experienced. As discussed above, Turkey Point permanent workforce and 18 wages represent a small portion of Miami-Dade Countys employed civilian workforce and total 19 wage earnings. Aesthetic impacts from continued operations during the SLR term are SMALL 20 and therefore are not expected to affect tourism and recreational businesses. Based on these 21 considerations, the NRC staff concludes that the impacts due to continued nuclear power plant 22 operations at Turkey Point during the SLR term on employment, income, recreation, and 23 tourism would be SMALL.
24 2.11.2      Tax Revenues 25 Nuclear power plants provide tax revenue to local jurisdictions in the form of property tax 26 payments, payments in lieu of tax (PILOT) payments, or tax payments related to energy 27 production. Changes in the workforce and property taxes or PILOTs paid to local governments 28 and public schools can directly affect socioeconomic conditions in the counties and communities 29 near the nuclear power plant. Property tax assessments, settlements, and agreements, and 30 State tax laws are continually changing the amount of taxes paid to tax jurisdictions by nuclear 31 power plant owners, independent of license renewal or refurbishment activities. Tax revenues 32 may be used by local, regional, and State governmental entities to fund education, public safety, 33 local government services, and transportation. In smaller rural communities, nuclear power plant 34 tax revenues can affect the level and quality of public services available to local residents. Even 35 in semiurban regions, revenues from nuclear power plants provide support for public services at 36 the local level. The primary impact of continued operation during the SLR term would be the 37 continuation of the receipt of tax revenue to local governments and public school districts.
38 The State of Florida does not have a State-level property tax. Private property owners pay 39 property taxes to the county and a local school district and may also pay taxes to regional taxing 40 districts. In Florida, real estate property and tangible personal property are subject to property 41 tax. Property values are set by the county property appraiser and are collected by the county tax 42 collector. The tax rate (millage) is set by each taxing unit. County and school district 43 governments may levy taxes up to 10 mills ($10.00 per thousand of assessed valuation) each.
44 As discussed below, FPL pays property taxes (real and tangible personal property) for Turkey 45 Point to Miami-Dade County, the Miami-Dade County Public School District, and several 46 regional taxing districts (FPL 2018a and 2022a).
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1 The Miami-Dade County budget comprises appropriations from various revenues. The total 2 Miami-Dade County operating revenues for the years 2018 through 2021 are presented in 3 Table 2-5. Property taxes are a significant source of Miami-Dade County funding. For instance, 4 property tax revenues have ranged from 27 to 37 percent of the total Miami-Dade County 5 revenues between 2018 and 2021 (MDC 2021). Miami-Dade County property taxes fund four 6 separate taxing jurisdictions: Countywide, Unincorporated Municipality Service Area, the Fire 7 Rescue District, and the Library System. Each of the four taxing jurisdictions is responsible for 8 different types of services (MDC 2021). For instance, the Countywide jurisdiction provides public 9 health and social services, transportation, regional parks, and county roads, the court systems, 10 and the regional sheriff services and jails. Additionally, Miami-Dade County has a Countywide 11 debt and a Fire Rescue District debt millage. The revenue raised from the debt service millage 12 pays outstanding debt for voter-approved general or special obligation bonds. The amount of 13 property tax received by a taxing jurisdiction is a result of the millage rate applied by each 14 county taxing jurisdiction. For fiscal year 2020-2021, the total millage rate for Miami-Dade 15 County (Countywide, Unincorporated Municipality Service Area, the Fire Rescue District, and 16 the Library System, Countywide debt, and Fire Rescue District debt) was 9.7779. Miami-Dade 17 County also imposes special district millage. These include the Childrens Trust Authority, the 18 Everglades Construction Project, the Okeechobee Basin, the SFWMD, and the Florida Inland 19 Navigation District. For year 2021, the total millage rate for special district was 0.7502 (MDC 20 2020).
21 Table 2-5        Miami-Dade County Total Operating Revenues, Miami-Dade County School 22                  Board Revenues, and Turkey Point Units 3 and 4 Total Property Tax Paid 23                  (2018-2021)
Property                              2018    2019    2020    2021 Miami-Dade County Total Operating Revenues                        6.385    6.940    7.433  6.743 (in billions of dollars)
Miami-Dade County School Board Revenues                            3.868    3.948    4.120  4.458 (in billions of dollars)
Turkey Point Units 3 and 4 Total Property Tax Paid                0.034    0.045    0.035  0.036 (in billions of dollars)
Percent Payment Assigned to Miami County                          54.4    56.6    55.2    55.4 Percent Payment Assigned to School District                        39.2    39      40.4    40.4 Percent Payment Assigned to Special District                        6.4      4.4      4.4    4.2 24 Sources: MDCPS 2021; MDC 2021; FPL 2022a.
25 The Miami-Dade County Public School District is a taxing entity separate from Miami-Dade 26 County. The Florida Education Finance Program is the primary mechanism for funding the 27 operating costs of Florida school districts (FDE 2022). The Florida Education Finance Program 28 allocates funds to the Miami-Dade County Public School District based on student enrollment 29 (FDE 2022). Funding for school districts comes from State, local, and Federal sources. Local 30 funding is obtained primarily from property taxes levied by Floridas counties, each of which 31 constitutes a school district. Property taxes on properties located within the school district are 32 levied after the millage rate is certified. Table 2-5 presents the Miami-Dade County School 33 Board revenues for years 2018 through 2021. Property tax revenues provided approximately 52 34 to 56 percent of the total Miami-Dade County School Board revenues for years 2018 through 35 2021 (MDCPS 2021). For year 2021, Miami-Dade County School Board millage was 7.129 36 (MDC 2020).
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1 Turkey Point property tax payments for 2018 through 2021 are presented in Table 2-5. In 2019, 2 Miami-Dade County over-assessed the taxable values for Turkey Point, resulting in an 3 overpayment of property taxes to Miami-Dade County by FPL (FPL 2022a). Due to the timing of 4 the discovery and the potential related impacts on municipalities in Miami-Dade County, the 5 County and FPL agreed to address the overpayment in the year 2020 (FPL 2023a). FPL worked 6 with Miami-Dade County to adjust the 2020 payment accordingly (FPL 2023a). Turkey Point 7 property tax payments to Miami-Dade County and the Miami-Dade County Public School District 8 have represented less than 1 percent of the Miami-Dade County revenue and of the Miami-9 Dade County Public School District revenues. FPL does not expect there to be a noticeable or 10 significant change in future property tax payments during the SLR term (FPL 2018a and FPL 11 2022a). Given that FPL does not plan to conduct refurbishment activities during the SLR term, 12 changes in the assessed value of Turkey Point from these activities are not anticipated.
13 Therefore, tax payments during the SLR term would be similar to those already being paid.
14 Based on these considerations, the NRC staff concludes that the impacts on tax revenue 15 resulting from continued nuclear power plant operations at Turkey Point during the SLR term 16 would be SMALL.
17 2.11.3    Community Services and Education 18 Nuclear power plant operations and refurbishment activities as a result of workforce changes 19 can affect the availability and quality of community (i.e., public safety and public utilities) and 20 educational services. An increase in operations and refurbishment activity and related 21 populations can increase the demand and cause disruption of community services and 22 education. The impact on community and educational services will depend on the projected 23 number of in-migrating workers and their families during the renewal term and the ability to 24 respond to the level of demand for services. Tax payments from nuclear power plants can 25 support a range of community services and have a beneficial impact on the quality and 26 availability of these services to local residents.
27 FPL indicated that there are no planned SLR-related refurbishment activities, and that FPL has 28 no plans to add additional employees to support plant operations during the SLR term (FPL 29 2022a). Therefore, continued operations of Turkey Point will not result in an increase in or 30 additional demand for services as a result of an influx of permanent workers during the SLR 31 term. Any potential increase in demand for community and educational services would be from 32 the increase in number of workers at FPL during regularly scheduled plant refueling and 33 maintenance outages. However, impacts on community and education services during SLR 34 would be the same that have occurred during past operations of Turkey Point. The discussion 35 that follows presents current community and educational services in Miami-Dade County.
36 The Miami-Dade Police Department is the largest police department in Miami and the eighth 37 largest department. In 2021, 3,052 sworn officers and 1,499 civilians were employed by the 38 Miami-Dade Police Department (MDPD 2022). The Miami-Dade Fire Rescue (MDFR) is one of 39 the top 10 largest fire rescue departments in the United States. MDFR has 71 fire rescue 40 stations and 2,220 active firefighters (MDFR 2022).
41 The Miami-Dade Water and Sewer Department (MDWSD) is the main public water supplier in 42 Miami-Dade County. Miami-Dade County relies on groundwater withdrawn from the Biscayne 43 Aquifer. Water is provided by MDWSD through four regional water treatment plants: Hialeah 44 and John E. Preston Water Treatment Plant, the Hialeah Reverse Osmosis Water Treatment 45 Plant, the Alexander Orr, Jr. Water Treatment Plant, and the South Dade Water Supply System 46 (which comprises five smaller water treatment plants) (MDC 2014). The Newton Water 2-57
 
1 Treatment Plant (part of the South Dade Water Supply System) serves Turkey Point. In addition 2 to the MDWSD, four water suppliers within Miami-Dade County provide water to parts of 3 unincorporated Miami-Dade County and within their municipal boundaries: the City of North 4 Miami, the City of North Miami Beach, Florida City, and the City of Homestead. The MDWSD 5 total wellfield supply capacity is 634.01 MGD and the installed treatment facility capacity is 6 497.19 MGD (MDC 2014). According to the Miami-Dade Water Supply Facilities Work Plan 7 (MDC 2014), when taking into consideration water conservation, by 2033, annual average daily 8 water demand in the MDWSD service area is projected to be 352 MGD (MDC 2014). Based on 9 this information, the MDWSD waste supply and treatment systems have sufficient installed 10 capacity to produce potable water through 2033.
11 MDWSD operates three regional wastewater treatment facilities and serves more than 12 2.5 million customers: Central District Wastewater Treatment Plant, North District Wastewater 13 Treatment Plan, and South District Wastewater Treatment Plant. Treated wastewater at the 14 North District Wastewater Treatment Plant and the Central District Wastewater Treatment Plant 15 is discharged into the Atlantic Ocean. Treated wastewater at the South District Wastewater 16 Treatment Plant is discharged though deep injection wells into the Lower Floridan Aquifer.
17 Ocean Outfall legislation requires utilities in Southeast Florida using ocean outfalls for disposal 18 of treated wastewater to eliminate the normal use of the ocean outfalls by 2025 and reuse 60 19 percent of the wastewater flows by 2025 (MDWSD 2019). In response to this legislation, the 20 MDWSD plans to add deep injection wells at the Central and North District Wastewater 21 Treatment Plants to eliminate the use of ocean outfalls. The MDWSD has experienced 22 decreases in wastewater generation, and average flows have remained consistently flat over 23 the last 20 years. The MDWSD evaluated 2035 wastewater flow projections and found that 24 wastewater volumes are projected to be 366 MGD by 2035, and that the existing annual 25 average day flow capacity at the waste treatment plants will be sufficient through 2035 26 (MDWSD 2019) 27 The Miami-Dade County Public School District comprises 400 public schools and approximately 28 350,000 students (GFLA 2022). The Miami-Dade County Public School District is the third 29 largest school district in the United States (MDCPS 2022). The 2020-2021 Miami-Dade County 30 Public School District total revenue was $4,458 million (MDCPS 2021). An amendment to the 31 Florida Constitution approved in 2002 set limits on the number of students in core classes (e.g.,
32 math, science, etc.) in public schools. These limits, and the average class size for traditional 33 schools in the Miami-Dade County Public School District, are shown in Table 2-6. Mandated 34 class sizes are met by Miami-Dade County public schools. School enrollment in the Miami-Dade 35 County Public School District has been in a general decline. According to Miami-Dade County 36 Public School District statistics, when comparing the number of students between the 2001-37 2002 and 2021-2022 school years, enrollment has decreased by more than 45,000 students 38 (MDCPS 2009, 2022; WLRN 2022) 39 Table 2-6      Miami-Dade County Public School District Class Limits and Average Class 40                Size Grade Levels                Mandated Class Size              Average Class Size Pre-K-3                                          18                            12.25 4-8                                              22                              NA 9-12                                            25                            12.00 41 Source: FDE 2016; NA = Not Available 2-58
 
1 Given that substantial workforce changes at Turkey Point Units 3 and 4 are not expected to 2 occur during the SLR term, the plants demand and effects on community services and 3 education in the vicinity of the plant are not expected to change from what is currently being 4 experienced. As discussed above, existing services in Miami-Dade County are adequate and 5 the impacts on community services and education resulting from Turkey Point operations during 6 the SLR term are not expected to change. Therefore, the NRC staff concludes that community 7 services and education impacts due to continued nuclear power plant operations at Turkey 8 Point during the SLR term would be SMALL.
9 2.11.4      Population and Housing 10 Population and housing demand and availability can be affected by changes in the numbers of 11 workers at a nuclear power plant related to continued operations and refurbishment activities.
12 Population growth from employment at a nuclear power plant is one of the main drivers of 13 socioeconomic impacts. Population growth can occur as a result of an increase in the number of 14 permanent onsite employees during the SLR term, as well as increases in the number of 15 workers at a nuclear power plant during regularly scheduled plant refueling and maintenance 16 outages and during refurbishment activities. Plant refueling and maintenance outages and 17 refurbishment activities, however, are of temporary and short duration and therefore create a 18 short-term increase in employment. In the vicinity of nuclear power plants, the number of 19 housing units and the type and quality of available housing varies. Long-term housing demand 20 can be affected by changes in the number of permanent onsite employees. Short-term increase 21 in the demand for temporary (rental) housing occurs during periodic outages or refurbishment 22 activities, when refueling and maintenance workers require rental accommodations.
23 Table 2-7 shows population and percent growth and projections from 1990 to 2070 in Miami-24 Dade County. Over the last several decades, Miami-Dade County has experienced increasing 25 population. Based on population projections, the population in Miami-Dade County is expected 26 to continue to increase, but at a slower rate. FPL employs a permanent workforce of 27 approximately 680 workers (FPL 2018a and FPL 2022a). Approximately 85 percent of the 28 workforce resides in Miami-Dade County. The remaining workers are spread among 12 counties 29 in Florida and Georgia, with numbers ranging from 1 worker to 49 workers per county (FPL 30 2018a and FPL 2022a). FPL also employs approximately 370 onsite contract workers; 80 31 percent of the contract workers reside in Miami-Dade County (FPL 2018a and FPL 2022a).
32 During refueling outages, onsite employment typically increases by an additional 1,200 workers 33 for 25-35 days.
34 Table 2-7      Population and Percent Growth in Miami-Dade County, 1990-2070 Year          Miami-Dade County Population              Percent Change Since Previous Entry 1990                        1,937,094                                        -
2000                        2,253,362                                      16.3 2010                        2,496,435                                      10.8 2020                        2,701,767                                        8.2 2030                        3,167,900                                      17.3 2040                        3,399,200                                        7.3 2050                        3,714,000                                        9.3 2060                        4,001,700                                        7.7 2070                        4,284,300                                        7.1 35 Sources: Decennial population data for 1970-2020 (USCB 1996, 2000, 2012, 2020); Projected population for 36 2030-2070 (FDOT 2020).
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1 FPL has no plans to add additional employees to support plant operations during the SLR term 2 and there are no planned SLR-related refurbishment activities (FPL 2018a and FPL 2022a).
3 Therefore, SLR would not involve new employment. Any population increase would be from the 4 increased number of workers at FPL during regularly scheduled plant refueling and 5 maintenance outages during the SLR term. Outage workers represent less that 1 percent of the 6 2020 and 2030-2070 projected population in Miami-Dade County. Furthermore, plant refueling 7 and maintenance outages and refurbishment activities are of temporary and short duration and 8 therefore would create a short-term increase in employment and population changes.
9 Because FPL has no plans to add additional employees to support plant operations during the 10 SLR term and because there are no planned SLR-related refurbishment activities, increases in 11 housing demand would only occur as a result of the short-term (25-35 days) increase in the 12 number of workers (approximately 1,200) during regularly scheduled plant refueling and 13 maintenance outages. Table 2-8 lists the total number of occupied and vacant housing units in 14 Miami-Dade County. Based on the United States Census Bureau (USCB) 2021 American 15 Community Survey 1-year estimates (USCB 2022a, 2022b), there were 1,084,304 housing units 16 in Miami-Dade County, of which 120,827 were vacant, and 56,916 housing units are vacant for 17 seasonal, recreational, or occasional use. Therefore, Miami-Dade County has available vacant 18 housing units to support the outage workforce.
19 Table 2-8      Housing in Miami-Dade County, 2021 Estimates Property                                                                  Miami-Dade County Total Housing Units                                                            1,084,304 Occupied Housing Units                                                            963,477 Total Vacant Housing Units                                                        120,827 Vacant Housing Units for Seasonal, Recreational, or Occasional Use                56,916 20 Sources: USCB 2022a and 2022b 21 The effects on population and housing values and availability in the vicinity of nuclear power 22 plants are not expected to change from what is currently being experienced. The NRC staff 23 determined that little or no population growth or increased demand for housing would occur 24 during the SLR term. Therefore, the NRC staff concludes that population and housing impacts 25 due to continued nuclear power plant operations at Turkey Point during the SLR term would be 26 SMALL.
27 2.11.5    Transportation 28 Continued operations and refurbishment associated with the SLR term can affect traffic volumes 29 and local transportation systems. Local and regional transportation networks in the vicinity of 30 nuclear power plants may vary considerably depending on the regional population density, 31 location, and size of local communities; nature of economic development patterns; location of 32 the region relative to interregional transportation corridors; and land surface features, such as 33 mountains, rivers, and lakes. Transportation impacts depend on the size of the workforce, the 34 capacity of the local road network, traffic patterns, and the availability of alternate commuting 35 routes to and from the nuclear power plant.
36 The transportation network surrounding Turkey Point comprises U.S. highways, Interstate 37 highways, local streets, and waterways. There are no ports or rail systems located within 6 mi 38 (9.6 km) of Turkey Point. The nearest rail line, operated by CSX Corporation, is located 2-60
 
1 approximately 10 mi (16 km) west of Turkey Point in Homestead, Florida; and the Port of Miami 2 is located approximately 23 mi (37 km) north of the plant. NUREG-2176, Environmental Impact 3 Statement for Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7, dated 4 October 2016, describes this transportation network in Section 2.5.2.3 (NRC 2016); the NRC 5 staff incorporates pages 2-175 through 2-178 of NUREG-2176 into this EIS by reference.
6 Access to Turkey Point is via East Palm Drive (SW 344 St.). East Palm Drive is a four-lane road 7 that turns into a two-lane road at its intersection with Tallahassee Road (SW 137th Avenue) as it 8 leads to the Turkey Point site. East Palm Drive intersects with US-1 approximately 8 mi (12.8 9 km) from Turkey Point. East Palm Drive provides access to the Homestead-Miami Speedway 10 and Homestead Bayfront Park. The reported 2021 average annual daily two-way traffic volume 11 for the monitoring site closest to Turkey Point on East Palm Drive was 8,300 vehicles; annual 12 daily traffic has decreased along East Palm Drive since 2017 (FDOT 2022) 13 In Miami-Dade County all State and County roads need to operate at or above a level of service 14 (LOS) C outside of the Urban Development Boundary (MDC 2012). The Transportation 15 Research Board LOS designations define the flow of traffic on a designated highway. LOS 16 designations can range from traffic freely flowing (LOS A) to a point where traffic flow exceeds 17 the design capacity of the highway resulting in severe congestion (LOS F). In 2009, FPL 18 commissioned a traffic study in connection with peak construction activities associated with the 19 proposed Turkey Point Units 6 and 7 (Traf Tech 2009). The traffic study assessed the available 20 capacity from three traffic stations in the vicinity of the Turkey Point site (see Table 2-9). In 21 Table 2-9, peak hour capacity (i.e., the maximum number of cars that can be supported on a 22 road per hour), minus the peak number of trips (i.e., the maximum existing traffic volume),
23 produces an estimate of the available peak hour capacity (i.e., how many more vehicles can be 24 accommodated on the road per hour). As indicated in Table 2-9, the traffic stations in the vicinity 25 of the Turkey Point site have sufficient peak hour capacity to accommodate additional traffic and 26 LOS designations operate at or above Miami-Dade Countys adopted LOS C, which provides an 27 acceptable level of service.
28 Table 2-9        Peak Hour Traffic, Reserve Capacity, and Level of Service at Roads in the 29                  Vicinity of the Turkey Point Site Peak        Available Station                                          Peak Hour        Hour      Peak Hour    Level of No.                    Location              Capacity(a)(b)  Trips(a)(c) Capacity(a)(d) Service 9556      Palm Drive/SW 344 west of 137th          3,030        231          2,799          B Ave/Tallahassee Road 9952      SW 328th St./North Canal Dr. west        2,600        254          2,346          A of SW 137th Ave/ Tallahassee Road 9944      SW 312th St./Campbell Drive east of      3,350      2,061          1,289          C Homestead Extension of Floridas Turnpike 30 (a) Passenger car unit.
31 (b) Maximum level of service capacity 32 (c) Existing traffic volumes 33 (d) Peak hour capacity minus peak hour trips 34 Source: Traf Tech 2009.
35 FPL indicated in ER Supplement 2 that there are no planned SLR-related refurbishment 36 activities, and that FPL has no plans to add additional employees to support plant operations 37 during the SLR term (FPL 2022a). Increases in the number of workers would occur during 2-61
 
1 regularly scheduled plant refueling and maintenance outages. During refueling outages, onsite 2 employment typically increases by an additional 1,200 workers and staff is split into two work 3 shifts (FPL 2023a). However, because of the short duration of the outages (25-35 days),
4 outages result in short-term increases in traffic volumes and, as noted in Table 2-9, roads in the 5 vicinity of Turkey Point have sufficient peak hour capacity to accommodate additional traffic.
6 Consistent with this information, the existing traffic from Turkey Points workforce has not 7 resulted in an exceedance of the capacity of roads, and roads have operated adequately.
8 Transportation impacts are ongoing and have become well established in the vicinity of Turkey 9 Point. Given that the size of the workforce is not expected to increase during the SLR term and 10 given the capacity availability of roads in the vicinity of Turkey Point, traffic on the roads 11 surrounding Turkey Point would not noticeably increase relative to the current traffic volumes.
12 No transportation impacts during the SLR term would occur beyond those already being 13 experienced. Therefore, the NRC staff concludes that the impacts on transportation due to 14 continued nuclear power plant operations at Turkey Point during the SLR term would be 15 SMALL.
16 2.12 Human Health 17 Human health at all nuclear power plants has been well established during the current license 18 term. Based on past environmental monitoring data and trends (discussed in detail in the 1996 19 LR GEIS and the 2013 LR GEIS), the NRC staff concludes that no significant human health 20 impacts are anticipated during the SLR term that would be different from those occurring during 21 the current license term. Certain operational changes (such as extended power uprates) that 22 could potentially affect human health would be evaluated by the NRC in a separate safety and 23 environmental review if such operational changes were to be requested by a licensee in the 24 future. The following sections address the site-specific environmental impacts of Turkey Point 25 SLR on five environmental issues related to human health.
26 2.12.1      Radiation Exposures to the Public 27 Nuclear power plants, under controlled conditions, release small amounts of radioactive 28 materials to the environment during normal operation. NRC regulations in 10 CFR Part 20 29 identify maximum allowable concentrations of radionuclides that can be released from a nuclear 30 power plant, such as Turkey Point, into the air and water above background at the boundary of 31 unrestricted areas, to control radiation exposures of the public and releases of radioactivity.
32 These concentrations are derived based on an annual total effective dose equivalent (TEDE) of 33 0.1 rem to individual members of the public. In addition, pursuant to 10 CFR 50.36a, Technical 34 specifications on effluents from nuclear power reactors, nuclear power plants have special 35 license requirements, called technical specifications, for radioactive gaseous and liquid releases 36 from the plant to minimize the radiological impacts associated with plant operations to levels 37 that are as low as is reasonably achievable (ALARA).
38 Radioactive waste management systems are incorporated into the design of each plant. They 39 are designed to remove most of the fission product radioactivity that leaks from the fuel, as well 40 as most of the activation- and corrosion-product radioactivity produced by neutrons in the 41 vicinity of the reactor core. The amounts of radioactivity released through vents and discharge 42 points to areas outside the plant boundary are recorded and published annually in the 43 radioactive effluent release reports. These environmental monitoring programs are in place at all 44 plants. Because there is no reason to expect effluents to increase at Turkey Point during the 45 SLR term, doses from continued operation during the SLR term are expected to be well within 46 regulatory limits established in 10 CFR Part 20 and 40 CFR Part 190, Environmental Radiation 2-62
 
1 Protection Standards for Nuclear Power Operations. No mitigation measures beyond those 2 already implemented under the licenses would be warranted, because current mitigation 3 practices have kept public radiation doses well below regulatory standards and are expected to 4 continue to do so.
5 The NRC staff reviewed Turkey Point effluent release reports for the years 2018 through 2022 6 (FPL 2019b, 2020c, 2021a, 2022c, 2023c) and determined that the recorded annual public dose 7 is a fraction of the regulatory limits and was in accordance with radiation protection standards 8 identified in 10 CFR Part 50 (Appendix I), 10 CFR Part 20, and 40 CFR Part 190. This 5-year 9 review period provided a data set that covers a broad range of activities that occur at a nuclear 10 power plant, such as refueling outages, routine operation, and maintenance that can affect the 11 generation and release of radioactive effluents into the environment. The NRC staff looked for 12 indications of adverse trends (e.g., increasing radioactivity levels) over the period of 2018 13 through 2022. Based on its review of this information, the NRC staff found no apparent 14 increasing trend in concentration or pattern indicating either a new inadvertent release or 15 persistently high tritium concentrations that might indicate an ongoing inadvertent release from 16 Turkey Point. The groundwater monitoring program at Turkey Point is robust, and any future 17 leaks that might occur during the SLR term should be readily detected. All spills are well 18 monitored, characterized, and actively remediated. Taken together, the data show that there 19 have been no significant radiological impacts on the environment from operations at Turkey 20 Point.
21 Radiation doses to the public from continued operation are expected to continue at current 22 levels and to remain below regulatory limits during the SLR term. The NRC staff identified no 23 information for Turkey Point that would result in different impacts than those of current 24 operations. The NRC staff concludes that the health impacts from public radiation exposure due 25 to continued nuclear power plant operations at Turkey Point during the SLR term would be 26 SMALL based on public doses being maintained within regulatory limits.
27 2.12.2    Radiation Exposures to Plant Workers 28 Nuclear power plant workers conducting activities involving radioactively contaminated systems 29 or working in radiation areas can be exposed to radiation. Individual occupational doses are 30 measured by nuclear power plant licensees as required by the NRC radiation protection 31 standard at 10 CFR Part 20. Most of the occupational radiation dose to nuclear power plant 32 workers results from external radiation exposure rather than from internal exposure from inhaled 33 or ingested radioactive materials. Workers also receive radiation exposure during the storage 34 and handling of radioactive waste. Occupational doses from refurbishment activities (if any are 35 conducted) and occupational doses from continued operations during the SLR term are 36 expected to be similar to the doses experienced during current operations and to be bounded by 37 the analysis conducted in the 1996 LR GEIS. The occupational doses are estimated to be much 38 less than the doses allowed by the regulatory dose limits.
39 Under 10 CFR 20.2206, Reports of individual monitoring, the NRC requires nuclear power 40 plant licensees to submit an annual report of the results of individual monitoring carried out by 41 the licensee for each individual for whom monitoring was required by 10 CFR 20.1502, 42 Conditions requiring individual monitoring of external and internal occupational dose, during 43 that year. The NRC staff reviewed the Turkey Point occupational dose reports and summary 44 reports through 2020 (NRC 2022f) and identified no information for Turkey Point that would 45 result in different impacts than those of current operations. The NRC staff concludes that the 46 health impacts from occupational radiation exposure due to continued nuclear power plant 2-63
 
1 operations at Turkey Point during the SLR term would be SMALL based on individual worker 2 doses being maintained within 10 CFR Part 20 limits. No mitigation measures beyond those 3 implemented during the current license term would be warranted, because the ALARA process 4 would continue to be effective in reducing radiation doses.
5 2.12.3      Human Health Impact from Chemicals 6 State and Federal environmental agencies regulate the use, storage, and discharge of 7 chemicals, biocides, and sanitary wastes. Such environmental agencies also regulate how 8 facilities like Turkey Point manage minor chemical spills. Chemical and hazardous wastes can 9 potentially affect workers, members of the public, and the environment.
10 FPL currently controls the use, storage, and discharge of chemicals, biocides, and sanitary 11 wastes at Turkey Point in accordance with its chemical control procedures, waste management 12 procedures, and Turkey Point site-specific chemical spill prevention plans. FPL monitors and 13 controls discharges of chemicals, biocides, and sanitary wastes through Turkey Points NPDES 14 permit process. These plant procedures, plans, and processes are designed to prevent and 15 minimize the potential for a chemical or hazardous waste release and, in the event of such a 16 release, minimize the impact on workers, members of the public, and the environment. The 17 NRC staff concludes that the health impacts from chemicals, biocides, and sanitary wastes due 18 to continued nuclear power plant operations at Turkey Point during the SLR term would be 19 SMALL based on these procedures, plans, and processes.
20 2.12.4      Microbiological Hazards to Plant Workers 21 No change in existing microbiological hazards to plant workers is expected due to SLR, for the 22 same reasons discussed in detail in the 2013 LR GEIS (NRC 2013a) for initial license renewal.
23 The NRC staff considers it unlikely that any nuclear power plants that have not already 24 experienced occupational microbiological hazards would do so during the SLR term or that 25 hazards would increase during the SLR term. The NRC staff has identified no information or 26 situations that would result in different impacts for this issue for the SLR term at Turkey Point.
27 FPL is expected to continue to employ proven industrial hygiene principles so that adverse 28 occupational health effects associated with microorganisms due to continued nuclear power 29 plant operations at Turkey Point during the SLR term would be of SMALL significance, and no 30 mitigation measures beyond those implemented during the current license term would be 31 warranted.
32 2.12.5      Physical Occupational Hazards 33 Nuclear power plants are industrial facilities that have many of the typical occupational hazards 34 found at any other electric power generation utility. Nuclear power plant workers may perform 35 electrical work, electric powerline maintenance, repair work, and maintenance activities and 36 may be exposed to potentially hazardous physical conditions (e.g., falls, excessive heat, cold, 37 noise, electric shock, and pressure).
38 The Occupational Safety and Health Administration (OSHA) is responsible for developing and 39 enforcing workplace safety regulations. With respect to nuclear power plants, plant conditions 40 that result in an occupational risk, but do not affect the safety of licensed radioactive materials, 41 are under the statutory authority of OSHA rather than the NRC as set forth in a Memorandum of 42 Understanding (NRC 2013b) between the NRC and OSHA. Occupational hazards are reduced 43 when workers adhere to safety standards and use appropriate protective equipment; however, 2-64
 
1 fatalities and injuries caused by accidents may still occur. FPL maintains an occupational safety 2 program at Turkey Point for its workers in accordance with OSHA regulations. The NRC staff 3 has identified no information or situations that would result in different impacts for this issue for 4 this SLR term at Turkey Point. The NRC staff expects that FPL will continue to employ an 5 occupational safety program so that physical occupational hazards due to continued nuclear 6 power plant operations at Turkey Point during the SLR term are minimized and would be of 7 SMALL significance.
8 2.13 Postulated Accidents 9 The following section and Appendix D address the site-specific environmental impacts of Turkey 10 Point SLR on environmental issues related to postulated accidents.
11 2.13.1      Design Basis Accidents 12 Design basis accidents are postulated accidents that a nuclear power plant must be designed 13 and built to withstand without loss of the systems, structures, and components necessary to 14 ensure public health and safety. Planning for design basis accidents ensures that the plant can 15 withstand normal transients (e.g., rapid changes in the reactor coolant system temperature or 16 pressure, or rapid changes in reactor power), as well as a broad spectrum of postulated 17 accidents without causing undue hazard to the health and safety of the public. Many of these 18 design basis accidents may occur but are unlikely to occur during the life of the plant; 19 nevertheless, carefully evaluating each design basis accident is crucial to establishing the 20 design basis of the plants preventive and mitigative safety systems. 10 CFR Part 50 and 21 10 CFR Part 100, Reactor Site Criteria, describe the NRCs acceptance criteria for design 22 basis accidents.
23 Before the NRC will issue an operating license for a nuclear power plant, the applicant must 24 demonstrate the ability of the plant to withstand all design basis accidents. The applicant and 25 the NRC staff evaluate the environmental impacts of design basis accidents for the hypothetical 26 maximally exposed individual (MEI). The results of these design basis accident evaluations are 27 found in the plants original licensing documents, such as the applicants final safety analysis 28 report, the NRC staffs safety evaluation report, and the NRC staffs final environmental 29 statement. Once the NRC issues the operating license for the plant, the licensee is required to 30 maintain the design and performance criteria that were found to be acceptable (which includes 31 withstanding design basis accidents), referred to, in part, as the plants current licensing basis 32 (CLB), throughout the operating life of the plant, including any license renewal terms.
33 Pursuant to 10 CFR 54.29, Standards for issuance of a renewed license, license renewal 34 applicants are required to manage the effects of aging and perform any required time-limited 35 aging analyses (as further described in the regulation), such that there is reasonable assurance 36 that the activities authorized by the renewed license will continue to be conducted in accordance 37 with the plants CLB and that any changes made to the plants CLB in order to comply with 38 10 CFR 54.29 are in accordance with the Atomic Energy Act of 1954, as amended (AEA; 42 39 U.S.C. 2011 et seq.) and the Commissions regulations. Because of the requirement that the 40 existing design basis and aging management programs be in effect for the renewal term, the 41 environmental impacts of design basis accidents as calculated for the original operating license 42 application should not differ significantly from the environmental impacts of design basis 43 accidents at any other time during plant operations, including during the SLR term. Accordingly, 44 the NRC staff considers the design of the plant, relative to design basis accidents, to remain 45 acceptable during the SLR term.
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1 Under the NRCs license renewal rules in 10 CFR Part 54, Requirements for Renewal of 2 Operating Licenses for Nuclear Power Plans, SLR applicants must take adequate steps to 3 account for aging during the SLR term either by updating time-limited aging analyses or 4 implementing aging management plans. Based on these required activities, the NRC staff 5 expects that operation during the SLR term would continue to provide a level of safety 6 equivalent to that provided during the current license term. Furthermore, as provided in the 7 statement of considerations for 10 CFR Part 54 (60 FR 22491), the Commission believes that 8 considerable experience has demonstrated that its regulatory process provides adequate 9 assurance that degradation due to the aging of structures, systems, and components that 10 perform active safety functions will be appropriately managed to ensure their continued 11 functionality during the period of extended operation. Furthermore, although the definition of 12 CLB in 10 CFR Part 54 is broad and encompasses various aspects of the NRC regulatory 13 process (e.g., operation and design requirements), the Commission concluded that a specific 14 focus on functionality is appropriate for performing license renewal reviews. Reasonable 15 assurance that the functionality of important structures, systems, and components will be 16 maintained throughout the renewal term, combined with the rules stipulation that all aspects of 17 a plants CLB (e.g., technical specifications) and the NRCs regulatory process carry forward 18 into the renewal period, support a conclusion that the CLB (which represents an acceptable 19 level of safety) will be maintained. Functional capability is the principal emphasis for much of the 20 CLB and is the focus of other regulatory requirements to ensure that aging issues are 21 appropriately managed during the license renewal term, including any subsequent license 22 renewal term.
23 The early identification and resolution of design basis accidents as part of the issuance of an 24 operating license make them a part of a plants CLB. The NRC requires a licensee to maintain 25 its plants CLB under the current operating license, as well as during any license renewal term 26 including the SLR term. Therefore, under the provisions of 10 CFR 54.30, Matters not subject 27 to a renewal review, design basis accidents are not subject to review as part of the NRCs 28 license renewal process.
29 Consistent with the above discussion and as stated in Section 5.3.2 of the 1996 LR GEIS, the 30 environmental impact of design basis accidents is assessed in the NRC staffs plant-specific 31 environmental review associated with the issuance of the operating license for a plant. Because 32 the licensee is required to maintain the plant within acceptable design and performance criteria 33 after operating license issuance, including during any license renewal term, these environmental 34 impacts are not expected to change significantly.
35 In the 2013 LR GEIS, the NRC reexamined the information from the 1996 LR GEIS regarding 36 design basis accidents and concluded that this information is still valid. The NRC found that the 37 environmental impacts of design basis accidents are of SMALL significance for the license 38 renewal of all nuclear power plants. This conclusion was reached because the plants were 39 designed to successfully withstand these accidents, and a licensee is required to maintain the 40 plant within acceptable design and performance criteria, including during any license renewal 41 term. The NRC also determined that the environmental impacts during a license renewal term 42 should not differ significantly from the impacts calculated for the design basis accident 43 assessments conducted during the initial plant licensing process. Impacts from design basis 44 accidents would not be affected by changes in the plants environment because such impacts 45 (1) are based on calculated radioactive releases that are not expected to change, (2) are 46 evaluated for the hypothetical MEI, and (3) have been previously determined acceptable 47 (NRC 1996, 2013a).
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1 An example of the NRCs previous review of Turkey Points design basis accidents is the June 2 23, 2011, Issuance of Amendments Regarding Alternative Source Term (NRC 2011), in which 3 the NRC staff determined that the radiological consequences estimated by the licensee for 4 various design basis accidents at Turkey Point will comply with the requirements of 10 CFR 5 50.67, Accident source term, and the guidelines of RG 1.183, Alternative Radiological Source 6 Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors (NRC 2000), and are 7 therefore acceptable. Another example is the NRCs review of updated external hazards 8 information for all operating power reactors (as ordered by the Commission after the Fukushima 9 Dai-Ichi accident). On March 24, 2020, the NRC completed its review of Fukushima-related 10 information relevant to Turkey Point and concluded that no further regulatory actions were 11 needed to ensure adequate protection or compliance with regulatory requirements, thereby 12 reconfirming the acceptability of Turkey Points design basis (NRC 2020a).
13 In its ER included in the Turkey Point SLR application, FPL did not identify any new and 14 significant information related to the environmental impacts of design basis accidents at Turkey 15 Point (FPL 2018f). The NRC staff also did not identify any new and significant information 16 related to the environmental impacts of design basis accidents at Turkey Point during its 17 independent review of FPLs ER, through the scoping process, or in its evaluation of other 18 available information. Therefore, in the FSEIS, the NRC staff concluded that the environmental 19 impacts of design basis accidents at Turkey Point during the SLR term would be SMALL.
20 Based upon its review of FPLs SLR application, including ER Supplement 2, the NRC staff has 21 determined that the environmental impacts of design basis accidents at Turkey Point during the 22 SLR term are of SMALL significance because the plant was designed to successfully withstand 23 these accidents. Due to the requirements for FPL to maintain the Turkey Point CLB (which the 24 NRC has previously determined to be acceptable) and implement aging management programs, 25 the environmental impacts of design basis accidents during the SLR term are not expected to 26 differ significantly from those calculated and found to be acceptable as part of the initial plant 27 licensing process. The NRC staff has identified no information or situations that would result in 28 different impacts for this issue for the SLR term at Turkey Point. Therefore, the NRC staff 29 concludes that the environmental impacts of design basis accidents at Turkey Point during the 30 SLR term would be SMALL based on previous determinations of the acceptability of the CLB 31 and the regulatory requirement for the continuation of the CLB during any license renewal term 32 including the SLR term.
33 2.13.2    Severe Accidents 34 As discussed in Section 2.13.1 above, U.S. nuclear power plants must be designed and built to 35 withstand design basis accidents without loss of the systems, structures, and components 36 necessary to ensure public health and safety. As also discussed above, these accidents include 37 normal transients as well as a broad spectrum of postulated accidents. In contrast, severe 38 accidents are accidents that could have severe consequences but, due to their extremely low 39 likelihood of occurrence, are not required to be included within the range of design basis 40 accidents that a plant must be able to withstand. This principle applies to initial reactor licensing, 41 as well as initial and subsequent license renewal, because the NRCs regulations in 10 CFR 42 54.29 require license renewal applicants to manage the effects of aging and perform any 43 required time-limited aging analyses, such that there is reasonable assurance (1) that the 44 activities authorized by the renewed license will continue to be conducted in accordance with 45 the plants CLB and (2) that any changes made to the plants CLB in order to comply with 46 10 CFR 54.29 are in accordance with the AEA and the Commissions regulations. Thus, the 47 environmental impacts of design basis accidents as calculated for the original operating license 2-67
 
1 application, should not differ significantly from the environmental impacts of design basis 2 accidents at any other time during plant operations, including during the SLR term.
3 With respect to severe accidents (i.e., postulated accidents that are more severe than design 4 basis accidents because severe accidents can result in substantial damage to the reactor core, 5 whether or not there are serious offsite consequences), the Commission concluded that the 6 probability-weighted consequences of severe accidents are SMALL for all plants (NRC 1996).
7 Nonetheless, the Commission has required that an analysis of severe accident mitigation 8 alternatives (SAMAs) be conducted for license renewal if such an analysis has not been 9 conducted previously (NRC 1996).
10 As discussed in the Turkey Point FSEIS (NRC 2019a) and Appendix D in this EIS, FPL 11 conducted a site-specific SAMA analysis in its initial license renewal application for Turkey 12 Point, which the NRC staff evaluated in its EIS for initial license renewal (NRC 2002a).
13 Subsequently, FPL updated its SAMA analysis in its ER for subsequent license renewal (FPL 14 2018f), which the NRC staff evaluated in its 2019 FSEIS on a site-specific basis (NRC 2019a).
15 Finally, the NRC staff conducted a further evaluation of new and significant information for 16 Turkey Point as it relates to population dose risk, as described in Appendix D of this EIS. As 17 discussed in Appendix D, based on a site-specific evaluation, the staff NRC has concluded that 18 the probability-weighted consequences of severe accidents from continued nuclear power plant 19 operations at Turkey Point during the SLR term would be SMALL.
20 2.14 Waste Management 21 As a result of normal operations, equipment repairs and replacements, and normal maintenance 22 activities, nuclear power plants routinely generate both radioactive and nonradioactive waste.
23 Nonradioactive waste includes hazardous and nonhazardous waste. There is also a class of 24 waste, called mixed waste, that is both radioactive and hazardous. The NRC licenses all nuclear 25 power plants with the expectation that they will release some radioactive material to both the air 26 and water during normal operations. However, NRC regulations require that gaseous and liquid 27 radioactive releases from nuclear power plants meet radiation dose-based limits specified in 28 10 CFR Part 20 and the ALARA criteria in 10 CFR Part 50, Appendix I. In other words, the NRC 29 places regulatory limits on the radiation dose that members of the public can receive from a 30 nuclear power plants radioactive effluent. For this reason, all nuclear power plants use 31 radioactive waste management systems to control and monitor radioactive wastes. FPL uses its 32 Offsite Dose Calculation Manual (ODCM) that contains the methods and parameters for 33 calculating offsite doses resulting from liquid and gaseous radioactive effluents. These methods 34 ensure that radioactive material discharges from Turkey Point meet NRC and EPA regulatory 35 dose standards. The ODCM also contains the requirements for the REMP. Turkey Point will 36 produce both radioactive and nonradioactive waste during the SLR term like any operating 37 nuclear power plant. The following sections address the site-specific environmental impacts of 38 Turkey Point SLR on five environmental issues related to waste management.
39 2.14.1      Low-Level Waste Storage and Disposal 40 At Turkey Point, low-level radioactive waste is stored temporarily onsite before being shipped 41 offsite for treatment or disposal at licensed treatment and disposal facilities (NRC 2019a).
42 Annual quantities of low-level radioactive waste generated at Turkey Point vary from year to 43 year depending on the number of maintenance activities undertaken. Due to the comprehensive 44 regulatory controls in place for the management of radioactive waste, FPLs compliance with 45 these regulations, and FPLs use of licensed treatment and disposal facilities, the impacts of 2-68
 
1 radioactive waste are expected to be SMALL during the SLR term. There are no other operating 2 nuclear power plants, fuel-cycle facilities, or radiological waste treatment and disposal facilities 3 within a 50 mi (80 km) radius of Turkey Point. The NRC staff has identified no information or 4 situations that would result in different impacts for this issue for the SLR term at Turkey Point.
5 Therefore, the NRC staff concludes that the environmental impacts from low-level waste storage 6 and disposal due to continued nuclear power plant operations at Turkey Point during the SLR 7 term would be SMALL.
8 2.14.2    Onsite Storage of Spent Nuclear Fuel 9 As discussed in the FSEIS, Turkey Points spent fuel is stored in a spent fuel pool and in an 10 onsite independent spent fuel storage installation (ISFSI) (NRC 2019a). The Turkey Point onsite 11 ISFSI is licensed under the general license provided to nuclear power plant licensees under 12 10 CFR 72.210, General license issued. The NRCs regulations and its oversight of onsite 13 spent fuel storage ensure that the increased volume in onsite storage from operation during the 14 SLR term can be safely accommodated with little environmental effect. The ISFSI safely stores 15 spent fuel onsite in licensed and approved dry cask storage containers. FPL indicated that there 16 are plans as part of SLR to expand the concrete pad inside the ISFSI area to accommodate 17 more fuel casks.
18 This issue was also considered for the NRC staffs environmental review of Turkey Points initial 19 license renewal, and no new and significant information was found at that time (NRC 2002a).
20 The NRC staff has identified no information or situations that would result in different impacts for 21 this issue for the SLR term at Turkey Point. Therefore, the NRC staff concludes that the 22 environmental impacts from onsite storage of spent nuclear fuel due to continued nuclear power 23 plant operations at Turkey Point during the SLR term would be SMALL.
24 2.14.3    Offsite Radiological Impacts of Spent Nuclear Fuel and High-Level Waste 25            Disposal 26 As related to the issue of offsite radiological impacts of spent nuclear fuel and high-level waste 27 disposal, a history of the NRCs Waste Confidence activities is provided in NUREG-2157, 28 Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, 29 Section 1.1, History of Waste Confidence (NRC 2014a). The management and ultimate 30 disposition of spent nuclear fuel is limited to the findings codified in the September 19, 2014, 31 Continued Storage of Spent Nuclear Fuel, Final Rule (79 FR 56238) and associated NUREG-32 2157. As stated in 10 CFR 51.23, the Commission has generically determined that the 33 environmental impacts of continued storage of spent nuclear fuel beyond the licensed life for 34 operation of a reactor are those impacts identified in NUREG-2157. The ultimate disposal of 35 spent nuclear fuel in a potential future geologic repository is a separate and independent 36 licensing action that is outside the regulatory scope of this site-specific review. In 10 CFR Part 37 51, Subpart A, the Commission concluded that the impacts presented in NUREG-2157 would 38 not be sufficiently large to require the conclusion, for any nuclear power plant, that the option of 39 extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the 40 Commission has not assigned a single level of significance for the offsite radiological impacts of 41 spent nuclear fuel and high-level waste disposal, this issue is considered generic to all nuclear 42 power plants pursuant to 10 CFR 51.23 and does not warrant a site-specific analysis for the 43 continued nuclear power plant operations at Turkey Point during the SLR term.
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1 2.14.4      Mixed-Waste Storage and Disposal 2 Mixed waste, regulated under the Resource Conservation and Recovery Act of 1976, as 3 amended (RCRA; 42 U.S.C. 6901 et seq.), and the AEA, is waste that is both radioactive and 4 hazardous (EPA 2019). Mixed waste is subject to dual regulation: by the EPA or an authorized 5 State for its hazardous component and by the NRC or an agreement state for its radioactive 6 component. Similar to hazardous waste, mixed waste is generally accumulated onsite in 7 designated areas as authorized under RCRA and then shipped offsite for treatment as 8 appropriate and for disposal. Occupational exposures and any releases from the onsite 9 treatment of these and any other types of wastes are considered when evaluating compliance 10 with the applicable Federal standards and regulations; for example, 10 CFR Part 20, 40 CFR 11 Part 190, and 10 CFR Part 50, Appendix I. Due to the comprehensive regulatory controls in 12 place for the management of mixed waste, FPLs compliance with these regulations, and FPLs 13 use of licensed treatment and disposal facilities, the impacts of mixed waste are expected to be 14 SMALL during the SLR term. The NRC staff identified no information or situations that would 15 result in different impacts for this issue for the SLR term at Turkey Point. Therefore, the NRC 16 staff concludes that the radiological and nonradiological environmental impacts from mixed-17 waste storage and disposal due to continued nuclear power plant operations at Turkey Point 18 during the SLR term would be SMALL.
19 2.14.5      Nonradioactive Waste Storage and Disposal 20 Like any other industrial facility, nuclear power plants generate wastes that are not 21 contaminated with either radionuclides or hazardous chemicals. Turkey Point has a 22 nonradioactive waste management system to handle its nonradioactive hazardous and 23 nonhazardous wastes. The waste is managed in accordance with FPLs procedures. Waste 24 minimization and pollution prevention are important elements of operations at all nuclear power 25 plants. Licensees are required to consider pollution prevention measures as dictated by the 26 Pollution Prevention Act (Public Law 101-508) and RCRA. In addition, as discussed in detail in 27 the FSEIS (NRC 2019a), Turkey Point has a nonradioactive waste management program to 28 handle nonradioactive waste in accordance with Federal, State, and corporate regulations and 29 procedures. Turkey Point will continue to store and dispose of nonradioactive hazardous and 30 nonhazardous waste in accordance with EPA, State, and local regulations in permitted disposal 31 facilities. With respect to unplanned, nonradiological releases, FPL reported no accidental spills 32 or similar releases of nonradioactive substances, including petroleum products, at Turkey Point 33 over the past 5 years, or any associated notices of violation issued to FPL for such releases 34 (FPL 2023a). The NRC staffs review of available information and regulatory databases found 35 no documented instances of accidental spills of chemical or petroleum products to groundwater 36 that resulted in a regulatory action over the last 5 years. Due to the comprehensive regulatory 37 controls in place for the management of nonradioactive waste and FPLs compliance with these 38 regulations, the impacts of nonradioactive waste are expected to be SMALL during the SLR 39 term. The NRC staff has identified no information or situations that would result in different 40 impacts for this issue for the SLR term at Turkey Point. Therefore, the NRC staff concludes that 41 the environmental impacts from nonradioactive waste storage and disposal due to continued 42 nuclear power plant operations at Turkey Point during the SLR term would be SMALL.
43 2.15 Uranium Fuel Cycle 44 The uranium fuel cycle includes uranium mining and milling, the production of uranium 45 hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation 46 of radioactive materials, and management of low-level and high-level wastes related to uranium 2-70
 
1 fuel cycle activities. The NRC evaluated the environmental impacts of operating uranium fuel-2 cycle facilities, not including nuclear power plants, in two NRC publications: WASH-1248, 3 Environmental Survey of the Uranium Fuel Cycle (AEC 1974), and NUREG-0116, 4 Environmental Survey of the Reprocessing and Waste Management Portions of the LWR 5 [Light-Water Reactor] Fuel Cycle (NRC 1976). More recently, facilities for managing the back 6 end of the uranium fuel cycle were considered in NUREG-2157 (NRC 2014a). As evaluated in 7 NUREG-2157, the NRC reaffirmed in 2014 that geological disposal remains technically feasible 8 and that acceptable sites can be identified.
9 The impacts associated with uranium mining, milling, and the transportation of radioactive 10 materials among facilities, including the transportation of wastes to disposal facilities, were 11 incorporated into the NRCs regulations at 10 CFR 51.51(b), Table S-3, Table of Uranium Fuel 12 Cycle Environmental Data (Normalized to model LWR annual fuel requirement [ASH-1248] or 13 reference reactor-year [NUREG-0116]). Specific categories of natural resource use included in 14 Table S-3 include land use; water consumption and thermal effluents; radioactive releases; 15 burial of transuranic waste, high-level waste, and low-level waste; and radiation doses from 16 transportation and occupational exposures. 10 CFR 51.51(a) states that environmental reports 17 related to the construction of nuclear power plants shall include Table S-3.
18 The environmental impacts associated with transporting fresh fuel to one model LWR and with 19 transporting spent fuel and radioactive waste (low-level waste and mixed waste) from that LWR 20 are provided in 10 CFR 51.52(c), Table S-4, Environmental Impact of Transportation of Fuel 21 and Waste To and From One Light-Water-Cooled Nuclear Power Reactor. 10 CFR 51.52, 22 Environmental effects of transportation of fuel and wasteTable S-4, requires the 23 consideration of Table S-4 in environmental reports related to the construction of nuclear power 24 plants.
25 Nuclear fuel is needed for the operation of nuclear power plants during the SLR term in the 26 same way that it is needed during the initial license term. Therefore, the factors that affect the 27 data presented in Tables S-3 and S-4 do not change whether a nuclear power plant is operating 28 under its initial license or a subsequent renewed license. The following sections address the 29 site-specific environmental impacts of Turkey Point SLR on four environmental issues related to 30 the uranium fuel cycle.
31 2.15.1      Offsite Radiological Impacts - Individual Impacts from Other than the Disposal 32            of Spent Fuel and High-Level Waste 33 The primary indicators of offsite radiological impacts on individuals who live near uranium fuel 34 cycle facilities are the concentrations of radionuclides in the effluents from the fuel-cycle 35 facilities and the radiological doses received by an MEI on the site boundary or at some location 36 away from the site boundary. The basis for establishing the significance of individual effects is 37 the comparison of the releases in the effluents and the MEI doses with the permissible levels in 38 applicable regulations. The analyses performed by the NRC in the preparation of Table S-3 39 indicate that if the facilities operate under a valid license issued by either the NRC or an 40 agreement State, the individual effects will meet the applicable regulations. Based on these 41 considerations, the NRC has concluded that the impacts on individuals from radioactive 42 gaseous and liquid releases during the SLR term would remain at or below the NRCs 43 regulatory limits. Efforts needed to keep releases and doses ALARA will continue to apply to 44 fuel-cycle-related activities. The NRC staff has identified no information or situations that would 45 result in different impacts for this issue for the SLR term at Turkey Point. Therefore, the NRC 46 staff concludes that offsite radiological impacts of the uranium fuel cycle (individual effects from 2-71
 
1 sources other than the disposal of spent fuel and high-level waste) due to continued nuclear 2 power plant operations at Turkey Point during the SLR term would be SMALL.
3 2.15.2    Offsite Radiological Impacts - Collective Impacts from Other than the Disposal 4            of Spent Fuel and High-Level Waste 5 The focus of this issue is the collective radiological doses to and health impacts on the public 6 resulting from uranium fuel cycle facilities during the SLR term. The radiological doses received 7 by the public are calculated based on releases from the uranium fuel-cycle facilities to the 8 environment, as provided in Table S-3. These estimates were provided in the 1996 LR GEIS for 9 the gaseous and liquid releases listed in Table S-3 as well as for radon-222 and technetium-99 10 releases (Rn-222 and Tc-99), which are not listed in Table S-3. The population dose 11 commitments were normalized for each year of operation of the model nuclear power plant 12 (reference reactor-year).
13 Based on the analyses provided in the 1996 LR GEIS, the estimated involuntary 100-year dose 14 commitment to the U.S. population resulting from the radioactive gaseous releases from 15 uranium fuel-cycle facilities (excluding the nuclear power plants and releases of Rn-222 and 16 Tc-99) was estimated to be 400 person-rem (4 person-Sv) per reference reactor-year. Similarly, 17 the environmental dose commitment to the U.S. population from the liquid releases was 18 estimated to be 200 person-rem (2 person-Sv) per reference reactor-year. As a result, the total 19 estimated involuntary 100-year dose commitment to the U.S. population from radioactive 20 gaseous and liquid releases listed in Table S-3 was given as 600 person-rem (6 person-Sv) per 21 reference reactor-year (see Section 6.2.2 of the 1996 LR GEIS).
22 The doses received by most members of the public would be so small that they would be 23 indistinguishable from the variations in natural background radiation. There are no regulatory 24 limits applicable to collective doses to the public from fuel cycle facilities. All regulatory limits are 25 based on individual doses. All fuel-cycle facilities are designed and operated to meet the 26 applicable regulatory limits.
27 Based on its consideration of the available information, the Commission concluded that these 28 impacts are acceptable in that they would not be sufficiently large to require the conclusion, for 29 any nuclear power plant, that the option of extended operation under 10 CFR Part 54 should be 30 eliminated. Accordingly, the Commission has not assigned a single level of significance for the 31 collective effects of the fuel cycle. The NRC staff has identified no information or situations that 32 would result in different impacts for this issue for the SLR term at Turkey Point. Therefore, the 33 NRC staff concludes that offsite radiological impacts of the uranium fuel cycle (collective 34 impacts from other than the disposal of spent fuel and high-level waste) due to continued 35 nuclear power plant operations at Turkey Point during the SLR term would not be sufficiently 36 large to require the conclusion that the option of Turkey Point SLR should be eliminated.
37 2.15.3    Nonradiological Impacts of the Uranium Fuel Cycle 38 Nonradiological impacts associated with the uranium fuel cycle as they relate to license renewal 39 are provided in Table S-3. The significance of the environmental impacts associated with land 40 use, water use, fossil fuel use, and chemical effluents were evaluated in the 1996 LR GEIS 41 based on several relative comparisons. The land requirements were compared to those for a 42 coal-fired power plant that could be built to replace the nuclear capacity if the operating license 43 is not renewed. Water requirements for the uranium fuel cycle were compared to the annual 44 requirements for a nuclear power plant. The amount of fossil fuel (coal and natural gas) 2-72
 
1 consumed to produce electrical energy and process heat during the various phases of the 2 uranium fuel cycle was compared to the amount of fossil fuel that would have been used if the 3 electrical output from the nuclear power plant were supplied by a coal-fired plant. Similarly, the 4 gaseous effluents SO2, nitric oxide (NO), hydrocarbons, carbon monoxide (CO), and other 5 particulate matter (PM) released because of the coal-fired electrical energy used in the uranium 6 fuel cycle were compared with equivalent quantities of the same effluents that would be 7 released from a 45-megawatt electric coal-fired plant. It was noted that the impacts associated 8 with uses of all resources would be SMALL. Any impacts associated with nonradiological liquid 9 releases from the fuel-cycle facilities would also be SMALL. The NRC staff has identified no 10 information or situations that would result in different impacts for this issue for the SLR term at 11 Turkey Point. Therefore, the NRC staff concludes that the aggregate nonradiological impacts of 12 the uranium fuel cycle due to continued nuclear power plant operations at Turkey Point during 13 the SLR term would be SMALL.
14 2.15.4    Transportation 15 The environmental impacts associated with the transportation of nuclear fuel and waste to and 16 from one model nuclear power plant as they relate to license renewal are addressed in 17 Table S-4. Table S-4 forms the basis for analysis of the environmental impacts of the 18 transportation of nuclear fuel and waste when evaluating applications for nuclear power plant 19 license renewal. The applicability of Table S-4 to license renewal applications was extensively 20 evaluated in the 1996 LR GEIS (NRC 1996) and its Addendum 1 (NRC 1999). The 21 environmental impacts from the transportation of fuel and waste attributable to license renewal 22 were found to be SMALL when they are within the parameters identified in 10 CFR 51.52. The 23 NRC staff has identified no information or situations that would result in different impacts for this 24 issue for the SLR term at Turkey Point and determined that Turkey Point is within the 25 parameters identified in 10 CFR 51.52. Therefore, the NRC staff concludes that the 26 transportation impacts of the uranium fuel cycle due to continued nuclear power plant 27 operations at Turkey Point during the SLR term would be SMALL.
28 2.16 Termination of Nuclear Power Plant Operations and Decommissioning 29 The following section addresses the site-specific environmental impacts of Turkey Point SLR on 30 one environmental issue related to termination of nuclear power plant operations and 31 decommissioning.
32 2.16.1    Termination of Plant Operations and Decommissioning 33 The decommissioning process begins when a licensee informs the NRC that it has permanently 34 ceased reactor operations, defueled, and intends to decommission the nuclear power plant. The 35 licensee may also notify the NRC of the permanent cessation of reactor operations prior to the 36 end of the license term. Consequently, most nuclear power plant activities and systems 37 dedicated to reactor operations would cease after reactor shutdown. The environmental impacts 38 of decommissioning a nuclear power plant are evaluated NUREG-0586, Generic 39 Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, 40 Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002b). The NRC staff 41 determined that license renewal would have a negligible effect on these impacts of terminating 42 operations and decommissioning on all resources. The NRC staff has identified no information 43 or situations that would result in different environmental impacts for this issue for the SLR term 44 at Turkey Point. Therefore, the NRC staff concludes that the incremental environmental impacts 45 of terminating plant operations and decommissioning due to continued nuclear power plant 46 operations at Turkey Point during the SLR term would be SMALL.
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1                                      3    CONCLUSION 2 This environmental impact statement (EIS), together with the Generic Environmental Impact 3 Statement for License Renewal of Nuclear Plants, Supplement 5, Second Renewal, Regarding 4 Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, Final 5 Report (FSEIS), contains the U.S. Nuclear Regulatory Commission (NRC) staffs environmental 6 review of the Florida Power & Light Company (FPL) subsequent license renewal (SLR) 7 application, as supplemented, for Turkey Point Nuclear Generating Unit Nos. 3 and 4. This 8 chapter of the EIS briefly summarizes the environmental impacts of Turkey Point SLR, the 9 environmental impacts of alternatives to Turkey Point SLR, and the NRC staffs preliminary 10 recommendation regarding its environmental review of Turkey Point SLR. The NRC staffs final 11 recommendation will be presented in the staffs final EIS, which will be issued after the staffs 12 consideration of public comments on this draft EIS.
13 3.1    Environmental Impacts of the Proposed Federal Action 14 This EIS supplements the FSEIS evaluation of the environmental issues that were dispositioned 15 as Category 1 issues (generic to all or a distinct subset of nuclear power plants) in the FSEIS by 16 reference to Table B-1 in Appendix B to Subpart A of Title 10 of the Code of Federal 17 Regulations (10 CFR) Part 51, Environmental Protection Regulations for Domestic Licensing 18 and Related Regulatory Functions, and NUREG-1437, Generic Environmental Impact 19 Statement for License Renewal of Nuclear Plants, Revision 1, Final Report (LR GEIS). Through 20 the consideration of any significant new information, this EIS also updates the FSEIS evaluation 21 of the environmental issues that were dispositioned as Category 2 issues (specific to individual 22 nuclear power plants) in the FSEIS. Together, this EIS and the FSEIS evaluate, on a site-23 specific basis, all of the environmental impacts of continued operation during the SLR term of 24 Turkey Point Unit 3 from July 19, 2032, to July 19, 2052, and Turkey Point Unit 4 from April 10, 25 2033, to April 10, 2053.
26 After reviewing the environmental impacts of Turkey Point SLR in this EIS and the FSEIS, the 27 NRC staff concludes that Turkey Point SLR would have SMALL impacts, with the following 28 exceptions: (1) for groundwater quality degradation, the impact would be SMALL 29 toMODERATE; (2) for groundwater use conflicts, the impact would be SMALL to MODERATE; 30 and (3) for aquatic resources (impingement and entrainment and thermal impacts), the impact 31 would be SMALL to MODERATE. The NRC staff considered mitigation measures for each 32 issue, as applicable, and concludes that no additional mitigation measures would be warranted.
33 3.2    Comparison of Alternatives 34 As part of its environmental review, the NRC is required to consider reasonable alternatives to 35 SLR and to evaluate the environmental impacts associated with each alternative. These 36 alternatives can include other methods of power generation (replacement power alternatives),
37 as well as not authorizing the operation of Turkey Point for an additional 20 years (the no-action 38 alternative).
39 In Chapter 4, Environmental Consequences and Mitigating Actions, of the FSEIS, the NRC 40 staff initially considered 16 replacement power alternatives but later dismissed 13 of them 41 because of technical, resource availability, or commercial limitations that existed at that time, 42 and that the NRC staff believed are likely to still exist when the Turkey Point subsequent 3-1
 
1 renewed licenses expire. This left the following three feasible and commercially viable 2 replacement power alternatives:
3
* new nuclear power 4
* natural gas combined-cycle power 5
* a combination of new natural gas combined-cycle and new solar photovoltaic power.
6 The NRC staff evaluated these alternatives, along with the no-action alternative, in depth in 7 Chapter 4 of the FSEIS (NRC 2019a). Additionally, the NRC staff evaluated an alternative 8 cooling water system to mitigate potential impacts associated with the continued use of the 9 existing cooling canal system. Finally, Appendix F of the FSEIS evaluated any new and 10 significant information that could alter the conclusions of the site-specific severe accident 11 mitigation alternatives (SAMA) analysis that was performed previously in connection with the 12 initial license renewal of Turkey Point. In developing this EIS, the NRC staff has identified no 13 significant new information that would change these discussions in the FSEIS.
14 Based on the evaluation in the FSEIS, as supplemented by this EIS, the NRC staff concludes 15 that the environmentally preferred alternative is the proposed action of authorizing SLR for 16 Turkey Point (i.e., operation for a period of 20 years beyond the expiration dates of the initial 17 renewed licensesi.e., until July 19, 2052, for Turkey Point Unit 3 and April 10, 2053, for 18 Turkey Point Unit 4). As shown in Table 2-2, Summary of Environmental Impacts of the 19 Proposed Action and Alternatives, of the FSEIS, all of the reasonable power-generation 20 alternatives have impacts in at least two resource areas that are greater than the impacts of 21 SLR, in addition to the environmental impacts inherent to new construction projects. To make up 22 the lost power generation if the NRC does not authorize operation for the SLR period (i.e., the 23 no-action alternative), energy decision-makers may implement one of the replacement power 24 alternatives discussed in the FSEIS, or a comparable alternative capable of replacing the power 25 generated by Turkey Point.
26 3.3      Preliminary Recommendation 27 This EIS supplements the FSEIS evaluation of the environmental impacts of SLR for Turkey 28 Point on a site-specific basis, and concludes that the environmental impacts of SLR, including 29 new information and impacts that were previously dispositioned as Category 1 issues, do not 30 warrant any modification to the NRC staffs previous determination in the FSEIS that the 31 adverse environmental impacts of SLR for Turkey Point are not so great that preserving the 32 option of SLR for energy-planning decision-makers would be unreasonable. Accordingly, the 33 NRC staffs preliminary recommendation is that the adverse environmental impacts of SLR for 34 Turkey Point Units 3 and 4 for an additional 20 years beyond the expiration dates of the initial 35 renewed licenses are not so great that preserving the option of SLR for energy-planning 36 decision-makers would be unreasonable. The NRC staff bases this recommendation on the 37 following:
38
* FPLs environmental report, as supplemented 39
* the NRC staffs consultation with Federal, State, Tribal, and local government agencies 40
* the NRC staffs independent environmental review, which is documented in the FSEIS and 41      this EIS 42
* the NRC staffs consideration of public comments.
43 3-2
 
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1 [NRC] U.S. Nuclear Regulatory Commission. 2000. Alternative Radiological Source Terms for 2 Evaluating Design Basis Accidents at Nuclear Power Reactors. Regulatory Guide 1.183, 3 Washington D.C. ADAMS Accession No. ML003716792.
4 [NRC] U.S. Nuclear Regulatory Commission. 2002a. Generic Environmental Impact Statement 5 for License Renewal of Nuclear Plants Regarding Turkey Point Plant Units 3 and 4, Final 6 Report. NUREG-1437, Supplement 5. January 2002. 669 p. ADAMS Accession Nos.
7 ML020280119, ML020280202, and ML020280226.
8 [NRC] U.S. Nuclear Regulatory Commission. 2002b. Generic Environmental Impact Statement 9 on Decommissioning of Nuclear Facilities Regarding the Decommissioning of Nuclear Power 10 Reactors. NUREG-0586, Supplement 1. ADAMS Accession No. ML023470304.
11 [NRC] U.S. Nuclear Regulatory Commission. 2009a. Options to Revise Radiation Protection 12 Regulations and Guidance with Respect to the 2007 Recommendations of the International 13 Commission on Radiological Protection. SRM-SECY-08-0197. ADAMS Accession No.
14 ML090920103.
15 [NRC] U.S. Nuclear Regulatory Commission. 2009b. Radiological Environmental Monitoring for 16 Nuclear Power Plants. Regulatory Guide 4.1, Revision 2. June 2009. 20 p. ADAMS Accession 17 No. ML091310141.
18 [NRC] U.S. Nuclear Regulatory Commission. 2011. Letter from J. Paige to M. Nazar, dated 19 June 23, 2011, regarding Turkey Point Units 3 and 4 - Issuance of Amendments Regarding 20 Alternative Source Term (TAC NOS. ME1624 and ME1625). Washington D.C. ADAMS 21 Accession No. ML110800666.
22 [NRC] U.S. Nuclear Regulatory Commission. 2013a. Generic Environmental Impact Statement 23 for License Renewal of Nuclear Plants. NUREG-1437, Revision 1, Volumes 1, 2, and 3.
24 June 2013. 1,535 p. ADAMS Package Accession No. ML13107A023.
25 [NRC] U.S. Nuclear Regulatory Commission. 2013b. Memorandum of Understanding Between 26 the U.S. Nuclear Regulatory Commission and the Occupational Safety and Health 27 Administration. September 6, 2013. ADAMS Accession No. ML11354A432.
28 [NRC] U.S. Nuclear Regulatory Commission. 2014a. Generic Environmental Impact Statement 29 for Continued Storage of Spent Nuclear Fuel. NUREG-2157, Volumes 1 and 2. September 30 2014. ADAMS Package Accession No. ML14198A440.
31 [NRC] U.S. Nuclear Regulatory Commission. 2014b. Turkey Point Nuclear Generating Unit Nos.
32 3 and 4 - Issuance of Amendments under Exigent Circumstances Regarding Ultimate Heat Sink 33 and Component Cooling Water Technical Specifications. April 8, 2014. ADAMS Accession No.
34 ML14199A107.
35 [NRC] U.S. Nuclear Regulatory Commission. 2016. Environmental Impact Statement for 36 Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7, Final Report.
37 NUREG-2176. October 2016. 2,092 p. ADAMS Package Accession No. ML16335A219.
38 [NRC] U.S. Nuclear Regulatory Commission. 2018. Biological Assessment for the Turkey Point 39 Nuclear Generating Unit Nos. 3 and 4 Proposed Subsequent License Renewal. December 40 2018. ADAMS Package Accession No. ML18344A008.
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1 [NRC] U.S. Nuclear Regulatory Commission. 2019. Generic Environmental Impact Statement 2 for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for Turkey 3 Point Nuclear Generating Unit Nos. 3 and 4, Draft Report for Comment. NUREG-1437, 4 Supplement 5, Second Renewal. March 2019. 429 p. ADAMS Accession No. ML19078A330.
5 [NRC] U.S. Nuclear Regulatory Commission. 2019a. Generic Environmental Impact Statement 6 for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for Turkey 7 Point Nuclear Generating Unit Nos. 3 and 4, Final Report. NUREG-1437, Supplement 5, 8 Second Renewal. October 2019. 656 p. ADAMS Accession No. ML19290H346.
9 [NRC] U.S. Nuclear Regulatory Commission. 2019b. Issuance of Subsequent Renewed Facility 10 Operating License Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Unit Nos. 3 11 and 4. December 4, 2019. ADAMS Accession No. ML19305C879.
12 [NRC] U.S. Nuclear Regulatory Commission. 2019c. Record of Decision, U.S. Nuclear 13 Regulatory Commission, Docket Nos. 50-250 and 50-251, Subsequent License Renewal 14 Application for Turkey Point Nuclear Generating Unit Nos. 3 and 4. December 4, 2019. ADAMS 15 Accession No. ML19309F859.
16 [NRC] U.S. Nuclear Regulatory Commission. 2019d. Appendix B to Subsequent Renewed 17 Facility Operating Licenses Nos. DRP-31 and DPR-41 Turkey Point Nuclear Generating Units 18 Nos. 3 and 4 Environmental Protection Plan (EPP) (Non-Radiological). December 4, 2019.
19 ADAMS Accession No. ML19308B570.
20 [NRC] U.S. Nuclear Regulatory Commission. 2020a. Letter to D. Moul from R.J. Bernardo, 21 dated March 24, 2020, regarding Turkey Point Units 3 and 4 - Documentation of the 22 Completion of Required Actions Taken in Response to the Lessons Learned from the 23 Fukushima Dai-ichi Accident. Washington D.C. ADAMS Accession No. ML20055F060.
24 [NRC] U.S. Nuclear Regulatory Commission. 2022a. Commission Memorandum and Order in 25 the Matter of Florida Power & Light Company (Turkey Point Nuclear Generating Units 3 and 4).
26 CLI-22-02, Rockville, Maryland. ADAMS Accession No. ML22055A496.
27 [NRC] U.S. Nuclear Regulatory Commission. 2022b. Commission Memorandum and Order in 28 the Matter of Duke Energy Carolinas, LLC (Oconee Nuclear Station, Units 1, 2, and 3), Exelon 29 Generation Company, LLC (Peach Bottom Atomic Power Station, Units 2 and 3), Florida Power 30 & Light Company (Turkey Point Nuclear Generating Units 3 and 4), NextEra Energy Point 31 Beach, LLC (Point Beach Nuclear Plant, Units 1 and 2), and Virginia Electric and Power 32 Company (North Anna Power Station, Units 1 and 2). CLI-22-03, Rockville, Maryland. ADAMS 33 Accession No. ML22055A533.
34 [NRC] U.S. Nuclear Regulatory Commission. 2022c. Commission Memorandum and Order in 35 the Matter of Florida Power & Light Company (Turkey Point Nuclear Generating Units 3 and 4).
36 CLI-22-06, Rockville, Maryland. ADAMS Accession No. ML22154A215.
37 [NRC] U.S. Nuclear Regulatory Commission. 2022d. Commission Memorandum and Order in 38 the Matter of Exelon Generation Company, LLC (Peach Bottom Atomic Power Station, Units 2 39 and 3). CLI-22-04, Rockville, Maryland. ADAMS Accession No. ML22055A557.
40 [NRC] U.S. Nuclear Regulatory Commission. 2022e. Turkey Point Nuclear Generating, Units 3 41 and 4Modification to Subsequent Renewed Facility Operating License Nos. DPR-31 and 4-11
 
1 DPR-41 in Conjunction with Commission Memorandum and Order CLI-22-02. ADAMS Package 2 Accession No. ML22073A121.
3 [NRC] U.S. Nuclear Regulatory Commission. 2022f. Occupational Radiation Exposure at 4 Commercial Nuclear Power Reactors and Other Facilities 2020: Fifty-Third Annual Report.
5 NUREG-0713, Volume 42. September 2022. ADAMS Accession No. ML22276A269.
6 [NRC] U.S. Nuclear Regulatory Commission. 2023. Turkey Point Nuclear Generating Station, 7 Units 3 and 4 Summary of the Environmental Remote Audit Related to the Review of the 8 Subsequent License Renewal Application. February 6, 2023. ADAMS Package Accession No.
9 ML23031A190.
10 Pollution Prevention Act of 1990. Public Law 101-508 11 Resource Conservation and Recovery Act of 1976. 42 U.S.C. &sect; 6901 et seq.
12 Romberg, G.P., S.A. Spigarelli, W. Prepejchal, M.M. Thommes, J.W. Gibbons, and R.R. Sharitz.
13 1974. Fish Behavior at a Thermal Discharge into Lake Michigan. Thermal Ecology 14 Symposium. CONF-730505. Aiken, South Carolina.
15 [SFWMD] South Florida Water Management District. 2017. Florida Power & Light Company 16 Turkey Point Groundwater Recovery Well System Permit. February 27, 2017.
17 [SFWMD] South Florida Water Management District. 2018. Lower East Coast Water Supply 18 Plan Update, Appendices, Appendix D.
19 [Traf Tech]. Traf Tech Engineering, Inc. 2009. Turkey Point Power Plant Peak Construction 20 Analysis, Traffic Study. Tamarac, Florida. Accession No. ML16167A504.
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26 [UNSCEAR] United Nations Scientific Committee on the Effects of Atomic Radiation. 2010.
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35 Available at <https://www2.census.gov/census_2000/census2000/states/fl.html> (accessed 36 March 28, 2023).
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2 Available at <https://www2.census.gov/library/publications/decennial/2010/cph-2/cph-2-11.pdf>
3 (accessed March 28, 2023).
4 [USCB] U.S. Census Bureau. 2020. 2020 Decennial Census for Miami-Dade County, Table P1.
5 Available at 6 <https://data.census.gov/table?g=0500000US12086&y=2020&d=DEC+Redistricting+Data+(PL+
7 94-171)&tid=DECENNIALPL2020.P1> (accessed December 16, 2022).
8 [USCB]U.S. Census Bureau. 2022a. 2021 American Community Survey 1-Year Estimates, 9 Table DP04. Available at 10 <https://data.census.gov/table?q=dp&g=0500000US12086&tid=ACSDP1Y2021.DP04>
11 (accessed December 16, 2022).
12 [USCB] U.S. Census Bureau. 2022b. 2021 American Community Survey 1-Year Estimates, 13 Table B25004. Available at 14 <https://data.census.gov/table?q=B25004&g=0500000US12086&tid=ACSDT1Y2021.B25004>
15 (accessed December 16, 2022).
16 [USCB] U.S. Census Bureau. 2022c. 2021 American Community Survey 1-Year Estimates, 17 Table DP03. Available at 18 <https://data.census.gov/table?q=DP03:+SELECTED+ECONOMIC+CHARACTERISTICS&g=0 19 100000US_0500000US12086&tid=ACSDP1Y2021.DP03> (accessed December 20, 2022).
20 WLRN 2022. WLRN Public Radio and Television. Miami-Dade Surpasses Chicago as the 21 Nations Third Largest School District. October 3, 2022. Available at 22 <https://www.wlrn.org/education/2022-10-03/miami-dade-surpasses-chicago-as-the-nations-23 third-largest-school-district-at-least-for-now> (accessed December 5, 2022).
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1                                    5    LIST OF PREPARERS 2 Members of the U.S. Nuclear Regulatory Commission (NRC) Office of Nuclear Material Safety 3 and Safeguards (NMSS) prepared this environmental impact statement with assistance from 4 other NRC organizations. Table 5-1 identifies each contributors name, education and 5 experience, and function or expertise.
6 Table 5-1      List of Preparers Name                        Education and Experience                Function or Expertise Beth Alferink        MS Environmental Engineering; MS Nuclear        Human Health, Termination of Engineering; BS Nuclear Engineering; 25 years    Operations and Decommissioning, of national laboratory, industry, and government Radiological and Nonradiological experience including radiation detection and    Waste Management, Uranium measurements, nuclear power plant emergency      Fuel Cycle, Spent Fuel response, operations, health physics, decommissioning, shielding and criticality Briana Arlene        Masters Certification, National Environmental  Terrestrial Resources, Aquatic Policy Act; BS Conservation Biology; 18 years of Resources, Federally Protected experience in ecological impact analysis,        Ecological Resources, Cumulative Endangered Species Act Section 7                Impacts consultations, and Essential Fish Habitat consultations Lloyd Desotell        MS Civil Engineering; MS Water Resources        Surface Water Resources, Management; BA Environmental Studies; Over      Groundwater Resources 20 years of experience conducting surface and subsurface hydrologic analyses Jerry Dozier          M.S. Reliability Engineering; MBA Business      Postulated Accidents Administration; BS Mechanical Engineering; 30+
years of experience including operations, reliability engineering, technical reviews, and NRC branch management Lifeng Guo            PhD Hydrogeology; MS Geology;                    Surface Water Resources, BS Hydrogeology and Engineering Geology;        Groundwater Resources, and Registered Professional Geologist; Over          Geologic Environment 30 years of combined experience in hydrogeologic investigation, hydrogeochemical analysis, and remediation Robert Hoffman        B.S. Environmental Resource Management;          Replacement Power Alternatives, 37 years of experience in NEPA compliance,      Air Quality, Noise environmental impact assessment, alternatives identification and development, and energy facility siting Nancy Martinez        BS Earth and Environmental Science; A.M.        Historic and Cultural Resources, Earth and Planetary Science; 11 years of        Socioeconomics, Environmental experience in environmental impact analysis      Justice 7
5-1
 
1 Table 5-1      List of Preparers (Continued)
Name                      Education and Experience                    Function or Expertise Philip Meyer          PhD Civil Engineering; BA Physics; 30 years      Groundwater Resources relevant experience in subsurface hydrology and contaminant transport, including 15 years of experience in groundwater resource assessment and environmental impacts analysis Donald Palmrose        PhD Nuclear Engineering; MS Nuclear              Postulated Accidents, Radiological Engineering; BS Nuclear Engineering;            and Nonradiological Waste 35 years of experience including operations on  Management U.S. Navy nuclear powered surface ships, technical and NEPA analyses, nuclear authorization basis support for DOE, and NRC project management Lance Rakovan          BS Engineering Physics; MS Nuclear              Environmental Project Manager Engineering; Project Management Professional (PMP); 25+ years project management experience; 20+ years of experience facilitating public NEPA interactions Jeffrey Rikhoff        M.R.P. Regional Environmental Planning; MS      Land Use, Visual Resources, Air Development Economics; BA English;              Quality and Noise, Cumulative 43 years of combined industry and Government Impacts experience in NEPA compliance for DOE Defense Programs/NNSA and Nuclear Energy, DoD, and DOI; project management; socioeconomics and environmental justice impact analysis, historic and cultural resource impact assessments, consultation with American Indian Tribes, and comprehensive land use and development planning studies Ted Smith              MS Environmental Engineering; BS Electrical      Management Oversight Engineering; 38 years of experience, including DOE Power Administration, support of site Environmental Management programs, and spent fuel management, oversight of U.S. Navy nuclear ships design, construction, and operation, NRC project management and management 2
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1        6    LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS 2              TO WHOM COPIES OF THIS ENVIRONMENTAL IMPACT 3                                  STATEMENT ARE SENT 4 Table 6-1      List of Agencies, Organizations, and Persons to Whom Copies of this 5                Environmental Impact Statement Are Sent Name                                          Affiliation Ayres, Richard                          Friends of the Earth Bennett, Elise Pautler                  Center for Biological Diversity Bryan, Stephanie                        Poarch Band of Creek Indians Chase, Kelly                            Florida State Historic Preservation Office Cody, Sarah                            Miami-Dade County Office of Historic Preservation Cypress, Talbert                        Miccosukee Tribe of Indians of Florida Dean, William Kenneth                  U.S. Environmental Protection Agency Hayes, Dr. Rose                        Citizen Hill, David                            The Muscogee (Creek) Nation Johnson, Lewis                          Seminole Nation of Oklahoma Lotane, Alissa                          Florida Division of Historical Resources Nelson, Reid                            Advisory Council on Historic Preservation Nester, Lindsay                        U.S. Fish and Wildlife Service Osceola, Marcellus                      Seminole Tribe of Florida Pate, Haigler                          U.S. National Park Service Perez, Gano                            The Muscogee Nation Reiser, Caroline                        Natural Resources Defense Council Silverstein, Rachel                    Miami Waterkeeper Soweka, Robin                          The Muscogee Nation Sprinkle, James                        Citizen Strand, Dianne                          Florida Power & Light Co.
Watson, Tracy                          U.S. Environmental Protection Agency 6
6-1
 
1                                          APPENDIX A 2
3        COMMENTS RECEIVED ON THE TURKEY POINT NUCLEAR 4          GENERATING UNITS 3 AND 4 ENVIRONMENTAL REVIEW 5 A.1    Comments Received During the Scoping Period 6 The scoping process for this site-specific environmental impact statement for Turkey Point 7 Nuclear Generating Unit Nos. 3 and 4 (Turkey Point) subsequent license renewal began in 8 October 2022, in accordance with the National Environmental Policy Act of 1969, as amended 9 (42 U.S.C. 4321 et seq.). On October 7, 2022, the U.S. Nuclear Regulatory Commission (NRC) 10 issued a notice of its intent to prepare an environmental impact statement and to conduct an 11 environmental scoping process for subsequent license renewal of Turkey Point that was 12 published in the Federal Register (87 FR 61104). Comments were received by email and 13 through the regulations.gov website.
14 The NRC received comments during the scoping process, which identified important issues that 15 were addressed by the NRC staff in this environmental impact statement. In accordance with 16 the NRCs regulations, the scoping summary report provides a concise summary of the 17 determinations and conclusions reached as a result of the scoping process and is available at 18 Agencywide Documents Access and Management System Accession No. ML23198A271 19 (NRC 2023).
20 A.2    References 21 87 FR 61104. October 7, 2022. Notice of Intent to Conduct Scoping Process and Prepare 22 Environmental Impact Statement Florida Power & Light Company Turkey Point Nuclear 23 Generating Unit Nos. 3 and 4. Federal Register, Nuclear Regulatory Commission.
24 National Environmental Policy Act of 1969, as amended. 42 U.S.C. &sect; 4321 et seq.
25 [NRC] U.S. Nuclear Regulatory Commission. 2023. Environmental Impact Statement Scoping 26 Process Summary Report Turkey Point Nuclear Generating Unit Nos. 3 and 4 Miami-Dade 27 County, FL. Rockville, Maryland. ADAMS Accession No. ML23198A271.
A-1
 
1                                              APPENDIX B 2
3                          CONSULTATION CORRESPONDENCE 4 B.1    Federally Protected Ecological Resources 5 Appendix C.1 of the Generic Environmental Impact Statement for License Renewal of Nuclear 6 Plants, Supplement 5, Second Renewal, Regarding Subsequent License Renewal for Turkey 7 Point Nuclear Generating Unit Nos. 3 and 4, Final Report (NUREG-1437, Supplement 5, 8 Second Renewal; NRC 2019) (FSEIS) describes the U.S. Nuclear Regulatory Commission 9 (NRC) consultations concerning federally protected ecological resources protected under the 10 Endangered Species Act of 1973, as amended (ESA; 16 U.S.C. 1531 et seq.), Magnuson-11 Stevens Fishery Conservation and Management Act, as amended (16 U.S.C. 1801 et seq.), and 12 National Marine Sanctuaries Act of 1966, as amended (16 U.S.C. 1431 et seq.). Since the 13 issuance of the FSEIS, the NRC staff engaged in reinitiated ESA consultation with the U.S. Fish 14 and Wildlife Service (FWS) concerning the continued operation of Turkey Point Nuclear 15 Generating Unit Nos. 3 and 4 (Turkey Point, Turkey Point Units 3 and 4). This section describes 16 that consultation and Table B-1 lists the correspondence related to the consultation.
17 Table B-1      Endangered Species Act Section 7 Consultation Correspondence with the 18                U.S. Fish and Wildlife Service Date                              Description                    ADAMS Accession No.(a)
Nov 18, 2021        NRC to FWS, Request to reinitiate ESA Section 7          ML21307A152 consultation for continued operation of Turkey Point Mar 21, 2022        FWS to NRC, Amendment to July 25, 2019,                  ML22089A060 biological opinion for Turkey Point Apr 19, 2022        NRC to FPL, Transmittal of the FWSs March 21,            ML22094A094 2022, amendment to the 2019 biological opinion for Turkey Point 19 (a) Access these documents through the NRCs Agencywide Documents Access and Management System 20    (ADAMS) at https://adams.nrc.gov/wba/
21 On November 18, 2021, the NRC staff requested to reinitiate consultation with the FWS under 22 Section 7 of the ESA following two vehicular collision-related American crocodile (Crocodylus 23 acutus) mortalities in calendar year 2021 that were associated with Turkey Point operations.
24 These incidents exceeded the amount of allowable take of this species specified in the 25 incidental take statement of the FWSs 2019 biological opinion.
26 As a result of the reinitiated consultation, the FWS revised the amount of allowable take of the 27 American crocodile as follows:
28        The proposed Project is expected to result in the incidental take of crocodiles in 29        the form of harm from habitat loss and injuries or mortalities from vehicle 30        collisions and/or plant operation. The [FWS] expects no more than three 31        crocodiles be taken within a calendar year or ten crocodiles within a five-year 32        period.
33 The eastern indigo snake (Drymarchon couperi) was not subject to this consultation, and the 34 amount of allowable take for that species is unchanged.
B-1
 
1 B.2    National Historic Preservation Act Section 106 Consultation 2 The National Historic Preservation Act of 1966, as amended (NHPA; 54 U.S.C. 300101 et seq.),
3 requires Federal agencies to take into account the effects of their undertakings on historic 4 properties and consult with applicable State and Federal agencies, Tribal groups, individuals, 5 and organizations that have a demonstrated interest in the undertaking before taking action.
6 Historic properties are defined as resources that are eligible for listing in the National Register of 7 Historic Places. The historic preservation review process (Section 106 of the NHPA) is outlined 8 in regulations issued by the Advisory Council on Historic Preservation in Title 36 of the Code of 9 Federal Regulations (36 CFR) Part 800, Protection of Historic Properties. In accordance with 10 36 CFR 800.8(c), Use of the NEPA Process for Section 106 Purposes, the NRC has elected to 11 use the NEPA process to comply with its obligations under Section 106 of the NHPA.
12 Table B-2 lists the chronology of consultation and consultation documents related to the NRCs 13 NHPA Section 106 review of the Turkey Point subsequent license renewal application in this 14 environmental impact statement. The NRC staff is required to consult with the noted agencies 15 and organizations in accordance with the statute and regulations listed in the previous 16 paragraph.
17 Table B-2      National Historic Preservation Act Correspondence ADAMS Accession Date                  Sender and Recipient                Description              No.
October 12,    T. Smith, NRC, to S. Cody,                Request for Scoping ML22277A829 2022            Miami-Dade County Office of Historic      Comments Preservation October 12,    T. Smith, NRC, to R. Nelson,              Request for Scoping  ML22277A828 2022            Advisory Council on Historic Preservation  Comments October 12,    T. Smith, NRC, to A.S. Lotane, Florida    Request for Scoping  ML22277A830 2022            Division of Historical Resources          Comments October 12,    T. Smith, NRC, to T. Cypress, Miccosukee  Request for Scoping  ML22277A831 2022            Tribe of Indians of Florida                Comments October 12,    T. Smith, NRC, to D. Hill, The Muscogee    Request for Scoping  ML22277A831 2022            (Creek) Nation                            Comments October 12,    T. Smith, NRC, to S. A. Bryan, Poarch      Request for Scoping  ML22277A831 2022            Band of Creek Indians                      Comments October 12,    T. Smith, NRC, to L. J. Johnson, Seminole  Request for Scoping  ML22277A831 2022            Nation of Oklahoma                        Comments October 12,    T. Smith, NRC, to M. W. Osceola,          Request for Scoping  ML22277A831 2022            Seminole Tribe of Florida                  Comments October 14,    R. Soweka, Muscogee (Creek) Nation, to    Re: Request for      ML23103A048 2022            N. Martinez, NRC                          Scoping Comments October 17,    G Perez, Muscogee (Creek) Nation, to N. Re: Request for      ML23103A032 2022            Martinez, NRC                              Scoping Comments      ML22294A106 November 7,    T. Cypress, Miccosukee Tribe of Indians of Re: Request for      ML22314A095 2022            Florida, to T. Smith, NRC                  Scoping Comments November 28,    A. Slade, Florida Division of Historical  Re: Request for      ML23103A047 2022            Resources, to T. Smith, NRC                Scoping Comments B-2
 
1 B.3    References 2 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 3 Part 800, "Protection of Historic Properties."
4 Endangered Species Act of 1973. 16 U.S.C. &sect; 1531 et seq.
5 Magnuson-Stevens Fishery Conservation and Management Act. 16 U.S.C. &sect; 1801 et seq.
6 National Historic Preservation Act of 1966, as amended. 54 U.S.C. &sect; 300101 et seq.
7 National Marine Sanctuaries Act, as amended. 16 U.S.C. &sect; 1431 et seq.
8 [NRC] U.S. Nuclear Regulatory Commission. 2019. Generic Environmental Impact Statement 9 for License Renewal of Nuclear Plants, Supplement 5, Second Renewal, Regarding 10 Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4. NUREG-11 1437, Supplement 5, Second Renewal, Washington, D.C. ADAMS Accession No.
12 ML19290H346.
B-3
 
1                                            APPENDIX C 2
3  CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE 4 This appendix contains a chronological list of correspondence between the U.S. Nuclear 5 Regulatory Commission (NRC) and external parties as part of the agencys environmental 6 review of the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point) subsequent 7 license renewal application in this environmental impact statement (EIS). This appendix does 8 not include consultation correspondence or comments received. For a list and discussion of 9 consultation correspondence, see Appendix B, Consultation Correspondence, of this EIS. For 10 comments received, see Appendix A, Comments Received on the Turkey Point Nuclear 11 Generating Units 3 and 4 Environmental Review, of this EIS. All documents are available 12 electronically from the NRCs Public Electronic Reading Room found at 13 https://www.nrc.gov/reading-rm.html. From that site, the public can gain access to the 14 Agencywide Documents Access and Management System (ADAMS), which provides text and 15 image files of the NRCs public documents. The ADAMS accession number for each document 16 is included in the following table, which lists the environmental review correspondence, by date, 17 beginning with the Florida Power & Light Company (FPL) Subsequent License Renewal 18 Application - Appendix E Environmental Report Supplement 2 for Turkey Point.
19                        Table C-1    Environmental Review Correspondence ADAMS Date                          Correspondence Description                Accession No.
June 9, 2022            Subsequent License Renewal Application - Appendix E        ML22160A301 Environmental Report Supplement 2 September 28, 2022      Letter to William D. Maher, Licensing Director - Nuclear  ML22268A001 Licensing Projects, FPL - Turkey Point Units 3 & 4 Subsequent License Renewal Application Supplement Environmental Review November 18, 2022      Turkey Point Nuclear Generating Station, Units 3 And 4 -  ML22321A323 License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application Supplement February 1, 2023        Turkey Point Nuclear Generating Station, Units 3 and 4    ML23031A190 Summary of the Environmental Remote Audit Related to the Review of the Subsequent License Renewal Application March 3, 2023          Response to Requests for Additional Information (RAls) and ML23062A367 Requests for Confirmation of Information (RCls) Following Regulatory Audit of Subsequent License Renewal Application April 26, 2023          Memorandum of Understanding Between the NRC and the        ML23117A022 U.S. National Park Service 20 C-1
 
1                                            APPENDIX D 2
3                                    SEVERE ACCIDENTS 4 This appendix discusses severe accidents. License renewal applicants consider the 5 environmental impacts of severe accidents at nuclear power plants, their probability of 6 occurrence, and potential means available to mitigate those accidents in severe accident 7 mitigation alternatives (SAMA) analyses. The purpose of SAMA analyses is to identify design 8 alternatives, procedural modifications, or training activities that may further reduce the risks of 9 severe accidents at nuclear power plants and that are also potentially cost-beneficial to 10 implement. SAMA analyses include the identification and evaluation of SAMAs that may reduce 11 the radiological risk from a severe accident by preventing substantial core damage (i.e.,
12 preventing a severe accident) or by limiting releases from containment if substantial core 13 damage occurs (i.e., mitigating the impacts of a severe accident) (NRC 2013).
14 As part of the initial license renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 15 (Turkey Point), Florida Power & Light Company (FPL) submitted to the U.S. Nuclear Regulatory 16 Commission (NRC, or the Commission) an environmental report (ER) that included a SAMA 17 analysis for Turkey Point (FPL 2000). FPL based this SAMA analysis on (1) the Turkey Point 18 probabilistic safety assessment (PSA) for total accident frequency, core damage frequency 19 (CDF), and containment large early release frequency; and (2) a supplemental analysis of 20 offsite consequences and economic impacts for risk determination. The Turkey Point PSA 21 included a Level 1 analysis to determine the CDF from internally initiated events and a Level 2 22 analysis to determine containment performance during severe accidents. The offsite 23 consequences and economic impacts analyses used the MELCOR Accident Consequence 24 Code System 2 (MACCS2) code, Version 1.2, to determine the offsite risk impacts on the 25 surrounding environment and the public. Inputs for the impacts analyses included plant/site-26 specific values for core radionuclide inventory, source term and release fractions, 27 meteorological data, projected population distribution (based on 1990 census data, projected 28 out to 2025), emergency response evacuation modeling, and economic data. To help identify 29 and evaluate potential SAMAs, FPL considered insights and recommendations from SAMA 30 analyses for other plants, potential plant improvements discussed in NRC and industry 31 documents, and documented insights provided by Turkey Point staff.
32 In its environmental review of the initial license renewal for Turkey Point (NRC 2002), the NRC 33 staff evaluated the potential environmental impacts of plant accidents and examined each 34 SAMA (individually and, in some cases, in combination) to determine the SAMAs individual risk 35 reduction potential. The NRC staff then compared this potential risk reduction against the cost of 36 implementing the SAMA to quantify the SAMAs cost-benefit value. The NRC staff found that 37 FPL used a systematic and comprehensive process for identifying potential plant improvements 38 for Turkey Point and that its bases for calculating the risk reductions afforded by these plant 39 improvements were reasonable and generally conservative. Further, the NRC staff found that 40 FPLs estimates of the costs of implementing each SAMA were reasonable and consistent with 41 estimates developed for other nuclear power plants. In addition, the NRC staff determined that 42 FPLs cost-benefit comparisons were performed appropriately. The NRC staff concluded that 43 FPLs SAMA methods and implementation of those methods were sound, and it agreed with 44 FPLs conclusion that none of the candidate SAMAs were potentially cost-beneficial based on 45 conservative treatment of costs and benefits.
D-1
 
1 As part of the subsequent license renewal (SLR) for Turkey Point, FPL submitted to the NRC an 2 ER (FPL 2018a), which it supplemented by {{letter dated|date=April 10, 2018|text=letter dated April 10, 2018}} (FPL 2018b) that included 3 a SAMA discussion. According to Table B-1 in Appendix B to Subpart A of Title 10 of the Code 4 of Federal Regulations (10 CFR) Part 51, alternatives to mitigate severe accidents must be 5 considered for all plants that have not considered such alternatives and according to 10 CFR 6 51.53(c)(3)(ii)(L), [i]f the staff has not previously considered severe accident mitigation 7 alternatives for the applicants plant in an environmental impact statement or related supplement 8 or in an environmental assessment, a consideration of alternatives to mitigate severe accidents 9 must be provided in the ER. Therefore, in its ER, FPL did not provide another SAMA analysis 10 for Turkey Point; instead, FPL evaluated areas of new and significant information that could 11 affect the environmental impact of postulated severe accidents during the SLR period of 12 extended operation, and possible new and significant information as it relates to SAMAs.
13 In its environmental review of the SLR for Turkey Point in the Generic Environmental Impact 14 Statement for License Renewal of Nuclear Plants, Supplement 5, Second Renewal, Regarding 15 Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, Final 16 Report (NUREG-1437, Supplement 5, Second Renewal) (FSEIS), issued in October 2019, the 17 NRC staff reviewed FPLs assessment of the significance of new information that relates to the 18 prior SAMA analysis and determined that it was performed consistent with NRC-endorsed 19 guidance. The NRC staff concluded that (1) there was no new and significant information 20 related to the severe accidents at Turkey Point that would alter the conclusions reached in 21 NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear 22 Plants, Revision 1 (2013 LR GEIS) or Turkey Points previous SAMA analysis; and (2) actions 23 taken by the NRC and the nuclear industry since the publication of NUREG-1437, Generic 24 Environmental Impact Statement for License Renewal of Nuclear Plants, Revision 0 (1996 LR 25 GEIS), on which the Turkey Point SAMA analysis was based, reinforce the conclusion that the 26 probability-weighted consequences of a severe accident are SMALL for all nuclear power 27 plants, as stated in the 2013 LR GEIS, and further reduce the likelihood of finding a cost-28 beneficial SAMA that would substantially reduce the severe accident risk at Turkey Point.
29 After the publication of the FSEIS, the Commission determined that the 1996 LR GEIS and the 30 2013 LR GEIS did not consider SLR and that, therefore, the NRC staffs environmental review 31 for Turkey Point SLR was inadequate insofar as the staff relied upon the 1996 LR GEIS and the 32 2013 LR GEIS (NRC 2022a, 2022b, 2022c). Since the NRC staffs environmental review for 33 Turkey Point SLR with respect to the issue of SAMAs relied in part on the 1996 LR GEIS and 34 the 2013 LR GEIS, this appendix evaluates those aspects of the 1996 LR GEIS and 2013 LR 35 GEIS on a site-specific basis. As a result, taken together, this environmental impact statement 36 (EIS) and the FSEIS evaluate, on a site-specific basis, all of the SAMA-related environmental 37 impacts of continued operations during the SLR term for Turkey Point Unit 3 from July 19, 2032, 38 to July 19, 2052, and for Turkey Point Unit 4 from April 10, 2033, to April 10, 2053.
39 D.1    Severe Accident Analysis 40 The NRC staffs evaluation of SAMAs with respect to the environmental review for Turkey Point 41 SLR in the FSEIS was based, in part, on the generic analysis of the impacts of severe accidents 42 in the 1996 LR GEIS and the 2013 LR GEIS, the conclusion from which is summarized in 43 Table B-1 in Appendix B to Subpart A of 10 CFR Part 51 as follows:
44          The probability-weighted consequences of atmospheric releases, fallout onto 45          open bodies of water, releases to groundwater, and societal and economic 46          impacts from severe accidents are SMALL for all plants.
D-2
 
1 D.1.1      Turkey Point Relative Comparison to Other Plants 2 The 1996 LR GEIS concluded that the probability-weighted consequences and impacts of 3 severe accidents at all nuclear power plants were SMALL compared to other risks to which the 4 populations surrounding nuclear power plants are routinely exposed. As part of this generic 5 conclusion, the 1996 LR GEIS conservatively predicted an estimated population dose risk 6 (95 percent upper confidence bound dose in units of person-rem/reactor-year [RY]) to be 278 7 person-rem specifically for Turkey Point in Table 5.6. The Turkey Point predicted value in the 8 1996 LR GEIS is much less than the mean value (approximately 1,560 person-rem/RY) for all of 9 the other nuclear power plants evaluated in the 1996 LR GEIS. This means that the predicted 10 probability-weighted consequences of severe accidents specific to Turkey Point were far less 11 than the mean value for all plants in the generic SMALL impact determination. This comparison 12 to other nuclear power plants demonstrates the relative impact of severe accidents for Turkey 13 Point, which reinforces the site-specific conclusion that the probability-weighted consequences 14 of severe accidents for Turkey Point are SMALL.
15 Regarding severe accidents during the initial license renewal term, the NRC staff evaluated the 16 information in the Turkey Point initial license renewal application in consideration of the 17 probability-weighted consequences of severe accidents. FPL calculated a population dose risk 18 of 22 person-rem/RY, using a Level 3 PRA analysis with site-specific Turkey Point values during 19 the initial license renewal term. Thus, the ratio of the 1996 LR GEIS 95 percent upper 20 confidence bound population dose risk (278 person-rem/RY) to FPLs calculated value (22 21 person-rem/RY) for initial license renewal is 13. This essentially means that the Turkey Point 22 population dose risk value that was determined to be SMALL in the 1996 LR GEIS had since 23 been reduced by 1.3 orders of magnitude. The value calculated for the Turkey Point initial 24 license renewal demonstrates the magnitude of conservatism used in the 1996 LR GEIS 25 predicted values. The more recent plant-specific information and the conservatism built into the 26 1996 LR GEIS methodology reinforces the NRC staffs site-specific conclusion that the 27 probability-weighted consequences of severe accidents for Turkey Point are SMALL.
28 D.1.2      Further Reduction in the Subsequent License Renewal Submittal 29 Regarding the SLR term, the NRC staff evaluated the information in the Turkey Point SLR 30 application in consideration of the probability-weighted consequences of severe accidents and 31 concluded that the aggregate risk impact decreased by a factor of 18.3 compared to the Turkey 32 Point previous SAMA analysis for the initial license renewal term (FPL 2018c). The sources of 33 new information were those that the NRC staff determined to be important to severe accident 34 impacts and included new internal events, new external events, new source term information, 35 use of the Biological Effects of Ionizing Radiation (BEIR) VII report (National Resource Council 36 2006) risk coefficients, spent fuel pool accidents, higher fuel burnup, low power and shutdown 37 events, and population increase. Therefore, the NRC staffs review of the Turkey Point SLR 38 application further reinforced the conclusion that the probability-weighted consequences of 39 severe accidents for Turkey Point SLR are SMALL.
40 D.1.3      Population 41 Section E.3.9.2, Population Increase, of Appendix E to the 2013 LR GEIS discusses the 42 impact of population increases on offsite dose and economic consequences, stating the 43 following:
D-3
 
1          The 1996 GEIS estimated impacts at the midyear of each plants license renewal 2          period (i.e., 2030 to 2050). To adjust the impacts estimated in the NUREGs and 3          NUREG/CRs to the midyear of the assessed plants license renewal period, the 4          information (i.e., exposure indexes [EIs]) in the 1996 GEIS can be used. The Els 5          adjust a plants airborne and economic impacts from the year 2000 to its midyear 6          license renewal period based on population increases. These adjustments result 7          in anywhere from a 5 to a 30 percent increase in impacts, depending upon the 8          plant being assessed. Given the range of uncertainty in these types of analyses, 9          a 5 to 30 percent change is not considered significant. Therefore, the effect of 10          increased population around the plant does not generally result in significant 11          increases in impacts.
12 Table 3.11-2, County Populations Totally or Partially Included within a 50-Mile Radius of 13 [Turkey Point], of the ER submitted with the SLR application for Turkey Point (FPL 2018a) 14 provides population information relevant to Turkey Point. As Table 3.11-2 shows, FPL estimated 15 that in 2053 (i.e., at the end of the SLR term for Turkey Point Unit 4) the population within the 16 50-mile radius of Turkey Point will be 6,890,445. Assuming a uniform increase in population, the 17 midyear population (2043) is projected to be 6,366,881 (37 percent higher for the four relevant 18 counties during the SLR term). FPLs estimated population increase is slightly above the 30 19 percent range determined by the NRC in the 2013 LR GEIS to not be significant. However, as 20 discussed in Section E.3.3 of the 2013 LR GEIS, more recent estimates using more 21 comprehensive updated site-specific information give a significantly lower population dose risk 22 than what was assumed in the 1996 LR GEIS. Specifically, for Turkey Point, the 1996 LR GEIS 23 estimated risks of 278 person-rem/RY were much higher than the Turkey Point initial license 24 renewal SAMA calculated population dose of 22 person-rem/RY. The ratio of the 1996 LR GEIS 25 95 percent upper confidence bound population dose to the initial license renewal calculated 26 population dose demonstrates a reduction in risk of a factor of 13. The effect of this significant 27 reduction (factor of 13) in the total population dose risk from a radiological release following a 28 severe accident far exceeds the effect of the estimated population increase (factor of 1.37).
29 Therefore, the NRC staff has determined that the effect of increased population around Turkey 30 Point during the SLR term would not result in a significant increase in impacts of severe 31 accidents for Turkey Point. Based on these considerations, the NRC staff concludes that 32 despite a site-specific prediction of population increase, the probability-weighted consequences 33 of severe accidents from continued nuclear power plant operations at Turkey Point during the 34 SLR term would be SMALL.
35 D.1.4      Severe Accident Mitigation Alternatives 36 An analysis of SAMAs was performed for Turkey Point at the time of the initial license renewal.
37 The NRC staff documented its review of this analysis in NUREG-1437, Generic Environmental 38 Impact Statement for License Renewal of Nuclear Plants, Supplement 5, Regarding Turkey 39 Point Units 3 and 4. Any new and significant information that might alter the conclusions of that 40 analysis was considered in the SLR application, as discussed below. No new and significant 41 SAMAs were identified through FPLs use of the NRC-endorsed topical report Nuclear Energy 42 Institute (NEI) 17-04, Model SLR New and Significant Assessment Approach for SAMA, nor 43 was any new and significant information regarding SAMAs identified by the NRC staff in the 44 FSEIS.
45 In its evaluation of the significance of new information related to plant-specific SAMA analyses, 46 the NRC staff considers new information to be significant if it provides a seriously different 47 picture of the impacts of the Federal action under consideration. Thus, for mitigation alternatives D-4
 
1 such as SAMAs, new information is significant if it indicates that a mitigation alternative would 2 substantially reduce an impact of the Federal action on the environment. Consequently, with 3 respect to SAMAs, new information may be significant if it indicates that a given potentially cost-4 beneficial SAMA would substantially reduce the impacts of a severe accident or the probability 5 or consequences (risk) of a severe accident occurring.
6 As discussed in Section E.2.2 of the FSEIS, FPL stated in its ER submitted as part of its SLR 7 application that it used the methodology in NEI 17-04 to evaluate new and significant 8 information as it relates to the Turkey Point SLR SAMAs. By {{letter dated|date=January 31, 2018|text=letter dated January 31, 2018}}, the 9 NRC staff reviewed NEI 17-04 and found it acceptable for interim use, pending formal NRC 10 endorsement of NEI 17-04 by incorporation into Regulatory Guide 4.2, Supplement 1, 11 Preparation of Environmental Reports for Nuclear Power Plant License Renewal Applications 12 (NRC 2018). In general, as discussed above, the NEI 17-04 methodology does not consider a 13 potential SAMA to be significant unless it reduces by at least 50 percent the maximum benefit 14 as defined in Section 4.5, Total Cost of Severe Accident Risk/Maximum Benefit, of NEI 05-01, 15 Revision A, Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document.
16 NEI 17-04 describes a three-stage process for determining whether there is any new and 17 significant information relevant to a previous SAMA analysis:
18
* Stage 1: The SLR applicant uses Probabilistic Risk Assessment risk insights and/or risk 19    model quantifications to estimate the percent of reduction in the maximum benefit 20    associated with (1) all unimplemented Phase 2 SAMAs for the analyzed plant and 21    (2) those SAMAs identified as potentially cost-beneficial for other U.S. nuclear power plants 22    and that are applicable to the analyzed plant. If one or more of those SAMAs are shown to 23    reduce the maximum benefit by 50 percent or more, then the applicant must complete 24    Stage 2. (Applicants that are able to demonstrate through the Stage 1 screening process 25    that there is no potentially significant new information are not required to perform the 26    Stage 2 or Stage 3 assessments).
27
* Stage 2: The SLR applicant develops updated averted cost-risk estimates for implementing 28    those SAMAs. If the Stage 2 assessment confirms that one or more SAMAs reduce the 29    maximum benefit by 50 percent or more, then the applicant must complete Stage 3.
30
* Stage 3: The SLR applicant performs a cost-benefit analysis for the potentially significant 31    SAMAs identified in Stage 2.
32 The FSEIS describes FPLs application of the NEI 17-04 methodology to Turkey Point SAMAs.
33 FPL determined that none of the SAMAs evaluated in Stage 1 reduced the maximum benefit by 34 50 percent or more. As a result, FPL concluded that it is not required to perform the Stage 2 or 35 Stage 3 evaluations for any Turkey Point SAMAs.
36 As provided in the FSEIS, the NRC staff reviewed FPLs new and significant information 37 analysis for severe accidents and SAMAs at Turkey Point during the SLR term and found the 38 analysis and the methods used to be reasonable. The NRC staff concluded that given the low 39 residual risk at Turkey Point, the substantial decrease in CDF at Turkey Point since the previous 40 SAMA analysis, and the fact that no potentially cost-beneficial SAMAs were identified during the 41 Turkey Point initial license renewal review, it is unlikely that FPL would have found any 42 potentially cost-beneficial SAMAs for the SLR term. Further, FPLs implementation of actions to 43 satisfy the NRCs orders and regulatory requirements regarding beyond design basis events 44 after the terrorist attacks of September 11, 2001, and the Fukushima Dai-Ichi accident, as well 45 as the conservative assumptions used in earlier severe accident studies and SAMA analyses, D-5
 
1 also made it unlikely that FPL would have found any potentially significant cost-beneficial 2 SAMAs during the SLR term. For these reasons, the NRC staff concluded that the conclusions 3 reached by FPL in its SLR application regarding SAMAs were reasonable and that there is no 4 new and significant information regarding any potentially cost-beneficial SAMAs that would 5 substantially reduce the risks of a severe accident at Turkey Point.
6 The NRC staff determined that all other sources of new information (e.g., new meteorological 7 information, new emergency preparedness information, etc.) do not contribute sufficiently to 8 impacts to warrant their inclusion in the severe accident analysis, especially given the factor of 9 18.3 reduction in risk over the prior analyses and the small likelihood of finding cost-effective 10 plant improvements from other new information sources. This aggregate risk reduction from new 11 sources of information supports the 2013 LR GEIS conclusions for severe accidents for the SLR 12 term (NRC 2019a, Appendix E.3.10) and supports the conclusion that the probability-weighted 13 consequences of severe accidents from continued nuclear power plant operations at Turkey 14 Point during the SLR term would be SMALL.
15 As explained above, plant-specific calculations performed during the initial Turkey Point license 16 renewal SAMA analysis demonstrated a reduction of 1.3 orders of magnitude from the 17 conservatively predicted population dose risk value for Turkey Point in the 1996 LR GEIS (in 18 which the probability-weighted consequences of severe accidents were determined to be 19 SMALL). This reduction demonstrates the magnitude of conservatism used in the 1996 LR 20 GEIS. Considering new Turkey Point plant-specific information since the Turkey Point SAMA 21 analysis, the aggregate risk was found to be further decreased by a factor of 18.3 compared to 22 the Turkey Point previous SAMA analysis. Therefore, the Turkey Point calculated population 23 dose risk and more recent plant-specific information reinforces the NRCs 1996 determination 24 that the probability-weighted consequences of severe accidents are SMALL. The NRC staff 25 concludes that the probability-weighted consequences of severe accidents from continued 26 operations at Turkey Point during the SLR term would be SMALL.
27 D.2    Uncertainty 28 Section 5.3.3 in the 1996 LR GEIS provides a discussion of the uncertainties associated with 29 the analysis in the GEIS and in the individual plant EISs used to estimate the environmental 30 impacts of severe accidents. The 1996 LR GEIS used 95th percentile upper confidence bound 31 estimates whenever available to estimate the environmental impacts of severe accidents. This 32 approach provides conservatism to cover uncertainties, as described in Section 5.3.3.2.2 of the 33 1996 LR GEIS. Many of these same uncertainties also apply to the analysis used in the 2013 34 LR GEIS. As discussed in Sections E.3.1 through E.3.8 of the 2013 LR GEIS, the GEIS used 35 more recent information to supplement the estimate of environmental impacts contained in the 36 1996 LR GEIS. In effect, the assessments contained in Sections E.3.1 through E.3.8 of the 37 2013 LR GEIS provided additional information and insights into certain areas of uncertainty 38 associated with the 1996 LR GEIS. However, as provided in the 2013 LR GEIS, the impact and 39 magnitude of uncertainties, as estimated in the 1996 LR GEIS, bound the uncertainties 40 introduced by the new information and considerations addressed in the 2013 LR GEIS.
41 Accordingly, in the 2013 LR GEIS, the NRC staff concluded that the reduction in environmental 42 impacts resulting from the use of new information (since the 1996 LR GEIS analysis) outweighs 43 any increases in impact resulting from the new information. As a result, the 2013 LR GEIS 44 concluded that the findings in the 1996 LR GEIS remain valid.
45 The NRC staff has identified no new and significant information regarding uncertainties during 46 its review of the Turkey Point SLR application, as supplemented, the SAMA audit, the scoping D-6
 
1 process, or the evaluation of other available information. As discussed above, more recent 2 Turkey Point plant-specific information demonstrates an overall reduction of the probability-3 weighted consequences of severe accidents compared to the 1996 LR GEIS. The NRC staff 4 has not identified any new information pertaining to uncertainties compared to the uncertainties 5 discussed in the 2013 LR GEIS, that would alter this conclusion for Turkey Point. Therefore, the 6 NRC staff concludes that, upon considering uncertainties, the probability-weighted 7 consequences of severe accidents from continued nuclear power plant operations at Turkey 8 Point during the SLR term would be SMALL.
9 D.3    References 10 [FPL] Florida Power & Light Company. 2000. Applicant's Environmental Report - Operating 11 License Renewal Stage Turkey Point Units 3 and 4. Miami, Florida.
12 [NRC] U.S. Nuclear Regulatory Commission. 2002. Generic Environmental Impact Statement 13 for License Renewal of Nuclear Plants Regarding Turkey Point Plant Units 3 and 4, Final 14 Report. NUREG-1437, Supplement 5. January 2002. 669 p. ADAMS Accession Nos.
15 ML020280119, ML020280202, and ML020280226.
16 [FPL] Florida Power & Light Company. 2018a. Applicants Environmental Report - Subsequent 17 Operating License Renewal Stage - Turkey Point Nuclear Plant Units 3 and 4. January 2018.
18 ADAMS Accession No. ML18037A836.
19 [FPL] Florida Power & Light Company. 2018b. Turkey Point Units 3 and 4 Subsequent License 20 Renewal Application - Revision 1. April 10, 2018. ADAMS Package Accession No.
21 ML18113A132.
22 [FPL] Florida Power & Light Company. 2018c. Turkey Point Units 3 and 4 Subsequent License 23 Renewal Application. January 30, 2018. ADAMS Package Accession No. ML18037A812.
24 [FPL] Florida Power & Light Company. 2022. Subsequent License Renewal Application -
25 Appendix E Environmental Report Supplement 2. June 9, 2022. 115 p. ADAMS Accession No.
26 ML22160A301.
27 [NRC] U.S. Nuclear Regulatory Commission. 2013. Memorandum of Understanding Between 28 the U.S. Nuclear Regulatory Commission and the Occupational Safety and Health 29 Administration. September 6, 2013. ADAMS Accession No. ML11354A432.
30 [NRC] U.S. Nuclear Regulatory Commission. 2018. Interim Endorsement of NEI 17-01, Industry 31 Guidance for Implementing the Requirements of 10 CFR PART 54 for Subsequent License 32 Renewal and NEI 17-04, Model SLR New and Significant Assessment Approach for SAMA.
33 January 31, 2018. ADAMS Accession No. ML18029A368.
34 [NRC] U.S. Nuclear Regulatory Commission. 2019. Generic Environmental Impact Statement 35 for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for Turkey 36 Point Nuclear Generating Unit Nos. 3 and 4, Draft Report for Comment. NUREG-1437, 37 Supplement 5, Second Renewal. March 2019. 429 p. ADAMS Accession No. ML19078A330.
38 [NRC] U.S. Nuclear Regulatory Commission. 2022a. Commission Memorandum and Order in 39 the Matter of Florida Power & Light Company (Turkey Point Nuclear Generating Units 3 and 4).
40 CLI-22-02. February 24, 2022. ADAMS Accession No. ML22055A496.
D-7
 
1 [NRC] U.S. Nuclear Regulatory Commission. 2022b. Commission Memorandum and Order in 2 the Matter of Duke Energy Carolinas, LLC (Oconee Nuclear Station, Units 1, 2, and 3), Exelon 3 Generation Company, LLC (Peach Bottom Atomic Power Station, Units 2 and 3), Florida Power 4 & Light Company (Turkey Point Nuclear Generating Units 3 and 4), NextEra Energy Point 5 Beach, LLC (Point Beach Nuclear Plant, Units 1 and 2), and Virginia Electric and Power 6 Company (North Anna Power Station, Units 1 and 2). CLI-22-03. February 24, 2022. ADAMS 7 Accession No. ML22055A533.
8 [NRC] U.S. Nuclear Regulatory Commission. 2022c. Commission Memorandum and Order in 9 the Matter of Florida Power & Light Company (Turkey Point Nuclear Generating Units 3 and 4).
10 CLI-22-06. June 3, 2022. ADAMS Accession No. ML22154A215.
11 National Research Council. 2006. Health Risks from Exposure to Low Levels of Ionizing 12 Radiation: BEIR VII Phase II. Washington, D.C. https://doi.org/10.17226/11340. Accessed May 13 13, 2023.
14 D-8
 
1                                          APPENDIX E 2
3    ENVIRONMENTAL ISSUES AND IMPACT FINDINGS CONTAINED IN 4        THE PROPOSED RULE, 10 CFR PART 51, ENVIRONMENTAL 5      PROTECTION REGULATIONS FOR DOMESTIC LICENSING AND 6                      RELATED REGULATORY FUNCTIONS 7 The U.S. Nuclear Regulatory Commission (NRC, the Commission) staff prepared this site-8 specific environmental impact statement (EIS) to supplement the staffs final supplemental 9 environmental impact statement (FSEIS), i.e., Generic Environmental Impact Statement for 10 License Renewal of Nuclear Plants, Supplement 5, Second Renewal, Regarding Subsequent 11 License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, Final Report 12 (NUREG-1437, Supplement 5, Second Renewal) (FSEIS; NRC 2019), issued in October 2019.
13 This EIS includes the NRC staffs site-specific evaluation of the environmental impacts of 14 subsequent license renewal (SLR) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 15 (Turkey Point) requested by Florida Power & Light Company (FPL) for each of the 16 environmental issues that were dispositioned as Category 1 issues (generic to all or a distinct 17 subset of nuclear power plants) in the FSEIS. The FSEIS was issued as a supplement to 18 NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear 19 Plants, Revision 1, Final Report (the 2013 LR GEIS; NRC 2013). The 2013 LR GEIS and the 20 associated revised rule (78 FR 37282) had identified 78 environmental impact issues, 61 of 21 which were deemed to be generic Category 1 issues and 17 of which were deemed to be 22 Category 2 issues that required a plant-specific analysis. The FSEIS followed that approach, 23 consistent with Table B-1 in Appendix B to Subpart A of Title 10 of the Code of Federal 24 Regulations (10 CFR) Part 51, Environmental protection regulations for domestic licensing and 25 related regulatory functions. In accordance with the Commissions decisions in Commission 26 Legal Issuance (CLI)-22-02 and CLI-22-03, this EIS provides a site-specific evaluation of the 27 issues that were treated as Class 1 issues in the FSEIS.
28 This EIS also considers whether there is any significant new information that would change the 29 NRC staffs conclusions concerning Category 2 issues (specific to individual nuclear power 30 plants) in the FSEIS. In CLI-22-02 and CLI-22-03, the Commission directed the NRC staff to 31 modify the expiration dates of the Turkey Point subsequent renewed licenses, which were 32 issued on December 4, 2019, to reflect the end dates of the previous renewed licenses (i.e.,
33 July 19, 2032, for Turkey Point Unit 3 and April 10, 2033, for Turkey Point Unit 4). Together, the 34 EIS and the FSEIS evaluate, on a site-specific basis, all of the environmental impacts of 35 continued operation during the SLR term for Turkey Point Unit 3 from July 19, 2032, to July 19, 36 2052, and for Turkey Point Unit 4 from April 10, 2033, to April 10, 2053.
37 On March 3, 2023, the NRC published a draft rule (88 FR 13329) proposing to amend its 38 environmental protection regulations in 10 CFR Part 51. Specifically, the proposed rule would 39 update the NRCs 2013 findings concerning the environmental impacts of renewing the 40 operating license of a nuclear power plant, and specifically address SLR. The technical basis for 41 the proposed rule is discussed in draft Revision 2 to NUREG-1437, Generic Environmental 42 Impact Statement for License Renewal of Nuclear Plants (the 2023 LR GEIS; NRC 2023),
43 which when finalized would update the 2013 LR GEIS; the 2013 LR GEIS, in turn, was an 44 update of NUREG-1437, Generic Environmental Impact Statement for License Renewal of 45 Nuclear Plants, Revision 0 (the 1996 LR GEIS; NRC 1996). The 2023 LR GEIS when finalized E-1
 
1 would support the proposed revised list of National Environmental Policy Act of 1969, as 2 amended (NEPA; 42 U.S.C. 4321 et seq.), issues and associated environmental impact findings 3 for license renewal (including SLR) to be contained in Table B-1 in Appendix B to Subpart A of 4 10 CFR Part 51. The 2023 LR GEIS and proposed rule reflect lessons learned and knowledge 5 gained from the NRCs conduct of environmental reviews for initial license renewal (LR) and 6 SLR since 2013.
7 The 2023 proposed rule would redefine the number and scope of the environmental issues that 8 must be addressed by the NRC during initial LR and SLR environmental reviews. In the 2013 9 rule, there were 78 environmental issues, 17 of which required a plant-specific analysis 10 (Category 2 issues) during LR environmental reviews. The proposed rule identifies 80 11 environmental impact issues, 20 of which would require plant-specific analysis. The proposed 12 rule would reclassify some previously site-specific (Category 2) issues as generic (Category 1) 13 issues and would consolidate other issues. It would also add new Category 1 and Category 2 14 issues to Table B-1. In Section 1.10 of the 2023 LR GEIS, these proposed changes are 15 summarized as follows.
16
* One Category 2 issue, Groundwater quality degradation (cooling ponds at inland sites),
17      and a related Category 1 issue, Groundwater quality degradation (cooling ponds in salt 18      marshes), would be consolidated into a single Category 2 issue, Groundwater quality 19      degradation (plants with cooling ponds).
20
* Two related Category 1 issues, Infrequently reported thermal impacts (all plants) and 21      Effects of cooling water discharge on dissolved oxygen, gas supersaturation, and 22      eutrophication, and the thermal effluent component of the Category 1 issue, Losses from 23      predation, parasitism, and disease among organisms exposed to sublethal stresses, would 24      be consolidated into a single Category 1 issue, Infrequently reported effects of thermal 25      effluents.
26
* One Category 2 issue, Impingement and entrainment of aquatic organisms (plants with 27      once-through cooling systems or cooling ponds), and the impingement component of the 28      Category 1 issue, Losses from predation, parasitism, and disease among organisms 29      exposed to sublethal stresses, would be consolidated into a single Category 2 issue, 30      Impingement mortality and entrainment of aquatic organisms (plants with once-through 31      cooling systems or cooling ponds).
32
* One Category 1 issue, Impingement and entrainment of aquatic organisms (plants with 33      cooling towers), and the impingement component of the Category 1 issue, Losses from 34      predation, parasitism, and disease among organisms exposed to sublethal stresses, would 35      be consolidated into a single Category 1 issue, Impingement mortality and entrainment of 36      aquatic organisms (plants with cooling towers).
37
* One Category 2 issue, Threatened, endangered, and protected species and essential fish 38      habitat, would be divided into three Category 2 issues: (1) Endangered Species Act:
39      federally listed species and critical habitats under U.S. Fish and Wildlife jurisdiction, (2) 40      Endangered Species Act: federally listed species and critical habitats under National 41      Marine Fisheries Service jurisdiction, and (3) Magnuson-Stevens Act: essential fish 42      habitat.
43
* Two new Category 2 issues, National Marine Sanctuaries Act: sanctuary resources and 44      Climate change impacts on environmental resources, would be added.
45
* One Category 2 issue, Severe accidents, would be changed to a Category 1 issue.
46
* One new Category 1 issue, Greenhouse gas impacts on climate change, would be added.
E-2
 
1
* Several issue titles and findings would be revised to clarify their intended meanings.
2 Finalization and publication of the 2023 LR GEIS and the proposed rule, is expected to occur in 3 or about May 2024. Upon being finalized, the rule would revise the NRCs environmental 4 protection regulations, as amended. Thereafter, the NRC would have to consider and analyze in 5 its initial LR or SLR environmental reviews any significant impacts associated with Category 2 6 issues and, to the extent that there is any new and significant information, the potential impacts 7 associated with Category 1 issues for the nuclear power plant LR application under review. To 8 account for the possibility that the proposed rule and the 2023 LR GEIS may be finalized before 9 a final determination is reached on FPLs SLR application, the NRC staff analyzes in this 10 appendix, on a site-specific basis, the new and revised environmental issues described in the 11 2023 LR GEIS because they may apply to SLR for Turkey Point. Table E-1 lists the new and 12 revised environmental issues that would apply to Turkey Point SLR. The sections that follow 13 discuss how the NRC staff addressed each of these new and revised issues in this site-specific 14 EIS and the FSEIS.
15    Table E-1    New and Revised 10 CFR Part 51 License Renewal Environmental Issues Issue                            2023 LR GEIS Section    Category Groundwater quality degradation (plants with cooling ponds)              4.5.1.2            2 Infrequently reported effects of thermal effluents                      4.6.1.2            1 Impingement mortality and entrainment of aquatic organisms              4.6.1.2            2 (plants with once-through cooling systems or cooling ponds)
Endangered Species Act: federally listed species and critical          4.6.1.3.1          2 habitats under U.S. Fish and Wildlife jurisdiction Endangered Species Act: federally listed species and critical          4.6.1.3.2          2 habitats under National Marine Fisheries Service jurisdiction Magnuson-Stevens Act: essential fish habitat                            4.6.1.3.3          2 National Marine Sanctuaries Act: sanctuary resources                    4.6.1.3.4          2 Severe accidents                                                        4.9.1.2.1          1 Greenhouse gas impacts on climate change                                4.12.1            1 Climate change impacts on environmental resources                        4.12.3            2 16 E.1      Groundwater Quality Degradation (Plants with Cooling Ponds) 17 With respect to groundwater resources, the draft rule proposes to amend Table B-1 in 18 Appendix B to Subpart A of 10 CFR Part 51 by consolidating one Category 2 issue, 19 Groundwater quality degradation (plants with cooling ponds at inland sites), and a related 20 Category 1 issue, Groundwater quality degradation (plants with cooling ponds in salt 21 marshes), into a single new Category 2 issue, Groundwater quality degradation (plants with 22 cooling ponds). This consolidated issue considers the possibility of groundwater quality and 23 beneficial use becoming degraded as a result of the migration of contaminants discharged to 24 cooling ponds. The significance of the impact on groundwater would depend on site-specific 25 conditions, including cooling pond water quality, site hydrogeologic conditions (including the 26 interaction of surface water and groundwater), and the location, depth, and pump rate of water 27 wells.
28 Section 2.8.3 of this EIS provides a site-specific analysis of groundwater quality degradation for 29 plants that have cooling ponds in salt marshes. Based on this site-specific analysis, the NRC 30 staff concludes that the impacts on groundwater quality from the Turkey Point cooling canal E-3
 
1 system (CCS) due to continued nuclear power plant operations at Turkey Point during the SLR 2 term would be MODERATE. Therefore, the issue Groundwater quality degradation (plants with 3 cooling ponds) has been addressed in this EIS.
4 E.2    Infrequently Reported Effects of Thermal Effluents 5 The draft rule proposes to combine two Category 1 issues, Infrequently reported thermal 6 impacts (all plants) and Effects of cooling water discharge on dissolved oxygen, gas 7 supersaturation, and eutrophication, and the thermal effluent component of the Category 1 8 issue, Losses from predation, parasitism, and disease among organisms exposed to sublethal 9 stresses, into one Category 1 issue, Infrequently reported effects of thermal effluents. This 10 issue pertains to interrelated and infrequently reported effects of thermal effluents, including 11 cold shock, thermal migration barriers, accelerated maturation of aquatic insects, and 12 proliferated growth of aquatic nuisance species, as well as the effects of thermal effluents on 13 dissolved oxygen, gas supersaturation, and eutrophication. This issue also considers sublethal 14 stresses associated with thermal effluents that can increase the susceptibility of exposed 15 organisms to predation, parasitism, or disease. These changes do not introduce any new 16 environmental issues; rather, the proposed rule would reorganize existing issues. The changes 17 are fully summarized and explained in Section 4.6.1.2 of the 2023 LR GEIS and in the proposed 18 rule.
19 Sections 2.10.2, 2.10.3, and 2.10.9 of this EIS analyze infrequently reported effects of thermal 20 effluents for Turkey Point SLR and conclude that the impacts would be SMALL. Therefore, the 21 issue Infrequently reported effects of thermal effluents has been addressed in this EIS.
22 E.3    Impingement Mortality and Entrainment of Aquatic Organisms (Plants with 23        Once-Through Cooling Systems or Cooling Ponds) 24 The draft rule proposes to combine the Category 2 issue, Impingement and entrainment of 25 aquatic organisms (plants with once-through cooling systems or cooling ponds), and the 26 impingement component of the Category 1 issue, Losses from predation, parasitism, and 27 disease among organisms exposed to sublethal stresses, into one Category 2 issue, 28 Impingement mortality and entrainment of aquatic organisms (plants with once-through cooling 29 systems or cooling ponds). This issue pertains to impingement mortality and entrainment of 30 finfish and shellfish at nuclear power plants with once-through cooling systems and cooling 31 ponds during the LR term (either initial LR or SLR). This includes plants with helper cooling 32 towers that are seasonally operated to reduce thermal load to the receiving water body, reduce 33 entrainment during peak spawning periods, or reduce consumptive water use during periods of 34 low river flow.
35 In the 2023 LR GEIS, the NRC renamed this issue to specify impingement mortality, rather than 36 simply impingement. This change is consistent with the U.S. Environmental Protection Agency 37 (EPA) 2014 Clean Water Act (CWA) Section 316(b) regulations and the EPAs assessment that 38 impingement reduction technology is available, feasible, and has been demonstrated to be 39 effective. Additionally, the EPAs 2014 CWA Section 316(b) regulations establish best 40 technology available standards for impingement mortality based on the fact that survival is a 41 more appropriate metric for determining environmental impact rather than simply looking at total 42 impingement. Therefore, the 2023 LR GEIS also consolidates the impingement component of 43 the Losses from predation, parasitism, and disease among organisms exposed to sublethal 44 stresses issue for plants with once-through cooling systems or cooling ponds into this issue.
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1 Section 4.7.1 of the FSEIS (NRC 2019) analyzed the impacts of impingement and entrainment 2 for Turkey Point SLR. The analysis considered the components of the proposed revision to this 3 issue, impingement mortality, and the impingement component of losses from predation, 4 parasitism, and disease among organisms exposed to sublethal stresses. In the FSEIS, the 5 NRC staff concluded that impingement and entrainment during the SLR term would be of 6 SMALL to MODERATE significance on the aquatic organisms of the Turkey Point CCS. With 7 respect to aquatic organisms in Biscayne Bay and connected water bodies (e.g., Card Sound, 8 the Atlantic Ocean), the NRC staff concluded that the issue of impingement and entrainment 9 during the SLR term does not apply because there are no surface water connections that allow 10 flow between the waters of the Biscayne Bay and the CCS and, therefore, organisms inhabiting 11 these waters never interact with the Turkey Point intake structure. Therefore, this issue has 12 been considered, as appropriate, for Turkey Point SLR.
13 E.4    Endangered Species Act: Federally Listed Species and Critical Habitats 14        Under U.S. Fish and Wildlife Jurisdiction 15 The draft rule proposes to divide the Category 2 issue, Threatened, endangered, and protected 16 species and essential fish habitat, into three separate Category 2 issues for clarity and 17 consistency with the separate Federal statues and interagency consultation requirements that 18 the NRC must consider with respect to federally protected ecological resources. When 19 combined, however, the scope of the three issues is the same as the scope of the former 20 Threatened, endangered, and protected species and essential fish habitat issue discussed in 21 the 2013 LR GEIS. As discussed below, such impacts were considered on a site-specific basis 22 in the Turkey Point FSEIS for SLR.
23 The first of the three issues, Endangered Species Act: federally listed species and critical 24 habitats under U.S. Fish and Wildlife jurisdiction, concerns the potential effects of continued 25 nuclear power plant operation and any refurbishment during the LR term on federally listed 26 species and critical habitats protected under the Endangered Species Act (ESA) and under the 27 jurisdiction of the U.S. Fish and Wildlife Service (FWS).
28 Section 4.8.1.1 of the Turkey Point FSEIS (NRC 2019) addresses the impacts of Turkey Point 29 SLR on federally listed species and critical habitats under FWS jurisdiction. That section, along 30 with Appendix C.1 of the FSEIS, describes impacts on federally listed terrestrial and freshwater 31 species and critical habitats, as well as ESA consultation between the NRC and the FWS, which 32 resulted in the FWSs issuance of a biological opinion for the American crocodile (Crocodylus 33 acutus) and eastern indigo snake (Drymarchon corais couperi). The NRC and the FWS 34 determined that Turkey Point SLR is likely to adversely affect the American crocodile and the 35 eastern indigo snake. With respect to critical habitat, the FSEIS determined that Turkey Point 36 SLR is not likely to adversely modify designated critical habitat for the West Indian manatee 37 (Trichechus manatus) but may adversely modify designated critical habitat for the American 38 crocodile. Section B.1 in Appendix B of this EIS describes reinitiated consultation, which the 39 NRC undertook because FPL exceeded the incidental take limit for crocodiles set forth in the 40 FWSs biological opinion. As a result of the reinitiated consultation, the FWS amended the 41 biological opinion.
42 Accordingly, the issue Endangered Species Act: federally listed species and critical habitats 43 under U.S. Fish and Wildlife jurisdiction, has been considered for Turkey Point SLR.
E-5
 
1 E.5    Endangered Species Act: Federally Listed Species and Critical Habitats 2        Under National Marine Fisheries Service Jurisdiction 3 As explained in the previous section, the draft rule proposes to divide the Category 2 issue, 4 Threatened, endangered, and protected species and essential fish habitat, into three separate 5 Category 2 issues. The second of the three issues, Endangered Species Act: federally listed 6 species and critical habitats under National Marine Fisheries Service jurisdiction, concerns the 7 potential effects of continued nuclear power plant operation and any refurbishment during the 8 LR term on federally listed species and critical habitats protected under the ESA and under the 9 jurisdiction of the National Marine Fisheries Service (NMFS).
10 Section 4.8.1.1 of the Turkey Point FSEIS (NRC 2019) addresses the impacts of Turkey Point 11 SLR on federally listed species and critical habitats under NMFS jurisdiction. That section, along 12 with Section C.1 in Appendix C of the FSEIS, describes impacts on federally listed marine 13 species and critical habitats, as well as ESA consultation between the NRC and the NMFS, 14 which resulted in the NMFSs concurrence with the NRCs finding that Turkey Point SLR is not 15 likely to adversely affect any listed marine species. Accordingly, this issue has been considered 16 for Turkey Point SLR.
17 E.6    Magnuson-Stevens Act: Essential Fish Habitat 18 As explained above, the draft rule proposes to divide the Category 2 issue, Threatened, 19 endangered, and protected species and essential fish habitat, into three separate Category 2 20 issues. The third of the three issues, Magnuson-Stevens Act: essential fish habitat, concerns 21 the potential effects of continued nuclear power plant operation and any refurbishment during 22 the LR term on essential fish habitat protected under the Magnuson-Stevens Act (MSA).
23 Section 4.8.1.2 of the Turkey Point FSEIS (NRC 2019) addresses the impacts of Turkey Point 24 SLR on essential fish habitat (EFH). That section, along with Section C.2 in Appendix C of the 25 FSEIS, describes impacts on EFH and that, although the NMFS has designated EFH for a 26 number of federally managed species within Biscayne Bay, neither EFH nor the species 27 themselves occur in the CCS or on the Turkey Point site because there are no surface water 28 connections between the CCS and any natural water bodies and, therefore, Turkey Point SLR 29 would not result in any impacts on EFH. Accordingly, the NRC was not required under the MSA 30 to consult with the NMFS for the proposed action, and this issue has been considered for 31 Turkey Point SLR.
32 E.7    National Marine Sanctuaries Act: Sanctuary Resources 33 The draft rule proposes to add a new Category 2 issue, National Marine Sanctuaries Act:
34 sanctuary resources, to evaluate the potential effects of continued nuclear power plant 35 operation and any refurbishment during the LR term on sanctuary resources protected under 36 the National Marine Sanctuaries Act (NMSA).
37 Under the NMSA, the National Oceanic and Atmospheric Administration (NOAA) Office of 38 National Marine Sanctuaries (ONMS) designates and manages the National Marine Sanctuary 39 System. Marine sanctuaries may occur near nuclear power plants located on or near marine 40 waters as well as the Great Lakes.
41 Section 4.8.1.3 of the Turkey Point FSEIS (NRC 2019) addresses the impacts of Turkey Point 42 SLR on sanctuary resources of the Florida Keys National Marine Sanctuary. That section, along E-6
 
1 with Section C.3 in Appendix C of the FSEIS, describes impacts on sanctuary resources and 2 concludes that Turkey Point SLR is not likely to destroy, cause the loss of, or injure any 3 sanctuary resources. Accordingly, the NRC was not required under the NMSA to consult with 4 the ONMS for the proposed action, and this issue has been considered for Turkey Point SLR.
5 E.8    Severe Accidents 6 With respect to postulated accidents, the draft rule proposes to amend Table B-1 in Appendix B 7 to Subpart A of 10 CFR Part 51 by reclassifying the Category 2 Severe accidents issue as a 8 Category 1 issue. In the 2013 LR GEIS, the issue of severe accidents was classified as a 9 Category 2 issue to the extent that alternatives to mitigate severe accidents must be considered 10 for all nuclear power plants where the licensee had not previously performed a severe accident 11 mitigation alternatives (SAMA) analysis for the plant. In the 2023 LR GEIS, the NRC staff notes 12 that this issue would be resolved generically for the vast majority, if not all, expected license 13 renewal applicants because the applicants who will likely reference the LR GEIS have 14 previously completed a SAMA analysis.
15 As discussed in Appendix D of this EIS, an analysis of SAMAs was performed for Turkey Point 16 and evaluated by the NRC staff at the time of initial LR (NRC 2002). In the FSEIS and in 17 Appendix D of this EIS, the NRC staff evaluated the significance of new information related to 18 the plant-specific SAMA analysis. Therefore, the issue of Severe accidents has been 19 addressed for Turkey Point SLR.
20 E.9    Greenhouse Gas Impacts on Climate Change 21 With respect to greenhouse gas (GHG) emissions and climate change, the draft rule proposes 22 to amend Table B-1 in Appendix B to Subpart A of 10 CFR Part 51 by adding a new Category 1 23 issue Greenhouse gas impacts on climate change. This new issue has an impact level of 24 SMALL. This new issue considers GHG impacts on climate change from routine operations of 25 nuclear power plants and construction vehicles and other motorized equipment used for 26 refurbishment activities. GHG emissions from routine operations of nuclear power plants are 27 typically very minor, because such plants, by their very nature, do not normally combust fossil 28 fuels to generate electricity. However, nuclear power plant operations do have some GHG 29 emission sources, including diesel generators, pumps, diesel engines, boilers, refrigeration 30 systems, and electrical transmission and distribution systems, as well as mobile sources (e.g.,
31 worker vehicles and delivery vehicles). GHG emissions from construction vehicles and other 32 motorized equipment for refurbishment activities would be intermittent and temporary, restricted 33 to the refurbishment period. GHG emissions from continued operations and refurbishment 34 activities are minor.
35 The issue of GHG impacts on climate change associated with nuclear power plant operations 36 was not identified as either a generic or plant-specific issue in the 1996 LR GEIS or 2013 LR 37 GEIS. In the 2013 LR GEIS, however, the NRC staff presented GHG emission factors 38 associated with the nuclear power life cycle. Following the issuance of CLI-09-21 (NRC 2009),
39 the NRC began to evaluate the effects of GHG emissions in plant-specific environmental 40 reviews for LR applications. Accordingly, Section 4.15.3.1 of the FSEIS (NRC 2019) evaluates 41 GHG emissions associated with the operation of Turkey Point during the SLR term. Table 4-6 of 42 the FSEIS presents quantified annual GHG emissions from sources at Turkey Point for the 43 2012-2016 time period when operation of Turkey Point emits GHGs directly and indirectly.
44 Turkey Points direct GHG emissions result from stationary portable combustion sources and 45 stationary refrigeration appliances. In response to an NRC staff request for additional E-7
 
1 information, FPL provided updated GHG emissions from sources at Turkey Point, which are 2 presented in Table E-2.
3 Table E-2      Estimated Greenhouse Gas Emissions(a) from Operation at Turkey Point, 4                Units 3 and 4 Turkey Point                  Workforce Combustion Sources(b)              Commuting(c)                    Total Year                    (tons/year)                  (tons/year)                (tons/year) 2017                          460                          3,345                      3,800 2018                          550                          3,345                      3,900 2019                          575                          3,345                      3,900 2020                          670                          3,345                      4,000 2021                          530                          3,345                      3,870 5 Note: Greenhouse gas (GHG) emissions reported in metric tons and converted to short tons. All reported values are 6 rounded. To convert tons per year to metric tons per year, multiply by 0.90718.
7 (a) Expressed in carbon dioxide equivalents (CO2eq), a metric used to compare the emissions of GHGs based on 8    their global warming potential (GWP). The GWP is a measure used to compare how much heat a GHG traps in 9    the atmosphere. The GWP is the total energy that a gas absorbs over a period of time compared to carbon 10    dioxide. CO2eq is obtained by multiplying the amount of the GHG by the associated GWP. For example, the 11    GWP of methane is 21; therefore, 1 ton of methane is equivalent to 21 tons of CO2 emissions.
12 (b) Includes stationary and portable diesel and gasoline engines.
13 (c) Emissions consider Turkey Point full-time employees and do not include additional contractor workers during 14    refueling outages. Refueling outages occur on a staggered, 18-month schedule and last approximately 25-35 15    days per unit.
16 Source: FPL 2023.
17 FPL has no plans to conduct major refurbishment during the Turkey Point SLR term and, 18 therefore, no GHG emissions from refurbishment or increases in GHG emissions beyond 19 current levels from routine operations at Turkey Point are anticipated. The NRC staff concludes 20 that there would be no impacts on climate change beyond the impacts discussed in the 2023 LR 21 GEIS and in Table B-1 in Appendix B to Subpart A of 10 CFR Part 51 of the proposed rule (88 22 FR 13329). Based on this information, the NRC staff concludes that GHG impacts on climate 23 change for Turkey Point SLR would be SMALL.
24 E.10 Climate Change Impacts on Environmental Resources 25 With respect to climate change, the draft rule proposes to amend Table B-1 in Appendix B to 26 Subpart A of 10 CFR Part 51 by adding the new Category 2 issue Climate change impacts on 27 environmental resources. This new issue considers the additive effects of climate change on 28 environmental resources that may also be directly affected by continued operations and 29 refurbishment during the LR term. The effects of climate change can vary regionally and climate 30 change information at the regional and local scale is necessary to assess trends and the 31 impacts on the human environment for a specific location. The impacts of climate change on 32 environmental resources during the LR term are location-specific and cannot be evaluated 33 generically.
34 The issue of climate change impacts was not identified as either a generic or plant-specific 35 issue in the 1996 LR GEIS or the 2013 LR GEIS. However, the 2013 LR GEIS described the 36 environmental impacts that could occur on resources areas (land use, air quality, water 37 resources, etc.) that may also be affected by LR. In site-specific initial LR and SLR 38 environmental reviews prepared since the development of the 2013 LR GEIS, the NRC staff has 39 considered projected differences in climate changes in the United States and climate change E-8
 
1 impacts on the resource areas that could be incrementally affected by the proposed action as 2 part of its cumulative impacts analysis. Accordingly, Section 4.15.3.1 of the FSEIS (NRC 2019) 3 discusses the observed changes in climate and the potential future climate change across the 4 Southeast region of the United States during the Turkey Point SLR term, based on climate 5 model simulations under future global GHG emissions scenarios. The NRC staff considered 6 regional projected climate changes from numerous climate assessment reports, including the 7 U.S. Global Change Research Program, the Intergovernmental Panel on Climate Change 8 (IPCC), the EPA, and the NOAA (NOAA 2013, USGCRP 2018). Furthermore, in Section 4.16 of 9 the FSEIS (NRC 2019), the NRC staff evaluated the overlapping impacts from climate change 10 on environmental resources (air quality, water resources, aquatic resources, socioeconomics, 11 historic and cultural resources, and environmental justice), for which the staff found there are 12 incremental impacts due to Turkey Point SLR.
13 Since the publication of the FSEIS, the IPCC has published a sixth assessment synthesis report 14 and concluded that [i]t is unequivocal that human influence has warmed the atmosphere, 15 ocean, and land (IPCC 2023). While the IPCC sixth assessment synthesis report provides 16 recent information regarding climate change, the information does not change the conclusions 17 stated in the FSEIS. In the FSEIS, the NRC staff relied on the best available national climate 18 change studies from the U.S. Global Change Research Program (USGCRP) and the NOAA 19 when discussing and considering climate change projections. There have been no updates to 20 the climate change reports from the USGCRP and the NOAA the since publication of the 21 FSEIS, and the new information published by the IPCC does not alter the conclusions in the 22 FSEIS regarding climate change. Therefore, this issue, Climate change impacts on 23 environmental resources, has been addressed in the Turkey Point FSEIS (NRC 2019).
24 E.11 References 25 88 FR 13329. U.S. Nuclear Regulatory Commission. Renewing Nuclear Power Plant Operating 26 LicensesEnvironmental Review. Federal Register 88(42): 13329-13357.
27 [FPL] Florida Power & Light Company. 2023. Letter from D. Strand, General Manager, 28 Regulatory Affairs, FPL, to NRC, Response to Requests for Additional Information (RAIs) and 29 Requests for Confirmation of Information (RCIs) Following Regulatory Audit of Subsequent 30 License Renewal Application. March 3, 2023. ADAMS Accession No. ML23062A367.
31 [IPCC] Intergovernmental Panel on Climate Change. 2023. AR6 Synthesis Report: Climate 32 Change 2023. Available at <https://www.ipcc.ch/report/sixth-assessment-report-cycle/>
33 (accessed April 18, 2023).
34 [NOAA] National Oceanic and Atmospheric Administration. 2013. Regional Climate Trends and 35 Scenarios for the U.S. National Climate Assessment, Part 2. Climate of the Southeast U.S.
36 Technical Report NESDIS 142-2. Washington, D.C.
37 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 38 for License Renewal of Nuclear Plants. NUREG-1437. ADAMS Accession Nos. ML040690705 39 and ML040690738.
40 [NRC] U.S. Nuclear Regulatory Commission. 2002. Generic Environmental Impact Statement 41 for License Renewal of Nuclear Plants Regarding Turkey Point Plant Units 3 and 4.
42 Washington, DC: NRC. NUREG-1437, Supplement 5. Final Report. January 2002. 669 p.
43 ADAMS Accession Nos. ML020280119, ML020280202, and ML020280226.
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1 [NRC] U.S. Nuclear Regulatory Commission. 2009. "Memorandum and Order in the Matter of 9 2 Duke Energy Carolinas, LLC and Tennessee Valley Authority." CLI-09-21, Rockville, 10 3 Maryland. ADAMS Accession No. ML093070690.
4 [NRC] U.S. Nuclear Regulatory Commission. 2013. Generic Environmental Impact Statement 5 for License Renewal of Nuclear Plants. Revision 1. NUREG-1437, Volumes 1, 2, and 3.
6 June 2013. 1,535 p. ADAMS Package Accession No. ML13107A023.
7 [NRC] U.S. Nuclear Regulatory Commission. 2019. Generic Environmental Impact Statement 8 for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for Turkey 9 Point Nuclear Generating Unit Nos. 3 and 4, Final Report. NUREG-1437, Supplement 5, 10 Second Renewal. October 2019. 656 p. ADAMS Accession No. ML19290H346.
11 [NRC] U.S. Nuclear Regulatory Commission. 2023. Generic Environmental Impact Statement 12 for License Renewal of Nuclear Plants, Draft Report for Comment. Revision 2. NUREG-1437, 13 Volumes 1 and 2. March 2023. 1,535 p. ADAMS Accession Nos. ML23010A078 and 14 ML23010A086.
15 [USGCRP] U.S. Global Change Research Program. 2018. Impacts, Risks, and Adaptation in 5 16 the United States: Fourth National Climate Assessment. Volume II. D.R. Reidmiller, C.W. 6 17 Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.). 7 18 Washington, D.C. ADAMS Accession No. ML19008A414. DOI: 10.7930/NCA4.2018.
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NRC FORM 335                                                                        U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (12-2010)                                                                                                                (Assigned by NRC, Add Vol., Supp., Rev.,
NRCMD 3.7                                                                                                                and Addendum Numbers, if any.)
BIBLIOGRAPHIC DATA SHEET                                                                    NUREG-1437 (See instructions on the reverse)
Supplement 5a Second Renewal
: 2. TITLE AND SUBTITLE                                                                                                        3. DATE REPORT PUBLISHED Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants                                            MONTH                  YEAR Regarding Subsequent License Renewal for Turkey Point Nuclear Generating August                  2023 Unit Nos. 3 and 4, NUREG-1437, Supplement 5a, Second Renewal
: 4. FIN OR GRANT NUMBER Draft Report
: 5. AUTHOR(S)                                                                                                          6. TYPE OF REPORT See Chapter 5                                                                                                                          Technical
: 7. PERIOD COVERED (Inclusive Dates)
: 8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address; if contractor, provide name and mailing address.)
Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
: 9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address.)
Same as above
: 10. SUPPLEMENTARY NOTES Docket Nos. 50-250 and 50-251
: 11. ABSTRACT (200 words or less)
The U.S. Nuclear Regulatory Commission (NRC) staff prepared this site-specific environmental impact statement (EIS) to supplement the Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 5, Second Renewal, Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, Final Report (NUREG-1437, Supplement 5, Second Renewal) (FSEIS), issued in October 2019. This EIS considers information contained in the Florida Power &
Light Company (FPL) June 9, 2022, submittal which supplements its 2018 subsequent license renewal (SLR) application that was considered in the FSEIS. The EIS also considers whether there is significant new information that would change the NRC staffs conclusions in the FSEIS. Together, this EIS and the previous FSEIS evaluate, on a site-specific basis, all the environmental impacts of continued operation during the SLR term.
Based on the FSEIS and the NRC staffs evaluation in this EIS, the staffs preliminary recommendation is that the adverse environmental impacts of SLR for Turkey Point (i.e., the continued operation of Turkey Point for a period of 20 years beyond the expiration dates of the initial renewed licenses) are not so great that preserving the option of SLR for energy-planning decision-makers would be unreasonable.
: 12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)                            13. AVAILABILITY STATEMENT Florida Power and Light Company                                                                                                              unlimited Turkey Point Nuclear Generating Unit Nos. 3 and 4                                                                                14. SECURITY CLASSIFICATION Turkey Point Units 3 and 4                                                                                                        (This Page)
Turkey Point                                                                                                                              unclassified Draft Environmental Impact Statement                                                                                              (This Report)
National Environmental Policy Act (NEPA)                                                                                                  unclassified
: 15. NUMBER OF PAGES
: 16. PRICE NRC FORM 335 (12-2010)
 
NUREG-1437          Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants August 2023 Supplement 5a Second    Supplement 5a, Second Renewal Regarding Subsequent License Renewal for Renewal, Draft                        Turkey Point Nuclear Generating Unit Nos. 3 and 4}}

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