June 22, 2015
Cindy Bladey
Chief, Rules,
Announcements, and Directives Branch
Division of
Administrative Services
Office of Administration
U.S. Nuclear Regulatory
Commission
Washington, D.C.
20555-000
Megan Clouser
Project Manager
U.S. Army Corps of
Engineers
Miami Permits Section
9900 SW 107th Ave., Ste.
203
Miami, FL 33176
Re: Comments on Turkey
Point Expansion, NRC-2009-0337, 2009-02417 (SP-MLC)
Dear Ms. Bladey and Ms.
Clouser:
The Sierra Club
appreciates this opportunity to submit comments on the Draft Environmental Impact
Statement (DEIS) for Combined Licenses (COLs) for Turkey Point Units 6 & 7.
Our members are FPL rate payers, recreational users of nearby surface waters
and lands, users of drinking water from subsurface aquifers serving Miami-Dade
and Monroe Counties. Our members live within the evacuation area of Turkey
Point, throughout the state of Florida and the United States.
The undersigned urge you to reject the application and choose the No Action
alternative.
The controversial nuclear era began on the shores of Biscayne Bay in 1967 when
the first of two reactors were constructed by Florida Power and Light. Even
before the construction of Units 3 and 4, major problems surfaced. FPL
originally planned to send its hot waste water from the reactors directly into
the Bay, which was already showing harmful effects from FPL’s oil-fired
generator on sea grass habitat and marine life in the U.S.’s first continental
underwater national park, Biscayne
National Park. After fierce objections and legal action, FPL built in 1974 a
system of “cooling canals” so massive it could be seen from space. The canals
were cut through the sensitive coastal wetlands inhibiting fresh water flow the
Bay and destroying important coastal wetland.
Environmental and technical problems have taken its toll on the machines built
more than 40 years ago. The most recent problems threaten the continued
viability of the reactors as well as the prospects for more. Rising
temperatures and a boost of power have caused algae to fill the canals, and threaten
to clog the system unless even more water can be brought in from the
Everglades. In 2014, summer temperatures routinely climbed above 100 degrees
Fahrenheit. Now a giant saline plume containing radioactive elements has formed
underneath the plant and is drifting west, threatening the water supply for the
Florida Keys.
Florida Power and Light seeks to add two additional reactors to this location.
The new reactors would not be immune from the underlying environmental and
logistical problems affecting the existing reactors, in fact, they would
exacerbate them. While there is a litany of concerns about the four reactors,
an overwhelming factor against their future viability is climate change.
According to government agencies, sea level rise will inundate the Turkey Point
site within the lifetime of the proposed reactors. There can be no fair
analysis that does not take into effect climate change on the
entire Turkey Point site: hotter water temperatures, significant sea level
rise, increase storm surge and more severe hurricanes.
The clustering effect of four reactors in one coastal at-risk location, similar
to the clustering of reactors at Fukishima is very worrisome. Should a disaster
strike, there is a possibility multiple reactors will be impacted at once,
considerably reducing FPL’s ability to isolate and contain the damage.
The new reactors are planned to be built on nearby mined limestone further
destroying the critical wetlands surrounding them, not only important for the
health of Biscayne National Park, but crucial to the community’s first line of
defense against hurricane impacts. Mined pits also increase the likelihood of
contamination of the Biscayne aquifer.
We are also concerned about the new radial wells and their impact on
groundwater supplies and salinity levels.
Even if FPL were to elevate the new reactors with limestone rock fill, they
still cannot escape the impacts of sea level rise, storm surge, increased
salinization, higher water tables, and increased severity of storms. These impacts
will negatively affect plant access, operation, transmission and safe storage
of nuclear waste.
Because of time and stark changes to the climate, the nuclear era on Biscayne
Bay and in Florida is nearing its end. Solar, which accounts for one tenth of a
percent of Florida’s power, is ripe for massive expansion. FPL has indicated
its intent to increase its solar generation and can easily produce enough power
through this lower cost, safe and renewable technology to meet the needs of
residents and businesses.
Turkey Point is located within six miles of two biologically rich natural
parks, a state aquatic preserve, a national wildlife refuge, and a wetland
habitat preserve. Everglades National Park is recognized as an endangered
UNESCO World Heritage Site, an International Biosphere Reserve and supports a
unique array of ecosystems and wildlife. Biscayne National Park, located
directly adjacent to Turkey Point, is one of our largest marine national parks,
and home to incredible biodiversity and important marine and wetland habitat
that has now enacted no-take zones to save its dwindling fish stocks. Expansion
of these reactors will adversely impact these national treasures and severely
curtail the public’s use and enjoyment of them.
South Florida’s water supply is a finite, dwindling resource that needs to be
conserved in order to support the population. According to the Union of
Concerned Scientists, nuclear fission is the most water intensive method of the
principal thermoelectric generation options in terms of the amount of water
withdrawn from sources.
The $20 billion or more investment in two new reactors would be better spent
developing lower cost solar energy. Compared to other forms of power
generation, solar photovoltaic (PV) power is leading the cost decline, with
solar PV module costs falling 75% since the end of 2009 and the cost of
electricity from utility-scale solar PV falling 50% since 2010. (Source:
International Renewable Energy Agency,
http://www.irena.org/DocumentDownloads/Publications/IRENA_RE_Power_Costs_2014_report.pdf)
Additionally, President Obama issued an Executive Order 13653 on November 1,
2013 that directs all agencies - federal, state and local - to incorporate sea
level rise projections into planning and construction along US coasts
(reference:
https://www.whitehouse.gov/the-pressoffice/2013/11/01/executive-order-preparing-united-states-impacts-climate-change).
Had that order been followed, the NRC would have automatically concluded that
construction and operation of two additional reactors at Turkey Point, in an
area that will be submerged due to sea level rise and to increased storm surges
from stronger storms, is untenable and poses an unacceptable risk to a region
that is ground zero for sea level rise. It poses an unacceptable risk for the
South Florida, the state and the nation.
We are opposed to all nuclear power expansion in Florida, as it is unsafe and
non-renewable, taxes limited water supplies. It is unworkable, especially in
the age of climate change. Instead of wasting tens of billions of dollars on an
unviable Turkey Point project, it’s time for FPL to focus on a far more viable,
economical technology in the Sunshine State: solar.
We, therefore, kindly ask that you choose the No Action Alternative.
Sincerely,
Debbie Matthews
Chair
Sierra Club Florida
Jim Teas
Chair
Sierra Club Miami Group
Stephen Mahoney
Conservation Chair
Sierra Club Miami Group
Noel Cleland
Executive Committee
Member
Sierra Club Miami Group
John Scott
Chair
Sierra Club Calusa Group
Rhonda Roff
Energy Chair
Sierra Club Calusa Group
Frank Jackalone
Florida Staff Director
Sierra Club
Jonathan Ullman
South Florida/Everglades
Senior Organizing Representative
Sierra Club
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