ML18213A534
| ML18213A534 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/18/2018 |
| From: | Martin K Friends of the Everglades, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Southern Alliance for Clean Energy, Tropical Audubon Society |
| To: | NRC/SECY |
| SECY RAS | |
| Shared Package | |
| ML18213A528 | List: |
| References | |
| License Renewal, RAS 54385, 50-250-SLR, 50-251-SLR | |
| Download: ML18213A534 (133) | |
Text
1 Expert Report of Kirk Martin, P.G.
United States District Court Southern District Court of Florida Miami Division Case Number: 1:16
-cv-23017-DPG Southern Alliance for Clean Energy Tropical Audubon Society Incorporated Friends of the Everglades Plaintiffs v s. Florida Power & Light Company Defendant Background Florida Power & Light (FPL) maintains a cooling canal system (CCS) for operation of power generation units at their Turkey Point Power Generation Facility in southeast Miami
-Dade County (Figure 1).
The CCS consists of some 6000 acres of canals through which water is circulated for dissipation of heat created by the power generation units.
The CCS is characterized as a "closed
-loop" cooling system in that the same water is circulated through the extensive canal network without direct input of new water to the system.
However, the CCS does not function as a closed loop system hydrologically in that as the warmed water is circulated, evaporation losses to the atmosphere remove freshwater from the canal system causing a concentration of salinity that exceeds typical ocean salinities by a factor of two or more.
This increased salinity is accompanied by a corresponding increase in water density that causes hypersaline water to migrate downward into the underlying groundwater system and radiall y outward from beneath the CCS.
Figure 1 - General Location Map
2 Groundwater Contamination Groundwater salinity data from monitoring wells surrounding the CCS (Figure 2) shows that hypersaline water emanating from the CCS has moved westward of the CCS and L-31E Canal in violation of minimum criteria for groundwater specified in Florida Administrative Code 62
-520.400 and in violation of Condition IV.1 of the FPL Turkey Point NPDES by allowing offsite discharges from the CCS to the surrounding groundwater system outside of the CCS area. The data show that hypersaline water from the CCS has moved more than two miles westward of the CCS and is currently influencing movement of the saline water interface within the Biscayne Aquifer more than four miles inland (Figure 3). Groundwater tritium data from the monitoring well network confirms that groundwater impacted by the CCS has extended more than four miles inland from the CCS (Figure 4).
Exhibit A shows specific violations of the NPDES permit based on sampling of certain groundwater monitoring wells (shaded cells indicate exceedances of groundwater standards). The violations have continued after July 12, 2016, the date the original Complaint was filed in this case.
Figure 2 - Groundwater Monitoring Well Locations
3 Figure 3 -Hypersaline Plume in the Biscayne Aquifer Figure 4 - Tritium Plume in the Biscayne Aquifer
4 Groundwater data from beneath Biscayne Bay to the east is far less available than groundwater data in the Biscayne Aquifer due to the lack of groundwater monitoring stations within the Bay. However, the limited groundwater data that are available from beneath Biscayne Bay indicate that movement of the contaminant plume originating from the CCS is radial and likely extends as far east as the empirical data show the plume migration to the west. Tritium data from three groundwater sampling points in Biscayne Bay (Figure
- 5) show migration of the CCS contaminant plume to the east beneath Biscayne Bay (Figure
- 6) with tritium levels ranging between 800 and 3000 pCi/L for the deepest groundwater sampling points. Background levels for tritium in the Biscayne Aquifer should be less than 6.6 pCi/L in the absence of the influence of the CCS contaminant plume.
Figure 5 -Sampling Sites in Biscayne Bay Figure 6 - Groundwater Tritium Levels Beneath Biscayne Bay
5 Surface Water Contamination Elevated tritium levels are also indicated in surface water samples taken in deeper portions of Biscayne Bay far above background levels. Surface water sampling conducted at various water depths within Biscayne Bay show elevated concentrations in bottom samples collected in the canals adjacent to the perimeter berm surrounding the CCS. Specifically, water samples taken from sampling sites TTBBSW
-6, TTPPSW-7 as well as TTBBSW
-8, TPBBCSC
-B, TPSWC-7, and TPBBSCS-M all show measured tritium levels ranging as high as 4000 pCi/L and well in excess of background levels for the Bay waters (Figure 7). The elevated nutrient and tritium levels found at these surface water monitoring stations within Biscayne Bay east of the CCS are conclusive evidence of wastewater that originated within or beneath the CCS and demonstrate a direct hydrological connection between the CCS and the Bay. Bedrock immediately underlying the CCS and Biscayne Bay consists of the Miami Limestone and the Fort Thompson Formation, both of which contain highly porous and permeable limestone within the shallow substratum and provide direct connection of the groundwater and surface water environments. Deeper portions of Biscayne Bay that intersect permeable groundwater strata exist as both natural seeps and manmade excavations (dredged canals). Each connection is likely to facilitate movement of contaminated water from within and beneath the CCS to Biscayne Bay. Discharge of wastewater from the CCS to Biscayne Bay is a violation of Condition I.A.1 of the facility NPDES permit prohibiting discharges to surface waters. The specific violations of this provision during the five years before this lawsuit was filed and during the time since the lawsuit are shown as shaded cells in Exhibit B based on data provided to FDEP and Miami-Dade County by FPL.
Figure 7 - Surface Water Tritium Levels in Biscayne Bay
Surface water sampling conducted in Biscayne Bay also indicate elevated nutrient levels likely originating from the CCS. Numeric Nutrient Criteria ("NNC") established in Florida Administrative Code ("FAC") 62
-302.532 were exceeded at several locations near Turkey Point violating Section VIII., 5 and 12 of the NPDES Permit, as well as provisions of the Clean Water Act and the Florida 6 Statutes. FAC 62-302 requires that the annual geometric mean (AGM) of a regulated nutrient not exceed the established criteria more than once in a three
-year period. The sampling locations labeled TTBBSW
-6 and TTPPBW
-7 (Figure
- 5) show Nitrogen, Phosphorous, and Chlorophyll A levels in excess of the FAC NNC (Figures 8-10). Both sampling sites are located adjacent to or within manmade channels that connect Biscayne Bay to the outer edge of the CCS. TTBBSW
-6 is adjacent to the channel known as the Barge Basin Canal and TTBBS W-7 is located within the Turtle Point Canal.
Data from discrete depth sampling in and adjacent to these two canals as well as within the Old Card Sound Canal located at the southern end of the CCS all show bottom samples exhibiting significantly higher nutrient levels than do mid or top water samples.
Sampling at sites TPBBSW
-1 through TPBBSW
-5 show violations of the FAC NNC for phosphorous without deeper excavations being present.
7 Figure 8. Nitrogen Levels in Biscayne Bay
8 Figure 9 - Phosphorous Levels in Biscayne Bay
9 Figure 10
- Chlorophyll A Levels in Biscayne Bay
10 Data from surface water monitoring stations in Biscayne Bay show particularly elevated nutrient concentrations when water levels are high in the CCS. Figure 11 shows water level conditions in the CCS along with ammonia concentrations at TPBBSW
-6 and TPBBSW
-7 indicating a correlation between driving head or water level stage in the CCS and ammonia levels in surface waters tidally connected to Biscayne Bay. The period of highest water levels in the CCS corresponds to water being added to the CCS from L
-31E and other sources to reduce temperature and salinity within the CCS. Review of Figure 11 indicates movement of wastewaters originating from the CCS to Biscayne Bay during times of high water level in the CCS and strongly suggests that the addition of significant amounts of water to the CCS will increase contaminant flows from the CCS to the surrounding groundwater system and to surface waters of Biscayne Bay.
Figure 11
- Ammonia Levels in Biscayne Bay Correlated to High Water Levels in the CCS
11 Data from electronic monitoring of salinity and water level at a cave site in Biscayne Bay (Figure 12) indicate that the salinity within the cave is higher when tides are low and lower when tides are high. The salinity levels at the mouth of the cave exhibit a pattern of pronounced increase upon each low tide event indicating water outflow from the underlying aquifer that is more saline than the surrounding surface water. The salinity levels of groundwater discharging from the cave are often hypersaline (>35 PSU) and show a strong correlation with salinity levels in groundwater measured within the adjacent CCS at monitor well TPGW-16. Figure 1 3 demonstrates this strong correlation and indicates that the source of hypersaline groundwater discharging from the cave is at least partially originating from the CCS. The strong correlation of deep surface water salinity at Biscayne Bay site TPBBSW
-14D with salinity in the cave site and at the shallow zone of monitor well TPGW
-16 indicate that both the cave and the deep surface water are hydraulically connected to the CCS through the groundwater
. Figure 12
- Location of Cave and Nearby Monitor Sites Figure 13
- Salinity for Biscayne Bay Cave Site, TPBBSW
-14B, and TPGW
-16S 12 Contaminant Remediation Based on my review of the proposed remedial actions being implemented by FPL, these actions will not stop the continued flow of contaminated water from the CCS to the surrounding groundwater system or to the surface waters of Biscayne Bay.
It is likely that the violations of the NPDES permit discussed in this report will continue even if these remedial actions are implemented as planned.
The Consent Agreement s between FPL and Miami Dade County DERM and between FPL and the FDEP focused on requirements for abatement and remediation of hyper
-saline groundwater west and north of FPL's property.
Principal components of the remediation plan entail installation of Biscayne Aquifer recovery wells located along the western edge of the CCS to extract hypersaline water from the aquifer and the addition of brackish water from the Upper Floridan Aquifer, saline water from Biscayne Aquifer wells, and freshwater from the L
-31E canal into the CCS. The Biscayne Aquifer recovery wells are a critical factor in the proposed remediation and removal of the hypersaline plume from the Biscayne Aquifer. However, the well location s being well distant from the western extent of the plume will limit their ability to fully extract the hypersaline water. More importantly, the addition of fresher waters to the CCS, while improving the effectivity of the CCS for cooling water used at Turkey Point, will have an adverse effect on the proposed extraction program by increasing the driving head of the CCS into the Biscayne Aquifer and Biscayne Bay. The effect of the addition of significant volumes of water to the CCS will likely accelerate extraction of hypersaline water from immediately beneath the CCS but increase the driving head in the CCS resulting in increase d outflow from the CCS through groundwater pathways into Biscayne Bay as well as reduce the ability of the recovery wells to extract the full extent of the hypersaline plume to the west
.
Addendum 1 to the FPL/Miami
-Dade Consent Agreement (August 2016) focused on the assessment and management of nutrient sources, specifically ammonia, exceeding DERM water quality standards in surface water monitoring stations tidally connected to Biscayne Bay.
The proposed plan to mitigate the nutrient contamination within Biscayne Bay adjacent to the CCS consists primarily of backfilling the two manmade excavations at the Barge Basin Canal (sites TPBBSW-6 and 8) and the Turtle Point Canal (site TPBBSW
-7). While backfilling of deeper excavations at these two sites will likely reduce the direct flow of contaminated groundwater into Biscayne Bay at those sites, only those two pathways for contaminant travel are being addressed, whereas numerous pathways exist.
Other existing deep excavated sites such as the Old Card Sound Canal and unfilled continuations of Barge Bay and Turtle Point canals will continue to provide direct pathways for contaminant travel. In addition, numerous natural underground connections exist within the Biscayne Aquifer and sampling from deep seeps within Biscayne Bay indicate groundwater migration into the Bay especially during low tide events.
A groundwater flow model was developed by FPL to evaluate remediation alternatives. Five remedial strategies and 19 remedial alternatives were evaluated with the selected alternative being backfilling deeper areas of the Barge Basin to an elevation of
-15 feet NAVD88 and backfilling deeper areas of Turtle Point to an elevation of
-7 feet NAVD88. The groundwater model developed by FPL and relied upon by FDEP for evaluation of various remedial measures has a number of technical issues that should be corrected before the model can be used reliably to justify the remedial measures proposed by FPL. Review of the model indicates the following inadequacies:
Inappropriate representation of canals in the model allowing only one way of water travel between the canals and the groundwater system
13 Inaccurate representation of net recharge to the groundwater system that does not allow for accurate simulation of rainfall, runoff, evaporation and transpiration.
Use of constant hydraulic coefficients over large areas of the model known to have highly varying aquifer characteristics Representation of an inappropriate hydraulic disconnect of the CCS from the underlying groundwater system during the remedial action simulations A lack of capture of existing contaminated groundwater in the lowermost portions of the aquifer Impacts to wetland systems adjacent to the CCS from the proposed remedial actions These opinions of model inadequacies are supported by technical reviews of the FPL model by University of Florida professor Dr. Lou Motz, SFWMD senior modeler Jeff Giddings, and U.S. Geological Survey SEAWAT model code developer Dr. Weixing Guo.
Conclusions Given the inaccuracies associated with the FPL model used to develop the proposed remedial actions and the limitations of only addressing two possible hydraulic connections between the CCS and Biscayne Bay within a highly permeable groundwater matrix, the proposed remedial actions by FPL will not stop the continued flow of contaminated water from the CCS to the surrounding groundwater system or to the surface waters of Biscayne Bay.
The hypersaline plume originating from the FPL CCS has dramatically impacted water quality in the Biscayne Aquifer west of the CCS and is the principle influence on the movement of the saline water interface in the Biscayne Aquifer that continues to threaten fresh drinking water sources in southern Miami
-Dade County. Impacts of the CCS plume are radial and adversely affecting water quality in Biscayne Bay to the east as indicated by nutrient and salinity data collected from Biscayne Bay surface water monitoring sites. Proposed remedial actions have positive elements but are inadequate to fully extract the hypersaline plume from the aquifer or stop the flow of contaminated water into Biscayne Bay.
I reserve the right to supplement this report as new data and new information become available.
Qualifications My resume is attached as Exhibit C.
W. Kirk Martin, P.G. #79 Principal Scientist/ President Water Science Associates Inc.
EXHIBIT A Selected Groundwater Data from FPL Uprate Monitoring
EXHIBIT B Nutrient and Tritium Data Collected from Selected Surface Water Stations
EXHIBIT C RESUME OF KIRK MARTIN, P.G.
Associates Water Supply Planning and Development B.S. Geology, Florida Atlantic University, 1981 Graduate Geophysics, Wright State University, 1984 Professional Geologist: North Carolina (1987), Florida, Kentucky, Texas, and Alabama Certified Professional Geologist Certified Groundwater Professional Technical Director, Wellfield Performance Evaluation. St. Johns County Utilities, 2013. Mr. Martin worked closely with SJCUD operations staff at the SR 214 brackish wellfield in evaluating historic and ongoing operational data including production rates, static and dynamic water levels, and production water salinity. Production wells with declining productivity or degraded water quality were identified for further analyses including dynamic video and geophysical logging to identify primary production intervals, contributions to flow, and production water quality with depth. Specific recommendations were provided for upgrades or modifications to well construction and operation of the most impacted wells. Additionally, Mr. Martin provided ongoing services to the operations staff in periodic evaluation of production data to optimize wellfield productivity and minimize raw water salinity over time. These efforts resulted in a more stabilized production water quality and general operational improvements of the SR 214 wellfield. Lead Hydrologist, Water, Transportation, and Stormwater Optimization Study, Collier County, 2014. Mr. Martin provided the key technical evaluation for development of irrigation water supplies using available stormwater in concert with planned potable water supply development, reclaimed water production, and Irrigation Quality (IQ) supplemental water management in the Northeast Region of the Collier County Water-Sewer District (CCWSD). The evaluation of these supply sources included a combination of surface water and groundwater systems that maintained a focus on beneficial use and management of available stormwaters generated in the area. The results of the investigation identified multiple opportunities for storage of seasonally or temporally available sources using aquifer storage and recovery technology and surface water reservoirs where appropriate. Key recommendations were provided for numerous water supply development options depending upon area specific demands, resources, constraints, and permitting challenges.
Managed Aquifer Recharge/Aquifer Storage and Recovery Deep Injection Well/Wastewater Disposal Professional Activities Publications/Presentations
EXHIBIT D TESTIMONY OF KIRK MARTIN, P.G.
During the past four years, I testified in the following matters by deposition and/or at trial: 1. In re Florida Power and Light Company Turkey Point Power Plant Unit s 3-5 Modification to Conditions of Certification. Case No. 15
-1559EPP (Florida Division of Administrative Hearings, December 1
-4, 2015). 2. Miromar Lakes, LLC., v. South Florida Water Management District and Alico East Fund, LLC , Case No. 15
-5621 (2016).
EXPERT FEE Kirk Martin
's hourly rate is $195 per hour.