RE: DOCKETS 52-040 AND 52-041


Dear Secretary Vietti-Cook:


This letter is to present issues for consideration at your Evidentiary Hearing on February 9, 2017 regarding the application to construct and operate two new nuclear plants in southeast Miami-Dade County. The Florida Keys Aqueduct Authority is an Independent Special District of the State of Florida with the responsibility of supplying the entire group of islands known as the Florida Keys with drinking water from the Class I Biscayne Aquifer located in southeast Miami-Dade County. Our Board of Directors is appointed by the Governor of the State of Florida and has directed staff to prepare this letter in accordance with your correspondence, dated December 8, 2016.


For more than a decade, Florida Power & Light Company (FPL) has been out of compliance with operating requirements of its cooling canal system (CCS). The salinity values in the CCS have risen to concentrations higher than found in seawater. These high concentrations were not contained to acceptable levels as required by FPL’s interceptor canal, and as a result, hypersaline conditions have migrated more than two miles beyond FPL’s property and a plume of hypersaline has contaminated a large portion of the Biscayne Aquifer. This hypersaline plume and its influence on the movement of saline water as much as four miles westward toward critical drinking water supplies has been an issue that FPL has ignored for years. In 2014, the CCS temperature increased above the permitted range and emergency provisions were granted to allow higher operating temperatures and to tap into unpermitted surface water supplies to reduce temperatures. The CCS experienced increased salinity, regulated nutrients, and other constituents during this emergency. It was later determined, that the CCS had not been properly maintained for many years resulting in  sediment accumulation that limited the volume of cooling water and restricted the water flow regime between the canals and the groundwater below and adjacent to the CCS. The primary impact to the Florida Keys from the failure of FPL to conduct the operation of its plant appropriately is to have put at risk the source of all the potable water we provide to our customers. If our wells, which are located approximately ten miles from the FPL plant, are contaminated by the FPL created high salinity plume, the entire water supply to the Florida Keys is gone.



After these FPL failures were discovered, both the State of Florida and Miami-Dade County found FPL in violation of their operating conditions. Both the State and Miami-Dade County filed regulatory and permit violations against FPL. FPL entered into Consent Orders with both entities rather than contest the violations in court. The primary element of both orders is to reduce the salinities in the groundwater aquifer which have been contaminated by FPL. Secondary impacts include nutrient loading from the CCS into Biscayne Bay. Because of the magnitude of these problems and the sensitivity of adjacent, environmentally-sensitive areas, the improvements will take many years to achieve even under favorable conditions.


There are serious concerns expressed by agency, university, and private sector experts that the plan proposed by FPL to fix the hypersaline problem is based on assumptions and analyses that are incorrect and/or inadequate and therefore will not provide the needed scope, capacities, and cost commitments to bring the aquifer back to pre-existing conditions.


Past and current operational issues caused by FPL have led to the environmental degradation of a sole-source aquifer and Biscayne Bay. FPL had shown little interest in dealing with these unpermitted consequences of its operation until enforcement action was taken. Even with consent orders in place, there is no clear evidence that FPL can resolve the issues they have caused by using the CCS over many years nor can they prove that the CCS is still a viable option to handle thermal loads from the existing nuclear reactors.


FKAA believes that the existing damage to the local environment must be fully reversed before FPL is granted any additional increase to thermal load capacity at its Turkey Point power plant. It makes no sense to allow this expansion when FPL has such a poor track record operating the existing system.


FKAA also requests the USNRC require cooling towers be built for use with the existing operation and the closure of the existing CCS. Once built, the towers would alleviate the thermal loads being imposed by the CCS, leading to recovery of the Biscayne Aquifer and Bay with proven technology.


We appreciate the opportunity to provide these comments to your Commission. If there are any questions regarding our comments, please let me know at your earliest convenience.





Kirk C. Zuelch

Executive Director