NRC-2022-0172, EPA Comments on the Site-Specific Final Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, NUREG 1437, Supplement 5a, Second
| ML24127A205 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/06/2024 |
| From: | Kajumba N US Environmental Protection Agency, Region 4 |
| To: | Lance Rakovan NRC/NMSS/DREFS/ELRB |
| References | |
| NRC-2022-0172, NUREG-1437 | |
| Download: ML24127A205 (1) | |
Text
May 6, 2024 Lance Rakovan U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Mail Stop T-4B72 11555 Rockville Pike Rockville, Maryland 20852 RE: EPA Comments on the Site-Specific Final Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4, NUREG 1437, Supplement 5a, Second Renewal Docket 50-250 and 50-251, NRC-2022- 0172, CEQ 20240060
Dear Lance Rakovan:
The U.S. Environmental Protection Agency has reviewed the Nuclear Regulatory Commissions Supplemental Final Environmental Impact Statement in accordance with Section 309 of the Clean Air Act and Section 102(2)(C) of the National Environmental Policy Act. The CAA Section 309 role is unique to the EPA. Among other things, CAA Section 309 requires the EPA to review and comment on the environmental impact of any proposed federal action subject to NEPAs environmental impact statement requirements and to make its comments public.
The purpose of the SFEIS is to address the environmental effects associated with NRCs proposal to grant subsequent license renewals for Florida Power & Light Companys Turkey Point facility. The current licenses for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point) expire on July 19, 2032, and April 10, 2033, respectively. Subsequent renewed operating licenses evaluated in this SFEIS would authorize FPL to operate Turkey Point for an additional 20 years beyond the period in each of the current licenses.
The SFEIS evaluated four feasible alternatives, along with the no-action alternative, that were evaluated in the 2019 SFEIS. These alternatives include: 1) new nuclear power, 2) new natural gas combined-cycle power, 3) a combination of new natural gas combined-cycle power and new solar photovoltaic power and 4) the No Action Alternative. The no-action alternative would result in the NRC not authorizing the operation of FPLs Turkey Point facility for an additional twenty years. The SFEIS states that the NRC staff concluded that the environmentally preferred alternative is the proposed action of authorizing SLR for Turkey Point for an additional 20-years.
The EPAs comments for the SDEIS were associated with surface and groundwater resources, radionucleotides, climate change, and environmental justice, along with the cumulative impacts
2 associated with discharges from these sources. While we appreciate that the SFEIS addresses several of EPAs concerns with the SDEIS, the EPA reiterates our concerns expressed on the SDEIS related to the consent agreement and the need for an updated Environmental Justice analysis in this SFEIS. The EPA provided comments for the SDEIS dated December 12, 2019, and has coordinated with NRC throughout the NEPA process for this proposed action, to include our November 7, 2022, response letter on the Notice of Intent response letter dated November 7, 2022, and in our conference calls with NRC on October 27,2023, March 11, 2024, and May 1, 2024. We have attached additional groundwater and Environmental Justice comments on the SFEIS for your review. We request that our comments be addressed in the Record of Decision as well as, to be conducted for this subsequent license renewal, and that those comments be made available to the public.
The EPA appreciates the opportunity to review the SFEIS. If you have any questions regarding our comments, please contact Larry Long of the NEPA Section at (404) 562-9460, or by e-mail at long.larry@epa.gov.
Sincerely, Ntale Kajumba NEPA Manager
Enclosure:
Detailed Comments for Turkey Point Nuclear Generating Units Nos. 3 and 4 NTALE KAJUMBA Digitally signed by NTALE KAJUMBA Date: 2024.05.06 11:52:12 -04'00'
3 EPAs Detailed Comments for the Site-Specific SFEIS Subsequent License Renewal of the Turkey Point Nuclear Generating Units Nos. 3 and 4 NREG1437, Docket 50-250 and 50251, NRC-2022-0172, CEQ 20240060 Water Resources The SFEIS states that Florida Power and Light operates five groundwater withdrawal systems at Turkey Point to support plant operation, including:
- 1. Closed-Cycle Cooling System freshening wells that withdraw brackish water from the Upper Floridan Aquifer.
- 2. Biscayne Aquifer marine wells that withdraw salt water to supplement CCS freshening.
- 3. Several Unit 5 production wells that withdraw brackish water from the UFA to support operations of Turkey Point Unit 5.
- 4. Recovery Well System wells that withdraw saltwater from the Biscayne Aquifer for control of the CCS hypersaline groundwater plume.
- 5. Use of Underground Injection Control wells for the disposal of hypersaline plume fluids collected from extraction.
The EPA notes that the NRC concluded that the probability-weighted consequences of severe accidents are SMALL for all plants (NRC 1996). Nonetheless, the NRC has required that an analysis of severe accident mitigation alternatives be conducted for license renewal if such an analysis has not been conducted previously (NRC 1996). The EPA recommends that our concerns be addressed in the ROD for the following issues:
Groundwater Impacts The hypersaline plume in the aquifer is the EPA's primary concern. The EPA notes that the Florida Department of Environmental Protection and the Miami-Dade County Department of Environmental Resources Management have historically entered into consent agreements with FPL to address issues related to the CCS. Past consent agreements have outlined corrective actions to address issues related to the CCS. However, the SFEIS indicates that Turkey Point is not meeting the mitigation goals for the hypersaline plume that were established by the consent agreement. The SFEIS states in Sec 2.8.3.1, Fig 2-3, 2-28, over a 7-year period (2013-2023) there has been a net seepage of approximately 1.2 Million Gallons per Day out of the CCS into the Biscayne Aquifer, and in 11 months (June 2022-May 2023) there was a net seepage of 4 MGD out of the CCS.
As discussed in Section 2.8.3.2, FPL is proposing to increase the existing RWS extraction capacity by 0.7 MGD for each well, for a combined total capacity of 22 MGD. Any revision to the RWS would require State and local agency approval, thereby ensuring consistency with applicable laws and provisions.
While a detailed impacts analysis for the RWS capacity increase was not provided by FPL, some impacts from this proposal can be inferred based on the information available. Specifically, because the proposal involves the continued removal of hypersaline groundwater as part of an approved groundwater remediation program, NRC staff concluded that the potential for groundwater quality degradation from FPLs groundwater withdrawals during the SLR term, with an approximately 20
4 percent increase in RWS capacity, coupled with continued regulatory oversight and enforcement of the terms of the 2016 FDEP Consent Order and the 2015 Miami-Dade County Consent Agreement, would be SMALL for the Biscayne Aquifer. FPL has not provided detailed modeling to forecast the drawdown from the RWS with the proposed increased capacity of 22 MGD.
Recommendations - The EPA recommends that the NRC and FPL continue to work with FDEP and DERM to reassess the alternative corrective measures for the hypersaline plume outlined in the Consent Order 16-0241, and the 2009 monitoring plan.
Environmental Justice The EPAs comments on the SDEIS recommended that the SFEIS be consistent with E.O. 14096. The SFEIS response to comments states that NRC's decision regarding its voluntary compliance with E.O.
14096 is pending before the Commission and that NRC staff are awaiting Commission direction on the treatment of Environmental Justice matters with respect to E.O. 14096. The EPA understands that as of the date of this letter, the NRC has not received Commission direction or made a policy decision to comply with E.O. 14096.
Recommendations - The EPA encourages NRC to provide EJ analysis that is in accordance with E.O.
14096, Revitalizing Our Nation's Commitment to Environmental Justice for All, published April 21, 2023.