June 22, 2015
Chief, Rules, Announcements, and Directives Branch
Division of Administrative Services
Office of Administration
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555-000
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.
Sierra Club Florida
Sierra Club Miami Group
Sierra Club Miami Group
Executive Committee Member
Sierra Club Miami Group
Sierra Club Calusa Group
Sierra Club Calusa Group
Florida Staff Director
South Florida/Everglades Senior Organizing Representative