On May 20th, Miami Waterkeeper submitted comments on the Nuclear Regulatory Commission's (NRC's) Draft Supplemental Environmental Impact Statement (DSEIS) for the proposed license extension for Turkey Point Nuclear Generating Units 3 and 4. We believe the draft SEIS fails to meet the requirements of the National Environmental Policy Act (NEPA). Specifically, our comments note that the draft SEIS fails to look at the effects of climate change and analyze the environmental benefits of replacing the cooling canal system with cooling towers.
Here are some highlights from our comments:
- The draft SEIS focuses on the environmental impacts of constructing and operating cooling towers but fails to describe the benefits to listed species or the environment that replacing the current cooling canal system with cooling towers would have.
- The draft SEIS acknowledges that the current cooling canal system is connected to the Biscayne Aquifer and so impacts surrounding water sources.
- It acknowledges that there are adverse impacts to protected species like the American Crocodile, but fails to provide an analysis of how constructing cooling towers would eliminate the negative impacts on the American Crocodile (and other species) by eliminating the ammonia now leaking from the cooling canal system.
- The draft SEIS fails to take a hard look at the impact continuing to operate Turkey Point in the face of climate change and sea level rise. Sea level rise for South Florida (including Turkey Point) will be faster than the average over the last century. There's a 90% probability that by 2030, sea level will rise between 0.3 and 0.6 feet and by 2050 it will rise 0.5 - 1.2 feet. This rise in sea levels will increase the frequency and degree of extreme flooding, which will exacerbate storm surges.
- Climate change will also affect groundwater availability, and the draft SEIS fails to discuss how groundwater availability and quality will affect the environment of the continued operation of Turkey Point reactors 3 and 4.
- The draft SEIS does not adequately address foreseeable impacts on surface water in conjunction with foreseeable sea level rise.
- The draft SEIS ignores the effects of climate change and related sea level rise on termination and decommissioning of Turkey Point Reactors 3 & 4. If the license renewal is granted, these reactors will be allowed to operate until the early 2050s. Decommissioning is expected to take approximately 60 years to complete, which means decommissioning activities will likely continue past 2100 when sea level rise at Turkey Point could rise between four to ten feet above current levels.
- The draft SEIS provides disjointed facts about climate change and sea level rise without relating them to the issue at hand. --further extension of the operating license for Turkey Point-- or analyzing how the facts recited affect the environmental impact of the plant.
- The document does not provide an understanding of the benefits of cooling towers over a cooling canal system and avoids any analysis of how climate disruption and resulting sea level rise would affect the environmental impact of operating Turkey Point for an additional 80 years, with a further 60 years of decommissioning.
Research into the effects of extending the operations of these nuclear reactors for a total of 80 years is essential, especially given the plant's proximity to Biscayne Bay where climate change is expected to significantly alter and impact the environment.
Read our full comments HERE
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