ML23340A033
| ML23340A033 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/01/2023 |
| From: | Eaton K Florida Power & Light Co |
| To: | US Dept of Interior, Fish & Wildlife Service |
| References | |
| FWA-R4-ES-2023-0103 | |
| Download: ML23340A033 (1) | |
Text
U.S. Department of the Interior December 1, 2023 Fish and Wildlife Service 5275 Leesburg Pike Falls Church, VA 22041-3803 Docket No. FWA-R4-ES-2023-0103 Comments submitted by Florida Power and Light on the Species Status Assessment accompanying the September 20, 2023 Proposed Threatened Species Status with Section 4(d) Rule for the Miami Cave Crayfish Florida Power & Light Company (FPL), is the largest electric utility in the state of Florida providing clean, affordable, reliable electricity to more than 12 million people. The following comments are not specifically related to the U.S. Fish and Wildlife Service (USFWS) proposed listing decision for the Miami cave crayfish (Procambarus milleri) under the Endangered Species Act but rather focused on the accompanying supporting information contained in the Species Status Assessment (SSA).1 Upon review of the SSA, it was discovered the report contains inaccurate and misleading information regarding the Turkey Point Clean Energy Center located in Homestead, FL. FPL is submitting these comments to assist the USFWS in identifying these misleading statements, so they can be removed from the SSA and the public record associated with this proposed species listing.
The Species Status Assessment framework is an analytical approach developed by the USFWS to deliver foundational science for informing all Endangered Species Act (ESA) decisions.2 The purpose of a species status assessment is to evaluate multiple factors influencing the status of a species, including habitat loss, pollution, climate change, invasive species, and human interactions. The SSA scope can be expanded to include special cases for evaluation if the decision is supported by scientific consensus and peer-reviewed research. In this instance, the SSA was expanded to include a special case for radiation, however, there does not appear to be sufficient data to support this decision nor were certain sections of this special case peer reviewed prior to publication.3 Upon review of the available SSAs associated with the other federally listed species within the vicinity of Turkey Point Clean Energy Center, it was noted that none of these other assessments included special cases for radiation.
Also, FPL identified several misleading comments related to the safety of the Turkey Point Clean Energy Center within the SSA, which are wildly speculative and not supported by sound scientific research. The primary responsibility of the USFWS is to assess factors that fall within their jurisdiction and expertise. The topic of radiation, particularly related to nuclear energy or radiation monitoring, clearly lies under the jurisdiction of other agencies including the Nuclear Regulatory Commission (NRC) or the Environmental Protection Agency (EPA). The speculative reference to a potential nuclear catastrophe in the SSA ignores the extensive, redundant, and rigorous safety requirements and procedures that are continuously maintained and 1
Miami Cave Crayfish (Procambarus milleri) Species Status Assessment, Version 1.1, (June 2023) 2 USFWS Species Status Assessment Framework, Version 3.4, p 4 (August 2016) 3 https://www.regulations.gov/document/FWS-R4-ES-2023-0103-0003 Florida Power & Light Company 700 Universe
reviewed by both the facility and the NRC. The USWFS should refrain from using speculative farfetched scenarios (i.e., nuclear meltdowns) in their scientific evaluation related to the factors affecting species population levels and defer to the NRC and the EPA for addressing radiation-related concerns.
Specific Comments to the SSA Comment #1:
Reference:
SSA, Section 3.4.3, Page 61, Line 36 Tritium leaks into the surrounding Biscayne Aquifer such that the tritium concentration of groundwater samples collected from sites located within 5.3 miles (8.5 km) of the canal system ranged from 4.1 to 53.3 Tritium Units (within safe drinking water limits) (Prinos et al. 2014, p.
47).
Response: This section is referencing tritium levels in groundwater reported for the United States Geological Survey (USGS) monitoring wells located within 5.3 miles of the cooling canal system (CCS) listed in Prinos et al 2014 and have sampling intervals ranging from -87 to -99 feet. As described in the SSA, Miami cave crayfish have been collected from wells 7.9-36 feet deep. Tritium data from the Turkey Point Clean Energy Center Annual Monitoring Reports 2011-2023 are provided below. The data were collected quarterly since 2010/2011 and represent porewater, rainfall, and shallow groundwater levels near the identified crayfish endemic range.
These tritium values are more representative of conditions near the plant site than what is presented in the SSA prepared by the USFWS. These sample sites are close to the southern extent of the crayfish habitat area and are representative of tritium concentrations collected over 12 years from the depth where crayfish occur. The elevated tritium values used in the USFWS SSA were collected at depths over 85 feet deep that are outside the reported Miami cave crayfish habitat range.
Comment #2:
Reference:
SSA, Section 3.4.3, Page 63, Line 1 Despite its aging infrastructure, two of the facilitys reactors gained a 20-year subsequent renewed license in 2018 (U.S. Nuclear Regulatory Commission 2016, entire).
Response: The NRC Supplemental Environmental Impact Statement (SEIS) is an independent source of information regarding Turkey Point Clean Energy Center compliance with Fukushima-based NRC requirements, demonstration of federal safety requirements for sea level rise and storm readiness as well as infrastructure safety information. Derogatory references to aging infrastructure are not supported by any evidentiary basis and fail to account for upgrades, replacements, and ongoing NRC regulation, NRC required aging management programs, and ongoing oversight. Safety concerns and structural integrity evaluations related to nuclear facilities are not within the area of expertise of the USFWS and any evaluations and comments related to these extremely important and highly sensitive technical subjects should be reserved for federal agencies qualified to make those evaluations (i.e., NRC).
Comment #3:
Reference:
SSA, Section 3.4.3, Page 63, Line 6 This risk of a natural disaster-related incident at Turkey Point Nuclear Power Plant will only grow as regional sea level rises and climate change elevates the number and intensity of severe weather events in the area.
Response: See response to Comment #2. Also, the NRCs SEIS discusses both the impacts of sea level rise and potential increases in the severity or frequency of storm events.
Comment #4:
Reference:
SSA, Section 3.4.3, Page 63, Line 9 In the event of a serious nuclear catastrophe (e.g., a partial or complete meltdown incident),
the area within a ten-mile radius of the reactor site is expected to experience severe effects, including unbreathable air, whereas an extended region within a 50-mile radius of the reactor site is predicted to experience severe radioactive contamination, notably of its food and water supplies.
Response: The reference cited for this statement is the NRC website on emergency planning, which does not support any of these assertions. NRC regulations provide reasonable assurance of adequate protection of the public health and safety. This in turn minimizes the risk of severe accidents, the consequences of which, the NRC studies have shown, can be slowed, stopped or reduced through compensatory measures. For example, see the NRCs State of the Art Reactor Consequence Analysis (https://www.nrc.gov/about-nrc/regulatory/research/soar.html), which discusses the very low risk of reactor accidents and explains that even if an accident were to occur, it would release much less radioactive material than earlier analyses suggested. We encourage you to reach out the NRC to gain a better understanding of accident risk and reasonable dose scenarios associated with reactor operation and accident scenarios.
Comment #5:
Reference:
SSA, Section 3.4.3, Page 64, Table 3.4 Table 3.4. Summary of effects of chronic and acute radiation exposure on crustacean morbidity. Acute exposures are defined as those lasting less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Chronic exposures are defined as those lasting over a period of the organisms life span and greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
HTO = Tritiated Water. From Fuller et al. (2015, p. 60). Refer to Fuller et al. (2015) for original references cited in table below.
Response
The doses cited in Table 3.4 are massive radiation doses that are unrealistic for this discussion.
For example, the NRC, Federal Emergency Management Agency (FEMA) and EPA use a dose of 1 REM4 for public protective actions. The doses in the table are orders of magnitude higher.
The dose of 200 Gray is equivalent to 20,000 REM. This exposure would also have to occur for a duration of 30 minutes to 220 minutes. Another example is from the NRC website that cites the plant workers and firefighters battling the fire at the Chernobyl power plant received high 4
https://www.nrc.gov/reading-rm/basic-ref/glossary/rem-roentgen-equivalent-man.html
radiation doses of 70 REM to 1340 REM. The doses on the referenced table far exceed these extreme exposures.
In addition, this table is a compilation of the limited number of studies on crustacean exposures to radiation identifying gaps in crustacean research following the events at Chernobyl and Fukushima nuclear accidents. Of the ionizing radiation exposure studies listed, only one studied the effects of beta particles from tritium while all other studies examined effects of alpha and gamma particles, which are known to have higher morbidity effects. The sole tritium exposure study evaluated the effects on Pollicipes polymerus (Gooseneck Barnacle) which would not be representative of expected effects to Procambarus milleri (Miami Cave Crayfish) as the species differ significantly in several important ways: 1) Crayfish and barnacles come from completely different taxonomic trees having different morphologies within the phylum Arthropoda where the crayfish possess complex digestive and nervous systems, and specialized sensory structures that barnacles do not possess; 2) Feeding & Diet: The barnacle is a filter feeder typically attached to rocks while the crayfish is motile feeding on plants, algae, invertebrates and detritus; 3)
Reproduction: The barnacle is hermaphroditic while the crayfish have distinct separate sexes.
Comment #6:
Reference:
SSA, Section 3.4.3, Page 65, Line 37 The close proximity of Turkey Point Nuclear Power Point to the Atlantic Coastal Ridge introduces the potential for radioactive contamination of Miami cave crayfish habitat. Few regulations exist to specifically protect groundwater quality in the Biscayne Aquifer.
Response: This statement is not appropriate or accurate. See Chapter 62-550 F.A.C.; MDC Code of Ordinances/Chapter 24, Article III for regulations that exist to protect groundwater quality in the Biscayne Aquifer. In addition, the facility is regulated under numerous provisions of the Clean Water Act and Florida water regulations that protect groundwater.
Comment #7:
References:
SSA, Section 4.2, Page 91, Line 14 and nuclear reactor accidents at the Turkey Point Nuclear Power Station that would result in the exposure of Miami cave crayfish to dangerously-high levels of radiation.
Response: See responses to Comments #2 and #4.
Please contact FPL if you have any questions (Kristin.Eaton@fpl.com).
Sincerely, Kristin Eaton Project Manager Florida Power & Light Company